On January 18th, the FDIC approved an interim final rule clarifying how it will treat certain creditor claims under the new orderly liquidation authority for non-bank financial institutions established under the Dodd-Frank Act. The interim final rule emphasizes the statutory intent that creditors bear the losses of any failure. The interim final rule differs from the proposed rule by clarifying the standard for valuation for collateral on secured claims and by clarifying the treatment of contingent claims. The interim final rule does not change the proposed rule's approach to the availability of additional payments to creditors. FDIC Press Release.