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https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis cot. /q2.? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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). https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -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. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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: • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis S https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 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 $5,000,000 1,269 1,332 1/ Tabulated from statements relating to individual banks, as given in the reports of the Bank Commissioner. Totals differ slightly from the figures liven in summary tables for the same dates in the Commissioner'speports. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 44 • G 0 14 I' 0-77,2 S /43 //4/ -71-e%- / /` .21 0 ? t."4-1 (d-61- .• ra../ /70,7 7 S, -'170 r t, / ' _ " 7, It. /5 i r , -'• 73 -(4 ( / /03 • It 9 32'" /it,' va- / • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7 V /6? . 74(74, ,/;2 d / ' .;) „ /0/,‘,..0e SI 7 I 4), /A • ' i fr-f !Po - https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 0 /rz , 7.6 - 779'9_s: ' ;4, QAP/0/_5;;--p-zo /tz(eji "ipi,d, t//b c//// --//5)9d-9O le* s)///ig7 5 /1/I/ 440!:, 4 ( /1//- -1/4 /9°5 ' *Iiiitit/i)/ p s-z-J/pzi.gal sci r/ TY5 /V/ h"r1-77'/-5 -----7911-1/0 /to - 64 pc7/.±7 S - -- A, ,frq-to,„ ...,,,,,...k.,,,, .„. ., d:„.2_,_..e.../,. -.1jp•A 44 , e 1/ .41( 4 ' ‘-= -t https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis IL A e • , r-p.r.•• 4-17 • Year All banks in tate (RepQrts Comptro11„er - ;17 t,u-i-rcncy)1 , %liter TRtsl Total :(includ- • catal • deposits ac ing loan & trust companies https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis All 6e, Nutber Ics STATI7TICAL DATA REGARDING DFPOSIT GUARKTY FUND IN I. COVF,BAGEANSSESSMENTS Banks members of guaranty fund n State (state reports 7/ Tat* Gap ;14 ouat I Total I deposits g1,770 I(41,5711 5-47t1we 67q 61 3oh,3), (-,c? I/9 d7 6cf 633 • 10 17 , , Total , Insur ed deposit deposits 5g3 5-63 557 51/ I/o 05 44353 2/8#6o 511/7 PIMhitE( 5(.4 66,9,24 5 ,I 57-1 0.2s q036 5'3634 4391 4/6671 56,3 e9 77.1' 556 5' • 13739 )096 Total captdI . 51714, labg 44AS iiumber 1707 I bob7 441-11/0 IsAff 15-365? yv rig t, - i rtj, y•••.• Aesessments Rate of Amount of assessment assessmAnte percent of levied a$ses$me,ite deposit were based Deposits on 2/ mhioh •( ' y https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4tZzs acit-tv-Q. citA.)k- A ,.kAA.A.,,w, uz..130-4 f 2/ ,2F1 6 30 4 " t. 33 Sq-a.41-Co_.1;u4„414-(2-tciag TIAAAA4.42, L.0 a1.2,1 1-t94 6-0'3 if.:1,Q0 CO ( 6•Z5 63 („ZO 1)2(f 573 55 6,31 t05 3?3 573 557 6i3 142? 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City 3-10-13 g.--oklahoma State Bank Hugo 3-17-13 The State Bank of Bank of Ito ill Stilwell 4-25-1 71 et,CO J -pp caol '7'7'½'7 c-ru .---2c10-3 ,4 5,37;15 3.5- 67•94/i 57'/Z66 3•-5-343-%.!, 70 / 3i.6W.33 19.570-76,2 I 03c 4'6 p.-/3 33 1.//.) e7 73•01 /1) /76,26 76 7-3 •••••••••• ; /- Px7G y.so ;7 /f779‘,oi 35, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1,10,23 VI 36,0 '11 c, q 59 ,r/1/. 7,2; / ay e/554 34 / 4 1/6, 7a6,', 29 "7, 6/6,t i /6/,,3 ) f2.3 Tr I /33576,:27 56 7+i), 14) 53 : 2; 2/07 77690 '/00 fi g'()-5 7V s-y ,97c.3.3,.3/ 29 7y6", /C 55.6F 6 //6-'-- •36 3, • Aci4 , 4 I6 " , •67°-//4 70/C 112.4e-40 14.a. AA e". -5:0;20e 6 cA.) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis LI OKLAHOMA - tata from Sate Banking De artment records - page 3 (o bts iAed in December 1955) tr • Anadardo State Bank Aandarko bank of Lawton 7-14-13 v vi/a/#70)-11Farmers and First v/Merchants Bk State Bank Snypr Wainw right ,_- Union Alva Secur- Oklahoma ity Bank State Bank State Bank Alva , Ok 1 a. City Muskogee 8-11-13 9-13-13 8-9-13 vBank of ForgIcgr _ le/-15LO"' Peoples 13ank Bank of & Trust Co Spencer .',usk ogee 12-16-13 v 1-31-14 Bank of El gin 2-5-14 Bank of Commerce Alva . 4-4-1.4 Afton Exchange Bank Afton 4-7-14 ft/ )5-0)1 -Jo 1411A, /30 TO IA 17 /3U8 '/353 /3eS,it7 c.:5-6.60 4t73. ,P79 -d(241 ? .41 / 1'.6 7. :16 / I 51 . 14 9,237.P- Ye.Ve ioo 3,c..2y/ I/ 3e • .• c 4/4 4j 44. ‘; 410 ! 11.0-, V .)-F 0? /0 1:F6g. 'I I 37 607,3o 70 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7/7/ , 76 61! ) - /Of/4 / 737/, // /61 7g7 3? 7i1.14/ sO6 6.98 2r,ri.f, 4;i 1- '36.7, Z67 /3 -2/ 626,30 3`/-7r.04/ ;z3 ..2t; Czi-Ceb0 e - / ofrek :27174/2 .0) 1.- si 5 r " .57 90,27 443 *1/,/ 947/53. 2 /C,6y ?-73,5,21 756/ 3.3/ 3,4063 7C /7 2.7 y,a‘ /7370 .r379,C7 g74,, .2C F, lo ()t) Q e- 36-,23,1/ (;776 c:2 V96, • /0400 3 t--. <--"4 • .., i: •:. 3 c 41 Qt, •,. '-‘ lir- 11,4) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis . / .il 0-'1 1 47" -7 c/C-VI \ • OKI;AHOMA - data from Btate Banking Departm‘nt records - page (obtained in December 1955) Ponca Garfield Farmers and Exchange Bk 'Merchants Ble State Bank Enid Movntain VieW Pone?.,City 5-27-14 2'IKL-1.51 f-22-15," ' First State Bank Mannsville Bank of , 7 -64‘“ Ck.iicti 9-30-15 - &21,6-. p-- .1,53 tpe, 4 Farmers 8c, First LV. Merchants Bk State Bank Coweta Row 11-17-16`1 12-21-15 I- Farmers St.ate St Bank Jefferson 1-11-17,/ First "/ First State Bank State Bank Jay Dewar 4-10-1,`" 54 , -1 7 `7 Citizens State Bank Tulsa 5-28-18/ gc--? ,1) Logan Mineral Belt Bank County "Bank Tax_River Cruthrie =64'1'8 oi 1-31-19, 1 17„)-). ji-0,`.)) (ifil -L. 1;2- TIi6,6' al /3Y6i,e/ -14 / g a io4/1?.2- .3) / 330250ibq 1.3./ 7;i334 q: .1-73/q/7 -.;, 3? 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Citizens t-Mulhall Bank State Bank of Bk State Bank Exchange Coal tate ,. Foss Boswell , • Diulhall ' z. 11-19-20' 11-26-20 10-11-20/ : 11-1 5-20 94't, 41) 5 I; A>v.,-,2in p; oPo fc' 5C-c (de) f".1/ 6 0 2,'71'`\7.`„Lan-az: tu 44b " -re t17 1 •`'i az-v-4 9 First I,- Security First Bank State Bank State Bank rietta Shawnee of Walls 11-17-20 ( 1,1-.30-20 Farmers State Bank Vs A!ZIP 1-' -21 P11;ob /7g,F J 41-44144 d I (CAA) ' J -'4/61-57 /q/; (._ „20 ,/7 /174/3a Oo /3 g'o3..v..ci& 601 3 Z;(..)0e) , /t/750'1:(7/ :2o 004co /77'60.0 ; 4 0,e ,9/ #153. b;79 t! I ( 77/4 i3 , 00 _ /-34.iwit 66.44 <); \ tite.dzo- 56 - k z-,)c44,446-3, 64 It/a 1 4444r 0444: I. 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'Ak ' rt J-.Ze"aa: 461 91,--trarWsof f • y,4•1 tifo q.5-6./11` t3 15;cry ".• 1 (1 411 -r S,0,33,Y3 /0q16, tg' 23 7j/ /1 _f tY,:-.,t, 64e....4. ,? c , ,.€11,. • — (6, /41d- I, 1 )22)1 , ,4. 4:971-4,41:4,1 6;:1 r s.5-,it 626-6. 6-e„tie(,ii-,_ (se-ce,e4.-tv-d-11)-/-ri) c „.1.,c*,,,,,,,, ,,-d _._,,, IP /y vej AiLei 41- " --.7 ..e•- 14-41 7;7 F(:2.) - i IV; 1 ' 114.1'4I 4Leuk ILE ,U 1 t efid-or›-nvi t4, 4-4--z--rat Atkse_.44//a/../"" ;4, „-) i , , .4/7, -1-Wg-*:• ie ,./.‘t-L .."..-e7 , t- 4 5 •2 1--4- '-' .65 elot-- L ,-, //, / AA 1 410tk ;Aft ; irAtto 44 2 Jc. /41' )1A 1"4 ‘' IN34.1 ‘‘. " \27, 1/A/L/0J itoi7 ptivfld.'t_Ak L:i-fape-‘44-- , Alt OvLaAa-s-74. yk,44,744.1-42- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 057,;11 ma,0-4 yo 71..0-7) _ 1.-74 va 1,444, Av 414/441:tiR".14,../,/, b-tt °'"P-- „„ect,t, (6,4 , 1144 2".4 (%7•".13-"-zu--1 /../ 30,0'0 .A-Ztes 5-e/6-44.7 -4 -r /2'7 0.-ras-6 4/111' 43/ 1?4, t‘, v OKLAHOMA - data from State Banking Department recorde - page 6 (obtained in December 1955) • Central Exchange'-' State Bank ,State Bank , Bank of Kiefer Kiefer Jenks i 5-3-21 5-2-21 First Pershing ,State Bank ,State Bank Aylesworth Pershing 7-30-21 , 8-15-21 jf -no 0"; t,,i 76 c\I # 7/f',t\A , O'r0 ro (40; ..)V2 411 ere 6 ii k-221,,frik ft ,4141, 1 /11,1)0 lop .3.5-1,u0 3_5/ / Yi&ii7 51% CC 71 44 " '' • .t ):2')1‘;‘3(} 71 l 11).ei 65 et11' ,) I 403_ 07-1). 1 / At7 6o7, 5' ,2//b -'T /A OO.36 u0 iL/ 4i 333,97 6-1) 13 o5", 6/ /1 7F33f, tr.2I7 /be/'Z10 I 70 000.{Iv5 b 0-4444. f9f3o,iL). lq6 -6 410) 0-070 00.707,41) V. , tr- 1 ..cbli) ,ct w e,36, 117/0::-/-5 4: 1/ 0do . 163 ,;:3-=77 7,(7) -3 19-377.g j,_ 9.10,67o,(1 1 or , ri 1 !s-- i ii 6 C. /f657 I a 1 I q 5 ry' -4 -7,)'/137/ •N 0 Bank of -Commerce Sulphur 11 L-3,-21 36,Ths, , rvrq 7&-t7g )- Bank of '--Commerce Okmul gee 11-1-21 1/rWthic.X 7•tiy 3/;- 2 4 (702 First Bank of Hoffman boffman 153„,,,4( -f, • 4 a4,e 5; . 44 A 06e/1 ,47) •0`,) 5- "r I 04--6,0,.31, trt.rv 1 1 I 2: et) :1 5 : 4 000? Oklahoma Citizens State Bank State Bank Driftwood; GIAIVe 10-10-21 10--25-1 idt41 / \ 3/ First State Bank Albion 0-20-21" iamiL.-1 State Bank Bank of Miami Pototoc 09-15-21 A, $-15-21 ‘dc,k 14)7,11;:c0 t `1) / / 17 (0i tt1 9 AAit .,yr /17 33/ 37 6577,03 s6 i•274 P-5); Li 5-. `.1) ./ 42-." /C6 /3/ 3)- .5Y33 70 3:3 ? • . J2. /y,5I ;\ 65_5,2 ,?,3 I 7,;4,7Y • r y5-13 3' 2"" 3_19;2 702 9.2.•2.3 Gyeizt4 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 6 E,67 54/ 3, Pi6/sive •, - q533// 12..5-0-v Lib /4 b:3e,61 ,1/ / &'V 3.,i-7...,-0 c;.7. t Po-0, ?Ito? ‘,/,F9•,4,5" d4,3 7 /0/6 Z/6 3.5) 7c3.7I0 Vef A.) t g t•.- 7 67 • * lc\ • 77 q-eA-)4-2A-oi 1124.atjt-'14 1-, Y-14 4 -al g , i 1150,6-0e"" ila 6•0 4 ,Y • / .12.2,4 / /03, A422 -5-9 •••••••••• 9 3 111, LT /e.2,77g,o? ,a3,5-7v, 01 r , 11/01 a 4/1)" 0?,;4 itAi,„a f q•34/ )4 y3)5- (-7 :› r. 2 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Lt. 41-:"t:r r_Irill., 14" a -1 lAteil • • 41) G ? 111 1r ' c.4, 44 / ) Cr)• 61? " \11 4)) at•21.-4 S•17:4:2- r;f1 / .,1 tiLi% 05 • 13-7,3.17 36 141, 3/8. az-tv% A • •11 190 A •7,1 OV,Vi 1 1121 hadV) 17:17/1A7.49 (-;e/1/44.4 co.4.4... Nati. 141 , -S ; j5-1 1_19 r‘V.) J?' dfiV, ." ,0,4, 6.2/.96 ,i6c5 ed./61, cof 39,371.L? ,iirAiot-A-4, -`1CLpoze/w ! - PS:41 6-f6-1 4.41-1-14 : 7 i5:61 4( 43 1,2,4 Z a.. ,,•;" / 72 • OKLAHOMA - data fro'r_ State banking Department records - page (obtained in December 1955) First Oklahoma V State Bank State Bank Pr91,•_tipa.2/ Bliss 11-12-21 11-12-21 -' 7 Miami Trust Chattanooga Delaware First Imo State t' Savin7r, Bk State Bank Bank Bank of Bank of State Bank State Bank Miami Chattanooga Goltr, Mil 1 erton Delaware Stonewall 12-10-21 12-12-21' 11-17-21/ 11-l7-21' 11-0-21 11-15-21 1.1 -16-2i First State Bank Pensacola 12-20-21` 12-30-21 v Bank of • Farmers State Bank ef1k ic1- 2 Guthrie State Bank Guthrie 1-11-22" el) )3)5z) • I iq i7965 53Leq i71/ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 51'7/' 83 `/S--.) /3 .;2-b/a2/. .:44;644 436,4 .11,6 7 - 4: i .2.93 (1.2;7, 6 3E; q3 3,96 3 -).7 35-0 C / r; "r /oct‘c4'74 31i "4 It 6.25 op I a P7'3 c/3/..%3 Dc 67.):9f 57 7/ 2,1/ 6; 071F? I I i. P-14171,4.,7 , 4k 1 p I 44"fa : ; / https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1;2-2,-PCA1 , Zia e4.44 • OKLAHOMA - data from State Banking Department records - page 8 (obtained in December 1955) • First State Bank ijurant 1-25-22 v I First First State Bank State Bank 1.1orris Bliss 1-27-22 fr 2-25-22 Commercial Bank El Reno 2-28-22 4,-Bank of Wilkin-Hale Oklahoma Commerce Bank State Bank Sulphur Okla4Cit .y Walters 2-2821-"/ 5-8-f-fF 3-10-22 v , - Western State Bank State Bank of Stratford Erick_ 3-1-22 5215/2. T Edmond State Bank Edmond 5-15-22' Old ahoma State Bank Caddo 3-18-22 First 'State "il don State Bank Bank of Wi1 son Clayton ' 6/4.4 , 1 4"41 4 `t ! 7 67 0:1 , 1." 13tlZ •c -77c 6_353`f, ci io- Gbql7; t0,0 653.3oI. ;1.2 ' /062 /35,o6 /1 3 ,A).7 f.32 / 763 Of7 )4E4prq •W3/ 536 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 75" 767; .--670Z•73. 33 IC /363.77 //1310 lb 761)7,76 63-56,0o 3 63E, it3 447ILLY, 77 • OKLAHOMA - data from State Banking Department records - page 19 (obtained in D:p ember 1955) Farmers V L'artl esvil le Peoples Brc'- Bank of/ tirst Farmers State Bank State Bank . &s Trust Co Cameron State Dank State Bank Park ftiii :Bartl esvil 1 e Warn Cwagiip Crtiata Jamèx5n .he 47-7-n2 5-11-22 5-19.-4 I 1 / , 141 &4-17 :339.1_36, 11 7c.5741, c*,26 1,2-34/1 61 — / /3 1./.3,a7 -‘1 e9.5; iz 3D()9 q/ :2- a- . 5547.;4. -,--,1 . '. ; 11 6,VS? ./, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .",/, z//3' Farmers Security State Bank State Bank ' G1 encoe Pawnee 8-14-22 - 8-17-22 Central State Bank liu,sku tee ?". 6/ 4/ Farmers Bank of Illinois Bank of Gore RWW-11 9-14-22 9;-19-222- 1 /5917627 //7t, C 204 19/ L79. 2-79t. Yale State Bank_ Yale 8-14-22 „ ;2 gif qq "-i6 34/401 360 0Y3.63 .1269-1/ hVo6 q ' 333.0->*1,26f,73 / 63 9-5:22/ HM86)9"ic,/4) A-5" /0 Y, Bank of Crowder 10-6-22 d',41 .5-437,5* /951/7 7/ /600,7/ 96,3,OF .2g- O5766 OKLAHOMA - data from State Banking Department records - page 10 (obtained in December 1955) • / First , State Bank State Bank •of Choctaw ilag.7-19211 11-2-224/ 12-1-22 I/ Bromide State Bank Brolalds • 1 First First '/ Oklahoma Central State Bank Exchange Bank State Bank State Bank Atwood Allen jer11Woodward. , I 1-22-23v/ 1-25-23 1-16-25 2111 -P First Farmers Foss State Bank State Bank State Bank Gage Ashland Foss , 1-27-23 , 4 4 1-28-23 Sal 1 isaw Bank Farmers and Guaranty Merchants Bic State Bank & Trust Co Sa141.,911_,3 Achil 1 e Nash 2-r-9-23 2-12-23 sY 2-12-23 ) . f 7I 36 5151,S3 az03375..21 , 1 3:i -)" . 2oli4j 5 ; 0 ( , ',.,z, c. _ st3 ,/ oy _ 4,704...r https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ,•• / 6/ 3656a r/11 /6 /01/,-). / /.2e,40 ei2739 8/53 ,2766/ 3 pis v/ 37;2,66 •2 J, 14 /9't77.9' :4/ foc,3V 747a,5D //PI/ 40' 2747 /5' ' :3/ 6.26/5 1/. 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Vqo737 A/A4 , 41 St-411 4/.1./) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 6 36r 41411 23 131Y? 7 27/1 -51, a? 672-.Wr '°// A 610 #14 Afit -131 /3v pi) ..- ) ". .4" \ N / • - - • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis •:,"• ; , 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 - 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 • • 63,213 (1-1-15) 44,204 (1-1-15) 86,939 (1-1-15) 111 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis June 3 July 14 Aug. 9 Disposition 51 105,383 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 '21 _26 0 2-7 ) CL-0 15L-eir t- S4 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis CL&J S'4.eat 94-t—kok..x.at 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. , ( ..A fiza-/ 9/q/fw_e,4 _ 200 1 • let-. 7 evil 333 - t G v1V14/4 -"jii ,4 , 33p I/90437 A).57/ 532/' 14:›7t 37 4-,164 71? 32 350 P/3 tilly ( • /9,3 42-s-660 cif 19 I /$1 17'23Y .73733 1.H"71 12V 7. .1,717,..4?"0( _56/4'f / 3751E3 tf44 36- )7 • sac..,/ ev 1///6 i •7.1 c /Y6 ' . 3/ p. 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"'? 3 ---0/-.1,/ Api-eAde. 7 64-:--4- -4• 3 e 04 1741'4 "et' 40 Aaie eAP' .‘,144e r Y / 90 #`9469V 1), be. a 3,* A•444- '931331 774 At6, 37ov 2:eZ4; t,o94-1 77 0 is,asi /1 fi ‘611'14441-. 4!).4e,v 6 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 701.-C 770I j 4;e* -4-••. f"?...37 7Z 42.Z.-7,4-,1 4hZ•• • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis _ „A _ • • • ), n• 44-61.4111 44 $14- ,64- ,1 411a-62-- 109-, 4 22 gA1114942 — https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ag , t401-#0-$4"-Ipt)(4:1:0_,,) , IL d..51441 67 ' rti 7.(A---041 ‘),--(vJd .400- ;- e46440-10-- ..77Z 1.7 9 413 / / 1/464"4 kl/'°14 " 1317"-777 .2 7 gri6k2 14 • e e / 67 t ;4' ktst. 0 20.2n 3.1 P P.4 7 2,7 0 0.6 7 2,1 13. 6.1. 7 7 2 CI .._,R 1,4 r 0 P 0 430 7r) , ' 4. 2 33 4 a P.6 - 6.r) ri r•n - P q' :7 ✓ a r: 1 ' P 1, 1 0 .4 2 • P 1 p q 7•26 q2 7 2 654 7 '7 6(.4 4.75 r 5 79 7 ✓ 7 00n a P 75 7.2 5 r ✓ 3 7 3.25 r: ,. 3g q5 ✓ 6 r 3.7 a 4 i. 0.1 2 ✓ 472.7 ✓ ' II_.,.. R 3 aF7.1 q 7, p . . ..5 A 7c) ,-, 7, c) 1.4 '3 - .9 .2 7 1,375.5 4 ,..7 q 1 , 3 ,, _i_ 1.61 2.25 1 r: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis <- 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 Unpaid monts 1 vled oerti but not yot oats* or oolleot d slain* ; outst ing A8818S• Accumula. Assess-Estilated Estimated net aogu• va/um of tion o ments' mulatiOn unliqui. probab (lanai or deficit dated not in in of fund assets collo* (sum 0 (sum of . able preoe0 banks preceding ing three (share or three colunn0 rund) oolumnS) /7 - I 144 c:17-e; - https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4 - /2. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • https://fraser.stlouisfed.org 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 • https://fraser.stlouisfed.org 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 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 3 4 6 9 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. • https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 10 -25- • 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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). https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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). https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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./ • https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. • https://fraser.stlouisfed.org 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, https://fraser.stlouisfed.org 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, • https://fraser.stlouisfed.org 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, https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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 https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org 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. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis