On Tuesday, February 4, SFA and the Bank Policy Institute (BPI) submitted a joint letter to the Federal Deposit Insurance Confirmation (FDIC) on its proposal regarding clarity around the Federal Interest Rate Authority. Our letter supports the FDIC’s efforts to address market uncertainty due to the Madden ruling by clarifying longstanding market expectations regarding the validity of a loan’s interest rate once the loan has been sold, assigned, or otherwise transferred. SFA previously submitted a joint letter to the Office of the Comptroller of the Currency on its valid-when-made proposed rule. If you’re interested in joining SFA’s Valid-When-Made Task Force, please contact the SFA Team.

Read full letter here.