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FDIC Decision Due Out Soon

Bruce Krasting's picture




On September 29th the FDIC announced a plan to bolster its reserves.
There were three basic choices. A) Borrow from the Federal Financing
Bank, B) Charge a large special assessment on the banks and C) Have the
banks pre-pay three years of insurance premiums up front.

At
the time, the FDIC gave the public a thirty-day comment period before
the final determination. That time period is up. The letters are in. I
would expect an announcement on this by Ms. Bair before the end of the
week.

This is the link
to the letters. There are a lot of them. The FDIC may choose to ignore
all of the comments, but I think they will address some core issues
raised in their final ruling.

The FDIC went after this with a carrot and a stick. They said to the banks,” If you pay up front we will make the accounting work for you”. “If you don’t, we will charge you a ‘Special Assessment’. That would go through your income statement”.

Bankers
being bankers it is understandable why they would not want to recognize
an expense up front if there was another way around it. Therefore
almost all of the letters were in support of the pre-pay deferred
recognition approach.

There was some support for the FDIC to
tap its credit lines at the Federal Financing Bank. They have a blank
check at the FFB for $100 billion. So the pre-pay option isn’t really
necessary. But the easier FFB option had a significant cost. Ms. Bair
is acutely aware of the ‘anti bailout’ mentality. Her words on the
subject:

“It's clear that the
American people would prefer to see an end to policies that look to the
federal balance sheet as a remedy for every problem.”

This is why the FDIC made it easy for the banks to choose door (C). It’s cosmetics.

Not
surprisingly the Banks all wanted a bone thrown to them. They made a
good case. If they did not prepay they would have earned a spread on
the cash. So in effect the proposal has a negative impact on income. We
wouldn’t want that. A few examples:

 

boa.fdic__1_0.pnggba.fdic__0.png

Some thoughts on what may come:

-The $45 b prepay is a done deal.

-There
will be exceptions in a number of cases and categories of banks. These
banks will get a drawing from the FFB. That drawing will be guaranteed
by the FDIC. This is small beer. Maybe $5b. It will look like the FDIC
will have no borrowings however.

-There will be no special assessments.

-There
will be a discount on the pre-payment. The banks will be allowed to
take that as income. Top line benefit that has no substance.

-The
assumption that deposits will grow by 5% will be reduced. This will
have the impact of reducing the net amount that the FDIC takes in. (by
just a few billion)

-The statement will reaffirm that deposits are safe and that the FFB (and this cash) is backstopping that promise.

-This will be made to look like a great success. A true private sector solution.

-The ‘system’ will have created another $45 billion of off balance/income statement funding. This will not show up anywhere.

-If
a discount is awarded to the banks then that percentage should be
compared to the cost of tapping the FFB for the shortfall. Any excess
would be a measure of the Government's willingness to avoid the
perception of a bailout.

Congressman Latta was very supportive of the proposal in his letter. I thought his side comments were interesting:

Also of interest was this comment by the ABA.

aba-fdic_0.png




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Fri, 11/13/2009 - 04:07 | Link to Comment Anonymous
Fri, 11/13/2009 - 01:44 | Link to Comment Anonymous
Thu, 11/12/2009 - 22:46 | Link to Comment FischerBlack
FischerBlack's picture

Let's see what Failure Friday brings. I can't wait to see the spike in bank failures after the FDIC replenishes the DIF. What amazing timing! Wow, good thing we replenished *before* all these banks failed. Whew!

Aaaand, it's gone.

Thu, 11/12/2009 - 22:20 | Link to Comment Anonymous
Thu, 11/12/2009 - 21:48 | Link to Comment Zippyin Annapolis
Zippyin Annapolis's picture

Timmy vs. Sheila--Sheila wins

Thu, 11/12/2009 - 19:02 | Link to Comment steve from virginia
steve from virginia's picture

 

The banks lending funds to the FDIC is the least bad option from what the worst situation offers; an assessment is simply a loan to the FDIC by the banks without interest.

As more and more banks fail the assessment/premium issue will become academic. Depositors will eventually be 'supported' by borrowing from the taxpayers' grandchildren. Which means depositors will be supported by nobody in particular.

The banks' biggest problem is they cannot/won't make good loans. Talk about voting, 'No- confidence' with their feet!

Fri, 11/13/2009 - 00:54 | Link to Comment Anonymous
Fri, 11/13/2009 - 00:41 | Link to Comment Anonymous
Thu, 11/12/2009 - 16:49 | Link to Comment carbonmutant
carbonmutant's picture

What is the FDIC going to do for next year's shortfall?

Thu, 11/12/2009 - 17:10 | Link to Comment TimmyM
TimmyM's picture

That is the scary question. They really need about 300B. Some alternatives are:

All the strong banks say FU and unplug from national charters and form theirown private insurance program.(maybe they could start a central bank too!) This would at least keep the A-holes from taking everybody down.

Repeal most of Gramm, Leach, Bliley and solve TBTF.

Get the rules changed where insured limits go way up but put in a 2% co-pay for investors-thus making the hot gatherers pay 200 bps over the well capitalized market.

Dissolve the FDIC and just make it all Treasury guaranteed with a co-pay.

Institute a material risk based premium system.

Thu, 11/12/2009 - 16:46 | Link to Comment Anonymous
Thu, 11/12/2009 - 16:46 | Link to Comment Anonymous
Thu, 11/12/2009 - 14:29 | Link to Comment chet
chet's picture

How long will $45 billion last the FDIC anyway?  How much have they gone through this year already?

Thu, 11/12/2009 - 14:25 | Link to Comment Racer
Racer's picture

What a cheek!!

Takes the biscuit that does completely

Thu, 11/12/2009 - 14:07 | Link to Comment Anonymous
Thu, 11/12/2009 - 19:24 | Link to Comment rational
rational's picture

You should read some history.  When a panic comes, depositors won't listen to your explanation of how strong your bank is, the will withdraw first and ask questions later.  Without deposit insurance, bank runs destroy all banks, weak or strong.  That's why it was created in the first place.

Thu, 11/12/2009 - 15:39 | Link to Comment Dburn
Dburn's picture

Go back to 1996 to 2006 when no premiums were paid thanks to the ABA lobbying congress. They felt that the 52 billion in the FDIC account was more than sufficient. The payments resumed when Bair took office in 2006 after she convinced congress that the amount really wasn't sufficient.

 

Or put another way, imagine if they had paid the premiums during the years they were flush.

Thu, 11/12/2009 - 12:52 | Link to Comment bugs_
bugs_'s picture

Banco Festiva!!!!!

Thu, 11/12/2009 - 12:35 | Link to Comment Anonymous
Thu, 11/12/2009 - 15:34 | Link to Comment Dburn
Dburn's picture

The response I would like to see from Bair to the whining bankers.

 

I can understand why you might think that this pre-assessment  would  inhibit your  capital without a discount.

 

 

So we came up with the BBFS Option:  We would hire an outside team of specialists  to  go through all your derivitives to find out your bank's  net liability if they were brought back on the balance sheet. This would help us  to see which would have the most detrimental effect on your capital. By golly if the pre-assessment outweighs your consolidated derivative liability, we would be open to a meeting between you , the FDIC and the Dept of Justice as we review your real estate transactions from 2004 on. If there are no problems there , meaning you still have your freedom, we may be open to preliminary discussions of a credit that could be used against the post-assessments  we are considering for the 10 years from 1996 to 2006 when you paid no premiums.

 

If the Liability does exceed the pre-assessement by a significant magin where it say zeroes out all your capital, well, lets not go into that now until we get all the assessements in. Lets just leave it as; we would have to create a new shit list that no bank would want to be on

 

So we are clear:

1. You can pay the pre-assessment and STFU or the PASTFU option

2. Our preference would be for you to place your bets on the BBFS option outlined above which we refer to as Bank Building For Sale. Please refer to it as the BBFS in all future communications as you must know by now how much Timmy loves his acronyms..

 

Please be advised that the assessment in no way immunizes you from any criminal prosecution or civil actions should someone with spine unexpectedly show themselves in Govt.

 

 

Please advise on what would be the best option for your fine institution.

 

Sincerely

 

Sheila "I found my FDIC rule book" Bair.

 

Thu, 11/12/2009 - 22:23 | Link to Comment Cistercian
Cistercian's picture

 That is the funniest post today by far, totally priceless!!!

Thu, 11/12/2009 - 12:01 | Link to Comment Catullus
Catullus's picture

Did the ABA just suggest that the FDIC take the pre-pay money and buy RE bonds?  The plan: take three years worth of premiums for insurance to backstop decapitalized banks (so take more money from already undercapitalized banks), pay interest on the pre-paid premiums, then take the premium payments and buy real estate off the books of the banks (effectively giving the money right back to banks).  Wonderful.  Except the banks you buy the RE bonds from are not all the same banks you took the premiums from.  So you decapitalize the smallest banks to buy the assets of the largest banks.  Bruce, I need a flow chart.

Thu, 11/12/2009 - 12:51 | Link to Comment economessed
economessed's picture

You just nailed it. 

R.I.P. Moral Hazard (1231 B.C. - 2007)

Thu, 11/12/2009 - 11:56 | Link to Comment Anonymous
Thu, 11/12/2009 - 18:22 | Link to Comment Master Bates
Master Bates's picture

GBE - Grubb and Ellis

* this recommendation should not be construed as financial advice.

Thu, 11/12/2009 - 14:54 | Link to Comment Dburn
Dburn's picture

Keep a hair trigger on the buy button if you do. This market has not shown one ounce of decency to us bears. It hates us.

Thu, 11/12/2009 - 11:42 | Link to Comment Anonymous
Fri, 11/13/2009 - 01:17 | Link to Comment Problem Is
Problem Is's picture

I still vote for special assessment on Timmay G's Aunt Lloyd and Uncle Jamie whether the prepay is a done deal or not...

Disclaimer: I hope none of the above violates any of Marla's new rules crackdown...

Thu, 11/12/2009 - 11:41 | Link to Comment Problem Is
Problem Is's picture

NSA messing with my internet connection again...

Thu, 11/12/2009 - 22:24 | Link to Comment Anonymous
Fri, 11/13/2009 - 01:16 | Link to Comment Problem Is
Problem Is's picture

Your mouse arrow moving non fluently, you know herky jerky out of the blue, is a sure sign of remote access...

I just can't figure out, exwife, exgirlfreind(s), suspicious tech savy exgirlfreind(s) insecure boyfreind(s) or the NSA...

Do NOT follow this link or you will be banned from the site!