On April 9, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) released term sheets outlining the Main Street Lending Program under the Coronavirus Economic Stabilization Act (the “CARES Act”): (1) the Main Street New Loan Facility (“New Loans”), and (2) the Main Street Expanded Loan Facility (“Expanded Loans”). On April 30, 2020, the Federal Reserve released updated term sheets for New Loans and Expanded Loans; added a third facility, the Main Street Priority Loan Facility (“Priority Loans”); and released Frequently Asked Questions (“FAQ”) about the Main Street Lending Program.

These programs are aimed at paving the way for increased lending to small and medium-sized businesses. Under these facilities, the Federal Reserve Bank of Boston will commit to lend to a Main Street Special Purpose Vehicle (“SPV”), which in turn will purchase 85% participations in Priority Loans and 95% participations in New Loans and Expanded Loans. Eligible lenders would hold 15% of the exposure on Priority Loans and 5% of the exposure of New Loans and Expanded Loans. The combined commitment of the Federal Reserve and Treasury Department to the SPV will be up to $600 billion...