Main Street Lending Program: Latest Updates

In our last general discussion on the Main Street Lending Program (the "Program"), we focused on providing an overview of the Program and some key commercial and legal matters for borrowers and lenders to consider when making a determination as to whether procuring a loan under one of the Program's facilities was the preferred option for such business. Since that publication, the Program has been operational for about four months, and to date, it has not achieved the desired market participation for a variety of reasons. As such, the Federal Reserve has again modified the Program to expand the base of potential borrowers that could access loans under the Program and to encourage lenders to make smaller sized loans. In this note, we will provide a short summary of these updates to the Program and explain how each modification is intended make the Program more accessible to a wider range of borrowers and encourage lenders to make loans of a smaller size.