The Board, however, believes that, because the corporate owners of ILCs operate outside the prudential and legislative framework applicable to the corporate owners of other types of insured banks, ILCs should not be authorized to offer transaction accounts to business customers or branch de novo across state lines.
Our position on these matters is long-standing and based on the broad policy issues presented by the special exemption in current law for ILCs chartered in certain states. ILCs are banks; specifically, they are state-chartered FDIC-insured banks.