Tier 1 issuers accept a deeper discount to access the Fed facility; as of last week, the funding facility was accepting paper at a discount rate of 1.21%, while Tier 1 nonfinancial paper in the regular market was going at a discount of 21 bps and Tier 1 financial paper at 51 bps. But the funding facility's pricing looks attractive to Tier 2 issuers; AFP calculates that Tier 2 companies are paying 2.12% more to issue 90-day paper than Tier 1 companies.

If Tier 2 companies, such as FedEx, Kraft and Safeway, can access the commercial paper market, that takes some pressure off banks, says Kalish. “Every dollar they can't fund themselves in the commercial paper market, they're turning around and funding with their banks,” he says. “That's one more dollar banks don't have to lend elsewhere.”

Still, the commercial paper market is showing some signs of life. Outstandings totaled $1.48 trillion in March, still well off the market's 2007 peak of $2.2 trillion. But the CPFF's holdings are off almost a third from the peak of $349.9 billion in late January, suggesting more issuers are able to stand on their own. In the final week of March, the facility held $240.8 billion, or about 16% of the total paper outstanding.