- As of Monday, September 21, the Main Street lender portal includes the additional functionality to support multi-borrower loan structures, meaning the program now permits the submission of multi-borrower loans – loans made to multiple co-borrowers. The program previously posted updated legal documents and forms for use in lending in these situations. Further guidance is available in the Instructions for Lender Required Documentation and the For-Profit Business FAQs and Nonprofit Organization FAQs.
- On September 18, 2020, the Federal Reserve Board updated program FAQs to clarify the Board and Department of Treasury’s expectations regarding lender underwriting for the Main Street Lending Program. The revised FAQs emphasize that lender underwriting should look back to the borrower’s pre-pandemic condition and forward to their post-pandemic prospects. The FAQs also clarify supervisory expectations for lenders originating Main Street loans. Specifically, the MSNLF, MSPLF and MSELF (for-profit facilities) Frequently Asked Questions (FAQs) (see comparison), NONLF and NOELF (nonprofit facilities) FAQs (see comparison), and Instructions for Lender Required Documentation (see comparison) were amended to provide clarity on a number of issues, including:
- emphasizing that lender underwriting should look back to the borrower’s pre-pandemic condition and forward to the borrower’s post-pandemic prospects and clarifying supervisory expectations for lenders originating Main Street loans (FAQs F.3, I.2, and K.4);
- providing guidance on completing and submitting Main Street legal documents, and entering data into the Portal, for multi-borrower loans (FAQs H.24, H.25, L.8, L.9, L.12, and M.5); and
- clarifying the application of the direct loan restrictions on loans between Main Street borrowers and their owners, employees, and officers (FAQs H.20, H.21, H.22, and H.23).