Public Comment, Industrial Banks, Independent Community Bankers of America

May 7, 2007 Robert E. Feldman Executive Secretary Attention: Comments/Legal ESS Federal Deposit Insurance Corporation th550 17 Street, NW Washington, D.C. 20429 Re: Industrial Bank Subsidiaries of Financial Companies; RIN 3064-AD15 Dear Mr. Feldman: 1The Independent Community Bankers of America (ICBA) appreciates the opportunity to comment on proposed rules that would impose conditions and requirements on corporate owners of insured industrial loan companies or industrial banks that are engaged solely in financial activities and that are not subject to consolidated bank supervision by the Federal Reserve Board or the Office of Thrift Supervision (“Federal Consolidated Bank Supervision”). Summary of ICBA’s Position ICBA commends the FDIC for proposing consolidated regulation of non-FCBS financial companies that own industrial banks. We agree with the recent Government 2Accountability Office Report that consolidated regulation of industrial bank holding companies would better ensure the safety and soundness of industrial banks, protect the 1The Independent Community Bankers of America represents the largest constituency of community banks of all sizes and charter types in the nation, and is dedicated exclusively to representing the interests of the community banking industry. ICBA aggregates the power of its members to provide a voice for community banking interests ...