Public Comment, Industrial Banks, Securities Industry and Financial Markets Assn.

May 7, 2007 Mr. Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation th550 17 Street N.W. Washington, D.C. 20429 VIA E-MAIL TO comments@FDIC.gov Re: Proposed Rule Part 354—Industrial Bank Subsidiaries of Financial Companies, RIN number 3064-AD15 Dear Mr. Feldman, 1 The Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to comment on the draft rule titled “Part 354—Industrial Bank Subsidiaries of Financial Companies” (the “Rule”), issued for comment on December 31, 2007. SIFMA has a direct interest in this subject because industrial banks owned by SIFMA members currently hold about 80 percent of all industrial bank assets. In addition, the substantive provisions of this Rule will affect some of our members that may decide to organize an industrial bank subsidiary in the future. Moreover, the Rule may serve as a template for a subsequent regulation that could apply to all of our members. In principle, SIFMA does not oppose a regulation to implement the FDIC’s authorities and procedures for regulating industrial bank parent companies that is consistent with applicable law and that is not unduly burdensome. Currently, the various statutes, regulations, policy statements, guidelines and informal practices that govern the regulation of industrial bank parent companies can be difficult to locate and understand. Bringing all of those provisions together in one place ...