Alert December 06, 2011

OCC Issues Summary of Fee Structure for 2012

The OCC issued a release (the “Release”) summarizing the OCC’s fee structure for 2012.  The OCC stated that its general assessment schedule will continue to be indexed to reflect inflation as measured by the Gross Domestic Product Implicit Price Deflator (“GDPIPD”) for the previous June-to-June period.  For 2012, the OCC stated, the GDPIPD adjustment will be 2.0%.  The Release states that the adjustment will apply to the first $20 billion in assets of a national back or federal savings association.

OCC assessments are due March 31 and September 30 based on call and thrift financial report information as of December 31 and June 30 respectively.  The assessment due March 31 covers the six-month period from January 1 through June 30.  Federal savings associations will be required to file call reports (rather than thrift financial reports) as of March 31, 2012.  The OCC, however, will base a federal savings bank’s assessment for the January 1, 2012 through June 30, 2012 period on either the  OCC or OTS fee structure (whichever yields the lower assessment for the applicable federal savings bank).  In future assessment periods, both national banks and federal savings associations will be assessed based upon the OCC’s fee structure.

As in the past, the OCC’s 2012 fee structure includes a surcharge for national banks and federal savings associations that require increased bank regulatory supervision, including those with composite CAMELS ratings of 3, 4 or 5.  Independent trust banks and independent credit card banks are also subject to assessment surcharges because their supervision requires allocation of increased OCC supervisory resources.  The Release provides additional detail on the OCC’s 2012 fee structure and its assessment methodology.