WIFIA-interest-rate-reset-amendment-language-09282023-InRecap

^{PDF here}

Yesterday the 20Y UST rate was about 4.75%. Where will it be in September 2024? Probably about the same or even higher, given recent Fed indications. But who knows? We live in interesting times and a lot could happen in a year. Known unknowns are bad enough — massive geopolitical change, serious economic uncertainty and a ferocious presidential election, to mention a few. Add black swans to that mix and it’s entirely possible that Fed policy will make a radical U-turn at some point in the next few years and long-term rates will be much lower, at least for a temporary period.

A Quandary for Long-Term Infrastructure Financing

If you’re planning on financing a public water infrastructure project with long-term debt anytime soon, uncertainty about falling rates poses a quandary. Yes, a standard tax-exempt bond series with a weighted-average-life (WAL) of about 20-25 years will have a sub-UST overall rate (around 4.25%) and the cost of the construction escrow will be negligible. Once issued, you’re protected from further rate rises. But you’re also locked out of tax-exempt refinancing by advance refunding restrictions until the bonds can be called, usually about 5-10 years out [1].

A WIFIA loan for 49% of project cost will have a higher fixed UST-based rate (about 4.75% for 20-25-year WAL). But it has other benefits. The rate is locked for construction draws so an escrow is unnecessary, the full loan term is about 40 years, and the loan has no commitment cancellation, prepayment or make-whole penalties. Obviously, a WIFIA loan is not subject to advance refunding rules and can be refinanced anytime.

On the surface, the option of refinancing to take advantage of near-term opportunities might seem to offset the loan’s slightly higher rate. But a federal loan will have crosscutters like Davis-Bacon that increase project cost. The increased costs are not necessarily major, but it would be better (at least optically) if they were amortized for a few years before sinking them. And there are more direct political angles. In contrast to standard muni bond decisions, a WIFIA loan will need to be championed internally. Externally, federal & local pols may show up for a loan closing photo-op and speechify about how great the loan is. You may hesitate before unwinding those stories too soon. As a practical matter, a WIFIA loan’s first refinancing option might be a few years after closing, not that different in principle from the first par call on some muni bonds.

WIFIA’s Downward Rate Reset

This is where WIFIA’s reset comes in. In 2018 and early 2019, WIFIA executed a few big loan commitments with highly rated water agencies. The commitments remained undrawn because short-term tax-exempt debt for construction draws was cheaper. In effect, the agencies were using their commitments as fixed-rate options for permanent financing. By late 2019 and 2020, these options were increasingly out-of-the-money as interest rates fell to historic lows. In a purely private-sector transaction, such options would simply be written off. As noted above, things are more complicated when a federal loan commitment is involved. But the political complications work both ways — with the threat of cancelling the big, much photo-op’d and press-released loan commitments, the agencies could pressure WIFIA into re-setting the option strike price (i.e., the loan’s rate) to market. It took a few months of internal wrangling, but WIFIA duly delivered the first loan reset in late summer 2020. With the precedent established, resets for six more out-of-the-money loan commitments were completed in late 2020 and early 2021. As interest rates began their steady rise to more normal levels and beyond, previously executed commitments were increasingly less underwater and new commitments were in-the-money, so further resets were unnecessary. [2]

A Bureaucratic Accommodation

It’s important to note that in essence WIFIA’s decision to do resets was a matter of unusual bureaucratic accommodation, not economic reallocation. If you have an out-of-the-money interest rate option but want one with a lower strike, it’s easy enough to sell the old option and buy a new one, though of course you’ll incur a net loss. For a WIFIA ‘option’ (the undrawn loan commitment), the borrower can cancel its existing one and re-apply for a new one executed at current UST rates. By clarifying that the purpose of the cancellation and re-application is solely to obtain a better rate, there shouldn’t be any sunk project costs or political friction. And since both options are ‘free’ anyway, there’s no loss. Well, other than transaction costs, right?

Ah, transaction costs — there’s that. The full WIFIA loan application and execution process involves a series of steps and approvals. Repeating it will involve re-submitting (and perhaps updating) a lot of documents and reports, which, though likely to be successful again, takes time and the outcome is not assured. Political and policy priorities may have changed in the competitive selection process for scarce credit subsidy, or there are just more worthy candidates this time around. Or OMB is in a surly mood and won’t approve anything to do with loans. Or the government has shutdown altogether for an indefinite period. And so on. Even if the incremental fees are trivial relative to the lower rate’s value, the process itself is a risky and potentially costly downside.

WIFIA’s accommodation was to short-circuit all that and simply re-execute the loan commitment with new UST rates. The important point is that they didn’t need to do it. There’s nothing in WIFIA’s statutes or typical federal credit procedures that anticipate this kind of situation because they’re built on the assumption that hard-pressed project finance borrowers will be only too happy with a UST rate and start drawing the loan right away. The default bureaucratic response in such cases is simply to shrug. Yet the WIFIA program, to its credit, saw the reverse of the medal in the absence of guidance — a re-execution wasn’t explicitly prohibited — and pro-actively got approval to do it. No doubt there was a political assist at various levels. Even so, I don’t know how technically difficult the expedited re-execution was, or what questions might have been asked (e.g., why do the borrowers need a WIFIA loan if they’ve got such good alternatives?), but a reset got done and then repeated six times to date. And the program wasn’t shy about advertising the outcomes in the usual terms. [3]

How Established is the Precedent Going Forward?

Obviously, there is still no WIFIA statutory provision that requires a reset even to be considered, much less granted. The program’s statement above from 2021 suggests that at least one reset will be “available”. But what is unexpectedly given by a bureaucratic system can be taken away just as opaquely. And what exactly is meant by the qualifier, “in limited circumstances”? Do they include your loan commitment being out-of-the-money by 25 bps. relative to the Aa3/AA- tax-exempt bond alternative the local underwriter keeps talking about over a 5-star lunch? Or your loan commitment is underwater by 2.50%, local loan sharks are offering a better rate, and you’re desperate to make your innovative environmental project at least somewhat economically feasible? They don’t say.

The exact nature of the reset precedent is relevant with respect to future applicants. Assuming that the reset remains “available”, there are two ways to see it in the context of the applicant’s intentions in applying to the program. The first sounds like WIFIA’s own statement:

The WIFIA loan was applied for as a primary and essential component of the project’s financing. If rates fall significantly, the program can and will help you out with a one-time rate reset if the loan commitment hasn’t yet been drawn, due to construction timetable or other real-world factors.

The other is quite different:

The WIFIA loan was applied for as an optional component of the project’s financing. Tax-exempt bonds are expected to be the primary source. The WIFIA loan commitment is an interest rate option and will remain undrawn until it’s optimally in-the-money for permanent financing. If rates fall significantly, or even materially, relative to bond alternatives, the program must reset the loan rate once when requested, as equitable treatment established by precedent.

The former is in line with WIFIA’s stated overall policy purpose and rationale, where the reset is provided as a helpful benefit to keep the project going in the face of unexpected developments. The latter is not. There the WIFIA loan is being used as a financial option, not a financing source, and the reset is simply a feature to improve its value. Of course, if the applicant is a public-sector agency (almost all are), then either way the benefit ends up reducing total project cost to local ratepayers, so there’s still a public purpose angle. Rather, the problem with the pure financial option usage is the explicit lack of any real or imagined additionality with respect to the actual infrastructure project, which gets built in any case. Not quite the narrative policymakers intended.

The intentions of WIFIA’s actual applicants and borrowers to date can objectively be said to fit somewhere between the two alternatives. This includes the seven recipients of past resets, all highly rated and sophisticated water agencies whose intentions would arguably be closer to the latter alternative.

WIFIA applicants obviously don’t advertise any intentions that might deviate from the approved policy narrative, and as far as I can tell, the program doesn’t ask too many questions. If available, and limiting circumstances are more nominal than constraining, the program will likely grant future resets to those of pure and impure intentions alike.

But the intentions of the applicants may matter more with respect to a different question that involves the reset — whether to apply for a WIFIA loan in the first place. For applicants that intend to use the loan as a primary source of financing, the reset is a welcome, but not necessary, feature. They’d apply even if it wasn’t offered again or if the precedents were considered an indicator of, but in no way a commitment to, future actions. Likewise, the ambiguity of “limited circumstances” won’t be a deterrent.

A potential applicant that intends to use the WIFIA loan commitment primarily as an interest rate management tool, however, might have a different perspective. They would want to see the precedents as establishing a de facto commitment to continue offering the feature and the “limited circumstances” as referring only to the fact that rates have fallen after a loan agreement has been executed. More like a real option, in other words. In the current rate environment, as discussed above, a reliable, hard-edged reset option might be an important factor in deciding whether to apply at all.

An Amendment to Attract Applicants?

The first resets were done in a reactive context — a pandemic caused rates to fall dramatically, which made powerful water agencies press for an adjustment to their loan commitments, which in turn prompted the program to re-execute their loans at the lower rate.

This time, the perspective on resets can be forward-looking. Long-term UST rates are high and may remain so, but there are plenty of reasons to think they may fall dramatically in the next few years. And many WIFIA loan commitments executed in the meantime will again be underwater, as in 2020. Potential demand is entirely predictable.

Of course, the WIFIA program and its stakeholders can simply wait for events to unfold. If rates fall, affected borrowers can be expected to request a reset, and the program can decide at the time whether the 2020 precedents apply. As described above, applicants for whom a WIFIA loan is a primary financing source will probably find such a passive approach acceptable enough.

But potential applicants that see WIFIA’s interest rate option features as the primary reason to apply may have a very different view. In current conditions, a reliable and relatively unlimited rate reset might the deciding factor in an application. If the reset feature were made more certain, both in terms of availability and specific limitations, an increased number of WIFIA loan applications would presumably result. This is especially true in light of WIFIA’s less-than-compelling current story relative to tax-exempt debt, as discussed here and here.

It’s easy enough to make the reset a statutory provision like the rate lock by a short amendment. That would give the feature a high level of certainty, enough for measurable option value in any case. The draft language at the top of this post is on the hard-edged side, but other versions could work too.

Bigger Questions

This scenario raises bigger questions that in theory ought to be addressed — does WIFIA want the type of options-focused applicant described above? That plans to build the project anyway and is just using the program as a source of financial subsidization? Where there’s actually no additionality with regard to US water infrastructure? Is this what the program is for?

In practice of course, none of these questions matter because no one will even want to admit that they’re worth asking. Any federal program wants more qualified applicants adding to their track record, and WIFIA is no different. Policymakers have no reason to disturb a narrative that appears to be working. And WIFIA stakeholders — especially options-focused potential borrowers — will be happy enough to see expanded capabilities, and policy details aren’t their concern.

There is one area where the questions matter in a practical way, however — predicting the future growth trajectory of federal infrastructure loan programs. Will their actual additionality be primarily in connection with real-world infrastructure? Or sophisticated and largely off-budget financial subsidies? How things develop for WIFIA’s reset going forward might shed some especially interesting light on that

_____________________________________________________________________________________________

Notes

[1] There is perennial discussion about reversing or softening these restrictions, but in light of current fiscal constraints and bitter spending battles, I’m pretty sure that anyone planning a major infrastructure financing will be assuming that they’ll remain in place for the foreseeable future.

[2] Apart from related posts here, this 2019 presentation, Rate Resets for Out-of-the-Money Loan Commitments, and a 2020 WFM article Resetting the Mission for WIFIA, cover the ground in some depth.

[3] In 2021, the TIFIA program also completed a reset. This was perhaps but not necessarily inspired by WIFIA’s resets in 2020.

DAM-SAFETY-PROJECTS-WITH-A-USEFUL-LIFE-OF-MORE-THAN-35-YEARS

As outlined in a previous post, a 55-year post-completion loan term might be an especially useful feature for CWIFP’s initial implementation. This post expands on the idea that limiting the scope of an amendment to extend WIFIA’s maximum may be critical to its chances.

Competing for High Quality Applications

The primary reason that the WIFIA program was surprisingly successful out of the gate was that very creditworthy entities submitted high-quality applications for low-risk projects. Applications like that get through the federal transaction processes and oversight bureaucracy with relative efficiency, quickly establishing an experience base of what works and a track record of reliably successful transaction completion. That kind of successful launch is self-reinforcing, internally by continually improving processing efficiency and externally by attracting further high-quality applications.

Contrast WIFIA’s story to that of TIFIA, a program that started with applications from complex and risky project financings. Those kinds of deals are hard enough for the private sector, but rough material indeed to feed into easily jammed federal machinery. And it showed in the program’s results and reputation.

However, there is one problem with high-quality applicants: they have very cost-effective financing alternatives in the tax-exempt bond market. Back in 2017, when WIFIA was starting up, a WIFIA loan with a 35-year post-completion term was competitive with 30-year muni high-grade water revenue muni bonds, primarily because the loan’s rate lock avoided negative arbitrage costs. That’s not the case in current market conditions, as outlined in the prior post.

A Quiet Veto

A 55-year loan term would dramatically improve the numbers and be a game changer for WIFIA and CWIFP loans. Unfortunately, the municipal bond industry knows that, too. Their lobby will have a quiet word with the Decision Makers Who Matter, and the 55-year term will be quietly dropped, as it has been when proposed over the past several years.

Wait…a federally subsidized debt market that has an effective monopoly on US public infrastructure finance due to that subsidy is acting behind-the-scenes to protect said monopoly by curtailing the capability of another federally subsidized source of infrastructure finance, one that incidentally utilizes genuine federal comparative advantages in lending and costs the taxpayers less? Isn’t that…rent-seeking? Yes, I’m afraid it is. And?

A Limited — and Realistic — Approach

Back in the real world, a 55-year term that can apply to all qualifying WIFIA projects (as HR 5664 and past amendments have proposed) will likely be a non-starter because the scope will include many municipal water projects that would otherwise be financed with bonds. But if the scope was limited to specific asset classes that aren’t part of the muni market’s bread-and-butter, then relative indifference, if not leniency, might be shown. The chances of that are improved if it can be shown that WIFIA loans to the asset class are likely to enable projects that wouldn’t have happened otherwise, providing the bond market (or at least its PAB segment) a new possible opportunity to get some of the non-WIFIA 51% share of project capitalization. I’d guess that similar arguments were critical in getting a 75-year term for TIFIA’s P3s and other tough transportation project financings.

It seems to me that dam safety projects are that kind of asset class, at least in terms of relative infrequency and unimportance to the muni market. And that’s the class CWIFP must start with in any case, not just because of the specific funding the program has received for dam safety projects, but due to the draconian strictures of the current FCRA Criteria, which block pretty much everything else that Congress intended CWIFP to do.

A successful start is important for any enterprise, but especially for a government lending program. A lot of long-term aspirations can be built on near-term results. So, with the real-world binding constraints and short-term goals in mind, I think there’s a compelling case to limit the current 55-year term amendment to dam safety projects for which CWIFP has funding. The operative language might look something like the draft at the top of this post.

At the end of a prior post, I noted that the authors of the current Criteria ought to explain why the ‘or assets’ was omitted from the conclusion of the Background section. Or, more exactly in the context of an apparently smoking gun, to provide an alternative explanation to the obvious one, which is that the omission arbitrarily makes otherwise eligible non-federal cost shares in federally involved projects ineligible for WIFIA financing, and that’s the result they wanted.

Well, it’s only fair that the authors be given a chance to explain their side. Below is an email sent yesterday to the OMB contact noted in the Criteria’s Federal Register publication, cc’d to relevant published contacts at GAO and CBO. Naturally, I’m not expecting any reply, but if there is one, I’ll post that too.

Email-to-OMB-re-omission-092223-InRecap

Yesterday, HR 8127 was essentially reintroduced in this Congress as HR 5664. There are a few minor changes, but the Section 7 FCRA amendment language remains the same. As discussed in previous posts, I have some reservations about this approach, not the least of which is that CBO will presumably apply the same scoring to the same language that they saw before. But obviously I don’t know all the political dynamics here and they, not technical FCRA matters, that will determine the outcome. So, the original approach remains effectively Plan A.

If it doesn’t work, perhaps the New Approach outlined recently can serve as Plan B.

But what if no FCRA amendment in any form is included in legislation that’s likely to be enacted this year? Again, I’m in no position to predict the odds of this political outcome, but I’d guess it’s far from negligible. Game over for another year?

Perhaps not necessarily. If things look like they’re going south for Plan A and B amendments, here’s a Plan C that doesn’t even require an amendment, just another Congressional directive. The core of the FCRA non-federal issue is not FCRA or WIFIA law, but the way the current Criteria require it to be interpreted. Yes, the right statutory amendment would settle the issue for good, but in the meantime it’s important to note that the current Criteria aren’t themselves statutory (as much as they have pretenses to be — looking at you, footnote 4) and what one Congressional Directive can create, another presumably can modify.

There’s nothing wrong with FCRA criteria per se, even if they don’t appear to be necessary in a world of honest and intelligent loan applicants. It’s just that the current Criteria are an unholy mess. With suitable revisions, even while leaving in place a lot of the blather about ‘federal projects’ for appearances’ sake, FCRA Criteria v2.0 could include a clear path to WIFIA eligibility for non-federal cost share assets in a federally involved project. The substantive criteria could be essentially the same as proposed in Plan A or B amendments, perhaps artfully camouflaged if necessary.

The new directive is required to re-open the ring for the correct parties — this time, CWIFP as well as OMB and WIFIA — and to precisely clarify the objective for the updates. Otherwise, it can look a lot like the original Directive. Perhaps something like this, changes in bold:

Provided further, That the Administrator, together with the Secretary of the Army and the Director of the Office of Management and Budget,, shall jointly develop updated criteria for Section 3908 (b)(8) eligibility for direct loans and loan guarantees authorized by the Water Infrastructure Finance and Innovation Act of 2014 that limit Federal credit participation in financing a non-Federal cost share in a project that has federal involvement consistent with the requirements for the budgetary treatment provided for in section 504 of the Federal Credit Reform Act of 1990 and based on all relevant recommendations contained in the 1967 Report of the President’s Commission on Budget Concepts; and the Administrator, the Director, and the Secretary, shall, not later than [90] days after the date of enactment of this Act, publish such criteria in the Federal Register.

As with the original Directive, presumably a new directive can be added into the WIFIA “Program Account” section of FY2024’s omnibus spending bill right up to the last minute, right?

Of course, even if the ring is re-opened with the right parties and clear rules, there’ll still be fight. But I’m pretty confident of a positive outcome in that forum. The Pro-Eligibility side will be prepared this time with clear and correct FCRA law and principles, while the Pro-Criteria side will be defending a baseless and embarrassing mess. And if there’s no agreement after 90 days, well, then it’s back to the amendment plan. As described at the end of the New Approach post, the Pro-Criteria side can do it the easy way or the hard way, but they’re bound to lose in the end.

The Corps’ section of the WIFIA loan program, CWIFP, has just published its first Notice of Funding Availability. It’s always great to see progress at federal infrastructure loan programs, for this one in particular.

As discussed in a prior post about CWIFP’s potential borrowers, large non-federal dams will likely be the majority of initial applicants, which is a good way to start things off because successful WIFIA precedents will smooth the way:

Direct loans to large dam projects should obviously be an important part of CWIFP’s development and policy outcomes, especially in the Program’s early phases. A lot of WIFIA experience will neatly translate to large dam loan origination and execution at CWIFP, jump-starting operations and the first closings.

But if you’re benefitting from WIFIA precedents, you’ll also get WIFIA’s challenges, including competition. Like large water agency projects, large non-federal dam projects are likely to be undertaken by substantial and highly creditworthy public-sector utilities that have plenty of cost-effective financing alternatives, especially in the tax-exempt bond market. Rates there are currently significantly below the UST curve that CWIFP lends at. Worse, the UST curve stubbornly remains very inverted, which means the usual primary benefit of a WIFIA-type loan, the avoidance of negative arbitrage during the construction phase, is pretty much negligible [1].

These conditions are reflected in the NPV of the difference between a CWIFP loan with a 35-year post-completion tenor relative to a 30-year high-grade muni bond. I’d estimate about a 1% benefit. That’s not as bad as a negative result, but you have to deduct the extra transaction costs and federal crosscutters, plus the possible execution friction with any new program, as compared to just doing another off-the-shelf muni issue with your friendly local bond underwriter.

Back in 2017, when WIFIA was getting started, things were very different, with a loan NPV benefit under the same methodology of about 9%, which is the level it more-or-less remained at until recently. Timing is everything, eh?

Things change, of course. The inverted UST yield curve should (must?) go back to normal sometime relatively soon, which will reestablish the negative arbitrage benefit. High long-term rates are likely to persist for a while, and they do improve the benefit of tax-exemption relative to low rates [2], which leads to sub-UST yields, other things being equal. But in this economic and geopolitical environment, who knows? Uncertainty is more likely to increase than not, and that increases the value of unique non-rate CWIFP loan features like flexibility and optionality. Most of all, the need for US essential infrastructure renewal and financing for it will certainly go only in one direction — up.

Even if CWIFP might have a harder row to hoe at the start than WIFIA did, the program’s longer-term prospects are of course good. Still, a successful launch is important. Given the likelihood of an initial large-dam project applicant base with serious market competition for the same deals, it makes sense to consider how CWIFP’s competitive position might be improved in the near-term.

Where that involves amending the statutes that CWIFP shares with WIFIA, I’d suggest prioritizing two that might have a chance to be included in this fall’s legislation. Both have been frequently discussed on this site:

A 55-year term — As you can see from the first column in the above chart, the NPV benefit of an extended loan term is around 6% even in the current adverse rate environment. That’s getting closer to levels that prevailed during WIFIA’s successful start. There’s no rational reason that legislators should object to something they gave to the TIFIA program in 2021, or for CBO to punitively score the change. OMB objects behind the scenes? Who knows, but maybe they can be kept busy enough with their FCRA issue.

But there’s still the competition, aka the tax-exempt bond lobby. It never surfaces publicly, but I cannot believe that they would be indifferent to the change if it applied to all WIFIA deals. Perhaps many municipal water projects have a useful life within 30 years, but not all of them. And for those projects with a long useful life, a 55-year post-completion term is a slam dunk relative to a 30-year maximum term bond. You think they’ll just watch as a 49% slice is taken away from a big part of their pie? I don’t think so — their response will be a very quiet but very firm veto expressed to the decision makers that matter most.

However, it is just possible that the lobby will be calmer about dam projects than they are about a mainstay source of water revenue bonds. Maybe they’ll listen long enough to see that a 55-year CWIFP loan in some cases will be the enabling component of a dam project’s capitalization, and they’ll get a shot at a 51% slice that wouldn’t have been there otherwise. So perhaps the near-term objective of an extended term amendment should be limited. Maybe propose that the amendment apply only those dam safety projects for which credit subsidy funding is already in place from the IIJA and last year’s appropriation bill? That’s limited enough, in size and time, but could serve the primary purpose of jumpstarting CWIFP’s applications.

Something like this, which slightly modifies amendment language that’s already been proposed:

‘‘(B) DAM SAFETY PROJECTS WITH A USEFUL LIFE OF MORE THAN 35 YEARS.
“Notwithstanding subparagraph (A), for a dam safety project with a useful life of more than 35 years (as determined by the Secretary or the Administrator, as applicable), and which is eligible for the financial assistance provided by the Consolidated Appropriations Act of 2021 and the Consolidated Appropriations Act of 2022, the final maturity date of a secured loan under this section shall be not later than the earlier of….”

The Limited Buydown — Despite its sure-fire appeal to applicants in these uncertain times and being an established precedent in other infrastructure loan programs, this one is a long shot as it hasn’t yet been included in any WIFIA amendment bill I’m aware of. But it’s worth a try, perhaps with the same limited scope described above for the 55-year amendment. Cost is a potential issue for this loan feature but actualizing it in a loan execution rate is always completely subject to program’s discretion (i.e., only if the money is available at the time). And cost doesn’t arise or is even measurable until loan executions start to happen, which is likely a year or so away in any case. The important point is that it shouldn’t cost anything in this Congress. In the meantime, applicants will see that locking in a contingent interest-rate benefit of this kind is better than not having it all, which may help build traffic.

Two potential amendments I haven’t mentioned here — a fix for the FCRA Criteria issue and a clarification and expansion of the rules for bundled projects — are of course also important for CWIFP, arguably even more than the other two for long-term growth prospects. Work on these will continue, but the priority should be on CWIFP’s near-term potential applicants. A successful launch will immensely improve the prospects for everything else.

_____________________________________________________________________________________________

Notes

[1] I’m not familiar enough with tax arbitrage rules to be certain that the negative arbitrage cost actually amounts to zero, despite the numbers based on current rates. There are tricky things about the limit like ‘lower of YTM and yield-to-first-call’. But I’m pretty sure it’s negligible, given how high UST rates within five years are.

[2] As noted in a recent post, higher absolute levels of interest rates also erode a WIFIA loan’s value relative to a tax-exempt bond with a comparable term because the tax exemption is applied to a larger amount of income. An older post describes the numbers: Subsidized Debt and Term, Interest Rates. Beyond the 30-year term in the muni market, however, uncertainty about the tax code and income will likely outweigh this advantage — hence another reason for a 55-year WIFIA term.