ACG submits comments on the Federal Reserve's Main Street Lending Program


Consumer confidence will never rebound if Americans are not gainfully employed

CHICAGO, April 16, 2020 – The Association for Corporate Growth (ACG) today sent comments to the Federal Reserve regarding the recently announced Main Street Lending Program, created under Coronavirus Aid, Relief, and Economic Security (CARES) Act.

The Federal Reserve created the Main Street Business Lending Program which is targeted for middle-market companies. ACG urges the Federal Reserve to be liberal in its administration of the Main Street Lending Program and recommended solutions in the areas of:  

  • EBITDA Loan Sizing Test
  • Meaning of “Bank Debt” in the 30% Size Limiting Test for ELP
  • Meaning of “Committed but Undrawn Debt” in the Leverage Size Limiting Test
  • Maturity for Expanded Loan Facility
  • Eligible Lenders
  • Distribution/Equity Repurchase Issues
  • Issues with Restriction on Ability to Repay “Other Debt of Equal or Lower Priority”
  • Interest Rate Issues
  • Foreign Ownership
  • Practical Access to ELF

Tom Bohn, ACG Global President and CEO and Martin Okner, Chairman of the ACG Global Board of Directors, wrote: "COVID-19 forces companies to face a profound confluence of concerns daily, at the forefront is the livelihood of their employees. The Federal Reserve is the fabric that keeps this U.S. economy together - wedding consumer and business interests to make it stable and vibrant. We urge the Federal Reserve to be liberal in allowing access to the relief loans intended to keep people employed and businesses operating and to respect the judgment of business leaders who are willing to assume debt as a means to survive this crisis. Consumer confidence will never rebound if Americans are not gainfully employed".

The letter can be found here.

ACG thanks Duane Morris and Goodwin Procter LLP for their support. Goodwin Procter's entire recommendation can be found here.