Overview

On April 30, 2020, the Federal Reserve issued term sheets for various new lending facilities under the CARES Act intended to facilitate lending to small and medium-sized businesses by eligible lenders. This article provides a summary of the CARES Act Programs offered by the Federal Reserve.

 

CARES Act Programs

Main Street New
The Main Street New Loan Facility eligible loan is an unsecured term loan that originated after April 24, 2020. An eligible borrower must be a business that is created or organized in the U.S. or under the laws of the U.S., with significant operations in and a majority of its employees based in the U.S.
Main Street Priority
The Main Street Priority Loan Facility is intended to facilitate lending to small and medium-sized Businesses by Eligible Lenders. The Priority Loan Facility, like the New Loan Facility, is for borrowers who do not have an existing loan with the Main Street Lending Program lender. However, the maximum loan size for the Priority Loan facility is the lesser of $50 million or 6 times the borrower's EBITDA, as opposed to only 4 times EBITDA for the New Loan Facility.
Main Street Expanded
The Main Street Expanded Loan Facility has similar loan terms to the Main Street New Loan Facility with a few key differences. The eligible loan is a term loan that was originated on or before April 24, 2020. Any collateral securing the loan, whether such collateral was pledged under the original terms of the loan or at the time of upsizing, will secure the loan participation on a pro rata basis.
Paycheck Protection Program (PPP)

The Paycheck Program provides small businesses with funds to pay up to 8 weeks of payroll costs including benefits. Funds can also be used to pay interest on mortgages, rent, and utilities. The last day for this program was June 30, 2020. 

For Program Information: Paycheck Protection Program

The chart below (based on the June 9, 2020 Federal Reserve updatesummarizes the limited information provided on these two facilities plus applicable restrictions set forth in the CARES Act.  Borrowers under the Paycheck Protection Program (PPP) may also take out Main Street loans.

Note: This information is based on our understanding of the programs at the time this was posted.  Banks should rely on their own internal guidance as these programs are subject to change and interpretation. For the latest guidance, see Mainstreet Lending Program.

Program Name

Main Street New

Main Street Priority

Main Street Expanded

Eligibility

Applicants must have no more than 15,000 employees or must have revenues of less than $5 billion

Form of Assistance

Loan originated after April 24, 2020

Upsized tranche of a loan that was originated on or before April 24, 2020

Loan Term

5 years

Loan Amount

  • Minimum loan size of $250,000

  • Maximum loan size = the lesser of $35 million or, an amount that, when added to the Borrower’s existing outstanding and undrawn but available debt does not exceed four times the Eligible Borrower's adjusted 2019 EBITDA

  • Minimum loan size of $250,000

  • Maximum loan size = the lesser of $50 million or, an amount that when added to the Borrower's existing outstanding or undrawn available debt does not exceed six times the Eligible Borrower's adjusted 2019 EBITDA

  • Minimum loan size of $10 million

  • Maximum loan size = the lesser of  $300 million or, an amount that, when added to the Borrower’s outstanding or undrawn available debt does not exceed six times the Eligible Borrower's adjusted 2019 EBITDA

Interest Rate

Libor + 3%

Loan Fees

  • Lender pays facility fee to the government SPV = 100 bp of principal amount of the loan participation purchased by the SPV (may require Borrower to pay this fee)

  • Borrower pays origination fee to lender
    = 100 bp of principal

  • Government SPV pays an annual servicing fee to lender = 25 bp of average principal

  • An Eligible Borrower will pay an Eligible Lender a fee of 100 bp of the principal amount of the Eligible Loan at the time of origination.

  • The SPV will pay an Eligible Lender 25 bp of the principal amount of its participation in the Eligible Loan per annum for loan servicing. 

  • An Eligible Borrower will pay an Eligible Lender a fee of 75 bp of the principal amount of the upsized tranche of the Eligible Loan at the time of upsizing. 

  • The SPV will pay an Eligible Lender 75 bp of the principal amount of its participation in the upsized tranche of the Eligible Loan per annum for loan servicing.

Principal Repayment

Principal deferred for two years.  For years 3-5, principal amortization of 15%, 15%, and balloon payment of 70% respectively.

Interest Payments

Deferred for one year

Loan Participation/Risk Retention for Lender

5%

The SPV will purchase at par value a 95% participation in the Eligible Loan. The Eligible Lender must retain its 5% of the Eligible Loan until it matures or the SPV sells all of its participation, whichever comes first. 

Forgiveness

Loans are not forgivable

Employment and Payroll Requirements

Must commit to make reasonable efforts to maintain payroll and retain workers

Compensation Limitations

  • Compensation and severance caps on employees and officers making over $425,000 in 2019

  • Compensation and severance caps on officers making over $3 million in 2019

Stock Repurchase Limitations

Other than due to an existing contractual obligation, may not purchase exchange-listed securities of the borrower or a parent company until 1 year after the loan is repaid

Capital Distribution Limitations

May not pay dividends or make distributions until 1 year after the loan is repaid