***This legal development is still in progress. We will
update this Alert as additional information is
provided.***
As previously described in a prior
Alert issued March 27, the bipartisan Coronavirus Aid, Relief,
and Economic Security Act (CARES Act), commonly referred to as
Phase 3 of the federal government's response to the coronavirus
outbreak, was approved by the House and signed into law by the
President. Title IV of the CARES Act directs the Federal Reserve to
establish programs and facilities through its mandate to support
impacted businesses. On April 9, the Federal Reserve announced a
$2.3 trillion series of new programs under the CARES Act. Term
sheets for each of these programs can be found here. Among the Federal Reserve programs is
the creation of a new "Main Street Lending Program,"
which will make loans available for U.S.-based borrowers with up to
10,000 employees or up to $2.5 billion in 2019 annual revenues. The
program will include facilities
