Our Position

Deposit Insurance


  • Our nation’s federal deposit insurance system is critical to depositor confidence in the banking system, to the protection of small depositors, and to the funding base of community banks. A strong Deposit Insurance Fund (DIF) is important to maintaining public confidence that the FDIC has adequate resources to protect the nation’s depositors.

  • ICBA commends the FDIC for remaining flexible during the pandemic and establishing a Deposit Insurance Fund Restoration Plan that provides until September 30, 2028 to restore the DIF reserve ratio to 1.35percent. This will allow deposits to return to pre-pandemic levels without increasing insurance assessments.

  • ICBA supported S. 2155 which ensures that reciprocal deposits are not considered brokered deposits under the Federal Deposit Insurance Act.

  • ICBA commends the FDIC for substantially mitigating the impact of SBA PPP lending on FDIC insurance assessments.


Deposit insurance has been the stabilizing force of our nation’s banking system for more than 85 years. It promotes public confidence by providing safe and secure depositories for small businesses and individuals alike.

Deposit Insurance Fund Restoration Plan. The Federal Deposit Insurance Act requires the FDIC to maintain a minimum reserve ratio for the DIF of 1.35 percent and to establish a Deposit Insurance Fund Restoration Plan if the reserve ratio falls below the statutory minimum.

Due to economic stimulus measures enacted in response to the pandemic, and elevated savings rates during this time, quarterly deposit growth rates outpaced deposit growth in the DIF causing the reserve ratio to decline below the required 1.35 percent minimum. ICBA commends the FDIC for establishing a Deposit Insurance Fund Restoration Plan that provides sufficient time and flexibility for the surge of insured deposits to recede and normalize without increasing community bank insurance assessments.

SBA Lending. ICBA commends the FDIC for substantially mitigating the impact of SBA PPP lending on FDIC insurance assessments. For instance, nearly every ratio that determines a small bank’s assessment rate excludes PPP loans because of the FDIC’s recent rule changes.

These ratios include: the net income before taxes to total assets ratio, the nonperforming loans and leases to gross assets ratio, the other real estate owned to gross assets ratio, the brokered deposit ratio, the one-year asset growth measure, and the loan mix index (LMI). Furthermore, the assessment base used to determine assessments excludes PPP loans.

Staff Contact

Christopher Cole

Executive Vice President, Senior Regulatory Counsel

Washington, DC


Jenna Burke

Senior Vice President and Senior Regulatory Counsel

Washington, DC


ICBA Urges FDIC to Permanently Raise Regulatory Asset Thresholds

Sep. 27, 2021

ICBA Press Release Banner 2020

Washington, D.C. (Sept. 27, 2021) — The Independent Community Bankers of America (ICBA) today called on the Federal Deposit Insurance Corp. to raise regulatory asset thresholds to account for industry consolidation, rising inflation, and a swell of deposits caused by COVID-19 stimulus efforts.

In today’s letter, ICBA asked the FDIC to permanently raise the audit and reporting requirement asset thresholds under Part 363 of its regulations, which have not been adjusted in years. These requirements impose excessive regulatory burdens on many community banks.

“When the FDIC Improvement Act was enacted, Congress intended to exempt small depository institutions from the rigors of independent annual audits and reporting requirements,” ICBA President and CEO Rebeca Romero Rainey said. “Because the FDIC has not made frequent or regular adjustments to the part 363 asset thresholds to keep pace with industry changes, the current limits no longer provide a meaningful exemption to community banks.”

Specifically, ICBA asked the FDIC to:

  • Raise the asset threshold for part 363 requirements on audited financial statements from $500 million to $1 billion.
  • Raise the threshold for internal control assessments for management and external auditors from $1 billion to $5 billion.

ICBA said the regulatory updates are needed because:

  • The smallest community banks are confronting the thresholds given industry consolidation, inflation, and a surge in deposits due to COVID-19 stimulus.
  • Temporary reporting relief related to the COVID-19 pandemic is scheduled to expire Dec. 31.
  • The regulatory requirements are costly and burdensome for small community banks.
  • The FDIC has not updated the regulatory deposit thresholds since 1993 and 2005.

For more information, visit icba.org.

About ICBA
The Independent Community Bankers of America® creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.

With nearly 50,000 locations nationwide, community banks constitute 99 percent of all banks, employ more than 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding more than $5.8 trillion in assets, over $4.8 trillion in deposits, and more than $3.5 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org


Letters to Regulators and Congress

Title Recipient Date
FDIC 10/11/22
FDIC 10/11/22
FDIC 08/20/22
FDIC 08/20/22
FDIC 10/04/21
FDIC 07/09/21
FDIC 06/09/20