ICBA and BPI submitted a comment letter to the FDIC on Paypal’s application for deposit insurance. ICBA said that until Congress closes the industrial loan company loophole—which allows commercial firms to own insured banks but not be subject to the federally mandated regulatory and supervisory framework intended to promote a safe, sound and stable U.S. banking system—the FDIC should not issue deposit insurance to any ILC applicant, including PayPal Bank.