Letter to FDIC on Special Assessment Pursuant to the Systemic Risk Determination

Dear Mr. Sheesley:

The American Bankers Association appreciates the opportunity to comment on the FDIC's proposed rule (the Proposal) that would impose a special assessment to recover losses to the Deposit Insurance Fund (DIF) in connection with the systemic risk determination related to the closures of Silicon Valley Bank and Signature Bank. Under the proposal, the FDIC would assess 12.5 basis points, over eight quarterly periods, against an institution's estimated uninsured deposits as of December 31, 2022. The FDIC proposes to adjust the assessment to exclude the first $5 billion in estimated uninsured deposits. The first quarterly assessment period beginning on January 1, 2024.

ABA represents banks of all sizes, from the smallest community banks to midsize and regional banks and the largest globally active institutions. Each of these cohorts plays a unique and valuable role in their communities and in the U.S. banking system, which lies at the heart of the U.S. economy. Given this diversity, there is a broad range of viewpoints on the Proposal among our membership, since every institution will be affected differently. As we have stated repeatedly and publicly, ABA supports that the FDIC proposes to carve out community banks with under $5 billion in uninsured deposits. We also urge the FDIC to continue to do everything possible to reduce the size of the assessment further through prudent asset sales and other steps to limit the financial impact on institutions scoped into the assessment.

Because any changes to the Proposal regarding the assessment base will necessarily redistribute the obligation among members subject to the assessment, we are neutral on the proposed assessment base other than to encourage the FDIC to take into consideration the comments of each and every institution that chooses to share perspectives on the Proposal. Instead, we offer technical recommendations as well as suggest improvements for future special assessments and related actions. As a threshold matter, we do not believe that the proposed special assessment should set a precedent for future special assessments. ABA recommends that the FDIC bolster its processes to ensure future systemic risk exceptions, resolutions and special assessments collectively are fair, evidence-based, transparent and predictable.

Download the comment letter to read the full text.