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Federal Reserve Lending Programs: Credit Markets Served by the Programs Have Stabilized, but Vulnerabilities Remain

Summary

GAO report GAO-22-104640, October 2021, to congressional committees, titled Federal Reserve Lending Programs: Credit Markets Served by the Programs Have Stabilized, but Vulnerabilities Remain. GAO reports that on July 30, 2021 the last of the 13 Federal Reserve lending facilities stopped purchasing assets or extending credit, and that as of September 1, 2021 the CARES Act facilities held about $19 billion in assets. It says available indicators suggest the facilities helped improve access to credit and liquidity in corporate and municipal credit markets, though those markets remain vulnerable. In a GAO survey of Main Street Lending Program borrowers, an estimated 88 percent said the program was very important in helping them maintain operations.

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“Federal Reserve Lending Programs: Credit Markets Served by the Programs Have Stabilized, but Vulnerabilities Remain.” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gaps-d72ace99bbdb/, SHA-256 d72ace99bbdbb14593ecb23a264c6b11f2758cbfcbfb6f76925733fcd8074ecb.

Full text

                United States Government Accountability Office
                Report to Congressional Committees




                FEDERAL RESERVE
October 2021




                LENDING
                PROGRAMS

                Credit Markets Served
                by the Programs Have
                Stabilized, but
                Vulnerabilities Remain




GAO-22-104640
                                              October 2021

                                              FEDERAL RESERVE LENDING PROGRAMS
                                              Credit Markets Served by the Programs Have
                                              Stabilized, but Vulnerabilities Remain

Highlights of GAO-22-104640, a report to
congressional committees




Why GAO Did This Study                        What GAO Found
On July 30, 2021, the last of the 13          The Board of Governors of the Federal Reserve System (Federal Reserve)
Federal Reserve lending facilities            authorized 13 lending programs—known as facilities—to ensure the flow of credit
stopped purchasing assets or                  to various parts of the economy affected by the COVID-19 pandemic. The last of
extending credit. However, some of            the nine facilities supported through CARES Act funding ceased purchasing
these facilities, including facilities that   assets, such as corporate bonds, or extending credit by January 8, 2021. As of
were supported through Department of          September 1, 2021, the CARES Act facilities held about $19 billion in assets. The
the Treasury funding appropriated             Federal Reserve oversight reviews completed in December 2020 identified
under section 4003(b)(4) of the               opportunities to enhance certain areas, including internal process and controls.
CARES Act, continue to hold
                                              These reviews also identified areas for continued monitoring, such as
outstanding assets and loans. The
                                              cybersecurity and conflicts of interest. GAO found that Federal Reserve’s plans
Federal Reserve will continue to
monitor and manage the facilities until
                                              for ongoing monitoring of the facilities align with federal internal control standards
these assets and loans are no longer          for ongoing monitoring of an entity’s internal control system.
outstanding.                                  Available indicators suggest the facilities helped improve access to credit and
                                              liquidity in the corporate and municipal credit markets. For example, corporate
The CARES Act included a provision            bond spreads (which reflect borrowing costs) have remained low, and municipal
for GAO to periodically report on             spreads have decreased to prepandemic levels. Also, officials from state and
section 4003 loans, loan guarantees,          local entities that participated in the Municipal Liquidity Facility (which targeted
and investments. This report examines
                                              the municipal bond market) generally said the facility was beneficial and helped
the Federal Reserve’s continued
                                              restore investor confidence in the municipal bond market. However, corporate
oversight and monitoring of the
CARES Act facilities; what available          and municipal credit markets remain vulnerable. For corporate credit markets,
evidence suggests about the facilities’       corporate bonds outstanding remain elevated and the high level of debt leaves
effects on corporate credit markets,          businesses vulnerable to distress. Municipal credit markets also remain
states and municipalities, and small          vulnerable because of the pandemic’s extended duration, which may adversely
businesses; and the characteristics of        affect local economies. According to surveys of small and independent
Main Street Lending Program                   businesses and lenders, access to credit has improved, but recovery remains
participants, among other things.             slow, including for businesses in the services sector.
                                              Loans made under the Main Street facilities (which targeted small and mid-sized
GAO reviewed applicable laws and
agency and Federal Reserve Bank
                                              businesses and nonprofits) were concentrated among small for-profit businesses
documentation; analyzed agency and            in certain economic sectors, such as restaurants. According to GAO’s
other data on the facilities and credit       generalizable survey of Main Street borrowers, an estimated 88 percent said that
markets; interviewed Federal Reserve          the program was “very important” in helping them maintain operations. Women-
and Treasury officials and                    owned businesses participated at lower rates compared to their representation
representatives of state and local            among U.S. businesses. Although estimates of veteran- and minority-owned
governments; and conducted a                  business participation were somewhat lower compared to their representation
generalizable survey of for-profit Main       among U.S. businesses, the differences were not statistically significant (see
Street borrowers.                             figure).
                                              Estimated Participation of Business Types in the Main Street Lending Program




View GAO-22-104640. For more information,
contact Michael E. Clements at (202) 512-
8678 or clementsm@gao.gov.


                                                                                          United States Government Accountability Office
Contents


Letter                                                                                      1
               Background                                                                   4
               CARES Act Facilities Ceased Extending Credit and Purchasing
                 Assets Based on Legal Requirements                                         9
               The Federal Reserve’s Oversight of Facilities Identified
                 Improvement Opportunities and Focus Areas for Ongoing
                 Monitoring                                                                11
               Corporate Credit Market Risks Have Remained Low since Mid-
                 2020, but Longer-Term Uncertainties Remain                                16
               Municipal Credit Market Outlook Remains Uncertain, and
                 Participants Found the Municipal Liquidity Facility Beneficial            28
               Small Businesses’ Access to Credit Has Improved, and the Main
                 Street Loans Were Concentrated in Certain Sectors                         33
               Agency Comments                                                             45

Appendix I     Objectives, Scope, and Methodology                                          48



Appendix II    Selected Indicators of Credit Markets for Corporations, State and
               Local Governments, and Small Businesses                                     53



Appendix III   Results of GAO’s Survey of Main Street Lending Program
               Borrowers                                                                   60



Appendix IV    GAO Contact and Staff Acknowledgments                                       63


Tables
               Table 1: Summary of Phase Three Oversight Focus Areas
                       Identified by the Federal Reserve’s Division of Reserve
                       Bank Operations and Payment Systems                                 13
               Table 2: Total Amount Loaned through the Main Street Lending
                       Program and Amount Loaned Relative to Gross Industry
                       Output, by Economic Sector                                          40
               Table 3: Survey Population, Sample Size, and Percentage of Valid
                       Survey Responses                                                    60




               Page i                                  GAO-22-104640 Federal Reserve Facilities
          Table 4: Is your business minority-owned? (A business is minority-
                  owned if it is at least 51 percent owned and controlled by
                  individuals who identify as members of one of the
                  following groups: Black Americans, Hispanic Americans,
                  Native Americans, Asian Pacific Americans, and
                  Subcontinent Asian Americans.)                                      60
          Table 5: Is your business women-owned? (A business is women-
                  owned if it is at least 51 percent owned and controlled by
                  individuals who identify as women.)                                 60
          Table 6: Is your business veteran-owned? (A business is veteran-
                  owned if it is at least 51 percent owned and controlled by
                  one or more veterans.)                                              61
          Table 7: How important was a Main Street loan in helping your
                  business maintain ongoing operations?                               61
          Table 8: How would you rate the process of finding a lender that
                  offered Main Street loans?                                          61
          Table 9: Approximately how many full-time equivalent employees
                  does your business currently have?                                  62

Figures
          Figure 1: Activity Dates of Federal Reserve Lending Facilities
                   Implemented during the COVID-19 Pandemic                            8
          Figure 2: Current and Forward Measures of Spreads on Short-
                   Term Credit, January 2019–July 2021                                18
          Figure 3: Year-Over-Year Commercial Paper Outstanding for
                   Large Nonfinancial Businesses, January 2019–July 2021              19
          Figure 4: Spreads on Corporate Bonds, January 2019–July 2021                21
          Figure 5: Annual Cumulative Issuances of Corporate Bonds,
                   January 2019–July 2021                                             22
          Figure 6: Nonfinancial Corporate Bonds Outstanding, First Quarter
                   2019–Second Quarter 2021                                           23
          Figure 7: Year-Over-Year Corporate Bankruptcy Filings with
                   Liabilities Exceeding $50 Million, January 2019–July
                   2021                                                               24
          Figure 8: The Secondary Market Corporate Credit Facility’s
                   Methodology for Purchasing Corporate Bonds                         26
          Figure 9: Corporate Bonds Purchased by the Secondary Market
                   Corporate Credit Facility, by Sector, as of May 31, 2021           27
          Figure 10: Spreads on Municipal Bonds, January 2019–July 2021               29
          Figure 11: Annual Cumulative Issuances of Municipal Bonds,
                   January 2019–July 2021                                             30



          Page ii                                 GAO-22-104640 Federal Reserve Facilities
Figure 12: Small Businesses’ Views on Credit Conditions, January
        2019–July 2021                                                     34
Figure 13: Banks’ Lending Conditions for Small Business Loans,
        First Quarter 2019–Third Quarter 2021                              36
Figure 14: Loans Made Through the Main Street Lending
        Program, by Loan Size                                              39
Figure 15: Total Dollar Amount Loaned through the Main Street
        Lending Program, by Metropolitan Area                              42
Figure 16: Estimated Participation of Business Types in the Main
        Street Lending Program, Compared to Their
        Representation among U.S. Businesses                               44
Figure 17: Annual Cumulative Triparty Repurchase Agreements of
        Corporate Securities, January 2019–June 2021                       54
Figure 18: Spreads on 90-day Commercial Paper for Large
        Nonfinancial Businesses, January 2019–July 2021                    55
Figure 19: Year-Over-Year Prime Money Market Funds
        Outstanding, January 2019–June 2021                                56
Figure 20: Annual Cumulative Issuances of Asset-Backed
        Securities, January 2019–July 2021                                 57
Figure 21: State and Local Government Bonds Outstanding, First
        Quarter 2019–Second Quarter 2021                                   58
Figure 22: Small Business Loans Outstanding, First Quarter
        2019–First Quarter 2021                                            59




Page iii                               GAO-22-104640 Federal Reserve Facilities
Abbreviations

COVID-19                   Coronavirus Disease 2019
Federal Reserve            Board of Governors of the Federal Reserve System
FRA                        forward rate agreement
LIBOR                      London Interbank Offered Rate
NAICS                      North American Industry Classification System
NFIB                       National Federation of Independent Business
OIS                        overnight indexed swap
RBOPS                      Division of Reserve Bank Operations and Payment
                           Systems
VRDN                       variable rate demand note



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Page iv                                           GAO-22-104640 Federal Reserve Facilities
                       Letter




441 G St. N.W.
Washington, DC 20548




                       October 19, 2021

                       Congressional Committees

                       The Coronavirus Disease 2019 (COVID-19) pandemic resulted in
                       substantial damage to the global economy and affected the stability and
                       functioning of credit markets. In response, from March to September
                       2020, the Board of Governors of the Federal Reserve System (Federal
                       Reserve) authorized 13 emergency lending programs—known as
                       facilities—to ensure the flow of credit to various parts of the economy
                       affected by the pandemic. 1

                       Nine of the facilities received CARES Act-appropriated funds that were
                       intended to support the flow of credit to employers, consumers, small and
                       mid-sized businesses, state and local governments, and nonprofit
                       organizations. 2 We refer to these nine facilities as CARES Act facilities.
                       Additionally, the Federal Reserve established four emergency lending
                       facilities that were not supported through CARES Act-appropriated funds
                       (we refer to these as non-CARES Act facilities), which were intended to
                       serve various markets and credit needs. The CARES Act facilities ceased
                       purchasing assets or extending credit by January 8, 2021. On July 30,
                       2021, the last of the non-CARES Act facilities stopped purchasing assets
                       or extending credit.

                       Although the Federal Reserve’s facilities have stopped purchasing assets
                       or extending credit, some of these facilities continue to hold large
                       amounts of outstanding assets and loans. As of September 1, 2021, the
                       CARES Act-supported facilities had about $19.3 billion in outstanding
                       asset purchases, of which about $13.5 billion were held by the Main
                       Street Lending Program (which targeted small and mid-sized businesses




                       1The facilities are authorized under section 13(3) of the Federal Reserve Act and
                       approved by the Secretary of the Treasury. Section 13(3) of the Federal Reserve Act
                       permits the Federal Reserve to provide emergency lending.
                       2In response to the national public health and economic threats caused by COVID-19,
                       several relief laws have been enacted, including the CARES Act in March 2020. To
                       provide economic relief, section 4003(b)(4) of the act made available at least $454 billion
                       for the Department of the Treasury to support the Federal Reserve in establishing
                       facilities. Pub. L. No. 116-136, § 4003(b)(4), 134 Stat. 281, 470 (2020).




                       Page 1                                             GAO-22-104640 Federal Reserve Facilities
and nonprofit organizations). 3 For the non-CARES Act facilities, as of
August 31, 2021, the Paycheck Protection Program Liquidity Facility—the
facility established to encourage use of the Paycheck Protection
Program—held about $74.8 billion in outstanding loans; the other three
non-CARES Act facilities had repaid all of their loans to the Federal
Reserve Banks. 4 The Federal Reserve will continue monitoring and
managing the facilities until no more assets or loans are outstanding.

Section 4026(f) of the CARES Act contains a provision for us to review
the loans, loan guarantees, and other investments provided under section
4003 of the CARES Act and report annually until 1 year after no
investments made under section 4003 remain outstanding. 5 We
expanded our review to include the Federal Reserve’s facilities not
supported by CARES Act section 4003 because they complete the
Federal Reserve’s full response to the pandemic using its section 13(3)
authority. 6

This report examines (1) why the CARES Act facilities ceased extending
credit and purchasing assets by January 8, 2021; (2) the Federal
Reserve’s oversight and monitoring of the CARES Act facilities; (3) what
available evidence suggests regarding the facilities’ effects on corporate
credit and related markets; (4) what available evidence suggests
regarding the facilities’ effects on states and municipalities, and entities’
experiences in accessing the Municipal Liquidity Facility; and (5) what

3The Main Street Lending Program comprised five facilities: Main Street New Loan
Facility, Main Street Priority Loan Facility, Main Street Expanded Loan Facility, Nonprofit
Organization New Loan Facility, and Nonprofit Organization Expanded Loan Facility.
4Since March 2020, Congress has provided commitment authority of about $814 billion for
the Paycheck Protection Program under the Small Business Administration’s largest
guaranteed loan program—its 7(a) small business lending program. The Paycheck
Protection Program loans, made by lenders but guaranteed 100 percent by the Small
Business Administration, are low interest (1 percent) and fully forgivable if certain
conditions are met, such as using a minimum percentage of the loan forgiveness amount
for payroll costs.
5See GAO, Federal Reserve Lending Programs: Use of CARES Act-Supported Programs
Has Been Limited and Flow of Credit Has Generally Improved, GAO-21-180 (Washington,
D.C.: Dec. 10, 2020).
6We also regularly issue government-wide reports on the federal response to COVID-19.
For the latest report, see GAO, COVID-19: Continued Attention Needed to Enhance
Federal Preparedness, Response, Service Delivery, and Program Integrity, GAO-21-551
(Washington, D.C.: July 19, 2021). Our next government-wide report will be issued in
October 2021, and will be available on GAO’s website at https://www.gao.gov/coronavirus.




Page 2                                             GAO-22-104640 Federal Reserve Facilities
available evidence suggests about trends in small businesses’ access to
credit, and the characteristics of Main Street Lending Program
participants.

To address the first objective, we reviewed Department of the Treasury
and Federal Reserve documentation, including correspondence from the
Treasury Secretary regarding the facilities. We also interviewed Treasury
and Federal Reserve officials.

To address the second objective, we analyzed documentation from the
Federal Reserve’s Division of Reserve Bank Operations and Payment
Systems (RBOPS) and relevant Federal Reserve Banks. This included
their policies and procedures for the monitoring and controls of the
CARES Act facilities and summaries of their completed reviews of the
facilities. We also compared agency controls against selected federal
internal control standards. 7 Additionally, we reviewed the Federal
Reserve’s periodic reports and financial statements for updates on
potential and actual losses incurred by the Federal Reserve facilities.

To address the third, fourth, and fifth objectives, we analyzed the most
recently available data on indicators of credit markets affected by the
facilities. To identify and select potential indicators, we reviewed prior
GAO work, reports and data from the Federal Reserve Board and Federal
Reserve Banks, and reports and data from Bloomberg and the Securities
Industry and Financial Markets Association. For our fourth objective, we
interviewed the three entities (state or local governments or authorities)
that participated in the Municipal Liquidity Facility. We also interviewed
the three additional entities that either filed a notice of intent or
communicated significant interest in accessing the facility but did not
participate in the facility.

For our fifth objective, we analyzed the most recently available survey
data on small business owners and lenders from the National Federation
of Independent Business, the Federal Reserve Board, and the Federal
Reserve Banks. Additionally, we obtained and analyzed relevant Federal
Reserve data to determine characteristics of the Main Street Lending
Program’s participants, their geographic dispersion, the distribution of
loan amounts, and their industry sector. We interviewed associations
representing women- or minority-owned businesses to obtain their


7GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).




Page 3                                        GAO-22-104640 Federal Reserve Facilities
                          perspectives on the Main Street Lending Program. We administered a
                          web-based survey to a sample of for-profit Main Street borrowers. We
                          obtained 266 responses and a survey response rate of 42 percent, and
                          we determined these results to be generalizable to the population of
                          businesses that participated in the Main Street Lending Program. 8

                          For all objectives, where relevant, we also reviewed relevant federal laws
                          and regulations, facilities’ term sheets, and press releases announcing
                          updates to the facilities’ terms.

                          To assess the reliability of the data sources and indicators for the third,
                          fourth, and fifth objectives, we reviewed documentation on data collection
                          methodology and reviewed prior GAO work. We also reviewed the data
                          dictionary for Main Street loan data and performed electronic testing of
                          certain key data fields. We found that, collectively, the indicators were
                          sufficiently reliable for the purposes of providing a general sense of how
                          credit markets have performed and for reporting on Main Street loan data.
                          See appendix I for more information on our scope and methodology,
                          including our survey methodology. See appendix II for data on credit
                          market indicators and appendix III for results of our web-based survey.

                          We conducted this performance audit from November 2020 to October
                          2021 in accordance with generally accepted government auditing
                          standards. Those standards require that we plan and perform the audit to
                          obtain sufficient, appropriate evidence to provide a reasonable basis for
                          our findings and conclusions based on our audit objectives. We believe
                          that the evidence obtained provides a reasonable basis for our findings
                          and conclusions based on our audit objectives.


Background
Overview of the Federal   The Federal Reserve Act established the Federal Reserve System as the
Reserve System and        country’s central bank. 9 The Federal Reserve System consists of three
Emergency Lending         parts: the Board of Governors of the Federal Reserve System, the
Authority


                          8See app. I for more information on our survey methodology.

                          9Federal Reserve Act, Pub. L. No. 63-43, 38 Stat. 251 (1913).




                          Page 4                                           GAO-22-104640 Federal Reserve Facilities
Federal Reserve Banks, and the Federal Open Market Committee. 10 The
Federal Reserve Board is a federal agency located in Washington, D.C.,
that oversees the operations of the Reserve Banks and shares with them
the responsibility for supervising and regulating certain financial
institutions and activities. The Federal Reserve System is divided into 12
districts, and each district is served by a regional Reserve Bank.

The Federal Reserve Board has the authority to authorize the Reserve
Banks to extend credit more broadly than usual during emergencies. 11
Specifically, under section 13(3) of the Federal Reserve Act, during
unusual and exigent circumstances the Federal Reserve can authorize
Reserve Banks to extend credit to a broader range of borrowers. 12

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection
Act added restrictions to the Federal Reserve’s section 13(3) authority. 13
The act required the Federal Reserve Board to, among other things,
implement any future emergency lending through facilities with broad-
based eligibility; required that emergency lending assistance be for the
purpose of providing liquidity to the financial system and not to aid a
failing financial company; and required the approval of the Secretary of
the Treasury prior to establishing a facility. Additionally, the act required
the Federal Reserve Board to promulgate a rule governing the use of
section 13(3) emergency lending authority—which it did on December 18,
2015, by amending Regulation A. 14




10The Federal Open Market Committee consists of the seven members of the Board of
Governors, the President of the Federal Reserve Bank of New York, and four other
Reserve Bank presidents who serve on a rotating basis. The committee is responsible for
directing open market operations to influence the total amount of money and credit
available in the economy.
11Reserve Banks typically lend to banks through discount window programs based on
established statutory criteria. 12 U.S.C. § 347b(a). The discount window is a Federal
Reserve lending program that allows eligible institutions to borrow money, usually on a
short-term basis, at an above-market rate to meet temporary liquidity shortages.
1212 U.S.C. § 343(3). During the 2007–2009 financial crisis, the Federal Reserve invoked
its section 13(3) authority to create emergency programs to stabilize financial markets and
avert the failures of a few individual institutions.
13Pub. L. No. 111-203, § 1101, 121 Stat. 1376, 2113 (2010).

1480 Fed. Reg. 78959, amending 12 C.F.R. Part 201 (Regulation A). Regulation A
governs extensions of credit by Federal Reserve Banks.




Page 5                                            GAO-22-104640 Federal Reserve Facilities
Federal Reserve             In response to the economic disruptions caused by the COVID-19
Emergency Lending           pandemic, the CARES Act authorized at least $454 billion for Treasury to
                            support the Federal Reserve in establishing facilities to provide liquidity to
Facilities in Response to
                            the financial system. With the Secretary of the Treasury’s approval, the
the COVID-19 Pandemic       Federal Reserve used its authority under section 13(3) to authorize 13
                            emergency lending facilities. The Federal Reserve cited a number of
                            factors in determining that unusual and exigent circumstances existed,
                            including disruption in the financial markets, reduced availability of credit,
                            a heightened need for credit, and an increase in business expenditures.

                            Nine of the 13 facilities received support from CARES Act funds:

                            •   Primary Market Corporate Credit Facility and Secondary Market
                                Corporate Credit Facility. These two facilities were designed to
                                support large businesses by purchasing qualifying corporate bonds
                                and other eligible assets, including corporate bond exchange-traded
                                funds.
                            •   Main Street Lending Program. Under this program, five facilities
                                were designed to support small and mid-sized for-profit businesses
                                and nonprofit organizations by purchasing participations in eligible
                                loans. 15
                            •   Municipal Liquidity Facility. This facility was designed to support
                                states, certain counties, municipalities, multistate entities, and
                                revenue bond issuers by purchasing eligible notes that these entities
                                issued.
                            •   Term Asset-Backed Securities Loan Facility. This facility was
                                designed to support the flow of credit consumers and businesses by
                                providing nonrecourse loans to U.S. companies secured by qualifying
                                asset-backed securities generally backed by recently originated
                                consumer and business loans. 16
                            To implement the CARES Act-supported facilities, the Federal Reserve
                            used legal entities known as special purpose vehicles to purchase
                            qualifying assets from, or initiate lending to, eligible entities. In this report,

                            15The Main Street Lending Program comprised five facilities: Main Street New Loan
                            Facility, Main Street Priority Loan Facility, Main Street Expanded Loan Facility, Nonprofit
                            Organization New Loan Facility, and Nonprofit Organization Expanded Loan Facility.
                            16A nonrecourse loan does not allow the lender to pursue anything other than the
                            borrower’s collateral, should the borrower default on a loan. The Term Asset-Backed
                            Securities Loan Facility was previously used during the 2007–2009 financial crisis.




                            Page 6                                             GAO-22-104640 Federal Reserve Facilities
we refer to assets purchased and loans extended by special purpose
vehicles generally as transactions by the CARES Act facilities. 17 The
CARES Act required that the CARES Act facilities purchase obligations
from and make loans to only businesses created or organized in the
United States, and that had significant operations and a majority of
employees in the United States. 18

The five Main Street facilities required borrowers to comply with additional
CARES Act requirements, including limitations on executive
compensation, dividends, and equity buybacks. 19 Overall, the CARES Act
facilities could support up to $1.95 trillion in transaction volume, and
Treasury disbursed $102.5 billion in CARES Act funds to support the
facilities. Over the life of the CARES Act facilities, they conducted about
$41 billion in transactions.

The Federal Reserve, with the Treasury Secretary’s approval, also
established four facilities that did not receive CARES Act-appropriated
funds. 20 These facilities were designed to provide liquidity to the financial
sector and businesses. All four facilities stopped purchasing assets or
extending credit by July 30, 2021 (see fig. 1). The non-CARES Act
facilities include the following:

•   Commercial Paper Funding Facility. This facility served as a
    funding backstop—an alternative funding source for borrowers unable
    to readily obtain credit during economic downturns—to provide
    liquidity for eligible U.S. issuers by purchasing their commercial paper.




17Federal Reserve Banks lent money on a recourse basis to special purpose vehicles that,
in turn, made purchases and loans, as detailed in this report. A recourse loan allows the
lender to pursue the borrower’s assets in the event of a default. Treasury used CARES
Act funds in making equity investments in the special purpose vehicles.
18Pub. L. No. 116-136, § 4003(c)(3)(C), 134 Stat. 281, 473 (2020).

19Pub. L. No. 116-136, §§ 4003, 4004, 134 Stat. 281, 472, 476 (2020).

20The Federal Reserve reinstated three emergency lending facilities that had previously
been used during the 2007–2009 financial crisis: the Commercial Paper Funding Facility,
the Money Market Mutual Fund Liquidity Facility, and the Primary Dealer Credit Facility.




Page 7                                           GAO-22-104640 Federal Reserve Facilities
                                        •   Money Market Mutual Fund Liquidity Facility. This facility assisted
                                            money market funds in meeting redemption demands by making
                                            nonrecourse loans available to eligible financial institutions. 21
                                        •   Paycheck Protection Program Liquidity Facility. This facility
                                            supported institutions’ lending to small businesses under the
                                            Paycheck Protection Program by making loans to eligible institutions
                                            and taking Paycheck Protection Program loans that institutions made
                                            to small businesses as collateral.
                                        •   Primary Dealer Credit Facility. This facility provided support to
                                            primary dealers by making loans in exchange for collateral. 22


Figure 1: Activity Dates of Federal Reserve Lending Facilities Implemented during the COVID-19 Pandemic




                                        The Federal Reserve Banks administered the Federal Reserve’s 13
                                        facilities. The Federal Reserve’s Division of Reserve Bank Operations
                                        and Payment Systems (RBOPS), which oversees the policies and
                                        operations of the Reserve Banks, is primarily responsible for the oversight
                                        of the Federal Reserve’s facilities. To fulfill its responsibilities for

                                        21The Money Market Mutual Fund Liquidity Facility was very similar in structure to the
                                        Asset-Backed Commercial Paper Money Market Mutual Fund Liquidity Facility used
                                        during the 2007–2009 financial crisis, but it accepted a broader range of assets.
                                        22The Primary Dealer Credit Facility differed from the facility used during the 2007–2009
                                        financial crisis, most notably in that it allowed loans up to 90 days, while the earlier version
                                        of the facility offered only overnight loans.




                                        Page 8                                              GAO-22-104640 Federal Reserve Facilities
                       overseeing the facilities on behalf of the Federal Reserve System,
                       RBOPS developed and documented a general framework and approach
                       to oversight, consisting of three phases:

                       •   Phase one. During its initial phase of oversight, RBOPS, through
                           communication with Reserve Bank staff, focused on providing
                           assistance in setting up the various facilities quickly.
                       •   Phase two. As the facilities became operational, RBOPS reviewed
                           the facilities’ established governance structures, process workflows,
                           and internal control design. Its objectives were to help the Reserve
                           Banks identify any enhancements early and obtain reasonable
                           assurance that the design of controls and processes was adequate to
                           ensure the facilities’ effective operation.
                       •   Phase three. Following the completion of phase two reviews, RBOPS
                           plans to maintain ongoing monitoring activities. These include
                           continued communication with Reserve Banks and periodic reviews of
                           facility operations and controls to obtain reasonable assurance that
                           controls are present and are functioning in a manner that addresses
                           identified risks.


                       In the Treasury Secretary’s November 19, 2020, letter to the Federal
CARES Act Facilities   Reserve Chair, the Secretary, citing his understanding of the CARES Act,
Ceased Extending       determined that facilities supported through CARES Act funding could not
                       be extended beyond December 31, 2020. Specifically, the Secretary
Credit and             referred to his understanding of the congressional intent outlined in
Purchasing Assets      Section 4029 of the CARES Act, which specified that the authority
                       provided to the Federal Reserve in the CARES Act to make new loans,
Based on Legal         loan guarantees, and other investments would generally terminate on
Requirements           December 31, 2020. 23 According to Treasury officials, the Treasury Office
                       of the General Counsel at that time examined whether the CARES Act-
                       appropriated funds could support new loans or purchase new assets
                       beyond December 31, 2020, and determined that they could not.

                       In his letter, the Secretary also stated that, in his view, the CARES Act
                       facilities had achieved their objective. As examples, he cited improved
                       financial conditions, including that investment-grade bonds, municipal
                       bonds, and other securities’ spreads (which reflect the premium
                       23Section 4029 of the CARES Act does allow for loans, loan guarantees, and other
                       investments outstanding on December 31, 2020, to be modified, restructured, or otherwise
                       amended after that date, provided that loans or loan guarantees are not extended beyond
                       5 years from their initial origination date.




                       Page 9                                          GAO-22-104640 Federal Reserve Facilities
borrowers pay investors for the risk of loss) had decreased; that bond
issuance volumes had reached or exceeded prepandemic levels; and that
banks had the lending capacity to meet borrowing needs.

Regulation A—which governs emergency lending by the Federal Reserve
and requires the Treasury Secretary’s approval for a facility to be
renewed—does not require that the Federal Reserve consider extending
facilities beyond their current end dates. Instead, Regulation A requires
that the Federal Reserve terminate lending by a facility promptly upon
finding that a facility’s continuation is no longer warranted by market
conditions, which the Federal Reserve is required to review at least every
6 months. 24 In the case of the CARES Act facilities, the Treasury
Secretary’s November 19, 2020, determination meant that the facilities
were set to end on their existing end date of December 31, 2020.
Because Regulation A does not require the Federal Reserve to consider
extending facilities beyond their current end dates, and because the
Secretary’s determination meant he would not approve any extensions,
the Federal Reserve did not need to take any specific action to consider
extending or terminating lending by the facilities. Additionally, because
the Federal Reserve’s prior review of market conditions was within 6
months of the facilities’ end date of December 31, 2020, the Federal
Reserve was not required to perform another periodic review of market
conditions.

The Consolidated Appropriations Act, 2021, which was enacted on
December 27, 2020, codified the December 31, 2020, deadline for the
CARES Act facilities, with the exception of the Main Street facilities, which
it extended until January 8, 2021. According to Federal Reserve officials,
the extension of the Main Street facilities allowed for the processing of
previously submitted applications. The Consolidated Appropriations Act,
2021 also rescinded most of Treasury’s funding for the CARES Act
facilities. In accordance with the act, of the $102.5 billion that Treasury
24Market conditions the Federal Reserve reviews include the existence of unusual and
exigent circumstances, the extent of usage of a facility, the extent to which the continuing
authorization of the program or facility facilitates restoring or sustaining confidence in
relevant financial markets, and the ongoing need for the liquidity support provided by a
facility. If the Federal Reserve’s review finds that a facility should be extended, Regulation
A requires a vote by at least five members of the Federal Reserve Board that unusual and
exigent circumstances exist and that conditions warrant the facility’s continuation, along
with the Treasury Secretary’s approval. For example, in July 2020, the Board determined
that unusual and exigent circumstances continued to exist and that the need for facilities
remained. As a result, the Board, with the Treasury Secretary’s approval, extended all of
the CARES Act facilities set to end in September 2020 through December 31, 2020.




Page 10                                             GAO-22-104640 Federal Reserve Facilities
                              had disbursed to support the facilities, the Federal Reserve returned a
                              little more than $62 billion to Treasury, leaving a little over $40 billion in
                              equity to cover any potential losses the facilities incur. According to
                              Treasury officials, Treasury used returned funds to repay borrowings
                              under the Federal Credit Reform Act, and those funds were deposited in
                              the General Fund. 25


The Federal
Reserve’s Oversight
of Facilities Identified
Improvement
Opportunities and
Focus Areas for
Ongoing Monitoring
Federal Reserve’s             As of December 2020, RBOPS had completed the second phase of its
Reviews of Facilities         three-phase reviews for all facilities. RBOPS’s phase two reviews broadly
                              focused on the facilities’ governance structures and processes and
Identified Opportunities to
                              covered a range of areas related to governance and risk, collateral and
Enhance Processes and         credit management, processes and controls, and accounting and
Controls                      reporting.

                              RBOPS noted opportunities for enhancements in processes and controls
                              for both CARES Act and non-CARES Act facilities and communicated
                              these opportunities to facility management teams at relevant Reserve
                              Banks and the Federal Reserve Board. According to RBOPS’s summary
                              documents, although the reviews identified opportunities for
                              enhancements in certain facilities, the overall finding was that the design
                              of controls and processes was sufficient to provide reasonable assurance
                              that operations are being conducted effectively for each of the facilities.



                              25The Federal Credit Reform Act of 1990 requires agencies to estimate the cost to the
                              government of extending or guaranteeing credit. This cost, referred to as subsidy cost,
                              equals the net present value of estimated cash flows from the government (e.g., loan
                              disbursements and claim payments to lenders) minus estimated cash flows to the
                              government (e.g., loan repayments, interest payments, fees, and recoveries on defaulted
                              loans) over the life of the loan, excluding administrative costs. Treasury borrowed under
                              the Federal Credit Reform Act to support the CARES Act facilities.




                              Page 11                                          GAO-22-104640 Federal Reserve Facilities
                             RBOPS identified several enhancement opportunities in the compliance
                             and governance, internal process and controls, and credit and collateral
                             focus areas. These enhancement opportunities focused primarily on the
                             need to more fully document processes and procedures. RBOPS also
                             noted opportunities to improve a facility’s credit evaluation model and to
                             document facilities’ comprehensive risk assessments. Some of these
                             processes and documentation were not finalized or formalized early on
                             because, according to some Federal Reserve Bank officials, the initial
                             focus was on setting up the facilities expeditiously to provide timely
                             assistance to struggling businesses during the pandemic. The officials
                             said they have begun addressing RBOPS’s opportunities for
                             enhancements. RBOPS plans to follow up on the status of these
                             enhancement opportunities as part of its phase three oversight reviews.

Federal Reserve Identified   As part of RBOPS’s third phase of its oversight framework, it has
Focus Areas for Ongoing      identified internal control focus areas for ongoing monitoring. According to
                             RBOPS’s documentation, the primary purpose of the ongoing monitoring
Monitoring and Plans to
                             is to obtain reasonable assurance that controls are present and
Apply a Risk-Based           functioning in a manner that addresses identified risks at the facilities. In
Approach Tailored to Each    planning phase three’s oversight activities, RBOPS considered the results
Facility                     of previous oversight activities, updated risk assessments, the strategic
                             goals of each facility, and analysis of each facility’s past risk events to
                             identify and tailor particular focus areas for each facility. Additionally,
                             RBOPS plans to periodically reassess operational and risk factors to
                             calibrate facilities’ oversight, as needed.

                             In preparing for its phase three reviews, RBOPS developed a planning
                             document that identifies internal control focus areas for continued
                             monitoring. According to this document, RBOPS will develop detailed
                             work plans for each focus area and will periodically review and update
                             them as necessary. RBOPS identified the focus areas through a
                             combination of top-down and bottom-up approaches, such as using
                             information obtained from prior conversations and interactions with
                             stakeholders (as an example of top-down) and using the results of phase
                             one and phase two activities (as an example of bottom-up). In its planning
                             document, RBOPS identifies nine focus areas for ongoing oversight
                             attention during its phase three reviews (see table 1).




                             Page 12                                   GAO-22-104640 Federal Reserve Facilities
Table 1: Summary of Phase Three Oversight Focus Areas Identified by the Federal Reserve’s Division of Reserve Bank
Operations and Payment Systems

 Focus area                                         Reason for inclusion
 Collateral and asset management                    Management of the underlying collateral, which includes decision-making on matters such as
                                                    asset dispositions, loan modifications, and valuations, will remain important.
 Certifications                                     The certifications Reserve Banks receive from program participants are a key element of the
                                                    banks’ accountability for determining program eligibility and controlling the risk of fraud. The
                                                    Reserve Banks’ procedures for maintaining, monitoring, and validating certifications received
                                                    from program participants should be sufficient to reasonably demonstrate accountability.
 Conflicts of interest                              The Reserve Banks’ policies and controls to prevent and monitor conflicts of interest among
                                                    those charged with managing the programs, including third parties, serve as an important
                                                    element of the Reserve Banks’ accountability by controlling the risk of fraud and protecting the
                                                    public interest that programs be managed for the benefit of taxpayers.
 Risk management                                    The Reserve Banks’ overall risk management program for the facilities is important to
                                                    understanding and responding to risks throughout the life of the programs.
 Vendor management                                  Because many of the programs use third parties to assist in significant aspects of facility
                                                    operations, effective vendor management programs are important to managing the relationships
                                                    over their life cycle from planning through off-boarding.
 Cybersecurity, resiliency, and data                Well-controlled information security and data management are important to mitigating strategic
 management                                         and reputational risk.
 Accounting and reporting                           Accounting policies and data should be appropriately considered and designed in a manner that
                                                    ensures compliance with accounting principles and facilitates financial reporting.
 Information systems, process, and                  Phase two review observations for the information systems, processes, and resources focus
 resources                                          area are consistent with risks and objectives associated with the cybersecurity, resiliency, and
                                                    data management focus area for phase three.
 Internal controls                                  Internal control design and effectiveness are subject to ongoing audit attention from the relevant
                                                    Reserve Banks’ internal audit functions and external auditor.
Source: GAO analysis of documentation from the Board of Governors of the Federal Reserve System (Federal Reserve). | GAO-22-104640



                                                               RBOPS has documented work plans for six of the nine focus areas listed
                                                               above, detailing the methodology for continuous monitoring of each area.
                                                               The three focus areas that RBOPS has not prepared work plans for are
                                                               accounting and reporting; information systems, process, and resources;
                                                               and internal controls. RBOPS has stated that the procedures for these
                                                               three focus areas are either included in other focus areas’ work plan
                                                               procedures or will be carried out by other entities, such as the relevant
                                                               Reserve Banks’ internal and external auditors.

                                                               According to RBOPS’s phase three planning documentation, because of
                                                               limited oversight resources, the work plans will employ a differentiated
                                                               and risk-based approach tailored to risks stemming from each facility.
                                                               Additionally, the approach may include coordinating with a Reserve
                                                               Bank’s internal audit functions and external auditors, and possibly
                                                               engaging third-party expertise.



                                                               Page 13                                                               GAO-22-104640 Federal Reserve Facilities
Our review of each work plan found that the approach was generally
consistent with the phase three planning documentation. Moreover, we
found that facilities with the same focus area risks often had a similar
monitoring approach. For example, the work plan for the collateral and
asset management focus area noted that RBOPS will use the same
approach to oversee third parties that provide collateral services for the
Term Asset-Backed Securities Loan Facility and the Main Street facilities.
Additionally, the work plans also described a general approach to perform
oversight activities that applied to all facilities with similar risk areas
identified in the Phase 2 review. According to the planning documents,
RBOPS will consider the following criteria when determining how to
allocate resources to the focus areas:

•   Direct interest. Consider and prioritize facilities where the Federal
    Reserve Board or RBOPS has a direct role. This includes cases
    where RBOPS has a direct role, such as policy determination, credit
    risk, accounting policy, or financial statement preparation, in contrast
    to an oversight role, such as oversight of vendor management activity
    or information security.
•   Risk level. Consider the residual risk of each possible oversight focus
    area and its impact to the overall program effort to determine
    appropriate RBOPS oversight and participation.
•   Subject-matter expertise. Consider tasks where RBOPS has a high
    level of subject-matter expertise.
•   Commonality. Consider tasks and matters that are common across
    several or all facilities, allowing RBOPS to be in a position to better
    identify and influence the direction of the common issues, as
    compared to entities focused on oversight activities at individual
    facilities.
•   Development. Consider areas where active participation will be
    useful from the perspective of long-term RBOPS staff development.
Throughout the phase three monitoring, RBOPS plans to issue an interim
report every 6 months summarizing the scope of its oversight activities
and findings. The plan also states that RBOPS may periodically change
the timing of the interim report, as approved by internal oversight groups
and advisors. According to RBOPS, any findings or issues identified in
the interim report will be communicated to the relevant facility’s
management team in a timely manner.

Generally, we found that RBOPS’s phase three review plans for ongoing
monitoring of the facilities align with federal internal control standards for


Page 14                                    GAO-22-104640 Federal Reserve Facilities
                          ongoing monitoring of an entity’s internal control system. 26 According to
                          the standards, management should establish and operate monitoring
                          activities to monitor the internal control system and evaluate the results.
                          This includes ongoing monitoring of the design and operating
                          effectiveness of the internal control system as part of the normal course
                          of operations. Further, management should remediate identified internal
                          control deficiencies on a timely basis. To this end, RBOPS’s plans for
                          ongoing monitoring of the facilities include periodic reviews of program
                          operations and controls to obtain reasonable assurance that controls are
                          in place and functioning in a manner that sufficiently addresses identified
                          risks. According to RBOPS officials, plans also include tracking the
                          relevant facilities’ progress in addressing the identified enhancements
                          from RBOPS’s phase two reviews. RBOPS plans to conduct ongoing
                          follow-up on and periodic reporting of facilities’ progress in incorporating
                          the enhancements as part of its phase three reviews.

Main Street Lending       As of June 30, 2021, the Main Street facilities were the only facilities that
Program Has Experienced   had experienced losses. According to Federal Reserve officials, this is
                          because a small number of Main Street borrowers experienced a credit
and Continues to Expect
                          event, such as a bankruptcy. These credit events have resulted in a
Some Losses, but These    recognized loss of about $4 million to the Main Street facilities.
Are Offset by CARES Act
Funds                     Regulations governing the Federal Reserve’s emergency lending
                          authority require that loans be secured to the satisfaction of the Federal
                          Reserve Bank making the loan. Losses in the Main Street Lending
                          Program are covered first by fees charged and interest earned in the
                          facility, and then by about $16.6 billion in funds that Treasury made
                          available under the CARES Act to support the Main Street facilities. In its
                          periodic reports to Congress, the Federal Reserve continues to state that
                          losses in the Main Street Lending Program will not result in any losses to
                          the Federal Reserve.

                          In addition to current losses, the Federal Reserve has also recorded a
                          loss allowance in anticipation of future losses from the Main Street
                          Lending Program. As of June 30, 2021, the Federal Reserve had
                          recorded a loan loss allowance of about $2.5 billion, which comprises
                          $1.27 billion in specific loss allowance and $1.26 billion in general loss




                          26GAO-14-704G.




                          Page 15                                    GAO-22-104640 Federal Reserve Facilities
Specific loss allowance. To generate the                   allowance, according to Federal Reserve officials (see sidebar).
specific loan loss allowance, the Federal                  Borrowers under the Main Street Lending Program are required to report
Reserve Bank of Boston evaluates loans with
an outstanding balance of $15 million or
                                                           certain financial data to their lender quarterly, and additional information
greater that fail to meet certain criteria related         annually. 27 The Federal Reserve also analyzes all of the CARES Act
to loan performance or credit rating to
determine if it is likely the borrower will not
                                                           facilities quarterly to determine if it is necessary to set aside an allowance
repay all of the principal and interest.                   for potential loan losses in accordance with generally accepted
If it is determined that a loss is likely, the Main        accounting principles. 28 As of March 31, 2021, only the Main Street
Street facilities recognize a specific loan loss           Lending Program anticipated probable losses.
allowance for that loan. As of June 30, 2021,
according to Federal Reserve officials, the total
amount of the specific loan loss allowance for
all such loans amounted to $1.27 billion.
General loss allowance. A loan may be
subject to the general allowance either
because the borrower is expected to repay all
of the principal and interest, or because the
balance of the loan is below the threshold for
the specific loan loss allowance. The general
loan loss allowance takes into account the
probability that some portion of a pool of loans
will default and the losses that would be
incurred if loans were to default, applied to the
outstanding principal of the pool of loans. As of
June 30, 2021, according to Federal Reserve
officials, the general loan loss allowance
amounted to $1.26 billion.
Source: Board of Governors of the Federal Reserve System
(Federal Reserve) documents. | GAO-22-104640



                                                           The Federal Reserve implemented emergency lending facilities to
Corporate Credit                                           mitigate disruptions in corporate credit markets as a result of the COVID-
Market Risks Have                                          19 pandemic. 29 We found that since mid-2020, credit risks in short-term
                                                           corporate credit markets have declined and remain low relative to
Remained Low since                                         prepandemic levels, corporate bond issuances have increased, and
Mid-2020, but
Longer-Term
Uncertainties Remain
                                                           27For instance, borrowers are required to report total assets, total liabilities, and total
                                                           revenue both annually and quarterly.
                                                           28The loan loss allowance does not represent incurred losses in the program—instead, it
                                                           is an estimate of probable losses.
                                                           29The Federal Reserve established the following facilities to primarily support large
                                                           businesses: Primary Dealer Credit Facility; Money Market Mutual Fund Liquidity Facility;
                                                           Commercial Paper Funding Facility; Secondary Market Corporate Credit Facility; Term
                                                           Asset-Backed Securities Loan Facility; and Primary Market Corporate Credit Facility.




                                                           Page 16                                              GAO-22-104640 Federal Reserve Facilities
                          outstanding bond balances have grown. 30 In addition, sectors hard hit by
                          the pandemic have experienced lower bankruptcy filings in 2021 relative
                          to 2020, but vulnerabilities remain in the corporate bond market. Although
                          it is difficult to completely isolate the impact of the corporate credit
                          facilities, they likely have contributed to restoring confidence among
                          market participants through the announcement of the facilities, purchases
                          of securities, and provision of a funding backstop. 31

Short-Term Corporate      Short-term market functioning—targeted by the Commercial Paper
Credit Risks Have         Funding Facility, the Money Market Mutual Fund Liquidity Facility, and the
                          Primary Dealer Credit Facility—allow companies to borrow to meet their
Remained Low since Mid-
                          immediate costs, such as making payroll, without the need to keep cash
2020, but Outstanding     on hand at any given moment. 32 Since our prior report in December 2020,
Balances Are Lower Than   credit risks in short-term corporate credit markets have continued to
Prepandemic Levels        remain low. Specifically, market metrics, including widely used measures
                          of the level of stress in the banking system, suggest that short-term credit
                          risks have decreased to prepandemic levels since June 2020. For
                          example, the forward rate agreement-overnight indexed swap (FRA-OIS)
                          spread and the TED spread—which provide a snapshot of how the
                          market views short-term credit conditions—suggest that credit risks have




                          30This report analyzed data that were available through July 2021. Our prior Federal
                          Reserve facilities report, which was issued in December 2020, analyzed data that were
                          available through September 2020. See GAO-21-180.
                          31See, for example, Nina Boyarchenko, Anna Kovner, and Or Shachar, It’s What You Say
                          and What You Buy: A Holistic Evaluation of the Corporate Credit Facilities, Federal
                          Reserve Bank of New York Staff Reports, no. 935 (July 2020). See also Simon Gilchrist et
                          al., “The Fed Takes on Corporate Credit Risk: An Analysis of the Efficacy of the SMCCF,”
                          working paper no. 27809 (National Bureau of Economic Research, September 2020),
                          accessed August 4, 2021, http://www.nber.org/papers/w27809. It is difficult to isolate the
                          impact of the facilities because the Federal Reserve also took a number of other actions in
                          response to market disruptions resulting from the COVID-19 pandemic, which included
                          regulatory and monetary policy actions that supported the flow of credit to households,
                          businesses, and the U.S. economy. See GAO-21-180.
                          32Short-term market functioning includes credit risks, liquidity risks, and market
                          intermediation.




                          Page 17                                            GAO-22-104640 Federal Reserve Facilities
                                       eased because the narrower the spreads, the lower the stress in financial
                                       markets (see fig. 2). 33

Figure 2: Current and Forward Measures of Spreads on Short-Term Credit, January 2019–July 2021




                                       Note: The FRA-OIS spread is the difference between a 3-month forward rate agreement (FRA) and a
                                       3-month overnight indexed swap (OIS). The TED spread is the difference between the 3-month
                                       London Interbank Offered Rate (LIBOR) based on U.S. dollars and the 3-month Treasury bill. A basis
                                       point is 1/100th of a percentage point.




                                       33Spreads are the difference in yields between a security (such as a commercial paper)
                                       and a safer asset (such as a Treasury security) with similar timing of interest and principal
                                       payments. Spreads measure the premium investors require to hold assets that are
                                       relatively riskier than safe assets. The FRA-OIS spread is the difference between a 3-
                                       month forward rate agreement (FRA) and a 3-month overnight indexed swap (OIS). The
                                       TED spread is the difference between the 3-month London Interbank Offered Rate
                                       (LIBOR) based on U.S. dollars and the 3-month Treasury bill.




                                       Page 18                                               GAO-22-104640 Federal Reserve Facilities
                                                 However, trends of issuances and outstanding balances among
Commercial Paper
                                                 commercial paper and money market funds have not recovered to
Commercial paper is short-term debt issued
primarily by corporations. The commercial
                                                 prepandemic levels (see sidebar for an explanation of commercial paper
paper market is an important source of short-    and prime money market mutual funds). 34 For example, issuances and
term credit for a range of financial and
nonfinancial businesses that may rely on it to
                                                 outstanding balances of commercial paper have decreased and are still
make payroll or for other short-term funding     lower than prepandemic levels (see fig. 3). Outstanding balances of prime
needs. Municipalities can also issue             money market funds have also decreased and were below prepandemic
commercial paper for short-term funding
needs, and asset-backed commercial paper         levels as of June 2021.
finances certain consumer loans, such as
auto loans. Because commercial paper
involves short maturities, many businesses       Figure 3: Year-Over-Year Commercial Paper Outstanding for Large Nonfinancial
must frequently issue new commercial paper       Businesses, January 2019–July 2021
to pay off expiring commercial paper.
Prime Money Market Funds
A money market fund is a type of mutual fund
that is required by law to invest in low-risk
securities. Money market funds act as
intermediaries between investors seeking
highly liquid, safe investments and corporate
and government entities that issue short-term
debt to fund operations. Prime money market
funds, one category of money market funds,
primarily invest in short-term corporate and
bank debt such as commercial paper, though
they may also hold U.S. government-backed
securities such as U.S. Treasury securities.
Source: GAO. | GAO-22-104640




                                                 Note: The data in this figure are for domestic nonfinancial commercial paper.


                                                 The reduced issuances and outstanding balances in the short-term credit
                                                 markets may indicate that businesses have shifted away from short-term
                                                 financing in favor of longer-term financing in the corporate bond market.
                                                 In particular, debt has grown in the corporate bond market as companies
                                                 increased their borrowing and refinanced their debt at low interest rates



                                                 34See app. II for information on the commercial paper market, prime money market, and
                                                 repurchase agreement market.




                                                 Page 19                                                 GAO-22-104640 Federal Reserve Facilities
                                                  and at longer maturities (as discussed later in this report). 35 This trend
                                                  could adversely affect the sustainability of short-term corporate credit
                                                  markets over time if the market becomes less liquid because a less liquid
                                                  market is likely to be more volatile.

Corporate Bond Market                             The corporate bond market—which allows companies to issue debt
Debt Remains Elevated,                            instruments to raise money to support continuing operations, including
                                                  employment and other activities such as investment and growth plans—
but Bankruptcy Filings
                                                  was targeted by the Primary Market Corporate Credit Facility and the
Have Declined from 2020                           Secondary Market Corporate Credit Facility.
Levels

Spreads on Corporate Bonds                        Since our prior report in December 2020, credit risks in the corporate
                                                  bond market have remained low (see sidebar for an explanation of
Corporate Bonds                                   corporate bonds). Specifically, spreads on both investment grade and
In the corporate bond market, large               non-investment-grade corporate bonds have remained low since the
companies issue and sell bonds to investors
in exchange for cash. Bond investors function     second half of 2020 (see fig. 4). 36 The facilities likely lowered corporate
as lenders that generally receive payments of     credit spreads through various means. Specifically, the announcements
principal plus interest over a period of time.
The borrowing cost and liquidity for
                                                  of the facilities may have improved confidence in the corporate bond
companies that issue corporate bonds are          market, thereby reducing the credit risk and the premium investors
largely determined by credit ratings, which are   require for taking on that risk. Also, the facilities’ presence served as a
assigned by credit rating agencies and are
intended to indicate the companies’               backstop and may have increased dealers’ willingness to trade the
investment risks and payment capabilities.        eligible securities. Lastly, the facilities’ transactions purchasing eligible
Bonds rated above a certain threshold are
called investment grade bonds.                    debt securities may have helped increase liquidity in the markets, thereby
Source: GAO. | GAO-22-104640                      benefitting market participants.




                                                  35See app. II for more information on short-term funding and credit risk, including spreads
                                                  on the 90-day commercial paper market and outstanding balances of prime money market
                                                  funds.
                                                  36The Primary Market Corporate Credit Facility and the Secondary Market Corporate
                                                  Credit Facility expired on December 31, 2020. The Primary Market Corporate Credit
                                                  Facility did not conduct any transactions.




                                                  Page 20                                           GAO-22-104640 Federal Reserve Facilities
Figure 4: Spreads on Corporate Bonds, January 2019–July 2021




                                       Note: Data represent option-adjusted spreads on dollar-denominated investment-grade and non-
                                       investment-grade bonds. A basis point is 1/100th of a percentage point.


                                       On June 2, 2021, the Federal Reserve Bank of New York announced that
                                       the Secondary Market Corporate Credit Facility would begin sales of its
                                       holdings of corporate bond exchange-traded funds on June 7, 2021. On
                                       July 8, 2021, the Reserve Bank announced that the facility also would
                                       begin sales of its corporate bond holdings on July 12, 2021. The
                                       announcements had little impact on the corporate bond market, possibly
                                       because the amount of the facility’s purchases was a small portion of the
                                       overall volume of the corporate bond market. 37 As of September 1, 2021,
                                       all of the facility’s holdings in exchange-traded funds and corporate bonds
                                       had either matured or been sold.

Corporate Bond Issuances and           Bond issuances are increasing and remain higher than prepandemic
Outstanding Debt                       levels, especially issuances of non-investment-grade bonds, which may
                                       also reflect that businesses have shifted from short-term debt in favor of
                                       long-term debt, as previously discussed (see fig. 5).


                                       37As of June 30, 2021, the outstanding asset purchases under the corporate credit
                                       facilities were $10.2 billion, while the outstanding balances in the corporate bond market
                                       were $6.6 trillion.




                                       Page 21                                              GAO-22-104640 Federal Reserve Facilities
Figure 5: Annual Cumulative Issuances of Corporate Bonds, January 2019–July
2021




Note: The issuances in this figure are for investment grade and non-investment-grade bonds. The
figure excludes all issuances with maturities of 1 year or less and certificates of deposit.


The large increase in the issuances of corporate bonds has occurred as
companies have built large cash positions to take advantage of low
interest rates and longer maturities, a situation that has been especially
advantageous for companies with lower-quality ratings. Issuances of both
investment grade and non-investment-grade bonds have increased as
these securities have been issued at lower interest rates, meaning it has
been cheaper for companies to borrow. 38

Corporate bonds outstanding remain elevated partly because of the
record issuances, and bankruptcy filings were higher in 2020 since the
onset of the pandemic compared to 2019 levels, but generally were lower
in 2021 compared to 2020 levels, especially in the service sector and
other sectors hard-hit by the pandemic (see figs. 6 and 7). Sectors with

38In addition, the number of “rising stars” (companies promoted to investment grade from
non-investment grade) outpacing the number of “fallen angels” (companies downgraded
from investment grade to non-investment grade) may have also increased issuances.
App. II provides information on issuances of asset-backed securities—a long-term debt
instrument intended to support provision of credit to households and businesses.




Page 22                                               GAO-22-104640 Federal Reserve Facilities
the most bankruptcies as of May 2021 were consumer discretionary
(including restaurants), energy (including exploration and production), and
real estate (including real estate services). Economic activity in these
sectors was adversely affected by the repercussions of policies to
mitigate the pandemic. The bankruptcy filings reflect defaults by
companies that probably could not refinance their corporate bond debt as
their revenues declined or the assets they own fell in value. The high level
of outstanding debt leaves businesses vulnerable to distress if it becomes
difficult to make repayments on their debt.

Figure 6: Nonfinancial Corporate Bonds Outstanding, First Quarter 2019–Second
Quarter 2021




Page 23                                     GAO-22-104640 Federal Reserve Facilities
                            Figure 7: Year-Over-Year Corporate Bankruptcy Filings with Liabilities Exceeding
                            $50 Million, January 2019–July 2021




                            Note: Bloomberg’s bankruptcy coverage is limited to public companies or private companies with
                            liabilities at the time of the bankruptcy filing greater than $50 million. The filings are for Chapter 7 or
                            Chapter 11 bankruptcies. Data were accessed on August 11, 2021.


Secondary Market            The Federal Reserve established the Secondary Market Corporate Credit
Corporate Credit Facility   Facility to support the availability of credit to large employers during the
                            COVID-19 pandemic. The facility purchased a percentage of average
Held a Diverse Mix of
                            daily volumes in the markets for corporate bonds, exchange-traded funds,
Corporate Bonds That        or both based on an assessment of credit markets. Specifically, according
Tracked a Broad Market      to Federal Reserve documentation, the Federal Reserve Bank of New
Index                       York assessed indicators of the health of credit markets daily to
                            determine how much in corporate bonds and exchange-traded funds the
                            facility should purchase. 39 For exchange-traded funds, the Federal
                            Reserve Bank of New York also used indicators specific to that market,
                            such as premium or discount to net asset value—that is, the difference
                            between the net value of the assets in the fund and the assets’ current
                            market price. The facility purchased a lower percentage if the indicators
                            showed that credit markets were improving, and purchased a higher

                            39Indicators used by the Federal Reserve Bank of New York, but were not limited to,
                            transaction cost estimates, bid-ask spreads, credit curve shape, credit curve shape,
                            spread levels and volatility, trading volumes, and dealer inventories.




                            Page 24                                                     GAO-22-104640 Federal Reserve Facilities
percentage if the indicators showed the markets were deteriorating
compared to prepandemic levels.

When the facility began purchasing assets on May 12, 2020, it purchased
exchange-traded funds that provided broad exposure to the U.S.
corporate bond market. According to Federal Reserve officials, it did so to
achieve its goals as quickly as possible. On June 16, 2020, the facility
began purchasing individual corporate bonds, and it gradually tapered its
purchases of exchange-traded funds to zero.

According to Federal Reserve documentation, for its individual corporate
bond purchases, the facility did not choose which specific bonds to
purchase. Instead, the Federal Reserve Bank of New York created a
Broad Market Index—which tracked the economic sectors of all corporate
bonds eligible for purchase by the facility—and purchased eligible bonds
in the secondary market in proportions that roughly mirrored the makeup
of the index. The Broad Market Index was recalculated every 4 to 5
weeks, and bond purchases by the facility were designed so that the
weight of each economic sector in the facility’s portfolio tracked as closely
as possible to the index’s economic sector weights (see fig. 8).




Page 25                                   GAO-22-104640 Federal Reserve Facilities
Figure 8: The Secondary Market Corporate Credit Facility’s Methodology for Purchasing Corporate Bonds




                                        Note: Not all corporate bonds were eligible for purchase by the facility, including bonds issued by
                                        companies not organized or created in the United States; bonds issued by banks, credit unions, or
                                        other institutions insured under the Federal Deposit Insurance Act; and bonds with a remaining
                                        maturity of more than 5 years.


                                        In addition, the facilities imposed maximum purchase limits on each
                                        company’s bonds. The combined holdings of the Primary Market
                                        Corporate Credit Facility and the Secondary Market Corporate Credit
                                        Facility could not exceed the lesser of

                                        •    10 percent of the issuer’s maximum outstanding bonds on any day
                                             from March 22, 2019, to March 22, 2020, or
                                        •    $11.25 billion, which is 1.5 percent of the combined potential $750
                                             billion size of the Primary Market Corporate Credit Facility and
                                             Secondary Market Corporate Credit Facility collectively.
                                        Over time, as markets improved, the Federal Reserve Bank of New York
                                        reduced the facility’s purchases. Of the $14.3 billion in asset purchases


                                        Page 26                                                 GAO-22-104640 Federal Reserve Facilities
made by the facility, over $10 billion were made over a 2-month period,
from mid-May to mid-July 2020.

As of December 31, 2020, when the Secondary Market Corporate Credit
Facility ceased purchasing assets, it held exchange-traded funds with a
market value of about $8.8 billion and corporate bonds with a par value of
about $5.2 billion. 40 As previously mentioned, as of September 1, 2021,
all of the facility’s holdings in exchange-traded funds and corporate bonds
had either matured or been sold.

Our review of Federal Reserve Bank of New York documents and data
showed that Secondary Market Corporate Credit Facility corporate bond
purchases represented a broad, diversified market index of U.S.
corporate bonds (see fig. 9).

Figure 9: Corporate Bonds Purchased by the Secondary Market Corporate Credit
Facility, by Sector, as of May 31, 2021




Note: Positions reflect bonds purchased through December 31, 2020, and redemptions, exchanges,
or maturities for which proceeds were received on or prior to May 31, 2021. The Secondary Market
Corporate Credit Facility began selling its corporate bond holdings on July 12, 2021.



40Par value, or face value, generally indicates the principal value of the bond which is paid
to the holder at maturity. Market value is the amount that a security can be sold for to
another willing buyer.




Page 27                                              GAO-22-104640 Federal Reserve Facilities
                          a
                           Noncyclical consumer goods are those associated with food production or other goods for which
                          consumer demand continues regardless of the overall economy.
                          b
                           Par value, or face value, generally indicates the principal value of the bond which is paid to the
                          holder at maturity.


                          The Federal Reserve established the Municipal Liquidity Facility to
Municipal Credit          specifically address deteriorating conditions in municipal credit markets.
Market Outlook            We found that since mid-2020, spreads on municipal bonds have
                          decreased to prepandemic levels and issuances have increased
Remains Uncertain,        slightly. 41 Although it is difficult to isolate the impact of the municipal credit
and Participants          facility, it likely has contributed to restoring confidence among market
                          participants through the announcement of intent to provide credit and
Found the Municipal       through the provision of a backstop in the municipal credit markets. 42
Liquidity Facility
Beneficial
Municipal Credit          Since our last report in December 2020, spreads on municipal bonds
Borrowing Costs Have      have decreased considerably, reaching prepandemic levels in January
                          2021 and falling further since then (see fig. 10). 43 This trend suggests that
Decreased to
                          perceived risk among municipal issuers has continued to fall, and that
Prepandemic Levels, but   state and local governments’ access to credit has continued to increase.
Market Outlook Is         Rates for variable rate demand notes—an asset in municipal money
Uncertain                 market funds—have also decreased, but their outstanding balances have
                          declined compared to prepandemic levels. See appendix II for more
                          information on variable rate demand notes.




                          41This report analyzed data that were available through July 2021. Our prior Federal
                          Reserve facilities report, which was issued in December 2020, analyzed data that were
                          available through September 2020. See GAO-21-180.
                          42See, for example, Nicholas Fritsch, John Bagley, and Shawn Nee, “Municipal Markets
                          and the Municipal Liquidity Facility,” Federal Reserve Bank of Cleveland, working paper
                          no. 21-07 (March 2021), accessed August 4, 2021, https://doi.org/10.26509/frbc-wp-
                          202107.
                          43Municipal bonds can be classified as either general obligation bonds or revenue bonds.
                          General obligation bonds are backed by general revenues of the issuing municipality,
                          while revenue bonds are repaid from the revenue generated by the specific project the
                          bonds paid for, such as income from a toll road.




                          Page 28                                                   GAO-22-104640 Federal Reserve Facilities
Figure 10: Spreads on Municipal Bonds, January 2019–July 2021




                                       Note: Spreads on municipal bonds are calculated relative to interest rates on Treasury 10-year yield
                                       based on the Bloomberg-Barclays Municipal Bond Index and are measured in basis points or 1/100th
                                       of a percentage point.


                                       Municipal bond issuances have increased to slightly higher than
                                       prepandemic levels (see fig. 11). 44 For example, issuances in 2021 have
                                       been slightly higher than 2020 levels, which were higher than
                                       prepandemic levels. (See app. II for information on state and local
                                       municipal bonds outstanding.) The increase in issuances, combined with
                                       the reduced spreads on municipal bonds, suggests credit risk concerns
                                       about issuers’ ability to service their bonds have eased. However, the
                                       longer-term outlook for the municipal bond market is uncertain, partly
                                       because of concerns that the slowing rate of vaccinations and the spread
                                       of new virus variants could result in the reinstatement of pandemic-related
                                       restrictions. Such restrictions could adversely affect local economic
                                       conditions, raising concerns about the ability of municipal bond issuers to
                                       service their debt. Further, the potential for additional federal support to
                                       help state and local governments manage loss of tax revenues and
                                       increased expenditures remains unknown.


                                       44The Municipal Liquidity Facility ceased purchasing eligible notes on December 31, 2020,
                                       and as of September 1, 2021, the outstanding amount of assets was $4.4 billion.




                                       Page 29                                                GAO-22-104640 Federal Reserve Facilities
                               Figure 11: Annual Cumulative Issuances of Municipal Bonds, January 2019–July
                               2021




                               Note: The issuances in this figure include private placements—transactions where a broker-dealer
                               sells the entire municipal bond placement to one of its clients. All issuance figures are based on deals
                               with a maturity of 13 months or greater. The average final maturity at issuance was 18.2 years, 17.4
                               years, and 17.3 years in 2019, 2020, and 2021, respectively.


Entities That Explored or      Even though the Municipal Liquidity Facility had limited usage, the six
Participated in the            state and local entities that used or explored using the facility said it was
                               beneficial as a backstop to the municipal credit market. 45 Officials from
Municipal Liquidity Facility
                               these six entities—of which three used the facility and three explored
Found It Beneficial as a       using it—told us the facility helped stabilize and restore investor
Municipal Credit Market        confidence in the municipal bond market, which made it less costly to
Backstop                       issue municipal bonds and, in turn, reduced the need for states and
                               localities to access the facility. Officials from five of the six entities said
                               the municipal credit market has recovered since the onset of the
                               pandemic. However, officials from four of the six entities stated that a
                               backstop would continue to help ensure the functioning of the municipal
                               bond market.




                               45We refer to state governments, county governments, and transit authorities as “state
                               and local entities.”




                               Page 30                                                  GAO-22-104640 Federal Reserve Facilities
According to officials from the state and local entities that participated or
explored participating in the Municipal Liquidity Facility, they generally did
so to mitigate budget shortfalls caused by the COVID-19 pandemic. For
example, officials from three of the entities said that the pandemic caused
temporary closures of shops, restaurants, and other businesses, reducing
revenues from sales tax, fees, and mass transit fares. In addition, officials
from two states told us that the extension of the 2019 federal tax-filing
deadline from April 15 to July 15, 2020, delayed state-tax revenue
receipts for states that also changed their state-tax filing deadline to
match the federal deadline.

The Municipal Liquidity Facility offered two options for participation:
borrowing directly from the facility (by selling bonds to it) or using the
facility as a backstop when issuing bonds. 46

•   In total, the facility conducted four transactions with two entities that
    borrowed directly, totaling almost $6.6 billion, with each entity selling
    bonds to the facility twice. 47
•   The facility served as a backstop for one entity (a county
    government). Officials from the county told us they issued notes twice
    in the municipal bond market and the notes were purchased by
    investors other than the Municipal Liquidity Facility.
We also identified three other state and local entities that explored
participating in the facility but that ultimately did not do so. Specifically, of
the three entities, Federal Reserve officials told us that one county
government and one mass transit entity each filed a notice of intent to
participate in the facility, and the third entity—a state—did not file a notice
of intent.

Officials from the three state and local entities that participated in the
Municipal Liquidity Facility cited various reasons for choosing the facility
over other borrowing options. For example, one entity chose to participate
in the facility because short-term borrowing costs in the municipal bond
market were too high, and the entity rejected private bids to purchase its
bond issuances. Another entity was uncertain of its ability to sell its
bonds, which it needed to do to avoid insolvency, and the facility provided
a guaranteed source of borrowing. Officials from the third entity told us
46When serving as a backstop, the facility agreed to purchase eligible bonds that were not
purchased by other buyers in a competitive sale.
47The two participants that participated in the Municipal Liquidity Facility are the State of
Illinois and the New York Metropolitan Transportation Authority.




Page 31                                             GAO-22-104640 Federal Reserve Facilities
the facility helped it maintain its investment-grade credit rating. Officials
from one entity also cited as a benefit the ability to prepay debt borrowed
through the facility (which would reduce interest payments). Officials from
two entities also told us that Federal Reserve staff were collaborative and
helpful in facilitating their participation in the facility.

Officials from the three entities that explored but did not participate in the
Municipal Liquidity Facility cited several reasons for choosing other
financing options. 48 Officials from one entity told us they did not
participate because they were able to obtain lower rates in the municipal
bond market. Officials from the other two entities told us their states’ legal
requirements and restrictions made participation in the facility
challenging. For example, officials from a transit agency told us that their
state generally limited loans to a term of 1 year. This was a relatively
short time frame for loan repayment given the pandemic’s uncertainty.

Overall, the six entities that participated or explored participating in the
facility cited three enhancements they believe would have encouraged
greater access and participation in the Municipal Liquidity Facility:

•   Lower interest rates. Regulation A requires a facility to charge a
    premium interest rate (under normal circumstances) to discourage
    borrowing from the facility as economic conditions normalize, but it
    also requires the rate to be set at a level that affords liquidity in
    unusual and exigent market conditions. 49 Officials from four of the six
    entities said the facility’s interest rates discouraged participation.
•   Longer term limits. The facility’s term sheet set a bond maturity term
    of 3 years. Officials from four of the six entities said the 3-year term
    discouraged borrowing. According to two of these entities, that time
    frame was not long enough for states and municipalities to be certain
    of their ability to repay the debt.


48Officials from the three entities that explored but did not participate in the Municipal
Liquidity Facility said other financing options included borrowing in the municipal bond
market, sale and leaseback of equipment, assistance from local and regional
governments, and creating a consolidated revenue credit.
49Regulation A specifically requires that facilities set interest rates that are at a premium to
the market rate available under normal circumstances; afford liquidity in unusual and
exigent circumstances; and encourage repayment of the credit and discourage use of the
program or facility as the unusual and exigent circumstances that motivated the program
or facility recede and economic conditions normalize.




Page 32                                             GAO-22-104640 Federal Reserve Facilities
                       •   Expanded participation eligibility. Entities eligible to participate in
                           the facility included cities and counties that met a population threshold
                           (at least 250,000 and 500,000 residents, respectively), states, and
                           multistate entities. Other entities, such as certain mass transit
                           agencies or certain cities and counties below the population threshold,
                           could participate, but only by obtaining a designation from their state’s
                           governor allowing them to do so. 50 Officials from three of the six
                           entities we spoke with said the population thresholds and the
                           requirement and associated steps to obtain a governor’s designation
                           made the facility more difficult to use.


                       The Federal Reserve took measures to support the flow of credit to small
Small Businesses’      businesses that were vulnerable to large and sustained loss of revenue
Access to Credit Has   due to the COVID-19 pandemic. 51 We found that starting from the third
                       quarter of 2020, small businesses’ access to credit generally improved,
Improved, and the      but recovery of small businesses remains slow, especially for businesses
Main Street Loans      owned by Asian, Black, or Hispanic people and businesses in the
                       services sector. 52 According to our generalizable survey, about 88
Were Concentrated in   percent of borrowers in the Main Street Lending Program reported that
Certain Sectors        the program was “very important” in helping them maintain operations.
                       According to Federal Reserve Bank of Boston data, borrowers in the Main
                       Street Lending Program were concentrated in certain economic sectors,
                       such as the food services and drinking places sector, and Main Street
                       loans were concentrated in certain metropolitan areas, such as Miami,
                       Dallas, and Los Angeles. According to our generalizable survey, women-
                       owned businesses were underrepresented in the Main Street Lending

                       50The Municipal Liquidity Facility was designed to support lending to U.S. states (including
                       the District of Columbia), U.S. counties with a population of at least 500,000 residents,
                       U.S. cities with a population of at least 250,000 residents, and certain multistate entities.
                       The facility’s terms provided states’ governors flexibilities to designate additional entities
                       for participation, such as mass transit agencies that issue revenue bonds and certain
                       smaller cities and counties, for states specified in the facility’s term sheet.
                       51The Federal Reserve established the following facilities to support primarily small for-
                       profit businesses: the Paycheck Protection Program Liquidity Facility and the Main Street
                       New Loan Facility, Main Street Priority Loan Facility, and Main Street Expanded Loan
                       Facility. As of September 1, 2021, the total outstanding amount of all advances under the
                       Paycheck Protection Program Liquidity Facility was $74.4 billion. The Main Street Lending
                       facilities ceased purchasing participations in eligible loans on January 8, 2021, and the
                       total value of the assets held by the facility was $13.5 billion as of September 1, 2021.
                       This amount is net of the $2.5 billion allowance for loan losses previously discussed.
                       52This report analyzed data that were available through July 2021. Our prior Federal
                       Reserve facilities report, which was issued in December 2020, analyzed data that were
                       available through September 2020. See GAO-21-180.




                       Page 33                                              GAO-22-104640 Federal Reserve Facilities
                              Program, compared to their representation among U.S. businesses as a
                              whole.

Small Businesses’ Access      Based on recent survey results, business owners’ views of lending
to Credit Generally Started   conditions for small businesses suggest that credit terms generally
                              started to improve in the third quarter of 2020. For example, according to
to Improve in the Third
                              surveys of the small and independent business owner membership of the
Quarter of 2020, but          National Federation of Independent Business, small businesses’ views on
Recovery Remains Slow         credit conditions started to improve in outlook in the third quarter of 2020.
                              However, the survey results also indicated that the views of small
                              business owners regarding their borrowing needs have generally
                              remained the same (see fig. 12).

                              Figure 12: Small Businesses’ Views on Credit Conditions, January 2019–July 2021




                              Note: Data are based on quarterly surveys of a sample of the membership of the National Federation
                              of Independent Business. Borrowing needs satisfied reflects the net percentage (“satisfied” minus
                              “not satisfied”) of borrowers in the last 3 months. Expected credit conditions reflects the net
                              percentage (“easier” minus “harder”) of borrowers during the next 3 months. The data are copyright of
                              the National Federation of Independent Business (NFIB) Research Center. © NFIB Research Center.
                              ISBS#0940791-24-2, NFIB Small Business Economic Trends, William C. Dunkelberg and Holly
                              Wade, July 2021. The Main Street for-profit lending facilities consist of the Main Street New Loan
                              Facility, the Main Street Expanded Loan Facility, and the Main Street Priority Loan Facility (which was
                              announced on April 30, 2020).




                              Page 34                                                 GAO-22-104640 Federal Reserve Facilities
According to the Federal Reserve’s Senior Loan Officer Opinion Survey,
survey responses on banks’ lending conditions for small business loans
suggest that credit terms have continued to improve since the third
quarter of 2020. Specifically, survey responses reflect that banks’
underwriting standards have loosened. Underwriting standards on small
business loans measure the selectivity of lenders in determining to which
small business borrowers they should extend credit. Changes in these
underwriting standards over time can provide a general indication of
changes in credit conditions facing small business borrowers.
Underwriting standards tighten as perceived economic risk increases—
that is, lenders focus on high-quality borrowers as the economy weakens
and loosen as perceived economic risk falls.

For example, based on responses to the Senior Loan Officer Opinion
Survey, banks have continued to loosen their credit standards and terms
on commercial and industrial loans to small businesses since the third
quarter of 2020 (see fig. 13). 53 Data from the survey also indicated that
banks have lowered spreads of loan rates over their costs of funds.
Decreased loan spreads indicate that banks are instituting a smaller
difference between the interest rates they charge on loans and the
interest rate paid to depositors on financial products, such as savings
accounts. This generally indicates perceived lower risk, which in turn
makes credit more available for small businesses. See appendix II for
information on small business loans outstanding.




53The survey reporting panel consists of up to 80 large domestically chartered commercial
banks and up to 24 large U.S. branches and agencies of foreign banks, and the
respondent bank’s senior loan officers complete the survey. In the survey, small
businesses are defined as those with annual sales of less than $50 million. Based on the
timing of survey completion, each quarter of the survey generally corresponds to the
previous quarter. The latest survey covers the previous 3 months, which generally
corresponds to the second quarter of 2021. Respondent banks received the survey on
June 21, 2021, and responses were due by July 1, 2021.




Page 35                                          GAO-22-104640 Federal Reserve Facilities
Figure 13: Banks’ Lending Conditions for Small Business Loans, First Quarter
2019–Third Quarter 2021




Note: We report results from the Federal Reserve’s Senior Loan Officer Opinion Survey on credit
standards and loan spreads on commercial and industrial loans. A positive number for credit
standards indicates that more banks are tightening rather than loosening standards. Similarly, a
positive number for loan spreads indicates that more banks are increasing rather than decreasing
loan spreads. Based on the timing of survey completion, each quarter of the survey generally
corresponds to the previous quarter. For more information, see
https://www.federalreserve.gov/data/sloos/sloos-202007.htm, accessed August 2, 2021. The Main
Street for-profit lending facilities consist of the Main Street New Loan Facility and the Main Street
Expanded Loan Facility (which were announced on April 9, 2020), and the Main Street Priority Loan
Facility (which was announced on April 30, 2020).


However, according to a 2020 small business credit survey by the
Federal Reserve Banks, recovery for small businesses remains slow,
especially for businesses owned by minorities. Among all businesses,
about 80 percent reported experiencing financial challenges, up from




Page 36                                                 GAO-22-104640 Federal Reserve Facilities
                           about 66 percent in 2019. 54 Minority business owners reported
                           experiencing continued financial challenges. Specifically, about 92
                           percent of Black-owned firms reported experiencing financial challenges
                           in 2020 (up from 85 percent in 2019), followed by about 89 percent of
                           Asian-owned firms (up from 70 percent in 2019) and about 85 percent of
                           Hispanic-owned firms (up from 78 percent in 2019). Additionally, firms
                           owned by people of color were more likely than White-owned firms to
                           report that they reduced their operations in response to the pandemic.
                           Also, Asian-owned businesses were more likely than others to have
                           temporarily closed.

                           Small businesses in the services sector were also affected by the COVID-
                           19 pandemic. According to an analysis by the Federal Reserve Bank of
                           New York using data from the tracking tool Homebase, about one-third of
                           small businesses in the services sector that were active before the
                           pandemic remained closed as of February 2021, with most of these
                           businesses having been inactive for 20 weeks or longer. 55 As of February
                           2021, these closures had not been offset by the entry of new businesses.

Main Street Lending        According to our generalizable survey of Main Street borrowers, about 50
Program Generally Helped   percent of loans made through the program went to small businesses with
                           between 11 and 99 employees. 56 Additionally, about 88 percent of the
Small For-Profit
                           borrowers reported that Main Street loans were “very important” in
Businesses Maintain
Operations


                           54Federal Reserve Banks of Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas City,
                           Minneapolis, New York, Philadelphia, Richmond, St. Louis, San Francisco, Small
                           Business Credit Survey: 2021 Report on Employer Firms (2021). This survey was
                           conducted in September and October 2020, with 9,693 responses from small employer
                           businesses with fewer than 500 full- or part-time employees in the 50 states and the
                           District of Columbia and with 4,531 responses from nonemployer firms. This survey used
                           a nonprobability convenience sampling method to gather data, and as such the results are
                           not generalizable to the population of U.S. small businesses. While the agency post-
                           weighted the data to known Census population data, the survey results suffer from
                           selection bias to an unknown extent.
                           55Homebase is a scheduling and tracking tool used by around 100,000 businesses, mostly
                           small firms, in the leisure and hospitality and retail industries.
                           56In our survey, 35 percent of respondents said their company had 11 to 49 employees
                           (95 percent confidence interval: 31 to 40 percent). A further 16 percent of respondents
                           said their company had 50 to 99 employees (95 percent confidence level: 12 to 21
                           percent).




                           Page 37                                          GAO-22-104640 Federal Reserve Facilities
helping them maintain business operations. 57 See appendix III for
complete survey results. 58

According to Federal Reserve data, from July 6, 2020, to January 8,
2021, when the Main Street Lending Program was operational, the Main
Street facilities purchased a participation in 1,830 loans, with almost all
loans supporting for-profit businesses. 59 The Main Street Lending
Program did not lend directly to borrowers; it purchased a 95 percent
participation in eligible loans, and the issuing lender retained the other 5
percent. Because one Main Street loan could support more than one
business, a total of 2,482 businesses participated in the program.

Almost two-thirds of Main Street loans were made after November 15,
2020, in the last 2 months of the program. According to Federal Reserve
officials, the increased activity in the Main Street Lending Program was
largely due to the Treasury Secretary’s announcement in mid-November
2020 that the program would cease purchasing loan participations by
December 31, 2020. 60

The Main Street Lending Program purchased about $16.6 billion in loan
participations, and the average Main Street loan was about $9.5 million.
In addition to the Main Street Lending Program, small businesses had
access to other federal aid programs, such as the Paycheck Protection
Program. For comparison, as of May 31, 2021, the Paycheck Protection
Program had authorized almost $800 billion in loans, and the average
Paycheck Protection Program loan was about $68,000. However,
Paycheck Protection Program loans could be fully forgiven and Main
Street loans could not, which likely made the Paycheck Protection
Program more appealing.




57The 95 percent confidence interval for this estimate ranges from 84 to 92 percent.

58We surveyed contacts for 636 loans made under the Main Street Lending Program and
received 266 responses, for a response rate of 42 percent. We refer to each of these
contacts as a “borrower,” although one borrower may have borrowed money on behalf of
multiple businesses.
59Of the 1,830 loans made through the Main Street Lending Program, 15 loans supported
nonprofit organizations.
60The Consolidated Appropriations Act, 2021 extended the Main Street facilities to
January 8, 2021.




Page 38                                           GAO-22-104640 Federal Reserve Facilities
Of the 1,830 Main Street loans, about 55 percent were for less than $5
million, and 15 percent were for less than $1 million (see fig. 14).


Figure 14: Loans Made Through the Main Street Lending Program, by Loan Size




The Federal Reserve lowered the threshold for a Main Street loan from
$250,000 to $100,000 on October 31, 2020, and it waived transaction
fees on loans under $250,000, but these changes did not result in a
notable increase in loans to small businesses. 61 In a press release, the
Federal Reserve stated it had made these adjustments to encourage
participation by smaller businesses. However, according to Federal
Reserve data, the percentage of loans made before and after November
1, 2020, for less than $1 million (15.4 percent and 14.9 percent,
respectively) did not change significantly. Over the life of the program, the
Main Street facilities purchased only 12 loan participations for less than
$250,000. According to Federal Reserve officials, there may have been a

61The Federal Reserve originally established the minimum loan threshold at $1 million,
and then lowered it to $500,000 in April 2020 and to $250,000 in June 2020. However,
these reductions took place before the Main Street facilities began purchasing loan
participations.




Page 39                                          GAO-22-104640 Federal Reserve Facilities
                                              couple of reasons the Main Street program made so few loans for less
                                              than $250,000:

                                              •    Companies that needed smaller loans may have had their needs met
                                                   through the Paycheck Protection Program.
                                              •    Main Street loans required a full underwriting process, and lenders
                                                   may have been reluctant to invest the time and resources to originate
                                                   smaller loans.


Main Street Lending                           Overall, Main Street loans were concentrated in certain economic sectors,
Program Was                                   in terms of total dollars loaned, according to Federal Reserve Bank of
                                              Boston data. The five North American Industry Classification System
Concentrated in Certain
                                              (NAICS) codes with the greatest loan volume accounted for slightly over
Sectors and Regions                           30 percent of total Main Street loan volume, and the 10 codes with the
                                              greatest loan volume accounted for almost half of total Main Street loan
                                              volume. The food services and drinking places sector accounted for the
                                              largest share of the amount of loans made through the program—over
                                              $1.5 billion in loans—followed by the professional, scientific, and technical
                                              services sector and the amusement, gambling, and recreation sector.
                                              However, some economic sectors have historically produced more goods
                                              and services than others. For instance, in 2019, the food services and
                                              drinking places sector produced just under $900 billion in goods and
                                              services. In comparison, the professional, scientific and technical services
                                              sector produced about $2.4 trillion. Sectors varied in the amount of
                                              assistance they received from the Main Street Lending Program relative
                                              to their gross economic output (see table 2).


Table 2: Total Amount Loaned through the Main Street Lending Program and Amount Loaned Relative to Gross Industry
Output, by Economic Sector

                                                                                      Total amount loaned per million dollars of
Economic sectora                                            Total amount loaned ($)             2019 gross industry output ($)
Food services and drinking places                                    1,579,271,777                                         1,759
Professional, scientific, and technical services                     1,158,558,342                                           475
Amusement, gambling, and recreation industries                         957,977,195                                         5,712
Real estate                                                            851,694,514                                           227
Rental and leasing services                                            776,133,279                                         2,002
Oil and gas extraction                                                 723,871,678                                         1,929
Administrative and support services                                    675,030,167                                           642
Support activities for mining                                          624,463,866                                         6,736




                                              Page 40                                     GAO-22-104640 Federal Reserve Facilities
                                                                                                                    Total amount loaned per million dollars of
 Economic sectora                                                                   Total amount loaned ($)                   2019 gross industry output ($)
 Accommodation                                                                                        603,157,419                                          2,042
 Construction of buildings                                                                            515,647,158                                            n/ab

Legend: n/a = not applicable
Source: GAO analysis of Federal Reserve Bank of Boston and Bureau of Economic Analysis data. | GAO-22-104640
                                                              a
                                                               ”Economic sector” refers to North American Industry Classification System (NAICS) codes. Gross
                                                              industry output is a measure of the goods and services produced by an industry, valued at producers’
                                                              prices (the prices received by the industry).
                                                              b
                                                               Gross industry output figures from the Bureau of Economic Analysis do not have a category that
                                                              corresponds precisely to construction of buildings.


                                                              Main Street loans also were concentrated in certain metropolitan areas,
                                                              as were the banks that provided the loans. The top five metropolitan
                                                              areas, by total amount borrowed, accounted for just over 32 percent of
                                                              total Main Street loan volume (see fig. 15). These five metropolitan areas
                                                              were

                                                              •      Miami-Fort Lauderdale-Pompano Beach, Florida;
                                                              •      Dallas-Fort Worth-Arlington, Texas;
                                                              •      Los Angeles-Long Beach-Anaheim, California;
                                                              •      New York-Newark-Jersey City, New York-New Jersey-Pennsylvania;
                                                                     and
                                                              •      Houston-The Woodlands-Sugar Land, Texas.




                                                              Page 41                                                   GAO-22-104640 Federal Reserve Facilities
Figure 15: Total Dollar Amount Loaned through the Main Street Lending Program, by Metropolitan Area




                                        Note: Metropolitan areas represent Core-Based Statistical Areas.


                                        Five banks were responsible for almost 25 percent of total Main Street
                                        loan volume, three of them headquartered in one of the top five
                                        metropolitan areas listed above (Miami, Dallas, and Los Angeles).
                                        Overall, 319 lenders made loans through the Main Street Lending




                                        Page 42                                                GAO-22-104640 Federal Reserve Facilities
                         Program. 62 For comparison, as of May 31, 2021, 5,467 lenders had
                         participated in the Paycheck Protection Program.

                         According to a Federal Reserve survey of bank senior loan officers
                         conducted in the second half of August 2020, banks had a variety of
                         reasons for choosing to not participate in the Main Street Lending
                         Program. 63 A majority of banks that did not participate stated they were
                         able to extend credit to potential Main Street borrowers without the
                         program. Other reasons they stated for not participating in the program
                         included unattractive key loan terms to the lender and burdensome
                         registration requirements. According to our survey, for about 40 percent
                         of Main Street loans, borrowers found it “somewhat difficult” or “very
                         difficult” to find a lender that offered loans through the Main Street
                         Lending Program. 64

Women-Owned              Women-owned businesses were underrepresented among Main Street
Businesses Were          borrowers, compared to representation among U.S. businesses as a
                         whole, according to our generalizable survey of Main Street borrowers. 65
Underrepresented Among
                         In contrast, the percentages of minority-owned businesses and veteran-
Main Street Borrowers    owned businesses in the Main Street Lending Program were not
                         statistically different from the percentages of these businesses in the




                         62Banks were not required to participate in the Main Street Lending Program. The
                         following institutions were eligible to make loans under the program: U.S. federally insured
                         depository institutions, U.S. Branches or agencies of foreign banks, U.S. bank holding
                         companies, U.S. savings and loan holding companies, U.S. intermediate holding
                         companies of a foreign banking organization, and U.S. subsidiaries of the foregoing.
                         Eligible lenders retained 5 percent of each eligible loan.
                         63Eighty-six domestically chartered banks responded to the Federal Reserve survey,
                         including 33 banks with assets above $50 billion and 53 banks with assets below $50
                         billion.
                         64In our survey, 24 percent said it was “somewhat difficult” (95 percent confidence interval:
                         19 to 28 percent), and 17 percent said it was “very difficult” (95 percent confidence
                         interval: 12 to 22 percent).
                         65According to Federal Reserve officials, Federal Reserve staff contacted more than 70
                         diverse business associations and organizations with strong connections to minority
                         communities, as well as tribal governments, to ensure they were aware of the Main Street
                         Lending Program. Federal Reserve staff also gave presentations at webinars sponsored
                         by outside entities targeted at potential borrowers and lenders, including minority
                         depository institutions and minority- and women-owned businesses.




                         Page 43                                            GAO-22-104640 Federal Reserve Facilities
population as a whole. 66 According to our generalizable survey of Main
Street borrowers, minority-, women-, and veteran-owned businesses
made up about 14.5 percent, 8.5 percent, and 5.3 percent of participants,
respectively (see fig. 16). 67 In comparison, according to the Census
Bureau’s 2019 Annual Business Survey, minority-, women-, and veteran-
owned businesses made up about 18.3 percent, 19.9 percent, and 5.9
percent of all American businesses with paid employees, respectively. 68

Figure 16: Estimated Participation of Business Types in the Main Street Lending
Program, Compared to Their Representation among U.S. Businesses




Note: Women-owned businesses were the only business type whose participation in the Main Street
Lending Program was statistically different from their overall representation among U.S. businesses.


Officials from an organization representing women-owned businesses
told us they may have participated in the Main Street Lending Program at

66Because one lender issued slightly more than 20 percent of Main Street loans, and
therefore may have had a disproportionate influence on the characteristics of borrowers
as a whole, we also analyzed all loans with the exception of loans made by this lender.
According to this analysis, the percentage of minority-owned Main Street borrowers is 9.5
percent. This number is statistically different from the percentage of minority-owned
businesses in the United States as a whole.
67In addition, according to Federal Reserve data, three tribal-owned businesses received
loans through the Main Street program. For complete survey results, see app. III. For the
complete survey methodology, see app. I.
68The Census Bureau’s 2019 Annual Business Survey sampled approximately 300,000
U.S. employer businesses (businesses with paid employees). Businesses sampled are
required to complete the survey. The difference between our survey results and the
results from the 2019 Annual Business Survey were within the margin of error for minority-
owned and veteran-owned businesses.




Page 44                                                GAO-22-104640 Federal Reserve Facilities
                  lower rates because some women-owned businesses do not have
                  established banking relationships, and therefore they may have been less
                  likely to hear about the program from a banker, among other factors.

                  We provided a draft of this report to the Federal Reserve and Treasury for
Agency Comments   review and comment. The agencies provided technical comments, which
                  we incorporated as appropriate.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Chair of the Board of Governors of the Federal Reserve
                  System, and the Secretary of the Treasury. This report will also be
                  available at no charge on our website at http://www.gao.gov.

                  Should you or your staff have questions concerning this report, please
                  contact me at (202) 512-8678 or clementsm@gao.gov. Contact points for
                  our Offices of Congressional Relations and Public Affairs may be found
                  on the last page of this report. Key contributors to this report are listed in
                  appendix IV.




                  Michael E. Clements
                  Director, Financial Markets and Community Investment




                  Page 45                                    GAO-22-104640 Federal Reserve Facilities
List of Committees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Sherrod Brown
Chairman
The Honorable Patrick J. Toomey
Ranking Member
Committee on Banking, Housing, and Urban Affairs
United States Senate

The Honorable Bernie Sanders
Chairman
The Honorable Lindsey Graham
Ranking Member
Committee on the Budget
United States Senate

The Honorable Maria Cantwell
Chair
The Honorable Roger Wicker
Ranking Member
Committee on Commerce, Science, and Transportation
United States Senate

The Honorable Kyrsten Sinema
Chair
The Honorable James Lankford
Ranking Member
Subcommittee on Government Operations and Border Management
Committee on Homeland Security and Governmental Affairs
United States Senate




Page 46                               GAO-22-104640 Federal Reserve Facilities
The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives

The Honorable John Yarmuth
Chairman
The Honorable Jason Smith
Ranking Member
Committee on the Budget
House of Representatives

The Honorable Maxine Waters
Chairwoman
The Honorable Patrick McHenry
Ranking Member
Committee on Financial Services
House of Representatives

The Honorable Peter A. DeFazio
Chairman
The Honorable Sam Graves
Ranking Member
Committee on Transportation and Infrastructure
House of Representatives




Page 47                                GAO-22-104640 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology


Methodology

              Our objectives in this report were to examine (1) why the CARES Act
              facilities ceased extending credit and purchasing assets by January 8,
              2021; (2) the Board of Governors of the Federal Reserve System’s
              (Federal Reserve) oversight and monitoring of the CARES Act facilities;
              (3) what available evidence suggests regarding the facilities’ effects on
              corporate credit and related markets; (4) what available evidence
              suggests regarding the facilities’ effects on states and municipalities, and
              entities’ experiences in accessing the Municipal Liquidity Facility; and (5)
              what available evidence suggests about trends in small businesses’
              access to credit, and the characteristics of Main Street Lending Program
              participants.

              To address the first objective, we reviewed documentation from the
              Department of the Treasury and the Federal Reserve, including the
              Treasury Secretary’s letter setting out his determination to not extend the
              CARES Act facilities beyond December 31, 2020. We also reviewed
              Federal Reserve and Treasury documentation related to the rescission of
              unused CARES Act funds (as required under the Consolidated
              Appropriations Act, 2021). We interviewed Treasury and Federal Reserve
              officials to understand the circumstances surrounding the Treasury
              Secretary’s determination not to extend the CARES Act facilities and the
              process for returning the unused funds.

              To address the second objective, we analyzed documentation from the
              Federal Reserve’s Division of Reserve Bank Operations and Payment
              Systems (RBOPS) and relevant Federal Reserve Banks. This included
              their policies and procedures pertaining to the monitoring and controls of
              the CARES Act facilities. We reviewed planning documents and
              summaries of completed reviews of the facilities, and we interviewed
              Federal Reserve officials on RBOPS’s framework and approach for
              continual monitoring of the facilities and results of RBOPS’s oversight
              reviews to date. We compared agency controls against selected federal
              internal control standards, including the principles that management
              should establish and operate monitoring activities to monitor the internal
              control system and evaluate the results, and that management should
              remediate identified internal control deficiencies on a timely basis. 1
              Additionally, we reviewed the Federal Reserve’s periodic reports and




              1See GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
              (Washington, D.C.: September 2014).




              Page 48                                       GAO-22-104640 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
Methodology




financial statements for updates on potential and actual losses incurred
by the Federal Reserve facilities.

To address the third, fourth, and fifth objectives, we analyzed indicators of
credit markets affected by the facilities. We reviewed research from
academics, the Federal Reserve, and industry experts, and analyzed the
most recently available data through July 2021 on indicators of credit
markets affected by the facilities. To identify and select potential
indicators, we reviewed several sources, including prior GAO work,
reports and data from the Federal Reserve Board and Federal Reserve
Banks, and reports and data from private organizations, including
Bloomberg and Securities Industry and Financial Markets Association.

For the third objective, the data on credit market indicators we analyzed
included credit spreads, issuances, and outstanding balances on short-
term and long-term corporate credit from the Federal Reserve, Federal
Reserve Bank of St. Louis’s Federal Reserve Economic Data database,
Bloomberg Terminal, and the Securities Industry and Financial Markets
Association. We also analyzed publicly available transaction data from
the Secondary Market Corporate Credit Facility to determine the
distribution of the facility’s holdings across broad industry sectors, and we
interviewed Federal Reserve officials to clarify the process for purchasing
exchange-traded funds and individual corporate bonds.

For the fourth objective, the data on credit market indicators we analyzed
included credit spreads, issuances, and outstanding balances of
municipal securities from the Federal Reserve, Bloomberg Terminal, and
the Securities Industry and Financial Markets Association.

For the third and fourth objectives, we also documented changes in the
conditions of credit markets and areas targeted by the facilities by
assessing indicators of the price (such as credit spreads) and availability
of credit (such as issuances and outstanding balances of securities).

In addition, we interviewed representatives of the three entities (state and
local governments) that participated in the Municipal Liquidity Facility. We
also interviewed representatives of the three entities that did not
participate in the facility but had explored doing so. 2



2For the entities that explored the Municipal Liquidity Facility, we interviewed entities that
either filed a notice of intent or communicated interest in accessing the facility.




Page 49                                             GAO-22-104640 Federal Reserve Facilities
                        Appendix I: Objectives, Scope, and
                        Methodology




                        For the fifth objective, the data on credit market indicators we analyzed
                        included the most recently available survey data on credit market
                        conditions experienced by small business owners and lenders from the
                        National Federation of Independent Business and the Federal Reserve
                        Board and Federal Reserve Banks. This included some analysis from the
                        Federal Reserve Bank of New York that had been derived from the
                        Homebase scheduling and tracking tool, which is used by about 100,000
                        businesses (mostly small firms in the leisure and hospitality and retail
                        industries) and the Federal Reserve’s Senior Loan Officer Opinion
                        Survey.

                        We obtained data from the Federal Reserve Bank of Boston on all 1,830
                        loans made under the Main Street Lending Program to determine
                        characteristics of the program’s participants, their geographic dispersion,
                        the distribution of loan amounts, and their industry sector. We used data
                        on gross economic output by economic sector from the Bureau of
                        Economic Analysis to calculate the amount loaned through the Main
                        Street Lending Program per million dollars of gross economic output. We
                        also interviewed representatives of five associations that represent
                        minority and women business owners to obtain their perspectives on the
                        program.

                        For all objectives, we reviewed relevant federal laws and regulations,
                        facilities’ term sheets, and press releases announcing updates to the
                        facilities’ terms.

Survey of Main Street   To determine certain characteristics of Main Street Lending Program
Lending Program         borrowers for our fifth objective, we administered a web-based survey to
                        a representative sample of for-profit Main Street Lending program
Borrowers
                        borrowers to obtain otherwise unavailable demographic data about them
                        and learn about their experience with the program. In the survey, we
                        asked borrowers about the ownership and size of their business, their
                        satisfaction with the program, and the ease or difficulty of finding a lender.
                        We administered the survey from May 2021 to July 2021.

                        To identify the universe of Main Street borrowers, we used data provided
                        by the Federal Reserve Bank of Boston on February 12, 2021, which
                        contained information on all 1,830 loans conducted under the program,
                        and we excluded the 15 loans to nonprofit organizations. We stratified our
                        sample using the median of the loan size and sorted the loans by
                        geographic region prior to selecting a systematic random sample within
                        each stratum.



                        Page 50                                    GAO-22-104640 Federal Reserve Facilities
                   Appendix I: Objectives, Scope, and
                   Methodology




                   Our sample size was designed to achieve a stratum-level margin of error
                   of no greater than plus or minus 5 percentage points for an attribute level
                   at the 95 percent level of confidence. We assumed a response rate of 50
                   percent to determine the sample size for each stratum. Our resulting
                   sample size was 636, and we received 266 survey responses. We
                   obtained a response rate of 42 percent. We used logistic regression
                   models on our survey data to look for correlation with the propensity to
                   respond among available administrative variables. We did not find
                   anything and used the standard nonresponse weight adjustment for a
                   stratified random sample.

                   Because we followed a probability procedure based on random
                   selections, our sample is only one of a large number of samples that we
                   might have drawn. Since each sample could have provided different
                   estimates, we express our confidence in the precision of our particular
                   sample’s results as a 95 percent confidence interval (for example, plus or
                   minus 7 percentage points). This is the interval that would contain the
                   actual population value for 95 percent of the samples we could have
                   drawn. Confidence intervals are provided with each sample estimate in
                   the report. All survey results presented in the body of this report are
                   generalizable to the population of 1,815 for-profit Main Street borrowers,
                   except where otherwise noted.

Data Reliability   We took a number of steps to assess the reliability of the data sources
                   and indicators of credit markets for businesses and state and local
                   governments, including reviewing relevant documentation on data
                   collection methodology and reviewing prior GAO work. We found that,
                   collectively, the indicators were sufficiently reliable for the purposes of
                   providing a general sense of how credit markets are performing.

                   To assess the reliability of Main Street loan data, we reviewed the data
                   dictionary and interviewed Federal Reserve officials about access to and
                   definitions of the data. In addition, we performed electronic testing of
                   certain key data fields. To assess the reliability of data on the national
                   prevalence of minority-owned, women-owned, and veteran-owned
                   businesses from the Census Bureau’s American Business Survey, we
                   reviewed the survey’s methodology. To assess the reliability of gross
                   economic output data from the Bureau of Economic Analysis, we
                   reviewed the bureau’s guide to the data. We found the data from all three
                   sources to be reliable for our purposes.

                   We conducted this performance audit from November 2020 to October
                   2021 in accordance with generally accepted government auditing


                   Page 51                                    GAO-22-104640 Federal Reserve Facilities
Appendix I: Objectives, Scope, and
Methodology




standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 52                                 GAO-22-104640 Federal Reserve Facilities
Appendix II: Selected Indicators of Credit
                           Appendix II: Selected Indicators of Credit
                           Markets for Corporations, State and Local


Markets for Corporations, State and Local
                           Governments, and Small Businesses




Governments, and Small Businesses
                           This appendix provides more detail on indicators of credit markets for
                           large and small businesses and state and local governments supported
                           by the Board of Governors of the Federal Reserve System (Federal
                           Reserve) lending facilities. The market indicators include corporate credit
                           markets for short-term funding (such as triparty repurchase agreements
                           and commercial paper), credit markets that were primarily for financial
                           businesses (such as asset-backed securities), other sources of debt
                           securities of state and local governments (such as variable rate demand
                           notes), and outstanding balances of debt of state and local governments
                           and small businesses.

Corporate Credit Markets   We provide details below on other indicators of corporate credit markets
                           for short-term funding and credit markets that supported primarily
                           financial businesses.

                           Repurchase agreement market. The Primary Dealer Credit Facility was
                           established by the Federal Reserve to provide support to primary dealers
                           to facilitate the availability of credit to businesses and households using
                           the triparty repurchase agreement market. 1 While a broad array of assets
                           may be financed in the repurchase agreement market, the most
                           commonly used instruments include U.S. Treasuries, federal agency
                           securities, high quality mortgage-backed securities, corporate bonds, and
                           money market instruments. Triparty repurchase agreements of corporate
                           securities increased in 2020 and 2021, above the prepandemic levels in
                           2019 (see fig. 17). When the facility stopped extending credit on March
                           31, 2021, the total amount of outstanding loans held by the facility was
                           $25 million.




                           1Primary dealers are a group of banks and broker-dealers designated by the Federal
                           Reserve Bank of New York to serve as trading counterparts in the implementation of
                           monetary policy. A repurchase agreement is a financial transaction in which one party
                           sells an asset to another party with a promise to repurchase the asset at a prespecified
                           later date. A reverse repurchase agreement is the same transaction, but from the
                           perspective of the security buyer. In a triparty repurchase agreement, market clearing
                           banks facilitate the settlement, unlike bilateral repurchase agreement markets, where the
                           parties directly exchange money and securities.




                           Page 53                                          GAO-22-104640 Federal Reserve Facilities
Appendix II: Selected Indicators of Credit
Markets for Corporations, State and Local
Governments, and Small Businesses




Figure 17: Annual Cumulative Triparty Repurchase Agreements of Corporate
Securities, January 2019–June 2021




Note: The values in this figure are collateral values of Fedwire-eligible and Fedwire non-eligible
triparty repurchase agreements and reverse repurchase agreements of investment grade and non-
investment grade corporate securities. A repurchase agreement is a financial transaction in which
one party sells an asset to another party with a promise to repurchase the asset at a prespecified
later date. A reverse repurchase agreement is the same transaction, but from the perspective of the
security buyer. In a triparty repurchase agreement, market clearing banks facilitate the settlement,
unlike bilateral repurchase agreement markets, where the parties directly exchange money and
securities.


Commercial paper. Since mid-2020, spreads on 90-day commercial
paper have declined to prepandemic levels (see fig. 18). 2 When the
Commercial Paper Funding Facility stopped purchasing assets on March
31, 2021, the facility had not made any purchases of commercial paper in
several months.




2This report analyzed data that were available through July 2021. Our prior Federal
Reserve facilities report, which was issued in December 2020, analyzed data that were
available through September 2020. See GAO, Federal Reserve Lending Programs: Use of
CARES Act-Supported Programs Has Been Limited and Flow of Credit Has Generally
Improved, GAO-21-180 (Washington, D.C.: Dec. 10, 2020).




Page 54                                                 GAO-22-104640 Federal Reserve Facilities
                                       Appendix II: Selected Indicators of Credit
                                       Markets for Corporations, State and Local
                                       Governments, and Small Businesses




Figure 18: Spreads on 90-day Commercial Paper for Large Nonfinancial Businesses, January 2019–July 2021




                                       Note: A rating of AA is for issuers with at least one “1” or “1+” rating, but no ratings other than “1,”
                                       according to the rating agencies Moody’s or Standard & Poor’s. An A2/P2 rating is for issuers with at
                                       least one “2” rating, but no ratings other than “2.” Maturities are 270 days or less. A line is broken if
                                       there are no data for the category on that date. A basis point is 1/100th of a percentage point. The
                                       spread is the difference between the commercial paper rate and the overnight indexed swap of the
                                       same maturity.


                                       Prime money market funds. Prime money market funds experienced
                                       large net outflows—that is, investors withdrew more money overall from
                                       the funds than they added—beginning in April 2020 and as of June 2021
                                       were below prepandemic levels (see fig. 19). When the Money Market
                                       Mutual Fund Liquidity Facility stopped extending credit on March 31,
                                       2021, the total amount of outstanding assets held by the facility was
                                       $202.5 million.




                                       Page 55                                                   GAO-22-104640 Federal Reserve Facilities
Appendix II: Selected Indicators of Credit
Markets for Corporations, State and Local
Governments, and Small Businesses




Figure 19: Year-Over-Year Prime Money Market Funds Outstanding, January 2019–
June 2021




Note: The prime money market funds reported are investment holdings of unsecured commercial
paper. Investment holdings of prime money market funds could include asset-backed commercial
paper, certificates of deposit, and government security repurchase agreements.


Asset-backed securities. In 2020, issuances of asset-backed securities
declined in almost all segments (except for student loans), especially for
credit cards, compared to prepandemic levels. 3 As of July 2021,
issuances were slightly below prepandemic levels (see fig. 20). The Term
Asset-Backed Securities Loan Facility, which supported financial
institutions and also benefited households, ceased extending credit on



3Asset-backed securities are tradable securities backed by pools of assets, such as loans,
leases, or other cash-flow producing assets. The holders of asset-backed securities are
entitled to payments that are distributed by the underlying assets. Common underlying
assets for asset-backed securities include auto loans and leases, credit card loans,
student loans, insurance premiums, commercial mortgages, and small business loans
guaranteed by the Small Business Administration. Well-functioning markets for asset-
backed securities benefit borrowers, who may gain access to funds with more favorable
terms, and lenders, who may better manage their capital and diversify their income
streams.




Page 56                                              GAO-22-104640 Federal Reserve Facilities
                    Appendix II: Selected Indicators of Credit
                    Markets for Corporations, State and Local
                    Governments, and Small Businesses




                    December 31, 2020. As of September 1, 2021, the total amount of
                    outstanding assets held by the facility was $1.5 billion.

                    Figure 20: Annual Cumulative Issuances of Asset-Backed Securities, January 2019–
                    July 2021




                    Note: Total asset-backed securities include autos, collateralized debt obligations and collateralized
                    loan obligations, credit cards, equipment, student loans, and other securities, such as Small Business
                    Administration pools and servicing advances.


State and Local     We provide details below on additional indicators of municipal credit and
Government Credit   outstanding balances of municipal bonds. Municipal bonds are debt
                    instruments that state and local governments issue to finance
Markets
                    transportation, housing, hospitals, education, and other diverse projects.

                    Variable rate demand notes. Variable rate demand notes (VRDN) are
                    long-term municipal securities that are payable on demand and accrue
                    interest based on the prevailing money market rate—effectively making
                    VRDNs short-term duration assets. These notes also are the most
                    commonly held type of asset in municipal money market funds. The
                    Securities Industry and Financial Markets Association municipal swap
                    index of rates—a commonly used benchmark rate for VRDNs—has
                    stabilized since the market disruptions in March 2020. The Federal
                    Reserve announced it was adding VRDNs to the list of eligible collateral
                    for the Money Market Mutual Fund Liquidity Facility on March 23, 2020.



                    Page 57                                                 GAO-22-104640 Federal Reserve Facilities
                        Appendix II: Selected Indicators of Credit
                        Markets for Corporations, State and Local
                        Governments, and Small Businesses




                        However, outstanding balances of VRDNs have declined compared to
                        prepandemic levels.

                        State and local government bonds. Municipal bonds outstanding have
                        remained largely unchanged since the onset of the pandemic (see fig.
                        21).

                        Figure 21: State and Local Government Bonds Outstanding, First Quarter 2019–
                        Second Quarter 2021




                        Note: The bonds outstanding consist mostly of long-term securities—those with maturities of more
                        than 13 months.


Small Business Credit   We provide details below on outstanding balances of loans to small
Markets                 businesses. Small businesses in particular are generally dependent on
                        bank lending for credit because they are too small to raise capital in bond
                        markets directly.

                        Small business loans. Small business loans outstanding have increased
                        since the second quarter of 2020 (see fig. 22). This increase may have
                        been driven in part by Paycheck Protection Program loans. As such,



                        Page 58                                               GAO-22-104640 Federal Reserve Facilities
Appendix II: Selected Indicators of Credit
Markets for Corporations, State and Local
Governments, and Small Businesses




outstanding loan balances may be overstated because Paycheck
Protection Program loans could be forgivable.

Figure 22: Small Business Loans Outstanding, First Quarter 2019–First Quarter
2021




Note: The loans shown in this figure include mortgages, depository institution loans, and other loans
and advances.




Page 59                                                 GAO-22-104640 Federal Reserve Facilities
Appendix III: Results of GAO’s Survey of                       Appendix III: Results of GAO’s Survey of Main
                                                               Street Lending Program Borrowers


Main Street Lending Program Borrowers

                                                               From May through July 2021, we administered a web-based survey to a
                                                               generalizable sample of for-profit borrowers in the Main Street Lending
                                                               Program.
                                                               As shown in table 3, we received valid responses from 42 percent of our
                                                               total sample. All survey results presented in this appendix are
                                                               generalizable to for-profit borrowers in the Main Street Lending Program.
                                                               We express our confidence in the precision of our estimates as a 95
                                                               percent confidence interval. 1 For a more detailed discussion of our survey
                                                               methodology, see appendix I.

Table 3: Survey Population, Sample Size, and Percentage of Valid Survey Responses

 Population size                                                                               Sample size                             Response rate (%)
 1,830                                                                                                  636                                             42
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640



Table 4: Is your business minority-owned? (A business is minority-owned if it is at least 51 percent owned and controlled by
individuals who identify as members of one of the following groups: Black Americans, Hispanic Americans, Native
Americans, Asian Pacific Americans, and Subcontinent Asian Americans.)

                                                                                               95 percent confidence              95 percent confidence
                                                                                               interval—lower bound               interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                       (percentage)
 Yes                                                                              14.5                             10.5                               19.4
 No                                                                               83.6                             78.6                               87.8
 Don’t know                                                                        1.9                               0.6                                4.3
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640



Table 5: Is your business women-owned? (A business is women-owned if it is at least 51 percent owned and controlled by
individuals who identify as women.)

                                                                                               95 percent confidence              95 percent confidence
                                                                                               interval—lower bound               interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                       (percentage)
 Yes                                                                               8.5                               5.4                              12.5
 No                                                                               90.5                             86.4                               93.8
 Don’t know                                                                        1.0                               0.2                                3.0
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640


                                                               1Because we followed a probability procedure based on random selections, our sample is
                                                               only one of a large number of samples that we might have drawn. Since each could have
                                                               provided different estimates, we express our confidence in the precision of our particular
                                                               sample’s results as a 95 percent confidence interval. This is the interval that would contain
                                                               the actual population value for 95 percent of the samples we could have drawn.




                                                               Page 60                                            GAO-22-104640 Federal Reserve Facilities
                                                               Appendix III: Results of GAO’s Survey of Main
                                                               Street Lending Program Borrowers




Table 6: Is your business veteran-owned? (A business is veteran-owned if it is at least 51 percent owned and controlled by
one or more veterans.)

                                                                                               95 percent confidence          95 percent confidence
                                                                                               interval—lower bound           interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                   (percentage)
 Yes                                                                               5.3                           2.9                               8.7
 No                                                                               93.3                          89.5                             96.0
 Don’t know                                                                        1.4                           0.4                               3.7
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640



Table 7: How important was a Main Street loan in helping your business maintain ongoing operations?

                                                                                               95 percent confidence          95 percent confidence
                                                                                               interval—lower bound           interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                   (percentage)
 Very important                                                                   88.0                          83.5                             91.7
 Somewhat important                                                               11.3                           7.8                             15.7
 Not too important                                                                 0.7                           0.1                               2.5
 Not important at all                                                              0.0                           0.0                               1.1
 My business has closed permanently                                                0.0                           0.0                               1.1
 Don’t know                                                                        0.0                           0.0                               1.1
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640



Table 8: How would you rate the process of finding a lender that offered Main Street loans?

                                                                                               95 percent confidence          95 percent confidence
                                                                                               interval—lower bound           interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                   (percentage)
 Very easy                                                                        29.7                          25.2                             34.2
 Somewhat easy                                                                    29.0                          24.5                             33.5
 Somewhat difficult                                                               23.6                          19.4                             27.8
 Very difficult                                                                   16.5                          12.3                             21.5
 Don’t know                                                                        1.2                           0.3                               3.4
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640




                                                               Page 61                                         GAO-22-104640 Federal Reserve Facilities
                                                               Appendix III: Results of GAO’s Survey of Main
                                                               Street Lending Program Borrowers




Table 9: Approximately how many full-time equivalent employees does your business currently have?

                                                                                               95 percent confidence          95 percent confidence
                                                                                               interval—lower bound           interval—upper bound
 Responses                                                   Estimated percentage                       (percentage)                   (percentage)
 10 or fewer                                                                      11.8                           8.2                             16.3
 11–49                                                                            35.3                          30.7                             40.0
 50–99                                                                            16.1                          11.9                             21.1
 100–499                                                                          27.4                          23.2                             31.7
 500 or more                                                                       7.3                           4.5                             11.1
 Don’t know                                                                        2.0                           0.7                               4.5
Source: GAO survey of Main Street Lending Program participants. | GAO-22-104640




                                                               Page 62                                         GAO-22-104640 Federal Reserve Facilities
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Michael E. Clements, clementsm@gao.gov, (202) 512-8678
GAO Contact
                  In addition to the contact named above, Tarek Mahmassani (Assistant
Staff             Director), Kun-Fang Lee (Analyst in Charge), Carl Barden, Daniel Flavin,
Acknowledgments   John Karikari, Christopher Klemmer, Matthew Levie, Joshua Marcus,
                  Jesse Mitchell, Marc Molino, Bryan Prince, Jessica Sandler, Jennifer
                  Schwartz, and Farrah Stone made key contributions to this report.




(104640)
                  Page 63                                 GAO-22-104640 Federal Reserve Facilities
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