The FDIC was probably wise to get its member banks to prepay their fees for 2010, 2011, and 2012. The agency brought in $45 billion by the action, just as its capital base went into the red early last October. The FDIC could have taken in the funds from the Treasury Department instead, but that would have meant another “loan” for the financial system by the taxpayers. Analysts now expect 200 or more banks to fail this year. Sixteen have already gone under.