- Our nation’s federal deposit insurance system is critical to depositor confidence in the banking system, to the protection of small depositors and to the funding base of community banks. A strong Deposit Insurance Fund (DIF) is important to maintaining public confidence that the FDIC has adequate resources to protect the nation’s depositors.
- ICBA strongly supported the changes to the deposit insurance assessment base as a result of the Dodd-Frank Act which are saving the community banking industry billions of dollars.
- Because of ICBA’s advocacy efforts, banks with assets of less than $10 billion were not responsible for increasing the DIF reserve ratio from 1.15 percent to 1.35 percent. As a result, these banks should receive approximately $750 million in FDIC assessment credits beginning in 2019.
- ICBA supported S. 2155 which ensures that reciprocal deposits are not considered brokered deposits under the Federal Deposit Insurance Act
Deposit insurance has been the stabilizing force of our nation’s banking system for more than 85 years. It promotes public confidence by providing safe and secure depositories for small businesses and individuals alike.
Deposit Insurance Victories
ICBA achieved several significant and long-sought deposit insurance victories in the Dodd-Frank Wall Street Reform and Consumer Protection Act. The law permanently increased deposit insurance coverage to $250,000 per depositor. The Dodd-Frank Act also provides for indemnification of banks under $10 billion in assets from any recapitalization costs associated with raising the DIF reserve ratio from 1.15 to 1.35 percent and a redefinition of the assessment base as average total consolidated assets minus average tangible equity. These changes helped create parity in the deposit insurance system by reducing community bank assessments and helping community banks offset the advantage of the largest banks in attracting deposits.
Banks Over $10 Billion Will Pay the Costs of Raising the DIF Reserve Ratio
ICBA supported the FDIC’s final rule which surcharged banks with assets over $10 billion to pay for raising the DIF reserve ratio from 1.15 percent to 1.35 percent, as required by the Dodd-Frank Act. Beginning in 2019, banks with assets less than $10 billion will receive FDIC assessment credits of approximately $750 million provided that the DIF reserve ratio is maintained at 1.38 percent.
In a victory for ICBA, Congress passed S. 2155 in 2018 which ensures that reciprocal deposits of an insured depository institution are not considered to be funds obtained by or through a deposit broker under the Federal Deposit Insurance Act. This legislation will allow reciprocal deposits to serve as a stable source of funding for community banks. Because reciprocal deposits have been wrongly classified as brokered deposits, it has been difficult for community banks to utilize them to their full potential. This new law supports local depositors while ensuring stable funding for community lending.
FDIC National Rate Caps
ICBA urges the FDIC to reconsider their methodology for calculating National Rate Caps for deposits. While these caps apply mainly to banks that are considered less than “well-capitalized,” ICBA has heard of cases where the FDIC has warned well-capitalized banks not to pay interest rates on deposits that are higher than prevailing National Rate Caps. In calculating National Rate Caps, the FDIC should include credit union interest rates on deposits as well as premiums and promotional rates on deposits and rates paid on non-standard certificates of deposits. Furthermore, interest rates paid by large banks should not be overrepresented in the calculation. Unreasonably low caps that do not represent actual rates paid in the market disadvantage community banks seeking deposits to support lending.
Staff Contact: Chris Cole