PORTFOLIO Checks & Balances By Chris Cole and Paul Merski, ICBA Closing the ILC back door for good Despite ICBA's previous victories blocking huge companies from entering the banking industry, the industrial loan corporation loophole still exists. ICBA is taking aim to close it permanently. F ourteen years ago, ICBA celebrated an important victory when Walmart withdrew its FDIC deposit insurance application as a Utah chartered industrial loan corporation (ILC). The association achieved success again in 2008 when Home Depot withdrew its ILC application. These huge wins prevented the nation's largest retailers from exploiting the ILC loophole and helped ensure the safety and soundness of the fi nancial system by maintaining the separation of banking and commerce. But it's under attack again. Despite several short-term moratoriums by the FDIC and Congress to stop its exploitation, the ILC loophole remains open 46 Q ICBA Independent Banker Q February 2020 Paul Merski, paul.merski@ Chris Cole, chris. cole@icba.org, is ICBA's executive vice president and senior regulatory counsel icba.org, is ICBA's group executive vice president of congressional relations and strategyhttp://www.icba.org