On January 25th, the FDIC issued an interim final rule, with request for comments, 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. The interim final rule is effective immediately. Comments should be submitted on or before March 28, 2011. 76 FR 4207.