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Main Street Lending Program Nonprofit Organizations Comments

Summary

This is a compilation of public comments headed Main Street Lending Program Nonprofit Organizations Comments, with columns for received date, name, email address, affiliation and comment. One opening comment says the description of retaining employees in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to take advantage of the facility. It recommends that reasonable efforts be interpreted in the totality of the circumstances, that the terms maintain its payroll and retain its employees be clarified, and that nonprofit borrowers not be penalized when employees decline offers of rehire or leave voluntarily. Another comment is headed Limitation of 50-Employee Minimum Should Be Removed.

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“Main Street Lending Program Nonprofit Organizations Comments.” Original at www.federalreserve.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/federal-reserve-public-comments-4-pdf-www-federalreserve-gov-a5fb327e2-58e4bbea91/, SHA-256 e33bd692b1f27eb4bdc78cfa00fb70e2fc5d924e9664fc405c70dc74196c21ea.

Full text

                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                        Comment
                                                                                                             "Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                             The description of " Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                             take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                             recommend the following:

                                                                                                             Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                             the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                             fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                             would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                             Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                             We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                             at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                             the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                             retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                             Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                             not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                             cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                             Limitation of 50-Employee Minimum Should Be Removed
                                                                                                             The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                             Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                             than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                             support.

                                                                                                             Recommendation: The 50-employee floor should be removed.

                                                                                                             Additional Recommendations and Requests for Clarification
                                                                                                             Lincoln Cultural Center respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                             Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                             cash on hand?
                                                                                                             Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if collateral
                                                                                                             is needed.
                                                                                                             Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                             until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                             credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                             Our needs are evident, the PPP provide short term relief, but sadly Covid-19 is a long term effect. How do we replace funds from fundraisers
                                                                                                             that can not occur? How do we keep staff at bay when there is no income for payroll? How do we maintain our position in the community if we
                                                                                                             are not sure we can move forward? We are set to celebrate our 30th anniversary next year, will we be able to do so. You are in a position to
                                                                                                             relieve the stress for us and so many organizations like us.

Staff Group - Main
Street Lending
Program - Nonprofit                                                                          Southside
Organization          PIO (Email    6/22/2020                                cesar@southsi   Redevelopment   It is imperative to provide access to credit to non-profits that allow then to keep people employed while serving the community, win-win
Facilities            from Web)     12:00:00 AM     Garcia      Cesar        deomaha.org     Corporation
                                                                                                             This opportunity being extended to the non-profit sector will benefit many non profits who have adjusted their programs based on the current
                                                                             info@empoweri                   state of the our country and communities. Many organizations did not have individuals on the payroll but are doing a lot of heavy lifting in their
Coronavirus           PIO (Email    6/22/2020                                ngthemasses.o   Empowering      communities to ensure that our most vulnerable populations are served.
(COVID-19)            from Web)     12:00:00 AM     Johnson     Tammy          ___________   the Masses



                                                                                                                Page 101 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address      Affiliation                                                                  Comment
                                                                                                               Comments to the Federal Reserve from the Association of Art Museum Directors regarding nonprofit access to the Main Street Lending
                                                                                                               Program.

                                                                                                               The Association of Art Museum Directors (AAMD) comprises the chief executive officers of the leading art museums in North America, with a
                                                                                                               mission of cultivating leadership, advocating for the field, and fostering excellence. AAMD appreciates the opportunity to submit comments to
                                                                                                               the Federal Reserve on the Nonprofit Organization Loan Facilities.

                                                                                                               Art museums have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. They are playing a
                                                                                                               critical role in providing educational programs, often to families that have no history of utilizing such resources. In fact a survey conducted in
                                                                                                               April and May, after the onset of the pandemic, found that 48% of people using art museum online services had not visited a museum in the
                                                                                                               previous year. However, art museums are facing challenges to their ability to sustain themselves with limited revenue while simultaneously
                                                                                                               altering their operations and service delivery. Although they have relied on a largely private model, with such government support as exists
                                                                                                               coming primarily from local sources, the challenges to private funding as well as state and local governments lead us to turn to the federal
                                                                                                               government for help in sustaining our operations. In these circumstances, it is critical that the federal government understand our models of
                                                                                                               governance and operations and fashion relief measures that rise to the need.

                                                                                                               We believe that the proposal is aimed more at nonprofits such as hospitals and institutions of higher education, which charge substantial fees
                                                                                                               for service, than at nonprofits such as art museums that rely on donations to support their missions. Indeed, a third of AAMD's members
                                                                                                               in the United States charge no fees for admission, two-thirds offer free admission to children, and nearly all offer reduced fees for seniors,
                                                                                                               students, and members of the military. Nearly all also offer free days per week or month, and labor intensively to reach traditionally
                                                                                                               underserved audiences, often with free or reduced-cost programming. Even those that charge for admission heavily subsidize entrance fees:
                                                                                                               while fees range up to $25, museums often incur costs exceeding $75 per visit.

                                                                                                               By definition, all types of charities are inherently organized around a public mission, but their business models differ. Many of the financial
                                                                                                               requirements included in this proposal simply are not applicable to organizations that rely on donations. With that in mind, AAMD respectfully
                                                                                                               requests Congress and/or the Federal Reserve to address the concerns and proposed changes outlined below, recognizing that other charities
                                                                                                               and associations may have additional requests that are beyond our focus here.

                                                                                                               1. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                               Charitable Sector

                                                                                                               The Federal Reserve's criterion that organizations must have 2019 revenues from donations that are less than 30% of total revenue
                                                                                                               disqualifies most art museums. Because the proposal is vague as to what would qualify as "donations," it is impossible to be
                                                                                                               precise as to exactly how many art museums might qualify, but if they include gifts from private individuals, foundations, corporations, and
                                                                                                               government grants, it seems likely that fewer than 15% could meet the proposed standard.

                                                                                                               As stated above, this loan facility seems more applicable to for-profit entities, as well as nonprofit educational institutions and hospitals, than to
                                                                                                               art museums and many other charitable organizations.

                                                                                                               Museums receive donations from the public, foundations, corporations and others to fund their public service missions. They often solicit and
                                                                                                               receive donations specifically to enable a broader public to benefit from their services. For example, the Baltimore Museum of Art used a
                                                                                                               combination of a gift, in the form of a permanently restricted endowment, and a government grant to offer free admission, allowing it to
                                                                                                               eliminate its admission fees in the early 2000s. Attendance at family programs rose by 70 percent as a consequence. Asking museums and
                                                                                                               other charities to reduce donations as a share of revenue is effectively asking them reduce their service to the public.

                                                                                                               Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                               instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                               2. Congress Should Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
Staff Group - Main
Street Lending                                                                                                 Congress should ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
Program - Nonprofit                                                                           Association of   Reserve making the Main Street Lending Program available to some nonprofits, this assistance still falls short of what is most needed by
Organization          PIO (Email    6/22/2020                                 afinch@aamd.o   Art Museum       nonprofit organizations - a provision that makes these loans forgivable.
Facilities            from Web)     12:00:00 AM     Finch       Andrew       J2               Directors

                                                                                                                  Page 102 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment
                                                                                                     Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                     Data released by Independent Sector show that nonprofits with between 500 to 5,000 employees have been severely impacted by this health
                                                                                                     and economic crisis. When asked "What types of additional assistance would be most helpful to your organization?" organizations
                                                                                                     overwhelmingly (92% of responses) suggested government support in the form of forgivable loans. Smaller nonprofits throughout the country
                                                                                                     have been hit equally hard. With an average of 123 Full Time Equivalents, AAMD members fall mainly into the latter category, but they are
                                                                                                     eager to advocate both for their larger charitable colleagues and for the relatively few art museums that exceed 500 FTE. In this regard they
                                                                                                     are also pleased that the proposed program would be available to charities with as few as 50 employees, though it needs to be said that this
                                                                                                     would still leave out a slight majority of AAMD members, and we accordingly request that smaller charities also be allowed to participate.

                                                                                                     Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                     forgiveness in the next round of COVID-19 relief legislation.

                                                                                                     3. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility.

                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in which the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts." We note also that the current crisis, and in
                                                                                                     particular the need for social distancing, has changed the way that art museums deliver services, with most shifting to entirely online operations
                                                                                                     at least for the duration. This shift necessarily entails a shift in operating procedures and thus in staffing.

                                                                                                     Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     4. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                     support.

                                                                                                     Recommendation: The 50-employee floor should be removed.

                                                                                                     AAMD is grateful for the opportunity to comment.




                                                                                                        Page 103 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment




                                                                                                              The non-profit agency I help lead 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.

Staff Group - Main                                                                                            With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we can continue to employ
Street Lending                                                                                                our staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists. We can continue to support children and
Program - Nonprofit                                                                          Thom Child       families. We can avoid an erosion of our social service sector. We need immediate action. Non-profit agencies of our size must be included in
Organization          PIO (Email    6/22/2020       Rowe                     growe@thomch    and Family       the Main Street Lending Program and any subsequent mid-size loan programs.
Facilities            from Web)     12:00:00 AM     Owens       Gretchen     ild.org         Services
                                                                                                              Comments to the Federal Reserve regarding the proposed Main Street Lending Program for nonprofit organizations - NONLF and NOELF

                                                                                                              The Nonprofit Association of the Midlands (NAM) provides the following recommendations to improve the proposed Nonprofit Organization
                                                                                                              Loan Programs:
                                                                                                              1. Loan Forgiveness: The Federal Reserve, working with Congress, must recognize the extent to which the public and economy rely on the
                                                                                                              vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                              2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor. The need is great in
                                                                                                              nonprofits. This is also a parity issue since this minimum number of employees does not apply to for profit businesses.
                                                                                                              3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                              organization's 2019 revenues come from donations. We also recommend that a review of multi-year budgets rather than just the 2019
                                                                                                              budget offers a better understanding of the nonprofit.
                                                                                                              4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                              on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                              requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                              5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                              allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                              needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                              operating budgets and capital funds for improvements.
                                                                                                              6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                              efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                              also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                              Program Flexibility Act should be extended to this loan program.
                                                                                                              7. Additional Questions Recommendations:
                                                                                                              o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                              include cash on hand?
                                                                                                              o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                              needed.
                                                                                                              o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
Staff Group - Main                                                                                            financial liquidity related to the impact of COVID-19.
Street Lending
Program - Nonprofit                                                                          Nonprofit        The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which the
Organization          PIO (Email    6/22/2020                                anne@nonprofi   Association of   Nonprofit Association of the Midlands (NAM) endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Hindery     Anne         tam.org         the Midlands



                                                                                                                 Page 104 of 300
                                                                                                               Main Street Lending Program
                                                                                                             Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name   Email Address          Affiliation                                                                           Comment
                                                                                                                     Seneca Family of Agencies is one of the largest children's behavioral health providers in California, and our strength comes from the hard
                                                                                                                     work and commitment of our direct service staff. We provide Unconditional Care across a comprehensive continuum of service settings that
                                                                                                                     support families through the most difficult time of their lives. Like most mental health providers, the COVID-19 crisis has presented
                                                                                                                     extraordinary financial challenges and threatened the viability of many of our critically necessary programs.
                                                                                                                     Our agency is grateful for the continued opportunities provided via the CARES Act for financial support. Unfortunately, we feel the Main Street
                                                                                                                     Lending Program as announced will not provide sustainable relief to nonprofits, as intended.
                                                                                                                     Specifically, while we understand that Congress must act to pass legislation allowing for loan forgiveness for mid-sized nonprofits under this
                                                                                                                     loan program, we hope to underscore that possible forgiveness on these loans is necessary for the opportunity to be viable, in any way, for a
                                                                                                                     nonprofit like ours.
Staff Group - Main                                                                                                   Further, the proposed interest rates for nonprofits utilizing this program are the same interest rates available to for-profit businesses. Both the
Street Lending                                                                                                       PPP and EIDL provide lower interest rates for nonprofits, and this program should be comparable. The fees involved in this opportunity,
Program - Nonprofit                                                            hope_kamer@                           especially without access to loan forgiveness, are prohibitively onerous.
Organization          PIO (Email    6/22/2020                                  senecacenter.o      Seneca Family     Thank you for your consideration on this urgent issue, and you committed leadership through this crisis.
Facilities            from Web)     12:00:00 AM     Kamer        Hope          rg                  of Agencies

                                                                                                                     The non-profit agency I help lead 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                                     communities, 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.

Staff Group - Main                                                                                                   With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we could start calling back
Street Lending                                                                                                       to work our furloughed staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists and administrators.
Program - Nonprofit                                                                                                  We could continue to support children and families. We could avoid an erosion of our social service sector. We need immediate action. Non­
Organization          PIO (Email    6/22/2020                                  pwolfe@thomc        Thom Anne         profit agencies of our size must be included in the Main Street Lending Program and any subsequent mid-size loan programs.
Facilities            from Web)     12:00:00 AM     Wolfe        Pamela        hild.org            Sullivan Center
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                Society of
Organization          PIO (Email    6/22/2020                                  philip.thakadiyil   Women             Please reduce the staffing size to 25, most not for profits are operating at reduced staffing levels.
Facilities            from Web)     12:00:00 AM     Thakadiyil   Philip        @swe.org            Engineers



                                                                                                                     Non-profits provide vital services that the government cannot and does not provide. These loans may be imperative to keep many of the non­
                                                                                                                     profit community afloat during these difficult economic times caused by the pandemic. There is an abundance of work to be done with limited
Staff Group - Main                                                                                                   numbers of organizations that have the capacity to do it. With so much fundraising happening through events that can no longer be held in the
Street Lending                                                                                                       same fashion, the income loss is substantial. Loan forgiveness for non-profits as well as lowering the minimum number of employees to enable
Program - Nonprofit                                                            JSCHOFIELD                            more small to mid-size non-profits to be eligible would be immensely helpful to so many doing the front line work of feeding the poor, housing
Organization          PIO (Email    6/22/2020       SCHOFIEL                   @MENTORRI.                            for homeless, supports for youth, etc.
Facilities            from Web)     12:00:00 AM     D            JO-ANN        ORG                 MENTOR Rl




                                                                                                                        Page 105 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                       Comment
                                                                                                              June 22, 2020

                                                                                                              Comments to the Federal Reserve Board from National Museum Associations

                                                                                                              The undersigned national nonprofit museum associations are writing to comment on the Federal Reserve Board's proposal to expand the
                                                                                                              Main Street Lending Program to provide access to credit for nonprofit organizations.

                                                                                                              Nonprofit museums are economic engines and job creators: According to "Museums as Economic Engines: A National Report",
                                                                                                              U.S. museums support more than 726,000 jobs and contribute $50 billion to the U.S. economy per year. America cannot afford to leave out
                                                                                                              such a vital part of the economy. Our nonprofit member institutions are important to every community, connecting residents to creativity and
                                                                                                              education and enhancing their quality of life. Museums are a robust and diverse business sector including African American museums,
                                                                                                              aquariums, arboreta, art museums, botanic gardens, children's museums, culturally-specific museums, historic sites, historical societies,
                                                                                                              history museums, maritime museums, military museums, natural history museums, planetariums, presidential libraries, public gardens, railway
                                                                                                              museums, science and technology centers, and zoos. We serve as community anchors, addressing challenges in times of crisis.

                                                                                                              Unfortunately, we expect the hardships facing our member organizations in communities across the country to increase significantly in the days
                                                                                                              and months ahead. Collectively, the nation's nonprofit museums are losing millions of dollars a day due to closures. The American
                                                                                                              Alliance of Museums (AAM) calculates that museums are losing at least $33 million a day due to closures as a result of COVID-19.
                                                                                                              Additionally, preliminary data from an AAM benchmarking survey shows that nearly 20% of museums indicated that there is a significant risk of
                                                                                                              closing permanently. Our members' economic stability depends heavily on revenue generated from our visitors. Even museums that have
                                                                                                              reopened are operating at reduced capacity, meaning that a return to normal operations will likely take months or years.

                                                                                                              By definition, all types of charities are inherently organized around a public mission, but their business models differ. Many of the financial
                                                                                                              requirements included in this proposal are not applicable to organizations that rely on donations. With that in mind, our organizations
                                                                                                              respectfully request Congress and/or the Federal Reserve to address the concerns and proposed changes outlined below, recognizing that
                                                                                                              other charities and associations may have additional requests that are beyond our focus here.

                                                                                                              1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness

                                                                                                              Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                              Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                              nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                              Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                              Data released by Independent Sector show that nonprofits with between 500 to 5,000 employees have been severely impacted by this health
                                                                                                              and economic crisis. When asked "What types of additional assistance would be most helpful to your organization?" organizations
                                                                                                              overwhelmingly (92% of responses) suggested government support in the form of forgivable loans. Smaller nonprofits throughout the country
                                                                                                              have been hit equally hard.

                                                                                                              Nonprofit organizations need funding to continue to meet the needs of their communities. Many of these organizations do not have steady
                                                                                                              streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                              employment sector and many hope to hire more workers as their organizations recover.

                                                                                                              Even as museums are experiencing closures and significant losses in revenue, they are meeting an increase in demand for their services and
                                                                                                              safeguarding and supporting their communities. They are contributing to the ongoing education of our country's children by providing free
                                                                                                              lesson plans, online learning opportunities, and drop-off learning kits to teachers and families. They are using their outdoor spaces to grow and
                                                                                                              donate produce to area food banks and are maintaining these spaces for individuals to safely relax, enjoy nature, and recover from the mental
                                                                                                              health impacts of social isolation. They are donating their PPE and scientific equipment to fight COVID-19, and providing access to child care
                                                                                                              and meals to families of health care workers and first responders. In the midst of financial distress, they are even raising funds for community
Staff Group - Main
Street Lending                                                                                                relief. Museums are pivotal to our nation's ability to manage through the pandemic and recover from it as our nation opens back up. But
Program - Nonprofit                                                                          American         they desperately need assistance in the form of forgivable loans.
Organization          PIO (Email    6/22/2020                                bszczesny@aa    Alliance of
Facilities            from Web)     12:00:00 AM     Szczesny    Barry        m-us.org        Museums          Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan

                                                                                                                 Page 106 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment
                                                                                                     forgiveness in the next round of COVID-19 relief legislation, including for the Main Street Lending Program.

                                                                                                     2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                     Charitable Sector

                                                                                                     The Federal Reserve's criterion that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                     including more than half of the nation's 33,000 museums. Overall, this loan facility seems more applicable to for-profit entities, but not
                                                                                                     most charitable organizations. Survey data from the American Alliance of Museums shows that private charitable giving was the largest source
                                                                                                     of operating income for nonprofit museums.

                                                                                                     Recommendation: Eliminate the requirement that no more than 30% of an organization's 2019 revenues come from donations, and
                                                                                                     instead make eligible 501(c)(3) organizations that are otherwise meeting the employee size.

                                                                                                     3. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification

                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility.

                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts." We note also that the current crisis, and in
                                                                                                     particular the need for social distancing, has changed the way that museums deliver services, with many shifting to entirely online operations.
                                                                                                     This shift necessarily entails a shift in operating procedures and thus in staffing.

                                                                                                     Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors included in other loan programs and state clearly that nonprofit
                                                                                                     borrowers will not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those
                                                                                                     who are fired for cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     4. Limitation of 50-Employee Minimum Should Be Removed

                                                                                                     The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                     support.

                                                                                                     Recommendation: The 50-employee floor should be removed.

                                                                                                     We appreciate your immediate attention to these critical issues. Thank you for your continued work to mitigate the impact that this public health
                                                                                                     crisis is having on our economy.

                                                                                                     Sincerely,

                                                                                                     American Alliance of Museums
                                                                                                     American Association for State and Local History
                                                                                                     American Institute for Conservation
                                                                                                     Association of African American Museums

                                                                                                        Page 107 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                   Comment
                                                                                                     Association of Art Museum Directors
                                                                                                     Association of Children's Museums
                                                                                                     Association of Science and Technology Centers
                                                                                                     Association of Science Museum Directors
                                                                                                     Association of Zoos and Aquariums




                                                                                                       Page 108 of 300
                                                                                                       Main Street Lending Program
                                                                                                     Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address    Affiliation                                                                       Comment
                                                                                                            l'm writing to express the strong support of Bethesda Lutheran Communities for the proposed expansion of eligibility criteria of the Main
                                                                                                            Street Lending Program to include not-for-profit organizations that have operated for at least 5 years with endowments that do not exceed $3
                                                                                                            billion.

                                                                                                            I thank Chairman Powell for proposing this eligibility expansion and his understanding of the critical role not-for-profit organizations play in our
                                                                                                            nation's economy and its health and human services delivery system. Bethesda has provided disability supports to people with intellectual
                                                                                                            and developmental disabilities since 1904. It has sustained itself through many economic downturns including the Great Depression. But the
                                                                                                            economic challenges facing organizations like Bethesda as a result of the COVID-19 pandemic are unprecedented and could not have been
                                                                                                            foreseen.

                                                                                                            Extending this program to not-for-profits is consistent with and supportive of the goals of the Main Street Loan program. The statement of the
                                                                                                            Federal Reserve that "small and medium-sized businesses are integral to the U.S. economy" are as relevant to nonprofits as for-
                                                                                                            profits. Bethesda employs more than 2,226 in 13 states. Not only does Bethesda contribute to local communities in those states but it provides
                                                                                                            essential services and supports to some of its most vulnerable citizens.

                                                                                                            The supports provided by Bethesda are essential healthcare and human services. It is essential for the health and well-being of thousands of
                                                                                                            Americans that not-for-profits like Bethesda continue to provide these services through the epidemic. However, continuation of this lifeline
                                                                                                            come at a tremendous financial cost. Bethesda's expenses directly attributed to COVID-19 are forecasted to be over $1.5 million,
                                                                                                            including;
                                                                                                             $500,000 in Personal Protective Equipment;
                                                                                                             $900,000 in staff wages for hazard pay, over time and coverage for necessary 24/7 coverage.

                                                                                                            And, unlike many for-profit organizations, Bethesda has not had access to emergency funding through the Paycheck Protection Program (PPP)
                                                                                                            due to the number of direct support professionals employed. And, healthcare and human services were not covered by the North American
                                                                                                            Industry Classification System (NAICS) codes inserted into the CARES Act legislation for expanded eligibility.

                                                                                                            Another compelling reason to expand eligibility of the Main Street Lending Program to include not-for-profits is that, in addition to loss of
                                                                                                            services revenue and increase in COVID-19-related expenses, charitable giving and other fundraising activities have been negatively impacted
                                                                                                            by the pandemic. The intellectual and developmental disability service system historically has been severely underfunded causing service
                                                                                                            providers to rely on fundraising activities to keep people employed and essential services operating.

                                                                                                            One such activity for Bethesda is retail thrift stores. Because all our stores were forced to shut down due to State mandates, that revue stream
                                                                                                            was lost at this most critical time. To date, Bethesda has forecasted $1.1 million in lost revenue. And, we are also facing increased expenses
                                                                                                            on labor and supplies as we begin reopening in a safe and responsible manner - these costs may exceed $400 thousand this year.

                                                                                                            Bethesda's tradition charitable giving efforts have also been stymied by the pandemic. Our fundraising has been greatly diminished to the
                                                                                                            COVID-19 outbreak. We are unable to visit donors and the many unknowns in the market are causing donors to hold back right now. This
                                                                                                            could have a $2 million impact on Bethesda.
Staff Group - Main
Street Lending                                                                                              Bethesda is a strong and financially viable organization that, like all nonprofits, has suffered significant economic hardships due to the
Program - Nonprofit                                                          Brian.Savoie@ Bethesda         pandemic. Expansion of the Main Street Lending Program would provide us with the cash assets to continue to provide essential services for
Organization          PIO (Email    6/22/2020                                BethesdaLC.or Lutheran         people with disabilities while putting systems in place to be effective in the new economic normal.
Facilities            from Web)     12:00:00 AM     Savoie      Brian         ____________ Communities




                                                                                                               Page 109 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                           Comment
                                                                                                             We are encouraged by the Federal Reserve's recent announcement that it plans to make the Main Street Lending program available to
                                                                                                             nonprofits. While this is a step in the right direction, this assistance falls short of what is really needed by most nonprofits in the wake of the
                                                                                                             ongoing pandemic - a provision that makes the loans forgivable.

                                                                                                             Nonprofits, both small and large, across the nation are struggling to maintain their mission-critical operations despite the significant public
                                                                                                             health and economic challenges posed by the current pandemic. At San Diego Zoo Global, we were forced to shut our doors to the public for
                                                                                                             the first time on — through    With this unprecedented closure, we are still incurring significant expenses to care for our animals and plants
                                                                                                             without revenue to mitigate costs. Many of the wildlife in our care are threatened or endangered, some of which belong to the U. S. Fish and
                                                                                                             Wildlife Service. While we recently reopened our facilities, to maintain social distancing we are only allowing - % of visitor capacity, meaning
                                                                                                             that we may be operating a net loss for some time.

                                                                                                             During normal operations, San Diego Zoo Global's (SDZG) economic impact is an estimated $1.7 billion annually, employing 3,000
                                                                                                             Californians, and indirectly contributing more than 14,000 jobs to California's labor market. SDZG houses more than 6,500 animals of
                                                                                                             more than 950 species and a renowned botanical collection representing more than 700,000 exotic plants. Additionally, we lead and make
                                                                                                             significant contributions to numerous successful local, national, and international public-private recovery partnerships in cooperation with our
                                                                                                             peer institutions and at the request of the U. S. Fish and Wildlife Service. To sustain base operations during this challenging time, we require
                                                                                                             the aid of our federal government until we can once again serve as an economic engine of our community.

                                                                                                             As the Federal Reserve develops it nonprofit lending mechanism, we encourage you to make the following changes that are critical to the
                                                                                                             health and sustainability of our nation's nonprofits during these unprecedented times.

                                                                                                             1. Expand access to credit through the Main Street Lending program including a provision for loan forgiveness for all eligible nonprofits.
                                                                                                             2. Eliminate the 30% limit on revenue from donations. This 30% limit seems more aimed at for-profit businesses, hospitals and institutional for
                                                                                                             higher education than most nonprofits and will disqualify many nonprofits in the greatest need.
                                                                                                             3. Liquidity - The Fed proposal requires high levels of liquidity, however the pandemic has reduced liquidity and makes this a challenge.
                                                                                                             4. Interest rates and fees - The interest rates proposed are the same as for for-profit businesses. Both the PPP and EIDL provide lower interest
                                                                                                             rates for nonprofits and this program should be comparable. In addition, the fees, especially without access to loan forgiveness, are also
                                                                                                             onerous.
                                                                                                             5. Balloon payment - The proposal includes a 70% balloon payment in 5 years, though nonprofits do not expect to have excess cash in 5 years
                                                                                                             to meet this balloon payment. We recommend this payment schedule be extended significantly.
                                                                                                             6. EBIDA (Earnings before interest, depreciation, and amortization) - Requiring unrestricted 2019 operating revenue be greater than or equal to
Staff Group - Main                                                                                           5% is overly restrictive for nonprofits facing financial difficulty.
Street Lending
Program - Nonprofit                                                                                          We appreciate your attention to these important provisions which would strengthen the MSLP's ability to provide relief to nonprofits that
Organization          PIO (Email    6/22/2020                                acaldwell@san   San Diego Zoo   are in dire need of assistance.
Facilities            from Web)     12:00:00 AM     Caldwell    Andrea       diegozoo.org    Global ”




                                                                                                                Page 110 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address         Affiliation                                                                          Comment
                                                                                                                 The Minnesota Council of Nonprofits (MCN) was founded in 1987 to meet the increasing information needs of nonprofits and to convene
                                                                                                                 nonprofits to address issues facing the sector. It is the largest state association of nonprofits in the United States. Through MCN, nonprofits join
                                                                                                                 together across interest areas to work on issues of common concern to all. MCN accomplishes this through education and professional
                                                                                                                 development for nonprofit managers and leaders, public policy education and civic engagement, cost saving product partnerships, research on
                                                                                                                 nonprofit sector trends and tax and budget issues, and advocacy at local, state, and federal levels.

                                                                                                                 Minnesota Council of Nonprofits appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan
                                                                                                                 Facilities. This proposal is aimed more at transactional nonprofits such as hospitals and institutions of higher education than at nonprofits that
                                                                                                                 have a larger reliance on donations from the public to support their missions. Indeed, many nonprofits pride themselves on offering their
                                                                                                                 services at no charge. Recognizing that their business models are different, even if both types of charities are inherently organized around a
                                                                                                                 public mission, many of the financial requirements included in this proposal simply are not applicable to organizations that rely on donations.
                                                                                                                 With that in mind, Minnesota Council of Nonprofits respectfully requests the Federal Reserve to address the concerns and proposed changes
                                                                                                                 outlined below.

                                                                                                                 1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                 Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                                 Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                                 nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                                 In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                 though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                                 meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                 Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                                 Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                                 Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                                 nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                                 helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                                 loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                                 Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                                 steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                                 employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                                 the economy.

                                                                                                                 Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                 forgiveness, in the next round of COVID-19 relief legislation

                                                                                                                 2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                                 Charitable Sector
                                                                                                                 The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities.
                                                                                                                 Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and nonprofit hospitals, but not most
                                                                                                                 charitable organizations.

                                                                                                                 Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                                 instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                                 3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                                 The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
Staff Group - Main
Street Lending                                                                                                   Facilities available to for-profit businesses.
Program - Nonprofit                                                          IMejia@minnes      Minnesota
Organization          PIO (Email    6/22/2020                                otanonprofits.or   Council of       Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
Facilities            from Web)     12:00:00 AM     Mejia       lleana              9           Nonprofits       margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,

                                                                                                                    Page 111 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work creates cash-flow
                                                                                                     challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. Xquot;Reasonable Efforts" Regarding Employee Retention Require Further Clarification

                                                                                                        Page 112 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment
                                                                                                              The description of Xquot;Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                              take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                              recommend the following:

                                                                                                              Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                              the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                              fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                              would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                              Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                              We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                              at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                              the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                              retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                              Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                              not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                              cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                              6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                              The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                              Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                              than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                              support.

                                                                                                              Many of the nonprofits in our network are on the frontlines of this pandemic, working with fewer than 50 employees to address immediate and
                                                                                                              growing needs. These vital organizations would be arbitrarily excluded from important loan program.

                                                                                                              Recommendation: The 50-employee floor should be removed.

                                                                                                              7. Additional Recommendations and Requests for Clarification
                                                                                                              Minnesota Council of Nonprofits respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                               Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                              cash on hand?
                                                                                                               Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                              collateral is needed.
                                                                                                               Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                              until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                              credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                              Thank you for your consideration on these important issues.

                                                                                                              Please consider extending the proposed nonprofit loan program to make nonprofits like ours eligible. We employ 15 FTE and do critical work to
                                                                                                              help keep youth off the streets and from falling through the cracks, through after-school programming in skateboarding, music and digital art.
Staff Group - Main                                                                                            We feed 150 kids weekly. With our projected revenue, which was to constitute 43% of our 2020 budget, nearly wiped out, we need federal
Street Lending                                                                                                support to sustain.
Program - Nonprofit
Organization          PIO (Email    6/22/2020                                andrew@rabbl                     Don't just bail out the big dogs. So many innovative nonprofits such as ours need support.
Facilities            from Web)     12:00:00 AM     Norman      Andrew       emill.org       Rabble Mill




                                                                                                                 Page 113 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                         Comment




                                                                                                             Using the best available data from the IRS Form 990, (see http : //seachangecap.org/wp-content/uploads/2020/06/MainStreet2.0-Proposal-
                                                                                                             Summary-of-Tests.pdf), we estimate that about 29% of nonprofits too large for PPP (expenses over $30 million) would qualify for loans under
                                                                                                             the proposal though only 13% in social services. A further 24% pass all tests but one; for 50% of these the test that they fail is the liquidity test
                                                                                                             (liquid assets > 90 days). In social services, 71% of organizations otherwise eligible fail this test. Given their low margins, slow paying
                                                                                                             funders (government), stable revenues and expenses (in normal situations) and mission orientation, larger nonprofits (particularly in social
                                                                                                             services) operate with limited liquidity. Our analysis suggests that only 26% of social service nonprofits pass the 90-day test. The Fed should
                                                                                                             consider moving this test to 60-days or even 45-days. This would increase the number of eligible borrowers by 27% and 45%, respectively.

                                                                                                             Incentives
                                                                                                             It should be made clear that banks would get CRA credit or the FRB should explore other methods to encourage lending. CDFIs should also be
                                                                                                             included as originators. Nonprofits should also be allowed to refinance high costs debt in some circumstances.

                                                                                                             Eligible Borrowers, item # 8 "unrestricted cash"
                                                                                                             Nonprofits are not required to report "unrestricted cash" in their financial statements or on IRS Form 990. Under generally accepted
                                                                                                             accounting standards, nonprofits does not define and report "unrestricted cash". (There was discussion to split the balance sheet
                                                                                                             items in FASB but they decided not too as it is very complex), However, there is a concept of "restricted cash" (example: escrow
                                                                                                             funds, client funds etc.) It will be confusing to nonprofits to define what "unrestricted cash" is and this will result in diversity and
                                                                                                             confusion with this calculation. I suggest saying "lf there is no restricted cash separately identified on the statement of financial position
                                                                                                             then all cash and cash equivalents reported should be used in this calculation; and/or say "Cash and Investments excluding permanent
                                                                                                             endowment funds." If this not the intention, then different language should be used in consultation with nonprofits auditors and
                                                                                                             accountants.

Staff Group - Main                                                                                           Donations: For purposes of test #5, revenues from donation includes "proceeds from fundraising events, federated campaigns, gifts, and
Street Lending                                                                                               funds from similar sources." This leaves unclear to main whether grants from foundations are intended to be included in similar sources. I
Program - Nonprofit                                                          jmacintosh@se   SeaChange       expect this is the intention, but it should be clear. It is not clear how to distinguish gifts from grants, but nonprofits often use the words
Organization          PIO (Email    6/22/2020                                achangecap.or   Capital         differently.
Facilities            from Web)     12:00:00 AM     Macintosh   John         9               Partners




                                                                                                                Page 114 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                      Comment
                                                                                                              We are writing on behalf of the more than 1,400 Federally Qualified Health Centers (FQHCs) across the country. FQHCs are community­
                                                                                                              based, non-profit organizations whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay.
                                                                                                              As explained below, we appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however,
                                                                                                              after closely reviewing the draft Term Sheet, we have determined that almost no FQHCs would qualify for these loans under the current
                                                                                                              eligibility requirements. Therefore, we are requesting that:
                                                                                                               the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                               FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                              the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                              BACKGROUND ON FQHCs AND THE COVID-19 PANDEMIC

                                                                                                              As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
                                                                                                              19 pandemic since the beginning. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients. Our
                                                                                                              patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and 68% are racial and
                                                                                                              ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.

                                                                                                              Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                              income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                              curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                              providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                              While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                              pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                              individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                              FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.

                                                                                                              RECOMMENDATION TO EXPAND ELIGIBILITY CRITERIA TO ALLOW THE MAJORITY OF FQHCs TO QUALIFY

                                                                                                              For these reasons, NACHC was relieved to hear that the Small Business Administration will soon make Main Street Loans available to non­
                                                                                                              profit organizations with 50 to 15,000 employees. However, after reviewing the Terms Sheet, we determined that almost no FQHCs would
                                                                                                              qualify under the proposed eligibility criteria.

                                                                                                              This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                              of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                               Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                              over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                               Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                              meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                              The most problematic financial parameters for FQHCs are:
                                                                                                               EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                               Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                               Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                              origination is 65% or greater

                                                                                                              In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                              the following lending parameters for FQHCs loans as follows:
                                                                                                               EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                               Days cash on hand at loan origination equal to or greater than 30 days
Staff Group - Main
Street Lending                                                                               National          Eliminate the unrestricted cash to debt ratio requirement
Program - Nonprofit                                                                          Association of    Lower the minimum employee requirement to 20.
Organization          PIO (Email    6/22/2020                                cmeiman@nac     Community
Facilities            from Web)     12:00:00 AM     Meiman      Colleen      hc.org          Health Centers   In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to

                                                                                                                 Page 115 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     REQUEST FOR FQHCs TO WORK DIRECTLY WITH CDFIs TO ACCESS MAIN STREET LOANS

                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                     coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                     billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                     detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                     current needs of Federally Qualified Health Centers.




                                                                                                        Page 116 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address      Affiliation                                                                       Comment
                                                                                                                The National Health Council (NHC) appreciates the announcement of the Main Street Lending Program plan to provide credit access for
                                                                                                                nonprofit organizations. Patient groups have been and will be significantly harmed by reduced charitable giving, travel restrictions, fundraising
                                                                                                                event cancellations, and reduced meeting attendance due to COVID-19. The new loans will provide some assistance to these groups to offset
                                                                                                                these losses and help assure our nation's vital nonprofit infrastructure can weather this storm.

                                                                                                                Patient advocacy organizations serve the patients and communities we represent at no-cost. We are the groups helping people most impacted
                                                                                                                by the virus, those with underlying chronic conditions that often result in more severe cases of illness. We have seen significantly increased
                                                                                                                demand for our invaluable services during this public health emergency, while at the same time seeing significant reductions in revenue. In
                                                                                                                addition, the nonprofit sector is the third largest workforce in the U.S., behind retail and manufacturing. In order to continue our valuable work, it
                                                                                                                is critical that patient advocacy and community-based organizations and other nonprofits have access to loans to weather the growing
                                                                                                                economic burden of the COVID-19 pandemic.

                                                                                                                We commented in April that you provide explicit funding for nonprofits through an exclusive pathway within the Mid-Size Business Loan
                                                                                                                Program. This funding will support loans to nonprofit employers with up to 10,000 employees, since those with over 500 employees are barred
                                                                                                                from the CARES Act's small business lending.

                                                                                                                We also wrote that is was also imperative this program include loan forgiveness modeled after the CARES Act Section 1106. It does not
                                                                                                                appear that the proposed model includes forgiveness, and we urge you to consider creating a path to forgiveness in the final model for this
                                                                                                                program. We are working with Congress to help make sure that the Fed has the capacity to offer forgiveness, knowing that it may not be
                                                                                                                possible under current statute. Without this change, the expanded loan program may not be viable for many nonprofits.

                                                                                                                Another significant concern is the 30% limit on revenue from donations. This is a major disqualifier for most of the nonprofits of the size
                                                                                                                targeted for this program. These are some of the largest and most established nonprofits in the country and are also those significantly affected
                                                                                                                by the economic impact of COVID-19. As previously stated, the pandemic has created a massive shortfall of charitable giving, much of it
                                                                                                                associated with canceled in-person events such as walks, runs, and bike rides. We expect that once the virus is contained, many of these
                                                                                                                events will resume, and giving will return. But until that time, organizations who rely on donations desperately need targeted assistance.
                                                                                                                Without access to this loan program much of the scientific progress and advocacy these organizations lead will be lost.

                                                                                                                There are several other specific eligibility criteria included in the plan that are also of concern to the nonprofit patient advocacy groups. First,
                                                                                                                the Fed proposal requires high levels of liquidity; however, the pandemic has reduced liquidity and makes this a challenge. And nonprofits in
                                                                                                                general have lower levels of liquidity than for-profit entities due to the nature of their structure, accounting practices, and laws regulating tax­
                                                                                                                exemption. Second, the interest rates proposed are the same as for for-profit businesses. Both the Paycheck Protection Program and
                                                                                                                Economic Injury Disaster Loan provide lower interest rates for nonprofits and this program should be comparable. The fees, especially without
                                                                                                                access to loan forgiveness, will also be onerous. Third, the proposal includes a 70% balloon payment in 5 years. The economic impact of
                                                                                                                COVID-19 is likely to impact nonprofits for many years. We request that this payment schedule be extended or that nonprofits have the
                                                                                                                opportunity renegotiate terms before the end of the loan period. Finally, requiring unrestricted 2019 operating revenue be greater than or equal
                                                                                                                to 5% is overly restrictive for nonprofits facing financial difficulty.
Staff Group - Main
Street Lending                                                                                                  Again, we thank you for taking this unprecedented step of creating a loan program specifically targeted at mid-sized nonprofit organizations
Program - Nonprofit                                                                                             that have been hit so hard during this emergency. We look forward to working with you on the details to create a program that will be most
Organization          PIO (Email    6/22/2020                                 jdexter@nhcou   National Health   effective for these critical organizations.
Facilities            from Web)     12:00:00 AM     Dexter      Jennifer      ncil.org        Council




                                                                                                                   Page 117 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                          Comment
                                                                                                                 The Human Services Council (HSC) appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization
                                                                                                                 Loan Facilities. HSC fosters a diverse network of human service organizations. Together, we discuss ideas and take collective action on issues
                                                                                                                 that impact the entire sector and those they serve. Through advocacy and collaboration, we support member organizations and their leaders in
                                                                                                                 addressing their concerns of public policy, economic trends, and the regulatory environment. This proposal is aimed more at transactional
                                                                                                                 nonprofits such as hospitals and institutions of higher ed than at nonprofits that have a larger reliance on donations from the public to support
                                                                                                                 their missions. Indeed, many nonprofits pride themselves on offering their services at no charge. Recognizing that their business models are
                                                                                                                 different, even if both types of charities are inherently organized around a public mission, many of the financial requirements included in this
                                                                                                                 proposal simply are not applicable to organizations that rely on donations. With that in mind, we respectfully request the Federal Reserve to
                                                                                                                 address the concerns and proposed changes outlined below.

                                                                                                                 1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                 Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                                 Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                                 nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                                 In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                 though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                                 meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                 Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                                 Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                                 Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                                 nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                                 helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                                 loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                                 Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                                 steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                                 employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                                 the economy.

                                                                                                                 Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                 forgiveness, in the next round of COVID-19 relief legislation

                                                                                                                 2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                                 Charitable Sector
                                                                                                                 The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities.
                                                                                                                 Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and nonprofit hospitals, but not most
                                                                                                                 charitable organizations.

                                                                                                                 The human services sector raises money and receives donations from the public, foundations, corporations and others to fund programs, and
                                                                                                                 many do not receive revenue through direct services. Charitable organizations play a fundamental role in strengthening civil society. Nonprofit
                                                                                                                 organizations provide vital services for all New Yorkers and the nation, and pride ourselves on the donations we receive rooted in the trust and
                                                                                                                 support that the public has of the sector.

                                                                                                                 Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                                 instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

Staff Group - Main                                                                                               3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
Street Lending                                                                                                   The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
Program - Nonprofit                                                          kimg@humans       Human             Facilities available to for-profit businesses.
Organization          PIO (Email    6/22/2020                                ervicescouncil.   Services
Facilities            from Web)     12:00:00 AM     Kim         Gloria       org               Council           Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate

                                                                                                                    Page 118 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work creates cash-flow
                                                                                                     challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.


                                                                                                        Page 119 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment
                                                                                                              5. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                              The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                              take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                              recommend the following:

                                                                                                              Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                              the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                              fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                              would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                              Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                              We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                              at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                              the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                              retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                              Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                              not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                              cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                              6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                              The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                              Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                              than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                              support.

                                                                                                              Many of the nonprofits in our network are on the frontlines of this pandemic, working with fewer than 50 employees to address immediate and
                                                                                                              growing needs. These vital organizations would be arbitrarily excluded from important loan program.

                                                                                                              Recommendation: The 50-employee floor should be removed.

                                                                                                              7. Additional Recommendations and Requests for Clarification
                                                                                                              We respectfully request the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                               Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                              cash on hand?
                                                                                                               Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                              collateral is needed.
                                                                                                               Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                              until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                              credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

Staff Group - Main
Street Lending                                                                                                It is important that small non-profits with less than 50 employees be included. We are also concerned with flexibility as to payback, loan
Program - Nonprofit                                                                                           forgiveness, and what funds can be used for, including but not limited to refinancing debt already had, purchasing equipment/supplies needed
Organization          PIO (Email    6/22/2020                                rbrissette@svd   SVDP Rhode      for business to continue, or meet new or expanded demand/need.
Facilities            from Web)     12:00:00 AM     Brissette   Renee        pri.org          Island




                                                                                                                 Page 120 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address       Affiliation                                                                       Comment
                                                                                                                 To Whom It May Concern,

                                                                                                                 Thank you for considering expanding the Main Street Lending Program to provide relief to credit for nonprofit organizations. However, as the
                                                                                                                 leading voice for the travel community, we are extremely concerned that under the current proposal, only 501(c)(3) and 501(c)(19)
                                                                                                                 organizations will be able to access such relief, leaving out most Destination Marketing Organizations (DMOs), which are often classified as
                                                                                                                 501(c)(6) or 501(c)(4) organizations.

                                                                                                                 As you know, 501(c)(3) and 501(c)(19) organizations have been able to access to the Paycheck Protection Program (PPP), while 501(c)(6)
                                                                                                                 and 501(c)(4) are ineligible for PPP and have been unable to access adequate relief under the Economic Injury Disaster Loans (EIDL)-forcing
                                                                                                                 many to severely downsize their staff or shut down completely. The CARES Act was meant to be a lifeline to employers of all shapes and
                                                                                                                 sizes, yet for many nonprofits, including DMOs, CARES Act relief was not been available to them.

                                                                                                                 The travel industry workforce has been disproportionately harmed by the economic slowdown caused by COVID-19-losing more than 8 million
                                                                                                                 jobs, which accounts for more than half (51%) of the travel industry's workforce. Currently, the unemployment rate in the travel industry is
                                                                                                                 more than twice the national unemployment rate during the worst point of the Great Depression.

                                                                                                                 DMOs play a critical role in the travel industry, supporting local travel markets through tourism management and convention and meeting
                                                                                                                 sales-connecting travelers with the travel businesses that would otherwise be ignored by mainstream media outlets and consumer channels.
                                                                                                                 We ask that you include the following changes to the Main Street Lending Program to ensure DMOs, as a key component of the travel
                                                                                                                 economy supply chain, can remain afloat during this difficult time:

                                                                                                                 Allow 501(c)(6) and 501(c)(4) organizations to access the Main Street Lending Program.
                                                                                                                 Increase the donation cap to 50% if the donations are automatic contributions based on a formula.
                                                                                                                 Allow the maturity term to extend to 10 years upon request by the borrower.
                                                                                                                 Reduce the minimum years of operations requirement to 2 years.
                                                                                                                 For the new loan program, allow the maximum loan size to be the lesser of $50 million or half of the borrower's annual revenue.
                                                                                                                 Lower the interest rate to 2% + LIBOR.
                                                                                                                 Reduce the minimum loan size to $100,000.
                                                                                                                 Allow nonprofits with as low as 20 employees to qualify for the loans.

                                                                                                                 With these changes, significant progress can be made to save DMOs and lay the groundwork for economic recovery. It's clear, with the
                                                                                                                 travel industry accounting for a full third of all jobs lost since March, there can be no economic recovery without a strong travel recovery-and
                                                                                                                 DMOs will play a critical role in that effort.

Staff Group - Main                                                                                               Thank you for your time and attention to this important matter.
Street Lending
Program - Nonprofit                                                                                              Sincerely,
Organization          PIO (Email    6/22/2020                                 vbarnes@ustra     U.S. Travel      Tori Barnes
Facilities            from Web)     12:00:00 AM     Barnes      Tori          vel.org           Association



                                                                                                                 The Kingston Chamber Music Festival has been presenting chamber music concerts to audiences in southern Rhode Island and beyond for
Staff Group - Main                                                                                               the past 31 years. This year, due to COVID-19, we will be presenting our festival online. We are able to retain our one-person full-time staff
Street Lending                                                                                                   member because of the support we received through the CARES Act and are truly grateful for this assistance. We are hoping that the loan will
Program - Nonprofit                                                            info@kingstonc   Kingston         be forgiven and ask you to consider this option as we are facing a revenue loss of $70,000 due to a lack of ticket sales. Our total budget is
Organization          PIO (Email    6/22/2020                                  hambermusic.o    Chamber Music    $250,000 so this is very impactful. Again, we are sincerely thankful for your support.
Facilities            from Web)     12:00:00 AM     Hunter      Pamela        J2                Festival




                                                                                                                    Page 121 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name    Email Address      Affiliation                                                                          Comment
                                                                                                                 The non-profit agency I help lead 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                                 communities, 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 could start calling back
Staff Group - Main                                                                                               to work our furloughed staff. We could continue to support children and families. We could avoid an erosion of our social service sector.
Street Lending                                                                                                   Necessarily, however, the eligibility criteria ratio of, "adjusted 2019 EBIDA to unrestricted 2019 operating revenue, greater than or equal
Program - Nonprofit                                                                            Thom Child        to 5%", excludes nearly every social service nonprofit known to us. This criteria is burdensome, unnecessary, and rewards nonprofit
Organization          PIO (Email    6/22/2020                                 tmateer@thom     & Family      agencies that have chosen to retain a high earnings margin. To support nonprofits and economic recovery, this criteria must be removed.
Facilities            from Web)     12:00:00 AM     Mateer       Tanya        child.org        Services



                                                                                                                 The vast bulk of nonprofits - nearly 70% - have fewer than 50 employees. During these economic times, these smaller organizations have far
                                                                                                                 less fat to cut from the budget. Without government support, many will go under. This costs jobs and also costs the community the benefits of
                                                                                                                 the organization. I would strongly argue that the smaller organizations are more likely to make every dollar count toward their mission.

                                                                                                                 Therefore, main street loans for nonprofits should include those with one or more employees. Limiting this is organizations with 50+ employees
                                                                                                                 will do terrible harm. This will particularly impact my own state, Rhode Island, which is the smallest state in the US. Many of our essential
Staff Group - Main                                                                                               organizations are also quite small in staff-size. A 50-person organization is large for Rl. The vast majority of nonprofits here are far smaller.
Street Lending                                                                                                   They deserve federal help too.
                                                                              Personal Email
Program - Nonprofit                                                           Address
Organization          PIO (Email    6/22/2020                                                  What Cheer        Thank you
Facilities            from Web)     12:00:00 AM     Holland      Anne                          Flower Farm
Staff Group - Main                                                                             Association of
Street Lending                                                                                 Private           Asociación de Colegios y Universidades Privadas de Puerto Rico (ACUP) [Association of Private Colleges and Universities of Puerto
Program - Nonprofit                                                           Personal Email   Colleges and      Rico] is supportive of the comments submitted by the American Council on Education (ACE) on June 22, 2020. Thank you for your attention to
Organization          PIO (Email    6/22/2020       Cividanes-                Address          Universities of   this matter. Yours sincerely.
Facilities            from Web)     12:00:00 AM     Lago         Carmen                        Puerto Rico




                                                                                                                    Page 122 of 300
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                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                       Comment




                                                                                                              The University of Wisconsin (UW) System has been exploring a range of options for short-term cash flow to assist with possible contingencies
                                                                                                              as a result of the COVID-19 pandemic. For example, we have sought a change in state law to provide the UW System with a line of credit, and
                                                                                                              we have exercised a flexibility provided in the CARES Act to temporarily withhold the employer share of payroll taxes. The proposed
                                                                                                              requirements for the Nonprofit Organization Expanded Loan Facility and the Nonprofit Organization New Loan Facility under the Main Street
                                                                                                              Lending Program would prohibit the UW System from participating. We respectfully ask that eligibility thresholds be expanded for public
                                                                                                              universities and systems of higher education to ensure access for these entities to the program.

                                                                                                              We request consideration for changes in the following areas:

                                                                                                               Program eligibility criteria require borrowers be "a tax-exempt nonprofit organization described in section 501(c)(3) of the Internal
                                                                                                              Revenue Code." As a public system of higher education, the UW System does not have 501(c)(3) status, but it is instead organized as an
                                                                                                              entity of the State of Wisconsin. Though the proposal notes that other forms of organizations may be considered for inclusion as a nonprofit
                                                                                                              organization, we request specific language to ensure all public colleges and universities are eligible.
                                                                                                               As one of the largest higher education systems in the country, the UW System, with 13 institutions at 26 locations, would exceed the caps for
                                                                                                              number of employees (15,000), annual 2019 revenue ($5 billion), and size of endowment ($3 billion). We ask that these restrictions be
                                                                                                              removed to ensure all public higher education institutions, regardless of size, may participate.
                                                                                                               Higher education institutions will likely feel the effects of COVID-19 for several years. Enrollment impacts continue throughout the years in
                                                                                                              which a cohort class advances through its degree programs. In addition, until the state's and nation's economies recover,
                                                                                                              appropriations to public institutions may be lower. We request a longer repayment period and a longer interest deferment period to ensure
                                                                                                              public higher education institutions are in a stronger financial position before loan payments are due.
Staff Group - Main
Street Lending                                                                                                Given the important role that public institutions of higher education play in their communities and regions, and the economic impact they will
Program - Nonprofit                                                                          University of    have as our economy recovers, we are interested in exploring any flexibility that increases options for addressing future liquidity. To the extent
Organization          PIO (Email    6/22/2020                                rcross@uwsa.e   Wisconsin        we can provide any information to illustrate our current situation and the need for short-term cash flow, please feel free to reach out.
Facilities            from Web)     12:00:00 AM     Cross       Ray          du              System




                                                                                                                 Page 123 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                      Comment
                                                                                                              We are writing on behalf of Health Center Partners of Southern California (HCP). Federally Qualified Health Centers (FQHCs) are community­
                                                                                                              based, non-profit organizations whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay.
                                                                                                              As explained below, we appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however,
                                                                                                              after analyzing the draft Term Sheet, we have determined that almost no FQHCs would qualify for these loans under the current eligibility
                                                                                                              requirements. Therefore, we are requesting that:
                                                                                                               the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                               FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                              the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                              Background on HCP and FQHCs

                                                                                                              On behalf of our 16 member organizations, which serve 858,757 patients for 3.6 million visits each year, in 140 practice locations, in the three
                                                                                                              southernmost California counties of San Diego, Imperial, and Riverside, we hope you will recognize how desperately the health care delivery
                                                                                                              system is in need of additional resources. As community-based, non-profit organizations committed to ensuring access to health care, FQHCs
                                                                                                              have been on the frontlines of the COVID-19 pandemic since the beginning and fulfill an irreplaceable role in our country's health care
                                                                                                              system. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients, including 7.2 million
                                                                                                              Californians. Our patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and
                                                                                                              68% are racial and ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of
                                                                                                              racism.

                                                                                                              During a public health emergency, FQHCs provide triage, treatment, and referrals in addition to working in partnership with the local health
                                                                                                              departments and states. FQHCs are uniquely positioned to assist in the fight against the spread of COVID-19 because they are rooted in the
                                                                                                              communities they serve, and are trusted sources of care for anyone that walks through their doors.

                                                                                                              Health centers are implementing drive-up, walk-up, and mobile COVID-19 testing centers, and they are working with local health departments
                                                                                                              to bring testing to the homeless populations throughout the country. It is essential that FQHCs have access to low-cost funding that can be
                                                                                                              used to offset losses attributable to COVID-19, as well as the costs of testing and treatment. This will enable health centers to re-employ staff
                                                                                                              in an effort to continue to expand services and outreach and to respond to COVID-19. This is especially critical as more and more people lose
                                                                                                              their jobs and become eligible for Medicaid. FQHCs anticipate that their patient caseload will increase significantly as a result.

                                                                                                              FQHCs have experienced a significant decline in revenue, due to the need to curtail many primary and preventive care visits. This combination
                                                                                                              has placed major financial strain on these non-profit, community-based providers, forcing them to close sites and lay off staff at the time when
                                                                                                              their services are most needed.

                                                                                                              While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                              pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                              individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                              FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.

                                                                                                              Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                              Because of these financial needs, HCP was relieved to learn that the Federal Reserve would soon start offering Main Street Loans to non­
                                                                                                              profits. However, after reviewing the proposed Terms Sheet, we have concluded that almost no FQHCs would qualify under the proposed
                                                                                                              eligibility criteria.

                                                                                                              This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                              of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                               Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                              over 500 staff, who are currently ineligible for the Paycheck Protection Program.
Staff Group - Main
Street Lending                                                                                                 Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
Program - Nonprofit                                                                                           meet the DCOH and Cash/Debt ratio at loan origination.
Organization          PIO (Email    6/22/2020                                fwhelan@hcps    Health Center
Facilities            from Web)     12:00:00 AM     Whelan      Frank        ocal.org        Partners         The most problematic financial parameters for FQHCs are:

                                                                                                                 Page 124 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                      Comment
                                                                                                                 EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                                 Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                                 Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                                origination is 65% or greater

                                                                                                                In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                                the following lending parameters for FQHCs loans as follows:
                                                                                                                 EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                                 Days cash on hand at loan origination equal to or greater than 30 days
                                                                                                                 Eliminate the unrestricted cash to debt ratio requirement
                                                                                                                 Lower the minimum employee requirement to 20.

                                                                                                                In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                                the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                                authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                                could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                                providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                                support" be revised to read "direct support."

                                                                                                                Request for FQHCs to work directly with CDFIs to access Main Street Loans

                                                                                                                Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                                financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                                coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                                billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                                Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                                directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                                the Main Street Loan Program to:
                                                                                                                 Allow CDFIs to participate as lenders in the program; and
                                                                                                                 Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                                at LIBOR +3%

                                                                                                                We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                                detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                                current needs of Federally Qualified Health Centers.

                                                                                                                On behalf of the National Council for Behavioral Health (NCBH), a nonprofit association composed of more than 3,300 Community Mental
                                                                                                                Health Centers and community behavioral health organizations serving more than 10 million low-income Americans with serious mental health
                                                                                                                and substance use disorders, thank you for the opportunity to provide comments on the Nonprofit Organization New Loan Facility, authorized
                                                                                                                by the Federal Reserve Act. 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
Staff Group - Main                                                                                              and desperately needed treatment and care. A lack of access to adequate mental and substance use care will lead many Americans to
Street Lending                                                                                 The National     utilization of emergency services, over-crowding community hospital emergency departments and drastically increasing health care costs. As
Program - Nonprofit                                                          stephaniek@th     Council for      such, NCBH strongly supports the Nonprofit Organization New Loan Facility eligibility that would include nonprofit organizations employing up
Organization          PIO (Email    6/22/2020                                enationalcounci   Behavioral       to 15,000 employees or with 2019 annual revenue up to $5 billion.
Facilities            from Web)     12:00:00 AM     Ingoglia    Chuck        l.org             Health




                                                                                                                   Page 125 of 300
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                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                      Comment




                                                                                                               The Florida Community Loan Fund (FCLF) is a nonprofit CDFI revolving loan fund certified by Treasury since 1996. Over the past 25 years
                                                                                                               FCLF has provided over $449 million in financing into projects valued at over $1.2 billion.

                                                                                                               FCLF appreciates this opportunity to provide comment on the Federal Reserve's proposal to expand the Main Street Program to
                                                                                                               Nonprofits.

                                                                                                               We would like to specifically suggest that the Federal Reserve:

                                                                                                               -1. Reduce the minimum number of employees' eligibility range criteria to 15 employees.

                                                                                                               - Rationale: Many Nonprofit organizations employ fewer than 50 employees. For example FCLF employs a staff of only 17 and nonprofits to
                                                                                                               which we provide financing range in size from a low of 3-5 employees to 100+ employees. We suggest that the number of employees is not
                                                                                                               necessarily the best metric to be used in determining eligibility because it may exclude organizations doing important work that contribute
                                                                                                               significantly to supporting the economy and the social fabric of communities for persons and places outside the economic mainstream. These
                                                                                                               same communities are disproportiately affected by poverty and the pandemic.

                                                                                                               - 2. Ensure that nonprofit Community Development Financial Institutions (CDFIs) are eligible to apply to the Main Street Program.

                                                                                                               - Rationale: CDFIs are important community development financial intermediaries that in many cases specialize in financing Nonprofits. These
                                                                                                               CDFIs have capacity, knowledge and experience in utilizing and leveraging capital in support of other nonprofit organizations. As such, CDFIs
                                                                                                               should be ensured access to Main Street Program's loans for direct support of their ongoing lending operations or as additional loan
                                                                                                               capital.

                                                                                                               - 3. The Federal Reserve should consider partnering with CDFIs in the administration and deployment of Main Street Program funding.

Staff Group - Main                                                                                             - Rationale: CDFIs are mission-driven, effective and efficient underwriters and lenders of capital to the Nonprofit Sector. CDFIs have already
Street Lending                                                                                                 participated effectively in expanding the Treasury's Payroll Protection Program to Nonprofits nationwide. In addition many CDFIs, like
Program - Nonprofit                                                                            Florida         FCLF, have extensive track records of making multi-year loans in amounts of $250,000-$6 million or more that are routinely based on
Organization          PIO (Email    6/22/2020                                jbeaton@fclf.or   Community       examining Nonprofit Borrower operating performance, liquidity, ability to repay debt; and operational histories.
Facilities            from Web)     12:00:00 AM     Beaton      Joy          9                 Loan Fund




                                                                                                                  Page 126 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                  Comment
                                                                                                               Subject: Main Street Lending Program for Nonprofits - NONLF and NOELF

                                                                                                               To Whom It May Concern:

                                                                                                               As a leading workforce development organization, Goodwill-Easter Seals Minnesota provides education, job training and placement services to
                                                                                                               more than 6,000 Minnesotans every year. We were significantly impacted by the retail closures due to the pandemic and the Minnesota
                                                                                                               Governor's Stay at Home mandate. With 50 Goodwill stores in Minnesota closed for more than 2 months, we find ourselves in
                                                                                                               unchartered financial territory. And, as a nonprofit with more than 500 employees, we have not qualified for any of the federal relief programs.
                                                                                                               The recent civic unrest in Minneapolis and St. Paul created another layer of complication for our financial picture with property destroyed in
                                                                                                               both cities.

                                                                                                               Goodwill-Easter Seals appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan Facilities.
                                                                                                               Nonprofit business models vary widely, but all charities are inherently organized around a public mission. Many of the financial requirements
                                                                                                               included in this proposal simply are not applicable to organizations that rely on donations. With that in mind, Goodwill-Easter Seals respectfully
                                                                                                               requests the Federal Reserve to address the concerns and proposed changes outlined below.

                                                                                                               1. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                               In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                               Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                               interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." In the
                                                                                                               context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria alone.
                                                                                                               This seems written more in the context of for-profit businesses as opposed to nonprofit organizations. It may certainly be prudent and
                                                                                                               necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin, both out of necessity and also so
                                                                                                               as to not leave excess surpluses that could be used for fulfilling our mission.

                                                                                                               Recommendation: The 5% requirement should be reduced to 3%, if not completely eliminated.

                                                                                                               2. Loans must be expedited
                                                                                                               Nonprofits like Goodwill-Easter Seals are at a critical economic juncture in which timing is of the essence. We must secure additional funding in
                                                                                                               the very near term or significant financial challenges will need to be addressed. While loan forgiveness is also a top priority, Congress could act
                                                                                                               retroactively once loans are already approved.

                                                                                                               Recommendation: Finalize the rules as soon as possible and ensure nonprofits have access to funds within the next few weeks.

                                                                                                               3. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                               Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                               Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                               nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                               In this critical time, nonprofits like Goodwill-Easter Seals have stepped up to meet the unprecedented level of need in our country due to the
                                                                                                               COVID-19 pandemic. Even though we face many of the same economic challenges as other industries, nonprofits are not shutting down.
                                                                                                               Rather, we are straining to meet increasing demands in our communities and will play an integral role as our nation recovers - providing job
                                                                                                               training and other core supports.

                                                                                                               Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                               forgiveness - especially for these Main Street Loans.

                                                                                                               4. More Favorable Loan Terms for Charitable Organizations Are Needed
                                                                                                               The proposal imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan Facilities available to
Staff Group - Main
Street Lending                                                                                                 for-profit businesses. Nonprofit organizations typically provide services with low-profit margins and only a few months of operating reserves.
Program - Nonprofit                                                                           Goodwill-
Organization          PIO (Email    6/22/2020                                dgulliford@ges   Easter Seals     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
Facilities            from Web)     12:00:00 AM     Gulliford   Deanna       mn.org           Minnesota        partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8 related to liquid

                                                                                                                  Page 127 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                    Comment
                                                                                                              assets and cash to debt ratio. While these may be standard bank loan requirements, nonprofits are in crisis and need funds to stabilize
                                                                                                              operations.

                                                                                                              We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                              in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                              Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                              imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                              with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                              balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                              Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                              permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                              to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment.


                                                                                                              With the onset of the COVID-19 pandemic, the organizational challenges have been significant for Goodwill-Easter Seals and other larger
                                                                                                              nonprofits who have not qualified for any federal assistance due to size restrictions (500+ employees). We appreciate your attention to these
                                                                                                              comments and believe that the inclusion of these provisions will directly help charitable nonprofits respond to the fallout from this pandemic and
                                                                                                              will continue to serve our communities as we move into recovery.
                                                                                                              Sincerely,

                                                                                                              Dr. Michael Wirth-Davis

                                                                                                              Dr. Michael Wirth-Davis, D.P.A.
                                                                                                              President and CEO
                                                                                                              Goodwill-Easter Seals Minnesota




Staff Group - Main                                                                                            The American Hospital Association (AHA) appreciates the opportunity to comment on the proposed Nonprofit Organization New Loan Facility
Street Lending                                                                                                Term Sheet and proposed Nonprofit Organization Expanded Loan Facility Term Sheet. Our full comments will be submitted by email and are
Program - Nonprofit                                                                          American         focused on increasing the possibility that hospitals around the country can make use of this potentially vital loan facility and on easing the
Organization          PIO (Email    6/22/2020                                mrock@aha.or    Hospital         daunting conditions imposed on hospitals in the midst of a public health crisis with devastating financial effects.
Facilities            from Web)     12:00:00 AM     Rock        Michael      9               Association




                                                                                                                 Page 128 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                      Comment
                                                                                                              Introduction
                                                                                                              The United States Hispanic Chamber of Commerce (USHCC) actively promotes the economic growth, development and interests of more than
                                                                                                              4.8 million Hispanic-owned businesses that aggregately contribute over $800 billion to the American economy every year. We also serve as a
                                                                                                              platform for our nationwide network of over 250 local Hispanic chambers of commerce. Given the growing diversity in communities across the
                                                                                                              nation, the face of business ownership in America is changing, with minority-owned firms driving growth in new business formation. In fact,
                                                                                                              Latinos open businesses at three times the rate of the national average and Latinas open businesses at six times the rate.

                                                                                                              Minority Business Enterprises (MBEs) have been succeeding in spite of the many historical barriers minority entrepreneurs face as they work
                                                                                                              to start and grow a business. MBEs are two to three times more likely to be denied business loans, have one third of the annual gross
                                                                                                              revenues when compared to non-minority owned companies, and are half as likely to have at least one employee on payroll. When we fail to
                                                                                                              invest in minority-owned firms, our economy suffers.

                                                                                                              Problems and solutions
                                                                                                              Problem: Current minimum loan amount limits ability to reach most of Main Street
                                                                                                              Solution: Lower minimum borrowing limit to $50,000
                                                                                                              Context: The majority of our 4.8 million business owners will not be covered by this program. In our estimation a $250,000 loan assuming a 2x
                                                                                                              EBITDA (Earnings before interest, taxes, depreciation and amortization) and a 10% profitability implies a $1.2 million in revenue. Only 1.7% of
                                                                                                              our business have revenues above $1 million. However, we see the validity of saving and supporting these businesses, which are significant
                                                                                                              as job creators to reestablish the American economy through this proposed lending structure.

                                                                                                              Problem: Limiting support to debt limits potential and speed of recovery
                                                                                                              Solution: Expand structure to inclusion equity
                                                                                                              Context: the current levels of uncertainty and the inability of many otherwise viable business owners to incur an additional debt requires the
                                                                                                              creation of equity solutions. These types of solutions have been used in the past, such as in the Public Private Investment Partnership. This will
                                                                                                              allow firms to create more flexible and closer to optimal capital structures, allowing them to go back to productivity and job creation, and will in
                                                                                                              fact allow businesses to utilize more debt.

                                                                                                              Problem: Allowing only banks to participate will limit reach and speed of recovery
                                                                                                              Solution: Allow other types of lenders to participate
                                                                                                              Context: Inclusion of a wider variety of lenders including debt and equity asset managers, CDFIs and diverse lenders who know our community
                                                                                                              will vastly help the Federal Reserve achieve its goals. These lenders are critical to ensure that the funds from these financial facilities make it
                                                                                                              into the hands of businesses on actual "Main Street", minority communities, and the most vulnerable businesses affected by the
                                                                                                              COVID-19 pandemic. Many of our businesses are small and need community lenders including CDFI's to support them with capital, with
                                                                                                              size of checks up to $500,000. But beyond those needs there is a next tier of solid businesses, across many industries, that need larger size of
                                                                                                              checks, both debt and equity, provided by value add capital providers, many of which are minority owned, who need to be visible and valuable
                                                                                                              to the Federal Reserve and Treasury and added as fiduciaries, service providers and advisors, in the next relief package.

                                                                                                              Problem: Address historical problem of diversity and inclusion regarding financial recovery solutions.
                                                                                                              Solution: Demonstrate commitment to inclusion by including opportunities for skilled minority managers to add value and help salvage
                                                                                                              productivity and job creation. This need has been largely compounded by the fact that many of our business owners are not closely working
                                                                                                              with a bank, which is why the Paycheck Protection Program (PPP) had significant challenges and low minority participation rates. If the Main
                                                                                                              Street Lending Program is distributed only through banks, this will continue to largely occur. The program excludes other valuable financial
Staff Group - Main                                                                                            entities, such as debt and equity asset managers, especially those that are diverse owned and have experience and knowledge in markets and
Street Lending                                                                               United States    with managing recession programs through proven track records based on previous recessions. If debt and equity asset managers are
Program - Nonprofit                                                                          Hispanic         included in these facilities it will allow the Federal Reserve to have diversity and flexibility in the capital that will be deployed and that capital will
Organization          PIO (Email    6/22/2020                                RCavazos@us     Chamber of       have replication abilities through debt and equity expanding the overall amounts for loans being made and secured by borrowers.
Facilities            from Web)     12:00:00 AM     Cavazos     Ramiro A.    hcc.com         Commerce




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                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address      Affiliation                                                                       Comment
                                                                                                               I strongly urge you to broaden the criteria for the expanded Main Street Lending Program to make 501 c4 organizations become eligible for the
                                                                                                               NONLF. The Las Vegas Monorail Company is a 501 c4 entity that provides critical transportation services in the Las Vegas tourism corridor.
                                                                                                               We carry approximately 5 million passengers annually on less than 4 miles and rely solely on fares from the system and other small contracts
                                                                                                               for all revenue. Our system was required to shut down on March 18, 2020 by Governor order when all nonessential businesses were ordered
                                                                                                               to close due to COVID 19. We have been forced to lay off over 90 percent of our workforce, and we cannot open until hotel occupancy creates
                                                                                                               enough demand to create a break-even scenario because we are a nonprofit without a lot of cash reserves. We would like to obtain a loan that
Other: Main Street                                                                                             will allow us to hire back some of our workforce and open the system, even if at an operating deficit for a short period of time, in order to aid in
Lending Program                                                                                Las Vegas       the recovery of the tourism sector. Without a loan or other funding source, we are unable to consider or accomplish this. We implore you to
Eligibility Public    PIO (Email    6/22/2020                                 ingrid@lvmonor   Monorail        consider adding 501 c4 organizations like the Las Vegas Monorail Company, even with other qualifying criteria.
Comment               from Web)     12:00:00 AM     Reisman     Ingrid        ail.com          Company




                                                                                                               Thank you for the opportunity to provide feedback on this vital program for U.S. Nonprofits.

                                                                                                               We wish to provide the following feedback and recommendations that we believe will allow for the greatest opportunity for nonprofits to utilize
                                                                                                               the program:
                                                                                                                Eligible Loans
                                                                                                               o In regard to principal amortization, we recommend a provision of flexibility in paying the loan and increasing or decreasing the amortization
                                                                                                               percent and timing in discussion with the Eligible Lender.
                                                                                                               o In regard to adjustable rate of LIBOR + 300 Basis points, we recommend that there be provided documentation language on alternate index
                                                                                                               or labor substitutes, and also reduction of rates in negotiation with the Eligible Lender as the future potential with an adjustable loan is a
                                                                                                               concern due to pending market volatility.
                                                                                                               o In regard to the condition that at the time of origination or at any time during the term of the Eligible Loan, it not be contractually subordinated
                                                                                                               in terms of priority to any of the Eligible Borrower's other loans or debt instruments; and Subordinated debt ranks after other debts if a
                                                                                                               company fall into liquidation or bankruptcy. We recommend that this provision be eliminated or a waiver provided for Eligible Borrowers. There
                                                                                                               is deep concern that this provision will sharply reduce borrower interest and needs significant clarification to avoid crossover issues with other
                                                                                                               popular debt instruments such as PPP.
                                                                                                                Required Borrower Certifications and Covenants
                                                                                                               o In regard to the condition that the Eligible Borrower must commit to refrain from repaying the principal balance of, or paying any interest on,
                                                                                                               any debt until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due. We recommend additional clarity on
                                                                                                               the wording "unless the debt or interest payment is Mandatory and Due" is requested. It is common to have other agreements that
                                                                                                               would default unless timely P&l payments are due. Nonprofits may be hesitant to enter into a Main Street Lending Program without clarity
                                                                                                               of this and understanding that they can move forward.
                                                                                                               o In regard to the condition that the Eligible Borrower must commit that it will not seek to cancel or reduce any of its committed lines of credit
                                                                                                               with the Eligible Lender or any other lender. We recommend that this be a covenant that is negotiable with the Eligible Borrower.
                                                                                                                Loan Origination and Servicing Fees
Staff Group - Main                                                                                             o In regard to the condition that an Eligible Borrower will pay an Eligible Lender an origination fee of up to 100 basis points of the principal
Street Lending                                                                                                 amount of the Eligible Loan at the time of origination. The SPV will pay an Eligible Lender 25 basis points of the principal amount of its
Program - Nonprofit                                                           Jesse.Torres@                    participation in the Eligible Loan per annum for loan servicing. We recommend that the origination fee be noted as between .5% and 1% in
Organization          PIO (Email    6/22/2020                                 arroyowest.co    ArroyoWest      discussion with the Eligible Lender and we recommend a waiver of the per annum loan servicing fee in consultation with the Eligible Lender.
Facilities            from Web)     12:00:00 AM     Torres      Jesse         m                LLC




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                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment
                                                                                                              June 22, 2020

                                                                                                              United States Federal Reserve System
                                                                                                              20th Street NW
                                                                                                              Washington, DC 20551

                                                                                                              RE: Comments in response to the Federal Reserve's intention to expand Main Street Loans to non-profit organizations

                                                                                                              Dear Sir/Madam:
                                                                                                              On behalf of the Rhode Island Health Center Association (RIHCA), and its members, we are submitting comments on the proposal to expand
                                                                                                              Main Street Loans to non-profit organizations. Federally Qualified Health Centers (FQHCs) are community-based, non-profit organizations
                                                                                                              whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay. As explained below, we
                                                                                                              appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however, after analyzing the draft
                                                                                                              Term Sheet, we have determined that almost no FQHCs would qualify for these loans under the current eligibility requirements. Therefore, we
                                                                                                              are requesting that:
                                                                                                               the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                               FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                              the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                              RIHCA represents Rhode lsland's nine community health centers, including eight federally qualified health centers (FQHCs), one island­
                                                                                                              based health center, and associate community mental health center member, the Providence Center. Community health centers are non-profit
                                                                                                              health care providers with a long history of serving patients who may otherwise confront financial, geographic, linguistic, and cultural barriers to
                                                                                                              accessing health care services.

                                                                                                              Throughout the pandemic, FQHCs have provided a range of critical frontline care and a growing proportion of testing, particularly in the low-
                                                                                                              income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue due to the need to
                                                                                                              curtail many primary, dental, and preventive care visits. This combination has placed major financial strain on these non-profit, community­
                                                                                                              based providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                              As community-based, non-profit organizations committed to ensuring access to health care, Rhode lsland's eight FQHCs have been on
                                                                                                              the frontlines of the COVID-19 pandemic since the beginning. With over 39 delivery sites, FQHCs provided care for nearly 179,000 patients in
                                                                                                              2018 alone. Many of these patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, Medicaid covers
                                                                                                              over 50%, and many patients suffer from multiple chronic health conditions associated with poverty and the effects of racism.

                                                                                                              While FQHCs have received some federal funding to support COVID relief, for many FQHCs, this funding is not enough to reestablish their
                                                                                                              pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                              individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                              FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.

                                                                                                              Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                              Because of these financial needs, RIHCA was relieved to learn that the Federal Reserve would soon start offering Main Street Loans to non­
                                                                                                              profits. However, after reviewing the proposed Terms Sheet and consulting with experts, we have concluded that almost no FQHCs would
                                                                                                              qualify under the proposed eligibility criteria.

                                                                                                              This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                              of Health and Human Services, to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                               Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                              over 500 staff, who are currently ineligible for the Paycheck Protection Program.
Staff Group - Main
Street Lending                                                                                                 Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
Program - Nonprofit                                                                          Rhode Island     meet the DCOH and Cash/Debt ratio at loan origination.
Organization          PIO (Email    6/22/2020                                jhayward@rihc   Health Center
Facilities            from Web)     12:00:00 AM     Hayward     Jane         a.org           Association      The most problematic financial parameters for FQHCs are:

                                                                                                                 Page 131 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                      Comment
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                      Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                      Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                     origination is 65% or greater

                                                                                                     In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                     the following lending parameters for FQHCs loans as follows:
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                      Days cash on hand at loan origination equal to or greater than 30 days
                                                                                                      Eliminate the unrestricted cash to debt ratio requirement
                                                                                                      Lower the minimum employee requirement to 20.

                                                                                                     In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans

                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                     coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers has collectively provided more than $2.1 billion
                                                                                                     in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the non-profit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                     detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                     current needs of Federally Qualified Health Centers.




                                                                                                        Page 132 of 300
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   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment



                                                                                                              Comments to the Federal Reserve regarding the proposed Main Street Lending Program for nonprofit organizations - NONLF and NOELF

                                                                                                              The PA Association of Nonprofit Organizations provides the following recommendations to improve the proposed Nonprofit Organization Loan
                                                                                                              Programs:
                                                                                                              1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                              economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                              2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor.
                                                                                                              3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                              organization's 2019 revenues come from donations.
                                                                                                              4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                              on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                              requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                              5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                              allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                              needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                              operating budgets and capital funds for improvements.
                                                                                                              6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                              efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                              also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                              Program Flexibility Act should be extended to this loan program.
                                                                                                              7. Additional Questions Recommendations:
                                                                                                              o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                              include cash on hand?
                                                                                                              o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                              needed.
                                                                                                              o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
Staff Group - Main                                                                                            financial liquidity related to the impact of COVID-19.
Street Lending
Program - Nonprofit                                                                          PA Association   The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which the PA
Organization          PIO (Email    6/22/2020                                anne@pano.or    of Nonprofit     Association of Nonprofit Organizations endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Gingerich   Anne         9               Organizations




                                                                                                                 Page 133 of 300
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                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                       Comment
                                                                                                               To Whom It May Concern:

                                                                                                               The YMCA of the USA (Y-USA) is respectfully submitting these comments in response to Federal Reserve Board's announcement on
                                                                                                               June 15, 2020 that it is seeking public feedback on the proposal to expand its Main Street Lending Program for nonprofit organizations. We
                                                                                                               appreciate the Federal Reserve Board making this program available to nonprofits; however, there are several concerns outlined below that
                                                                                                               could help improve the program and make it truly applicable and accessible to nonprofit organizations, such as local YMCAs.

                                                                                                               YMCA of the USA is the national resource office for the nation's 2,700 local 501(c)3,
                                                                                                               charitable, nonprofit YMCAs. Each of these YMCAs helps strengthen their local communities through youth development, healthy living, and
                                                                                                               social responsibility. Annually, YMCAs engage 22 million men, women, and children-regardless of age, income, or background-to nurture the
                                                                                                               potential of children and teens, improve the nation's health and well-being, and provide opportunities to give back and support neighbors.
                                                                                                               The Y works side-by-side with its neighbors to make sure everyone has the opportunity to learn, grow, and thrive.

                                                                                                               Despite mandated facility closures, cancellation of traditional programming and a decrease in giving, the Y has stepped up to address the
                                                                                                               critical need for safe childcare options and other needed services across the country. At the height of the pandemic the Y offered emergency
                                                                                                               childcare at more than 1,100 locations for families of medical personnel, essential employees and first responders. With school closures,
                                                                                                               children cannot access USDA breakfasts and lunch and during this time of economic uncertainty, a rapidly increasing number of adults and
                                                                                                               families are facing food insecurity. In response, over 1,000 Ys nationwide are providing free grab-and-go meals to help address this urgent
                                                                                                               need.

                                                                                                               Citizens in communities of all sizes are depending on local charitable nonprofits to a far greater degree during the response and relief phases
                                                                                                               to the COVID-19 health and economic crises, and that reliance will only grow during the recovery period ahead (including response and relief
                                                                                                               for any second and third waves of the virus).

                                                                                                               Y-USA has worked with YMCA State Alliances and local Ys to identify and address areas of confusion and contradiction in regard to the much-
                                                                                                               anticipated Mainstreet Lending Program. These real-life, current concerns and questions based on experiences of Ys across America are the
                                                                                                               basis for the following comments and recommendations.

                                                                                                               Comments and Recommendations

                                                                                                               1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness

                                                                                                               Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                               Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                               nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                               In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                               though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                               meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                               Furthermore, they will play an integral role as our nation recovers - providing childcare, job training, and other core supports.

                                                                                                               Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                               Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                               nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                               helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                               loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                               Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                               steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
Staff Group - Main
Street Lending                                                                                                 employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
Program - Nonprofit                                                                          YMCA of           the economy.
Organization          PIO (Email    6/22/2020                                cdavis@ymcap    Pierce and
Facilities            from Web)     12:00:00 AM     Davis       Charlie      kc.org          Kitsap Counties   Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan

                                                                                                                  Page 134 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     forgiveness, in the next round of COVID-19 relief legislation.

                                                                                                     2. The Federal Reserve Needs to Make Loan Terms More Favorable to Charitable Organizations

                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for-profit businesses.

                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard. The statistics above should not be
                                                                                                     viewed as an indictment of the efficiencies or management policies of nonprofits.

                                                                                                     Also, many nonprofits are facility-based and carry planned debt which may be disqualified under the proposed calculation. Furthermore,
                                                                                                     creditworthiness can be established on other criteria.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and eliminating the specific 65% debt ratio requirement and instead allow a statement of
                                                                                                     explanation for debt that may be of concern as it relates to credit worthiness.

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is too high. In addition, the imposition of loan
                                                                                                     origination and service fees adds to the cost. Finally, the 70% balloon payment at the end of the fifth year of the loan would be difficult for many
                                                                                                     nonprofits, unless provided an opportunity to refinance such loans at low rates.

                                                                                                     Recommendation: Revisit the loan terms including interest rate and balloon payments and recommend the lowest permissible rate such as the
                                                                                                     0.5% rate initially proposed for PPP loans. We also urge some flexibility in the balloon payment requirement to afford the opportunity for
                                                                                                     renegotiation. Extending the 5-year amortization to seven years could lessen the balloon payment. We request that borrowers have access to
                                                                                                     engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     3. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised

                                                                                                     In the "Draft for Public Consultation," one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019
                                                                                                     earnings before interest, depreciation, and amortization (EBIDA) to unrestricted 2019 operating revenue, greater than or equal to 5%."
                                                                                                     (#6) In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these
                                                                                                     criteria alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin, both out of
                                                                                                     necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit may have
                                                                                                     a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of instability.

                                                                                                     Furthermore, the footnotes for #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating revenue,
                                                                                                     excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and contracts
                                                                                                     built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be sensible
                                                                                                     to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for maintenance
                                                                                                     and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation

                                                                                                        Page 135 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     methodology-in the context of nonprofit operating budgets-is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     4. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification

                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in which the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                     Recommendation: Further refine the terms "maintain its payroll" and "retain its employees" are vague, and make clear
                                                                                                     that nonprofits participating in the Main Street loan program generally should endeavor to pay staff at the same or increased income levels and
                                                                                                     should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at the same or increased levels, both for the
                                                                                                     duration of the loan. It is also important that the loan documents expressly state that the employee retention provision begins on the date that
                                                                                                     loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: Adopt the safe harbors of other loan programs and state clearly that nonprofit borrowers will not be penalized under the
                                                                                                     employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for cause, voluntarily resign, or
                                                                                                     voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     5. Limitation of 50-Employee Minimum Should Be Removed

                                                                                                     The proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street Loan Facilities for for-profit businesses.
                                                                                                     There is no explanation why the Federal Reserve is proposing that nonprofits with fewer than 50 employees should not be eligible for Main
                                                                                                     Street loans for which their small business counterparts of equal size could secure lending support.

                                                                                                     Recommendation: Remove the 50-employee floor.

                                                                                                     6. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                     Charitable Sector

                                                                                                     The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities.
                                                                                                     Overall, this loan facility seems more geared to educational institutions and nonprofit hospitals, but not most charitable organizations.

                                                                                                     Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations.

                                                                                                     Conclusion
                                                                                                     Y-USA appreciates the opportunity to submit these comments to the Federal Reserve about the Mainstreet Lending Program for Nonprofits,
                                                                                                     which, in its proposed form, seems aimed more at nonprofits such as hospitals and institutions of higher education than at nonprofits like local
                                                                                                     YMCAs. Given that, Y-USA respectfully requests the Federal Reserve to address the concerns and proposed changes outlined above.

                                                                                                     Thank you for considering these comments and recommendations. We stand ready to work with you to strengthen the Mainstreet Lending
                                                                                                     Program and give YMCAs the resources to help communities across America get through this crisis and promote a vibrant and equitable
                                                                                                     economic recovery.

                                                                                                     Sincerely,

                                                                                                     Charlie Davis

                                                                                                        Page 136 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address      Affiliation                                                                          Comment
                                                                                                               President and CEO
                                                                                                               YMCA of Pierce and Kitsap Counties




                                                                                                               The 5% EBIDA requirement, if it is not modified, will disqualify our nonprofit organization from the Fed's Nonprofit New Loan Facility. The
                                                                                                               requirement of earnings before interest, depreciation, and amortization ("EBIDA") of at least 5% of operating revenue is not
                                                                                                               realistic. Our EBIDA is 2%, or $6.8 million, which is more than sufficient to service a $20 million, 5-year term loan. The Fed's formula
                                                                                                               would require EBIDA of $17 million. If we were generating surpluses of $17 million a year instead of spending it on our constituents, we would
                                                                                                               not be fulfilling our mission. EBIDA standards for profit-motivated business and nonprofits are not the same.

                                                                                                               This can be rectified by any one of the following:
                                                                                                               1. Require nonprofits to meet one of the financial requirements (EBIDA, Days of Liquid Assets, and Unrestricted Cash and Investments to
                                                                                                               Debt), not all three.
                                                                                                               2. Set EBIDA at a level-1.5% or 2% of operating revenue-that acknowledges the critical difference in surplus objectives between for-profit
                                                                                                               entities and mission-driven nonprofits.
                                                                                                               3. Exclude pass-through revenue (funds disbursed directly to third parties in support of the organization's constituents) from
                                                                                                               "unrestricted operating revenue."

Staff Group - Main                                                                                             In addition to the eligibility issue above, the loan cost is too high. An origination fee of 1% and interest at Libor plus 300 basis points will divert
Street Lending                                                                                                 funds that should be spent on retaining staff and serving constituents. An origination fee of 25 basis points, and an interest rate of Libor plus
Program - Nonprofit                                                          Personal Email
                                                                                                               200 basis points, would allow nonprofits to continue to provide critical services, contribute meaningfully to the country's economic
                                                                             Address
Organization          PIO (Email    6/22/2020                                                                  recovery, and generate an acceptable financial return for the overall program.
Facilities            from Web)     12:00:00 AM     Partridge   Lowell                        Road Scholar
Staff Group - Main    PIO (Email    6/22/2020                                mshepherd@gi     Girl Scouts of   A comment has been submitted by email on behalf of Sue Santa, Vice President of Public Policy and Advocacy at Girl Scouts of the USA.
Street Lending        from Web)     12:00:00 AM     Shepherd    Madeline     rlscouts.org     the USA
                                                                                                                  Page 137 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

    Event Title /
    Description       Ticket Type   Received Date   Last Name    First Name    Email Address      Affiliation                                                                      Comment
Program - Nonprofit
Organization
Facilities
                                                                                                                Orange County Grantmakers is pleased to provide comments on and support the Federal Reserve Board's proposal to expand its Main
                                                                                                                Street Lending Program to provide access to credit to nonprofit organizations. This proposed expansion to small and medium sized nonprofits
                                                                                                                is a valuable tool to help Orange County nonprofits as they continue to serve their communities during these challenging times. While this is a
                                                                                                                positive move to support nonprofits so critical to our economy, we also encourage the Federal Reserve to consider expanding the loan
                                                                                                                qualifications to include even the smallest nonprofits in our community or develop nonprofit microloans to support those organizations that
                                                                                                                might not qualify for the program.

                                                                                                                Orange County Grantmakers is an association of foundations, corporate giving programs, and community organizations actively involved in
                                                                                                                philanthropy in Orange County, CA. Our mission is to advance social impact by supporting, strengthening, and building adaptive leadership
                                                                                                                across our nonprofit and philanthropic community. Our vision is a community of philanthropists committed to improving outcomes for Orange
                                                                                                                County and beyond.
                                                                                                                Orange County Grantmakers is almost 20 years old and serves the important role of convening and connecting nonprofits and funders around
                                                                                                                issues and ideas most impactful to our community. As funders, we see every day the vital and important role nonprofits serve in our community
                                                                                                                as well as the unique challenges faced by a not-for-profit providing critical services to Orange County.

                                                                                                                We appreciate Chairman Powell's acknowledgement that "Nonprofit organizations are critical parts of our economy, employing
                                                                                                                millions of people, providing essential services to communities, and supporting innovation and the development of a highly skilled
                                                                                                                workforce.Xquot; Yet, far too often, nonprofits are not recognized as the vital small businesses they are when it comes to financial support. A
                                                                                                                recent survey, conducted by Charitable Ventures, the administrator for the Orange County Community Resilience Fund that provided $4.2 of
                                                                                                                philanthropic emergency dollars to our nonprofit community in the immediate COVID-19 shutdown, found that 79% of organizations surveyed
                                                                                                                experienced significant revenue shortfalls while experiencing a significant increase in costs and an increase in requests for services. Many of
                                                                                                                these nonprofits have also had to pivot to continue to provide operations and are unclear when normal operations may resume.

                                                                                                                Orange County Grantmakers supports the differentiation of two options for the loan, taking into account the differences between for profit and
                                                                                                                nonprofit organizations. We strongly encourage the Federal Resource Board to revise the eligibility criteria related to the employee number
                                                                                                                however, so that nonprofits with fewer than 50 employees are eligible to apply for the loans and lower the maximum number to much fewer
                                                                                                                than 15,000 employees in order to truly open up the loans to small and medium sized nonprofits.

                                                                                                                Orange County philanthropy raised more than $6 million and counting in emergency and community response dollars during the COVID-19
                                                                                                                pandemic. These dollars have been critical to nonprofits serving on our front-lines to provide food access and distribution, emergency housing,
                                                                                                                and improving and expanding our community's health infrastructure. These dollars however are not enough to fill the gap of what is
                                                                                                                needed. We appreciate the federal efforts to date that are helping to keep nonprofits in operation and return to full capacity and encourage the
                                                                                                                Federal Reserve Board to do its part. Thank you for considering our input and please do not hesitate to contact us with any questions.

Staff Group - Main                                                                                              Submitted by:
Street Lending
Program - Nonprofit                                                           Taryn.Palumbo                     Taryn Palumbo
Organization          PIO (Email    6/22/2020                                 @ocgrantmake     Orange County    Executive Director
Facilities            from Web)     12:00:00 AM     Palumbo     Taryn         rs.org           Grantmakers



                                                                                                                Small and medium sized non-profits often are employers in small towns and contribute to the quality of life and economy of smalls towns. The
Staff Group - Main                                                                                              program should allow for organizations that employ less than 50 people, and should assist in helping to sustain them when their local donors
Street Lending                                                                                                  and paid participants can no longer afford to continue to give money to these types of orgs for the time being. Smaller loans, like the $10,000
Program - Nonprofit                                                           Personal Email   Wisconsin        that was given to small businesses through the Small Business loan program would assist non-profits in the same way, helping them to
                                                                              Address
Organization          PIO (Email    6/22/2020       Van                                        Federation of    continue to pay qualified and local staff who will also contribute to the local economy with their sales.
Facilities            from Web)     12:00:00 AM     Haaften     Jennifer                       Museums




                                                                                                                   Page 138 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment
                                                                                                              To Whom It May Concern:

                                                                                                              Thank you for the opportunity to provide comment on the Proposed Parameters for Main Street Loans for Non-Profits. I write on behalf of Bi­
                                                                                                              State Primary Care Association and our members. We appreciate the Federal Reserve's efforts to expand Main Street Loans to non-profit
                                                                                                              organizations like our members. However, according to the Term Sheet, it appears that none of our FQHC members would qualify for these
                                                                                                              loans. As discussed below, we request that the loan terms be revised to enable the majority of FQHCs to qualify, and that they be permitted to
                                                                                                              work with Community Development Financial Institutions (CDFIs) to access Main Street loans.

                                                                                                              Bi-State Primary Care Association (Bi-State) is a nonpartisan, nonprofit 501(c)(3) charitable organization that promotes access to effective and
                                                                                                              affordable primary care and preventive services for all, with special emphasis on underserved populations in Vermont and New Hampshire. Bi-
                                                                                                              State's combined Vermont and New Hampshire membership includes 29 Community Health Centers (CHCs) delivering primary care at
                                                                                                              126 sites and serving over 315,000 patients. The majority of these CHCs are Federally Qualified Health Centers (FQHCs). Part of our
                                                                                                              providers' mission is to serve everyone, regardless of ability to pay, and to deliver comprehensive medical services. We provide
                                                                                                              preventive and primary care that helps achieve the best possible health outcomes and contains overall costs within the system. Access to
                                                                                                              substance misuse treatment for substances, including opioids, is critical for this work.

                                                                                                              Bi-State's response to the COVID-19 pandemic:

                                                                                                              Bi-State is engaged in robust pandemic response providing support to our members, and education to governmental entities at the federal
                                                                                                              level, in New Hampshire, and in Vermont. Our health centers are on the front lines caring for their patients and providing evaluation and testing
                                                                                                              for the uninsured and general population. They are caring for patients using telehealth, while operating testing sites, respiratory clinics, and
                                                                                                              providing time sensitive primary care services. These non-profits are caring for the homeless and translating pandemic information into multiple
                                                                                                              languages.

                                                                                                              Our members are increasingly relied upon by their communities to care for more uninsured and serve as a critical part of the public health
                                                                                                              infrastructure. At the same time, they have experienced a significant decline in revenue, due to the need to curtail many primary and preventive
                                                                                                              visits. Further, they do not have a full staff complement due to quarantine, school at home, and health concerns impacting the workforce. This
                                                                                                              combination has caused significant financial strain on these non-profit, community-based providers.

                                                                                                              While many of our members, including FQHCs, have received some federal funding to support COVID-19 response. For many this is not
                                                                                                              enough to return to pre-COVID-19 operations, nor is it sufficient to prepare for the increased demand as more newly-unemployed, uninsured,
                                                                                                              and underinsured individuals turn to them for care. Additionally, it is unclear how long the pandemic will last, which provides significant financial
                                                                                                              uncertainty.

                                                                                                              Recommendation 1: Expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                              Given these financial needs, Bi-State is hopeful that the Main Street Loans for Non-Profits program can be used by our members, including
                                                                                                              FQHCs. After reviewing the proposed Terms Sheet and consulting with experts, we have concluded that almost no FQHCs would qualify under
                                                                                                              the proposed eligibility criteria.

                                                                                                              Recent analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department of Health and Human
                                                                                                              Services to assist FQHCs with accessing capital, determined that the proposed lending parameters limit FQHC eligibility:
                                                                                                               Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                              over 500 staff, who are currently ineligible for the Paycheck Protection Program. We have two such health centers in Vermont.
                                                                                                               Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                              meet the days cash on hand and Cash/Debt ratio at loan origination.

                                                                                                              The most problematic financial parameters for FQHCs are:
                                                                                                               EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%.
Staff Group - Main
Street Lending                                                                                                 Days cash on hand at loan origination equal to or greater than 90 days.
Program - Nonprofit                                                                          Bi-State          Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
Organization          PIO (Email    6/22/2020                                gmaheras@bist   Primary Care     origination is 65% or greater.
Facilities            from Web)     12:00:00 AM     Maheras     Georgia      atepca.org      Assn

                                                                                                                 Page 139 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address       Affiliation                                                                      Comment
                                                                                                                With the following simple modifications, the program could be viable for approximately 60% of FQHCs. We request that the Federal Reserve
                                                                                                                adjust the following lending parameters for FQHC loans as follows:
                                                                                                                 EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%.
                                                                                                                 Days cash on hand at loan origination equal to or greater than 30 days.
                                                                                                                 Eliminate the unrestricted cash to debt ratio requirement.
                                                                                                                 Lower the minimum employee requirement to 20.

                                                                                                                We also ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to the
                                                                                                                Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                                authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                                could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                                providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                                support" be revised to read "direct support."

                                                                                                                Request to work directly with CDFIs to access Main Street Loans:

                                                                                                                Community Development Financial Institutions (CDFIs) have historically played a major role in providing financing to non-profits and especially
                                                                                                                FQHCs. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A coalition of 25 CDFIs who
                                                                                                                are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1 billion in loans to FQHCs, with
                                                                                                                a default rate of less than 1/1 Oth of 1%.

                                                                                                                Our review indicates that very few CDFIs would qualify as eligible lenders under the program as it is currently construed. We recommend that
                                                                                                                the Federal Reserve structure the non-profit portion of the Main Street Loans Program to:
                                                                                                                 Allow CDFIs to participate as lenders in the program; and
                                                                                                                 Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                                at LIBOR +3%

                                                                                                                Several of our FQHCs have worked closely with CDFIs and other commercial lenders to support services and physical plant to meet the needs
                                                                                                                of their communities. These lenders understand the unique structure of FQHCs and their strong mission as community-based providers of
                                                                                                                primary health care services.

                                                                                                                We welcome the opportunity to provide additional information to assist the Federal Reserve in developing a program that will be responsive to
                                                                                                                the current needs of Federally Qualified Health Centers. If you have any questions, please contact Georgia Maheras at
                                                                                                                gmaheras@bistatepca.org or 802-229-0002, ext. 218. Thank you for your consideration.

                                                                                                                Sincerely,


                                                                                                                Tess Stack Kuenning, CNS, MS, RN
                                                                                                                President and Chief Executive Officer
                                                                                                                Bi-State Primary Care Association

Staff Group - Main
Street Lending                                                                                                  Limit access to this program to smaller nonprofit organizations that are disproportionately less able to access credit
Program - Nonprofit
Organization          PIO (Email    6/22/2020                                 orebanal@capit   Capital Impact   Expansion to include larger organizations is to dilute the intent. Focus should remain on serving smaller organizations
Facilities            from Web)     12:00:00 AM     Rebanal     Olivia        alimpact.org     Partners




                                                                                                                   Page 140 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                          Comment
                                                                                                               We are writing on behalf of the North Carolina Community Health Center Association (NCCHCA), the membership association for 42 federally
                                                                                                               qualified health center (FQHC) and look-alike organizations. FQHCs are a community-based, non-profit organizations whose goal is to provide
                                                                                                               affordable, accessible health care for all individuals, regardless of their ability to pay. As explained below, we appreciate the Federal
                                                                                                               Reserve's intention to expand Main Street Loans to non-profit organizations; however, after analyzing the draft Term Sheet, we have
                                                                                                               determined that almost no FQHCs would qualify for these loans under the current eligibility requirements. Therefore, we are requesting that:
                                                                                                                the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                                FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                               the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                               As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
                                                                                                               19 pandemic since the beginning. With more than 270 care delivery sites in the state, North Carolina's FQHCs provide care for over
                                                                                                               600,000 patients. Our patients have been disproportionately impacted by the pandemic, as roughly 90% of them live in low-income
                                                                                                               households, roughly 40% are uninsured, and a majority are racial and ethnic minorities, many of whom suffer from multiple chronic health
                                                                                                               conditions associated with poverty and the effects of racism.

                                                                                                               Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                               income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                               curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                               providers, forcing them to close sites and lay off staff at the time when their services are most needed. The impact has been even more severe
                                                                                                               on our FQHCs that operate much-needed dental service programs, which have been more severely disrupted in part due to the nature of the
                                                                                                               procedures, as well as those that provide school-based health services. However, even those health centers who do not operate such
                                                                                                               programs still report patient volume and revenue figures far below their pre-COVID levels, causing financial strain and draining cash on hand
                                                                                                               for many.

                                                                                                               While FQHCs have received some federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their pre-
                                                                                                               COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                               individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                               FQHCs with over 500 staff - which in total care for about 9 million patients nationwide - are ineligible for Paycheck Protection Program Loans
                                                                                                               because of their size.

                                                                                                               Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                               Because of these financial needs, NCCHCA was relieved to learn that the Federal Reserve would soon start offering Main Street Loans to non­
                                                                                                               profits. However, after reviewing the proposed Terms Sheet and consulting with experts , we have concluded that almost no FQHCs would
                                                                                                               qualify under the proposed eligibility criteria.

                                                                                                               This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                               of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                                Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                               over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                                Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                               meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                               The most problematic financial parameters for FQHCs are:
                                                                                                                EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                                Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                                Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                               origination is 65% or greater
Staff Group - Main
Street Lending                                                                                North Carolina   In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
Program - Nonprofit                                                                           Community        the following lending parameters for FQHCs loans as follows:
Organization          PIO (Email    6/22/2020                                rileyb@ncchca.   Health Center     EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
Facilities            from Web)     12:00:00 AM     Riley       Brendan      org              Association       Days cash on hand at loan origination equal to or greater than 30 days

                                                                                                                  Page 141 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                      Comment
                                                                                                     Eliminate the unrestricted cash to debt ratio requirement
                                                                                                     Lower the minimum employee requirement to 20.

                                                                                                     In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans

                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                     coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                     billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve&#39:s request. We would be happy to provide more
                                                                                                     detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                     current needs of Federally Qualified Health Centers.




                                                                                                        Page 142 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                    Comment
                                                                                                                We are writing on behalf of the Virginia Community Healthcare Association, and over 150 Federally Qualified Health Center sites (FQHCs),
                                                                                                                more commonly known as community health center sites, operating across the Commonwealth of Virginia.

                                                                                                                FQHCs are community-based, non-profit organizations whose goal is to provide affordable, accessible health care for all individuals,
                                                                                                                regardless of their ability to pay.

                                                                                                                As explained below, we appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however,
                                                                                                                after analyzing the draft Term Sheet, we have determined that almost no FQHCs would qualify for these loans under the current eligibility
                                                                                                                requirements.

                                                                                                                Therefore, we are requesting that:
                                                                                                                 the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                                 FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                                the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                                Background on Virginia Community Healthcare Association and the COVID-19 Pandemic

                                                                                                                In Virginia, community health centers, and affiliated safety net providers, operate over 150 sites across Virginia, from Chincoteague on the
                                                                                                                Eastern Shore, to the far corners and coalfields of Southwest Virginia, and across the Southside of Virginia.

                                                                                                                Our health centers operate in Medically Underserved Areas, or with Medically Underserved Populations. In many cases, our centers are the
                                                                                                                only source of primary health care for their communities and the patients that we serve.

                                                                                                                Health centers serve over 350,000 Virginians across the Commonwealth. Many of those that we serve are at or below 200% of the Federal
                                                                                                                Poverty Level. In addition, a significant portion of our patients are uninsured, or on Medicaid.

                                                                                                                Virginia has been particularly impacted by the COVID-19 pandemic. Our health centers have seen drastic reductions in patient visits and
                                                                                                                revenues. As of June 5th, 21 of our health center sites are still closed, and patient visits have only recovered to 67% of pre-pandemic visits.

                                                                                                                Although an improvement from prior weeks, the financial harm of our health centers since March will take months, if not years, for our health
                                                                                                                centers to recover.

                                                                                                                Our analysis indicates that the health centers are experiencing significantly increased costs for COVID-19 related supplies, while at the same
                                                                                                                time suffering from revenues that have and may well continue to decrease as the pandemic continues into the foreseeable future.

                                                                                                                Community health centers and related safety net providers are being placed in a financial vise.

                                                                                                                Our estimates indicate that in a potentially "worst case" scenario, health centers in Virginia alone could face a loss of revenues as
                                                                                                                high as $159 million, while additional expenses related to COVID-19 may run over $44 million, on top of the revenue losses.

                                                                                                                Nationally, those figures will be drastically higher.

                                                                                                                To help meet the needs in our medically underserved communities, our health centers are in critical need of funding to assist them in staying
                                                                                                                open and serving their communities, retaining highly skilled health care providers, and serving their patients and communities in new ways,
                                                                                                                such as expanding the use of telehealth, creating pandemic safe medical facilities, and revamping operations to the new and continually
                                                                                                                changing "normal" of health care services.

                                                                                                                As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
Staff Group - Main                                                                                              19 pandemic since the beginning. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients. Our
Street Lending                                                                                 Virginia         patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and 68% are racial and
Program - Nonprofit                                                          rshinn@vacom      Community        ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.
Organization          PIO (Email    6/22/2020                                munityhealth.or   Healthcare
Facilities            from Web)     12:00:00 AM     Shinn       Rick                9          Association      Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-

                                                                                                                   Page 143 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                     curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                     providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                     While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                     pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                     individuals turn to them for care.

                                                                                                     To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also, FQHCs with over 500 staff - which in
                                                                                                     total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.


                                                                                                     Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                     Because of these financial needs, the Association and our health centers were relieved to learn that the Federal Reserve would soon start
                                                                                                     offering Main Street Loans to non-profits. However, after reviewing the proposed Terms Sheet and consulting with experts, we have concluded
                                                                                                     that almost no FQHCs would qualify under the proposed eligibility criteria.

                                                                                                     This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                     of Health and Human Services to assist FQHCs with accessing capital.

                                                                                                     Capital Link determined that under the proposed lending parameters:
                                                                                                      Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                     over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                      Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                     meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                     The most problematic financial parameters for FQHCs are:
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                      Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                      Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                     origination is 65% or greater

                                                                                                     In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                     the following lending parameters for FQHCs loans as follows:
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                      Days cash on hand at loan origination equal to or greater than 30 days
                                                                                                      Eliminate the unrestricted cash to debt ratio requirement
                                                                                                      Lower the minimum employee requirement to 20.

                                                                                                     In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans

                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                     coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                     billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                        Page 144 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                      Comment

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed.

                                                                                                     To enable FQHCs to work directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure
                                                                                                     the nonprofit portion of the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request.

                                                                                                     We would be happy to provide more detailed comments and/or provide additional information to assist the Federal Reserve in developing a
                                                                                                     program that will be responsive to the current needs of Federally Qualified Health Centers.




                                                                                                       Page 145 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                Comment
                                                                                                               Comments of the American Cancer Society Cancer Action Network Regarding the Proposed Main Street Lending Program for Nonprofit
                                                                                                               Organizations - NONLF and NOELF

                                                                                                               June 22, 2020

                                                                                                               The American Cancer Society Cancer Action Network, Inc. (ACS CAN) appreciates the opportunity to submit comments to the Federal
                                                                                                               Reserve about the Nonprofit Organization Loan Facilities. ACS CAN is the advocacy affiliate of the American Cancer Society (ACS), a
                                                                                                               nonprofit public charity that may benefit from a loan program. This proposal as drafted, however, would prevent many publicly supported
                                                                                                               charities from qualifying.

                                                                                                               ACS is a health organization with a century of experience serving cancer patients, caregivers, and health providers in the prevention of,
                                                                                                               treatment for, and recovery from cancer. This support does not come with a fee. For instance, ACS responds to 1 million callers a year seeking
                                                                                                               cancer information and assistance. It has a history of housing cancer patients and caregivers in 31 Hope Lodges without charge during cancer
                                                                                                               treatment. In recent years, ACS invested more than $250 million a year on these patient services; $100 million a year in cancer prevention
                                                                                                               programs, such as training and partnerships for cancer screening to hospitals and doctors, including 8,000 health systems; promoting
                                                                                                               prevention or cessation of tobacco use; and $150 million a year to conduct research to prevent and treat cancer. Each year there are more
                                                                                                               than 1.5 million new cancer cases in the US, and ACS is here for Americans because of contributions from individuals and other donors.

                                                                                                               Our comments on specific aspects of the proposed Nonprofit Organization Loan Facilities program are as follows:

                                                                                                               1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness

                                                                                                               Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development that the Federal Reserve
                                                                                                               is making its Main Street lending program available to some nonprofits, this assistance will fall short of what is most needed by nonprofit
                                                                                                               organizations - a statutory provision that makes these loans forgivable.

                                                                                                               In this critical time, charities have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                               though they face many of the same economic challenges as other entities, charitable organizations are not shutting down, but retooling under
                                                                                                               new realities. The ACS opened its doors to first responders, allowing them to take respite and protect their own families, by offering use of the
                                                                                                               ACS's Hope Lodges near hospitals. ACS is adopting measures to protect cancer patients as they return to treatment and Hope Lodges.
                                                                                                               ACS has been resilient to adjust to new ways to help cancer patients. As with other charities, ACS is strained financially to meet the demands
                                                                                                               of cancer patients and families, advancing preventive care, and keeping our communities connected. ACS plays an integral role in the lives of
                                                                                                               cancer patients, their caregivers, and in primary care services that detect or prevent cancer while these individuals face COVID-19.

                                                                                                               Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                               Data released by Independent Sector shows that nonprofits with between 500 and 5,000 employees, key to scaling relief efforts across the
                                                                                                               nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                               helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                               loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                               Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                               steady streams of payment for services income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third
                                                                                                               largest employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital
                                                                                                               part of the economy.

                                                                                                               Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                               forgiveness in the next round of COVID-19 relief legislation.

                                                                                                               2. The Federal Reserve's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies
Staff Group - Main
Street Lending                                                                                American         Many in the Charitable Sector
Program - Nonprofit                                                                           Cancer Society
Organization          PIO (Email    6/22/2020                                gregg.haifley@   Cancer Action    The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
Facilities            from Web)     12:00:00 AM     Haifley     Gregg        cancer.org       Network          including ACS. Overall, this loan facility seems more applicable to for-profit entities, as well as nonprofit that sell services like educational

                                                                                                                  Page 146 of 300
                                                                                                       Main Street Lending Program
                                                                                                     Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address   Affiliation                                                                          Comment
                                                                                                            institutions and nonprofit hospitals, but not many critical charitable organizations. ACS in the past has generally received approximately 90% of
                                                                                                            revenues from donations.

                                                                                                            ACS raises money and receives donations from the public, foundations, corporations and others to fund our mission for patient services,
                                                                                                            prevention and research. ACS provides vital services for people trying to access health care for preventive or screening services, cancer
                                                                                                            patients, caregivers, and health partners trying to prevent or treat cancer. The charitable financial support of ACS and its mission demonstrates
                                                                                                            the trust that the public has in ACS, yet that trust as exhibited by individual donations is inadequate in the face of the 30% provision to qualify
                                                                                                            for support through the proposed lending facilities.

                                                                                                            Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                            instead, make Section 501 c(3) organizations eligible that otherwise meet the employee size standard.

                                                                                                            3. The Federal Reserve Needs to Make Loan Terms More Favorable for Charitable Organizations

                                                                                                            With the uncertainty of economic conditions, driven by the health concerns around COVID-19 for the foreseeable future, the recovery for
                                                                                                            businesses and nonprofits will be slow. For that reason, the terms of lending should fully accommodate the conditions around not only
                                                                                                            spending and employment, but also charitable giving. The U.S. Congressional Budget Office predicts recovery will likely take a full decade. A
                                                                                                            loan of five years will create a balloon payment for nonprofit borrowers at just the time they may be returning to increasing income. In addition,
                                                                                                            in a time that interest rates are at historic lows, this proposal has interest rates of LIBOR plus 300 basis points, significantly higher than that
                                                                                                            offered for Paycheck Protection Program Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%).

                                                                                                            Recommendation: The public charities participating should be given a longer term of years for repayment. In particular, the Expanded Loan
                                                                                                            Facility for larger loans should have options for a longer term-of-years reflective of the decade plus economic recovery. This approach would
                                                                                                            keep charities with nationwide service programs on stronger financial ground and allow the benefits to continue for critical communities in
                                                                                                            need. In addition, a range of lower interest rates based on size and length of the loan should be permissible in the absence of a Congressional
                                                                                                            mandate for forgivable loans.

                                                                                                            4. Additional Recommendations and Requests for Clarification

                                                                                                            The Federal Reserve should also clarify and reconsider the following issues:

                                                                                                             Endowment: Endowments are the least flexible source of funding for a charity, because the use has been restricted by donor intent. Lending
                                                                                                            based on the endowment criterium should be carefully tailored to the true liquidity of endowments in an evaluation between the lender and
                                                                                                            borrower.
                                                                                                             Collateral: Flexibility on collateral should be incorporated. Many organization's assets are already restricted to donor intent and mission
                                                                                                            services. As a result, they cannot be obligated for loans. It may be a point better left between a lender and borrower.
                                                                                                             Refinancing. There may be value in offering lending guarantees to refinance debts at lower rates to allow a charity to place itself on strong
                                                                                                            financial footing given the expected long-term economic conditions.

                                                                                                            ACS CAN appreciates this opportunity to comment on the nonprofit lending proposal and welcomes the opportunity to answer questions about
                                                                                                            these comments. For further information, please contact Gregg Haifley, Director, Federal Relations, ACS CAN at Gregg.Haifley@Cancer.org.

                                                                                                            Please reconsider the proposed eligibility requirement that non-profits have at least 50 employees to qualify for a Main Street Lending Program
                                                                                                            loan. A non-profit shouldn't be discriminated against based on employee size. The impact of a non-profit and the ability to pay back a loan
                                                                                                            is not aligned with the the employee size of the organization. The point of this program seems to be the ability for a PRE-covid successful small
                                                                                                            to mid-size business/non-profit that has been impacted by the pandemic to have access to a loan to help the company or non-profit navigate
                                                                                                            and rebound from the negative impact of the virus.
Staff Group - Main
Street Lending                                                                                              There are many small non-profits that have a tremendous impact on many people and will be put out of business because of the virus. Please
Program - Nonprofit                                                          Personal Email                 eliminate the employee minimum and make the program an option for these successful organizations knowing the loan will allow these smaller
Organization          PIO (Email    6/22/2020                                Address
                                                                                                            organizations a pathway to survival and less disruption for the direct impact they have on impacting the lives of many people.
Facilities            from Web)     12:00:00 AM     Ferguson    Chris



                                                                                                               Page 147 of 300
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                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address      Affiliation                                                                      Comment
                                                                                                               I am writing on behalf of Borrego Health, A Federally Qualified Health Center (FQHC) based in Southern California. FQHCs are community­
                                                                                                               based, non-profit organizations whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay.
                                                                                                               As explained below, we appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however,
                                                                                                               after analyzing the draft Term Sheet, we have determined that almost no FQHCs would qualify for these loans under the current eligibility
                                                                                                               requirements. Therefore, we are requesting that:
                                                                                                                the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                                FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                               the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                               Background on Borrego Health and the COVID-19 Pandemic
                                                                                                               Borrego Health has maintained operations at 40 clinic locations, including three pharmacies, during the COVID-19 pandemic to serve our most
                                                                                                               vulnerable patients throughout San Diego, Riverside and San Bernardino Counties. We have also expanded our telehealth, teledentistry and
                                                                                                               telephonic services to avoid unnecessary exposure for our patients, and today all of our providers are able to offer remote health services.
                                                                                                               Additionally, we have launched a COVID-19 hotline number, through which our patients and the population at large can have immediate
                                                                                                               access to a triage nurse and, if needed, to schedule an appointment for testing. We continue to partner with local businesses, fellow
                                                                                                               community health centers, and organizations to bring high-quality health services for the communities we serve, to the extent that we are able.
                                                                                                               As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
                                                                                                               19 pandemic since the beginning. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients. Our
                                                                                                               patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and 68% are racial and
                                                                                                               ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.
                                                                                                               Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                               income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                               curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                               providers, forcing them to close sites and lay off staff at the time when their services are most needed.
                                                                                                               While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                               pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                               individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                               FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.
                                                                                                               Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:
                                                                                                               Because of these financial needs, Borrego Health was relieved to learn that the Federal Reserve would soon start offering Main Street Loans
                                                                                                               to non-profits. However, after reviewing the proposed Terms Sheet and consulting with experts, we have concluded that almost no FQHCs
                                                                                                               would qualify under the proposed eligibility criteria.
                                                                                                               This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                               of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                                Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                               over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                                Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                               meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                               The most problematic financial parameters for FQHCs are:
                                                                                                                EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                                Days cash on hand at loan origination equal to or greater than 90 days
                                                                                                                Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
                                                                                                               origination is 65% or greater

                                                                                                               In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                               the following lending parameters for FQHCs loans as follows:
                                                                                                                EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                                Days cash on hand at loan origination equal to or greater than 30 days
Staff Group - Main
Street Lending                                                                                                  Eliminate the unrestricted cash to debt ratio requirement
Program - Nonprofit                                                                                             Lower the minimum employee requirement to 20.
Organization          PIO (Email    6/22/2020                                 vcoral@borreg
Facilities            from Web)     12:00:00 AM     Coral       Vitor         ohealth.org     Borrego Health   In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to

                                                                                                                  Page 148 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans
                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                     coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                     billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.
                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                     detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                     current needs of Federally Qualified Health Centers.




                                                                                                        Page 149 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                       Comment
                                                                                                              Comments for Main Street Loan Programs for Nonprofits
                                                                                                              Thank you for the opportunity to provide comments on the Main Street Loan Program for Nonprofits. BlueHub Loan Fund, Inc. (BlueHub) is a
                                                                                                              nonprofit Community Development Financial Institution (CDFI) that provides facility financing for Federally Qualified Health Centers (FQHCs),
                                                                                                              which are nonprofit organizations whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay.
                                                                                                              BlueHub is the lending affiliate of BlueHub Capital, whose mission is to help build healthy communities where low-income people live and work.

                                                                                                              Over the past ten years, BlueHub has provided over $40 million in financing in 18 loans to eight different FQHCs in the Northeast and New
                                                                                                              England. Our FQHC borrowers leveraged our debt to attract additional conventional capital for their facility projects. As a financing partner to
                                                                                                              these community-based nonprofit organizations, we are writing in support of the more than 1,400 Federally Qualified Health Centers across the
                                                                                                              country.

                                                                                                              We appreciate the Federal Reserve's intention to expand Main Street Loans to nonprofit organizations. However, after reviewing the draft
                                                                                                              Term Sheet, we believe that almost no FQHCs would qualify for these loans under the current eligibility requirements. Therefore, we request
                                                                                                              that:
                                                                                                               the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                               FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                              the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                              Background on FQHCs and the COVID-19 Pandemic
                                                                                                              As community-based, nonprofit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
                                                                                                              19 pandemic since the beginning. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients.
                                                                                                              FQHC patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and 68% are
                                                                                                              racial and ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.

                                                                                                              Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                              income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                              curtail many primary and preventive care visits. This combination has placed major financial strain on these nonprofit, community-based
                                                                                                              providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                              While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                              pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                              individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                              FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.

                                                                                                              Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:
                                                                                                              For these reasons, BlueHub was relieved to hear that the Small Business Administration will soon make Main Street Loans available to
                                                                                                              nonprofit organizations with 50 to 15,000 employees. However, after reviewing the Terms Sheet, we determined that almost no FQHCs would
                                                                                                              qualify under the proposed eligibility criteria.

                                                                                                              This conclusion is based on an analysis conducted by Capital Link, a nonprofit organization that receives funding from the Federal Department
                                                                                                              of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                               Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                              over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                              At present, because of the significant cash declines experienced by FQHCs as a result of COVID-19, far fewer than 13% would be able to
                                                                                                              meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                              The most problematic financial parameters for FQHCs are:
                                                                                                               EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%;
                                                                                                               Days cash on hand at loan origination equal to or greater than 90 days; and
Staff Group - Main
Street Lending                                                                                                 Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
Program - Nonprofit                                                                                           origination is 65% or greater.
Organization          PIO (Email    6/22/2020                                mnilles@blueh   BlueHub
Facilities            from Web)     12:00:00 AM     Nilles      Michael      ubcapital.org   Capital          To provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust the

                                                                                                                 Page 150 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                      Comment
                                                                                                     following lending parameters for FQHCs loans as follows:
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%;
                                                                                                      Days cash on hand at loan origination equal to or greater than 30 days;
                                                                                                      Eliminate the unrestricted cash to debt ratio requirement; and
                                                                                                      Lower the minimum employee requirement to 20.

                                                                                                     In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans
                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. We
                                                                                                     are part of a 25-member coalition of CDFIs who have joined together to promote access to capital for FQHCs. Together, members of the
                                                                                                     Lenders Coalition for Community Health Centers have collectively provided more than $2.1 billion in loans to FQHCs, with a default rate of less
                                                                                                     than 1/1 Oth of 1%.

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently constructed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%.

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request. We would welcome the opportunity to
                                                                                                     provide more detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be
                                                                                                     responsive to the current needs of Federally Qualified Health Centers.




                                                                                                        Page 151 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                       Comment




                                                                                                              The non-profit agency I help lead 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                              communities, 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 could start calling back
                                                                                                              to work our furloughed staff. We could continue to support children and families. We could avoid an erosion of our social service sector.
Staff Group - Main                                                                                            Necessarily, however, the eligibility criteria ratio of, "adjusted 2019 EBIDA to unrestricted 2019 operating revenue, greater than or equal
Street Lending                                                                               Thom Westfield   to 5%", excludes nearly every social service nonprofit known to us. This criteria is burdensome, unnecessary, and rewards nonprofit
Program - Nonprofit                                                                          Infant &     agencies that have chosen to retain a high earnings margin. To support nonprofits and economic recovery, this criteria must be removed.
Organization          PIO (Email    6/22/2020                                pkuzmeski@th    Toddler          Thank you for your thoughtful consideration.
Facilities            from Web)     12:00:00 AM     Kuzmeski    Patricia     omhcild.org     Services




                                                                                                                 Page 152 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment

                                                                                                              Comments to the Federal Reserve regarding the proposed Main Street Lending Program for nonprofit organizations - NONLF and NOELF

                                                                                                              Maryland Nonprofits, a statewide association of more than 1100 nonprofit organizations and institutions, provides the following
                                                                                                              recommendations to improve the proposed Nonprofit Organization Loan Programs:
                                                                                                              1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                              economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                              2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor, that alone would exclude
                                                                                                              the majority of 501(c)(3) entities from consideration.
                                                                                                              3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                              organization's 2019 revenues come from donations, as that would exclude many of the larger nonprofits for whom this relief is essential.
                                                                                                              4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                              on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                              requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                              5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                              allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                              needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                              operating budgets and capital funds for improvements.
                                                                                                              6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                              efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                              also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                              Program Flexibility Act should be extended to this loan program.
                                                                                                              7. Additional Questions Recommendations:
                                                                                                              o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                              include cash on hand?
                                                                                                              o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                              needed.
                                                                                                              o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
Staff Group - Main                                                                                            financial liquidity related to the impact of COVID-19.
Street Lending
Program - Nonprofit                                                                                           The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which Maryland
Organization          PIO (Email    6/22/2020                                hbogdan@mdn     Maryland         Nonprofits endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Bogdan      Henry        onprofit.org    Nonprofits




                                                                                                                 Page 153 of 300
                                                                                                        Main Street Lending Program
                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                       Comment
                                                                                                              June 22, 2020

                                                                                                              Board of Governors of the Federal Reserve Board

                                                                                                              Via Email
                                                                                                              Re: Comments on Main Street Lending Program to Provide Access to Credit for Nonprofit Organizations

                                                                                                              To Whom it May Concern at the Board of Governors of the Federal Reserve Board:

                                                                                                              Established more than 100 years ago, UJA-Federation of New York is one of the nation's largest local philanthropies. UJA identifies and
                                                                                                              meets the needs of New Yorkers of all backgrounds and Jews around the world, supporting hundreds of nonprofit organizations that serve
                                                                                                              those who are most vulnerable and others searching for programs and services. UJA is proud to partner with many of New York's human
                                                                                                              service organizations. These nonprofits provide essential services, such as shelter and residential programs, services for the elderly, access to
                                                                                                              food supports, home care and mental health care. These nonprofits are competitively selected to provide these services though contracts with
                                                                                                              State and Local governments.
                                                                                                              The Main Street Lending Program was established with the approval of the Treasury Secretary and with $75 billion in equity provided by the
                                                                                                              Treasury Department from the CARES Act. While the nonprofit loans, including the interest rate, deferral of principal and interest payments,
                                                                                                              and five-year term, are the same as for Main Street business loans, the borrower eligibility requirements for the proposed nonprofit facilities
                                                                                                              (defined as a tax-exempt organization under section 501(c)(3) or 501(c)(19) of the Internal Revenue Code) would be modified from the for-
                                                                                                              profit facilities to reflect the operational and accounting practices of the nonprofit sector.
                                                                                                              UJA welcomes the opportunity to comment and supports the Main Street Lending Program being extended to nonprofit organizations with the
                                                                                                              following comments:

                                                                                                              1) The interest rate of LIBOR+3 is the same interest rate as for-profit corporations. Not having a distinction in interest rates based on
                                                                                                              organization's corporate structure and mission holds human service nonprofit organizations to the same payment standards as
                                                                                                              businesses. The intention of Main Street is to infuse cash into organizations struggling due to COVID-19. Nonprofits that provide essential
                                                                                                              services are all the more financially challenged in the COVID era, and this interest rate does not reflect the missions, business structures or
                                                                                                              challenges that human service nonprofit organizations face.
                                                                                                              2) The Paycheck Protection Program was only available to organizations with 500 or fewer employees. Many New York based human service
                                                                                                              nonprofits have significantly more than 500 employees. In order to provide essential human service nonprofit organizations the same
                                                                                                              opportunities as their smaller peers, UJA proposes that Main Street create loan forgiveness (move from loan to grants) for organizations
                                                                                                              providing essential human services and utilizing Main Street as they were too large (more than 500 employees) to participate in Paycheck
                                                                                                              Protection.
                                                                                                              3) Main Street loans are issued by lenders' evaluation of borrower's "financial health". UJA encourages understanding of
                                                                                                              nonprofit accounting and fiscal pressures, particularly as State and local government budgets are dramatically shrinking. Nonprofit
                                                                                                              organizations have different revenue sources and accounting principles and should be guided by experts in nonprofit financial health
                                                                                                              evaluation.


                                                                                                              On behalf of UJA-Federation of New York, thank you for the opportunity to comment on the Main Street Lending Program proposal to provide
                                                                                                              access to credit for nonprofit organizations.

                                                                                                              Sincerely yours,
Staff Group - Main
Street Lending
Program - Nonprofit
Organization          PIO (Email    6/22/2020                                goldsteine@UJ   UJA-Federation   Eric S. Goldstein
Facilities            from Web)     12:00:00 AM     Goldstein   Eric         AFEDNY.org      of NY




                                                                                                                 Page 154 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name     Email Address      Affiliation                                                                      Comment

                                                                                                                Expanding access to Main Street Lending Program for non-profit organizations is welcome news and much appreciated. However limiting this
                                                                                                                access to organizations that are 501 c3 or 501 c19 is disappointing,. Many nonprofit organizations (in particular Professional Associations) have
                                                                                                                a 501 c6 tax exempt designation. Associations have been particularly hard hit financially by COVID-19 due to the cancelation of their in-person
                                                                                                                meetings. The in-person meetings and conferences are a major source of revenue for these nonprofit Associations and the lost revenue they
                                                                                                                are experiencing is creating tremendous financial hardship. While some are able to replicate the educational component of the meeting via a
Staff Group - Main                                                                             American         virtual platform, the lost revenue from vendor support cannot be replaced. I strongly urge you to consider making these Main Street loans
Street Lending                                                                                 Collge of        available to nonprofit organizations that have a 501 c6 tax status.
Program - Nonprofit                                                          Personal Email    Allergy.
Organization          PIO (Email    6/22/2020                                Address           Asthma, and      Your consideration of this recommendation is appreciated.
Facilities            from Web)     12:00:00 AM     Blaiss      Michael                        Immunlogy
                                                                                                                On behalf of the North Carolina Center for Nonprofits (the Center), I am writing to submit comments on the Federal Reserve's proposed
                                                                                                                Nonprofit Organization Loan programs - the Nonprofit Organization New Loan Facility (NONLF) and the Nonprofit Organization Extended Loan
                                                                                                                Facility (NOELF). The Center is a 501(c)(3) public charity with more than 1,400 nonprofit members serving all 100 counties of North Carolina.
                                                                                                                The Center has heard from hundreds of nonprofits in North Carolina that have lost revenue due to COVID-19 and are seeking access to capital
                                                                                                                to continue their operations.

                                                                                                                The Center appreciates the opportunity to submit comment to the Federal Reserve. This proposal appears to be aimed at organizations with a
                                                                                                                high percentage of their revenue coming from earned income rather than nonprofits with a larger reliance on donations from the public to
                                                                                                                support their missions. Indeed, many nonprofits pride themselves on offering their services at no charge. Recognizing that their business
                                                                                                                models are different, even if both types of charities are inherently organized around a public mission, many of the financial requirements
                                                                                                                included in this proposal simply are not applicable to organizations that rely on donations. With that in mind, the Center respectfully requests
                                                                                                                the Federal Reserve to address the concerns and proposed changes outlined below.

                                                                                                                1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                                Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                                nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                                In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                                meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                                Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                                steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits provide about 10% of
                                                                                                                private sector jobs in North Carolina, and many nonprofits hope to hire more workers as their organizations recover. America cannot afford to
                                                                                                                leave out such a vital part of the economy.

                                                                                                                Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                forgiveness in the next round of COVID-19 relief legislation. We hope that that Federal Reserve will work with Congress to make these loans
                                                                                                                forgivable for nonprofits.

                                                                                                                2. The Federal Reserve's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies
                                                                                                                Many in Charitable Sector
                                                                                                                The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities in
                                                                                                                North Carolina and elsewhere in the country. Overall, this loan facility seems more applicable to for-profit entities, as well as educational
                                                                                                                institutions and nonprofit hospitals, but not most charitable organizations.
Staff Group - Main
Street Lending                                                                                                  Recommendation: Eliminate the requirement that no more than 30% of an organization's 2019 revenues come from donations, and
Program - Nonprofit                                                          Personal Email    North Carolina   instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.
Organization          PIO (Email    6/22/2020                                Address           Center for
Facilities            from Web)     12:00:00 AM     Heinen      David                          Nonprofits       3. The Federal Reserve Needs to Make Loan Terms More Favorable to Charitable Organizations

                                                                                                                   Page 155 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for-profit businesses.

                                                                                                     Nonprofit organizations typically provide services with low-profit margins and many provide services below cost. It is important to note that the
                                                                                                     vast majority of overall funding for social service nonprofits comes from government grants contracts, recognizing the key role such
                                                                                                     organizations play in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing
                                                                                                     contracted work, which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work
                                                                                                     creates cash-flow challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the five-year amortization were extended to seven years, this could lessen the balloon payment.
                                                                                                     We request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the NONLF and the NOELF, one of the eligibility criteria for borrowers is that they
                                                                                                     must have "a ratio of adjusted 2019 earnings before interest, depreciation, and amortization ("EBIDA") to unrestricted 2019
                                                                                                     operating revenue, greater than or equal to 5%." (#6) In the context of nonprofit operations, this threshold is too high and would make
                                                                                                     many, if not most, nonprofits ineligible based on these criteria alone, which seems written more in the context of for-profit businesses as
                                                                                                     opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and

                                                                                                        Page 156 of 300
                                                                                                       Main Street Lending Program
                                                                                                     Nonprofit Organizations Comments

   Event Title /
   Description     Ticket Type   Received Date   Last Name   First Name    Email Address      Affiliation                                                                       Comment
                                                                                                            recommend the following:

                                                                                                            Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                            the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                            fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                            would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                            Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                            We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                            at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                            the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                            retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                            Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                            not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                            cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                            6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                            The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                            Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                            than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                            support.

                                                                                                            Many of the nonprofits in our network are on the frontlines of this pandemic, working with fewer than 50 employees to address immediate and
                                                                                                            growing needs. These vital organizations would be arbitrarily excluded from important loan program.

                                                                                                            Recommendation: The 50-employee floor should be removed.

                                                                                                            7. Additional Recommendations and Requests for Clarification
                                                                                                            The Center respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                             Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                            cash on hand?
                                                                                                             Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                            collateral is needed.
                                                                                                             Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                            until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                            credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                            Thank you for your consideration of these concerns.



                                                                                                            Thank you for looking to expand the Main Street Lending Program to non-profits. Not only do they employ many people across the United
                                                                          Personal Email                    States, they also solve social problems that are expensive for government entities to try to resolve. As a consultant to non-profits, I know that
                                                                          Address                           there are many doing good work that are below your staffing threshold that could use support at lower dollar amounts. My request is that you
Coronavirus        PIO (Email    6/22/2020                                                 The Non-Profit   also expand support to non-profits at this level.
(COVID-19)         from Web)     12:00:00 AM     Finlayson   Elizabeth                     Coach




                                                                                                               Page 157 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                       Comment
                                                                                                                The Council of Michigan Foundations (CMF) respectfully submits the following comments to the Federal Reserve System in response to
                                                                                                                "a proposal to expand its Main Street Lending Program to provide access to credit for nonprofit organizations,Xquot; as published in the
                                                                                                                Federal Reserve press release on June 15, 2020. As you are exploring ways to expand the program and provide access to credit for nonprofit
                                                                                                                organizations, we ask that you include the following provisions in your proposal:

                                                                                                                Apply the same NO minimum number of employees for for-profits to nonprofits
                                                                                                                Make loans forgivable for nonprofits
                                                                                                                Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations

                                                                                                                CMF members have been working around the clock to support nonprofits serving on the frontlines of the COVID-19 pandemic to ensure the
                                                                                                                public's safety, and leading recovery efforts. Michigan's charitable sector is an economic engine, working yet starved of resources,
                                                                                                                as they employ nearly 470,000 people who provide critical services and economic benefit across our state and leverage more than one million
                                                                                                                volunteers. The pandemic has been highly disruptive to many nonprofits of all sizes deemed as essential businesses- requiring that they
                                                                                                                continue services while revenues are uncertain. The economic injury is particularly acute for smaller nonprofits often led by and serving
                                                                                                                communities of color. These communities have been disproportionately impacted by the COVID-19 pandemic. According to the Bureau of
                                                                                                                 Labor Statistics research data on employment and wages for the nonprofit sector, a majority of nonprofit firms have 9 or fewer employees, with
                                                                                                                over 80 percent of nonprofits having 49 employees or fewer. Nonprofits with fewer than 50 employees should be eligible for Main Street loans
                                                                                                                just as their small business counterparts of equal size are eligible.

                                                                                                                As Federal Reserve Chair Powell indicated, "Nonprofit organizations are critical parts of our economy, employing millions of people,
                                                                                                                providing essential services to communities, and supporting innovation and the development of a highly skilled workforce," now more
                                                                                                                than ever they need your support. Loan forgiveness has been central to the sustainability of many of our frontline community-based
                                                                                                                organizations.

                                                                                                                Finally, revenue from direct services is not the way that most nonprofits receive funding. The Federal Reserve's proposal to limit loans to
                                                                                                                nonprofits with less than 30 percent of revenue from donations disqualify many nonprofits who receive donations and funding from the public,
                                                                                                                corporations and foundations like CMF members. Without appropriate federal assistance, many organizations on which Americans rely on are
                                                                                                                not likely to survive.

                                                                                                                In order for charitable nonprofits and the communities they serve to fully benefit from the program, adjustments must be made to ensure
Staff Group - Main                                                                                              nonprofits with fewer than 50 employees are eligible, loan forgiveness provisions are included, and Eliminate the requirement that no more
Street Lending                                                                                                  than 30 percent of an organization's 2019 revenues come from donations.
Program - Nonprofit                                                                            Council of
Organization          PIO (Email    6/22/2020                                rbell@michigan    Michigan         Thank you for your consideration and as always, please let us know if you have any questions.
Facilities            from Web)     12:00:00 AM     Caldwell    Kyle         foundations.org   Foundations
                                                                                                                Our non-profit agency 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                                communities, 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 could start calling back
                                                                                                                to work our furloughed staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists and administrators.
                                                                                                                We could continue to support children and families. We could avoid an erosion of our social service sector. We need immediate action. Non­
Coronavirus           PIO (Email    6/22/2020                                mpeirent@tho      Thom             profit agencies of our size must be included in the Main Street Lending Program and any subsequent mid-size loan programs.
(COVID-19)            from Web)     12:00:00 AM     Peirent     Marie        mchild.org        Springfield




                                                                                                                   Page 158 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment



                                                                                                               Nonprofit organizations are often part of an affiliated group that can include different types of nonprofit organizations as well as for-profit
Staff Group - Main                                                                                             entities. Assuming a for-profit member meets the MSLP requirements for the small and medium-sized business program and is controlled by a
Street Lending                                                                                                 nonprofit that was eligible for the nonprofit program, would both be able to apply for a loan and to what limit? Does one member receiving a
Program - Nonprofit                                                                                            loan in one facility preclude the other from obtaining a loan in the other? How would financial information be provided where this group had
Organization          PIO (Email    6/22/2020                                junderwood@b                      audited financial statements only reporting consolidated totals and not separate amounts for each nonprofit and for-profit entity.
Facilities            from Web)     12:00:00 AM     Underwood   Joyce        do.com            BDO USA, LLP
                                                                                                               The Jewish Federations of North America ("JFNA") is the umbrella organization of 145 Jewish federations across North America as
                                                                                                               well as over 300 "network communities." In their individual communities, the Jewish Federations (collectively the "Federation
                                                                                                               system") are the fundraising, central planning, and grant allocation coordinating body for any extensive network of Jewish health, social
                                                                                                               service, and educational agencies and organizations. Many of the employees of the Federation system and those of this network of agencies
                                                                                                               are on the frontline responding to the needs of the most vulnerable during this pandemic. We partner with government agencies at all levels to
                                                                                                               deliver life-saving nutrition, health care, and basic services each and every day.
                                                                                                               JFNA appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan Facilities under the Main
                                                                                                               Street Lending Program. These facilities can be a vital source of financing for so-called "mid-sized" nonprofits responding to the
                                                                                                               pandemic.

                                                                                                               1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                               While it is a welcome development to see the Federal Reserve making its Main Street lending program available to some nonprofits, this
                                                                                                               assistance still falls short of what is most needed by nonprofit organizations - a provision that makes these loans forgivable. All nonprofit
                                                                                                               organizations face funding challenges so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                               steady streams of commercial income and have little capacity for loan and interest repayment. Congress must ensure that mid-sized nonprofits
                                                                                                               have access to loan forgiveness.

                                                                                                               In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. They
                                                                                                               are straining to meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our
                                                                                                               communities connected. Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core
                                                                                                               supports. Furthermore, nonprofits are the third largest employment sector and many hope to hire more workers as their organizations recover.
                                                                                                               America cannot afford to leave out such a vital part of the economy.

                                                                                                               Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                               forgiveness, in the next round of COVID-19 relief legislation

                                                                                                               2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                               Charitable Sector
                                                                                                               The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                               including many social service and health care nonprofits affiliated with the Federation system. Overall, this loan facility seems more applicable
                                                                                                               to for-profit entities, as well as educational institutions and nonprofit hospitals, but not most charitable organizations..

                                                                                                               Charitable organizations play a fundamental role in strengthening civil society. Our organizations provide vital services for the most vulnerable
                                                                                                               throughout the nation. Support from donors is based on public recognition of the importance of our mission and continues to generate public
                                                                                                               trust.

                                                                                                               We also question why the Federal Reserve would chose to impose a requirement that serves to contradict the current Internal Revenue
                                                                                                               Service standard which sets the minimum of "public support" for public charity status at 33 1/3%. The public support test is a long­
                                                                                                               standing minimum for an organization to qualify for preferable tax status.
                                                                                                               Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
Staff Group - Main                                                                                             instead allow 501(c)(3) organizations that meet the "public charity" status to qualify for the Main Street program.
Street Lending
Program - Nonprofit                                                          steven.woolf@j                    3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
Organization          PIO (Email    6/22/2020                                ewishfederation                   The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
Facilities            from Web)     12:00:00 AM     Woolf       Steven       s.org             JFNA            Facilities available to for-profit businesses.

                                                                                                                  Page 159 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment

                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work creates cash-flow
                                                                                                     challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     The Nonprofit Organization loan facilities would require borrowers to maintain "a ratio of adjusted 2019 earnings before interest,
                                                                                                     depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." This threshold
                                                                                                     is too high and would make many, if not most, nonprofits ineligible and appears to be more appropriate for for-profit businesses.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and because surplus, if any, are normally redirected toward mission-based programs.. Moreover, at times a nonprofit may
                                                                                                     have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of instability.

                                                                                                     Furthermore, the requirement contemplates that the ratio should calculate operating revenue as unrestricted operating revenue, excluding
                                                                                                     funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and contracts built into
                                                                                                     their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and

                                                                                                        Page 160 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                       Comment
                                                                                                     recommend the following:

                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                     Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                     support.

                                                                                                     Recommendation: The 50-employee floor should be removed.

                                                                                                     JFNA again thanks the Federal Reserve for making its Main Street lending program available to nonprofit. However, we believe that in order for
                                                                                                     the program to be successful and meet the important goal of providing needed financial assistance to operating "mid-size"
                                                                                                     nonprofits, the recommendations listed above need to be incorporated into the program.
                                                                                                     Please feel free to contact Steven Woolf, JFNA senior tax policy counsel, at steven.woolf@jewishfederations.org or at 301-767-7073.




                                                                                                        Page 161 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name   Email Address        Affiliation                                                                       Comment
                                                                                                                  The Council of Michigan Foundations (CMF) respectfully submits the following comments to the Federal Reserve System in response to
                                                                                                                  "a proposal to expand its Main Street Lending Program to provide access to credit for nonprofit organizations,Xquot; as published in the
                                                                                                                  Federal Reserve press release on June 15, 2020. As you are exploring ways to expand the program and provide access to credit for nonprofit
                                                                                                                  organizations, we ask that you include the following provisions in your proposal:

                                                                                                                  Apply the same NO minimum number of employees for for-profits to nonprofits
                                                                                                                  Make loans forgivable for nonprofits
                                                                                                                  Eliminate the requirement that no more than 30 percent of an organizationX#39;s 2019 revenues come from donations

                                                                                                                  CMF members have been working around the clock to support nonprofits serving on the frontlines of the COVID-19 pandemic to ensure the
                                                                                                                  publicX#39;s safety, and leading recovery efforts. MichiganX#39;s charitable sector is an economic engine, working yet starved of resources,
                                                                                                                  as they employ nearly 470,000 people who provide critical services and economic benefit across our state and leverage more than one million
                                                                                                                  volunteers. The pandemic has been highly disruptive to many nonprofits of all sizes deemed as essential businesses- requiring that they
                                                                                                                  continue services while revenues are uncertain. The economic injury is particularly acute for smaller nonprofits often led by and serving
                                                                                                                  communities of color. These communities have been disproportionately impacted by the COVID-19 pandemic. According to the Bureau of
                                                                                                                   Labor Statistics research data on employment and wages for the nonprofit sector, a majority of nonprofit firms have 9 or fewer employees, with
                                                                                                                  over 80 percent of nonprofits having 49 employees or fewer. Nonprofits with fewer than 50 employees should be eligible for Main Street loans
                                                                                                                  just as their small business counterparts of equal size are eligible.

                                                                                                                  As Federal Reserve Chair Powell indicated, Xquot;Nonprofit organizations are critical parts of our economy, employing millions of people,
                                                                                                                  providing essential services to communities, and supporting innovation and the development of a highly skilled workforce,Xquot; now more
                                                                                                                  than ever they need your support. Loan forgiveness has been central to the sustainability of many of our frontline community-based
                                                                                                                  organizations.

                                                                                                                  Finally, revenue from direct services is not the way that most nonprofits receive funding. The Federal ReserveX#39;s proposal to limit loans to
                                                                                                                  nonprofits with less than 30 percent of revenue from donations disqualify many nonprofits who receive donations and funding from the public,
                                                                                                                  corporations and foundations like CMF members. Without appropriate federal assistance, many organizations on which Americans rely on are
                                                                                                                  not likely to survive.

                                                                                                                  In order for charitable nonprofits and the communities they serve to fully benefit from the program, adjustments must be made to ensure
Staff Group - Main                                                                                                nonprofits with fewer than 50 employees are eligible, loan forgiveness provisions are included, and Eliminate the requirement that no more
Street Lending                                                                                                    than 30 percent of an organizationX#39;s 2019 revenues come from donations.
Program - Nonprofit                                                                              Council of
Organization          PIO (Email    6/22/2020                                  rbell@michigan    Michigan         Thank you for your consideration and as always, please let us know if you have any questions.
Facilities            from Web)     12:00:00 AM     Caldwell     Kyle          foundations.org   Foundations




                                                                                                                  First thank you for being open enough to create a space for us to give insight. With everything that has happened this year so many non profit
                                                                                                                  organizations have not been able to complete any of the fundraising requirements that continue to let us operate. For my organization we need
Staff Group - Main                                                                                                to meet our federal match and because of Covid-19 we have worried about our ability to do just that. But there is still basic maintenance and
Street Lending                                                                                                    operations as well as staffing. What you are proposing would impact the midsize to larger non profits who have more employees than we do
Program - Nonprofit                                                                                               but I would hope that at some point in the future the smaller companies with less than 50 employees would also be considered. We provide
Organization          PIO (Email    6/22/2020                                  js@myplaceger     My Place         permanent supportive housing with an annual operating budget of $250,000 and every little bit helps us to keep our doors open.
Facilities            from Web)     12:00:00 AM     Williamson   Jeff          mantown.org       Germantown

                                                                                                                  My note today is about the loan program for non-profits to help in these unprecendted times. This program carries an employee minimum
                                                                                                                  which is unnecessary, unfair, and irelevant. I would like to make the point that a 501-c-3 is a 501-c-3. They should not be discriminated against
                                                                                                                  based on employee size. The impact of a non-profit and the ability to pay back a loan is not aligned with the the employee size of the
Staff Group - Main                                                                                                organization. The point of this program seems to be the ability for a PRE-covid successful small to mid-size business/non-profit that has been
Street Lending                                                                                   National         impacted by the pandemic to have access to a loan to help the company or non-profit navigate and rebound from the negative impact of the
Program - Nonprofit                                                            julie.staggs@b    Society of       virus.
Organization          PIO (Email    6/22/2020                                  eyondtheorytop    Collegiate
Facilities            from Web)     12:00:00 AM     Staggs       Julie         ractice.com       Scholars         There are many small non-profits that have a tremendous impact on many people and will be put out of business because of the virus. Please
                                                                                                                     Page 162 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                       Comment
                                                                                                                eliminate the employee minimum and make the program an option for these successful organizations knowing the loan will allow these smaller
                                                                                                                organizations a pathway to survival and less disruption for the direct impact they have on impacting the lives of many people.




                                                                                                                The Los Angeles Philharmonic Association (LA Phil) appreciates the opportunity to submit comment to the Federal Reserve about the
                                                                                                                Nonprofit Organization Loan Facilities. This proposal is aimed more at transactional nonprofits such as hospitals and institutions of higher ed
                                                                                                                than at nonprofits like the LA Phil that have a larger reliance on donations from the public to support their missions. Indeed, many nonprofits
                                                                                                                pride themselves on offering their services at no charge or at low cost. Recognizing that their business models are different, even if both types
                                                                                                                of charities are inherently organized around a public mission, many of the financial requirements included in this proposal simply are not
                                                                                                                applicable to organizations that rely on donations. With that in mind, the LA Phil respectfully requests the Federal Reserve to address the
                                                                                                                concerns and proposed changes outlined below.

                                                                                                                Short list of comments:
                                                                                                                a. It is not clear that the limitation on contributions is gross or net of fundraising expenses. Limiting contributions to 30% on a gross basis will
                                                                                                                exclude many worthy non-profits, which tend to have more significant levels of contributed revenue.
                                                                                                                b. Since the very concept of non-profit means that 501 c3 organizations often work on a balanced financial operating basis, the requirement that
                                                                                                                the qualifying organizations must have an EBIDA of at least 5% is prohibitive. There should be a measure based on the availability of
                                                                                                                underlying assets or EBIDA to evaluate the financial strength of the applicant non-profit.
                                                                                                                c. The 90-day liquidity measure, again, will be prohibitive for many worthy qualifying organizations. Per your guidelines draft, the eligible
                                                                                                                borrower "has a ratio (expressed as a number of days) of (i) liquid assets at the time of loan origination to (ii) average daily expenses
                                                                                                                over the previous year, equal to or greater than 90 days." Using the previous year's expenses and the current year's liquid
                                                                                                                assets is setting a measure which uses highly impacted liquidity against a previous year's higher expenses, making for an "apples
                                                                                                                to oranges" comparison, an unfairly high hurdle rate.
                                                                                                                More comments:
                                                                                                                1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                                Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                                nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                                In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                though we face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, we are straining to meet
                                                                                                                increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                Furthermore, nonprofits will play an integral role as our nation recovers - providing childcare, job training, and other core supports.

                                                                                                                Nonprofits are the third largest employment sector and many hope to hire more workers as their organizations recover. America cannot afford
                                                                                                                to leave out such a vital part of the economy.

                                                                                                                Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                forgiveness, in the next round of COVID-19 relief legislation

                                                                                                                2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                                Charitable Sector
                                                                                                                The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                                including The LA Phil. Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and nonprofit
Staff Group - Main                                                                                              hospitals, but not most charitable organizations.
Street Lending
Program - Nonprofit                                                                            Los Angeles      Charitable organizations play a fundamental role in strengthening civil society. Our organizations provide vital services for, and in some circles,
Organization          PIO (Email    6/22/2020                                lboorstin@laphi   Philharmonic     the nonprofit arts and culture community is considered a 'second responder' - there to assist in community wellbeing, to support
Facilities            from Web)     12:00:00 AM     Boorstin    Leni         l.org             Association      mental health, and reestablish community cohesion. [
                                                                                                                   Page 163 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment

                                                                                                     Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                     instead make 501 c(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                     3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for-profit businesses.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit may
                                                                                                     have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed regarding both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                     The description of "Retaining Employees" in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:


                                                                                                        Page 164 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                       Comment
                                                                                                     Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier "mission-based" before "reasonable efforts."

                                                                                                     Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.
                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.


                                                                                                     6. Additional Recommendations and Requests for Clarification
                                                                                                     [ORGANIZATION] respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                      Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                     cash on hand?
                                                                                                      Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                     collateral is needed.
                                                                                                      Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                     until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                     credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19

                                                                                                     As a nonprofit performing arts organization that provides a number of its services free and at low cost (as well as generating revenues from
                                                                                                     concert performances and contributions), we find it an issue of fairness: our smaller organizational colleagues have been eligible for PPP! And
                                                                                                     we have not, no have we been eligible for other federal relief. We rely on your thoughtful leadership and understanding of the value of the
                                                                                                     nonprofit sector to help the US rebound and thrive. While we have been unable to hold a Hollywood Bowl season, thereby cutting our earned
                                                                                                     revenues by at least 50% this year, we have maintained our connection to more than 1000 students and their families through our free learning
                                                                                                     program: Youth Orchestra LA (YOLA). While we cannot perform live and provide the community healing and solace and joy in shared
                                                                                                     experiences that we seek, we are offering social media, radio and television performances, many from our archives. We rely on you to help us
                                                                                                     to continue to serve our community. We are still in mourning that we could not hire our 900 seasonal employees this summer, and do what we
                                                                                                     do best to contribute to our community's well being.

                                                                                                     Thank you for your careful consideration of these issues.




                                                                                                        Page 165 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                            Comment
                                                                                                              The Community Health Care Association of New York State (CHCANYS) is grateful for the opportunity to provide comments on the expansion
                                                                                                              of Main Street Loans to nonprofit organizations. CHCANYS represents all of New York's federally qualified health centers (FQHCs), also
                                                                                                              known as community health centers. FQHCs are community-based, non-profit organizations whose goal is to provide affordable, accessible
                                                                                                              health care for all individuals, regardless of their ability to pay. As explained below, we appreciate the Federal Reserve's intention to
                                                                                                              expand Main Street Loans to non-profit organizations; however, after analyzing the draft Term Sheet, we have determined that almost no
                                                                                                              FQHCs would qualify for these loans under the current eligibility requirements. Therefore, we are requesting that:
                                                                                                               the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                               FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                              the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                              As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been critical responders to the
                                                                                                              COVID-19 pandemic. With more than 800 care delivery sites in NYS, NY FQHCs provide care for nearly 2.4 million patients. Our patients have
                                                                                                              been disproportionately impacted by the pandemic, as 89% of them are low-income, 16% are uninsured, and 73% are people of color, many of
                                                                                                              whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.

                                                                                                              Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                              income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                              curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                              providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                              In response to National and State stay at home orders in March, NYS FQHCs saw dramatic decreases in their visit volume. Across the State,
                                                                                                              visit volume decreased by an average of 56% between March 14 and March 28. CHCANYS projected that due to this rapid decrease, the
                                                                                                              State's health centers were collectively losing $30M per week in March and the beginning weeks of April. Many health centers saw no
                                                                                                              other option than to temporarily close sites, both to diminish financial losses and to mitigate community spread of COVID-19, per social
                                                                                                              distancing requirements. However, patients continue to require primary care services, regardless of social distancing requirements or stay at
                                                                                                              home orders. As such, CHCs rapidly pivoted to providing remote care, including investing in and standing up programs to deliver services via
                                                                                                              audio-visual telehealth and the telephone. Additionally, many CHCs have identified the need for additional capital improvements due to
                                                                                                              COVID-19 to ensure the safety of their patients and staff at their brick and mortar locations. Projects like expanding parking lots, creating
                                                                                                              separate and distinct screening and testing locations, renovations to HVAC systems, or remodeled waiting rooms are needed for CHCs to
                                                                                                              mitigate the spread of COVID-19 and prevent a second outbreak. On average, NYS CHCs report the need for about $575,000 in capital
                                                                                                              projects as a result of COVID-19.

                                                                                                              While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                              pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                              individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                              FQHCs with over 500 staff - which in total care for about 9 million patients across the nation - are ineligible for Paycheck Protection Loans
                                                                                                              because of their size.

                                                                                                              Because of these financial needs, CHCANYS was relieved to learn that the Federal Reserve would soon start offering Main Street Loans to
                                                                                                              non-profits. However, after reviewing the proposed Terms Sheet and consulting with experts, we have concluded that almost no FQHCs would
                                                                                                              qualify under the proposed eligibility criteria.

                                                                                                              This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                              of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                               Prior to the pandemic, only 13% of health centers nationwide would have met the combined criteria. This includes less than one in five of the
                                                                                                              FQHCs with over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                               Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                              meet the DCOH and Cash/Debt ratio at loan origination.
Staff Group - Main                                                                           Community
Street Lending                                                                               Health Care      The most problematic financial parameters for FQHCs are:
Program - Nonprofit                                                                          Association of    EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
Organization          PIO (Email    6/22/2020                                mmongeon@c      New York State    Days cash on hand at loan origination equal to or greater than 90 days
Facilities            from Web)     12:00:00 AM     Mongeon     Marie        hcanys.org      (CHCANYS)         Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at

                                                                                                                 Page 166 of 300
                                                                                                              Main Street Lending Program
                                                                                                            Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address           Affiliation                                                                        Comment
                                                                                                                   origination is 65% or greater

                                                                                                                   In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust
                                                                                                                   the following lending parameters for FQHCs loans as follows:
                                                                                                                    EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                                    Days cash on hand at loan origination equal to or greater than 30 days
                                                                                                                    Eliminate the unrestricted cash to debt ratio requirement
                                                                                                                    Lower the minimum employee requirement to 20.

                                                                                                                   In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                                   the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                                   authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                                   could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                                   providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                                   support" be revised to read "direct support."

                                                                                                                   Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                                   financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. A
                                                                                                                   coalition of 25 CDFIs who are members of the Lenders Coalition for Community Health Centers have collectively provided more than $2.1
                                                                                                                   billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                                   Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                                   directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                                   the Main Street Loan Program to:
                                                                                                                    Allow CDFIs to participate as lenders in the program; and
                                                                                                                    Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                                   at LIBOR +3%

                                                                                                                   We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                                   detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                                   current needs of Federally Qualified Health Centers.




                                                                                                                   Our company is a non-profit business training organization and our primary source of revenue has been live, in-person public seminars. Our
                                                                                                                   seminars focus on professional training and skills development to assist individuals and corporate customers to advance in personal and/or
                                                                                                                   professional areas. Historically, we have sacrificed margins by keeping our prices low and promoting to as many potential customers as
                                                                                                                   possible via direct mail, which is our main method of obtaining registrations to our seminars. We could increase our margin by raising prices
                                                                                                                   and reducing our direct mail promotions, however, it would result in significantly fewer individuals benefiting from our training. Our beneficiaries
                                                                                                                   have always understood and supported our purpose.

Staff Group - Main                                                                                                 Therefore, we feel the 5% EBIDA borrower eligibility requirement is unfair to non-profits. If we were classified as a for-profit organization, we
Street Lending                                                                                                     would meet the eligibility requirements to obtain a loan under the program. As long as we can demonstrate the ability to operate without a loss,
Program - Nonprofit                                                                                                we believe non-profit organizations should receive the same consideration as a for-profit organization. EBIDA margins are rarely the focal point
Organization          PIO (Email    6/22/2020                                pfields@pryor.c                       of most non-profit organizations.
Facilities            from Web)     12:00:00 AM     Fields      Paula        om                PLI




                                                                                                                      Page 167 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment
                                                                                                               The non-profit agency I help lead 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                               communities, 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.

Staff Group - Main                                                                                             With access to favorable lending terms and with the same stimulus funding that was offered to smaller non-profits, we could start calling back
Street Lending                                                                                                 to work our furloughed staff of nurses, therapists, speech-language pathologists, educators, and other skilled specialists and administrators.
Program - Nonprofit                                                                           Thom Child       We could continue to support children and families. We could avoid an erosion of our social service sector. We need immediate action. Non­
Organization          PIO (Email    6/22/2020                                iiemma@thomc     and Family       profit agencies of our size must be included in the Main Street Lending Program and any subsequent mid-size loan programs.
Facilities            from Web)     12:00:00 AM     lemma       Isabella     hild.org         Services




                                                                                                               Good afternoon,

                                                                                                               Please see below a list of comments and suggestions collected from FFTA member agencies:

                                                                                                               Loan Forgiveness: for this to be truly impactful to Non-profits, the program should have loan forgiveness opportunities, similar to what the PPP
                                                                                                               allows.
                                                                                                               Cash on hand or Liquidity: While 90 days of Cash is a recommended industry standard, many non-profits have a hard time meeting this in
                                                                                                               more "normal" times, and most certainly will have a hard time meeting it now, as many have tapped into reserves to offset other
                                                                                                               financial challenges (such as inability to have fundraisers) during pandemic. 30-60 days is more realistic.
                                                                                                               Balloon Payment: Concern here is that 5 years down the road as loans balloon, agencies may still struggle with having excess cash for
                                                                                                               repayment. Consideration should be given to allowing renegotiating terms into the loan and/or extending payback period.
                                                                                                               EBIDA: Most all said this would be a deal breaker--they wouldn't be able to meet this, at this time.
                                                                                                               ?Some consensus built around average of 0% over 3 years..noting that a single-year target would exclude many and that good years/bad
                                                                                                               years happen, but they "hopefully" balance out over a group of years to still essentially breaking even across those years.
                                                                                                               30% limit on revenue from donations: Suggest removing this requirement, as it would eliminate a number of agencies from being eligible.

                                                                                                               Please feel free to contact me with any questions or follow up.
Staff Group - Main                                                                                             Regards
Street Lending                                                                                Family           Treva R. Johnson
Program - Nonprofit                                                                           Focused          FFTA
Organization          PIO (Email    6/22/2020                                Tjohnson@ffta.   Treatment        Public Policy Director
Facilities            from Web)     12:00:00 AM     Johnson     Treva        org              Association




                                                                                                                  Page 168 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                    Comment
                                                                                                              As a representative of the entire field of camp, American Camp Association (ACA) is appreciative of the current proposal to extend the Main
                                                                                                              Street Lending program to non-profits. While we have a number of suggestions that will maximize the intended benefit of this expansion, we
                                                                                                              are strongly in support of it.

                                                                                                              There are more than 15,000 camps in the United States who serve more than 26 million children each year. Research demonstrates that a
                                                                                                              camp experience is a critical educational and developmental experience for children, who gain important life skills, avoid summer learning loss,
                                                                                                              take a break from technology, and try new activities in an outdoor environment. In addition, camps are providing essential care and supervision
                                                                                                              for working parents during the summer months.

                                                                                                              The economic damage to the field of camp, and the resulting impact on the broader economy, as a result of the coronavirus has quickly
                                                                                                              reached staggering levels. ACA's emerging data indicates that over 70% of overnight camps are not operating core programs at all this
                                                                                                              summer. While closer to 70% to 80% of day camps are operating, they will do so within a compressed calendar, significantly reduced capacity
                                                                                                              and increased expenses related to safety protocols and requirements. Projections of the economic impact on the entire field of camp based on
                                                                                                              this information are as follows:
                                                                                                               Over $16 billion in lost revenue
                                                                                                               19.5 million youth will not be served
                                                                                                               Over 900,000 lost jobs
                                                                                                               Over $4.4 billion in lost wages
                                                                                                               Over $26 billion in lost economic impact to the broader economy

                                                                                                              Further, the camp industry is in a uniquely vulnerable position as the majority of camps receive 90% of their income from 7 to 10 weeks in the
                                                                                                              summer. If that revenue is lost, most camps will have to span 22 months without substantial revenue. Without industry-specific mechanisms for
                                                                                                              financial relief beyond the PPP program, many camps will permanently go out of businesses. This uniquely American industry is under
                                                                                                              existential threat.

                                                                                                              ACA supports the expansion of the Main Street Lending program as a potential vehicle to provide critical refiled to the camps most impacted by
                                                                                                              this crisis. In order for the camp industry to maximize the benefits of this change, ACA recommends the following changes in the proposed
                                                                                                              program:

                                                                                                               Most non-profit camps are small businesses. As such, many have fewer than 50 full time employees. In order for the majority of camps to
                                                                                                              have access to this program, one of the following adjustments should be incorporated:
                                                                                                              o Remove the minimum requirement for employees, as there is no strong logic for disallowing businesses with 1 to 49 employees
                                                                                                              o Allow for seasonal employees to be included in the total employee calculation
                                                                                                               Loan amounts are calculated on an average of quarterly earnings in 2019. As seasonal businesses, averaging quarterly revenue will
                                                                                                              significantly decrease the effective loan amounts available to camps. To maximize the loan amount available, providing a mechanism to
                                                                                                              calculate the appropriate loan amount for seasonal businesses will be critical (which could include allowing an average of the two highest
                                                                                                              revenue quarters or selecting the highest revenue quarter from 2019).
                                                                                                               The requirement that no more than 30% of revenue in 2019 can be through philanthropic donations will eliminate a section of camps who
                                                                                                              provide essential services to the most vulnerable participants in the country. Many of these specialized camps rely almost entirely on donations
                                                                                                              to support their operations. Removing this requirement for non-profits with annual operating revenue of under $3 million would allow them to
Staff Group - Main                                                                                            continue to provide experiences for these under-served communities, while limiting the potential abuse of this provision.
Street Lending
Program - Nonprofit                                                                          American         Thank you for the work you are doing to support the vitally important non-profit sector. These comments are intended to maximize the essential
Organization          PIO (Email    6/22/2020                                hdehart@acac    Camp             relief needed across the field of camp because of the devastating impact the coronavirus has had on their most important summer season.
Facilities            from Web)     12:00:00 AM     DeHart      Henry        amps.org        Association




                                                                                                                 Page 169 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address      Affiliation                                                                     Comment
                                                                                                                On behalf of the American Society of Travel Advisors (ASTA), a 501 (c)6 organization, thank you for the opportunity to comment on the Federal
                                                                                                                Reserve's proposal regarding Nonprofit Organization Facilities within the broader Main Street Lending Program.

                                                                                                                Rebranded in 2018 as the American Society of Travel Advisors, ASTA is the leading global advocate for travel advisors, the travel industry and
                                                                                                                the traveling public. Our 14,000-plus member companies represent 80 percent of all travel sold in the United States through the travel agency
                                                                                                                distribution channel. Together with hundreds of internationally-based members, ASTA's history of industry advocacy traces back to its
                                                                                                                founding in 1931 when it launched with the mission to facilitate the business of selling travel through effective representation, shared
                                                                                                                knowledge and the enhancement of professionalism.

                                                                                                                We appreciate that the Federal Reserve is considering expanding the Main Street Lending Program to include nonprofit trade associations,
                                                                                                                many of whose revenues have been devastated by the coronavirus (COVID-19) pandemic along with those of their member companies. This
                                                                                                                expansion is especially important given trade associations' exclusion (to date) from the centerpiece of the Coronavirus Aid, Relief, and
                                                                                                                Economic Security (CARES) Act (P.L. 116-136), the Paycheck Protection Program (PPP).

                                                                                                                We offer the following comments on the Federal Reserve's proposal on nonprofits:

                                                                                                                -Lower the employee threshold for eligibility from 50 to 25 employees, or lower. We know of no basis for establishing this cap at 50 employees,
                                                                                                                and at just above 25 can attest that the pandemic has devastated trade associations of all sizes.

                                                                                                                -Increase the loan terms from 5 to 10 years, with principal payments rising over years 3 to 10 incrementally, beginning with 5 percent principal
                                                                                                                payment. We believe that this change will reflect the anticipated long recovery period, especially in truly hard-hit industries like travel.

                                                                                                                -The provision regarding nonprofits not being able to receive both a PPP loan and a MSLP loan should include some flexibility given the push
                                                                                                                to include 501(c)6s in the PPP, which we support. If they PPP is broadened to include trade associations, those associations should have the
                                                                                                                option to pay back their MSLP loan and then apply for the PPP.

                                                                                                                Thank you for considering our views on this critical subject. I am happy to discuss our comments at any time.

                                                                                                                Eben Peck
Staff Group - Main                                                                                              Executive Vice President, Advocacy
Street Lending                                                                                                  American Society of Travel Advisors (ASTA)
Program - Nonprofit                                                                           American          675 N Washington St, Ste 490, Alexandria, VA 22314
Organization          PIO (Email    6/22/2020                                 epeck@asta.or   Society of        (W) 703.739.6842 | (C) 202.573.2914 | epeck@asta.org | asta.org
Facilities            from Web)     12:00:00 AM     Peck         Eben         g               Travel Advisors


Staff Group - Main                                                                                              COVID-19 has caused a severe financial hardship to our Clubs and 2020 is proving to be challenging. As a non-profit, many time when funding
Street Lending                                                                                Boys Samp;        is allocated for relief, we are not included. Our organization has gone from operating in the black to deciding who might have to be laid off in a
Program - Nonprofit                                                                           Girls Club Of     matter of a few months. This pandemic has impacted our financials at every turn whether it is donations from corporations and individuals,
Organization          PIO (Email    6/22/2020                                 kbarrientos@b   The Coastal       foundation grants, special event, or program revenue.
Facilities            from Web)     12:00:00 AM     Barrientos   Kimberly     gccb.org        Bend




                                                                                                                   Page 170 of 300
                                                                                                             Main Street Lending Program
                                                                                                           Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                        Comment
                                                                                                                  The National Multiple Sclerosis Society (Society) appreciates the opportunity to provide feedback on the proposed Main Street Lending
                                                                                                                  Program Nonprofit Organization New Loan Facility and Nonprofit Organization Expanded Loan Facility term sheets. We urge this proposal to
                                                                                                                  be re-examined, keeping in mind that charitable nonprofits have a different business model than transactional nonprofits, such as hospitals and
                                                                                                                  institutions of higher education.

                                                                                                                  Charitable nonprofits like the Society rely largely on donations from the public to support their missions. Given this, many of the financial
                                                                                                                  requirements included in the current proposal simply are not applicable to organizations that rely on charitable donations. As written, our
                                                                                                                  organization and many others would not be able to leverage the Main Street lending program for nonprofits. With this in mind, the Society
                                                                                                                  respectfully requests the Federal Reserve re-examine the proposal and address the concerns and proposed changes outlined below.

                                                                                                                  1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                                  Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While we appreciate the Federal Reserve making its Main
                                                                                                                  Street lending program available to some nonprofits, this assistance does not address what is most needed by nonprofit organizations - a
                                                                                                                  provision that makes these loans forgivable.

                                                                                                                  In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                                  though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                                  meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                                  Further, they will play an integral role as our nation recovers - providing childcare and job training, funding research and other core supports.

                                                                                                                  Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                                  Data released by Independent Sector (https : //independentsector.org/resource/covid19-survey/ ) shows that nonprofits with between 500 to
                                                                                                                  5,000 employees, who have been key to scaling relief efforts across the nation, have also been severely impacted by this health and economic
                                                                                                                  crisis. When asked "What types of additional assistance would be most helpful to your organization?" organizations overwhelmingly
                                                                                                                  (92% of responses) suggested government support in the form of forgivable loans.

                                                                                                                  Nonprofit organizations need support to continue to meet the needs of their communities. Many charitable organizations do not have steady
                                                                                                                  streams of commercial income and have little capacity for loan and interest repayment. Nonprofits are the third largest employment sector and
                                                                                                                  the fourth largest contributor for U.S. medical and health research. America cannot afford to leave out such a vital part of the economy.

                                                                                                                  Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                                  forgiveness in the next round of COVID-19 relief legislation.

                                                                                                                  2. The Federal Reserve Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                                  Charitable Sector
                                                                                                                  The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                                  including the National MS Society. Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and
                                                                                                                  nonprofit hospitals, but not most charitable organizations. The National MS Society received 97% from donations in 2019.

                                                                                                                  The Society fundraises and receives donations from the public, foundations, corporations and others to fund innovative research to stop
                                                                                                                  disease progression and restore function and provide services to help ensure that people with MS have what they need to live their best lives.
                                                                                                                  We do not receive any revenue through direct services. Charitable organizations are a fundamental partner to the federal government in
                                                                                                                  strengthening civil society.

                                                                                                                  Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                                  instead make 501 c(3) organizations that otherwise meet the employee size, eligible for the program.

                                                                                                                  3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                                  This draft proposal imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan Facilities available
Staff Group - Main
Street Lending                                                                                 National           to for-profit businesses.
Program - Nonprofit                                                                            Multiple
Organization          PIO (Email    6/22/2020                                Leslie.Ritter@n   Sclerosis          Nonprofits typically provide services with low-profit margins. Social service nonprofits specifically report an average aggregate margin of 1.5%.
Facilities            from Web)     12:00:00 AM     Ritter      Leslie       mss.org           Society            According to a recent report by Seachange Capital Partners (https : //www.issuelab.org/resources/36677/36677.pdf ), the median social

                                                                                                                     Page 171 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment
                                                                                                     services nonprofit has a margin of 1.0%, receives 3.6% of its revenue from philanthropy (including investment income), has total financial
                                                                                                     assets (including endowments and other assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves
                                                                                                     of less than one month of expenses. Less than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted
                                                                                                     standard for "financial strength" for nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this
                                                                                                     standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     nonprofits have a different finance structure than for-profit entities. Most social service nonprofit funding comes from government grants
                                                                                                     contracts, recognizing the key role such organizations play in serving the most vulnerable. Numerous studies confirm that government funding
                                                                                                     seldom covers the full cost of providing contracted work, which inhibits nonprofits from accumulating reserves through surpluses. In many
                                                                                                     instances, government grant/contract work creates cash-flow challenges since it is paid after the work has been completed and can be subject
                                                                                                     to significant delays in payment.

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.


                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We also recommend that the loan terms including interest rate and balloon payments be revisited and recommend the lowest permissible rate
                                                                                                     such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement to afford the
                                                                                                     opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We request that the
                                                                                                     borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the draft proposal, borrowers must have "a ratio of adjusted 2019 earnings before interest, depreciation, and amortization
                                                                                                     ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6) In the context of nonprofit operations,
                                                                                                     this threshold is too high and would render many, if not most, nonprofits ineligible for loans. Again, we believe this shows a fundamental
                                                                                                     misunderstanding of the business models of charitable nonprofits.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, as stated previously, nonprofits generally run
                                                                                                     on a small margin, both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover,
                                                                                                     a nonprofit may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an
                                                                                                     indication of instability. Additionally, for nonprofits that fund multi-year research projects, those grant commitments are viewed as a current
                                                                                                     liability on the organizational balance sheet and should be not viewed as detrimental to the overall financial health of the organization since
                                                                                                     these obligations are mission-related activities.

                                                                                                     Further, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Further clarification is also recommended on
                                                                                                     the calculation methodology within the context of nonprofit operating budgets, in regard to both restricted funding from grants in annual

                                                                                                        Page 172 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name    Email Address   Affiliation                                                                        Comment
                                                                                                              operating budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted
                                                                                                              revenues to remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                              5. Xquot; Reasonable Efforts" Regarding Employee Retention Require Further Clarification
                                                                                                              The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                              take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention (https :
                                                                                                              //www.councilofnonprofits.org/thought-leadership/nonprofits-remain-committed-restoring-maintaining-and-expanding-employment-the ), and
                                                                                                              recommend the following:

                                                                                                              Recommendations: XquotjReasonable effortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                              the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                              fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                              would be to add the qualifier Xquot;mission-basedXquot; before Xquotjreasonable efforts.Xquot;

                                                                                                              The terms Xquot;maintain its payrollXquot; and Xquot;retain its employeesXquot; are vague and need further refinement. We ask the Federal
                                                                                                              Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff at the same or
                                                                                                              increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at the same or
                                                                                                              increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee retention
                                                                                                              provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                              We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will not be penalized
                                                                                                              under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for cause, voluntarily
                                                                                                              resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.


                                                                                                              6. Additional Recommendations and Requests for Clarification
                                                                                                              The Society respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                               Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                              cash on hand?
                                                                                                               Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                              collateral is needed.
                                                                                                               Other Debts: The proposal requires that borrowers, Xquot;refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                              until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due.Xquot; We request that this exclude lines of
                                                                                                              credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                              The Society appreciates the opportunity to provide feedback on the proposed Main Street Lending Program Nonprofit Organization New Loan
                                                                                                              Facility and Nonprofit Organization Expanded Loan Facility term sheets. Nonprofits are fundamental partners to the federal government and
                                                                                                              other entities to ensure that the needs AmericaX#39;s most vulnerable populations are met. Please do not hesitate to contact us if our
                                                                                                              organization can provide context or details to further clarify our recommendations.

                                                                                                              I am writing regarding the current funding situation for ICF individuals in the State of Ohio and mainly on behalf of my brother who has been in
                                                                                                              a facility his whole life. Budgets are tight, but he and the other members of the ICF community can not survive or have any quality of life in a
                                                                                                              halfway house type setting. He requires constant care, supervision and monitoring of his prescription meds. That funding must remain in place
                                                                                                              for these individuals to survive. Some politicians feel the current funding levels can not be sustained for this class of american citizens. We as a
Staff Group - Main                                                                                            country must provide for our most vulnerable citizens through no fault of their own have these disabilities to live with. We need the Fed to step
Street Lending                                                                                                up and fill any economic funding gap to ensure these citizens are adequately cared for. On behalf of my brother and his peers, I implore the
Program - Nonprofit                                                            Personal Email                 Fed to do the due diligence and maintain adequate funding for all ICF citizens in the State of Ohio.
Organization          PIO (Email    6/22/2020                                  Address
                                                                                                              Thank you for your consideration and action on behalf off all these citizens.
Facilities            from Web)     12:00:00 AM     Stuhldreher   AF




                                                                                                                 Page 173 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                     Comment
                                                                                                              Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness

                                                                                                              We fully recognize that the Federal Reserve is not empowered to grant loan forgiveness. Nonetheless, we take this opportunity to call on
                                                                                                              Congress to pass legislation ensuring that mid-sized nonprofits have access to loan forgiveness through the Fed's proposed new loan
                                                                                                              facility.

                                                                                                              In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. They
                                                                                                              face many of the same economic challenges as other industries and are straining to meet increasing demands in our communities on the
                                                                                                              frontlines, caring for the sick, feeding families, and keeping our communities connected. Furthermore, they will play an integral role as our
                                                                                                              nation recovers - providing child care, job training, and other core needs.

                                                                                                              Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                              Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                              nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                              helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                              loans.

                                                                                                              Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                              steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                              employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                              the economy.

                                                                                                              The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in the
                                                                                                              Charitable Sector

                                                                                                              The 30% limit seems more aimed at hospitals and institutions of higher learning, rather than the overall nonprofit sector. Accordingly, this
                                                                                                              limitation will disqualify many nonprofits which badly need access to this loan facility.

                                                                                                              Therefore, we recommend elimination of this requirement that no more than 30% of an organization's 2019 revenues come from
                                                                                                              donations, and instead make 501 (c)3 organizations that otherwise meet the employee size requirement be eligible for the Fed's loan
                                                                                                              facility.

                                                                                                              The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations

                                                                                                              The draft Nonprofit Loan Facility imposes liquidity, asset, and reserve requirements that are not required in the Main Street New Loan Facilities
                                                                                                              available to for-profit businesses.

                                                                                                              According to a recent report by Seachange Capital Partners, less than 20% of large nonprofits have 6 months or more of operating reserves, a
                                                                                                              widely accepted standard for "financial

                                                                                                              strength" for nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                              Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners on the front lines
                                                                                                              of the COVID-19 crisis, we urge the Federal Reserve to modify its requirements to reflect the economic realities of nonprofit operations. In
                                                                                                              particular, reducing the liquidity requirement to 30 days cash on hand would be highly beneficial.

                                                                                                              We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                              in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                              Paycheck Protection Program ("PPP") Loans (1.0%).
Staff Group - Main
Street Lending
Program - Nonprofit                                                                                           The Ratio of Adjusted 2019 Earnings before EBIDA Should Be Revised
Organization          PIO (Email    6/22/2020                                mmicali@tnpa.   The Nonprofit
Facilities            from Web)     12:00:00 AM     Micali      Mark         org             Alliance         In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization

                                                                                                                 Page 174 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%.Xquot; In the
                                                                                                     context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on this criterion alone,
                                                                                                     which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Thus, we believe the 5% requirement should be eliminated. In addition, a statement of explanation of a deficit should be allowed, so that a
                                                                                                     negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation methodology -in the
                                                                                                     context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating budgets, as well as
                                                                                                     capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to remain in
                                                                                                     calculation to ease the restriction and not further restrict eligibility.

                                                                                                     "Reasonable Efforts" Regarding Employee Retention Require Further Clarification

                                                                                                     The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     -Xquot;Reasonable EffortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only the general
                                                                                                     economic environment in the community or communities in which the borrower operates, but also factors such as workforce, fundraising ability,
                                                                                                     revenue-generating activities, and overall demand for the services and programs the organization provides. One option would be to add the
                                                                                                     qualifier Xquot;mission-basedXquot; before Xquotjreasonable efforts.Xquot;

                                                                                                     -The terms Xquotjmaintain its payrollXquot; and Xquot;retain its employeesXquot; are vague and need further refinement. We ask the Federal
                                                                                                     Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff at the same or
                                                                                                     increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at the same or
                                                                                                     increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee retention
                                                                                                     provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     --We ask that the Federal Reserve state clearly that nonprofit borrowers will not be penalized under the employee retention provision for the
                                                                                                     decision of employees to decline offers of rehire, or for those who are fired for cause, voluntarily resign, or voluntarily request a reduced
                                                                                                     schedule during the time that the loan is outstanding.




                                                                                                        Page 175 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name    Email Address     Affiliation                                                                         Comment
                                                                                                              I am a donor and supporter of Ensemble Stage, a nonprofit arts organization in Banner Elk, NO. I appreciate the opportunity to submit
                                                                                                              comment to the Federal Reserve about the Nonprofit Organization Loan Facilities. This proposal is aimed more at transactional nonprofits such
                                                                                                              as hospitals and institutions of higher ed than at nonprofits like Ensemble Stage that have a larger reliance on donations from the public to
                                                                                                              support their missions. Indeed, many nonprofits pride themselves on offering their services at no charge. Recognizing that their business
                                                                                                              models are different, even if both types of charities are inherently organized around a public mission, many of the financial requirements
                                                                                                              included in this proposal simply are not applicable to organizations that rely on donations. With that in mind, I respectfully request the Federal
                                                                                                              Reserve to address the concerns and proposed changes outlined below.

                                                                                                              1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness

                                                                                                              Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                              forgiveness, in the next round of COVID-19 relief legislation

                                                                                                              2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                              Charitable Sector

                                                                                                              Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                              instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                              3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations

                                                                                                              Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                              partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                              possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                              example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                              We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                              in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                              Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                              imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                              with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                              balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                              Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                              permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                              to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                              request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                              4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised

                                                                                                              Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                              be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                              methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                              budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                              remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                              5. " Reasonable Efforts" Regarding Employee Retention Require Further Clarification

                                                                                                              Recommendation: "Reasonable efforts" should be interpreted in the totality of the circumstances, taking into consideration not only
Staff Group - Main
Street Lending                                                                                                the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
Program - Nonprofit                                                          Personal Email
                                                                                                              fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
Organization          PIO (Email    6/22/2020                                Address          Ensemble        would be to add the qualifier "mission-based" before "reasonable efforts."
Facilities            from Web)     12:00:00 AM     Marty       Paulette                      Stage

                                                                                                                 Page 176 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                          Comment
                                                                                                              Recommendation: The terms "maintain its payroll" and "retain its employees" are vague and need further refinement.
                                                                                                              We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                              at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                              the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                              retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                              Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                              not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                              cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                              6. Limitation of 50-Employee Minimum Should Be Removed

                                                                                                              Recommendation: The 50-employee floor should be removed.

                                                                                                              7. Additional Recommendations and Requests for Clarification
                                                                                                              I respectfully request the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                               Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                              cash on hand?
                                                                                                               Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                              collateral is needed.
                                                                                                               Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                              until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                              credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.




                                                                                                              The loan requirements include a minimum of 50 employees, but we strongly believe that threshold should be lowered or even removed. A lot of
                                                                                                              non-profits that require this funding have fewer than 50 employees.
Staff Group - Main                                                                                            The requirements also have a revenue cap that includes less than 30% sourced from donations. Donations technically include contribution
Street Lending                                                                                                revenue from individuals, as well as private and federal grant awards. The economic downfall as resulted in paused or cancelled funding from
Program - Nonprofit                                                          cmurphy@com     Compass          individual and institutional donors, which results in a need for loan funding for non-profits. Having a revenue requirement with a limitation
Organization          PIO (Email    6/22/2020                                passworkingca   Working          directly related to the economic crisis for which lending programs are needed makes no sense.
Facilities            from Web)     12:00:00 AM     Murphy      Crystal      pital.org       Capital, Inc.




                                                                                                                 Page 177 of 300
                                                                                                            Main Street Lending Program
                                                                                                          Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name    First Name   Email Address        Affiliation                                                                        Comment




                                                                                                                 Nonprofit New York, an association of 1,500 nonprofits in the downstate New York region, provides the following recommendations to improve
                                                                                                                 the proposed Nonprofit Organization Loan Programs:
                                                                                                                 1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                                 economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                                 2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor.
                                                                                                                 3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                                 organization's 2019 revenues come from donations.
                                                                                                                 4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                                 on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                                 requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                                 5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                                 allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                                 needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                                 operating budgets and capital funds for improvements.
                                                                                                                 6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                                 efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                                 also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                                 Program Flexibility Act should be extended to this loan program.
                                                                                                                 7. Additional Questions Recommendations:
                                                                                                                 o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                                 include cash on hand?
                                                                                                                 o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                                 needed.
                                                                                                                 o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
Staff Group - Main                                                                                               financial liquidity related to the impact of COVID-19.
Street Lending
Program - Nonprofit                                                           cjindasurat@no                     The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which Nonprofit
Organization          PIO (Email    6/22/2020                                 nprofitnewyork.   Nonprofit New    New York endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Jindasurat   Chai         org               York




                                                                                                                    Page 178 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                      Comment
                                                                                                              June 22, 2020
                                                                                                              Federal Reserve Board of Governors
                                                                                                              Constitution Ave NW &, 20th St NW
                                                                                                              Washington, DC 20551

                                                                                                              Subject: Main Street Lending Program - NONLF and NOELF

                                                                                                              To Whom It May Concern:

                                                                                                              The Oregon Alliance of YMCAs is respectfully submitting these comments in response to Federal Reserve Board's announcement on
                                                                                                              June 15, 2020 that it is seeking public feedback on the proposal to expand its Main Street Lending Program for nonprofit organizations. We
                                                                                                              appreciate the Federal Reserve Board making this program available to nonprofits; however, there are several concerns outlined below that
                                                                                                              could help improve the program and make it truly applicable and accessible to nonprofit organizations, such as local YMCAs.

                                                                                                              The 11 YMCAs of Oregon are member associations of the YMCA of the USA (Y-USA). Y-USA is the national resource office for the
                                                                                                              nation's 2,700 local 501 (c)3, charitable, nonprofit YMCAs. YMCAs helps strengthen their local communities through youth development,
                                                                                                              healthy living, and social responsibility.Annually, YMCAs engage 22 million men, women, and children-regardless of age, income, or
                                                                                                              background-to nurture the potential of children and teens, improve the nation's health and well-being, and provide opportunities to give
                                                                                                              back and support neighbors. The Y works side-by-side with its neighbors to make sure everyone has the opportunity to learn, grow, and thrive.

                                                                                                              Despite mandated facility closures, cancellation of traditional programming and a decrease in giving, the Y has stepped up to address the
                                                                                                              critical need for safe childcare options and other needed services across the country. At the height of the pandemic the Y offered emergency
                                                                                                              childcare at more than 1,100 locations for families of medical personnel, essential employees and first responders - 40 locations in Oregon
                                                                                                              along serving over 1,000 children. With school closures, children cannot access USDA breakfasts and lunch and during this time of economic
                                                                                                              uncertainty, a rapidly increasing number of adults and families are facing food insecurity. In response, over 1,000 Ys nationwide are providing
                                                                                                              free grab-and-go meals to help address this urgent need.

                                                                                                              Citizens in communities of all sizes are depending on local charitable nonprofits to a far greater degree during the response and relief phases
                                                                                                              to the COVID-19 health and economic crises, and that reliance will only grow during the recovery period ahead.

                                                                                                              Y-USA has worked with YMCA State Alliances and local Ys to identify and address areas of confusion and contradiction in regard to the much-
                                                                                                              anticipated Mainstreet Lending Program. These real-life, current concerns and questions based on experiences of Ys across America are the
                                                                                                              basis for the following comments and recommendations.

                                                                                                              Comments and Recommendations
                                                                                                              1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                              Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                              Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                              nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                              In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                              though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                              meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                              Furthermore, they will play an integral role as our nation recovers - providing childcare, job training, and other core supports.

                                                                                                              Charitable nonprofits of all sizes and focus areas are struggling to maintain mission- critical operations despite enormous economic challenges.
                                                                                                              Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                              nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                              helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
Staff Group - Main
Street Lending                                                                                                loans. Smaller nonprofits throughout the country have been hit equally hard.
Program - Nonprofit                                                                          Oregon
Organization          PIO (Email    6/22/2020                                marisa@orego    Alliance of      Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
Facilities            from Web)     12:00:00 AM     Fink        Marisa       nymcas.org      YMCAs            steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest

                                                                                                                 Page 179 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                  Comment
                                                                                                     employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                     the economy.

                                                                                                     Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                     forgiveness, in the next round of COVID-19 relief legislation.

                                                                                                     2. The Federal Reserve Needs to Make Loan Terms More Favorable to Charitable Organizations

                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for- profit businesses.

                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard. The statistics above should not be
                                                                                                     viewed as an indictment of the efficiencies or management policies of nonprofits.

                                                                                                     Also, many nonprofits are facility-based and carry planned debt which may be disqualified under the proposed calculation. Furthermore,
                                                                                                     creditworthiness can be established on other criteria.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and eliminating the specific 65% debt ratio requirement and instead allow a statement of
                                                                                                     explanation for debt that may be of concern as it relates to credit worthiness.

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is too high. In addition, the imposition of loan
                                                                                                     origination and service fees adds to the cost. Finally, the 70% balloon payment at the end of the fifth year of the loan would be difficult for many
                                                                                                     nonprofits, unless provided an opportunity to refinance such loans at low rates.

                                                                                                     Recommendation: Revisit the loan terms including interest rate and balloon payments and recommend the lowest permissible rate such as the
                                                                                                     0.5% rate initially proposed for PPP loans. We also urge some flexibility in the balloon payment requirement to afford the opportunity for
                                                                                                     renegotiation. Extending the 5-year amortization to seven years could lessen the balloon payment. We request that borrowers have access to
                                                                                                     engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     3. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019
                                                                                                     earnings before interest, depreciation, and amortization (EBIDA) to unrestricted 2019 operating revenue, greater than or equal to 5%."
                                                                                                     (#6) In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these
                                                                                                     criteria alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin, both out of
                                                                                                     necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions.
                                                                                                     Moreover, at times a nonprofit may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is
                                                                                                     not always an indication of instability.

                                                                                                     Furthermore, the footnotes for #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating revenue,
                                                                                                     excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and contracts
                                                                                                     built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be sensible
                                                                                                     to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for maintenance

                                                                                                        Page 180 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment
                                                                                                     and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology-in the context of nonprofit operating budgets-is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     4. Xquot;Reasonable EffortsXquot; Regarding Employee Retention Require Further
                                                                                                     Clarification

                                                                                                     The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     Recommendation: XquotjReasonable effortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in which the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier Xquot;mission-basedXquot; before Xquotjreasonable efforts.Xquot;

                                                                                                     Recommendation: Further refine the terms Xquot;maintain its payrollXquot; and Xquot;retain its employeesXquot; are vague, and make clear
                                                                                                     that nonprofits participating in the Main Street loan program generally should endeavor to pay staff at the same or increased income levels and
                                                                                                     should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at the same or increased levels, both for the
                                                                                                     duration of the loan. It is also important that the loan documents expressly state that the employee retention provision begins on the date that
                                                                                                     loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: Adopt the safe harbors of other loan programs and state clearly that nonprofit borrowers will not be penalized under the
                                                                                                     employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for cause, voluntarily resign, or
                                                                                                     voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     5. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street Loan Facilities for for-profit businesses.
                                                                                                     There is no explanation why the Federal Reserve is proposing that nonprofits with fewer than 50 employees should not be eligible for Main
                                                                                                     Street loans for which their small business counterparts of equal size could secure lending support.

                                                                                                     Recommendation: Remove the 50-employee floor.

                                                                                                     6. The FedX#39;s Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                     Charitable Sector. The Federal ReserveX#39;s criteria that organizations must have revenues from donations that are less than 30% disqualify
                                                                                                     many charities. Overall, this loan facility seems more geared to educational institutions and nonprofit hospitals, but not most charitable
                                                                                                     organizations.

                                                                                                     Recommendation: Eliminate the requirement that no more than 30 percent of an
                                                                                                     organizationX#39;s 2019 revenues come from donations.

                                                                                                     7. Additional Recommendations and Requests for Clarification


                                                                                                     The Oregon Alliance of YMCAs respectfully requests clarification of the following issues in the final notice.

                                                                                                      Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                     cash on hand?
                                                                                                      Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if

                                                                                                        Page 181 of 300
                                                                                                               Main Street Lending Program
                                                                                                             Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name     First Name   Email Address          Affiliation                                                                            Comment
                                                                                                                    collateral is needed.
                                                                                                                     Other Debts: The proposal requires that borrowers, "refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                                    until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due." We request that this exclude lines of
                                                                                                                    credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                                    Conclusion
                                                                                                                    The Oregon Alliance of YMCAs appreciates the opportunity to submit these comments to the Federal Reserve about the Mainstreet Lending
                                                                                                                    Program for Nonprofits, which, in its proposed form, seems aimed more at nonprofits such as hospitals and institutions of higher education
                                                                                                                    than at nonprofits like local YMCAs. Given that, we respectfully request the Federal Reserve to address the concerns and proposed changes
                                                                                                                    outlined above.

                                                                                                                    Thank you for considering these comments and recommendations. We stand ready to work with you to strengthen the Mainstreet Lending
                                                                                                                    Program and give YMCAs the resources to help communities across America get through this crisis and promote a vibrant and equitable
                                                                                                                    economic recovery.

                                                                                                                    Sincerely,
                                                                                                                    Marisa Fink
                                                                                                                    Executive Director
                                                                                                                    Oregon Alliance of YMCAs




                                                                                                                    With similar underwriting requirements comparable to for profit corporations, not for profits such as ours will be seen as a worthwhile loan risk
                                                                                                                    for the Federal Reserve/lending institutions. Prior to the pandemic, our organization was on track to fulfill our mission to encourage women to
Staff Group - Main                                                                                                  pursue careers in the STEM fields, unfortunately due to the pandemic, we cancelled multiple in person conferences that facilitate these
Street Lending                                                                                                      interactions and are needed by our sponsor corporations to source employees. With the main street lending program and our substantial
Program - Nonprofit                                                                                Society of       history of maintaining fiscally responsible policies we would be able to continue this programming and encouraging women in STEM fields
Organization          PIO (Email    6/22/2020                                  philip.thakadiyil   Women            without suffering significant financial setbacks.
Facilities            from Web)     12:00:00 AM     Thakadiyil   Philip        @swe.org            Engineers




                                                                                                                       Page 182 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                     Comment
                                                                                                                We believe the proposal to expand the Main Street Lending Program to provide access to credit for nonprofit organizations has significant merit
                                                                                                                and would provide small and medium-sized nonprofits access to low cost additional liquidity during the current challenging period. However, we
                                                                                                                respectfully submit the following two comments to address the reality of revenue sourcing and the cost of capital specifically as it relates to
                                                                                                                small and medium-sized nonprofits that lend to small businesses.

                                                                                                                1. Revenue Source Requirement: Recommend that the Revenue Source Requirement proposal limiting the amount of revenue sourced from
                                                                                                                donations to "less than 30%" be increased to "less than 50% sourced from donations". Many nonprofits may receive in
                                                                                                                excess of 30% of their revenue from donations; particularly during this time when almost all of their small business lending is directly related to
                                                                                                                COVID-19 and PPP loans. Many of these programs are supported by grant funds to assist the nonprofits with adequate grant and donation
                                                                                                                funds to help cover administrative costs of managing the programs as well as the loss of interest revenue due to principal and interest deferral
                                                                                                                programs offered to their existing small business loan portfolio customers and potential loan losses that may be incurred on small business
                                                                                                                loans in their existing portfolio. As many financial institutions, foundations and individuals have become more cognizant of the essential
                                                                                                                economic service that the nonprofit small business lending organizations are providing during this current critical period they have increased
                                                                                                                their grants and donations accordingly; thereby increasing the percentage of revenue from these sources to unprecedented levels.

                                                                                                                2. Interest Rate: Recommend that the interest rate proposed of LIBOR + 3% be revised to a fixed rate of 1% - 2%. The majority of small
                                                                                                                business loans that a nonprofit small business lender makes are at a fixed rate and therefore make up the largest portion of the loan portfolio.
                                                                                                                The primary reason for this is so that when the loan is being underwritten, both the lender and the borrower can more properly forecast the
Staff Group - Main                                                                                              future cash flow available to service the loan than could be done with a variable rate loan. To make fixed rate loans with variable rate debt will
Street Lending                                                                                                  cause a significant asset and liability mismatch on the nonprofits balance sheet which would cause a negative cash flow and interest
Program - Nonprofit                                                                                             revenue/expense net margin effect on the nonprofits operations. A fixed rate debt instrument will allow the nonprofits to better manage their
Organization          PIO (Email    6/22/2020                                tclausen@liftfu                    interest rate environment and the effect on their ability to continue making manageable fixed rate loans to small business borrowers.
Facilities            from Web)     12:00:00 AM     Clausen     Thomas       nd.com            LiftFund Inc.




                                                                                                                Thank you for accepting comments on this important program.
                                                                                                                1) Nonprofit organizations provide essential services to the public yet have been hardest hit by the COVID-19 pandemic. This program is
                                                                                                                essential to support nonprofits.
                                                                                                                2) Because of the structure of nonprofit organizations (including revenue streams), they are not often considered good credit risks for banks or
                                                                                                                they are prioritized after commercial/for-profit enterprises. Therefore, it would be beneficial if the Main Street Lending program somehow
                                                                                                                incentivized banks to lend to nonprofits. For example, the fed could allow the funds to be used as collateral to issue loans to nonprofits, thereby
                                                                                                                reducing the risk taken on by the lender.
                                                                                                                3) In order to ensure that communities in greatest need continue to receive services, nonprofits that work with minority and/or economically
Staff Group - Main                                                                                              disadvantaged populations should be prioritized. Banks should be incentivized to provide loans under this program to those nonprofits.
Street Lending                                                                                                  4) Because nonprofits (particularly the smaller ones) typically do not have the capacity to manage complicated financial transactions, the
Program - Nonprofit                                                                                             application and loan funding process should be streamline and as simple as possible.
Organization          PIO (Email    6/22/2020                                tking@urbanpr                      Again, thank you very much for considering these comments/suggestions.
Facilities            from Web)     12:00:00 AM     King        Tim          ep.org
                                                                                                                Hathaway-Sycamores wishes to submit public comments for consideration by the Board of Governors.
                                                                                                                We are opposed to the proposed requirement that sets a maximum limit of 30% from donations for non-profits that are eligible for this program.
                                                                                                                This requirement would likely disqualify many non-profits from eligibility. Additionally, the Federal Reserve proposes to require high levels of
                                                                                                                liquidity; however, the public health emergency has reduced the level of liquidity for non-profit organizations. We are also very concerned about
                                                                                                                the proposed interest rates which are set at the same rates as for-profit firms. Hathaway-Sycamores wants to highlight that the fact that other
Staff Group - Main                                                                                              federal COVID-19 economic assistance programs (PPP and EIDL) for non-profits have set a lower interest rate(s) for these entities, realizing
Street Lending                                                                                                  that there are some unique financial challenges faced by 501 ©3 corporations during this time. Lastly, we suggest that there should be a
Program - Nonprofit                                                                                             longer length of time for payment schedules for balloon payments or an option to re-negotiate the loan period with the qualified entity. Thank
Organization          PIO (Email    6/22/2020                                wwang@hscfs.                       you for your consideration.
Facilities            from Web)     12:00:00 AM     Wang        Wendy        org               Ms.




                                                                                                                   Page 183 of 300
                                                                                                          Main Street Lending Program
                                                                                                        Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address       Affiliation                                                                       Comment
                                                                                                               Please accept this letter of support regarding the Federal Reserve Board proposal to expand its Main Street Lending Program to provide
                                                                                                               access to credit for nonprofit organizations. Expanding this program to allow small and medium-sized nonprofits that were in sound financial
                                                                                                               condition before the coronavirus pandemic will help reach a lot of employers who could benefit from additional liquidity to manage through this
                                                                                                               challenging period.

                                                                                                               As a non-profit leader I can attest to this statement:

                                                                                                               "Nonprofit organizations are critical parts of our economy, employing millions of people, providing essential services to communities, and
                                                                                                               supporting innovation and the development of a highly skilled workforce,Xquot; Federal Reserve Chair Jerome H. Powell said.
                                                                                                               "Nonprofits provide vital services across the country and we are working to help them through this difficult time.Xquot;

                                                                                                               Too often the non-profit designation eliminates these necessary businesses from access to lending opportunities that limit their reach to the for-
                                                                                                               profit sector. In doing so, organizations are forced to operate on small margins, limited by outdated notions that they are not in need of
                                                                                                               investment in overhead, infrastructure and other costs necessary for maintaining stability.

                                                                                                               By opening this program to qualifying 501c3 and 501c(19), the Federal Reserve not only acknowledges the value of the work done by these
                                                                                                               organizations across the country, but also validates the excellent business leadership of these agencies and their boards, as well as their
                                                                                                               ability to use these funds wisely. Our attention to a double bottom line - sound financial management and meeting our missions - make
                                                                                                               investing in, and doing business with, us a win-win.

                                                                                                               If I could add one comment, I would ask that consideration be made to offer this opportunity or a similar one, to agencies that have staff of 30
                                                                                                               or more. Many of us have had to maintain less than optimum levels of staffing but still achieve so much through leveraging, thoughtful planning
                                                                                                               and healthy management practices. Access to credit when needed, as in times like this, could be a major win for these non-profits and the
                                                                                                               communities they serve.

                                                                                                               Please do not hesitate to contact me if you would like additional information -


                                                                                                               Sincerely,


                                                                                                               Carla Miklos
                                                                                                               Executive Director




Staff Group - Main
Street Lending
Program - Nonprofit                                                                                            Carla Miklos
Organization          PIO (Email    6/22/2020                                cmiklos@opera    Operation        Executive Director
Facilities            from Web)     12:00:00 AM     Miklos      Carla        tionhopect.org   HOPE




                                                                                                                  Page 184 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                         Comment
                                                                                                                Comments for Main Street Loan Programs for Nonprofits

                                                                                                                Thank you for the opportunity to provide comments on the Main Street Loan Program for Nonprofits. As a Community Development Financial
                                                                                                                Institutions dedicated exclusively to providing financing to Federally Qualified Health Centers (FQHCs), Community Health Capital Fund has
                                                                                                                provided $108 million in financing to FQHCs nationally for projects totaling over $270 million. As such, we are uniquely positioned to advise the
                                                                                                                Federal Reserve on reasonable lending parameters for the Main Street Loan Program as they relate to FQHCs.

                                                                                                                We are writing on behalf of the more than 1,400 Federally Qualified Health Centers across the country. FQHCs are community-based, non­
                                                                                                                profit organizations whose goal is to provide affordable, accessible health care for all individuals, regardless of their ability to pay. As explained
                                                                                                                below, we appreciate the Federal Reserve's intention to expand Main Street Loans to non-profit organizations; however, after closely
                                                                                                                reviewing the draft Term Sheet, we determined that almost no FQHCs would qualify for these loans under the current eligibility requirements.
                                                                                                                Therefore, we are therefore requesting that:
                                                                                                                 the loan terms be revised to enable the majority of FQHCs to qualify, and
                                                                                                                 FQHCs be permitted to work with Community Development Financial Institutions (CDFIs) to access Main Street loans, as CDFIs understand
                                                                                                                the unique FQHC model and collectively have provided more than $2.1 billion in loans to FQHCs, with a default rate of less than 1/1 Oth of 1%.

                                                                                                                Background on FQHCs and the COVID-19 Pandemic

                                                                                                                As community-based, non-profit organizations committed to ensuring access to health care, FQHCs have been on the frontlines of the COVID-
                                                                                                                19 pandemic since the beginning. With more than 12,000 care delivery sites nationally, FQHCs provide care for nearly 30 million patients.
                                                                                                                FQHC patients have been disproportionately impacted by the pandemic, as 91% of them are low-income, 23% are uninsured, and 68% are
                                                                                                                racial and ethnic minorities, many of whom suffer from multiple chronic health conditions associated with poverty and the effects of racism.

                                                                                                                Throughout the pandemic, FQHCs have provided a range of critical front-line care and a growing proportion of testing, particularly in the low-
                                                                                                                income, minority communities they serve. At the same time, FQHCs have experienced a significant decline in revenue, due to the need to
                                                                                                                curtail many primary and preventive care visits. This combination has placed major financial strain on these non-profit, community-based
                                                                                                                providers, forcing them to close sites and lay off staff at the time when their services are most needed.

                                                                                                                While FQHCs have received some Federal funding to support COVID relief, for many FQHCs this funding is not enough to reestablish their
                                                                                                                pre-COVID level of operations, let alone prepare for the increased demand that will result as millions of newly-unemployed and uninsured
                                                                                                                individuals turn to them for care. To date, the Provider Relief Fund has offered most FQHCs only 2% of their net patient revenues; also,
                                                                                                                FQHCs with over 500 staff - which in total care for about 9 million patients - are ineligible for Paycheck Protection Loans because of their size.

                                                                                                                Recommendation to expand eligibility criteria to allow majority of FQHCs to qualify:

                                                                                                                For these reasons, Community Health Center Capital Fund was relieved to hear that the Small Business Administration will soon make Main
                                                                                                                Street Loans available to non-profit organizations with 50 to 15,000 employees. However, after reviewing the Terms Sheet, we determined that
                                                                                                                almost no FQHCs would qualify under the proposed eligibility criteria.

                                                                                                                This conclusion is based on an analysis conducted by Capital Link, a non-profit organization that receives funding from the Federal Department
                                                                                                                of Health and Human Services to assist FQHCs with accessing capital. Capital Link determined that under the proposed lending parameters:
                                                                                                                 Prior to the pandemic, only 13% of health centers would have met the combined criteria. This includes less than one in five of the FQHCs with
                                                                                                                over 500 staff, who are currently ineligible for the Paycheck Protection Program.
                                                                                                                 Because of the significant cash declines experienced by FQHCs as a result of COVID-19, at present, far fewer than 13% would be able to
                                                                                                                meet the DCOH and Cash/Debt ratio at loan origination.

                                                                                                                The most problematic financial parameters for FQHCs are:
                                                                                                                 EBIDA to unrestricted 2019 operating revenue greater than or equal to 5%
                                                                                                                 Days cash on hand at loan origination equal to or greater than 90 days
Staff Group - Main
Street Lending                                                                                                   Ratio of unrestricted cash and investments to outstanding debt (including Main Street debt and CMS Accelerated and Advance Payments) at
Program - Nonprofit                                                                            Community        origination is 65% or greater
Organization          PIO (Email    6/22/2020                                bboyle@chc-       Health Center
Facilities            from Web)     12:00:00 AM     Boyle       Brandon      capitalfund.org   Capital Fund     In order to provide a meaningful program for which approximately 60% of FQHCs would qualify, we request that the Federal Reserve adjust

                                                                                                                   Page 185 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                      Comment
                                                                                                     the following lending parameters for FQHCs loans as follows:
                                                                                                      EBIDA to unrestricted 2019 operating revenue greater than or equal to 3%
                                                                                                      Days cash on hand at loan origination equal to or greater than 30 days
                                                                                                      Eliminate the unrestricted cash to debt ratio requirement
                                                                                                      Lower the minimum employee requirement to 20.

                                                                                                     In addition, we ask that the Federal Reserve clarify the eligibility requirement that reads: "has not received specific support pursuant to
                                                                                                     the Coronavirus Economic Stabilization Act of 2020 (Subtitle A of Title IV of the CARES Act)." As you know, Section 4003 of Title IV
                                                                                                     authorizes the Federal government to make loans to States and municipalities for COVID-19 relief. It is possible that a state or municipality
                                                                                                     could receive a loan under Section 4003, and use part of it to support FQHCs or other safety net providers. To make clear that FQHCs or other
                                                                                                     providers who receive this type of support from their state are still eligible for Main Street Loans, we recommend that the term "specific
                                                                                                     support" be revised to read "direct support."

                                                                                                     Request for FQHCs to work directly with CDFIs to access Main Street Loans

                                                                                                     Finally, it is important to note that Community Development Financial Institutions (CDFIs) have historically played a major role in providing
                                                                                                     financing to FQHCs for decades. As such, they understand the FQHC model and are best positioned to underwrite loans to health centers. We
                                                                                                     are part of a 25-member coalition of CDFIs who have joined together to promote access to capital for FQHCs. Together, members of the
                                                                                                     Lenders Coalition for Community Health Centers have collectively provided more than $2.1 billion in loans to FQHCs, with a default rate of less
                                                                                                     than 1/1 Oth of 1%.

                                                                                                     Unfortunately, very few CDFIs would qualify as eligible lenders under the program as it is currently construed. To enable FQHCs to work
                                                                                                     directly with lenders who best understand their model and needs, we recommend that the Federal Reserve structure the nonprofit portion of
                                                                                                     the Main Street Loan Program to:
                                                                                                      Allow CDFIs to participate as lenders in the program; and
                                                                                                      Allow CDFIs to borrow from the Federal Reserve under the same terms as banks, which would enable CDFIs to offer interest rates to FQHCs
                                                                                                     at LIBOR +3%

                                                                                                     We are providing these comments on short notice to accommodate the Federal Reserve's request. We would be happy to provide more
                                                                                                     detailed comments and/or provide additional information to assist the Federal Reserve in developing a program that will be responsive to the
                                                                                                     current needs of Federally Qualified Health Centers.




                                                                                                        Page 186 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description     Ticket Type   Received Date   Last Name   First Name   Email Address         Affiliation                                                                      Comment
                                                                                                              The Alliance is the statewide association of community nonprofits in Connecticut. Community nonprofits provide essential services in every city
                                                                                                              and town in Connecticut, serving more than half a million people in need and employing 117,000 people across the State.

                                                                                                              We appreciate the proposal to expand the Main Street lending program to community nonprofits, as these community-based organizations
                                                                                                              continue to confront a myriad of issues dues to the COVID-19 crisis. While another funding stream is welcome, it must be designed
                                                                                                              appropriately with a clear understanding of the nonprofit budget and service delivery model. As an example, many nonprofits will be hesitant to
                                                                                                              take on the risk associated with a loan of this size because, unlike for-profits businesses that have time to make a profit to pay back the loan
                                                                                                              (interest and principal), nonprofits are not in the business of making profits, they serve people and communities and those needs often
                                                                                                              increase. A forgivable loan would be a better option.

                                                                                                              The Alliance appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan Facilities. This
                                                                                                              proposal is aimed more at transactional nonprofits such as hospitals and institutions of higher ed than at community nonprofits that have a
                                                                                                              larger reliance on donations from the public to support their missions. Indeed, many community nonprofits pride themselves on offering their
                                                                                                              services at no charge. Recognizing that their business models are different, even if both types of organizations are inherently organized around
                                                                                                              a public mission, many of the financial requirements included in this proposal simply are not applicable to community nonprofits. With that in
                                                                                                              mind, The Alliance respectfully requests the Federal Reserve to address the concerns and proposed changes outlined below.

                                                                                                              1. Congress Must Act to Ensure Mid-Sized Community Nonprofits are Eligible for Loan Forgiveness
                                                                                                              Congress must ensure that mid-sized community nonprofits have access to loan forgiveness. While it is a welcome development to see the
                                                                                                              Federal Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                              nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                               In this critical time, community nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19
                                                                                                              pandemic. Even though they face many of the same economic challenges as other industries, many community nonprofits never shut down.
                                                                                                              Rather, they are straining to meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping
                                                                                                              our communities connected. Furthermore, they will play a critical role as our nation recovers - providing child care, job training, and other core
                                                                                                              supports.

                                                                                                               Community nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic
                                                                                                              challenges. Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts
                                                                                                              across the nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance
                                                                                                              would be most helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the
                                                                                                              form of forgivable loans. Smaller community nonprofits have been hit equally hard, especially those that rely on in-person services and indoor
                                                                                                              venues.

                                                                                                               Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many community nonprofits do not have
                                                                                                              steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                              employment sector and many hope to hire more workers as their organizations recover.

                                                                                                              Recommendation: Congress must recognize the vital services community nonprofits provide to communities and the economy by including
                                                                                                              loan forgiveness, in the next round of COVID-19 relief legislation.

                                                                                                              2. The Fed's Proposal to Limit Loans to Mid-Size Community Nonprofits with Less than 30% of Revenue from Donations Will Disqualify
                                                                                                              Many
                                                                                                               The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% may disqualify
                                                                                                              organizations that could most benefit from the program.

                                                                                                              Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                              instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                              3. The Fed Needs to Make Loan Terms More Favorable to Community Nonprofits
Coronavirus        PIO (Email    6/22/2020                                jshaw@ctnonpr                       The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
(COVID-19)         from Web)     12:00:00 AM     Casa        Gian-Carl    ofitalliance.org   The Alliance     Facilities available to for-profit businesses.

                                                                                                                 Page 187 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment

                                                                                                      Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                      The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits community nonprofits from accumulating reserves through surpluses. In Connecticut, the practice of "cost settlement"
                                                                                                     goes even farther, by requiring nonprofits to return any unspent funds at the end of the fiscal year, even if they were able to do something more
                                                                                                     efficiently or through innovation. Building reserves is difficult even in the best circumstances. In many instances, government grant/contract
                                                                                                     work creates cash-flow challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for community nonprofits and are less favorable than those offered in
                                                                                                     other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for Paycheck
                                                                                                     Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the imposition of loan
                                                                                                     origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that community nonprofits would be faced with a
                                                                                                     70% balloon payment at the end of the fifth year of the loan would be off-putting for many organizations. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                      In the "Draft for Public Consultation,Xquot; for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have Xquot;a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization (Xquot;EBIDAXquot;) to unrestricted 2019 operating revenue, greater than or equal to 5%.Xquot; (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                      It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, community nonprofits generally run on a
                                                                                                     small margin, both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at
                                                                                                     times a community nonprofit may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not
                                                                                                     always an indication of instability.

                                                                                                      Furthermore, the footnotes for criteria #6 clarify that XquotjThe Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital.Xquot; Many nonprofits have Xquot;restricted revenueXquot; through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a Xquot;capital campaign,Xquot; excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation

                                                                                                        Page 188 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. Xquot;Reasonable EffortsXquot; Regarding Employee Retention Require Further Clarification
                                                                                                      The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects community
                                                                                                     nonprofits to take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention,
                                                                                                     and recommend the following:

                                                                                                     Recommendation: XquotjReasonable effortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier Xquot;mission-basedXquot; before Xquotjreasonable efforts.Xquot;

                                                                                                     Recommendation: The terms Xquot;maintain its payrollXquot; and Xquotjretain its employeesXquot; are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                      The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                     support.

                                                                                                      Many of the nonprofits in our network are on the frontlines of this pandemic, working with fewer than 50 employees to address immediate and
                                                                                                     growing needs. These vital organizations would be arbitrarily excluded from important loan program.

                                                                                                     Recommendation: The 50-employee floor should be removed.

                                                                                                     7. Additional Recommendations and Requests for Clarification
                                                                                                      The Alliance respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                     o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                     include cash on hand?
                                                                                                     o Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                     collateral is needed.
                                                                                                     o Other Debts: The proposal requires that borrowers, Xquot;refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                     until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due.Xquot; We request that this exclude lines of
                                                                                                     credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.

                                                                                                     Thank you for your consideration of these recommendations, which will better ensure the Main Street Loan Program helps as many community
                                                                                                     nonprofits as intended.

                                                                                                     Gian-Carl Casa
                                                                                                     President Xamp; CEO
                                                                                                     The Alliance



                                                                                                        Page 189 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                          Comment
                                                                                                              Michigan Nonprofit Association (MNA) is a statewide membership organization serving more than 50,000 nonprofits in Michigan by providing
                                                                                                              resources, training, and advocacy. Nonprofits play a vital role in Michigan's economy and in providing essential services. In response to
                                                                                                              Covid-19, Michigan's nonprofits have stepped up to meet the unprecedented level of need due to the COVID-19 pandemic. Even though
                                                                                                              they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to meet
                                                                                                              increasing demands on the frontlines, caring for the sick, feeding families, and keeping our communities connected. Furthermore, they will play
                                                                                                              an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                              MNA appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan Facilities and respectfully
                                                                                                              requests the Federal Reserve to address the concerns and proposed changes outlined below.

                                                                                                              1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                              While it is a welcome development to see the Federal Reserve making its Main Street lending program available to some nonprofits, this
                                                                                                              assistance still falls short of what is most needed by nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                              Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                              Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                              nation, have been severely impacted by this health and economic crisis.

                                                                                                              Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                              forgiveness, in the next round of COVID-19 relief legislation

                                                                                                              2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                              Charitable Sector
                                                                                                              The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities.
                                                                                                              Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and nonprofit hospitals, but not most
                                                                                                              charitable organizations.
                                                                                                              Nonprofits raise money and receives donations from the public, foundations, corporations and others to fund their work. Many do not receive a
                                                                                                              significant amount of revenue through direct services.

                                                                                                              Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
                                                                                                              instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                              3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                              The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                              Facilities available to for-profit businesses.

                                                                                                              Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                              margin of 1.5%. It is important to note that the vast majority of social service nonprofit funding comes from government grants contracts,
                                                                                                              recognizing the key role such organizations play in serving the most vulnerable. Numerous studies confirm that government funding seldom
                                                                                                              covers the full cost of providing contracted work, which inhibits nonprofits from accumulating reserves through surpluses. In many instances,
                                                                                                              government grant/contract work creates cash-flow challenges since it is paid after the work has been completed and can be subject to
                                                                                                              significant delays in payment.

                                                                                                              Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                              partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                              possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                              example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                              We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
Staff Group - Main
Street Lending                                                                                                in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
Program - Nonprofit                                                                          Michigan         Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
Organization          PIO (Email    6/22/2020                                jgustafson@mn   Nonprofit        imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
Facilities            from Web)     12:00:00 AM     Gustafson   Joan         aonline.org     Association      with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with

                                                                                                                 Page 190 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                     Comment
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%.Xquot; (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that Xquot;The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital.Xquot; Many nonprofits have Xquot;restricted revenueXquot; through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a Xquot;capital campaign,Xquot; excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.

                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. Xquot;Reasonable EffortsXquot; Regarding Employee Retention Require Further Clarification
                                                                                                     The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     Recommendation: XquotjReasonable effortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier Xquot;mission-basedXquot; before Xquotjreasonable efforts.Xquot;

                                                                                                     Recommendation: The terms Xquot;maintain its payrollXquot; and Xquot;retain its employeesXquot; are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending

                                                                                                        Page 191 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                              Comment
                                                                                                     support.

                                                                                                     Recommendation: The 50-employee floor should be removed.




                                                                                                       Page 192 of 300
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                                                                                                      Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address     Affiliation                                                                        Comment




                                                                                                             Together SC, the statewide association of charitable nonprofit organization in South Carolina, provides the following recommendations to
                                                                                                             improve the proposed Nonprofit Organization Loan Programs:
                                                                                                             1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                             economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                             2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor.
                                                                                                             3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                             organization's 2019 revenues come from donations.
                                                                                                             4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                             on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                             requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                             5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                             allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                             needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                             operating budgets and capital funds for improvements.
                                                                                                             6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                             efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                             also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                             Program Flexibility Act should be extended to this loan program.
                                                                                                             7. Additional Questions Recommendations:
                                                                                                             o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                             include cash on hand?
                                                                                                             o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                             needed.
                                                                                                             o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
                                                                                                             financial liquidity related to the impact of COVID-19.
Staff Group - Main
Street Lending                                                                                               The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits (https :
Program - Nonprofit                                                                                          //www.councilofnonprofits.org/sites/default/files/documents/national-council-of-nonprofits-comments-to-nonlf-and-noelf-6-21-2020.pdf ), which
Organization          PIO (Email    6/22/2020                                benjamin@toge                   Together SC endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Bullock     Benjamin     thersc.org      Together SC




                                                                                                                Page 193 of 300
                                                                                                    Main Street Lending Program
                                                                                                  Nonprofit Organizations Comments

   Event Title /
   Description      Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                         Comment
                                                                                                         Hello,
                                                                                                         Snbsp;
                                                                                                         The Composite Recycling Technology Center (CRTC) fully supports the idea of including not for profits in the Main Street Lending
                                                                                                         Programs.  501(c)3's like the CRTC have been hit hard by the pandemic and need assistance in order to recover and get back on
                                                                                                         our feet again.
                                                                                                         Snbsp;
                                                                                                         I have 3 upgrades to the program for your consideration:
                                                                                                         Snbsp;
                                                                                                         1. Years in Operation: At least 5 years -1 would like to see this be set at 3 years for the minimum.Snbsp; Newer not for profits are likely going
                                                                                                         to need more help then better established entities.  3 years seems like a decent compromise by avoiding brand new not for profits but
                                                                                                         being more inclusive for those who are at least established and have proved their ability to operate for 3 or more years.
                                                                                                         Snbsp;
                                                                                                         2. Employee Min/Max: Employees fewer than 15,000 and greater than 50 - The 15,000 max is fine but the minimum threshold is too high at
                                                                                                         50.  There are many fine not for profits that are doing great work with less.  Also, many not for profits have a mix of employees
                                                                                                         and contractors, so the definition of an employee should include part time and full time contractors.  Not for profits have to be efficient
                                                                                                         and use our donors resources wisely, so it does not seem fair to only offer the program to those entities that are large.  I propose a
                                                                                                         minimum of 10 employees.  It is enough to be of legitimate size but not so high as to eliminate many smaller not for profits.
                                                                                                         Snbsp;
                                                                                                         3. Revenue cap and source requirement: 2019 Revenues less than $5 billion, with less than 30% sourced from donations -1 am OK with a max
                                                                                                         of less than 5 billion although it seems quite high.  Why does the donation percentage need to be so low at 30% or less?  This will
                                                                                                         exclude many not for profits that are mainly donation sourced.Snbsp; I am not clear why the percentage is critical to the Fed.Snbsp; Whether a
                                                                                                         not for profit gets the majority of their income from donations or not, should not influence their worthiness to participate in the program.Snbsp; I
                                                                                                         would like to see the max donation percentage eliminated.Snbsp; If that is not doable then it should be raised to at least 75%.
                                                                                                         Snbsp;
                                                                                                         The CRTC is anxious to participate in this program and we could really use the loan but we would be excluded as we have been in operation
                                                                                                         for only 4 years (rejects us based on item #1 above), we only have 15 employees (rejects us based on item #2 above) and about 60% of our
                                                                                                         revenue comes from donations (rejects us based on item #3 above).
                                                                                                         Snbsp;
                                                                                                         Thank you for the opportunity to share our perspective.Snbsp; We hope you will consider these adjustments as it sounds like a great program
                                                                                                         that would be help many not for profits to be able to survive and make it to the other side of this pandemic.
                                                                                                         Snbsp;
                                                                                                         David L. Walter
                                                                                                         Chief Executive Officer
                                                                                                         Composite Recycling Technology Center
                                                                                                         Snbsp;
                                                                                                         Snbsp;
                                                                                                         2220 West 18th St.
Main Street                                                                                              Port Angeles, WASnbsp; 98363
Lending Program -                                                                                        dwalter@CRTC-WA ,org[mailto :dwalter@CRTC-WA .org]
NONLF and           PIO (E-       6/22/2020                                dwalter@crtc-                 360-819-1203 (office)
NOELF               mail)         12:00:00 AM     Walter      David        wa.org




                                                                                                            Page 194 of 300
                                                                                                         Main Street Lending Program
                                                                                                       Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                        Comment
                                                                                                              RESPECT is a nonprofit organization located in Omaha, Nebraska utilizing interactive theatre to educate about mental health, child abuse,
                                                                                                              bullying, and healthy relationships. We reach 30,000 participants each year with hundreds of schools, teachers and counselors relying upon us
                                                                                                              to fill needs in their counseling curriculum. Our organization has about ten employees and we are rapidly adapting to meet the needs of our
                                                                                                              audiences in ways that can be done safely during the pandemic. Our audiences have limited budgets of their own to provide educational and
                                                                                                              youth services through schools and organizations. We therefore rely heavily upon foundation and donor support to fulfill our mission so that no
                                                                                                              student or school should be without our services due to cost. The uncertainty regarding the ability for donors to give their usual amounts may
                                                                                                              mean that we need to reduce services and reduce staff if ways that would harm our community.

                                                                                                              RESPECT appreciates the opportunity to submit comment to the Federal Reserve about the Nonprofit Organization Loan Facilities. This
                                                                                                              proposal is aimed more at transactional nonprofits such as hospitals and institutions of higher ed than at nonprofits like RESPECT that have a
                                                                                                              larger reliance on donations from the public to support their missions. Indeed, many nonprofits pride themselves on offering their services at no
                                                                                                              charge. Recognizing that their business models are different, even if both types of charities are inherently organized around a public mission,
                                                                                                              many of the financial requirements included in this proposal simply are not applicable to organizations that rely on donations. With that in mind,
                                                                                                              RESPECT respectfully requests the Federal Reserve to address the concerns and proposed changes outlined below.

                                                                                                              1. Congress Must Act to Ensure Mid-Sized Nonprofits are Eligible for Loan Forgiveness
                                                                                                              Congress must ensure that mid-sized nonprofits have access to loan forgiveness. While it is a welcome development to see the Federal
                                                                                                              Reserve making its Main Street lending program available to some nonprofits, this assistance still falls short of what is most needed by
                                                                                                              nonprofit organizations - a provision that makes these loans forgivable.

                                                                                                              In this critical time, nonprofits have stepped up to meet the unprecedented level of need in our country due to the COVID-19 pandemic. Even
                                                                                                              though they face many of the same economic challenges as other industries, nonprofits are not shutting down. Rather, they are straining to
                                                                                                              meet increasing demands in our communities on the frontlines, caring for the sick, feeding families, and keeping our communities connected.
                                                                                                              Furthermore, they will play an integral role as our nation recovers - providing child care, job training, and other core supports.

                                                                                                              Charitable nonprofits of all sizes and focus areas are struggling to maintain mission-critical operations despite enormous economic challenges.
                                                                                                              Data released by Independent Sector shows that nonprofits with between 500 to 5,000 employees, key to scaling relief efforts across the
                                                                                                              nation, have been severely impacted by this health and economic crisis. When asked "What types of additional assistance would be most
                                                                                                              helpful to your organization?" organizations overwhelmingly (92% of responses) suggested government support in the form of forgivable
                                                                                                              loans. Smaller nonprofits throughout the country have been hit equally hard.

                                                                                                              Nonprofit organizations need funding so they can continue to meet the needs of their communities. Many charitable organizations do not have
                                                                                                              steady streams of commercial income and have little capacity for loan and interest repayment. Furthermore, nonprofits are the third largest
                                                                                                              employment sector and many hope to hire more workers as their organizations recover. America cannot afford to leave out such a vital part of
                                                                                                              the economy.

                                                                                                              Recommendation: Congress must recognize the vital services nonprofits provide to communities and the economy by including loan
                                                                                                              forgiveness, in the next round of COVID-19 relief legislation

                                                                                                              2. The Fed's Proposal to Limit Loans to Mid-Size Nonprofits with Less than 30% of Revenue from Donations Disqualifies Many in
                                                                                                              Charitable Sector
                                                                                                              The Federal Reserve's criteria that organizations must have revenues from donations that are less than 30% disqualify many charities,
                                                                                                              including RESPECT. Overall, this loan facility seems more applicable to for-profit entities, as well as educational institutions and nonprofit
                                                                                                              hospitals, but not most charitable organizations. RESPECT received 88% from donations in 2019.

                                                                                                              We raise money and receives donations from the public, foundations, corporations and others to fund in school and out-of-school programs
                                                                                                              about mental health, relationships, child abuse, and bullying, and we do not receive a significant amount of funding through direct services.
                                                                                                              Charitable organizations play a fundamental role in strengthening civil society. Our organizations provide vital services for 30,000 children each
Staff Group - Main                                                                                            year in need of understanding how to find resources and help to address these challenges the nation, and pride ourselves on the donations we
Street Lending                                                                                                receive rooted in the trust and support that the public has of the sector.
Program - Nonprofit
Organization          PIO (Email    6/22/2020                                ilana.weiss@re                   Recommendation: Eliminate the requirement that no more than 30 percent of an organization's 2019 revenues come from donations, and
Facilities            from Web)     12:00:00 AM     Weiss       Ilana        spect2all.org    RESPECT         instead make 501(c)(3) organizations that are otherwise meet the employee size are eligible.

                                                                                                                 Page 195 of 300
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                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                        Comment

                                                                                                     3. The Fed Needs to Make Loan Terms More Favorable to Charitable Organizations
                                                                                                     The draft Nonprofit Loan Facility imposes certain liquidity, asset, and reserve requirements that are not required in Main Street New Loan
                                                                                                     Facilities available to for-profit businesses.

                                                                                                     Nonprofit organizations typically provide services with low-profit margins. Indeed, social service organizations report an average aggregate
                                                                                                     margin of 1.5%. According to a recent report by Seachange Capital Partners, the median social services nonprofit has a margin of 1.0%,
                                                                                                     receives 3.6% of its revenue from philanthropy (including investment income), has total financial assets (including endowments and other
                                                                                                     assets that are subject to legal restrictions) equal to 1.9 months of expenses, and operating reserves of less than one month of expenses. Less
                                                                                                     than 20% of large nonprofits have 6 months or more of operating reserves, a widely accepted standard for "financial strength" for
                                                                                                     nonprofits. Social services organizations are the most fragile, with fewer than 10% reaching this standard.

                                                                                                     The statistics above should not be viewed as an indictment of the efficiencies or management policies of nonprofits. It is important to note that
                                                                                                     the vast majority of social service nonprofit funding comes from government grants contracts, recognizing the key role such organizations play
                                                                                                     in serving the most vulnerable. Numerous studies confirm that government funding seldom covers the full cost of providing contracted work,
                                                                                                     which inhibits nonprofits from accumulating reserves through surpluses. In many instances, government grant/contract work creates cash-flow
                                                                                                     challenges since it is paid after the work has been completed and can be subject to significant delays in payment.

                                                                                                     Recommendation: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as
                                                                                                     partners on the front lines of the COVID-19 crisis, we urge the Federal Reserve to eliminate borrower requirements 7 and 8. If this is not
                                                                                                     possible, we alternatively ask that the requirements be lessened significantly to reflect the economic realities of nonprofit operations, for
                                                                                                     example by requiring only 30 days cash on hand, and bringing the loan origination ratio of 40-50% (down from 65% as proposed).

                                                                                                     We are also concerned that certain eligible loan features are too onerous for nonprofit organizations and are less favorable than those offered
                                                                                                     in other government programs. Specifically, the interest rate of LIBOR plus 300 basis points is significantly higher than that offered for
                                                                                                     Paycheck Protection Program ("PPP") Loans (1.0%) and that for Economic Injury Disaster Loans (2.75%). In addition, the
                                                                                                     imposition of loan origination and service fees adds to the cost under the Nonprofit Facility. Finally, the notion that nonprofits would be faced
                                                                                                     with a 70% balloon payment at the end of the fifth year of the loan would be off-putting for many nonprofits. Nonprofits with existing loans with
                                                                                                     balloon payments are usually provided an opportunity to renegotiate such loans at prevailing market rates.

                                                                                                     Recommendation: We urge that the loan terms including interest rate and balloon payments be revisited and recommend the lowest
                                                                                                     permissible rate such as the 0.5% rate initially proposed for PPP loans. In addition, we urge some flexibility in the balloon payment requirement
                                                                                                     to afford the opportunity for renegotiation. If the 5-year amortization were extended to 7 years, this could lessen the balloon payment. We
                                                                                                     request that the borrower have access to engage with derivatives (change to a fixed rate) without the minimum swap requirements.

                                                                                                     4. The Ratio of Adjusted 2019 Earnings before "EBIDA" Should Be Revised
                                                                                                     In the "Draft for Public Consultation," for both the Nonprofit Organization New Loan Facility and the Nonprofit Organization
                                                                                                     Expanded Loan Facility, one of the eligibility criteria for borrowers is that they must have "a ratio of adjusted 2019 earnings before
                                                                                                     interest, depreciation, and amortization ("EBIDA") to unrestricted 2019 operating revenue, greater than or equal to 5%." (#6)
                                                                                                     In the context of nonprofit operations, this threshold is too high and would make many, if not most, nonprofits ineligible based on these criteria
                                                                                                     alone, which seems written more in the context of for-profit businesses as opposed to nonprofit organizations.

                                                                                                     It may certainly be prudent and necessary to have a positive ratio of adjusted earnings; however, nonprofits generally run on a small margin,
                                                                                                     both out of necessity and also so as to not leave excess surpluses that could be used for fulfilling their missions. Moreover, at times a nonprofit
                                                                                                     may have a planned and manageable deficit as part of a strategic plan-a negative ratio at one isolated point is not always an indication of
                                                                                                     instability.

                                                                                                     Furthermore, the footnotes for criteria #6 clarify that "The Eligible Lender should calculate operating revenue as unrestricted operating
                                                                                                     revenue, excluding funds committed to be spent on capital." Many nonprofits have "restricted revenue" through grants and
                                                                                                     contracts built into their operating budgets. Excluding this revenue would compound the problem of meeting the 5% ratio. Although it would be
                                                                                                     sensible to exclude contributions raised for a "capital campaign," excluding other capital funds included in an annual budget for
                                                                                                     maintenance and planned upgrades would further decrease the required ratio.


                                                                                                        Page 196 of 300
                                                                                                Main Street Lending Program
                                                                                              Nonprofit Organizations Comments

Event Title /
Description     Ticket Type   Received Date   Last Name   First Name   Email Address   Affiliation                                                                          Comment
                                                                                                     Recommendation: The 5% requirement should be reduced to zero, if not eliminated. In addition, a statement of explanation of a deficit should
                                                                                                     be allowed so that a negative ratio does not mean automatic ineligibility for a nonprofit borrower. Finally, further clarification on the calculation
                                                                                                     methodology -in the context of nonprofit operating budgets- is needed in regard to both restricted funding from grants in annual operating
                                                                                                     budgets, as well as capital funds for improvements that are part of an annual operating budget. This clarification would allow noted revenues to
                                                                                                     remain in calculation to ease the restriction and not further restrict eligibility.

                                                                                                     5. Xquot;Reasonable EffortsXquot; Regarding Employee Retention Require Further Clarification
                                                                                                     The description of Xquot;Retaining EmployeesXquot; in the draft term sheet requires refinement if the Federal Reserve expects nonprofits to
                                                                                                     take advantage of this facility. We endorse the analysis of the National Council of Nonprofits on the issue of employee retention, and
                                                                                                     recommend the following:

                                                                                                     Recommendation: XquotjReasonable effortsXquot; should be interpreted in the totality of the circumstances, taking into consideration not only
                                                                                                     the general economic environment in the community or communities in with the borrower operates, but also factors such as workforce,
                                                                                                     fundraising ability, revenue-generating activities, and overall demand for the services and programs the organization provides. One option
                                                                                                     would be to add the qualifier Xquot;mission-basedXquot; before Xquot;reasonable efforts.Xquot;

                                                                                                     Recommendation: The terms Xquot;maintain its payrollXquot; and Xquot;retain its employeesXquot; are vague and need further refinement.
                                                                                                     We ask the Federal Reserve to make clear that nonprofits participating in the Main Street loan program generally should endeavor to pay staff
                                                                                                     at the same or increased income levels and should act in good faith to keep staffing levels (measured on the basis of full-time equivalents) at
                                                                                                     the same or increased levels, both for the duration of the loan. It is also important that the loan documents expressly state that the employee
                                                                                                     retention provision begins on the date that loan funding is received by the borrower rather than at an earlier date.

                                                                                                     Recommendation: We ask that the Federal Reserve adopt safe harbors of other loan programs and state clearly that nonprofit borrowers will
                                                                                                     not be penalized under the employee retention provision for the decision of employees to decline offers of rehire, or for those who are fired for
                                                                                                     cause, voluntarily resign, or voluntarily request a reduced schedule during the time that the loan is outstanding.

                                                                                                     6. Limitation of 50-Employee Minimum Should Be Removed
                                                                                                     The term sheet for the proposed nonprofit loan facility imposes a size minimum that is not imposed in the Main Street New, Priority, or
                                                                                                     Expanded Loan Facilities for for-profit businesses. There is no explanation why the Federal Reserve is proposing that nonprofits with fewer
                                                                                                     than 50 employees should not be eligible for Main Street loans for which their small business counterparts of equal size could secure lending
                                                                                                     support.

                                                                                                     Recommendation: The 50-employee floor should be removed.

                                                                                                     7. Additional Recommendations and Requests for Clarification
                                                                                                     RESPECT respectfully requests the Federal Reserve clarify the following issues in its final expansion notice.
                                                                                                      Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to include
                                                                                                     cash on hand?
                                                                                                      Collateral: Flexibility on collateral is requested. The loan should be able to be approved with no more than 50% Loan to Value (LTV) if
                                                                                                     collateral is needed.
                                                                                                      Other Debts: The proposal requires that borrowers, Xquot;refrain from repaying the principal balance of, or paying any interest on, any debt
                                                                                                     until the Eligible Loan is repaid in full, unless the debt or interest payment is mandatory and due.Xquot; We request that this exclude lines of
                                                                                                     credit and other debt that are assumed to provide financial liquidity related to the impact of COVID-19.




                                                                                                        Page 197 of 300
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                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address      Affiliation                                                                          Comment




                                                                                                                Comments to the Federal Reserve regarding the proposed Main Street Lending Program for nonprofit organizations - NONLF and NOELF

                                                                                                                Kentucky Nonprofit Network provides the following recommendations to improve the proposed Nonprofit Organization Loan Programs:
                                                                                                                1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                                economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                                2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor.
                                                                                                                3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                                organization's 2019 revenues come from donations.
                                                                                                                4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                                on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                                requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                                5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                                allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                                needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                                operating budgets and capital funds for improvements.
                                                                                                                6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                                efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                                also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                                Program Flexibility Act should be extended to this loan program.
                                                                                                                7. Additional Questions Recommendations:
                                                                                                                o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                                include cash on hand?
                                                                                                                o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                                needed.
                                                                                                                o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
Staff Group - Main                                                                                              financial liquidity related to the impact of COVID-19.
Street Lending
Program - Nonprofit                                                                          Kentucky           The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which Kentucky
Organization          PIO (Email    6/22/2020                                danielle@kyno   Nonprofit          Nonprofit Network endorses and incorporates here by reference.
Facilities            from Web)     12:00:00 AM     Clore       Danielle     nprofits.org    Network



                                                                                                                Expanding access to Main Street Lending Program for non-profit organizations is welcome news and much appreciated. However limiting this
                                                                                                                access to organizations that are 501 c3 or 501 c19 is disappointing,. Many nonprofit organizations (in particular Professional Associations) have
                                                                                                                a 501 c6 tax exempt designation.

                                                                                                                Associations have been particularly hard hit financially by COVID-19 due to the cancelation of their in-person meetings. The in-person
                                                                                                                meetings and conferences are a major source of revenue for these nonprofit Associations and the lost revenue they are experiencing is
                                                                                                                creating tremendous financial hardship. While some are able to replicate the educational component of the meeting via a virtual platform, the
Staff Group - Main                                                                           American           lost revenue from vendor support cannot be replaced. I strongly urge you to consider making these Main Street loans available to nonprofit
Street Lending                                                                               Healthcare         organizations that have a 501 c6 tax status.
Program - Nonprofit                                                                          Radiology
Organization          PIO (Email    6/22/2020                                dkelsey@ahra.   Administrators,    Your consideration of this recommendation is appreciated.
Facilities            from Web)     12:00:00 AM     Kelsey      Daniel       org             Inc




                                                                                                                   Page 198 of 300
                                                                                                           Main Street Lending Program
                                                                                                         Nonprofit Organizations Comments

   Event Title /
   Description        Ticket Type   Received Date   Last Name   First Name   Email Address        Affiliation                                                                        Comment

                                                                                                                New Mexico Thrives provides the following recommendations to improve the proposed Nonprofit Organization Loan Programs:
                                                                                                                1. Loan Forgiveness: The Federal Reserve, either on its own or working with Congress, must recognize the extent to which the public and
                                                                                                                economy rely on the vital services nonprofits provide to communities and the economy by creating a forgivable loan program.
                                                                                                                2. 50-Employee Floor: The Nonprofit Organization Loan programs must be revised to remove the 50-employee floor. The majority of New
                                                                                                                Mexico nonprofits are small to midisize.
                                                                                                                3. 30% Donations Cap: It is essential that the Federal Reserve eliminate the requirement that no more than 30 percent of an
                                                                                                                organization's 2019 revenues come from donations.
                                                                                                                4. Loan Terms: Recognizing the unique nature of nonprofit operations and their importance in continuing to provide vital services as partners
                                                                                                                on the frontlines of the COVID-19 crisis, we urge the Federal Reserve to eliminate the liquidity and debt ratio provisions in the loan
                                                                                                                requirements. We also recommend lower interest rates in line with other nonprofit loan programs and a seven-year amortization.
                                                                                                                5. Revising EBITA Ratio: The 5 percent requirement should be reduced to zero, if not eliminated. Further, nonprofit borrowers should be
                                                                                                                allowed to provide a statement of explanation of a deficit so that a negative ratio does not mean automatic ineligibility. Finally, clarification is
                                                                                                                needed on the calculation methodology - in the context of nonprofit operating budgets - regarding both restricted funding from grants in annual
                                                                                                                operating budgets and capital funds for improvements.
                                                                                                                6. Clarifying Employee Retention Requirements: The term "mission-based" should be inserted before "reasonable
                                                                                                                efforts" to tailor employee retention requirements to the realities of nonprofit operations. The Employee retention requirements should
                                                                                                                also apply based on employment levels on the date of loan origination. The reasonable safe harbor provisions of the Paycheck Protection
                                                                                                                Program Flexibility Act should be extended to this loan program.
                                                                                                                7. Additional Questions Recommendations:
                                                                                                                o Endowment: What resources should be included in endowment calculations? Does it include restricted endowments? Does it extend to
                                                                                                                include cash on hand?
                                                                                                                o Collateral: Flexibility on collateral is requested. The loan should be available with no more than 50 percent Loan to Value (LTV) if collateral is
                                                                                                                needed.
                                                                                                                o Other Debts: The proposal to restrict paying off existing loans should exclude lines of credit and other debt that are assumed to provide
                                                                                                                financial liquidity related to the impact of COVID-19.

                                                                                                                The details of these recommendations are discussed in the set of comments submitted by the National Council of Nonprofits, which New
Staff Group - Main                                                                                              Mexico Thrives endorses and incorporates here by reference.
Street Lending
Program - Nonprofit                                                                                             Thank you.
Organization          PIO (Email    6/22/2020                                tsiporah@nmth     New Mexico       Tsiporah Nephesh
Facilities            from Web)     12:00:00 AM     Nephesh     Tsiporah     rives.org         Thrives
                                                                                                                We implore you to include mid-size nonprofit organizations with multiple locations as able participants into the Paycheck Protection Program as
                                                                                                                forgivable loan recipients. Nonprofit organizations are working across our country to keep communities connected throughout this unpresented
                                                                                                                time.

                                                                                                                Exhausted, frustrated, alone, and at risk of unemployment; that is how it feels for members of the disability community who have seen little
                                                                                                                relief throughout this pandemic. These are people who will experience the most difficult recovery from unemployment, and many may never
                                                                                                                find a job again. This community needs help and the nonprofit organizations serving them across this country are stepping up to do the work.
                                                                                                                We cannot do it alone.

                                                                                                                As a critical part of our community's safety net, we understand the demands are great and the resources few. People with disabilities are
                                                                                                                not castaways of society - they deserve to be supported and that means providing the infrastructure necessary to see them through. While
                                                                                                                there has been a concerted effort to provide relief from the economic devastation of this pandemic, the non-profit sector and people with
                                                                                                                disabilities has yet to be recognized.

                                                                                                                Opportunity Village is, by SBA definition, a mid-size organization. We actively maintain approximately 750 employees; many of whom have
                                                                                                                disabilities. Our mission is to train and employ people who have the most significant barriers to employment. The organization has five address
                                                                                                                locations throughout southern Nevada and is doing everything possible to maintain employment for all of the people on its rolls. We need help
                                                                                                                to make sure our employees have a place to work tomorrow, next week, and far into the future.
Other: Economic       PIO (Email    6/22/2020                                mayt@opportu      Opportunity
Data                  from Web)     12:00:00 AM     Brown-May   Tracy        nityvillage.org   Village          We understand the needs are many. People with disabilities are an important part to our integrated community. We implore you; include mid-

                                                                                                                   Page 199 of 300
                                                                                                      Main Street Lending Program
                                                                                                    Nonprofit Organizations Comments

   Event Title /
   Description     Ticket Type   Received Date   Last Name    First Name   Email Address     Affiliation                                                                         Comment
                                                                                                           size nonprofit organizations with multiple locations as able participants into the Paycheck Protection Program as forgivable loan recipients. Our
                                                                                                           payroll is essential to ensuring the fabric of communities across the country. We need your help.




                                                                                                           To Whom It May Concern:
                                                                                                           The non-profit agency I work in 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 has led to job loss and has delayed job creation. The longer term impact is that
                                                                                                           communities, 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 could start calling back
                                                                                                           to work our furloughed staff of nurses, therapists, speech-language pathologists, educators, social workers and other skilled specialists and
                                                                                                           administrators. We could continue to support children and families. We could avoid an erosion of our social service sector. We need immediate
                                                                                                           action. Non-profit agencies of our size must be included in the Main Street Lending Program and any subsequent mid-size loan programs.
                                                                                                           Please act now to help us restore our work force and services for infants and toddlers and their families.
                                                                                           Thom Child      Respectfully,
Coronavirus        PIO (Email    6/22/2020                                 ahaefner@tho    & Family    April Haefner
(COVID-19)         from Web)     12:00:00 AM     Haefner     April         mchild.org      Services




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