FDIC proposes assessment and resolution submission changes for insured depository institutions
On June 25, the FDIC Board approved a proposed rule to revise deposit insurance assessment regulations for all FDIC-insured institutions and separately approved a proposed rule to amend resolution submission requirements for covered insured depository institutions (IDIs). These proposals follow remarks from FDIC Chairman Travis Hill previewing assessment and resolution-planning changes (previously covered by InfoBytes here). Comments on both proposals are due August 31.
The proposal related to deposit insurance assessments would raise the asset threshold used to determine whether an institution is considered small or large for assessment purposes from $10 billion to $30 billion and implement further adjustments to the threshold every four years for inflation, lower initial base deposit insurance assessment rate schedules by 2 basis points for small institutions and 1 basis point for large and highly complex institutions, and provide a downward resolution readiness adjustment for large and highly complex institutions.
The FDIC stated that the threshold update and future indexing of the threshold are intended to preserve, in real terms, the assessment methodology threshold used to define small and large institutions, while the rate changes reflect recent growth in the Deposit Insurance Fund and reserve ratio. The resolution readiness adjustment component of the proposal would include a 0.5 basis-point reduction for passing virtual data room testing and 0.5 basis-point reduction for providing prescribed data access. According to the FDIC, the ability to quickly establish a data room and provide advanced access to certain systems could reduce losses to the Deposit Insurance Fund if an institution fails.
Additionally, the proposal related to resolution submissions would raise the asset threshold for covered IDIs from $50 billion to $100 billion, automatically adjust the threshold over time based on an indexing methodology, streamline filing requirements to focus on information that the FDIC determined would most directly support its readiness to resolve an institution in a cost-effective manner, and move all covered IDIs to a three-year filing cycle. The proposal also would eliminate the FDIC’s credibility assessment of IDI submissions, expectations for capabilities testing, interim supplements, the public section requirement, and board approval requirements under the current rule. The Board approved an exemption from filing requirements in October 2026 and in 2027 for all IDIs subject to the current rule to facilitate the ongoing rulemaking process.