Notice of Proposed Rulemaking to Amend the Rule Requiring Resolution Submissions by Covered Insured Depository Institutions
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FDIC Financial Institution Letters › Notice of Proposed Rulemaking to Amend the Rule Requiring Resolution Submissions by Covered Insured Depository Institutions
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39794
Federal Register / Vol. 91, No. 124 / Tuesday, June 30, 2026 / Proposed Rules
1 See 12 U.S.C. 1817(b).
2 As used in this notice of proposed rulemaking,
the term ‘‘bank’’ is synonymous with the term
‘‘insured depository institution’’ as it is used in
section 3(c)(2) of the FDI Act, 12 U.S.C. 1813(c)(2).
As used in this notice, the term ‘‘small bank’’ is
synonymous with the term ‘‘small institution,’’ as
defined in 12 CFR 327.8(e), or using the proposed
revised definition. Additionally, as used in this
notice, the terms ‘‘large bank’’ and ‘‘highly complex
institution’’ refer to an insured depository
institution that meets the definition of a large
institution or highly complex institution as defined
in 12 CFR 327.8(f) and (g), or using the proposed
revised definitions of those terms.
3 12 CFR part 327.
4 See 12 U.S.C. 1817(b)(1)(C).
5 See 12 U.S.C. 1817(b)(1)(D).
6 See 12 CFR 327.16(a) and (b).
7 See 12 CFR 327.3(b)(1).
8 See 12 CFR 327.5(a).
9 See 12 CFR 327.16.
10 Banks that elect to use the community bank
leverage ratio framework are also considered small
institutions, even if those banks would otherwise
meet the definition of a large institution. See 12
CFR 327.8(e)(3). An insured branch of a foreign
bank is not considered a large institution. See 12
CFR 327.8(f).
A small institution is reclassified as a large
institution beginning in the fourth consecutive
quarter that it reports assets of $10 billion or more
on the Call Report. Similarly, a large institution is
reclassified as a small institution beginning in the
fourth consecutive quarter that it reports assets of
less than $10 billion on the Call Report.
FEDERAL DEPOSIT INSURANCE
CORPORATION
12 CFR Part 327
RIN 3064–AG27
Assessments Thresholds, Rate
Schedules, and Adjustments
AGENCY: Federal Deposit Insurance
Corporation.
ACTION: Notice of proposed rulemaking
milarly, a large institution is
reclassified as a small institution beginning in the
fourth consecutive quarter that it reports assets of
less than $10 billion on the Call Report.
FEDERAL DEPOSIT INSURANCE
CORPORATION
12 CFR Part 327
RIN 3064–AG27
Assessments Thresholds, Rate
Schedules, and Adjustments
AGENCY: Federal Deposit Insurance
Corporation.
ACTION: Notice of proposed rulemaking.
SUMMARY: The Federal Deposit
Insurance Corporation (FDIC) invites
public comment on a proposed rule that
would amend the assessment
regulations in 12 CFR part 327 to:
update the $10 billion asset threshold in
the definitions of small and large
institutions to $30 billion and adjust the
threshold every four years to reflect
inflation, pursuant to a pre-determined
indexing methodology; decrease initial
base deposit insurance assessment rate
schedules by 2 basis points for small
institutions and by 1 basis point for
large and highly complex institutions;
provide a downward resolution
readiness adjustment to assessment
rates for large and highly complex
institutions, including 0.5 basis points
for passing virtual data room testing and
0.5 basis points for providing prescribed
data access; and remove obsolete
provisions.
DATES: Comments must be received no
later than August 31, 2026.
ADDRESSES: You may submit comments
on the notice of proposed rulemaking,
identified by RIN 3064–AG27 using any
of the following methods:
• FDIC website: https://www.fdic.gov/
federal-register-publications. Follow the
instructions for submitting comments
on the agency website.
• Email: Comments@fdic.gov. Include
RIN 3064–AG27 on the subject line of
the message.
• Mail: Jennifer M. Jones, Deputy
Executive Secretary, Attention:
Comments—RIN 3064–AG27, Federal
Deposit Insurance Corporation, 550 17th
Street NW, Washington, DC 20429
website: https://www.fdic.gov/
federal-register-publications. Follow the
instructions for submitting comments
on the agency website.
• Email: Comments@fdic.gov. Include
RIN 3064–AG27 on the subject line of
the message.
• Mail: Jennifer M. Jones, Deputy
Executive Secretary, Attention:
Comments—RIN 3064–AG27, Federal
Deposit Insurance Corporation, 550 17th
Street NW, Washington, DC 20429.
• Hand Delivery to FDIC: Comments
may be hand-delivered to the guard
station at the rear of the 550 17th Street
NW building (located on F Street NW)
on business days between 7 a.m. and 5
p.m.
• Public Inspection: Comments
received, including any personal
information provided, may be posted
without change to https://www.fdic.gov/
federal-register-publications.
Commenters should submit only
information that the commenter wishes
to make available publicly. The FDIC
may review, redact, or refrain from
posting all or any portion of any
comment that it may deem to be
inappropriate for publication, such as
irrelevant or obscene material. The FDIC
may post only a single representative
example of identical or substantially
identical comments, and in such cases
will generally identify the number of
identical or substantially identical
comments represented by the posted
example. All comments that have been
redacted, as well as those that have not
been posted, that contain comments on
the merits of the proposed rule will be
retained in the public comment file and
will be considered as required under all
applicable laws. All comments may be
accessible under the Freedom of
Information Act.
This proposal, all comments received,
and a summary of not more than 100
words of the proposed rule pursuant to
the Providing Accountability Through
Transparency Act of 2023 are available
at https://www.fdic.gov/federal-register-
publications
ic comment file and
will be considered as required under all
applicable laws. All comments may be
accessible under the Freedom of
Information Act.
This proposal, all comments received,
and a summary of not more than 100
words of the proposed rule pursuant to
the Providing Accountability Through
Transparency Act of 2023 are available
at https://www.fdic.gov/federal-register-
publications.
FOR FURTHER INFORMATION CONTACT:
Division of Insurance and Research:
Daniel Hoople, Associate Director,
Financial Risk Management Branch,
202–898–3835, dhoople@fdic.gov;
Division of Complex Institution
Supervision and Resolution: Ryan
Tetrick, Deputy Director, Resolution
Readiness Branch, 202–898–7028,
rtetrick@fdic.gov; Sean Healey, Acting
Associate Director, Policy Analysis,
Systemic Risk Branch, 202–898–7049,
seahealey@fdic.gov; Patrick Bittner,
Senior Policy Specialist, Policy
Analysis, Systemic Risk Branch, 202–
898–3550, pabittner@fdic.gov; Division
of Resolutions and Receiverships:
Shivali Nangia, Deputy Director,
Receivership Operations, 972–761–
2945, snangia@fdic.gov; Catherine
Linhart, Assistant Director, Closing
Operations and Data, 571–242–5368,
clinhart@fdic.gov; Legal Division: Ryan
McCarthy, Counsel, 202–898–7301,
rymccarthy@fdic.gov; Jacques Schillaci,
Counsel, 202–898–7298, jschillaci@
fdic.gov; Dena Kessler, Counsel, 202–
898–3833, dkessler@fdic.gov.
SUPPLEMENTARY INFORMATION:
I. Background
A
ship Operations, 972–761–
2945, snangia@fdic.gov; Catherine
Linhart, Assistant Director, Closing
Operations and Data, 571–242–5368,
clinhart@fdic.gov; Legal Division: Ryan
McCarthy, Counsel, 202–898–7301,
rymccarthy@fdic.gov; Jacques Schillaci,
Counsel, 202–898–7298, jschillaci@
fdic.gov; Dena Kessler, Counsel, 202–
898–3833, dkessler@fdic.gov.
SUPPLEMENTARY INFORMATION:
I. Background
A. Legal Framework
Pursuant to section 7 of the Federal
Deposit Insurance (FDI) Act,1 the FDIC
has established a risk-based assessment
system for calculating and charging all
insured depository institutions (IDIs) 2 a
quarterly assessment for deposit
insurance.3 The FDI Act defines a risk-
based assessment system as a system for
calculating a depository institution’s
assessment based on: (1) the probability
that the Deposit Insurance Fund (DIF)
will incur a loss with respect to the
institution; (2) the likely amount of any
such loss; and (3) the revenue needs of
the DIF.4 The FDIC has established
separate risk-based assessment systems 5
and calculates a bank’s assessment rate
using different methods for small, large,
and highly-complex institutions.6
Under the assessment regulations, the
amount of an IDI’s deposit insurance
assessment is equal to its assessment
base multiplied by its risk-based
assessment rate.7 Generally, an IDI’s
assessment base equals its average
consolidated total assets minus its
average tangible equity.8 An IDI’s risk-
based assessment rate is determined
each quarter based on supervisory
ratings and information collected on the
Consolidated Reports of Condition and
Income (Call Report) or the Report of
Assets and Liabilities of U.S
plied by its risk-based
assessment rate.7 Generally, an IDI’s
assessment base equals its average
consolidated total assets minus its
average tangible equity.8 An IDI’s risk-
based assessment rate is determined
each quarter based on supervisory
ratings and information collected on the
Consolidated Reports of Condition and
Income (Call Report) or the Report of
Assets and Liabilities of U.S. Branches
and Agencies of Foreign Banks (FFIEC
002), as appropriate.9
The assessment regulations generally
define a small institution as an IDI with
total assets of less than $10 billion, as
reported on the Call Report.10
Assessment rates for established small
banks (i.e., small banks that have been
federally insured for at least five years)
are calculated based on seven financial
ratios and a weighted average of
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Federal Register / Vol. 91, No. 124 / Tuesday, June 30, 2026 / Proposed Rules
11 Bank examiners review and evaluate an
institution’s condition using the Uniform Financial
Institutions Rating System, also known as CAMELS
(Capital, Asset quality, Management, Earnings,
Liquidity, and Sensitivity to market risk). CAMELS
ratings are scored on a scale of ‘‘1’’ (best) to ‘‘5’’
(worst). Examiners assign a rating for each CAMELS
component and an overall Composite rating.
12 See 12 CFR 327.16(a); see also 81 FR 32180
(May 20, 2016).
13 See 12 CFR 327.8(f).
14 See 12 CFR 327.8(g).
15 See 12 CFR 327.16(b)(1) and (2); see also 76 FR
10672 (Feb. 25, 2011) and 77 FR 66000 (Oct. 31,
2012).
16 See 12 CFR 327.16(e).
17 Id. See also 74 FR 9525 (Mar. 4, 2009) and 76
FR 10672, 10680 (Feb. 25, 2011). The unsecured
debt adjustment applies to all institutions except
new institutions and insured branches of foreign
banks.
18 See 12 CFR 327.16(e)(3)
(f).
14 See 12 CFR 327.8(g).
15 See 12 CFR 327.16(b)(1) and (2); see also 76 FR
10672 (Feb. 25, 2011) and 77 FR 66000 (Oct. 31,
2012).
16 See 12 CFR 327.16(e).
17 Id. See also 74 FR 9525 (Mar. 4, 2009) and 76
FR 10672, 10680 (Feb. 25, 2011). The unsecured
debt adjustment applies to all institutions except
new institutions and insured branches of foreign
banks.
18 See 12 CFR 327.16(e)(3).
19 See 12 CFR 327.16(b)(3); see also Assessment
Rate Adjustment Guidelines for Large and Highly
Complex Institutions, 76 FR 57992 (Sept. 19, 2011).
20 See 12 U.S.C. 1817 and 1819 (Tenth).
21 See 12 CFR 327.8(e) and (f).
22 See Adjusting and Indexing Certain Regulatory
Thresholds, 90 FR 55789 (Dec. 4, 2025). Any
references to inflation in this proposal refer to
inflation as measured under the consumer price
index for urban wage earners and clerical workers
(CPI–W), unless specifically noted otherwise.
23 Progressively lower assessment rate schedules
will take effect when the reserve ratio exceeds 2
percent and 2.5 percent, and the FDIC did not
modify those schedules when increasing rates in
2023. See 12 CFR 327.10(c) and (d). See also 87 FR
64314 (Oct. 24, 2022).
supervisory CAMELS 11 components
that are statistically significant in
predicting the probability of an
institution’s failure over a three-year
horizon.12 The CAMELS composite
rating is used to determine the
minimum and maximum assessment
rate for a small institution
modify those schedules when increasing rates in
2023. See 12 CFR 327.10(c) and (d). See also 87 FR
64314 (Oct. 24, 2022).
supervisory CAMELS 11 components
that are statistically significant in
predicting the probability of an
institution’s failure over a three-year
horizon.12 The CAMELS composite
rating is used to determine the
minimum and maximum assessment
rate for a small institution.
For purposes of deposit insurance
assessments, a large institution is
generally defined as an IDI that reports
assets of $10 billion or more on its Call
Report for four consecutive quarters that
does not meet the definition of a highly
complex institution.13 A highly
complex institution is generally defined
as an institution that has $50 billion or
more in total assets and is controlled by
a parent holding company that has $500
billion or more in total assets, or is a
processing bank or trust company.14
Assessment rates for large banks and
highly complex institutions are
calculated using a scorecard approach
based on CAMELS component ratings
and certain forward-looking financial
measures to assess the risk that the
institution poses to the DIF. One version
of the scorecard applies to most large
banks and another to highly complex
institutions.15
As part of the risk-based assessment
system, institutions are subject to
certain adjustments to their assessment
rates for factors that can increase or
reduce loss to the DIF in the event the
bank fails.16 For example, the unsecured
debt adjustment is a downward
adjustment intended to better account
for certain liabilities that can reduce the
loss to the DIF in the event of failure.17
The brokered deposit adjustment is an
upward adjustment.18 In addition, the
FDIC may adjust a large or highly
complex institution’s total score, which
is used in the calculation of its
assessment rate, to consider
idiosyncratic or other relevant risk
factors not reflected in the appropriate
scorecard.19
B
certain liabilities that can reduce the
loss to the DIF in the event of failure.17
The brokered deposit adjustment is an
upward adjustment.18 In addition, the
FDIC may adjust a large or highly
complex institution’s total score, which
is used in the calculation of its
assessment rate, to consider
idiosyncratic or other relevant risk
factors not reflected in the appropriate
scorecard.19
B. Overview of the Proposal and Policy
Objectives
The FDIC, under its general
rulemaking authority in section 9 of the
FDI Act, and its specific authority under
section 7 of the FDI Act to set
assessments and establish a risk-based
assessment system,20 is proposing to
make several revisions to the deposit
insurance assessment regulations (the
proposal), including to: (1) update the
$10 billion asset threshold in the
definitions of small and large
institutions to $30 billion and adjust the
threshold every four years to reflect
inflation, pursuant to a pre-determined
indexing methodology; (2) decrease
initial base assessment rate schedules by
2 basis points for all small institutions,
including new small institutions and
insured branches of foreign banks, and
by 1 basis point for large and highly
complex institutions; and (3) provide a
downward resolution readiness
adjustment (RRA) to assessment rates
for large and highly complex
institutions electing to participate,
including 0.5 basis points for passing
voluntary virtual data room (VDR)
testing and 0.5 basis points for
providing prescribed data access. In
addition, the FDIC is proposing to make
certain technical amendments to the
assessment regulations to remove
obsolete provisions.
The FDIC continues to explore
opportunities for updating the
assessment regulations, including
adjusting other thresholds and possible
updates and improvements to the
scorecard methodology applied to
calculate assessments for large banks
and highly complex institutions
the FDIC is proposing to make
certain technical amendments to the
assessment regulations to remove
obsolete provisions.
The FDIC continues to explore
opportunities for updating the
assessment regulations, including
adjusting other thresholds and possible
updates and improvements to the
scorecard methodology applied to
calculate assessments for large banks
and highly complex institutions. Any
future updates would be made through
a separate notice and comment
rulemaking.
1. Proposed Updates to Small and Large
Institution Definitions
The FDIC is proposing to update the
definitions of small and large
institutions that determine which risk-
based deposit insurance assessment
methodology is applied to calculate an
institution’s deposit insurance
assessment rate.21 Specifically, the FDIC
is proposing to update the asset-based
threshold (the assessment methodology
threshold) used to define small and
large institutions from $10 billion to $30
billion and to adjust the threshold every
four years to reflect inflation, pursuant
to a pre-determined indexing
methodology which would generally
align with the methodology used to
adjust certain other thresholds within
FDIC regulations.22
The primary objective of the proposed
update and future indexing is to provide
for a more durable deposit insurance
assessment framework by preserving, in
real terms, the assessment methodology
threshold used to define small and large
institutions. The inflation adjustment
would also preserve the FDIC’s ability to
apply different assessment
methodologies based on size that are
more appropriate to banks’ risk profiles
and risk exposure to the DIF.
2. Proposed Revisions to Assessment
Rates
The FDIC is also proposing revisions
to deposit insurance assessment rate
schedules
ology
threshold used to define small and large
institutions. The inflation adjustment
would also preserve the FDIC’s ability to
apply different assessment
methodologies based on size that are
more appropriate to banks’ risk profiles
and risk exposure to the DIF.
2. Proposed Revisions to Assessment
Rates
The FDIC is also proposing revisions
to deposit insurance assessment rate
schedules. First, the proposal would
decrease initial base deposit insurance
assessment rate schedules uniformly by
2 basis points for IDIs that meet the
proposed definition of a small
institution, and by 1 basis point for IDIs
that meet the proposed definition of a
large institution or that are highly
complex institutions. The proposed
reductions would only apply to initial
base assessment rate schedules
applicable while the reserve ratio is less
than 2 percent.23
3. The Resolution Readiness Adjustment
The proposed rule would amend the
risk-based assessment system to include
a downward adjustment, the RRA, of up
to 1 basis point to initial base
assessment rates if a large or highly
complex institution elects to (1) submit
to testing of the institution’s ability to
populate a VDR with information that
could be used to market a bank in the
event of its failure; and/or (2) provide
the FDIC access to an institution’s
service provider(s) and/or internal
systems to obtain detailed bank data
needed to manage and market the bank
in receivership. The RRA would be
applied to a large or highly complex
institution’s assessment rate in
recognition of the expected reduction in
losses to the DIF in the event of the
failure of a bank that successfully
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market the bank
in receivership. The RRA would be
applied to a large or highly complex
institution’s assessment rate in
recognition of the expected reduction in
losses to the DIF in the event of the
failure of a bank that successfully
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Federal Register / Vol. 91, No. 124 / Tuesday, June 30, 2026 / Proposed Rules
24 The FDI Act requires the FDIC to establish a
risk-based assessment system for calculating an
IDI’s assessment based on the probability that the
DIF will incur a loss with respect to that IDI and
the likely amount of any such loss, among other
factors. See 12 U.S.C. 1817(b)(1)(C).
25 See supra fn 23.
26 See 12 CFR 327.8(e), (f), and (g).
27 Generally, an established institution is one that
has been federally insured for at least five years. See
12 CFR 327.8(k).
28 See supra fn 10.
29 See 71 FR 69270, 69281 (Nov. 30, 2006).
30 See 76 FR 57992 (Sept. 19, 2011).
completes the VDR testing exercise and/
or provides the prescribed data access.24
The RRA would be applied to a bank’s
initial base assessment rate prior to
application of any other applicable
adjustments to initial base assessment
rates. Under the current regulations, the
minimum initial base assessment rate
applied to large and highly complex
institutions becomes progressively
lower when the reserve ratio reaches 2
percent and 2.5 percent. Under the
proposal, the minimum initial base
assessment rates applied to large and
highly complex institutions would still
become progressively lower, but the
decrease would be smaller in order to
incorporate the RRA
minimum initial base assessment rate
applied to large and highly complex
institutions becomes progressively
lower when the reserve ratio reaches 2
percent and 2.5 percent. Under the
proposal, the minimum initial base
assessment rates applied to large and
highly complex institutions would still
become progressively lower, but the
decrease would be smaller in order to
incorporate the RRA.
Under the revised schedules, a large
or highly complex institution at the
minimum initial base assessment rate
that also earns the full 1 basis point
RRA would be eligible to receive the
same maximum unsecured debt
adjustment as it would under the rate
schedules applied in the current
regulation after the reserve ratio reaches
2 percent. In addition, under the
proposed rate schedules, the minimum
assessment rate after application of all
adjustments would be the same for large
and highly complex institutions and for
small banks, which is equal to the
minimum assessment rates applied
prior to the increase implemented in
2023.25
4. Technical Amendments To Remove
Obsolete Content
The FDIC is also proposing technical
amendments to its regulations governing
deposit insurance assessments to
remove obsolete provisions that are no
longer applicable and have not been
applicable to any IDI for at least three
years.
II. Updating Definitions of Small and
Large Institutions
A. Background
The FDIC is proposing to amend the
definitions of small and large
institutions in the assessment
regulations. Under the assessment
regulations, the definitions of small,
large, and highly complex institutions
determine which risk-based deposit
insurance assessments methodology is
applied when calculating an
institution’s deposit insurance
assessment rate.26
The current definitions of small and
large institutions, first adopted in 2006,
use certain static, dollar-based
thresholds, which have not been
updated in twenty years
ons, the definitions of small,
large, and highly complex institutions
determine which risk-based deposit
insurance assessments methodology is
applied when calculating an
institution’s deposit insurance
assessment rate.26
The current definitions of small and
large institutions, first adopted in 2006,
use certain static, dollar-based
thresholds, which have not been
updated in twenty years. Adjusting
these thresholds on a consistent
schedule would mitigate the risk that
the deposit insurance assessment
system becomes less effective at
differentiating risk and more
burdensome on smaller institutions due
solely to inflation rather than
meaningful changes in an institution’s
size, risk profile, or level of complexity.
Under the proposal, the dollar-based
asset threshold used to define small and
large institutions would be updated and
adjusted in the future to reflect
inflation, pursuant to a pre-determined
indexing methodology. The primary
objective of this component of the
proposal is to provide for a more
durable deposit insurance assessment
framework by preserving, in real terms,
the threshold used to define small and
large institutions. The inflation
adjustment, in combination with the
proposed threshold and definition
updates, also would preserve the FDIC’s
ability to apply different assessment
methodologies based on size and
engagement in certain activities that are
more appropriate to banks’ risk profiles
and risk exposure to the DIF.
In the absence of these ongoing
threshold adjustments, institutions
would also become subject to additional
assessment-related reporting
requirements as they grow above the
threshold. This additional reporting
burden may be justified in cases where
asset growth reflects changes to actual
size, risk profile, and complexity but
would be less appropriate to the extent
that growth instead reflects inflation
f these ongoing
threshold adjustments, institutions
would also become subject to additional
assessment-related reporting
requirements as they grow above the
threshold. This additional reporting
burden may be justified in cases where
asset growth reflects changes to actual
size, risk profile, and complexity but
would be less appropriate to the extent
that growth instead reflects inflation.
Adjusting regulatory thresholds over
time helps preserve the intended use
and application, in real terms, of
additional reporting requirements and
helps ensure that IDIs are assessed
appropriately, commensurate with the
risk they pose to the DIF.
B. Current Definitions of Small and
Large Institutions
For established institutions that are
not insured branches of foreign banks,
asset size, as measured by total assets
reported on the Call Report, is the sole
factor used by the FDIC to determine
whether an institution’s assessment rate
is calculated using the pricing
methodology for small institutions or
large institutions.27 The FDIC’s
assessment regulations generally define
a small institution as an IDI with total
assets of less than $10 billion, as
reported on the Call Report, while a
large institution is defined as an IDI that
reports total assets of $10 billion or
more on its Call Report for four
consecutive quarters and that does not
meet the definition of a highly complex
institution.28 The $10 billion asset size
threshold has been in place since the
FDIC first established separate risk-
based pricing methods for large and
small banks in 2006.29
C
Report, while a
large institution is defined as an IDI that
reports total assets of $10 billion or
more on its Call Report for four
consecutive quarters and that does not
meet the definition of a highly complex
institution.28 The $10 billion asset size
threshold has been in place since the
FDIC first established separate risk-
based pricing methods for large and
small banks in 2006.29
C. Proposed Increase in the Asset
Threshold in the Definitions of Small
and Large Institutions
The FDIC is proposing to update the
asset-based threshold in the assessment
regulations used to define small and
large institutions for deposit insurance
assessments purposes and to determine
whether assessment rates are calculated
using the small bank pricing
methodology or the large bank scorecard
approach from $10 billion in total assets
to $30 billion in total assets. In future
years, the proposed assessment
methodology threshold of $30 billion
would be adjusted on a consistent basis
as later described in section II.F. of this
Supplementary Information.
An institution that is priced as a large
institution immediately prior to the
effective date of any final rule but that
reports less than $30 billion in total
assets would be classified as a small
institution as of the effective date of any
final rule. Such a bank would not need
to report less than $30 billion in total
assets for four consecutive quarters
before being reclassified as small.
Thereafter, a small institution would be
reclassified as a large institution only if
it reports total assets of $30 billion (or
such threshold adjusted in the future for
inflation) or more for four consecutive
quarters. Similarly, a large institution
would be reclassified as a small
institution only if it reports total assets
under $30 billion (or such threshold
adjusted in the future for inflation) for
four consecutive quarters
reclassified as a large institution only if
it reports total assets of $30 billion (or
such threshold adjusted in the future for
inflation) or more for four consecutive
quarters. Similarly, a large institution
would be reclassified as a small
institution only if it reports total assets
under $30 billion (or such threshold
adjusted in the future for inflation) for
four consecutive quarters.
For large and highly complex
institutions, the FDIC can adjust the
total score based on relevant risk or risk-
mitigating factors that are not
adequately reflected in the scorecards.30
The proposed increase in the
assessment methodology threshold from
$10 billion to $30 billion has the effect
that institutions with total assets under
$30 billion that are not priced as large
banks would not be considered for these
potential score adjustments, though the
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31 See FDIC Chairman Travis Hill, ‘‘Oversight of
Prudential Regulators,’’ Testimony, Committee on
Financial Services, United States House of
Representatives, December 2, 2025, available at:
https://www.fdic.gov/news/speeches/2025/
oversight-prudential-regulators. A revised
assessment methodology threshold of $30 billion in
total assets is also consistent with recent actions
taken by the Office of the Comptroller of the
Currency (OCC) to tailor its regulatory and
supervisory frameworks to minimize burden for its
regulated institutions and promote economic
growth. See OCC News Release, ‘‘OCC Announces
Actions to Reduce Regulatory Burden for
Community Banks,’’ October 6, 2025, available at:
https://occ.gov/news-issuances/news-releases/2025/
nr-occ-2025-95.html
taken by the Office of the Comptroller of the
Currency (OCC) to tailor its regulatory and
supervisory frameworks to minimize burden for its
regulated institutions and promote economic
growth. See OCC News Release, ‘‘OCC Announces
Actions to Reduce Regulatory Burden for
Community Banks,’’ October 6, 2025, available at:
https://occ.gov/news-issuances/news-releases/2025/
nr-occ-2025-95.html.
32 Analysis is based on data from the Call Report
and FFIEC 002 for the reporting period that ended
December 31, 2025, reported as of February 16,
2026.
33 The regulatory and reporting requirements for
institutions with total assets under $1 billion
generally differ from that of those with over $1
billion. See, e.g., 12 CFR 363.1(a).
adjustment guidelines would be
retained and would be unchanged for an
institution that would meet the
proposed definition of a large institution
or that is defined as a highly complex
institution.
The proposed assessment
methodology threshold of $30 billion in
total assets is consistent with the recent
update to the FDIC’s continuous
examination process. The FDIC has
historically supervised banks under
either a point-in-time examination
process or a continuous examination
process. Prior to recent changes, nearly
all FDIC-supervised banks with $10
billion or more in total assets were
subject to the continuous examination
process, as were a small handful below
$10 billion in total assets based on
certain risk considerations. The FDIC
recently raised the threshold for
presumptive inclusion in the
continuous examination process from
$10 billion to $30 billion in total assets,
while retaining the ability to include a
bank below $30 billion in total assets if
warranted.31
1
ject to the continuous examination
process, as were a small handful below
$10 billion in total assets based on
certain risk considerations. The FDIC
recently raised the threshold for
presumptive inclusion in the
continuous examination process from
$10 billion to $30 billion in total assets,
while retaining the ability to include a
bank below $30 billion in total assets if
warranted.31
1. Analysis
The FDIC anticipates that increasing
the assessment methodology threshold
to $30 billion in total assets would shift
the share of industry assets held by
banks priced using the scorecard
methodology to more closely align with
the share held by such institutions in
2011, when the current large bank and
highly complex scorecard methodology
was first implemented. At that time,
institutions priced as large or highly
complex institutions made up 78.9
percent of industry assets. As of
December 31, 2025, that share has
increased to 85.0 percent. Under the
proposed $30 billion assessment
methodology threshold, large and highly
complex institutions would make up
79.5 percent of industry assets based on
data as of December 31, 2025.
The FDIC anticipates that increasing
the assessment methodology threshold
to $30 billion in total assets would
result in 76 institutions shifting from
the large bank pricing scorecard
methodology to the small bank pricing
methodology based on data as of
December 31, 2025.
The FDIC estimates that among the 76
institutions that would shift from the
large bank pricing scorecard
methodology to the small bank pricing
methodology as a result of the proposal,
almost all would pay less in
assessments, particularly after applying
the proposed 2 basis point reduction in
initial base assessment rate schedules
applicable to small banks detailed
below
ember 31, 2025.
The FDIC estimates that among the 76
institutions that would shift from the
large bank pricing scorecard
methodology to the small bank pricing
methodology as a result of the proposal,
almost all would pay less in
assessments, particularly after applying
the proposed 2 basis point reduction in
initial base assessment rate schedules
applicable to small banks detailed
below. However, to mitigate possible
effects on some institutions, the FDIC is
proposing to provide for a one-time
election for reclassified institutions to
be temporarily priced using the large
bank scorecard methodology to mitigate
any impact and allow for a transition, as
described below.
The overall impact to institutions’
assessments from the proposed change
in definitions would vary by institution,
based on differences in the pricing
methodologies for small and large banks
and the institution’s specific financial
data and supervisory ratings. Therefore,
the shift in pricing methodology is
expected to result in varied financial
outcomes for the affected IDIs, which
will further vary over time and through
banking and economic cycles. For
example, a given bank likely would
have paid a lower rate when priced as
large in 2020 due to the influx of
deposits in response to the pandemic
and related relief efforts which
improved liquidity and core deposits
measures applicable to large banks,
whereas the small bank pricing
methodology directly prices for rapid
asset growth.
Generally, possible impacts could
include, but would not be limited to,
banks with significant concentrations in
higher-risk assets or elevated funding
stress paying lower assessments, and
banks with greater concentrations in
core deposits or larger government
guaranteed loan portfolios paying higher
assessments under the small bank
pricing methodology relative to the
current large bank scorecard
methodology
pacts could
include, but would not be limited to,
banks with significant concentrations in
higher-risk assets or elevated funding
stress paying lower assessments, and
banks with greater concentrations in
core deposits or larger government
guaranteed loan portfolios paying higher
assessments under the small bank
pricing methodology relative to the
current large bank scorecard
methodology. Institutions with higher
leverage ratios could also pay lower
assessments if shifted to the small bank
pricing methodology. These potential
effects arise because the small bank
pricing methodology uses a different set
of financial measures and weights based
on how the measures corresponded with
the probability of failure for small
banks.
In aggregate and disregarding the
other proposed changes to the
assessment regulations in this proposal,
the proposed increase in the assessment
methodology threshold is estimated to
result in an approximate net decrease of
$129 million in annual assessments
based on data as of December 31,
2025.32 This component of the proposal,
if adopted, is therefore expected to
reduce the banking industry’s aggregate
assessment cost, with varied impacts on
individual affected institutions
depending on how their specific risk
profiles at a specific point in time are
priced under the small bank pricing
methodology.
The FDIC analyzed the similarity
between institutions with total assets
between $1 billion and $10 billion and
the 76 institutions with assets between
$10 billion and $30 billion that would
be reclassified as small institutions
under the proposal. As reflected in
Table 1, on average, both groups
reported approximately similar shares of
deposit and loan types and leverage
ratios as of December 31, 2025.33
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llion that would
be reclassified as small institutions
under the proposal. As reflected in
Table 1, on average, both groups
reported approximately similar shares of
deposit and loan types and leverage
ratios as of December 31, 2025.33
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Institutions that would shift from the
large bank scorecard methodology to the
small bank pricing methodology would
also benefit from a reduction in
reporting burden, as large institutions
must report granular data on higher-risk
asset exposures and specific liability
concentrations under the scorecard
approach. These reporting burden
reductions would be expected to create
operational savings for the reclassified
IDIs.
2. Alternatives Considered
In developing the proposal, the FDIC
considered alternatives to the proposed
$30 billion assessment methodology
threshold, including maintaining the
$10 billion threshold or increasing the
assessment methodology threshold to
$20 billion, $25 billion, or $50 billion.
The FDIC believes that maintaining
the current $10 billion assessment
methodology threshold would not be
appropriate because institutions
between $10 billion and $30 billion in
total assets are more appropriately
priced using the small bank pricing
methodology than the large bank
scorecard. Increasing the asset-based
threshold in the definitions of small and
large banks in the assessments
regulations to $30 billion would more
closely align the share of industry assets
held by banks priced using the
scorecard methodology under the
proposal with the share held by such
institutions when the current large bank
and highly complex scorecard
methodology was first implemented in
2011. At that time, institutions priced as
large or highly complex institutions
made up 78.9 percent of industry assets
0 billion would more
closely align the share of industry assets
held by banks priced using the
scorecard methodology under the
proposal with the share held by such
institutions when the current large bank
and highly complex scorecard
methodology was first implemented in
2011. At that time, institutions priced as
large or highly complex institutions
made up 78.9 percent of industry assets.
As of December 31, 2025, that share has
increased to 85.0 percent. Under the
proposed $30 billion assessment
methodology threshold, large and highly
complex institutions would make up
79.5 percent of industry assets based on
data as of December 31, 2025.
Further, institutions that would shift
from the large bank scorecard
methodology to the small bank pricing
methodology under the proposal
demonstrate certain similarities with
other small institutions. For example,
and as described above, small
institutions with total assets between $1
billion and $10 billion report
approximately similar shares of foreign
deposits, uninsured deposits, and real
estate loans as those of the 76
institutions that would shift from the
large bank pricing scorecard
methodology to the small bank pricing
methodology under the proposal.
The FDIC considered several
alternative thresholds. In general,
relative to the alternatives considered,
the FDIC believes that the proposed
threshold of $30 billion best preserves
its intended purpose as it most closely
aligns with the shares of industry assets
held by small and large institutions in
2011, when the current large bank
pricing methodology was implemented,
but seeks comments on alternatives
d several
alternative thresholds. In general,
relative to the alternatives considered,
the FDIC believes that the proposed
threshold of $30 billion best preserves
its intended purpose as it most closely
aligns with the shares of industry assets
held by small and large institutions in
2011, when the current large bank
pricing methodology was implemented,
but seeks comments on alternatives.
Question 1: What are the advantages
and disadvantages of updating the
threshold for defining an institution as
small or large for deposit insurance
assessments purposes from $10 billion
in total assets to $30 billion in total
assets, as described above? Should the
FDIC consider other asset thresholds for
defining an institution as small or large
for deposit assessment purposes? Are
there any other factors the FDIC should
consider?
Question 2: What are the potential
unintended consequences, if any, of
establishing a higher threshold for
deposit insurance assessments
purposes?
D. Removing the Option for a Small
Institution To Request That the FDIC
Determine Its Assessment Rates as a
Large Institution
The FDIC’s assessment regulations
currently permit a small institution with
assets between $5 billion and $10
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34 12 CFR 327.16(f)(1).
35 The U.S. Bureau of Labor Statistics publishes
the CPI–W on a monthly basis. The CPI–W is used
to annually adjust benefits paid to Social Security
beneficiaries and Supplemental Security Income
recipients. See U.S. Social Security Administration,
CPI for Urban Wage Earners and Clerical Workers,
available at: www.ssa.gov/oact/STATS/cpiw.html
, 2026 / Proposed Rules
34 12 CFR 327.16(f)(1).
35 The U.S. Bureau of Labor Statistics publishes
the CPI–W on a monthly basis. The CPI–W is used
to annually adjust benefits paid to Social Security
beneficiaries and Supplemental Security Income
recipients. See U.S. Social Security Administration,
CPI for Urban Wage Earners and Clerical Workers,
available at: www.ssa.gov/oact/STATS/cpiw.html.
36 The use of CPI–W to index thresholds is
consistent with other bank regulations, such as
those relating to the Community Reinvestment Act
and the March 2026 proposed updates to the
regulatory capital rules. The indexing methodology
would also generally align with the methodology
used to adjust certain thresholds within FDIC
regulations. See, e.g., Community Reinvestment Act
Regulations Asset-Size Thresholds, 89 FR 106480,
106481 (Dec. 30, 2024); Regulatory Capital Rule:
Category I and II Banking Organizations, Banking
Organizations With Significant Trading Activity,
and Optional Adoption for Other Banking
Organizations, 91 FR 14952, 14960 (Mar. 27, 2026);
and Regulatory Capital Rules: Regulatory Capital
and Standardized Approach for Risk-Weighted
Assets, 91 FR 15332, 15364 (Mar. 27, 2026). See
also 12 CFR 229.11.
billion to request that the FDIC
determine its assessment rate as a large
institution.34 Approved requests
become effective within one year of the
date of the request. If an institution
whose request has been granted
subsequently reports total assets of less
than $5 billion in its Call Report for four
consecutive quarters, the institution
shall be deemed a small institution for
assessment purposes. If the FDIC
approves an institution’s request to be
treated as a large institution, the
institution is not eligible to request to be
assessed as a small institution for a
period of three years from the first
quarter its approval became effective
s
than $5 billion in its Call Report for four
consecutive quarters, the institution
shall be deemed a small institution for
assessment purposes. If the FDIC
approves an institution’s request to be
treated as a large institution, the
institution is not eligible to request to be
assessed as a small institution for a
period of three years from the first
quarter its approval became effective.
Small institutions that have exercised
this option generally have paid lower
assessments under the large bank
scorecard approach relative to the small
bank pricing methodology. However,
several additional reasons for requesting
this option have been cited, including
anticipated growth above the $10 billion
threshold and having an affiliated large
bank with which the small bank shares
the same reporting and risk framework.
The FDIC is proposing to remove this
option to promote fairness, simplicity,
and accuracy in risk-based deposit
insurance assessments. Additionally, if
the assessment methodology threshold
is consistently adjusted in the future to
reflect inflation, banks will be less likely
to naturally grow above the threshold.
The FDIC expects the impact of
removing this provision to be minimal
given that only nine requests were
received in the last ten years.
Question 3: What are the advantages
and disadvantages of eliminating the
option for a small institution to request
treatment as a large institution for
purposes of the assessment regulations,
as described above?
Question 4: What are the potential
unintended consequences, if any, of
eliminating this option?
E. One-Time Election for Reclassified
Institutions To Be Temporarily Priced
Using the Large Bank Scorecard Pricing
Methodology
Under the proposal, an institution
priced as a large institution immediately
prior to the effective date of any final
rule that reports total assets below the
updated threshold of $30 billion would
be priced as a small institution as of the
effective date of any final rule
e Election for Reclassified
Institutions To Be Temporarily Priced
Using the Large Bank Scorecard Pricing
Methodology
Under the proposal, an institution
priced as a large institution immediately
prior to the effective date of any final
rule that reports total assets below the
updated threshold of $30 billion would
be priced as a small institution as of the
effective date of any final rule. To
mitigate possible effects on some
institutions, including the potential
‘‘cliff effect’’ of immediately switching
pricing frameworks, the FDIC is
proposing to provide any bank classified
as a large institution immediately prior
to the effective date of any final rule that
report total assets below $30 billion a
one-time option to temporarily continue
to be priced as a large institution. Under
the proposal, a bank that exercises this
option would be ineligible for the RRA
unless and until the bank meets the
proposed definition of a large institution
by reporting total assets of $30 billion
(or such threshold adjusted in the future
for inflation) or more for four
consecutive quarters and elects to
submit to VDR testing or provides the
prescribed data access.
An institution electing this option
would continue to be priced as a large
institution for eight consecutive quarters
(inclusive of the first quarter) after the
effective date of any final rule. If an
institution that elects to be priced as a
large institution and has not reported
total assets of $30 billion or more for at
least four consecutive quarters reports
total assets of less than $30 billion at the
end of the eight-quarter transition
period, it will be classified as a small
institution beginning on the first day of
the subsequent quarter
effective date of any final rule. If an
institution that elects to be priced as a
large institution and has not reported
total assets of $30 billion or more for at
least four consecutive quarters reports
total assets of less than $30 billion at the
end of the eight-quarter transition
period, it will be classified as a small
institution beginning on the first day of
the subsequent quarter. If an institution
that elects to be priced as a large
institution reports total assets of $30
billion or more for four consecutive
quarters during the eight-quarter
transition period, it would be classified
as a large institution unless and until it
subsequently reports total assets below
the proposed threshold of $30 billion for
four consecutive quarters.
To elect this option, an eligible
institution would be required to provide
notice to the FDIC indicating its one-
time election for the FDIC to determine
its assessment rate as a large institution
for a period of time not to exceed the
eight-quarter transition period, as
defined under the proposal. The FDIC
anticipates posting on its website a form
letter that an eligible institution can
submit as notice. The FDIC must receive
such correspondence by mail or email
prior to the end of the quarter in which
any final rule becomes effective.
1. Alternatives Considered
An alternative to the proposed
approach would be to allow banks
reporting total assets between $10
billion and $30 billion a one-time
election to remain a large institution for
a longer period—for example, until the
next indexing adjustment. Another
alternative would be to reclassify banks
as small or large based on their asset
size as of the effective date of any final
rule without allowing any transition
period
sed
approach would be to allow banks
reporting total assets between $10
billion and $30 billion a one-time
election to remain a large institution for
a longer period—for example, until the
next indexing adjustment. Another
alternative would be to reclassify banks
as small or large based on their asset
size as of the effective date of any final
rule without allowing any transition
period.
The FDIC believes that providing for
a transition period would mitigate
possible effects on some institutions,
including the potential ‘‘cliff effect’’ of
immediately switching pricing
frameworks and invites comment,
including the appropriate length of any
transition.
Question 5: What are the advantages
and disadvantages of providing an
institution that is reclassified as a small
institution as a result of the proposed
update to the assessment methodology
threshold a one-time option to continue
to be priced as large for eight
consecutive quarters following the
effective date of any final rule?
Question 6: Should the FDIC consider
a shorter or longer transition period for
institutions reclassified as small
institutions as a result of the proposal?
Please explain.
Question 7: Should the FDIC permit
an institution that exercises the election
to be treated as a large institution to be
eligible for all or some of the RRA
during the time period it is priced as a
large institution?
F. Indexing of Threshold Used To
Define Small and Large Institutions
Under the proposal, the dollar-based
threshold included in the proposed
definitions of a small and large
institution would be updated and
adjusted every four years to reflect
inflation, pursuant to a pre-determined
indexing methodology. Specifically, the
proposed indexing methodology would
adjust the threshold based on the
consumer price index for urban wage
earners and clerical workers (CPI–W)
published by the U.S
r-based
threshold included in the proposed
definitions of a small and large
institution would be updated and
adjusted every four years to reflect
inflation, pursuant to a pre-determined
indexing methodology. Specifically, the
proposed indexing methodology would
adjust the threshold based on the
consumer price index for urban wage
earners and clerical workers (CPI–W)
published by the U.S. Bureau of Labor
Statistics.35 The use of CPI–W to index
thresholds is consistent with the
indexing methodology in other bank
regulations.36 Further, the indexing
methodology included under the
proposal would generally align with the
methodology used to adjust certain
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37 See supra fn 22.
38 See 91 FR 14952, 14960 (Mar. 27, 2026) and 91
FR 15332, 15364 (Mar. 27, 2026). See also 90 FR
55789 (Dec. 4, 2025).
39 Any periods of deflation would be reflected in
future threshold increases, as threshold adjustments
in the future would be based on the positive net
cumulative change in CPI–W.
40 For example, a threshold that would otherwise
be calculated as $30.964 billion would be rounded
to $31 billion.
41 The U.S. Bureau of Labor Statistics publishes
the CPI–W on a monthly basis.
42 Deposit insurance assessments are collected
quarterly in arrears. For example, for deposit
insurance coverage in the first quarter of each year
(i.e. from January 1 through March 31), institutions
are invoiced and payment is due in June of each
year. Accordingly, if an institution is reclassified as
a small institution with an effective date of January
1, for example, payment for the institution’s first
quarterly assessment calculated pursuant to the
small bank pricing methodology would not be
invoiced and due until June. See 12 CFR
327.3(b)(2).
43 See supra fn 22
31), institutions
are invoiced and payment is due in June of each
year. Accordingly, if an institution is reclassified as
a small institution with an effective date of January
1, for example, payment for the institution’s first
quarterly assessment calculated pursuant to the
small bank pricing methodology would not be
invoiced and due until June. See 12 CFR
327.3(b)(2).
43 See supra fn 22.
44 See 90 FR 35449, 35458 (Jul. 28, 2025). See also
90 FR 55789, 55791 (Dec. 4, 2025).
45 See supra fn 22.
other thresholds within FDIC
regulations.37
Under the proposal the asset-based
threshold defining small and large
institutions for purposes of deposit
insurance assessments would be
adjusted at the end of every consecutive
four-year period based on the
cumulative percent change of the non-
seasonally adjusted CPI–W since the
effective date of any final rule. This
four-year period is intended to provide
an appropriate cadence for capturing
meaningful changes in inflation on a
timely basis while minimizing the
burden of adjustment. The proposed
four-year cadence differs from the two-
year cadence proposed in the March
2026 proposed updates to the regulatory
capital rules and adopted in other FDIC
regulations in consideration of the
requirement that an institution exceed
the dollar-based asset threshold in the
definitions of small and large
institutions in the assessment
regulations for at least four consecutive
quarters before a definition becomes
applicable.38
The proposal would not lower the
threshold in the event of deflation.39 In
contrast to the indexing methodology
included in the March 2026 proposed
updates to the regulatory capital rules,
the threshold defining small and large
institutions in the assessment
regulations would not be adjusted
during any intervening calendar year to
address the possibility of periods of
unusual inflation
The proposal would not lower the
threshold in the event of deflation.39 In
contrast to the indexing methodology
included in the March 2026 proposed
updates to the regulatory capital rules,
the threshold defining small and large
institutions in the assessment
regulations would not be adjusted
during any intervening calendar year to
address the possibility of periods of
unusual inflation. The FDIC believes
this difference is appropriate given the
requirement that an institution must
generally report dollar amounts above or
below the asset threshold defining small
and large institutions in the assessment
regulations for four consecutive quarters
in order to meet the criteria for
applicability of the definitions and the
regular cadence of threshold
adjustments would instill consistency
and transparency in quarterly
assessment payments for IDIs.
Additionally, the threshold adjusted
under the proposed indexing
methodology would be rounded based
on the size of the threshold (e.g.,
billions, millions, thousands), generally,
to the nearest two significant digits, as
appropriate.40
To effectuate future threshold
adjustments under the proposal, the
FDIC would announce the thresholds
adjusted in accordance with the
indexing methodology by issuing a final
rule in the Federal Register to announce
the updated threshold without notice
and comment. Although the FDIC
would be required to publish a final rule
in the Federal Register, the adjustment
would occur even in the absence of
publication in the Federal Register
der the proposal, the
FDIC would announce the thresholds
adjusted in accordance with the
indexing methodology by issuing a final
rule in the Federal Register to announce
the updated threshold without notice
and comment. Although the FDIC
would be required to publish a final rule
in the Federal Register, the adjustment
would occur even in the absence of
publication in the Federal Register.
Threshold adjustments would be
calculated based on cumulative CPI–W
data through August of the year in
which the adjustment is made, relative
to the same initial baseline and would
be effective for the assessment period
beginning on October 1 of the year
during which an adjustment is made.41
An institution priced as a large bank
immediately prior to the effective date
of any final rule announcing a threshold
update that reports total assets below
the updated threshold, would be priced
as a small bank as of the effective date
of any final rule.42
1. Alternatives Considered
In developing this proposal and in
proposing and finalizing the first phase
of adjustments to certain thresholds
within FDIC regulations,43 the FDIC
considered other factors that could be
used to adjust certain thresholds in the
assessment regulations to preserve the
threshold levels in real terms over
time.44 For example, the indexing
methodology could rely on an
alternative index or measure of inflation
(e.g., core versus non-core measures).
Additionally, the FDIC considered using
changes in economic growth, such as
gross domestic product (GDP), or
banking industry assets as well as
alternative approaches using a less or
more frequent cadence or a process that
is less automated (e.g., requiring Board
approval or public notice and
comment).
Properly constructed, periodic
adjustments can avoid unintended and
undesirable outcomes
itionally, the FDIC considered using
changes in economic growth, such as
gross domestic product (GDP), or
banking industry assets as well as
alternative approaches using a less or
more frequent cadence or a process that
is less automated (e.g., requiring Board
approval or public notice and
comment).
Properly constructed, periodic
adjustments can avoid unintended and
undesirable outcomes. For example,
frequent adjustments in the absence of
meaningful change can result in
inefficiencies, as institutions realign
their reporting and balance sheet
management practices to reflect
adjusted thresholds. Conversely,
infrequent adjustments increase the risk
that the intended purpose of the
threshold is not preserved consistently
over time.
A threshold may be periodically
updated through ad-hoc review or
consistent adjustments. An ad-hoc
approach that does not pre-determine
future adjustments may better preserve
the threshold’s intended application by
allowing consideration of relevant
contextual factors at each future
adjustment. Such an approach may also
be less predictable and introduce
inefficiencies. Conversely, periodic
adjustments using a pre-determined
indexing methodology based on one or
more specified factors, such as inflation,
would increase efficiency and
predictability, but may limit flexibility
in cases where the measure is less
relevant to a future context.
Finally, the threshold used in the
assessment regulations to define an
institution as a small or large institution
and determine which assessment
methodology is applied can influence a
bank’s decision to grow, as a bank’s
deposit insurance assessment rate may
increase or decrease depending on
whether it is defined as a small, large,
or highly complex institution.
Moreover, while all banks are required
to report certain items on the Call
Report, as noted above, large and highly
complex institutions have additional
reporting requirements related to
assessments
fluence a
bank’s decision to grow, as a bank’s
deposit insurance assessment rate may
increase or decrease depending on
whether it is defined as a small, large,
or highly complex institution.
Moreover, while all banks are required
to report certain items on the Call
Report, as noted above, large and highly
complex institutions have additional
reporting requirements related to
assessments.
In general, properly structured and
appropriately sequenced threshold
adjustments promote consistent
application of regulatory requirements
over time and contribute to a more
durable regulatory framework that
enhances the overall efficacy of the risk-
based assessment system. In addition,
such adjustments can enhance
transparency and certainty and therefore
allow for more enhanced balance sheet
management practices for IDIs.
As noted in the FDIC’s 2025 final rule
on adjusting and indexing certain
regulatory thresholds, many
commenters supported the proposed
indexing methodology and related
process for automatic threshold
adjustments.45 The FDIC is proposing
substantively the same indexing
methodology as the 2025 final rule, with
the exception of the four-year cadence
and disallowing adjustments in
intervening years for periods of unusual
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tic threshold
adjustments.45 The FDIC is proposing
substantively the same indexing
methodology as the 2025 final rule, with
the exception of the four-year cadence
and disallowing adjustments in
intervening years for periods of unusual
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46 See supra fn 1.
47 See supra fn 7.
48 12 U.S.C. 1817(b)(2)(A).
49 The risk factors referred to in factor (iv) include
the probability that the DIF will incur a loss with
respect to the institution, the likely amount of any
such loss, and the revenue needs of the DIF. See
section 7(b)(1)(C) of the FDI Act, 12 U.S.C.
1817(b)(1)(C).
50 See section 7(b)(2)(B) of the FDI Act, 12 U.S.C.
1817(b)(2)(B).
51 See 12 CFR 327.10(f)(3). In no case may any
such rate adjustments result in total base
assessment rates that are negative. See 12 CFR
327.10(f)(1).
52 See 87 FR 39388 (Jul. 1, 2022) and 87 FR 64314
(Oct. 24, 2022). The FDI Act requires the Board to
adopt a restoration plan when the DIF reserve ratio
falls below the statutory minimum of 1.35 percent
or is expected to within 6 months, to restore the DIF
to at least 1.35 percent within eight years, absent
extraordinary circumstances. See 12 U.S.C.
1817(b)(3)(B) and (E). The reserve ratio is calculated
as the ratio of the net worth of the DIF to the value
of the aggregate estimated insured deposits at the
end of a given quarter. See 12 U.S.C. 1813(y)(3).
53 See 12 CFR 327.10(b).
54 See 12 CFR 327.10(c) and (d).
55 The DRR is expressed as a percentage of
estimated insured deposits. The FDI Act requires
that the Board designate the DRR for the DIF and
publish the DRR before the beginning of each
calendar year
et worth of the DIF to the value
of the aggregate estimated insured deposits at the
end of a given quarter. See 12 U.S.C. 1813(y)(3).
53 See 12 CFR 327.10(b).
54 See 12 CFR 327.10(c) and (d).
55 The DRR is expressed as a percentage of
estimated insured deposits. The FDI Act requires
that the Board designate the DRR for the DIF and
publish the DRR before the beginning of each
calendar year. The Board must set the DRR in
accordance with its analysis of certain statutory
factors: risk of losses to the DIF; economic
conditions generally affecting IDIs; preventing
sharp swings in assessment rates; and any other
factors that the Board determines to be appropriate.
In December 2010, the Board set the DRR at 2
percent based on a comprehensive, long-range
management plan for the DIF and has voted
annually since then to maintain the 2 percent DRR,
most recently in November 2025. See 90 FR 54688
(Nov. 28, 2025).
56 See supra fn 16.
57 See 12 CFR 327.10(b)(2). An established
insured depository institution is a bank or savings
association that has been federally insured for at
least five years as of the last day of any quarter for
which it is being assessed. See 12 CFR 327.8(k).
inflation, in lieu of alternatives, to
reflect that general support.
Comments on the 2025 final rule on
adjusting and indexing certain
regulatory thresholds were mixed as to
whether to use CPI–W as the reference
index under the proposed indexing
methodology. A few commenters
supported the FDIC applying the same
methodology when updating and
adjusting thresholds across its
regulations. Others suggested
alternatives to CPI–W, including
nominal GDP, banking industry assets,
or an approach that would tailor the
reference index by threshold type—for
example, using CPI–W for consumer-
facing monetary thresholds, and
nominal GDP for asset-based thresholds
mmenters
supported the FDIC applying the same
methodology when updating and
adjusting thresholds across its
regulations. Others suggested
alternatives to CPI–W, including
nominal GDP, banking industry assets,
or an approach that would tailor the
reference index by threshold type—for
example, using CPI–W for consumer-
facing monetary thresholds, and
nominal GDP for asset-based thresholds.
In general, the FDIC is proposing to
update the assessment methodology
threshold using CPI–W rather than
using one or more other potential
measures to promote consistency and
reduce complexity across regulatory
thresholds.
The FDIC considered these
alternatives and comments in
developing the proposal for adjusting
thresholds in the assessment
regulations. The FDIC requests
additional feedback on all alternative
approaches discussed and any other
alternative approaches that should be
considered.
The FDIC continues to evaluate other
dollar-based thresholds in the
assessment regulations and may
consider soliciting comment on
updating and adjusting additional
thresholds through a subsequent
proposal to amend the assessment
regulations.
Question 8: What are the advantages
and disadvantages of the proposed
approach for indexing the threshold
used for defining large and small
institutions for purposes of deposit
insurance assessments? What
alternatives should the FDIC consider
and why?
Question 9: What are the advantages
and disadvantages of using a different
index for adjusting the threshold, such
as banking industry assets, nominal
GDP, or the GDP deflator, instead of
CPI–W?
Question 10: Should the FDIC
consider a shorter or longer interval
than four years for automatic threshold
adjustments, and if so, why?
Question 11: What are the advantages
and disadvantages of discretionary off-
year adjustments for periods of unusual
inflation? Should the FDIC consider a
framework for adjustment in off years,
and if so, why?
III. Proposed Revisions to Assessment
Rates
A
stion 10: Should the FDIC
consider a shorter or longer interval
than four years for automatic threshold
adjustments, and if so, why?
Question 11: What are the advantages
and disadvantages of discretionary off-
year adjustments for periods of unusual
inflation? Should the FDIC consider a
framework for adjustment in off years,
and if so, why?
III. Proposed Revisions to Assessment
Rates
A. Background
1. Deposit Insurance Assessment Rates
Pursuant to section 7 of the FDI Act,
the FDIC has established a risk-based
assessment system through which it
charges all IDIs an assessment amount
for deposit insurance.46 Under the
FDIC’s assessment regulations, an IDI’s
assessment amount is equal to its
assessment base multiplied by its risk-
based assessment rate.47 The FDIC is
authorized to set assessments for IDIs in
such amounts as the FDIC may
determine to be necessary or
appropriate.48 In setting assessment
rates, the FDIC is required by statute to
consider the following factors:
(i) The estimated operating expenses
of the DIF.
(ii) The estimated case resolution
expenses and income of the DIF.
(iii) The projected effects of the
payment of assessments on the capital
and earnings of IDIs.
(iv) The risk factors and other factors
taken into account pursuant to section
7(b)(1) of the FDI Act (12 U.S.C.
1817(b)(1)) under the risk-based
assessment system, including the
requirement under such section to
maintain a risk-based system.49
case resolution
expenses and income of the DIF.
(iii) The projected effects of the
payment of assessments on the capital
and earnings of IDIs.
(iv) The risk factors and other factors
taken into account pursuant to section
7(b)(1) of the FDI Act (12 U.S.C.
1817(b)(1)) under the risk-based
assessment system, including the
requirement under such section to
maintain a risk-based system.49
(v) Other factors the FDIC has
determined to be appropriate.50
In addition, the FDIC Board of
Directors (Board) is authorized to
uniformly increase or decrease the total
base rate assessment schedule up to a
maximum of 2 basis points or a fraction
thereof, as the Board deems necessary,
without further rulemaking.51
2. Current Assessment Rate Schedules
and the Reserve Ratio
Effective January 1, 2023, the FDIC
adopted an increase in initial base
deposit insurance assessment rate
schedules of 2 basis points as part of the
statutorily-required Restoration Plan.52
Those rate schedules are currently in
effect and are detailed below.53
Progressively lower assessment rate
schedules will take effect when the
reserve ratio exceeds 2 percent and 2.5
percent, and the FDIC did not modify
those schedules when increasing rates
in 2023.54
As of June 30, 2025, the reserve ratio
increased to 1.36 percent, above the
statutory minimum of 1.35 percent.
Therefore, the FDIC is no longer
operating under a Restoration Plan. The
reserve ratio was 1.43 percent as of
March 31, 2026, and has continued to
progress toward the FDIC’s long-term
goal of a 2 percent designated reserve
ratio (DRR).55
a. Current Assessment Rate Schedules
for Established Small Institutions and
Large and Highly Complex Institutions
Assessment rates for established small
institutions and large and highly
complex institutions currently in effect
while the reserve ratio is less than 2
percent are set forth in Table 2 below
ss toward the FDIC’s long-term
goal of a 2 percent designated reserve
ratio (DRR).55
a. Current Assessment Rate Schedules
for Established Small Institutions and
Large and Highly Complex Institutions
Assessment rates for established small
institutions and large and highly
complex institutions currently in effect
while the reserve ratio is less than 2
percent are set forth in Table 2 below.
An institution’s total base assessment
rate may vary from the institution’s
initial base assessment rate as a result of
possible adjustments for certain
liabilities that can increase or reduce
loss to the DIF in the event the
institution fails.56 After applying all
possible adjustments, the current
minimum and maximum total base
assessment rates for established small
institutions and large and highly
complex institutions are set forth in
Table 2 below.57
BILLING CODE 6714–01–P
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58 In lieu of dividends, and pursuant to the FDIC’s
authority to set assessments, the progressively
lower initial base and total base assessment rates set
forth in 12 CFR 327.10(c) and (d) will come into
effect without further action by the Board when the
fund reserve ratio at the end of the prior assessment
period reaches 2 percent and 2.5 percent,
respectively.
The assessment rates currently
applicable to established small
institutions and large and highly
complex institutions in Table 2 above
remain in effect unless and until the
reserve ratio meets or exceeds 2
percent.58
Table 3 below applies if the reserve
ratio of the DIF as of the end of the prior
assessment period is equal to or greater
than 2 percent and less than 2.5 percent
ectively.
The assessment rates currently
applicable to established small
institutions and large and highly
complex institutions in Table 2 above
remain in effect unless and until the
reserve ratio meets or exceeds 2
percent.58
Table 3 below applies if the reserve
ratio of the DIF as of the end of the prior
assessment period is equal to or greater
than 2 percent and less than 2.5 percent.
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Under the current regulations, Table 4
below applies to established small
institutions and large and highly
complex institutions if the reserve ratio
of the DIF as of the end of the prior
assessment period is greater than 2.5
percent.
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59 See 12 CFR 327.10(e)(1)(iv)(B). Subject to
exceptions, a new depository institution is a bank
or savings association that has been federally
insured for less than five years as of the last day
of any quarter for which it is being assessed. See
also 12 CFR 327.8(j).
60 See 12 CFR 327.10(e)(1)(iv)(B).
61 See 75 FR 66272, 66283 (Oct. 27, 2010) and 76
FR 10672, 10686 (Feb. 25, 2011).
b
es
59 See 12 CFR 327.10(e)(1)(iv)(B). Subject to
exceptions, a new depository institution is a bank
or savings association that has been federally
insured for less than five years as of the last day
of any quarter for which it is being assessed. See
also 12 CFR 327.8(j).
60 See 12 CFR 327.10(e)(1)(iv)(B).
61 See 75 FR 66272, 66283 (Oct. 27, 2010) and 76
FR 10672, 10686 (Feb. 25, 2011).
b. Current Assessment Rate Schedules
for New Small Institutions
Current assessment rates applicable to
new small institutions are set forth in
Table 5 below.59 New small institutions
remain subject to the assessment
schedules in Table 5 when the reserve
ratio reaches 2 percent or 2.5 percent.60
As stated in the 2010 notice of proposed
rulemaking describing the FDIC’s
comprehensive, long-term fund
management plan, and adopted in a
2011 Final Rule, the lower assessment
rate schedules applicable when the
reserve ratio reaches 2 percent and 2.5
percent do not apply to any new
depository institutions; these
institutions will remain subject to the
assessment rates shown below, until
they no longer are new depository
institutions.61
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62 See 12 CFR 327.10(e)(2)(ii).
63 In lieu of dividends, and pursuant to the FDIC’s
authority to set assessments, the progressively
lower initial base and total base assessment rates set
forth in 12 CFR 327.10(e)(2)(iii) and (iv) will come
into effect without further action by the FDIC Board
when the fund reserve ratio at the end of the prior
assessment period reaches 2 percent and 2.5
percent, respectively.
c
)(2)(ii).
63 In lieu of dividends, and pursuant to the FDIC’s
authority to set assessments, the progressively
lower initial base and total base assessment rates set
forth in 12 CFR 327.10(e)(2)(iii) and (iv) will come
into effect without further action by the FDIC Board
when the fund reserve ratio at the end of the prior
assessment period reaches 2 percent and 2.5
percent, respectively.
c. Current Assessment Rate Schedule for
Insured Branches of Foreign Banks
Current assessment rates applicable to
insured branches of foreign banks are
set forth in Table 6 below.62 The rates
in Table 6 remain in effect unless and
until the reserve ratio meets or exceeds
2 percent.63 Progressively lower
assessment rate schedules for insured
branches of foreign banks will become
effective when the reserve ratio exceeds
2 percent and 2.5 percent.
BILLING CODE 6714–01–C
B. Proposed Updates to Assessment
Rate Schedules
The FDIC is proposing several
updates to deposit insurance assessment
rate schedules after considering the
statutory factors and the current status
of the DIF, as discussed below in section
VII. of this Supplementary Information.
As noted, the DIF is no longer operating
under a Restoration Plan, and the
reserve ratio is steadily progressing
toward the 2 percent DRR.
1. Proposed 2 Basis Point Reduction in
Initial Base Assessment Rate Schedules
Applied to Small Institutions
The FDIC is proposing to decrease
certain initial base deposit insurance
assessment rate schedules by 2 basis
points, beginning upon the effective
date of any final rule. Specifically, the
proposed 2 basis point decrease in
initial base assessment rate schedules
would apply to small institutions as
defined under this proposal and would
be applicable to established small
institutions, new small institutions, and
insured branches of foreign banks
osit insurance
assessment rate schedules by 2 basis
points, beginning upon the effective
date of any final rule. Specifically, the
proposed 2 basis point decrease in
initial base assessment rate schedules
would apply to small institutions as
defined under this proposal and would
be applicable to established small
institutions, new small institutions, and
insured branches of foreign banks.
As earlier described, the FDIC is
proposing to update the asset-based
threshold in the assessment regulations
used to define a small institution from
$10 billion in total assets to $30 billion
in total assets. Based on Call Report data
as of December 31, 2025, raising the
threshold from $10 billion to $30 billion
would result in approximately 76 IDIs
shifting from the large institution
definition to the small institution
definition for which the small
institution pricing methodology and the
proposed 2 basis point decrease in
initial base assessment rate schedules
would apply.
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64 See 12 CFR 327.10(c) and (d).
65 The FDI Act requires the FDIC to establish a
risk-based assessment system for calculating an
IDI’s assessment based on the probability that the
DIF will incur a loss with respect to that IDI and
the likely amount of any such loss, among other
factors. See 12 U.S.C. 1817(b)(1)(C).
66 If a large or highly complex institution is
affiliated with other IDIs, only an affiliate that is
itself a large or highly complex institution would
be eligible to seek a resolution readiness assessment
adjustment.
67 See 12 CFR 327.10(c) and (d).
68 See supra fn 16.
The proposed initial base assessment
rate schedules would remain in effect
unless and until the reserve ratio meets
or exceeds 2 percent
highly complex institution is
affiliated with other IDIs, only an affiliate that is
itself a large or highly complex institution would
be eligible to seek a resolution readiness assessment
adjustment.
67 See 12 CFR 327.10(c) and (d).
68 See supra fn 16.
The proposed initial base assessment
rate schedules would remain in effect
unless and until the reserve ratio meets
or exceeds 2 percent. In lieu of
dividends, the progressively lower
initial base assessment rate schedules
currently in the regulation would
remain unchanged for small institutions
and would come into effect without
further action by the Board when the
DIF reserve ratio at the end of the prior
assessment period reaches 2 percent and
2.5 percent, respectively.64
a. Analysis
Based on data as of December 31,
2025, a 2 basis point reduction in initial
base assessment rate schedules
applicable to banks that would meet the
proposed definition of a small
institution (generally, those under $30
billion in total assets) is estimated to
result in a decline in annual
assessments of approximately $917
million, or 7.5 percent of total annual
assessments.
2. Proposed Updates to Assessment Rate
Schedules Applied to Large and Highly
Complex Institutions
a. Proposed Reduction in Initial Base
Assessment Rates
The FDIC is also proposing to
decrease initial base deposit insurance
assessment rate schedules applicable to
large and highly complex institutions by
1 basis point, beginning upon the
effective date of any final rule.
b
assessments.
2. Proposed Updates to Assessment Rate
Schedules Applied to Large and Highly
Complex Institutions
a. Proposed Reduction in Initial Base
Assessment Rates
The FDIC is also proposing to
decrease initial base deposit insurance
assessment rate schedules applicable to
large and highly complex institutions by
1 basis point, beginning upon the
effective date of any final rule.
b. Proposed Resolution Readiness
Adjustment
The proposal would also establish a
new downward assessment rate
adjustment, the RRA, available to IDIs
that meet the proposed definition of a
large institution or that are highly
complex institutions, and that elect to
submit to testing of the institution’s
ability to populate a VDR with
information that could be used to
market a bank in the event of failure,
and/or provide the FDIC prescribed data
access, including access to an
institution’s service provider(s) and/or
internal systems, to support readiness
for the resolution of rapid failures.
In recognition of the expected
reduction in losses to the DIF in the
event of failure,65 the FDIC is proposing
to apply a downward adjustment of up
to 1 basis point to assessment rates,
available to large and highly complex
institutions that elect to participate,
including 0.5 basis points for passing
the VDR testing exercise and 0.5 basis
points for providing prescribed data
access, as described in section IV. of this
Supplementary Information.66
c
the
event of failure,65 the FDIC is proposing
to apply a downward adjustment of up
to 1 basis point to assessment rates,
available to large and highly complex
institutions that elect to participate,
including 0.5 basis points for passing
the VDR testing exercise and 0.5 basis
points for providing prescribed data
access, as described in section IV. of this
Supplementary Information.66
c. Proposed Revisions to Initial Base
Assessment Rates When the Reserve
Ratio Reaches 2 Percent and 2.5 Percent
Under the current regulation,
progressively lower initial base
assessment rate schedules applicable to
large and highly complex institutions
will come into effect when the reserve
ratio reaches 2 percent and 2.5 percent,
with minimum initial base assessment
rates declining from 5 basis points to 2
basis points and 1 basis point,
respectively.67 Under the proposal, the
minimum initial base assessment rates
applied to large and highly complex
institutions would still become
progressively lower, declining from 4
basis points to 3 basis points and to 2
basis points when the reserve ratio
reaches 2 percent and 2.5 percent,
respectively, in order to incorporate the
RRA into the assessment rate schedules.
This proposed revision to the initial
base assessment rate schedules
combined with the proposed allocation
of adjustments described below have the
result that a large or highly complex
institution at the minimum initial base
assessment rate could effectively
achieve the maximum proposed RRA.
This proposal would also maintain the
same minimum total base assessment
rates applicable to large and highly
complex institutions as the rates in the
current schedules that come into effect
when the reserve ratio reaches 2 percent
and 2.5 percent applicable to small
banks.
d
lex
institution at the minimum initial base
assessment rate could effectively
achieve the maximum proposed RRA.
This proposal would also maintain the
same minimum total base assessment
rates applicable to large and highly
complex institutions as the rates in the
current schedules that come into effect
when the reserve ratio reaches 2 percent
and 2.5 percent applicable to small
banks.
d. Proposed Allocation of Assessment
Rate Adjustments Applicable to Large
and Highly Complex Institutions
Assessment Rates
Under the current assessment
regulations, adjustments to the initial
base assessment rates of institutions are
made in the following order: (1) the
unsecured debt adjustment can reduce
an institution’s assessment rate by the
lesser of 5 basis points or 50 percent of
the institution’s initial base assessment
rate; (2) the depository institution debt
adjustment can increase an institution’s
assessment rate based on unsecured
debt held by the institution that is
issued by another depository institution;
and finally (3), the brokered deposit
adjustment can increase an institution’s
assessment rate by up to 10 basis
points.68
The FDIC is proposing that the RRA
would be applied to a large or highly
complex institution’s initial base
assessment rate first, prior to the
application of the other adjustments,
and the unsecured debt adjustment
would be limited to the lesser of 5 basis
points or 50 percent of a large or highly
complex institution’s initial base
assessment rate less any applicable
RRA. Under the proposal, the allocation
of, and limitations on, a small bank’s
rate adjustments would remain
unchanged
al base
assessment rate first, prior to the
application of the other adjustments,
and the unsecured debt adjustment
would be limited to the lesser of 5 basis
points or 50 percent of a large or highly
complex institution’s initial base
assessment rate less any applicable
RRA. Under the proposal, the allocation
of, and limitations on, a small bank’s
rate adjustments would remain
unchanged.
The proposed allocation of
adjustments—specifically, allowing for
an institution’s initial base assessment
rate to be reduced by up to the
maximum RRA of 1 basis point before
applying the unsecured debt
adjustment—would have the result that
a large or highly complex institution
that is assigned an assessment rate that
is the least risky, or the minimum initial
base assessment rate, would be able to
apply an unsecured debt adjustment of
up to 1.5 basis points when the reserve
ratio is less than 2 percent, as shown in
Table 7. This maximum unsecured debt
adjustment of 1.5 basis points would be
equal to the maximum unsecured debt
adjustment that could apply to a small
institution assigned the minimum initial
base assessment rate, and would also be
equal to the maximum unsecured debt
adjustment available prior to the 2023
increase in the rate schedules applied
while the reserve ratio is less than 2
percent.
Similarly, when the reserve ratio
exceeds 2 percent, allocating the RRA
before the unsecured debt adjustment
would result in a large or highly
complex institution that is assigned the
minimum initial base assessment rate
being able to apply up to a 1 basis point
unsecured debt adjustment, also shown
in Table 7, and on par with a small
institution assigned the minimum initial
base assessment rate.
When the reserve ratio exceeds 2.5
percent, the proposed allocation would
result in a large or highly complex
institution that is assigned the
minimum initial base assessment rate
being able to apply up to a 0.5 basis
point unsecured debt adjustment
nt
unsecured debt adjustment, also shown
in Table 7, and on par with a small
institution assigned the minimum initial
base assessment rate.
When the reserve ratio exceeds 2.5
percent, the proposed allocation would
result in a large or highly complex
institution that is assigned the
minimum initial base assessment rate
being able to apply up to a 0.5 basis
point unsecured debt adjustment. As
proposed, the 1 basis point RRA is equal
to or exceeds the maximum unsecured
debt adjustments of 1 basis point and
0.5 basis points available to large and
highly complex institutions with the
minimum initial base assessment rate in
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the schedules applied when the reserve
ratio is between 2 percent and 2.5
percent, and 2.5 percent or greater.
In absence of these revisions, the
maximum unsecured debt adjustment
that a bank at the minimum initial base
assessment rate could receive would
decrease because the adjustment is
limited to the lesser of 5 basis points or
50 percent of the bank’s initial base
assessment rate (or, in the case of the
proposal, 50 percent of the bank’s initial
base assessment rate less any applicable
RRA). For example, when the reserve
ratio is equal to or greater than 2 percent
but less than 2.5 percent, the minimum
initial base assessment rate for large and
highly complex institutions is 2 basis
points. Under the current assessments
regulations, a bank receiving the
minimum initial base assessment rate of
2 basis points would have a maximum
unsecured debt adjustment of 1 basis
point. If the same bank under the
proposal also received the full RRA of
1 basis point, its maximum unsecured
debt adjustment would decline to 0.5
basis points
e and
highly complex institutions is 2 basis
points. Under the current assessments
regulations, a bank receiving the
minimum initial base assessment rate of
2 basis points would have a maximum
unsecured debt adjustment of 1 basis
point. If the same bank under the
proposal also received the full RRA of
1 basis point, its maximum unsecured
debt adjustment would decline to 0.5
basis points.
Recognizing the significant benefit
that the issuance of unsecured debt may
have on potential losses to the DIF in
the event of a bank failure, the proposed
rate schedules would result in no
change to the maximum unsecured debt
adjustment for banks receiving the
minimum initial base assessment rate in
the rate schedules applied when the
reserve ratio exceeds 2 percent. In the
preceding example, the minimum initial
base assessment rate for large and highly
complex institutions would be 3 basis
points and the maximum unsecured
debt adjustment for a bank receiving the
minimum would remain 1 basis point.
In addition, under the proposed rate
schedules, the minimum assessment
rate after all adjustments are applied
would be the same for large and highly
complex institutions and for small
banks.
e. Timing of the Application of the
Resolution Readiness Adjustment
As further described below in section
IV. of this Supplementary Information,
to be eligible for the RRA, a large or
highly complex institution that wishes
to opt into the RRA would submit a
notice of election to the FDIC to
participate in testing of the institution’s
ability to populate a VDR and/or to
provide access to an institution’s service
provider(s) and/or internal systems to
obtain detailed bank data needed to
manage and market the bank in
receivership.
f. Timing of the Component of the RRA
for Data Access Engagement
The FDIC anticipates that the initial
round of data access engagement would
take approximately four years to
complete for large or highly complex
institutions that elect to participate
nstitution’s service
provider(s) and/or internal systems to
obtain detailed bank data needed to
manage and market the bank in
receivership.
f. Timing of the Component of the RRA
for Data Access Engagement
The FDIC anticipates that the initial
round of data access engagement would
take approximately four years to
complete for large or highly complex
institutions that elect to participate.
Under this proposal, the first 0.5 basis
points of the RRA for providing the
FDIC access to an institution’s service
provider(s) and/or internal systems to
obtain detailed bank data needed to
manage and market the bank in
receivership would be applied at the
beginning of the first full quarterly
assessment period after the date on
which the institution elects to
participate. For instance, if an
institution elected to participate on May
15, it would first be entitled to a 0.5
basis point adjustment for providing
data access in the quarterly assessment
period beginning on July 1, for which
payment would be invoiced and due in
December.
If an institution fails to follow through
on providing prescribed data access or
does not provide information or access
to personnel that the FDIC needs to
assess the data, documents, and other
materials that must be provided, the
FDIC would cease application of the 0.5
basis point adjustment beginning the
following quarterly assessment period.
If this occurs in the initial data access
engagement, the institution would be
liable to reimburse the FDIC for an
amount equal to the total amount of the
0.5 basis point component of the
adjustment for data access the
institution already received.
g. Timing of the Component of the RRA
for VDR Testing
If the institution satisfies the
requirements of the rule with respect to
the VDR test, the FDIC would generally
apply the 0.5 basis point component of
the RRA beginning in the first quarterly
assessment period after the institution
passes the VDR test
oint component of the
adjustment for data access the
institution already received.
g. Timing of the Component of the RRA
for VDR Testing
If the institution satisfies the
requirements of the rule with respect to
the VDR test, the FDIC would generally
apply the 0.5 basis point component of
the RRA beginning in the first quarterly
assessment period after the institution
passes the VDR test. However, as
described further below, the FDIC will
not initially apply the downward
adjustment until all banks have
completed the initial round of testing, to
ensure that institutions who are tested
sooner do not unfairly benefit from the
timing of the tests.
h. Retesting and Follow-Up Data Access
Engagements
Participating institutions would be
subject to periodic retesting and follow-
up data access engagements, as
described in section IV. of this
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Supplementary Information. If an
institution receives an RRA, the
institution would generally continue to
receive the adjustment for each
quarterly assessment period unless and
until the institution does not
successfully complete a future VDR test
or declines to participate in subsequent
data access engagement, at which point
the institution’s downward adjustment
for the applicable component would
cease to apply in the next quarterly
assessment period.
i. Analysis
While the reserve ratio is less than 2
percent, the minimum total base
assessment rate for large and highly
complex institutions that receive the
maximum proposed RRA would be 1.5
basis points, the same minimum that
would apply to small institutions
he institution’s downward adjustment
for the applicable component would
cease to apply in the next quarterly
assessment period.
i. Analysis
While the reserve ratio is less than 2
percent, the minimum total base
assessment rate for large and highly
complex institutions that receive the
maximum proposed RRA would be 1.5
basis points, the same minimum that
would apply to small institutions. The
proposed minimum total base
assessment rate of 1.5 basis points is 1
basis point lower than in the current
schedule and is the same as the
minimum total base assessment rate that
was applicable prior to the 2023
increase in the assessment rate schedule
in place while the reserve ratio is less
than 2 percent.
The minimum total base assessment
rates when the reserve ratio is equal to
or greater than 2 percent are the same
for small, large, and highly complex
institutions and are unchanged from the
current schedules, which were not
raised in 2023. The proposed revisions
to the assessment rate schedules are
illustrated in the tables below.
If all IDIs that meet the proposed
definition of a large institution or that
are highly complex institutions
successfully participate in and pass the
VDR exercise and provide the
prescribed data access to achieve the
maximum RRA of 1 basis point, the
RRA combined with the proposed 1
basis point reduction in initial base
assessment rates is generally estimated
to result in a decline in annual
assessments of approximately $3.4
billion, or approximately 27.8 percent of
total annual assessments, based on data
as of December 31, 2025
the
VDR exercise and provide the
prescribed data access to achieve the
maximum RRA of 1 basis point, the
RRA combined with the proposed 1
basis point reduction in initial base
assessment rates is generally estimated
to result in a decline in annual
assessments of approximately $3.4
billion, or approximately 27.8 percent of
total annual assessments, based on data
as of December 31, 2025.
While the proposed reduction in the
initial base assessment rates would be
applied beginning with the effective
date of any final rule, and the
component of the RRA associated with
data access engagement would be
applied the quarterly assessment period
following the institution’s election, the
effects of the component of the RRA
associated with the initial VDR testing
would not be applied until all
institutions who initially elect to
participate have completed testing,
which under the proposal the FDIC
would complete within one year from
the effective date of any final rule. In
addition to the staggered timing for
completion of the first cycle and
application of the adjustment, the
aggregate effect of the RRA is also
contingent on the number of large and
highly complex institutions that elect to
participate in and successfully pass the
VDR testing and provide the prescribed
data access.
Expanded analysis of the aggregate
expected effects of the proposal,
evaluation of the costs and benefits, and
consideration of the statutory factors are
included below in sections VII. and VIII.
of this SUPPLEMENTARY INFORMATION.
C. Proposed Assessment Rate Schedules
1. Proposed Assessment Rate Schedules
for Established Small Institutions and
Large and Highly Complex Institutions
Pursuant to the FDIC’s authority to set
assessments, the FDIC is proposing the
following initial base assessment rates,
adjustments, and total base assessment
rates applicable to established small
institutions and large and highly
complex institutions set forth in Table
8 below
Proposed Assessment Rate Schedules
for Established Small Institutions and
Large and Highly Complex Institutions
Pursuant to the FDIC’s authority to set
assessments, the FDIC is proposing the
following initial base assessment rates,
adjustments, and total base assessment
rates applicable to established small
institutions and large and highly
complex institutions set forth in Table
8 below.
BILLING CODE 6714–01–P
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69 In lieu of dividends, and pursuant to the FDIC’s
authority to set assessments, the progressively
lower initial base and total base assessment rates set
forth in 12 CFR 327.10(c) and (d) will come into
effect without further action by the Board when the
fund reserve ratio at the end of the prior assessment
period reaches 2 percent and 2.5 percent,
respectively.
The proposed assessment rate
schedules applicable to established
small institutions and large and highly
complex institutions in Table 8 above
would remain in effect unless and until
the reserve ratio meets or exceeds 2
percent.69
The proposed initial base assessment
rates, adjustments, and total base
assessment rates in Table 9 below
would be in effect if the reserve ratio of
the DIF as of the end of the prior
assessment period is equal to or greater
than 2 percent and less than 2.5 percent.
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ments, and total base
assessment rates in Table 9 below
would be in effect if the reserve ratio of
the DIF as of the end of the prior
assessment period is equal to or greater
than 2 percent and less than 2.5 percent.
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Federal Register / Vol. 91, No. 124 / Tuesday, June 30, 2026 / Proposed Rules
The proposed initial base assessment
rates, adjustments, and total base
assessment rates in Table 10 below
would be in effect if the reserve ratio of
the DIF as of the end of the prior
assessment period is equal to or greater
than 2.5 percent.
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Federal Register / Vol. 91, No. 124 / Tuesday, June 30, 2026 / Proposed Rules
2. Proposed Assessment Rates for New
Small Institutions
Pursuant to the FDIC’s authority to set
assessments, the proposed initial and
total base assessment rates applicable to
new small institutions set forth in Table
11 below would take effect beginning
upon the effective date of any final rule.
New small institutions would remain
subject to the assessment schedules in
Table 11, even when the reserve ratio
reaches 2 percent or 2.5 percent, until
they no longer were new depository
institutions, consistent with current
assessment regulations.
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n
subject to the assessment schedules in
Table 11, even when the reserve ratio
reaches 2 percent or 2.5 percent, until
they no longer were new depository
institutions, consistent with current
assessment regulations.
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3. Insured Branches of Foreign Banks
Pursuant to the FDIC’s authority to set
assessments, the proposed initial and
total base assessment rates applicable to
insured branches of foreign banks set
forth in Table 12 below would take
effect beginning upon the effective date
of any final rule.
BILLING CODE 6714–01–C
a. Alternatives Considered
In proposing the updates to
assessment rate schedules, the FDIC
considered a number of potential
alternatives, including maintaining the
current schedule of initial base
assessment rates, applying higher or
lower reductions to initial base
assessment rates, applying higher or
lower VDR and data access adjustments,
and modifying the assessment rate
schedules that apply when the reserve
ratio exceeds 2 percent and 2.5 percent.
The FDIC also considered how the
unsecured debt adjustment would
interact with the RRA and the impact on
the maximum unsecured debt
adjustment applicable to large and
highly complex institutions at the
minimum initial base assessment rates
and at higher rates. The unsecured debt
adjustment was adopted in recognition
that, all else equal, greater amounts of
long-term unsecured debt can reduce
the potential loss to the DIF in the event
of an IDI’s failure
teract with the RRA and the impact on
the maximum unsecured debt
adjustment applicable to large and
highly complex institutions at the
minimum initial base assessment rates
and at higher rates. The unsecured debt
adjustment was adopted in recognition
that, all else equal, greater amounts of
long-term unsecured debt can reduce
the potential loss to the DIF in the event
of an IDI’s failure. The FDIC is
proposing to adopt the RRA in
recognition that a large or highly
complex institution’s ability to both
populate a VDR with information that
could be used to market the bank in the
event of its failure and provide the FDIC
access to detailed bank data needed to
manage and market the bank in
receivership can improve resolution
efficiencies and result in a reduction in
losses to the DIF in the event of the
institution’s failure. The FDIC
recognizes that the proposed structure
creates a potential asymmetry in which
the unsecured debt adjustment can be
significantly greater than the RRA for
institutions with higher initial base
assessment rates, while the RRA would
be equal to or greater than the
unsecured debt adjustment for
institutions with the minimum initial
base assessment rate when the reserve
ratio exceeds 2 percent, and seeks
comment on this proposed structure.
Question 12: The FDIC invites
comment on the proposal to revise
deposit insurance assessment rates,
beginning with the effective date of any
final rule. How does the approach in the
proposed rule support or not support
the objectives of the FDIC’s
comprehensive, long-range management
plan for the DIF? What are the
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effective date of any
final rule. How does the approach in the
proposed rule support or not support
the objectives of the FDIC’s
comprehensive, long-range management
plan for the DIF? What are the
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70 If a large or highly complex institution is
affiliated with other IDIs, only an affiliate that is
itself a large or highly complex institution would
be eligible to seek a resolution readiness assessment
adjustment.
advantages and disadvantages of the
proposed reductions in assessment
rates? Are there alternatives the FDIC
should consider, and if so, why?
Question 13:The FDIC invites
comment on the proposed RRA. What
are the advantages and disadvantages of
implementing such an adjustment? Is
the calibration appropriate, and if not,
why?
Question 14: The FDIC additionally
invites comment on the proposed
allocation of the RRA and incorporation
into the assessment rate schedules. Are
there alternative approaches for
allocation or incorporation into the
assessment rate schedules the FDIC
should consider?
Question 15: Under the proposal, the
unsecured debt adjustment would be
limited to the lesser of 5 basis points or
half of an institution’s initial base
assessment rate less any applicable
RRA. As proposed, the 1 basis point
RRA equals or exceeds the maximum
unsecured debt adjustments of 1 basis
point and 0.5 basis points available to
large and highly complex institutions
with the minimum initial base
assessment rate in the schedules
applied when the reserve ratio is
between 2 percent and 2.5 percent, and
2.5 percent or greater. The FDIC invites
comment on the relative allocation of
these adjustments. Are there are
alternative allocations or limitations the
FDIC should consider?
IV
t and 0.5 basis points available to
large and highly complex institutions
with the minimum initial base
assessment rate in the schedules
applied when the reserve ratio is
between 2 percent and 2.5 percent, and
2.5 percent or greater. The FDIC invites
comment on the relative allocation of
these adjustments. Are there are
alternative allocations or limitations the
FDIC should consider?
IV. Resolution Readiness Adjustment
Under the proposed rule, the FDIC
would apply a downward resolution
readiness adjustment to the assessment
rate of a large or highly complex
institution that elects to (1) submit to
testing of the institution’s ability to
populate a VDR (VDR test) with
information that could be used to
market the bank in the event of its
failure (VDR component) and/or (2)
provide the FDIC access to an
institution’s service provider(s) and/or
internal systems if the institution
maintains its own proprietary data
systems, to obtain detailed bank data
needed to manage and market the bank
in receivership (data access
component).70 The proposed RRA
would be comprised of a 0.5 basis point
adjustment for successfully passing a
VDR test (VDR adjustment) and a 0.5
basis point adjustment for completing
the data access component (data access
adjustment) in recognition of the
expected reduction in losses to the DIF
in the event of the failure of an
institution that participates and
completes both components.
A. Background
A large or highly complex
institution’s ability to quickly populate
a VDR with complete, timely, and
accurate information can be key to
ensuring that the FDIC receives high
quality bids in the event of the
institution’s failure, which would
reduce the likely amount of loss to the
DIF. From a marketing standpoint, an
institution’s ability to quickly populate
a VDR is critical to ensuring necessary
information on unique business lines
can be supplied in a timely manner for
bidders to evaluate the institution’s
franchise
o
ensuring that the FDIC receives high
quality bids in the event of the
institution’s failure, which would
reduce the likely amount of loss to the
DIF. From a marketing standpoint, an
institution’s ability to quickly populate
a VDR is critical to ensuring necessary
information on unique business lines
can be supplied in a timely manner for
bidders to evaluate the institution’s
franchise. Better information for bidders
when marketing a franchise increases
bid quality which, in turn, increases the
likelihood that a failed bank will be
acquired over the course of the weekend
immediately following its entry into
receivership. This also decreases the
likelihood of needing to operate the
bank as a bridge depository institution,
which can further erode franchise value
and increase costs to the DIF.
While having the ability to quickly
populate a VDR is important for the
rapid marketing and sale of a failed
institution, directly accessing data from
the institution’s systems and/or its
service provider(s), as applicable, would
allow the FDIC to build out internal
FDIC infrastructure to enable the FDIC
to receive and process necessary data in
the event of an institution’s rapid
failure. Additionally, the data would
further enhance the quality and
robustness of the information provided
to potential bidders and enable the FDIC
to more effectively operate an eventual
receivership or, if needed, a bridge
depository institution.
B. Election Process
Under the proposed rule, a large or
highly complex institution that wishes
to opt into the RRA would submit a
notice of its election or elections to the
FDIC. An institution’s election would
include certain information needed by
the FDIC for the elected component or
components. To support the VDR
component, the institution’s notice of
election would provide the FDIC with
the contact information of the
institution’s personnel with whom the
FDIC should engage prior to the VDR
test
would submit a
notice of its election or elections to the
FDIC. An institution’s election would
include certain information needed by
the FDIC for the elected component or
components. To support the VDR
component, the institution’s notice of
election would provide the FDIC with
the contact information of the
institution’s personnel with whom the
FDIC should engage prior to the VDR
test. To support the data access
component, the institution’s notice of
election would provide the FDIC a
complete list of all systems and
applications maintained by itself and/or
third-party vendor(s) that serve as core
data processors for deposit and loan
data and the institution’s general ledger,
and a list of key personnel (including
personnel of third-party vendors)
needed to support and operate such
systems and applications. The
institution would also authorize the
FDIC to communicate with, and request
data from, its third-party vendors and
acknowledge that any costs required to
obtain any necessary data would be
borne by the institution. The institution
would be able to opt in to one of or both
components of the RRA as part of its
election, whether it be one election
submission or two.
An institution that is a large or highly
complex institution as of the effective
date of any final rule would submit a
notice of election to the FDIC within 30
days of the effective date of the rule.
Such an institution would be eligible to
receive a data access adjustment
beginning in the assessment period
following the institution’s election, and
would be eligible to receive a VDR
adjustment beginning in the assessment
period one year after the effective date
of the final rule if the institution passes
the VDR test.
Following the end of this 30-day
period, institutions would still be able
to make an election at any time
receive a data access adjustment
beginning in the assessment period
following the institution’s election, and
would be eligible to receive a VDR
adjustment beginning in the assessment
period one year after the effective date
of the final rule if the institution passes
the VDR test.
Following the end of this 30-day
period, institutions would still be able
to make an election at any time.
However, the FDIC would not conduct
a VDR test of such an institution until
after all institutions who initially opted
in completed VDR tests, and the
institution’s VDR adjustment would not
be available until after completing the
VDR test. Additionally, an institution
that is a large or highly complex
institution on the effective date of the
final rule that does not opt in to the data
access component during the initial 30
days, but does opt in to the data access
component within the initial four year
period subsequent to the expiration of
the initial 30 day period, will not
receive the adjustment until two
quarters after the end of the quarter in
which the election is made, to
discourage institutions from delaying
making an election.
An institution that becomes a large or
highly complex institution after the
effective date of any final rule would be
eligible to submit a resolution readiness
adjustment election notice to the FDIC
upon becoming a large or highly
complex institution. Such an institution
would be eligible to receive a data
access adjustment beginning in the
quarterly assessment period following
the institution’s election, and would be
eligible to receive a VDR adjustment
beginning in the quarterly assessment
period after the institution passes the
VDR test. Such an institution would not,
however, receive the VDR adjustment
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g
the institution’s election, and would be
eligible to receive a VDR adjustment
beginning in the quarterly assessment
period after the institution passes the
VDR test. Such an institution would not,
however, receive the VDR adjustment
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71 The FDIC would generally delete data shortly
after concluding the test.
until the initial round of VDR testing is
complete.
If an institution’s notice of election for
the data access component contains
materially inaccurate information or the
institution does not provide required
information in its notice of election, the
FDIC may notify the institution that it
is no longer eligible for the data access
adjustment. In that case, the data access
adjustment would be removed
beginning the next quarterly assessment
period, and the institution would be
liable to reimburse the FDIC for an
amount equal to the amount of data
access adjustment the institution
received. The institution could seek to
resume eligibility for the data access
adjustment by submitting another notice
of election.
C. VDR Test
In order to demonstrate its ability to
adequately populate a VDR, a large or
highly complex institution must be able
to provide information under the below
categories in a VDR set up by the FDIC
within 48 hours of a request.71 These
categories of information reflect the data
and information that potential bidders
have identified as most useful for
conducting due diligence, especially
when there is a short runway to an
institution’s failure:
1. Key financial information,
including balance sheets, income
statements, general ledgers (both
consolidated and unconsolidated), and
other relevant financial information;
2
e
categories of information reflect the data
and information that potential bidders
have identified as most useful for
conducting due diligence, especially
when there is a short runway to an
institution’s failure:
1. Key financial information,
including balance sheets, income
statements, general ledgers (both
consolidated and unconsolidated), and
other relevant financial information;
2. Deposit data and information,
including deposit tapes and data
dictionary, and a report regarding key
depositors (including key depositors by
name and business segment, the amount
of each key depositor’s deposits, and a
list of other services provided to such
key depositors), though existing
management reports are acceptable;
3. Loan and lending data and
information, including loan tapes and
data dictionary, and a report regarding
key loan relationships (including key
loan relationships by name and business
segment, the amount of each
outstanding loan of each key loan
relationship, and a list of other services
provided to such key loan
relationships), though existing
management reports are acceptable;
4. A sample of imaged loan files
sufficient for a potential bidder to
conduct due diligence to inform a
potential bid;
5. Securities and investment portfolio
information, including securities tapes
and data dictionary;
6. A corporate organizational chart
showing all financially or operationally
significant entities, as well as a
description of each of these entity’s
operations and role within the
institution’s operations, and licensing
and regulatory information for each
entity;
7. A list of key personnel identified by
title, function, physical location,
employing legal entity, and business
line or business segment the individual
supports, and if an individual is ‘‘dual
hatted’’ at the institution and at one or
more of its affiliates;
8. A list of material third-party
contracts and a description of what
services or business lines each contract
supports;
9
ity;
7. A list of key personnel identified by
title, function, physical location,
employing legal entity, and business
line or business segment the individual
supports, and if an individual is ‘‘dual
hatted’’ at the institution and at one or
more of its affiliates;
8. A list of material third-party
contracts and a description of what
services or business lines each contract
supports;
9. Recent key internal risk
management reports, such as
assessments concerning credit, capital,
liquidity, risk governance risks; and
10. Other information the institution
believes is necessary to facilitate a rapid
and effective due diligence process for
the sale of the institution, as well as
data or information requested by the
FDIC in its notice concerning the timing
of the institution’s VDR test that is not
covered by other items listed above.
FDIC resolution experience has
shown that VDRs that can be quickly
and accurately populated with key
financial data and operational
information are necessary for bidder due
diligence and results in more and
higher-quality bids.
1. Initial Timing of VDR Test
The FDIC anticipates that the initial
round of VDR tests for institutions that
are large or highly complex as of the
effective date of the final rule would
take up to one year from the effective
date of the final rule. The FDIC would
notify an institution not less than four
weeks in advance of when it would
conduct the VDR test, and on the date
of the test, the institution would have 48
hours to populate the VDR.
2
initial
round of VDR tests for institutions that
are large or highly complex as of the
effective date of the final rule would
take up to one year from the effective
date of the final rule. The FDIC would
notify an institution not less than four
weeks in advance of when it would
conduct the VDR test, and on the date
of the test, the institution would have 48
hours to populate the VDR.
2. Satisfaction of VDR Test
The institution would be considered
to have satisfied the VDR test if (1) all
of the required documents, data and
information are uploaded to the virtual
data room within 48 hours after the test
begins, (2) the FDIC determines that the
information and data uploaded is
sufficient for a potential bidder to
conduct adequate due diligence to
inform a potential bid, including that
the financial information provided is
consistent with the general ledger, and
(3) the institution provides the FDIC
such information and access to such
personnel of the institution as the FDIC
in its discretion determines is relevant
to properly evaluate the documents and
information uploaded to the VDR.
3. Results of VDR Test and Application
of VDR Adjustment
The FDIC will notify the institution in
writing concerning the results of its test.
If the institution has satisfied the
requirements of the rule with respect to
the VDR test, it will be entitled to a VDR
adjustment. The FDIC would retest an
institution’s capabilities with respect to
the VDR test once every three years. In
certain circumstances, such as when the
FDIC determines that it can access
certain important information in a
timely manner in connection with data
access engagement, the FDIC may waive
aspects of future VDR tests. The FDIC
would provide an institution with not
less than four weeks’ notice if it plans
to retest an institution’s VDR population
capabilities. The FDIC may extend the
timeline to more than three years at its
discretion
determines that it can access
certain important information in a
timely manner in connection with data
access engagement, the FDIC may waive
aspects of future VDR tests. The FDIC
would provide an institution with not
less than four weeks’ notice if it plans
to retest an institution’s VDR population
capabilities. The FDIC may extend the
timeline to more than three years at its
discretion. The FDIC may do so if, for
example, there is an increase in bank
failures resulting in increased resources
devoted to resolution activity. If an
institution has experienced material
changes with respect to its ability to
populate a data room, such as
undergoing a merger, the FDIC may
conduct a retest in less than three years
at its discretion. If the institution does
not satisfy the requirements of the VDR
test, the FDIC may offer the institution
an opportunity to retake the test not less
than one month after the initial test.
If the institution receives a 0.5 basis
point adjustment for successfully
completing the VDR test, the institution
will continue to receive the adjustment
for each quarterly assessment period
unless and until the institution does not
successfully complete a future VDR test,
at which point the institution’s
downward adjustment would cease to
apply in the next quarterly assessment
period.
Under the proposal, because the VDR
component is intended to incentivize
banks to maintain the ability to produce
robust information within a 48-hour
timeframe, an institution would not be
able to receive partial credit if it is able
to produce the required data in a period
longer than 48 hours, or if the
institution is able to produce some but
not all of the content required. The FDIC
is seeking comment on whether partial
credit should be offered.
D
ntivize
banks to maintain the ability to produce
robust information within a 48-hour
timeframe, an institution would not be
able to receive partial credit if it is able
to produce the required data in a period
longer than 48 hours, or if the
institution is able to produce some but
not all of the content required. The FDIC
is seeking comment on whether partial
credit should be offered.
D. Data Access
As discussed above, a large or highly
complex institution will be entitled to
the data access adjustment beginning in
the first full assessment period after the
date on which the institution submits its
notice of election.
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72 The FDIC would generally delete data shortly
after concluding the engagement.
1. Initial Timing of Data Access
Engagement
The FDIC anticipates that the initial
round of engagement with respect to the
data access component for electing
institutions that are large or highly
complex as of the effective date of the
final rule would take four years from
this date and therefore believes it
appropriate to grant the data access
adjustment upon submission of a notice
of election rather than require
institutions to wait until every
institution has completed the process
before applying adjustments.
Furthermore, the FDIC believes it is
generally unlikely an institution that
elects to participate in the data access
component will fail to ultimately
qualify for the data access adjustment.
An institution that elects to
participate in the data access
component would be required to
facilitate the FDIC’s access to its data
service provider(s) and/or any internal
data systems
adjustments.
Furthermore, the FDIC believes it is
generally unlikely an institution that
elects to participate in the data access
component will fail to ultimately
qualify for the data access adjustment.
An institution that elects to
participate in the data access
component would be required to
facilitate the FDIC’s access to its data
service provider(s) and/or any internal
data systems. As noted above, the
purpose of data access engagement by
the FDIC would be to allow the FDIC to
engage with service provider(s) and/or
institution personnel to build out
internal FDIC infrastructure to enable
the FDIC to receive and process
necessary data in the event of an
institution’s rapid failure. Specifically,
the FDIC would seek access to such data
service provider(s) and/or internal data
systems in order to access and process
the following data:72
1. The institution’s consolidated and
unconsolidated ledger;
2. Core data regarding the institution’s
deposit portfolio, including:
a. Depositor and beneficiary
information;
b. Deposit account title;
c. Deposit account type;
d. Deposit account balances,
including principal and accrued
interest;
e. Deposit account status;
f. Deposit account rate terms; and
g. Any other information about
material characteristics of deposits;
3. Core data concerning the
institution’s loan portfolio, including:
a. Borrower, co-borrower, and
guarantor information;
b. Loan balances, including charge
offs;
c. Participation information;
d. Loan status;
e. Loan terms;
f. Loan type;
g. Collateral associated with each
loan; and
h. Any other information about
material characteristics of loans;
4. A list of key personnel (including
those employed by third-party vendors)
needed to support and operate each
system and application used to produce
data, information, and other materials
listed above identified by name, title,
employer, telephone number, and email
address
;
g. Collateral associated with each
loan; and
h. Any other information about
material characteristics of loans;
4. A list of key personnel (including
those employed by third-party vendors)
needed to support and operate each
system and application used to produce
data, information, and other materials
listed above identified by name, title,
employer, telephone number, and email
address.
If an institution fails to follow through
on providing prescribed data access or
does not provide information or access
to personnel that the FDIC needs to
assess the data, documents, and other
materials that must be provided, the
FDIC would cease application of the
adjustment beginning the following
quarterly assessment period. If this
occurs during the initial data access
engagement, the institution would be
liable to reimburse the FDIC for an
amount equal to the amount of data
access adjustment the institution
received.
After the initial engagement, the
institution must notify the FDIC within
30 days of any material changes to its
internal data systems or data service
providers that made the FDIC’s prior
engagement with respect to data access
no longer relevant, such as when an
institution engages a new data service
provider with respect to the data that
the FDIC would seek to collect in the
event of the institution’s failure. The
FDIC anticipates that such notices
would be rare. Failure to provide notice
of material change may result in the
data access adjustment being removed
in the following assessment period and,
potentially, liability for repayment if
discovered after multiple assessment
periods.
The FDIC will conduct follow-up
engagements every seven years, except
that the FDIC may (1) extend the
timeline at its discretion or (2) conduct
a follow-up engagement sooner than
seven years in the event of a material
change to an internal data system or
data service provider
ng assessment period and,
potentially, liability for repayment if
discovered after multiple assessment
periods.
The FDIC will conduct follow-up
engagements every seven years, except
that the FDIC may (1) extend the
timeline at its discretion or (2) conduct
a follow-up engagement sooner than
seven years in the event of a material
change to an internal data system or
data service provider. The FDIC would
provide an institution with not less than
four weeks’ notice if it chooses to
conduct a new engagement concerning
an institution’s data access capabilities.
If the institution qualifies for the data
access adjustment after the first
engagement, and then declines to
participate in subsequent engagement,
the data access adjustment will be
removed in the assessment period
following receipt of notice that it
declines to participate, and the
institution would not be liable to
reimburse the FDIC.
Question 16: Please describe and
quantify the costs that large and highly
complex institutions would expect to
incur in seeking the RRA? If possible,
please delineate costs by VDR test and
data access engagement.
Question 17: Do commenters believe
that the amount of the RRA is
appropriately calibrated to recognize
the potential reduction in losses to the
DIF in the event of a large or highly
complex institution’s failure? If not,
what would be a more appropriate
calibration and why?
Question 18: Do commenters believe
that the proposed rule asks for large and
highly complex institutions to provide
the correct set of data for a VDR test?
What, if any, alternative data and
information would potential bidders
want access to in connection with the
marketing of a failed bank and why?
What other information in the
possession of a large or highly complex
institution would help facilitate
competitive, high-quality bids? Should
any of the data or information items
requested under the proposal for
purposes of the VDR test be removed
under any final rule and, if so, why?
Would this set
ntial bidders
want access to in connection with the
marketing of a failed bank and why?
What other information in the
possession of a large or highly complex
institution would help facilitate
competitive, high-quality bids? Should
any of the data or information items
requested under the proposal for
purposes of the VDR test be removed
under any final rule and, if so, why?
Would this set of data benefit from more
or less prescription in the rule and why?
Question 19: What, if any, other data
would be useful to potential bidders,
help improve the marketing process for
a failed institution, or be useful to
operate the institution if the FDIC is
unable to solicit adequate bids over
resolution weekend? Would this set of
data benefit from more or less
prescription in the rule and why?
Question 20: Does the information
that must be populated in a VDR and
to which access would be provided
under the proposed rule overlap with
information that is otherwise provided
by large and highly complex institutions
to the FDIC or information that is
otherwise publicly available?
Question 21: Is the information that
would be required to be submitted with
respect to the election notice
appropriate and sufficient to provide
the FDIC an understanding of the
institution’s information technology
systems in order to aid the FDIC in
conducting testing under the proposed
rule? What, if any, other information
should a large or highly complex
institution provide when seeking an
adjustment?
Question 22: Are the timelines for the
initial VDR test and data access
engagement appropriate and, if not,
why? What alternative timeframe, if any,
would be more appropriate to ensure
sufficient time for the FDIC to conduct
testing under the proposed rule?
Question 23: To what extent would an
appeals process be beneficial for
situations in which the FDIC denies all
or part of the resolution readiness
adjustment?
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lternative timeframe, if any,
would be more appropriate to ensure
sufficient time for the FDIC to conduct
testing under the proposed rule?
Question 23: To what extent would an
appeals process be beneficial for
situations in which the FDIC denies all
or part of the resolution readiness
adjustment?
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73 See 12 U.S.C. 1817(e)(3). See also 71 FR 61374
(Oct. 18, 2006).
74 90 FR 55240 (Dec. 1, 2025).
75 See supra fn 45.
76 See supra fn 50.
77 See supra fn 23.
Question 24: Should an institution be
liable to reimburse the FDIC for an
amount equal to the amount of the data
access component of the RRA in the
event that the institution elects to opt in
but is subsequently notified that it failed
to provide the prescribed data access?
Should the application of the 0.5 basis
point component of the RRA for
satisfying the requirements of the data
access engagement be applied after the
engagement is completed and the
institution is notified of their eligibility?
If so, how would that be implemented?
Question 25: Should the proposal
provide a partial adjustment for
institutions that satisfy some, but not
all, of the requirements of the VDR test?
If so, how should the FDIC calibrate any
partial adjustment? Should the FDIC
consider partial credit of the VDR
adjustment to be divided between a
timeliness and information
subcomponent? If so, what is an
appropriate scoring for partial credit in
each category?
Question 26: Do commenters believe
that the categories of information
requested with respect to the VDR test
are sufficiently clear? Do institutions
have existing internal management
reports that could be used to populate
a VDR, even on a partial basis, without
having to generate additional reports
and, if so, which types of existing
internal
scoring for partial credit in
each category?
Question 26: Do commenters believe
that the categories of information
requested with respect to the VDR test
are sufficiently clear? Do institutions
have existing internal management
reports that could be used to populate
a VDR, even on a partial basis, without
having to generate additional reports
and, if so, which types of existing
internal management reports could be
leveraged by institutions?
V. Other Proposed Amendments to Part
327
A. Conforming Amendments to the
Assessment Regulations
The FDIC also is proposing
conforming amendments to sections
327.8, 327.10, and 327.16 of the
assessment regulations to effectuate the
modifications described above. These
conforming amendments would ensure
that the proposed updates to the
definitions, thresholds, and assessment
rate schedules are properly incorporated
into the assessments regulation
provisions governing the calculations of
an IDI’s quarterly deposit insurance
assessment. The FDIC is proposing
revisions to section 327.10 to reflect the
assessment rate schedules that would be
applicable before and after the effective
date of any final rule.
The FDIC is also proposing to revise
the uniform amounts for small banks
and insured branches of foreign banks
in sections 327.16(a) and (d),
respectively, to reflect the proposed 2
basis point decrease in initial base
assessment rate schedules applicable to
these institutions.
B. Technical Amendments to the
Assessment Regulations To Remove
Obsolete Provisions
The FDIC is proposing other technical
amendments to its regulations governing
deposit insurance assessments to
remove obsolete provisions. Removal of
these provisions, described below, will
neither affect deposit insurance
assessments nor result in new
requirements for IDIs.
1
le to
these institutions.
B. Technical Amendments to the
Assessment Regulations To Remove
Obsolete Provisions
The FDIC is proposing other technical
amendments to its regulations governing
deposit insurance assessments to
remove obsolete provisions. Removal of
these provisions, described below, will
neither affect deposit insurance
assessments nor result in new
requirements for IDIs.
1. Surcharges and Assessments
Required To Raise the Reserve Ratio of
the DIF to 1.35 Percent in Section
327.11
As a technical change, the FDIC is
proposing to rescind in its entirety 12
CFR 327.11 which includes provisions
relating to surcharges and assessments
required to raise the reserve ratio of the
DIF to 1.35 percent that are no longer
applicable.
2. Prepayment of Quarterly Risk-Based
Assessments in 12 CFR 327.12
As a technical change, the FDIC is
rescinding in its entirety 12 CFR 327.12,
which includes provisions relating to
the prepayment of quarterly risk-based
assessments that are no longer
applicable.
3. Implementation of One-Time
Assessment Credit in 12 CFR part 327
Subpart B
As a technical change, the FDIC is
proposing to rescind in its entirety 12
CFR 327 Subpart B which implemented
a one-time assessment credit required
by section 7(e)(3) of the FDI Act.73
VI. Reporting
In December 2025, the FDIC, the
Office of the Comptroller of the
Currency, and the Board of Governors of
the Federal Reserve System (the
agencies), issued a Request for
Information on Streamlining the Call
Report.74 The request offered the
opportunity for interested stakeholders
to identify ways that the agencies could
streamline the Call Report forms and
instructions while still meeting the
purposes of the collection.
The agencies received several
comments in response to the request
addressing the collection of data on
Schedule RC–O—Other Data for Deposit
Insurance Assessments
g the Call
Report.74 The request offered the
opportunity for interested stakeholders
to identify ways that the agencies could
streamline the Call Report forms and
instructions while still meeting the
purposes of the collection.
The agencies received several
comments in response to the request
addressing the collection of data on
Schedule RC–O—Other Data for Deposit
Insurance Assessments. Many of the
comments on Schedule RC–O addressed
line items that are used in the
calculation of deposit insurance
assessments for small, large, and highly
complex institutions. Revisions to such
line items would generally require
changes to the risk-based pricing
methodologies in the assessment
regulations. The FDIC continues to
consider the comments received
addressing line items on Schedule RC–
O and is considering addressing those
comments through a potential future
proposal to amend risk-based deposit
insurance pricing methodologies in the
assessment regulations.
VII. Statutory Considerations and
Expected Effects
A. Background
In setting assessment rates, the FDIC
is required by statute to consider the
following factors:
(i) The estimated operating expenses
of the DIF.
(ii) The estimated case resolution
expenses and income of the DIF.
(iii) The projected effects of the
payment of assessments on the capital
and earnings of IDIs.
(iv) The risk factors and other factors
taken into account pursuant to section
7(b)(1) of the FDI Act (12 U.S.C.
1817(b)(1)) under the risk-based
assessment system, including the
requirement under such section to
maintain a risk-based system.75
case resolution
expenses and income of the DIF.
(iii) The projected effects of the
payment of assessments on the capital
and earnings of IDIs.
(iv) The risk factors and other factors
taken into account pursuant to section
7(b)(1) of the FDI Act (12 U.S.C.
1817(b)(1)) under the risk-based
assessment system, including the
requirement under such section to
maintain a risk-based system.75
(v) Other factors the FDIC has
determined to be appropriate.76
For purposes of statutory
considerations and expected effects, the
FDIC based its analysis on data as of
December 31, 2025, including data from
the Call Report and FFIEC 002 for the
reporting period that ended December
31, 2025, reported as of February 16,
2026.
B. Deposit Insurance Fund Expenses
and Income
As of December 31, 2025, the DIF
balance totaled $153.9 billion, an
increase of $16.8 billion from the
previous year. Since second quarter
2023, the DIF balance has steadily
increased, primarily from assessments
earned. Assessments earned totaled $13
billion for 2025. The weighted average
assessment rate was approximately 5.6
basis points as of December 31, 2025, up
1.8 basis points from the weighted
average assessment rate of 3.8 basis
points for the assessment period ending
June 30, 2022, just prior to the adoption
of the 2022 final rule implementing a
uniform increase in initial base deposit
insurance assessment rate schedules of
2 basis points.77 Net investment income
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ts for the assessment period ending
June 30, 2022, just prior to the adoption
of the 2022 final rule implementing a
uniform increase in initial base deposit
insurance assessment rate schedules of
2 basis points.77 Net investment income
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78 Estimated losses do not include amounts
associated with the special assessment to recover
estimated losses attributable to protecting
uninsured depositors pursuant to the systemic risk
determination announced following the failures of
Silicon Valley Bank and Signature Bank in March
2023. The FDIC is required by statute to recover
such losses through a special assessment. See 12
U.S.C. 1823(c)(4)(G)(ii). See also 88 FR 83329 (Nov.
29, 2023) and 90 FR 59369 (Dec. 19, 2025).
79 Loss estimates for failures that occurred
between 2023 through 2026 as of March 31, 2026.
FDIC BankFind Suite: Bank Failures & Assistance
Data, available at: https://banks.data.fdic.gov/
bankfind-suite/failures. See also ‘‘Anchor Bank
Assumes Insured Deposits of Community Bank and
Trust—West Georgia, LeGrange, Georgia,’’ May 1,
2026, available at: https://www.fdic.gov/news/press-
releases/2026/anchor-bank-assumes-insured-
deposits-community-bank-and-trust-west-georgia.
80 ‘‘Problem’’ institutions are institutions with a
CAMELS composite rating of ‘‘4’’ or ‘‘5’’ due to
financial, operational, or managerial weaknesses
that threaten their continued financial viability.
further added to the DIF balance,
totaling $4.8 billion for 2025.
Operating expenses partially offset
increases in the DIF balance, ranging
between $497 million and $666 million
on a quarterly basis for the past three
years. Full-year operating expenses were
$2.4 billion for 2025, unchanged from
2024
operational, or managerial weaknesses
that threaten their continued financial viability.
further added to the DIF balance,
totaling $4.8 billion for 2025.
Operating expenses partially offset
increases in the DIF balance, ranging
between $497 million and $666 million
on a quarterly basis for the past three
years. Full-year operating expenses were
$2.4 billion for 2025, unchanged from
2024.
Losses from bank failures, or case
resolution expenses, represent the
largest potential expenses of the DIF.
Except for 2023, the DIF has
experienced low losses since 2016.
Between 2016 and 2022, three banks per
year failed, at an average annual cost to
the DIF of about $177 million. In 2023,
five banks failed with estimated losses
to the DIF of $18.0 billion, excluding
losses that are being recovered through
the special assessment.78 Since 2023, six
institutions have failed as of May 2026,
with an estimated cost to the DIF of
$928 million.79
The total number of institutions on
the FDIC’s Problem Bank List was 60 at
the end of the fourth quarter of 2025, up
by a net of three institutions from the
previous quarter.80 The number of
problem banks represented 1.4 percent
of total banks in the fourth quarter of
2025, which is in the normal range of
1 to 2 percent for non-crisis periods.
While future losses to the DIF are
highly uncertain, FDIC-insured
institutions reported strong earnings in
2025. Loan growth accelerated in 2025,
as did domestic deposit growth. Asset
quality metrics remained favorable
overall despite continued weakness in
certain portfolios. Unrealized losses
reported by banks continued to decline
from the second quarter 2022 peak but
remained elevated relative to historical
conditions. The banking industry
continued to have strong capital and
liquidity levels, which support lending
and protect against potential losses
growth. Asset
quality metrics remained favorable
overall despite continued weakness in
certain portfolios. Unrealized losses
reported by banks continued to decline
from the second quarter 2022 peak but
remained elevated relative to historical
conditions. The banking industry
continued to have strong capital and
liquidity levels, which support lending
and protect against potential losses.
As shown in Table 13 below, the DIF
balance has risen steadily since fourth
quarter 2022, just prior to the 2 basis
point increase in assessment rate
schedules. Over the period from the
fourth quarter 2022 to fourth quarter
2025, growth in the DIF balance
outpaced growth in estimated insured
deposits, resulting in continued growth
in the reserve ratio—DIF balance as a
percentage of estimated insured
deposits. As previously noted, the
reserve ratio further increased to 1.43
percent on March 31, 2026, up 15 basis
points from the year-end 2024 and 28
basis points from year-end 2023.
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C. Projections for DIF Balance, Insured
Deposits, and Reserve Ratio
In developing the proposal, the FDIC
projected how changes to the threshold
used to define small and large
institutions and to rate schedules would
affect assessment revenue and therefore
growth in the DIF balance and reserve
ratio, including when the reserve ratio
would reach 2 percent. These
projections assume the continuation of
current trends, including low to
moderate losses from bank failures, and
do not contemplate a significant
downturn in banking or economic
conditions. Projections also assume no
change in bank behavior
ld
affect assessment revenue and therefore
growth in the DIF balance and reserve
ratio, including when the reserve ratio
would reach 2 percent. These
projections assume the continuation of
current trends, including low to
moderate losses from bank failures, and
do not contemplate a significant
downturn in banking or economic
conditions. Projections also assume no
change in bank behavior. For example,
changes to assessment rates and pricing
methodologies because of the proposal
may motivate banks to adjust their risk
profiles or practices, including changes
to borrowing rates, deposits rates, or
service fees. Any potential adjustments
to bank behavior are unknown and
therefore not incorporated into
projections.
The projections generally assume that
changes to the definitions of small and
large institutions and decreases to
assessment rate schedules take effect at
the beginning of 2027. Projections
further assume that 75 percent of large
and highly complex institutions elect to
participate and receive assessment rate
adjustments of 0.5 basis points for the
data access component of the RRA and
0.5 basis points for the VDR testing
component of the RRA beginning in
2027 and 2028, respectively. The FDIC
believes these are reasonable
assumptions given the expected cost of
initial and continued participation in
the proposed engagement relative to the
proposed assessment benefit.
In total, the FDIC projects a decline in
assessment revenue of $3.7 billion in
2027 and $22.6 billion, cumulatively,
through 2031, as shown in Chart 1. By
2031, the DIF balance would be reduced
by about $24.6 billion under the
proposal, which includes reduced
investment income resulting from the
decrease in assessment revenue.
As a result of the reduced DIF balance
relative to the baseline, the reserve ratio
would rise under the proposal but at a
slower pace than the baseline. Under
the baseline, the reserve ratio is
projected to reach the current DRR by
the end of 2031, as shown in Chart 2
6 billion under the
proposal, which includes reduced
investment income resulting from the
decrease in assessment revenue.
As a result of the reduced DIF balance
relative to the baseline, the reserve ratio
would rise under the proposal but at a
slower pace than the baseline. Under
the baseline, the reserve ratio is
projected to reach the current DRR by
the end of 2031, as shown in Chart 2.
Under the proposal, the reserve ratio is
projected to be 1.85 percent at the end
of 2031 and would reach the 2 percent
DRR in 2035.
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81 Equity capital is defined as capital (stock and/
or surplus earnings) that is free of debt, calculated
as assets less liabilities.
82 Annual income is assumed to equal income
from January 1, 2025, through December 31, 2025,
adjusted for mergers.
83 Profitable institutions are defined as those
having positive merger-adjusted income before
taxes for the 12 months ending December 31, 2025.
Analysis excludes nine insured branches of foreign
banks and three institutions that reported an
assessment base of zero as of December 31, 2025,
as their estimated annual change in assessments as
a percentage of income would be zero. Of the
remaining 4,333 IDIs, 230 were unprofitable based
Continued
D. Projected Effects on Capital and
Earnings
Consistent with section 7(b)(2)(B) of
the FDI Act, the analysis that follows
estimates the annual effect on equity
capital and earnings of IDIs from the
proposal
o as of December 31, 2025,
as their estimated annual change in assessments as
a percentage of income would be zero. Of the
remaining 4,333 IDIs, 230 were unprofitable based
Continued
D. Projected Effects on Capital and
Earnings
Consistent with section 7(b)(2)(B) of
the FDI Act, the analysis that follows
estimates the annual effect on equity
capital and earnings of IDIs from the
proposal. Specifically, the analysis
considers the effects from raising the
threshold defining a small institution
and a large institution from $10 billion
to $30 billion, decreasing initial base
assessment rate schedules by 2 basis
points for small institutions and by 1
basis point for large and highly complex
institutions, and implementing the
proposed RRA applicable to large and
highly complex institutions.81
Data as of December 31, 2025, are
used to calculate each bank’s
assessment base and risk-based
assessment rate, absent the proposed
changes. In 2025, the industry reported
full-year net income of $295.6 billion,
up $27.5 billion from full-year 2024.
The industry’s ROA increased to 1.20
percent from 1.12 percent the year prior.
The increase was driven by higher net
interest and noninterest income, which
offset higher noninterest expense.
For institutions that would experience
a change in assessment rates under the
proposal, the immediate financial
impact would be either (1) a decrease in
assessment expense and a
corresponding increase in pre-tax
income; or (2) an increase in assessment
expense and a corresponding decrease
in pre-tax income. To avoid the
possibility of underestimating effects on
bank earnings or capital, the analysis
also assumes that the effects of the
proposal are not transferred to
customers in the form of changes in
borrowing rates, deposit rates, or service
fees.
A banking organization’s earnings
retention and dividend policies
influence the extent to which changes in
assessments affect equity levels
. To avoid the
possibility of underestimating effects on
bank earnings or capital, the analysis
also assumes that the effects of the
proposal are not transferred to
customers in the form of changes in
borrowing rates, deposit rates, or service
fees.
A banking organization’s earnings
retention and dividend policies
influence the extent to which changes in
assessments affect equity levels. If an
IDI maintains the same dollar amount of
dividends when it recognizes the
assessment expense, equity (retained
earnings) will be
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