We, the undersigned companies, are writing to ask you to oppose any action that would eliminate or unduly weaken a historically strong, safe avenue for innovation and growth in the financial services industry: industrial loan corporations (ILC), also described as industrial banks.

One of the most difficult challenges industrial banks face in Washington is correcting the misinformation spread by critics, much of which is deliberately misleading. A good example is a recent article on industrial banks written by Arthur E. Wilmarth, Jr., of the George Washington University Law School.

The National Association of Industrial Bankers, the Utah Bankers Association and the Nevada Bankers Association appreciate the opportunity to submit this statement for the record of the Subcommittee on Consumer Protection and Financial Institutions hearing on “Banking Innovation or Regulatory Evasion? Exploring Trends in Financial Institution Charters.”