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Proposal:

1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck
Protection Program Loans

Description:
Comment ID:

137211

From:

Benjamin Bronfman

Proposal:

1712(AF86) Reg Q; Paycheck Protection Program Lending Facility and Paycheck
Protection Program Loans

Subject:

Regulatory Capital Rule: Paycheck Protection Program Lending Facility and
Paycheck Protection Progra

Comments:

Date:Apr 17, 2020
Proposal:Regulatory Capital Rule: Paycheck Protection Program Lending Facility and Paycheck [R1712]
Document ID:R-1712
Revision:1
First name:Benjamin
Middle initial:Z
Last name:Bronfman
Affiliation (if any):
Affiliation Type:Other (Oth)
Address line 1:660 Madison Ave
Address line 2:Suite 1250
City:New York City
State:New York
Zip:10065
Country:UNITED STATES
Postal (if outside the U.S.):
Your comment: As I've been dealing with the many ramificaitons of the COVID19 pandemic, i've also
been taking considerable time to asses how the government response to the pandemic is being
recieved by people across the economic spectrum.
Obviously, this is a major poltiical issue in terms of the public perception of this massive government
bailout.
To me, it's extremely important that Community Development Financial Institutions (CDFI's) are
included, and their precense highlighted within the financial sector.
I think we can all agree on is that when we emerge from this pandemic, the economic toll will be the
largest we've seen in decades and it will take time for our economy to rebuild itself.
One consequence of this crisis is that wealth dispartiy will most likely increase as we emerge from this
unfortunate episode.
CDFI's will also emerge as a pivotal pillar in the context of engaging with minorties, women and the
underbanked.
To get specific, I think it is extremely important (both economically and politically) that Community
Development Financial Institutions (CDFI's) are included by the Fed in the "supply chain" of the PPP
and PPPLF programs.
As you know, CDFI's primarily serve minorities, women and and the "under-banked."
By making sure that these financial institutions can both originate and purchase PPP loans and pledge
them under the PPPLF it will be extremely helpful to continue serving their target customers. It will also
help publics'; perception as it relates to government's sincere attempt to make sure that capital flows
into the hands of the underserved during this crisis.