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11/12/25

ILC White Paper Letter to the FDIC

In a comprehensive white paper titled “Closing the Industrial Loan Company Loophole: An Urgent Priority to Prevent Systemic Risk and Consumer Harm,” ICBA calls on policymakersto close a legal loophole that allows ILCs and their parent companies to skirt regulatory oversight, endangering consumers and the economy.

Delivered to the FDIC and congressional offices, the white paper:

  • Says the ILC loophole allows commercial interests to own full-service banks while avoiding key regulations and consolidated supervision by the Federal Reserve, which threatens the financial system and creates an uneven regulatory playing field.

  • Calls on Congress to close the loophole and on the FDIC to delay final decisions on pending ILC deposit insurance applications until all stakeholder feedback is fully considered.

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