ICBA comments on FDIC proposal to mitigate deposit-insurance impact of PPP

ICBA commended the FDIC’s proposal to partially mitigate the effects of participating in the Paycheck Protection Program and other emergency programs on deposit-insurance assessments, while calling for additional relief measures. In its filed comment letter, ICBA asked the FDIC to ensure that community banks that originated and hold PPP loans, but do not participate in Federal Reserve’s PPP Lending Facility, are not unfairly penalized.

“All PPP loans should be excluded not only from the calculation of the loan mix index, but from any measure used to calculate an insured depository institution’s assessment rate if their inclusion would have an adverse impact on an IDI’s assessment rate. Furthermore, all PPP loans should be excluded from an IDI’s assessment base,” ICBA wrote.