Stated simply, if ILCs want to benefit from expanded powers and become functionally indistinguishable from other insured banks, then they and their corporate parents should be subject to the same rules that apply to the owners of other full-service insured banks.
The Board believes that important principles governing the structure of the nation’s banking system such as consolidated supervision, the separation of banking and commerce, and the maintenance of a level playing field for all competitors in the financial services marketplace - should not be abandoned without careful consideration by the Congress.