The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. Key measures of safety and soundness in banking are capital, asset quality and profitability.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of industrial banks. Key measures of safety and soundness in banking are capital, asset quality, and profitability.

The National Association of Industrial Bankers welcomes the 119th Congress and looks forward to working with members toward our shared goal of a strong and safe banking sector.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. Key measures of safety and soundness in banking are capital, asset quality, and profitability. We have compared levels of capital, asset quality and profitability ratios for the US banking industry and the industrial banking sectors.

The National Association of Industrial Bankers (NAIB), the Utah Bankers Association (UBA), and the Nevada Bankers Association (NBA) appreciate the opportunity to submit the following comments on the proposed rule RIN 3064-AF88, Parent Companies of Industrial Banks and Industrial Loan Companies, which amends 12 CFR Part 354 (the Proposed Rule). We urge the FDIC to withdraw the Proposed Rule. The Proposed Rule ignores the financial record of industrial banks, which has been superior to other insured depository institutions in every measure for the last 40 years.

The Stena Center for Financial Technology prepared this report to highlight the safety and soundness of industrial banks. Key measures of safety and soundness in banking are capital, asset quality and profitability. The underlying financial information is drawn from the  call report data for individual banks and for aggregated banking industry segments from 2021- Q2 of 2024.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of industrial banks. Key measures of safety and soundness in banking are capital, asset quality and profitability.

The banking industry, in general, enjoyed strong profitability and solid financial condition in 2023 and 2022. The industrial bank sector continues to achieve strong capital and asset quality and superior profitability ratios.

We write today to reiterate our support for the industrial loan company (ILC) charter and respectfully remind you to ensure the Federal Deposit Insurance Corporation continues to follow the laws that Congress carefully designed for the FDIC to consider new deposit insurance applicants, including ILCs.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of industrial banks. Key measures of safety and soundness in banking are capital, asset quality, and profitability.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. Key measures of safety and soundness in banking are Capital, Asset Quality and Profitability. We have compared levels of Capital, Asset Quality and Profitability ratios for the US banking industry and the industrial banking sectors.

Thirteen of the 24 industrial banks met the threshold (assets in excess of one billion dollars) and accordingly reported estimated amounts of uninsured deposits.

The National Association of Industrial Bankers (NAIB) appreciates the opportunity to submit comments on proposed amendments to § 1026.52(b) and its accompanying commentary as they relate to credit card late fees.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. The banking industry enjoyed strong profitability and solid financial condition in 2022. While the banking industry is sound and safe as of December 31, 2021, the industrial bank sector continues to achieve superior earning strength and strong capital and asset quality ratios. As expected, economic conditions are causing a small increase in troubled loan ratios of industrial banks, leading to increased reserves for potential losses.

We appreciate the Committee’s desire to protect consumers from risks in the financial sector. However, the legislation introduced in the Close the Shadow Banking Loophole Act unfairly targets Industrial Loan Companies (ILCs), which are among the safest and soundest banks in the U.S. financial system. The proposed legislation is anti-innovation, anti-competition, and runs counter to its stated objectives.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. While the banking industry is sound and safe as of September 30, 2022, the industrial bank sector continues to demonstrate superior financial strength.

The Utah Center for Financial Services at the University of Utah prepared this report to highlight the safety and soundness of Industrial Banks. Key safety and soundness measures in banking are Capital, Asset Quality, and Profitability. We have compared levels of Capital, Asset Quality and Profitability for the US banking industry and the industrial banking sectors. The underlying financial information is drawn from the June 30, 2022 call report data for individual banks and for aggregated banking industry segments.

The undersigned also work with a variety of depository institutions in their CRA obligations. This includes a strong working relationship with the National Association of Industrial Bankers, which represents industrial banks chartered in Utah and Nevada. Industrial banks have been an enthusiastic and helpful partner in many of our CRA projects and endeavors.

The National Association of Industrial Bankers (NAIB) appreciates the opportunity to submit comments on the Notice of Proposed Rulemaking promulgated by the Board of Governors of the Federal Reserve System the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (“Agencies”) relating to amendments to the regulations implementing the Community Reinvestment Act (CRA), issued May 5, 2022.

The undersigned organizations, trade associations and companies that represent a significant portion of the American vehicle industry, write today to urge the House Committee on Financial Services to oppose H.R. 5912 – the Close the ILC Loophole Act. This bill as drafted will adversely impact the vehicle industry by eliminating decades-long Industrial Loan Company (ILCs) charters and unnecessarily creating a prohibition on future auto-related businesses seeking an ILC charter.