Wal-Mart Stores Inc. reiterated its commitment Wednesday not to engage in branch banking and defended the existing regulatory system — including Utah's — providing industry oversight.

At the close of the Federal Deposit Insurance Corp.'s "comment period" in its consideration of Wal-Mart's application for deposit insurance for its proposed industrial bank in Utah, the world's largest retailer submitted a 52-page letter arguing that it poses "no unusual risks or problems" to the nation's financial system.

The FDIC provides deposit insurance to the nation's banks and thrift institutions.

"We would like to reiterate that we are fully committed to meet all statutory factors necessary to obtain federal deposit insurance," Jane J. Thompson, president of Wal-Mart Financial Services, wrote in the letter's introduction. "In addition, as we have stated several times publicly in oral and written testimony, our business plan does not include branch banking and we fully expect to receive a condition stating such a restriction."

To operate in Utah, industrial loan corporations (ILCs, or industrial banks) need approval from the FDIC and the state's Department of Financial Institutions. Wal-Mart filed its applications with both agencies in July 2005.

Furor and protests ensued, with critics fearing that Wal-Mart would approach banking the way it has approached retail, resulting in market domination and the demise of competition, and that the growth of the industrial bank industry serves to blur the line between banking and commerce, destabilizing the nation's financial system.

Wal-Mart has repeatedly asserted that its bank will handle only credit card and other electronic transactions, eliminating the need for a third party processor and saving the company money.

In an unprecedented move, the FDIC began public hearings on Wal-Mart Bank's application in April. On July 28, it imposed a six-month moratorium on industrial bank applications for deposit insurance, citing the need to "assess developments in the ILC industry, to determine if any emerging safety and soundness or policy issues exist involving ILCs."

The moratorium is effective through Jan. 27, 2007, and includes all pending bank applications and applications for changes in banking control, which include Wal-Mart Bank and another high-profile application submitted by Home Depot.

As of Wednesday, the Utah Department of Financial Institutions had not accepted the bank's application as complete, according to department commissioner Edward Leary.

In its letter, Wal-Mart argued that "the FDIC and the State of Utah have a long track record of successfully supervising ILC organizations in a manner that is comprehensive, effective and tailored to the facts and circumstances posed by a particular organization."