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Has relief been provided to mitigate the deposit insurance assessment effects of participating in the SBA's PPP and the Federal Reserve's PPPLF and Money Market Mutual Fund Liquidity Facility (MMLF)?
Yes. On June 22, 2020, the FDIC Board of Directors authorized publication of a final rule that mitigates the deposit insurance assessment effects of participating in the SBA PPP, as well as the PPPLF and the MMLF established by the Board of Governors of the Federal Reserve System. The final rule: 1) removes the effect of participation in the PPP and borrowings under the PPPLF on various risk measures used to calculate an IDI’s assessment rate, 2) removes the effect of participation in the PPP and MMLF on certain adjustments to an IDI’s assessment rate, 3) provides an offset to an IDI’s assessment for the increase to its assessment base attributable to participation in the PPP and MMLF, and 4) removes the effect of participation in the PPP and MMLF when classifying IDIs as small, large, or highly complex for assessment purposes. The final rule became effective immediately upon publication with an application date of April 1, 2020.
Final Rule Mitigating the Deposit Insurance Assessment Effect of Participation in the Paycheck Protection Program, the PPP Liquidity Facility, and the Money Market Mutual Fund Liquidity Facility FDIC FIL-63-2020 https://www.fdic.gov/news/financial-institution-letters/2020/fil20063.html