Public Comment, Industrials Banks, National Assn. of Realtors

REGULATORY & INDUSTRYRELATIONS Joseph M. Ventrone Vice President 202.383.1095 500 New Jersey Avenue, NW Fax 202.383.1204 Washington, DC 20001-2020 May 7, 2007 Robert E. Feldman Executive Secretary Attention: Comments/Legal ESS Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 [transmitted by e-mail to comments@fdic.gov] RE: RIN 3064-AD15 Dear Mr. Feldman: On behalf of more than 1.3 million members of the National Association of ®REALTORS (NAR), I am pleased to provide comments to the Federal Deposit Insurance Corporation on the proposed rule on Industrial Bank Subsidiaries of Financial Companies 1published in the Federal Register on February 5, 2007. ®The National Association of REALTORS , “The Voice for Real Estate,” is America’s largest trade association, including NAR’s five commercial real estate institutes and its societies ®and councils. REALTORS are involved in all aspects of the residential and commercial real estate industries and belong to one or more of some 1,500 local associations or boards, and 54 ®state and territory associations of REALTORS . The proposed Guidance will have an impact on ®the availability of financing homeownership and, therefore, is of vital concern to REALTORS . The proposed rule establishes new oversight rules for industrial loan companies (ILCs) owned by companies that are (a) engaged solely in financial activities and (b) not subject to ...