The program is intended for issuers with "significant U.S. operations" and a "majority of U.S. based employees." Query whether this will lead to difficult counting or accounting decisions for issuers that might be on the fringes of eligibility?

In addition, here are two small eccentricities of the program: despite the official disfavor of the use of LIBOR-based interest rates and reliance on credit rating agencies, the program will (i) rely on credit ratings to determine eligibility…

See also and associated commentary.

One unfortunate, but inescapable, fact illustrated by the letter is that forbearance requirements are not cost-free. If borrowers do not have to pay their loans, then servicers will in turn need government assistance or they may fail. In the housing and real estate market, the long-term economic cost of those failures could be significant.

What does the virus do to New York City property values? It may be the case that all property values are somewhat speculative at this point, or maybe also in the intermediate future. It will take time before we know the extent, if any, to which the ordinary routines of life, such as riding the subway, are impacted.