Effective June 26, 2020, the FDIC adopted a Final Rule to mitigate the effect on deposit insurance assessments resulting from an insured institution’s participation in the Paycheck Protection Program (PPP), the Paycheck Protection Program Liquidity Facility (PPPLF), and the Money Market Mutual Fund Liquidity Facility (MMLF). The MMLF ended in July 2023.
Adjustment to the Risk Based Assessment Computation
The regulation provides adjustments to remove the effects of participating in PPP and PPPLF on the assessment rate calculation and provides an offset to assessments attributable to assessment base increase.
The regulation: 1) removes the effect of participation in the PPP and PPPLF on various risk measures used to calculate an Insured Depository Institution’s (IDI's) assessment rate, 2) removes the effect of participation in the PPPLF programs on certain adjustments to an IDI’s assessment rate, and 3) removes the effect of participation in the PPPLF program when classifying IDIs as small, large, or highly complex for assessment purposes.
To view the assessment offset computation, see Sample Invoices.
Call Report Changes
Institutions need to report on the following Call Report line to take advantage of the FDIC rule changes for deposit insurance assessment mitigation:
RC-M Memoranda
- U.S. Small Business Administration Paycheck Protection Program (PPP) loans and the Federal Reserve PPP Liquidity Facility (PPPLF):
a. Number of PPP loans outstanding
b. Outstanding balance of PPP loans
c. Outstanding balance of PPP loans pledged to the PPPLF
d. Outstanding balance of borrowings from Federal Reserve Banks under the PPPLF with a remaining maturity of:
(1) One year or less
(2) More than one year
e. Quarterly average amount of PPP loans pledged to the PPPLF and excluded from “Total assets for the leverage ratio” reported in Schedule RC-R, Part I, item 30
Effective Dates
The final rule was effective June 26, 2020, applied as of April 1, 2020, and was first reflected on the second quarter deposit insurance assessment (collected on September 30, 2020) based on amounts reported on June 2020 Call Reports.
For Assistance with Reporting
Please see: Call Report Forms and Instructions and FDIC Call Analysts.