The Federal Reserve’s Coronavirus Crisis Actions, Explained (Part 5)

By Nathan Tankus, Research Director of @thepublicmoney, Research Scholar at Global Institute for Sustainable Prosperity, and has often published in Naked Capitalism. Originally published at his blog, Notes on the Crisis.

This is part 5 of my ongoing coverage of the Federal Reserve’s Coronavirus actions. You can read Part 1 here, Part 2 here, Part 3 here and Part 4 here. Thursday’s post was very unfortunately timed as its main theme was the lack of big actions for almost two weeks and then the Federal Reserve announced a big suite of policy actions a mere hour later. The bright side is it makes writing this post relatively straightforward- we’re breaking down the many different things that were announced on Thursday. That being said, this is probably the most wide-ranging and complicated Federal Reserve announcement yet. What exactly is this “2.3 Trillion dollars” in lending devoted to?

April 9th

Municipal Liquidity Facility

Despite coming later in the announcement, I’m going to start with what I’ve been harping on for a while- Local and State debt purchases. Before getting into the details, I want to take a step back and comment on how huge this moment is. A decade ago, purchases of state and local municipal debt would have been unimaginable. There were not even leftists proposing state and municipal bond purchases at that time. It will forever change monetary policy that an option on the table is loosening financial constraints of state and local governments. One way to think about this is to look at Europe. Europe has no federal budget of macroeconomic significance and certainly doesn’t have a federal debt for the European Central Bank to buy and sell. Instead it picks and chooses the Eurozone member government debts it purchases- or doesn’t purchase. This is a political issue of profound significance. U.S. monetary policy may become politicized in this way, especially as we likely stay near zero interest rates for an extended period of time. We will likely be debating these points for many years to come.

The first significant thing to know about the Municipal Liquidity Facility (MLF) is that it is set up through a special purpose vehicle using section 13.3 emergency authority. This is significant because it means the Federal Reserve is trying to avoid the precedent of using section 14.2(b) powers where it has authority to purchase state and local debt of maturities 6 months or less. The program is authorized to buy debt that matures 2 years from the date of issuance or less, which is substantially shorter than congresswoman Maxine Waters’s proposal of 5 years or less. Since this facility is using special emergency powers and the Federal Reserve has politically committed to the idea that it “can’t take losses”, this program requires an “equity injection” from the Treasury and will be getting it to the tune of 35 billion dollars. The program is capped per issuer in that it can only purchase notes equal to 20% of the issuer’s 2017 revenue. 

The strangest and worst thing about the Municipal Liquidity Facility is the arbitrary population cut offs on eligibility for the program. While all states are allowed participation in the program, cities must have at least 1 million residents to get support while counties must have at least 2 million residents. The logic of these cutoffs is that states can use their better financial situation to support smaller municipalities. This is bad reasoning and ignores the political divides between small local governments and their state governments. As Brookings Institution fellow Aaron Klein pointed out on twitter, this arbitrarily benefits cities in the southwest and the west coast which annexed adjacent territory. To the extent that population limits make sense (I’m skeptical of that), it certainly doesn’t make sense to exclude cities with large Metropolitan Statistical Areas. Also, as he says, this excludes the 35 most African American cities. That is unacceptable

The facility is capped at 500 billion dollars which, while large, does not seem anywhere near large enough given the need. An associated Federal Reserve Bank of New York blog post argues that this cap is well above municipal and state issuance of short maturity liabilities. This defense is not very convincing for a number of reasons. First, the latest crisis radically raises financing needs because of collapses in incomes and sales which in turn collapse tax revenues. Second states not only need to be able to cover current shortfalls but they also need to be able to refinance longer maturity debt which they may have trouble refinancing under current conditions. This program has been launched under the assumption that sub-federal governments are facing short term “cash flow” issues because of delays in the payment of income taxes.  

The problem is this crisis is not merely about those delays, it is about actual losses in income for these governments. They need to quickly begin issuing small denomination, tax receivable IOUs so they can become less worried with the fiscal effects of the collapse. The Federal Reserve can facilitate their issuance and circulation by purchasing large quantities of these small denomination “Tax Anticipation Notes”.

Overall, this program is a good start but it doesn’t recognize the long term support the Federal Reserve will need to provide sub-federal governments, including territories like Puerto rico and smaller cities. This is a historic moment and it will hopefully be the first of many to come.

Paycheck Protection Program Lending Facility

This facility is far more conventional than the Municipal Liquidity Facility. It, like Term Asset-Backed Securities Loan Facility, is meant to provide liquidity to certain asset classes by making those assets acceptable collateral for loans. In fact, at first glance, what is strange is that this is a distinct facility rather than simply an extension of TALF. After all, certain loans guaranteed by the small business association are already acceptable as collateral for TALF. One reason that could motivate this decision is to highlight and make clear to everyone that these loans were getting liquidity backing. The details make it clear that there is a specific reason- the all important matter of recourse. These loans are no-recourse which means the borrower can default and all the lender will have is the collateral for the loan. In essence, a no-recourse loan is a purchase which gives the seller the opportunity to hold the underlying collateral in case holding it is profitable to them. 

This facility on one level makes sense- the Federal Reserve should do all it can to support congress’s program to help small businesses. On another level, it drives me absolutely crazy. If we were simply going to have banks originate loans and then have the Federal Reserve purchase them, why did we bother with congressional appropriations in the first place? This could have simply been a part of the Federal Reserve’s Main Street Lending Program. The political football that is the losses the Federal Reserve would have taken from forgiving loans could have been fixed by alternative accounting gimmicks. Instead of equity stakes into Federal Reserve SPVs, congress could have simply said that all losses should be booked in a separate emergency facility account that doesn’t count when calculating the Federal Reserve’s net-worth. Simply having the Fed manage and implement this program would have been far simpler than trying to roll out this program and have the Fed come in to fix technical issues in the background. This is a clear case where congress didn’t adequately think through program design and their initial design has been rendered incoherent by subsequent events.

Main Street Lending Program

The Main Street Lending Program is probably the most “out there” program announced. Municipal bond purchases are a big deal, but they also date back to a provision in the Federal Reserve Act from 1934. These programs are not completely unprecedented- during the great depression there was a section 13(b) in the Federal Reserve Act which provided similar powers- but those powers were removed in 1958 and are mostly forgotten. There is nothing the Fed wants to do less than lend to individual small businesses. There is no type of loan that needs proper underwriting more than a loan to a small business and the fed is currently nowhere near set up to do underwriting on individual loans. Their solution to this is have banks make loans and then the Federal Reserve will purchase 95% of those loans originated. The theory being that having to hold 5% of the loans on their books will incentivize prudent underwriting. This seems… optimistic and will likely slow down the lending process considerably. 

The program is actually divided up into two facilities, similar to the corporate debt facilities. There is a facility for purchasing existing loans of the accepted maturity and structure called the “Main Street Expanded Loan Facility”. There is also a new loan facility straightforwardly called the “Main Street New Loan Facility”. The loans must have a 4 year maturity from the date the loan was made. The big benefit of these loans is that they defer principal and interest for one year. This is an extraordinary feature for the Federal Reserve to include as it represents losses today that may, or may not be made with future payments. That said, just because its extraordinary the Fed included it doesn’t mean it’s very beneficial to borrowers. As always, a business will take this kind of loan over going out of business but greater quantities of debt still put them on more and more of a backfoot.

– principal and interest payments deferred for one year.

The terms of accessing the facility naturally center around what to do with the proceeds of the loan. You aren’t allowed to repay other debts with it and should only make scheduled principal payments. You also aren’t allowed to seek reductions in your lines of credit. In contrast to PPP loans, these loans only require borrowers to make “reasonable efforts” to keep employees on payroll. Finally, for the duration of the loan, borrowers must restrict executive compensation, dividends and stock buybacks. The terms of these loans are about what we’d expect. The coming months will tell us how they are enforced. Finally, the facilities will be purchasing up to 600 billion dollars in loans. It doesn’t seem like this will be enough, though between this and PPP we’re getting to very high dollar amounts directed to small businesses

Old Business

The first three programs we assessed are brand new. The next two under discussion are already announced programs that we are already very familiar with. TALF has been expanded to include Commercial Mortgage Backed Securities rated AAA by rating agencies and a number of newly issued Collateralized Loan Obligations. Recall that these loans are non-recourse, so they function as effectively purchases of these assets. The overall size of the program hasn’t been expanded, which suggests there hasn’t been much interest in it so far. Overall though, these changes are relatively small.

More interesting are the changes to the corporate debt facilities. As I expected, the facility has been changed to “grandfather” in corporations who had their ratings downgraded recently. Strangely, they picked March 22nd as the cutoff date when its possible that a company would have already been downgraded because of coronavirus predictions by then. The overall size of the Primary Market Corporate Credit Facility and the Secondary Market Corporate Credit Facility has also been expanded to 750 billion dollars altogether. The differential caps have been eliminated so that now any entity that meets the minimum rating standard will get the same benefit. The secondary market facility is now capped at 10% the eligible corporation’s highest outstanding total of securities at any point in the past year. The primary market facility is capped at 130% of the eligible corporation’s highest outstanding loans plus securities outstanding over the past year. Additionally, they’ve introduced an overall program cap. Both facilities combined will not devote more than 1.5% of their total size to any one eligible issuer. That is currently 11.25 billion dollars. The overall amount of shares of an exchange traded fund that the program will hold is also capped at 20% of their outstanding shares.


It is becoming a running theme in my coverage here that the Fed’s announcements are both a great leap forward for them but, at the same time, far too little. The latest announcements are no different. I’m also concerned that the accounting gimmick the Federal Reserve and the Treasury have chosen to politically defend the Federal Reserve from attack is inhibiting the functioning of their programs. A different accounting gimmick- such as creating a special account for emergency facilities where losses are booked but don’t affect the Federal Reserve’s balance sheet and calculation of net-worth- wouldn’t have relied on congress appropriating specific sums of money to be invested in Federal Reserve programs. That political effort could instead be devoted elsewhere. Meanwhile, the Federal Reserve could declare open-ended purchases that would be far more effective. Currently they are running into the “Quantitative Easing” problem where it takes many, many purchases to get a small movement in interest rates. Their municipal purchases program especially suffers from. It will be interesting to see how they deal with this problem as time goes on.

Stay Safe!


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About Lambert Strether

Readers, I have had a correspondent characterize my views as realistic cynical. Let me briefly explain them. I believe in universal programs that provide concrete material benefits, especially to the working class. Medicare for All is the prime example, but tuition-free college and a Post Office Bank also fall under this heading. So do a Jobs Guarantee and a Debt Jubilee. Clearly, neither liberal Democrats nor conservative Republicans can deliver on such programs, because the two are different flavors of neoliberalism (“Because markets”). I don’t much care about the “ism” that delivers the benefits, although whichever one does have to put common humanity first, as opposed to markets. Could be a second FDR saving capitalism, democratic socialism leashing and collaring it, or communism razing it. I don’t much care, as long as the benefits are delivered. To me, the key issue — and this is why Medicare for All is always first with me — is the tens of thousands of excess “deaths from despair,” as described by the Case-Deaton study, and other recent studies. That enormous body count makes Medicare for All, at the very least, a moral and strategic imperative. And that level of suffering and organic damage makes the concerns of identity politics — even the worthy fight to help the refugees Bush, Obama, and Clinton’s wars created — bright shiny objects by comparison. Hence my frustration with the news flow — currently in my view the swirling intersection of two, separate Shock Doctrine campaigns, one by the Administration, and the other by out-of-power liberals and their allies in the State and in the press — a news flow that constantly forces me to focus on matters that I regard as of secondary importance to the excess deaths. What kind of political economy is it that halts or even reverses the increases in life expectancy that civilized societies have achieved? I am also very hopeful that the continuing destruction of both party establishments will open the space for voices supporting programs similar to those I have listed; let’s call such voices “the left.” Volatility creates opportunity, especially if the Democrat establishment, which puts markets first and opposes all such programs, isn’t allowed to get back into the saddle. Eyes on the prize! I love the tactical level, and secretly love even the horse race, since I’ve been blogging about it daily for fourteen years, but everything I write has this perspective at the back of it.


  1. notabanker

    Excellent post, thanks. Seems to be a pretty undeniable theme of the bigger you are, the more you get.

  2. Jose Oliveira

    It seems to me that the main issue is always left to the side and that is the pure capitalist way of organizing the economy and society. The facts show that all that has failed miserabily. All efforts to return to the old fashion way are doomed. A very different approach is needed, something like the Green New Deal or even going deeper.

  3. Mattski

    Huge lot to learn here; some MMT friends drew my attention to it this a.m. Thanks for posting. To the degree possible, we must get the word out!

  4. griffen

    The population count seems like it was plucked from thin air. Where im at now, in upstate SC, the local city / county / MSA for Greenville & Spartanburg most likely does not qualify. One supposes the density of population also infers more likely to have Covid-related outbreaks, thus the 1 million & 2 million.

    I think the FED found everything it can possibly do. And this time they included the kitchen sink. Tis curious that CLO issues are viable for purchase.

  5. Susan the other

    I don’t follow debt instrument design. So forgive this comment please. It’s way too convoluted for me. But I’m glad to see the Fed and Congress are infusing states and municipalities with emergency funding. The setup to go through state banks who can bundle loans for smaller municipalities sounds like it will work. But the Fed’s hesitancy against incurring “losses” is laughable. Considering how much money they have poured into, and wasted on, corporate America. They seem to be realizing too late that the only thing that will save corporate America now is, in fact, mainstreet America. And they are so reluctant to take this “leap” that they are acting like the ECB almost – in that the ECB is now willing to loan to EU members but they insist they can only do so if those countries’ central banks are the conduit and take responsibility for the loans as “sovereign debt.” All the while the Fed and the ECB are creating and stuffing bad banks with corporate debt, like a pig roast.

    1. JTMcPhee

      “They seem to be realizing too late that the only thing that will save corporate America now is, in fact, mainstreet America.“

      Isn’t that what in effect happened in the GFC? All that Funny Munny that got pumped into the banks and corps exists, in the end, only because there is a “real” economy out there that did the bootstrapping (however saddled with outsourcing and corruption) in Regenerating the real wealth that is the firm ground the “full faith and credit” of the US stands on. MMT money might seem infinite, but there has to be something tangible that people can eat, wear, live in, ride around in, do stuff with. Always, of course, with the looters doing everything their inventive little minds can come up with to keep stripping away real wealth as fast as it is generated.

      My thinking is that the folks that invented the Jubilee notion understood that reality implicitly. While the Banksters and CEOs and their purchased legislators living in bubbles while inflating other bubbles, constantly bleed and cut “tranches” off the old “body politic.”

      One has to ask why, with all the smart people who come up with all these models thinking about it, and operating the financial froth generating machinery, there does not seem to be any understanding of how to get to at least a metastable political economy that has the kinds of homeostatic negative feedback loops in place to spare us mopes the repeated miseries and failures of boom-and-bust. Or maybe it’s that there are possible mechanisms to accomplish that, but the people that gather in all the power and the real and frothy wealth just make implementing anything like that possible.

      1. Lambert Strether Post author

        > My thinking is that the folks that invented the Jubilee notion understood that reality implicitly

        It has occurred to me, from some vague memories of Thinking Like a State, is that the Jubilees were invented not because the leaders were wise, because they were exit. In the early days, states regularly collapsed, and of the triad, exit, voice, and loyalty, exit was virtually frictionless.

  6. diptherio

    There’s barely a million people in Montana as a whole, much less in any one city or county. So no soup for us from the Muni programs, I guess. Clarifying. At least the State is eligible, but that hardly helps for little places like mine, that are small even by Montana standards.

    And word on the street is that the SBA lenders are swamped with PPP applications, and if you didn’t have a pre-existing relationship with one of them, you’re in for a long wait to get your application through. Heck, even if you do already bank at Wells, if you’re tiny, good luck. And if your business has been banking at a credit union, no soup for you either. Also clarifying.

    I’m getting the impression that bottlenecks in application processing capacity at the SBA lender banks is going to be a real issue in the effectiveness of the PPP.

    1. False Solace

      Yes, the help is too little too late. This isn’t a recession like the ones Pelosi and Trump understand. For some business segments smoke is coming out of the crater where demand used to be.

      We had about a month to get aid and loan guarantees lined up. That time is now gone. Small business is not coming back. That means consolidation. Big players can wrangle the bureaucracy. They’ll survive and get bigger. That’s great for the politicians who depend on them for campaign donations: they’ve earned their pay. Not so great for the rest of us.

      Conditions truly are on the scale of a war but the political class is treating it like a weekend hurricane or your run-of-the-mill debt-based recession. I don’t see anything like a V shaped recovery. Expect heavy bloodshed in November.

  7. Rory

    Thanks for posting this, and to Nathan Tankus for the clarity of his presentation. It really helps me try to understand what is going on.

  8. RJM Consulting

    Two questions for anyone with the answers:
    1. I thought Dodd-Frank prohibits the use of a ratings requirement?
    2. My quick read of the SBA loan application requires deducting any amount received from EIDL assistance; but the EIDLs have also been delayed. If correct, (and I could be wildly incorrect) how are the local banks to proceed?

  9. Jeremy Grimm

    I am still trying to understand all the complexities of the FED’s actions and the mysterious accounting rules and principles they must adhere to. As I watch the processes unfold I have an eerie feeling of watching a fast moving shell game, trying to figure out where the pea ends up and I keep wondering what sort of action is going on under the table.

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