The Fifth Circuit held that an arbitrator may award a non-statutory rate of post-judgment interest if the parties agreed to submit that issue to arbitration. Tricon Energy Ltd. v. Vinmar Int’l, Ltd., No. 12-20100 (5th Cir. May 3, 2013). In this case, the court found that the parties had agreed to submit the issue of the rate of post-judgment interest to arbitration and the arbitrator could have awarded post-judgment interest at a rate different than the prescribed statutory rate. The court noted, however, that the arbitrator’s order referred only to “post-award” interest, and did not mention “post-judgment” interest expressly. Accordingly, the court would not find that the arbitrator had awarded “post-judgment” interest at a non-statutory rate, and instead applied the statutory rate of post-judgment interest upon the district court’s confirmation of the arbitration award..