The FDIC approved a final rule on Assessments, Dividends, and Assessment Base and Large Bank Pricing. The rule is mandated by Dodd-Frank and changes the deposit insurance assessment system from one that is based on domestic deposits to one that is based on average consolidated total assets minus average tangible equity. The Rule adopts a “scorecard” assessment scheme for larger banks and suspends dividend payments if the Depository Insurance Fund (“DIF”) reserve ratio exceeds 1.5%. Related changes required by Dodd-Frank may delay this effective date. For more information, see our client alert at