Letter in Opposition to GM’s Application to Be an ILC

ICBA told the Chicago Regional FDIC that General Motors’ application to form an industrial loan company should not be approved because ILCs owned by commercial parent companies cannot function as neutral arbiters of credit due to the inherent conflict of interest at the heart of their business model. ICBA noted that they pose an undue risk of losses to the Deposit Insurance Fund and add unnecessary systemic risks that harm the entire banking system.