Coronavirus (COVID-19)

Last week the Board of Governors of the Federal Reserve System (the Federal Reserve) announced changes to the terms of the Main Street Lending Program (the Program) aimed at boosting small business participation in the Program. As explained in further detail below, the Federal Reserve reduced the minimum
Continue Reading Federal Reserve Board Amends the Terms of the Main Street Lending Program to Support Small Businesses

The SBA has issued a long-awaited Procedural Notice providing guidance on the procedures for changes of ownership of an entity that has received Paycheck Protection Program funds.

Our memorandum contains flowcharts outlining when SBA consent is required for M&A transactions involving borrowers that want to sell their business to another
Continue Reading SBA Guidance: M&A Transactions and PPP Borrowers

The Federal Reserve has opened the Main Street Lending Program to nonprofits. Main Street loans are complicated, and the fact that Main Street’s nonprofit lending facilities were bolted onto an existing framework for profit-driven corporations adds another layer of complexity. We hope this memo helps clarify the program and serves
Continue Reading Main Street Support for Nonprofits

We have updated our visual memo on the Main Street Program and our memo on the legal architecture of the Main Street Program to reflect the expansion of the program and the revised program documents that the Federal Reserve announced this week. The visual memo provides an overview of the
Continue Reading Main Street Program: Updated Davis Polk Memos

Following our initial post and subsequent update on the Bank of England’s (the “Bank”) Covid Corporate Financing Facility (“CCFF”), on 19 May 2020 the Bank issued a press release announcing the publication of a consolidated market notice that incorporates revisions to the operation of the CCFF, including with respect to
Continue Reading COVID-19: Update to the Covid Corporate Financing Facility

The Federal Reserve announced on May 11 a revised term sheet and FAQs for its Municipal Liquidity Facility (MLF), which will provide up to $500 billion of direct support to states and local governments to help them manage cash flow stress related to the COVID-19 pandemic.  Relative to
Continue Reading Fed Announces Pricing for Municipal Liquidity Facility

Updated May 7, 2020

We have updated Davis Polk’s table summarizing the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website.

Visit Davis Polk’s Government Support for Businesses page for more information on these and other federal Continue Reading Fed Actions to Address the Coronavirus Crisis

The Federal Reserve has taken temporary measures (and has published FAQs) to (1) lift the net debit cap on and waive fees for daylight overdrafts for financially sound depository institutions, including U.S. branches and agencies of foreign banking organizations, and (2) provide a streamlined approval process for other depository
Continue Reading Federal Reserve Eases Daylight Overdraft Limits

Our UK COVID-19 Considerations for Authorised Firms memorandum published earlier this month focused on the steps UK authorised firms can take to ensure their responses to the coronavirus (COVID-19) crisis are consistent with the expectations of the Financial Conduct Authority (FCA) and summarised some of the key announcements and measures
Continue Reading UK COVID-19 Considerations for Authorised Firms – Update

The Federal Reserve announced on April 27 the expansion of its Municipal Liquidity Facility (MLF), which will provide up to $500 billion of direct support to states and local governments to help them manage cash flow stress related to the COVID-19 pandemic.  Key features of the MLF as
Continue Reading Fed Expands Support for Municipal Funding Markets