Federal rate. The Second Circuit has held that the federal rate of post-judgment interest rather than the New York rate should be applied in a diversity case where the contract at issue contains a choice-of-law provision providing that New York law applies. The Court held that the choice-of-law provision was insufficient to establish that the parties intended that the federal rate would not apply. The decision in FCS Advisors, Inc. v. Fair Finance Co. can be found here.