Celtic Bank Comments on Industrial Banks (RIN 3064-ZA48)
Archived source: Celtic Bank Reese S Howell Jr Rin 3064 Za48 Pdf 3feab8f94ac32586. Captured from www.fdic.gov.
Cited in: Reese Howell Jr.
Full text
celtic
bank
September 19, 2025
Federal Deposit Insurance Corporation
Jennifer Jones, Deputy Executive Secretary
550 17th St NW
Washington, DC 20429
Re: Comments RIN 3064-ZA48 - Request for Information on Industrial Banks and Industrial
Loan Companies and Their Parent Companies
Ladies and Gentlemen,
Celtic Bank appreciates the opportunity to respond to the FDIC’s Request for Information
regarding oversight of industrial banks and their parent companies. As an operating industrial
bank, we support efforts of the FDIC to provide more clarity around the approach for industrial
bank charter issuance, oversight, and ensuring safety, soundness, and consumer protection while
fostering innovation and responsible growth.
Celtic Bank is a Utah-chartered industrial bank headquartered in Salt Lake City, Utah, founded in
2001. We operate as a nationwide lender with strong focus on Small Business Administration
loans, innovative commercial financing, and strategic lending partnerships with fintech
companies. Over the years, Celtic Bank has demonstrated remarkable resilience, successfully
navigated the Great Recession and other economic downturns while continuing to grow and
serve communities across the country. Our ability to adapt and innovate during times of financial
uncertainty has expanded opportunities for both consumers and small businesses, helping them
access the capital they need to thrive. Celtic Bank has consistently ranked among the top 10 SBA
lenders nationally for more than a decade, assisting thousands of small businesses each year
across the United States. As an industrial bank, Celtic Bank is able to play a vital role in providing
loans to a diverse range of borrowers, including those with limited access to traditional credit.
Widely recognized as a leader in innovative banking, we have built strong, forward-thinking
partnerships with fintechs and have consistently maintained sound and secure operations. Our
commitment to financial inclusion and innovative lending solutions continues to empower
entrepreneurs and strengthen local economies nationwide.
Industrial banks are, and should continue to be, regulated in the same manner as other insured
depository institutions. Although industrial banks are not subject to Federal Reserve consolidated
supervision, the FDIC imposes rigorous ongoing supervision over our bank and our parent
Page 1 of 3
celtic
bank
company that is similar to the supervision of the other prudential regulators. This ensures safety
and soundness, and consumer protection, while allowing more diverse ownership structures.
Industrial bank applications for deposit insurance are and should be subject to the same statutory
factors that apply to any other applicants for deposit insurance. The requirements for approval
should be calibrated based on the bank’s proposed business model, as well as the parent’s size,
complexity, and operational characteristics. The business model should be evaluated to ensure
that an industrial bank is not a captive structure that may pose heightened risks to safety and
soundness, limit market competition, and undermine the public benefit standard required for
deposit insurance. An industrial bank must demonstrate independence from their parent; this
should be supported by requiring separate boards, management, and financials. Additionally,
capital adequacy requirements of the industrial bank should be clearly established to ensure the
bank can operate independently of their parent companies, while the parent should be capable
of providing additional support if needed.
Parent companies engaging in non-bank financial services may benefit the marketplace with
additional regulatory experience, strength of governance, and risk management expertise. Their
affiliation with industrial banks is mutually beneficial, enabling shared customer bases and
product lines. Under current regulatory requirements, services between parent and bank must
comply with Regulation W and Sections 23A and 23B of the Federal Reserve Act. These
relationships can reduce costs and improve access to underserved markets.
Non-financial parent companies may also benefit the banking industry by diversifying bank
ownership to support broader access to financial services and economic development. Non-
financial companies can aid underserved markets and introduce innovation under FDIC oversight.
The FDIC should require foreign-owned industrial banks to provide access to the same level of
information from foreign parent companies as it does from U.S.-based parents. Due to the
varying degrees of information, the requirements for foreign owned banks should be tailored to
the parent’s risk profile and agreed to prior to charter issuance.
Industrial banks continue to be among the safest and soundest banks in the country and must
meet the same requirements for consumer protection as other banks. The FDIC has historically
and continues to maintain robust oversight of both the industrial bank and their parent, in so
much as the parent company of an industrial bank is required to enter into an extensive written
supervisory agreement with the FDIC and the subsidiary industrial bank.
In conclusion, we believe that industrial banks contribute to the diversification of the banking
system in a meaningful way by introducing alternative business models into the banking
ecosystem while undergoing robust regulatory oversight by the FDIC and the respective state
Page 2 of 3
celtic
bank
departments of financial institutions. We appreciate the opportunity to share our perspective
and look forward to a thoughtful and transparent policymaking process by the FDIC to foster
meaningful dialogue on the role of industrial banks in expanding access to financial services,
supporting communities, and driving innovation across the banking sector.
Sincerely,
Reese S Howell, Jr.
Chairman & CEO
Page 3 of 3
File and source
- File
- celtic-bank-reese-s-howell-jr-rin-3064-za48-pdf_3feab8f94ac32586.pdf
- Size
- 688,915 bytes
- SHA-256
- 497b91fad2a8c2b5b7f5e28edf58c787cb3c7d413a00e4822801b25ac095aa32
- Original
- www.fdic.gov