Rakuten Bank America’s resubmitted deposit insurance application continues to pose risks of mixing banking and commerce due to Rakuten Inc.’s diverse and global commercial activities, ICBA told the FDIC.

Background: Rakuten is refiling for deposit insurance as an industrial loan company after twice withdrawing applications. The e-commerce giant known as the "Amazon of Japan" has said it will continue to adjust the application until it has exhausted the FDIC process.

ICBA Position: ICBA has strongly opposed Rakuten's efforts to establish an ILC and continues advocating the closure of the ILC loophole. In its comment letter, ICBA said Rakuten's application continues to pose safety and soundness, privacy, conflict-of-interest, and data security risks.