Mnuchin v. Waters

On November 19, Treasury Secretary Steven Mnuchin announced that he would sunset five of the Federal Reserve’s emergency lending programs at year-end: the Primary Market Corporate Credit Facility, Secondary Market CCF, Municipal Liquidity Facility, Main Street Lending Program, and Term Asset-Backed Securities Loan Facility (TALF). His decision,…

Under the  Coronavirus Aid, Relief, and Economic Security (CARES) Act, Congress appropriated $454 billion to the Treasury’s Exchange Stabilization Fund (ESF) to backstop emergency lending facilities known as “special purpose vehicles” (SPVs).[1]  With the Treasury backstop, the Fed has the potential to lend a maximum of $4.5…