The FRB has issued a proposal to collect the assessment fees from large BHCs and systemic firms mandated by the Dodd-Frank Act. Although based on asset size, the assessment was complicated by the difficulties measuring this for covered institutions, as well as by the manner in which the FRB proposes to compute the expenses it incurs that are to be reimbursed by the new assessment. Given its magnitude – estimated this year at $440 million for seventy entities – these uncertainties may have significant cost implications.

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