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COPY BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION March 11, 1941 Messrs. W i l l i a m P. Funsten, Supervising Examiner, Federal Deposit Insurance Corporation; R. B. West, Vice President, Federal Reserve Bank of San Francisco; and Irwin D. Wright, Chief National Bank Examiner, San Francisco, C a l i f o r n i a . Gentlemen: As you know, we have maintained that our as$et values f o r bank premises should be our a c q u i s i t i o n cost plus c a p i t a l additions l e s s depreciation allowance f o r ordinary wear and obsolescence from the date of a c q u i s i t i o n . We have c o n s i s t e n t l y maintained that the o v e r - a l l book value of our bank premises i s proper and conservative. In t h i s contention we believe that we have been sustained by current American Appraisal Company valuations. You a l s o know that there has been disagreement on t h i s question. I t i s my understanding that the adjustment committee appointed pursuant to the provisions of Paragraph 5 of the C o m p t r o l l e r s "Requirements" of March 6, 1940, i s not agreed as to the use of the formula set f o r t h i n that paragraph. I understand further that the committee i s prepared t o give favorable consideration to the f o l l o w ing plan, which w i l l be regarded as f u l l y s a t i s f y i n g Requirement 5 and w i l l meet the basic ideas of the committee, and w i l l at the same time be consistent w i t h the p o l i c y we have followed. We w i l l agree to e s t a b l i s h a new cost basis f o r the bank premises l i s t e d i n E x h i b i t "A" hereto attached i n such manner as w i l l r e s u l t i n a charge of approximately $1,000,000 against our p r o f i t s f o r the period ending June 30, 1941* and a s i m i l a r charge i n the t h i r d quarter of 1941* The new cost basis to be established s h a l l be determined from the American Appraisal Company a p p r a i s a l , using the lowest a p p r a i s a l of the American Appraisal Company as to the p a r t i c u l a r properties involved. No adjustment w i l l be made as to properties w i t h respect to which American Appraisal Company1 s most adverse a p p r a i s a l exceeds book value. Please advise us i f t h i s plan has the approval of the committee and i s acceptable as meeting a l l of the requirements of Paragraph 5 of the Comptroller's "Requirements" dated March 6, 1940, so that we may proceed without delay t o carry out the contemplated program. Yours very t r u l y , (signed) R. G. Smith Executive Vice President.