My concern with this bill is that it is a solution in search of a problem.

We already have a number of banks that have been chartered with commercial parents.  The regulation track record of this type of institution is a stellar track record.  I think that the Federal Deposit Insurance Corporation -- the FDIC -- along with the State of Utah, which regulates these particular banks, has a great track record.  I fear that this bill takes us down a path that blocks a circumstance that won’t arise. I question whether Congress should take us down that path.

As the debate about ILCs has moved along, we’ve also said, well, what about the auto companies?  Maybe we should carve out an exemption for them.  What about the existing commercial entities -- for example Target already has one. We need to create an exemption for them.  All this calls into question the basic premise of if there is a problem to have commercial ownership of this industry.

During a hearing in the House Financial Services Committee a few weeks ago, a comment was repeated by a witness that in essence was, “My gosh, what if Enron and WorldCom had one of these?  Where would we be then?