For example, the FDIC noted in its recent rulemaking that some of the large corporate owners of ILCs tend to use these banks in ways that involve "unusual, affiliate-dependent" business plans and data show that seven of the ten largest ILCs each have more than $ billion in assets but fewer than seventy-five full-time employees. H.R.
698 takes an important step by recognizing that the potential lack of consolidated supervision of the parent and nonbank affiliates of an ILC creates special risks that should be addressed.