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Federal Reserve Bank of St. Louis

July 23, 1965
Mrs. Virginia Self
Oklahoma Bankers kasociation
611 Coleord Buading
Oklahoma City, Oklahoma 73102
Dear Mks. Self:
greatly appreciate your prompt response to
my request for a copy of the address by Eugene P. Gum.
Thank you very surA for the ewes it is a
valuable document, and will be woeful in completing my
research on the history of deposit guaranty.
Sincerely yours,

Clark Warburton, Chief
Jerking and Business Section
Division of lasearch and Statistics


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Federal Reserve Bank of St. Louis

July 19, 1965
Mr. Joe T. Gilliland
Executive Secretary
Oklahoma Banker's Association
611 Colcord Building
Oklahoma City 2, Oklahoma
Dear Mr. Gilliland:
Nearly ten years aco, in a letter dated September 21, 1955,
your predecessor, Mt. Charles L. Fuson, wrote to Mt. Edison H. Cramer,
then Chief of this Division, that his office had a copy of an
address by Eugene P. Gum, former Secretary of the Oklahoma Bankers
Association, Which had been delivered before the Colorado leikers
Association on June 20, 192)4, and was entitled, "How the Barik
Guaranty Law Failed in the State of Onlikoman. Mr. Fuson offered
to make the copy available to us, but es did not request him to
do so, because of my pending trip to Okliboma and other States to
collect information regarding their deposit guaranty sy0ems.
'hen I visited Oktaheme in December 1955 and made an
appointment to talk with Mr. Gumbo indicated that he leuld give me
a copy of this speech, Which had been printed as a pemplet, but
when I saw him (just before I left Oklahoma City) be IMO unable
to locate the copy. The next year, eken I was preparing my report
on the Oklahoma deposit guaranty fund I did not write to W. Fuson
to inform him that I had not obtained a copy from Mr. Gum, though
I have a note in my records that I Should do this.
I am now writing to you to ask Whether, after this lapse
time, there is still a copy of Mt. Gum's address in the files of
the Oklahoma Bankers Association, and if so, if you could make if
available to me. I will be glad to renumerate you for the cost of
securing a xerox or photostat copy; or if you should wish to loan
it to me, I will have a xerox copy made here and return your copy to
you.
My reports on the State deposit guaranty funds are in
manuscript, never having been published, theegh a summary of the
results was included in the 1956 annual report of the Federal Deposit
Insurance Corporation, popes 47-73. But I am still interested in
making a few revisions in my manus:!ript, to place it in final form for
publication, and therefore would like to obtain a copy of Mr. Gum's
address, if it is still available.
Thanking you for your cooperation, I am
Sincerely yours,
Clark Warburton, Chief
Banking and Business Section
Division of Research and Statistics


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Stat

CW:jk

January 26, 1956

Mr. Charles L. Fuson, Executive Secretary
Oklahoma Bankers Association
1106 Colcord Building
15 N. Robinson St.
Oklahoma City, Oklahoma
Dear Mt. Fuson:
Mt. Clark Warburton has returned from his trip to
several States that formerly had deposit guaranty systems
in operation. He has told me about the material that he
obtained from your office. On behalf of the Corporation,
I want to thank you for your splendid cooperation in
making it possible for him to obtain so much information
about the Oklahoma fund.
Very truly yours,

Edison H. Cramer, Chief
Division of Research and Statistics


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CW:jk

Stat

January 26, 1956

Mk. 0. B. Mothersead
Bank Commissioner
Oklahoma State Banking Department
Oklahoma City, Oklahoma
Dear Mr. Mothersead:
Mk. Clark Warburton has returned from his trip to
several States that formerly had depoait guaranty systems
in operation. He has told me about the material that he
obtained from your office. On behalf of the Corporation,
want to thaak you and Mr. Kelly for your splendid
cooperation in making it possible for him to obtain so
much information about the Oklahoma fund.
Very truly yours,

Edison H. Cramer, Chief
-Axision of ,Wsearch and Statistics

December 29, 1955
MEMORANDUM
TO:

Dr. Cramer

FROM:

Clark Warburton

SUBJECT;

Report of work for week ended December 23

Reports of work of the staff of the Banking and Business Section are
attached. Annual leave - Miss Morton - 12/21-12/23; Miss Thompson - 12/23.
From Oklahoma City, Oklahoma
Saturday afternoon, December 17, wrote to the Deputy Bank Commissioner,
Texas, that I was remaining in Oklahoma City longer than I had anticipated,
and now expect to be in Austin the first week in January. Also, wrote to
the FDIC Supervisory Examiners in Kansas City and Dallas, referring to
Mr. Sailor's memorandum, and stating that it had not been possible to make
stops in their respective cities.
Monday, Tuesday, Wednesday, and. five hours on Thursday were spent at the
office of the Bank Commissioner examining records of the State Banking Board
for the period of operation of the deposit guaranty fund. The materials used
included minutes of the State Banking Board for the entire period; warrant
register shaving warrants on the guaranty fund issued, paid, and outstanding;
liquidation register showing the record of three banks closed about 1910; an
untitled volume containing statements as of date of failure for most of the
banks that failed while the fund was in operation, and results of liquidation
up to a date about the mid-1920's; and an inventory of property of the fund
(cash and assets of failed banks) in 1930 prepared in connection with the
litigation regarding closing of the fund. Data taken off from these sources
include three sets of figures for the expenditures of the fund in the respective failed banks; two sets of figures for the recoveries of the fund; deposits
in each failed bank by type (to be added to obtain total deposits) at date of
failure; and guaranty fund warrants issued, Paid or cancelled, and outstanding by quarters from the latter part of 1911 to the close of the fund. Materials examined but not used included various ledgers and cash books of the
fund, dealing with individual transactions. Use of these books to obtain
annual statements of receipts and disbursements of the fund might conceivably
have been possible, but did not appear to be practicable.
Three hours on Thursday and all day Friday - on compensatory leave for
time spent on Sunday, November 27, in reviewing the Nebraska report and on
Sunday, December 4, in reviewing the Kansas report, and materials collected
in connection with those reports. See first and second paragraphs of report
of work for week ended December 9. (Compensatory leave subject to approval).


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Stat

//CW:jk
'
December 20,

1955

MEMWANDUM
Dr. Cramer
TO:
FROM:

Clark Warburton

SUBJECT:

Report of work for week ended December

16

ss Section are
Reports of work of the stuff of the Banking and Busine
attached. Sick leave - Mks. Shea, Dec. 12-14.
Economic developments and °staking history
regarding the
Continued all week to work at Oklahoma City on material
banking journals
ing
review
to
on
deposi guaranty fund in that State. In auditi
ed on interobtain
be
could
they
where
not available in Washington, nor located
and records
s
record
court
from
data
library loan, it is necessary to transcribe
dual
inaivi
to
relate
Luau'
such
pert,
of the State Banking Boar. For the most
those
were
as
form
y
summar
ient
conven
in
banks, and have not been assembled
. Will continue to
regarding payments to depositors in Nebraska and Kansas
Austin, Texas, therefore,
work here at least half of next week. Will not viait
mas; and it is possible
until after taking a few lays' annual leave at Christ
few additional days also.
that it will be desirable to return here for a
ma Banker for 1920-25,
On Saturday and Sunday, Dec. 10-11, reviewed the Oklaho
and The State Banker, 1914-1918, takthe Aga Despatt Guarantee 4a=1161, 1914-1918,
of receipts and disbursements of
ing notes. Also began to take off statements
issued and retired. Most
the guaranty fund, and of warrants outstanding and
hed by the Treasurer of
of these were quarterly statements, originally publis
the statements were not
the State Banking Board. However, quite a few of
not in the files borrowed
issues
of
e
becaus
located in the journals, in part
from the Oklahoma Bankers Association.
District Court and
Monday, Tuesday, and Wednesday were spent on the
final disposition of the
Supreme Court records of the court cases regarding
provided much information
fund after the law was repealed in 1923. These
ted by claims prove, at the
regarding the ladeotedness of the fund, as indica
most of the failed banks
time of repeal--or rather, a few years later after
the claims (i.e., whether
had been liquidated--and regarding the holders of
information about the way
banks or depositors). Also, they gave considerable
previously very little
had
the fund was handled toward the end, for which we
ts and substitution
warran
of
ce
information, particularly with respect to issuan
to deposit as
ed
requir
been
had
of these f r the securities that the banks
them.
t
agains
collateral for payment of assessments levied
statements of the
Evenings and on Thursday I completed taking ar the
notes on the
made
and
ed
review
fund as published in banking journals, and
ation for 1907-16,
Associ
s
Banker
ma
proceedings of the convettions of the Oklaho
the journals
All
no.
loaned
also
had
which the secretary of the Association
with
talked
I
g
mornin
the
In
and proceedings borrowed were returned.
about
now
would
ant
assist
an
that
ted
Mr. Mothersead again. He had indica


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-2-

records of the Department, which were stored in the Capitol attic. (However,
he had wanted me to examine the court records first). The man who knew about
the records, he told me Thursday, was one of the bank examiners who would not
be in until Saturday morning. Also on Thursday, visited the State Library
at the Capitol, where Mr. Hudson, the librarian had an assistant see what he
could find. He located seven issues of the Biennial Report of the Bank Commissioner, covering the period from 1907 to 1920 (all that were issued); and
the First Annual Report of the State Banking Board, which I had not previously
seen. Checked some data I had taken from the Commissioner's reports years ago
(when we borrowed them from the Library of Congress), and took off some data
from the report of the State Banking Board. Thursday afternoon I talked with
Mt. Eugene P. Gum, former secretary of the Oklahoma Bankers Association, now
retired, at the suggestion of the present secretary. However, he did not add
much to the information I already had. Called at the Oklahoma City University,
but did not find any material in the library, and was net able to see the
professor in charge of money and banking. There is no graduate work at this
university.
Friday was spent at the University of Oklahoma, at Norman, about twenty
miles from Oklahoma City. Talked first with Prof. James M. Murphy, who
teaches some of the courses in money and banking. He was interested, and
promised to inauire of Prof. O. J. Sollenberger, an older professor in charge
of the work in money and banking (whom I was not able to aet) whether he might
have in his files any lames of the Bank Deposit Guarantee Journal or The State
Banker or other pempOlet material regarding the fund. Talked with Mr. James N.
Babcock, the assistant archivist, who spent considerable time looking through
materials from files of former Governors and others who were interested in the
guaranty plan, to see if any of these Journals or pamphlets might be located.
None were found, but Mr. Babcock introauced me to Prof. W. N. Peach, who has
been working on a history of banking in Texas. Prof. Peach, who is not now
working on this study though it is not completed, said he had obtained considerable material on the guaranty fund from the records of the State Banking
Department (obviously before they were destroyed, which he did nct know about).
He offered and agreed to go through his trial and send to me in Washington all
the material he has regarding the guaranty fund. This may be of great value
in the Texas study. At the University I also checked at the library for the
banking journals, finding none that I had not previously seen, and for other
material regarding deposit guaranty. Pound one M.A. thesis in 1926 which had
some useful material, on which I took notes and auotations.
Saturday morning was spent at the State Banking Department. Met Mr. C. R.
Donart, Assistant Sank Commissioner, and Mr. B. H. Kelly. Mr. Kelly immediately
brought out the third volume of the minutes of the State Banking Board, covering
the period from May 1919 to near the time of repeal of the law. Worked from
this volume until the office closed at about 11:30. Found data regarding the
handling of banks in 1920, including expenditures from the fund. This was information not published in the reports of the Commissioner, and which we had
not previously found elsewhere. Will continue to work with this volume of
minutes or Monday. /n addition to thi., volume of minutes, Mr. Kelly also
brought down from the attic several other volumes of records relating to the
fund, and showed me where additional volumes are located in the attic. How
many of these will prove to have information that is useful and can be obtained
in a reasonable length of time I will not know until I examine them next week.


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PRE SICEN'i

THOMAS D. TARPLEY, MUSKOGEE

KLA 0MA_ BANKER S ASS0C
1106 COLCORD BUILDING
ij- AK,
VICE-PRESIDENT

K.G. BRALEY,CHEROKEE
TREASURER

ARTHUR M. FOSTER, BRISTOW

TEL EPH

ONE

PO 5-5608

OKLAHOMA. CM
September 21, 1955

EXECUTIVE-SECRETARY

CHARLES L.F USON,OKLAHOMA CITY
ASSISTANT-SECRETARY

MARY CHAPMAN, OKLAHOMA crnr

Mr. Edison H. Cramer, Chief
Division of Research and Statistics
Federal Deposit Insurance Corporation
Washington 25, D. C.
Dear Mr. Cramer:

•


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I am sorry that my being out of town has delayed my replying to
your letter of August 12, inquiring as to whether or not the
Oklahoma Banker was being published between 1908 and 1921.
Bound copies of the Oklahoma Banker from 1909 to 1921 are on
file in this office. To my knowledge, our copy is the only one
in existance.
You advise that your division is making a study of the history
of the deposit guaranty in Oklahoma. For your information, we
have in our office one copy of an address by Eugene P. Gum,
former secretary of the Oklahora Bankers Association, delivered
before the Colorado Bankers Association on June 20, 1924 entitled
"How the Bank Guaranty Law Failed in the State of Oklahoma". We
could make the copy of this speech available to you. I would also
suggest that additional information on this subject might be
obtained from the book "The Guaranty of Bank Deposits" by Thomas
Bruce Robb, associate professor of economics, University of
Missouri, published in 1921 by Houghton Mifflin Company--The
Riverside Press, Cambridge. This book contains a chapter on the
Oklahoma system. This book is available at the library of this
Association.
If we may assist you further, please do not hesitate to ask.
Very truly yours,

Executive Secretary
c I

f/vrb

CW:jk

Stat

November 7, 1955

Mr. O. B. Mlothersead
Banking Commissioner
Oklahoma State Banking Department
Oklahoma City, Oklahoma
Dear Mr. Mothersead:
Soon after the beginsing of Federal deposit insurance, we
began to collect information an the eperience of various States with
deposit guaranty. Our studies of these atate systems were not brought
to completion at that time. They have recently been resumed, and we
are now preparing reports on each of them which we plea tc complete for
publication.
In the case of Oklahoma, a report prepared by Clark Warburton,
of our staff, was mimeographed and given a limited distribution. A
copy of this report is enclosed. Subsequent to its preparation, we were
'Dole to borrow a copy of the thesis for the Graduate School of Banking
by Mt. Linwood O. Neal, then Bask Commissioner, "The History and Develop-meat of State Bank Supervision in Oklahoma," which provides SOSO information not available to us when our report was prepared.
Rovever, there is still some information which vs would like to
obtain, if possible, before making cur final revision of the report for
publication. The material which we are particularly anxious to check and
revise is the annual data in Table 9, paze 41, of our report. We are
therefore writing to ask whether records of the guaranty fund and of the
results of liquidation of the failed banks which vs presume may nov be
in archives or storage, would be available for the use of a member of our
staff? Mr. Warburton is expecting to be in Oklahoma City during the early
part of December, and if useful material is available, would like to spend
a day or a few days amplifying and correcting our worksheets dealing with
this material.
We shall be very grateful to you for any material that can be
made available, and also for any criticisms or other comments on the
report as mimeographed.


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Very truly yours,

Edison R. Cramer, Chief
Division of Research and Statistics

MAT

Irr:MVP

August 12, 1955

Mr. Charles L. Fuson, Executive
Secretary
Oklahoma Bankers' Association
1106 Colcord Building
Oklahoma City, Oklahoma
Dear Mr. Fuson:
This Division is making a study of the history of deposit
guaranty in Oklahoma, 1908-1921, and we you'd like to examine the
Oklahoma Banker for mmterial pertaining to the deposit guaranty
experience of this State.
Was the Oklahoma Banker being published during the above
mentioned period, and if so could you tell us liter, a file might
be available?


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Very truly yours,

Edison R. Cramer, Chief
Division of Research and Statistics

•
September 22, 1939

Mr. Linwood 0. Neal,
Bank Commissioner,
Oklahoma City, Oklahoma.
Dear Mr. Neal:
Five years ago this Division collected some material relating
to guaranty of bank deposits in various States prior to the creation
of the Federal Deposit Insurance Corporation. It was impossible to
complete our study at that time and we are now attempting to obtain
further information regarding the various State funds.
We find that our information regarding the operation of the
guaranty fund in Oklahoma is scanty. Would it be possible for you to
furnish us with the material described below? We shall be glad to reimburse you for any clerical or stenographic expense incurred in compiling
the material or having copies made if this should be necessary.
1. Quarterly or annual statements of the cash account and warrant account of the fund, similar to those for the quarters December
31, 1914, December 31, 1916, and December 31, 1918, given in the Fourth,
Fifth, and Sixth Biennial Reports of the Bank Commissioner.
2. A list of the banks which failed during the period of operation
of the fund showing for each bank its deposits at date of failure,
amount paid out by the guaranty fund, amount recovered from liquidation
of the assets of the bank, and the net cost to the guaranty fund.
3. The proceedings and decision of the State Supreme Court on
September 11, 1934, regarding disposition of the remaining assets of
the fund, and statements regarding the fund prepared for the use of the
Supreme Court in connection with the case.

Very truly yours,

Donald S. Thompson, Chief
Division of Research and Statistics

•

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0

OY
October 14, 1939

Mr. F. M. Brooks,
Bank Commissioner,
Topeka, Kansas.
Dear Mr. Brooks:
Five years ago this Division collected some material
relating to guaranty of bank deposits in various Statesprior
to the creation of the Federal Deposit Insurance Corporation. It
was impossible to complete our study at that time and we are now
attempting to obtain further information regarding the various
State funds.

•

Your office supplied us with information regarding the
final results of the operation of the guaranty fund in Kansas, and
we have obtained a 'record of the annual receipts and disbursements
of the fund from the reports of the Treasurer of State. We would
like, however, to obtain the information described below which we do
not have. We shall be glad to supply clerical or stenographic
assistance or reimburse you for expenses incurred in compiling the
material or having copies made.
The information which we desire is a table showing the
location and name of each guaranteed bank which failed together with
the following data for each bank:
a.
b.
c.
d.
e.

Total deposits at date of failure;
Guaranteed deposits (that is, certificates issued);
Dividends paid by bank on certificates issued;
Certificates paid from the guaranty fund;
Losses to depositors (that is, certificates never paid).
Very truly yours,

Donald S. Thompson, Chief
Division of Research and Statistics

•

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S


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October 21, 1934.

OKLAHOMA INTERVIEW
Mr. Fred J. ?aro, Vice President,
Mercantile Commerce Bank and Trust Company,
St. Louis, .iissouri.

Mr. Paro as an officer in a St Louis bank
with many correspondent banks in neighboring states has
attended many state Bankers' Association meetings.
When questioned concerning the attitude of bankers in
the states with guaranty of bank deposit laws, he
stated that he had had a part in the events leading
to repeal in Oklahoma.
He was in a state meeting in Oklahoma
when the cuestion,was put to the meeting as to whether
or not the bankers should favor a repeal of the guaran?aro was called upon
ty law. The vote was a tie.
to express an opinion on the subject as a disinterested
onlooker. He said that while the vote showed an even
division of opinion he was sure that deep in their hearts
all the bankers present, including the little red-headed
fellow who had been arguing most emphatically for the
retention of the law, were desiring its repeal. The vote
was then taken again and the motion passed with only the
little red-headed man dissenting.

October 22, 1934.

S

OKLAHOMA INTERVIEW
Mr. S. A. Bryant,
President of the Oklahoma Bankers' kss'n,
Farmers' National Bank,
Cushing, Oklahoma.
In this interview it was evident that as a National banker
Mr. Bryant had not taken a keen interest in the state bank guaranty of
deposits in Oklahoma. rile attributed the break-down of the plan in Oklahoma
,'to the promiscuious granting of charters. Banks were established where
;there was no economic need for a bank, and men assumed control of these
institutions who were not prepared to assume the responsibility of conduc- t
a legitimate banking business. , There were many promoters who were
controlling officers in banks. An example of this was to be seen in the
large business built up by Mr. Norton, (for further discussion of this
case see 'Robb Guaranty of Bank Deposits).

•

Following the passing of the guaranty law there were changes
among the banks from national to state charter in order to be able to state
that deposits were guaranteed. The movement did not originate with the bankers, but was a political devise of Governor Haskell. Many of the bankers
were antagonistic in the beginning, but not all of them. There was no definite attempt to prevent the passage of the law.
At the same time that this law was passed a law was also
put on the books compelling state banks to keep their reserve deposits in
state guaranteed banks.
Mr. Bryant was not opposed to the present Federal Deposit
Insurance but said, "Be sure to keep the provision that all banks shall
become members of the Federal Reserve System".
The conversation turned from the subject of guaranty of
deposits. Mr. Bryant said that women made bad bank customers; that they
did not feel any responsibility toward the bank and withdrew their funds
whenever there was a rummer that a bank might be in difficulty. Hesaid
that men hesitated to do this, but admitted that some of them sent their
wives to withdraw their joint accounts.


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OKLAHOMA STATE BANKING DEPARTMENT
W. J. Barnett, Bank Commissioner

Oklahoma City
December 26, 1934

Mr. Mortimer J. Fox, Jr.
Chief Statistician
Federal Deposit Insurance Corporation
Washington, D. C.
Dear Mr. Fox:

In re:

Oklahoma Guaranty Fund.

I am directing your inquiry of the 20th to Mr.
M. B. Cope, Chief Counsel of the Department, who has handled
the legal end of the above captioned matter for the Department
for many years past. I am suggesting to lir. Cope that if he
can not supply the information requested in your letter, that
he ask for the assistance of Mr. Harry L. McConnell, Assistant
to the Commissioner, to help in the preparation of the
information requested.
You will hear from Mr. Cope shortly regarding the
matter.
Yours very truly

(s)

W. J. Barnett

W. J. BARNETT
Bank Commissioner

WJB:BL

OKLAHOMA STATE BANKING DEPARMENT
Howard C. Johnson, Bank Commissioner

Oklahoma City
March 7, 1965.

Mr. Mortimer J. Fox, Jr., Chief,
Division of Research and Statistics,
Federal Deposit Insurance Corporation,
reshington, D. C.

Dear Mr. Fox:

•

I regret that I have not heretofore furnished
you the information referred to in your letter of March
4th. This office has been so extremely busy since January 1st that I have not had an opportunity to assemble
the information you desire. I will get this compiled
and mailed to you early next week.

Yours very truly,

(s) a. B.

Cope

M. B. COPE, ATTORNEY
MBC:DW

•

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B.

Zonuary 7, 1933

n.

kr. 4.
CO"
Chief Counsel,
Oklahoma 2tate Banking Department,
Oklahoaa City, Oklahoma.
Dear Mr. Copes
1 letter tron Zr. W. 3. Barnett, Bank Gamissiewer
that he has referred to you our inquiry caneerto
states
Oklaboaa,
of
of the guaranty of bank deposit fund Is
eettlerAent
lag the final
lklahoma.
Saws of the other States which bare bed guaranty of
te lied to um their reeorde of the
bank deposits have been
the emerentorfted.
decision
hich
finally
nosed
legal
Enplaned find a mailing fres*, which weeid sever
postagv on any materiel which you nisht be eble to funnia 114
We would retnrn the some to you very promptly.
We will oppreciate very much much assistenee en you
give us in obtaining information about the whole
to
are willing
Guaranty Fund in Oklahoma.
the
of
experience
Very truly yours,

Mortimer 3. Vox, Jr.,
Chief Stettetician.

Enclosure.

FHOU


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TAT.

February et 15

Mr. K. K. Cope, Chief Counsel,
Oklahoma State Banking Dopartment,
Oklahoma City, Oklahoma*
Dear Mr. Copes
On Janwry 7 we wrote to you concern.
in*, the decision in regerd to the closing of the
6auk depositors' gueraety fund is Oklahoma.
You will find enclosed a copy of
thht letter, which say have gone astray.

Very trniy yours,

Martimor J. Fox, Jr.,
Chief Statistician.

Enclosure,


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ALMOI

4, 1936.

U. Cope,
Chief Counsel,
Alabama State Baking Deportment,
0k1ahoma City, Oklahoma.
t;ear Mr. Copes
Tlle Division of Vssearoh and Statistics of thi
Federal Deposit Insuranco Corporation is asking a study
of bank depositors' guararty funds. Ws were referred to
you by ;Alr. W. J. Barnette Bank Commissionore of Oklahoma,
for information eoneorning t e resent dessision in regard
to t4 closing of tbst Bank Depositors' Ouaranty rund in
oklakane4
OR January 7 and ain on February 6, we swots,
to you enclosing assailing frank. We mould like very
much to hear frau you as to mhoter or not it will be
possible for you to sur ,-ly us mitt ts-ss information re—
quested.
Very truly yours,

Mortimer Jo Foxe Jr., Chiofe
Division of Researoh and Statistios.


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TAT.,

Decasiber

-r. W. J. Barnett,
:late Bank Commissioner,
Canitel Building,
Oklahosa City, 0',..111hnea.
Dear 11r. Burnett:
The 5tatistica1. Division of the ?Were'
Deposit Insurance Corporation is /saltine a study of the
plans for the guaranty of benic deposits which we
developed in eight Oates. ft noted in theteerisan
Bankereof October a, 1934 taut a court 'tells' bed been
mode to close the rand in Otlahoma.
It seemed probable 0,0,, in commotion
with th,t easey
prepared a weimar7 of total receipts
and disbursoments during the entire period of the guar.
asty of deposits arperiment se4 of present assets sad
outstanding liabilities. If se we would like very nach
to hove a copy of your summarys
If it is reedfly available from yr.ur
raelrds will yen else state the total amount lf the
deposit& in banks which failed while the guaranty law
was is fors* and of the amount of depositors' claims
which wee est froz the liquidation of the closed banks.
Any information which you may furnish
as in regard to the guaranty of bank deposits in Okla.
hoes will he apresiatod very much,
Var

truly yours,

Borti4am j. Fox, Jr.,
Chief Aatisticien.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

noisy

4;TrT

October 19, 1934

lir. Eugene P. Gus, Secretury,
Oklahoma Bankers Associution,
American flanker', Asnocition Convention,
Willard Hotel,
VVzhingtou p D. C.
Der ?lir* Gumt.
In connection with our studies of the bcnk—
ins laws and their operation in the state which 11,,vo in
the peat had deposit inLurvnce or guaranty leo*, it would
be of vtauable csAvtAnct if 03V of the &seashore of this
pilone.1 Interview with you While
Division could h6,141
you are in Inshington.
Your firtthand Xnowledee of the olfaction
La Oklahoma would shed Ught on how the various pertc of
the law operated.
The offices of the Federt1 Deposit InEurtnce
Corporntion are locted in the Netic,nAl Pre Building,
which ie Just Across the atref from the Willard notel«
Our room numte2. is 433 end our teledhoos number i$ District
1240, ENtension 112.

YieW

W. could appreciate your granting ua en Inter.
vnd rAviaing lib when tAnd where it amy be bed.
Very triAly Anen,

lortiner J. Fox, Jr.,
Chief Stetistician.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

MT.

nisi=

October

29,

1934,

skr. S.i. rr;liknt.,
204erlorii 14;t1a)at17. Dr,x0r,
Cushing Olds/lose
Dear Ir. Dryz,nt;
Thc laforn,Aion np-r1.7111*1 by yam
yfr,:r coavrtiot. vith uo on October 2, will
prove of value to le in our mtmly 0 state ewestp reeinte the fret tht,
ty of bank depositt*
bus.?
A
ciliwantiss to carat in
yet toot tine during
And talk irith us.
in the COUTS4 of tht informal conversation ..;!lieh folloved our dionuasing of guerenty
of beak ceposits. the question aroma concerning ins
insurnace of .Ncrtifiortkz of decoeit issued to ode
individual. T1.40 iftclosed menortzdun .Jdnlo.4%tes the
eseeennent shift ithwold he osid and the csount of
inewsce recov.:rtble by one eleitnnt.
No :lops that this 14111 r,noTcr vay
questions Ithte; ,71,7 home arisen in your And in
mard to thit; 44,
:vc.er•
11‘ ry

truly,

:•orilur J. Foy, Jr.,
Chief 5tAlstician.

•


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

RAT

October 1J. 1934

gr. S. 4..Bryent, ?resident,
Oklahoma 4.sulters Association,
AAarican Bunkum, AssociAion Conventions
TTit:Lrd%otel.
Nuahington, D. C.
Dear Mr. Bryant:
In connectim with our studies of the benk—
inz lays and their opertian in the ortAes which 21,Art,Ln
the past had deposit Liv.oareace or eutsranty lees, it would
cmeAnberei of this
be of valuc,ble asaistance if one of
wth you while
interview
perzonal
Division could have a
you are In Washington.
Tour fir;Fthand tnowledge of the situktt=
in Oki OWL would shed Light on how the various parts of
4'
10, operated.
The offices of tht Fedeml Deposit Insurance
Corporation ere loiwted in tha gvtional Press Building,
which LC just across the street from the Willard Motel.
Our room number is 433 end MIT telephone nUmber is District
1240, Extene.nn 11,4
We would appreciate your grenting us
when PIO where it may be had.
view and 'advising
Tory truly youf6,
14.3.10bz,Jr.
.
Mortimer J. PDX, Jr.,
Chief Statistician.

•

•


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

•

•

•`TA
(
-)i).146e .w4s

FOR ',JORKSHEETS OF DATA FOR EACi. FAILED BANK
See file folder

•

•

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

-•

Table 11.

NUMBER AND DEPOSITS OF STATE BANKS IN OKLAHOMA, 1908-1920
Banks grouped by amount of deposits

Number of banks - total)]
Banics with
$100,000
$100,000
$250,000

deposits of or less
to $250,000
to $500,000

$500,000 to $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $5,000,000

Nov. 26,
1912

Dec. 8,
1914

Nov. 17,
1916

Nov. 17,
1918

Dec. 29,
1920

Sept. 23,
1908

Nov. 10,
1910

520

693

61_7.

562

550

582

621

466
41

520
133
34

500
91
20

436
102
20

250
231
54

170
293

76

174
268
119

11

4
1

31
9
3

41
14
5

11
2

5
1
••

6
••

••

3
1
••

43ems**in thousands vf
Deposits - total/

26,587

61,612

47,775

44,589

-83,983

123,594

158,960

In banks with
$100,000 or
$100,000 to
$250,000 to

16,136
5,535
3,647

26,590

19,150
11,178

24,063
13,095
6,446

19,987
14,444
6,670

15,627
34,620
17,661

11,937
45,705
25,334

12,053
43,671
40,437

3,362

4,171

2,307

7,734

1,181

6,120
2,621

20,824
11,549
8,245

27,512
19,833
15,454

deposits of less
$250,000
$500,000

$500,000 to $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $5,000,000

1,269

1,332

1/ Tabulated from statements relating to individual banks, as given in the reports of the Bank
Commissioner. Totals differ slightly from the figures liven in summary tables for the same dates in the
Commissioner'speports.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

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Federal Reserve Bank of St. Louis

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Year

All banks in tate
(RepQrts Comptro11„er - ;17 t,u-i-rcncy)1
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https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

All

6e,
Nutber

Ics

STATI7TICAL DATA REGARDING DFPOSIT GUARKTY FUND IN
I. COVF,BAGEANSSESSMENTS
Banks members of guaranty fund
n State (state reports 7/
Tat*
Gap
;14 ouat
I

Total I
deposits

g1,770
I(41,5711
5-47t1we 67q
61 3oh,3), (-,c?
I/9
d7

6cf
633 •
10 17
,

,

Total , Insur ed
deposit
deposits

5g3
5-63
557
51/

I/o 05
44353

2/8#6o 511/7
PIMhitE( 5(.4

66,9,24

5 ,I

57-1

0.2s
q036
5'3634
4391

4/6671
56,3 e9
77.1' 556 5' •
13739

)096

Total
captdI

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labg

44AS

iiumber

1707
I bob7

441-11/0

IsAff
15-365?
yv rig

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Aesessments
Rate of
Amount of
assessment assessmAnte
percent of levied
a$ses$me,ite deposit
were
based

Deposits
on
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https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

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https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

DFFOSITS OF NATIONAL DANKS r.,N OKLAHOMA - in dollars
(From rcperts cf Comytroller of the Currency)
)
o`t 1A,
W)

1,932,411
1,630,436
60,049
110,026
14,568
38,318,729
L464,702
84,250

#

1,789,108
L925,589
3,907,492
2,536,099
22,784
55,758
56,8815
4,576
51,763 42,017,905
:37,527,035
489,308
246,029
296,735
121,816
491,231
444,326
413,008
4 7,615,171n
527,248
632
10,332
18
3,744,394
4,190,586
2 7,7 2 4
132,919
107,932
30 9 5,6 5 3
16,588
10,492
2 7 4,7 4 7
2,395,308
L954,989
10 0,3 4 5
2,069,894
1,02,3,228
2 7,6 8 9
5,81:5
11,415
36,2 8 0,3 4 6
270
6,332,065
1,5 8 1,1 5 0
6,380,011
176,588
1 3 3,6 2
221,238
52,718
31,762
4 7,621,336
5:1,7 03,013.

,449,82,3
983,796
15, 72,010
6 4,385
089
44,56
93
1,100,4 :5
83,103
25,196
96,083,01 8 11

2,0
1,0
22,30
54
38

1:1

34.114.,
1A....13.14tY
6
95,355
3
3,035,72 G
7
1,155
a508
3
57,860
7 51,653,255
47,356
314,89 8
2
64,112,784
316,084
1
37 (5,477
788,111
9
210,283
469,270
7
253,3215
5,200
5
1,060,349
47
3
415,836
4,329,101
4
3,474
107,208
4
2,807
10,52:5
1
4,970,2 3 2
2,685,097
1 70,8 4 0
1,347,7'77
9
3,621
6,71
'7
7
143,526
1
00
2
2,312,430
6,463,25.5
8
905,470
17 a513
22,356
23,487
3
11,985
51,045,963n 61,783,66 41_1 76,222,6 9 0 Y1
7,22 _3,725
203,231
61,334
t‘d

1,311,2 53
18
2,937,4 80 2•15 '
1,7
35,3 80
26,1 21
32,784,8 '78
42,3
233,9 74
5
96,2 64
2
215,2 96
5
303,0 32
3
11,3 90
3,533,6 80
4,7
111,8 62
16,3 S.
1,407,8 77
982,3'75
7,9 O 0
2 56
6,793,4 85
146,0 44
89,2 49

•


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

31213,454

4,094,685
10,000
197,400

98,601,535u

DEPOSITS OF NATIONAL BANKS IN OKLAHOMA
In thousands of dollars
(From reports of Controller of the Currency)

0,1-73-3v
4-A4471
6,i 3
7.
1,0301
25,0
4,211,i6
929,5
2,567,
15,68
7,144,168
84,531,812.,u
41, .0-"" g 0 0 `.9

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8,824
331
70,086
7,789
1,310
44
4,650
1,212
4,708
21
9,168
1,550
109,693 11
20,977
65
107,356
13,84
2,753
1
6,076
1,530_
12,633
6
13,237
2,072z
180,550u
273,691u


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

") 8,056
9,847
118,164
12,787
2,493
1166
7,759
1938
1233
9,138
3,887
15,026
k,248
6,780
5,152
27,962
6,5'71
1,533

7,549
9,572
92
8,088
144,327
18,319
2,017
2,438
2,181
8
1,905
9,397
2,892
597
11755
7,986
49
1,455
22,300
5,392
1,047
7,128
4,272
206
4,427
38,343
6,982
1447

245,740 Ti
i 3 9,
tr
"
4.cro-o
" 43

s
4,545
3,926
"? 103,533
15,055
1530
1,189
925
9,705
2,117
708
5,322
041
16,791
4,098
1,839
4,459
2,065
31,547
5,402
1,741
2 1 2.333)-1
o,108
2,937
145
1185
40,189
8,289
797

7 a 2,171 rc
7-

3,653
4,006
56
4,439
120,532
24,141654
1,0 31
1293
920
8,492
3,208
116
6,596
5,564
24
952
20,192
8;870
299

2,828
3,366
80
5,199
103,716
28,110
442
847
394
13
1,090
6,343
3,451
349
6,983
3,730
31
2„564
21,417

a992
232
3,597
2,4'75
71
4,416
27,365
8,791
220
247,112 LI
5,908
3,659
156
5,081
129,327
34,412
889
1905
576
13
719
6,019
4,33 '3
114
10,774
4,247
19
1596
26,649
1 1420
611
7,436
3,751
104
6,877
38,393
9,760
1210
3 17,963u

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rietta
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•

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1-25-22 v

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First
State Bank
State Bank
1.1orris
Bliss
1-27-22 fr
2-25-22

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El Reno
2-28-22

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Wilkin-Hale Oklahoma
Commerce
Bank
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Sulphur
Okla4Cit
.y
Walters
2-2821-"/ 5-8-f-fF
3-10-22 v

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of Stratford Erick_
3-1-22
5215/2. T

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State Bank
Edmond
5-15-22'

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Caddo
3-18-22

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Bank of
Wi1 son
Clayton

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LIST OF BANKS FAILED DURING PERIOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923

Location and name

Coalgate:

International Bank of Coalgate

Date of
closing
1908
May 21

Deposits/

Loss to /
guaranty fund?J

A - $ 36,745

None

Liquidated (completed Sept. 4, 1908)

582,284
44,000

Liquidated
Liquidated
Succeeded By the Oklahoma State Bank

Oklahoma City: Columbia Bank & Trust Company
Kiefer: First State Bank of Kiefer
Ochelata: Bank of Ochelata

1909
Sept. 27
Dec. 14
Dec. 31

Durant: Oklahoma State Bank /
Muskogee: Alamo State Bank'
Sapulpa: Creek Bank & Trust Company

1910
Apr. 28
Aug. 25
Nov. 11

A
A A -

Mountain Park:

1911
Apr. 10

A -

43,638

B

May3

A -

56,247

•

Apr. 6
May 20

A -

245,634
43,243

A

105,626
18,732

June 7
June 18
Oct. 3
Sept. 28
1912
Feb. 19
Sept. 10
Oct. 22
Nov. 26

A - 459,283
A - 108,137

A
A

365,229
26,557
20,004

Geary:

Citizens Bank

Bank of Commerce

Oklahoma City: Planters & Mechanics Bank
Snyder: Bank of Snyder
Oklahoma City: Night & Day Bank
Sulphur: Security State Bank
lhatluck: First State Bank
L-Tushka: Farmers State Bank
Watonga: State Guaranty Bank
Sapulpa: Farmers & Merchants Bank
Watonga: Watonga State Bank
Prior: First State Bank

A -2,742,138
A 76,482

A -

A -

A A -

A
A

18,023 '0-30-10)

53,894
B
121,632
360,00C (11-10-10) A
A
109,859

55,686

25,000V
160,911
46,418

17,559
23,024 (1-1-13)

27,957
-

A
A
A
A

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58,000 (11-10-10)
447,862
A
30,221
75,000 (11-10-10) B

1913
Sapulpa: Oklahoma State Bank
Jan. 14
Garvin: Bank of Garvin'
Jan. 16
Spiro: Choctaw Commercial Bank,Feb. 4
Oklahoma City: First State Bank
Mar. 10
Hugo: Oklahoma State Bank
Mar. 17
Capitol Hill: The State Bank of Capitol Hill- April 25
Stilwell: Bank of Stilwell ,
May 28

A
A
A
A
A
A
A

-

160,258

•

59,489
64,946
277,805
35,813
63,225
67,301

•
•
A
•
A
•

18,225 (1-1-15)
148,261
None
36,004
29,260 (1-1-15)

Anadarko: Anadarko State Bank
Lawton: Bank of Lawton
Alva: Alva Security Bank

A A A -

162)585
62,842
205,606

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44,204 (1-1-15)
86,939 (1-1-15)

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July 14
Aug. 9

Disposition

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105,383
9,936
None__

48,722 (1-1-15)
58,718 (1-1-15)

Absorbed by Guaranteed State Bank
Reorganized as Union State Bank
Succeeded by the Oklahoma State Bank

Succeeded by the Planters State Bank of
Mountain Park
Absorbed by the American State Bank of
Geary
Liquidated
Absorbed by the Kiowa County Bank of
Snyder
Absorbed by the Wilkin-Hale State Bank
Absorbed by the Bank of Commerce, Sulphur
Liquidated through Guarantee State Bank,
Shatluck
_bsorbed by Planters State Bank of Tushka
Succeeded by Watonga State Bank
Liquidated
Absorbed by the Blaine County Bank of Watong.
Succeeded by American State Bank of Pryor

Absorbed by the Sapulpa State Bank
Succeeded by Farmers' State Bank of Garvin
Succeeded by the Spiro State Bank
Reopened with same name
Absorbed by First State Bank of Hugo
Succeeded by Capitol State Bank
Succeeded by The First State Bank of
Stilwell
Liquidated
Liquidated through Citizens' State Bank
Absorbed by Central State Bank of Alva

- 2-

•

LIST OF BANKS FAILED DURING PERIOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923 (continued)

Location and name

2/
Loss to
guaranty fund-/

Disposition

1913 (cont.)
Aug. 11
Sept. 13

A A -

487,244
226,209

A A -

61,743
7,393

Snyder:

Sept. 16

A -

38,449

B -

13,800 (1-1-15)

Wainwright: First State Bank \
Foraker: Bank of Foraker
Spencer: Bank of Spencer.,

Oct. 16
Oct. 31
Dec. 16

A A A -

48,213
10,726
31,671

B B B -

15,500 (1-1-15)
6,867 (1-1-15)
21,896(1-1-15)

Muskogee: Peoples Bank and Trust Company
Elgin: Bank of Elgin,
Alva: Bank of Commerce,
Afton: Afton Exchange Bank.

1914
Jan. 31
Feb. 5
Apr. 4
Apr. 7

A
A
A
A

-

54,808
17,282
76,638
24,559

B - 48,758 (1-1-15)
B - 11,351 (1-1-15)
B - 37,368 (1-1-15)
None

May 27

A -

257,743

Farmers and Merchants Bank,

Garfield Exchange Bank

F-Coweta: Farmers & Merchants Bank
MountainView: Farmers & Merchants Bank.
Ponca City: Ponca State Bank
Mazie: Bank of Mazie
Mannsville:

Row:

First State Bank

First State Bank

Jefferson: Farmers State Bank
Jay: First State Bank

Dewar:
Tulsa:

First State Bank
Citizens State Bank

Tar River:

11/

Deposits-1/

Oklahoma City: Oklahoma State Bank'
Muskogee: Union State Bank,

Enid:

1

Date of
closing

Mineral Belt Bank

Guthrie: Logan County Bank
Wilburton: Citizens Bank
Sentinel: Oklahoma State Bank
Hallett: First State Bank
Weatherford: Farmers State Bank


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

A - 105,570
/

Absorbed by Tradesmens State Bank
Absorbed by American National Bank of
Muskogee
Consolidated with Kiowa National Bank;
succeeded by Kiowa State Bank
Succeeded by The Farmers State Bank
Liquidated
Succeeded by Spencer State Bank

Liquidated
Reopened under same name
Absorbed by Central State Bank of Alva
Succeeded by The Farmers State Bank of
Afton
Succeeded by Garfield County Bank of
Enid

1915
Dec. 21
Feb. 16
Feb. 22
Mar. 24

A
A
A
A

Sept. 30

A -

32,340

1916
Nov. 17

A -

40,337

5/

1917
Jan. 11
May 13

38,026
A A - 46,972

None
None

Absorbed by The Bank of Jefferson
Absorbed by Delaware County Bank of Jay

1918
Apr. 10
May 28

A A -

120,117
965,283

B -

10,076 (1-1-19)
None

July 26

A -

113,575

B - 24 000

Succeeded by Dewar State Bank
Absorbed by American National Bank of
Tulsa
Succeeded by Cardin State Bank

1919
Jan. 31
Apr. 9
May 3
July 15
Aug. 4

A
A
A
A
C

- 102,822
67,961
94,391
14,026

- 261,000
- 286,000
- 153,000
52,000
- 150,000

B - 25,000 (1-1-17) Succeeded by First State Bank of Coweta
B - 30,988 (1-1-17) Succeeded by Bank of Mountain View
City
B - 19,179 (1-1-17) Absorbed by Oklahoma State Bank of Ponca/
None
Liquidated through Citizens State Bank,
Wagoner
None
Succeeded by Mannsville State Bank

5/
5/
5/
5/

/

1-1-19)

Liquidated

- 3

LIST OF BANKS FAILED DURING PERIOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923 (continued)

•

Location and name

11/

Date of
closing

Deposits-/

Loss to
,/
guaranty funcW

Jones: Bank of Jones
Mulhall: Mulhall State Bank
Boswell: State Exchange Bank
Coalgate: Citizens State Bank
Foss: Bank of Foss
Fallis: First Bank of Fallis
Marietta: First State Bank
Shawnee: Security State Bank

1920
Oct. 6
Oct. 11
Nov. 15
Nov. 19
Nov. 26
Nov. 27
Nov. 30
Dec. 13

C
C
C
C
C
C
C
C

- 180,000
- 115,000
- 383,000
- 575,000
- 191,000
75,000
- 498,000
-1,550,000

Ada: Farmers State Bankl/
Kiefer: Central State Bank
Kiefer: Exchange State Bank
Jenks: Bank of Jenks
Aylesworth: First State Bank
Pershing: Pershing State Bank
Miami: Miami State Bank
Pontotoc: Bank of Pontotoc

1921
January
May 3
May 3
May 3
July 30
Aug. 15
Aug. 15
Sept. 15

C
B
B
B
B
B
B
B

-

246,000
359,000
128,000
173,000
28,000
77,000
285,000
93,000

C C C C C CC C -

Albion: First State Bank
Driftwood: Citizens State Bank
Guthrie: Oklahoma State Bank

Sept. 20
Oct. 10
Oct. 25

B B B -

39,000
93,000
839,000

C - 12,880
C - 56,973
C - 589,059

Disposition

5/
5/

5/
5/
5/
917,000Y

-7/
50,000171,525
109,385
137,404
4,508
None
91,200
56,470

t,

Succeeded by Security State Bank
Succeeded by Security State Bank
Succeeded by First State Bank of Jenks
Liquidated(5-31-24)
Succeeded by Security State Bank
Succeeded by First State Bank
Absorbed by Guaranty State Bank,
Tishomingo
Reopened by Albion State Bank
Succeeded by Security State Bank
Succeeded by Guthrie State Bank

Loss to
depositors-/
Hoffman: First Bank of Hoffman
Okmulgee: Bank of Commerce
Sulphur: Bank of Commerce
Bliss: First State Bank
Preston: Oklahoma State Bank
Imo: Imo State Bank
Goltry: Bank of Goltry
Millerton: Bank of Millerton

Oct.
Nov.
Nov.
Nov.
Nov.
Nov.
Nov.
Nov.

25
1
3
12
12
15
16
17

Delaware: Delaware State Bank
Stonewall: First State Bank
Miami: Miami Trust & Savings Bank
Chattanooga: Chattanooga State Bank
Meno: Bank of Meno
Pensacola: First State Bank

Nov.
Nov.
Dec.
Dec.
Dec.
Dec.

17
30
10
12
20
30


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

70,000
-2,065,000
- 329,000
94,000
- 103,000
71,000
- 112,000
40,000
-

-

124,000
108,000
290,000
112,000
62,000
39,000

- 119,084
-1,039,691(1931)
None
None
- 138,298
29,862
- 78,044
None
C CC C C -

30,956
None
58,905
5,795
40,103 (1931)
20,034

Liquidated (5-10-29)
Liquidated
Reopened with same name
Reopened with same name
Liquidated (5-10-29)
Liquidated (12-15-28)
Liquidated (8-13-28)
Succeeded by Citizens State Bank of
Millerton
Succeeded by First State Bank
Reopened with same name
Absorbed by Ottawa County National Bank
Liquidated (6-27-30)
Liquidated
Absorbed by First State Bank, Vinita

-4

LIST OF BANKS FAILED DURING PERIOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923 (continued)

Location and name

III

Date of
closing

Kenefick: Farmers State Bank
Guthrie: Guthrie State Bank
Durant: First State Bank
Morris: First State Bank
Bliss: First State Bank
El Reno: Commercial Bank
Sulphur: Bank of Commerce
Oklahoma City: Wilkin-Hale Bank
Walters: Oklahoma State Bank
Stratford: State Bank of Stratford
Erick: Western State Bank
Edmond: Edmond State Bank
Caddo: Oklahoma State Bank
Clayton: First State Bank of Clayton
Wilson: Wilson State Bank
Park Hill: Farmers'State Bank
Bartlesville: Bartlesville State Bank
Warm: Peoples Bank & Trust Co.
Cameron: Bank of Cameron
Clarita: First State Bank
Comanche: Farmers State Bank
Yale: Yale State Bank
Pawnee: Security State Bank
Glencoe: Farmers State Bank
Muskogee: Central State Bank
Gore: Farmers Bank of Illinois
Richmond: Bank of Richmond
Crowder: Bank of Crowder
Choctaw: State Bank of Choctaw
Wagoner: First State Bank
Bromide: Bromide State Bank

1922
Jan. 10
Jan. 11
Jan. 25
Jan. 27
Feb. 25
Feb. 28
Feb. 28
Mar. 8
Mar. 10
Mar. 1
Mar. 15
Mar. 15
Mar. 18
Mar. 27
Apr. 3
Apr. 7
May 11
May 18
June 17
Aug. 3
Aug. 7
Aug. 14
Aug. 14
Aug. 17
Aug. 18
Sept. 14
Sept. 18
Oct. 6
Nov. 2
Dec. 21
Dec. 29

Jennings: Oklahoma State Bank
Woodward: Central Exchange Bank
Allen: First State Bank
Atwood: First State Bank
Ashland: First State Bank
Gage: Farmers State Bank
Foss: Foss State Bank
Nash: Farmers & Merchants Bank
Achille: Guaranty State Bank
Sallisaw: Sallisaw Bank & Trust Co.

1923
Jan. 1
Jan. 16
Jan. 22
Jan. 25
Jan. 25
Jan. 27
Jan. 28
Feb. 12
Feb. 12
Feb. 19


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Deposits-/

-

49,000
390,000
235,000
132,000
52,000
963,000
364,000
1,666,000
287,000
104,000
107,000
143,000
236,000
42,000
178,000
32,000
821,000
70,000
42,000
156,000
194,000
544,000
194,000
143,000
498,000
47,000
36,000
76,000
96,000
252,000
70,000

-

119,000
466,000
137,000
49,000
39,000
230,000
69,000
165,000
25,000
221,000

-

B
B
B
B
B
B
B
B
B
B

Loss to 8/
depositors-J

Disposition

Liquidated (6-27-29)
35,632
271,627 (1931) Liquidated
206,731 (1931) Liquidated
Succeeded by Peoples State Bank
Succeeded by Marland State Bank, Marland
None
(1931)
Liquidated
687,803
(1931)
Liquidated
303,995
(1931)
Liquidated
361,713
Liquidated (8-15-29)
106,086
Liquidated (11-20-28)
94,597
Liquidated (11-30-24)
None
Liquidated (9-28-22)
37,000
131,795 (1931) Liquidated
Liquidated (6-25-29)
38,085
Succeeded by Producers State Bank
None
24,037 (1931) Liquidated
379,095 (1931) Liquidated
Succeeded by Bank of Wann
None
20,511
Liquidated (10-1-27)
Liquidated (5-13-29)
122,777
116,616 (1931) Liquidated
339,569 (1931) Liquidated
Liquidated(12-5-28)
132,835
51,858 (1931) Liquidated
Liquidated (5-9-29)
359,900
36,608
Liquidated (5-9-29)
30,912
Liquidated (11-1-29)
60,230 (1931) Liquidated
Liquidated (11-24-28)
74,027
Liquidated (12-15-28)
149,368
58,2
Liquidated (12-7-29)

94,894
234,348
25,866
12,800
16,553
None
14,471
None
18,611 (1931)

Liquidated (5-21-30)
Succeeded by Bank of Woodward
Succeeded by Depositors State Bank
Succeeded by Farmers State Bank
Liquidated (12-15-28)
Reopened with same name
Succeeded by Farmers State Bank
Succeeded by Farmers State Bank
Liquidated
Succeeded by Security State Bank

5
LIST OF BANKS FAILED DURING PERIOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923 (continued)

1/

A - from Report of Bank Commissioner, as of date of failure unless otherwise specified.
Individual deposits
Savings deposits
Bank deposits
Certificates of deposit
Cashier's checks
Certified checks

Items included:

B - from schedules submitted to Federal Reserve Committee on Branch, Group and Chain Banking.
C - Rand McNally Bankers Directory.
A - from Robb, The Guaranty of Bank Deposits. Figures presumably represent final loss to guaranty fund. Slightly larger figures for some
of these banks are given in the biennial reports of the Bank Commissioner for net payments by the guaranty fund to January 1, 1913,
or January 1, 1915.
B - from biennial reports of the Bank Commissioner.

Figures represent net payments to date indicated.

C - from schedules submitted to Federal Reserve Committee oh Branch, Group and Chain Banking.
V

Paid by State Banking Board to absorbing bank to protect it against loss.
This case is listed in the Report of the Bank Commissioner as a reorganization, with no mention of any assistance by the guaranty fund.

41
5/

No data available.

5/

Cooke, in article in Quarterly Journal of Economics, November 1923, states that Warrants for $2,196,000 were issued in 1921, to cover the
deposits of 13 banks. These 13 banks probably include:

9 which failed in 1921 and for which payments from the guaranty fund are shown on the schedules collected by the Federal Reserve

2/

Committee on Branch, Group and Chain Banking.
1 which failed in January 1921, and not listed by the Federal Reserve Committee.
3 listed here as 1920 failures (late in the year) - since issuance of warrants would be made at a date subsequent to closing (after books
had been examined by guaranty fund ofricials).
The figure of estimated loss to guaranty fund for the three 1920 failures is derived by deducting the loss in the 10 banks failed in 1921 from
Cooke, Quarterly Journal of Economics, November 1923, p. 112. This failure is not listed by Federal Reserve Committee; is probably the bank
listed in Rand McNally, July 1920 but not January 1921, under title of Guaranty State Bank.

.8_/

Estimated by deducting offsets and dividends paid from total claims allowed, as reported on schedules submitted to the Federal Reserve
Committee on Branch, Group and Chain Banking. For cases marked (1931), relating to banks still in process of liquidation, this figure
represents unpaid claims at the time schedules were prepared for the Federal Reserve Committee on Branch, Group and Chain Banking.

2/

Deposits November 10, 1910, amounting to $360,322, are those of the Union State Bank, which was a reorganization of the Alamo State Bank,
the banking board agreeing to protect it against loss. The deposit figure for November 10, 1910, is probably similar to that for the
Alamo State Bank at the time of reorganization on August 25, 1910.

622i-e__fi___,_or__•eforIbs—amorraunt_o.ntssuedinthe case of the 13 bank)
4111


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Division of Research and Statistics
Federal Deposit Insurance Corporation
CW:mod - September 20, 1941

100-

17
.

LIST OF BAKS FAILED DURINCi PERIOD OF DEPO:IT GUARANTY LAW IN

Loeution and name

Date of
closing

Deposits-1/

e
Oss.•

t o" A

KLAHOMA, 1908-1923

Loss to,/
guaranty fungi

Disposition

1908
May 21

A - $ 3(3,745

A

Oklahoma City: Columbia Bank Fe Trust Company
Kiefer: First State Bank of Kiefer
Ochelata: Bank of Ochelata

1909
Sept. 27
Dec. 14
Dec. 31

A -2,742,138
A 76,482
A 53,894

Liquidated
A $ 582,284
Liquidated
A
44,000
B
18,023 (9-30-10) Succeeded By the Oklahoma State Bank

Durant: Oklahoma State Bank
Muskogee: Alamo State Ba
Sapulpa: Creek Bank & Trust Company

1910
Apr. 28
Aug. 25
Nov. 11

A
A A -

1911
Apr. 10

A -

43,638

May3

A -

56,247

Apr. 6
May 20

A - 245,634
A 43,243

A
B

- 459,283
A - 108,137
55,686
A 27,957

A
A
B
B

Watonea: State Guaranty Bank
Sapulpa: Farmers & Merchants Bank
?iatonga: Watonga State Bank
Prior: First State Bank

June 7
June 18
Oct. 3
Sept. 28
1912
Feb. 19
Sept. 10
Oct. 22
Nov. 26

Sapulpa: Oklahoma State Bank
Garvin: Bank of Garvin
Spiro: Choctaw Commercial Bank
Oklahoma Cita: First State Bank
Hugo: Oklahoma State Bank
Capital Hill: The State Bank of Capitol Hill
Stilwell: Bank of Stilwell

1913
Jan. 14
Jan. 16
Feb. 4
Mar. 10
Mar. 17
April 25
May 28

Anadarko: Anadarko State Bank
Lawton: Bank of Lawton
Alva: Alva Security Bank

Juno 3
July 14
Aug. 9

Coalgate:

International Bank of Coalgata

'Mountain Park:
Geary:

Citizens Bank

Bank of Commerce

*-Oklahoma City: Planters & Mechanics Bank
Snyder: Bank of Snyder

•

Oklahoma City: Night & Day Bank
Sulphur: Security State Bank
thatluck: First State Bank
Tushka: Farmers State Bank

E


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

AAA A

A
A
A
A
A
A

a,

121,632
360,0002
(11-10-10) A
109,859
A

B

53,000 (11-10-10)
447,862
A
30,221
B
75,000 (4-10-10) B

160,258
59,489
64,946
- 277,805
35,813
63,225
67,301

A

162,585
62,842
205,606

B
B
B

Ji

A A -

B
A

Liauidated (completed Sept. 4, 1908)

Nono

25,000k"
1
46,418

Absorbed by Guaranteed State Bank
Reorganized as Union State Bank
Succeeded by the Oklahoma State Bank

Succeeded by the Planters State Bank of
Mountain Park
Absorbed by the American State Bank of
23,024 (1-1-13)
Geary
Liquidated
105,626
Absorbed by the Kiowa County Bank of
18,732
Snyder
Absorbed by the Wilkin-Hale State Bank
365,229
Absorbed by the Bank of Commerce, Sulphur
26,557
Liquidated
through Guarantee State Bank,
20,004
26,827
Shatluck
\j4bsorbed by Planters State Bank of Tushka
Succeeded by Watonga State Bank
105,383
Liquidated
Absorbed by the Blaine County dank of ;iatonfia
9,936
None
Succeeded by American State Bank of Pryor
17,559

48,722
58,718
13,225
148,261
None
36,004
29,260

(1-1-15)
(1-1-15)
(1-1-15)

(1-1-15)

63,213 (1-1-15)
44,204 (1-1-15)
86,939 (1-1-15)

Absorbed by the Sapulpa State Bank
Succeeded by Farmers' State Bank of Garvin
Succeeded by the Spiro State Bank
Reopened with same name
Absorbed by First State Bank of Hugo
Succeeded by Capitol tate bank
Succeeded by The First :tate Bank of
Stillwell
Liquidated
Liquidated through Citizens' State dank
Absorbed by Central State Bank of elva

- 2 -

•

LIST OF LieliKS FAILM DURING 2 IOD OF DEPOSIT GUARANTY LAW IN OKLAHOMA, 1908-1923 (continued)

Date of
closing

Location and name

Oklahoma City: Oklahoma State Bank
Muskogee: Union State Bank
Snyder:

Farmers and Merchants Bank

Wainwright: First State 3ank
Foraker: Bank of Foraker
Spencer: Bank of Spencer

Muskogee: Peoples 3ank and
Elgin: Bank of Elgin
Alva: Bank of Commerce
Afton: Afton .7xchange Bank

rust Company

Garfield '..)cchane-e Bunk

Enid:

•
eeCoweta: Farmers & Merchants Bunk
Mountain View: Farmers & Merchants Bank
Ponca City: Ponca State Bank
Mazie: Bank of Mazie
Mannsville:

Row:

First State Bank

First State Bank

Jefferson: Farmers state Bank
Jay: First State Bank

Dewar:
Tulsa:

First State Bank
Citizens State Bank

Tar River:

•

Minoral Belt Bank

Guthrie: Logan County Bank
Wilburton: Citizens BoDir
Sentinel: Oklahoma State Bank
Hallett: First State Bank
Keatherford: Farmers State Bank


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Deposits1/

L066 to

1913 (cont.)
Aug. 11
Sept. 13

A A -

487,244
226,209

Sept. 16

A -

38,449

B -

13,800 (1-1-15)

Oct. 16
Oct. 31
Dec. 16

A A A -

48,213
10,726
31,671

3B B -

15,500 (1-1-15)
6,867 (1-1-15)
21,896 (1-1-15)

1914
Jan. 31
Feb. 5
,.11r. 4
Apr. 7

A
A
A
A

-

54,808
17,232
76,633
24,559

B - 48,758 (1-1-15)
B - 11,351 (1-1-15)
8 - 37,363 (1-1-15)
None

May 27

A -

257,743

1915
Dec. 21
Feb. 16
Feb. 22
Mar. 24

A
A
A
A

Sept. 30

A -

32,340

1916
Nov. 17

A -

40,337

1917
Jan. 11
May 13

38,026
A 46,972
A

1918
Apr. 10
May 28

A A -

July 26

A - 113,575

1919
Jan. 31
Apr. 9
May 3
July 15
Aug. 4

A
A
A
A
C

- 102,822
67,961
94,391
14,026
-

-

120,117
965,283

261,000
286,000
153,000
52,000
150,000

Disposition

guaranty fund

A - 61,743
A 7,e93

A - 105,570

Absorbed by Tradesmene State Bank
Absorbed by American National Bank of
Muskogee
Consolidated with Kiowa National bank;
succeeded by Kiowa State Bank
Succeeded by The iarmers State Bank
Liquidated
Succeeded by Speecer State Bank

Liquidated
Reopened under Same name
Absorbed by Central State Bank of Alva
Succeeded by The Farmers State Benk of
Afton
Succeeded by Garfield County Sank of
Enid

B - 25,000 (1-1-17) Succeeded by First State bank of Coweta
City
B - 30,988 (1-1-17) Succeeded by Bank of Mountain View
Ponca/
of
• - 19,179 (1-1-17) Absorbed by Oklahoma State Bank
Liquidated through Citizens State Bank,
None
Viagoner
None
Succeeded by Mannsville State Bank

Liquidated

None
None

8 - 10,076 (1-1-19)
None
B - 24,000 (1-1-19)

Absorbed by The Bank of Jefferson
Absorbed by Delaware County Sank of Jay

Succeeded by Dewar State Bank
Absorbed by American National Bank of
Tulsa
Succeeded by Cardin State Bank

It

LIST OF BANKS FAILED DURING PERIOD OF DEP:S:T-GUaRANTY LAW IN OKLAHOMA, 1908-1923 (continued)

/

Location and name

Date of
closing

Deposits-1/

,
Loss to
guaranty fund /

- 180,000
- 115,000
- 383,000
- 575,000
- 191,000
75,000
- 498,000
-1,550,000

Ji

Disposition

1920
Jon-s: Bank of Jonas
Mulhall: Mulhall State Bank
Botwell: State Exchange Bank
CoalgaLe: Citizens State Bank
Foss: Bank of Foss
Fallis: First Bank of Fallis
Marietta: First State Bank
Shawnee: Securita State Bank

•

Oct. 6
Oct. 11
Nov.
Nov.
Nov.
Nov.
Nov.
Dec.

15
19
26
27
30
13

tda: Farmers State Ban1Q2/
Kiefer: Central State Bank
Kiefer: Exchange State Bank
Jenks: Bank of Jenka
Aylesworth: First State Bank
Pershing: Pershing State Bank
Miami: Miami State Bank
Pontotoc: Bank of Pontotoc

1921.
January
May 3
May 3
May 3
July 30
Aug. 15
Aug. 15
Sept. 15

Albion: First State Bank
Driftwcod: Citizens State Bank
Guthrie: Oklahoma State Bank

Sept. 20
Oct. 10
Oct. 25

C
C
C
C
C
C
C

917,000§1

C
3
B
13
B

B B -

246,000
359,000
128,000
173,000
28,000
77,000
235,000
93,000

-

B B B -

39,000
93,000
839,000

-

/
50,0002
171,525
109,385
137,404
4,508
None
91,200
- 56,470
12,880

- 56,973
- 589,059

Succeeded by Security State Bank
Succeeded by Security State Bank
Succeeded by First State Bank of Jenks
Liquidated(5-31-24)
Succeeded by Security State Bank
Succeeded by First State Bank
Absorbed by Guaranty State Bank,
Tishomingo
Reopened by Albion State Bank
Succeeded by Security State Bank
Succeeded by Guthrie State Rank

Loss to
depositor./
70,000
-2,065,000
- 329,000
94,000
- 103,000
71,000
112,000
40,000

Hoffman: First Bank of Hoffman
Okmulgee: Bank of Commerce
Sulphur: Bank of Commerce
Bliss: First State Bank
Preston: Oklahoma State Bank
Imo: Imo State Bank
Goltr: Bank of Goltry
Millerton: Bank of Millerton

Oct.
Nov.
Nov.
Nov.
Nov.
Nov.
Nov.
Nov.

25
1
3
12
12
15
16
17

B
B
B
B
B
B
B
B

Delaware: Delaware State Bank
Stonerall: First State Bank
Miami: Miami Trust & Savings Bunk
Chattanooga: Chattanooga State Bank
Meno: Bank of Meno
Pensacola: First State Bank

Nov.
Nov.
Dec.
Dec.
Dec.
Dec.

17
30
10
12
20
30

B - 124,000
B - 108,000
B - 290,000
B - 112,000
62,000
B 39,000
3-

•

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

C - 119,084
C -1,039,691 (1931)
None
C None
CC - 138,298
C - 29,862
C - 78,044
None
CC
-

30,956
None
58,905

cC-5,795
- 40,103
C-20,034

(1931)

Liquidated (5-10-29)
Liquidated
Reopened with same name
Reopened with same name
Liquidated (5-10-29)
Liquidated (12-15-28)
Liquidated (8-13-28)
Succeeded by Citizens State Bank of
Millerton
Succeeded by First State Bank
Reopened with same name
Absorbed by Ottawa County National Bank
Liquidated (6-27-30)
Liquidated
Absorbed by First State Bank, Vinita

4

•

LIST OF BANKS FhIL -D DURING PeUOD OF DEPOSIT GUARANTY LAW IN OKI.H014-,, 1908-1923 (continued)

Location and name

•

•

Date of
closin

Kenefick: Farmers State Bank
Guthrie: Guthrie State Bank
Durant: First State Bank
Morris: First State Bank
Bliss: First State Bank
El Reno: Comnercial Bank
Sulphur: Bank of Commerce
Oklahoma City: Wilkin-Hale Bank
Walters: Oklahoma State Bank
Stratford: State Bank of Stratford
Thetern State Bank
?]dmond State Bank
Caddo: Oklahoma State Bank
Clayton: First State Bank of Clayton
'Anson: Wilson State Bank
Park Hill: Farmers State Bank
Bartlesville: Bartlesville State 'Bank
Watn: Peoples Bank & Trust Co.
Cameron: Bank of Cameron
Clarita: First State Bank
Conancha: Farmers State Bank
Yale: Yale State Bank
Pawnee: Security State Bank
Glencoe: Farmers State Bank
Muskogee: Central State Bank
Gore: Farmers Bank of Illinois
Richmond: Bank of Richmond
Crowder: Bank of Crowder
Choctaw: State Bank of Choctaw
Wagoner: First State Bank
Bromide: Bromide State Bank

1922
Jan. 10
Jan. 11
Jan. 25
Jan. 27
Feb. 25
Feb. 23
Feb. 28
Mar. 8
Mar. 10
Mar. 1
Mar. 15
Mar. 15
Mar.
lar. 27
Apr. 3
Apr. 7
May 11
Zay 18
June 17
Aug. Aug. 7
Aug. 14
Aug. 14
Aug. 17
Aug. 18
Sept. 14
Sept. 18
Oct. 6
Nov. 2
Dec. 21
Dec. 29

Jennings: Oklahoma State Bank
Woodward: Central ',xchange Bank
Allen: First State Bank
Atwood: First State Bank
Ashland: First State Bank
Gage: Farmers State Bank
Foss: Foss State Bank
Merchanto Bank
Nash: 7arm.;
- re
Guaranty
State Bank
Achille:
Sallisaw: Sallisaw Bank .qf Trust Co.

1923
Jan. 1
Jan. 16
Jan. 22
Jan. 25
Jan. 25
Jan. 27
Jan. 28
Feb. 12
Feb. 12
Feb. 19


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Deposits:1/

B

•BB B B B B B B 3B B B B B B -

BBB •3B B B B BB B B B -

B
B
B
B
B
B
B
B
B
B

-

49,000
390,000
235,000
132,000
52,000
963,000
364,000
1,666,000
287,000
104,000
107,000
143,000
236,000
42,000
178,000
32,000
821,000
70,000
42,000
156,000
194,000
544,000
194,000
143,000
498,000
47,000
36,000
76,000
96,000
252,000
70,000

119,000
466,000
137,000
49,000
39,000
230,000
69,000
165,000
25,000
221,000

depositor_
Loss tr; /
' 8

:
C
C

l iEi:9
119:1
1)
)
359,900
36,608
30,912
60,230(1931)
74,027
149,368
58,266

Liquidated (6-27-29)
Liquidated
Liquidated
Succeeded by Peoples State Wink
Succeeded by Marland State Bank, Mariann
Liquidated
Liquidated
Liquidated
Liquidated (8-15-29)
Liquidated (11-20-28)
Liquidated (11-30-24)
Liquidated (9-28-22)
Liquidated
Liquidated (6-25-29)
Succeeded by Producers State Bank
Liquidated
Liquidated
Succeeded by Bank of 'il-ann
Liquidated (10-1-27)
Liuidat.ad (5;13-29)
Liquidated
Lic,uidated '
Liquidated(12-5-28)
Liquidated
Liquidated (5-9-29)
Liquidated (5-9-29)
Liquidated (11-1-29)
Liquidated
Liquidated (11-24-28)
Liquidated (12-15-28)
Liquidated (12-7-29)

94,894
234,343
25,866
12,800
16,553
Non
14,471
Non
18,6141931)
38,477

Liquidated (5-21-30)
Succeeded by Bank of Woodward
Succeeded by Depoeitors State Bank
Succeeded by Farmers State Bank
Liquidated (12-15-28)
Reopened with same name
Succeeded by Farmers State Bank
Succeeded by Farmers State Bank
Liquidated
Succeeded by Security State Bank

35,62'2

271,627(1931)
,y1(1931)
2065
None
687,803(1931)
303,995(1931)
.1.:/(1931)

C
C :
C -

C C

94,597
None
37,000
131,795(1931)
38,035
None
24,037(1931)
379,095(1931)
None
;
.
7
33
,i
2,
1;
2
116,616(1931)

_
C C C -

Disposition

5

LIST OF BANKS FAILED DIPING PERIOD OF DEPOSIT GUAisjINTY LA:i IN OKLAHOMA, 1908-1923 (continued)

1/

A - from Report of dank Commission:Ir, as of date of failure unless otherwi.e specified.
Individual deposits
Savings deposits
Bank deposits
Certificates of deposit
Cashier's checks
Certified checks

Items included:

3 - from schedules submitted to Federal Reserve Committee on Branch, Group and Chain Banking.
C - ?and McNally Bonk rs Directory.
A - from Robb, The Guaranty of Bank Deoosits. Figures presumably represent final loss to guaranty fund. Slightly larger fiures for some
of these banks are given in the biennial reports of the Bank Commissioner for net payments by the guarant.i fund to January 1, 1913,
or January 1, 1915.
3 - from biennial reports of the Bank Commissioner.

Figures represent net. payments to date indicated.

C - from schedules submitte4to Federal Reserve Committee on Branch, Group an

Chain Banking.

"2 Paid by State Banking Board to absorbing bank to protect it against loss.
This, :ase is listed in tha deport ol the Bank Commissionor as a reorganization, with no mention of any assist ace by the gur..nty f-and.
.):/

No data available.

L)/

Cooke, in article in Quart.:r1L Journal of Economics, November 1923, states that warrants for $2,196,000 were issued in 19.1, to cover the
deposits of 13 banks. Thae 13 oane,0 probably include:
9 which failed in 1921 and for which parmente from th._ :
:;uaranty fund are shown on the schedules collected by the Feth,rel P- .eserve
Committee on Branch, Group and Chain Banking.
1 whi::'n failed in January 1921, and not listed by the Federal Reserve Committee.
3 listed here as 19:20 failures (late in the year) - since issuance of warrants would be made at a date su )
uent to closing (after books
had V:,en examind by cruarantv fund of
The figure of estimated 1ohs-to guatanty fund ror tne three 1920 failures is derived by deducting the loss in the 10 banks failed in 1921 from
Cooke, Cluarterly Journal of Y,conomics, November 1923, p. 112. This failure i. not listed by Federal Reserve Committee; is probably the bank
listed in Rand McNally, July 1920 but not JanuLry 1921, under title of Guaranty State Bank.
nstimnted by dedu-ting offsets and dividends paid prom total claims allo,pd, as reported on schedules submitted to the Federal Peserve
Committee on Branch, Group and Chain Banking. For cases marked (1931), relating to bank.: still in process of liquioation, thi figure
represents unpais claims at the time schedules were prepared fo.' the Federal Reserve Committee on Blanch, Grouk. and Chain Boaking.

2/ Deposits November 10, 1910, amounting to $360,322, are those of the Union State Bank, which was a reorganization of the Alamo State Bank,
the banking board agreeing to protect it against loss. The deposit figure for November 10, 1910, is prooably similar to that for the
Alamo State Bank at the time of reorganization on August 25, 1910.
** Cooke's figure for th,.; amount of warrants issued in the case of the 13 banks.

•


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Division of Research ane Statistics
Federal Depo.it Imurance Corporation
CW:mod - September 20, 1941

**

•

For data on
warrants issued
and paid

On adding machine tapes
run from original
records in Bank
ComNissioner's office

See file folder with
data for individual
failed banks


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

it
c•
A


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

•

"
,7

.

.___.--

loans to inte7‘ts associated wi
, the managements of th
/6

banks which

failed.
///
//
/ The decline
aCCO

anying climb

a/ACt also UP

factor

Was

Cooke a
of t

the price of agricult

n the value of real es

al products and tbp-

e undoubtedly had-some

bank failures in Okla _cm in 1921 and l92.

f minor important, how

Mr. Pobb give very 1
causes of failures i

That this

er, is indicated/by the fact Mr.

tle atttention t9 it in their analysis

the z)tete.

The deposit guaranty plan in Oklahoma was in operation during
only two of the ten years for which the Federal Reserve Committee on
Branch, Group, and Chair Banking obtained orinions from State banking
authorities regarding the primary and contributing causes of suspensions.

•

Classification of the primary and contingent causes reported to the
Committee for 215 susp-nsions during 1921-30 is given below.

Number of cases
Primary Contingent
Decline of real estate values
Losses due to unforeseen agricultural or industrial disasters such as flood, drought,
boll weevil, etc.
Insufficient diversification or incompetent
management
Defalcation
Failure of affiliated institutions, correspondents, or large debtors
Heavy withdrawals and other causes

•

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

••

18

8

37

52
12

110
32

10
131

66

23

7,77'

*
L
"

y(

STATISTTCAL DATA REGAPDIrG DEPOSIT .":TJARANTY FUND IN
II, SUSPEND-,
1) BANKS AA) RESULTS Cr LIQUIDATION
•
I
Receivers' cbllect ons
Payments by receivers er liquidating agents
Banks suspended
Number of
Pd to demos. Pd to guar•Pd to other 4penees o
Total de.
Insured 1 olleatiope Colleotioys Total
111111eng from clout) 0
acimmezra-6
:beaks su
°netters direct arity f nd sources!
posits f
deposits o
tion &
-c
gih
* liability (3011°4:Ai
pended
banks
of bkai
Pen
•
suspend d
O. ofst
suspey3.ld
horis
ed 1
de
ir
5.
r°21

I

taker

/

'tAkivQ-044
r-IL4

Gr;13,55

64.0:70

-3\
t38'1

o.203,047

0

115,315 -13

I 30

q't
337

Ak_eA
A.A_o 12_041.21

r •75

314(>7(0
(1•Ar--

,

AA-

Mims of depositors
finally eelleoted from assets of bank
Amounts

.e.
https://fraser.stlouisfed.org ``'"4`1"-eZir?-1/trt
Federal Reserve Bank of St. Louis

I

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S4


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

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u-AWA.

•


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

•
INFORMATION REGARDING FINANCIAL OPERATIONS OF THE
OKLAHOMA DEPOSIT GUARANTY FUND
Cost to January 1923
The guaranty system, in its fifteen years of operation to January
last, had cost the banks of Oklahoma $3,647,486.42.
Excerpt from Cooke's article in QUarterly Journal of Economics,
Nov. 1923, p. 117.
During the life ot the guaranty 18w, from February of 1908 to
March of 1923, State banks paid into the fund assessments totaling
4•3,729,937; a total of 42,195,137,was realized from liquidation of
the assets of failed banks taken over by the department, and approximately $6,000,000 was paid out to depositors.
Excerpt from Federal Reserve Bulletin, September 1925, D. 631.

Warrants outstanding and derosits unpaid
Warrants outstanding on that day (Sept. 26, 1923) were $1,336,999.27.

•

Excerpt from Cook, op. cit.
In March, 1923, when the law was repealed, the assumed liabilities
of the fund ircluded interest-bearing warrants outstanding, and in
addition there were the unpaid deposits in banks which became insolvent
in the period from October, 1921, when the system became inoperative,
to March, 1923. On the warrants outstanding no interest had been paid
since their issue and the amount still outstanding in 1925 is given by
the State office as 41,330,000. The unpaid deposits totaled approximately

46,000,000.
Excerpt from Federal Reserve Bulletin, Sept. 1925, p. 631
On February 19, 1929, the indebtedness of the fund, represented
by outstanding warrants, amounted to $1,297,000.
Excerpt from Blocker, "The Guaranty of State Bank Deposits," p. 26.
The decision September 11 of this year set forth that there was
Z214,057 in cash and 4149,621 in Liberty bonds and oth-r securities in
the fund and that there are outstanding and unpaid 41,200,000 in
depositors' guaranty fund warrants. It also was shown that there was
available to the fund 41,500,000 consisting of prcbmissory notes and
other frozen assets received from various failed banks which are of
doubtful value.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Excerpt from The American Banker, Oct. 23, 1934, in article
regarding the State Supreme ''ourt decision. That decision
provided for payment of warrants lowest in numerical order.

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Federal Reserve Bank of St. Louis

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Federal Reserve Bank of St. Louis

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Federal Reserve Bank of St. Louis

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Federal Reserve Bank of St. Louis

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<- 641..5

STATISTICAL DATA REGARDIl:G DEF'..)SIT GUARAI'TY FT IN
V. ACCU11JLATIO1 OR DEFICIT IN FUND

S

Balance in
rund
(income
minus
expense
pad to
date)

Year

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monts 1 vled oerti
but not yot oats* or
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slain*
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outst
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net aogu•
va/um of
tion o
ments'
mulatiOn
unliqui.
probab
(lanai
or
deficit
dated
not
in
in
of
fund
assets
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(sum
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preceding
ing three
(share or three
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•


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Federal Reserve Bank of St. Louis

•

•

A

•

DEPOSIT GUARANTY IN OKLAHOMA

by

•

•

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Clark Warburton, Principal Economist
Division of Research and Statistics
Federal Deposit Insurance Corporation

0

•
FOREWORD

This re-?ort on deposit guaranty in Oklahoma, 190g1923, prepared by Clark Warburton, is the first of a
projected group of reports on the character and operation
of deposit guaranty systems in various States loner to the
adopTion of Federal deposit insurance. A study of the
previous systems of deposit guaranty in the United States was
undertaken in the belief that a knowledge of the character
and operation of those systems would be helpful in the formu—
lation of policies contributing to the success of deposit
insurance.
In collecting data for the report, Mr. Warburton
has been assisted by Mrs. Ethel Bastedo and other members of
the clerical and statistical staff of the Division. He has
also had the advice and criticism of other members of the
Staff of the Division in the preparation of the report.

Donald S. Thompson, Chief
Division of Research and Statistics
Federal Deposit Insurance Corporation

January 15, 1942

•

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Federal Reserve Bank of St. Louis

TABLE OF CONTENTS

•

DEPOSIT GUARANTY IN OKLAHOMA

Page

•

2
2

Character of the guaranty legislation
Admission of banks
Deposits guaranteed
Assessments
Administration and custody of the fund
Indebtedness of guaranty fund
Method of paying depositors and of liquidating failed banks
Expenses of administration

10

Constitutionality of the deposit guaranty law
Decisions of the State courts
Decision of the United States Supreme Court

10
12
12

Supervision and regulation of guaranteed banks
Supervisory authority
Examination of banks for admission to guaranty
Supervisory powers of the Bank Commissioner
Statutory limitations on bank operations

15
15
16
17
20

Number and deposits of guaranteed banks
Number of participating banks
Deposits of participating and non-participating banks
Concentration of ban deposits

23
23
23
23

Bank failures
Number and deposits of failed banks
Suspensions by size of bank
Comparison with suspensions in other States
Causes of bank failures

27
27
29
32
32

Financial history of the guaranty fund
Sources and adequacy of information
Income and expenses of the guaranty fund
Annual assessments and losses in failed banks
Adequacy of the guaranty fund
The burden of assessments

36
37
4o
43

Effectiveness of bank supervision

4g

Closing of the guaranty fund

52

•

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Federal Reserve Bank of St. Louis

3
4
6
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36

47

•

LIST OF TABLES

Page,

Table
1.

2.

3.

4.

5.

•

6.

7.

8.

9.

10.

11.

•

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

Number of operating banks in Oklahoma participating
and not participating in the deposit guaranty
system, 1908-1923, by years

24

Deposits of operating banks in Oklahoma participating
and not participating in the deposit guaranty
system, 1908-1923, by years

25

Number and deposits of State banks in Oklahoma,
November 10, 1910, and December 29, 1920, banks
grouped by amount of deposits

26

Number and deposits of State banks in Oklahoma closed
because of financial difficulties, February 14,
1908, to March 31, 1923

28

Number and deposits of State banks in Oklahoma closed
because of financial difficulties, February 14,
1908, to harch 31, 1923, by years

30

Size distribution of failed banks in Oklahoma compared
with average size distribution of operating State
banks: period of operation of deposit guaranty system

31

Bank failure rates in Oklahoma, 1908-1922, compared
with rates in contiguous States and in the United
States

33

Estimated total income and expenses of the Oklahoma
Depositors' Guaranty Fund

3g

Rates and amounts of assessment, and estimated losbes
from bank failures, Oklahoma Depositors' Guaranty
Fund, by years

141

Deposits in failed banks in Oklahoma during the period
of operation of the deposit guaranty law, paid and
unpaid, with sources of funds used in payment

44

Number and deposits of State banks in Oklahoma,
1906-1920

53

•

DEPOSIT GUARANTY IN OKLAHOMA

The Oklahoma law for the guaranty of deposits was approved
December 17, 1907, at the first session of the Legislature after admission
of Oklahoma into the Federal Union as a State.

The law became effective

February 14, 1908, and continued in full operation for 13 years.

In 1921,

when the liabilities of the fund exceeded its receipts, the law became
inoperative with respect to protection of depositors in closed

banks, but

the liability of the banks for payment of assessments continued until the
repeal of the law in 1923.

The affairs of the fund were not fully settled

until 1934.
Eight States established deposit guaranty funds during the period

411

1907-1917.11

Oklahoma was the first of these States, and is generally

regarded as the pioneer in the movement to provide safety for bank deposits
through application of the insurance principle.

In fact, however, sev—

eral States had established guaranty funds for bank obligations, or had
provided for the mutual guaranty of such obligations, during the preceding
century.

When the Oklahoma law was enacted, forty years had elapsed

since these plans had been in operation, and very little was known about
their character or the success of their operations.
The States other than Oklahoma were Kansas, Nebraska, and
Texas in 1909; Mississippi in 1914; South Dakota in 1915; and North
Dakota and Washington in 1917.
2/ New York in 1829; Vermont in 1831; Indiana in 1834; Michigan
in 1836; Ohio in 1845; Iowa in 1858. All debts of the banks were covered
in Vermont, Indiana, and Michigan; only circulating notes were covered in
Ohio and Iowa. In New York all debts of the banks were covered from 1829
to 1842 and only circulating notes thereafter.

•

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Federal Reserve Bank of St. Louis

-2-

CHARACTER OF THE GUARANTY LEGISLATIO11/

Admission of banks.

Participation in the deposit guaranty plan

was made compulsory for all banks and trust companies operating under a
State charter in Oklahoma.

At the same time, private banks, which had

been permitted to operate in the Indian Territory part of the State, were
required to incorporate.

Under a ruling of the attorney general the

guaranty became effective immediately upon the levy of the first assessment, which was required to be made within

60

days after passage of the

law.
Approximately 475 banks, excluding national banks, were operating in Oklahoma at the time the deposit guaranty law was enacted.

•

Of

these, 294 were located in the former Oklahoma Territory, and the remainder
in the former Indian Territory.

Banks in Oklahoma Territory had been

subject to examination by the Territorial Bank Commissioner for a decade,
but banks in the Indian Territory had never peen subject to examination
or supervision.
The guaranty law in Oklahoma also provided that any national
bank in the State might voluntarily come under the protection of the
depositors' guaranty fund with the approval of the Bank Commissioner.

The

Attorney-General of the United States in July 1908 ruled that national
banks could not legally participate in a State system of deposit guaranty.
1/ The banking laws of Oklahoma were codified, revised and
reenacted on May 25, 1908. The guaranty law was not substantially modified
at that time, ana the description of its provisions given here is based
on the revised banking code.

•

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Federal Reserve Bank of St. Louis

- 3In 1911 the law was amended to exclude from the fund, after
September 1 of that year, corporations doing a trust business.

This

change excluded only two institutions, holding about one per cent of the
aggregate deposits previously covered by the guaranty.11
Deposits guaranteed.

Deposit guaranty in Oklahoma originally

covered all deposits, the law providing that the State Banking Board should
draw from the depositors' guaranty fund whatever amount, in addition to the
cash which could be made immediately available in a failed bank, was
necessary to meet the deposits of the bank.
In 1913 deposits otherwise secured, and denosits on which a
greater rate of interest was paid than was authorized by the Bank Commis—

•

sioner, were excluded from the protection of the fund.

The application of

the guaranty to certain secured deposits was also limited by a decision
of the State Supreme Court in 1917.

This decision referred to moneys

belonging to the permanent school fund deposited in a
insolvent in 1909.

an

which became

The assets of the bank were insufficient to pay the

general depositors, and the court ruled that the school fund deposit was
not entitled to protection by the depositors' guaranty fund, since the
statute provided a specific system for the protection of the school fund.
The court also ruled that the school fund deposit was not entitled to
share in the assets of the institution.
1/ One of these two trust companies relinquished its trust
company charter and became a State bank, thus coming back under the guar—
anty system, about eighteen months later; the other consolidated with a
national bank in 1914.

•

2/ United States Fidelity & Guaranty_ Co.
67 Okla. 14-, 168 Pac.
4.


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Federal Reserve Bank of St. Louis

V.

State et al. (1917)

-4-

•
Two years after the statutory exemption of deposits otherwise
secured, an amendment to the law provided that surety companies paying a
deposit of public funds for which they were liable in a failed bank were
entitled to a pro-rata share with the depositors' guaranty fund in the
proceeds of the assets of such failed banks.

This amendment, however, was

declared void by the State Supreme Court.
These decisions did not reduce the protection afforded school
out
or other public funds, but prevented surety companies from recouping,
of the guaranty fund or the assets of closed banks, any part of their
losses in Oklahoma banks.
Assessments.

•

The original deposit guaranty law in Oklahoma pro-

s,
vided for an initial assessment of 1 percent of average daily deposit
during the
excluding United States and State funds if otherwise secured,
year preceding the first call by the State Banking Board.

Annual assess-

growth
ments, using the same method of computation, were to be made on the
?../
of deposits.

If the fund became depleted, it became the duty of the

State Banking Board to levy a special assessment sufficient to restore
the fund to 1 percent of average daily deposits, excluding United States
and State funds.
In 1909, about a year after the initial assessment was levied,
the assessment provisions were revised.

The new law provided for the

accumulation of a fund amounting to 5 percent of average daily deposits

•

1/ State ex rel. Short, Atti. Gen. v. Johnson et al. (1923) 90
lity,
Okla. 21. The ground on which this decision was made was a technica
against
fund
y
guarant
ors'
namely, that the preference right of the deposit
not
the assets of a failed bank had been impaired, and that this was
expressed in the title of the amendatory act.
No provision was made for refund if the deposits of a bank
decreased.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

I

5

(

through an assessment payable in annual instalments of one—twentieth of
1 percent of average daily deposits (modified in 1911 to annual assess—
ments at this rate) with a credit for the initial assessment already paid.
Each bank was also required, once a year, to make such additional payment
as was necessary to adjust its total payments into the fund in propor—
tion to any growth in its deposits.

Special assessments for restoration

of the fund when reduced by payments to depositors of closed banks were
limited to 2 percent in any calendar year.

All assessments were computed

on the basis of average daily deposits during a period of a year, the
deduction for United States and State funds being eliminated.
Further changes in assessments were made ia 1913, following two

•

years in which the total assessments averaged over 1 percent of deposits

Lea4)

'The regular annual assessmentA,lma,e,raised to one—fifth of
per year.1
1 percent of average daily deposits, and the maximum funa to be accumu—
lated was reduced to 2 percent of deposits.

Assessments for restoration

of the fund, when reduced below 2 percent of average daily deposits, were
limited to one—fifth of 1 percent in any year.

Also, special assessments

not exceeding one—fifth of 1 percent each year were expressly authorized
during the following three years and forbidden thereafter.

These provi—

sions remained in force during the subsequent duration of the fund.
The 1913 amendment to the guaranty law also provided for the
posting with the State Banking Board, by each oank, of State or local
government obligations approved by the Board in an amount not less than
1 percent of average daily deposits, with a minimum of $500, as security
1/ The regular and special assessments in 1911 amounted to 1.2
percent of deposits, and in 1912 to .95 percent of deposits.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

-6

•
for the payment of assessments.
A problem of collecting the assessment arose from the conversion of State banks to national banks.

Under a State Supreme Court decisinn

in 1915 a bank subject to the law of 1909 which had become a national bank
was liable for the full

5

percent assessment, payable ia accordance with

the instalment payments imposed by that law.

The court held that the

State bank, though it had ceased to exist as a State corporation, did not
thereby escape liabilities incurred by it during its continuance as a
State bank.

The effect of this decision was neither to mature nor discharge

the deferred payments of the assessment.'"

This decision, however, was

reversed four years later, when the Court decided that the bank was liable

•

only for such payments as matured or were payable while it was doing
business as a State bank.
Banks organized subsequent to the enactment of the deposit
guaranty law, excluding those formed by reorganization or consolidation
of banks subject to the law, were required to pay into the fund at the
time of opening for business

3

percent of the amount of their capital stock.

This payment was a credit fund, subject to adjustment on the basis of
deposits at the end of one year.

This provision was retained throughout

the entire period of the law's existence.
Administration and custody of the fund.

Supervision and manage-

ment of the depositors' guaranty fund in Oklahoma were placed in the State
lj State ex rel. West, Atty. Gen. v. Farmers' National Bank of
Cushing (1915) 47 Okla. 667, 150 Pac. 212.
?../ Citizens National Bank of Broken Arrow v. State ex rel.
Freeling, Atty. Gen. (1919) 76 Okla. 94, 184 Pac. 63.


https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

0

7

•

^

Banking Board, composed of the Governor, Lieutenant Governor, the Presi—
dent of the Board of Agriculture, State Treasurer, and State Auditor.
This Board was empowered to adopt all suitable rules and regulations not
inconsistent with law for the management and administration of the fund.
In 1911 the composition of the State Banking Board was altered to consist
of the Governor and two other members appointed by the Governor, with the
approval of the Senate, to be remunerated on a per diem plus expenses
basis.

The Bank Commissioner was made ex officio secretary of the State

Banking Board.
Two years later the composition of the State Banking Board was
again changed.

•

After that date the Board was composed of the Bank Com—

missioner as ex officio chairman and three members appointed by the
Governor.

The Commissioner was appointed by the Governor from a panel of

three persons, and the other members from a panel of nine persons, recom—
mended by the executive council of the State Bankers Association, an
association consisting of a representative selected by the board of direc—
tors of each bank.

After two years' experience with this method of

appointment, the recommendation of persons for Commissioner by the State
Bankers Association was dropped, and the Commissioner was appointed by
the Governor.
The original law contained no provision regarding investment of
the guaranty fund, but in 1909 provision was made for the investment of

75

percent of the guaranty fund in State warrants or such other securities

as were specified for State funds.

Two years later, after a large part

of the fund kept in cash had been tied up by the failure of the bank in


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Federal Reserve Bank of St. Louis

—

—

which it was danosited, the law was amended to provide for the re—deposit
of the entire fund in the respective banks, according to the amounts of
their assessments, the banks issuing to the Bank Commissioner certificates
of deposit bearing

4

percent interest.

In 1.13 the law was again amended

to provide for the payment of the assessment in the form of cashier's checks
to be held by the State Banking Board until it was necessary to collect
them.

Such cashiers' checks were to bear no interest.

The requirement of

deposit of securities as surety for the payment of assessments, adopted
at this time, has been mentioned above.
Indebtedness of guaranty fund.

The original law contained no

provision against the contingency that the assessments collected might be

S

inadequate to pay all of the deposits in closed banks, other than the
provision for such additional assessments as might be needed.

In 1909, when

a maximum was placed upon the special assessments which could be levied
in any one year, the State Banking Board was authorized, in the event
that the assessments were insufficient to meet the claims of depositors
in failed banks, to issue certificates of indebtedness bearing
interest to the depositors.

6

percent

Such certificates were to be consecutively

numbered and to be paid by the State Banking Board as soon as possible in
the order in which they had been issued.
The foregoing provisions were in effect until 1913, when they
were replaced by a method of borrowing designed to provide immediate cash
with which the guaranty fund could pay the depositors of failed banks.

The

State Banking Board was authorized to issue "Depositors' Guaranty Fund

•

Warrants," bearing


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Federal Reserve Bank of St. Louis

6

percent interest, which could be disposed of at not

-9

1

•
less than par value.

These warrants were given a first lien upon future

receipts of the guaranty fund from assessments or from the proceeds of
liquidation of failed banks, and were to be retired in order of issue.

The

warrants were made non—taxable; and were authorized as investments of trust
funds and as collateral required to be deposited for the security of public
Any bank, trust company, building and loan association, or insur—

funds.

ance company was authorized to purchase the warrants to the extent of its
capital and surplus.

In 1915 the investment of a bank in such warrants

was limited to its surplus and 10 percent of its capital stock.
Method of payin“epositors and of liquidating failed banks.
Depositors in a failed bank were to be paid by the State Banking Board in
cash when the Bank Commissioner took possession of the bank.

•

From 1909 to

1913, as has been indicated, the Board issued certificates of indebtedness
to the depositors if the amount in the fund was insufficient.

After 1913,

the Board was authorized to sell warrants and use the proceeds therefrom
to make immediate payment to the depositors.
The State was given a first lien, for the benefit of the deposi—
tors

guaranty fund, upon the assets of any failed bank, including the

personal liabilities of stockholders, officers, directors or other persons
to the bank.

In 1909 an amendment to the law provided that the funds

realized by the Bank Commissioner from the assets of a failed bank should
first be applied to the expenses of liquidation, then to payment to the
depositors' guaranty fund of all money paid by that fund to depositors of
the bank concerned, then to the refunding of any emergency assessments

•

levted upon the guaranteed banks.


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Federal Reserve Bank of St. Louis

S
— 10—

•

Expenses of administration.

Expenses incurred by the State Bank-

ing Board in administering the depositors' guaranty fund were paid by the
Board from the proceeds of examination fees levied upon the banks for
each examination maae.

Under the 1908 law the Bank Commissioner's salary

and other expenses of his office were also to be paid from the proceeds
of the examination fees.

However, in 1913 the salaries of the Commissioner

and of 12 assistants were made payable frcm the general revenue fund of
the State.

CONSTITUTIONALITY OF THE DEPOSIT GUARANTY LAW

Bankers objected to the deposit guaranty law in Oklahoma, and a
test of the constitutionality of the law was made by the Noble State Bank.
This Bank asked the district court of Logan County for an injunction
restraining the levy of the first assessment by the State Banking Board.
The Noble State Bank contended that the guaranty law was in
conflict with several sections of the Constitution of the State of
Oklahoma, for the following reasons:
1.

That the law deprived the bank of the enjoyment of the

gains of its own industry for the benefit of depositors of
other banks in which the plaintiff had no interest.
2.

That the law deprived the bank of its property without

due process of law.

411

1/ It was claimed that the law violated the following sections
of the State Constitution: (1) Sec. 2, Art. 2; (2) Sec. 7, Art. 2;
(3) Sec. 15, Art. 2; (L) Sec. 23, Art. 2; (5) Sec. 24, Art. 2; (6) Sec.
57, Art. 5; (7) Sec. 8, Art. 10; (8) Sec. 9, Art. 10; (9) Sec. 14, Art.
10; and (10) Sec. 1, Art. 14.


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Federal Reserve Bank of St. Louis

- 11-

•

3.

That the law violated the contract between the bank

and the State of Oklahoma, evidenced by its charter, patent, and
certificate of authority.
4.

That the property of the bank was taken for private use

without compensation and against the consent of the bank.
5.

That, if it be held that the property was taken for

public use, then it was taken without compensation and not in
accordance with the form prescribed.

6.

That the law embraced more than one subject.

7. That, if the law be construed as levying a tax, this
tax was assessed upon an arbitrary basis without regard to the
fair cash value of the property assessed.
S.

That, if the law be construed as levying a tax, this

tax excceded the maximum permitted.
9.

That, if the law be construed as levying a tax, this

tax was levied for private purposes rather than public use.
10.

That the deposit guaranty law did not provide for the

protection of individual stockholders in the bank.
The Noble State Bank also contended that the depositors' guaranty
fund law violated the Constitution of the United States:

(1) by impairing

the obligation of the contract between the bank and the State of Oklahoma
as evidenced by its articles of incorporation, patent, and certificate of
authority; and (2) by depriving the bank of its property without due
process of the law, denying to it equal protection of the law.1/

411

1/ It was claimed that the law violated the following sections
of the Constitution of the United States: (1) Sec. 10, Art. 1; (2) Fourteenth Amendment.


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Federal Reserve Bank of St. Louis

- 12 -

Decisions of the State courts.

The district court of Logan

Bank.
County refused to grant the injunction requested by the Noble State
The Bank appealed the case to the Oklahoma Supreme Court, which upheld
the decision of the lower court.
The State Supreme Court, in a lengthy opinion, maintained the
point of view illustrated by the following quotation:
Banks are chartered by the state, not with the paramount
view of enabling the stockholders to make investments and derive
profits therefrom, but to meet a public necessity. The stockholders, having made investments therein, should be protected,
but private interEst must always be subordinated by the state,
in the reasonable exercise of its police power, to the public
as
welfare or good. With the view that the depositor, as well
interthe stockholder, and the general public with an incidental
est therein, may be protected, banking is regulated, and limitations, restraints, and requirements are imposed. The imposition
of
of double liability upon the stockholders; the requirement
reserve funds, stipulations as to what capital stock cannot be
invested in; prescribed qualifications of the directors--all
these having been tried, in the judgment of the Legislature the
further restriction that active officers should not borrow from
the bank without incurring pains and penalties was deemed salutary. In addition to further and more completely protect the
depositors, the depositors' guaranty fund is created, the
Legislature acting pursuant to the mandatory declaration of the
Constitution . . .
Decision of the United States Supreme Court.

The Noble State

Bank was dissatisfied with the decision of the Oklahoma Supreme Court
and appealed to the United States Supreme Court.

While the case was

pending, similar cases came before the United States Supreme Court regarddeciing deposit guaranty laws in Nebraska and Kansas, on appeals from
sions of the Nebraska Supreme Court and the Circuit Court of the United
States for the District of Kansas, respectively.

410

1/ Supreme Court of Oklahoma, Noble State Bank v. Haskell et
al., 22 Okla. 48, 97 Pac. 590, No. 83. Opinion filed September 11, 1909.


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Federal Reserve Bank of St. Louis

-13-

•

The United States Supreme Court heard the arguments regarding
the three cases at its fall term in 1910.

On January 3, 1911, the Court

rendered its decision on the Oklahoma case, which was also applicable to
the Nebraska and Kansas cases.
The principal point in the cases considered by the United States
Supreme Court was the contention that the deposit guaranty laws took the
private property of one bank for the private use of another bank without
compensation.

That this might be the case was admitted by the Court, but

the decision pointed out that such transfers of property are constitutional
if there is sufficient purpose and necessity.

•

... It is established by a series of cases that an ulterior
public advantage may justify a comparatively insignificant taking
of private property for what, in its imediate purpose, is a
private use... There may be other cases besides the everyday one
of taxation, in which the share to each party in the benefit of a
scheme of mutual protection is sufficient compensation for the
correlative burden that it is compelled to assume... At least, if
we have a case within the reasonable exercse of the police power
as above explained, no more need be said.li
The Court discussed the application of police power to the guaranty of bank deposits as follows:
The levy and collection, under a State statute, from every
bank existing under the State laws, of an assessment based upon
average daily deposits, for the purpose of creating a depositors'
guaranty fund to secure the full repayment of deposits in case
any such bank becomes insolvent, is a valid exercise of the police
power, and cannot be regarded as depriving a solvent bank of its
liberty or property without due process of law... The police power
of a State extends to the regulation of the banking business, and
even to its prohibition, except on such conditions as the State
may prescribe.

•

It may be said in a general way that the police power extends
to all the great public needs. It may be put forth in aid of
what is sanctioned by usage, or held by the prevailing morality
or strong and preponderant opinion to be greatly and immediately


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Federal Reserve Bank of St. Louis

21 Noble State Bank v. Haskell

(1911) 219 U.S. 112.

•
necessary to the public welfare. Among matters of that sort
probably few would doubt that both usage and preponderant opinion
give their sanction to enforcing the primary conditions of successful commerce. One of those conditions at the present time is
the possibility of payment by checks drawn against bank deposits,
to such an extent do checks replace currency in daily business.
If then the legislature of the State thinks that the public welfare
requires the measure under consideration, analogy and principle
are in favor of the pover to enact it. Even the primary object
of the required assessment is not a private benefit as it was in
the cases above cited of a ditch for irrigation or a railway to a
mine, but it is to make the currency of checks secure, and by the
same stroke to make safe the almost compulsory resort of depositors
to banks as the only available means for keeping money on hand./
This decision is notable not only because it affirmed the constitutionality of the deposit guaranty legislation, but also because of the
grounds on which that affirmation was made.

The uecision is based on the

ground that safety of payments made by check is one of the primary condi-

•

tions of successful commerce, that the police -,mwer covers any regulations
necessary to make the currency of checks secure, and to make safe the
money kept on hand by depositors in the form of bank deposits.

The deci-

sion thus rests wholly on the idea that the purpose of the legislation is
the protection of the circulating media.
The problem of the constitutionality of a deposit guaranty or
insurance plan designed primarily to protect the invested savings of individuals was not considered by the Supreme Court in this case.

The Court

neither asserted nor implied that assessments upon one bank for the purpose
of protecting interest-bearing deposits, or other deposits not subject to
check, are constitutional, except as such protection may be incidental
to the protection of deposits which are part of the circulating media.

•

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Federal Reserve Bank of St. Louis

1/

Noble State Bank v. Haskell, 219 U.S. 104, 111-12.

—15 -

SUPERVISION AND REGULATION OF GUARANTEED BANKSli

Supervisory authority.

The deposit guaranty law in Oklahoma was

enacted almost immediately after the admission of Oklahoma into the Federal
Union as a State.

At that time banks in the former Oklahoma Territory,

comprising the eastern part of the new State, had been subject to examination by the Territorial Bank Commissioner for about ten years.

Banks in

the former Indian Territory, comprising the western part of the State,
operated as private banks or with charters obtained under the general incorporation law of Arkansas, which had been extended to the Indian Territory
by Act of Congress.

However, neither the private nor the incorporated

banks were examined or supervised.
The Oklahoma banking code adopted in 1907 and 1908, at the time
of enactment of the deposit guaranty law, provided for the appointment of

•

a State Banking Board and of a Bank Commissioner.

The State Banking Board

was given no duties other than administration of the deposit guaranty law.
The Bank Commissioner was charged with the following duties:

certifica-

tion of compliance with the law by persons organizing new banks and
authorization of such banks to open for business, examination of all Statechartered banks and trust companies and of national banks if they should
apply for the benefits of deposit guaranty, reporting of violations of
law to enforcement authorities, handling of banks closed because of
insolvency or for violations of law, and other duties, such as obtaining
reports of condition, associated with bank supervision.
Under the 1908 law the Bank Commissioner was appointed by the
Governor, with the advice and consent of the Senate, for a term of four

•

The deposit guaranty law as enacted December 17, 1907, contained several amendments to the old banking laws of Oklahoma Territory, and
further amendments were made in February 1908. The banking laws of the
State were codified, revised and re-enacted on Tilay 25, 1908. References
given here to the banking laws at the time of inauguration of deposit
guaranty, or to the 1908 law, are based on the revised banking code.


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Federal Reserve Bank of St. Louis

-16 years.

The Bank Commissioner must have had, prior to appointment, at least

three years' practical experience as a banker, but at the time of appointment could not be an officer or employee of any bank or any person interested as an owner or stockholder of a bank.

In 1911 the .dank Commissioner

was made ex officio secretary of the Board.

Two years later the Bank

Commissioner was made ex officio chairman of the State Banking Board, the
practical banking experience required of the person appointed was raised
to five years, and the appointment was required to be made from a panel of
three persons named by the State Bankers Association.

The last of these

provisions was drapped after two years.
Examination of banks for admission to guaranty.

The first task

of the State Banking Board and the Bank Commissioner after enactment of the
deposit guaranty law was to examine all banks in the State, other than
national banks, before the deposit guaranty law should become effective.
The Commissioner did not have sufficient examiners to make these examinations, particularly in view of the fact that the banks in the former Indian
Territory had not nreviously been examined.

A special force of 31 examiners

selected from among bankers in the State was employed and 513 examinations
were made within a period of a month.
The Bank Commissioner, in his report for 1908, states that
those banks whose condition or past record did not justify a continuation
of business were ordered to discontinue receiving deposits and to liquidate, and that they did so.

However, no record is available of the number

of banks which failed to meet the standards which were required by the
Commissioner and the State Banking Board for continuance in business and

•

admission to guaranty.


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Federal Reserve Bank of St. Louis

-17—

•

The examinations appear to have been inadequate.

They were con—

ducted in great haste by men who had not been trained as bank examiners.
The Bank Commissioner, in his 190S report, stated that a large number of
banks which were not being operated in full accordance with the banking
laws were allowed to continue in operation on their promise to correct
objectionable features, but claimed that the banks admitted to guaranty
were solvent.

Twelve years later T. Bruce Robb studied the operation of

the guaranty system and concluded:
... this description of the condition of the banks was far
too roseate. It is now well known that a goodly number of banks,
especially 9n the Indian Territory side, were positively
insolvent —1-i
Supervisory powers of the Bank Commissioner.

The supervisory

powers given the Bank Commissioner related chiefly to examinations, the

•

capital position of the banks, and conditions under which a bank could be
closed.

The Commissioner also had some powers relating to the opening of

new banks and to the quality of bank management.
The Commissioner was required to make two examinations a year of
each bank, and empowered to make additional examinations at any time
deemed necessary.

He was required to call at least four times a year for

reports of condition.

Fees for examinations were specified in the law,

ranging from $15 to $35 for each examination.
Under the 190S law the Bank Commissioner prescribed the maximum
amount of deposits which a bank could receive in proportion to its paid—
up capital and surplus.

In 1909 this power was replaced by a statutory

prohibition on the receipt of deposits (excluding deposits of other banks)

•

in excess of ten times paid—up capital and surplus.


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Federal Reserve Bank of St. Louis

1/

If the reports of a

T. Bruce Robb, The Guaranty of Bank Deposits, p. 41.

—18—

•

bank indicated deposits in excess of this ratio, it became the duty of the
Commissioner to require the bank to increase its capital or surplus or to
cease to receive deposits.

This provision of law could have been made an

extremely valuable weapon in maintaining the banks in a sound condition and
in preventing unwise bank expansion, had the ratio been computed on the
capital and surplus as appraised by bank examiners instead of being com—
puted on capital and surplus as stated in the reports of the banks, and
had the examining force been sufficiently large and competent to provide
good appraisals.
The Commissioner was also required to notify a bank to make good,
within sixty days, any impairment of its capital stock.

•

He could order

the removal from office of any bank official whom he found to be dishonest,
reckless or incompetent.

He was required to report to the county attorney

any violation of law constituting misdemeanor or a felony by an officer,
owner, or employee of a bank.
No bank was permitted to open for business without authorization
by the Bank Commissioner.

The Bank Commissioner, from 1903 to 1910,

declined to grant certificates of authorization to open if conditions in
the various communities did not justify the organization of additional
banks.

However, exercise of this discretion was stopped by a decision of

the State Supreme Court, and the Commissioner was required to issue such
authorization if the bank had been organized in the manner prescribed by
lj The law specified that action was to be taken on the basis
of the reports submitted by the banks, such reports to be in the form
required by the Commissioner. The law did not specify whether the
Commissioner could require the banks, in submitting reports of assets
and liabilities, to adjust valuations in accordance with examiners'
appraisals.


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Federal Reserve Bank of St. Louis

- 19 -

•

law and its capital was fully paid)'

In 1913, however, the law was amended

to require the approval of the Commissioner and of the State Banking Board
before issuance of a charter for the organization of a bank.

No speci-

fications were given in the law for the guidance of the Board in exercising
its discretion in passing on applications, but the Bank Commissioner, in
his report for 1914, laid down the following principles:
Under the present system ... no charter is issued unless
positive proof be furnished that the banking facilities of the
community are not adequate to the public needs. There must be
convincing evidence at hand that the enterprise will be an assured
success. Those applying for a charter must be men in every way
worthy of confidence and the proposed officers must be of the 2/
highest honesty and integrity, having ample banking experience.
The Bank Commissioner was given authority to close a bank if he

•

was satisfied of its insolvency after examination, or if a bank were
judged insolvent by a court.

The law specified that a bank should be

deemed insolvent when the actual cash market value of its assets was insufficient to pay its liabilities, or when it was unable to meet the demands
of its creditors in the usual and customary manner, or when it failed to
make good its reserve as required by law.

The Bank Commissioner could

also close a bank for violation of the banking law by any of its officers,
or for interference with or refusal to permit examination of any of the
affairs of the bank.

The board of directors of a bank could place the

bank in the hands of the Commissioner by posting a notice on the door.
If a bank which had been closed placed its affairs in legal and
proper condition, the Commissioner could authorize its reopening; otherwise,
Second Biennial Report of the Bank Commissioner, 1910, p. xii.

111

Fourth Biennial Report of the Bank Commissioner, January 1,
1915, p.


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Federal Reserve Bank of St. Louis

— 20—

•

he took possession of the bank for liquidation.

Sale of the bank's assets,

and compounding of any bad or doubtful debts, were subject to approval of
the District Court or judge thereof.
Statutory limitations on bank operations.

The principal statu—

tory limitations on banking operations, under the 190S law and the amend—
ments adopted while deposit guaranty was in force, are summarized below.
Responsibility of officers, directors
and stockholders:

411

Losses resulting from loans made in
violation of legal limitations

Any person participating in any
violation of the banking laws
liable for damages sustained
by stockholders, depositors,
or creditors

Liability of stockholders

Additionally liable for amount
of stock owned, and no more

Bonding of active officers and
employees

Board of Directors to require
good and sufficient bond of
the cashier and all officers
having care of funds

Meetings of directors

At least two each year

Examinations by directors

Thorough examination twice a year
of the books, records, funds
and securities held by the bank,
to be recorded in detail upon
its record book and copy for—
warded to Bank Commissioner
and each stockholder

Limitations on loans and investments:

•

Loans to officers and employees

Loan to any active managing offi—
cer, directly or indirectly,
prohibited

Loans to directors and stockholders

Total loans to stockholders not over
50 percent of paid—up capital

Loans to stockholders' or officers'
interests

No provision except prohibition
of indirect loans to active
managing officers


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Federal Reserve Bank of St. Louis

- 21 -

Limitations on loans and investments (continued):
Maximum to single borrower

20 percent of paid-up capital stock

Maximum secured by real estate

20 percent of aggregate loans

Limitations on ownership of Property:
Maximum value of banking house
and fixtures

One-third of paid-up capital

Time limit on real estate acquired
by collection of debt

Five years

Ownership of other real estate

Prohibited

Ownership of corporate stock

Prohibited, unless acquired through
collection of debt, except Federal
Reserve bank stock after 1921

Limitations relating to deposits:
Maximum amount of deposits

Ten times capital and surplus,
deducting deposits of other banks
(proportion fixed by Bank Commissioner prior to 1909)

Maximum rate of interest on deposits

To be fixed by Bank Commissioner

Receipt of deposits when insolvent

Prohibited

Limitations on borrowings:
Maximum

50 percent of paid-up capital (no
limitation after 1921 on borrowings from Federal Reserve bank
by a member bank)

Power of Bank Commissioner

May require reduction if bank is
borrowing habitually to re-loan

Maximum value of assets which may
be pledged for borrowings

No provision

Limitations on payment of dividends:
Percentage of earnings to be
carried to surplus prior to
dividends

One-tenth of net profits until
surplus reaches 50 percent of
capital stock

When losses exceed or equal
undivided profits

Prohibited


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Federal Reserve Bank of St. Louis

- 22-

•

Limitations on payment of dividends (continued):
When reserve is impaired

Prohibited

When capital or surplus is
impaired

Prohibited if any losses in excess
of undivided profits have been
charged to surplus and not
restored

If bank is in danger of insolvency

No provision

Required available funds, i.e., reserves:

•

Total amount of required reservell

Banks located in places under 2,500
population, 20 percent of deposits;
in places over 2,500 population,
25 percent - reduced in 1915 to
15 and 20 percent, respectively.
Federal Reserve member banks,
after 1921, permitted to substitute requirements for such banks

Proportion of reserve required to
be held in actual cash

One-third

Permissible character of remainder
of reserve

Balances due from good solvent banks

Required fully-paid capital stock:Ei
In places with
500 inhabitants or less
500 to 1,500 inhabitants
"
1,500 to 6,000
Il
6,000 to 20,000
More than 20,000 "

$10,000
15,000
25,000
50,000
100,000

Required reports:
Resources and liabilities

At least four each year, oftener if
called for by Bank Commissioner

Earnings and dividends

Annual statementX of receipts and
disbursements; each dividend declared
and amount carried to surplus and
undivided profits accounts

Average daily deposits during
previous year
1/ These reserve requirements applicable to banks and to trust
companies engaged in banking, but not to savings associations not transacting a general banking business. Reserves of savings associations: actual
cash equal to 10 percent of deposits; bonds of the United States or State
of Oklahoma, or subdivisions thereof, worth not less than par, 10 percent
Deposits

•

of deposits.
After 1909.
$25,000.


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Federal Reserve Bank of St. Louis

Requirements in 1908 ranged from $10,000 to

-23-

NUMBER AND DEPOSITS OF GUARANTEED BANKS

Number of participating banks.

The number of banks operating

in Oklahoma which participated, and the number which were not eligible to
participate, in the deposit guaranty system each year, are given in Table 1.
The participating banks include all State banks and, during the years
1908-1911, trust companies.

The non-participating banks include national

banks and, after September 1911, trust companies operating under State law.
During the first two years of deposit guaranty the proportion
of banks in the State operating under the guaranty system rose rapidly,
due primarily to the conversion of national banks to State banks.

After

the third year the proportion operating under the guaranty system declined,

•

primarily as the result of conversions of State to national banks.
Deposits of participating and non-participating banks.

The

deposits of the participating banks and non-participating banks, for each
year, are given in Table 2.

During the first two years of deposit guar-

anty the proportion of all bank deposits in the State which was held by
the participating banks rose rapidly.

After 1911, however, the proportion

held by banks in the guaranty system declined.
The deposits of participating banks given in Table 2 should not
be considered identical with the deposits specifically covered by guaranty.
Public funds otherwise guaranteed, and certified and cashier's checks,
items which were excluded from guaranty, are included in the figures
given here.

•

Concentration of bank deposits.

Table 3 shows the amounts of

deposits held on November 10, 1910, and December 29, 1920, by State banks


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Federal Reserve Bank of St. Louis

- 24 -

Table 1. NUMBER OF OPERATING BANKS IN OKLAHOMA PARTICIPATING AND
NOT PARTICIPATING IN THE DEPOSIT GUARANTY SYSTEM, 1908-1923, BY YEARS

Call date
nearest
January 1.1./

All banks
operating
in Oklahoma

1908
1909
1911
1912

777
834
887
924
914

1913
1914

1915
1916
1917
1918
1919
1920
1921
1922
1923

1910

Participating
in deposit
guaranty.)

Not participating in depo9it
guarantyii

Percentage of
total number
participating

468

309

60

546

288

65

668
695

219
229

75
75

923
913

631
615
582

283
308
331

69
67

913
903
885
901
936
944
977
938
910

563
557
547
566
581
599
622
556
463

350
346
338
335
355
345
355
382

447

64
62
62
62
63
62
63
64
59
51

1/ Call dates for State and national banks are not identical
in several years.
.?./ Includes all banks and trust companies operating under
State law, except 2 trust companies in 1912, 2 in 1913, and 1 in 1914.
After 1911 trust companies were excluded from deposit guaranty, but none
is reported in operation after 1914. Figures for 1908-1921 from annual
reports of the Bank Commissioner; figures for 1922 and 1923 from Federal
Reserve Bulletin, November 1937, p. 1117. No reports of the Bank
Commissioner have been published since 1920.
3/ Includes national banks operating in Oklahoma, and also 2
trust companies in 1912, 2 in 1913, and 1 in 1914, operating under State
law but excluded from deposit guaranty.

•

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Federal Reserve Bank of St. Louis

10

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•
Table 2. DEPOSITS OF OPERATING BANKS IN OKLAHOMA PARTICIPATING
AND NOT PARTICIPATING IN THE DEPOSIT GUARANTY SYSTEM,
1908-1923, BY YEARS
(In thousands of dollars)

Call date
nearest
January

1908
1909
1910
1911
1912
1913
1914
1915
1916
1917
1918
1919
1920
1921
1922
1923

All banks
operating
in Oklahoma

61,797
75,238
105,815
121,012
106,698
122,802
135,233
129,301
158,153
265,349

381,935
338,998
513,071
434,364
359,691
392,990

Banks
participating
in deposit
guaranty?'

18,182
31,617
54,769

61,309
44,004
45,878
46,131
44,773
148,1460
84,799
137,392
120,660
190,900
160,673
112,579
75,027

Banks not
participating
in deposit
guaranty3'

43,615
43,621
51,o46
59,703
62,694
76,924
89,102
84,528
109,693
180,550
244,543
218,338
322,171
273,691
247,112
317,963

Percentage of
deposits in all
banks held by
participating
banks
29
42
52
51

)41
37
34

35
31
32
36

36
37
37
31
19

2/ Call dates for State and national banks are not identical in
several years.
.2/ Deposits of all State banks and trust companies, with deposits
of trust companies deducted. Deposits of trust companies are as follows:
1912, $600,000 (est.); 1913, $701,000; 1914, $500,000 (est.). Figures for
1908-1921 from annual reports of the Bank Commissioner; figures for 1922
and 1923 estimated by averaging the deposits for the preceding and succeeding June 30, as given in the annual reports of the Comptroller of the
Currency. No reports of the Bank Commissioner have been published since
1920.
The amounts of deposits given here exceed the amounts of deposits
specifically protected by the depositors' guaranty fund, since public funds
otherwise secured, certified and cashier's checks, and other items which
were excluded from guaranty, are included in total deposits.

411

I/ Deposits of national banks plus the deposits of trust
companies given in footnote 2.


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Federal Reserve Bank of St. Louis

-26-

Table 3.

NUMBER AND DEPOSITS OF STATE BANKS IN OKLAHOMA,
NOVEMBER 10, 1910, AND DECEMBER 29, 1920
Banks grouped by amount of deposits

Number
of banks

All State Ipqnks, November 10,
1910:Li
Banks with deposits of $100,000 or less
$100,000 to $250,000
$250,000 to $500,000
$500,000 to $1,000,000
$1,000,000 to $2,000,000

S

Banks with deposits of $100,000 or less
$100,000 to $250,000
$250,000 to $500,000
$500,000 to $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $5,000,000
Largest bank
Largest 5 banks
Largest 10 banks

•

Percentage
of number
of banks

Percentage
of aggregate
deposits

61,612

100.0

100.0

26,590
19,150
11,178

75.0

43.2

19.2
4.9

31.1
18.1

5

3,362

0.7

5.5

1

1,332

0.1

2.2

520
133
34

2.2

1,332
4,157
6,513

Largest bank
Largest 5 banks
Largest 10 banks
All State O
- nks, December 29,
1920-4J

Amount of
deposits
(thousands
of dollars

6.7
10.6

621

158,960

100.0

100.0

174
268
119

12,053
43,671
40,437

28.0
43.2
19.2

27.5
25.4

41
14
5

27,512
19,833
15,454

6.6

17.3

4,222
15,454
24,507

7.6

12.5

3.1

9.7

)

)22.2

2.7
9.7
15.4

lj Tabulated from statements relating to individual banks, as
given in the reports of the Bank Commissioner. Totals differ slightly from
the figures given in summary tables for the same dates in the Commissioner's
reports, the latter figures being as follows: November 19, 1910, 694 banks
with deposits of $61,442,000; December 29, 1920, 622 banks with deposits of
$160,673,000.


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Federal Reserve Bank of St. Louis

—27—

•

in Oklahoma grouped according to their deposits.1/

In 1910, 11 percent of

the deposits, and in 1920, 15 percent, were concentrated in the ten
largest banks.

The largest bank in 1910 held 2.2 percent, while the

largest bank in 1920 held 2.7 percent, of the deposits of all State banks.
The figures for 1910 do not show as great a concentration of
the risk falling =on the guaranty fund as actually existed during the
early years of the guaranty system.

The largest bank in the State, with

deposits of $2,742,000, had failed in September 1909.
failure, this bank held approximately

5

At the time of its

percent of the deposits of all

banks covered by the guaranty system.

BANK FAILURES

Number and deposits of failed banks.

During the 15 years of

the guaranty system in Oklahoma, 130 participating banks closed because
of financial difficulties.

The aggregate deposits of these banks at time

of suspension amounted to approximately

29,407,000.

Twelve of the banks

which closed were banks which had previously suspended and had reopened
or reorganized.
Nearly one—half of the closed banks were very small, having less
than $100,000 deposits each.

These banks held about one—tenth of the

deposits of all of the suspended banks.

Only four of the closed banks

had deposits of more than $1,000,000, but these four banks accounted for
over one—fourth of the deposits of all of the closed banks.

A distribution

of the closed banks and of their deposits according to the amount of
deposits held is given in Table

•

4.

1/ Similar figures by two—year intervals during this decade
are shown in Table 11, p. 53.


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Federal Reserve Bank of St. Louis

•

-28-

S

Table

NUMBER AND DEPOSITS OF STATE BANKS IN OKLAHOMA CLOSED
BECAUSE OF FINANCIAL DIFFICULTIES, FEBRUARY 14, 1908,
TO MARCH 31, 1923

4.

Banks grouped by amount of deposits at time of closing

Number of
banks

Deposits
(in thousands
of dollars)

130.

29,407

100.0

100.0

60
40

3,173
6,266

46.1
30.8

10.8
21.3

20

7,238

15.4

24.6

6

4,707

4.6

16.0

4

8,023

3.1

27.3

Total
Banks with deposits of $100,000 or less
$100,000 to $250,000
$250,000 to $500,000
$500,000 to $1,000,000
$1,000,000 to $3,000,000

Percentage of total
Deposits
Number

Failures occurred each year that the guaranty fund was in operation.

The average annual rate of failure, computed as the number of banks

which failed per 100 in operation at the beginning of the year, was 1.4.
The deposits of the suspended banks averaged $2.22 per year for each
$100 of deposits in operating banks.
The heaviest failure rates, with respect to the number of banks,
were in 1921, 1922, and early 1923.

A substantial part of these failures

occurred after the fund was exhausted in the autumn of 1921 and the
officials had ceased to pay off the depositors of closed banks.

In terms

of deposits, failures in 1921, which exhausted the fund, were relatively
less serious than those in 1909 and in 1913.

In fact, the fund was as

insolvent in 1909, after the failure of the largest bank in the State,
with deposits of $2,742,000, as it was when payments to depositors ceased
in 1921.


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Federal Reserve Bank of St. Louis

However, in 1909, the Banking Board was able to delay or adjust

-29—

•

payments to some of the large depositors who were closely associated with
the management of the bank and thus to tide the fund over the crisis.
Further, the 1909 crisis was succeeded by a period with failure rates
sufficiently low and assessment rates sufficiently high to permit the
fund to be recouped, while the failures in 1921 and 1922 resulted in
obligations so great that, with the reduced maximum. rate of assessment,
many years would be required to meet them.
The number of failures each year, together with the deposits
of the closed banks, and ratios to the number and deposits of operating
banks at the beginning of the year, are given in Table
Suspensions by size of bank.

In Table

6

5.

the size distribution

of closed State banks is compared with an average of the size distributions

•

of operating banks for dates for which such data are available.
During the period of the guaranty fund, that is, from February
14, 1908, to March 31, 1923, failures among State banks were positively
correlated with size of bank.

The smallest banks had the lowest, and the

largest banks the highest, failure rate.

Failures among banks with less

than $100,000 of deposits, for the entire 15-year period, were about
one-sixth of the average number of operating banks of this size, while
failures among banks with more than $1,000,000 deposits were four-fifths
of the average number of such banks in operation.

If failure rates are

computed for the period up to October 31, 1921, when payments to depositors
in closed banks ceased, the same relationship holds - the failure rate
for banks of more than $1,000,000 deposits being four times as high as
that for banks with deposits under $100,000.
1/ This relationship of failures to size of bank was also characteristic of national banks in Oklahoma during the same period. The
failure rate of national banks with more than 4a,000,on0 deposits was five
times as high as that for banks with deposits under $100,000.

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Federal Reserve Bank of St. Louis

-30-

•

Table 5. NUMBER AND DEPOSITS OF STATE BANKS IN OKLAHOMA CLOSED
BECAUSE OF FINANCIAL DIFFICULTIES, FEBRUARY 14, 1908, TO
MARCH 31, 1923, BY YEARS

Closed banks
Deposits
Number
(in thousands
of dollars)

Year

1908 (after
February 14)
1909
1910
1911
1912

•

Deposits in closed
Number
banks per $100 of
suspended
deposits in
per 100
active banks
active banks

.2
•5

$0.20
9.09
1.08
1.70
1.39

1
3
3
8
4

37
2,873
591
1,040
611

1913
1914
1915
1916
1917

16
5
5
1
2

2,002
431
311
40
85

2.6
•9
.9
.2
.4

4.36
.93
.69
.08
.10

1918
1919
1920
1921
1922

3
5
8
251/
31

1,199
902
3,567. ,
5,979!/
8,219

.5
.9
1.3
4.o
5.6

.87
•75
1.87
3.72
7.30

1923 (to March 31)

10

1,520

56
19

10,122
5.927
13,358

6.8?/

1.37?"
1.82?]
8.31V

29,407,

1.5?./

2.41?/

1.2
.6

8.10.?./

Sub-totals for
selected periods:
1908-1919
Jan.1920-Oct.1921
Nov.1921-March 1923
Total

55
130

.8.g/
1.7_?,/

1/ Of these banks, 11 with deposits of $2,360,000, closed prior
to the time payments to depositors ceased because of insolvency of the
fund.
Annual rate.

•

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Federal Reserve Bank of St. Louis

-31-

•

Table 6. SIZE DISTRIBUTION OF FAILED BANKS IN OKLAHOMA COMPARED
WITH AVERAGE SIZE DISTRIBUTION OF OPERATING STATE BANKS:
PERIOD OF OPERATION OF DEPOSIT GUARANTY SYSTEM

Average
number of
operating
banks /
Total
Banks with deposits of —
$100,000 or less
$100,000 to $250,000
$250,000 to $500,000
$500,000 to $1,000,000
$1,000,000 to $3,000,000

Percentage of total number
Operat— Failed Failed banks
per 100
banks
ing
active banks
banks

592

130

100.0

100.0

22

359
166
48

60
40

60.7
27.9

46.1
30.8

17
24

20

8.1

15.14

42

14

6
14

2.4
.9

4.6
3.1

43
SO

5

Average
deposits of
operating
banks
(thousands
of dollars)li

•

Number of
failed
banks.g./

Deposits of
Percentage of
failed banks total deposits
Operat— Failed
(thousands
of dollars)?] ing
banks
banks

Deposits in
failed banks
per $100
deposits in
operating
banks

78,157

29,407

100.0

100.0

Banks with deposits of —
18,056
$100,000 or less
$100,000 to $250,000 25,174
15,911
$250,000 to $500,000

3,173
6,266
7,238

23.1
32.2
20.4

10.8
21.3
24.6

18
25
45

9,540

4,707

12.2

lb.0

49

9,476

8,023

12.1

27.3

85

Total

$500,000 to $1,000,000
$1,000,000 to
$3,000,000

lj Averages of number operating on dates for which data regarding
individual banks are available in the reports of the Bank Commissioner, as
follows: September 23, 1908; November 10, 1910; November 26, 1912; December
S, 1914; November 17, 1916; November 17, 1918; and December 29, 1920.
2./ Banks closed because of financial difficulties during period
of operation of guaranty fund, February 14, 1908, to March 31, 1923.

•

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Federal Reserve Bank of St. Louis

—32—

•

Comparison with suspensions in other States.

The number of bank

failures during the years, 190S-1922, relative to active banks, was
nearly twice as large in Oklahoma as in the United States as a whole, or
as in the six States contiguous to Oklahoma combined.

However, in one

of the contiguous States (New Mexico), the relative number of State bank
susnensions was higher, and in two other contiguous States (Colorado and
Arkansas), the rate was nearly as high as in Oklahoma.

In terms of

deposits the Oklahoma rate for State banks was apparently higher than in
any of the contiguous States, though not far above that in New Mexico.11
A comparison of the Oklahoma rates with those for contiguous States and
the United States is given in Table 7.
In two of the contiguous States, Kansas and Texas, deposit

•

guaranty systems were operative during most of the period embraced by
these figures.

The failure rates for both of these States were far below

those for Oklahoma.
These figures suggest that the existence of de--)osit guaranty
in Oklahoma was not a significant causative factor in the high rate of
bank suspensions, as has been claimed by opponents of the principle of
deposit insurance.

The high rate of failures in the State appears more

probably due to causes which operated also in New Mexico and Colorado,
and to a lesser extent in Arkansas and Texas, but were of much less
consequence in Kansas and Missouri.
Causes of bank failures.

Numerous circumstances contribute to

the financial difficulties which result in bank failures.

•

However, in

1/ Information regarding failures of State banks in New Mexico
is not available for four years of the period, so that the rate for that
State may have been higher than the rate for Oklahoma.


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Federal Reserve Bank of St. Louis

~33 -

•
Table 7. BANK FAILURE RATLS IN OKLAHOAA, 1908-1922, COMPARED
WITH RATES IN CONTIGUOUS STATES AND IN THE UNITED STATES1/

Failures per 100 operating
banks
State National
State and
banks
banks
national
banks
Oklahoma
Six contiguous States
Kansas
Missouri
Arkansas
Texas
New Mexico
Colorado
Entire United States

Deposits in failed banks
per 4;100 in operating banks
National
State and State
banks
banks
national
banks

14.6

20.4

4.0

$15.36

4,34.80

$4.26

7.3

g.4

3.5

3.81

6.73

1.42

4.6
3.4
15.7

2.6
..
3.3
3.8

3.34
1.33
9.19
6.48

6.19
2.49

.83

12.2

11.92

10.96
17.56
27.78

6.14

30.9

5.4
3.7
17.0
11.4
45.3

2.23
4.24

13.9

19.7

5.0

3.30

6.41

2.07

2.9

2.72

4.11

1.04

8.2

8.7

9.t.g.

•
Tabulated from data from the following sources: reports of
bank commissioners in the various States; Willis, Banking Inquia of 1925;
annual reports of the Comptroller of the Currency; Federal Reserve Bulletin,
September 1937.

•

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Federal Reserve Bank of St. Louis

dr

-34most cases the factors responsible for failure are predominantly associated
with one of the following groups:

(a) dishonesty on the part of officers

or employees; (b) excessive loans directly or indirectly to certain business interests, often to the interests of an influential official or
stockholder; (c) adverse economic conditions in a dominant industry and
collapse of property values associated therewith; and (d) general managerial
incompetence.
For 35 failures which occurred during the years 1909 to 1918,
the Biennial Reports of the Ban)c. Commissioner of Oklahoma contain brief
comments regarding the cause of failure, the character of the bank's management, or other aspects of the bank's operations.

In about one-half of

these cases sufficient information is given to indicate the major factor

•

responsible for the failure.

In twelve cases defalcation by officers or

employees is mentioned, and was assigned primary responsibility for the
failure in the majority of these cases.

In four cases excessive loans to

certain interests were noted, and in four cases failure was ascribed to
bad or incompetent management.

In only two cases was any mention made of

business depression or of adverse economic circumstances.
The operation of the deposit guaranty law in Oklahoma during the
first 12 years of its history, from 1903 to early 1920, has been carefully
studied by Mr. T. Bruce Robb)'

During that period, 56 failures in the

State occurred of which a number are selected as typical.

Of the 18 cases

for which Mr. Robb cites specific causes of failure, or for which he gives
sufficient information to warrant classification, six were attributed

•

1/ Robb, The Guaranty of Bank Deposits, pp. 42773. In this book
Mr. Robb states that 57 failures had occurred, but only 5b are mentioned
in the reports of the Bank Commissioner for the period.


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Federal Reserve Bank of St. Louis

- 3- 5 -

•

chiefly to fraud or defalcation on the part of bank officers, and 12 to
speculative and excessive loans to interests associated with the bank
managements.
The Comptroller of the Currency, in his report for 1921, summar—
ized the experience of States with deposit guaranty plans in operation.
His statement regarding the causes of bank failures in Oklahoma is as
follows:
The closing of 42 of the 95 banks was due to a decline in
the value of the assets, poor management, and slow loans, inability
to realize on loans, injudicious investments, and shrinkage in
deposits. In 34 cases closing was due to criminal acts on the
part of officers, including embezzlement, misapplications, or use
of the banks' funds in speculation for privEqe gain. In 19 cases
the cause of closing is not on record here.D
The failures described in the Bank Commissioner's reports, and

•

those reviewed by Mr. Robb, took place prior to the collapse in prices of
farm products and the business depression in 1921.

The failures in 1921

and in 1922 were more directly associated with adverse economic circumstances than were those in the preceding years, though such evidence as is
available indicates that incompetent management and speculative loans also
played a part in these failures.

There is no evidence that the number of

failures during this period was affected by the insolvency of the guar—
anty fund.

High failure rates in 1921 and 1922, in comparison with those

during the previous decade, occurred not only among the State banks in
Oklahoma, but also among national banks in the State, and among both
State and national banks in most of the contiguous States.
Annual Report of the Comptroller of the Currency, 1921,
p. 1Sg.


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Federal Reserve Bank of St. Louis

I

— 36 —

•

FINANCIAL HISTORY OF THE GUARANTY FUND

Sources and adequacy of information.

Information regarding the

operation of the Oklahoma Depositors' Guaranty Fund is decidedly inadequate.
No statements of the fund were published in the reports of the Bank Com—
missioner, except for the last three months of each of the years 1914,
1916, and 191S.

A partial statement for the entire period appears in a
•

report made to the Oklahoma House of Representatives in February 1923.1/
Some additional information is available in surveys of deposit guaranty
plans made by students and agencies outside the State,?' and in the decisicn
of the Oklahoma Supreme Court regarding final disposition of the fund and
newspaper comments thereon.
For the period, 1908-1919, the receipts from assessments were

•

sufficient to cover losses and expenses by a small margin, though the fund
Incurred a heavy indebtedness during the first half of this period.
Information regarding the cost to the guaranty fund of most of the bank
failures during this period is given in the Biennial Reports of the Bank
Commissioner, except for those occurring during the years

1916

and 1919.

Additional information regarding some of these failures, and also some
information regarding the receipts of the fund and its status early in
1920, are given by Robb in his book puulished in 1921.
During the period from January 1, 1920, to October 31, 1921,
depositors in failed banks were paid by the Depositors' Guaranty Fund for
1/

•

House Journal, February 21, 1923, pp.

773-75.

?./ These include Robb, The Guaranty of Bank Deposits (Houghton
Mifflin Company, 1921); Thornton Cooke, articles in the igliarterly Journal
of Economics, November 1913 and November 1923; Federal Reserve Board, in
Federal Reserve Bulletin, September 1925; Blocker, The Guaranty of Bank
Deposits (The School of Business, University of Kansas, 1929).


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Federal Reserve Bank of St. Louis

-37-

•

the most part with money borrowed through the sale of Depositors' Guaranty
Fund Warrants for cash.

For this period no information is given in

reports of the Bank Commissioner regarding bank failures, or the operations
of the guaranty fund, except the names of banks taken over by the Commis—
sioner during the year 1920.

Some information regarding the amount of

warrants issued is given by Thornton Cooke in an article in the quarterly
Journal of Economics, November 1923; and the amounts paid out by the guar—
anty fund for banks which failed between January 1 and October 31, 1921,
are given in schedules submitted in 1931 to the Federal Reserve Committee
on Branch, Group, and Chain Banking-1i
For the period from November 1, 1921, after which warrants were
no longer issued and the fund became inoperative, to March 31, 1923, the

•

only information available is that given in the schedules submitted to the
Federal Reserve Committee on Branch, Group, and Chain Banking.
Income and expenses of the guaranty fund.

An estimate of the

income and expenses of the Oklahoma Depositors' Guaranty Fund during its
entire existence is given in Table 8.

The figures take into account

receipts and disbursements subsequent to repeal of the law, including the
final disposition of the fund in 1934.

The estimates in this table

exclude borrowings of the fund which were eventually repaid, and also pay—
ments to depositors in failed banks which were made directly from the cash
and quickly liquidated assets of those bunks.
The information available indicates that the total receipts of
the guaranty fund throughout the entire period of its operation, excluding

•

lj The schedules were prepared from the records in the Bank
Commissioner's office.


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Federal Reserve Bank of St. Louis

-3g ESTImATED TOTAL INCOME AND EXPENSES OF THE OKLAHOMA
DEPOSITORS' GUARANTY FUND

Table S.

Amount
(thousands
of dollars)
Income and net unpaid borrowings
Assessments collectedli
Liquidation of assets of failed banks?../
Final default (net amount of warrants issued and
not redeemed)1/
Total income

3,730
2,330
1,070
7,130

Expenses
4
Payments to depositors in suspended banke/-i
Interest on indebtednessJ
Administrative expenses
Total expenses

6,555
225
350
7,130

•
NOTE: This is not an accurate statement of the income and expenses of
the Oklahoma depositors' guaranty fund. It is an estimate prepared from
available data, and shows only the approximate magnitudes of the various
items.
Federal Reserve Bulletin, September 1925, to. 631.
gj To 1923, amounting to $2,195,000, Federal Reserve Bulletin,
op. cit., plus an allowance of $135,000 for subsequent recoveries (estimated from difference between cash on hand as given in Federal Reserve
Bulletin, op. cit., and cash on hand at time of final disposition of the
fund in 1934).
3./ Estimated from warrants unpaid at time of final disposition
of fund ($1,200,000) and estimated amount of final cash payment to holders
of those warrants ($130,000), as reported in The American Banker,
October 23, 1934.
Li] Estimate derived indirectly from the remaining figures.
. cit., states that about $6,000,000 was
The Federal Reserve Bulletin, .91.
paid to depositors by the guaranty fund.

•

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Federal Reserve Bank of St. Louis

- 39 Table S.

ESTIMATED TOTAL INC01..E AND EXPENSES OF THE OKLAHOMA
DEPOSITORS' GUARANTY FUND (continued)

5/ Based on rate of 6 percent and amount of warrants outstand—
ing at the end of the years 1914, 1916, and 1918, as given in the
Biennial Reports of the Bank Commissioner, and amounts outstanding at
the end of other years, prior to 1921, estimated from assessments levied
and deposits paid by the guaranty fund. No interest was paid on warrants
issued in 1921, according to the Federal Reserve Bulletin, September
1925, p. 631.
J Warrants issued up to January 31, 1923, for salaries,
expense of examiners, office supplies, bank robbers and miscellaneous,
amounted to $252,261, House Journal, February 21, 1923. The remainder
is an allowance for expenses subsequent to January 31, 1923, based
largely on the difference between the reported cash on hand, and of
final payment to warrant holders, at time of final disposition of the
fund in 1934 (The American Banker, October 23, 193)4).


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Federal Reserve Bank of St. Louis

•

all borrowings, amounted, approximately, to

$6 million. Three—fifths of

der from the liquida—
these receipts were from assessments, and the remain
above, assets immedi—
tion of assets of failed banks (excluding, as noted
ately liquidated).

The fund paid out about

$6.6 million to depositors,

directly from assets
in addition to amounts made available to del)ositors
in administrative
of failed banks, and spent approximately $0.6 million
expenses and interest.

Of the amount paid to depositors, about $1.0

was
million was obtained from that portion of the warrants sold which
defaulted and never paid by the guaranty fund.
Annual assessments and losses in failed banks.

The annual rates

es of losses from
of assessment, amounts of assessment levied, and estimat
bank failures, are given in Table

•

9.

The annual rates of assessment raaged from one—fifth of 1 percent
fth percent
of deposits, in 1916 and subsequent years, to one and one—fi
In 1911.

The amounts of assessments levied or due ranged from $90,000

in 1916 to $601,000 in 1911.
The total loss to the guaranty fund incurred in banks whose
tors were
depositors were paid by the fund (including ban's whose deposi
the loss
paid from proceeds of warrants which were defaulted)--that is,
in the autumn of
in all banks closed before payments to depositors ceased
1921--amounted approximately to $4.2 million.

This compares with assess—

.
ments which had been levied amounting approximately to $3.$ million
Losses suffered by depositors in banks which failed during the
ceased and
17 months which elapsed between the time payments to depositors

•

the date of repeal of the law amounted tc more than qi6 million, or


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Federal Reserve Bank of St. Louis

Table 9. RATES AND AMOUNTS OF ASSESSMENT, ADD ESTIMATED LOSSES
FROM BANK FAILURES, OKLAHOMA DEPOSITORS' GUARANTY FUND, BY YEARS

•

(Amounts of assessments, losses, and deposits in
thousands of dollars)
Rate of
assessment
(percent of,
deposits)±.1

Year

190g
1.00
1909
•95
1910
.20
1911
1.20
1912
.95
1913
.4o
1914
.4o
1915
.4o
1916
.20
1917
.20
191g
.20
1919
.20
1908-1919, un—
allotted by years ..
I.
.20
1921 (Jan.—Oct.)
.20
1921 (Nov.—Dec.)
1922
.20
1923 (to March 31) .20

•

Total

60

Amount of
assessment
levieq,
or duze-/
199
327
287
601
511
202
148
162
90
133
209
232

Losses in failed banks
Borne by
Paid by
guarant4., depositorsV
fund -V

37
644
232

11

2,002
431
311
••

34

1,605
1,279

4o
85
1,199
902

253
Se

456

3,567
2,36o
3,619
8,219
1,52°

6,555

6,24g

29 407

— 2,330

•.

4,225

6 24g

••

4 227

1,o4o
611

• •

278

is4

2,873
591

6o4
115
661
2o3
75

839
302
362

Deposits
in failed
banks

••

••

• •

1,561
4,231

Adjustments:
For uncollected
assessments
For recoveries
from •
assets
acquired from
failed banks
Net total

•

3,730

29,4o7

Includes regular and special assessments, but excludes bonds or
cash deposited as security for payment of aEsessments. These rates were
applied to average daily deposits during the preceding year, except in the
case of the initial assessment, which was applied to dePosits as of December
11, 1907. Rates for 190g-1920 from Robb, The Guaranty of Bank Deposits,page
73. Rates for 1921-1923, according to provisions of law, since information
is not available regarding assessments actually levied.


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Federal Reserve Bank of St. Louis

-42-

•

Table 9. RATES AND AMOUNTS OF ASSESSMENT, AND ESTIMATED LOSSES FROM
BANK FAILURES, OKLAHOMA DEPOSITORS' GUARANTY FUND, BY YEARS (cont.)

Ei Includes regular and special assessments levied or due in
accordance with the rates in the preceding column, and also additional
collections resulting from increases in deposits in certain banks and from
new banks opening. Figures for 1908-1920 from Robb, a. cit.; for 19211923, estimated from average deposits for available dates during preceding
year. Total assessments collected from Federal Reserve Bulletin, September
1925, page 631. The adjustment for uncollected assessments is the difference between the total amount levied or due and the total amount
collected.

•

3./ Figures for 1909-1915, and 1917-1918 are taken from informa.2. cit., or in the biennial
tion regarding individual banks given in Robb, 9
represent the net cost to
figures
These
the
Bank
Commissioner.
reports of
from each bank had
acquired
assets
the
of
most
Fund
after
the Guaranty
at the same average
estimated
1919
and
1916
been liquidated. Figures for
and 1917-1918.
1909-1915
for
those
as
percent)
of
(28
deposits
percentage
indirectly
is
derived
years,
by
unallocated
1908-1919,
figure
for
The
fund which
the
by
guaranty
paid
deposits
the
of
represents
portions
and
banks
prior to
the
of
failed
assets
the
of
liquidation
from
recovered
were
the
fund
in
is
given
guaranty
the
to
cost
for
dates
net
which
the
the
taken
are
(to
31)
1921
October
for
Figures
reports.
Bank Commissioner's
Reserve
Federal
the
to
submitted
bank
suspended
from schedules for each
Committee on Branch, Group, and Chain Banking, supplemented by information regarding one bank given in Cooke's article in the Quarterly Journal
of Economics, November 1923, p. 112. Figures for 1920 estimated at 45
percent of deposits, slightly lower than the figure (50 percent) for 1921.
Substantially the same total for the period from January 1, 1920, to
October 31, 1921, may be obtained by adding to the figure for warrants
issued in thirteen banks as given by Mr. Cooke ($2,196,000), one-half of
the deposits of five banks which failed in 1920, for which no unpaid warrants appear to have been outstanding in October 1921.
For total see footnote 4, Table 8, and for recoveries from
from failed banks see footnote 2, Table 8.
acquired
assets
Estimated from payments on claims in the case of banks
fully liquidated, and payments to 1931 in the case of those still in
process of liquidation at that time, as reported on schedules submitted
to the Federal Reserve Committee on Branch, Group, and Chain Banking.
5./

•

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Federal Reserve Bank of St. Louis

See Table

5.

-43-

•

substantially more than the losses to the fund during the preceding 12
years.
Adequacy of the guaranty fund.

The extent to which the Oklahoma

Depositors' Guaranty Fund met the claims of depositors in failed banks is
shown in Table 10.

For the entire period during which the law was on the

statute books, about

64

percent of the deposits of failed banks were

eventually paid from the proceeds of liquidation of the assets of those
Guaranty fund assessments provided payments equivalent to 11

banks.

percent of the deposits, while the remaining 25 percent were lost to the
depositors or to holders of guaranty fund warrants.

The assessments

collected during the entire period thus amounted to less than one-third
of the amount which would have been necessary to have met all losses in
failed banks up to the time the law was repealed.
The estimate of eventual losses from bank failures during the
period in which the guaranty law was on the statute books in Oklahoma,
given in Table 9, indicates that aggregate assessments of approximately
$11,000,000 would have been sufficient to have met those losses and the
administrative expenses of the fund.

An average annual assessment during

the fifteen years of nine-tenths of 1 percent would have provided this
sum.

The average actually collected amounted to three-tenths of 1 per-

cent, or approximately one-third of the required amount.
Reference to Table 9 shows that the rate of assessment during
the first eight years of the period, excel)t for one year in which only
the regular assessment of one-fifth of 1 percent was levied, ranged from
four-tenths of 1 percent to one and one-fifth percent.

411

The assessments

collected during those eight years amounted to seven-tenths of 1 percent


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Federal Reserve Bank of St. Louis

44

•

Table 10. DEPOSITS IN FAILED BANKS IN OKLAHOMA DURING THE PERIOD
OF OPERATION OF THE DEPOSIT GUARANTY LAW, PAID AND UNPAID,
WITH SOURCES OF FUNDS USED IN PAYMENT
(In millions of dollars)

75
Total

Total deposits

banks
closed
Feb. 1908—
Oct. 19211/

55

banks
closed
Nov. 1921—
Mar. 1923E/

29.4,

16.0

13.4

lg.9

11.g

7.1

3.1

3.1

1.1

1.1

Deposits paid from:
Liquidation of ap,9ets directly
and indirectly
Depositors' Guaranty Fund
assessmentslY
Borrowings never repaid
warrants not redeemed)
Losses to depositorsi

6.3

6.3

Percentage of total deposits
Realized from liquidation of
assets
Met by Depositors' Guaranty Fund
assessments
Losses to warrant holders
Losses to depositors

•

100

100

100

64

74

53

11
4

19

7

21

I.7

Banks the depositors of which were paid by the Depositors'
Guaranty Fund from the proceeds of assessments and of warrants sold.
.2/ Banks closed after issuance of warrants and payments to
depositors ceased, but prior to repeal of the deposit guaranty law.
3./ Of the total for the period February 190g — October 1921, it
is estimated that approximately $9.5 million was paid directly to deposi—
tors from the proceeds of the assets of the banks (i.e., from cash and
quickly liquidated assets), and approximately $2.3 million indirectly
through collections from assets taken over by the guaranty fund. The
entire amount for the 55 banks suspended in 1921-1923 was paid directly
from the proceeds of liquidation of the assets of the failed banks, such
proceeds for each bank being used to pay its own depositors.

•

V Assessments collected minus administrative expenses and
interest paid on indebtedness. See Table g.


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Federal Reserve Bank of St. Louis

Cl

51

See Table

%, and

footnote 4 to that table.

- 145-

•

per year of total deposits.

The assessments collected during the first

five years of the fund amounted to nine-tenths of 1 percent of total
denosits per year.
Had the guaranty law remained in its original form or as amended
in 1909, but without the amendments with respect to assessments which
were enacted in 1913, the State Banking Board would have been authorized
to levy assessments sufficient to have met all of the losses arising
from closed banks up to the date of repeal.

Further, the average rate

of assessment during the 15-year period would not have been higher than
the average rate during the first five years of the fund.
This does not mean that with an average rate of assessment of
nine-tenths of 1 percent, the fund would have been enabled to pay depositors promptly without borrowing, since borrowing would have been necessary
to advance to the depositors in some years the amounts which were later
collected from liquidation of the assets of the failed banks.
The period from February 1908, to iiiarch 31, 1923, during which
the law was on the statute books, included several years in which bank
failures were infrequent and losses light.

On the other hand, it covered

three periods in which serious and extensive waves of failure occurred:
1909, with the failure of the largest bank in the State; 1913, when several
good-sized banks closed; and 1921 and 1922, in which failures were widespread among all sizes of banks.
lj This statement does not take into account the possibility
that continuation of the rates of assessment prevalent during the early
years of the fund would have resulted in the conversion of a large number
of State banks into national banks.

•

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Federal Reserve Bank of St. Louis

- 46 -

The abnormally high failure record of large banks was an important influence in the rate of assessment which would have been necessary
to have met the burden falling upon the guaranty fund.

Approximately one-

fourth of the total loss on account of failed banks during the 15-year
period was incurred in the four banks with deposits of more than
$1,000,000 at time of failure; and one-fifth of the total loss in six
other banks with deposits of more than $500,000.
The failures of large banks were also responsible for the
periods of crisis in the operation of the guaranty fund.

The Columbia

Bank and Trust Company, of Oklahoma City, which failed in September
1909, when the guaranty law had been in operation less than two years, was
the largest bank in the State.
system.

This failure nearly wrecked the guaranty

The guaranty fund at that time amounted only to $300,000, of

which one-sixth was on deposit in the failed bank, while the deposit
liabilities of the bank amounted to nearly $3 million.

The fund was

kept in existence only by the determination of the officials to demonstrate the success of the law, and the adoption of emergency methods of
handling the situation.

Holders of accounts with small balances were paid

off in full with the aid of additional funds obtained from the owners of
the failed bank.

Nearly one-half of the deposits of the failed bank were

those of country banks throughout the State, and these banks were permitted
to select assets from the portfolio of the defunct bank to offset their
claims.

The remaining claimants were finally paid from the assessments

in future years.

•

Also, it was primarily the failure of the Bank of

Commerce, Okmulgee, with deposits of nearly $2 million, on November 1,


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Federal Reserve Bank of St. Louis

-47-

•

1921, which increased the outstanding obligations of the guaranty fund so
much that guaranty fund warrants could no longer be sold and the fund
became inoperative.
The burden of assessments.

To bankers in Oklahoma the assess-

ments levied during the first few years of the Depositors' Guaranty Fund
appeared to be heavier than could be borne by the banks.

They pointed to

the fact that the assessments amounted to what they deemed an extremely
high percentage of their capital and surplus, averaging during the first
six years of the fund approximately

3 percent per year of the total

capital and surplus of the banks, and taus presumably absorbing a very
large proportion of the profits available for dividends to stockholders.
Whether the assessments did in fact absorb a large proportion

•

of profits which would otherwise have been available for dividends is
unknown.

No figures of profits or dividends of State banks in Oklahoma

during the period are available.

Nor is information available regarding

the extent to which the limitation on the rate of interest paid on deposits,
imposed by the deposit guaranty law, reduced the expenses of operation
of the banks.
The problem of making adequate profits is not so much a problem
of the magnitude of expenditures which have to be borne by all banks as
a part of their cost of business, as it is of the margin between the
charges which they can make for their services and the aggregate expenses
which they must incur.

Since the rate of interest currently charged on

loans by the banks in Oklahoma was very high, judged by average rates in
eastern money centers or by average rates for the United States as a whole,

•

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Federal Reserve Bank of St. Louis

comparaand the rate of interest paid by the banks on deposits was also
among
tively high, and since the latter rates are determined by competition
particithe banks themselves, it should have been possible for the banks
by
pating in deposit guaranty to have maintained their profit position
reducing the rate of interest paid to depositors.
However, the presence of another group of banks in the State,
operating under national rather than under State law, provided a competitive situation which made it difficult for State banks as a group to make
these adjustments.

For two years prior to 1913, when the law was amended

in such a way that adequate assessments could no longer be levied, there
had been a substantial tendency for State banks to convert to national
banks.

•

The proportion of the total number of banks operating under State

law and therefore participating in the deposit guaranty system had declined
from

75

percent to 67 percent, and the proportion of aggregate deposits

in the participating banks from 51 percent to

37

percent of all banks in

the State.
There is good reason to believe that the guaranty system could
have been successful had it embraced all banks operating in the State.
ng
Further, if all banks in the State had been covered, without affecti
number
the quality of bank supervision or other factors determining the
of failures, the necessary assessment rate for the entire 15-year period
would have averaged less than four-tenths of 1 percent per year.
EFFECTIVENESS OF BANK SUPERVISION
The high rate of assessment which would have been necessary to
in
have prevented insolvency of the Oklahoma depositors' guaranty fund,


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Federal Reserve Bank of St. Louis

-49comparison with the rate necessary to have operated a similar fund on a
national scale during the same period of time, is a direct reflection of
the relatively high frequency rate of bank failures in the State.

This

abnormally high failure rate, as has been noted above, was due in substantial part to deliberate bank mismanagement - sheer dishonesty, participation in unduly speculative enterprises, and overextension of loans to
enterprises with which bank officials or favored customers were connected.
It is proper to ask whether the failure rate could have been markedly
reduced by a reasonably effective supervision over banking operations by
a department of the State government.
The powers of the Bank Commissioner, which have been outlined
above, ap7ear sufficient, had they been adequately used, to have checked

•

many of the malpractices of Oklahoma banks.

The two examinations required

to be made each year, if thoroughly conducted, would have disclosed, long
before failure, the conditions described in Robb's account of the affairs
of the chief banks which failed.

Use of the legal power of the Commissioner

to close banks for violation of the banking law by its officers, and more
vigorous use of the power to order the removal from office of bank officials
found to be dishonest, reckless or incompetent, would have prevented much
of the dissipation of bank assets.
The actual conduct of the Office of Bank Commissioner has not
been a part of the present study of the operation of the Depositors'
Guaranty Fund in Oklahoma.

Nor has an attempt been made to determine

whether bank examinations and the operation of the Commissioner's office
were hampered by paucity of funds.

•

However, such information as has been

found in the State reports regarding the staff and expenses of the
Commissioner's office is given below.


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Federal Reserve Bank of St. Louis

-50-

110

From 1913 to the repeal of the deposit guaranty law in 1923 the
salary of the Bank Commissioner was fixed by law at

$4,00o,

his 12 specifically authorized assistants at $2,000 each.

and those of

Of these

assistants, one was designated by law as Assistant Bank Commissioner, and
one as building and loan auditor.
bank examining force.1/

The remaining ten constituted the

Since the number of operating State banks was

about six hundred, and two examinations per year were required, each
examiner was apparently required to make about 120 bank examinations per
year.
The total cost of the Bank Commissioner's office appears to
have averaged about

$44,000

per year during the operation of the deposit

guaranty fund, made up of $2E5,000 in salaries prescribed by law and met
from the general revenue fund of the State, and about $16,000 in other
salaries, expenses of examiners, and administrative expenses met from the
examination fees levied upon the banks../
1/ The reports of the Bank Commissioner state that in 1912 the
Department had one special and eight regular examiners; in 1914 ten examiners.
2j The Federal Deposit Insurance Corporation in 1941 had two
examiners and two assistant examiners in Oklahoma to make one examination
per year of approximately 160 banks, or an average of 40 examinations per
year per member of the examining force. Comparison of the examining task
at present with that during the -period of operation of the guaranty fund
is not invalidated by differences in the size distribution of the banks
examined. From 1916 to the repeal of the guaranty law, the average proportion of banks in the size groups above $500,000 of deposits was nearly the
same as the proportion in those groups of banks examined in 1941 by the
Corporation.
I/ The figure of an annual average of $16,000 in expenses other
than the salaries paid from the general revenue fund of the State is estimated from warrants issued to January 31, 1923, for the following items:
salaries, $44,674; expense of examiners, $76,556; office supplies, $25,721;
and miscellaneous, $73,310. House Journal, February 21, 1923, p. 774.

•

No figures are available of the yield of the examination fees,
but an estimate for one year based on a distribution of State banks


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Federal Reserve Bank of St. Louis

—51—

or

The effectiveness of a State department of banking is limited
not only by the funds placed at its disposal, but also by the economic
and political climate.

Throughout American history business interests

have been an extremely powerful, if not dominating, element in political
affairs.

As a result, the persons appointed to State offices of a busi—

ness regulatory character have had, in general, the same point of view
and outlook and the same attitude toward business ethics as have prevailed
among business men.

Consequently the laxity of the examining force, in

its examinations and corrective actions, probably reflected primarily
the general attitude of the bankers and business men in Oklahoma.

A

politico—economic analysis of this period in the history of the State
would be necessary to reach an opinion on the question of whether the
Department of Banking could have exercised more effective supervision
than it actually did.
Nevertheless, one conclusion of vital importance to the success
of other systems of deposit guaranty or insurance can be drawn with
certainty.

That is, that dishonesty, favoritism to special interests,

and speculative activities on the part of the largest banks in the system
will lead to disaster, and that the supervisory authorities must be alert
and vigorous in watching the policies of the banks in which the risk is
concentrated.

according to capital stock and the scale of examination fees indicates
that collections probably averaged less than $20,000 per year.
For the biennium 1917-1919 a total of $127,000 was appropriated
for the Department of Banking (Sixth Biennial Report of the Bank Commis—
sioner). However, this included $30,000 for contingent expenses, which
may have been used only in part.


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Federal Reserve Bank of St. Louis

•

- 52 -

•

CLOSING OF THE GUARANTY FUND

Oklahoma was the first of eight States to create deposit insurance systems during the period 1908-1917.

It was also the first of the

eight States definitely to abandon the deposit guaranty plan.

In 1923

and warrants
all assessments and the provisions for issuing certificates
banks and
were repealed, effective March 31 of that year, though the
ed.
their officers were not released from obligations already incurr
The repeal of the law was followed by litigation regarding the
which delayed
distribution of the assets remaining in the Guaranty Fund,
settlement of the affairs of the fund until 1934.

In September of that

that the
year the State Supreme Court rendered a decision, which ordered
be paid in full
holders of the warrants lowest in numerical order should
to the extent of the remaining funds)'

lj Security Bank and Trust Co., of Miami, Oklahoma, et al., v.
11, 1934,
Barnett, et al., no. 24551, Supreme Court of Oklahoma, September
36 Pao.


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Federal Reserve Bank of St. Louis

874'.

•

•
Table 11.

NUMBER AND DEPCSITS OF STATE BANKS IN OKLAHOMA, 1908-1920
Banks grouped by amount of deposits

Number of banks - totall/
Banks with
$100,000
$100,000
$250,000

deposits of or less
to $250,000
to $500,000

$500,000 to $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $5,000,000

Nov. 17,
1916

Nov. 17,
1918

Dec. 29,
1920

550

582

621

20

170
293
76

17)4

102
20

250
231
54

6
••

3
1

11
14

31

Sept. 23,
1908

Nov. 10,
1910

Nov. 26,
1912

520

693

617

466
41

500
91

11

520
133
34

2

5

••

••

Dec. 8,
1914

436

400

1

268
119

9
3

41
14
5

(Deposits in thousands of dollars)
Deposits In banks with
$100,000 or
$100,000 to
$250,000 to

deposits of less
$250,000
$500,000

$500,000 to $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $5,000,000

26,587

61,612

47,775

44,589

83,983

123,594

158,960

16,136
5,535
3,647

26,590
19,150
11,178

24,063
13,095
6,446

19,987
14,444
6,670

15,627
34,620
17,661

11,937
45,705
25,334

12,053
43,671
40,437

3,362

4,171

2,307

7,734

1,181

6,120

20,824
11,549

19,833

2,621

8,2
45

15,454

1,269
••

1,332
e$

00

WO

••

27,512

1/ Tabulated from statements relating to individual banks, as given in the reports of the Bank
Commissioner. Totals differ slightly from the figures .q.iven in summary tables for the same dates in the
Commissioner's Reports.


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Federal Reserve Bank of St. Louis