Resources

Issues and Resources

ABOUT ILCs

These guides give a quick overview of the history and purposes of ILCs.

Industrial Loan Companies (ILCs) or Industrial Banks have been an integral part of the US financial system for over a century, providing credit and financial innovation during good times and bad. Perhaps one of the most compelling facts about ILCs is that during the worst years of the financial crisis, when most banks and credit unions were contracting their balance sheets and dramatically reducing lending, ILCs continued to lend and actually grew their assets (loans) year over year, providing needed capital for the US economy.

COMMENT LETTERS

Conference of State Bank Supervisors Comment Letter to U.S. Representative Garcia on proposed ILC legislation – November 2021

Proposed Interagency Guidance on Third Party Relationships Comment Letter from NAIB to Federal Reserve System, Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation – October 2021

NAIB Response Letter to US House Financial Services Committee Subcommittee on Consumer Protection and Financial Institutions – September 2021 

NAIB and UAFS Parent Company Letter to Congress – July 2021

NAIB, UBA, and NBA Comment Letter to US House Financial Services Committee Subcommittee on Consumer Protection and Financial Institutions – April 2021

NAIB and UBA Industrial Banks Myths Explained – April 2021

NAIB and UBA Comment Letter on Proposals Under Consideration and Alternatives Considered for Section 1071 of the Dodd-Frank Act – December 2020

Utah Department of Financial Institutions Board Renewal Comment Letter – October 2020

NAIB and UBA Statement for the record to the Task Force on Financial Technology Committee on Financial Services – September 2020

NAIB Letter to Senator Cortez Masto – September 2020 

NAIB Letter to Congressman Comer – September 2020

NAIB and UBA Letter on Proposed Amendment regarding Current Expected Credit Loss (CECL) – August 2020

NAIB Response to joint trade association letter – August 2020

ABA Comment Letter on FDIC ILC Proposal – July 2020

NAIB and UBA Comment Letter on FDIC ILC Proposal – July 2020

NAIB and UBA Comment Letter on Proposed Rulemaking Regarding the Community Reinvestment Act – April 2020