The Kem C. Gardner Policy Institute finds that Utah benefits from a high concentration of commercial banks, industrial banks, and other financial institutions that engage in Community Reinvestment Act (CRA) activities throughout the state.

The National Association of Industrial Bankers, the Utah Bankers Association, and the Nevada Bankers Association appreciate the FDIC’s ongoing support in improving the transparency, timing, and consistency of the current application process. We also appreciate the FDIC's desire to address the historic decline in de novo bank formations.

Letter from Senators Cortez Masto, Curtis, Ricketts, and King commending the Federal Deposit Insurance Corporation’s (FDIC) request for information on the agency’s approach to evaluating industrial loan company (ILC) charter applications and their support for the ILC charter and the laws Congress designed that permit the existence of ILCs.

This study aims to help policymakers better understand the dynamics of the modern credit markets and the safeguards that could allow legitimate, capable businesses to deploy capital into the banking industry.

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.