- The revised term sheet and FAQs clarified that investment funds may be eligible borrowers;
- The Fed will provide monthly public disclosures identifying TALF borrowers, their “Material Investors” (i.e., any direct or indirect owner of 10% or more of any outstanding class of securities of such borrowers), amounts borrowed, interest rates and other information;
- TALF borrowers must certify that they are unable to secure adequate credit accommodations from other banking institutions;
- No new asset classes have been added; the FAQs include detailed requirements for CLOs, CMBS and other eligible assets;
- Only S&P, Moody’s and Fitch are eligible rating agencies under TALF 2020;
- Collateral review, issuer certifications, auditor assurances and SBA loan documentation have not yet been detailed; and
- The operational starting date for TALF 2020 has not yet been announced, and a form of the Master Loan and Security Agreement has not been provided.