BPI Comments on FDIC Assessments Notice of Proposed Rulemaking

Ladies and Gentlemen:

The Bank Policy Institute^[1] submits these comments in response to the notice of proposed rulemaking issued by the Federal Deposit Insurance Corporation entitled Assessments Thresholds, Rate Schedules, and Adjustments.^[2] We welcome the proposed reduction in deposit insurance assessment rate schedules, which is warranted in light of the overall position and trajectory of the Deposit Insurance Fund. We also support the FDIC's ongoing efforts to ensure that it has access to accurate and relevant information about a failing institution in a timely manner to facilitate the resolution process. However, the proposed resolution readiness adjustment ("RRA") is flawed in several critical respects and should not be adopted as proposed.

The current deposit insurance assessment schedules were adopted effective January 2023 as part of the FDIC's DIF Restoration Plan, which was put in place after the reserve ratio fell below its statutory minimum of 1.35 percent in the second quarter of 2020 as a result of a temporary increase in the aggregate outstanding amount of insured deposits during the COVID-19 pandemic.^[3] The 2023 adjustments included a 2-basis-point across-the-board increase to the initial base assessment rate ("IBAR") schedules that would be applicable during the period when the reserve ratio was less than 2 percent. The progressively lower assessment rates which were already slated to come into effect if the reserve ratio were to reach 2 percent or 2.5 percent were left unchanged.

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[1] The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. BPI produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] FDIC, Notice of Proposed Rulemaking, Assessments Thresholds, Rate Schedules, and Adjustments, 91 Fed. Reg. 39794 (June 30, 2026).

[3] FDIC, Assessments, Revised Deposit Insurance Assessment Rates, 87 Fed. Reg. 64314 (Oct. 24, 2022).