The purpose of this note is threefold. First, in addition to the well-
known seasonal pattern to the eleventh-district cost-of-funds (COF), w
e document a twelve-month seasonal in the national median COF. Second,
we demonstrate that the cause of seasonality in each of these COF ser
ies is due to the maladjustment of length-of-month effects. In particu
lar, the eleventh-district COF is biased upwards in relatively short m
onths while the national median is biased downward. Third, we show tha
t the popular partial adjustment model for modeling the COF is misspec
ified.