Question: 

Will the published Administrative Interpretation suffice as “law” when Fannie Mae retires the net yield index (RNYI) on June 3, 2024 and in the event the proviso is not adopted by the General Assembly. 

Answer:

Pursuant to Section 37-6-506(3), if a creditor acts in conformity with an interpretation of the Administrator, the creditor will not be subject to penalties under Title 37 or any statute that refers to Title 37 while the interpretation is in effect. In essence, the Administrative Interpretation provides a safe harbor to creditors that comply with the interpretation. The Department issued the interpretation to cover creditors between the retirement date and the effective date of the proviso or, in the event the proviso is not adopted, until such time the interpretation is rescinded or overruled/changed by another authority (e.g., court, General Assembly).

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