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current year’s insurance. The use and purpose of the entrance
fee is diametrically different from that of the exit fee. In
addition to the fact that the entrance fee is significantly less
than the exit fee, the entrance fee is paid to the fund that
insures the deposits of the institution that assumes the deposit
liabilities in a conversion transaction. Moreover, the entrance
fee is imposed in accordance with an express congressional intent
to prevent dilution of the reserves of the current insurer
through the addition of unworthy participants which could prove
to be financially troubled and cause an undesired depletion of
that insurer’s resources. See H. Rept. 101-54(I), at 325 (1989).
But for the imposition of the entrance fee, the participants in
an FDIC fund could deplete the reserves of that fund if the fund
became liable for an extraordinary amount of deposit liabilities
which had been assumed by the participants in conversion
transactions. After a BIF participant assumes the deposit
liabilities of a SAIF participant and pays an entrance fee,
however, the value of the BIF generally bears the same ratio to
the total deposits insured by the BIF (inclusive of the deposits
underlying the assumed deposit liabilities) as before the
conversion transaction.
We find additional support for our conclusion that Metrobank
derived insignificant benefits from its payment of the fees by
noting that Metrobank paid both fees incident to its management’s
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