The key question in the FDIC ILC RFI

There’s a question in the FDIC’s Industrial Bank RFI that will make or break an industrial bank application.

Which one? That depends on the applicant, the business model, and the structure. But I can say this with certainty: the question is in there.

That's because the RFI goes far beyond the high-level debate over whether industrial banks should exist or who should be allowed to own them. It drills into specific factors that drive FDIC’s decision-making on individual applications.

In fact, almost every decisive issue I’ve seen in real-world industrial bank applications is reflected somewhere in the RFI. If you are considering an application, it’s essential to understand which questions touch your circumstances, and to respond with the best case for your preferred policy outcome, framed in terms that could persuade the FDIC.

This is not a paper exercise. The leadership shift at the FDIC is just part of the story. A significant wave of senior FDIC staff has retired early in the past couple of months. That means new decision-makers and new voices in the room.

This RFI matters more than most people think. If you’re considering filing or advising on an industrial bank application, now is the time for informed and nuanced engagement.