WASHINGTON -- Bankers from Sleepy Eye, Minn., to New York City generally like the idea of risk-based insurance premiums.

But almost every one of 200 comment letters to the Federal Deposit Insurance Corp. offered at least one idea for improving the plan, which is due to take effect on Jan. 1.

The letters, submitted before the July 20 comment deadline, suggested that the agency widen the spread between the premiums paid by healthy and weak banks, create a more objective system for measuring risk, and guarantee that a bank's premium rate not be made public.

15-Cent Premium Spread Urged

"The financial institutions that are poorly managed should pay more," wrote director Joseph J. Friend of First Security State Bank in Sleepy Eye. Mr. Friend urged a premium spread of at least 15 cents.

Under the FDIC's May 12 proposal, risk-based premiums would range from 25 cents per $100 of insured deposits for the best banks to 31 cents per $100 for the worst.

Some critics accused the FDIC of playing politics with the new plan.

The riskiest banks are often "large, politically powerful institutions," wrote Martin Hughes 3d, secretary of the Fahey Banking Co. in Marion, Ohio. "The fact that they receive the huge subsidy of a premium rate that is well below what their risk would mandate leads to the perception that the benefit is the result of that influence" and "leads to a gross distortion of the free market."

Risk Criteria

Bankers are also dubious about the FDIC criteria for determining which banks are the riskiest. The agency intends to rely on capital strength and supervisory examinations to decide how much each bank will pay.

Many commenters said reviews by bank examiners fail to adequately reflect the objective, financial condition of the banks.

"Examiners, sometimes unseasoned or untrained, or sometimes just plain incapable, have too much input into the rating process," said Maurice Sapp, president of Home Federal Savings and Loan of Lexington, Neb.

Bankers viewed financial data such as earnings, asset-quality ratios, and capital levels as more objective than supervisory evaluations for measuring a bank's risk level.

Safeguarding Confidentiality

Any disclosure of risk evaluations "could lead to the indirect breach of the regulators' confidentiality policy regarding examination information, which could have adverse macroeconomic effects," warned Lester Stephens Jr., a senior vice president of Chase Manhattan Corp.

But the Shadow Financial Regulatory Committee, a group of private economists, said public disclosure could encourage examiners to improve their skills while inducing banks to strengthen their financial position.

"Customer reaction to adverse changes in ratings could be expected to spur healthy shifts or business from weaker to stronger institutions," the group wrote.

Among other suggestions in the comments:

* Clarify the steps for a bank to move to a lower risk category.

* Limit the complexity and volume of paperwork.

* Establish a simple appeals process. Ms. Cummins writes for the Medill News Service.

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