ICBA and BPI sent a letter to the FDIC opposing Affirm Bank’s application for deposit insurance. ICBA and BPI said that, if granted insurance, Affirm Bank could pose a significant and unnecessary risk to the Deposit Insurance Fund and the broader financial system. They added that by exploiting the industrial loan company loophole to avoid consolidated Federal Reserve supervision, relying heavily on its nonbank parent for core operations, and introducing potential conflicts of interest in offering lending and other products to its parent’s existing customer base, this application fails to satisfy key statutory factors under the Federal Deposit Insurance Act.