Letter on Nelnet ILC Application
To:
Dear Mr. LaPierre:
The
According to the application,
ICBA's Comments As we indicated with both the
As we stated in our comment letters regarding the
The
Both moratoriums were imposed to evaluate (1) industry developments, (2) emerging safety and soundness issues or policy issues involving ILCs or other risks to the insurance fund, and (3) whether statutory, regulatory, or policy changes should be made in the
A third moratorium on ILC deposit insurance applications was imposed when the Dodd-Frank Act was passed in 2010. Section 603 of the Dodd Frank Act imposed a three-year moratorium on ILCs controlled by commercial firms and prohibited the
ICBA believes that if the
As we pointed out in our letter opposing Square's
In 1999, the
The
Sincerely,
/s/
Executive Vice President and Senior Regulatory Counsel
cc:
Foot notes:-
1
2 See the FDIC Notice dated
3 See also Federal Register Notice, 71 FR 43482, dated
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