December 6, 2022

Letter of Support for the Close the Shadow Banking Loophole Act

The undersigned organizations, which together represent a broad cross-section of regulated banks,
credit unions, and consumer protection organizations, write today to express support for your recently
introduced legislation, the Close the Shadow Banking Loophole Act, which would close the industrial
loan company (ILC) loophole in current law.

ILCs operate under a special exemption in federal law that permits any type of organization – including a
large technology company or commercial firm – to control a full-service FDIC-insured bank without
being subject to the same oversight and prudential standards or limitations on the mixing of banking
and commerce that Congress has established for the U.S. financial system.