4000 - Advisory Opinions
Insured Depository Institutions May Pass Cost of Federal Deposit Insurance Directly to Depositors Provided Notice is Given
December 24, 1990
Mark A. Mellon, Attorney
This is in response to your letter of December 7, 1990. Based on your letter, it is my understanding that your institution proposes to compute on a monthly basis the cost of federal deposit insurance on each of your deposit accounts. You further propose to directly pass this cost on to your customers and to notify depositors in their monthly statements that the cost is specifically incurred to pay for deposit insurance. You wish to ascertain whether the FDIC has any objection to this proposed practice.
We are not aware of any reason which would preclude FDIC-insured depository institutions from passing the costs of federal deposit insurance directly to depositors with notice that the cost is for that purpose specifically. This does not mean, however, that the FDIC endorses the practice. If an insured depository institution imposes a cost on depositors and informs them that the cost will pay for deposit insurance assessments, it is our belief that the cost should be accurately calculated and that the depositor should not pay any more than the actual cost of insurance for his deposits.
I hope that this letter has been responsive to your inquiry. Please contact me if you have any questions about this or any other matter.