Definition

An industrial bank charter (industrial loan company / ILC) is a U.S. state-chartered banking license — commonly sought in Utah — that allows non-bank parent companies to own FDIC-insured institutions with restrictions on certain commercial lending activities compared to full national banks.

Key Points

  • 2026-07-31: Related state track — circle nydfs limited-purpose-trust-charter complements federal OCC trust (not an industrial bank charter) (2026-07-31-circle-nydfs-trust-charter)

  • Fintech route: klarna, Affirm, PayPal, and others have pursued or hold industrial bank charters

  • Requires dual approval: state regulator (e.g., Utah DFI) + FDIC deposit insurance

  • Enables in-house payments, savings, credit, and merchant services without full national bank conversion

  • Subject to heightened regulatory scrutiny; approval timelines uncertain

Sources