Adjustment rules could provide for a gradual return to the midpoint of a range and some flexibility to adjust to changing conditions. First, merging the funds. That's no surprise. We've urged a merger for years. It is the only way to assure that you are not paying 23 basis points for deposit insurance while your competitor across the street is paying nothing.
Premiums are very high - or they are zero for almost all banks.
And that makes the down side of the business cycle worse. On pricing, if we are going to draw down the fund in bad times, it means that we must build it up in good times. And that means charging some premiums. Steadier premiums would allow you to plan and manage better. Which brings me to tying premiums more closely to risk.