Additionally, ICBA supports two types of systemic-risk fees that would hold systemic-risk institutions accountable and, ultimately, protect and compensate taxpayers and the FDIC Deposit Insurance Fund from future risk exposure. First, Congress should impose a systemic-risk premium on all systemically dangerous holding companies to help defray the cost of enhanced regulation of these companies and to pay for the orderly unwinding of the affairs of any of these institutions should they fail. Second, Congress should require all FDIC-insured affiliates of systemically dangerous financial companies to pay a systemic-risk premium to the FDIC in addition to their regular FDIC premiums to compensate the agency for the increased risk they pose.

ICBA has sent our proposals for dealing with the systemically dangerous firms to both the House and Senate. We are urging Congress to deal with this too-big-to-fail problem once and for all so the nation’s community banks and America’s taxpayers never again have to pay for and suffer through another catastrophic financial meltdown.