The missing piece from the FDIC ILC RFI

The FDIC's ILC RFI is missing a very important section on funding. Deposit and funding strategy issues determine the outcome of many ILC applications. Here are some questions they could have asked:

1. How should the FDIC assess an applicant business plan funded primarily by sources other than customer deposits? Should the FDIC's analysis differ to the extent the proposed funding consists of: (1) traditional brokered deposits, (2) securitization, (3) secured wholesale borrowings, (4) parent credit lines or asset purchases? In the case of securitization, how much weight should the FDIC give the presence or absence of a successful securitization program at the parent company?
2. How should the FDIC view deposits that come from the parent's existing customers? Does it matter if the customers currently use deposit-like services offered by the parent (such as through a brokerage, bank partnership, or prepaid stored-value)?
3. What criteria and burden of proof should the FDIC apply in assessing the credibility of the applicant's deposit-raising assumptions? Should the answer be different if the proposed deposit plan involves (1) an innovative strategy with no previous track record; (2) a strategy successfully employed by its parent company or affiliates in other countries or under different licensing structures; or (3) a "plain vanilla" online savings MMDA and CD offering?
4. If an applicant presents a credible alternative business plan to wind down the industrial bank without loss to the DIF, to what extent should the FDIC view this as mitigating the risks of an unproven or difficult-to-achieve deposit strategy?