BPI and ICBA Comment on Albert Corporation’s Application for Deposit Insurance

Dear Director Worthing:

The Bank Policy Institute^[1] ("BPI") and the Independent Community Bankers of America^[2] ("ICBA") write regarding Albert Corporation's ("Albert") application on behalf of its proposed Utah state-chartered industrial bank ("Albert Bank") for Federal Deposit Insurance Corporation insurance.

For the reasons discussed below, and as we have long advocated, Congress should close the industrial loan company ("ILC") loophole-and, until such time, the FDIC should not issue deposit insurance to any ILC applicant, including Albert Bank. At a minimum, the FDIC should pause consideration of the application until the Agency provides greater transparency regarding its policy approach to new ILC applications and establishes a framework that appropriately addresses the unique risks posed by technology-company-owned ILCs.

Albert is a fintech company founded in 2015 that enables its users "to take control of their finances through a suite of financial tools and services that Albert provides online and through its mobile application."^[3] These tools and services include "a budgeting application," an "automatic savings tool that allows subscribers to save money into a savings or brokerage account, an "Albert Cash" product that provides users access to a consumer checking account and "Albert Protect" which provides credit monitoring and identity theft protection services."^[4]

Albert proposes to establish Albert Bank as a wholly owned subsidiary to provide banking services directly to Albert users. The application states that the Bank's primary purpose will be to provide those services "at lower costs and with better service than Albert currently is able to provide."^[5]

While we support innovation and competition in financial services, we do not support providing a technology company with access to the federal safety net through an insured bank while avoiding the consolidated prudential supervision and activity restrictions applicable to the corporate owners of other full-service insured banks.

To read the full comment letter, please click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.

[2] The Independent Community Bankers of America® has one mission: to create and promote an environment where community banks flourish. We power the potential of the nation's community banks through effective advocacy, education, and innovation. As local and trusted sources of credit, America's community banks leverage their relationship-based business model and innovative offerings to channel deposits into the neighborhoods they serve, creating jobs, fostering economic prosperity, and fueling their customers' financial goals and dreams. For more information, visit ICBA's website at icba.org.

[3] Albert Bank, Interagency Charter and Federal Deposit Insurance Application - Public Volume I, at 1 (submitted July 20, 2026) ("Albert Application").

[4] Id.

[5] Id.