Who Needs to Know
Lenders and potential borrowers considering making loans or borrowing under the MSLP.
Why It Matters
In the month of September, the Federal Reserve Bank of Boston (Boston Fed) released multiple revisions to the business loans MSLP Frequently Asked Questions (FAQs) to provide practical guidance for for-profit borrowers and lenders and also officially expand the MSLP program to include multi-borrower facilities.
MSLP Facilities for For-Profit Businesses
During the month of September, the Boston Fed updated the business MSLP FAQs (released on September 18) with some additional details and clarifications. Significant changes and additions to the existing FAQs for MSLP facilities for-profit Eligible Borrowers include:
MSLP Facilities for Nonprofit Businesses
After initially announcing the nonprofit facilities under the MSLP in July, the Boston Fed officially announced on September 4 that the MSLP was fully operational for loans to nonprofit organizations.
 The FAQ does not directly address the timing issue inherent in this guidance, but we presume that a loan meeting the standards for a bona fide loan is not considered a distribution at that time. However, if the MSLP borrower as lender does not enforce its rights, then this would constitute a distribution at that time.