On April 30, 2020 the Federal Reserve released new term sheets for the Main Street Loan Program, which is a $600 billion loan program, that will include $75 billion capitalized by the Treasury Department under the $454 billion Congressional appropriation of Section 4003(b)(4) of Title IV of the CARES Act. The loans will target small and mid-sized companies, defined as having less than 15,000 employees or $5 billion or less in 2019 annual revenue, and will be made by banks and other eligible lenders, with the government then purchasing between 85% to 95% of the lenders’ interest in the loans.

The summary we are releasing today highlights key aspects of, and compares differences between, the three types of loans that will be available under the Main Street Loan Program. On April 16, 2020 the Sheppard Mullin team provided comments to the Federal Reserve on the previous draft term sheets it released for the Main Street Loan program.

The Federal Reserve has not yet announced when the Main Street Loan Program will be formally opened but that is expected soon...