The US Securities and Exchange Commission (“SEC”) issued an order on May 15, 2020, granting broker-dealers exemptive relief in connection with their participation in the Term Asset-Backed Securities Loan Facility (“TALF 2020”) in response to a request of the Federal Reserve Bank of New York (“FRBNY”).  TALF 2020 contemplates that certain broker-dealers will act as intermediaries (“TALF Agents”) between borrowers and a special purpose entity established under the program (“TALF SPV”) to make loans available to borrowers that are to be fully secured by eligible asset-backed securities.  Borrowers must maintain an account with a TALF Agent in order to gain access to TALF 2020 loans through the TALF SPV.