Where is Main Street?—Fed Provides Guidance on the Main Street Lending Program - September 2020

Fed Releases Updated Frequently Asked Questions for Business and Nonprofit Facilities and Instructions for Lender Required Documentation -

On September 18, 2020, the Federal Reserve Bank of Boston (the “Boston Fed”) released an updated set of Main Street Lending Program (the “Program”) Frequently Asked Questions for the Business Facilities (defined below) (“FAQs”,) and Nonprofit Facilities (defined below) (“Nonprofit FAQs”, ). The Boston Fed also released updated Instructions for Lender Required Documentation to reflect that as of September 21, 2020, the SPV (defined below) expects to accept multi-borrower loans.

As noted in our prior alerts (and in numerous updates to this alert), the Department of the Treasury will use funding from the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) to make a $75 billion equity investment in the Program through MS Facilities LLC (the “SPV”), a special purpose vehicle operated by the Boston Fed. The Program will leverage this investment from Treasury up to eight times, for up to $600 billion in term loans for eligible borrowers.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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