View or download a PDF of the letter here.

AFREF, Consumer Federation of America, Prof. Arthur Wilmarth, Jr. and Center for Responsible Lending submitted a comment to the Federal Deposit Insurance Corporation supporting the effort to strengthen the oversight of industrial loan companies (ILCs). These ILC charters provide a regulatory exemption that blurs the line between banking and commerce, sidesteps traditional banking supervisory regulation and oversight, and poses safety and soundness risks to the ILCs, their corporate parents, consumers, and the financial system. The proposed rule would heighten scrutiny of new ILCs or attempts to take over existing ILCs that will more fully consider the unique risks of these banks.