Federal Deposit Insurance Corp. staff members are scrambling to implement Chairman Donna A. Tanoue's recent pledge to make more banks pay for the government's guarantee.

When she addressed the American Bankers Association last month, Ms. Tanoue vowed to target banks and thrifts "whose practices make them outliers in terms of underwriting, concentration of risk, or undisciplined growth."

But now her staff must determine just what an "outlier" is, how many there are, and when these institutions will start paying for their high- stakes behavior.

More than 10,000 well-capitalized institutions with Camels ratings of 1 or 2 currently pay nothing for deposit insurance. These banks are branded 1-A, the top rating in the nine-box matrix the agency uses to decide how much each institution is charged.

Ms. Tanoue is not the first FDIC official to question why 95% of all banks are squeezed into just one box. But given the current economic slowdown and reports of declining loan standards, the uneven distribution of banks now seems even more surprising.

The reform process is just getting under way, but Ms. Tanoue is expected to provide more details in a speech Tuesday at an America's Community Bankers conference in Chicago.

Though nothing is certain yet, FDIC officials working on the project sketched a probable scenario. Rather than rely on a bank's overall supervisory rating, the agency might focus on individual components or subcomponents of a bank's Camels rating. (Camels is an acronym for capital, asset quality, management strength, earnings, liquidity, and sensitivity to risk.)

Under this approach, for example, a bank that had an overall Camels rating of 2 but had trouble managing its subprime lending portfolio might be charged more for insurance.

Camels components often overlap. But Ms. Tanoue seems most interested in a bank's asset quality, leadership, and risk management.

Joe Belew, president of the Consumer Bankers Association, said focusing on bank management makes sense. "It's harder and harder for the FDIC to look at a representative number of loan documents," he said. "They are going to have to spend more time making sure that the bank itself is managing its risk."

Robert R. Davis, ACB's director of government relations, said thrifts would support the FDIC's effort "if they have a strong statistical or analytical basis for making distinctions."

ABA chief economist James H. Chessen warned the FDIC to focus on more objective measures of bank performance, such as capital, earnings, and liquidity. Bankers, he said, want risk-based premiums to be simple and "as quantitative as possible."

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