{"content":[{"text":"August 10, 2020","bbox":{"left":0.10469,"top":0.149423,"width":0.131192,"height":0.019134999999999985}},{"text":"The Honorable Mike Crapo \n Chairman \n Committee on Banking, Housing \n and Urban Affairs \n United States Senate \n Washington, DC 20510","bbox":{"left":0.10469,"top":0.181299,"width":0.24628,"height":0.09451500000000002}},{"text":"The Honorable Sherrod Brown \n Ranking Member \n Committee on Banking, Housing \n and Urban Affairs \n United States Senate \n Washington, DC 20510","bbox":{"left":0.447239,"top":0.181299,"width":0.24667100000000003,"height":0.09451500000000002}},{"text":"The Honorable Maxine Waters \n Chairwoman \n Committee on Financial Services \n U.S. House of Representatives \n Washington, DC 20515","bbox":{"left":0.10469,"top":0.287953,"width":0.25099,"height":0.079376}},{"text":"The Honorable Patrick McHenry \n Ranking Member \n Committee on Financial Services \n U.S. House of Representatives \n Washington, DC 20515","bbox":{"left":0.447239,"top":0.287953,"width":0.251384,"height":0.079376}},{"text":"Dear Chairman Crapo, Ranking Member Brown, Chairwoman Waters, and Ranking Member McHenry:","bbox":{"left":0.10469,"top":0.379468,"width":0.778168,"height":0.018303000000000014}},{"text":"We are writing in response to a recent joint trade association letter sent by the Bank Policy Institute \n (BPI), the Center for Responsible Lending (CRL), and the Independent Community Bankers of America \n (ICBA). This letter calls on Congress to enact a three-year moratorium on new Industrial Loan Company \n (ILC) charters, to provide Congress the time to address the ILC loophole. Their letter is long on opinion, \n but unfortunately short on actual facts. It not only misrepresents the nominal risk posed by ILCs to the \n US financial system, but it also misstates the regulation of ILCs and the role they play in the US \n economy.","bbox":{"left":0.10469,"top":0.409923,"width":0.7879309999999999,"height":0.10982999999999993}},{"text":"This letter will correct those mistakes and provide you with an accurate story about ILCs, their \n regulation, the risks they pose, and how they are helping to grow the economy and provide much- \n needed innovation to the US banking system.","bbox":{"left":0.10469,"top":0.531905,"width":0.7403379999999999,"height":0.04889600000000005}},{"text":"At the outset, the most telling fact that merits repeating every time the subject of ILCs is raised is that \n the FDIC-insured industrial banks in Utah and Nevada have for the past 35+ years been the best \n capitalized, most profitable, safest and soundest group of banks insured by the FDIC. This is fact, not \n hyperbole. Nothing in the history of the industrial banks provides any basis to argue that they present a \n significant risk to the FDIC, the banking industry, or the nation’s economy. The position taken by these \n trade associations is pure political posturing advanced to try to stifle competition.","bbox":{"left":0.10469,"top":0.592966,"width":0.7794719999999999,"height":0.09451500000000002}},{"text":"1","bbox":{"left":0.885882,"top":0.882667,"width":0.00813699999999995,"height":0.016776000000000013}}],"images_bbox":[{"left":0.105098,"top":0.055458,"width":0.256075,"height":0.057271},{"left":0.0,"top":0.765453,"width":0.988626,"height":0.106061}],"images_bbox_not_text_overlap":[{"left":0.105098,"top":0.055458,"width":0.256075,"height":0.057271},{"left":0.0,"top":0.765453,"width":0.988626,"height":0.106061}]}