On April 9, 2020, the board of governors of the Federal Reserve System (the “Federal Reserve”) took several steps designed to promote maximum employment and stabilize the financial system during the pendency of the COVID-19 pandemic, including the creation of the Main Street New Loan Facility (the “New Loan Facility”) and the Main Street Expanded Loan Facility (the “Expanded Loan Facility,” and collectively with the New Loan Facility, the “Main Street Lending Programs” or the “Programs”), which will provide up to $600 billion in new credit to eligible businesses that were in good standing prior to the COVID-19 crisis, including small businesses and the approximately 20,000 medium-sized U.S. businesses that employ between 500 and 10,000 workers and who were not able to access PPP funds or other initiatives limited to small businesses.  The Federal Reserve expects to launch the Programs one day this week.  Small businesses that have benefitted from the PPP program may also participate in the Main Street Lending Programs.

The following summarizes the latest available information as of the above date and is largely based on the Federal Reserve’s Term Sheets for the Programs (the “Term Sheets”). In the coming days, we anticipate adjustments to and guidance on the Programs by the Board of Governors of the Federal Reserve and/or the Secretary of the U.S. Department of Treasury (“Treasury”). Any changes to the Programs will be announced on the Board of Governors’ website.  Accordingly, while this overview may be useful for prospective participants, it is necessarily preliminary in nature and should not be relied upon as the final statement of the terms of the Main Street Lending Programs.

The Federal Reserve has not yet provided information regarding how businesses can obtain a new loan or upsize an existing loan under the Programs, except that prospective borrowers will apply directly to eligible lending institutions (“Eligible Lenders”), and will not apply to a governmental agency.

If you have any questions, please contact Lina Angelici or another member of Gunster’s Corporate Practice Group.

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This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

About Gunster

Gunster, Florida’s law firm for business, provides full-service legal counsel to leading organizations and individuals from its 12 offices statewide. Established in 1925, the firm has expanded, diversified and evolved, but always with a singular focus: Florida and its clients’ stake in it. A magnet for business-savvy attorneys who embrace collaboration for the greatest advantage of clients, Gunster’s growth has not been at the expense of personalized service but because of it. The firm serves clients from its offices in Boca Raton, Fort Lauderdale, Jacksonville, Miami, Orlando, Palm Beach, Stuart, Tallahassee, Tampa, Vero Beach, and its headquarters in West Palm Beach. With more than 240 attorneys and consultants, and over 240 committed support staff, Gunster is ranked among the National Law Journal’s list of the 500 largest law firms and has been recognized as one of the Top 100 Diverse Law Firms by Law360. More information about its practice areas, offices and insider’s view newsletters is available at


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