The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.
Main St Loan Program and Non Profits and Dividends and Capital Distributions
Lloyd Lewis [llewis@arcthrift.com]
The non profit community in the US has 12 million employees and a $2
trillion annual impact on the US economy.
The non profit community in the US provides critical social and other
services, particularly needed during this crisis.
Large non profits have been left out of the funding picture to date – not
eligible for PPP.
*It’s critical that non profits be included in the Main St. program **given
it’s large employee base, economic impact, and critical social and other
services provided.*
The stress on traditional funding streams for non profits is extremely
pronounced with the virus and so many who work for non profits are in
jeopardy of losing their jobs and livelihoods.
*Prohibitions against capital distribution and dividend payouts don’t apply
to non profits,** and apart from bank loan repayments, any payments made by
non profits to support their critical missions should be allowed.*
Thank you in advance for your support during this very challenging time.
Sincerely,
Lloyd Lewis
President/CEO
Arc Thriftstores
4/30/2020 8:24:43
Main Street Program
Lloyd Lewis [llewis@arcthrift.com]
Have seen some potential Main St guidance per a published FAQ:
“E.6. Are non-profit organizations eligible to borrow under the Program?
While non-profit organizations are not currently eligible under the
Program, the Federal Reserve acknowledges the unique needs of non-profit
organizations, many of which are on the front lines providing critical
services and research to fight the pandemic. EBITDA is the key underwriting
metric required for the MSNLF, MSPLF, and MSELF. The Federal Reserve
recognizes that the credit risk of non-profit organizations, as a matter of
practice, is generally not evaluated on the basis of EBITDA. The Federal
Reserve and the Treasury Department will be evaluating the feasibility of
adjusting the borrower eligibility criteria and loan eligibility metrics of
the Program for such organizations.”
*I would ask that non profits who do have EBITDA metrics have an option to
be evaluated on that basis if they can calculate EBITDA.*
Most non profit thriftstores are social enterprises, businesses who sell
donations in retail stores to benefit their missions. We, and I presume
many other non profit thrifts, can easily classify EBITDA by looking at
revenue from sales less operating expenses, interest, depreciation, and
amortization and excluding funding of non profit mission work. Arc
Thriftstores, a Colorado non profit funding advocacy for persons with
intellectual disabilities, uses EBITDA metrics to determine how much
cashflow we have to fund our mission and capital improvements to our stores.
Non profit thriftstores are in this sense like retail in that they sell
donated clothing, appliances, domestics, toys, furniture to make a profit
to support their social missions.
The state shutdowns have had a severe impact on non profit thriftstore
revenue and ability to retain employees, with thousands and thousands and
thousands of layoffs throughout the country.
Please also note the magnitude of the thriftstore industry across the
United States:
4/30/2020 6:43:10
Approx 25,000 Thrift Stores in US (estimated thrift store employees 350,000)
Annual Thrift Store Revenue – 17.5 Billion
16-18% of Americans shop thrift
*Source: US Census Bureau and The Association of Resale Professionals*
Main Street Lending
Matt Altman [maltman@altmanplants.com]
4/17/2020 6:23:26
Hello, I am the owner of a wholesale greenhouse/nursery business that was started over 40 years ago
by my parents and is now second generation. It was started out of their backyard and we have kept the
business in the family while growing it to over 5000 employees as the largest wholesale nursery in the
country. We have locations in CA, TX, CO, FL as well as a few others. We supply retail garden centers
across the country but especially stores like Home Depot, Lowe's and other grocery stores.
The reason I am writing you is that we are impacted in a very specific way by the virus and economic
shutdown. We grow a perishable inventory that sells during a peak window of March through May. We
are located across the southern belt of the country that has an earlier "spring" season for sales, which
means our season has already started and has been incredibly impacted. Our sales reductions have
been dramatic, partly caused by retailers restricting customer entry and mostly due to shoppers staying
at home.
It is an understandable situation given how events have unfolded in the country but unprecedented and
impossible to plan for. By Feb 15 we had already planted everything for our spring season selling
window, which accounts for 65% of our annual sales. We are seeing a 50% reduction in our sales at
this point which will lead to dramatic amounts of scrap and nonetheless we are unable to do much
reduction in cost because of our live inventory.
We are not able to apply for the PPP program due to the amount of employees we have. The main
street lending program seems to be our only avenue. The metrics used for lending however are
restrictive for a company like ours that is seasonal in nature. We have a seasonal credit line that
increases as we build inventory heading into Spring. When we sell our inventory we pay down the line.
The way the Main street lending program seems to work it bases the amount you can be lent on the
amount of debt you have outstanding at the time of the loan. We will have our max lending moment
during these next couple months. Our lending is done as a factor of our inventory and receivables, and
as our inventory recedes (either through sales or dumps) we have less lending capacity. We can really
use the help of additional financing, and deferring the payments for a year will allow us to run our
business for another year and build back up profits to pay it down.
Over 40 years we have proved capable and hardworking enough to make our business successful. We
have created a great working company with a good team of engaged and loyal employees that we want
to keep together for the long term. But I am concerned a company like ours will not qualify for enough
assistance to get us through to another year if the lending guidelines stay as written.
I appreciate your time in reading this. Please feel free to contact me if you would like more information,
care for additional input or have any questions.
Thanks,
Matthew Altman
_____________________
Matthew Altman
Chief Operating Officer / Co-President
Altman Plants, Inc.
3742 Blue Bird Canyon Road
Vista, CA 92084 USA
Phone: 760.744.8191 x186
Fax: 760.744.8835
Email: maltman@altmanplants .com<mailto :maltman@altmanplants .com>
Main Street Lending
ToddSilver ersonal Email -ress
4/16/2020 11 :41 :03
NONCONFIDENTIAL // EXTERNAL
To whom it may concern,
I am a small business owner as a landlord which owns retail s aces. onfidentiallrus1ness
Information
I don't see where I can apply for The Main Street lending program ?
For the SPA or disaster relief fund programs I have reached out too many different banks and none of
them can help me. They all suggest that I just go online. With Wells Fargo they finally sent me an email
indicating I can now apply online and after applying online I then received a message saying they are
out of funds on the SBA program and they suggest that I apply elsewhere.
CoofiooiitiallJusiness Information
I do not have payroll per se, I am a K-1 recipient and deal with outside third � as far as
management company and vendors. 'Confidential Business Information
Any assistance or suggestions would be greatly appreciated of who I can talk to about Main Street
Coofiilen
Lending and other disaster relief programs that could be available to me lnfAPnAfiAn------iial Bu siness
Please advise.
Thank you,
Todd Silver
PO Box 88
Beverly' Hills, CA 90213
CelfPtiorie Nunifier
Sent from my iPhone
Main Street Lending Facility – EBITDA Restriction
Naomi Beckman-Straus [naomi.beckmanstraus@lulus.com]
Lulu's Fashion Lounge, LLC agrees and signs on to the comment submitted by
TechGC on April 15, 2020 that other metrics in addition to EBITDA should be
used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility. In particular, as a high-growth company that
(prior to COVID-19) employed around 1000 Americans (and thus is ineligible
for the SBA facilities), we would encourage the adoption of the following
adjustments:
- Define EBITDA to be closer to Adjusted EBITDA than GAAP EBITDA – this
would present a more normalized view on profitability
- In particular, we would suggest that the following be permitted
as add-backs to EBITDA: non-cash stock based compensation, one-time
transaction fees related to the incurrence of debt, M&A and other
nonrecurring events, and shareholder management fees
- Maturity: we would suggest that maturity is extended beyond 4 years
or in any case, occurs no earlier than any of the issuer’s existing debt.
Naomi Beckman-Straus
General Counsel
<http ://www. lulus .com/>
naomi.beckmanstraus@lulus .com
530.924.3819
195 Humboldt Ave.
Chico, CA 95928
[image: Facebook] <https ://www. facebook .com/lulusdotcom>[image: Pinterest]
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<https ://lulusdotcom.tumblr .com/>[image: Instagram]
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4/16/2020 9:08:19
Consider Non-Profits in CARES Act Program
Eileen Spath [Eileen.Spath@ccrcda.org]
4/16/2020 9:03:26
Good Afternoon,
I am reaching out on behalf of Catholic Charities of the Diocese of Albany, in regards to the creation of
a program as directed under the CARES Act section 4003(c)(3)(D) to provide financing to banks and
other lenders to make loans to nonprofits and other mid-size business of between 500-10,000
employees.
We are one of the largest private, non-profit human service organizations in Upstate New York,
employing upwards of 900 individuals. As a non-profit, we've seen demand for our services increase,
while more and more individuals are struggling to make ends meet. As an employer, hundreds of
people rely on us for a paycheck to keep them financially stable. It is for them, and for those we serve,
that we request that the program:
* Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year
amortization
* Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
* Payments shall not be due until two years after a direct loan is made
* Employee retention provisions should begin on the date that loan funding is received by the
borrower
* In implementing any workforce restoration and retention provisions, �workforce� should be defined
as full-time employees or full-time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck
Protection Program, which contains loan forgiveness provisions which are critical to these
organizations and necessary to help ensure they will be able to continue to provide services during the
crisis and assist with our nation�s recovery efforts when the crisis is over.
Simply put, charitable nonprofits play the third largest employer in our nation�s economy, and provide
immeasurable economic value to the communities we serve.The recommendations above will help to
keep Organizations like Catholic Charities financially strong and allows us to continue to meet the
immediate needs of our communities while planning for the future when many of their services will be
needed most. Nonprofit organizations are our country's only institutions solely focused on making
communities stronger. In the toughest times, we do the toughest work.
We ask that you consider us, our far reaching economic impact and the people we serve when creating
this program.
All the Best,
Eileen Spath
Marketing & Communications Manager, Executive Office
Catholic Charities of the Diocese of Albany
40 N. Main Avenue, Albany, NY 12203
518.641.6842
Will I get a response?
Liam Clougherty Personal Email Address
4/16/2020 8:38:46
Will I get a response? I spoke to the office of Inspector General on April 13, 2020, and was told, �The
Office of Inspector General (OIG) of the Board of Governors of the Federal Reserve System (Board)
and the CFPB of Consumer Financial Protection (the CFPB) has received your April 9, 2020, and April
13, 2020, emails regarding your economic policy proposal.� I since have been referred to the Board
staff due to (OIG) limitations and or restrictions. Again, I understand, �that neither the Federal Reserve
Board, Federal Reserve System (FRS), nor the Federal Reserve Banks (FRBs) operate, offer, sponsor,
or engage in any commercial dealings with the general public.� However, I sent the specific information
with the intent for the Federal Reserve to execute and or establish using my assistance! If I am not
granted a response then I would like to know, how am I going to get credit for the proposal or
establishment and if so, I would like that credit in the way that I specifically stated in the information! I
would like a response regarding the information that I sent both on April 9, 2020, and April 13, 2020! I
also understand that the Board and other entities are very busy and have many daily responsibilities
they must attend to, but I need any form of confirmation and communication from the Federal Reserve
Board! What was to be advised is completely different in this circumstance! I do not know if the Board
as even looked at the information nor as read any of the information or even understands the
information? This proposal is of extreme value! The whole point of me even contacting the Federal
Reserve was to establish the information given, using my assistance! Please do not waste my time!
Main Street Lending Facility – EBITDA Restriction
Cara Schembri [cara@renttherunway.com]
4/16/2020 8:08:11
Dear Chairman Powell:
Rent the Runway, Inc. agrees and sign-ons to the comment submitted by
TechGC on April 15, 2020 that other metrics in addition to EBITDA should be
used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.
About RTR:
RTR is a female-founded and led fashion rental company that lets
customers rent designer clothing and accessories, as well as kids apparel
and home goods, at a fraction of the retail price.
RTR has built a community of 12M+ members and partners directly with an
ecosystem of 1,000+ designer brands.
RTR is the largest dry-cleaner in the United States, ships to 77% of
U.S. zip codes, and operates a 100% reverse logistics business with an
entirely vertically-integrated operation.
RTR is headquartered in NYC and has fulfillment centers in New Jersey
and Texas.
In Fall 2019, our peak season, RTR employed 2,700 people across New
York, New Jersey, Texas, California, Colorado, Illinois and Washington,
DC.
Best regards,
Cara Schembri
-Cara Schembri
General Counsel
917.287.7294
cara@renttherunway .com
345 Hudson Street, 6th floor
<https ://maps.google .com/?
q=345+Hudson+Street,+6th+floor++New+York,+NY+10014&entry=gmail&source=g>
New York, NY 10014
<https ://maps.google .com/?
q=345+Hudson+Street,+6th+floor++New+York,+NY+10014&entry=gmail&source=g>
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Main Street Lending
4/16/2020 8:07:51
jcooner Ocooner@theitmo.com}
NONCONFIDENTIAL // EXTERNAL
Hello,I have two businesses that were in good standing at the end of 2019, 'Confiae� Busm e
mormation
= �♦ I
l
wasn able to part1c1pate m f e PPP program, so your new MSN:Fisthe only option 1flave o ge my
businesses back up and running.♦ I contacted the bank I have a business relationship with, Regions
Bank, and they have no idea on how to assist or even if they will be participating in the MSNLF.♦ Can
you please have someone assist me in applying for and successfully participating in your new loan
program for my two businesses?♦ I am afraid I won't receive any assistance from my bank, and the
SBA hasn't been of any assistance either.♦ I really need your assistance as I can't find anyone else that
has any idea on how to help.♦ Please advise.Thanks for any assistance.Best Regards,
Jason R. Cooner
Chief Executive OfficerlTMO US
7
corporate +1 833.843.4866mobile CelrPhon e Nuriibe'
email jcooner@theitmo .comweb liftps:/7www. tneffmo .com
The information transmitted is the property of ITMO US and is intended only for the person or entity to
which it is addressed and may contain confidential and/or privileged material.♦ Statements and
opinions expressed in this email may not represent those of the company.♦ Any review, retransmission,
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any error or omission in the contents of this message, which arises as a result of email transmission.
Judy Schnobrich [jschnobrich@people-inc.org]
4/16/2020 6:32:07
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
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Main Street Lending
Precious Scott [pscott@people-inc.org]
4/16/2020 6:05:49
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
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Main Street Lending
Vicki Wrigley [vwrigley@millikin.edu]
4/16/2020 6:03:24
To whom it may concern:
As a non-profit private institution of higher education, we submit the following comments in regards to
the Main Street Lending program. Specifically, we ask that the Federal Reserve update the guidance to
clarify that non-profit private and public institutions are eligible for the Main Street Lending program.
Our institution is one of the largest employers in our local community, and we are facing a major cash
flow crisis in light of the reduced revenue and increased expenses imposed by the COVID-19
pandemic. Our institution expects to refund nearly $2 million in room and board charges alone.
Anticipated sources of auxiliary revenue have dried up as campus events have been canceled.
Summer programs that provide revenue also have been canceled. At the same time, our institution is
facing additional costs of course delivery, auxiliary activity refunds, and student support, as well as
cleaning and other general costs.
Recruiting students for the upcoming school year beginning in August 2020 is proving to be challenging
because of the unknown factors surrounding the COVID-19 pandemic and how long the need for social
distancing will continue. Some of our students are already contacting us about the difficulty of payment
of outstanding balances in the current year because of employment layoffs and furloughs in their
families. Many of our students are recruited from out of state and are unwilling to commit to leaving
their home states for the fall semester. Because of these circumstances and a possible reduced
enrollment of 8 to 10%, we are projecting an operating budget deficit for the 2020-21 academic year of
up to $10 million. A reduction in enrollment for an incoming class translates to smaller class size for the
following 3 years and possible large deficits for those years as well.
Our institution is seeking low cost loans to help address the financial impact of the COVID-19 crisis,
and we are interested in accessing the credit and loans available under the Main Street Lending
program, recently announced by the Federal Reserve. Unfortunately, we are concerned with a major
barrier keeping our institution from accessing these programs. There has been confusion about the
Main Street Lending program and whether or not non-profits are eligible, because the current guidance
is silent. We ask that the Federal Reserve update the guidance to clarify that non-profit private and
public institutions of higher education, with direct borrowing authority, are eligible for the Main Street
Lending program.
It is vital to provide this access to low-interest loans to non-profit colleges and universities financially
devastated by the pandemic and struggling to continue to educate and assist students and employ the
millions of faculty and staff who work on campuses around the country. We look forward to working
with you on this and other important loan programs as the Federal Reserve responds to the COVID-19
crisis.
Thank you for your attention.
Vicki Wrigley
Director of Financial Services
Millikin University
1184 W. Main Street
Decatur IL 62522
217-362-6485
Main Street Lending Program - Requested Modification
Brent King [Brent.King@pfgc.com]
4/16/2020 5:59:17
Dear Federal Reserve Board,
The foodservice distribution industry is a critical part of our food supply chain in this country, providing
the transportation and logistics support to ensure that fresh, safe food produced by America's farmers
and manufacturers, fills the kitchens, shelves, and pantries of our nation's hospitals, nursing homes,
assisted living centers, restaurants, schools, military bases, hotels, entertainment venues, correction
facilities and other public service institutions.
The industry as a whole operates more than 15,000 distribution centers and sources and delivers
nearly 24 million cases of food and goods per day. The National Restaurant Association estimates that
restaurants could sustain $225 billion in losses and eliminate 5-7 million jobs over the next three
months as a result of the COVID-19 emergency.
We are already experiencing significant revenue impacts with a direct impact on jobs as restaurant
customers close their doors and are unable to pay outstanding bills. We expect deeper and more
substantial impacts over the next days and months without intervention or a return to normal
operations.
The Main Street Lending Program is vital to ensure that this industry can survive the current crisis and
be in a position to rebound and help the nation recover when the economy reopens. An issue in the
MSLP has arisen that we need to call to your immediate attention. There is a provision in the MSLP
that requires a borrower to calculate and deduct from its maximum loan the amount of its "committed
but undrawn debt." While the apparent intent of this provision is to require a business to use its
available debt/credit before taking advantage of MSLP loans, it may have unintended consequences for
many distributors and make them ineligible for a MSLP loan because many banks do not allow
borrowers to draw the entire amount of the committed debt without significant penalties and restrictions
on operations. To ensure that the MSLP provides the critical assistance that foodservice distributors
need, we request a modification to the MSLP as follows:
Requested change:
*
Substitute "available" for "committed" in item 5.
*
Add the following clarifying language: "For purposes of determining the eligible loan amount
(or, for purposes of this provision), an eligible borrower's existing outstanding and available but
undrawn bank debt does not include any amount that, if drawn, would cause the Borrower to suffer
fees, penalties, restrictions, or limitations on its operations. Lease financing obligations are also
excluded."
Thank you for your consideration of this important modification to MSLP.
Best regards,
A. Brent King
Senior Vice President, General Counsel and Secretary
Performance Food Group Company
12500 West Creek Parkway
Richmond, Virginia 23238
804-484-7993 - office
Cell Phone Number
The information contained in this communication is confidential, may be privileged pursuant to the
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Loans to nonprofits with 500-10,000 employees
"Kohomban, Jeremy" [JKohomban@childrensvillage.org]
4/16/2020 5:27:46
Dear Treasury Department:
Founded in 1851, The Children's Village is one of the nation's oldest child serving charities. Today we
are caring for over 400 children in various residential programs and serving over 1,5000 children in the
community, many living in New York's neighborhoods most impacted by COVID-19. Of the 1,400 staff
employed by The Children's Village, over 1200 of us are essential and we report to the frontlines every
day. 24 hours a day, seven days a week.
As the Treasury Department works to create a program as directed under the CARES Act section 4003
(c)(3)(D) to provide financing to banks and other lenders to make loans to nonprofits and other mid-size
business of between 500-10,000 employees, we request that the program:
* Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year
amortization
* Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
* Payments shall not be due until two years after a direct loan is made
* Employee retention provisions should begin on the date that loan funding is received by the
borrower
* In implementing any workforce restoration and retention provisions, "workforce" should be defined
as full-time employees or full-time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck
Protection Program, which contains loan forgiveness provisions which are critical to these
organizations and necessary to help ensure they will be able to continue to provide services during the
crisis and assist with our nation's recovery efforts when the crisis is over.
Charitable nonprofits play the third largest employer in our nation's economy and as valued problem
solvers. The recommendations above will help to keep these organizations financially strong and allow
them to continue to meet the immediate needs of their communities while planning for the future when
many of their services will be needed most. Nonprofit organizations are our country's only institutions
solely focused on making communities stronger. In the toughest times, we do the toughest work. When
it's time to restore and repair our wellbeing, these community based institutions need to be equipped to
do that as well and their unique needs should not be overlooked.
Dr. Jeremy Christopher Kohomban
President and Chief Executive Officer,
The Children's Village
President
Harlem Dowling - West Side Center
p. 914-693-0600 X 1201
p. 212-749-3656 X 1201
www. childrensvillage .org<http ://www. childrensvillage .org/>
Main Street Lending Facility – EBITDA Restriction
Kala Sherman-Presser Personal Email Address
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.
<http ://www. earnup .com/>
* Kala Sherman-Presser*
Head of Legal
*E* kshermanpresser@earnup .com | *P* (415) 729-5146
<http ://facebook .com/earnupnow> <http ://twitter .com/earnup>
<https ://www. linkedin .com/company/earnup> <https ://angel.co/earnup> We're
hiring! <http ://www. earnup .com/careers/>
<http ://smart.earnup .com/vsig/kshermanpresser/cnbc.html>
4/16/2020 4:36:49
Main Street Lending Facility – EBITDA Restriction
Megan Niedermeyer [megan.niedermeyer@gusto.com]
4/16/2020 4:35:31
We agree and sign-on to the comment submitted by TechGC on April 15, 2020 that other metrics in
addition to EBITDA should be used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.***Insert 1-2 sentence novel paragraph and signature***
Gusto
Megan Niedermeyer, Head of Legal & Compliance
Sent from my iPhone
Main Street Lending
Michael Lawler [Michael.Lawler@ccrcda.org]
4/16/2020 4:31:14
As Treasury works to create a program, as directed under the CARES Act section 4003(c)(3)(D), to
provide financing to banks and other lenders to make loans to nonprofits and other mid-size business
of between 500-10,000 employees, we request that the program include the following provisions:
* a 0.50% interest rate for 501(c)(3) charitable nonprofits at a 5 year amortization;
* give a prioritization to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts;
* no payments shall be due until two years after a direct loan is made;
* allow employee retention provisions to begin on the date that loan funding is received by the
borrower; and
* implementing any workforce restoration and retention provisions, that �workforce� should be
defined as full-time employees or full-time equivalents.
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck
Protection Program (PPP). PPP contains loan forgiveness provisions that are critical to these
organizations, and necessary to help ensure they can continue to provide services during the crisis,
and assist with recovery efforts when the crisis is over.
Charitable nonprofits are the third largest employer in our economy and will be key to the nation�s
overall recovery. The recommendations above will help to keep nonprofits financially strong and allow
them to continue meeting the needs of our communities, both now and in the future. Nonprofits are our
country's only institution solely focused on making communities stronger. In the toughest times, we do
the toughest work. When it's time to restore and repair our wellbeing, these community based
institutions need to be equipped to do that as well and their unique needs should not be overlooked.
Michael A. Lawler, CFO/COO
Catholic Charities of the Diocese of Albany, NY
Sent from Mail<https ://go.microsoft .com/fwlink/?LinkId=550986> for Windows 10
Main Street Lending
Sharon Plant [splant@people-inc.org]
4/16/2020 4:19:31
To Whom it May Concern,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Sincerely,
Sharon Plant
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Main Street Lending
Bart Naylor [bnaylor@citizen.org]
4/16/2020 3:57:52
To: FRS officers
Public Citizen strongly urges full transparency with this program, including the names of recipients,
terms and other relevant data. No lender would expect any less. Since the American taxpayer is
effectively the lender, we should be fully informed. The chance to play favorites, to lock out disfavored
sectors, to engage in other inequities can be deterred if the public can see who and how gets these
prodigious sums. There should be no stigma attached, as no business was responsible for the virus.
We heartily endorse the comments from Commissioner Ramamurti in his letter to Chair Powell, and his
NYTimes letter.
Bartlett Naylor
Financial policy advocate
Congress Watch
a division of
PUBLIC CITIZEN
215 Pennsylvania Ave SE
202.580.5626
@bartnaylor
author-TOO Big
Main Street Lending
Wendy Menz [wmenz@people-inc.org]
4/16/2020 3:52:56
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Wendy Menz
People Inc
Program Director
Orchard Park Day Hab
Broadway Day Hab
Lancaster Day Hab
wmenz@people-inc .org
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"Main Street lending"
Bill Keyes Personal Email Address
(re. money printer request }
4/16/2020 3:32:22
Dear Mr. Chairman
I am writing to receive my fair share of money being printed to inject into our economy. i humbly
demand the maximum amount allowed by law, and� ��
wish to receive that amount every month for the rest of my life. you see i am entitled to this free money
without doing any work, because i am alive.�
I will surely spend this money to the best of my ability to stimulate the economy to the fullest extent.
Much Appreciation and thanks
Bill Keyes
Main Street Lending
Carlos Aviles Personal Email Address
I hear money printers are up and running, “brrrr”. I am seeking $100,000. I
have my eyes on a 2020 Ford Mustang GT350R and would like to purchase this
with the newly printed Trump bucks. Get back to me for contact information.
Thank you
4/16/2020 2:54:09
Main Street Lending Facility – EBITDA Restriction
Brooke Smarsh [brooke@flow.io]
Flow Commerce agrees and signs-on to the comment submitted by TechGC on
April 15, 2020 that other metrics in addition to EBITDA should be used to
determine eligibility and the permissible size of a loan under the Main
Street Lending Facility. We were in the process of hyper-growth, hoping to
hire an additional 40 people this year. But we are a tech vendor to
retailers and our business is significantly impacted. Access to this loan
would be extremely helpful to Flow to get through this tough time.
Please consider allowing other metrics.
Sincerely,
Brooke Smarsh
________
*Brooke Smarsh - *General Counsel
m.917-494-7787 | www. flow.io
*Global Ecommerce now has Flow*
4/16/2020 2:38:52
Main Street Lending
Will Stennett [wstennett@vficil.org]
4/16/2020 2:34:26
To: The Board of Governors of the Federal Reserve System
The government distinguishes "large" from "small" organizations in many ways, but the most common
is whether they have 500 or more employees. On this basis, while small nonprofits are collectively
important, the large ones do most of the work, particularly in areas like residential care (e.g. homeless
shelters, foster care, homes for the developmentally disabled, etc.) They are individually critical
partners to state and local government in maintaining the social safety net. They are on the front lines
of the COVID-19 crisis, and they are at the breaking point.
Unfortunately, policy makers and funders underappreciate the importance of the large groups and often
believe that they are stronger, more resilient, and less worthy of support than their smaller colleagues.
Nothing could be further from the truth. Yet, so far, the large groups have been excluded from the most
important federal aid-The Paycheck Protection Program-because of their size.
Without immediate assistance, some large nonprofits may not make it through May; few, if any, will be
able to continue services that are needed more than ever during the COVID-19 crisis and its aftermath.
The failure of any large group-and it will likely be more than one-will tear the fabric of our country's
social safety net with devastating consequences for all. Even if the government somehow picks up the
pieces, it will end up costing far more in financial and human terms than it would have to prevent the
failure in the first place.
Large nonprofits are under enormous pressure and need assistance now. There are lots of reasons for
this:
* an inclusive nonprofit culture that keeps large and small "in the same tent";
* a widespread feeling that small is a proxy for diverse, community-based, mission-driven or
otherwise inherently valuable over and above the efficiency and effectiveness of their programs;
* donors preferring to make many grants to small organizations.
Under normal circumstances, nonprofits may have two weeks of cash; very few have any meaningful
endowment; and most have limited access to credit. Their operating margins are razor thin (an average
of 1%), even before the reduction of revenue and increase in expenses associated with the COVID-19
crisis. The precarious financial condition of large nonprofits is not a function of inefficiency or poor
management. It is the inevitable consequence of the context in which they operate.
Larger human service organizations are overwhelmingly funded by government. Most government
funding does not cover the full cost of doing the associated work. Government funding also creates
cash-flow issues since, unlike grants, it is paid after the work has been done and can be subject to long
and unpredictable delays. Large groups also have fixed and semi-fixed costs: real estate, workforces
with collective bargaining protections, and government contracts with detailed stipulations about exactly
what is to be delivered. As a result, cash is always an issue for large nonprofits but, unlike large forprofits, they do not have access to the capital markets, cannot easily unlock illiquid assets, and are
unable to use bankruptcy to restructure while continuing to deliver services. So, any increase in costs,
reduction in revenue, or delay in cash receipts will put some of them permanently over the edge. Yet all
these things are happening simultaneously as they scramble to maintain essential services, keep staff
safe, and not run out of money during May, a three-payroll month. These groups cannot be allowed to
fail.
Here is what must be done:
1. Policymakers should follow the plea of the broad nonprofit community that the CARES Act and all
other federal aid be amended to be available to larger nonprofit groups.
2. States should be allowed to make large advances against registered government contracts to any
large, long-term nonprofit partner in good standing that faces immediate liquidity challenges.
3. Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5-year
amortization
4. Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
5. Payments shall not be due until two years after a direct loan is made
6. Employee retention provisions should begin on the date that loan funding is received by the
borrower
7. In implementing any workforce restoration and retention provisions, "workforce" should be defined
as full-time employees or full-time equivalents
Getting the money to them now, and accounting for it later, while entailing a small amount of theoretical
risk, is the only viable strategy. If things don't change immediately, some of these nonprofits will falter,
leaving the vulnerable people they serve, their employees, and our country far worse off. It is an
economic and moral imperative that government rescue its long-standing partners. The total dollars
required is a minuscule fraction of what is being spent to support for-profit businesses while the return
on investment is larger in human and financial terms.
William H. Stennett
Chief Officer of Developmental Disabilities & HSCBS Policy
69 East Beau Street
Wasington, PA 15301
Cell Phone Number
Office 724-223-5115 Ext. 2114
Comments on CARES ACT
"Gettman, William" [William.Gettman@northernrivers.org]
4/16/2020 2:12:17
As the Treasury Department works to create a program as directed under the CARES Act section 4003
(c)(3)(D) to provide financing to banks and other lenders to make loans to nonprofits and other mid-size
business of between 500-10,000 employees, we request that the program:
* Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year
amortization
* Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
* Payments shall not be due until two years after a direct loan is made
* Employee retention provisions should begin on the date that loan funding is received by the
borrower
* In implementing any workforce restoration and retention provisions, "workforce" should be defined
as full-time employees or full-time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck
Protection Program, which contains loan forgiveness provisions which are critical to these
organizations and necessary to help ensure they will be able to continue to provide services during the
crisis and assist with our nation's recovery efforts when the crisis is over.
Charitable nonprofits play the third largest employer in our nation's economy and as valued problem
solvers. The recommendations above will help to keep these organizations financially strong and allow
them to continue to meet the immediate needs of their communities while planning for the future when
many of their services will be needed most. Nonprofit organizations are our country's only institutions
solely focused on making communities stronger. In the toughest times, we do the toughest work. When
it's time to restore and repair our wellbeing, these community based institutions need to be equipped to
do that as well and their unique needs should not be overlooked.
Thank you
William Gettman
CEO
Comments on Main Street Lending
"Christian-Michaels, Stephen" [Stephen.
Christian-Michaels@wfspa.org]
4/16/2020 2:04:49
NONCONFIDENTIAL // EXTERNAL
As the Treasury Department works to create a program as directed under the CARES Act section 4003
(c)(3)(D) to provide financing to banks and other lenders to make loans to nonprofits and other mid-size
business of between 500-10,000 employees, we request that the program:
* Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year
amortization
* Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts
* Payments shall not be due until two years after a direct loan is made
* Employee retention provisions should begin on the date that loan funding is received by the
borrower
* In implementing any workforce restoration and retention provisions, "workforce" should be defined
as full-time employees or full-time equivalents
Many nonprofits employ more than 500 employees and have not been able to access the Paycheck
Protection Program, which contains loan forgiveness provisions which are critical to these
organizations and necessary to help ensure they will be able to continue to provide services during the
crisis and assist with our nation's recovery efforts when the crisis is over.
Charitable nonprofits play the third largest employer in our nation's economy and as valued problem
solvers. The recommendations above will help to keep these organizations financially strong and allow
them to continue to meet the immediate needs of their communities while planning for the future when
many of their services will be needed most. Nonprofit organizations are our country's only institutions
solely focused on making communities stronger. In the toughest times, we do the toughest work. When
it's time to restore and repair our wellbeing, these community based institutions need to be equipped to
do that as well and their unique needs should not be overlooked.
Stephen Christian-Michaels
Chief Executive Officer of Family Services of Western Pa
A member of Wesley Family Services
615 Alpha Drive, Suite 250, Pittsburgh, PA 15238
412-342-2351
Cell Phone Number
412-406-8152 Fax
Stephen.Christian-Michaels@wfspa .org
[Wesley Family Services]
"Empowering children, adults and families by providing transformational care"
[Transformation Empathy Excellence Innovation Inspiration]
[follow me on facebook]<https ://www. facebook .com/WesleyFamilyServices/> [follow me on twitter]
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Main Street Lending Facility – EBITDA Restriction
Ron Bell [ron.bell@collectivehealth.com]
4/16/2020 1:22:08
Dear Chairman Powell:
CollectiveHealth, Inc. ("Collective Health") agrees with and signs on to
the comment submitted by TechGC on April 15, 2020 that metrics in addition to
EBITDA should be used to determine eligibility and the permissible size of a loan under
the Main Street Lending Facility.
As currently constructed, SBA affiliation rules for the Paycheck Protection Program and
the exclusive use of EBITDA metrics for the Main Street Lending Facility may exclude
many startup companies from participating in the economic relief offered by either
program. In devoting $377 billion in emergency relief funds to aid small businesses
under the Coronavirus Aid, Relief, and Economic Security Act, Congress cannot have
intended to deliberately exclude from loan consideration early-stage startup businesses
that collectively employ—and serve—many thousands of Americans.
Collective Health, for example, is an early-stage startup that adjudicates healthcare
claims for more than 200,000 employees of other businesses in all 50 states. Our
clients span industries that range from agriculture, content, food, and technology to
transportation, and our 484 employees serve them by helping their people find,
navigate, and pay for healthcare. This role is even more critical during a pandemic, as
employees and employers seek guidance in how to find care and in how to return to
work safely.
Thank you for the opportunity to provide this feedback on the Main Street Lending
Facility and for the Federal Reserve’s efforts to support
growth-stage technology startups during unprecedented economic turbulence. Both are
deeply valued and appreciated.
Respectfully,
Ron Bell
Chief Legal & Administrative Officer
Collective Health
-Collective Health introduces the Employer-Driven Healthcare
Economy <https ://collectivehealth .com/our-mission/>
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Main Street Lending Facility � EBITDA Restriction
Jordan Zamir [jordan@secondmeasure.com]
4/16/2020 3:21:01
We agree and sign-on to the comment submitted by TechGC on April 15, 2020 that other metrics in
addition to EBITDA should be used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.
Second Measure is an early stage venture backed startup that does not yet have positive EBITDA but
is providing a valuable service to clients. Our clients span public and private investors, financial
technology businesses as well as consumer facing businesses. We also have recently begun to
provide the Chicago Fed with data to help it understand the impact of COVID and shelter in place
orders on consumer behavior. As an early stage startup attempting to extend our limited runway in
these uncertain times, we would welcome the opportunity to obtain debt on favorable terms via the
Main Street Lending Facility if it were made available to companies like us.
Sincerely,
Jordan Zamir | General Counsel, Second Measure | site<https ://secondmeasure .com/> |
blog<https ://secondmeasure .com/datapoints/>
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Main Street Lending Facility – EBITDA Restriction
Ashley Harris [aharris@figure.com]
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.
Figure is a financial technology company leveraging blockchain, AI, and
analytics to deliver innovative home equity release solutions and other
products that help improve the financial lives of our customers. We are
building a blockchain protocol to fundamentally transform finance.
Best regards,
Ashley Harris
-Ashley Harris
General Counsel
(917) 855-3213
San Francisco
figure .com <http ://www. figure .com/>
-This message and its contents are confidential. If you received this
message in error, do not use or rely upon it. Instead, please inform the
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4/16/2020 3:18:57
Main Street Lending Facility – EBITDA Restriction
"Zamir, Jordan" [zamir2001@lawnet.ucla.edu]
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.***Insert 1-2 sentence novel paragraph and signature***
Second Measure, Inc.
Jordan Zamir
General Counsel
4/16/2020 3:12:53
Main Street Lending Facility – EBITDA Restriction
Jeanine Wright [jeanine@simplecast.com]
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.
An EBITDA requirement makes no sense if the true intention is to help small
"main street" businesses since most operate for many years at negative
EBITDA. With these additional funds, we'd be able to significantly grow our
team with stable, well-paying jobs. Our company is entirely remote, so this
could create jobs immediately for workers that can work effectively while
social distancing.
Regards,
*Jeanine Percival Wright*
Chief Operating Officer & Chief Legal Officer
<http ://simplecast .com/>
<http ://www. simplecast .com>
Cell Phone Number
E: jeanine@simplecast .com
4/16/2020 3:10:52
MAIN STREET LENDING --comments
"Kaplan, Lawrence D." [lawrencekaplan@Paulhastings.com]
4/16/2020 2:14:29
On behalf of our client Integral Communities, Inc. (“Integral Communities”) and its partner Lennar
Corporation, the nation’s largest homebuilder, we encourage the Federal Reserve and the Treasury to
expand their programs under the CARES Act and other authority to provide much needed relief for the
real estate sector.
The COVID-19 crises has hit the real estate and housing industry especially hard, and the economic
damage could be even greater and longer lasting than that of the subprime mortgage crisis unless the
federal government takes swift and concerted action among the various housing agencies and
government sponsored entities. Home construction is both an important engine for economic growth
and essential to making the American dream of home ownership a reality. Spending within the housing
market (factoring both construction of new homes and spending on housing services) accounts for
approximately 15% of the U.S. GDP. However, the current economic crisis caused by COVID-19 has
starved development and construction companies from the necessary capital they need to continue
land development and housing construction, which will have a long-term effect of exacerbating the
current housing affordability crisis.
The financial market support facilities being made available exclude critical companies in the housing
sector such as Integral Communities, a real estate development company whose developments create
many thousands of jobs that purchases land, secures the necessary governmental approvals for new
housing projects, and installs necessary utilities and infrastructure for its partner Lennar Corporation.
Specifically, the blanket restrictions on refinancing existing credit imposed by the Main Street Loan
Facilities are problematic. These restrictions are uniquely burdensome on developers like Integral
Communities that rely on multiple tranches of loans that support each individual stage of the process of
building out housing developments, first, for land acquisition, and then for development of required
infrastructure—utilities, roads, bridges, schools, parks and open space—before ultimately providing
thousands of affordable and market-rate for sale and multi-family homes for working class families.
We further ask that the Federal Reserve and Treasury specifically focus on infrastructure and housing
sectors that have been neglected in targeted relief to-date. These companies are critical in rebuilding
the American economy once businesses are permitted to “re-open” and need financing lifelines to
continue operating during the crisis.
____________________________________________________________________________
[Paul Hastings LLP]<http ://www. paulhastings .com/>
Lawrence D. Kaplan | Chair, Bank Regulatory
Paul Hastings LLP | 875 15th Street, N.W., Washington, DC 20005 | Direct: +1.202.551.1829 | Main:
+1.202.551.1700 | Fax: +1.202.551.0229 | lawrencekaplan@paulhastings .com| www.
paulhastings .com<http ://www. paulhastings .com/> Follow
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phglobalbanking .com/>
Fintech and Payments Group (Chambers 2019 Fintech Guide Band 1: USA – Legal; and Legal 500 Tier
1).
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+Main+Street+Lending+Facility+�+EBITDA+Restriction
Victoria Libin [victoria.libin@brightmachines.com]
4/16/2020 2:13:16
We+agree+and+signon+to+the+comment+submitted+by+TechGC+on+April+15,+2020+that+other+metrics+in+addition+to+
EBITDA+should+be+used+to+determine+eligibility+and+the+permissible+size+of+a+loan+under+the+
Main+Street+Lending+Facility.***Insert+1-2+sentence+novel+paragraph+and+signature***
Sent from Mail<https ://go.microsoft .com/fwlink/?LinkId=550986> for Windows 10
Main Street Lending
==
ersona1 Email -ress
Nicole Malinowski �"
4/16/2020 1:37:51
NONCONFIDENTIAL // EXTERNAL
Dear Honorable,
I am writing on behalf of the wide and diverse Live Events Industry that represents $845 billion in
business sales annually and employees 5.9 million jobs worth $249 in labor income contributing $104
billion to federal, state and local taxes.
I am an owner of a Music Festival that has been around for 43 years. Our event takes place once a
year and we rely on ticket sales to cash flow the business. All staff are 1099 and with the current state
of affairs, it is unknown as to when we will be able to Ian and activate our event. =rBusiness
One key piece of information we would like to bring to light is how the small festival owner is being
missed in the current relief legislation (PPP Loan)
Some context: The relief being offered is helpful to our 1099 employees as well as festivals and events
that are of a scale that can afford full time year round salaried employees. We, however, are currently
being overlooked.
We would be considered a "mom and pop" or "boutique" festival event. We welcome about 3,000
guests to our festival each year. This is a size that does not allow for full-time, year round employment.
It relies on contracted skilled labor for pre-production, promotion, and on-site management and staff.
Our event has brought joy to tens of thousands of people over our long history. We are at risk of closing
our business. We need support.
If relief were provided to events of our scale, the benefits would not only reach our audience, but the
people that we employ across marketing, digital media, production, advertising, event staff, local
businesses, musicians, and event companies who rely on us year over year to help their own bottom
line as vendors and service providers. Not to mention, our event brings in ancillary revenue to the host
city via hotel sales, bar and restaurants in the area, and tourism from outside visitors.
We are asking to be eligible for relief loans in effort to stay in business, not default on current loans,
and to keep our tradition alive, bringing great benefit to all involved.
I thank you once again and urge you to sponsor and support legislation that addresses the crisis in our
industry.
Sincerely,
Live Events Coalition Supporter/ Music Festival Owner
Nicole Malinowski
Main Street Lending Facility – EBITDA Restriction
Justin Aragon [justin@listreports.com]
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.
-Justin Aragon
VP of Legal, ListReports
510.761.2861
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contain proprietary and confidential information. This email, and any
attachments, are intended for the named recipient(s) only and may not be
distributed or copied. If you have received this email by mistake, please
notify the sender by reply email, do not disclose the content to anyone,
and permanently delete it, and any copies or printouts.*
4/16/2020 12:58:03
Main St Lending
Jamie Marzec
Personal Email Address
4/16/2020 12:52:53
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Jamie Marzec
Sent from my iPhone
Main Street Lending Facility – EBITDA Restriction
Greg Baden
Personal Email Address
4/16/2020 12:39:33
We agree and sign-on to the comment submitted by TechGC on April 15, 2020 that other metrics in
addition to EBITDA should be used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.
As the General Counsel of Aras Corporation, a business-to-business enterprise software company that
has grown 40% or more year-over-year for the last several years but is not yet EBITDA positive, we
would greatly benefit from potentially using the Main Street Lending Facility. At the time the COVID-19
pandemic began, Aras was negotiating terms on a debt facility. Due to the rapidly deteriorating market
conditions, the lender refused to fund the facility and Aras is still seeking opportunities to replace the
funding we anticipated receiving. The Main Street Lending Facility would be a timely and very helpful
alternative option to replace that funding, but that will only be an option if eligibility measures other than
positive EBITDA are introduced.
Best regards,
Gregory Baden
General Counsel
Aras Corporation
www. aras .com
gbaden@aras .com
Main Street Lending Facility – EBITDA Restriction
Arthur Roberts [arthur.roberts@healthiq.com]
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility.
We are a health and life insurance broker that has seen an impact from the
coronavirus pandemic. Because we are a venture-backed company, we did not
have positive EBITDA in 2019, but employ over 200 people across several
states. It could help us save jobs if we were eligible for the Main Street
Lending Facility, and we urge you to expand the eligibility criteria to
include us and other companies in our position. Thank you.
Best regards,
Arthur Roberts
--
Arthur Roberts
Vice President, Head of Legal & Compliance
(916) 769-7686
arthur.roberts@healthiq .com
This message, including attachments, is confidential and may contain
information protected by the attorney-client privilege or work product
doctrine.
4/16/2020 12:24:03
"mikeysmom87 ." Personal Email Address
In support of the many employees of a regional non-profit health and human
services agency that provides programs and services to countless people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
many non-profit agencies are fully engaged in dealing with the COVID-19
crisis. They must ensure that more than 150 community-based homes and
services for people with disabilities remain as safe as possible and are
staffed 24/7. The vulnerable people that depend on these agencies deserve
no less. However, because they are providing essential services during the
crisis, these agencies have incurred highly unusual increased costs in
staffing, PPE, and cleaning services.
Since some of these agencies arenot eligible for the Payroll Protection
Program (PPP) due to their size and the fact that they must remain fully
operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due
to COVID-19. This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support.
Kasey Rubinstein
4/16/2020 12:09:47
Main Street Lending Facility – EBITDA Restriction (Segment)
Mark Kahn [mark.kahn@segment.com]
Hi,
I am the General Counsel and VP of Policy for Segment. We are a
business-to-business software service based in San Francisco and employ
more than 500 people globally (most are in the US).
We agree and sign-on to the comment submitted by TechGC on April 15, 2020
that other metrics in addition to EBITDA should be used to determine
eligibility and the permissible size of a loan under the Main Street
Lending Facility as having this facility available would be important to us.
Thank you.
Best regards,
Mark Kahn
4/16/2020 12:08:51
"Main Street Lending"
loafershews Personal Email Address
4/15/2020 11:29:01
I am asking that the Mid-Size loan program be forgivable or People-Inc. We provide work for disabled
adults. Thank you.Mike Todoroff
Main Street Lending
Mark Nelson Personal Email Address
4/15/2020 11:06:10
The Problems: I worked in the $1.2 trillion leveraged loan market for 16 years. I read that the Main
Street Lending program can only be loaned to companies with <4.1x leverage guideline based on
unadjusted EBITDA. This creates several major problems: 1.) nobody uses unadjusted EBITDA in the
leveraged loan market and it shouldn't be used as there are material one-time expenses that should be
add backs such as transaction expenses, severance, etc.; however, using adjusted EBITDA becomes
highly discretionary and it would be tough to put criteria around EBITDA adjustments (see my solution
below); 2.) the leverage guidelines are too low and most companies that actually need the financing
won't be able to qualify for it. What is the purpose of a Main Street Lending fund if you don't lend it to
companies that actually need it? Most companies with unadjusted leverage of <4.1x will be able to get
additional loans without the Main Street Lending program. 3.) using leverage as a threshold is not a
good criteria as some industries are capex intensive and can't even generate positive FCF with 4.0x
leverage while there are other industries that can generate cash flow with >7.0x leverage (i.e.
established software companies and distributors).
My solution: Make the loan based off the cash flow statement from the most recent audit. Specifically,
cash flow after operations - capex (which is PP&E from investing activities), is one of the best indicators
on if the Company is generating recurring free cash flow (FCF) as it accounts for Net Income (including
interest expense), changes in working capital and adds back non-cash items that are included in the
P&L. If there are any material increases in debt since the audit, the PF interest from the new debt
should be factored into the calculation (same thing for the interest being borrowed from the Main Street
Lending program). Most importantly, it's simple and you could process applications quickly, accurately
(pulled from the audit), and the calculation can't be manipulated (cash is king and so is the ability to
generate cash!). All companies in the leverage loan market require annual audits and FY 19 audits are
likely available for most companies at this point.
I think the purpose of the Main Street Lending ("MSL") facility is to help save companies from
bankruptcy that deserve saving. Not every company deserves to be saved, but there are a lot of good
companies that will be fine if they can just get a temporary life line until the economy gets back to
normal conditions. If there are too many restrictions and the focus is on leverage and not cash flow, the
MSL is not going to save us from having historic default rates in Corporate America. Getting these
loans out soon is critical, so the criteria for accessing these loans needs to be straight forward and
based off reliable and readily available information that can effectively determine if a company is worth
saving. In my view, if a company can generate FCF in "normal conditions" and employs thousands of
people in the US, it seems like a deserving company to save regardless of what leverage is. Not all
industries and companies are created equal when it comes to leverage.
Respectfully submitted,
Mark Nelson
Main Street Lending - Comments
"Pickard, Gary" [PickardG@pacden.com]
4/15/2020 11:04:54
Thank you for providing an opportunity to comment on the Main Street Lending Programs (MSLP). We
appreciate the effort the government is making to help businesses of all sizes that have been impacted
by COVID.
More than 13,000 individuals (with less than $2.5b in revenues - making us still eligible) rely on us for
their livelihoods across more than 23 states. They consist of a broad range of team members, from
dentists to call center representatives; oral healthcare professionals of all ages, and education levels.
Overall, the MSLPs are too much like a normal credit facility, not enough like a bailout or assistance
that most companies need right now to continue operating and employing people.
* The interest rates are too high to provide meaningful relief (2.5% minimum, up to 5.5%, is not
cheap money); and
* The EBITDA limits are too low to allow for distressed companies to access the additional credit they
need (companies will need something higher, in the range of 10-12x to help).
The terms of the MSLPs are not the same as those outlined under "Assistance for Mid-sized
Businesses" in Section 4003(c)(3)(D) of the CARES Act. The MSLPs and other facilities will use only a
portion of the funds allocated to Treasury under the CARES Act, so further programs/facilities may be
possible, and the full relationship between these facilities and the MSLPs are not defined.
Title IV seem to have better terms (2% interest rate for example). It is not clear that Treasury is going
to plan more programs. Are you? If there is any sense that there is more coming around the corner that
would be good to know.
Again, thank you for the opportunity to comment. Please don't hesitate to contact me if I can provide
additional insight regarding how the MSLPs or other programs can better assist businesses.
Respectfully,
Gary J Pickard
Senior Director, Government & Industry Affairs
Pacific Dental Services, Legislative Affairs
17000 Red Hill Ave, Irvine, CA 92614
Cell Phone Number E pickardg@pacden .com<mailto :pickardg@pacden .com>
Main Street Lending
Jordan Fein [jfein@unitehere11.org]
To Whom It May Concern:
We write to request that 501(c)(5) nonprofits like labor unions be added as
eligible borrowers for the Main Street Lending Program, due to the critical
role they and their members play in overcoming the crisis. We also ask that
eligible borrowers be subject to the conditions of the “Assistance for
Mid-Sized Businesses” section of the CARES Act, so as to ensure aid gets to
the struggling workers most in need.
The exclusion of labor unions from this program is a serious impediment to
achieving the main goal of the CARES Act—to help workers weather the
economic effects of the crisis. Exposing themselves to great personal
health risks, America’s 14.6 million union members are at the forefront of
our response to the crisis, from nurses caring for patients to grocery
store workers ensuring access to food to hotel workers providing services
to homeless people now living in hotel rooms.
Moreover, it is especially crucial that 501(c)(5) organizations be eligible
for this program because they were excluded from the Paycheck Protection
Program, which faith institutions and 501(c)(3) nonprofits are eligible for.
Main Street Lending Program borrowers should also be subject to the
conditions for “Assistance for Mid-Sized Businesses” specified in CARES Act
Section 4003(c)(3)(D)(i). Most importantly, these conditions mandate that
borrowers restore not less than 90% of their workforce that existed as of
February 1, 2020, among other requirements that will accelerate our
recovery.
Regards,
Jordan Fein
UNITE HERE Local 11
464 Lucas Ave, Ste 201
Los Angeles, CA 90017
4/15/2020 8:51:23
FW: Main Street Lending -- comment submission
"Kaplan, Lawrence D." [lawrencekaplan@Paulhastings.com]
4/15/2020 7:33:17
On behalf of our clients, we hope that the Federal Reserve and the Treasury recognize that businesses
vary widely in their financing needs and will adjust or expand on the programs for mid-sized
businesses. We further request implementation of additional programs for mid-sized businesses as
specifically described in 4003(c)(3)(D)(i) of the CARES Act.
We note that the term sheets for the Main Street Loan Facilities currently do not adequately address
the needs of mid-sized companies adversely affected by the COVID-19 crisis for the following reasons.
First, the loan facilities are likely unavailable under the MSNLF and definitely unavailable under the
MSELF to borrowers that do not have existing credit facilities with banks. Many mid-sized businesses
obtain credit from business development companies or non-bank specialty finance companies.
Second, blanket restrictions on debt refinancing are problematic. Some businesses have a pre-existing
need to refinance credit prudently obtained prior to the pandemic due to near term maturities.
Companies that could have refinanced that debt absent economic disruption and resulting catastrophic
revenue declines need a refinancing solution, not more debt. These companies expect to repay all
amounts borrowed plus interest.
Third, the maximum loan sizes are too small for companies in need of a refinancing solution.
Fourth, the leverage conditions will automatically and indiscriminately eliminate aid to too many credit
worthy borrowers.
Relief under the current Main Street programs may be non-existent for credit worthy mid-sized
companies with a current need to refinance pre-existing debt owed to non-bank lender and that, absent
the current economic crises, could have refinanced that debt.
____________________________________________________________________________
[Paul Hastings LLP]<http ://www. paulhastings .com/>
Lawrence D. Kaplan | Chair, Bank Regulatory
Paul Hastings LLP | 875 15th Street, N.W., Washington, DC 20005 | Direct: +1.202.551.1829 | Main:
+1.202.551.1700 | Fax: +1.202.551.0229 |
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Main Street Lending
Matthew Borowick [Matthew.Borowick@shu.edu]
4/15/2020 6:36:24
Dear Board of Governors of the Federal Reserve System:
On behalf of Seton Hall University, I am writing to submit comments on the recently announced Main
Street Lending Program to urge the Federal Reserve to make institutions of higher education eligible to
apply for and receive financial support under this important initiative.
Seton Hall University and all of higher education in the United States are experiencing unprecedented
challenges due to the coronavirus. Seton Hall has been doing its utmost to serve the needs of our
students by safeguarding their health and working hard to provide them opportunities to continue their
education in the face of challenges that are unprecedented in their scale and scope. Due to the public
health guidance and prudent action, Seton Hall shut down its live operations and shifted to remote
learning even before the State of New Jersey issued its stay at home order, and this change in
operations will continue through the end of the spring semester. Students fulfilling the necessary
academic requirements will graduate and receive their diplomas. Seton Hall University's Board of
Regents has also voted unanimously to issue pro-rated refunds or credits for room, board, and parking
fees in an effort to provide relief for students and families during this difficult time.
Responding to the coronavirus and meeting the needs of our students and employees during this time
has posed a series of difficult issues that would challenge any institution of higher education, let alone
the entire postsecondary education sector nationwide simultaneously. Seton Hall University is very
grateful for the emergency assistance afforded to our institution and our students under the CARES
Act. At the same time, the assistance furnished will only represent a fraction of the expenses that have
been incurred and the revenue that has been lost.
Because Seton Hall University employs over 500 people, it is not eligible for some of the other forms of
assistance that Congress enacted in the CARES Act. The Main Street Lending Program is one of the
key ways that larger entities can be resilient in the face of the coronavirus pandemic. Access to lowcost and affordable capital represents an essential means of ensuring that Seton Hall and other
institutions of higher education can weather the storm. Even otherwise financially stable institutions are
going to be profoundly affected by the short-term revenue disruptions and expenses related to COVID
19 and having the option of low-cost loans would be an important option to have under these under
these extraordinary circumstances.
I understand and appreciate the many ways that the Federal Reserve is working to cushion the blow of
the COVID 19 pandemic on the economy, including implementation of the Main Street Lending
Program. Seton Hall University is a significant driver of economic activity in Northern New Jersey, as
are other colleges and universities in the communities that host them throughout the United States.
Allowing Seton Hall and other institutions of higher education to participate in the Main Street Lending
Program is a prudent and smart investment that will serve as ballast to the economy, help keep
hundreds of thousands of instructors and support staff employed, and ensure that there is a vibrant
higher education sector when our country emerges from the current public health emergency. I
respectfully urge you to modify the eligibility requirements for this important program to include the
higher education sector as the Federal Reserve moves forward with implementation.
Sincerely,
Matthew Borowick
Interim Vice President
University Advancement
Seton Hall University
457 Centre Street
South Orange, NJ 07079
(973) 378-9847
What great minds can do.<https ://advancement.shu.edu/>
People Inc and Loan Forgiveness
Max Donatelli
ersonal Email Aaaress
*April 15, 2020*
*To Whom It May Concern:*
eop e nc in es em ew ork.
Is regIona non-pro I ea an uman services agency has over 4,000
employees and provides programs and services to nearly 10,000 people with
intellectual and developmental disabilities, special needs, their families
and older adults throughout numerous counties in Western New York and the
Greater Rochester region, we are writing today to inform you that this
agency, People Inc., is fully engaged in dealing with the COVID-19 crisis.
They must ensure that their homes and services for people with disabilities
remain as safe as possible and are staffed 24/7. The vulnerable people that
depend on them deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly
unusual increased costs in staffing, PPE, and cleaning services.*
*Since People Inc is not eligible for the Payroll Protection Program (PPP)
due to their size and they must remain fully operational, we request that
the Mid-Size Loan Program have provisions to convert to a forgivable loan
for nonprofits that face staggering losses due to COVID-19. This would
grant us the same protections as PPP. As family members that rely on this
outstanding organization for services to our son, we implore you to assure
this loan is forgivable since it would help People Inc get through this
crisis and be able to continue to offer the full continuum of their
services. Thanking you in advance for your consideration. *
*Sincerely,*
*Max and Joyce Donatelli*
*3264 Queens Lane*
*Hamburg, New York 14075*
*716-481-1730*
Max Donatelli
Family Advocate
716-481-1730
"If you don't stand for something, you fall for anything."
4/15/2020 4:47:01
Main Street Lending Program Inquiries
"Carellini, Frank" [Frank.Carellini@mizuhogroup.com]
4/15/2020 4:30:25
Greetings,
We have the following questions regarding the Main Street Lending Program:
1. Are FBOs eligible lenders?
* If so, do they fall under the same criteria or a different set?
2.
Are U.S. subsidiaries of foreign multi-national company's eligible borrowers for the program?
a.
If yes, do the requirements apply to the U.S. subsidiary only or to the consolidated company?
b.
Can the program be used at other various corporate levels (i.e. Hold Cos, SP entities,
subsidiaries, etc.)?
3.
Can private equity owned companies apply through an eligible lender or directly?
4.
Can BDC portfolio companies engage directly with the FRB?
1. What is the relationship between the FRB and the lender in terms of loan administration, including
voting rights?
2. May lenders rely on representations by borrowers to verify compliance with program rules?
3. May the FRB modify the rules of the program in a way that affects loans already made under the
program?
8.
How does the FRB define EBITDA (GAAP vs. cash or add on adjustments)?
a.
What adjustments, if any, are permitted?
i.
ii.
Are any adjustments expressly prohibited?
Are leases/rent allowed for certain sectors or broadly?
b.
Is it measured at the subsidiary level or at the parent level?
c.
Can you confirm the measurement period (Dec 2019)?
year end? LTM?
i.
Will it vary by sector? Retailers (Jan 20) or is it latest fiscal
9.
How do you measure Total Debt? Is it the same way as the FRB in determination of leveraged
lending?
a.
Can cash be netted in Total Debt?
b.
Will Total Debt it be measured only at origination or will it be assessed throughout the duration of
the program?
10. Are there any ratings considerations for borrower eligibility?
a.
How does the FRB account for unrated non-investment grade companies?
11. Will the FRB assume 95% of the credit risk per borrower or does it accept up to 95% of this loan
as eligible to provide bank funding (provides funding but lenders retain the risk)?
a.
If the FRB does assume the risk and lenders only take 5% risk, then does this only make sense
for one lender / Admin Agent (5% of max $150 is $7.5mm loan)?
12. What is the proposed treatment of 5% held by banks (i.e. accrual vs mark to market, RWA, etc.)?
1. May a lender participate out its 5% interest in the loan to an FBO or other person, whether or not
that person would be an eligible lender?
14. Do we have to be the admin agent or currently lend to the company or does the fact that they have
an eligible loan extended prior to 4/08/20 mean we can do it? (i.e. if a company has an existing
syndicated TL from Morgan Stanley, can Mizuho step in and do an incremental TL)?
15. Do the existing loans have to be unsecured like the New Loans program?
16. Would participating banks such as Mizuho be precluded from otherwise hedging their exposure to
an obligor through our normal credit hedging program?
17. What is the approval process with the FRB?
a.
How do we ensure the loan will qualify for this treatment before lenders close/ fund?
b.
Is there standard legal documentation provided by the FRB that all parties sign or case by case?
c.
How long is the process expected to take?
d.
What is the estimated "go-live" date?
18. Are any of these programs capable of handling counterparty credit on derivatives? If not, are
there plans to add one that does?
19. What if a bank isn't setup for SOFR? [Current timelines for readiness at Mizuho are fall 2020]
20. How will SOFR calculated (in Advance, in Arrears, or Daily Simple)?
21. Can this program be utilized in the context of corporate activities such as spin offs, divestures,
intracompany dividends, etc.?
22. Is it correct that the borrower has option to defer amortization on principal and interest for 1 year?
23. Can a company do a one stop solution (i.e. take in private equity, perpetual preferred etc. to hit
leverage limit and access Main Street)?
24. Can these programs be combined with others (TALF etc.)?
Should you have any questions and/or comments regarding the above, please do not hesitate to
contact me directly.
Best regards,
Frank Carellini III
Managing Director
Americas Legal and Compliance Department
Mizuho Bank, Ltd. / Mizuho Bank (USA)
Mizuho Americas
1271 Avenue of the Americas
New York, NY 10020
(t) 212-282-3696
Frank.Carellini@mizuhocbus .com<mailto :Frank.Carellini@mizuhocbus .com>
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Loan Program
Marge Barone [mbarone@people-inc.org]
4/15/2020 4:22:22
To whom it may concern,
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc
Marge Barone
Residential Compliance Coordinator
People Inc.
280 Spindrift Dr.
Williamsville NY 14221
817-9297 (Office)
Cell Phone Number
817-9197 (Fax)
MBarone@People-Inc.Org

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Main Street Lending Program
Jason Nichols [Jason.Nichols@AmericasAutoAuction.com]
4/15/2020 3:58:03
To whom it may concern:
I am the VP of Finance for a national auto auction chain with 23 locations and approximately 1,500
employees. While our business did not/could not qualify for the COVID-19 relief being offered through
the SBA, I believe we would qualify for federal relief under the Federal Reserve's newly announced
Main Street Lending Program based on the term sheet that has been published. I am seeking more
information on qualification for this program, the anticipated roll-out of the program and the next steps
to participate in the program. I have already reached out to the Dallas Federal Reserve and left a
voicemail. I appreciate your time and response.
Regards,
Jason Nichols
Jason Nichols | VP Finance
America’s Auto Auction
14951 Dallas Pkwy, Ste 200
Dallas, TX 75254
P | (214) 736-7897
Cell Phone Number
F | (214) 301-4146
jason.nichols@americasautoauction .com<mailto :jason.nichols@americasautoauction .com>
www. americasautoauction .com
Main Street Lending
Christine Melchiorre
Personal Email Address
4/15/2020 3:55:14
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc deserve no less. However because they are providing
essential services during the crisis, People Inc has incurred unusual increased costs in staffing, PPE,
and cleaning services.
Since People Inc is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Christine Gayla Melchiorre
People inc.
connie donatelli Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
4/15/2020 3:18:38
Main Street Lending
Natalie Ryan [nryan@people-inc.org]
4/15/2020 2:58:38
To Whom It May Concern:
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Natalie A. Ryan, MS
Director of Admissions/Care Management
3332 Walden Ave., Suite 100
Depew, NY 14043
(716)880-3785
Fax# (716)817-2602
nryan@people-inc .org<mailto :nryan@people-inc .org>
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--------------------------------------------------------------------------------------
Main Street Lending
Anthony Rushford [arushford@people-inc.org]
4/15/2020 1:03:23
Good day and thank you for taking the time to consider the needs of the non-profit sector supporting
vulnerable people through the COVID-19 crisis.
I am one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region.
I writing these comments today while fully engaged in dealing with the COVID-19 crisis. We must
ensure that our homes and services for people with disabilities remain as safe as possible and are
staffed 24/7. The vulnerable people that depend on us deserve no less. However, because we are
providing essential services during the crisis, People Inc. has incurred highly unusual increased costs
in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Anthony J. Rushford
Project Director
Community Based Services
People Inc.
3332 Walden Ave., suite 100
Depew, NY 14043
Phone 716.880.3775
Fax
Web
716.817.2604
www. people-inc .org<http ://www. people-inc .org>
This communication, including attachments, is confidential, may be subject to legal privileges, and is
intended for the sole use of the intended addressee only. Any use, duplication, disclosure or
dissemination of this communication, is prohibited. If you have received this communication in error,
please notify the sender immediately and delete or destroy this communication and all copies. This
communication may contain nonpublic personal information about individuals subject to the restrictions
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the information. There are risks associated with the use of electronic transmission. The sender of this
information does not control the method of transmittal or service providers and assumes no duty or
obligation for the security, receipt, or third party interception of this transmission.
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Main Street Lending
David Squires [dsquires@people-inc.org]
4/15/2020 12:42:06
Good morning,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
David Squires
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Main Street Lending
Emily Litwin [elitwin@daemen.edu]
4/15/2020 12:27:50
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP
Sent from my iPhone
Main Street Lending
Jessica Milano [jmilano@people-inc.org]
4/15/2020 12:22:51
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Jessica Milano-Carty, FI Representative
Self Determination Services
People Inc.
3332 Walden Ave Suite 100
Depew NY 14043
Phone: 716-880-3807
Cell Phone Number
Fax: 716-817-2604
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---------------------------------------------------------------------------------------
Main Street Business Lending Program
Melissa Mahagan [mmahagan@people-inc.org]
4/15/2020 11:35:05
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Melissa Mahagan
Lead Insurance Specialist
People Inc
1219 North Forest
Williamsville, NY 14221
716-817-7431
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--------------------------------------------------------------------------------------
Main Street Lending
Doreen Sutherland [dsutherland@people-inc.org]
4/15/2020 11:03:59
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Doreen E. Sutherland
Director of Accounts Receivable
People Inc.
1219 North Forest Road
Williamsvile, NY 14221
Direct line: 716-817-7460
Fax direct to A/R: 716-817-2503
Fax: 716-633-1709
dsutherland@people-inc .org<mailto :dsutherland@people-inc .org>
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--------------------------------------------------------------------------------------
Main Street Landing
Cesaria Gotham [cgotham@people-inc.org]
4/15/2020 11:03:03
Hello,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
The people under our care and their families depend on us day in and day out to provide care for their
loved ones even more so during times like these. We love and care for all those we serve and without
this assistance it would put great strain on our ability to serve our community and those that need it
most.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Thank you,
Cesaria Gotham
Accounting Supervisor
Monday -Friday: 6am to 1:30pm
716-817-7205
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Main Street Landing
Personal Email Address
4/15/2020 10:29:44
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sent from AOL Mobile Mail
People Inc. needs your help
karch7
Personal Email Address
4/15/2020 8:01:28
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we request that the Mid-Size Loan
Program have provisions to convert to a forgivable loan for nonprofits that face staggering losses due
to COVID-19. This would grant them the same protections as PPP.Thank you in advance for your
support of direct care staff, the people they support and People Inc.Sent from my Verizon, Samsung
Galaxy smartphone
Forgivable loans for non profits
Sharee Personal Email Address
4/15/2020 5:33:45
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sharee Dominick
Appeal for reasonable assistance for non-profit agencies
Sarah Bruml Personal Email Address
4/15/2020 5:03:27
In support of the 4,000 employees of several regional non-profit health and human services agencies
that provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services. They are not alone in their actions to help this group of people.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP. Please consider extending these protections to all agencies
that are currently under financial stress because of COVID-19. We as a society owe these companies
and their workers. Please step up to the plate for them.
Sincerely,
Sarah Bruml, M.S., CCC/SLP
Main Street Lending
Leslee Chilcott
Personal Email Address
4/15/2020 4:18:03
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Thank you,
Leslee Chilcott
Main St Lending
miriam silkes Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
4/15/2020 3:53:52
Main st lending
Christine Willert
Personal Email Address
4/15/2020 3:01:44
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sincerely,
Cris and Don Willert
Sent from my iPad
Non profit loans
Susan Marmion
Personal Email Address
4/15/2020 2:40:14
Please reconsider repayment of non profit loans to not for profit organizations like People Inc. These
groups provide valuable services to developmentally disabled individuals & need all the support they
can get.
Sincerely,
Susan Marmion
Nurse Practitioner
Sent from my iPhone
Mid size loan program
Jackie Graw
Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
4/15/2020 1:28:41
Re: Main Street Lending multifamily loan comments
Amariah Olson [amariah@olsoncapitalinvestments.com]
*In further explanation to my last email, our understanding is that this
loan MSNLF/MSELF is not structured to be able to handle a non stabilized
construction project.*
*Construction projects would not qualify per this language, they are based
off of future value and future revenue, not trailing revenue. This needs to
be fixed so that these projects don't go into default and get
repossessed. *
*What is the maximum loan amount?*
Under the MSNLF, loans are available up to the lesser of:
(i) $25 million; or
(ii) An amount that, when added to the eligible borrower’s existing
outstanding and committed but undrawn debt, does not exceed four times the
eligible borrower’s 2019 EBITDA.*
Under the MSELF, loans are available up to the lesser of:
(i) $150 million;
(ii) Thirty percent of the eligible borrower’s existing outstanding and
committed but undrawn bank debt; or
(iii) An amount that, when added to the eligible borrower’s existing
outstanding and committed but undrawn debt, does not exceed six times the
eligible borrower’s 2019 EBITDA.*
*The term sheets do not clarify whether the calculation for EBIDTA is
driven by GAAP or whether the calculation of EBIDTA will allow for
adjustments to eliminate one-time gains or losses.
On Tue, Apr 14, 2020 at 6:04 PM Amariah Olson <
amariah@olsoncapitalinvestments .com> wrote:
> Please make sure that this loan can be used for pay off and replace 1st
> position multifamily real estate loans. Also, it would be good to be able
> to add a 2nd position loan for some borrowers who need access to
> liquidity. Typical deal sizes are $1m to $50m.
>
> Also, it needs to be able to pay off bridge loans which are collateralized
> by a non cash-flowing assets under construction or renovation. There is no
> liquidity for these assets at the moment.
Confidential Business Information
> many borrowers loan docs. The MSL loan needs to have a forgiveness during
> the entire time that there is an eviction moratorium to cover lost rent
> from covid induced gov mandated orders, plus at least 3-6 months
4/15/2020 1:13:09
> forgiveness to evict and stabilize the tenants afterwords or work out
> repayment (most tenants will skip instead of repaying). Because this is a
> bridge (not stabilized property) all liquidity to get off this loan is
> gone, and Fannie Mae and Freddie Mac will not issue a loan for non
> stabilized properties. This is going to be an urgent need for multiple
> multifamily borrowers in the near future to keep from having all their
> equity wiped out in foreclosure.
>
> We would recommend terms:
>
> 5 years term minimum, 10 years maximum
> Interest Only
> Interest forgiveness during eviction moratoriums, plus 6 months to
> stabilize afterwords
> Low rates that will allow the business to stabilize (2-3%)
> It should work for stabilized or non stabilized multifamily property, but
> more important for property which is not stabilized yet. There is liquidity
> for stable assets through Agency Debt. There is no liquidity for
> construction or renovation projects.
> Closing fees should not exceed 2%. 1% for the lender. 1% for the broker.
> Some banks only charge 1% and split that.
>
> -> *Amariah Olson | *Principal
> *910.262.7226*
> amariah@olsoncapitalinvestments .com
> www. olsoncapitalinvestments .com
> 5823 Mulberry St, Austell GA, 30168
>
>
> CONFIDENTIALITY NOTICE: The contents of this email message and any
> attachments are intended solely for the addressee(s) and may contain
> confidential and/or privileged information and may be legally protected
> from disclosure. If you are not the intended recipient of this message or
> their agent, or if this message has been addressed to you in error, please
> immediately alert the sender by reply email and then delete this message
> and any attachments. If you are not the intended recipient, you are hereby
> notified that any use, dissemination, copying, or storage of this message
> or its attachments is strictly prohibited.
>
-*Amariah Olson | *Principal
*910.262.7226*
amariah@olsoncapitalinvestments .com
www. olsoncapitalinvestments .com
5823 Mulberry St, Austell GA, 30168
CONFIDENTIALITY NOTICE: The contents of this email message and any
attachments are intended solely for the addressee(s) and may contain
confidential and/or privileged information and may be legally protected
from disclosure. If you are not the intended recipient of this message or
their agent, or if this message has been addressed to you in error, please
immediately alert the sender by reply email and then delete this message
and any attachments. If you are not the intended recipient, you are hereby
notified that any use, dissemination, copying, or storage of this message
or its attachments is strictly prohibited.
Main Street Lending multifamily loan comments
Amariah Olson [amariah@olsoncapitalinvestments.com]
Please make sure that this loan can be used for pay off and replace 1st
position multifamily real estate loans. Also, it would be good to be able
to add a 2nd position loan for some borrowers who need access to
liquidity. Typical deal sizes are $1m to $50m.
Also, it needs to be able to pay off bridge loans which are collateralized
by a non cash-flowing assets under construction or renovation. There is no
liquidity for these assets at the moment.
Confidential Business Information
the entire time that there is an eviction moratorium to cover lost rent
from covid induced gov mandated orders, plus at least 3-6 months
forgiveness to evict and stabilize the tenants afterwords or work out
repayment (most tenants will skip instead of repaying). Because this is a
bridge (not stabilized property) all liquidity to get off this loan is
gone, and Fannie Mae and Freddie Mac will not issue a loan for non
stabilized properties. This is going to be an urgent need for multiple
multifamily borrowers in the near future to keep from having all their
equity wiped out in foreclosure.
We would recommend terms:
5 years term minimum, 10 years maximum
Interest Only
Interest forgiveness during eviction moratoriums, plus 6 months to
stabilize afterwords
Low rates that will allow the business to stabilize (2-3%)
It should work for stabilized or non stabilized multifamily property, but
more important for property which is not stabilized yet. There is liquidity
for stable assets through Agency Debt. There is no liquidity for
construction or renovation projects.
Closing fees should not exceed 2%. 1% for the lender. 1% for the broker.
Some banks only charge 1% and split that.
-*Amariah Olson | *Principal
*910.262.7226*
amariah@olsoncapitalinvestments .com
www. olsoncapitalinvestments .com
5823 Mulberry St, Austell GA, 30168
CONFIDENTIALITY NOTICE: The contents of this email message and any
attachments are intended solely for the addressee(s) and may contain
confidential and/or privileged information and may be legally protected
4/15/2020 1:05:17
from disclosure. If you are not the intended recipient of this message or
their agent, or if this message has been addressed to you in error, please
immediately alert the sender by reply email and then delete this message
and any attachments. If you are not the intended recipient, you are hereby
notified that any use, dissemination, copying, or storage of this message
or its attachments is strictly prohibited.
Main Street Lending- People Inc.
Andrea Irvine
Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
4/15/2020 12:59:08
People Inc
Kelly Getty
Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
4/14/2020 11:06:48
Loan forgiveness for non profits
Jill Echtenkamp
Personal Email Address
I work for People inc., a non-profit agency that employs 4000 employees
who provide services for 10,000 developmentally disabled individuals, their
families, seniors and other members of the community. Because we have had
to continue operations to ensure the safety of the individuals in our many
group homes, health care center and other programs , we are not eligible
for the PPP loan. I ask that you please have a provision in the mid-size
loan program to convert it to a forgivable loan. It has been very
difficult financially to fund the extra expenses of ppe, 24 hr staffing and
other unforseen expenses during this crisis. Thank you for this
consideration.
Jill Echtenkamp
4/14/2020 10:55:50
Main Street Lending
Gina Rak [grak@people-inc.org]
4/14/2020 10:42:42
To Whom It May Concern,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Gina Rak
Senior Day Supervisor
Southgate CAPP
950-A Union Road, Suite 215
West Seneca, New York 14224
Cell Phone Number
Office fax:
675-5793
People Inc
Cathy Burger
Personal Email Address
4/14/2020 10:38:46
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sent from my iPhone
Loans for non profits
Rick Abbott
Personal Email Address
4/14/2020 10:35:46
Personal Address
Sent from my iPhone
People Inc.
Melissa Griffin
Personal Email Address
4/14/2020 10:26:46
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sent from my iPhone
Main Street lending
Noel Schmitt
Personal Email Address
4/14/2020 10:26:04
Please as a social worker and 27 year employee of People Inc. consider rethinking guidelines for loans.
Asking kindly to make the loans forgivable-we need this support. People Inc. provides much needed
services to thousands of people with developmentally disabilities. Please help this Is a dire situation to
protect our most at risk populations during the COVID crisis. Our Residential programs provide 24 hour
support. Please help.
Sincerely yours,
Noel Schmitt
Sent from my iPad
Main Street Lending
Christine Mathieu
Personal Email Address
In support of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
1. CHILDREN
SERVICES <https ://www. people-inc .org/children_services_home/index.html>
2. SENIO <https ://www. people-inc .org/senior_services_home/index.html>
pport of the 4,000 employees of a regional non-profit health and human
services agency that provides programs and services to nearly 10,000 people
with intellectual and developmental disabilities, special needs, their
families and older adults throughout numerous counties in Western New York
and the Greater Rochester region, I am writing today to inform you that
People Inc. is fully engaged in dealing with the COVID-19 crisis. They must
ensure that more than 150 community-based homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However,
because they are providing essential services during the crisis, People
Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
4/14/2020 9:46:17
Since People Inc. is not eligible for the Payroll Protection Program (PPP)
due to their size and the fact that they must remain fully operational, we
request that the Mid-Size Loan Program have provisions to convert to a
forgivable loan for nonprofits that face staggering losses due to COVID-19.
This would grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they
support and People Inc.
1. CHILDREN
SERVICES <https ://www. people-inc .org/children_services_home/index.html>
2. SENIO <https ://www. people-inc .org/senior_services_home/index.html>
Main Street Lending
Shemi Hart [SHart@WETDesign.com]
4/14/2020 9:26:45
Main Street Lending Staff,
Can you please provide a list of participating banks in the Main Street Lending or direct me to where to
find this information.
Thanks.
SHEMI HART
Chief Financial Officer
shemi.hart@wetdesign .com<mailto :shemi.hart@wetdesign .com>
WET
10847 Sherman Way
Sun Valley, CA 91352
T 818.769.6200
F 818.301.6111
www. wetdesign .com<http ://www. wetdesign .com>
Main Street Lending
Nancy Palumbo [NPalumbo@people-inc.org]
4/14/2020 8:59:48
To whom it may concern:
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7<outlook-data-detector://6>. The
vulnerable people that depend on us deserve no less. However, because we are providing essential
services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Sincerely,
Nancy A. Palumbo
Get Outlook for iOS<https ://aka.ms/o0ukef>
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Main Street lending
Robert Battaglia
Personal Email Address
People Incorporated of Western New York a non-profit that serves people
with disabilities must be fully staffed during the covid 19 crisis they are
not eligible for the payroll protection plan but have incurred extra
expenses due to the covid-19 crisis my brother is in one of their group
homes and needs 24/7 care please include them in the midsize loan program
for nonprofits so it can convert to a forgivable loan.
4/14/2020 8:43:26
Main Street Lending
Britta Kelley [bkelley@people-inc.org]
4/14/2020 8:35:02
Hello,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Britta Kelley
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Main Street Lending
Mahmoud Ibrahim [mibrahim@precisionmdca.com]
4/14/2020 8:27:13
NONCONFIDENTIAL // EXTERNAL
Hello,
i recived the below email and not sure what it means
i just want to apply for the Main street loan and not sure how or through how?
please advice
Mahmoud
________________________________
From: Board of Governors of Federal Reserve System - Public Affairs
Sent: Tuesday, April 14, 2020 9:58 AM
To: Mahmoud Ibrahim <mibrahim@precisionmdca .com>
Subject: RE: Coronavirus (COVID-19)
Dear Dr. Mahmoud Ibrahim:
Thank you for your recent inquiry to the Federal Reserve Board in which you requested additional
information about applying for a loan.
As the Federal Reserve has established several funding facilities, we are unable to determine the
funding facility you're referencing. Please write back to our office, via the "contact us" form and provide
additional information.
Sincerely,
Board Staff
________________________________
From: mahmoud Ibrahim
Date: Monday, April 13, 2020 12:00 AM
Reference Number: 202000044322
Hello,
how can i apply for this loan? and what bank do offer it i cant find any of this information
Thanks
Mahmoud Khattab
Main Street Lending
Kelly Hawkins [khawkins@people-inc.org]
4/14/2020 8:25:07
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Kelly Hawkins
Program Director/Fiscal Intermediary
People Inc.
3332 Walden Ave., Suite 100
Depew, NY 14043
Phone: 716.880.3877
Cell Phone Number
Fax: 716.817.2511
Web: www. people-inc .org<http ://www. people-inc .org/>
[cid:image001.jpg@01D356FB.C0899B20]
Nationally accredited by The Council on Quality and Leadership
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Main Street Lending
Cheryl Stiller [cstiller@people-inc.org]
4/14/2020 8:17:58
Hello,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Thank you,
Cheryl P. Stiller, PHR, SHRM-CP
Director of Employee Benefits & Safety
People Inc.
1219 North Forest Road
Williamsville, NY 14221
Tel: 716-817-7212
Fax: 716-817-2600
cstiller@people-inc .org<mailto :cstiller@people-inc .org>
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Main Street Lending
Caroline Roeder [croeder@people-inc.org]
4/14/2020 8:13:30
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Caroline Roeder
Director Quality Improvement
People Inc.
280 Spindrift Drive
Williamsville, NY 14221
Phone 716.817.9056
croeder@people-inc .org<mailto :croeder@people-inc .org>
Web www. people-inc .org<http ://www. people-inc .org>
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--------------------------------------------------------------------------------------
Main Street Lending
"Tina M. Tyran" [tmtyran@people-inc.org]
4/14/2020 8:12:47
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7<outlook-data-detector://6>. The
vulnerable people that depend on us deserve no less. However, because we are providing essential
services during the crisis, People Inc. has incurred highly unusual increased costs in staffing, PPE, and
cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Tina Tyran
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Main Street Lending
Christy Ferriter [cferriter@people-inc.org]
4/14/2020 8:10:21
To whom it may concern:
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Christy Ferriter, LMSW
Associate Vice President- Population Health
People Inc.
2128 Elmwood Ave.
Buffalo, NY 14207
Office
716 566-4848
Cell Phone Number
Fax
716.874-0388
Web
www. people-inc .org<http ://www. people-inc .org/>
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Main Street Lending
Jennifer Ireland [jennifer.ireland@people-inc.org]
4/14/2020 8:09:48
Hello,
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Jenni Ireland
Fiscal Intermediary
Program Director
People Inc.
1860 Buffalo Road
Rochester, NY 14624
Direct: 585.719.3439
Fax: 585.441.9399
Main: 585.441.9300
"You're braver than you believe, stronger than you seem, and smarter than you think" -A.A. Milne
Note my email has changed: Jennifer.Ireland@people-inc .org<mailto :Jennifer.Ireland@peopleinc .org>
*Please update your contact information as I will only receive emails at jshaw@people-inc .org for the
next 30 days.
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Please forgive loans to non profits needing PPE to support our individuals
Anna Korus [akorus@people-inc.org]
4/14/2020 8:09:42
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Anna N. Korus
Senior Vice President
People Inc.
1219 North Forest Road
Williamsville, New York 14450
(716) 817-7446 (Office)
Cell Phone Number
(716) 817-8063
(Fax)
[PeopleIncWithAffiliateLogos2018]
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---------------------------------------------------------------------------------------
Main Street Lending
Jill Magno [jmagno@people-inc.org]
4/14/2020 8:09:13
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Sincerely, Jill M.Magno
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Please consider forgiving loans for non profits
Anna Korus [akorus@people-inc.org]
4/14/2020 8:08:30
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Anna N. Korus
Senior Vice President
People Inc.
1219 North Forest Road
Williamsville, New York 14450
(716) 817-7446 (Office)
Cell Phone Number
(716) 817-8063
(Fax)
[PeopleIncWithAffiliateLogos2018]
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Main Street Lending
Nichole Gebera [ngebera@people-inc.org]
4/14/2020 8:07:54
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you for your consideration.
Nichole Gebera
Director of Payroll and Support Services, People Inc.
Direct Phone: (716)817-7493
For General Payroll Questions:
(716) 817-7276 or email at payrollquestions@people-inc .org<mailto :payrollquestions@peopleinc .org>
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Mid size non profit, given a forgivable loan for Covid-19
Jennifer Robinson
Personal Email Address
4/14/2020 6:34:07
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Sincerely,
Jennifer Robinson
Sent from my iPhone
Main Street Lending
Personal Email Address
4/14/2020 6:33:54
Good afternoon,
Personal Information
People Inc. employs 4,000 staff who provide supports to nearly 10,000 people with intellectual and
developmental disabilities in Western New York and Rochester. They are fully engaged in dealing with
the COVID-19 crisis as evidenced by the care they provide my daughter 24/7. They must ensure that
more than 150 group homes and services for people with disabilities remain as safe as possible and
are staffed 24/7. The vulnerable people that depend on People Inc. deserve no less.
Because they are providing essential services during the crisis, People Inc. has incurred highly unusual
increased costs in staffing, PPE, and cleaning services. People Inc. isn’t eligible for the Payroll
Protection Program (PPP) due to its size and because it must remain fully operational. I’m asking the
Mid-Size Loan Program to include provisions to convert to a forgivable loan for nonprofits that face
staggering losses due to COVID-19. This would grant them the same protections as PPP.
Thank you for supporting the caring staff who help my daughter every day and the People Inc. team.
If you have any questions, please feel free to contact me at this email address or by phone at 716-4301065.
Sincerely,Ellen Spangenthal
People Inc
Personal Email Address
Stephanie Mayer
4/14/2020 6:07:57
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc.
Sent from Yahoo Mail on Android
Main Street Lending
[jnobers@buildersguild.org]
Jeff Nobers
Executive Director
Builders Guild of Western Pennsylvania
631 Iron City Drive
Pittsburgh, PA 15205
O) 412-921-9000
Cell Phone Number
jnobers@buildersguild .org <mailto :jnobers@buildersguild .org>
"Presence is more than just being there." - Malcolm Forbes
4/14/2020 5:46:32
Main street lending
Danielle Carlisle [dcarlisle@people-inc.org]
4/14/2020 5:38:49
In support of the 4,000 employees of a regional non-profit health and human services agency that
provides programs and services to nearly 10,000 people with intellectual and developmental
disabilities, special needs, their families and older adults throughout numerous counties in Western
New York and the Greater Rochester region, I am writing today to inform you that People Inc. is fully
engaged in dealing with the COVID-19 crisis. They must ensure that more than 150 community-based
homes and services for people with disabilities remain as safe as possible and are staffed 24/7. The
vulnerable people that depend on People Inc. deserve no less. However, because they are providing
essential services during the crisis, People Inc. has incurred highly unusual increased costs in staffing,
PPE, and cleaning services.
Since People Inc. is not eligible for the Payroll Protection Program (PPP) due to their size and the fact
that they must remain fully operational, we request that the Mid-Size Loan Program have provisions to
convert to a forgivable loan for nonprofits that face staggering losses due to COVID-19. This would
grant them the same protections as PPP.
Thank you in advance for your support of direct care staff, the people they support and People Inc
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Main Street Lending
Jon Wagner
Personal Email Address
4/14/2020 4:06:05
NONCONFIDENTIAL // EXTERNAL
Good afternoon ,
Will the new lending program allow non-profits to borrow money in addition to companies?
Thank you,
Jon F Wagner
Sent from my iPhone
Main Street Lending
Mitesh Raval
Personal Email Address
I would encourage you to lower the minimum loan amount from $1 million to
$500,000. As a small business with 65 employees and about $5 million in
revenue, $1 million is more than I need or can afford to finance.
Paycheck Protection Program funds provide limited flexibility outside of
funding payroll for a short period of time during 2020. There are other
intermediate-to-longer term business needs that require financing due to
the cash flow challenges brought on by COVID19. For example: capital
improvement projects that have been agreed to, scheduled equipment that
must be replaced, marketing expenditures to build back business, recruiting
and training new employees, paying back deferred expenses, etc. There is
no other avenue to address these non-PPP related cash concerns. I suspect
a loan floor of $1 million eliminates many businesses that are in need of
capital from eligibility.
Thank you for reconsidering.
Mitesh Raval
E: Personal Information
T:
______________________________________
4/14/2020 1:39:15
SCG Capital - TALF & Main Street Lending Program
[sgoichman@scglease.com]
4/13/2020 11:06:38
To whom it may concern,
SCG Capital is an independent equipment Lessor to Fortune 1000 Companies and Hospitals. SCG is
carrying leases with companies such as Goodyear, Cooper Tire, Dana, etc.
SCG typically discounts our lease streams (Payments) with banks, but due to recent market volatility
and COVID, our ability to place debt for our
Lessees has been impacted.
Is there a program for SCG to discount/syndicate our lease payments for
those auto suppliers and hospitals who have been impacted by COVID.
I don't know if we are eligible for TALF or the Main Street Lending Program.
Can you please suggest which program might be a fit for us and a contact for
the respective program?
Thank you,
Sam Goichman
Senior Vice President
917-597-8568
sgoichman@scglease .com
SCG Capital Corporation
74 West Park Place Stamford, CT 06901
74 West Park Place
Stamford, CT 06901
<http ://www. scglease .com/> www. scglease .com
Phone: (203) 324-9495 E.235
Fax:
(203) 324-3195
This message and any attachments is intended only for the use of the
individual or entity to which it is addressed and may contain information
that is privileged, confidential, and exempt from disclosure under
applicable law. If the reader of this message is not the intended recipient,
you are hereby notified that any retention, dissemination, or copying of
this communication is strictly prohibited.
MAIN STREET LENDING for People-inc
Ron Fernandez [rfernandez@HeadwayofWNY.org]
4/15/2020 9:02:11
Dear Federal Reserve:
I am writing as the Director of Headway of WNY, an Affiliated Agency of People-Inc and in support of
their application for the Mid-Size Loan Program with the provision to convert to a forgivable loan for
nonprofits during this COVID-19 Pandemic.
Headway of WNY is a nonprofit agency that manages two waiver programs for individuals with
Traumatic Brain injury, cognitive issues and Seniors. We serve the Western NY Community helping this
vulnerable population. In addition as an affiliate of People-Inc we are part of a family of agencies
helping over 10,000 individuals with disabilities and challenges which are now greater due to the
Pandemic. These agencies which are committed to provide services even during this challenging times
are facing monumental financial losses due to the COVID-19 Pandemic; this grant would offer us the
same protection as PPP.
Thank you for your support for our mission and deserving constituents.
Sincerely,
Ronald Fernandez
[Headway logo - Copy]
Ronald Fern�ndez RRDS, CRC, LMHC
Director
Headway of WNY
Regional Center, Buffalo Region: Erie, Niagara, Chautauqua, Cattaraugus, Orleans and Wyoming
TBI and NHTD Waiver Programs
2635 Delaware Ave.
Suite E
Buffalo NY 14216
716-408-3100
TBI/NHTD Waivers 408-3120
Cell Phone Number
Fax 882-1289
This communication, including attachments, is confidential, may be subject to legal privileges, and is
intended for the sole use of the intended addressee only. Any use, duplication, disclosure or
dissemination of this communication, is prohibited. If you have received this communication in error,
please notify the sender immediately and delete or destroy this communication and all copies. This
communication may contain nonpublic personal information about individuals subject to the restrictions
of the Health Insurance Portability and Accountability Act. You may not directly or indirectly reuse or
disclose such information for any purpose other than to provide the services for which you are receiving
the information. There are risks associated with the use of electronic transmission. The sender of this
information does not control the method of transmittal or service providers and assumes no duty or
obligation for the security, receipt, or third party interception of this transmission.
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Main Street Lending
Don Endres [don@novitanutrition.com)
4/15/2020 3:43:07
NONCONFIDENTIAL // EXTERNAL
Dear Board of Governors of the Federal Reserve,
Novita Nutrition is in the business of producing high guality protein for the dai!)'. industry and have a
lant investment o(:omfclentiiil Business mfooiiafioo
Would ft be possible to aad a Deot o Asset metric of60%
after adamgthelVlainstreetri-na_ n_c...
,in _g _a _s_another method to determine the eligible amount? We
appreciate your consideration and hope you would consider our request. With additional capital we are
confident we can stay in operation and return to profitability after business returns to a more normal
operating environment.
We have tried to apply for the PPP program but the affiliation rule prevents our business from being
eligible to receive financing. I would welcome the opportunity to answer additional questions and look
forward to hearing back from you.
Best regards,
Don Endres
CEO Novita Nutrition.
[cid:image002.jpg@01O12114.A1635840]
Don Endres CEO
Direct: 605.610.1001 I Office: 605.610.1026 I www. NovitaNutrition .com<http ://www.
novitanutrition .com/>
2301 Research Park Way, Suite 226 I Brookings, SD 57006
» SIGN-UP FOR NOVAMEAL PRODUCT & PRICING E
NEWSLETTERS<https ://visitor.r20.constantcontact .com/manage/optin?
v=0013cWGsWN1119zSXBYCTwoG16yrzPn22W_bH_yMPTqH61fWLvPwjgUyuRqRl7k-jil-c17i1nntdlllpjc81RzpWbHzhLgNqqoCUIBguVNiPa9HMTCrTHbhL-XppUqXi6WqNudDwEw1G_4p3KGjJtRMPplYt7iVccM5OAOAw5yU%3D>
Main Street Lending
Thomas Ess [tess@people-inc.org]
4/15/2020 12:55:52
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Thomas Ess
Associate Vice President
Emergency Preparedness Coordinator
1219 North Forest
Williamsville, NY 14221
Cell Phone Number
716-817-9208 (office)
716-817-9108 (fax)
[PeopleIncWithAffiliateLogoshorizontal]
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Main Street Lending
Sarah Alessi [salessi@people-inc.org]
4/15/2020 12:53:48
To Whom it May Concern:
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Sarah Alessi
Associate Vice President
People Inc.
3332 Walden Ave., Suite 100
Depew, NY 14043
Office 716.880.3893
Cell Phone Number
Fax
Web
716.817.9157
www. people-inc .org<http ://www. people-inc .org/>
[cid:6cf465f1-6188-4901-8e24-7dada521ca8b]
Nationally accredited by The Council on Quality and Leadership
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MAIN STREET LENDING - IMPORTANT.
Pamela King [pking@people-inc.org]
4/16/2020 3:44:37
My name is Pamela King - I live in west Seneca NY and have dedicated my life long career 30 plus
years working at a not for profit supporting people with developmental disabilities. I have never
experience such a time as we are experiencing this year. In saying that our agency and staff are daily
continuing to support our participants through this crisis.
As one of 4,000 employees of a regional non-profit health and human services agency that provides
programs and services to nearly 10,000 people with intellectual and developmental disabilities, special
needs, their families and older adults throughout numerous counties in Western New York and the
Greater Rochester region, I am writing today to inform you that our agency, People Inc., is fully
engaged in dealing with the COVID-19 crisis. We must ensure that our homes and services for people
with disabilities remain as safe as possible and are staffed 24/7. The vulnerable people that depend on
us deserve no less. However, because we are providing essential services during the crisis, People Inc.
has incurred highly unusual increased costs in staffing, PPE, and cleaning services.
Since we are not eligible for the Payroll Protection Program (PPP) due to our size and we must remain
fully operational, we request that the Mid-Size Loan Program have provisions to convert to a forgivable
loan for nonprofits that face staggering losses due to COVID-19. This would grant us the same
protections as PPP.
Thank you in advance for your support of direct care staff, the people we support and our agency,
People Inc.
Thank you Pam King
Pamela King
People Inc.
280 Spindrift Drive
Williamsville, NY 14221
Phone 716.817.9052
[cid:6cf465f1-6188-4901-8e24-7dada521ca8b]
Nationally accredited by The Council on Quality and Leadership.
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Main Street Lending
[Chris.Harrington@ucdc.edu]
4/16/2020 3:40:24
Good morning:
On behalf of the University of California, please find attached the University's comments regarding the
establishment of the Main Street Lending Program: Main Street New Loan Facility (MSNLF) and Main
Street Expanded Loan Facility (MSELF). As outlined in detail in the attached letter, the University
specifically requests the following:
* UC asks that the Federal Reserve update its guidance regarding the Main Street Lending Program
to clarify that non-profit private and public institutions of higher education, regardless of how many
employees they have, are eligible to apply for loans and other financial tools made available under the
program.
* UC also requests that non-profit private and public institutions of higher education be made eligible
for participation in the Main Street Lending Program without having to meet the eligibility requirement
established for businesses, of having fewer than 10,000 employees, or meeting certain annual income
requirements. Non-profit private and public higher education institutions may have more than 10,000
employees, especially if they are part of a large public university system, such as UC, and would
benefit from being eligible to participate in programs such as the Main Street Lending Program as part
of their response efforts to COVID-19.
* UC also asks that as guidance is developed for these programs, the Federal Reserve consider the
positive impact Main Street Lending Program loans could have for individual UC campuses in
bolstering their efforts to cover operating costs and payroll expenses. We request that the Federal
Reserve implements the Main Street Lending Program in a manner that allows for individual UC
campuses to be eligible for these loans.
If you have questions regarding the University of California�s specific requests, please contact Chris
Harrington at (202) 997- 3150 or Chris.Harrington@ucdc.edu.
Sincerely,
Chris Harrington
Chris Harrington
Associate Vice President for Federal Governmental Relations
University of California Office of the President
Washington, DC
Office: (202)974-6314
Cell Phone Number
Main Street Lending
[shusmoe@fabrictech.com]
With respect to the "Main Street" loans that will be available for
businesses, with 95% backed by the SVA, and 5% by the lending institution...
is a business eligible for these loans if it also applies for and received
an Emergency Disaster Loan from the SBA? In other words, can you get both a
SBA ED loan (not the PPP, the disaster one) and the "Main Street" loan? I
want to make sure that by accepting the SBA loan we don't make ourselves
ineligible for the "Main Street" one.
Thanks,
Sean
Sean Husmoe
Chief Financial Officer
PureCareR
1402 S 40th Ave
Phoenix, AZ 85009
Direct: 602.293.3901
www. PureCare .com <http ://www. purecare .com/>
4/15/2020 11:25:51
Main Street Lending--Comments and Request for Clarification
"Zive, Josh" [joshua.zive@bracewell.com]
4/16/2020 7:29:31
To whom it may concern:
Ensuring that all eligible companies have access to the MSLP is an essential aspect of our country’s
response to the COVID-19 crisis, and the Federal Reserve should ensure that partnerships are able to
participate. Specifically, it is important that the Federal Reserve provides guidance stating clearly that
normal cash distributions made by partnerships are not prohibited by dividend restrictions targeted at
corporate entities.
Background
The term sheet<https ://www.
federalreserve.gov/newsevents/pressreleases/files/monetary20200409a7.pdf> for the MSLP released
by the Federal Reserve states that “The Eligible Borrower must attest that it will follow compensation,
stock repurchase, and capital distribution restrictions that apply to direct loan programs under section
4003(c)(3)(A)(ii) of the CARES Act.”
Section 4003(c)(3)(A)(ii)(II) of the CARES Act states that an eligible MSLP borrow must agree “until the
date 12 months after the date on which the direct loan is no longer outstanding, not to pay
dividends or make other capital distributions with respect to the common stock of the eligible
business.”
This language was clearly included by Congress based on concerns stemming from the 2008 financial
crisis<https ://www. wsj .com/articles/spend-generously-take-care-of-workers-coronavirus-stimulustakes-lessons-from-tarp-11585246787>, and is designed to prevent corporate entities from returning
loan proceeds to stockholders through dividends. However, the language can be construed as
prohibiting all cash distributions by eligible borrowers, including distributions made by partnerships.
Partnership entities, including master limited partnerships (MLPs), operate differently than corporations
and must be able to make regular distributions as an inherent component of their unique business
model. This model allows MLPS to attract the dollars needed to provide our nation’s critical energy
infrastructure. MLPs do not pay dividends to stockholders. Instead, they distribute their income in a
pro rata fashion to unitholders, who primarily invest in MLPs to receive these regular cash distributions.
And it is only after these distributions are made that the income becomes taxable. Prohibiting such
distributions would be incompatible with the operation of these partnerships, and would preclude MLPs
from utilizing the MSLP, unnecessarily restricting relief to a crucial sector of our economy and nation’s
energy infrastructure.
Ensuring that all eligible companies have access to the MSLP is an essential aspect of our country’s
response to the COVID-19 crisis, and the Federal Reserve should ensure that partnerships are able to
access these relief programs. Specifically, it is important that the Federal Reserve provides guidance
stating clearly that normal cash distributions made by partnerships are not prohibited by dividend
restrictions targeted at corporate entities. Prohibiting such distributions would be incompatible with the
operation of these partnerships, and would preclude MLPs from utilizing the MSLP, unnecessarily
restricting access to the MSLP from a crucial sector of our economy and nation’s energy infrastructure.
Request for Clarification
The goal of prohibiting corporate dividends in connection with COVID-19 relief can be accomplished
without barring partnerships from access to the MSLP. The Federal Reserve should provide guidance
making it clear that MSLP dividend restrictions, including the term sheet language related to “other
capital distributions,” do not prohibit partnerships from making regular cash distributions in the ordinary
course of business.
I appreciate your consideration of this request,
Joshua Zive
______
JOSH ZIVE
Senior Principal
joshua.zive@policyres .com<
T: +1.202.828.5838 | F: +1.800.404.3970
POLICY RESOLUTION GROUP | BRACEWELL LLP
2001 M Street NW, Suite 900 | Washington, D.C. | 20036-3310
policyres .com<http ://www. policyres .com> | profile<https ://bracewell .com/people/joshua-c-zive> |
download v-card<http ://www. bracewell .com/vcard/13419>
[cid:image6ce1ce.PNG@f1d2feac.44b5dd65]<https ://www. policyresolutiongroup .com/>
CONFIDENTIALITY STATEMENT
This message is sent by a law firm and may contain information that is privileged or confidential. If you
received this transmission in error, please notify the sender by reply e-mail and delete the message and
any attachments.
Main Street Lending
Taylor Clark [tclark@revbirmingham.org]
4/16/2020 7:23:51
Hello,
As a nonprofit with a mission of creating vibrant commercial districts, small businesses are the fabric of
our community and the core focus of our technical assistance efforts. A study recently conducted by
Main Street America found that millions of small businesses will be at great risk of closing permanently
if the crisis continues for several months. Of the nation's approximately 30 million small businesses,
nearly 7.5 million small businesses may be at risk of closing permanently over the coming five months,
and 3.5 million are at risk of closure in the next two months. COVID-19 has had a devastating impact
on small businesses' revenue, and millions of Americans employed by our nation's smallest businesses
are at risk of unemployment as a result. Approximately 35.7 million Americans employed by small
businesses appear to be at risk of unemployment. Beyond low-interest loans, The Main Street America
survey finds that business owners primarily need financial assistance and penalty-free extensions on
expenses.
It is imperative that the Main Street Lending Program account for two things: the dire need for terms
that allow our small business community to fully rebound and to allow nonprofits - particularly those
supporting small, lifestyle businesses - to be included in these provisions.
While the CARES Act is being deployed, there remains critical voids. We urge federal and state
economic development authorities to consider supporting the following need areas: The U.S. Small
Business Administration needs to expand technical assistance support funding to Small Business
Technical Assistance Providers and nonprofit partner organizations like ours. State and cities need
funding to invest in small business education and technical support programs rather than being forced
to pull back spending on these programs due to budget constraints. The Federal government should
not only prioritize giving CARES Act and future stimulus funding to small businesses with less than 20
employees, but allow for the nonprofit community who support these businesses to obtain funding.
These are the businesses that make up the bulk of jobs and are at the heart of communities across
America. New stimulus funding should address the expense side of small business operation, for
example measures to support rent or mortgage relief. It should also provide forbearance on all small
business loans, including credit card payments for at least six months.
The stimulus package provided loan forbearance for SBA loans, which is a great first step, but we must
ensure that small businesses with other forms of debt are supported. We recommend incentivizing the
adjustment of repayment due dates on taxes and commercial rent to give small businesses the
flexibility they need to stay afloat, ensuring insurance companies cover COVID-19 revenue losses,
ensuring small businesses that offer paid family medical and sick leave receive cash reimbursement,
instead of quarterly tax credits.
Again, our nonprofit and small business community are working in collaboration to ensure resiliency in
Birmingham, Alabama. Please consider allowing nonprofits the opportunity to receive funding under this
legislation as a boots-on-the-ground resource to advocate for and implement policies and programs to
help our small business community rebound. Furthermore, implement provisions that extend beyond
favorable loan terms and earmark a portion as forgivable as our small business desperately need
financial assistance that will not further impact their bottom line through the accrual of more debt.
Thank you,
[photograph]
Taylor Clark Jacobson
Director of Recruitment & Growth
p: 205.623.0642
e: taylor@revbirmingham .org<mailto :taylor@revbirmingham .org>
www. revbirmingham .org<http ://www. revbirmingham .org/>
Main Street Lending
Ben Hawn [ben.hawn@pohladcompanies.com]
4/16/2020 6:23:19
Limited Comments on the Main Street Lending Term Sheets.
Main Street New Loan Facility
1.
In the Required Attestations' 2nd bullet point, an Eligible Borrower is prohibited from repaying
other debt of equal or lower priority, with the exception of mandatory principal payments unless the
Eligible Borrower has first repaid the Eligible Loan in full.
Shouldn't mandatory interest payments on pre-existing debt be permitted as well?
2.
How do we actually calculate 2019 EBITDA for the purpose of determining the capacity limits.
Main Street Expanded Loan Facility
1.
What is the definition of a "Term Loan" that makes an Eligible Borrower able to access funds
under this program?
2.
Why is the Existing Loan Facility only available with respect Term Loans and not warehouse
lines or lines of credit?
3.
If we paid off a traditional Term Loan on April 6, 2020, could the documentation simply be
updated to include a "new tranche" under the Main Street Existing Loan Facility?
4.
Under the "Maximum Loan Size" in item number five, the Term Sheet includes in romanette (ii)
a limitation of 30% of the Eligible Borrower's existing and undrawn bank debt. This seems to require
that for an Eligible Borrower to access the program in any size it has to be highly levered, but any
highly levered entity is likely going to fail the test enumerated in romanette (iii) which limits the
maximum loan size to "an amount that, when added to the Eligible Borrower's existing outstanding and
committed but undrawn debt, does not exceed six times the Eligible Borrower's 2019 earnings before
interest, taxes, depreciation, and amortization."
Thank you very much for your time and work on these matters.
Best,
Ben Hawn
[cid:image003.png@01D613F2.2C68FE20]
.
Ben Hawn
Chief of Staff
Pohlad Companies, LLC
P 612 661 3067
Cell Phone Number
E Ben.Hawn@pohladcompanies .com<mailto :Ben.Hawn@pohladcompanies .com>
Pohlad Companies
60 S 6th St, Suite 3900, Minneapolis, MN 55402
pohladcompanies .com
Main Street Lending Facility � EBITDA Restriction
Michael Meehan [mjmeehan@diveplane.com]
4/16/2020 6:18:55
We agree and sign-on to the comment submitted by TechGC on April 15, 2020 that other metrics in
addition to EBITDA should be used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.
Diveplane is a leader in natively-explainable artificial intelligence, and like so many early stage
companies we reinvest all the money we bring in to make our products better, and expand the reach of
where our technology can help companies and people. (For example, we are currently working with a
top hospital to create a statistical �twin� of medical data restricted by HIPAA in order to help them
unlock further research using the statistical �twin� data.). As such, we request that alternative metrics
other than EBITDA be used for determining loan minimums and eligibility, such as (i) as a percentage
of enterprise valuation, (ii) determined by commonly accepted debt/equity metrics on a per industry
basis and/or (iii) as determined by the lending bank (who retains 5% risk) in applying reasonable
underwriting criteria relevant to growth-stage companies, such as cash on hand, existing debt,
operating costs, gross margins, etc. Use of alternatives to EDITDA could allow Diveplane to qualify for
the Main Street Lending Program. Further, our receipt and reinvestment of these funds will allow for
employee retention, and even job creation, two things that are needed now more than ever.
Thank you,
Michael Meehan, JD, PhD
General Counsel, Diveplane Corporation
[cid:image002.png@01D613E0.6B95F4C0]
Twitter<https ://nam12.safelinks.protection.outlook .com/?url=https%3A%2F%
Main Street Lending
David Gamboa [dgamboa@csudh.edu]
4/16/2020 4:31:22
On behalf of the California State University (CSU), specifically the Dominguez Hills campus, I submit
the following comments with respect to the "Main Street Lending" facility.
By way of background, the CSU is the largest system of four-year higher education in the country, with
23 campuses, 53,000 faculty and staff and 482,000 students. Half of the CSU's students transfer from
California community colleges. Created in 1960, the mission of the CSU is to provide high-quality,
affordable education to meet the ever-changing needs of California. With its commitment to quality,
opportunity, and student success, the CSU is renowned for superb teaching, innovative research and
for producing job-ready graduates. Each year, the CSU awards more than 127,000 degrees. One in
every 20 Americans holding a college degree is a graduate of the CSU and our alumni are 3.8 million
strong.
As with many entities across the country, the current health crisis combined with steps taken to reduce
the spread of COVID-19 have taken a tremendous financial toll on the CSU and its campuses. Across
the university system, CSU campuses have moved classes to online instruction, which is one of many
factors driving significant cost increases in providing a high-quality postsecondary education. At the
same time, revenue streams have decreased significantly and refunds have been made to students in
a number of areas, including student housing, parking, and student dining. Maintenance and debt
service for unused facilities continues, even though revenue is no longer generated. In order to meet
these challenges and keep personnel employed, public universities and non-profit entities will require
access to low-cost capital, such as that envisioned by the Main Street Lending facility. The CSU notes:
1.
There has been confusion about the Main Street Lending program and the eligibility of public
universities and non-profits because the current guidance is silent. We ask that the Federal Reserve
update the guidance to clarify that non-profit entities and public institutions of higher education with
direct borrowing authority are eligible for the Main Street Lending program; and
2.
Clarity is needed with respect to the definition of employment of student workers. Specifically,
the CSU asks that student workers be exempted for the purposes of the employee threshold for
eligibility (businesses with under 10,000 employees). We hope that future guidance from the Federal
Reserve will make it clear that institutions can exempt student workers from the employee count. Many
of our campuses employ student workers as a part of overall student financial support to help pay for
college and to provide students with work experiences while keeping them close to campus. With our
campuses closed, all or most of these student employees are no longer present, and therefore should
not be included for the purposes of the employee threshold.
Thank you in advance for your attention to these comments.
Best,
David
David Andres Gamboa
Associate Vice President, External Relations
California State University, Dominguez Hills
1000 E. Victoria Street, WH-490
Carson, California 90747
T: (310) 243-3819 | F: (310) 516-3976
E: dgamboa@csudh.edu<mailto :dgamboa@csudh.edu>
www. csudh.edu<https ://www. csudh.edu/>
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main street lending
Terry Glebocki [terry.glebocki@theoceanac.com]
4/16/2020 9:00:34
To Whom it May Concern:
Ocean Casino Resort ("OCR") is the largest independently-owned casino and resort in Atlantic City, NJ.
OCR employs nearly 3,000 workers. The term in the Main Street New Loan Facility (MSNLF) limiting
the maximum loan size to 4x 2019 EBITDA arbitrarily precludes creditworthy businesses like OCR from
participating in the MSNLF. JPMorganChase and other Eligible Lenders lend to OCR against the
appraised value of its real estate (RE), and not its annual EBITDA. Lenders to companies that own RE,
such as casinos, hotels, office buildings, retail centers, multifamily dwellings and other similar
businesses, typically use appraised RE values to measure borrowing capacity. Typical leverage in
commercial RE asset classes ranges between 65% and 75% of appraised value. Because of the
stability and limited volatility of EBITDA in most commercial RE, leverage levels in companies that own
and operate world-class RE like OCR tend to be higher than more volatile industries. The EBITDA
leverage test arbitrarily harm owner-operators of high-quality RE who responsibly carry leverage above
4x while maintaining credit performance. The 4x test results in aid failing to reach a large portion of the
commercial RE market. We urge the FRB to add an alternative leverage test of 65-75% of appraised
value (calculated by an Eligible Lender using its customary practices) for industries that customarily use
appraised RE values as the primary metric of borrowing capacity.
Thank you for your consideration,
[cid:image001.png@01D4EED6.54E62D10]
Terry Glebocki
Chief Executive Officer
500 Boardwalk
Atlantic City, NJ 08401
609-783-8040 (o)
Cell Phone Number
This communication and any files transmitted are PRIVILEGED AND CONFIDENTIAL INFORMATION
intended only for the use of the individual or entity to whom they are addressed. The information
contained in this communication is the property of Ocean Casino Resort and its subsidiaries and
affiliates. The information contained in this communication is confidential, may be attorney-client
privileged, and may constitute inside information. If you are not the named addressee, the unauthorized
use, dissemination, or copying of this communication or any part thereof is strictly prohibited and may
be unlawful. If you have received this communication in error, please notify me immediately by return email and destroy this communication and all copies thereof, including all attachments. If you have any
questions or concerns, please contact Ocean Casino Resort at (609) 783-8000.
Main Street Loan Comments
"lbo1d, Charles J." [Clbold@ThingsRemembered.com]
4/16/2020 8:54:42
NONCONFIDENTIAL // EXTERNAL
Enesco Properties, LLC provided comments through the Main Street Loan website at https ://www.
federalreserve.gov/apps/contactus/feedback.aspx?refurl=/main/. The below is an expansion on those
comments, and attached are exhibits that will serve as background/conformational data regarding the
website submission and the extended commentary and requests provide below. If there are comments
or questions please reach out to me at my contact information below.
CONTEXT: Things Remembered (TR) is a 53-year-old retailer of engraved gifts. It was acquired out of
bankruptcy (in a transaction that saved 1000+ jobs (Ex1) and merited a Distressed Transaction of the
Year award (Ex2)) by Enesco, a 62-year-old, profitable, gift wholesaler.
Conl@eiilial Business lnfoonatioo
REQUEST RE JOB-SAVING TURNAROUNDS: We respectfully request that applicants be permitted to
either:
(1) use "3 x ( 2019 avg mo. payroll + 2019 avg mo. rent )" instead of"2019 EBITDA" or
(2) add back "6 x 2019 avg mo. payroll" to EBITDA to account for the social benefit of the jobs it has
saved.
We propose this alternative only in the limited cases where 2 conditions are met:
(A) the Company was a bona fide purchaser of third-party assets in a bankruptcy that can be
demonstrated to have saved 500+ jobs in 2019 and incurred startup losses in so doing and/or
(8) a majority of the subject company's operations have been substantially shut down in March
through May 2020 due to a stay at home orders (e.g., a mall-based retail that cannot open due to its
stores being shut down).
We also request that Parent companies be permitted to deconsolidate subsidiaries or sister companies
from the EBITDA/leverage analysis, but only where conditions (A) and (8) above are met.
Respectfully Submitted,
Charles J. lbold
Charles J. lbold
Enesco Properties, LLC.
General Counsel
Things Remembered
26301 Curtiss Wright Parkway, Suite 400.
Richmond Heights, OH 44143
cibold@thingsremembered .com<mailto :cibold@thingsremembered .com>
44_0423-200.0.x 533_6,____
Cell Phone Number
Main Street Lending Comments
Frank Sinito [fsinito@mhmltd.com]
4/16/2020 10:05:31
Ladies and Gentlemen:
My name is Frank T. Sinito and I am the CEO and principal of The Millennia Companies, a group of
companies which own, operate and/or manage over 30,000 residential apartment units across 26
states ("Millennia"). Millennia's principal office is located in Cleveland, Ohio. I am also the principal of
companies which own, operate and/or manage mixed-use projects which house many hospitality
venues, including six restaurants, a party center, and a Marriott hotel (which is part of a 1.4M square
foot office tower, hotel and restaurant complex). The hospitality venues in our projects are all closed
due to Covid-19 and, as a result, I have been forced to lay off 466 employees who I hope to be able to
re-employ in the future.
In addition to the closing of hospitality venues, the economic impact of Covid-19 has significantly
Business
delayed our Confidential
of a currently vacant 1.1M square foot historic bank building in the
Information
heart of Cleveland: a redevelopment that will create thousands of new jobs, revitalize the center of the
City and add significantly to Cleveland's tax base. This delay was caused by the need to remove the
hotel component from the development as the market for new hotels has collapsed due to Covid-19.
There will be a 1 to 2 year delay in this project and the project cannot cover the existing carrying cost,
debt service and debt maturity cost that will occur during this delay.
In light of the above, I am writing you today to comment on the Main Street Loan Program and give you
my perspective on what is needed to avoid a financial crisis involving real estate with significant
hospitality components.
As everyone knows, the Covid-19 pandemic has resulted in the closure of hospitality venues across the
country. In my case, all six restaurants, the party center and the hotel have closed. These hospitality
venues provide significant income to the mixed-use projects my companies own. While EDIL and PPP
loans have been applied for with respect to the hospitality venues, it is unclear whether any or all of
these hospitality venues will receive EDIL or PPP loans. The EDIL loans and PPP loans are intended
to provide short-term funding to allow businesses to keep and/or retain employees and pay short-term
operating and other deficits that arise due to the economic impact of Covid-19. However, these
programs do not provide any MEANINGFUL assistance to owners of projects containing hospitality
venues which, PRIOR TO COVID-19, provided a significant revenue stream for the projects.
The impact of Covid-19 on the hospitality industry will continue long after the hospitality venues are reopened. Our estimate of the revenue losses for the 12-month period beginning April 1, 2020 on all of
Business
our hospitality venues Confidential
. These lost revenues mean that insufficient cash flow will
Information
be available to meet debt service and other obligations on these projects for at least the next 12-month
period.
The Main Street Loan Facility Program tries to provide funds to Eligible Borrowers to assist in covering
losses sustained due to the Covid-19 virus. However, because the loan program prohibits the use of
Main Street loans to pay or repay existing loans, the Main Street Loan Program will merely add
additional debt to projects which will not be able to pay the increased debt. The loss of revenue from
hospitality venues to the owners of the real estate in which those hospitality venues exist will result in
defaults under existing debt. What is needed are programs to provide funding to cover at least a year
of shortfalls in revenues due to the Covid-19 virus, but also a broader program of loans similar to the
FHA program to provide funding for the refinancing of existing debt on these projects at below market
rates. Absent the foregoing, this country will see thousands of loan defaults on projects that but, for the
downturn in the hospitality revenues, are viable and provide significant jobs and economic substance to
our economy.
With respect to my companies, we had 365 full-time equivalent employees in our hospitality venues.
We expect that once we can re-open, we will do so on a gradual basis and hire back employees over a
6 to 12 month period until we reach the same employment levels as we had on March 15th. The
revenue stream from these hospitality venues will be substantFrom fsinito@mhmltd .com Thu Apr 16
18:05:27 2020
MainStreet Lending
Chet White [cwhite@biotricity.com]
4/30/2020 4:41:07
1) we are a fast-growing medical devices company serving the remote medical monitoring cardiac
market. We have negative EBITDA in 2019 and positive EBITDA in the Froward 12 months. Will you
consider Froward EBITDA for this program like the EIDL??
2) We have a large amount of non-cash stock/warrant compensation (40% of G&A) of which other
lenders including the EIDL program with SBA have allowed us to take out of the expenses and add to
our "free cash flow" EBITDA calculation. Will you allow this??
Thank you
Chet WHite
Chet White
Cell Phone Number
+1 800 590 4155
275 Shoreline Blvd, Suite 150
Redwood City, CA 94065
cwhite@biotricity .com<mailto :cwhite@biotricity .com>
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Main Street Lending Program Feedback
"Solomon, Karen" [KSolomon@cov.com]
4/17/2020 1:53:46
Ladies and Gentlemen:
On behalf of the Marketplace Lending Association (MLA), we submit the following comment with
respect to the Federal Reserve's recently announced Main Street Lending Program. MLA is an
association of 35 technology-enabled lending companies with a mission to promote transparent,
efficient, and customer-friendly financial systems by supporting the responsible growth of marketplace
lending, fostering innovation in financial technology, and encouraging sound public policy.
The 35 members of the MLA applaud the Main Street Lending Program to support mid-sized
companies during the Covid-19 pandemic.
These programs can provide relief for our members, but to do so, the following terms should be
clarified: The Main Street Extended Loan Facility (MSELF) loan size test in 5(ii) is designed so
borrowers do not take on more than 30% in additional debt. The test in 5(iii) of the MSELF and 5(ii) of
the Main Street New Loan Facility should make clear that "bank debt" as defined in these tests should
permit, at the borrower's election, inclusion of all lending facilities, including asset-based warehouse
facilities, and should be consistently applied to the calculations in 5(ii) and 5(iii).
Our members often have existing bank loan facilities, including revolving and warehouse facilities, that
are integral to financing their businesses and they may have drawn these facilities in anticipation of the
pandemic's impacts and to house loans while access to capital markets is limited. The ability to extend
or refinance these facilities is constrained at this time. Without relief from the Main Street Lending
Program, our members may need to take more severe actions that will further restrict consumer lending
in order to repay bank debts when due.
If the above clarification is made, eligible MLA Members will be able to utilize the Main Street facilities
and keep credit flowing to consumers and small businesses.
Should you have questions, please do not hesitate to contact Nathaniel L. Hoopes, Executive Director,
MLA, at
nat.hoopes@marketplacelendingassociation .org<mailto :nat.hoopes@marketplacelendingassociation .
org> or (202) 662-1825.
Thank you for your consideration.
Karen Solomon
Covington & Burling LLP
One CityCenter, 850 Tenth Street, NW
Washington, DC 20001-4956
T +1 202 662 5489 | ksolomon@cov .com
www. cov .com
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Main Street Lending Facility EBITDA Restrictions
Victoria Libin [victoria.libin@brightmachines.com]
4/17/2020 1:51:50
We agree and sign-on to the comment submitted by TechGC on April 15, 2020 that other metrics in
addition to EBITDA should be used to determine eligibility and the permissible size of a loan under the
Main Street Lending Facility.
Our company, like many other start-ups and growth companies, would not qualify for the Main Street
New Loan Facility because the program requires borrowers to have positive EBITDA. We urge you to
modify the program's terms to ensure its availability to growing, entrepreneurial companies with
negative EBITDA by focusing instead on maximum loan amounts (i) as a percentage of enterprise
valuation, (ii) determined by commonly accepted debt/equity metrics on a per industry basis and/or (iii)
as determined by the lending bank (who retains 5% risk) in applying reasonable underwriting criteria
relevant to growth-stage companies, such as operating costs, existing debt, cash burn rate, etc.
Technology growth companies are the backbone of American innovation and job growth and the U.S.
government needs to support such companies during this pandemic and economic crisis.
Sincerely,
Victoria Libin
Sr. Vice President Legal Affairs
Victoria.Libin@brightmachines .com<mailto :Victoria.Libin@brightmachines .com>
+1 415 3050872
585 Howard St, San Francisco, CA 94105 USA
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dissemination or other use of, or taking of any action in reliance upon this information by person or
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sender and delete the material from any computer.
Main Street Lending
"Glickman, Christen" [Christen.Glickman@YouthVillages.org]
4/17/2020 1:32:05
My name is Pat Lawler, CEO of Youth Villages<https ://www. youthvillages .org/about-us/>, a national
nonprofit based in Tennessee<https ://www. youthvillages .org/about-us/locations/tennessee/>. Youth
Villages is a national leader in children's mental and behavioral health committed to building strong
families, delivering effective services and significantly improving outcomes for children, families and
young people involved in child welfare and juvenile justice systems across the country.
With a presence in 21 states and the District of Columbia<https ://www. youthvillages .org/aboutus/locations/>, Youth Villages employs over 3,000 individuals, and in 2019 we were able to serve over
30,000 people across our spectrum of services including foster care, mental health services,
therapeutic residential care, older youth services, and other community supports.
As the Treasury Department works to create a program to provide financing to banks and other lenders
to make loans to nonprofits and other mid-size business of between 500-10,000 employees, we ask
that the program:
*
Include a 0.50% interest rate (50 basis points) for 501(c)(3) charitable nonprofits at a 5 year
amortization.
*
Provide priority to 501(c)(3) charitable nonprofits responding to COVID-19 relief efforts.
*
Payments shall not be due until two years after a direct loan is made.
*
Employee retention provisions should begin on the date that loan funding is received by the
borrower.
*
In implementing any workforce restoration and retention provisions, "workforce" should be
defined as full-time employees or full-time equivalents.
Nonprofits are the third largest employer in our nation's economy. The recommendations above will
help to keep organizations financially strong and allow us to continue to meet the immediate needs in
our communities while planning for the future. In the toughest times, we do the toughest work. When it's
time to repair our nation, we need to be equipped to do that and our unique needs should not be
overlooked.
Allowing larger nonprofits like Youth Villages to access the Paycheck Protection Program is critical to
ensuring that during and after the COVID-19 crisis we are able to meet the needs of those we serve
and maintain the infrastructure and workforce to do so effectively. I would be happy to share more
about our work in Tennessee and across the country.
Sincerely,
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Patrick W. Lawler
Chief Executive Officer
Youth Villages
Christen Glickman
Federal Policy Manager
Youth Villages
777 6th Street NW, WeWork
Washington, DC 20001
Cell Phone Number
Christen.Glickman@youthvillages .org<mailto :Christen.Glickman@youthvillages .org>
www. youthvillages .org
[Logo - Email]