Deposit Insurance Funds: Compliance with Obligation and Repayment
Requirements as of September 30, 1993 (Letter Report, 05/09/94,
GAO/AIMD-94-100).

The Federal Deposit Insurance Corporation's (FDIC) maximum obligation
calculations show that as of September 30, 1993, (1) the Bank Insurance
Fund's (BIF) assets and other funding sources exceeded its obligations
by $44 billion and (2) the Savings Association Insurance Fund's (SAIF)
assets and other funding sources exceeded its obligations by $1.2
billion.  Nothing came to GAO's attention that would lead it to question
the reasonableness of the amounts reported.  As of September 30, 1993,
neither BIF nor SAIF had borrowed funds for insurance losses from the
U.S. Treasury, although changing economic conditions and other factors
could affect the need for future borrowings.  FDIC anticipates that BIF
will not need to borrow money from Treasury to cover insurance losses
through fiscal year 1999 and that BIF will achieve its designated ratio
of reserves to insured deposits of 1.25 percent by 1996. Passage of the
Resolution Trust Corporation (RTC) Completion Act, which provided RTC
with funding to resolve troubled thrifts, should reduce the likelihood
that SAIF will need to borrow from Treasury to cover insurance losses in
the near future.  In August 1993, FDIC repaid the $2.5 billion
outstanding Federal Financing Bank balance of BIF's working capital
borrowings.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  AIMD-94-100
     TITLE:  Deposit Insurance Funds: Compliance with Obligation and 
             Repayment Requirements as of September 30, 1993
      DATE:  05/09/94
   SUBJECT:  Bank failures
             Savings and loan associations
             Authority to borrow from Treasury
             Funds management
             Total obligational authority
             Compliance
             Reimbursements to government
             Insurance losses
             Future budget projections
IDENTIFIER:  Bank Insurance Fund
             Savings Association Insurance Fund
             BIF
             SAIF
             
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Cover
================================================================ COVER


Report to Congressional Committees

May 1994

DEPOSIT INSURANCE FUNDS -
COMPLIANCE WITH OBLIGATION AND
REPAYMENT REQUIREMENTS AS OF
SEPTEMBER 30, 1993

GAO/AIMD-94-100

Deposit Insurance Funds


Abbreviations
=============================================================== ABBREV

  BIF - Bank Insurance Fund
  FDI - Federal Deposit Insurance
  FDIC - Federal Deposit Insurance Corporation
  FDICIA - Federal Deposit Insurance Corporation Improvement Act of
     1991
  FFB - Federal Financing Bank
  FIRREA - Financial Institutions Reform, Recovery, and Enforcement
     Act of 1989
  FSLIC - Federal Savings and Loan Insurance Corporation
  OMB - Office of Management and Budget
  RTC - Resolution Trust Corporation
  SAIF - Savings Association Insurance Fund

Letter
=============================================================== LETTER


B-251583

May 9, 1994

The Honorable Donald W.  Riegle, Jr.
Chairman
The Honorable Alfonse M.  D'Amato
Ranking Minority Member
Committee on Banking, Housing,
 and Urban Affairs
United States Senate

The Honorable Henry B.  Gonzalez
Chairman
The Honorable Jim Leach
Ranking Minority Member
Committee on Banking, Finance
 and Urban Affairs
House of Representatives

This is the fifth of our required reports on the Federal Deposit
Insurance Corporation's (FDIC) quarterly compliance with the maximum
obligation limitation established by the Federal Deposit Insurance
Corporation Improvement Act of 1991 (FDICIA).  This obligation
limitation applies separately to both the Bank Insurance Fund (BIF),
insurer of commercial bank deposits, and the Savings Association
Insurance Fund (SAIF), insurer of thrift deposits, and is designed to
provide assurance that each fund's assets and other funding sources
are sufficient to fund its obligations.  FDIC administers both
insurance funds. 

FDICIA also requires us to report on BIF's and SAIF's ability to
repay amounts borrowed from the Department of the Treasury for
insurance losses and to analyze data related to the sale of assets of
failed institutions.  As agreed with your respective offices, the
latter requirement was modified to include an assessment of whether
BIF's total collections from the management and disposition of assets
acquired from failed institutions would be sufficient to repay its
existing working capital borrowings. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

FDIC's maximum obligation limitation calculations show that as of
September 30, 1993, (1) BIF's assets and other funding sources
exceeded its obligations by $44 billion and (2) SAIF's assets and
other funding sources exceeded its obligations by $1.2 billion. 
Based on our review of FDIC's calculations and explanatory notes for
both BIF and SAIF, nothing came to our attention that would lead us
to question the reasonableness of the amounts reported as of
September 30, 1993.  For the third quarter of calendar year 1993,
FDIC allocated the entire amount of Treasury borrowing authority to
BIF based on BIF's projected funding needs when funding legislation
was first proposed. 

As of September 30, 1993, neither BIF nor SAIF had borrowed funds for
insurance losses from the U.S.  Treasury.  The need for future
borrowings for insurance losses, and each fund's ability to repay any
such borrowings, depends on the impact of future economic conditions
on financial institution failures, the cost of these failures to the
insurance funds, future assessment revenues, and other funding
alternatives.  Currently, FDIC anticipates that BIF will not need to
borrow funds from Treasury to cover insurance losses through fiscal
year 1999, and that BIF will achieve its designated ratio of reserves
to insured deposits of 1.25 percent by 1996.  Additionally, the
Resolution Trust Corporation Completion Act, by extending the
Resolution Trust Corporation's authority to resolve troubled thrifts
and providing it with the necessary funding for its resolution
activities, should reduce the likelihood that SAIF will need to
borrow funds from Treasury to cover insurance losses in the near
future. 

On August 6, 1993, FDIC repaid the $2.5 billion outstanding Federal
Financing Bank (FFB) balance of BIF's working capital borrowings. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Section 15(c) of the Federal Deposit Insurance (FDI) Act, as amended
by FDICIA, requires that FDIC determine the limitation on outstanding
obligations for BIF and SAIF based on a maximum obligation limitation
formula.  In general, the formula involves comparing the assets and
liabilities of each of the two insurance funds to ensure that at any
point in time, each fund's assets are sufficient to cover its
liabilities.  The obligation limitation precludes FDIC from issuing
or incurring obligations for BIF or SAIF if, after doing so, total
outstanding obligations of each fund, considered separately, would
exceed the sum of its available funding sources.  The obligation
formula is designed to provide assurance that the obligations of each
fund are adequately supported by its assets and available funding
sources and to alert the Congress to FDIC's funding needs. 

FDICIA defines funding sources for each fund as (1) its cash and cash
equivalents, (2) the amount equal to 90 percent of the fair market
value of its assets other than cash and cash equivalents, and (3) its
allocated portion of the total amount authorized to be borrowed from
Treasury under section 14(a) of the FDI Act, as amended by FDICIA. 
Section 14(a) of the FDI Act, as amended by FDICIA, provided FDIC
with $30 billion in borrowing authority with Treasury to cover
insurance losses.  The borrowing authority is available for both BIF
and SAIF, but FDICIA does not specify how the $30 billion should be
allocated between the two funds.  In defining obligations, the act
requires that FDIC identify all guarantees (excluding deposit
guarantees), any amounts borrowed from Treasury or FFB pursuant to
section 14 of the FDI Act, and any other obligations for which the
funds have a direct or contingent liability.\1


--------------------
\1 As agreed to by the Senate and House Banking Committees, FDIC's
estimated liability for future financial institution failures or
assistance transactions is excluded in determining each fund's total
obligations where there is no contractual agreement between FDIC and
the troubled institutions comprising the estimated liability. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :3

The objectives of this review were to determine whether (1) BIF and
SAIF have complied with the statutory maximum obligation limitation
specified in FDICIA for the quarter ending September 30, 1993, and
(2) BIF and SAIF have borrowed from the U.S.  Treasury for insurance
losses and what factors may affect the need for future borrowings, as
well as BIF's and SAIF's ability to meet established repayment
schedules when borrowings occur.  See appendix I for details on the
scope and methodology of our work. 

We performed our work at FDIC's headquarters offices in Washington,
D.C., and Arlington, Virginia, from January through March 1994.  We
performed our work in accordance with generally accepted government
auditing standards.  However, the scope of our work was substantially
less than that of a financial audit and, as such, did not include a
review of FDIC's internal control structure.  Also, we did not test
or verify FDIC's books and records or the data contained in
appendixes II and III, except for the procedures detailed in appendix
I.  Our review of compliance with laws and regulations was limited to
BIF's and SAIF's compliance with the maximum obligation limitation
established by FDICIA.  While we did not obtain written comments on
this report, we discussed its contents with cognizant FDIC officials
and have incorporated their comments where appropriate. 


   FDIC REPORTS BIF AND SAIF
   COMPLIED WITH THEIR MAXIMUM
   OBLIGATION LIMITATIONS
------------------------------------------------------------ Letter :4

FDIC's maximum obligation limitation calculations for BIF and SAIF
show that as of September 30, 1993, BIF's assets and other funding
sources exceeded its obligations by $44 billion, and SAIF's assets
and other funding sources exceeded its obligations by $1.2 billion. 
This excess is described in the calculations as "Remaining Obligation
Authority." The obligation limitation calculations and explanatory
notes for BIF and SAIF are included as appendixes II and III,
respectively. 

Based on our review of FDIC's third quarter 1993 calculations and
explanatory notes for BIF and SAIF, nothing came to our attention
that would lead us to question the reasonableness of the amounts
reported. 


      ALLOCATION OF TREASURY
      BORROWING AUTHORITY
---------------------------------------------------------- Letter :4.1

In August 1993, FDIC amended its statement of accounting policy for
calculating the maximum obligation limitation to incorporate guidance
on how to allocate Treasury borrowing authority.  Under this
guidance, Treasury borrowing authority will be allocated based on
funding needs identified in recapitalization schedules FDIC prepares
for BIF and SAIF.  FDIC prepares these schedules semiannually when it
proposes the semiannual assessment rates to be charged to insured
institutions.  According to the guidance in the amended policy
statement, any Treasury borrowing authority exceeding projected
funding needs identified in the recapitalization schedules will be
allocated based on the proportion of the insured deposit base of each
fund to the total combined deposit base of the two funds.  In
addition, any alternative funding source already committed at the
time the maximum obligation limitation calculation is made will be
factored into the allocation process.  For the quarter ending
September 30, 1993, as in the first and second quarters of 1993 and
in each quarter of 1992, FDIC allocated all $30 billion of its
Treasury borrowing authority to BIF. 


   SEVERAL FACTORS WILL AFFECT
   FDIC'S TREASURY BORROWING NEEDS
------------------------------------------------------------ Letter :5

To date, FDIC has not borrowed funds from Treasury to cover insurance
losses for either BIF or SAIF.  The timing and extent to which such
funding may be needed will depend on a number of factors, including
(1) the effect of future economic conditions on financial institution
failures and the cost of these failures to the insurance funds, (2)
the impact of recent legislation, and (3) future revenue streams
available to the funds.  These factors will also affect FDIC's
ability to rebuild the insurance funds' reserves to designated
levels. 

FDICIA prohibits Treasury borrowing unless Treasury and FDIC have an
agreement which provides a repayment schedule and demonstrates that
income for BIF or SAIF will be sufficient to repay principal and
interest on Treasury borrowings within the period established in the
repayment schedule.  Separate agreements must be established for BIF
and SAIF. 

According to the recent cash flow projections FDIC submitted to the
Office of Management and Budget (OMB), FDIC does not anticipate that
BIF will need to borrow from Treasury for insurance losses through
fiscal year 1999.  FDIC has cautioned that its projections of
financial institution failures are subject to variables beyond its
control and that the reliability of the projections declines as the
time period covered by the forecast increases.  For example, FDIC's
cash flow projections are influenced in part by changes in economic
conditions and fluctuations in interest rates.  These factors can
affect the timing of financial institution failures and the closure
of institutions by the regulators. 

FDIC's borrowing needs can also be affected by legislative action. 
For example, until recently, SAIF was scheduled to assume full
responsibility for resolving troubled thrifts from the Resolution
Trust Corporation (RTC) on October 1, 1993.\2 However, the Resolution
Trust Corporation Completion Act (Public Law 103-204, enacted on
December 17, 1993) extends RTC's resolution authority and provides
RTC additional funding to resolve troubled thrifts identified by the
Office of Thrift Supervision.  The act also modifies SAIF's available
sources of funding for insurance losses. 

Specifically, the act extends RTC's resolution authority through a
date to be determined by the Chairman of the Thrift Depositor
Protection Oversight Board but no earlier than January 1, 1995, and
no later than July 1, 1995.\3 The act also restores to RTC through
December 31, 1995, $18.3 billion to resolve troubled thrifts.\4
Additionally, the act amends section 11(a) of the FDI Act by
authorizing up to $8 billion to SAIF to cover losses incurred by SAIF
in fiscal years 1994 through 1998.  However, prior to receiving such
funds, FDIC must certify, among other things, that SAIF is unable to
cover its losses through insurance premiums or through available
Treasury borrowing without adversely affecting the health of its
member institutions and thus causing the government to incur greater
losses.  The act also makes available to SAIF, upon RTC's December
31, 1995, termination and through December 31, 1997, any of the $18.3
billion in appropriated funds not used by RTC.  As with the $8
billion, FDIC must first certify that SAIF cannot fund its incurred
losses through industry premium assessments or Treasury borrowings
without adversely affecting the health of its member institutions and
causing the government to incur greater losses. 

FDIC recently submitted to OMB revised cash flow projections which
reflect changes resulting from the RTC Completion Act.  These revised
projections indicate that FDIC does not anticipate that it will need
to borrow from Treasury on behalf of SAIF through fiscal year 1999. 

FDIC also considers assessment revenues in projecting its borrowing
needs.  For premiums due in the semiannual period beginning on
January 1, 1993, and thereafter, FDIC adopted a risk-based premium
system.  Under this system, banks and thrifts posing higher risks of
loss to the insurance funds are charged higher premiums.  The
assessment rates charged to federally insured institutions during
1993 range from 23 cents to 31 cents per $100 of domestic deposits. 
Recent FDIC estimates show the average assessments charged to
BIF-insured institutions to be 24.3 cents per $100 of domestic
deposits in 1993, an increase of about 6 percent over the assessment
rate of 23 cents per $100 of domestic deposits in effect through
calendar year 1992.  FDIC's estimates show the average assessments
charged to SAIF-insured institutions in 1993 to be 24.9 cents per
$100 of domestic deposits, an increase of about 8 percent over the
assessment rate of 23 cents per $100 of domestic deposits charged in
1992. 


--------------------
\2 The Financial Institutions Reform, Recovery, and Enforcement Act
of 1989 (FIRREA) established RTC to resolve thrifts whose deposits
had been insured by the Federal Savings and Loan Insurance
Corporation (FSLIC) that were placed into conservatorship or
receivership from January 1, 1989, through August 8, 1992.  The
Resolution Trust Corporation Refinancing, Restructuring, and
Improvement Act of 1991 (Public Law 102-233), enacted on December 12,
1991, extended RTC's resolution authority to thrifts placed into
conservatorship or receivership through September 30, 1993. 

\3 However, any thrift requiring resolution after the expiration of
RTC's resolution authority which had previously been under RTC
conservatorship or receivership may be transferred back to RTC for
resolution.  Through the expiration of RTC's resolution authority,
SAIF is responsible for the resolution costs of any federally insured
thrift that was not previously insured by FSLIC.  Additionally, SAIF
may also incur resolution costs related to certain other institutions
prior to assuming full resolution responsibility.  Section 5(d)(3) of
the FDI Act, as amended by FIRREA, generally allows bank holding
companies to merge their SAIF-insured subsidiaries into their
BIF-insured bank subsidiaries.  The resulting banks would continue to
pay a portion of their premiums to SAIF based on the amount of thrift
deposits acquired.  Accordingly, in the event of failure or
assistance, any loss would be allocated between BIF and SAIF in
proportion to the institution's deposits insured by each fund. 
FDICIA expanded on the FIRREA amendment to allow an insured bank or
thrift to acquire, merge, or assume the deposit liabilities of the
other type of insured depository institution.  As with the FIRREA
amendment, insurance premiums and loss expenses are to be allocated
between BIF and SAIF. 

\4 The act amends section 21A(i) of the Federal Home Loan Bank Act by
removing the April 1, 1992, deadline for obligating $25 billion
provided to RTC by Public Law 102-233 for resolution activity. 
Through April 1, 1992, RTC had obligated $6.7 billion of the $25
billion. 


      SIMILAR FACTORS COULD AFFECT
      EFFORTS TO REBUILD THE
      INSURANCE FUNDS
---------------------------------------------------------- Letter :5.1

Resolution costs and assessment revenues are also significant factors
to be considered in projecting BIF's and SAIF's future fund balances. 
In an effort to achieve a level of self-sufficiency, FDICIA requires
FDIC to develop a recapitalization plan for BIF that specifies target
ratios of reserves to insured deposits at semiannual intervals,
culminating in a reserve ratio equal to the designated 1.25 percent
reserve ratio in no more than 15 years. 

At September 30, 1993, FDIC reported that BIF had an unaudited fund
balance of $10.5 billion.  The most recent FDIC projections contained
in FDIC's revised BIF recapitalization schedule show that BIF will
achieve the designated ratio by the year 1996, within the 15-year
period stipulated in FDICIA.  However, these projections are subject
to significant uncertainties.  Forecasting bank failures and their
costs to BIF is a highly imprecise process.  Additionally,
assumptions about the level of bank failures, growth in industry
assets and insured deposits, and BIF's assessment revenues are
subject to considerable fluctuations due to future economic
conditions, further industry consolidation, and the implementation of
regulatory reforms mandated by FDICIA. 

Section 7(b) of the FDI Act also establishes SAIF's designated
reserve ratio at 1.25 percent of estimated insured deposits and
stipulates that this ratio is to be achieved within a "reasonable
period of time." As of September 30, 1993, FDIC reported that SAIF
had an unaudited fund balance of $861 million, making its ratio of
reserves to insured deposits negligible.  However, the RTC Completion
Act's extension of RTC's resolution authority and restoration of
funds to enable it to resume resolution of troubled thrifts provides
SAIF additional time to build its reserves through premium
assessments prior to assuming full resolution responsibility. 
Additionally, the RTC Completion Act's provisions for backup funding
sources for SAIF's insurance losses should the need arise, coupled
with FDIC's risk-based premium system, should also assist in building
SAIF's reserves, subject to future economic conditions and other
factors affecting the health of institutions for which SAIF currently
has resolution responsibility. 


   FDIC REPAID WORKING CAPITAL
   BORROWINGS DURING 1993
------------------------------------------------------------ Letter :6

FDIC has authority to borrow funds for BIF's working capital needs
from FFB, but the amount of its outstanding working capital
borrowings is subject to BIF's maximum obligation limitation. 

During 1992 and 1993, conditions in the banking industry improved,
resulting in substantially fewer bank failures than in recent years
and, consequently, in lower disbursements to fund resolution
activity.  At the same time, BIF's funding from the liquidation of
assets from its failed institution asset inventory and from its
premium assessments increased.  As a result, on August 6, 1993, FDIC
repaid BIF's outstanding FFB borrowings of $2.5 billion. 
Additionally, FDIC's recent cash flow projections submitted to OMB
indicate that FDIC does not anticipate the need to borrow from FFB
for BIF's working capital needs in the next 5 years.  As noted
earlier, however, the reliability of such projections declines as the
time period covered by the forecast increases. 


---------------------------------------------------------- Letter :6.1

We are sending copies of this report to the Acting Chairman of the
Board of Directors, Federal Deposit Insurance Corporation; the
Director, Office of Management and Budget; and the Secretary of the
Treasury. 

Please contact me at (202) 512-9406 if you or your staffs have any
questions concerning the report.  Major contributors are listed in
appendix IV. 

Robert W.  Gramling
Director, Corporate Financial Audits


SCOPE AND METHODOLOGY
=========================================================== Appendix I

To determine whether BIF and SAIF complied with the statutory maximum
obligation limitation specified in FDICIA for the quarter ending
September 30, 1993, we reviewed the completeness and reasonableness
of the components and explanatory notes in FDIC's third quarter
calendar year 1993 maximum obligation limitation reports for BIF and
SAIF.  For this review, we performed procedures more limited in scope
than those conducted in an actual financial statement audit of the
insurance funds.  For example, we only reviewed the activity that
occurred in the third quarter of 1993.  To obtain assurance as to the
reasonableness of third quarter 1993 opening balances, we relied on
the results of the procedures performed on the June 30, 1993,
balances in our review of the first and second quarters of 1993.\1 We
believe our procedures provide us with sufficient assurance to draw
conclusions regarding FDIC's third quarter 1993 compliance with its
maximum obligation limitation. 

Our review work included the following. 

  We compared the components of FDIC's maximum obligation limitation
     calculations for BIF and SAIF to the provisions of FDICIA and to
     each fund's September 30, 1993, Statement of Financial Position
     and corporate general ledger trial balance. 

  We performed analytical procedures on the individual accounts that
     comprised each of the maximum obligation limitation
     calculation's line item components to identify (1) the dollar
     and percentage change in the account balances from June 30,
     1993, to September 30, 1993, and (2) any unusual account
     balances. 

  We developed criteria to identify accounts that required detailed
     review procedures.  These criteria considered the account's
     materiality as it relates to the balance of the line item
     component in which it is grouped, and the extent to which the
     account balance changed from quarter to quarter.  For accounts
     meeting these criteria, we performed the following additional
     procedures:  (1) obtained explanations for any large or unusual
     fluctuations in the account balances from appropriate FDIC
     officials, (2) obtained and reviewed supporting documentation
     for those accounts exhibiting large or unusual fluctuations for
     which FDIC officials did not provide sufficient explanation, (3)
     obtained and reviewed account reconciliations for specific
     accounts and verified the adequacy of these reconciliations, (4)
     confirmed balances for specific accounts, and (5) selected a
     judgmental sample of transactions for certain accounts and
     traced these transactions to supporting documentation. 

To determine whether BIF and SAIF had borrowed from the U.S. 
Treasury for insurance losses, what factors may affect the need for
future borrowings, and whether BIF and SAIF will be able to meet
established repayment schedules, we reviewed the status of FDIC
borrowings from Treasury as of September 30, 1993.  We also discussed
anticipated borrowing needs with FDIC officials and reviewed FDIC's
most recent projections of potential funding needs for BIF and SAIF. 



(See figure in printed edition.)Appendix II

--------------------
\1 Deposit Insurance Funds:  Compliance With Obligation and Repayment
Requirements as of 3/31/93 and 6/30/93 (GAO/AIMD-94-62, February 4,
1994). 


BIF MAXIMUM OBLIGATION LIMITATION
CALCULATION AND NOTES AS OF
SEPTEMBER 30, 1993
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)




(See figure in printed edition.)Appendix III
SAIF MAXIMUM OBLIGATION LIMITATION
CALCULATION AND NOTES AS OF
SEPTEMBER 30, 1993
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IV

ACCOUNTING AND INFORMATION
MANAGEMENT DIVISION, WASHINGTON,
D.C. 

Steven J.  Sebastian, Assistant Director
Michael C.  Hrapsky, Audit Manager
Elizabeth Martinez, Senior Auditor
Dennis L.  Clarke, Senior Auditor

OFFICE OF GENERAL COUNSEL

Jeffrey A.  Jacobson, Assistant General Counsel
Helen Desaulniers, Attorney
