The Federal Reserve Board issued initial guidance regarding its Main Street Lending Program on April 9, 2020, as authorized under the Coronavirus Economic Stabilization Act (Title IV of the CARES Act). This original guidance established the broad brush parameters of the program, but was short on details, raising concerns among both borrowers and lenders about its eventual implementation. On April 30, in response to a flood of public comments, the Federal Reserve released updated guidance, containing substantially greater operational details. The new guidance both modified and supplemented the two previously announced facilities―the Main Street New Loan Facility and the Main Street Expanded Loan Facility―and added a third facility, the Main Street Priority Loan Facility, expanding the overall scope of the program.
This Alert supplements our prior program summary, identifying revisions to guidance relating to the original facilities and providing details on the new Priority Loan Facility. This Alert does not entirely restate provisions, which remain unchanged and were covered in our prior Alert about the program.