FDIC: Industrial Loan Companies and Industrial Banks

ABA Contact: Compliance staff
Published: 71 Federal Register 163, August 23, 2006
Comments Due: October 10, 2006
Disposition: Filed


The FDIC is seeking comment on specific issues related to industrial loan companies and industrial banks (collectively, ILCs), including issues regarding the current legal and business framework of ILCs and the possible benefits, detrimental effects, risks, and supervisory issues associated with the ILC industry. The FDIC believes that public input will assist the FDIC in identifying any potential risks to the Deposit Insurance Fund, any emerging safety and soundness issues, or other policy issues raised by ILCs and, further, will assist the FDIC in determining whether statutory, regulatory, or policy changes should be made in the FDIC's supervision of ILCs in order to protect the Deposit Insurance Fund or other important Congressional objectives.

The ABA has prepared a response in which we conclude that Congress is the appropriate entity to address the changes that have occurred in the ILC industry in the past 20 years. We also suggest that it would be inappropriate for the FDIC to attempt to resolve these issues through the use of conditional approvals of applications to acquire FDIC insurance or notices of proposed changes in the control of ILCs.

2006 Regulatory Chart
ABA Comment Letter
Federal Register