TCF Bank 2014 Annual Report Download - page 18

Financing Corporation assessments of $1.0 million, $1.1 million and $1.1 million were paid by TCF Bank in 2014, 2013 and 2012,
respectively.
The Dodd-Frank Act also gave the FDIC much greater discretion to manage the Deposit Insurance Fund (‘‘DIF’’). Among other
things, the Dodd-Frank Act: (1) raised the minimum designated reserve ratio (‘‘DRR’’) from 1.15% to 1.35% and removed the
upper limit on the DRR; (2) requires the DIF to reach 1.35% by September 30, 2020; (3) requires that in setting assessments the
FDIC offset the effect of the DRR reaching 1.35% by September 30, 2020, rather than 1.15% by the end of 2016, on insured
depository institutions with total consolidated assets of less than $10 billion; (4) eliminated the requirement that the FDIC pay
dividends from the fund when the DRR is between 1.35% and 1.5%; and (5) continued the FDIC’s authority to declare dividends
when the DRR at the end of a calendar year is at least 1.5%. On December 15, 2010, the FDIC set the DRR at 2.0% and it has not
changed since that time.
The Dodd-Frank Act requires that, for at least five years, the FDIC must make available to the public the reserve ratio using both
estimated insured deposits and the new assessment base. As of September 30, 2014, the DIF ratio calculated by the FDIC using
estimated insured deposits was 0.89%. The DIF reserve ratio would have been 0.41% using the new assessment base. In 2014,
for banks with at least $10 billion in total assets, the annual insurance premiums on bank deposits insured by the DIF ranged from
2.5 cents to 45 cents per $100 of deposits.
Examinations and Regulatory Sanctions TCF is subject to periodic examination by the Federal Reserve, the OCC, the CFPB
and the FDIC. Bank regulatory authorities may impose a number of restrictions or new requirements on institutions, including,
but not limited to, growth limitations, dividend restrictions, increased regulatory capital requirements, increased loan and lease
loss reserve requirements, increased supervisory assessments, activity limitations or other restrictions that could have an
adverse effect on such institutions, their holding companies or holders of their debt and equity securities. Various enforcement
remedies, including civil money penalties, may be assessed against an institution or an institution’s directors, officers,
employees, agents or independent contractors. Certain enforcement actions may not be publicly disclosed by TCF or its
regulatory authorities. Subsidiaries of TCF Bank are also subject to state and/or self-regulatory organization licensing, regulation
and examination requirements in connection with certain activities.
National Bank Investment Limitations Permissible investments by national banks are limited by the National Bank Act of
1864, as amended, and by rules of the OCC. Non-traditional bank activities permitted by the Gramm-Leach-Bliley Act of 1999 will
subject a bank to additional regulatory limitations or requirements, including a required regulatory capital deduction and
application of transactions with affiliates limitations in connection with such activities.
Dodd-Frank Wall Street Reform and Consumer Protection Act Congress enacted the Dodd-Frank Act in July 2010. The
Dodd-Frank Act created the CFPB and gave it broad authority to administer and carry out the purposes and objectives of the
federal consumer financial laws with respect to all consumer financial products and services. Among other things, the
Dodd-Frank Act: (i) directed the Federal Reserve to issue rules limiting debit-card interchange fees for larger banks, (ii) eliminated
federal preemption for subsidiaries of national banks and federal savings associations, and (iii) required larger banks to conduct
annual stress tests and report results.
Taxation
Federal Taxation TCF’s federal income tax returns are open and subject to examination for 2012 and later tax return years.
State Taxation TCF and/or its subsidiaries currently file tax returns in all states and local taxing jurisdictions which impose
corporate income, franchise or other taxes. The methods of filing and the methods for calculating taxable and apportionable
income vary depending upon the laws of the taxing jurisdiction. See ‘‘Item 1A. Risk Factors.’’
Foreign Taxation TCF and/or its subsidiaries currently file tax returns in Canada and certain Canadian provinces which impose
corporate income taxes. The methods of filing and the methods for calculating taxable and apportionable income vary depending
upon the laws of the taxing jurisdiction. See ‘‘Item 1A. Risk Factors.’’
See ‘‘Item 7. Management’s Discussion and Analysis – Consolidated Income Statement Analysis – Income Taxes’’ and Note 1
and Note 12 of Notes to Consolidated Financial Statements, Summary of Significant Accounting Policies and Income Taxes,
respectively, for additional information regarding TCF’s income taxes.
Available Information
TCF’s website, www.tcfbank.com, includes free access to Company news releases, investor presentations, conference calls to
discuss published financial results, TCF’s Annual Report, and periodic filings required by the United States Securities and
Exchange Commission (‘‘SEC’’), including annual reports on Form 10-K, quarterly reports on Form 10-Q, current reports on
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