The transition away from LIBOR to SOFR is due to become a reality by year-end 2021. With the impact of COVID-19 still evolving, some have questioned whether more uncertainty should be introduced into the market. We look at recent developments and their potential impacts.

SFA submitted a letter to the Office of the Comptroller of the Currency (OCC) in response to its proposal concerning when national banks or federal savings associations (a “Bank”) make loans and are the “true lender”. SFA supports the proposal as an important corollary to the recently finalized ‘valid when made’ rule in order to ensure the enforceability of the interest rate and other terms of loan agreements when a Bank finances or sell the loans to non-bank entities.

As colleges commence their fall semesters across the country, we take a look at how the pandemic is affecting college enrollment, student loan repayment, and the ultimate impact on student loan ABS.