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An industrial loan company (ILC) or industrial bank is a financial institution in the United States that lends money, and may be owned by non-financial institutions. They provide niche financial services nationwide. ILCs offer FDIC-insured deposits and are subject to FDIC and state regulator oversight. All "FDIC-insured entities are subject to Sections 23A and 23B of the Federal Reserve Act, which limits bank transactions with affiliates, including the non-bank parent company."[1] ILCs are permitted to have branches in multiple states (which is permitted by many states on a reciprocal basis). They are regulated and supervised by state-charters and insured by the Federal Deposit Insurance Corporation. They are authorized to make consumer and commercial loans and accept federally insured deposits. Banks may not accept demand deposits if the bank has total assets greater than $100 million. ILCs are exempted from the Bank Holding Company Act.

ILCs assist numerous charities and provide millions of dollars annually in grants, low interest loans, and service through the Community Reinvestment Act (CRA). Currently, only seven states offer an ILC bank charter. Most ILCs have been chartered by the Utah Department of Financial Institutions.[2] Other states permitting ILCs include California, Colorado, Minnesota, Indiana, Hawaii, and Nevada.

U.S. Industrial Banks Total Assets as of September 30, 2021 (Figures in USD)[3]
Balboa Thrift and Loan Association 320,343
Beal Bank USA 5,752,953
BMW Bank of North America 11,647,749
Celtic Bank 2,712,631
Comenity Capital Bank 9,469,582
Community Commerce Bank 324,319
Eaglemark Savings 388,708
Finance Factors, Ltd 551,608
First Electronic Bank 63,900
Hatch Bank 466,319
LCA Bank Corporation 180,341
Medallion Bank 1,480,084
Merrick Bank 4,357,924
Minnesota First Credit and Savings 25,161
Nelnet Bank 413,155
Optum Bank, Inc 14,624,612
Pitney Bowes Bank, Inc. 796,185
Sallie Mae Bank 28,740,416
Square Financial Services 163,933
Toyota Financial Savings Bank 3,597,650
The Morris Plan Company of Terre Haute 123,361
UBS Bank USA 103,662,107
USAA Savings Bank 1,966,330
WebBank 1,441,759
WEX Bank 3,287,721

Origins of the concept

In 1910, attorney Arthur J. Morris (1881–1973) opened the Fidelity Savings and Trust Company in Norfolk, Virginia, which made small loans to working people under a concept he called the "Morris Plan". Under this lending approach, would-be borrowers had to submit references from two people of like character and earning-power to prove the borrower's creditworthiness, and agreed to repay the loan through the purchase of Installment Thrift Certificates in weekly installments equal to the face value of the loan, less origination and investigative fees.[dubious ] Morris Plan Banks expanded to more than 100 locations in the United States.

Morris Plan banks pioneered the use of automotive financing (through arrangements between the Morris Plan Company of America, essentially a holding company for Morris Plan banks, and the Studebaker Corporation), and, through the subsidiary Morris Plan Insurance Society, credit life insurance (which provided for the loan to be repaid in case the borrower died during the term of the loan, with any residue going to the borrower's estate).


  1. ^ "FDIC Law, Regulations, Related Acts - FRB Regulations".
  2. ^ "Industrial Banks | Utah Department of Financial Institutions".
  3. ^ Federal Financial Institutions Examination Council Central Data Repository's Public Data Distribution, Call Reports