U.S. Federal Reserve Announces Changes to, Provides Guidance On, And Posts Additional Documents With Respect to The Main Street Lending Program

On May 27, 2020, the U.S. Federal Reserve (“Fed”) announced additional changes to the Main Street Lending Program (“MSLP”), while also providing additional guidance through an updated FAQ and posting documents for MSLP to the Federal Reserve Bank of Boston’s website, available here. While certain changes helped clarify certain gray areas of the existing MSLP terms, there were certain changes that further restricted the use of MSLP for companies and there were also certain areas of the MSLP terms which were not addressed if the MSLP is to be made available to certain companies, such as negative EBITDA companies. The below chart provides the highlights with respect to the changes and guidance, and describes the effects of any such changes (and non-changes) and guidance on borrowers. For a summary of the changes to MSLP that were made on April 30, 2020, please see Goodwin’s May 2, 2020 client alert here.

U.S. Federal Reserve Board – Main Street Lending Program – Changes and Guidance Highlights (May 27, 2020) 

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