Public Comment, Industrial Loan Companies and Industrial Banks, Retail Industry Leaders Assn.

1700 N. Moore Street, Suite 2250, Arlington, VA 22209 Phone: 703-841-2300 Fax: 703-841-1184 Email: info@retail-leaders.org www.retail-leaders.org RIN 3064-AD15 Retail Industry Leaders Association’s Public Comments in Response to the FDIC’s February 5, 2007 Notice and Request for Comment Regarding Industrial Loan Companies and Industrial Banks On behalf of its members, Retail Industry Leaders Association (“RILA”) respectfully submits its response to the Federal Deposit Insurance Corporation’s (“FDIC”) February 5, 2007 request for public comment. 72 Fed. Reg. 5217 (February 5, 2007). In particular, RILA appreciates the opportunity to respond to Question 10, which addresses the FDIC’s moratorium regarding applications by commercial companies for industrial loan companies and industrial banks (“ILCs”). I. Introduction By way of background, RILA promotes consumer choice and economic freedom through public policy and industry operational excellence. Our members include the largest and fastest growing companies in the retail industry --retailers, product manufacturers, and service suppliers--which together account for more than $1.5 trillion in annual sales. RILA members provide millions of jobs and operate more than 100,000 stores, manufacturing facilities and distribution centers domestically and abroad. RILA believes that this ILC moratorium is improper because, as noted earlier this year by the Comptroller of the Currency, whether or ...