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For release at 2 PM, EST
Monday, March 3, 1969




Banking Structure and Banking Markets
Remarks of George W. Mitchell
Member, Board of Governors of the Federal Reserve System
at a
Conference Sponsored by Marketing/Savings Division
of
The American Bankers Association
St. Louis, Missouri
March 3, 1969

Banking Structure and Banking Markets
Growth seems to be the magic word among businessmen today.
The more aggressive American firms aspire to outgrow their community,
their State, the Nation, the industry and any record of their past
performance.

The extension of this drive is apparent in the con­

glomerate movement, the flow abroad of American capital and the
concentrated attention of investors on firms exploiting new products
and innovative processes made possible by technological progress.
Banks have not been entirely immune to this virus,
especially the larger and more aggressive institutions.

This is

evident by their interest in -the one-bank holding company, foreign
branches or affiliates, and in "buying bigger footings" by the
issuance of negotiable

CD's and the purchase of Euro-doilars

and Federal funds.
For a long time after the restructuring of banking in the
1930's banks were content to accept the confines of State laws on
office locations and an elaborate harness of statutory and regulatory
constraints on innovative practices.

In turn, grants of quasi­

monopoly power came from State legislatures in the form of home-office
protection and branching limitations and from regulatory authorities
in the form of limitations on entry supported by findings of "over
banked" conditions when competition threatened earnings.

All of

this was consistent with an environment in which banks were relatively
indifferent to growth objectives beyond retaining their share of a
Government delineated neighborhood, city, county or State market.




In recent years more and more banks have been chafing at
these restrictions.

They see first hand the spectacular growth of

nany of their industrial and commercial customers.

Looking back

chev realize how much more perceptive nonbank financial institutions
were in occupying and developing the markets that they might have
nurtured.

But there is more to it than rekindled envy for the green

grass on the other side of the fence so far as some banks are concerned.
The realistically minded know that accelerated growth is not going to
be theirs by virtue of Government fiat or sheltering policies but that
to succeed they must meet the compelling force of competition for
manpower and financial resources.
For example, a banking institution cannot break out of a
treadmill existence without a superior management and technical cadre.
It has problems like persuading a "top of his class" graduate to con­
sider a career in an industry burdened by overlapping growth lids when
the young man's alternative is moving up with an innovating concern
whose growth ceiling is limited only by its resourcefulness in
technological adaptations.
Or consider the difficulties faced by the planning officer
in a growth-minded bank who has to identify the sources of deposits
or borrowings to achieve his institution's growth in the face of
continuing attrition in demand deposit balances and the steadily
rising interest in equities or equity-sweetened debt.

Even for banks,

as we know, the question often is, where is the money coming from?




-3-

This, I take it, is a key part of your problem today.
tell your planning officer where money is and how to get it.

To

In

1969, and perhaps for some time to come, investing or loaning the
bank's money will involve a minimal promotional effort--in fact, I
am often told these days that such promotional effort is mainly
negative.

And I am sure it is— for some kinds of loans.

But there

are other loans and customers whose business is more profitable and
on which promotional efforts could still be concentrated even though
the institution as a whole was "loaned up" or fully invested.
Rather than explore these possibilities, of necessity as an amateur,
I want to discuss some of the promotional possibilities of adding
to your institution's resources, given the nature of our banking
structure.
The banking structure of the United States is usually
characterized as diffused because there are upwards of 13,500
banking organizations in the Nation.

It is said to be dominated

by unit banks because about 10,000 of these 13,500 organizations
are unit banks.

And it is asserted that it is becoming more con­

centrated because of merger and holding company acquisitions and
because of the relatively limited growth in numbers of banks
(about 400 since 1959) compared to population and economic growth.
For example, this is the way the Supreme Court of the
United States characterized the Nation's banking structure in
U.S. vs. The Philadelphia National Bank, in 1963:




-4-

"Commercial banking in this country is primarily unit
banking. That is, control of commercial banking is diffused
throughout a very large number of independent, local banks-13,460 of them in 1960--rather than concentrated in a handful
of nationwide banks, as, for example, in England and Germany.
There are, to be sure, in addition to the independent banks,
some 10,000 branch banks; but branching, which is controlled
largely by state law--and prohibited altogether by some States-enables a bank to extend itself only to state lines and often
not that far. It is also the case, of course, that many banks
place loans and solicit deposits outside their home area. But
with these qualifications, it remains true that ours is essentially
a decentralized system of cotnmunity banks. Recent years, however,
have witnessed a definite trend toward concentration. Thus, during
the decade ending in 1960 the number of commercial banks in the
United States declined by 714, despite the chartering of 887 new
banks and a very substantial increase in the Nation's credit
needs during the period. Of the 1,601 independent banks which
thus disappeared, 1,503, with combined total resources of well
over $25,000,000,000, disappeared as the result of mergers."
Host of us have unthinkingly accepted such superficial
and inadequate characterizations of our banking structure because
we've not considered them analytically or tested them against our
own knowledge and experience.

How should our banking structure be

described?
While the FDIC Summary of Accounts and Deposits for 1966
shows that over 75 per cent of the country's banks are unit banks
it does not follow from this one fact that "commercial banking in
this country is primarily unit banking."

Actually, the 10,525 unit

banks hsd only 30 per cent of the country's bank deposits and only
31 per cent of the country's banking customers.
even less prevalent among large banks.




Unit banking is

There are, among the 150

largest banking organizations in the country, 103 branching
systems, 34 holding companies, and only 13 unit banks.

These

unit banks have only 8 per cent of the total deposits held by
the 150 banking organizations.

Thus, in any meaningful sense:

i.e., in terms of aggregate resources, deposits or number of
customers— U.S. banking is primarily composed of branching systems
even though office locations are confined, for the most part, by
State lines.
In the second place, our system may appear significantly
different from that of many other countries only because of a false
assumption— namely, that since there are 13,500 banking organizations
there could hardly be such great disparities in size as to allow of
much concentration.

Few people realize how sharply the siice dis­

tribution of U.S. banks is skewed by the large size of a taw
institutions.

They are surprised to learn that 13 banks have one-

fourth of the country's deposits.

And even more surprised to learn

that at the other end of the distribution the smallest 6,500 of the
country's banks, combined, have only 5 per cent of total deposits.
These facts, however, are not inconsistent with the
structure of the American economy nor do they necessarily imply
a level of concentration or dispersion that should be viewed with
alarm.

A banking structure in which 150 institutions have 55 per

cent of the country's deposits is not inappropriately geared to
serve enterprises, institutions and government« of the size that




-6-

account for the preponderance of the country's economic activity.
And the fact that these 150 banks serve nearly half of the country's
banking customers is not surprising if wc bear in mind where most
Americans live and work.
It is a little more difficult to rationalize the economics
of the other end of the banking structure--though it can be explained
and justified on other grounds.

One-fourth of the country's banks

have less than $2.7 million in deposits and half of our banks have
deposits of less than $5.4 million.

It is by no means certain banks

of this size can survive and prosper in the main stream of a competitive,
rapidly changing economy.
A third point about the U.S. banking structure has to do
with concentration trends.

The best evidence presently available

indicates that banking has not shown a significant trend toward or
away from greater concentration in the past 10-12 years.

The shares

of the market held by the largest and smallest banks have changed
very little since 1957 (the earliest date as of which we have such
data).

For example, the largest one-tenth of one per cent of the

banks had 23.1 per cent of total deposits in 1957--they have 24.3 now.
The next largest .9 per cent had 28.4 in 1957 and 28.5 now.— ^

1/ (See table on next page)




-7-

Nat.tonal Trends in Concentration Ratios for Total Deposits
1957________
Per cent Cumulated
The largest banks
Largest .1 per cent
Next largest .9 per cent
tt
••
4 >0
"
"

"

10.0

"

The smallest banks
Smallest 25 per cent
Next smallest 25 per cent
•I

m

"

»

25
10

"
"

1.6

3.7
7.4
5.6
12

CO




12.0

00

Number of bank organizations

23.1
28.4
18.2

Share of total deposits
1961
1967
Per cent Cumulated
Per cent Cumulated

51.5
69.7
81.*/

24.5
28.1
18.5
11.3

52.6
71.1
82.4

5.3
12.7
18.3

1.5
3.5
7.1
5.4

5 &
12.1

17.5

12 ,752

24.3
28.5
18.6

52.8
71.4
82.5

11.1

1.5
3.6
7.1
5.3

5.1
12.2

17.5
13 ,014

-8-

Let me revert now to the relationship between banking
structure--in being and in transition— and bank liability markets.
It seems to me that in recent years there has been a steady
diminution in the constraints that structure places on competition
and growth, and this trend is continuing, structure itself is being
modified by the liberalization of locational constraints.

Such

changes have been spectacular in some sections of the country, as,
for example, along the Atlantic seaboard.
Everyone knows, I am sure, that the largest banks in the
country have grown by competing in national and even world-wide
asset and liability markets.

And most of us realize that the

inability of a bank to freely branch beyond home city, county or
State has only partially restricted aggressive well-managed
institutions from competing for loanable funds well beyond the
boundaries of their primary service areas.
The major nonlocal sources of funds are the money and
security markets where banks can borrow short, for as little as
one day, or long, for as much as several years, using a considerable
variety of debt or depository instruments.

Many of these alterna­

tives are not as available for the medium-sized bank as for the
larger or largest banks.

This is often the case, for example,

when banks have gone beyond local sources by borrowing, in some
form, from other banks.

Obviously, the well-established correspondent

practice of supplying certain services to other banks in return




-9-

for invostible balances is pretty much of a one-way street.

These

means of adding to a bank's resources involve, to a greater rather
than lesser degree, increased competition in impersonal money and
capital markets: their impact on local liability markets is limited.
But what can banks do to sweep up more resources that lie
closer to home?

How tightly do locational constraints limit the

capacity of an aggressive, innovative institution to penetrate-intensively and extensively— these bank or nonbank markets?
Some part of the failure of banks to exploit such markets
is traditional and imbedded in the attitudes of bankers.

Reaching

out beyond one's traditional "territory" to compete for customers
served by others is a venturesome step and not always easily taken.
A competitive behavior which at one time was considered bad taste,
if not bad banking, is not easily embraced.

But if a bank wants to

compete aggressively, albeit fairly, in its primary service area or
in an expanded service area with whom would it be competing, and how?
If we think of banks as providing a money service they
compete with other banks and the Treasury's currency and coin.

If

we think of banks as providing a liquidity or near-money service
they also compete with other banks but in this arena a large variety
of nonbank competition is likewise very active.

Banks in this

function are competing with savings and loan associations, credit
unions, short- and long-term market instruments and, in a degree,
equities.




-10How can banks promote larger shares in these markets?
Speaking first of money services, it seems to me that EDP has
opened up possibilities of cxoanded service that tmve only been
timidly and selectively considered.

Some of the caution, no doubt,

stems from the wariness of people who have found that computers
have a way of not attaining their obvious potential within a
predicted time period.

But there is much more to it than that.

Banks have not accepted the logical form of a money service implicit
in computer technology, namely, the credit transfer.

They continue

to visualize the check tailing along behind the electronic impulse
in an ever rising paper accumulation.

The debit transfer (check)

is outmoded by the computer; the recent English giro system
installation dramatizes this fact.
Simply put, if we are going to use computers in banking
we cannot avoid an ultimate breakdown in our capacity to make
paper flow as fast as electronic data processing and transmission
unless we have a more efficient mechanism than the check for
authorizing money payments within the banking system.

An arrange­

ment compatible with EDP would be a direct instruction by the
depositor to his bank directing it to credit the account of another
party in that bank, or any other bank in the country.

The proof

of authorization would thus at all times be in possession of the
paying bank.

The transfer of funds and proof that the transaction

has been consummated would be the contribution of the electronic
gear and the essence of the bank's money service to its customers.




-

11-

A credit transfer mechanism is vastly cheaper than the*
check, more certain, dateable, and capable of being a builder of
demand deposit balances, as well as an eroder.

Banks have learned

that many of their services other than credit can be charged for and
here is a service that has enormous possibilities for intensifying
market penetration as well as extending it.
Banks have probably been somewhat myopic in resigning
themselves to locational constraints in light of the opportunities
inherent in transport and communication changes of recent years.
An electronic credit transfer mechanism has the potential to do
far more for aggressive bank merchandising over the years ahead
than a far-flung string of branches.

Electronic networks connecting

the bank's computers with those of their largest customers, and with
their customers' customers— can attract and service sizable deposits
with much greater efficiency and mobility and less per-dollar cost
than static street-corner plants, or community branches.

Even the

small personal depositor is much more reachable remotely than is
often thought. Only a few banks— in fact I know of only one--promote
a fairly complete banking service from remote locations, yet 1
know a great many people who have moved to Washington and still
retain their previous banking connection's services, however remote
the location.

People are not adverse--given some incentive--to

remote banking but bankers often seem to be.




-

12-

The language "a cluster of products and services" has
been used by the Supreme Court to suggest that banks' services
are primarily sold in prepackaged combinations--or, to use an
invidious term, as "tied in sales."

My own view is that there is

not nearly as much of this today as the Court implies or as is
advantageous to banks or their customers.

A systematic promotion

of various service combinations could ensure more stability in
deposits and less costly services to depositors particularly if
"near money" services were a part of the package.
The competition banks face from some other intermediaries
and from the market for such services has been intense for several
years now.

It has been held in check to some degree by interest

rate ceilings.

But banks, with their uniquely broad variety of

services and packaging potential seem to have the competitive edge
except in periods of severe monetary restraint when they have lost
ground to market instruments.

Promotion of "near money" services

has been most difficult and the sell the hardest, yet the record
again shows numerous competitive opportunities, e.g., the penetration
of locations where rates are below ceilings because of ineffective
competition or the further tailoring of liability instruments to
customer:;' needs and convenience.
going t"> come as manna from Heaven.

Gains along these lines are not
They will require imaginative

promotional and technical skill as well as the desire to innovate
banking's role and function.




But if banks want to be a growth

-13-

business in today1s economy they can only do so by intensifying
and extending their competitive effort in every direction.