Federal Reserve Publishes Updated Main Street Lending Programs

On April 9, 2020, the Federal Reserve, published term sheets for a Main Street Lending Program for small and/or mid-size businesses. The April 9 term sheets set forth two separate loan programs under the Main Street Lending Program—the Main Street Lending Program and the Main Street Expanded Lending Program. Comments from lenders and borrowers concerning the two programs were due to the Federal Reserve on April 16, 2020.

On April 30, 2020, after receiving and reviewing public input, the Federal Reserve made adjustments to the Main Street Lending Program and Main Street Expanded Lending Program and added a third loan option (though the Federal Reserve will only purchase 85% of this loan).  Especially notable, the Federal Reserve increased the maximum size of businesses that are eligible to include business with up to 15,000 employees or $5 billion in annual revenue.

As such, we have adjusted our summary chart outlining the various Main Street Lending Programs, which can be found here.

Also worth noting is that the Federal Reserve specifically acknowledged that nonprofits are ineligible to participate, but stated it is working with the Treasury to evaluate whether nonprofit organizations might participate in the future. We will continue to monitor the implementation of these programs, along with any further guidance that is issued. A start date for the programs is expected soon.


If you have questions concerning issues raised by the Coronavirus pandemic and/or issues concerning your participation with any of the CARES Act or any other government program enacted in response to Coronavirus, please reach out.

We are available to assist with any questions you have concerning the CARES Act and related enforcement.

About the Attorneys

Michelle F. Schwerin represents individuals and businesses in a variety of tax matters, including tax liability disputes, innocent spouse claims, claims for penalty abatement, refund claims and litigation, preparer and promoter penalty investigations and tax collection matters.

For additional information about Michelle, please visit her profile.

Danielle M. Durban specializes in entity formation and structuring, business disputes, commercial transactions, copyrights, and trademarks. She is committed to thoroughly understanding each of her client’s business goals, mission, and values in order to provide effective and efficient solutions unique to each client’s business.

For additional information about Danielle, please visit her profile.

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