Standards for Prepaid Assessment Exemptions
We understand that the FDIC has decided to exempt the following categories of financial institutions from the requirement to prepay three years of deposit assessments:
- Institutions with a CAMELS rating of 4 or 5; and
- Institutions that are less than well-capitalized.
Institutions falling in either of these categories should have already received an electronic letter from the FDIC confirming that they have been exempted from the prepayment of deposit assessments.
Confidentiality for Prepaid Assessment Waivers
The FDIC does NOT plan to publicly announce the banks that are given exemptions from the prepayment.
The FDIC believes that the information is confidential and will NOT be subject to disclosure under the Freedom of Information Act (generally as bank supervisory information).
The FDIC intends for the Call Reports starting with the December 31, 2009 Call Report to include in Schedule RC-F an explicit line item for prepaid assessments, but that line item will be confidential and withheld from the publicly available call reports. Analysts may be able to deconstruct whether a bank is exempt due to fluctuations in the Other Assets generally, but the FDIC does not believe that such detection will necessarily be easy or accurate.