Request for Information on Industrial Banks and Industrial Loan Companies and Their Parent Companies

The FDIC’s approach to industrial loan companies (ILCs) continues to generate strong views from a wide range of perspectives. High-profile developments in this area over the past several decades are well-known, and I have previously discussed some of them in greater detail.¹ I have also expressed my view that the FDIC should solicit feedback from the public on a comprehensive set of questions related to ILCs to inform its policy development.²

Today, the FDIC Board is considering a request for information (RFI) that would present stakeholders with an opportunity to provide feedback to inform the FDIC’s approach to ILCs. This RFI is particularly focused on information relevant to the evaluation of applicable statutory factors when reviewing ILC applications.

Although many of the arguments related to ILCs are familiar, sustained interest in the charter by a diverse set of institutions suggests that a wide-ranging RFI would be a helpful step. As I have said previously, I believe our ultimate objective should be a policy statement or similar issuance that provides clarity on how the FDIC interprets the applicable statutory factors in the context of ILC filings. At the same time, we will continue work on pending ILC applications that have been filed with the agency. 

I would like to thank the staff for their work on this RFI and look forward to reviewing comments.