Proposal to increase thresholds for fee assessments to be issued, as mandated by reg relief law

The minimum threshold for being considered an “assessed company” would rise to $100 billion (from $50 billion) for bank holding companies under a proposal scheduled to be published in the Federal Register Tuesday.

Under the Federal Reserve’s proposal (issued for comments due Jan. 9), Regulation TT would be amended to raise the threshold from $50 billion to the $100 billion. In addition, the amount charged to assessed companies with total consolidated assets between $100 billion and $250 billion would be adjusted to reflect changes in supervisory and regulatory responsibilities resulting from last year’s regulatory relief legislation, the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA, S.2155). The thresholds adjustments were also mandated by last year’s law.

Legislation passed in the wake of the financial crisis a decade ago (the Dodd-Frank Wall Street Reform and Consumer Protection Act, “Dodd-Frank”), fees are collected from financial institution holding companies with $50 billion or more in total consolidated assets (and nonbank financial companies designated by the Financial Stability Oversight Council (FSOC) for supervision by the Federal Reserve), equal to the expenses the Fed estimates are needed to carry out supervision of those companies. The Board transfers the assessment proceeds to the U.S. Treasury’s General Account.

But last year’s reg relief legislation raised the threshold to $100 million for firms subject to paying the fees.

While the fee threshold is rising for some financial firms, all nonbank companies designated by FSOC for supervision by the Fed would continue to be considered “assessed companies.”

Supervision and Regulation Assessments of Fees for Bank Holding Companies and Savings and Loan Holding Companies with Total Consolidated Assets of $100 Billion or More

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