For context, read this profile alongside the global bank map and the financial-licensing map. It is a case study in a licensed or partner-bank business model, not a product recommendation. Primary source: FDIC decision.
For a decade and a half industrial and commercial groups effectively had no working route to a bank of their own in the United States: new industrial loan companies waited for FDIC insurance for years without an answer. In 2026, under acting chairman Travis Hill, the door swung open: within five months Ford, GM, Edward Jones and Stellantis obtained approvals for captive ILCs — the first for commercial groups of that caliber in decades.
For the customer this means future deposit products from brands they already pay for a car or a brokerage account. For the builder of financial structures it is a working map of the most flexible charter in the American license zoo: with a published price of entry, a live queue and a clear set of alternatives from OCC trust charters to Georgia's MALPB.
Background
An ILC — industrial loan company — is a state banking charter with full FDIC deposit insurance. The format appeared at the start of the twentieth century as small-loan offices for industrial workers with no collateral and no credit history — hence the name. The defining property of the modern ILC was fixed by the Competitive Equality Banking Act of 1987: such a bank is carved out of the definition of a "bank" in the Bank Holding Company Act, and the parent group stays outside Federal Reserve holding-company supervision — which is why an industrial or commercial company can own one.
An industry grew on that exemption: ILC assets rose from $4.2bn in 1987 to $213bn by 2006, and GE, Merrill Lynch, Goldman Sachs, Target and Harley-Davidson all held banks of their own. Then the format went on pause: Walmart's application (2005) triggered an FDIC moratorium (July 2006, extended into 2007), Walmart and Home Depot retreated, Dodd-Frank added a statutory moratorium (2010–2013), and an unspoken freeze applied thereafter. Exceptions were isolated: Square and Nelnet in March 2020, and the non-commercial Thrivent in 2024.
The genre itself is alive: per FDIC data, as of spring 2025 there were 23 industrial banks operating with $247.4bn of assets — 15 charters in Utah, three each in Nevada and California, and one each in Hawaii and Minnesota. Long-standing residents of the format include WebBank (the partner bank for Klarna and PayPal), BMW Bank of North America, Toyota Financial Savings Bank, Sallie Mae Bank and UnitedHealth's Optum Bank. The turn came under Travis Hill: the FDIC wound down the previous administration's supervisory initiatives and began approving the captives of industrial groups.
Products and pricing
There are no tariffs in the usual sense yet: as of August 2026 none of the four new banks has opened and no rates have been published. What is public are the business models set out in the FDIC approvals:
- Ford Credit Bank and GM Financial Bank (approvals announced 22.01.2026) — auto finance through the purchase of dealer instalment contracts; funding from retail savings accounts and CDs via website and app; starting capital of $1.5bn and $667m, tier 1 leverage ratio of 15% or more.
- Edward Jones Bank (FDIC press release 27.02.2026) — securities-based lending against the portfolios of the broker's clients, funded by sweep deposits, plus deposit accounts and CDs; leverage of 9% or more, starting capital of at least $330m, with the launch planned for 2027.
- Stellantis Bank USA (FDIC press release 14.05.2026) — the same captive model for Stellantis dealers; leverage of 15% or more, deposits through digital channels, brokers and affiliates.
A benchmark for how a captive works with retail already exists: Toyota Financial Savings Bank — a Nevada ILC of 2004 vintage — grew over a year from ≈$9bn to $16bn of assets, became the largest bank in Nevada and offers a CD line-up paying up to 4.37% APY on a $1 minimum, while its money market rates are several times the market average. The newcomers face the same game: building up a deposit base by paying a premium to the market rate.
The Detroit News described the future products of the auto banks as "vehicle savings accounts" — savings accounts earmarked for buying a car, with obvious potential for a discount loop of saving with us and buying from us. The rate policy of Ford Credit Bank and GM Financial Bank will be the wave's first public test: both need to assemble a base quickly to fund their dealer instalment portfolios.
Competitive landscape
The ILC is one track in the charter zoo, and it should be chosen against the alternatives. A classic de novo national bank from the OCC gives the full set of powers, but it pulls the parent under the BHC Act and consolidated Federal Reserve supervision — for a commercial group that path is closed by construction. A national trust charter solves a narrow task — custody and payments without lending and without FDIC insurance: in December 2025 the OCC conditionally approved Circle, Ripple, Paxos, BitGo and Fidelity Digital Assets, so that track is densely occupied by the crypto industry.
The niche edge of the spectrum is Georgia's MALPB, the merchant acquirer limited purpose bank: a charter solely for acquiring, with direct access to the card networks; Fiserv was the first to obtain one and has been processing transactions since spring 2025. The tracks are conveniently compared along three axes: capital (for an ILC, hundreds of millions of dollars and leverage of 9–15%), timing (for an ILC, years against months for niche state formats), and the perimeter of powers and supervision. For a full bank with insured deposits under a commercial parent, the ILC remains the only door.
What it means for the client
Deposit products are appearing at brands the customer already pays: auto finance and brokerage. The scale is serious: Edward Jones means $2.5tn of client assets and ≈9m clients, and the balance sheets of the auto captives are measured in hundreds of billions of dollars. A captive's bank means a single window: the car loan, the savings account earmarked for the same car and a CD in one app.
Onboarding is designed to be digital: the approved business plans describe taking deposits through websites, apps and brokerage channels, with no branches in them. A practical frame: the 2026–2027 window is worth meeting with standard hygiene — the FDIC limit of $250k per depositor per bank, careful reading of the terms and a sober attitude to promotional rates. For the observer the launches will yield rare data: how a captive model digests retail deposits and what premium it actually pays.
Under the hood
The price of entry is now public. The FDIC set the auto groups a tier 1 leverage ratio of 15% — noticeably above the typical 8–9% for a de novo — while Edward Jones got away with 9%: a specialized model with sweep funding looks calmer to the regulator. The common package of conditions: open within 12 months (otherwise the approval expires), capital and liquidity support agreements from the parent — those same capital and liquidity maintenance agreements from Part 354 of the FDIC rules, in force since 2021 — an independent audit, and approval of management changes in the first years.
The application histories show the second currency of the process — time and persistence. GM had been filing since 2020, withdrew its application in 2024 and returned under the new administration; Edward Jones went through the cycle of application in 2020, withdrawal in 2022, refiling in April 2025 and approval. The queue is live: Nissan (June 2025), PayPal (15.12.2025), Affirm with a Nevada ILC (23.01.2026), Klarna (July 2026), and Rakuten, which has been trying since 2019.
Regulation and status
Milestones of the wave: 22.01.2026 — Ford Credit Bank and GM Financial Bank; 27.02.2026 — Edward Jones Bank; 14.05.2026 — Stellantis Bank USA. All four are Utah charters registered in Salt Lake City, all the approvals are conditional, with a 12-month shelf life before opening. In parallel the FDIC is redrawing the framework: in the summer of 2025 the regulator asked the market about the future of industrial banks and proposed amendments to Part 354, while Hill publicly set the task of reviving the entire de novo pipeline.
The opposition is in place. The ICBA calls the format a "relic of a 1980s loophole" that blurs the line between banking and commerce, recalls 2008 — GM's ILC bank of the time went as far as ≈$17bn of government support — and demands that Congress close the loophole; the BPI works through the same arguments in a historical register. For now the thaw has the upper hand — and each successive FDIC decision refines the map of requirements for those in the queue.
FAQ
What is an ILC in plain terms?
A state banking charter in Utah or Nevada with FDIC deposit insurance that a commercial group is allowed to own. The parent stays outside the Bank Holding Company Act, so Federal Reserve holding-company supervision does not extend to the group — a property unique among American banking licenses.
Are these really the first approvals of new ILCs in many years?
Almost: in March 2020 Square and Nelnet received insurance, and in 2024 Thrivent, a financial organization without a commercial parent. Ford and GM became the first industrial captives approved in decades — and that is exactly what makes the 2026 wave a turning point.
Why do the banks of the wave have different conditions — 15% and 9%?
The FDIC calibrates capital to the risk of the model. The auto captives are assembling a retail deposit base from scratch to fund a loan portfolio — they were set a tier 1 leverage ratio of 15%. Edward Jones funds itself with sweep deposits from its own brokerage clients against secured loans — for the regulator 9% and capital from $330m was enough.
How does an ILC differ from an OCC trust charter and a MALPB?
A national trust charter covers custody and payment services without insured deposits and without lending — Circle, Ripple, Paxos and BitGo received one conditionally at the end of 2025. Georgia's MALPB covers acquiring only. The ILC delivers a full bank: insured deposits plus lending under a parent outside the BHC Act; the price is elevated capital and the political vulnerability of the format.
Can a group of smaller scale realistically repeat this path?
The reference points from the approvals: capital from $330m (Edward Jones) to $1.5bn (Ford) and leverage of 9–15%. The bar is high, so the choice of charter is worth modeling against the alternatives — a national trust, a MALPB, a classic de novo — on capital, timing and the perimeter of supervision.