States are the primary regulators of nonbank mortgage companies. State financial regulators have broad licensing, examination, investigation, and enforcement authorities, as outlined below. Prudential standards, including financial capacity (i.e., net worth/capital and liquidity), governance, and risk management requirements, are also a matter of state law enforced by state regulators. Since the largest nonbank mortgage companies are licensed in all or

In 1996, with overwhelming support, Congress amended the Federal Deposit Insurance Act to require that one of the positions on the FDIC Board be held by someone with “State bank supervisory experience.”

The letter and the spirit of the law all indicate that this FDIC Board Seat requirement is only met by a person who has worked in state government as a supervisor of state-chartered banks

The Honorable Sherrod Brown Chairman Banking, Housing, and Urban Affairs Committee United States Senate Washington, DC 20510 The Honorable Pat Toomey Ranking Member Banking, Housing, and Urban Affairs Committee United States Senate Washington, DC 20510 Dear Chairman Brown and Ranking Member Toomey: On behalf of the Conference of State Bank Supervisors (CSBS)1, I write to express my disappointment with the

The Honorable Jesus “Chuy” Garcia U.S. House of Representatives Washington, D.C. 20515 Dear Representative Garcia: On behalf of the Conference of State Bank Supervisors (CSBS), 1 I write to express our concern regarding legislation Congress is considering eliminating the exemption for industrial loan companies (“ILCs”) from the definition of a bank under the Bank Holding Company Act (“BHCA”). State regulators