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A De Novo Strategy for the FDIC: Prepaid Insurance Premiums

  
  
  
  
  

The ongoing wave of bank failures related to the financial crisis continues to impact the health of the FDIC's Deposit Insurance Fund (DIF). At the end of the second quarter, the DIF balance was down to $10.4 billion. Compared to a year ago, when the DIF amounted to $45.2 billion, this is a decline of some 77 percent.

As at-risk banks continue to deteriorate, the DIF's growing loss provisions have simply outpaced accrued and collected premiums, including a special assessment that was levied on insured institutions at the end of the second quarter. Rather than demand another special assessment, the FDIC is trying a new tactic to deal with the fund's depletion: prepaid premiums.

According to an FDIC press release, the FDIC Board "has adopted a Notice of Proposed Rulemaking (NPR) that would require insured institutions to prepay their estimated quarterly risk-based assessments for the fourth quarter of 2009 and for all of 2010, 2011 and 2012." The prepayments should generate roughly $45 billion in cash, a much-needed infusion for the anemic DIF.

Numbers game

Time Magazine is calling the tactic "an accounting trick," (http://www.time.com/time/business/article/0,8599,1926877,00.html?iid=tsmodule ) but FDIC Chair Sheila Bair sees it as a necessary step in the fund's restoration. The move won't impact banks' profitability, since they won't recognize the expenses any sooner under prepayment. It will impact liquidity, but the FDIC's position is that banks have sufficient cash to absorb these prepayments.

The push for prepayments underscores the FDIC's commitment to manage through this crisis without asking the Treasury or taxpayers to foot the bill.

Assessment increase ahead

The aforementioned NPR also included an assessment increase of three basis points across the board, to be made effective on January 1, 2011.

Comments

On the surface,these DIF Insurance Prepayments should not have an 'adverse effect' on the banks due to the 'TARP Program' success. 
 
 
 
However, wouldn't it be more diplomatic to gain consensus (approval) from the Banking membership/ Community, as opposed to, craming this, almost mandate/ more-than-a-proposal, down memberships throats? 
 
 
 
Collaboration has always proven that 'inclusion' is always more effective (long-term) than 'exclusion' (comes back to haunt you).
Posted @ Thursday, October 01, 2009 12:50 PM by BEN CARTER
Amendment: 
 
 
 
 
 
 
 
In all fairness to Shelia, it should be noted that her approach (prepayment) could be that she knows, banks are not lending money.  
 
 
 
What do you think the lending trend is in banking currently? 1:20, 1:40? We know the 1:(approval rate) is close to right, unless its pure zero. What we don't know is the fluctuation point (out of how many).  
 
 
 
I will give the banks a bit of a break for a second though: 
 
 
 
 
 
Frankly, it’s not really the banks’ fault. You can’t really blame them for tightening their belts in this economy. In fact, if you dig deep enough, you’ll see this all goes back to the government pulling on the economy’s strings. 
 
 
 
 
 
Now, this statement gives my earlier response more balance. 
 
Posted @ Thursday, October 01, 2009 2:46 PM by BEN CARTER
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