S&P Global Market Intelligence reports that corporate bankruptcies totaled 470 between January and September 2020, the highest number of filings for any comparable period in the past 9 years. Of these, 36 were so-called mega-bankruptcies as these companies had more than $1 billion in liabilities at the time of filing. Consumer discretionary, industrials and energy sectors led bankruptcy filings.

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.