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ICBA commended the FDIC for working to strengthen its supervisory processes for non-commercial parent companies of industrial loan companies, but it said the agency's proposal falls short of ensuring the safety and soundness of these companies.
However, ICBA made clear that under no circumstances should a commercial firm own a bank or ILC even if it is subject to enhanced supervision and regulation.
ICBA suggested that ILC holding companies should be subject to the Bank Holding Company Act and the consolidated supervision of the Federal Reserve rather than the supervision of the FDIC. ICBA also noted deficiencies with the FDIC’s proposal, including that it stops short of establishing consolidated capital requirements that would ensure ILC parents are a source of strength for their subsidiaries.
Wednesday's comment letter follows a separate ICBA letter calling on the FDIC to deny Rakuten Bank America’s resubmitted deposit insurance application and urging Congress to permanently close the ILC loophole.