I hope my interpretation is incorrect, but I believe the banking industry sought permission from the SEC to treat loans originated under the Main Street program as loan sales. This would allow banks to not include the loans on balance sheet, and so not have to allocate any capital or loss reserve against them. However, the bank does retain a 5% loss exposure to the loan balances. I think this is a bad precedent, crafted out of a noble cause, which is to help businesses survive an unprecedented shutdown. Still, It’s a slippery slope; it’s not a true sale when 5% credit risk remains.