Elsewhere in the Trust Examination Manual, the FDIC notes your concern about pledging securities for private funds and states: “In order for a state nonmember bank to pledge assets to secure private deposits, the bank must file an application for approval under Part 362 of the FDIC's Rules and Regulations.” Section E.3.b. ERISA, Deposit Insurance, and Pledging. Meanwhile, the Illinois Department of Financial Regulation (IDFPR) has issued an Interpretive Letter, 98-12, which opines that the Illinois Banking Act permits state banks to pledge assets to secure private deposits, not just public funds. See 205 ILCS 5/7(25)(a) (granting Illinois banks the same powers as Illinois savings banks), and 205 ILCS 5/1008(a)(13)(B) (granting Illinois savings banks the general power to “secure deposits”). However, the IDFPR’s Interpretive Letter goes on to note that an institution should contact the FDIC to determine whether the FDIC’s written consent is required before pledging any assets to secure private deposits. See 12 CFR 362.3(b).