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.

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.

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 for the US banking industry and the industrial banking sectors. The underlying financial information is drawn from the March 31, 2022 call report data for individual banks and for aggregated banking industry segments. While the banking industry is sound and safe as of March 31, 2022, the industrial bank sector continues to demonstrate superior financial strength.

The National Association of Industrial Bankers hereby responds to a recent joint trade association letter (“Joint Letter”) sent by the Bank Policy Institute (BPI), the Center for Responsible Lending (CRL), the Independent Community Bankers of America (ICBA) and other organizations. This Joint Letter calls on Congress to pass H.R. 5912, The Close the ILC Loophole Act. This letter will correct the misrepresentations made in the Joint Letter and provide you with an accurate story about Industrial Loan Corporations (ILCs).

Key measures of an insured institution’s safety and soundness are capital adequacy, asset quality and profitability. We have compiled and analyzed data related to these measures to provide an objective view of the US banking industry or a banking industry segment’s safety and soundness profile. All data is derived from FDIC quarterly call reports as of September 30, 2021.

Congress is considering eliminating the exemption for industrial loan companies (“ILCs”) from the definition of a bank under the Bank Holding Company Act (“BHCA”). State regulators believe there are several misconceptions regarding ILCs and the permissible activities of ILCs and their commercial parents.

NAIB member banks understand the importance of managing third party relationships in a safe and sound manner. We hope the comments provided will be helpful in developing well balanced and effective guidelines without regulatory burdens that may be overkill and without adequately considering the impact on the banks.

Key measures of an insured institution’s safety and soundness are capital adequacy, asset quality and profitability. We have compiled and analyzed data related to these measures to provide an objective view of the US banking industry or a banking industry segment’s safety and soundness profile.

The National Association of Industrial Bankers appreciates the opportunity to submit this statement for the record to the Subcommittee on Consumer Protection and Financial Institutions hearing on: The Future of Banking: How Consolidation, Nonbank Competition, and Technology are Reshaping the Banking System.

Key measures of an insured institution’s safety and soundness are capital adequacy, asset quality and profitability. We have compiled and analyzed data related to these measures to provide an objective view of the US banking industry or a banking industry segment’s safety and soundness profile. Industry segments in our report include: all insured institutions; industrial banks (a/k/a industrial loan companies or ILC’s); commercially-owned industrial banks; and insured institutions net of industrial banks (“Other Banks”). All data is derived from FDIC quarterly call reports as of March 31, 2021.