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


FDIC board meeting tomorrow on assessments, supervisory appeals

Oct. 17, 2022

The FDIC scheduled a board meeting for tomorrow to vote on its ICBA-opposed proposals to dramatically increase deposit insurance assessments and to eliminate its Office of Supervisory Appeals.

Assessment Proposal: The agency is proposing to raise deposit insurance assessment rates by 2 basis points on all insured institutions. ICBA and community bankers have repeatedly expressed opposition to the plan, including in an ICBA-led grassroots campaign earlier this year.

Faulty Assumptions: In a joint letter last week, ICBA and other groups said the FDIC’s proposal is based on a faulty assumption that the Deposit Insurance Fund will not meet its minimum level by as late as 2034. In fact, the latest Quarterly Banking Profile suggests the statutory minimum is likely to be satisfied as soon as the first quarter of 2023, they said. A previous joint letter called on the FDIC to halt its proposed rate hike.

ICBA Pushback: In a national news release after the FDIC released its quarterly data last month, ICBA President and CEO Rebeca Romero Rainey said the data show there is no need for a rate hike. In a previous comment letter, ICBA said dramatically raising rates would disproportionately affect community banks and fail to appropriately account for large and complex institutions.

Supervisory Appeals: The FDIC board is also set to discuss proposed amendments to guidelines for appeals of material supervisory determinations. ICBA has strongly opposed the agency’s decision to reinstate the Supervision Appeals Review Committee and eliminate the Office of Supervisory Appeals less than six months after the independent appeals forum became operational.

Ongoing Advocacy: ICBA will continue to engage policymakers in opposition to these proposals ahead of tomorrow’s board meeting.

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