On Sept. 29 the Federal Deposit Insurance Corp. proposed that banks prepay their deposit insurance assessments for the fourth quarter of 2009 and all of 2010-2012. If approved, the plan would immediately require all insured banks to pay roughly $45 billion into the deposit insurance fund, which has dwindled to $10.4 billion in unallocated funds.

However, not enough attention is being paid to whether this amount will be sufficient because the economic consequences have not been considered.

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