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413.la - Source Material (Pockets Only) 6tudy #12 Branch Group & Chain Banking Evolution --n '04' https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • - • • .= t Removal Notice The item(s) identified below have been removed in accordance with FRASER's policy on handling sensitive information in digitization projects due to copyright protections. Citation Information Document Type: Newspaper/magazine articles Citations: Number of Pages Removed: 321 Items which fall under copyright restrictions have been removed. The complete collection is available at the National Archives at College Park, MD. Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis CLIPPINGS (OTHER) EMPIRE FOLDER Better folders for better files 306S Send your Order to the nearest "Y and E" Representatives or to our Home Office YAWMAN AND ERBE MFG.O. Main Factories and Executive Offices FlOC.1-1EST711, fq. Y. Branches and Agenr,in all Principal Cities https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Address of W. F. Gephart, V. Pres., First National Bank in St. Louis, 40th Annual Convention, Indiana Bankers Association, May 1956 (Hoosier Banker, June 1936) But the situattnliver a longer term period is not hopeless for the commercial banking business in time will recover and we hope the Government will in time retire from its numerous financing activities and modify some of the detailed control of bank operation on the basis of experience. Business in full swing will need larger working capital as well as a large amount for replacement of obsolete and depleted machinery,and the credit for these needs should be supplied I_Dy commercial banks./Another thing ,-that would help the commercial banking situation in the United States is a properly delimited system of branch banking which would, on the one hand, supply ad-equate banking facilities for each com-m unity and, on the other hand, reduce tli-e present rather high expense of coml- bank operation. ihercia _ We probably still have too many individual banks in the United States, but in reducing them we should not adopt a ation-wide system of branch banking, 1 t ut limit it to the industrial areas. Agai\6 the general situation will be improved by still greater co-operation among banks in the city and county or group clearing house associations, as well as more cooperation by the individual banks in the towns and cities. The outlook is not hopeless by any means, but it is a serious situation, calling for greater enterprise and more co-operation from commercial ,—....,, s. / banker — if 1 PROCEEDINGS NEW JERSEY BANKNiS ASSOCIATION—MAY 1954 BANKING--Yesterday, Today and Tomorrow--by Dr. W. Randolph Burgess, Deputy Gov. FRBk., N.Y. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Before the automobile the depositor was more closely limited to the local bank. With the coming of the automobile a much greater number of banks became accessible to each customer. Under these circumstances the larger bank which can render a wider diversity of banking services and inspire greater confidence gains an added advantage. These causes operating toward a smaller number of stronger banks have been further supplemented by changes in busine.,s organization. Business has tended toward consolidation and concentration, and has, therefore, favored the stronger banks in principal centers. As business units have become larger the need for diversification of banking risks has been accentuated, again to the advantage of the larger banks. Under all these circumstances many smaller banks have melted away. This is shown convincingly in the figures for bank suspensions. The highest ratio of suspensions has been in the smallest sized groups. More than fifty per cent, for example, of the banks which in 1920 had under $150,00o. of loans and investments, have suspended since that time. Figures for earnings show similarly that the smaller banks have had difficulty in earning their expenses. There are still many good small banks in this country and I believe they will always have a place, but clearly the current tendency is toward fewer and larger banks. It may be added that this tendency distinctly favors the further extension of branch banking. REPORT OF SPECIAL COMMISSION FOR INVESTIGATION AND STUDY OF BANKING STRUCTURE-MASS.—Created by Chap. 35, Resolves of 1933 (Jan. 1934) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Commission has no desire to do away with the competitive system of banking, but it does recognize ' the necessity for permitting an extension of branch banking within county limits, and for imposing certain regulations which will prevent that type of competition which tends to destroy the stability of our banking institutions. The Commission has not limited its efforts to the protection of any one group, be they depositors, borrowers, stockholders or officers, nor to any one angle of the banking situation. It has tried to cover the whole field, giving protection to all, so that, as in the past, others may continue to look to the banks of this Commonwealth as leaders. Another important change suggested is the strengthening of the capital of existing banks in order that depositors may have more protection from losses due either to bad loans or shrinkage in the value of investments. This could not be fully accomplished without permitting branches in communities which, while they may require banking services, have not sufficient need for a local bank to warrant the capital investment. In many cases this has resulted in the formation of banks with the minimum capital permitted by statute, but which is, nevertheless, a capital too large to earn a satisfactory rate of dividend and at the same time too small to accommodate the larger business enterprises of the community. Countywide banking will perhaps result in fewer banks, but it qtron trPr banks, and more communities would obt&in direct banking service. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2- 1934.] SENATE — No. 100. 45 BRANCH OFFICES. At present, branch offices are limited to the same town or city, or to other conununities after enactment of special legislation. The Commission feels that banking service should be given to communities which cannot profitably support an independent bank, and that these communities are entitled to some banking accommodation. In other communities where there is only one bank, it is frequently too small to be able to accommodate adequately the commercial requirements of its larger depositors. In such cases, the consolidation of banks in different communities might well result in a banking institution of sufficient size to accommodate all depositors in the several communities which could be li. served by its branches. Therefore the Commission ecommends that• legislation be enacted to provide for the establislunent of branches within the same county. (See Appendix A, sections 45, 46.) - BRANCH OFFICES. of SECTION 45. A bank may with the approval oper2 the board of bank incorporation establish and where 3 ate one or more branch offices in the county com4 its main office is located; provided, that the less than 5 mon stock of such bank shall at no time be red by 6 the aggregate minimurn common stock requi number of 7 law for the establishment of an equal where 8 banks situated in the various cities and towns 9 the bank and its branches are situated. AM. PROCEEDINGS NEW JERSEY BANKERS ASSOCIATION--MAY 1934 The Pres.'s Address—Carl K. Withers, Tr. Officer, First—Mechanics Nat. Bk., Trenton https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ei0/ Prominently in the foreground of discussion at the moment, is the perennial question of branch bankin present g, which takes on a new significance under the provisions of the Banking Act; allowing the establishment of branches of national banks in States where branch banking is permitted. Again, a sharp line may be drawn, and a formidable array of argument presented both for and against this extension of individual banking power, with all of its sinister implications of domina tion and control, toward the ultimate extinction of local independent banking. There is a unanimity of opinion that one of the principal faults of our dual banking system in the past has been the competition for charters existing between the State and National sNstems. The entire system was unquestionably weaken ed by the competitive conditions created through the over-establi shment of banks without adequate regard to community needs. This same objection—and danger—will apply with equal, if not greater significance to the over-establishment of branche s. At least, this has been the common experience wherever branch banking has been permitted under comparable circumstances. In New Jersey, should State-wide branch banking come to pass, the possible and only logical solution, may be found in the enactment of legislation which shall provide for the mutual approval of both State and National authorities before the establishment of branches oi either State or NationaT banks in 'any community—and then, only_after careful analysis of the normarbiriking_ needs di tE-at community, made by the ICaTik Advisory Board, or someraer coMp-etent and imp=r7u-tTiOrity. To accomplish this end—changes must be made in the Banking Act itself, for in its present form, no restriction as to the n of ,hranches which. may- be established is implied, ot er than to those States in which branch banking is not permitted. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • BASKLESS TOWNS "Banking Service For Communities Without Banks" R. W. Putnam. First Bank Stocic Corporatio n, Minneapolis, Minn. WITH 79 North Dakota towns of from 200 to 1,400 population with no banks, the problem exists of supplying banking services. Four possible avenues , are open: first, banking by mail; second, local messenger service; thir d, by E. visits of bank officers; four th, by branch banking throughout the state. The last plan is forbidden by law, but banking-by-mail has made real progress. In some towns, the local merchants have arranged daily trips on an alternating basis whereby one man each day handles the banking funclisga_of the group. In another, a former bank er pays andisiues checks drawn on- an 2utside bank, and renders all services except taki . ng d9osits. Another bank kept a man in a rented office in a neighboring town, but discontinued this plan after losing $600 in six months. Wit h opportunities so meager for banking profit in small communities, plans such as these offer at least a temporary solu-f tion to a real problem. 1 • /za;:livfr, Jo, / vs THE COMMERCIAL & FINANCIAL CHRONICLE—ABA Convention --Nov. 1935 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ) port of Resolutions Committee Re-affirms Stand for ) R State Unit Banks—Preservation of Rights of State Banks in Administration of FDIC The report of the Resolutions Committee was presented as follows by 1,,,,A,, Andrew, Chairman: The State Bank Division in annual convention wishes to first re-affirm its time-honored principles as standing primarily for the interests of the State Unit Bank as opposed to trade area or nation-wide branch banking. We realize our responsibility to the thousands of small banks which have again no other representation in the affairs of the Association. We wish to maintain our position in favor of the American dual system of banking as managebank better of opposed to any unification idea. We are in favor ment and improved banking laws and supervision. We realize the importance to all banks of the Federal Deposit Insurance Corporation. We are now all co-insurers, to a certain degree,of the deposits of the people. We wish to commend the regulations in so far as they have been put into effect that have helped in the operation of better and safer banking institutions. We urge that the rights of State banks be fully preserved in the administration of this most important Government department of banking. he National Government has within recent years broadened the partici ation of the Government in the loaning activities which rightfully belong as t the banks. In several cases these loaning activities were proposed temporary expediencies to aid the people until public confidence had been restored. We believe that this time has now arrived and we urge, first, that all banks broaden and extend their loaning activities so that in the near future they can take over the better grade of loans now handled by the Government agencies of all kinds. We further urge that the loaning activities of the different Government agencies be gradually reduced until they can safely be taken over by banking institutions and be terminated within a reasonable time. We again urge that the rate of interest on Postal Savings deposits be now reduced so as to do away with the unfair competition that this agency practices in opposition to banking institutions. We ask for reduction in the rate paid on RFC preferred stock and capital stock notes. We wish to commend in the highest terms the good work done by our the efficient officers and committees during the past year and particularly this Division help that our Deputy Manager, Frank Simmonds, has been to and its thousands of members. L. A. Andrew, Chairman F. B. Brady R. M. Hanes 1The report was duly adopted.) -,'' .. ,T)cv,ti • a. THE COMMERCIAL AND FINANCIAL CHRONICLE--ABA Convention--Oct. 1952 Remarks of Pres. Haas of ABA Before State Bank Div.--Comments on Unified Banking--Comparison of U.S. and Foreign Banking Systems. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ) Pou run Banks. We frequently have non-banke rs refer to the banking sytstenta of other untries and compare them with our country. espec of bank failures in the ially in the number United States as compared to those countries. Let us briefly take a look at their situation as comp ared to our ovrn. Canada has 10 banks with 4.000 branches and total 000,000. They have a popul deposits of $2,450,ation of 10.400.0(10 and an area of 3,690.000 square miles. England has 17 Joint Stoc k Banks with 9,000 bran ches and total dePos of $9.200,000,000. They its have a population of 46.200.000 and an area of 94.000 square miles. In France they have no real system of repor ting or public statistics regarding their banks, but we do know that the six largest banks operate 4,000 branches and have total deposits of $450 t here are perhaps about .000.000. In addition 1.000 other small banks. of 41.000.000 and an They have a population area of 213.000 squa re miles. The United States has 19,500 banks with total aollars and 796 banks deposits of 50 billion operate 3.600 branches. We have a population of 123 million and an area of 3,7:38.393 square miles. In other words, we have probably 5,000 more banks than Canada, England and France comb ined while our total least :37 billion dollans deposits are probably at in excess of the total of these three countries. As a matter of fact it may be interesting to you to know that banks in New York State alone have about four billi of these combined on dollars deposits in exces s countries. Does not this indicate the difficulty of tryin g to pattern our banking ,ystem along the lines of any of the principal foreign countries. I might continue this discu ssion at great length ment of our country unde and point out the developr our dual banking system as compared to Canada. each with nearly the same numb er of squa re miles of territory or the of our businesses as diversitY compared to Canada, also the development of the bran banking system in other ch countries and the years t hose who operate their of training required from system, but I think enou gh has been said on this subject. I want to say a few words to you about time deposits. Mr. Andr referred to notice on ews withdrawal of time deposits. I thoroughly with him, but you couldn't possibly have agree passed such a bill during period without doin this g harm. If we had recommended that they ime limit in effec t all over and at the Put the same time, deposits woul . eeped out while the d have matter was being discu ssed. You know they a bill and discuss it a lot. and during that bring period we would have ,t of money which woul lost a d have gone into hoar ding 1 THE COMMEECIAL & FINANCIAL CHEONICLE--ABA Convention-Oct. 1932 CommitteP and Officers' heports--address of Pres. of State Bank Div., Felix M. McWhirter, Pres., Peoples State Bank, Indianapolis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Unless responsible officers, directors and stockholders of the btate chartered bank and trust compirny, together with those active in banking circles. take a hand and declare themselves that it National is best for American banking that we have a dual system of banking thereby recognizing both the sovereignty of States and the inherent American policy of giving freedom for individual initiative and enterpris e. there maY be only one system of banking in that system, gentleme n, in the opinion of many of us. and in the end may not be a National banking system— chartered by bureaucratic Washington. The stockholde,rs, directors and officer's of the 10,000 State chartered institutions we,re first nause,ated bY the attack on State chartered banks on behalf of bureaucrats, and, later, amused and now they propose to vigilantly control the situation in their respective States. bY their own hands. Certainly, none of us here but who firmly believe that progress in better banking management and operation must come entirely from within rather than through some superimposed dictatorship holding company privileges, or any other Federal permissive or coercive means. In fact. the majority / of main street bankers, and, my friends. they are the ones closest to most of the people most of the time, know that generally speaking, the debacl -of banking and finance followed an orgy of flagrant speculation. Anythint... which feeds upon itself finally disintegrates. America will not tolerate bolding company banking concentration. From all the loose conversation in our Nation's capital, and propaganda emanating from holding company bank operators, one might feel justified in wondering if State chartered financial institutio ns and their owners have ceased to constitute a part of the structure making up the common public of this country. Is it true that the representatives in Congress from our respective States do not represent us as well as any other group of citizens or institutions? Have we ceased to be entitled to thought as to what would be best for our welfare as well as any other element or class of this nation? Nevertheless, you have no doubt been astonished. as have I. to observe the thought seriously presented, that CongTess has the constitutional power to prohibit State chartered financial institutio ns from operating at all. It has been seriously stated that because the States and the people of the States gave to the Federal Govermnent the right to coin money and control inter-state commerce and because the Federal Government requires the assistance of banks in conducting the fiscal affairs of the National Government it has the implied power to close the entire field of all banking activities to other than Federal institutions. The thought, of course, is so grotesque as to be little short of amusing. but the serious element is that at the time when we are called upon to co-operate and as usual are doing so, to our patriotic utmost, there is such evidence of utter lack of sober thought and considera tion in the responsible elements of bank holding company operators to advocate or propose such ill-advised and discriminatory legislation, the only possible effect of which is to promote skepticism of banks generally if not to cause inquiry into holding company banking concentration itself. Section 19 of the last draft of the Glass bill would provide if enacted and found constitutional that a National bank could be permitted brancli in any State of the Union, irrespective of the.will of the people of a State as expressed by their State Legislattn•e. It is time, my friends, to stop and consider: Are we in America to permit bank stock holding companies to cause a Federal Government to foist branch banking whether or no upon sovereign States that the bank stock holding companies may sell their National bank shares to natural perso What a monopolistic concentration of banking would be possible with "parent" National bank operating in each State scores of branches—yo choice is your right and the. people's choice is the people', ritrht hot are entitled to the truth. THE COMMERCIAL & FINANCIAL CHRONICLE--ABA Convention--Oct. 22, 1932 State Banks and Their Important Field of Service--by L. A. Andrew, VP., First Bank & Trust Co., Ottumwa, Iowa https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Congress, giving Section 19 of the Glass Bill now before the right to more, capital, or $500,000 National banks of even business do they establish branches in any State where attack on direct banking, a is branch prohibits if the State e sovereignty of our States and an attempt to override e expressed will of the people of the individual states by ational legislation. Many students of our constitution believe the proposed section to be unlawful, but, nevertheless, it is receiving substantial support from selfish interests who wish to make it an entering wedge of a nation-wide system of branch banking and to concentrate all of the banking interests of the country in a few hands. It is a deliberate attempt to destroy the integrity of all of the smaller banks in1his country under $500,000 capital whether National or St te. l The Commercial & Financial Chronicle--ABA Convention--Oct. 22, 1932 "State Banks and Their Important Field of ServicOL-by L.A. Andrew, VP. First Bank & Trust Co., Ottumwa, Iowa https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -The independent unit bank , however, was by no means the only sufferer . In fact every type of bank ing organization was repre sented in the situation. i f small banks in the country failed, so did sizable unit branch bank organizations banks and large ' in the cities fail. And if unit and branch bank , organizations failed so did members of chain and group banking organizations and likewise so did entir e chains or groups go under. Without making any statistical comparisons, for we do not believe the sufficient to indicate the respe data of this type is ctive merits of these vario us types of banking organizations, we would ment ion that during the first half of 1930 there were 12 instances of branc h systems suspending , 24 instances of members of group or chains, and also a number of instances of these latter types of multiple organizations failing as a whole. The only generalization we would draw from this is that no type of banking institution or organ was entirely immune from ization as such the plague of failtme. The deter as universally the type of management, not type of organ mining factor ,tno.gement kept unit, chain ization. Good group i ks sound as well as large banks or branch banking sound; it kept small . country as well as city banks, National, .i.t e, Federal Reserve member or non-member bank s—in brief, good management kept all class of banks sound." I 1 • THE COMMERCIAL & FINANCIAL CHRONICLF---ABA Convention Oct. 1932 Resolutions presented by R.S.Hecht, Pres., Hibernia Bk & Tr Co., New Orlean: as Chmn of Resolutions Comoittee https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis It is recognized that the subject of branch banking has become a questi on of such a highly controversial nature as between banks operating under arious conditions that the Associ ation as a whole feels it should not attempt this time to formulate a definit e attitude aimed to commit all types of nkers on this many-sided questi on. We believe, therefore, that any expression and action on branch bank ing should be left to the specialized consideration of the various divisio ns. 1 • • ,Py • • fHE COMMERCIAL & FINANCIAL CHRONICLE—ABA Convention Oct. 1932 Report of Economic Policy Commission--by R.S.Hechtt Pres., Hibernia Bk & Tr Co New Orleans---"Bankers Favor Unification of Banking Through Fed. Res. 6ystem" https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis . atirn7" expected that the porcesses of (xmsolid „,___,..... Within banking it is to be required continue to eliminate where a'nd as and voluntary liquidation will i , of means and that they will be the chief such u. economic units as still remain, .r) P from the destructive forces of the bank shed distingui as n, correctio this run a more normal course. suspensions, which, it is to be hoped, will hereafter ' deprived of needed banking facilities Also in those places which have been ..,40....re .in___Inent q bt _estab j_____gs, re_52peniii__ by restored be they should ied from. or organizestif State lawa_zr and desirable These procesSes present the most effective .'oints Ot vie_,..w taii" number, capital the banking structure, both as to the i antIMTS. irffli.'grig needs of economic contact with the and distribution of its units, into closer t he Nation. i • • • • THE COMMERCIAL & FINANCIAL CHRONCILE--ABA Convention--Sept. 23, 1933 The Need for Revision of the Glass-Steagall Act and a Sane Legislative Program for Banking--Geo. V. McLaughlin, Pres. Bklyn. Tr. Co., Bklyn, N.Y. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis On the controversial subject of branch banking, I think 1 t the answer lies in a gradual extension of branch privils. In my opinion, it would be at.mistake to legajizo wi.th n, nation-wide or even state-wide brancD 0 TO e of the (--might create now exist, since..that ______ banking where it does not . . )1' chaotic conditions. Yet, the urgent need for new bankIng / facilities in many communities, coupled with the fact that i/ resent banking conditions are not attractive to new capital, cerin banking for extension of branch necessity fuggests the ain localities. t e • THE COMMERCIAL & FINANCIAL CHRONICLE---ABA Convention--Sept. 23, 1933 Annual address of Pres. Francis H. Sisson, VP., Guaranty Trust Co., NYC https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Whatever we may say a,s to the factor of too many small banks in the banking structure, we likewise realize that there are at the same time ny small but thoroughly sound banks that are rendering good service to eir communities and that they should be allowed to live. If over a p iod of years a bank has earned reasonable returns on the invested capital, if it has given its community sound and adequate services, if it is in good hands and if the prospects are that these various satisfactory conditions will continue on into the future, there is no reason why it should be arbitrarily destroyed simply beca,use it does not measure up to certain dimensions and specifications that are based on banking experience in other larger places. I thoroughLy_believe in a reasonable extension of branch banking, 4144L1 I believe that many places with sub-standard-hanks would be befieFed bY-givWxg those places the benefit of larger city-banking-through—branch Et-alit-1es,nut I do not believe the situation cans ror a ruthless and wlieTeela -Te slaughter or country Banking, good- and -bad alike, such as would be brought a ut ux-------tnIrlIgrance plan of the Glass-Steagall Furthermore, granting the replacement of weak unit banks with branches of stronger banks in some places is to be desired, the fact remains tha going about it by the method of enforced membership in a guaranty of deposits scheme would only be to set up a situation that is worse in some respects than that it is aimed to cure. it', In the opinion of some authorities. it is in the general adoption of principle of branch banking that the remedy is to be found. This is on, controversial of the most important and, at the same time, one of the most been of all our banking problems. Despite the bitter opposition that has branch toward been certainly years has presented to it, the trend in recent banking. The Banking Act of 1933 goes further in this direction than any other Federal statute has ever gone by placing national banks on a parity with State banks as far as branch banking privileges are concerned. The advocates of the system point to foreign countries, particularly Great Britain and Canada, where branch banking is widely practiced and bank failures are almost unknown. To offset this argument, our experience in this country in the last few years has shown tbat branch banking has ' provided no automatic immunity to financial difficulties, while many unit(1 banks have emerged from the crisis with records of which they may well and be proud. Certainly branch banking, in and of itself, is no panacea; all we should not rush into it blindly in the belief that it will sweep away most our troubles. On the other hand, if it is found to be a feature of the . constructive solution of our banking problexns, we must adapt ourselves / [ t o it. V • sp • THE COMMhRCIAL & FINANCIAL CHRONICLE--ABA Convention--Sept. 23, 1957 Addiess https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis of the Pres., L.A. Andrew, VP., First Bank & Trust Co., Ottumwa, Ia. P.ditor De Puy of the "Northwestern 13ankers, " in a recent editorial stated: "Let us not forget that under otir present unit system of banking the urces in the United States increased 600% in the last 30 years. Let continue to protect the sovereignty of our individua l States. Let us !ontinue our dual system of American Banking and prevent a foreign system of banking from being superimposed upon local American farming and rural communities and upon the people of the United States. Let us have rules and . . • . . 6 hich w 1 . 07;-.1 . d iu every tIe . money of dela Vs. .11 us tuopuuse a c and credit resourGeis jae,....LuiteLLY.Lat.e..s_ihwugla-skaty...ayktel um 1 or centralized lit in this country upon the fa.lse iuea thatn l Let us not easily forget the large business gness can ever mean 'Sattitri•C banking crashes that have come from 'Bigness' and these crashes have and been heard from one end of the land to the other since 1929. "Let us continue to have State banks. "Let us continue to have national banks, but let us see to it that neither one of the groups nor any part of them be sacrificed or crucified for the betnefit of the other.•' —- • on--Nov. 17, 1934 IAL CHRONICLE—ABA Conventi THE COMMERCIAL & FINANC OAI ER RELATIONS CLINIC CONSTRUCTIVE CUST ve Customer Relations The Importance of Constructi k & Trust Co., Minneapolis, Minn. By L. E. WAKEFIELD, President First National Ban lived in Minlement: I wish Mr. Stonier Mr. Stonier, Ladies and Gent e just at the present l campaign going on out ther tica a poli e hav We ta. neso and the institutions ds which he has said about me gs moment. The kind wor in the fog of all of those thin lost be ld wou ed ciat t over the radio with which I azn asso rary on each day and nigh cont the to said g is bein vv-hich are which t octopus e and how we are that grea about us and our influenc ral. gene in ty seeking to destroy humani eld's address, sion of Mr. Wakefi Following the conclu t: following to say iu par Dr. Stonier had. the the keynote of the said, has given I set the tenor, as with respect to the Mr. Wakefield has said, the danger to get at. As he only of this country. true t isn' thing we are trying ness d, for instance, the banking busi world. In Englan Government owning r sections of the ay facing a proIt is also true in othe failure since 1865, they are to-d ' bank the Government, not which has had no over the banks by yI campaign. to take en't—not because the hav they se gram, a political ecau have failed—b because the banks ions or fraud, but because the banks ic with them. number of defalcat carrying their publ have had any great in ul essf banks suzc not been rity, the English secu and of England have ty record for safe the people. and In spite of their fineconsideration to the rank and file of t deal of money, ugh have not given eno the banks made a grea the money as e got the idea that lending the people over ther rates, and are not nt bita exor k, ladies and thin ging I that they are char is much closer, in spite of the England to-day ks than we are ban they should. And of p • rshi owne rntnent do not use against gentlemen, to Gove nst us here, they nt they use agai ks have failed. ban that • ) fact that the argume t inen all—namely, the argu matter of fact, the English banks( English banks at a dwide question. As know what we are So this is a worl prograzn, wanting to of talking to our about this very m us gra to pro ten writ this e hav we are carrying out trying to do a.nd how . ness banking busi customers about the :'tI https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis THE COMMERCIAL & FINANCIAL CHRONICLE--ABA Convention--Nov. 17, 1934 What the Country Wants--by Clinton B. Axford, Editor "American Banker" https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Branch Banking I-; I somethnes falter in my antipathy to branch banking. and wonder if perhaps we would be better off if the commercial and demand deposit business of our communities were in the hands of branch banks and they were limited exclusively to such business so that the local banker could settle back in comfort as the local trustee of the local investment fund servicing local loan needs, untroubled by the fear that some (lay sooner or later his depositors would liquidate him down to bare rock. dissipate their capital, wreck their communi- ties' borrowers, and destroy the banker himself because h assumed to guarantee as liquid deposits which he had to in vest in illiquid assets in order to earn interest. I say falter in my distaste for branch banking, but I do not find it necessary to surrender, for New England is full of such sanely operated local savings banks as I have described, and in many, many cases the same banker is both the commercial banker in his local National bank office and the savings trustee. How much better for the country as a whole if the reform in banking could be thus along the pattern of New England's success rather than along some pattern of branch banking or Government banking which would pile upon the basic error of holding forth savings as demand funds, the immense dangers of centralization, of concentration of investment trusteeship in the hands of a comparatively few big city men, and, finally, of politician control. The picture I paint of New England's parallel State savings and trust and commercial banking systems may not be ilea. But in vivid contrast are statistics of Canada' rogress under branch banking, relating to her Eastern provces, which correspond in time of settlement and natural resources to our own Down East New England. We are all familiar with the success with which New England has maintained its wealth accumulated from days when it was the shipping center of the world and cotton weaving center of the United States, and how it has added to that wealth and increased its population. But we do not know that Canada's Eastern provinces, once he'r most prosperous, 'have been drained both of people and of money through the great Canadian banking systems which were more interested in financing evelopineDt__Of_territory supporting their railin the West of Canada than in conserving rnsifd-T nvestments. the prosperity of the Eastern provinces. And for the country-tura whole the record of file last two decades to 1931 is interesting.: 3,500,000 immigrants were brought in at heavy ubsidies by the Canadian Government, while population in he same 20 years showed an increase of only 3,100,000, a net loss of 400,000 people under the benevolence of branch len banking. Clinton B. Axford (Contd.) Page 50 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The fight of the "American Banker" against branch banking has been a fight against the illusion that to exchange our present system for branch banking would be reform. We have known and we believe that time has now demonstrated that branch banking is only a system of having bigger bank failures. Let us cite the fact that when the artificial support of big names was removed from the banking system in the United States in 1933 the banking holiday found 17 of the first 200 banks in the United States unable to reopen, and, of the branch banking /' / systems in the United States, 19 were unable to reopen, L/ and they carried down with them 494 branches. We know now that the reason why the United btates was within two weeks of going off the gold standard under President Hoover in 1932 was because we were within days of the collapse of the largest branch banking system in the United States, a system into which the United States Government and correspondent banks threw at least $150,000,000 during February 1932 in order to save it from a collapse which in 1933 came when the branch banking structures in Detroit collapsed and finally brought the national crash. Moreover, we know that the only thing which saved the big British branch banks in 1931 from the same sort of a collapse as a result of the heavy internal and international runs upon them was the fact that England suspended gold payments, before they were forced to close their doors. We relieved our banks in 1933 by the same method when they were reopened. And Canadian banks have been off gold since 1930. We have seen Germant's branch banks mortgaged to the German Treasury and finally taken over. We have seen French branch banks with hundreds of branches collapse. Italian branch banks were rescued when Mussolini bought their frozen assets. Yet despite the evidence which damns branch banking as no better than unit banking when it is under pressure of the United States are going to take branch banking in the name of reform if State and unit bankers do not give them something better. THE COMMERCIAL & FINANCIAL CHRONICLE--ABA Convention--Nov. 1935 40 BANKERS' CONVENTION. Railroads We approve the action of the econstruction Finance Corporation in making loans to the railroa -for he purpose of carrying on their essential services and urge the co nuati of the policy of thus extending financial aid when necess y. e appr e reasonable regulation of those agencies of transportatio ich compete with the railroads in order that such competition shall e )11 a fair basis. We approve the efforts of the Federal Co-ordinato of tailroads to bring a ut true co-ordination of railroad services, to eliminate so far as possible plication of facilities and to reduce the costs of operation. We believe that his great industry should be assured by wise laws that burdens or expense all not be put upon it while its income is restricted by rigid regulatio of rates. It is fundamental that, while any utility should be regulated i the public Intel est, it must be given the opportunity to collect the cost of he service rendered, including a fair return on the capital invested. W urge a liberal attitude towards the railroads for the good of the employ , the investor and the maintenan ce of conditions insuring the safety of p lic travel. TFIE RE OLUTIONS COMMITTEE: Francis Marion Law, President. Fi t Orval W. Adams, Chairman Bank National Bank, Houston, Te Management Commission, ExecuChairman. tive Vice-President Utah State NaC. W. Allendoerfer, Vice-Presid t tional Bank, Salt La,ke City, Utah. National Bank Division, Vi °- Fred I. Kent, Chairman Commerce President First National Ba , and Marine Commission, Director Kansas City, Mo. Bankers Trust Co., N. Y. City. Philip A. Benson, President Savings Frank M. Tott,on, Chairman Public Division, President Dime Savitigs Education Commission, Second Bank of Brooklyn, N. Y. Vice-President Chase National Fred B. Brady, President State nk 13ank, New York City. Division, Vice-President m- Robertson Griswold, Chairman Commerce Trust Co., Kansas ity, o. mittee on Taxation, Vice-President Merrel P. Callaway, Vice- esi ent Maryland Trust Co., Baltimore, Trust Division, Vice- es ent Md. Guaranty Trust Co., N.Y CI . Ronald Ransom, Executive ViceHenry Verdelin, Vice-les ent President, Fulton National Bank, American Institute of ing, Atlanta, Ga. ca,re First Service Corp.. nne- Max 13. Nahm, Vice-President, Citispoils, Minn. zens National Bank, Bowling David M.Auch, Vice-Preside tate Green. Ky. Secretaries Section. Secretar Ohio Andrew Price, President National Bankers Association, Colum s, O. Bank of Commerce,Seattle, Wash. Leonard P. Ayres, Chairman Eco- Thomas F. Wallace, President Farmnomic Polley Conunission, Vicoers & Mechanics Savings Bank, President Cleveland Trust Co., Minneapolis, Minn. Cleveland, Ohio. John G. Lonsdale, Chairman of the H. Lane Young, Chairman culBoard Mercantile-Commerce Bank; tural Commission, Executive. an& Trust Co., St. Louis, Mo. ager Citizens & Southern Nati nal Gurden Edwards, New York, N. Y.," Bank, Atlanta, Ga. Secretary. [The report was unanimously adopted.] Resolutions of Appreciation The following special resolutions were presented, and unanimously adopted: The American Bankers Associatitin takes this opportunity of expressink its appreciation of the high 4ervicAs‘to all banking rendered by its retiring President, Rudolf S. Hechti with tlte able counsel and assistance of First Vice-President Robert V. Inereing, a.nd Second Vice-President Tom It. Smith. We feel that their leadership. has been a stimulating influence n t only among bankers, but also the pultic during this period when a gene I return of confidence in tho characteriof banks, bankers and banking has been essential to the national welfare.. We express our thanks to the leadertiln public life who have given us t e benefit of their time aud coUnsel during this convention as speakers befolre our various meetings. We particularly wish to express and extend our good wishes to Sena r Carter Glass of Virginia whose health would not permit him to be with us o enable us to expres to him in person pur appreciation of his splen d services in behalf of sound banking. We also thank the New Orleans bankers, the local committee s,the hote the press and the citizens of New Orleans for the cordial treatment we ha e received at this meeting. This is the fount' convention our Associatio nh held in this city and we trust it is by no means the last. know, that the Banking Act of 1935 was largely due to the heroic and intelligent efforts put forth by this man and his loyal associates. A mandate has been given them by this convention, that mandate being that the independence of American banking must be preserved, that its foundations should be m intained and that any changes in its sitperstruc ture mu.st be a.shioned th an eye single to meeting soundly and adequately the demands of griculture, commerce and industry. "As a ark of respect, confidence and affectlen of the bankers of this Associ ion, I present to you, Mr. Hecht, some ieces of silver. You and your vely wife will use them as long as you th may live and then they are be handed down to your children and our children's children with the egend that the American Bankers A °elation highly valued and ac owledged the services of a faithful s vent. The measure of your seivice cannot yet be appraised, but I am re I voice the sentiment s of the great company of bankers who have wat ed you at your job When I hand in the verdict that you have made a eat President. We say to you 'Vale! Farewell!' but in our hearts we e saying, Ave! Ave Hail! " Mr. Hecht replied: "President Flem g, words could not ossibly express what my heart so warmly feels, and al I can do on beha of Mrs. lIecht and myself to thank you from the bottom of my heart for Your generosity.' Report of Committee on Nominations In accordance with the recommendations of the Nominating Committee. Robert V. Fleming, President Riggs National Bank, Washingto n, D. C.. was elected President, and Tom K. Smith, President Boatmen's National Bank, St. Louis, Mo., was elected First Vice-President for the coming year. E. G. Bennett, President First Security Bank of Idaho, Ogden, Utah, was recommended for the Second Vice-Presidenc y by the Nominating Committee. Orval W. Adams, Executive Vice-President Utah State National Bank, Salt Lake City, Utah, was nominated for this office from the floor by Charles F. Zimmerman, President First National Bank, Huntingdon, Pa.. and, following several seconds of both nominations. it was decided to have secret balloting to determine the choice of the convention. Later Mr. Bennett withdrew and a unanimous vote was cast for Mr. Adams at the final session. At a meeting of the Executive Council of the Association Nov. 14, Arthur B. Taylor, President Lorain County Savings & Trust Co., Elyria, Ohio, was elected Association Treasurer for the coming year. He succeeds Hal Y. Lemon, Vice-President National Bank of Detroit, who has served in that capacity for the past two years. The Council also re-elected F. N. Shepherd as Executive Manager of the Association. Debate Incident to the Presentation of the Report of the Nominating Committee [Second Day's Session Nov. 13] The next order on the program is the report of the Nominating Com mittee. Is the Chairman of the Nominating Committe e ready to report? Colonel Edens: Mr. President, Members of the Convention : The members of the Nominating Committee met yesterday aft,ernoon at 5 o'clock at the Roosevelt Hotel and remained in session until 7 o'clock. The 48 States and the District of Columbia were represented. After frank, free and full discussion, the Committee authorizes me to make the following recommendations to this convention for your officers: For President—Robert Vedder Fleming, President of the Riggs National Bank of Washington, D. C. For Vice-President--Tom K. Smith, President of the Boatmen's National Bank of St. Louis, Mo. For Second Vice-President--E. G. Bennett, President of the First Security Bank of Ogden. Utah. Mr. President, I shall at this time refrain from making the usual motion as to the adoption of this report, in order that you may ascertain if there are other nominations to be presented, as is provided for in the constitution. Charles F. Zimmerman (Pennsylvania): Mr. President, I move you that the election be held viva voce for the offices of President and First VicePresident, and that the election for Second Vice-President be deferred until after that action has been taken. Lewis A. Howell (Honesdale National Bank, Honesdale , Pa.): I second the motion. President Hecht: Gentlemen, it has been moved and seconded that we separate the election of the President and First Vice-Pr esident from the Presentation of Silver Service to Retiring Presiden report that has been submitted and first submit their names to you for Rudolph S. Hecht your consideration. What is your pleasure? All those in favor of that In recognition of his services as President of the American Bankers A motion will please say "Aye"; opposed, "No." The "Ayes" have it. ciation during the past year, Rudolf S. Hecht, Chairman of the Board Mr. Zimmerman: Mr. President, with the indulgence of the convention Hibernia National Bank, New Orleans, Louisiana, was presented I wish t,o place in nomination another candidate for with the office of Second silver service at the final session of the convention. Francis Marion Vice-Presi dent. Law, President of the First National Bank, Houston, Texas, who was Richard S. Hawes (First National I3ank, St. Louis): Mr. Mr. Chairman, Hecht's immediate predecessor aa President of the Association, I would suggest that the President and Vice-President have made the not been elected presentation. Mr. Law said: yet. I am sure Mr. Zimmerman's original motion was to that effect. "You have commissioned me to say a word to your retiring President I move that the Secretary of this meeting be requested to cast the ballot expressing your approval of and appreciation for the work of this convention for Mr. Fleming for President and Mr. he has acSmith for First complished in your behalf. It is a most pleasing as.signment. Vice-President. "The man who is now relinquishing the gavel to a worthy successor [The motion was duly seconded.] has been a faithful servant of the American Bankers Association for President Hecht: It has been moved and seconded that many years. the Secretary be At all times and in every capacity he has given his best without instructed to cast the ballot for Mr. Fleming as President and stint or SaVMr. Smith as ing. lle came into the high office of President unusually I First Vice-President. All those in favor of that motion well-equipped by will please say long experience in associational work. Moreover he was well steeped "Aye"; opposed, "No." Mr. Fleming and Mr. Smith in are unanimously the traditions, ideals and principles which have ever been the back-log lected as President and First Vice-Prosident, respective of ly, if the Secretary the American Bankers Association and which have made it great. It was ill so report. in the City of Washington, 13 months ago, that he was elected President Mr. Dunkerley: The vote has been cast, Mr. President. and I doubt if there has been an hour during Ms waking moments Mr. Zimmerman: Mr. President, I wish to place in nominatio since n another that time until now when he has not been giving his best thought ndidate for the office of Second Vice-Prtsident, and ask for the and indulgence energy in promoting the welfare of this Association. qf the convention to preface the nomination with a few remarks. . . . "It would be difficult to say which was the more fortunate, the 4, In the meeting of the Nominating Committee yesterday, I Associamade a few tion or Mr. Hecht himself. The Association was indeed fortunate r marks on behalf of the rights of the rank and file of our member in banks having a leader of his caliber and mental stature during this der the constitution of the American Bankers Association, itnportant from which past year. Likewise he was fortunate in that he came upon the I hould like to be permitted to quote sevevral excerpts. I now stage at quote from a time when his unusual talents were to be challenged to nly remarks yesterday: the utmost in meeting a situation full of possibilities for good or evil. He 1"We are all cognizant of the fact that recent developments would not have changed have had it otherwise. the outlook from what it has been heretofore regarding the American bank"You have been told, but it bears retelling, that he has spent ing system. We can readily understand that the greatest practically issue we face the preservation of the independence of the bankers of America. is his entire time during his Presidential term in active service in your behalf. "We have a call to-day to discharge the responsibility that By air commuting back and forth between Washingto n and New Orleans us, so as to preserve the best interests of the American Bankers rests upon he was able to spend some, but not all, of his week-ends Unprecedented conditions surround us in this meeting. We Association. with his family have to deal and v.-ith him bank. Satisfaction is his as it is given to with them on their merits. few men to realize "So far am I from believing that anything we are doing hat kis labors have not been in vain. I only tell you here involves what you already questions of personality that I atnnot accommodate myself to the thought https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t i' .3', ,!,-°8., , GENERAL SESSION. A period of inflation, characterized by abnormally rapid advances in the general level of the prices for commodities, is a phenomenon that develops when the demand for goods is so active that would-be buyers bid up the prices of the goods in order to get them, while sellers are reluctant to part with them. It is almost impossible for an inflationary boom based on the confidence of a period of credit expansion to get under way in a country where the facilities of production are efficient, but are operating far below full capacity, as they are here. me reason is that under such conditions demands for goods at higher prices are promptly met by increased outputs which tend to retard further price advances. When our productive plant is operating once more at normal capacity the prospects will be quite different from what they are in 1935, or promise to be in 1936. Summary and Conclusion In summary and conclusion your Commission points out that we have already had a major measure of recovery in many of those parts of our national economy that are dependent on individual consumer purchasing power. The parts of our economy in which we have had the least recovery, and which are mainly responsible for most of our continuing large volume of unemployment, are those of construction and the heavy industries which in the main make goods for corporations. These goods are mostly bought from the proceeds of long-term bond issues or mortgages, and the industries are operating at low capacity because the flow of new long-term corporate financing is greatly restricted. Your Commission is confident that no economic barrier now exists which should prevent a resumption of this flow of long-term corporate financing. It believes that when it is restored the activity and output of these industries will be greatly increased, unemployment will be sharply diminished, a balanced recovery will be under way, and the people of this Nation will resume their traditional task of building and rebuilding America. Your Conunission believes that these constructive developments will be facilitated, assured and hastened in proportion as progress is made toward securing a balancing of our Federal budget and expenditures. Economic Policy Commission: Leonard P. Ayres, Vice-President Cleveland Trust Co., Cleveland, Ohio Chairman. Walter H. Bennett, President Emigrant Industrial Savings 13ank, New York City. A. P. Giannini, Chairman of Board Bank of America N.T. & S.A., San Francisco. James It. Leave11, President Continental Illinois National Bank & Trust Co., Chicago. Theodore Wold, President Northwestern National 13ank & Trust Co., Minneapolis, Minn. Nathan Adams, President First National Bank, Dallas, Texa.s. Thomas B. McAdams, Pres. Union Trust Co. of Uaryland, Baltimore. Max B. Nahm, Vice-President Citizens National lhink, Bowling Green, Kentucky. 4Huntingdon, Pa. Cha'rlts F.Zimnaerman, President First National BaniF J. Stewart I3aker, Chairman of Board Bank of the Ma attan Company, New York City. is, Mo. R. S. Hawes, Vice-President First National Bank, St. Walter S. McLucas, President National Bank of Detroit, etroit, Mich. ry. City, Secr York New St., Gurden Edwards, 22 East 40th Report of Official Acts and Proceedings of Executive Council, Presented by Raymond Dunkerley Since the adjournment of the Convention at Washington, D. ., the C.. Executive Council has held meetings, Oct. 25 1934, at Washington, April 16 and 17 at Augusta, Ga., and Nov. 11 at New Orleans. on, At the meeting in Washington, the Council elected Hal Y. Le Treasurer, and F. N. Shepherd, Executive Manager; and, in accorda ce with the nominations of the Nominating Committee, elected members f various coinmittees and Vice-Presidents for foreign countries; and approv the appropriations recommended by the Financ,e Committee. The sessions at Augusta, Ga., were devoted to the approval of Committee and Council appointments, the creation of and granting of authority to the Special Committee on the Banking Act of 1935; the detailed reports from and consideration of the work of the Divisions, Sections, Commissions, and Committees of the Association; the review and approval of various acts affecting legislation, all of which are covered in various Committee reports, and a variety of routine business of the Association. Resolutions to the meinory of past presidents, John H. Puelicher and Rome C. Stephenson were drawn, and engrossed copies were sent to the bereaved families. The Executive Council recommends that Article X, Section 1, last paragraph, of the Constitution be amended by substituting the following: "Members of the Association may enroll as regular members of but one Division in which they shall have full powers and privileges of membership; but may also enroll as associate members of any other Division or Divisions. An associate member of a Division shall have no power to vote but an officer, director, trustee, -manager or partner of an associate member of any Division shall have such power to hold office or committee membership including the right to vote as officer or committee member as shall be granted by the by-laws of the Division." [A motion by President Hecht to approve the report was carried.] Report of Committee on Resolutions- -Government Urged to Retire from Control and Operation of Industrial, Commercial and Financial Enterprise Tile report of the Committee on Resolutions was presented as follows by Francis Marion Law, Chairman: The Business Situation of conPrevailing business sentiment in the United States to-day is one There have been large viction that recovery is making vigorous progress. populathe of portions groat of increases in the consumer purchasing power those lines which supply goods tion and broad recovery in production in have clearly stimulated developments These retail. widely purchased at create widening business many lines of industrial activity and helped confidence. in widespread unOn the other hand, there has been but little decrease has not ademployment and the total volume of industrial production vanced during the year. These adverse conditions characterize particularly by new financed normally are the heavy industries and construction that investment funds, the flow of which still suffers an almost complete cessation https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 39 \ in this country, although there is an abundance of private capital awaiting opportunity for employment. It is our opinion that a concentration of effort on the part of both Government and private business initiative in stimulating the flow of new capital issues for private undertakings in these still depressed portions of our national economy is essential to bring about a balanced recovery in all lines and resultant important decreases in unemployment. On behalf of banking we are able to report a complete restoration of public confidence. This has put it in the position where it can function fully and vigorously in playing its full economic part in the progress of recovery. The passage of a generally constructive banking law in the Banking Act of 1935 has stabilized the banking situation and enabled bankers to devote undivided attention to the normal administration of their institutions in promoting the business and public welfare of their communities. We feel that it is a particularly important feature of this law that it aims to create through the revision of the Federal Reserve Board a Supreme Court of Finance which, with the non-politica,1 appointment of exceptionally competent men, should ctmstitute one of the greatest forward steps in building a sound banking and credit system for this country. Retirement of Government from Business With the passing of emergency conditions from a large portion of our rrational economy, and with increasing evidence that the full restoration of industrial enterprise under private finance and initiative is essential to complete the return of recovery, we'believe the time is at hand for recognition as a matter of national polq of the need for the retireinent of the possible from the field of control and Federal Government as rapidly operation of the nation's industrial, commercial and financial enterprise into which it has entered so widely. It is our conviction that preponderant public opinion in this nation is against any form of socializatiori of our national industry, commerce or finance. We believe that the ottly fundamental cure of unemploytnent is through the stimulation of re-rnployinent by the removal of unjustified barriers to the free play of pr ate enterprise and individual initiative. The G'verntnent in Banking We particularly emphasize he desirability of the retirement of Governnding credits of various types which can be ment from those fields of e adequately served by priva y owned institutions. We recognize that the exigencies of the now passi g depression made necessary a large participation by Government for a t e in the task of meeting the public's emergency financial needs. We beli e those conditions have been largely remedied and that the obligation ow rests upon the banks and other financial agencies to demonstrate o the people of this country that they are fully able and willing to mee all demands upon them for sound credit co-operation. It is our duty a bankers to facilitate in every effective way the retirement of Governme agencies from credit activiti by promoting public understanding of the roper function of privately owned banking. Government Expenditures e of the most serious dangers confronting the nation We believe that to-day is the illusio which appears to be widespread among portions of our people that Gover ment expenditure is of itself a cure for economic ills. There are well de nod though limited fields within which Government expenditures are j tilled. While the deficits of the past six years which have carried our irect national debt to a total of 29 billion dollars in part have been justi ed by efforts to relieve human suffering and deprivation, allowed to obscure the fact that definite efforts to return this should not to a balanced ational budget should be the prime consideration of sound policy. We believe that this procedure is now the surest national fis way of relie ng human suffering and deprivation, chiefly because of the stimulus an confidence it would give to private industry and trade whose normal act ities should be the fundamental source of employment and security. Taxation The 1 rease of taxes, both Federal, State and municipal, throughout the nat n, is an outstanding public problem from which no class of our people ltimately can remain exempt. While a large portion of the inthe burden of taxes since the depression has been caused by efforts crease o rel ve misfortune resulting therefrom, it is also a fact that, apart from t is, the costs of our multiform government have in many cases long been u tily increasing. Factors in this have been the increase in functions and act 'Ries assumed by government, the relatively high costs of such operation* when performed ucder government auspices, the inevitable wastefujneilp of bureaucratic oragnizations and the increasing demands of the public', upon government. Unless the upward trend of taxes is curbed, I constitute such a heavy btzden as to repress individual initiative they and ent prise and thereby increase the very types of human misfortunes in so large part are aimed to relieve. In the long run the burwhich th must fall not upon any one class but upon all classes and they den of ta therefore c nstitute a problem and a menace for all our people. Postal Savings We enders the statement of' President Hecht in his address to this convention, that e competition of the Postal Savings System with privatelYrough the relatively high interest rate and liberal withowned banks allowed its depositors is inequitable. Every depositor drawal privileg can now get ins ance for his deposits up to $5,000 and we feel the need for System has really passed, except perhaps in such comthe Postal Sa munities as do not enjoy other banking facilities. A serious effort should therefore be made at the COMing session of Congress to at least modify, if not abolish, the law governing the Postal Savings System. Restriction on Bank Charters We are also wholly in accord with President Hecht's statement, in his address before this convention Tuesday [Nov. 12], relative to the necessity of limiting the chartering of new banks rigidly in accordance with the economic needs of the country. Every effort should be made by bankers, and they should enlist the support of public opinion, to prevent a new overproduction of banks through the indiscriminate chartering of new banks in places which are either not large enough to support a bank or in which there already are available sufficient banking facilities to take care of their reasonable requirements. We commend those provisions of the Banking Act of 1935 which give the Federal Deposit Instvance Corporation new authority to determine whether there exists an economic necessity for the creation of a new bank before a newly-chartered institution shall be admitted to the benefits of the Insurance Fund. We believe the banking profession should give the Corporation the fullest co-operation in this connection at all times. ,9'ct.,, 1 ;is, 9 e ,s. , -,='•s; 0&e --,i -% ??,,, ie,t" , 14,,/4 :/ -. •c7„.10_ 4.' \ 48,,F,„: 4Ft, ,,,, \ \g4 GENERAL SESSION. that the discharge of our duty attaches itself in the first instance directly to one or other of these three splendid men (meaning those who had been proposed for the office of Second Vice-President). "I have been most ardent in my hope that such principles as are represented in the candidacies of these men shall be understood by those who compose the intelligent electorate of the American I3ankers Association, and that we should discharge our duty in the light of such principles as those of which these men are the exponents. "In looking for a guide as to the fairness of the situation I needed no outside answer. As for the basis of the fitness of the suggestion to be offered before this Committee, I refer to the constitution of the American Bankers Association. We are under obligation to the fathers of the American Bankers Association for having anticipated the very type of question we face here to-day so that responsibility need not rest upon us of taking a position at variance with the best interests of the American I3ankers Association. "I turn, therefore, to article III of the constitution which says, 'Election of officers shall be by ballot, but when a single nominee is presented for any office the ballot may be dispensed with and the vote taken viva voce.' "In article V of the constitution which has to do with the discretion of the Nominating Committee is this sentence: 'The Committee shall recommend a candidate or candidates for President and First and Second VicePresidents, who shall report its recommendations at the time fixed in the program for the nomination of officers.'" That is the end of the quotation from my remarks made yesterday. At that time, those of us who have been considering tbe principles of which the man whose name I am going to place before you has been the outstanding exponent in recent months, presented a resolution to the effect that all three of the men be presented to this convention for your decision, based upon the principles which they represent. The motion offered before the Committee was thereupon tabled viva voce, and those of us who were of the persuasion to which I have referred ceased thereupon to have part in the fmther deliverations of the Committee. Gentlemen, I just wish to take a moment to refer to the fact that we must never forget in this country that the constitutional rights that have been disclosed to our several States, and under which our great State chartered banks and State banking systems have grown up, have been a foundation stone in the remarkable growth of this country. Despite all other policies, or theories that may be advanced for the future of American banking, we should give our allegiance to the preservation of that principle so far as it is within our power. The system has not beea without its imperfections. But in view of the fact that wo are talking about principles, I do not wish to take your time in discussing any further the consideratioias that enter into this question. I now want to present just ono paragraph from the latest letter that I received before leaving my home for the convention, from the man whose name I wish to present at this time. It is an index of his spirit. It is an index of all that he exemplifies in behalf of the future structure of banking in America. This was just a little peisonal message: "There isn't any reason in the world why you should have supported me, other than for the pure matter of principle. In a letter you wrote the other day, you said that you were nothing more than a country banker. So am I. The country bankers, however, comprise the majority membership of the American Bankers Association, and if it were not for this class, the American system of banking would soon vanish. It has always been a mystery to me why the big city bankers have not as yet seen the handwriting on the wall, that unification of the system means the vanishing of our great independent system, and the banishing of this system means the socialization not only of the big and little banks. but of the Government as well. So we are united, because we love America, and its divinely inspired constitution." Mr. President, I wish to place in nomination the name of the writer of this letter, the friend of all of us without exception, for the office of Second Vice-President, Orval W. Adams, Vice-President of the Utah State National Bank of Salt Lake City, Utah. [The nomination was seconded by various delegates.] President liecht: Gentlemen, before we proceed to the question, we have to do two things: First of all, I don't believe any formal report is now before this meeting from the Nominating Committee. Richard S. Ilawes (First National Bank, St. Louis): Mr. President and Fellow Delegates. I arise as one of the old-timers of the American Bankers Association. For 30 years I have been interested in it and have had something to do with its affairs. The parade of States which has just gone before is an interesting exhibit of the independence of the American bankers, but just remember when you consider the problem before you that this is not a fight between independent bankers and city bankers, or any other kind of bankers. ... Now, men,remember when you cast your ballots for these two gentlemen —and I shall not measure the capacity of either one of them, both of them being excellent, high-standing bankers of America—that, in each State in the Union, there was held a caucus called at the State Conventions, and in that caucus sat the country banker, the city banker, the independent banker —and I wouldn't know what an independent banker Is if you were to ask me. I think we are all independent. I have tried to be independent in all my views all my life. But in these caucuses sat these men, and they elected one of their chosen men as their representative, and I challenge again any man within tho hearing of my voice to read the names on the Nominating Committee and say they are a crowd of men who could be led by the nose by anybody. . If you repudiate your Nominating Committee to-day, the time . .come when you will rue the act, and the American Bankers Association will will feel its effects for many years to come. I admit the right of suffrage for presentation of names, but I still cherish the traditions of the Association, the history of the Association, to such an extent that I want to second the nomination of Mr. Bennett and ask your loyal support of him for Second Vice-President. President Hecht: Gentlemen, we aro confronted here with a really serious and complicated technical question, and I ask your help and consideration in trying to solve it. The Chair is interested in only one thing and that is to have a fair election between two competent men, whose names have been presented. As you know, we have a registration of somewhere between 3,500 and 4,000 people at this meeting. Out of that number, there are only about 1,100 that have a right to vote. There are in this audience certainly a large number of people who are guests, but not delegates, because only one man can vote from each bank. The hour is late. The Constitution provides that the voting must now be by secret ballot. The ballots are prepared. It seems to me that the only way in which we can properly check (and I am only making this suggestion; I have no desire to do anything, but to ask your opinion on it) and the fairest way to give every delegate who has a right to vote a chance to cast his ballot, would be to recess this meeting because we have to get out of here within the hour, or before two o'clock, and go to the registration room and set aside a corner there, where some one will have the official list of those who have a right to vote, and fix either one definite hour, or I think it would be better to say from two to five, or whatever you want. We would of course appoint tellers, representing each of the two candidates. In that way we can give everyone here an opportunity to vote, without our now having to ask those who cannot vote to leave the theatre, and then check all of the names, because we do want to be absolutely fair. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 41 It seems to me since, in the generation I have been in the American •Bankers Association, this is the first time this question has come before it in this way,that we ought to do it right, and I want you to decide what you think is right. But I do believe that in all fairness, and for simplicity's sake, we ought to be sure that everyone that has a right to vote will have an opportunity to vote. The Chair is ready to hear any suggestions from the floor. William S. Elliott (Bank of Canton, Canton, Ga.): Mr. Pre,sident, as one who is deeply interested in this proposition, as I am sure all other delegates are interested, and as one who has been impressed with the fairness and the courtesy manife,sted by our splendid President on this occasion, I want to say that I thoroughly endorse the suggestion made by the President, and I make a motion to that effect. [The motion was seconded by B. F. Clark, State Bank, Denver, Colo.] The question was called for. President Hecht: There are two other questions, gentlemen. First of all, my attention is called to the fact that the nominations are not closed, but I take it that if there were any other names to be offered they would have been presented. Mr. Elliott: I move the nominations be closed. President Hecht: Mr. Smith of Salt Lake asked for the floor. Charles L. Smith (First National Bank, Salt Lake City, Utah): I occupy the position of representing the State which is presenting the two candidates to this convention. This matter has been thoroughly discussed in the State of Utah. It was frankly discussed and voted upon at the State convention. I was elected as the member of the Nominating Committee, the alternate member, and our instructions were to support E. G. Bennett. At that meeting we had before us the name of Orval W. Adams also. A very full, free, frank discussion was held and this entire matter of State banking versus branch banking was had. Mr. Bennett received a clear-cut majority and in so doing he received a majority of the votes of the non-member State banks of that State. Ile has their hearty support. He has been the friend of the unit banker. He has done more to preserve the interests of the unit bankers in that State and in surrounding States than any other banker we have. He has been responsible for the enactment of branch banking laws along lines which protect to the full the unit bankers. The law that Mr. Bennett was instrumental in endorsing and having passed provided that no conununity already served with banking facilities could be entered by a branch banking institution, and that no bank could be established in a competing point for the purpose of being taken over by a branch banking organization. This vote was not only settled in the State of Utah, but it was taken to surrounding States, for instance, the State of Idaho, in which Mr. 13ennett operates. The sa,me campaign was carried on there as between Mr. Bennett and Mr. Adams, and Mr. Bennett secured the unanimous support of all those in attendance at the convention. The only ones who even considered any opposition to Mr. Bennett were two competing branch bank organizations. The support of the unit bankers in the State of Idaho was absolutely unanimous in favor of Mr. Bennett. The unit banker has no better friend than Mr. Bennett and I am distressed that the question should be raised here of denying the right of representation to a man simply because he believes in one school of thought which in our part of the country is absolutely essential, to provide proper banking facilities. I urge upon you, gentlemen, to carry out the recommendations of the Nominating Committee, who have considered tlais matter for months. They were elected months ago. They have corresponded between themselves on the matter. They have studied the situation, and after careful deliberation they decided that Mr. Bennett was the candidate who should be presented to you. On behalf of the State of Utah, I urge this election. He is their choice, by mandate and vote of their convention. I further urge it upon you as the mandate from the Nominating Committee yesterday. T. R. Preston (Hamilton National Bank, Chattanooga): I want to say just one word at this point, Mr. President. I hope there will be some simpler method of arriving at the wishes of the people of this convention suggested than voting by secret ballot. I think that we are attempting to break a precedent here, and it is a very serious matter. The Nominating Committee is made up of members who come, as others have said, from every State of the Union. All of them could have been instructed, and some of them were instructed. In that way I think they have a better picture of the situation than we could have. You represent everybody by having the States do this. They can instruct their delegates. 1 want to say to you now, as Dick Hawes has said, that if we break a precedent that this Association has followed for many years so successfully, we may regret it. I don't know of any time in its history when this Association has been of greater benefit to the banks and to the public than in the past few years. They have rendered a service to the public that we will be a long time in repaying. . . . Before I take my seat, I want to say again, I hope that we may find some simpler method of expressing our wishes, rather than the long and tedious method of balloting by secret ballot. I desire to heartily second and commend the report of your Nominating Committee, which recommends E. G. Bennett. I second bis nomination. [Calls for question on the motion.] President Hecht: I want to answer Mr. Preston by saying that much as I would like to see a simpler means of deciding this question, the constitution absolutely prohibits me from doing anything except telling you that two names being before you, only by a secret ballot, separately cast by those specifically authorized to cast their ballot by being registered as delegates from their banks, and not as guests, can this question be decided. I also want to again say I have no desire to cut short the discussion. I have no desire to tell you how to handle this election, but I don't see how we can go on much longer here. We must be out of here by 2 o'clock. I arn going to take the liberty of saying that if this question must be decided now, I think it ought to be decided so that every one who has a right to vote may have a chance to cast his ballot. I would like to ask, to simplify things, for some one to please make a motion to close the nomination, so we may be rid of that technicality. Ira A. Moore (Peoples National Bank, Grand Rapids, Mich.): Mr. President, I move that the nominations be closed. [The motion was seconded by L. A. Howell (the Honesdale National Bank, Honesdale, Pa.)]. President Hecht: It is moved and seconded that the nominations be closed and the names of Mr. Bennett and Mr. Adams be put before you. All those in favor of that motion will please say, "Aye," opposed, "No." It is so ordered. There is already before you a motion, which followed the suggestion that I made, that instead of staying here and separating those who have no right to vote, asking them to leave, that we take the tedious process of balloting by secret ballot at some later designated time, and I am going to insist that every name be checked, because this election is going to be conducted fairly. And I don't see how we could do that now, even if we stayed here another hour. I therefore strongly recommend to you that we do it the other way. Then there cannot be any complaint that someone got an advantage over the other. I hope that that motion will prevail, but it is now open for discussion. As I understand the motion it is that from 2 o'clock to 5 o'clock this afternoon in the registration room a section be set aside where the staff will be prepareci to check everY narne that is on that list, and where everyone who is entitled r-"Orr Ey J104,1e. 42 BANKERS' CONVENTION. to vote can come in and cast his secret ballot. Is that motion correctly stated? Mr. Elliott: That is the correct motion, Mr. President. President Hecht: That motion is now open for discussion. Col. W. G. Edens (Terminal National Bank, Chitago, Ill.): Will the members of the Nominating Committee have a right to be beard where you are going to cast this ballot ? Members: No. President Hecht: No. Mr. Edens: It was stated from the platform by Mr. Zinamerman, who is also my friend, that after his resolution was by a vote of about 47 to 2 laid on the table, the gentlemen representing the candidacy of Mr. Adams took no further part in the deliberations of the Coramittee. I think it is only fair to say tbat as Chairman of the Committee I noted that they voted on each subsequent motion or proposition that came before the Committee, and I wanted the delegates who are going to vote on this proposition to know the nianner in which that meeting was conducted. I challenge any one here to refute tbat, and I would like to have a roll call of the members of the Nominating Committee, if we are not going to have a chance to be heard on this after the action on that motion. Mr. Elliott: I rise to a question of personal privilege. In the interests of accuracy, I want to say this: I was one of the members who took no further part in tbe proceedings except we did protest when the majority of that committee attempted to vote a resolution through which stated that it was the unanimous opinion of that committee that Mr. Bennett was the choice of that committee. That is tbe only part we took in that. [Calls for the question.] Col. Edens: That motion to have a unanimous ballot in the report was made by a gentlemen from Virginia. I do not know for whom he voted but he thought as a matter of the best interests of this Association that as heretofore, if possible, we should come in to this convention with a unanimous report. I think each of the men on that Committee was actuated, not by a thought as to what individual or what geographical location was involved . . . but only in tbe interests of all the members of tbe Association. Fred J. Paro (Mercantile Commerce 13ank & Trust Co., St. Louis, Mo.): I am heartily in sympathy with the suggestions made by the Chairman and the motion that has been put before the house. I believe, however, that motion ought to incorporate the selection of three tellers, one for Mr. Bennett and one for Mr. Adams. President Hecht: I think that is a very proper suggestion. That was the Chair's intention. I mentioned awhile ago that that would be done. If the maker of that motion will permit that amendment I think it might be better to have five and have two from Mr. Bennett's side and two from Mr. Adams's side, and then one to be appointed by the Chair, if that is agreeable. Mr. Elliott: Mr. President, with the permission of the Chair and tbe Permission of the seconder of tbis motion, I will accept the amendment. President Hecht: Before we vote on this motion I want to just clear up one other point so that when you vote on this and it is carried we can adjourn. ... We will designate a corner in the Registration room, and if it is agreeable to you then, the meeting will not adjourn but will recess and we will not meet again to-night but will meet again to-morrow at the regular hour. Is that agreeable? Members: High t I President Hecht: All right. I am now going to put that motion. All those in favor of the motion which specifies that between tbe bours of 2 and 6, in tbe Gold Room, tbe Registration Room at the Roosevelt Hotel, every delegate who is registered and who represents his bank as a delegate will cast his secret ballot. The tellers will be appointed,two of Mr. Adams's choice,two of Mr. Bennett's and one individual designated by the Chairman. All those in favor of that motion will please say "aye:" opposed, "no." There seems to be one dissenting vote. The "ayes" have it. The meeting adjourned at 1.45 o'clock. [Final Day's Session Nov. 14] President Hecht: The unfinished business of this session this morning is the election of officers. After our adjournment yesterday, when I returned to the hotel, I received a communication from Mr. Bennett to the effect that he did not wish any election to be held, but wanted to withdraw his name. I will now read you the letter which I received from Mr. Bennett: Mr. Bennett's letter of withdrawal: New Orleans, La. Nov. 13 1935. Mr. R. S. Hecht. President, American Bankers Association, New Orleans, La. Dear Mr. Hecht: Naturally I felt highly honored when the Nominating Committee, consisting of one duly elected representative from every State in the Union, presented my name as a candidate for the Second Vice-Presidency of the Association. These nominating delegates were elected at the State conventions where practically full representation was had of the banks of their respective States, and the delegates thus elected have had some intervening months to give mature consideration to this question. My feeling of appreciation was the more accentuated because the movement to have me nominated originated with some of my friends before I was consulted about it, and I have not conducted any sort of c,ampaign. I should of course have been very happy to have served the Association had it been the unanimous desire of the members that I do so, but since another name was presented from the floor, and since it was vetry evident that there would have been a sharp division in the Association over this election, I feel that in the interest of peace and harmony, and for the good of the Association, it is better that no such contest take place. and I therefore desire to formally withdraw my name from any further consideration for this office. Please convey to the members of the Nominating Committee my deep appreciation of the honor which they did me in recommending my name to the convention, and I trust that they will feel what I have done Is, under the circumstances, the proper thing and for the best interests of the Asaociation. Accept for yourself my sincere appreciation of the impartial manner in which you handled the difficult situation. Please also convey to incoming President Fleming my assurance that in the future, as in the past, the Association can command my services and whole-hearted support whenever I can be of service to the banking fraternity. To Vice-President Adams I have already extended my personal congratulations. Cordially yours, E. G. BENNETT. Gentlemen of the Convention: I desire to Mr. Hawes: Mr. President and arise and make a motion that the Secretary of this cony ntion be instructed to cast its ballot for that distinguished Western banker, Orval Adams, for https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Second Vice-President, and I pledge my hearty support to him, through t Chair, in his endeavors. President Hecht: Is there a second to the motion? iThe motion was seconded by Mark Homes.] President Flecht: It is moved and seconded that the Secretary be instructed to cast a ballot for Mr. Adams for Second Vice-President. All those in favor say "Aye;" contrary,"No." The "Ayes" have it. Mr. Dunkerley: Mr. President, the vote has been cast. President Hecht: Mr. Adams is duly elected Second Vice-President of this Association. Remarks of President-Elect Robert V. Fleming, President and Chairman of the Board of the Riggs National Bank, Washingto, D. C.—Proposed Regional Conferences Fellow Members of the American Bankers Association: You have paid me the highest honor that can be conferred by this great Association and I, therefore, desire to express my deep appreciation of your confidence. I accept this high office with a full realization of ita obligations and responsibilities. I sincerely trust that through this opportunity for useful service and leadership, which will be shared by rne with the members of my administration, the affairs of our Association will be conducted in a manner which will justify the trust you have placed in us. Our Association has co-operated wherever it could properly do so in every measure for National recovery. It has offered constructive recommendations for such changes in banking laws as we recognized were necessary, and we now have a better law under which to operate. The Banking Act of 1935 affords us opportunities for broader service and, at the same time, retains the fundamentals which we believe are so vital to our national welfare and which have played a large part in bringing our country, in a comparatively short space of time, to the position of the greatest industrial nation on the earth. In order that our Association may be of the greatest possibile usefulness. It will be one of the objectives of my administration to take to our membership the broad services made available through our highly organized committees and well-trained staff. I believe this can best be accomplished by the establishinent of regional conferences, to be held in strategic sections of the country and embracing the managerial, legislative and operating problems confronted by all types and classes of banks represented in our membership, which will be in addition to the established trust and savings conferences. These will be strictly business sessions designed to acquaint bankers with the broad principles under which we can now operate. There will also be forums or clinics on specific questions of management and operation which should promote a better understanding of the best methods of operating our banks and at the same time enable us to render more efficient service to the public. This is one side of otu. program which I consider important; but there is another side equally vital—the question of public relations—which ?I consider essential in order that the banks of the country may function to the fullest extent. I feel it is necessary that the public have a thorough understanding of the functions of banks, what they can do and what they cannot do, for it must bo recognized that to many people the business of banking is still somewhat of a mystery. I believe we should frankly explain these functions to the public, acquaint them with the laws under which we operate and emphasize the vital part which banks play in the economic life of the nation. Therefore, in order that there may be the fullest co-operation and understanding between the banks and the people of the country, it will also be one of our. objectives to take the mystery out of banking wherever it exists in the public mind. A plan of action has been formulated and within the next few weeks you will be acquainted with the details of this program. On proposals affecting banking and the public interest, I believe it is our duty to take a comtructive position, supporting all measures which we believe are ecoonmically sound and which will assist in re.covery and in the stability of the country. On the other hand, I believe it is also constructive to oppose all measures which we believe are unsound and not based upon the fundamental traditions of America. In these undertakings I pledge you every effort at my command and I am sure that my administration will have the same fine co-operation which you have given my predecessors in office. In united effort I know we can confidently face the problenas of the future San Francisco Chosen as 1936 Convention City At the concluding session of the General Convention (Nov. 14), President Hecht made the following remarks: President Hecht: We have an invitation from San Francisco which the Secretary will present. Mr. Dunkerley: This is from C. K. McIntosh, President ot the San Francisco Clearing House Association: "I have the pleasure of extending to you the cordial invitation' of the San Francisco Clearing House Association to hold the 1936 convention of the American Bankers Association in San Francisco." Mr. Dunkerley: I have another invitation from Angelo J. Rossi, Mayor cot San Francisco. In fact, we have several invitations from many of the civic organizations in San Francisco to hold our convention there next year. President Hecht: Gentlemen, you have heard the invitation from San Francisco. A. P. Giannini (San Francisco): I move you, Mr. Chairman, that the invitation of the Clearing House of San Francisco, and of the civic authorities of San Francisco, to hold the A. B. A. convention of 1936 in San Francisco be accepted, and that the President and Executive Manager be instructed to set the dates and to make such other detailed arrangements as may be necessary. President Hecth: Gentlemen, you have heard the motion. Is there any second? A.L.Lathrop (Union Bank & Trust Co., Los Angeles): I have the honor of seconding that motion. President Hecht: It has been moved and seconded that the invitation of San Francisco be accepted under the conditions named by Mr. Giannini. Is there any discussion? If not, all those in favor please say "Aye;" opposed, "No." The invitation of San Francisco is accepted under the conditions named. REPORT OF COMMITTEE ON THE STUDY OF ADEQUACY OF BANKING SERVICE IN MISSOURI FORTY-SEVENTH ANNUAL CONVENTION MISSOURI BANKERS ASSOCIATION https://fraser.stlouisfed.org L Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis REPORT OF COMMITTEE ON THE STUDY OF ADEQUACY OF BANKING SERVICE IN MISSOURI FORTY-SEVENTH ANNUAL CONVENTION MISSOURI BANKERS ASSOCIATION In the spring of 1936 President Allendoerfer appointed a Committee on the Study of Adequacy of Banking Service in Missouri composed of R. R. Calkins, Clarence Evans, G. R. Fredrick, F. W. Pendleton, W. S. Pettit, R. B. Price and J. C. Welman, Chairman. These members were reappointed by President Major after his election in May, 1936. In July, 1936, G. R. Fredrick resigned from the Committee and Clem T. Kelly was appointed to succeed him. The Committee decided to approach its work with the view of studying two major questions, namely: I. Question of whether banking service in Missouri is adequate, and if not, in what respect is'it inadequate? II. If not adequate, what are the available remedies? It was decided that for the purpose of studying the "adequacy of banking service" we would consider the following items as the most essential in banking service: 1. Checking account facilities. 2. Facilities for cashing checks. 3. Facilities for making change. 4. Facilities for deposit of money. 5. Loan facilities. 6. Facilities for transfer of money. In determining the scope of our study we reached the conclusion that we could and should assume that banking service was adequate in towns or cities in which chartered banks were operating at the time of the beginning of this study. We realized that there might have been isolated cases of towns or cities in which a bank was operating where banking service might be inadequate in some respects. However, we believed that this was true only in a few cases and would have no importance in connection with our study. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 3 Accordingly, we decided to limit the study to towns or cities in which there are no chartered banks. We obtained a list of towns and cities which in 1926 had one or more state banks, and which in 1936 had no banks. We found that in Missouri there were 340 of such towns and that in the year 1926 they were being served by 400 state banks located therein. You will note that the study was confined to towns and cities now without banks in which one or more state banks were located in 1926. This was done because investigation disclosed that there were only four national banks operating in these 340 towns and cities in 1926 and for the further reason that there are only four towns and cities now without banks but which had one or more national banks in 1926 and no state banks. We therefore concluded that the study could not be materially affected by the omission of national banks and for the purpose of more easily obtaining uniform information they were disregarded. We next obtained the following information relative to the towns and cities in the above described category: • Number of towns and cities without banking facilities at the present time in which one or more state banks were operating in 1926 340 Number of counties affected 105 (None of the 340 towns studied being located in the other 9 counties.) Average population of such towns or cities 365 Number of state banks operating in such 340 towns and cities in 1926 400 Average resources of such 400 banks in 1926 $107,670 Average distance in miles from such towns and cities to the nearest bank present time at the 11 Number of such towns over 11 miles from bank at present time 120 Number of such towns less than 11 miles from bank at present time 220 Greatest number of miles of any of such towns and cities to nearest bank at present time 25 Smallest number of miles of any of such towns and cities to nearest bank at present time 1 Number of such towns and cities having hard-surfaced roads the complete distance to nearest bank at present time 293 Number of such towns and cities not having hard-surfaced roads the complete distance to nearest bank at present time 47 (Note: Some of these towns and cities have a partial mileage of hard-surfaced roads to the nearest bank at present time.) Number of such towns and cities that have postal savings offices operating therein at present time 32 Average amount of postal savings deposits per town or city in the 32 such towns and cities $ 17,062 Average number per county of P. C. A. loans made during 1935 in the 105 counties affected 41 Average amount of such loans $ 552 Average amount per county $ 22,600 (Note: The above figures include all P. C. A. loans made in the entire county. Naturally a part of these loans were made in the vicinity of towns and cities where banks are operating. We have been unable to allocate the number and amount of loans made during 1935 to the 340 towns being studied. If we should assume that the loans were all made in the vicinity of the 340 towns and cities without bank- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4 ing facilities being studied, it would mean an average number made during 1935 per town or city of 13 P. C. A. loans, and an average amount per city of $6,647. Obviously, the average number and amount is considerably less.) Studying further with the assistance of various other bankers the 340 towns and cities, we reached the following conclusions: No. Cities or Towns Yes No. Cities or Towns No No. Cities or Towns Uncertain 62 83 273 256 4 1 149 183 8 10 319 11 13 1 Lacking adequate loan facilities Lacking adequate facilities for deposit of money Lacking adequate facilities for cashing checks or making change Would a regularly chartered bank be profitable in the 340 cities or towns included in this survey? In the 161 towns and cities believed to lack adequate facilities for either the deposit of money or the cashing of checks and making change, and in which it is believed that a regularly chartered bank would not be profitable, would an agency for cashing checks and making change, and possibly accepting deposits either for itself or for some bank, adequately care for the needs of the community at the present time? No. Cities or Tounss Profitable In the 147 towns and cities in which it is believed that such an agency would adequately care for the needs of the community, would such an agency be profitable to the operators? If not, self-supporting? 46 147 No. Cities or Towns Not Profitable but Self-Supporting 25 No. Cities or No. Cities Towns Not or Towns Profitable Uncertain or SelfSupPorting 52 24 Obviously, any town or city without a bank, in which a chartered bank formerly operated, lacks adequate facilities of the type above mentioned, but the Committee concerned itself with listing those towns or cities lacking the various facilities where it was determined that they were lacking to such an extent as to present a serious need. We desire to point out that it was thought that 62 towns and cities lacked adequate loan facilities to a serious extent, 83 towns and cities lacked adequate facilities for deposit of money to a serious extent and 149 lacked adequate facilities for cashing thecks or making change to a serious extent. Summarizing, with deductions for duplications, 161 towns were believed to lack adequate facilities in connection with one or more of the three above mentioned services. The Committee therefore felt that the most essential of banking services were inadequate in a sufficiently large number of towns and cities in Missouri to be of concern to the bankcrs of Missouri, with the most prevalent type of service lacking being that of cashing checks and making change. The Committee feels that the lack of loan facilities and the lack of facilities for the deposit of money pre- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 5 vails in a considerably smaller number of towns and cities and is of considerably less importance than that of cashing checks and making change. Feeling that there existed some inadequacy of banking service in Missouri as expressed above, the Committee turned its efforts toward existing and possible remedies. The question of limited branch banking was presented to the Committee and summarily dismissed because it was the unanimous opinion of the Committee members that the great majority of the members of the Missouri Bankers Association were whole-heartedly opposed to branch banking. The Committee wishes also to go on record as stating its opposition to branch banking as a possible solution to the remedying of whatever inadequacy exists. It was found that there exists five states which do not permit branch banking but which by statute permit the supplying of banking service to bankless towns and cities by chartered banks located at nearby towns. These five states are: Iowa, Wisconsin, Arkansas, New Mexico and Kentucky. Briefly we outline below their methods: Iowa— Statute forbids branch banking, but permits establishment of offices under jurisdiction of banking department for purpose of receiving deposits, paying checks and other clerical and routine duties. Offices limited to county in which parent institution is located and counties contiguous thereto. Must not be established in city or town in which there is already an established banking institution. Must be discontinued when a legally chartered banking institution commences business in town or city. Provides that nothing in the act shall prohibit national banks the privileges offered state banks when authorized by federal law. Wisconsin-Statute sets forth that it shall not be construed as committing the state in any manner to a policy of permitting branch banking. Permits establishment of stations upon approval of banking review board to be operated under rules and regulations of banking commission. Limits operation to receiving and paying out deposits, issuing drafts and travelers' checks, handling and making collections, and cashing checks and drafts. Provides for closing of such stations by banking review board or by the bank operating station upon approval of the commission. Prohibits establishment within four miles of a bank or another station, and limits to county in which home office is located or to adjoining county if population of such adjoining county is less than 16,000, or to any other county if within trade area of parent bank and not more than 25 miles away. Limits number of such stations permitted to any one bank to four. Arkansas— Statute permits establishment of windows or offices by any state or national bank operating in state for purpose of receiving deposits and paying checks and performing such other duties under terms and conditions as prescribed by super- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 6 vising banking authority. Limits establishment to county in which parent bank is located and counties contiguous thereto. Forbids establishment in any town or city in which either state or national bank is operating. Provides for discontinuance of office or window upon a legally chartered bank commencing business in such town or city. New Mexico— Statute prohibits branches, except permits mercantile corporations which maintain banking departments in accordance with provisions of Act to receive deposits and buy and sell exchange at any of its branch stores. Allows banks to open agencies upon obtaining permit from State Bank Examiner, such agencies to be operated in same county, adjoining county, or within radius of 100 miles from said bank, if there be no bank in operation within county in which such agencies are opened. Kentucky— No statute either prohibiting or allowing the operation of agencies. However, agencies have been established, with approval of Banking Department, under a Court decision. Upon investigation we learned that the following number of banks were operating agencies in the states above mentioned at the time of our inquiry: 105 68 10 9 4 Iowa Wisconsin Arkansas Kentucky New Mexico 196 1 Several of the 196 banks operating agencies operated more than one. We are informed that since the compilation of our figures there has been some increase in the number of banks operating such agencies. We next mailed a questionnaire to all of the banks operating agencies in the five states above mentioned. 196.questionnaires were mailed and 145 replies received. The 145 answering banks reported on 197 agencies. Returns were tabulated by states but on account of lack of space no attempt is made here to set out such tabulation. We give you below tabulation of totals of answers to the various questions: SUMMARY FOR THE FIVE STATES Number of questionnaires sent out Number filled out and returned Number of offices reported on 196 145 197 1. Populations of towns where offices are located: Under 500 500-999 1000-1999 2000-4999 102 63 25 4 7 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I 5000 and over 3 2. Distances between parent banks and their offices: 20 to 29 mi. 5 to 9 mi. 10 to 19 mi. Less than 5 mi. 20 83 65 15 3. How long have offices been in operation ? 5-10 yrs. 3-5 yrs. 1-2 yrs. 2-3 yrs. Less than 1 yr. 22 80 13 25 49 4. Number of employees at each office: Three employees Two employees One employee 6 146 44 5. Were there formerly banks where offices now located? No: 8 Yes: 189 30 mi. or over 14 10 yrs. or over 4 Five employees 1 6. Are offices open every day? No: 5 Yes: 192 offices profitable? 7. Are No answer: 1 No: 55 Yes: 141 they are self-supporting? 8. If not profitable, No: 5 Yes: 50 9. Are charges for services at office higher than at parent bank? No answer: 3 No: 167 Yes: 27 10. Do offices make loans direct? Yes: 26 No: 171 11. Do offices accept loan applications for parent bank? No answer: 1 Yes: 175 No: 21 12. Do offices cash checks? Yes: 197 No : 0 13. Do offices accept deposits? Yes: 197 No : 0 (a) For immediate credit-159 (b) For transmission to parent bank-38 14. Do offices issue drafts? No answer: 1 Yes: 170 No: 26 15. Do offices issue cashiers' checks? No answer: 1 Yes: 154 No: 42 16. Do offices sell travelers' cheques? Yes: 102 No: 95 17. Do offices rent safe deposit boxes? No answer : 1 Yes: 165 No: 31 18. Are notes kept on premises of offices? Yes: 21 No: 176 19. Are books kept on premises of offices? No: 55 Yes: 142 20. Are daily reports made by offices to parent banks? No answer : 2 No: 2 Yes: 193 TABULATION OF ANSWERS TO GENF.RAL QUESTIONS I. Is there much rivalry between banks in establishing agencies? No answer: 5 No: 133 Yes: 7 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 8 2. Do national banks seriously object to state banks operating agencies? No: 138 Yes: 2 No answer: 5 3. As a result of your state law establishing state banks to operate these agencies have there been any national bank branches established ? Yes: 5 No: 135 No answer: 5 In addition to the above figures we received many interesting criticisms, comments, explanations and suggestions. We regret that we are unable to set them out in detail in this report. Continuing our study we found that there were 57 national banks operating in the same towns where state banks operating out-of-town agencies were located. We mailed a questionnaire to each of these 57 national banks and give you below a tabulation of the replies: TABULATION OF ANSWERS TO QUESTIONNAIRE SENT MARCH 24, 1937, TO NATIONAL BANKS IN TOWNS WHERE STATE BANKS OPERATING OUT-OF-TOWN OFFICES OR AGENCIES ARE LOCATED Totals 57 45 Number of questionnaires sent out Number of questionnaires returned Question 1: Do you. believe that .the laws in your state permitting state banks to operate windows, agencies, offices, etc. (not branches), place you under a handicap from a competitive standpoint ? Answering yes Answering no Non-committal Question 2: Do you favor the plan in operation in your state? Answering yes Answering no Non-committal Question 3: If not, do you think some such banking service as permitted by your state law is needed by bankless towns in your state ? Answering yes Answering no Non-committal Question 4: Would you favor an amendment.to National Banking Laws permitting national banks to operate agencies in the same manner as state banks? Answering yes Answering no Non-committal Question 5: Do you think that your state law makes it possible for you to operate a branch provided you obtain permission from the Comptroller and have the required capital? Answering yes Answering no Non-committal Question 6: If so, have you considered establishing such a branch? Answering yes Answering no Non-committal 9 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1- 31 10 4 16 19 10 14 13 18 25 13 7 26 9 10 5 26 14 Our next step was to contact the supervising authorities in the states permitting establishment of agencies and we found an attitude generally favorable to the plans and their experience generally satisfactory. Attempting to learn the attitude of the Comptroller of the Currency we discovered that his office takes the position that in states having statutes which authorize establishment of limited branch offices by state banks, it is permissible for national banks, subject to approval and the usual capital limitations, to establish a branch in such localities, which branch however, is unlimited in its branch functions and is not restricted to the services permitted to branch offices of state banks under the state law. We also understood that the Comptroller's office holds that once a branch is established, even though the authority rests upon such a statute as those of the states we have studied which generally require closing of an agency upon the establishment of a bank, the branch need not be withdrawn when a bank is opened there. We believe the position of the Comptroller's office to be of vital importance in our study for the following reasons: 1. It would permit branch banking to' a certain extent. 2. It would in effect cause discrimination against the smaller national banks for the reason that they would not be permitted to operate agencies of limited functions, nor could they establish a branch on account of inadequate capitalization. We learned that "Credit Unions" and "Co-operative Credit Associations" were being established in some states on a rather large scale. In some cases a rather complete banking service is being rendered. Our investigation convinces us that such organizations are in many cases in direct competition with banks, that they do not as a general rule furnish a desirable amount of protection for their patrons and that they are not a satisfactory solution for providing banking service to bankless communities. We recognize, however, that agitation can easily arise for this type of service in the absence of an acceptable substitute. The possibility was discussed of banking service being supplied to bankless towns and cities by agencies, under appropriate licensing and supervision, such agencies to be established by citizens of bankless communities and financed in such localities, free from bank control and domination. Such agencies would eliminate the branch banking question which is apparent from the statutes enacted by the states we have studied and from the Comptroller's ruling. It is apparent that such agencies would have to be limited in their functions. We find no record of the functioning of a similar plan but believe that it holds interesting possibilities. Our time would not permit us to give this phase further study. We present the following conclusions: 1. That very few of the 340 towns and cities which had one or more state banks in 1926 and now have none could profitably support a regularly chartered bank. 2. That the most essential banking services are inadequate in some respects, particularly in connection with cashing checks and making change, in a sufficiently large number of towns and cities to be of concern to bankers in Missouri. 3. That the establishment of Credit Unions or Co-operative Credit Associa- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 10 tions to supply general banking service to bankless communities is not a satisfactory solution, is undesirable from the standpoint of the public and the banks, and should be opposed by the banks of Missouri. 4. That branch banking is not desirable or acceptable to the bankers in Missouri as a solution of the problem. 5. That the laws of the states of Iowa, Wisconsin, New Mexico, Arkansas, and Kentucky, authorizing the supplying of banking services by banks to bankless communities seem to be generally satisfactory to the state banks supplying such service. 6. That national banks located in the towns where state banks operating such agencies are located are divided in their opinion as to the desirability of such statutes, but that the majority believe that they are handicapped by such statutes from a competitive standpoint. 7. That the supervising authorities of the five states supplying such service consider the plans generally acceptable and satisfactory. 8. That the Comptroller of the Currency considers that the enactment of statutes such as those of the states above mentioned gives him authority to authorize national banks to establish branches. 9. That small national banks in Missouri would be discriminated against by a similar statute because they could not obtain a license to operate an agency of limited functions, nor could they establish a branch on account of capital requirements. 10. That on account of the branch banking question and the discrimination against small national banks, the enactment of such a statute in Missouri would, we believe, be opposed by the majority of the bankers of Missouri, notwithstanding the apparent reasonable success of such a plan in other states. 11. That the suggestion of a plan to provide for the establishment by the citizens of bankless communities of some kind of agency to supply, under proper authorization and supervision, the most needed banking services such as cashing checks and making change, and possibly to accept deposits for transmission to a chartered bank, has interesting possibilities and should be explored fully and given further study by the Association. 12. That the entire problem is of importance and deserves the continued attention of the Association. The Committee desires to express its appreciation of the assistance and cooperation of the President, the Secretary, Assistant Secretary and Association office force, the various Missouri bankers who assisted us, the various supervising authorities and the bankers and bankers associations of the states studied. Respectfully submitted, R. R. CALKINS CLARENCE EVANS CLEM T. KELLY F. W. PENDLETON W.S. PETTIT R. B. PRICE j. C. WELMAN, Chairman. 11 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. W. Pole, Comptroller of the Currency Hearings — S. Res. 71 , /93/ STATEMENT OF HON. J. W.POLE, COMPTROLLER OF THE CIIRRENCir • 1 Mr. POLE. Mr. Chairman,I have prepared a brief statement which I should like to give to the committee. The CHAIRMAN. Very well. Mr. POLE. Mr. Chairman, I have heretofore, in my annual report to Congress for 1929, in my appearance before the House Committee on I3anking and Currency and in my annual report to Congress for the year 1930, made statements and recommendations with reference to new banking legislation. These documents are available to your committee and I shall not at this time engage in a repetition other than to attempt briefly to summarize the position I have taken. This can be stated under two heads: First, branch banking emanating from commercial centers should be permitted gradually to be established in the rural communities in order to give to them the benefits of the best type of banking we have developed, and, second, f that the question is national in scope and Congress alone has .the power to make effective a policy which will put this type of branch banking,•_into effect. . jOn the other hand, we have developed in the large commercial c nters a type of banking which is fundamentally strong and effi- ' eient. They hold the bulk of the banking resources of the country , and they are the real support of the Federal reserve system. They have not only developed a wide diversification of banking business ' within the cities in which they are located but they have an active business in the entire geographical area in the rural communities , within the circumference of the trade zone or trade influence of such ' a city. It is for this reason that I have recommended that banks of i this type be authorized to establish branches within the regional trade area of the city in which they are situated. Many inhabitants of rural communities are now dealing directly with these banks or with branches of them but this is a cause of inconvenience. Would it not be a sounder policy to permit the best type of banks we have to establish branches in the surrounding local communities in order that these outlying populations may enjoy the same safety and the same variety of banking facilities which they could obtain by making a journey to the city ? Under this theory these branches would no doubt be established through business negotiations between the locq bank and the city bank through the ordinary processes of merger or purchase. It is recognized that Congress can enlarge the charter powers onl& of the national banks. In the present situation, it seems to me that a positive declaration of a national policy for the further extension of branch banking is essential. I have, therefore, predicated my recommendations for trade area branch banking upon the theory that it is necessary to disregard State boundary lines with respect to the trade areas of many cities just as it was necessary to disregard State boundary lines in many cases when the Federal reserve districts were established. I see no relief to be gained from branch banking for the rural communities unless Congress is willing to permit the national banks in the commercial centers to establish branches in the trade area of the city, notwithstanding the fact that such trade areas of some cities may embrace territory.in more than one State and that the States in question have no similar branch banking laws. Congress could not, of course, give to the large city https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. W. Pole — Page 2 / 3/ 4 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS State banks and trust companies in commercial centers a similar authority to establish branches, but a way would be open for such banks to convert into national banks for the purpose of gaining these branch banking privileges if it carried with it an operating advantage sufficient to justify such action. Many national banks have taken out State charters for the reason that the State law gave them operating advantages of much less importance over the national law. I • The CHAIRMAN. Mr. Comptroller, I do not understand that you advocate chain banking. Mr. POLE. Not at all; but the Senator's statement is not in accord with our information—not only with our information but with our actual knowledge. While it is true there have been a (Treat many banks which were quite good banks—the best in that whore section of the country—which have been taken over by these groups, at the same time the groups have come to the relief of many banks which would not have weathered the storm without that relief. Senator NORBECK. In the same way that banks.in the large cities have come to the relief of their correspondent banks out in the country. And'that condition has existed for 50 years. Therefore the chain part does not enter into it. . Mr. POLE. Of course, you understand I am not advocating chain banking. Senator NORBECK. I thought that was the thing you advocated. Mr. POLE. No. Perhaps you do not distinguish in your mind between chain, group, and branch banking. Senator NORBECK. Well, they are all controlled from the center; they are all alike in being controlled from the center. Mr. POLE. Not with respect to group and chain banking. The group-bank system is generally controlled from the center. Senator NORBECK. And branch banks—are they not alike in being controlled from the center V Mr. POLE. Yes, there is central control. Senator NORBECK. Well, I do not get the distinction. The CHAIRMAN. There is a vast difference in responsibility between branch banking and chain banking, is there not? Mr. POLE. You put your finger on the very thing, then, Mr. Chairman. Branch banking would operate entirely differently with respect to the very thing you have in mind. Under a group-banking system the members of the group, which are community banks, retain their local identity, have their own boards of directors, separate officers, and operate independently, theoretically, but are more or less managed from a head office, and necessarily have all the overhead incident to an independent bank; whereas, if branch banking were permitted, the parent bank could go out and throw all of its resources and all of its facilities to the smallest hamlet, if you please. Senator NORBECK. And could likewise draw the reserves from the smallest; hamlet. Mr. POLE. Without doubt, but what is the history of it ? The history of it, as far as branch banking has been carried in this country, particularly in California, is that the parent banks have thrown far more of their funds to the small rural communities than they have ever drawn from them. \ • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. W. Pole — Page 3 10 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. That is a California condition; if they had foreseen that they probably would not have aquired all these branches. The CHAIRMAN. Is not that conspicuously true of the Canadian system, Mr. Comptroller ? Mr. POLE. I do not think there is any doubt about it, Senator. Senator NORBECK. Is the branch banking you advocate similar to the Canadian system? Mr. POLE. It is similar, but not as comprehensive. I will say that. My idea is that branch banking should develop gradually and that it should develop from centers of importance, to the limits of what I term the trade areas of those particular centers, so that I have no idea of advocating, nor have I ever done so, a branch-bankina system which would comprehend the whole United States, which istlhe case in Canada. 1 'Senator NORBECK. Was it not fortunate indeed that bank did not have hundreds of branche,s over the country? Mr. POLE. Under my recommended system, Senator, that bank would not have had country branches. Senator NORBECK. IS it not fortunate inde,ed that they were not allowed to have branches outside of New York? As a matter of fact, they had 50 or 60 there. Mr. POLE. I think it was fortunate, Senator, but I am not advocating that that bank should ever have been permitted to--Senator NORBECK. But you are advocating a system that would permit banks like that to have branches? POLE. I beg your pardon Senator, not like that--unlike that. - Mr. • — • • 1 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator NORBECK. Would it not be well to let Mr. Pole amplify the distinction between chain banks and branch banks? He make 'rite a distinction. I do not make so much. Let us have the dis unction, in his own words. The CHAIRMAN. All right. Go ahead, Senator. You are privileged to ask any questions you please. Mr. POLE. A chain bank is a system of independent banks usually i owned—the stock of which, either a majority or in an important 1 , 1 1 • NATIONAL AND FEDERAL RESERVE •BANKING SYSTEMS 15 measure--by an individual or a group of individuals without central management. A group-banking system is usually a number of banks, the stock of each owned or controlled in an important measure, by a holding corporation formed for that purpose, and the management of these independent banks being usually through a central member of the holding corporation, which is located at a central point. Senator NORBECK. What designation would you give under that definition to the chain system that exists in the Northwest now? Mr. POLE. I would call that a group banking system where the stock of the individual bank is held by the holding corporation. Senator NORBECK. With a branch banking system such as you suggest, there would be no stock owned by a holding company? The banks themselves would issue no stock? Mr. POLE. No stock at all. SellaOr NORBECK. And they would have no stockholders—the branches would not? Mr. POLE. Not as a branch. Senator NORBECK. They would have no local lioard of directors? Mr. POLE. Not in the sense that the independent bank has. It would probably have a local advisory board. Senator NORBECK. Yes; but not local directors. The power Mr. POLE. Unless you would call this local advisory board the local board, which is the custom now— Senator NORBECK. But their function would be only advisory. They would have no power. For instance, if the central bank should say,"Send us $50,000," they would have to send it? Mr. POLE. Yes. Senator NORBECK. The control would be in the center, as in the chain-banking system? Mr. Pom. Yes. Senator NORBECK. In that northwestern situation, the c,omptroller's view is that this thing has rather been a good thing for the Northwest--this acquiring of the branches or these chain banks throughout the Northwest has been rather a good thing for the banking situation? Mr. POLE. I think so. Senator NORBECK. What benefit has accrued to the small banks or to the communities where the acquired banks are located? Mr. POLE. They have loaned money—probably not quite as great an amount as loaned formerly, but they have done it more scientifically ; they have prevented many banks from failing and, in a great many instances, the very banks they took over would have failed. Senator NORBECK. The banks acquired by the Northwest chain system are banks that have stood the test of the deflation. They were recognized as sound. I think the comptroller will agree with me that all South Dakota banks acquired by the chains enjoyed the confidence of the community, with the possible exception of one, against which some withdrawals were being made, but it must have been financially sound or it would not have been taken over by the chain. Do you believe they would have bought one that was not good? Mr. POLE. Not without readjustment. 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. W. Pole — Page 4 y a,et.„-.7 / 16 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 2/ J. W. Pole — Page 5 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. In other words, it had to be susceptible of rea,djustment or they would not have bought it. Mr. POLE. They seemed to be very willing to go in and give a rea,sonable premium on whatever good business there might be there. Senator NORBECK. But the comptroller -will also agree with me that helping a community also consists of pushing out money to the community in times like this? Mr. POLE. Yes; where it can be done soundly. Senator NORBECK. But the comptroller insists that it has been going the other way—it has been pulled into the centers. The comptroller has called attention to the fact that this great growth of branch banking in the Twin Cities has progressed to the extent of acquiring 150 branches. He says the Twin Cities showed increased deposits. Mr. POLE. We are talking about two different things. I think each has helped the other. Senator NORBECK. But if there are more funds in Minneapolis, and less in South Dakota, who is helped? Mr. POLE. I do not know of any good account in the small communities which the First Bank stock- or the Northwest Bank Corportation is permitting to suffer. Senator NORBECK. That, of course, is a matter of opinion. A banker can say"We are not making any loans and therefore nobody is suffering." That is their view. The fact of the matter is that they are hardly making any loans, are they? The CHAIRMAN. Mr. Comptroller— Mr. POLE. I hope you understand, Senator, that I am not advocating or defending the group or chain systems. The CHAIRMAN. On that point, Mr. Comptroller, have you examined— Senator NORBECK. But there is this distinction between a chain and group: You do not recommend the group, but you recommend the chain. But the group has certain advantages; for instance, local capital and a local board and partially local management. The chain would have none. It would be all governed from the center. Mr. POLE. That is branch banking. Senator NORBECK. I beg your pardon. I said chain, did I not? Mr. POLE. Yes. The CHAIRMAN. Would not the branch have its local office and local agents and local establishments? Mr. POLE. I think one of the things which the Senator overlooks is the fact that, while it is true that under a group banking system the member of the group must be a bank of a character which could be profitably operated under this— Senator NORBECK. In other words, it must have been a good bank, or they would not have bought it; therefore they are not helping a community by buying good banks which have been getting along all right and getting control of them and taking funds out of the community. Mr. POLE. They do not always do that. But under the central management with better management it is better able to operate successfully. Under the branch banking system the large bank could throw its resources into the small communities that might need them. J. VI. Pole - Page 6 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 17 1 Senator NORBECK. I note the word"could." Mr. POLE. Could throw its facilities and resources to the farthest corner within its district, whatever its district may be, and deal with that branch as though you were dealing with the main office in Minneapolis. The CHAIRMAN. Would it not have been the same acquisitive inducement to do that with the local bank? Mr. POLE. Precisely. Senator NORBECK. Would not the manao•ement of any bank put the money where it was worst needed, or where they could gain the most from its use? Human nature is the same in banks as in politics. Mr. POLE. Well, banking is a business. Senator NORBECK. It is a business for gain. Mr. POLE. Banking is a business in which people engage for profit as in any other business • and if they are simply going to bleed the business for some particular selfish interest, of course the end of that business is disaster. Now, they are going to operate that business scientifically, which means that they would distribute their funds over the district, because they are not going to make an investment in an outlying district and then starve it to death; they are going to build it up. Senator NORBECK. Exactly, but they will have no investment. You propose that they should do away with the local stock and management and have no investment there. You prefer the branch. Mr. PoLE. It would be a distribution of the investment they make as a part of their whole system. A part would be made to the small hamlet—a small part because the amount of business is small— but having invested that in the banking house, salaries of officers, stationery, and general expenses of that bank, there would be that investment, be it large or small. It would be large or small in proportion to the amount of business done. They will not make anv investment there and starve it to death. They will foster it, nourish it, and feed it funds when necessary, and experience h_as shown that in....m.y_• _many instlaus_maneg. is sent-nut from the head office...fir in excess of the amount of the deposits_Ythich rrLay be collected from Mit- little community. -The CHAIRMAN. On this question of chain banking: Have you examined S. 4723? Look at section 3 and see if you think that abates the evil of chain banking, if it may be said to be an evil ? I am not asking you if you think it would be a valid exercise of authority or whether the authority would be valid. I am asking what you think the effect of it would be. Mr. POLE. I am not prepared at this time to say what the effect of that would be, Senator. The CHAIRMAN. That would at least maintain control of the bank in the local community, would it not? Mr. POLE. Yes, sir. I think that the history of the disposition of these corporations which hold stock is naturally in the direction of the idea of having that stock pretty well distributed and undoubtedly if it were a branch of a bank established in a certain locality, it would be the disposition of the parent bank to distribute a reasonable amount of that stock within that community which, of course, would be held by individuals and voted as such. The CHAIRMAN. That would not permit a central bank to vote ite stock in the local bank? Mr. POLE. No. The CHAIRMAN. That does not relate to branch banking. POLE. I understand that. 1 1 I\ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *N J. Pole — Page 7 /93/ . .. Senator BULKLEY. The other thing I wanted to ask you about is 1 his: You said under your proposal there would be no branches at 11 established by such a bank as the one that recently had trouble n New York City. Will you amplify that a little bit? I did not quite catch the distinction. Mr. POLE. That is a State bank, and my information with respect to it is only from the newspapers, but I have been led to understand that it was a bank which indulged in unsound banking practices, and I am taking it for granted that by any comptroller there would be no branch banks permitted to any bank unles.s the bank itself were a bank which had proven itself to be sound and indulged in safe and sound banking. Senator BULKLEY. Your plan would be for each bank to. get the approval of the comptroller with respect to the establishment of each branch ? Mr. POLE. That is my recommendation. Senator NORBECK. IS it not a fact that many banks well organized and well set up and well managed go wrong gradually afterwards and make the comptroller a lot of trouble? Mr. POLE. Yes. Senator NORBECK. Would the fact that they have branches tend to obviate—would that make them virtuous or would they be subject to the same peculiarities of human nature ? Mr. POLE. That might happen to any business, Senator. In other words, we can not forsee what will happen, and if a bank is in good shape now you can not deny it privileges because, say, six years from now it may have gone down instead of up. Senator NORBECK. And the same might _happen with a branchbanking system as might happen to a bank without branches? Mr. POLE. Yes. t • 1 Mr. Wm.'s. I have one question about chain banking, Mr. Comptroller. When you have a situation like that which existed in the Northwest, how does it affect the double liability of the shareholders provision? Mr. POLE. We call that a group-banking system in the Northwest. In the case of the Northwest and the First Bank Stock Corporation, I think that their stock is not subject to the double liability, although the stock of some holding corporations is subject to double liability. But in the case of those two corporations, in those particular cases-not that it obtains too generally—they have invested in securities other than bank stocks, so that a judgment against either one of those corporations would be good for the assessment. Mr. WILLIs. In those particular cases? Mr. POLE. In those particular cases; yes, sir. Mr. Wax's. But there are cases where they are not subject to the assessment? Mr. POLE. There are cases where they are not subject to the assessment; yes, and where they hold nothing but bank stocks. Mr. Wm.'s. In those cases where you have an affiliated bank that buys all the stock of the bank itself, what becomes of the double liability of the shareholder? Mr. POLE. The securities company where it buys the stock of the bank itself, would be the holder of the stock and subject to assessment. ) https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 George L. Harrison, Governor, FRB, N. Y. Hearings — S. Res. 71 Governor HARRISON. Unfortlinately, practically everything I say about this rate relationship must refer to the money market, because in this country the barriers between the principal money centers and the country districts are very great. There is great reluctance on the part of funds to seep out from the money centers to the more ‘, remote districts even when rates get as easy as they are in New York to-day. That reluctance is due to a number of causes. New York City banks may have a large overage of funds that they do not know what to do with, an overage of reserves in excess of requirements, because they have not employed their funds. Those funds may not go out of town for two reasons—first, there may not be an active demand of the kind or in the sections that these banks have been accustomed to dealing with, and, second, the conservative attitude on the part of the banking community in periods such as we have been hearing about and a consequent desire to keep in a very liquid position. In this connection, Mr. Chairman, there has never been a time since I • 76 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS have been in New York,in 10 years, when I have considered the principal banks in New York generally as liquid as they are to-day. Now, if it were possible to develop a system of branch banking which would enable banks in New York City and in other money centers to feed out their surplus funds to the interior through management and officers who are their own, and whom they know, and who know their policies, I think you would take one great step toward a more effective distribution of credit now available in the, various centers. The CHAIRMAN. You mean nation-wide branch banking ? Governor HARRISON. I imagine that is not practicable, and I would not advocate it. I like the phrase that the comptroller has used, trade areas, although I do not know exactly what it would mean. The difficulty is a practical one. The normal and natural thing to do, and I felt five years ago that it might be wise, is to authorize State-wide branch banking because it is a definite and concrete limitation to prescribe. On the other hand, that obviously works some injustices. There may be very much more reason why you should authorize branches within a radius of a hundred miles than within State limits. In the case of New York City, for instance, if you authorize a New York City bank to put a branch in White Plains, N. Y., and not in Newark, N. J., it would not seem a logical distinction to make. On the other hand, a definition of a trade area that would permit a branch being established in Newark as well as in White Plains would, I think, be quite reasonable. Whether you can define trade area by geographical radius or not I do not know, but I think the thing your committee will likely wish to consider is what sort of limitation you may put upon branch banking that will be adequately restrictive without defeating the very purpose that you are trying to accomplish. The Federal Reserve System has done a good deal to equalize interest rates throughout the country already. It has also done much to equalize interest rates in the different seasons throughout the year, as well as throughout the country, but there is yet much to be accomplished in making for •a, better distribution of credit from the principal centers out to the more remote country districts, where rates have been much more reluctant to decline. That is due to two reasons: ^ e -; George L. Harrison — Page 2 93/ First of all there is a natural shortage, or not so much credit available, in more remote districts, and, secondly, in the agricultural or other sections where borrowers have already been forced by economic conditions to hold over their loans for a year or more, bankers are a little reluctant to loan at a lesser rate, and, indeed, are entitled to lend at a higher rate. Even so, I think branch banking would do much to make for a somewhat better distribution of credit at more equal rates in the different sections of the country. The CHAIRMAN. On that point I am going to ask leave of the committee, if there is no objection, to insert in the record a brief that I have asked to be prepared giving the court decisions on the question of branch banking and the right to have the system adopted across State lines. I may incidentally say that my own view is that it is not feasible to attempt to do anything of the kind, but I would like that to go into the record, so that the members of the committee and others may see what has been the court decision on the question. (The paper referred to is printed in full, as follows:) NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS THE ESTABLISHMENT OF THE CONSTITUTIONAL POWER OF CONGRESS TO AUTHORIZE BRANCHES BY NATIONA.L BANKS IRRESPECTIVE OF STATE LAWS • 1 • 77 The first Bank of the United States, 1791-1811.—The legal theory upon which Congress enacted the national bank act and the Federal reserve act is the same as that upon which Congress authorized the establishment of the first Bank of the United States in 1791 and the second Bank of'the United States in 1816. When the first bank was proposed in Congress the constitutionality of the bill was seriously debated, but a majority of both Houses supported it. President Washington signed the bill after considering the official opinions both for and against its constitutionality. The first Bank of the United States was opened December 12, 1791, and established eight branches in several States, namely, at Boston, New York, Baltimore, Washington, Norfolk, Charleston, Savannah, and New Orleans. This is the first precedent of the establishment of branches by a national bank. the bank, upon the occasion of the failure of Congress to renew the charter of and some vvhich expired in 1811, the constitutional question was again raised, of the opposition against the renewal was upon the ground that Congress was without power to establish and maintain a national bank. The second National Bank of the Un4ted States, 1816-1836.—The attempt to finance the War of 1812-1814 without any banking instrumentality under the control of the Federal Government proved so disastrous that Congress in 1816 passed a new bill to charter a Bank of the United States similar to the first bank, President Madison approving the act, having the year before vetoed a similar measure which did not meet his views. As compared with the first Bank of the United States, there was little difference between their organization and purpose. The second Bank of the United States likewise established branches in various States in the Union. In 1818 the Legislature of the State of Maryland passed an act, the effect of which was to place a special tax upon the branch of the Bank of the United States in operation in Baltimore. The Baltimore branch refused to pay this tax, its cashier, McCulioch, was sued in the State court, and a judgment sustained against him by the court of final jurisdiction. He thereupon sued out a writ of error under which the case was brought before the Supreme Court of the United States. Here for the first time the constitutional power of Congress to establish the bank and of the bank to establish branches was considered by that tribunal. (McCulloch v. Maryland, 4 Wheat. 424.) In the following year, 1819, the State of Ohio imposed a tax of $50,000 on each of the two branches of the Bank of the United States established at Cincinnati and Chillicothe. Upon the refusal of these branches to pay the tax the sheriff on behalf of the State seized $98,000 in money. The State officials concerned were arrested by the Federal authorities and tried in the Federal circuit court, where judgment was rendered against them to restore to the bank with interest the funds seized. An appeal was taken to the Supreme Court of the United States (Osborn v. Bank of the United States, 9 Wheat. 738), where again the constitutional power of Congress was brought into question and formed the basis of the opinion. The opinions in both of these cases were written by Chief Justice Marshall and for practical purposes can be considered as one case, the second being an aboration and a review of the first. The principles decided in these cases may be briefly stated as follows: (1) Congress has the constitutional power to incorporate a national bank. (2) The existence of State banks can have no influence upon the question of this paramount power of Congress. X https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis k) P14 -4 George L. Harrison - Page 3 , / 93/ / (3) "After the most deliberate consideration, it is the unanimous and decided opinion of this court that the act to incorporate the Bank of the United States is a law made in pursuance of the Constitution, and is a part of the 1-, supreme law of the land. The branches proceeding from the same stock, and i "--being conducive to the complete accomplishment of the object, are equally 424.) constitutional." (McCulloch case, 4 Wheat. (4) Congress having the constitutional power to create a national bank has also the constitutional power to determine, authorize, or create the faculties necessary to enable it to perform the services for which it was created, and Congress alone is the judge of the means to be employed in the exercise of these faculties. . A,10 01-APT 1-6 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS k 78 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Supreme Court of the United States in these two cases upheld the power of a national bank to establish branches in the various States without permission or authority from the State Governments. The national bank act of 1863.—With the failure of Congress to renew the charter of the second Bank of the United States the Federal Government operated without a banking instrumentality under its control until the enactment of the national bank act in 1863. That act set up a system of independent national banks rather than one central national bank with branches. The question of the power of national banks to establish branches did not again come before the Supreme Court of the United States until 1924, more than a century after the decisions of McCulloch v. Maryland, and Osborn v. Bank of the United States, when it was presented in the case of the First National Bank in St. Louis v. Missouri (263 U. S. 640). In the meantime, however many cases had come before the Supreme Court of the United States in which it became necessary to interpret and construe the national bank act with reference to the charter powers of national banks in their relationship to the State legislatures, in all of which the fundamental principles enunciated in the McCulloch and the Osborn cases were sustained and followed. It seems appropriate to consider some of these cases before proceeding to the First National Bank in St. Louis v. Missouri. Farmers d Mechanics' National Bank v. Dearing (91 U. S. 29, 1875).— This was the first case before the Supreme Court which construed the nationalbank act with reference to the authority of the State governments and involved the application of the usury law of the State of New York. The court said: "The constitutionality of the act of 1864 is not questioned. It rests on the same principle as the act creating the second Bank of the United States. The reasoning of Secretary Hamilton and of this court in McCulloch v. Maryland (4 Wheat. 316) and in Osborn v. Bank (9 Wheat. 738) therefore applies. The national banks organized under the act are instruments designed to be used to aid the Government in the administration of an important branch of the public service. They are means appropriate to that end. Of the degree of the necessity which existed for creating them Congress is the sole judge. "Being such means, brought into existence for this purpose, and intended to be so employed, the States can exercise no control over then), nor in any wise affect their operation except in so far as Congress may see proper to permit. Anything beyond this is an abuse, because it is the usurpation of power which a single State can not give.' Against the national will the States have no power, by taxation or otherwise, to retard, impede, burthen, or in any manner control the operation of the constitutional laws enacted by Congress to carry into execution the powers vested in the General Government.' Osborn v. Bank, supra ; Weston v. Charleston (2 Pet. 466) ; Brown v. Maryland (12 Wheat. 419) ; Dobbins v. Erie Co. (16 Pet. 435). "The power to create carries with it the power to preserve. The latter is a corollary from the former. The principle, announced in the authorities cited, is indispensable to the efficiency, the independence, and, indeed, to the beneficial existence of the General Government ; otherwise it would be liable, in the discharge of its most important trusts, to be annoyed and thwarted by the will or caprice of every State in the Union. Infinite confusion would follow. The Government would be reduced to a pitiable condition of weakness. The form might remain, but the vital essence would have departed. In the complex system of polity which obtains in this country the powers of government may be divided into four classes: "Those which belong exclusively to the States; "Those which belong exclusively to the National Government; "Those which may be exercised concurrently and independently by both ; "And those which may be exercised by the States, but only with the consent, express or implied, of Congress. "Whenever the will of the Nation intervenes exclusively in this class of cases the authority of the State retires and lies in abeyance until a proper occasion for its exercise shall recur. Gilman v. Philadelphia (3 Wall. 713, 18 L. Ed. 96); Ex parte McNiel (13 Wall. 240, 20 L. Ed. 625). "The power of the States to tax the existing national banks lies within the category last mentioned. "It must always be borne in mind that the Constitution of the United States and the laws which shall be made in pursuance thereof'are the supreme law of the land'(Const. Art. VI). and that this law is as much a part of the law /fg, George L. Harrison - Page 4 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • of each State, and as binding upon its authorities and people, as its own local constitution and laws." Casey v. Galli (94 U. S. 673, 18'77).—This case held that Congress had the power to authorize a State-chartered ba,nk to convert into a national bank without any assent or permission by the State. upon the ground that no authority from the State was necessary. Davis v. Elnvira Savings Bank (161 U. S. 275, 1896).—The court in denying the validity of at statute of the State of New York fixing preference in cases of insolvency, in so far as it applied to national banks, through Mr. Justice White, said: "National banks are instrumentalities of the Federal Government, created for a public purpose, and as such necessarily subject to the paramount authority of the United States. It follows that an attempt by a State to define their duties or control the conduct of their affairs is absolutely void, wherever such :attempted exercise of authority expressly conflicts with the laws of the United :States, and either frustrates the purpose of the national legislation or impairs the efficiency of these agencies of the Federal Government to discharge the duties for the performance of which they were created. These principles are axiomatic and are sanctioned by the repeated adjudications of this court." Easton v. Iowa (188 U. S. 220, 1903).—In this case the president of a national bank was sentenced under a criminal statute of the State penalizing the receipt a deposits with knowledge of the insolvency of the bank. In taking issue with the supreme court of the State Mr. Justice Shiras, in delivering the opinion of the court, said: "We think that this view of the subject is not based on a correct conception of the Federal legislation creating and regulating national banks. r.t.'hat legislation has in view the erection of a system extending throughout the 'country, and independent, so far as powers conferred are concerned, of State legislation which, if permitted to be applicable, might impose limitations and restrictions as various and as numerous as the States. Having due regard to the national character and purposes of that system, we can not concur in the suggestions that national banks, in respect to the powers conferred upon them, are to be viewed as solely organized and operated for private gain. The prin. ,ciples enunciated in McCullough v. Maryland (4 Wheat. 425, 4 L. ed. 606) and in Osborn v. Bank of United States (9 Wheat. 738, 6 L. ed. 204), though exPressed in respect to banks incorporated directly by acts of Congress, are Yet applicable to the latter and present system of national banks. "Such being the nature of these national institutions, it must be obvious that their operations caul not be limited or controlled by State legislation, and the Supreme Court of Iowa was in error when it held that national banks are organized and their business prosecuted for private gain, and that there is no reason why the officers of such banks should be exempt from the penalties prescribed for fraudulent banking." First National Bank v. Fellows (244 U. S. 416, 1917).—In this ease the State of Michigan contested the power of Congress to enact the provisions of the Federal reserve act conferring trust powers upon national banks. The Supreme Court of the United States (opinion delivered by Mr. Chief Justice White) revel sed the Supreme Court of Michigan and upheld the powers of Congress, citing with approval the principles enunciated in McCullough v. Maryland and Osborn v. Bank of the United States. Referring to the basic principles of constitutional law laid down in the above two cases, the court further said: "The doctrines thus announced have been reiterated in a multitude of judicial decisions, and have been undeviatingly applied in legislative :and enforced in administrative action." Burnes National Bank v. Duncan (265 U. S. 17, 1924).—In this case the 'State of Missouri attempted to enforce against a national bank the State law regulating the exercise of trust powers. The Supreme Court of the United States reversed the State supreme court upon the authority of the Fellows case and others above cited. Mr. Justice Holmes in delivering the opinion 44 the court reiterated the principle that the constitutional power of Congress was to be tested by the right to create the bank and the authority to attach to it that which vvas revelant in the judgment of Congress to make the business ,of the bank successful, and that this excluded the power of the State in such cases, First National Bank itt St. Louis v. Missouri (263 U. S. 640, 1924).—This case involved primarily the question of the power of national banks to estab- I • 79 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis George L. Harrison — Page 5 80 • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS list branches under the authority of the national bank act and rests upon a state of facts different from that of McCulloch r. 11laryland, in which the question of branches for national banks was first considered by the Supreme Court. to The First National Bank. upon the advice of its own counsel, proceeded establish and conduct a branch bank in the city of st. Louis upon the theory that whereas the Federal statutes did not expressly authorize national banks to establishArranches, such banks nevertheless possessed the incidental charter power so 1•6,..tdo. No permission from the comptroller was obtained for the. establishment of the branch. There was upon the statute books of the State a law prohibiting the establishment of branch banks in that State. The attorney general of Missouri on behalf of the State took the position. first. that the national bank act the national bank exceeded its charter powers under when it established,the branch and, second, that there being no permissive Federal statute, the 'State was competent to enforce against the national bank its own law against branches. The following propositions are quoted from. the brief of the attorney general of the State, which he tiled before the Supreme Court of the United States: (1) "Branch banking by a national bank in a State is conduct in excessof any authority from the Nation." (2) "Acts of a national bank in a State which are in excess of any authority from the Nation, and in contravention of State law, can be stopped by the State." (3) "An unauthorized, unlawful act of a national bank in a State should stand upon the same footing as the unauthorized, unlawful act of any other. corporation." (4) "A national agency is no more free from responsibility to the State. for unlawful acts done in the State beyond the scope of its powers and authority than is a State agent." (5) "The same conduct may be an offense against both State and national sovereignty, and may be restrained by both Nation and State." It was upon these grounds that the action was brought by the State in. the supreme court of the State in the nature of quo warranto. The formal allegation of the State was to the effect, first, that the bank was not authorized by Congress to establish a branch and, second, that in establishing the branch it violated a statute of the State expressly prohibiting the establishment of branch banks. At the request of the Comptroller of the Currency the Attorney General of the United States intervened in this case, not, however, for the purpose of upholding the right of the national bank to establish the branch but to contest the jurisdiction of the State to inquire into the question whether Congress. had authorized a national bank to establish a branch. It was shown before the court that the office of the Comptroller of the. Currency had for years construed the national bank act as denying the right of national banks to establish branches. This opinion was supported by an opinion of the Attorney General, May 11, 1911, which was cited with approval in sthe opinion of the court in this case. The principal argument of counsel on both sides before the court, and the bulk of the opinion of the court, is, devoted to the question of whether Congress had authorized national banks. to establish branches. The court reached the conclusion that there was no doubt, especially in view of the long-continued construction of the national bank act by the Comptroller of the Currency, that Congress had not conferred upon national banks the charter power to establish branches. In view, therefore, of this condition precedent the court held that the State. was competent to enforce its own law against the national bank. The question, therefore, of the constitutional power of Congress to permit national banks to establish branches was not involved in this case. The case is in harmony with the previous decisions of the court hereinabove considered.. Had there been upon the Federal statute books an amendment to the national bank act permitting national banks to establish branches the Supreme Court of the United States would have undoubtedly held the State law invalid as applied to national banks. The question asked by the court of the State law.. "Does it conflict with the laws of the United States?" would have been necessarily answered in the affirmative. In the absence of such an amendment the question WfIS answered in the negative. Congress inserted in the so-called MeFadden-Pepper Aet of February 25: 1927, a clause in its branch banking section that branehes of national hanks 81 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS X ) would be permitted only in those States which permitted the State banks to establish branches. This clause was a concession to the States not as a matter of constitutional necessity but rather as a matter of legislative policy. In view of the above consideration there appears to be no doubt of the constitutional power of Congress to permit the national banks to establish branches in any State of the Union, Irrespective of the laws of the State. If Congress determines that the national banks could better serve as instrumentalities of the Federal Government through the establishment of branches it would not be within the jurisdiction of a State to prohibit or restrict the purpose of the National Legislature to this effect. George L. Harrison - Page 6 /f / / Senator WALcOrr. I would like to refer. fOr a moment to the bank-I / ing system. Are you familiar with the English system of branch banking? Governor HARRISON. Just generally. \ Senator WALcorr. In the method of controlling the organization N,there you had a system which is exceedingly flexible, where you have- NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • • 83 a maximum responsibility on the branch banks rather than in the dictation from headquarters. Take Lloyds for instance, or any ' d example, where you large bank ; take Midland, which is a goo have now a pretty well-defined tendency of different groups or different banks to go into what we are trying to define as trade areas, trades, certain trades, into which certain banks ramify, or on which they specialize and with great flexibility and broad powers lodged in the branches themselves, because they are supposed to be expert, and because they are localized ; they are in that particular trade center, like Manchester textiles, like steel in Lancaster, and so forth, and shipping in Liverpool. Governor HARIUSON. Yes. Senator WALcurr. Are we working toward that or are we not t Apparently,I judge from the conversations that we are not working toward it at all. Governor HARRISON. I think we have not worked very far in that irection as yet. Of course you can never do it in this country in 11he same degree that they have in England, in my judgment, because of the difference in geographical area, and also secondarily because of the complication of conflicting State and Federal laws. We have never looked into the question whether Congress could authorize a national bank to have branches in several different States, but I suppose that would be possible. The CHAIRMAN. You know it took us 14 months, do you not, under the so-called McFadden bill, to get a fragmentary branch banking authorization. Governor HARRISON. But if our experience is demonstrating, Mr. Chairman, that the small country bank is finding less and less need for its existence, if the small banks will not find it profitable or necessary for them to continue in small communities, is there not the risk that sooner or later there will be certain sections of the country that will need some sort of banking accommodation with credit supplies from the central reservoirs where it is more plentiful ? I feeI that there is a real need for that system of conduits from the centers. to the more remote communities. The CHAIRMAN. Yes, I have felt that for a long time, but I have never been able to show it to Congress. Governor HARRISON. One danger of not doing so we are facing ‘now in the development of the chain and group banking, which in my budgment is unsound and frauaht with risk. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 ) • 04-*)91'44 J. H. Case, Chairman, FRB, N. Y. Hearings — S. Res. 71 /93/ ( The CHAIRMAN. Mr. Case, I take it from some of your observa/ tions there in your prepared statement, that you are rather disposed to favor a system of branch banking. Mr. CASE. Mr. Chairman, it seems to me at the present time that we are gradually drifting toward branch banking. Personally, while I think we are a long way off—and I personally hope we shall continue to be a long way off—from nation-wide branch banking, it seems to me that it might be desirable to permit a gradual extension of the branch-banking privilege, allowing banks, for instance,. to spread throughout their own county, and in course of time throughout the State. Then, as suggested by the comptroller, natural trade areas would develop. The CHAIRMAN. Would it not be extremely difficult to determine what is a trade area ? Mr. CASE. Perhaps it would. Of course, I am thinking of the metropolitan area, and it seems to me that there it would not be difficult. In New York we have the northern part of New Jersey and one corner of Connecticut, the southern tier of Connecticut. It seems to me--I do not know whether Senator Walcott will agree with this—that perhaps Bridgeport a,nd Stamford are large enough cities to become the center of a trade area in Connecticut, and that Newark, Pat,erson, Passaic, Elizabeth, and of course Jersey City and Hoboken and other places adjacent to the metropolis, might constitute trade areas of New York City. • # I ( NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 119 The CHAIRMAN. Are not there in Connecticut towns or banks large enough which might have their branches throughout the State of Connecticut, confined to State lines of Connecticut, who could attend to the commercial and industria 1 requirements of that State pretty well V Mr. CASE. I should think they might do that pretty well, although of course large corporations which are domiciled, say, in Bridgeport, might elect to either come to New York, or continue their banking )connections in New York, which have been established over a period of years. The CHAIRMAN. Of course, they do that under the State banking law. Mr. CASE. Yes, that is true. Still I would think there are or could be developed suitable banking institutions in Connecticut. The CHAIRMAN. You see the difficulty is, that we have to deal with this much contemned specimen of humanity called a politician, and there are some in Congress, as well as a large number of statesmen, and we can not jump right into the nation-wide branch banking. Mr. CASE. No,I should hope we would not. The CHAIRMAN. And probably with no expectation on earth of doing anything with it. It is very doubtful whether we can do much with the state-wide branch-banking proposition. I hope we may. Mr. CASE. Yes. I https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -4 ' J. H. Case — Page 2 /93/ i 1 • 1 The CHAIRMAN. But certainly we can not go beyond that. Mr. CASE. These bank failures, of course, are very disconcerting, and when you consider the number of lives which are adversely affected by them it seems clear that we must try to find a solution. It seems to me that a banker in a small community occupies pretty much the same position toward that community in a financial way as the local physician does in looking after the physical health of the people of the community. If the physicians do not do a good job, you do not have a healthy commumty, and similarly it seems to •._ me this is true of banks. When they are not able properly to adjust themselves to the economic changes, which have been alluded to, we i have too many failures and the community suffers. It is our duty ) to study the problem and find some way of solving it. The CHAIRMAN. You differentiate very greatly, do you not, be-----i tween branch banking and chain and group banking? Mr. CASE. Oh, my, yes, sir ; I certainly do. Senator WALcoTT. I hope, Mr. Chairman, we can bring that out before we are through with all of our questions, because that, to my mind, is very important and there is a great deal of misconception about it all. The CHAIRMAN. A very small conception. Senator WALCUIT. The public knows little about the difference. The CHAIRMAN. I think we will be able to do that by our inquiries and the report which they shall make to the committee as a result of these inquiries. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Albert H. Wiggin, Chairman, Chase Nat'l Bk., N. Y. Hearings - S. Res. 71 /93/ The ACTING CHAIRMAN. Let us discuss, for a little while, this question of chain banking versus branch banking and see if we can clear up the minds of the public to some extent. There is a great deal of confusion to-day that exists between those two terms. You are, of course, familiar with the English system of branch banking. What do you think of extending that system to some extent in this country, gradu ally? Mr. WIGGIN. Every community in this country that will support a bank is well cared for already. The communities that are not provided with banking facilities are communities that can not support a bank. We have had a very long experience in acting as correspondent of banks throughout the country, and we do not know of a cas where a solvent bank has been permitted to fail from lack of accommo dation from its correspondent. Our own preference would be not to see any extension of braneh bankin . If the branch banking were limited to...trade areas or. to e era reserve di.strids, it woulcLcause, in the New Y.-ork district, 1 lanks in other cities, which we a coinpetition in the buying of.sAtel would-dislike to see,__ present banking system as set -Y ou must also remember, with our York bank serving Nebraska New a for reason much up, there is just as We act as the correYork. New of as there is for serving the State the country and we lend those banks over all from spondent of banks was any_suggestion of brush from all over the country and if therecountry, we would conislez it whole the _of extenk banking to the difficulty and impossilaty eTc-Fidingly inactiFigible bemuse of the a satisfactory_wyay. A lot in e, distanc a uch i ritrs iiiore llinii OrriMi -ittee and I the House comm before argd orthis you had Notarirtlifipe much. too repeat to do not want r it be country-wide So in the suggestion of branch banking, whethe see nothing that is I can ts, e distric reserv l Federa or area or trade t a bank, with a suppor not will that nity going to supply a commu g for. strivin are they thing one the is ntly appare that bank, and banks many too are there think you Do The ACTING CHAIRMAN. now? a mushroom Mr. WIGGIN. Oh, I do not know. I think there was few years, last the in growth of banks, especially in the larger cities hat in the somew d reduce been has that but thy, that has been unheal last few months. taken care of? The ACTING CHAIRMAN. Most of them have been do not know. I drawn, be Mr. WIGGIN. Where that line should nice point to say The ACTING CHAIRMAN. Of course, it iS a pretty . You are, of system g bankin where any line should be drawn in a ations and ramific its and Board Loan Farm our r with course, familia system of the with r familia are the system of banking set up. You g. They sleddin hard having been have They banks. land joint-stock ment. Govern the by are not, in any sense, guaranteed helped without Have you an idea as to how that situation can be too much paternalism? I think Mr. WIGGIN. No; I think we have helped it too much. I able. obtain easily too her altoget we have made the farm loans think that is one of the causes of the trouble. ral? The ACTING CHAIRMAN. Insufficient collate s money, he buys Mr. WIGGIN. Well, the minute a farmer borrow liquid. kept not was another farm. It Mr. WiLus. It is not the fault of the banks? Mr. WIGGIN. In part. The ACTING CHAIRMAN. The bank permits that? Mr. WIGGIN. Yes. Eltr. 4 "fr' . Albert H. Wiggin — Page 2 / 1 3/ The ACTING CHAIRMAN. It might be well to cover chain banking for the record. Mr. WIGGIN. Well, I have no objection to chain banking. We simply do not want to do it ourselves. Mr. WILLis. Is it a sound system, Mr. Wiggin? NIr. WIGGIN. Well, y-es; I think it is sound. It is all a question of how far it goes and who does it. Mr. WILLIs. Under past conditions, do you think it can continue to be carried on? Mr. WIGGIN. Yes. Mr. WILms. Does it not tend to exert a central control, without central responsibility? • 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Nlr. WIGGIN. No; I think the responsibility is there just the same. Mr. WILLis. It largely nullifies or may nullify the double liability on bank stocks, for whatever it is worth, may it not? IvIr. WIGGIN. That is true. Mr. WILLts. What do you think of the provision in this bill with reference to chain banking—or have you examined that? Mr. WIGGIN. I do not know the provisions of the bill and I will not try to answer that. Mr. WILLis. The provision, in brief, is simply to give the voting power solely to the local owners so that the outside owners lose their voting power on the shares they OWD. Mr. Wmcusr. Is that constitutional? NIr. WILLis. I think it has been held that Congress can make the holding of national bank shares subject to whatever conditions it may see fit to impose, within specified limits. Suppose it were constitutional: Do you think it would have any beneficial effect, or the reverse? Mr. WIGGIN. I do not think so. I think there are several groups of chain banks that have strengthened the local banks. Nlr. WILLIs. Strengthened the local control Mr. WIGGIN. Strengthened the institution. NIr. WILLIs. IIere is a question, as it seems to me: The people in the various towns where banks aro bought up, for one reason or another—perhaps unwisely—object to that. They think they should have an institution locally controlled. Ought they not to be able to control that bank locally so that if an outsider conies in and buys it, he simply buys an investment, or ought they remain subject to the danger of losing their control of the local bank? Mr. WIGGIN. All they have to do, if they sell it, is to start another bank. Mr. WILLis. But you have already said there were too many banks. Mr. WIGGIN. No; I said I did not know whether there were too many banks. Mr. WILLIs. I thought you said there had been a fortunate reduction of a lot of weak ones. Mr. WIGGIN. Yes; I said that. Mr. WILLis. Then, the starting of another bank is not a satisfactory remedy for the existing situation. is it? l • 1 197 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Albert H. Wiggin — Page 3 3/ Mr. WIGG'IN. It depends on the community and its particular needs. Mr. WILLis. Take the ordinary small community, that can support a small bank; it ought not to have more than one, should it? Mr. WIGGIN. That is right. Mr. Wimas. It ought not to be necessary to start another bank to bring about a satisfactory conduct of that particular bank? Mr. WIGGIN. No. Mr. WILLis. It is perfectly true that if the people who ov,-n the bank stock resolutely say: "We will not sell it"—if they feel that way— we need not discuss it, but they do not feel that way, and when they have a high price offered them, they frequently sell to the disadvantage of the welfare of the town. That has happened. Is it not well to have a limitation on that,if you are going to continue to have a system based on the idea of the unit bank? You yourself have spoken against branch banking. • 1 198 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. WIGGIN. I think the people who put their money in the banks should have the right to run it. Mr. WiLms. Regardless of what they do? Mr. WIGGIN. I do not mean to say they should have the right to abuse it. Mr. WILLis. We are assuming they are abusing it; that they are withdrawing funds from the community; using the local bank as a means of mopping up the funds of the community and sending them elsewhere, which undoubtedly has been done in many cases, so that local industries have not been given the loaning facilities they ought to have. I am speaking now purposely assuming sound banking, but that the local funds have been mopped up and sent somewhere else. Mr. WIGGIN. Well, all they have to do is to start another bank. Mr. WILLis. But you are recommending as a remedy,the same thing that you have pointed out as a crying evil. Mr. WIGGIN. There are two different purposes involved. The local purpose did not exist for starting the bank where there were too many before, but in the event this bank that has been sold is run in such a way that local industries feel they are suffering, then they can correct that by starting another bank. Mr. WILLis. But suppose the comptroller said they should not have a charter? Mr. WIGGIN. He would not, if it was a respectable crowd. Mr. WiLus. Suppose he said he would prefer to give a charter to the local bank in a chain? Mr. WIGGIN. You are going a little too far for me. I do not know what would happen. Mr. WILLis. It seems to me you would have to make some provision against that contingency. The ACTING CHAIRMAN. Of course, we do not want to go into any unborn contingencies that may happen. I think we have briefly covered the ground we have covered with the various Federal reserve directors. Have you any questions, Senator Norbeck, you want to bring out? Senator NORBECK. I have none. Albert H. Wiggin — Page 4 / 95 / enator tsuLicLEy. 1 shouict ince to return to tn' at question of branch banks. I think you said the only purpose of permitting branch banks would be to provide banks for small communities that are possibly not in shape to sustain banks. As I understood Comptroller Pole's recommendation, it had a further purpose than that. I think his theory was that many small communities that have already banks would have stronger and better managed banks if they were taken over as branches of larger institutions. Would you care to comment on that? Mr. WIGGIN. Now, let me see if I understand. You are asking about the small bank in the small place? Senator BULKLEY. I am asking about the desirability of permitting branch banks, and one element of that is what effect it would have on the banks in the small communities. Now, as I understand it, Comptroller Pole believes that by permitting the larger banks in centers to buy up existing banks, or establish branches.in communities that can well support branches, those communities would be better served in that they would have banks of greater responsibility and better management represented in their Communities. Mr. WIGGIN. Well, where the community will. support a bank, I think that community is just as well served by one locally owned, as one owned outside , 1 • \ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Edmund Platt, V. P., Marine Midland Corp. Hearings - S. Res. 71 See clippings filed under No. 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Edmund Platt, V. P., Marine Midland Corp. Hearings — S. Res. 71 /93/ I • • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. WILids. I have read, in your writings, the statement iha .t well-managed country banks may helpfully establish sound branch banks. Mr. PLATT. Well, the word "country" is applied to banks as a technical expression. As used by the comptroller, it includes some rather large banks It does not mean ten or twenty five thousand dollar capitalized banks. It may be.banks of four or five hundred thousand dollars or a million capital. The ACTING CHAIRMAN. Suppose you go ahead and develop your suggested remedy for this. Mr. PLATT. I think the banking. laws should be amended so that country banks can consolidate just as the city banks do. I think the McFadden Act discriminates against the country banks. Under that act, you can combine the banks in fotu. or five counties if you cover them with brick and mortar, as in New York, but you can not combine them even in one county if it contains several small cities or towns. I do not see why they should not be allowed to merge. The thing that is important is that the country bank should be given an opportunity to do a diversified business. It should not be confined to one crop or to one class of.business—agriculture or anything else. Most of the country banks in this country, are, outside of New England and the East, where they generally have a sufficient diversification, so that those country banks can lend on a lot of different things. Outside of the New England and eastern country banks, the country banks are often located in neighborhoods where they have no chance to do a diversified business. The Chase National Bank, the National City Bank, and other large banks izr New York do business all over the country. It is not only business done with correspondent banks,. but with big business. Pretty nearly every town of any size has individuals and corporations that carry accounts in New York. Generally speaking, the local bank is not large enough to handle their business. Some of those local banks could be increased to handle the business by consolidations. That is one of the things the comptroller speaks about as decentralization of credit. I do not know how much that will amount to. I think big business will always carry accounts to ft large extent with New York and Chicago. They are our financial centers. 218 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS However, when...Led:pin banks were consolidated in Dowit they held certain of the business .Eit. reviouslv forced to New York. The same thin Eappened in tifraTo and in tTe-velanT.— sai , in my speec es on ranc an ing, tta -TTIE-oirght the "-Blaine law, permitting branches in groups of counties, was about right. If you can start with that and allow branches further away, through consolidation, where necessary for diversification, as it would be in the Dakotas and much of the West, where you would have to go much farther away in order to get enough diversification—if you can start in that way, you can begin to build up a system that will stand up. , 3 I think our banking system, for the purpose of serving small agricultural communities—I think it serves the cities excellently, as a rule--but for the purpose of serving safely and adequately the small agricultural cOmmunities, we have the worst banking system in the world. We practically deny access to the strong banks to the small man. Edmund Platt - Page 2 Mr. WILus. Just following that up: You talk about the consolidation of the small banks or isolated country banks. How are you going to get diversification? Let us take a group of small banks in South Carolina or North Dakota or Wyoming, where they are mostly all farmers, and in South Carolina where they raise cotton, and so forth, where you have a one-crop situation: How are you going to do it, unless you have a contact with some large center outside of that area? Mr. PLATT. In many places I think you would have to do that. Buc there is in South Carolina, since you have mentioned that, a. bank called, I believe, the South Carolina National Bank, with its headquarters in Charleston and a branch in Columbia and a branch over in the Piedmont at Greenville, and Mr. Small, president of that bank, in getting out his circular with relation to it, stated that when Charleston has a surplus of money and is lending it in New York, Greenville has a demand for money and, conversely, when Greenville was lending in Wall Street, Charleston had a demand for money. So, by connecting the banks across the country, they could keep the money in the State and more fully employed at home. In other words, Greenville is a manufacturing center, and the Columbia section has diversified fruit growing and cotton, mostly, while Charleston has some shipping and largely garden .truck, so that the peak demands do not come at exactly the same time. On a smaller scale it is very much what happens in California. I used to say that branch banking within city limits was of no consequence, economically; that it was all a matter of accomodation, like branch post offices, but since I have been getting some actual experience I find that our little group of five branches of the Marine Midland Trust in New York handle quite a diversified line of business. For instance, the branch at Chambers Street they call the butter and eggs branch, the branch at West and Liberty Streets does business with the railroads, so there is some diversification through branches in the big cities. The uptown branches handle a business differing considerably from that of the down-town offices. Mr. WILLIs. The group in South Carolina was a group of small banks picked up because they had gotten so weak they could not carry on? • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 219 Mr. PLATT. You are speaking of a different group. This group of banks, consolidated into a branch banking system by Mr. Small, was organized in January, 1926. There has been a group, perhaps more than one, organized since. The recent systems took a number of banks out of the Federal reserve system. The Federal reserve law as amended by the McFadden Act, does not allow branch banks outside of city limits. • Mr. WILLis. Would you apply the English development of branchbanking business to this country? Would that help? Mr. PLATT. I should agree with Mr. Wiggin, that I should hate to I see our banks have to compete with each other for branches all over ,___.. the country. You may come to that in the long run, but it seems to me it will be a long time coming and I do not believe there is any reason for authorizing it at the present time. All we need to do is to give the country banks a chance to gro_up themselves together for vouTd insure aThouse with an insurance diversification. No aiFT— company that had all of its risks in one town. But that is what depositors in some of the small banks are doing. Some of these banks are not really iust drying failinz, but. , 1.1D. ..%._ ____-___ l Edmund Platt - Page 3 f 3/ „ The ACTING CHAIRMAN. You approve, in a general way, m certain cases, of branch banks; in certain other cases you approve of group banks, where you have an economic and geographical situation that favors it? Mr. PLATT. Yes. I think a proper definition of group banking is the one the comptroller gave; a group of banks, the stock of which is controlled by a holding company and more or less integrated in management with a rather large central institution. The ACTING CHAIRMAN. Located in some proximity to the general area? Mr. PLATT. Yes. In the old chain banks there was never, as a rule, any big bank or parent bank, so-called. They were simply a string of small banks of about the same size. I think in Iowa there • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis was a chain of banks with what they called a parent bank not much larger, however, than the others. The ACTING CHAIRMAN. Bllt a Chicago bank could not have a small cluster of banks in North Dakota and call that a group banking system? It would be much nearer branch banking? Mr. PLATT. I do not know that I understood the question. The ACTING CHAIRMAN. It is a zonal thing or a regional thing? Mr. PLATT. Yes; the central institution should be contiguous to the rest of the group. All these nationally known groups have a large bank in the same general region with which the other banks are more or less integrated in management. They advise them on buying bonds, and so forth, and supervise their loaning policies, and it seems to me there is a great deal of advantage in the system. It is not as economical as branch banking, but it is the best that can be done in the circumstances. When the stock of the holding company has been exchanged for the stock of the banks,it seems to me you still have the neighborhood bank idea. The people still have a stock interest in the local bank as well as the group. Senator BULKLEY. Are you in accord with the comptroller's recommendation in that respect? Mr. PLATT. I think so. I think he has given us the right recommendation. It will give us the strongest branch banking systems. If I understand him correctly, he considers trade areas as rather large areas, and I am not quite sure that they need to be very large. You can have a trade area around a town of 50,000 inhabitants or even 25,000 inhabitants that would include two or three counties. Senator BULKLEY. We have had some difficulty in defining trade areas. What would you suggest as the limit, if not trade areas? Mr. PLATT. I think"trade areas"is perhaps as good a term as you could use, but I would not say that the trade area can exist only outside of a city of 500,000. I think that cities of 50,000 inhabitants or smaller also have trade areas that would compete with each other. I think all we need is an area large enough to psrmit diversification so that the banks will not have too many eggs in one-Kaska:— — --The ACTING CHAIRMAN. Treir, obviou-iTy, you can not limit a trade area to any radius, m miles; you must get diversification no matter how far you reach out for it? Mr. PLATT. Yes. Still, there is some diversification even in agricultural products. There is some advantage in loaning some money on wheat and some on corn and some on flax, and so forth. Crops do not all go down at once. Senator NORBECK. I think Mr. Platt is laboring under a great deal of misapprehension as to the products of our State. For instance, our income from butter and eggs is larger than our revenue from wheat; our income from tourists is greater than the income from wheat, and we lead in gold production. Mr. PLATT. Yes; that is right--out in the Black Hills. I got you for the moment mixed up with North Dakota. Senator NORBECK. North Dakota is a wonderful wheat State, and Canada is even better. There they have conditions which permit them to raise wheat at an advantage of 42 cents a bushel over the American farmer. 4 • B. W. Trafford, Vice Chairman, First National Bank of Boston Hearings — S. Res. 71 / 3/ 1 • The ACTING CHAIRMAN. Mr. Trafford, We want to consider the branch-banking question a little, also groups and chains. Of course, there is some modification between them. Have you given much , thought to branch banking and would you advise an extension of some form of branch banking for New England or the Northeastern group?* Mr. TRAFFORD. Speaking just of New England? The ACTING CHAIRMAN. Well, yes. Mr. TRAFFORD. I do not see any need for branch banking in New England. The ACTING &AIRMAN. Are you familiar with the point of view of the present Comptroller of the Currency on branch banking? He speaks of trade areas which, or course, is a pretty indefinite term. It might be a radius of 100 miles in the East and a thousand miles in the West. But whatever that might mean, branch banking, somewhat along the English line, perhaps. Mr. TRAFFORD. We would like that. The ACTING CHAIRMAN. You would like that? Mr. TRAFFORD. Yes, in trade areas. 244 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The ACTING CHAIRMAN. You would like to go out and establish branches—say, commercial banks along sound lines in any particular field? MT. TRAFFORD. Buy them. The ACTING CHAIRMAN. Buy up existing banks? Mr. TRAFFORD. 011r bank would, because Boston, as you know, is a little island with 30 municipalities around it. Municipal Boston is really a small thing. We think we would like to have banks not only in this municipality but in this entire area, which is simply metropolitan Boston. Mr. WILLis. Would that need be relieved by allowing branches to be established in counties—adjacent counties? Mr. TRAFFORD. Yes; but we would have to take in four or five counties. The city itself is one. Mr. WILLis. That has been suggested here. Mr. TRAFFORD. Certain adjoining counties. Mr. WILLis. Any county adjoining the one in which you are located? Mr. TRAFFORD. That might fit our case. I do not know what kind of arrangement you would have for the country over, to put that into effect. My own feeling is that the slower you go in branch banking at present, the better. Personally, I would go to as limited an extent and area as possible. Mr. WILLis. You think branch banking would give rise to unsoundness in banking or bad management in banking? One witness from New York has said that the effect of branch banking on a large scale would be to produce a race for the nurchase of banks, with the result of embarking upon perhaps a feverish speculaTfori. in the stock of those banks. Is that your thought? Mr. TRAFFORD. Yes; I think they are all right on the line ready to go. I do not know how many would go. I think it would have that effect. I do not think it would do much good. Mr. WILLis. If you had it in your Federal reserve district, as proposed by others, do you think the same effect would be produced? Mr. TRAFFORD. Yes; on a much smaller scale. There would be a few banks in New England bidding against each other. The ACTING CHAIRMAN. And you would bid those values up probably out of all reason? MT. TRAFFORD. That is quite true. f4L-' 1» https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis B. 77. Trafford — Page 2 / 3/ The ACTING CHAIRMAN.•Then, there is not anything in the suggestion unless it is done very quietly and without competition, and that is pretty difficult to regulate. Mr. TRAFFORD. If you raise the bars, that would allow a certain amount of competition. If you raise the bars for the county, there would be some; in the State it would be a little more, in the district it would be still more, but if you made it the whole country, there would be a great stampede. I do not think it would do any particular good. The larger banks do not need to be larger. The large business can be taken care of as it is now. 245 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS damage Mr. WiLus. You think the branch-banking system would off them cut to your correspondent relationships considerably—tend and drive them away? but if Mr. TRAFFORD. Yes; it would chop that system to pieces, would ities commun the think not do I law, it were permitted by resent it as much as if it were done indirectly. is some The ACTING CHAIRMAN. What we are feeling around for e the becaus d, EnOan New in way of improvement—not particularly st. Southea the like s, section other in than there r situation is sounde h throug periods lean long have and There you have a 1-crop situation the where ition compet -store grocery your have you each year, and villages, and often a trader is practically the banker in one of those system would relieve group the r whethe Now, factor. very bad load to steer the group the in bank large the situation, with perhaps one group--good group. Mr. TRAFFORD. I suppose it would if it was aserious in the Southvery is m proble The AN. CHAIRM The ACTING units being weak e imagin not you Can east and the Northwest. group which that in bank ling control single a h throug strengthened could diversify their loans and their business? Mr. TRAFFORD. YeS; I can. in New England for The ACTING CHAIRMAN. There is no parallel that situation, is there? e farming is a small perMr. TRAFFORD. No; there is not; becauscountr y banks are pretty the even centage of the business there and ion quite as depress the have not do we locally and well diversified and so we rule, a as good pretty is ment hard, and I think the manage s of section other in had have they uences conseq dire have not the The help. any needs really that end the country. That is the only bank does not. I big bank does not need it and the middle-sizedwhat the answer is. know not do I bank. think it is only the little had been they if losses same the made have would I suppose they in mortthe money had they If bank. -by the branches of some near affected have not it might but there, been have would losses gages, the bank. the depositors of that had close The ACTING CHAIRMAN. IS it not conceivable that if they have g would bankin their bank, master ed affiliation with a so-call ative? conserv more and r sounde little a been I do not know Mr. TRAFFORD. It might have been more sound. owned by a big is it r Whethe . district p 1-cro a in do can you what banks, small the of case the In a loss. is there bank or a small bank, get could you if ly Probab the money. lose ors deposit the s perhap areas, small in g bankin group than rather g bankin some small branch une to-1 that might help the situation./ I do not think it is opport presen.t the at scale, a large g on bankin branch to open the country and time. I would rather see an improvement in the management -be would -We d7 o -Tfed is prett got, which have we what stuRervision of do I lly Persona ft. not or nriert—iii experiment Which might rymg fit. would not lmow what extenThe ACTING CHAIRMAN. Of course, branch banking is a very the think I d. Midlan City ds, London d—Lloy Englan in sive system s. branche of number vast London City Midland has a Mr. TRAFFORD. Two thousand two hundred branches. B. W. Trafford — Page 3 1 • 246 vi NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The ACTING CHAIRMAN. hi England alon.e, which is a very small area. Mr. TRAFFORD. Yes. If you put England down on this map [indicating] it would not look very large. I do not luiow whether it works well. The ACTING CHAIRMAN. They think so. Mr. TRAFFORD. Perhaps it does. It might work better than ours, but it is not entirely clear to me. The ACTING CHAIRMAN. Have you any questions that occur to you, Doctor Willis? Mr. WILLIs. Yes; one or two. Have you any development -of chain banking in New England to any important extent? Mr. TRAFFORD. It is not growing. We have, I think, the largest chain. Mr. Wm.'s. Including how many members? Mr. TRAFFORD. We call it a group. We have what we call the Old Colony Associates, in which our corporation owns 10 per cent of the stock. The "Associates" which is a holding group banking system, owns a certain amount of stock of, I think it is, 20 of these suburban banks around Boston. Mr. WILLIs. What function does it perform in reference to them? What is its relation to the banks? Mr. TRAFFORD. They help the management. They have a management committee and they try to introduce the best methods of one into all others—really run them. Mr. WILLis. Do they pass on loans and discounts in the Old Colony Associates, or in each of the banks? Mr. TRAFFORD. They have a central loan committee which, I think, passes on loans over a certain size. Mr. WILLIs. Do you have a local board of directors in each case? i Mr. TRAFFORD. Yes. Senator TOWNSEND. Is the local board permitted to make loans? Mr. TRAFFORD. Up to a certain figure, and above that the central committee. Mr. WILLIs. How many such chains are there in New England? Mr. TRAFFORD. We have about 20 in that group which may represent $100,000,000 deposits. In case of branch banking of the type which has been suggested, they would likely become branches. I think there are three other chains, or two others, in Boston. Then there is a chain in Worcester County. I am not sure whether there are any more. Mr. WILLIs. Are these chains pretty successful? Mr. TRAFFORD. They have done very well. Mr. WILLIs. The central management has been a good thing; it has been shown to be a practical way of managing? Mr. TRAFFORD. Our management committee tell us so. Mr. WILLIs. I am spealung of it in general terms and questioning you about it as a method of banking, and not merely as handled by one of the best banks, or under its auspices, but handled generally Mr. TRAFFORD. I, personally, would prefer the branch-banking method. It seems to me the responsibilit is more centralized. Mr. WILLI . I al 1: .I : ,, :, :lu yvu ctittlrorthink highly of branch banking. 1 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis v.,- 6 AAA i, B. W. Trafford — Page 4 • /9,5/ NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • • 247 Mr. TRAFFORD. I think it is a mistake to do it now. Whether, 20 years from now, we will have it, I do not know. Mr. WILLIs. It is preferable to a chain. Mr. TRAFFORD. Yes; you have it all under one head and there is no shifting around. Mr. WILLIs. Who owns the other 90 cer cent of the old Colony Associates stock? Mr. TRAFFORD. The public. The ACTING CHAIRMAN. Where is your chief saving in a chain banking system? Are you saving in the overhead? Mr. TRAFFORD. Yes; we are saving a bit in the overhead, but not much. The ACTING CHAIRMAN. You think you could. do better where you have central control— Mr. TRAFFORD. They think they do it better. They think now that bank No. 20 is run just as well as bank No. 1, which had a spectacular record. The ACTING CHAIRMAN. That is by comparison of details of management? Mr. TRAFFORD. Yes,and watching the security lists, watching gen•eral trends, and so forth, and they think they have generally good results, and I think they have myself. Mr. WILLis. Do they give out to the public the information that they are in a chain system? Mr. TRAFFORD. I think they all do it—issue elaborate pamphlets. The ACTING CHAIRMAN. There is nothing hidden about it? MT. TRAFFORD. NO. The ACTING CHAIRMAN. Does the State take any cognizance of it? Mr. TRAFFORD. NO. The ACTING CHAIRMAN. There is no recognition legally? Mr. TRAFFORD. No. The ACTING CHAIRMAN. NO interference with it? Mr. TRAFFORD. No. Mr. WILLIs. They simply examine the banks each as an independent unit? Mr. TRAFFORD. Yes. The ACTING CHAIRMAN. Can a national bank take into its chain both a State bank and/or National bank and carry them in the same chain? Mr. TRAFFORD. Well, the chain is done through a vehicle which can do it. The ACTING CHAIRMAN. I mean such a vehicle. Mr. TRAFFORD. Yes. The ACTING CHAIRMAN. And that vehicle may be entirely owned by a national bank? Mr. TRAFFORD. It can not be held by a national bank, can it? Mr. WILLIS. By the stockholders. Mr. TRAFFORD. By a holding company; yes. Senator TOWNSEND.• Your published statements—are they published separately for each bank in a chain or altogether? Mr. TRAFFORD. In the legal statements they are each published separately and then the associates get out a group consolidated .statement. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 etfril r- George W. Davison, Pres., Central Hanover Bank & Trust Co. Hearings — S. Res. 71 / • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The CHAIRMAN. Mr. Davison, we are obliged to you for coming down. We have in process a general inquiry into the banking situation of the country with the expectation and hope of being able to do something to prevent a recurrence of such a situation as we now have. I believe you appeared before the House Committee on the 5th of last June? MT. DAVISON. YeS. The CHAIRMAN. And practically confined your statement to a discussion of the question of branch banks? MT. DAVISON. Yes. The CHAIRMAN. So that that hearing is available to the committee and the likelihood is that we shall not ask you to talk, certainly in an extended way, about branch banking, except that some members of the committee might have occasion to ask you some question about that. What we should like you to do is to give us a general statement of the situation as you see it, and of proposed legislation or any legislation that may commend itself to your favorable consideration; in other words, state to us what is the situation and what you think may be done to prevent a recurrence of it, if it is bad. Mr. DAVISON. That is a very large order, Mr. Chairman. The CHAIRMAN. Yes, but that is what we are making the inquiry about. Mr. DAVISON. I do not believe that you could make good banking by legislation. I do not know of any good banks that have failed. I think one— The CHAIRMAN. What we want to do is to prevent bad banking, as far as we may by legislation. 251 _ . The CHAIRMAN. And the only reason we did not have a very decided currency panic was, that under the Vreeland-Aldrich Act as amended, we put out about $300,000,000 of emergency currency. I believe—in fact, I know, having read your testimony—you are ppposed to branch banking. Mr. DAVISON. Noi_ I am not_ opposed to branch bankin_g within definite limits. I think I am opposed to chain banking of any kind".—The CHAIRMAN. And group banking? Mr. DAVISON. I thinkitis hadiinchrresponalLk. Branch banking within defmite limits, where your head office can know the needs of a community and where the branch is in close touch with the head office, has proven to be a satisfactory form of banking. The CHAIRMAN. Would state-wide branch banking appeal to your judgment? Mr. DAVISON. It would not. It would be very unfortunate. I think it would mean a remote control, which is entirely foreign to all our ideas and the theory and practice upon which this country has been built up. You would have clerks running the branch office, whose prime purpose would be safety, and loans made on personal character would not be made. The CHAIRMAN. Why would they not be made? , George T. Davison - Page 2 793/ 264 • • 1 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Me. DAVISON. Well, the record of branch management_is_go_ing to be, as far as the manager can make it, that he inalitLko losses. He will play safe always. The CHAIRMAN. Would not the parent bank be somewhat guided by the recotnmendation of its local representatives? Mr. DAVISON. Lt_a!yid npthave_the_touch and..knowledge that is riece_sary in_making some kin.da_of 14-)ans— loans that oeople would he entitled to. Senator WALCOTT. Would you be willing to extend branch banking somewhat as under the English system? Mr. DAVISON. I do not think our people would like it at all, and after I made some remarks about this out in San Francisco,I got one or two letters, particularly from a man who had been in touch with Canada, and he said that the people in outlying sec,tions there were just dried up;that the branches were deposit places, but they could not at loan's. Senator WALCOTT. They have practically the English method? Mr. DAVISON. They have; but it is a different nature of people. The CHAIRMAN. Well, is not the unit banking system carried to an undesirable, if not a disastrous, extreme when you have banks chartered all over the country with a capital anywhere from $15,000 up to $50,000? Mr. DAVISON. I am very sure that it is. The CHAIRMAN. And they break all to pieces. Could statewide branch banking do any worse than that? Mr. DAVISON. I do not think it would help it at all, because in all the groups that have been formed, you can not find the people, forming them, buying the little country banks. They buy the big, v. well-established country banks. The CHAIRMAN. Of course they would not buy these little country banks. They are simply pawnshops. They are not banks. Mr. DAVISON. You will not have branches going out there. The CHAIRMAN. No community should have any banking facilities if it be not able to support a bank. Mr. DAVISON. That is right. The CHAIRMAN. A unit bank that will stand, I mean. I Mr. DAVISON. YOU should not have more than the community can support. Senator TOWNSEND. Mr. Davison, you said you favored branch banking, but not on State lines. How would you define the limit? ,Z,A..trtMr. DAVISON. The limit would be where head office could be with the familiar situation of the thorotIghly branc anrs and where tbranch could be in constant touch with the head office, so that the wlio-le situation would We before_ diem. Senator TOWNSEND. Afid—ial—WOUld define it by county lines or trade areas? \ Mr. DAVISON. No. Trade areas might be very wide and too wide. The CHAIRMAN. Mr. Davison, is not the correspondent bank system of the country now practically nation-wide branch banking? Mr. DAVISON. No;it is not practically nation-wide branch banking. I think it is very much better than branch banking in that in each community you have a responsible body or bank that knows the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 34718- 31--PT 1 18 e v 4 e f"1/ ) ire C- George W. Davison 270 Page 3 NATIONAL AND FEDERAL RESER'VE BANKING SYSTEMS needs of that community and, as a rule, commands the respect of the community and knows all about it. It does its business independent of any direction whatever from the correspondent bank, but it does know that when it has made good loans and has pressure for money, it can always go and get money from the.correspondent bank, but the initiative and responsibiity are in the locality where they should be. Senator TOWNSEND. Would that be true with a well established and soundly-conducted parent bank with an agency in the community? Mr. DAVISON. I do not think it would. If you would go into one of the English banks, you would find they would receive your money, but when you wanted to talk about a loan, you would find it was a matter of long negotiation. The local managpment, as a rule, has no authority_i___ I think an extearTrbrancli baniing system would be simply using the remote community as a source of contributing, in a sense—simply draining money out of that community to the money center. The CHAIRMAN. There is one thing in connection with this discussion of branch banking that has always appeared to be outstanding to me, Mr. Davison. I have been in Congress about 30 years, on the Banking and Currency Committee of the House for 18 years and on this committee for 12 years, and I have never known a borrower to object to branch bankin. The onlyTobjeclions.farhavne have come from the bankers theinseives, and there seems to be some indicated by the more recent bankers, Change 91-1171.7F-aniong _Bind iers Association. action of the Americtui, Mr.ThvisoN. That was very limited, and that was a rather equivocal resolution that they passed. Certainly when I saw the American Bankers Association a year ago, in October, in San Francisco, they were whole-heartedly opposed to branch banking to any extent, and the way bankers talk to me, they feel that way still. The CHAIRMAN. Two years ago the American Bankers Association, was it not, at Los Angeles-Mr. DAVISON. They were at San Francisco a year ago in October. The CHAIRMAN. Well, were they not at Los Angeles two years ago when they had the McFadden Bill under discussion, with its very meagre, limited grant of branch banking? Mr. DAVISON. I do not know. Mr. WILLis. It was four years ago. The CHAIRMAN. Time goes by fast with me now. Mr. DAVISON. It certainly does. The CHAIRMAN. I know the American Bankers Association then reversed its attitude and 1 have never known a man or an association r lythaavaated_fredit to_ cthiectJAL a branch bankimg -system. _____Leji of Under the 10 per cent limitation, Mr. Davison, on loans to individuals, concerns or corporations, would a branch banking system overcome the many objections to that restriction? Mr. DAVISON. I do not believe that it works a hardship. If a inan is entitled to further credit, the correspondent bank is usually glad to takg_the.excess of it. —The CHAIRMAN. Is not that an aspect of branch banking? Mr. DAVISON. It is an aspect of cooperation which helps to overcome what you might call an objection to a local bank. • • The CHAIRMAN. It helps if it is always available. Mr. DAVISON. It is going to be just as available as the loan is going to be available if it is the branch of some bank, because we are going to have the same knowledge and going to have a man with experience and whose money is at stake in the community, rather than some one we hire. The CHAIRMAN. You think you have carried the spirit of independent banking to an excess when we charter a lot of little banks all over the country that can not stand up? Mr. DAVISON. I think beyond question. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I4 6 \ 1 John A. Broderick, Supt. of Banks, State of New York, Hearings — S. Res. 71 /9'3/ The CHAIRMAN. I do not think so. What do you think, Mr. Broderick, of branch banking? Mr. BRODERICK. Well, first off, I think there is no power on the globe that can stop the development of branch banking. Whether it is the best thing or not for the country is something that experience alone will show. It is coming. It is the only thing for cities. The day of the small bank in the cities has gone. It is hard for a small b,ank to find the type of managem.ent that is:_necessary to piotielly run the bank. The small banks get the extra hazardous credit risks, atia tiol the big banks. The CHAIRMAN. What is your exact definition of a city? Mr. BRODERICK. Well The CHAIRMAN. A city in which a small bank may not exist'? Mr. BRODERICK. I would say 100,000 or more. I find a tendency in every city of that size. A small bank will be chartered and it will 1 • • 1 282 t https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS be run about a year and then sold out. So with the national bank. A national bank will be chartered and will run about a year and will then sell out. Senator TOWNSEND. They convert them into branches? Mr. BRODERICK. We have killed that by giving branches direct. The CHAIRMAN. Is there a distinct analogy between a correspondent bank and a branch bank? Mr. BRODERICK. Somewhat, except the correspondent banks that take in the whole country. The CHAIRMAN. It is nation-wide, if the bank is large enough? XII% BRODERICK. I do not think we will ever have a nation-wide branch banking system that will run successfully. The CHAIRMAN. Bid we -have a correspondent banking system that is nation-wide. Mr. BRODERICK. That is true, but that has been built up over a period of years. In most cases, you will find there is a generation of experience with the particular banks. There is only a small number of banks in New York that have that system. The CHAIRMAN. If there is objection to branch banking, even to a limited extent, such as State wide branch banking, would not the same objection apply with equal force to the correspondent banking— nation-wide correspondent banking? Mr. BRODERICK. It is a case where we have one and have not the other. The CHAIRMAN. Well, have you not to some extent the other? Mr. BRODERICK. The New York City banks and Chicago banks that have a large number of correspondents are really banks of rediscount. They are doing a large rediscount business for their correspondent banks, performying the same function for their correspondents, as the Federal reserve banks do for their members. The CHAIRMAN. Which it was never intended they should do. ( 1"1" 4 1 tar4444* f 4441m A. Broderick - Page f" Mr. BRODERICK. May I go on and answer the question about , branch banking? The CHAIRMAN. Yes. Mr. BRODERICK. I think there are two or three things that will bring about branch banking within limited areas.. One is the difficulty in replacing the present inanagers of small unit banks and one subreason for that is the expense of running these small banks is growing each year and the income is not sufficient, and the second big reason is that in a community like New York or New England, where most of the banks have excess funds on deposit—that is, deposits in excess of the borrowing demand in that particular community—are having difficulty in properly and safely investing their surplus funds. The average banker at the present time has not the skill that is necessary to invest those funds in the proper way. The CHAIRMAN. Is there any greater incentive for a small bank, locally organized, to do business than there is for the established agency of a branch bank in the same community? Mr. BRODERICK. I do not think I am clear on that question, Senator. The CHAIRMAN. What I mean is Mr. BRODERICK. What is the advantage? The CHAIRMAN. Is there more incentive to a bank locally organized and conducted by officers and the board of directors, to do business 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 1 283 in the community than there would be for a branch bank of a large parent bank, doing business through an agency? Mr. BRODERICK. No; except the prestige which generally comes to a man who is president or a director in a bank. Objection is raised by the opponents of branch banking that the communities would not I II he branch of an existin lg Lnk as receive as much co I • _ ...2 they would from an independent institution,. The UHAIRMAN. Why-hair-That is wbat I am trying to reach. Mr. BRODERICK. I can not answer that. I think that idea is _a fallacy. The CHAIRMAN. The parent bank is in business to do a banking business and I should think it would to the fullest extent respond to the demands of the local community just as readily and as completely as a locally organized bank. Mr. BRODERICK. For all the legitimate needs of the community. What they really mean is that they want a local bank there because thez will hayelin easier credit policy than they wouldzet from a Targer institution. rITAIRMAN. Would that be true if the overhead of the local --TECt bank exceeds considerably the charge of an agency there? Mr. BRODERICK. It would exceed it. The CHAIRMAN. Well, I say it would exceed it, and if it would exceed it to any considerable extent, could not the branch agency of a parent bank be just as liberal as a local bank with its credit accommodations? Mr. BRODERICK. YeS; except a local bank will be probably more liberal to its own officers and-directors than an outside institution.--Th--6 CHAIRMAN.-Arid that has been an abuse, has it not? Mr. BRODERICK. Yes; and I think you will find one of the recommendations I have here is an attempt to curb quite a few abuses, Senator, which I would not dare mention in times like this. https://fraser.stlouisfed.org imp Federal Reserve Bank of St. Louis 1 cs----TF5 • Charles E. Mitchell, Chairman, National City Bank, N. Y. Hearings - S. Res. 71 /93/ Mr. MITCHELL. I take no firm position as favoring unit, branch, group, or chain banking. I can not, however, be blind to the fact that while unit banking as a sole system has played a prominent part in the development of our country, and still has its ardent.adherents, there is a very definite trend away from it, a trend that is fostered not by individual authorities but by public interest. It is to be.expected that as.time goes on and the public has tested these various types of banking, the right kind of banking for this country will develop from popular demand. It is my observation that, while national feeling in the United States is second to none existing anywhere else in the world, local civic and neighborhood pride and desire for autonomy is prevalent throughout the United States to an outstanding and exceptional degree. I feel that this must be taken into consideration as the trend in banking develops, and that, while in the ultimate whatever system best serves the public interest will doubtless be adopted, it is important that no banking trend should be forced by precipitate legislation, either permissive or restrictive. The development should be no more rapid in any direction than is sanctioned by the gradual change of public feeling. Frankly,it would seem clear that the small unit banks for outlying and rural districts have as a system outrun their exclusive position of popularity. It always has been claimed for the locally owned unit institution that it was more responsive to the wants of the conununity than a branch of a larger institution, with headquarters elsewhere, would be. Doubtless there is something in the argument, but it works both ways. The most important of all considerations in valuing the services of a bank to a community is that it shall care for the funds entrusted to its custody in such manner that they shall always be safe and ready for return to the depositors on demand. There is such a thing as a banker.being too responsive to local applications and too much under the influence of local and personal ap .41s. from-Tocal The fact that a local bank-e-i's is under greii"W. borrowers than a branch manager, supervised by an outside author. depositors to be imperiled for the ity, may cause the interests of accommodation of borrowers; indeed, the record of failures proves this to be frequently the case. Every period of boom times has had many bank failures in its wake, because the local bankers were under the same influences and affected by the same psychology as their customers. Branch banking where permitted by law, and group banking in part as a substitute where branch banking is not permitted, and a https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Charles E. Mitchell - Page 2 316 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS combination of these developments sometimes working hand in hand, is gradually but assuredly taking hold alongside of the old unit system. The development has come about not by the establishment of new banks to compete with the old nor by aggressive action from large financial centers. It has been largely due to local conditions where the opportunity existed for constructive reorganization. It is well that this movement is gradual, as it is educational to a public that is primarily interested in banking service. It is not a movement to be feared. Banking is not a business which can be monopolized. _dra,w.n_ away_from-the The idea that local molity_Dr_capital wi cities and. thatioca 1 TIPPils_wilLgia...unc.ared towns for is unwarranitesl. It is not at all likely that money will be drawn from a higher to a lower market, and since money is usually cheaper in large centers than in the outlying districts, closer relations between the two are most likely to result. There will be no monopoly. It should be borne in mind, however, and the importance of it is so vital as to justify repetition that the normal banking development which has occurred in a natural and orderly way in most other countries has been discouraged and restricted in this country, and this fact creates a danger of a hasty, competitive development and one that will be publicly resented in case all'restrictions are taken off at once. It is undoubtedly best that we gain experience gradually, with legislation keeping pace therewith. No reasonable obte_ction, ever from the standpoint of public inter_est _can_bei_offezeJ to the atresisille branch banking privilege-for-State and zatio,pftl tey_ond the present restricted areas. If such a develop- ( banks alike b ment gives o the public ra. safer and better 'banking service, the demand for a further extension of power will come from a convinced pubilic and the development will be a normal and accTpted one. How far immediate leg,islation should go in advantageously extending permissive powers for branch banking is a difficult problem. The trade area suggestion appears to me at present too broad in its scope. The suggestion of extension to county or to Siateliiies seems a_rtifir-iaL The expansion to Federal reserve -districts -eitends the territory ta-asuinKarranted, deffee,under existing circumstances and furthermore is filled with impracticabilities owing to the fact that the districts themselves do not represent either trade areas or spheres of natural banking relationships. My one suggestion would be that legislation should be such that under the carefully giyen yermits of the_comptrAler's offica_tba_limitations of branch banking be extended to a somewhat larger field in IE.einainediiite vicinity •, oLour alTifiWing fhe ex-pertene-e- of this extension to be the guide in future legislation. I feel that group banking is playing a most important rale in what may be a real trend from unit banking at the one pole to widely practiced branch banking at the other. Where well managed, the groups se,em to be satisfying the needs of the public which they serve. That they lack the flexibility, the effectiveness, and the economies of the branch system is obvious. As a measure of prudence, I feel that the holding companies should be under the inspection powers of the office of the Comptroller of the Currency. Senator WALcorr. You would rather have a swing toward the branch banking idea than to work out its salvation ultimately • • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 317 through the group-banking system. You think the natural trend should be toward branch banking? Mr. MircHELL. I feel that the trend is to be toward branch banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • 0.401-r-a c Henry m. Robinson, Chairman, Security-First Nat. Bk. of Los Angeles Hearings - B. Res. 71 /93/ been favorably Mr. ROBINSON. Based on our experience, I have amplification the of impressed with the comptroller's suggestion be defined might that areas in s branche of the permission to extend That center. the as ity commun larger some with areas ic as econom funa be would think I That nce. experie is based largely on our change. al dament Senator WALCOTT. You would let that grow slowly ? Mr. ROBINSON. Yes; grow slowly. 1 323 a Senator WALCOTT. To avoid competing for banks at too high price? +Litd`; Mr. ROBINSON. Yes, sir. 1 Senator WALcorr. A.nd if it went through it would be more along ? Jeg4) 1 the English system, where you would actually own the branch is Mr. RosricsoN. I think it should be a branch instead of what I base called a chain or group bank. I believe. the control is better.. -ah7 frial have i that on my own experience where-We veyi The possibilities of, impropebr ranc inbecause , banking much greater than they are in ranch between the difbanking the definite information as to transactions the management by both ble, obtaina ferent branches is more readily I think it is . banking group of case the in than ies and the authorit safer and final Anare-iisconomical. rs-t'started in branch banking was that, ur experience when we fi— many differin giving autonomy to the branches, we ran into a great t branches differen the of ement manag, the of part the ent attitudes on ity and as to what their duties and obligation$ were to the commun to get IQQA#44/v-.):::r growth slow of matter a been has it And itself. to the-bank Mtjpg the branch managprs tio conforin_tio whaels considered bestthe I know and ate7 accentu be would ibit ihai see can piadice. banks ual individ the where g revifie accentuated in (Troup bankin carry on, either along the lines that have been our experience or new lines, and they may not always be safe or sound. I do not mean to say that necessarily the branch-banking management is always safe and sound, but that it can be more easily controlled as to safety and soundness in a branch-banking system is my belief based on experience. Senator WALcorr. You think that the contact between the large controlling bank and the outlying or small district bank is a wholesome thing for the small bank? Mr. ROBINSON. Yes. Senator WALCOTT. And do you think the small bank would give fully as good service and perhaps be safer ? Mr. ROBINSON. Our experience in the countr/ is that we have done s than the could-have done • • • II more for the bra ks. In other words city um, have gone to our coUTTI ry- branc es. And that has been true for the last 10 years. Senator WALcorr. So that the country districts are better oft, you think, under the branch system? Mr. ROBINSON. Not necessarily. That again would be a question of the administration's view of its obligations to the various communities that it served. But I think in our experience that our branch banks generally have done that. Senator WALCOTT. And do you get through your branches a kind of diversification ? Mr. ROBINSON. In our particular case; yes, sir. We have almost what the comptroller calls an economic area. We have a great, wide diversity, and that means a better use of our funds than the individual banks could have had. Senator WALcarr. You increase your load factor for your loans? Mr. Rosnisorr. Yes; for instance our crops come on through th various months through the year. 'So it is almost a revolving fun through the year. ( • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 Henry M. Robinson — Page 2 1 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 325 Senator WALcorr. Yes. Mr. RoBiNsoN. So we are rather in a fortunate position in that respect. But we do believe that diversity is good, and that you want to get it through a branch-banking medium that covers a reasonable area. Senator WALcorr. Senator Norbeck, have you any questions on this point ? These are rather general questions until we get to something more specific. Senator NORBECK. I was late in attending the committee meeting, so I did not hear the opening remarks of Mr. Robinson, but I am •interested in what I did hear. In speaking of getting the money out into the country in larger quantity than before, is it not a fact that even prior to branch banking that funds from the center or cities went out into the country banks more or less through their correspondents ? Mr. ROBINSON. Yes Senator. Senator NORBECK. in other words, in so far as the city banks are concerned they had the outlet before as well as now, did they not ?' Mr. RomNsoN. They had an outlet; yes. I do not think it was a satisfactory outlet always. Senator NOBBECK. That is rather a general description. I wish you would go into that further and state as to what you consider satisfactory. Mr. ROBINSON. The difficulty was to be sure of the use of the funds that were put out through the local banks. In our own branch organization we are able to appraise the value of the loan with greater accuracy, and it was safer for the bank, and really safer for the community through the brnch system, than it was where the city bank advanced occasionally and on emergencies to the country banks, the unit bank. Senator NORBECK. You mean that in the past the local bank could make too liberal loans, which can be avoided under the branch system ? Mr. ROBINSON. At times; yes1 sir. Not always. It depended upon the character of the management of the unit bank. Senator NORBECK. The local bank, of course, has a board of directors who live in the community and are generally familiar with the personal situation as well as the security ? Mr. ROBINSON. Yes. Senator NORBECK. And under the branch system you have the one man in charge who makes a written report to the centers, and on that information the loan is generally made, is it not ? Mr. ROBINSON. No, sir. We have in the local branches in each case an executive board which corresponds with the board of the unit bank, of the men in the community who are best informed. And they have full authority to make loans up to certain limits without any consultation with the head officers. Senator NORBECK. And what would the limit usually be ? Mr. ROBINSON. It varies somewhat with the community. It will run as high as $50,000, and I think in one instance $100,000. Senator NORBECK. And as low as what? Mr. Rom/ism:T. As low as $10,000. 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Henry M. Robinson — Page 3 / 3/ 326 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. You do not maintain that usually that is the way that the ordinary branch-bank system is handled ? Mr. ROBINSON. I can not answer you RS to that. In the California branch bank I think that is the usual system. Senator NORBECK. A few years ago I spent some time in Canada, and I found a farmer who wanted a few hundred dollars for seed grain in the spring, and who had put in an application some time earlier, and it was sent down to the central bank in Montreal or Toronto, and he had to wait a week for a reply, and I know in one case, at least, that the bank changed managers, and when the farmer came in for his money the manager said,"Well, we decided not to make any loans out here." Mr. ROBINSON. That does not apply to our operation. Senator NORBECK. Is not that a condition that can easily develop where the authority is so far from the business? Mr. RosiNsoN. I suppose it could, Senator. But it would seem to me that the administration of a bank would be very unwise if it permitted it to develop, because the bank, after all, is dependent upon these various communities for its merchandise and for the sale of its merchandise. Senator NORBECK. I agree to that, but is not that almost the rule of life, that the unwise things are done? Mr. RomNsoN. At least occasionally. Senator NORBECK. Both with bankers and farmers. Mr. ROBINSON. I think some errors have been made by bankers. Senator NORBECK. Are not they liable to be made under a branch system, too ? Mr. ROBINSON. The probability is not as great. Senator WALcorrr. In other words, you give to your district bank or branch almost complete autonomy ? Mr. RomNsoN. No; as I say, not complete autonomy, because we ask them to conform to proper banking practices, as we view them in the head office and we try, of course, to study banking practices And that means that they must conform as to their all of the time. ' forms. And when it comes to the matter of loans the local executive board has authority within limits that vary according to the com munity to make the loans, and they do. Senator NORBECK. I think you stated before I came in what your connections were. Mr. RosnrsoN. Yes, sir; I am chairman of the board of the Security-First National Bank of Los Angeles. Senator NORBECK. With how many branches ? Mr. RomNsoN. I can not say exactly, but certainly I think 130. We keep consolidating them. Senator NORBECK. And when did you first branch out? Mr. RonntsoN. About 1921. Senator NORBECK. There is the same old trouble again. We have pretty short experience on a matter which we are asked to legislate upon. Mr. ROBINSON. Yes, sir; it is only 10 years. But possibly our experience is as old as most of them in the country. Senator NORBECK. The unit banking system is much older in this country ? Mr. RomNsoN. Yes, sir ; and it seems to have had its troubles, too. Henry M. Robinson — Page 4 /7 / _ __ Senator NORBECK. Why condemn the banking system because an economic situation becomes so impossible that banks can not survive in certain sections. Mr. RoniNsoN. I think there is a good deal of truth in your statement, Senator. I may venture the opinion, however, that the other is more elastic, and, a,s we view it, more beneficial to the local community than the unit bank has been in the past. Senator NORBECK. I must admit that we in the prairie States are / deeply appreciative of the great concern that has been shown over our welfare in the past few years. It seems that branch banking has _been talked before. We have been hearing it before. . .. - -- j https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator WALCOTT. Mr. Robinson, are you familiar with this provision of the proposed law, section 4, on page 4? There is a proviWill sion there which amplifies the law regarding branch banking.favor ? with you strikes it whether us you glance at that and tell Mr. RowNsort. I have never thought that we have reached a time limits of yet where it was a large advantage necessarily within_the economic so-called the thought I that believe, I stated, I State. a measure area, if it could be properly established, would be a better furnish really boundaries State that know not do I because this than of necessity, a diversification. Mr. Wthms. Is there any harm in this one, Mr. Robinson? Do you see any danger in it at all? Mr. ROBINSON. I do not know that I do. /' NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator WALcorr. That is without limitation to the area, or would 328 you put in a mileage limitation ? Mr. ROBINSON. A mileage limitation would be a very difficult thing. Mr. WILLIs. How would you fix the area ? Mr. ROBINSON. I understood the suggestion had been made of trade areas. Senator WALCOTT. That is the comptroller's word, trade areas. Mr. ROBINSON. Yes, sir. Senator WALcorr. But neither he nor we ourselves have ever defined trade areas. It would be different with every section, of course. Mr. ROBINSON. I tried to study that out myself. But my brance is that the suggestion was made that a committee rememof the Secretary of the Treasury, the comptroller, and theconsisting of the Federal Reserve Bank act as a committee in trying governor to define such an area. And I think possibly they could do that. Mr. Wm.'s. You mean you would let them fix the area in every case without having an application and on their own motion ? Mr. ROBINSON. Yes, sir; I believe that would be a method. of getting at it. Mr. WILLIs. Is the California law working out on the whole satisfactorily now ? I mean to say is the legislative situation there as to branch banking about as good as vou can makp Henry M. Rob Lnson — Page 5 /f3/ 1 Mr. ROBINSON. Of course, they have the law which permits branches anywhere in the State. There is only one bank that undertaken that. The banks in California—the branch bankshas California—could be put into really four groups • first, " in statewide "; what might be called "economic area" as 2; and No. 3 "metropolitan area "; and as No. 4 "city branches ". There is only one attempt to :g,o state-wide. Our bank is next in order, and covers what we call the area, and we get as our boundary on the north the point economic rail rates break as between San Francisco and Los Angeles. where the Mr. WILLis. Now, the California law has some nts as to number of branches, hasn't it, in proportion torequireme capital of the bank, or am I wrong about that? Mr. ROBINSON. I do not recall that. I think not. Mr. Wm.'s. Do you think there should be any such ? Mr. ROBINSON. I do. Mr. Wm.'s. How would you arrange that? Mr. ROBINSON. There,.._again, I think it would depend somewhat on the character of the business being done in the area where branches would be located. I would hesitate to say what ratio the that should be. "Mr. WiLus. You would limit the number of branches in proportion to the capital of the bank ? Mr. ROBINSON. Yes. Mr. Wm.'s Would not that eliminate a great many objections that have been made to branch banking Mr. ROBINSON. I think so. Of course, we have had an area of competition in our particular section for the creation of branches that has created an unwholesome condition, and that would be a step in the right direction, undoubtedly. NO. r'‘ • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 1 329 Mr. Wniss. Are there any changes in the California law that are contemplated in the early future ? Mr. ROBINSON. I have heard of none; no. Senator NORBECK. I am impressed with your using the words"unwholesome condition" with branch banking in California. Might we not also get an unwholesome condition when we get branch bankin in South Dakota ? . r. Rosucsorr. If it comes in the immediate future I think there is very little danger. You see ours was a type of competition that came in when the speculation in the banking field was very high. Senator WALcorr. The prices of the banks were too high ? • ... Mr Rnwricsnw_ Yes. ...„ ...,. .. . . . . Senator NORBECK. I notice again we have our branch banking discussion based on the 10-year experience. I would like to have it based on the 50-year experience, which I think would be a better one. Mr. RomNsoN. I agree that it would be better, but I am afraid that I will not be present at that time. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "4/t, •, t, " //3/ Henry M. Robinson — Page 6 Senator INTORBE-CK. Tell us about these committees of the branc banks that are authorized to make loans without consulting the cen tral bank. I wish you would explain that a little further. I pre sume there is a fixed limit as to the amount they may loan. i Mr. ROBINSON. Not in any given case. Senator NORBECK. Nor as a total for the branch ? Mr. ROBINSON. No ,• not that exactly. But we show them a chart, give them a chart, which indicates what, if they were a unit bank, \ they would have a right to loan. When they have reached that in their loans they then take up with the head office to find out whether we might be willing for them to go beyond that. Senator NORBECK. In other words, you determine what you allocate to the community. Mr. ROBINSON. By its deposits. Senator NORBECK. By its deposits? MT. ROBINSON. Yes. Senator NORBECK. Are they the actual deposits or theoretical deposits ? Mr. RosucsoN. No; the actual. Senator NORBECK. The actual deposits ? Mr. ROBINSON. YeS. Senator NORBECK. And they are permitted to loan what part of those deposits ? \ NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 335 Mr. ROBINSON. The same percentage that we would in the head office. Senator NORBECK. And then if there is anything further they have got to apply to the head office ? Mr. ROBINSON. Yes; to go beyond that. Senator NORBECK. I can not see they differ much. If they were a unit bank they would be able to loan just the same amount they are loaning now. Mr. ROBINSON. Yes, sir. Senator NORBECK. Only in the latter case they would apply to the other bank for additional funds. Mr. RosiNsoN. Yes; additional funds. Senator NORBECK. I can not see the distinction. I can not get the advantage that comes to the branch with those limitations on it. Mr. RoniNsoN. There is just one other difference, which is that with the unit banking system the city bank might not be as willing to advance excess funds as the central office might be willing to advance to its own branch. Senator NORBECK. Might it not also work both ways? Does not the city bank advance funds to its correspondent to help it hold its business ? Mr. ROBINSON. Yes; I think that is the primary reason. Senator NORBECK. And that influence would not enter here, since the branch banks would be the only banks. Mr. ROBINSON. No. But the other influence I think is stronger, and that is a desire to maintain your community. For instance, these advances are seasonal, and, as I say, in our area they are rather revolving, and one bank at one time flourishes, and at another time another bank, and it enables the funds to go to different districts. They do not fail to employ their funds in that way, and I think it works out better than it would with the unit banking system in that respect. Henry M. Robinson — Page 7 /9 / Senator NORBECK. For instance, here is a correspondent bank getting money from you, getting funds from you rather, for which they pay a certain rate of interest somewhat below the rate at which they loaned ; is that right? Mr. ROBINSON. Yes. Senator NORBECK. In this case you get the benefit of the whole return on whatever the money is put out at, do you not ? Mr. ROBINSON. Yes. _ Senator NORBECK. In other words, where you might be putting money out to a correspondent at 4 per cent, you can in this way put it out at 6 per cent? Mr. RosiNsoN. Yes, you can do that. And, on the other hand, I think—I do not know that I would want to state it positively— it would show during the last eight years that the community has had a lower rate than it would have had from unit banks borrowing from central banks. Senator NORBECK. But this much you admit, you take more out of the community than the unit bank did. Mr. ROBINSON. No,I do not. I say we take less, I think. Senator NORBECK. I mean in the way of interest charge. Mr. RomNsorr. I mean in the way of interest charge. 1 336 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. Your interest to a correspondent bank might be 4 per cent, and now you get 6. Mr. ROBINSON. That is correct, but we get it because we maintain an office in the community. Senator NORBECK. Yes. Mr. ROBINSON. And furnish the machinery that a unit bank furnishes. And I say the community bank gets it at a lower rate, I believe, than it would where the unit bank in the community borrowed it from the central bank. Senator NORBECK. Of course there would be less distribution in the community of dividends and salaries than there was formerly. Mr. ROBINSON. I do not even agree with you on that, because in our case our stock is scattered and owned very largely in the communities where we have branches. And I would say as to salaries that perhaps we do not pay quite as much in the large, but I do not think it would differ very widely. Senator NORBECK. As near as I can figure out, as you tell me, you may have a certain greater advantage in dealing with the branch 'bank than in dealing with the correspondent. Mr. ROBINSON. Yes. Senator NORBECK. But I do not see where the community gets any advantaffe out of it, except the possibility that in case of great need they might be taken care of better. Mr. ROBINSON. I am sorry you have gotten the impres.sion of possibility, because I have said that in our case that has been our practice. Senator NORBECK. We are not talking about your practice. We are talking about the banking laws of 48 States. Mr. ROBINSON. I can tell you that I think that the administration of the branch banking would take the same view that we have. This is mv belief. It is only a matter of belief, of course. 1 Henry M. Robinson — Page 8 1 • Senator NORBECK. Yes; it is possible. It is your belief that they would have such a liberal attitude toward the small communities and that they would furnish them more funds than they are getting now V Mr. ROBINSON. No; I would not put it on that ground. I think that they would use the funds of their branch banking to the best advantage of the communities, first, in safety, and then to the best advantage of the communities in which a bank is placed. Senator WALcorr. By diversification you can revolve and move the funds from one community to another, and in that way you can keep your money working better. Mr. ROBINSON. Yes. Senator NORBECK. May I ask if that has not been done for 100 years in banking in America ? Mr. ROBINSON. Yes. Credit moves very fast. Senator NORBECK. Yes. But this is not an innovation. Mr. ROBINSON. No; it is not an innovation. It is an improvement, because I think there was a definite lag in the movement of funds where you had a multiplicity of the unit banks, a very definite one. In the first place the management of the small unit bank, we will say, from which the customer is desirous of obtaining funds, has quite a little time making up its mind. Then it goes to the city bank 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 337 and they wrangle about security, and this and that, and try to appraise the security value, and at last get the money. Yet, at other times, hardships have come because the city bank felt no responsibility for the community,.which the branch bank does, and at times would decline to assist, where the head office of the branch bank would feel that it was its duty to assist. 1 /—Senator WALCOTT. Has the progess of bank mergers in Calis/ fornia been retarded or furthered by the branch-banking system ? \ 1 ,\ Mr. ROBINSON. I ShOlIld say it had been retarded, because most \9_f the banks have gotten into branch banking by this time. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Owen D. YounE, Chairman, General Electric Co. Hearings — S. Res. 71 /93/ 77f7=7 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The CHAIRMAN. Do you advocate branch banking ? Mr. YOUNG. I see no escape from it if we are to have the required credit service for the country. The CHAIRMAN. Would you think that branch banking should be nation-wide? Do you think we should attempt that at this time? Mr. YOUNG. I should think not. The CHAIRMAN. Would you confine it to the States? Mr. YOUNG. Personally, I should experiment with it in limited areas. The CHAIRMAN. The Comptroller of the Currency suggested trade areas. It occurs to some of us that that is a rather general term, and it would be difficult in a statute to define a, trade area. Mr. YouNo. Yes, sir. It seems to me as a practical matter you would have to take some well-defined geographical division, either State or, if one wished to make the experiment that large, a_ Federal fe-§erve district. rilioTiI1 Have gnat doubt-whether branch banking , ever na-d be extended beyond the district, but so long as it, were confined to the district--The CHAIRMAN. The Federal reserve districts ? Mr. YOUNG. The Federal reserve districts; and the Federal reserve bank of that district, therefore, being familiar with the home bank and all its branches, there would be then no divided authority, and __ possibly we might go that far even in an initial experiment. _ \" (!? Rome C. Stephenson, Pres., Americ8n Bankers Asso. Hearings — S. Fes. 71 /9.3/ Mr. WILLis. The paper you read speaks in more general terms of the broadening of the base. n ) (Jr 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 374 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. STEPHENSoN. Yes; it refers to munic and railroad bonds._ , —At the Cleveland, Ohio, convention, held ipal in September and Octo, ber, 1930, there was a report adopted _which was association on the subject of branch banking, and itthe voice of the was as follows: The American system of unit banking, as contra sted with the banking systems of other countries, has been peculiarly adapte community life of the United States. The futured to the highly diversified demands the continued growth and service of the unit bank in areas econom sound, independent banking of this type, especially ically able to support as a protection against undue centralization of banking power. Modern economic changes, both in large centers and countr transportation and other y districts, make necessary some readjustment of banking facilities. . In view of these facts, this association, while reaffi unit bank, recognized that a modification of its forme rming its belief in the r resolutions condemning branch banking in any form is advisable. The association believes in the economic desirability of community-wide branch banking ip metropolitan areas and county-wide branch banking in rural distric ts The' aRgoetatIon supPoits in every respect t- he where economically justifik.4.autonomy of the laws of the separate States in respect to banking. No class of banks in the several States should enjoy greater rights in respect to the establishment of branches than banks chartered under the State laws. - / Mr. Wm.'s. Does that community-wide branc h banking that you speak of mean that metropolitan banks shoul allowed to spread d be out into the counties in which they are situa ted? Mr. STEPHENSON. I believe it would, because it says"communitywide branch banking." Mr. Wimrs. That seems as if it were one of those "weasel words" that often appear in resolutions. Mr. STEPHENSON. In many places, of course, the city covers the entire county, like Chicago, which covers all of Cook York City; and Philadelphia; so I think that would County; New mean that the American Bankers Association was in favor of branch banking in the metropolitan areas, which indicates that it shoul wide branch banking, and I think that would d be communitycover the whole county. The AcrusTo CHAIRMAN. And in the rural districts, it would cover several counties? Mr. STEPHENSON. No; I think county-wide branc banking would limit the bank to having its branches within thehsame county in which it is located. The Acrina CHAIRMAN. Does that imply that bankers association would not favor suppressing or gradually the doing State banks in order to force all the banks under away with the Federal reserve system? Mr. STEPHENSON. I think that this resolu the preservation of the present State lawstion is very strong for protecting the State banks. The Amiga CHAIRMAN. Which would mean that they would want to_p_reserve the State banks? Mr. STEPHENSON. Yes, sir. Rome C. Stephenson — Page 2 f3/ / Mr. WiLms. We have heard that chain stores were very numerous / f in that part of the country and you have them even in the smaller places. Mr. STEPHENSON. Not a great many, but you will find on investigation where they have these hard-surfaced roads many of the ' e,....e.tvA--c0 farmers have abandoned the smaller communities and go to the ^t.er in and of goods, larger cities, where they have a larger assortment , -,- Y 1 many instances they are slightly more reasonable, and if he does his I '." ' -15-... his deposits to the trading in the larger cities he will naturally take larger cities. The ACTING CHAIRMAN. Does not that indicate we must put our wits together and find some solution? Is it branch banking, in your opinion, that will solve this problem? Apparently the American Bankers Association has been, until recently, opposed to any extension of branch banking. Now,this committee that you are quoting is apparently in favor of some slight modification toward branch banking. Would not branch banking tend to diversify the loans and increase your load factor ; in other words, act as a kind of check or shock absorber in saving some of the small communities? Mr. STEPHENSON. I believe not. In a great many of these communities where the banks have closed there will never be any demand for banks for those communities again, because the citizens 7 who live in the communities surrounding the smaller places go to back. go not will and places larger the Mr. WiLms. That is not the case in Great Britain, because you have the branch banks all over the country in the smaller places, and 1 • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 379 the same on the continent, sometimes keeping a, branch open o_Lty. a day in the week. Is not that irtie —IVIF.—SrEpHENsoN. I could not say from personal observation, because I have never been there. Mr. Wm.'s. It is shown by descriptions that I have read. Why should we have a different situation here than there? Mr. STEl'HENSON. I do not believe that we would need any of the branch banks in those smaller communities to be open a day or two days when they have those hard-surfaced roads and can get into the larger communities in 10 or 15 minutes. Mr. WiLms. Well, they have the best roads in the world in England and Scotland. Mr. STEPHENSON. But I do not believe they have as many automobiles there as here. Mr. Wimis. But they have excellent bus systems so that what is true here is equally true there. Mr. STEPHENSON. From reading, I take it in those rural communities in Great Britain and Europe they have very few autos among the members of the rural communities that would patronize banks. Mr. Wm.'s. But they have excellent bus systems and there is no reason why the situation would not be the same here, is there? Mr. STEPHENSON. No. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Rome C. Stephenson - Page 3 /f.fi/ .. _, Mr. Wm.'s. is it. lio-t .a htc-t that the bank of deposit in the smaller community has often not been well run under our existing banking situation V Mr. STEPHENSON. They seem to have had no difficulty until about 10 years ago in those communities, which was when the price of commodities was fair and reasonable and before real estate began to depreciate. There were very few banks in the smaller communities comparatively that failed at that time because farmers were enabled to pay their notes when the rural real estate was gradually appreciating in price. Mr. WiLms. If you had high prices for farm commodities you think the small banks could have stood up in spite of the hard-surfaced roads? Mr. STEPHENSON. I do not think so in a great many instances, because I think the business of those communities would be naturally absorbed by the larger communities, and I do not believe the smaller communities would get it back. Mr. Wm.'s. The Northwestern chain banks are keepifig the units of their chains open. Mr. STEPHENSON. But the banks in the Northwest group are in fairly good-sized communities. They are not in the very small communities, where the population is only from three to five hundred. Senator NORBECK. Mr. Chairman, I think that is developing the very point that will be of interest. In making reference to the small community you do not have reference to the small county seats? You mean the villages around in the counties? i • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 Melvin W. Traylor, Chairman, First National Bank of Chicago Hearings — S. Res. 71 /f / 1 I belieVe in the independent unit system of banking which this -‘ country has always enjoyed. I believe the thing we have most of all is the extent to which, in supposed emerge to fear ncies, we modify that system. My conviction is that if we were to nationa which politically I think is impossible—our banking structu lize-re, that the extension of branch banking would be inevitable and that inevitable development of that system would be, perhaps not in the our lifetime, but in due course, a very small number of large units which would control completely the credit facilities of this countr y, which I think would be extremely unfortunate. , The CHAIRMAN. Mr. Traylor, what is the practical difference between correspondent banking and branch banking? Mr. TRAYLOR. You mean as we practice it to-day, and actual branch banking? The CHAIRMAN. As the larger banks of the country practice it. Mr. TRAYLOR. I meant the banking fraternity. The CHAIRMAN. Your bank has perhaps a larger number of correspondent banks than any other bank in the country. Mr. TRAYLOR. No; I do not think so. The Continental probably do have more corre,spondents than we have and so have some of the banks in New York City. The CHAIRMAN. The Continental is Mr. Reynolds's bank V Mr. TRAYLOR. Yes. The CHAIRMAN. Of course I know what is the technical difference, but, in effect, what is the practical difference between correspondent banking and branch banking? Mr. TRAYLOR. Actual supervision of management, capital responsibility, and practically every difference that you could very well think of,I should say. The CHAIRD/IAN. I am trying to find what difference you think there is. I do not think there is a great deal myself. Mr. TRAYLOR. In the first place we have a bank down at Podunk, we will say, which carries its account with us. The CHAIRMAN. And you are not confined to the State of Illinoi s by any means. Mr. TRAYLOR. Anywhere—wherever it may happen to be. We have absolutely, first of all, no responsibility for the capital structu We have no responsibility for management; no authority for re. agement; we are concerned only, as a very practical proposition,manseeing that such loans as we make to that bank are proper with ly and safely secured, and that is really as far the mangernent of a deposi relationship, such as ours to the country banks, can really have.tory periods of trouble, we do go down and actually sit_ with.the...bia In ath of _directora and do everything else _we can to heTP- them out and sometimes put up money. My objection to group and chain bankina, as distin guished from direct branch banking, is very much of ta same character. I do not think a group of banks can be successfully run unless they are run from the head office. . The CHAIRMAN. I agree with you. Mr. TRAYLOR. I know they will not be successful unless the head office. That can best be done without local boardsrun from of directors— Mr. Wmas. The California branches have been very successful in having local boards of directors, have they not? Mr. TRAYLOR. They seem to be. 1 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • • I "I, b-r"--er•-• I ;-. 4 if Melvin W. Traylor - Page / 3/ 404 • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The CHAIRMAN. Is Chicago now in favor of branch banking in any measure? Mr. TRAYLOR. Senator, our friends, who rode us so hard, are now its most noted exponents and champions. The CHAIRMAN. They are? Mr. TRAYLOR. Yes. I think I can say that without any fear of contradiction. The CHAIRMAN. They would have saved me 14 months of hard work if they had felt that way at first. Mr. TRAYLOR. I have some sympathy with you. The CHAIRMAN. Everyone in Chicago now is in favor of branch banking as set forth in the McFadden Act? Mr. TRAYLOR. If I was quoted as saying _ so they might deny it. but privately I think they are. Senator NORBECK. How old is- ou'r experience in granch banking'e Is it not rather modern? Mr. TRAYLOR. Not over 8 or 10 years, I should say. Senator NORBECK. You feel that is not long enough to determine the relative merits of the system? Mr. TRAYLOR. Well, I think the te,st that that particular experiment has gone through in the last two years is pretty conclusive evidence that, if properly managed, the system sound. It gets back to the degree of sanity in management within is the system. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Oscar Tells, Chairman, First National Bank, Birmingham, Alabama Hearings — S. Res. 71 /79/ The CHAIRMAN. What have you to say about the problem of branch banking? We have had various suggestions along that line— one by the Comptroller of the Currency—to have branch banking for designated trade areas. Mr. WELLS. Senator Glass, I am rather in favor of the development of independent banks rather than the development of branch banks, but I recognize that that is not an answer to present conditions. 'The American Bankers Association has also come to that recognifion as at the last convention? I realize the conflict of interest that has arisen by the development of branch banking in some States. and by the development of group banking in others. 422 • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The CHAIRMAN. Which do you prefer? Mr. WELLS. I think that most group bankers will admit that they think that branch banking is desirable as against group banking. The CHAIRMAN. And they engage in group banking because-Mr. WELLS. Because they have no facilities for developing branch banking, although there have been some instanceT-Where group-bunking lias undettliken on a large-geale iihere branai banking, in ---Tartent;l a___ itts be-en-in practice, silet as in.Detroit. e ShOuld we adopt a system of branch banking, do you think it should be confined to the State; that is, should we have state-wide branch banking? Mr. WELLs. I am not yet in favor of saying we should have statewide branch banking, but at any rate I do not think we should go beyond that. In saying that I have particular regard for the status of the State-chartered banks. 1 Prof. Iarcus Nadler, of N.Y. Univ. Hearings — S. Res. 71 /9.3/ Branch banking: Under modern conditions of rapid transportation, of chain stores and branch factories, small unit banks have to a considerable extent outlived their purpose. Failure of banks with branches, however, is not unknown in Europe and in the United States. A failure of a bank with a string of branches operating in one district would cause disaster to the entire district. Branch banking also tends to create a monopoly of banking business in certain sections of the country. Furthermore, business houses are accustomed to have two or more banking accounts. The absorption of one bank by another often results in unnecessarily restricting the line of credit to individual firms. It would seem to me,therefore, advisable that if branch banking is allow, certain provisions should be made to guard against the creation of a banking monopoly in certain parts of the country; and, secondly, not to restrict unnecessarily legitimate business. Before branch banking is allowed, it seems to me that the powers of the,/ Comptroller of the Currency should be greatly increased. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis H. Pushae Williams, Chairman of the Executive Committee of the N.Y. Title & Mortgage Co. Hearings — S. Res. 71 f.9/ Mr. Wm.'s. In England they have a rather serious re-al-estate problem growing out of the branch-banking situation, and in Ireland, too, and I think the same on the Continent. Do you think that branch banking necessarily involves any serious real-estate question through the buying of branch buildings and carrying them along in the portfolio of the parent? Mr. WILLIAMS. I can not say that as to England, but I would absolutely say it was necessary in New York. You can not get a • 538 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS location unless you buy. If you get a location by rentals, it is very high and not economical. Mr. WILLIs. Branch banking involves a large real-estate portfolio on the part of the parent bank, does it not? Mr. WILLIAMS. Yes. It has been extraordinarily successful with us. I suppose we bought at the right time. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. Cameron Thomson, V. P., Northwest Bancorporation, Minneapolis Hearings — S. Res. 71 13/ 566 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. THOMSON. The Northwest Bancorporation—I am going to describe it later—is a holding company, owning stock in financial institutions, including national banks. We went into this plan of ours on the basis that we would try to get the leading key banks as our partners and work this thing out. We realized that whether we succeeded depended on our ability to manage our affairs, and we therefore got the key banks because they were the banks that could afford to pay for good management, and they were the banks that were more representative and banks that would be the best partners. We tried to set this company up on the basis that these banks would really be partners, managing their own affairs. I think our by-laws provide that 75 per cent of the directors of these banks have to be local men, and more than that percentage of the directors of these banks are local men. We said, further, that these banks must come in on the basis of exchanging stock. We wanted to make sure that the banks would be willing to say to us that"We will not sell out to you, but we will exchange our stock for your stock. We will become your partners, and you will be our partners." We felt in doing this that we were not only benefiting the communities but were also benefiting the stockholders of these banks, because they got an investment that represented a diversified interest and ownership in the larger banks in the territory, covering a wider range of territory than individual banks could serve, not so much dependent upon the local bank's business in any one year, and we felt if we could stabilize the banking situation we would benefit not only the customers and the banks but the territory as a whole. The CHAIRMAN. You say they would not sell out to you ? Mr. THOMSON. That is right. The CHAIRMAN. Would not that largely depend on the terms on which you exchanged your stock ? Mr. THomsoN. That gets to a question of whether we have been paying high prices or whether we have been offering a fair price. We think, Senator Glass, if you were to investigate it yourself, you would find that both the Northwest Bancorporation and the First Bank Stock Corporation have paid very reasonable prices and less than many other organizations that have bought bank stocks have paid ; in fact, we would not pay what some people have paid, and our whole idea was to convince the people that came to us that they were going really to become our partners, and if the whole thing was right and well managed that they would eventually benefit by becoming associated in this central holding company. The CHAIRMAN. I have not intended to imply that you did not pay a fair price. Nevertheless, it would largely depend upon the adjustment of the holdin_gs as to whether you owned them or they own you. Mr. THomsow. You are right in that. The Northwest Bancorporation itself is a Delaware corporation, a holding company not engaged in the banking business and making very careful that it does not get into the banking business. It is a Delaware corporation. It was not advantageous to our own stockholders to have a Minnesota corporation because of the risk of double taxation. It exists for the purpose of providing supervision to the extent that such supervision helps the individual bank, also that such supervision J. Cameron Thomson — Page 2 77-7 / / NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS c) 567 • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis protects the corporation, and for rendering service in that territory. We believe this service is generally appreciated to-day, and if appreciated and extended it is going to make the Bancorporation a valuable property for the stockholders. As to the fundamentals in that corporation : They are just the same as in an individual bank. I think that our principle of operation is right and I will give you, a little more in detail, a description of how we operate and you can judge from that. The CHAIRMAN. Have you done that in the House hearings, Mr. Thomson Mr. THomsort. No• we did not, Senator. We think that we are well located in that t'erritory in spite of all the failures and in spite of all the changing conditions. As to the management, I will leave with you copies of the annual report of the Northwest Bancorporation which has some comparisons with a year ago, a list of our directors, and a statement of our stockholders and where they reside. Every important city in our section of the country is represented in either one of these two corporations. These are the men that have been interested in the development of that territory. They are the men who will profit by the continued development of the territory. These men, we believe, with an institution so vital to the success of that territory and an institution with the chances for profitable operation that these corporations have, are going to see that the corporations are well managed. We have, in the Northwest Bancorporation, an active executive committee as fully informed regarding the operations of the Northwest Bancorporation and in general of the operations of the banks, as the executive committee of a bank. In fact, they are better informed than the executive committee of many banks. The CHAIRMAN. WhO supervises the corporation ? Mr. THOMSON. The executive committee, and the active officers. The CHAIRMAN. Is there any State examination provided for it ? Mr. THOMSON. There is no examination by any public body. We are on record with Mr. Pole, personally, and I would like to be on record here, as favoring an examination by the comptroller's office of the affiliates and the corporation itself and of the bank. We should like that. The CHAIRMAN. And publicity of statements likewise ? Mr. THomsow. Yes, sir. Mr. Wimirs. Who owns the majority of the stock , of this corporation? Mr. TnomsoN. The majority of the stock is owned in the four principal States that we do business in. Ninety-five per cent of the stock is owned, Doctor Willis, in the territory we serve. Mr. WILLIS. What bank has a predominating ownership in the stock ? Mr. TnomsoN. There is not any one bank. Mr. Wmus. What is the largest stock ownership in any one individual institution V Mr. THomsorr. I do not recall, but I think that the largest individual holding would be around 20,000 shares out of 1,670,000 shares, and of course the largest block of stock is owned by the men who are connected with the Northwestern National Bank of Minneapolis. J. Cameron Thomson — Page 3 / 568 -3 / NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS MI% WILLIS. HOW much stock is owned by interests, men or corporations, or affiliates, connected with the Northwestern National Bank of Minneapolis? Mr. THomsoN. I do not know that offhand, but I shall be glad to get it for you. Mr. You can give it approximately. Mr. THOMSON. I do not know that, Doctor. Senator NoRRECK. Is it a control? Mr. THomsoN. No; this corporation is owned by the public in that territory, and there is no one interest that has control. If, for instance, you should go to the First Nationak, of Duluth, that city, being a very strong competitor of Minneapolis, as you know, Senator, the First and American National Bank is the largest bank in northern Minnesota outside of the Twin Cities; they would tell you they had as much right and interest in the corporation as the Northwestern National Bank of Minneapolis. Mr. Wm.'s. You will send in here a complete list of the stock holdings? Mr. THomsoN. Yes, sir. Mr. Winus. Showing not only the names but the groups, so as to show the affiliations of the owners, and so to indicate in whose hands the control really is ? Mr. THomsort. Yes, sir. (The witness submitted partial listings of stockholders of the Northwest Bancorporation, as follows:) • Distribution of stock in States in which we operate, as follows: Stockholders in Minnesota own 929,212 shares; Iowa, 132,912; Montana, 34,702; Nebraska, 70,761; North Dakota, 36,647 ; South Dakota, 67,626; Washington, 39,072; Wisconsin, 38,895. Stockholders in miscellaneous States own 320,000 shares, of which the largest holdings are as follows: Illinois, 116,864; New York, 95,135; California, 53,221. We have stockholders in practically every State in the Union. One individual stockholder has over 25,000 shares and half a dozen other individuals own over 12,000 shares. The officers and directors of Northwestern National (Minneapolis) and affiiates own 213,920 shares; the officers and directors of Iowa-Des Moines National Bank & Trust Co., Des Moines, 27,441 ; the officers and directors of First and American National Bank, Duluth, 107,9'73; the officers and directors of United States National Bank and Stock Yards National Bank, Omaha, 25,704; the officers and directors of Spokane & Eastern Trust Co., Spokane, Wash., 11,581. Mr. THOMSON. We believe that this set-up gives us a diversification because of the territory that we cover, and the range of business transacted in that territory. May I just call your attention to this situation: If you are going to have diversification on a large scale in our section, you have to cover territory. The total bank resources of the ninth Federal reserve district are not so large as the resources of one bank in New York. We have whole sections that are largely dependent on wheat. So, to get diversification on a large scale, you have to cover territory and covering the territory that we do we have diversification through various forms of agriculture and industries. The largest portion of our income from agriculture comes from livestock and livestock products. We have copper mining and iron mining. We have some manufacturing. Iowa produces as much values in 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis , /f.5/ 7/2A- J. Cameron Thomson — Page 4 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 1 • 569 manufacturing as it does in agriculture. Des Moines is one of the largest— Senator NORBECS. May I ask, for information, just one question ? That would include such manufacturing as creameries and cheese factories, milk, and so forth? Mr. THOMSON. Yes,sir. Senator NORBECH. Even that might mean that agricultural products predominated, even in manufacturing, as well as agriculture? Mr. THOMSON. Agricultural products are the predominating factor in that territory. Mr. WILLTs. How many banks are owned in this corporation? Mr. THOMSON. I am coming to that. We have, as of to-day, 134 institutions in the group. Mr. WILLTs. How many banks are there in your Federal Reserve district? Mr. THomsozi. There are 2,200 in the ninth Federal reserve district. Mr. Winus. Do you have a vote for each of your banks in electing directors of the Federal reserve bank? Mr. THomsoN. These banks are not all members of the Federal reserve system. Mr. WILLIS. But as far as they are members of the Federal reserve system— Mr. THomsox. Each bank, a member of the Federal reserve, votes as a member bank in any other district. Mr. WILLis. Does your Bancorporation have the right to, and does it, tell them how to vote? Mr. THomsoN. The Bancorporation on all matters of policy— and I should be very glad to have you verify that—tells the banks to do just exactly as they feel they should in the interest of their local community. Mr. Wimis. But theoretically it is possible, is it not, by the working out of this system, as it goes further, that there may be vested in one or two or a small number of corporations of this kind, the entire control of the Federal Reserve Bank of Minneapolis? That is possible, is it notf Mr. THOMSON. I suppose it might be possible, but may I also raise this question with you, doctor: Talking of things theoretically, we ean figure out dangers, but, in the last analysis, this depends upon management and personality, does it not ? Mr. Wm.'s. As everything does. Mr. THOMSON. As everything does ; yes sir. Now,our thought has been—and for instance, if you personally were to investigate our , ituation' and knew the men, you would realize that to-day. and as far as anybody can humanly see, we are not interested in controlling Mr. WILLI& I know the men and think highly of them, but you are not immortal and what you are doing is setting up a system that might profoundly affect the Federal reserve system. You do that by a corporation not controlled by, supervised, or subject to public law. Does not that present a serious problem for constructive and WelI thought out legislation? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 J. Cameron Thomson — Page 5 /f2/ ' 570 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. THomsoN. Well,there is that possibility and it certainly ought to be taken into account by this committee. Mr. Wm.'s. That is all I wanted to bring out. Mr. THOMSON. I should like to add one thing more. The First Bank Stock Corporation represents, in its key banks, and personnel, some of the very finest banks in our territory, and that institution is strongly competitive. Mr. Wn,Lis. Under present management? Mr. THOMPSON. Yes. Mr. Wm.'s. But we are considering legislation for the future, when the present generation shall have passed from the scene. Mr. THomsow. We have felt in our corporation that it was the best /thing in the world in this territory that it had the strong competing 'groups, and while we have, as Mr. Wakefield will tell you, the utmost / confidence in the men of their group and feel we are working toward the same thing, nevertheless we are- strong competitors. We feel that to be a good thing for us and for the territory. It is a safeguard for the territory at the pre,sent time. It is not a legal restriction, but it is a safeguard against control or domination or anything \ of that kind in that territory. \ We have in these 134 institutions 122 banks and 12 investment or \cattle loaning companies. 1 1 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. THomsoN. The activities of our institutions are confined to the banking business as transacted in that territory ; that is, we have the ordinary banking facilities and trust facilities. Our affiliates in the security business are in the business of underwriting and distributing securties. Mr. WiLms. You have affiliates who are in the securities business? Mr. THOMSON. Yes, Doctor Willis. Mr. Wmus. How many of those have you ? Mr. THomsow. I believe there are five. Mr. WiLus. What do they do ? Mr. THOMSON. Those affiliates were the affiliates of banks that became members of our group and we took them in ; that is, in they had the First National Duluth Co. In Minneapolis the Duluth Minne\sota Loan & Trust Co. had— Mr. Wm.'s. You merely inherited those and have not created any .affiliates? \it Mr. THOMSON. I do recall that we created a single securities ffiliate. 1 /93/ J. Cameron Thomson — Page 6 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 573 Mr. Wthris. You have not done so? Mr. THOMSON. No, sir. We have two or three cattle-loan companies. We are, I suppose, the largest factor in that territory in making loans on livestock and that business was largely an inheritance resulting from the affiliation of certain banks doing that business. Mr. Wm.'s. When you bring out securities or make cattle loans in these affiliates, do you do so with the understanding or agreement that they will be. absorbed by the various banks in your chain or group? Mr. THOMSON. You can find in all the operations of the Northwest Bancorporation that no bank is ever asked to purchase any securitie,s, whether it comes from our own affiliates or any other bank; that we have continuously stressed and have insisted that the management of these individual banks and boards of directors must understand that we hold them solely accountable for the management of their banks and the Bancorporation will not do anything in the way of recommendation or suggestion that will relieve thern from the feeling that they have the absolute responsibility for the operation of their bank and its management. Senator NORBECK. I do not question that at all. but it makes me wonder why you insist on 51 per cent of the stock instead of 49, if you are going to leave the control and maRagement with them. Mr. THOMSON. YOU might ask Mr. Wakefield about that. Our general feeling in the start of the Northwest Bancorporation wa:: that if a man was going to be your partner he would prefer to come in entirely rather than have a divided interest, and we have found that you can not get the better banks in the territory to come in on a basis of divided interest. Senator,NoRsEcR. They only came in 51 per cent Mr. THOMSON. In our corporation we have, from the beginning, held over 95 per cent of the stock of the banks in our group, and. in addition to_that 95 per cent, there is over 2 per cent that represents the qualifying shares of the directors of those banks. Senator NOIUIECK. I am glad you brought that out because I have not understood that. Does that mean then that only 5 per cent of the stock is held locally by the particular group of directors that manages the bank in a town? Mr. THOMSON. That is right. The CHAIRMAN. In your view. after all. it conies down to a question of management ? Mr. THOMSON. Absolutely. The CIIAIRMAN. Your vindication of the system is good management? Mr. THomsoN. Absolutely. The CHAIRMAN. What would happen if there had been bad management? Mr. THOMSON. Of course, you can do a lot of harm. You have an illustration in recent months of that, but we believe that, with the character of banks that are the foundation of our structure and with the business interests that are represented there and with the necessity for meeting competition in that territory, you are not going to have to worry about the corporation being well managed. ,' Mr. THomsoN. I should like to go further and state that the North/west Bancorporation management is separate and distinct from any affiliate. We are just as much working for the United States National Bank of Omaha, which is one of our partners, as we may be for the Northwestern National Bank of Minneapolis. We take the position that any of our affiliates can compete for the business of our group. We have gone further and set up a securities department in the Northwestern Bancorporation office for the J. Cameron Thomson — Page 7 /9 _3 / NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 575 sole purpose of furnishing information to our banks and of cooperat and get they ion informat the check can they that so them with ing for each bank in our group may write in for recommendations or also we on, suggesti or ndation recomme a make we if but ons, suggesti tell them in the last analysis they must determine whether they will buy that security or not. I shall be perfectly frank with you and go further and say that in a group such as this, the group management has got to see that those banks are well run, and if those banks bought poor securities and the management and the local board of directors did not correct that situation, we would have to see that that situation was corrected, but— Mr. %%Timis. You would never bring out bad ones through your affiliates ? Mr. THomsoN. Never intentionally. Mr. WILLIs. So that they would be good, would they not V Mr. THOMSON. Yes. Mr. Wm.'s. So, if a member of your group wanted to buy really good securities, you would not tell them yours were bad? Mr. THOMSON. You understand, of course, we can not get enough good securities, nor can we probably get as great a diversification, as we would like. Mr. Wuxi's. Of course. Mr. THOMSON. Of the 122 banks that have been taken into our group, 102 of them came in without a change of their corporate status. Senator NORBECK. May I ask just what that means? Mr. THomsoN. That is, these banks were taken in on a basis of exchanging our stock for theirs, without changing their corporate structure. Senator NORBECK. Do a great many banks change their corporate structure? Mr. THOMSON. We started out to get the strong key banks in order to have the benefit of good partners and good management, but in probably 30 cases out of 122 banks coming into our group we have taken what you might call remedial action in one way or another, either to save a bank or recapitalize it or put in a new bank where there were no banking facilities. One hundred and two banks came in without either recapitalization or without putting up a new bank—just as they were, in effect. The CHAIRMAN. What becomes of the American spirit of unit banking when an outside unit bank undertakes to compete with your system ? Mr. TnomsoN. Mr. Adams, here from Fergus Falls, is one of the outstanding bankers in Minnesota, and he has a bank that competes with another bank that is a member of our group in his own town. The First Bank Stock Corporation is not represented in that town. I do not know what Mr. Adams will say, but you can get a frank statement from him, a strong independent banker, as to whether we are a good competitor or a constructive factor in the community. I think you can ask Mr. Bremer, who is an independent competitor of ours. 576 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The CHAIRMAN. I do not think the reference to one or two strong banks would afford a sufficient answer to the question. Mr. THomsoN. Generally speaking, the Northwest Bancorporation has been a very constructive factor and we welcome the competition of independent banks. In the last analysis, if we are Ting to run a good bank, Senator, and the other fellow runs a good ank, the difference in the business they get is going to depend upon the personality and the local appeal. If we can not get business, we do not deserve to live under that kind of competition. We are a constructive factor and are good citizens and have not hurt any independent well-run bank. We have, for instance, in the last year, devoted our energies to perfecting our management rather than going out for a lot more banks; but of the 31 institutions taken in last year, 19 represented cases where we took in a bank in order to help a local situation. I should like to say this without its getting into your public record. The CHAIRMAN. You may say it off the record, if you care to. (Discussion off the record.) Senator NORBECK. I should like to say at that point I have not talked to Comptroller Pole this last year about it, but about a year or so ago, or a little over a year ago we had a discussion about banks that had then been taken over by die groups in South Dakota or by chains, and we went over them individually and carefully. That was prior to your taking over the Milbank bank. Up to that time I had not been able to discover you had taken over any weak ones. You may have since. The CHAIRMAN. Let me ask you this question Mr. Thomson: How and in what measure do you differentiate interst;te banking by group and interstate branch banking? Mr. THOMSON. Well, on the question of branch banking, our officers are opposed to nation-wide branch banking. The CHAIRMAN. I did not say nation-wide. Mr. THomsoN. On the question generally of branch banking, we believe that is a matter directly for these States to settle. It is conceivable that in general terms of management a group-banking organization covering all these States might be very comparable to a branch-banking organization; but we are, as far as we are concerned, perfectly willing to leave that decision as to branch banking in the hands of the States we do business in; and as far as the public goes, they will keep a check on our operations and if they do not think that they want branch banking or do no't want our banks to have branches in view of the fact we are covering these various States Mr. WILLIS. I do not think that covers the question. Mr. THomsoN. I am wondering whether you mean the difference in the operation or from the public standpoint or Mr. WILLIS. I think the important thing is: In what way do the effects of the banking you carry on differ from the actual operating effects of the Northwestern National Bank if it had an equal number of branches equally capitalized in the same places you have unit banks? Mr. THOMSON. If we had branch banking in our section, obviously these banks would be branches of, say, the Northwestern of Minneapolis, or if it was just state-wide branch banking of, say, our largest bank in South Dakota - https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 6 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 4 577 Mr. WIws. Let us say that the Northwestern of Minneapolis buys out your system and amalgamates your system with it—in what way would the financial results or effects of that system differ from that which exists now ? Mr. THomsoN. There certainly would be more centralized management, Doctor. Now we are operating as partners. Then we would have a definite centralized management vested in the parent bank. Senator NORBECK. Your partners have two things—they have 5 per rent of the stock and have jobs and are on the pay roll. At the present time I should think the partners would be very anxious to please you or they would lose their nieal ticket. In what way would that differ from branch banking, where you would have an employee in charge of a branch? Mr. THOMSON. In the first place, these men have a very strong local interest. Senator NORBECK. But they sold their interest to you. Mr. THOMSON. No • they did not. Senator NORBECK. 'Well, 95 per cent of it. Mr. THomsoN. They just exchanged their stock for ours. Senator NORBECK. But your stock is not local stock. Mr. THomsoN. It is very largely local in that territory, and 95 per cent is owned in that territory. They own their own homes and their focal business and they profit by the development of their own local community. Naturally they are thinking in terms directly ,of what is in the interest of their local community, and they realize that those banks will not develop in those communities nor be profitable to themselves or to this corporation unless the local bank is prosperous and the community is prosperous. Senator NORBECK. I do not want to question the motives of the men who sofd out to you, but I do not see how they have their local business after selling it out to you. Mr. THomsoN. In actual practice those men are as interested in that territory as before, and those men tell us they are more interested than before and I think you will find that the men who are s are working harder to-day than when they had ' running the bank individual banks. The CHAIRMAN. Not one of these banks employs anyone whose services they do not ne,ed? Mr. THOMSON. That is right. The CHAIRMAN. That would be true of a central bank with branches. Mr. THomsoN. In the last analysis, when it gets down to management and operation, I can conceive of a branch-banking organization being of just as much service to a community. I presume you think there would be a greater centralization of funds under branch banking. There is no diversion of funds in our banks. The CHAIRMAN. I think a branch bank would be as much interested in deveroping the community as your bank is. Mr. THomsoN. I think it depends on the manao•ement. The CHAIRMAN. Yes; it all devolves on the management. Senator NORBECK. You are not going to assert that self-interest is not a strong element in the business? You are not going to assert that a man on salary is more interested in the success of the institution than the owner? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -1/ 578 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS / The CHAIRMAN. The question here is, Who is the owner ? Senator NORBECK. That has changed, of course. Mr. THOMSON. He is still the owner. Senator NORBECK. He owns about 1 per cent of the stock Senator WALcoTr. The man who has transferred his stock has diversified his risk. Senator NORBECK. It is less local than it was. Senator WALCOTT. He is a member of a group instead of an individual, but would you not have picked out the same type of man in that community if you had a branch banking system ? Mr. THOMSON. By all means. Senator WALcorr. The same personnel, in other words? Mr. THomsoN. We have the largest bank in Minne,sota, North Dakota, South Dakota, and Iowa, and the oldest bank in Nebraska. Naturally we would try to get banks of that type and men who could build up that type of bank. Senator WALCOTT. Does it not boil down to this, that your essential difference is not a matter of personnel, but a matter of individual initiative? There must be some difference there. Mr. THOMSON. Yes; but I think, though, that this plan of operation, maintaining a local unit, does retain more local intere,st and a stronger sense of responsibility in our territory than if you had branch banking to-day. Whether that would be true eventually, time only will tell. The CHAIRMAN. What is to prevent your parent bank in Minneapolis from acquiring a greater proportion of the stock of these other banks? Mr. THOMSON. In our section ? The CHAIRMAN. Yes. Mr. THomsoN. Well, in the first place, we do not want to do it. The CHAIRMAN. Well, suppose you had a board of directors that would want to do it? • What would prevent it? Mr. THomsoN. In the second place, it is inconceivable that the directors would, want to acquire them on a basis that was not of benefit to the parent corporation. The CHAIRMAN. Of course not. Mr. THomsoN. And the other man is not under any obligation to sell. The CHAIRMAN. But it is conceivable that the parent organization might want to acquire them because they are profitable. Mr. THomsoN. There is no legal restriction against our going out and buying all the banks we want to buy providing we think it would be profitable, which we do not, and providing we would buy them on a fair basis and we are satisfied we are getting good management. We have in our corporation 12,750 stockholders and 95 per cent of them live in our territory. In a great many cases the number of stockholders in the Northwest Bancorporation in a community where we have a bank, has increased very decidedly over the number of stockholders that the local bank had; in other words, there is a vastly greater number of people who are stockholders in the Bancorporation in a given locality than there were that were stockholders in the local bank. So there is a wider public interest in the success https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS I 4 579 of the Bancorporation than there was, certainly, in a great many cases, in the individual local bank. That does not apply in every case, but in a great many cases it does apply. As to the basic principles of operation and supervision that we apply: In the first place, we have an efficient examining department which examines these banks at least once a year. These examiners , and leave oflicars-ami-the exeettt with the the reports over go corporation the of e or a representativ officers and the executive committee of each bank in person, and leave with the directors a written report of our examination of the bank. That report is made from the standpoint of a partner. It covers not only the condition of the bank but the personnel and the earnings and the development of the business. It represents, from an impartial viewpoint, our analysis of the way that bank is operated and it should, and I believe does, give the directors of that bank a better opportunity to be good directors than in a very large number of cases they could have been before their bank was a member of the corporation. We insist that the executive committee and the directors shall definitely go over that report with our own people. Naturally, as owners of the stock of those banks, and as partners we are in a position to go further and more into detail than the National or State examiner would be. The CHAIRMAN. Suppose your management was to imitate some other managements, of which we have had examples, and undertake to put off on these individual banks of your group, at an exaggerated price, minor stocks or other stocks or securities that were practically worthless, what would happen to you ? Mr. THomsoN. Well, if we did that over a period of time the Bancorporation would not be worth anything. But as against that, you have our present policy and our present management and supervision by National and State authorities, which would certainly check that condition in a very short time. Senator WALCO1T. They do not examine the holding company ? Mr. THOMSON. No; but I think it would be only a fair statement to say here that we have done everythinug in our power to acquaint not only Mr. Pole but the supervisors of banks in these various States, with not only the set-up of the holding company and its assets but the plan of operation and we would welcome all the supervision that those public officials want to give our corporation. I believe that they are familiar with the character of the management and policy of the management of these groups in our territory; in other words. we say to these communities that we will see that their banks are well managed. If the officers do not manage them in the right way, we will come to the directors as the responsible heads of that bank. If the management is wrong and the directors do not correct it, then the Bancorporation will see that those situations are corrected. The CHAIRMAN. You are talking altogether about administration and not about the system. Mr. THomsoN. That is right. I grant you that. Senator NORBECK. I might say, Mr. Chairman, that I do not think there is any member of this committee who has yet questioned their https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I ti 580 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS administration of their system. However, I am sure there is a.difference of view in the committee as to whether it is a good system or not. Mr. THOMSON. I should like to make this statement, since you gentlemen evidently may have in mind what may happen and what has happened in some cases. There is not, in the set-up of the Northwest Bancorporation, any bonus stock—just one class of stock owned by the public—there was no promotion expense. The only expenses were just the ordinary legal expenses. The stocks of our banks are carried on the books of the corporation at actual cost or less and— Senator NORBECK. Which stocks? Mr. THOMSON. The stocks of the banks which we own are carried on the books of the corporation at actual cost or less. Senator NORBECK. At the actual purchase price or less? Mr. THOMSON. Yes. Senator NORBECK. That might have a different relation to the book value, might it not? Mr. THomsoN. That is right, absolutely. Senator NORBECK. IS it not a fact you paid large premiums for a great many of these banks? Mr. THOMSON. No; that is not true, Senator. Senator NORBECK. IS it not a fact you paid 51/2 to 1 for some of this stock ? Mr. THomsoN. Well, the statement that we paid 51/2 shares to 1 means nothing unless you know the book value and the earningcapacity of the bank. Senator NORBECK. That is the reason I asked the question. Did you pay more than that for some of them? Mr. THomsoN. I do not remember the figures. I shall be glad to give you the total figures. Senator NORBECK. But you have stated that the cost was not necessarily the book value. That is the reason I asked the other question. Mr. THomsox. The actual liquidating value of the Northwestern Bancorporation stock, without taking into account nonledger assets, without any value for good will, and after writing down considerably on furniture and fixtures, is approximately $37 a share and the par value is $50 a share. Senator WALcorr. What is the market value? Mr. THOMSON. The market value to-day is about $34. It is following just the same tendency as other bank stocks are. Senator NORBECK. How high did the bank stock go ? Mr. THOMSON. Against our desire it went to 99. Senator NORBECK. What is the highest you sold any treasury stock at? Mr. THomsoN. Well, we offered to our stockholders, our corporation by-la ws provide that—aside from an original issue of $5,000,000 for cash in order to provide the first working capital—no stock can be sold except as it is offered to the stockholders; we twice offered stock to our stockholders, in 1929 once at $62 a share and once at $72.50 a share. Those are the highest prices at which stock was offered to them, and not all stockholders availed themselves of the privileges. Senator NORBECK. Now, at what price was the original $5,000,000 sold ? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 4 581 Mr. THOMSON. At $50. $72.50? Senator NORBECK. But you sold some at $62 and some at . olders stockh our to that offered Mr. THOMSON. We Senator NORBECK. Did they take some at that figure ? Mr. THomsoN. They did not have to take it. Senator NORBECK. But you did sell some at that price ? Mr. THOMSON. Yes sir. Senator NORBECK. And it is now at $34 a share? , you Mr. THOMPSON. Yes; and if you will check up on the figures will find that stock has followed the same trend as other bank stocks. butter Senator NORBECK. Is that due to a surplus, the same as with and wheat? Mr. THomsort. It is due to lack of purchasing power. banks in Now, you might question in your mind why we have have the banks These ka. Nebras and Iowa as such some States the and have, ry territo our in banks same general problems that asked cases, many in States, those in group our in are banks that on livestock, to be in our group. We are it large factor in loaningbusine ss from draws Iowa, in City, Sioux tion connec and in that larly, particu , Omaha ry. territo our Minnesota and South Dakota in ss busine draws group, our in is which Bank, Yards in the Stock rather would they said banks Those from Montana in our territory. . Having be our partners than be in another group in another section for inka, Nebras e becaus n ficatio these banks adds to our diversi wheat spring a y largel rather are we while wheat, winter stance, has . similar lly genera country and yet our problems are any cure-all, but we We do not believe that the Bancorporation is that is kept becau,;e ts interes local of do believe that the combination isory organizasuperv a of s benefit the with rate, directo of the local g which has bankin of type a , section tion, have provided, for our the public by ed accept now is which factor, ctive constru been a very system, best the is it that to-day and by the banks, and we believe y. countr the of section at least for our does all The question has been raised as to whether this systemnot afford can that towns small the in larly particu that may be done, be inmight you States, Those to maintain an independent bank. State The on. questi very that ering consid are g, terested in knowin ing of Iowa passed a limited branch banking bill last week providand ts deposi receive to es counti uous contig in banks of for branches ed maintain such other routine facilities as were necessary, provid there as e long as operat to and nity, commu a in bank a there was not was not a bank in that community. The State of Montana has passed, in one branch of the legislature, es a bill providing for consolidations of banks in adjoining counti superState the of ision the superv under ued contin which might be intendent of banks as branches. best to Those legislatures are in the best position to judge howfacilit ies g bankin of sort some need serve the local communities that do, may they ver Whate bank. ndent indepe an and can not afford we will adjust our program to that situation. I do not want to call on anybody unprepared, or suggest you call sitting anybody, but Colonel Marsh from Litchfield happens to be defiyou tell can He group. our of r membe a is here. His bank https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 582 NATIONAL AND FEDERAL RESERVE BANKING SYSTE MS nitely of the basis on which they operate their bank and we would be glad if you could acquaint yourselves with the actual effects of the operation of these corporations in that territo ry. I am going to leave with you several copies of our annual report and I will see that all the members of this commit tee get a copy of that report. Senator NORBECK. I should like to ask you a few point. Do I understand that your view is that thisquestions at this group banking Is a better banking system for the country generally branch system, where it is all owned and controlled fromthan a pure Mr. THomsorr. I think that group banking, owned by the center ? the public and operated by the local people, is very much preferable to or claim chain system owned by an individual or controlleda branch by one interest, without that local interest and management. Senator NORBECK. You feel that the branch-bank system would ' have too much of a tendency to centralize ? Mr. THOMSON. There again it depends upon management. Senator NORBECK. I know but you think there would be too of a tendency to centralize. 'I know under good management it much not necessarily be abused, but I am talking about the system. would Mr. THomsoN. In our section of the country we do not think that-rather, we think that group banking is preferable to general branch banking in that territory. Senator NORBECK. Because it has not the same tendency to centra lize • is that it ? Mr. THOMSON. Yes; it has more local interest. Senator NORBECK. It has less tendency to centralize than the branch-banking system? Mr. THOMSON. YeS, sir. Senator NORBECK. And therefore you feel it is better for the country ? Mr. THOMSON. Yes sir. Senator NORBECK. frhat is your view as to the territory over which the,se organizations should spread? You said you feel they should not go all over the country. Mr. THOMSON. Well, our whole feeling about the questi of whether we are going to have branch banking or group or on chain banking, covering the territory we operate in, is that those things should develop along economic lines. The First Bank Stock Corpo ration covers only the ninth Federal reserve district. They are in Michigan, and we are not. We have reasons for determining the ritory we cover. I think that should be determined by the econotermic situation and the business situation rather than by any rule. Senator NORBECK. In other words, you feel it should not be defined by law, but by experience? Mr. THOMSON. Certainly, by experience. Senator NORBECK. As far as the law is concerned, you would leave the whole 48 States or Territories open to any organization that wanted to go out and attempt to branch out? Mr. THomsort. I would rather let experience determine that question. Senator NORBECK. In other words, you do not advocate or recommend a legal limit, limiting them to any territory or Federa l reserv e district or any particular area? / i https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS . • 4 583 Mr. THomsoN. I do not think it is necessary and I think experi ence will determine that. Senator NORBECK. Nor best? Mr. THOMSON. NO, sir I do not. Senator NORBECK. Speaking now of economic areas, what do you especially have in mind in that statement? Mr. THomsoN. Well, we think that ours is a good example of an as economic unit. Some people differ from us. No one, as I farecoory satisfact a e determin to able been has read, I have seen or nomic unit, and son Senator NORBECK. In other words, you feel that the expressio define? to le impossib and "an economic unit"is a very vague thing Mr. THomsoN. That is right. Senator NORBECK. How far from Minneapolis is your farthestaway bank, 2,000 miles? Mr. THOMSON. No. SeIlatOr NORBECK. Not quite? Mr. THomsoN. Spokane is 1,200 miles west of us. Senator NORBECK. Is that as far west as you have gone? Mr. THOMSON. That is as far west as we have gone. Some of you gentlemen who come from the East have got to visualize that, for instance it is as far from Minneapolis to the western portion of the Ninth Federal Reserve District as it is on an air line from Minneapolis to Jacksonville, Fla. So when you say 1,200 miles you have got to keep in mind in our territory distances are enormous and that this does not mean large population or large concentration of wealth and that the Ninth Federal Reserve District stretches, I presume, halfway across the United States from northern Michigan to the western boundary of Montana, which is just east of Spokane. Senator NORBECK. I am mistaken about 2,000 miles; it is only 1,200 miles? Mr. THOMSON. Yes, sir. Senator NORBECK. You go in the other direction, south, how far ? Mr. THOMSON. I have never figured those distances. Mr. WAKEFIELD. About 350 miles. Senator NORBECK. Now, the capital of the bank Mr. THomsow. Of the Northwestern National Bank? Senator NORBECK. Yes. Mr. THomsoN. The Northwestern Bank and its affiliates in Minneapolis employ about $13,000,000 in capital? Senator NORBECK. How much of that is bank capital ? Mr. THOMSON. The Northwestern Bank itself has $5,000,000 capital. Senator NORBECK. How much surplus and undivided profits? Mr. THomsow. It has $2,000,000 surplus and between a million and two million undivided profits. Senator NORBECK. Speaking of affiliates, how many affiliates do you have V Mr. THomsoN. The stock of the Minnesota Loan & Trust Co. is owned by the stockholders of the Northwestern National Bank, which has a million capital and a million and a half surplus and some undivided profits. There are some other small banks in the city included. When I speak of the affiliates, all told they employ about $13,000,000 of capital. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ( 584 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. How many affiliates does that capital include ? Mr. THOMS0N. That includes six units. Senator NORBECK. Would you place in the record, when you revise your remarks, a list of those affiliates, the capital and surplus, and the nature of their business V Mr. THOMSON. It is all in the report. SellatOr NORBECK. But we are not going to publish all of the report. Mr. THOMSON. The deposits, resources, and so forth, of every institution in the group are included in the annual report. (Thereafter the witness submitted the following statement:) Following is the information asked for relative to institutions located in Minneapolis that are affiliated with the Northwestern National Bank of Minneapolis. They are: Northwestern National Bank : Lake Street office, Lincoln office, North American office; Minnesota Loan & Trust Co., Second Northwestern State Bank, Third Northwestern National Bank, Fourth Northwestern National Bank, Fifth Northwestern National Bank, Midland National Bank & Trust Co., and Central National Bank. The total capital and surplus, and undivided profits of these institutions ig $13,981,749.04. Senator NORBECK. You speak of the Bancorporation as an affiliate ? Mr. THOMSON. No• the Bancorporation is a holding company. Senator NORBECK.'And has $5,000,000 capital ? Mr. THomsoN. The Bancorporation Senator NORBECK. Oh, you started with $5,000.000—a first stock issue of $5,000,000? Mr. THomsow. The Bancorporation started with an exchange of stock of four principal banks, the Northwestern National of Minneapolis, the First National of Fargo the First National of Mason City, Iowa, and the National Bank of' La Crosse, Wis., and after it was formed it sold this $5,000,000 of stock for cash. Senator NORBECK. Now, may I ask what the par value of the stock is? Mr. TuomsoN. $50 a share. Senator NORBECK. May I ask when the Northwestern 13ank was taken into that corporation, at what figure it was taken in, and as of what date? Mr. THOMSON. The Northwestern Bank and its affiliates had over $13,000,000 capital and the stockholders of the Northwestern Bank, if they had all exchanged their stock, would have received $20,000,000 worth of Bancorporation stock and the actual asset value of that stock, eliminating any nonledger assets, was in excess of $13,000,000. Senator NORBECK. In other words, the ledger assets were about $13,000,000 and the stock issued on it was about $20,000,000? Mr. THomsoN. That is right. Senator NORBECK. And the total issue of Bancorporation stock at this time, you say, is what? Mr. THOMSON. The total stock outstanding is $83,695,000. Senator NORBECK. And most of that has been issued in exchange for bank properties? Mr. THomsoN. That is right. Senator NORBECK. And the officers of the holding company are the Northwestern National Banki https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis F NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 585 Mr. THOMSON. No; the officers of the holding company—well, I happen to be both vice president and general ma,nager of the holding company, as well as vice president of the Northwestern National Bank, but generally the officers of the Bancorporation are not connected with any unit in the group. Senator NORBECK. How did they come into the corporation? Those officers ? Did they come in by purchase of stock or cash or in the taking in of bank properties ? Mr. THOMSON. They were picked because of their ability— Senator NORBECK. How did they happen to be stockholders ? Mr. THomsoN. They were not picked because they were stockholders. Senator NORBECK. Did they buy their stock for cash, or are they men who turned in their properties ? Mr. THOMSON. One or two of them were connected with banks in the group. Some of them had no connection with the group, and I will go further as long as you bring up the question— Senator NORBECK. I do not care to go into that particular thing. Our time is short and— Mr. THomsoN. I do not think— Senator NORBECK. The whole point I am trying to make is this: Is the Bancorporation virtually controlled by the Northwestern or controlled by some one else V Mr. THOMSON. It is controlled by the interests identified with our group. Senator NORBECK. Or does the Northwestern own everything in the way of size--Mr. THomsoN. I made the statement before, Senator, that the Northwestern Bank group owns the largest block of stock, but it is not control. Senator NORBECK. But it overshadows the other banks. You can explain it briefly by saying,"Yes; it is controlled by the Northwestern bankers and their friends and associates." I am not saying that in criticism, but I want to get the record straight. Mr. TuomsoN. Well,I suppose that is correct. Senator NORBECK. If it is controlled by anyone else, say so. We have lived long enough to know the public does not control anything. Mr. TiromsoN. Some of our partners would resent the statement that the Northwestern Bank is the overshadowing and dominating interest in that group. Senator NORBECK. But they would not resent your telling the truth about it, if I put the question to you. I think you are right in that you gave the figures which show they overshadow it. Mr. THOMSON. I think that is right. Senator NORBECK. You sold $5,000,000 for cash at $50 a share ? Mr. THomsoN. That is right. Senator NORBECK. How much of that did your Northwestern Bank group take ? Most of it? Mr. ThomsoN. The Northwestern National Bank and the original banks that came,in took, I would say, almost entirely stock and no cash. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 586 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. The thing I am not clear on is this—and that may be my fault and not yours: You spoke of a $5,000,000 stock issue, sold for cash, at $50 a share. Mr. THomsoN. That is right. Senator NORBECK. And as I understand it, that was done after the four big banks had gone in and formed the holding company. Who bought the most of the $5,000,000? Mr. THomsoN. I do not know whether our group bought the most or another group. It was sold in that territory. Senator NORBECK. Did the stockholders of your bank buy heavily of it? Mr. THomsoN. They have bought he,avily of Bancorporation stock for cash at $50 a share and at vastly higher prices and still hold it. Senator NORBECK. And still you think you are smarter than the farmers who took a shrinkage in their lands? Mr. THomsox. I am not quarreling with you about the farmers at all. Senator. Senator NORBECK. Now, then I do not question your good faith in this matter at all. I am just'trying to get at the facts. Now, you offered for sale at $62, stock at one time, as some still considerably Iligher V Mr. THomsoN. That is right. Senator NORBECK. But you did not force anybody to take it? Mr. THomsoN. That is right. Senator NORBECK. That offer—was that sold by you or through some brokerage concern? Have you sold that stock yourself ? Mr. THOMSON. I think that was offered to the stockholders of the Bancorporation. Senator NORBECK. First? Mr. THomsoN. First by the corporation and then Senator WALcorr. Was it underwritten? Mr. THomsoN. That issue at $62 was not underwritten. I think there was a tremendous demand for the stock at that price. The issue for $72.50 a share— Senator NORBECK. Let us take one thing at a time. That was sold direct by your coryoration? Mr. THomsoN. Y es, sir. Senator NORBECK. Would you mind putting in the record the advertising or soliciting asking them to take the stock, or your reconimendation ? Mr. ThomsoN. We made no recommendation. Senator NORBECK. But you made an offer; you sent out your letters to the people about this stock. Would you put copies of them in the record ? Mr. THomsox. Yes. (Copies of the letters referred to are printed in full as follows:) NORTHWEST BANCORPORATION, Minneapolis, Minn., July 18, 1929. To the oaminan-stook holders of Northwest Bancorporation: Northwest Bancorporation will offer to its common stockholder s additional shares of its common capital stock for subscription at $62 per share as follows: Stockholders entitled to subscribe: Common stockholders of record at the close of business on Thursday, August 15, 1929, will be entitled to subscribe for additional common stock in the proportion of 1 share of common stock for each 10 shares of common stock then held by them as shown by the books of the company. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 0 587 Closing of books: The stock-transfer books of the company will be closed from the close of business on the 5th day of August, 1929, until the opening of business on the 16th day of August, 1929, except that where executed contracts are now, or may hereafter be, outstanding under the terms of which the shareholders of any bank, the stock of which has been acquired by the corporation, may elect to become a party to such contract by executing a counterpart of such contract and by depositing his bank stock, under the terms thereof, the stocktransfer books of the corporation will be open to the extent that it is necessary to issue shares of this corporation, in exchange for the bank stock, pursuant to any such contract. Expiration of offer: The subscription privilege will expire on Saturday, August 31, 1929. Warrants will become null and void and of no value, unless exercised on or before such date. Subscription rights: One "right attaches to each share of common stock outstanding at the close of business on August 15, 1929. Common stockholders of that date are entitled to subscription rights on the basis of shares then registered in their names. Ten rights are required to subscribe for each share of the additional stock. Subscriptions will be accepted by the company for full shares only. Issue of warrants: On August 15, 1929, warrants will be mailed to the common stockholders evidencing their subscription rights and specifying the number of shares for which each is entitled to subscribe under this offer. Warrants will be of two kinds: (1) Full-share warrants entitling the holder to subscribe for one or more full shares of this stock and representing 10 rights or multiples thereof ; and (2) fractional-share warrants for less than a full share, representing less than 10 rights. Rights evidenced by full-share warrants may be transferred to others by assignments duly executed in the form printed upon the warrants. Rights evidenced by fractional-share warrants may be transferred to others by delivery. Subscriptions: Subscriptions must be made by executing the subscription agreements on the back of the warrants and delivering them with payment at the rate of $62 for each full share and $62 for each 10 rights-10 rights being the equivalent of 1 full shark )—said payment to be in cash or solvent checks or drafts with Minneapolis Exchange, free and clear of collection charges, to Northwest Banco'poration at the office of the Minnesota Loan & Trust Co., Minneapolb-., Minn., on or before August 31, 1929. Subscriptions will be accepted for full shares only. Payment: Payment for shares subscribed for must be made to Northwest Bancorporation at the aforesaid office of the Minnesota Loan & Trust Co. not later than August 31, 1929. By order of the board of directors. E. W. DECKER, President. NORTII WEST BANCORPORATION, Alinneapolis, Minn., August 15, 1929. To the stockholders of Northwest Bancorporation: In accordance with our circular letter dated July 18, 1929, addressed to the stockholders of Northwest Bancorporation, we inclose to you herewith stock purchase warrant (or warrants) showing the number of additional shares of stock of Northwest Bancorporation for which you are entitled to subscribe at $62 per share. For your assistance we give you the following information: Warrants to whom issued: Warrants are issued to the stockholders of record of Northwest Bancorporation as of the close of business on the 15th day of August, 1929. How to subscribe: Subscriptions must be made by executing the subscription agreement on the back of the warrants and delivering them, with payment in full at $62 per share, to the company at the office of the Minnesota Loan & Trust Co., 405 Marquette Avenue, Minneapolis, Minn., on or before August 31, 1929. Payment: Payment of the subscription price in full, in cash or solvent cheeks or drafts with Minneapolis exchange, free and clear of collection charges, must accompany the subscription. Fractional share warrants: Fractional shares of stock can not be issued. If you have received a fractional share warrant, you may either purchase oil https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 588 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS the market sufficient additional fractional share warrants so as to make up a total of 10 rights (10 rights being the equivalent of one warrant for a full share), or you may sell your fractional share warrant. Expiration of time to subscribe: All rights to subscribe for additional stock expire at the close of business on August 31, 1929. Warrants not exercised on or before such date will become null and void. In order to exercise your right to subscribe, your subscription, together with the subscription price, must actually be received by the company, at the office of the Minnesota Loan & Trust Co., on or before such date; merely depositing same in the mail on or before such date is not sufficient. Signatures: Signatures on the subscription blank or assignment must correspond exactly with the name as written in the face of the warrant. Signatures on assignments should be witnessed. All signatures not known to the company should be guaranteed by a responsible bank or trust company. When assignments or subscriptions are executed by adminitrators, executors, trustees, guardians, attorneys, etc., proper evidence of their authority to do so must be tiled with the company at the office of the Minnesota Loan & Trust Co. Assignment of rights: Inasmuch as the company is offering the stockholders an opportunity to subscribe for stock at less than the present market price, these warrants are valuable. If you do not care to exercise your rights to subscribe for additional stock, you may sell your rights. Full share warrants may be assigned by executing the assignment on the reverse side of the warrants. Fractional share warrants may be assigned and transferred by delivery without executing a formal assignment. In the event of assignment, United States stock transfer stamps, at the rate of 2 cents per hundred or fraction thereof of the par value of the shares of stock for which rights are assigned, must be affixed to the warrant and canceled. If you wish to assign a part of your rights and retain part, you may surrender your warrant to the company at the office of the Minnesota Loan & Trust Co. and new warrants will be issued in the proportion which you desire. Sale of warrants: If you wish to sell either your full share warrants or your fractional share warrants and do not know with whom to list them for sale, the same may be offered for sale either through this company or the Minnesota Co. at 405 Marquette Avenue, Minneapolis, Minn. Yours very truly, E. W. DECKER, President. NORTH WEST BANCORPORATION, Minneapolis, Minn., October 12, 1929. To the common-stock holders of Northwe.st Bancorporation: Northwest Bancorporation will offer to its common stockholders additional shares of its common capital stock for subscription at $72.50 per share, as follows: Stockholders entitled to subscribe: Common stockholders of record at the close of business on Wednesday, October 30, 1929, will be entitled to subscribe for additional common stock in the proportion of 1 share of common stock for each 10 shares of common stock then held by them as shown by the books of the company. Closing of books: The stock transfer books of the company will be closed from the close of business on the 19th day of October, 1929, until the opening of business on the 31st day of October, 1929, except that where executed contracts are now, or may hereafter be, outstanding under the terms of which the shareholders of any bank, the stock of which has been acquired by the corporation, may elect to become a party to such contract by executing a counterpart of such contract and by depositing his bank stock, under the terms thereof, the stock-transfer books of the corporation will be open to the extent that it is necessary to issue shares of this corporation in exchange for the bank stock pursuant to any such contract. Expiration of offer: The subscription privilege will expire on Friday, November 15, 1929. Warrants will become null and void and of no value unless exercised on or before such date. Subscription rights: One "right" attaches to each share of common stock outstanding at the close of business on October 30, 1929. Common-stock holders of that date are entitled to subscription rights on the basis of shares then registered in their names. Ten rights are required to subscribe for each https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 4 , • NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 589 share of the additional stock. Subscriptions will be accepted by the company for full shares only. Issue of warrants: On October 30, 1929, warrants will be mailed to the common-stock holders evidencing their subscription rights and specifying the number of shares for which each is entitled to subscribe under this offer. Warrants will be.of two kinds: (1) Full-share warrants entitling the holder to subscribe for one or more full shares of this stock and representing 10 rights or multiples thereof ; and (2) fractional-share warrants for less than a full share. representing less than 10 rights. Rights evidenced by full-share warrants may be transferred to others by assignment duly executed in the form printed upon the warrants. Rights evidenced by fractional-share warrants may be transferred to others by delivery. Subscriptions: Subscriptions must be made by executing the subscription agreements on the back of the warrants and delivering them with payment at the rate of $72.50 for each full share and $72.50 for each 10 rights-10 rights being the equivalent of one full share--said payment to be in cash or solvent checks or drafts with Minneapolis exchange, free and clear of collection charges, to Northwest Bancorporation at the office of the Minnesota Loan & Trust Co., Minneapolis, Minn., on or before November 15, 1929. Subscriptions will be accepted for full shares only. Payment: Payment for shares subscribed for must be made to Northwest Bancorporation at the aforesaid office of the Minnesota Loan & Trust Co. not later than November 15, 1929. By order of the board of directors: E. W. DECKrn, President. NOTE.—Warrants will be mailed to the stockholders on October 30, 1929. No action by the stockholders is necessary until the warrants have been mailed. NORTH WEST BANCORPORATION, Minneapolis, Minn., October 30, 1929. To the stockholders of Northwest Bancorporation: In accordance with our circular letter dated October 12, 1929, addressed to the stockholders of Northwest Bancorporation, we inclose to you herewith stock purchase warrant (or warrants) showing the number of additional shares of stock of Northwest Bancorporation for which you are entitled to subscribe at $72.50 per share. For your assistance, we give you the following information: Warrants, to whom issued: Warrants are issued to the stockholders of record of Northwest Bancorporation as of the close of business on the 30th day of October, 1929. How to subscribe: Subscriptions must be made by executing the subscription agreement on the back of the warrants and delivering them, with payment in full, at $72.50 per share, to the company at the office of the Minnesota Loan & Trust Co., 405 Marquette Avenue, Minneapolis. Minn., or to the Continental Illinois Bank & Trust Co., Chicago, Ill., on or before November 15, 1929. Payment: Payment of the subscription price in full, in cash or solvent checks or drafts with Minneapolis or Chicago exehange, free and clear of colleetion charges, must accompany the subscription. Fractional share warrants: Fractional shares of stock can not be issued. If you receive a fractional share warrant, you may either purchase, on the market, sufficient additional fractional share warrants so as to make up a total of 10 rights (10 rights being the equivalent of one warrant for a full share) or you may sell your fractional share warrant. Expiration of time to subscribe: All rights to subscribe for additional stock expire at the close of business on November 15, 1929. Warrants not exercised on or before such date will become null and void. In order to exercise your right to subscribe, your subscription together with the subscription price must actually be received by the cOmpany, at the office of the Minnesota Loan & Trust Co., in Minneapolis, or the Continental Illinois Bank & Trust Co. in Chicago. on or before such date; merely depositing same in the mail on or before such date is not sufficient. Signatures: Signatures on the subscription blank or assignment must correspond exactly with the name as written in the face of the warrant. 84:matures on assignments should be witnessed. All signatures not known to the ompany should be guaranteed by a responsible bank or trust company. When r, 34718--31—PT 4 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis v 590 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS assignments or subscriptions are executed by administrators, executors, trustees, guardians, attorneys, etc., proper evidence of their authority to do so must be filed with the company at the office of the Minnesota Loan & Trust Co. or at the Continental Illinciis Bank & Trust Co. Assignment of rights: Inasmuch as the company is offering the stockholders an opportunity to subscribe for stock at less than the present market price, these warrants are valuable. If you do not care to exercise your rights to subscribe for additional stock, you may sell your rights. Full share warrants may be assigned by executing the assignment on the reverse side of the warrants and surrendering the warrant to the company at the office of the Minnesota Loan & Trust Co. in Minneapolis or the Continental Illinois Bank & Trust Co. in Chicago, in exchange for new warrants to be issued tci the assignee. Fractional share warrants may be assigned and transferred by delivery without executing a formal assignment. In the event of assignment, United States stock transfer stamps, at the rate of 2 cents per hundred or fraction thereof of the par value of the shares of stock for which rights are assigned, must be affixed to the warrant and canceled. If you wish tci assign a part of your rights and retain part, you may surrender your warrant to the company at the office of the Minnesota Loan & Trust Co. in Minneapolis or at the office of the Continental Illinois Bank & Trust Co. in Chicago, and new warrants will be issued in the prciportion which you desire. Sale of warrants: If you wish to sell either your full share warrants or your fractional share warrants and do not know with whom to list them for sale, the same may be offered for sale either through this company or the Minnewita Co., at 405 Marquette Avenue, Minneapolis, or through A. G. Becker & Co., at Chicago, ill. Transfer or exercise of warrants at Chicago: For the convenience of those whci wish to do so, arrangements have been made so that warrants may be transferred or exercised at the office of the Continental Illinois Bank & Trust Co., Chicago, Ill. Warrants issued by the Continental Illinois Bank & Trust Co., in exchange for warrants which are transferred, must be countersigned by a duly authorized officer of the Continental Illinois Bank & Trust Co. befcire they are valid. In case warrants are exercised at the office of the Continental Illinois Bank & Trust Co., the warrant holders must allow a reasonable time within which the Continental Illinois Bank & Trust Co. may procure the stcick certificates from the office of the company or the transfer agent in Minneapolis, Minn. By order of the board of directors: E. W. DECKER, President. Senator NORBECK. Was there more than one letter that went out recommending the stock ? Mr. THomsoN. There was not a letter that went out recommending the stock. The Bancorporation has not recommended any stock. It k has recommended, from the beginning, that the banks in the group should not lend on the stock because we anticipated legislation. preventing us from doing that, and the only letters that went out were the letters notifying the stockholders that the directors had authorized a certain stock issue and they were entitled to buy it at a certain price. Senator NORBECK. Whatever the letters contained, if we can put them in the record, they will speak for themselves. Mr. THomsoN. Yes. Senator NORBECK. Now, the issue that was sold at $72.50. Why was that offered at $72.50 instead of at $50? Mr. THomsorr. At that time, in 1929, Senator, people were paying higher prices for stocks generally than they are now. That represented the judgment of men in our group who were in touch with general conditions as to a fair price for the stock under the conditions at that time. Senator NORBECK. In other words, there was a prospective profit that would justify that? Mr. THOMSON. It was felt that the corporation would be benefited by having the amount realized above the par value of the stock. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • ./t A, 591 This was put in a surplus fund, and the corporation to-day is the beneficiary of the surplus realized from the sale of that stock at $72.50. We have felt from the beginning that this corporation should have a surplus and we have provided that we must have investments in other than bank stocks equal to more than 10 per cent of our capital. Senator NORBECK. All of which sounds good but does not answer the question. Our time is getting short. If you felt that there were prospective earnings that justified the $72.50 a share at the time you offered it Mr. THOMSON. The market value of the stock justified offering the stock at that price, and there was no question of profit in the sense of earnings-Senator NORBECK. In other words, you do not claim an earning that justified that value? Mr. THomsoN. No; not based on present conditions. Senator NORBECK. But you sold it at that price? Mr. THomsoN. We offered it at that price. Senator NORBECK. And sold it at that price? Mr. THomsow. A great many stockholders took it at that price. Senator NORBECK. Then you sold it, did you not? Mr. THomsoN. Yes• you can put it that way. Senator NORBECK. bid those statements that went out promoting that sale carry the statement that the book value of the property was $37 a share? Mr. THomsoN. I do not recall, Senator. I will send you a copy of those letters and you can see for yourself, but our annual report of last year Senator NORBECK. I am speaking of the letter soliciting the stock sales. Mr. THomsoN. I do not recall. I shall have to get the letter for you. Senator NORBECK. What is the capital of your corporation? Mr. THOMSON. $83,000,000, approximately. Senator NORBECK. What dividends has the Northwest Bancorporation paid on this stock? Mr. THomsoN. The Bancorporation has paid $1.80 per share dividend per annum since it started. Senator NORBECK. How many dividends have been paid? Mr. THomsoN. It paid eight quarterly dividends. Senator NORBECK. They paid dividends for two years on the basis of $1.80 per share per annum. Mr. TnomsoN. Yes. Senator WALcorr. Quarterly ? Mr. THomsoN. On an annual basis. Senator NORBECK. Forty-five cents quarterly ? Mr. THOMSON. Yes, sir. Senator NORBECK. You spo e in your opening remarks here of a bad condition developing in the Northwest that led to people taking their money out of banks and putting it into postal-savings certificates? Mr. THOMSON. Yes. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 592 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator NORBECK. Did you say $18,000,000 in the ninth Federal reserve district has gone into postal savings? Mr. THOMSON. I said the increa•se in postal-savings deposits in the four States of Minnesota, North Dakota, South Dakota, and Montana in the last 10 years was in excess of $18,000,000, which -svas more than the increase in postal-savings deposits in the entire United States outside these four States during that period. Senator NORBECK. Now, then, I notice you named one town. Let me ask about other towns. The inference is that your bank came in and corrected a bad situation. Did you have any such situation at Lead when you bought the bank there? You spoke of Milbank. Did you have that situation at Lead? Mr. THOMSON. I do not recall whether our deposits in Lead have gone up or not. Senator NORBECK. Have you an increase in postal-savings certificates in Lead? Mr. THomsoN. I do not know, Senator. Senator NORBECK. Is Milbank the only one you have in my Statp Mr. THOMSON. I would have to look it up. Senator NORBECK. Is that the only one you can think of ? THOMSON. The reason I remember that is that I happened to be down here making provision for getting some of that postalsavings money and I recall that particularly. Senator NORBECK. Do you not recall that prior to your purchase of the bank at Milbank, that there was a row between the stockholders and they went into court and put witnesses on the stand to show that the large part of the bank loans was worthless? Mr. THOMSON. They did have a row there. Senator NORBECK. Exactly. But they did not have that sort of situation in other places, did they ? That would not be a fair reflection of the situation in that territory as a whole? Mr. THOMSON. All I wanted to convey was that the establishment of a bank owned by the Northwest Bancorporation in that town did restore confidence in that bank. Senator NORBEC'K. That is admitted, because there was no confidence in it before. It is the same as though you started a new bank. Mr. THomsow. That is true. Senator NORBECK. IS it not true that you acquired banks out there— a bank like the Lead bank—which had weathered the storm and was in splendid condition when you bought it ? Mr. THOMSON. That is right. Senator NORBECK. Was it not as good as any bank in the United States? Mr. THOMSON. I will not say that, but it was a good bank. and we are glad to have it. Senator NORBECK. IS it not a fact that its assets were liquid and carried a large surplus fund and had nothing to charge against it ? Was not the largest part of the assets in Government bonds? Mr. THomsoN. I do not recall whether that was true, but it was a good bank and we were glad to have it in the corporation. Senator NORBECK. Was not the bank at Deadwood a good bank? Mr. THOMSON. Yes, sir. Senator NORBECK. And was not the Miller bank a good bank? Mr. THemsos. Miller is not in our group. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4 j. Cameron Thomson — Page 8 777 /9_3 / Senator NORBECK. The bank is a powerful factor in selling some: thing. European bonds are sold here by the banks. The banks of New York allot them around and say, Your share is so much," and they have to take them. I have no doubt you can allot a lot of bonds to your banks and they will have to take them. Mr. THomsoN. Except that in our case you have independent banks that determine their own policies. They are under supervision by either State or national authority and we have a definite policy that these banks or their affiliates shall determine what they wish to buy or sell. NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 597 Senator NORBECK. As far as that policy is concerned, I commend it. I do not say you are running the worst kind of banking system. Not at all; but you are running a new kind, and while it sounds nice to say the directors are in charge, they are, in fact, in charge as long as vou let them have a meal ticket. You also said your banks had an opportunity to sell out to eastern interests. Mr. THOMSON. That is right. Senator NORBECK. There was a demand from the East to acquire t he properties? Mr. THomsoN. Yes sir. Senator NORBECK. Your holding company would control the banks if it had a majority of the stock ? Mr. THOMSON. Y es, sir. Senator NORBECK. If some one had a majority of the holding company stock, they would control the whole thing, would they not ? Mr. THOMSON. They could. Senator NoRBEcKAnd might also easily control the Federal Reserve Bank of Minneapolis? Mr. THomsoN. Yes sir; with the First Bank Stock Corporation. Senator NORBECK. 'And all they would have to invest was about one-eighth of the capital? Mr. THOMSON. As a practical proposition—and this has got to be my opinion—I do not think there is much chance of the Northwest Bancorporation either owning or controlling— Senator NORBECK. But I am talking about the system now, and not the way it is administered under your policies. Mr. THomsoN. Oh, you can raise all the questions you want as to what might happen. You say one-eighth of the value of the banks might control all ? Senator NORBECK. In other words, the capital of that bank is $20,000,000. What is the total deposits of your banks? Mr. THomsow. $409,000,000. Senator NORBECK. For five or six million dollars properly placed the whole $400,000,000 stock could be controlled. MI% THOMPSON. The capital of the holding company is $83,000,000. Senator NORBECK. In other words, they would have to get half of that? Mr. THomsori. Yes; and if some one owned a majority of that stock or any other corporation they could control it. Elmer E. Adams, Pres., First Nat. Bank of Fergus Falls, Minn. Hearings — S. Res. 71 772a---„Z , , -• / Mr. VViLus. What rate were they paying for savings ? Mr. ADAMS. Four per cent was the going rate in Minnesota until about three years ago, when we cut to 3/ 2 and 3. Every time a new 1 bank came in they would start at 5 per cent and disconcert things. They would advertise even 5 or 6, and that would tend to draw ignorant people from the regular banks, but I think we have a State law now that no bank can pay more than 4 per cent. We all concede that as a result of the purchase of local banks by the groups or chains, banking conditions are improved. They must, of necessity, tighten up in requiring their links to comply with certain fixed standards and rules with which the local bankers had Or • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 603 been remiss and careless. This is particularly true in the requiring of financial statements and in insisting. that a note be paid or attended to when due and in the maintaining of a proper deposit or the paying of a charge for failing to do so. Competition is vigorous between the group banks and those locally owned. The group banks must make dividends or the management will be changed, and the local banks are eager to make money as their stockholders need the dividends. Depositors who have lost their money in closed banks complain bitterly that they are unable to get any information as to why.their deposits are lost and why they were not paid more by the receivers. Practically no information is given out to the depositors, and they only know that the bank was closed. If our authorities in the Northwest would dig into some of the bank failures, as is being done in New York in the case of the Bank of the United States, it would certainly have a more salutary effect. Four hundred State banks have failed in Minnesota in the last eight or nine years. I have not the figures, but I think this is a larger proportion than is the case with the national banks. However, many bankers are now considering the advisability of asking the legislature to drop the word "State"from their names as there is a feeling that there is a loss of prestige. A great many good "State" banks are suffering on account of the failure of the poor ones. There is a good deal of discussion as to the advisability and necessity of permitting local banks to operate branches in near-by areas. Many of the small villages which have had 1, 2, and 3 banks are now without 1, and they complain of the inconvenience and are urging that the banks in the county seats be permitted to operate branches in such villages. I am myself in doubt as to the necessity and whether the branches could be made to pay. The improvement of the roads makes it possible for the residents of the small villages of the county to drive to the larger points without gi:eat inconvenience. They go to the larger places to do their shopping, and with rural mail delivery there is grave doubt whether branches would pay in these villages which have lost their own banks. Elmer E. Adams — Page 2 722 /93/ • . • •• • I think most independent bankers agree that in the metropolitan districts the large banks should be allowed to operate branches within the city limits. The inconvenience of traffic and the constantly increasing menace of hold-ups make it next to impossible for people living at a very great distance to reach the down-town institutions. If legislation of this kind is enacted, I think the independent bankers feel that the branches ought to be restricted to the metropolitan districts and that the large banks of the terminal centers should not be permitted to invade the territory where local banks are able to handle the business satisfactorily. The crying need, however, is for banks which will take care of the poor borrowers. By the poor borrowers I mean the men who never want to pay a note when it is due and who, too often, want to add the interest to the principal. These men need help and must be helped if they are going to function. They have to have seed when spring comes. They have to have feed for their stock if there is a 604 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS shortage, and they are quite likely to need machinery and twine when it is time to harvest. They mean to pay their notes, but every now and then some disaster comes and they are tillable to do what they agreed to do; and so these banks, which have been carrying this class of business, have been involved in situations from wilich it was impossible to extricate themselves. Neither a group bank or a branch bank will ever take care of this class of trade. The local banks have done their share of it. In former days the general merchant and the implement dealer aided. They not only gave them credit for goods but it was not an uncommon thing for the farmer who was trading at a store to borrow small sums until he could harvest, sell an animal, or raise the funds in some other way. The old-time storekeepers were generous in this way and the banks carried them, but you can imagine a farmer who suddenly needs a little money going to see Mr. Woolworth's manager. or Mr. Montgomery Ward's manager, or Mr. Sears-Roebuck's manager and getting die accommodation which he used to get from the old-time merchant. This situation of the poor borrower is constantly gettin worse as the number of farms acquired by mortgages increases. 1he tenants on these farms are very seldom in financial condition so that thev can provide an equipment of machinery, their one-half of the stock, and get along from harvest to harvest. There is a crying need for institutions to take care of this class of business, but I am unable to determine how it can be done, and I have lived among them for , many years. We do what we can along these lines, and while the \ losses have not been very large, it is because we have been very \ discriminating in accepting them. L. E. Wakefield, V. P., First Bank Stock Corp., Minneapolis, Hearings — S. Res. 71 1 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis condiMr. WAKEFIELD. Mr. Chairman,I want to explain to you the in doing tions that exist in our territory in a banking way and believe ons and so that your primary interest is in knowing those conditi fit to situations. in order that in any legislation that you may see as ours and pass you may not do an injustic,e to a community such what we doing ahead going and ce existen in to institutions that are job. good a be to believe Federal I want first to call your attention to just what the ninth Stock CorBank First The way. g bankin a in is district reserve poration operates in the ninth Federal reserve district. Senator NORBECK. That is your corporation? district was Mr. WAKEFIELD. Yes, sir. The ninth Federal reserve bank and reserve Federal the of n creatio the of time the created at g business, was determined by.the flow of transactions in the bankin that parin tions transac those of center the being Cities the Twin establishticular area. The borders of it were, at the time of its borders those in be may there and ersial controv at ment, somewh is to-day some conflict as to the flow of banking transactions, which markets the is that tions; transac s busines of flow the of ive indicat terriwhere they come from or originate in and the limits of those consists It area. osen well-ch pretty a believe, I was, it But tories. Montana, of the States of Minnesota, North Dakota, South Dakota, of Wisoff strip little a and an, Michig of la peninsu n norther the close consin. So, our business of the Twin Cities has naturally been area. lar particu that in nship relatio its had and to g The ninth Federal reserve district, when considered as to bankin resources and deposits, is of comparative unimportance in its relaour tionship to the entire banking facilities of the country, and yet banking resources and deposits are all we have to work with. They are of vital importance to us. We have now, in the ninth district, 2,218 banks with total deposits of $1,594,580,000. Those deposits are $979,800,000 in Minnesota; $109,7002000 in North Dakota; $143,000,000 in South Dakota ; $149,000,000 in Montana; there are $88,800,000 deposits in the northern peninsula of Michigan, and $123,700,000 in the ninth Federal reserve district in Wisconsin. So. when we think of the ninth Federal reserve district in its relation 'to a country-wide consideration, we recognize its comparative unimportance. But we also recognize that as far as it concerns those of us who are residents in and do business in that particular territory, it is of vital importance. Our competition, in a banking way, has for a great many years in the Twin Cities been more definitely related with Chicago and New York banks than with any other single factor, and they to-day are our chief competition. When it comes to the rates that we make to borrowers of importance those rates are definitely related to the rates they make in New York and Chicago. We are in competition all the time in matters of that kind. We have in the First Bank Stock Corporation just about 100 banks to-day. the center of those institutions being the two Twin City banks that are in our group ; that is, the First National Bank of St. Paul and the First National Bank of Minneapolis and we also have about 85 or 90 banks—I have forgotten the exact' number—outside. The CHAIRMAN. Is your company an affiliate of these national banks ? Mr. WAKEFIELD. Our company, the First Bank Stock Corporation, is a holding company which owns practically 98 per cent of the 608 NATIONAL AND .FEDERAL RESERVE BANKING SYSTEMS capital stock of all of the banks in the group. The First Bank Stock Corporation has outstanding, at the present time, 3,097,000 shares of stock of a, par value of $25 per share. That stock is owned by 17,918 stockholders. Of that number of stockholders, 13,223 own 74.19 per cent of the total number of shares and reside in Minnesota. In Montana there are 1,180 stockhAders owning 6.6 per cent of :he stock. In North Dakota there are 1,062 sAwkliolders owning 5.92 per cent of the stock. In South Dakota there are 598 stockholders owning 3 33 per cent of the stock. In 'Wisconsin there are 486 sto..kli iders owning 2.172 per cent and in. States outside of the ninth FeJeral reserve district there. are 846 stockholders owning 4.73 per cent of the stock of the corporation. Now, in the relation of the stock ownership to the $385,000,000 of deposits in the group of banks in the First Bank Stock Corporation, $286,639,000 is in Minnesota banks, or 75 per cent of the deposits are in Minnesota banks, and 74 per cent of the stock is owned by Minnesota people. The next largest amount is $62,415,000 of the deposits, which are in Montana banks, which own 61A per cent of the stock; $18,666,000 is in North Dakota banks, and $10,070,000 is in South DakOta banks; $8,043,000 is in banks in the northern peninsula of Michigan, and we have none in Wisconsin. Now, the thing that I am trying to bring to your attention is this, that this corporation is owned, operated, and managed by people whose every business interest and investment is in the territory served by the banks and that its vital interest is always in the development and improvement and carrying on of this business which is in the ninth district, which is the vital' factor on which we have to depend for our progress and success. In addition to the group of men who are directors of the First Bank Stock Corporation, in every town where we have a bank we have a local board of directors, and no bank operated by the group system could get to first base or be successful in any degree except with the hearty approval and support of that local board of directors. I would not give 5 cents for a bank in any town up there except with the support and approval of a group of business people in that town who were interested in the town and the banks that are there. Senator NORBECK. You do not consider the branch-banking system a good system at all? Mr. WAKEFIELD. I am going to get to that. But I consider this set-up of ownership and control, with its vital interest in the local territory, a. more responsive and better system thin anv that can be devised. Now, then, that, being the case, and with all of the changes that have taken place over which we had no control, but which we have been obliged to meet in a banking way, there have been mistakes in the past. No one can be blamed. These people who have run their banks in the past could be put before you and you could get the history, time after time, where the men associated with the banks that have been closed up have given every bit of everything in them and every bit of property that they owned and their friends and associates have put in everything in addition to save the depositors from loss. Sa it is not anything that .you can lightly talk about or ant https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIOgAL AND FEDERAL RESERVE BANKING SYSTEMS 609 you can pass off with just an expression of some particular facto? being responsible. It was the result of conditions that have occurred and of economic changes, and there was not any way of stopping it. Our interest in group banking is not because in the First National Bank of St. Paul and the First National Bank of Minneapolis we were desirous of gaining control of a greater number of institutions. It was because of the fact that we know that as far as the Twin Cities are concerned, they can not develop and grow in a business and banking way except as there is that same growth and development and stability in the territory from which we draw our business and in which our associates are located. The facts are, as far as making money for the stockholders of the First National Bank of St. Paul and the First National Bank of Minneapolis is concerned, we knew when we went into this undertaking that we were going to help be the cause of improving the general situation the Northwest ; that it was not going to be an added money maker to us except as it conies from the continuous development and improvement of the territory served. In the years to come there may be profit to us in it in proportion as we aid the territory's development. But the fact is, that what we have had to do and what we have done is to attempt to build a structure which would be in the position of assisting and advising and controlling the management of banks out through the territory. When a bank becomes associated with the First Bank Stock Corporation we recognize that at that time, , regardless of what we may wish to do Or anyone inay want to say, „. that the responsibility for that bank rests on its, and under no circumstances can we permit it to go to pieces. So, in building up our method of administering these properties, we called together a year ago, immediately after we got these banks, two or three representatives from each bank, and.we sat down and discussed with them methods of operation. and in this particular enterprise you will be interested. In' the first place, one of the first things they said to us was this, "that we have been obliged, in years past, and more so all of the time, to purchase bonds and securities for some of the funds in our banks. We recognize that this is a topic about which we have not adequate facilities and information, and so we would like to have you set up some kind of machinery which will do that purchasing for us." We did that in this way: We established in the head office of the First Bank Stock Corporation a department which has charge of the securities owned in any one of our banks, and in all of them. That department is in charge of a vice president, whose business it is to follow and watch securities which we own. Some of the bonds which came into our banks are not bonds we want to keep. We have been turning those out and converting them and bringing them into satisfactory line. But no bond is purchased bv any bank in the First Bank Stock group except as it is purchased through that department in the head office, and it has to have the approval of a group of several men before it is purchased, and our ONVII securities company can not sell any bond to any bank in our group except as they are purchased for the group through the main office. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -- 610 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS We keep a control in the main office of every single security owned and where it is lodged—which bank it is in—in order that we may not find ourselves sometimes with more bonds of a particular issue lodged in our banks than we think it would be wise for us to hold a.s a single line of securities. When it comes to buying commercial paper, we do exactly- the same thing. We do not send a bond to a bank. We send them a list of bonds and they can choose what they want to buy, but it must have the approval of the main office. In buying commercial paper, our banks have set up this program-it is their program ; we have constructed it and they have put it into.operation. It provides that in the purchase of commercial paper all companies whose paper we would be willing to buy and have in our banks, shall be approved by the executive committee in the First Bank Stock Corporation. We have also, built up a credit file of commercial paper names; that is, the names of paper that appears in the market, and we have checked those companies from every angle that a bank would check them if they were giving them a line of credit and then have approved an amount we are willing to carry-, of, say, $200,000 of the paper of a eertain concern. That amount is approved and that name goes on the list and, with that approval, the management may buy the paper of that concern if it appears in the market and we will furnish it to those banks. There is not any way of doing a constructive job, in my opinion, unless you organize to give it the most competent and experienced management that you can give it and do it with the approval of the people who are interested in it. We have found that that program is heartily approved and indorsed by the people in our banks. They are enthusiastic about it. They like to feel that they have some direct way of getting this stuff and yet know what they are getting, and I think we will find, as time goes on, that this system will be of material—very material—benefit to those banks. We have organized an examining force, which is making two examinations each year of each bank, in an exhaustive way. Every loan that is made in any bank is reported to the head office the day following with a statement of the borrower or the collateral. We have credit files in the main office of all borrowers in all banks. The creation of this machinery has cost money and the main contributor to the cost of the operation comes from the two big banks in the Twin Cities. I am simply giving you that to show you that the interest of those banks is more vitally concerned with good banking in the territory than with the immediate purpose of attempting to make an extra dollar, because we believe, and I know this is true, that the entry of these two groups into the field has helped the banking situation in the Northwest. Mr. Wthus. Are all of the* surplus funds of these banks deposited in the bank in St. Paul? Mr. WAKEFIELD. No; they carry the usual deposits they used to \ send to--\\, Mr. WiLus. To the eastern cities ? Mr. WAKEFIELD. Yes, sir. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 611 Mr. WILLis. Does the central board, or whatever you call it in the Bank Stock Corporation—does that dictate to them how much they shall send to the correspondents? Mr. WAKEFIELD. No; it is according to the volume of their business, and so forth. Mr. WILLIs. You never have placed call loans for them ? Mr. WAKEFIELD. It never has. I wish the call money market would pick up. We have plenty of money. Mr. Wthms. It did pick up. Mr. WAKEFIELD. During the period of the high call rate some of the banks in the group did have money in the call market. We (the First National Bank in Minneapolis) did not. During that period of 1929 we did not have a dollar Maned on call. Mr. Wm.'s. You exercised no control over their entry into the call market in any way whatever ? Mr. WAKEFIELD. I certainly think we would advise with them at the time. Mr. WILLIs. But at that time you did not? Mr. WAKEFIELD. This group has been going since--it has operated nearly two years. Mr. WILLIs. You have never done it so far ? Mr. WAKEFrELD. No, sir. Mr. WiLus. But in the future it would be part of this central board's policy ? Mr. WAKEFIELD. I think we would use some judgment as to what was being done. The CHAIRMAN. And what rate must the call-money rate get to before you would go into the call market? Mr. WAKEFIELD. We are not in it at the present time because the rates are not satisfactory. With the excess money we have to-day we would like to be. in. The CHAIRMAN. At what rate would you ordinarily want to go into the call-money market? Mr. WAKEFIELD. That depends on the comparative situation. The CHAIRMAN. Do you ever give your own merchants and your own industries the advantage of a low rate of discount? For instance right now, when you have more money than you need or what you know what to do with. Mr. WAKEFIELD. Oh, they make the rates for us. Mr. Willa's. You do not fix a uniform rate for the borrowers in the several towns? Mr. WAKEFIELD. We have never disturbed those rates in those towns. The CHAIRMAN. You never disturb them in any town? Mr. WAKEFIELD. You must remember this, Senator Glass, which is a point I want to bring out: It has be,en said by some people that there was a conflict of interest between the independent banker and the group bank. I claim that there is not. The CHAIRMAN. I am not discussing that particular point now. What I want to find out is why the bankers generally utterly refuse to demoralize their standard rate of interest by giving the local industries and commerce of their own territory the advantage of abundant funds and credits rather than play the market with it? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 612 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. WAKEFIELD. Let me tell you that in 1929, when the call money was loaning at 9, 10, 11, and 12 per cent, we never had a rate in our banks to our business people above 6 per cent. Six per cent was our top rate. We did charge people who borrowed on stocks and bonds as high as 7 per cent. The CHAIRMAN. What is your leaal rate? Mr. WAKEFIELD. Eight per cent. We were never above 6 per cent. Mr. WILLis. Have you been below it? Mr. WAKEFIELD. On standard paper to-day the rate is 3 per cent. WiLLis. I mean the average man in the small town. Arr. 'WAKEFIELD. He will pay 6 per cent. Mr. WILLis. Just as he always did? A r. WAKEFIELD. Yes. r. WiLms. He has a stable, unvarying rate of interest? Mr. WAKEFIELD. Yes. Let me give you an illustration. I want to bring this out so you will see what that relationship is. For instance. the First National Bank of Minneapolis has to-day the correspondent accounts of 1,400 banks. The business of those 1,400 banks represented a deposit account with our bank of over $20,000,000, or practically one-fifth of our deposits. Our relationship with those people is such, and we are interested sufficiently in them and their business, so we have been always in the position of wanting to keep them sound and prosperous and we will go a long way with them. The CHAIRMAN. Why should you keep them sound and prosperous? Mr. WAKEFIELD. Because they are—well, here is the situation The CHAIRMAN. In other words, you accommodate them when they are in an emergency? Mr. WAKEFIELD. Yes. The CHAIRMAN. And that makes them practically subservient to your bank? Mr. WAKEFIELD. NO. The CIIAIRMAN. I think it does. Mr. WAKEFIELD. Here is the situation. I will illustrate to-day how this is going on. Here is a banker in a small town in Mennesota with a bank with $1,000,000 of deposits. He arrives in the office Saturday morning and states on account/ of the closing of the bank in a near-by town that in about 90 days he had lost $450,000 of his deposits. Now, I know that, because we have helped him take care of the payment of those deposits. He came in and said this: "Unless you fellows can find some way to step in and take this bank, I have got to close it Monday mormng. I can not open." Now, remember that everything we do to-day has a vital effect upon those banks in our territory, and you gentlemen do not need to be told of the disaster that follows the closing of a bank, no matter how small, if it relates in its size to the resources of that town and we can not afford to do what we may sometimes desire to do; we can not afford to disturb the earnino• power of those institutions under present conditions. It can not bte done. The CHAIRMAN. That is an extraordinary emergency. That does not relate to the ordinary relationship of correspondent bank—taking over a bank like that. Mr. WAKEFIELD. Oh, no; but in all these ways the man who happened to be a correspondent of our bank has not been subservient to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 613 us. We have been very careful to try to handle his business in a way which would keep him a customer of ours instead of going to another bank. The CHAIRMAN. When I use the word "subservient,'" that does not mean a legal or practical compulsion. You put him under such obliaations he is obliged to patronize you. Arr. WAKEFIELD. Oh, he can pay us off and move to-morrow. The CHARMAN. He can, but he does not. Mr. WAKEFIELD. No; because (rood treatment will keep him. Mr. Wii.ms. It seems to me this is the right point to enlarge upon the question I asked Mr. Thomson this morning as to how you think this remarkable, new structure fits in with the general situation of our banking system and the Federal reserve. Here you have something that is not under the supervision of the State or Federal authorities. How many votes have you in the Federal reserve bank ? Mr. WAKEFIELD. There are three classes of directors in the Federal reserve bank. Mr. Wm.'s. Yes. Mr. WAKEFIELD. I think our two groups could elect one class. I think of the number of banks of that size, we have perhaps enough to elect one class. Mr. Wthms. Theoretically, you two concerns can control one-third of the directors of the Federal reserve bank in Minnesota. Mr. WAKF.FIELD. Yes; but I would be willing to make an absolute agreement, if you can fix up some method of electing Federal reserve directors, to let them be elected— Mr. WILLIS. The Government controls one-third and all the other banks one-third. Mr. WAKEFIELD. Yes. Mr. Wm.'s. Look at the thing from the public standpoint—and of course you are looking at that—and you must realize that this is a great innovation in bank control. What plan do you suggest to modify the present banking system to accord with your scheme ? What regulation of your system is desirable? Mr. WAKEFIELD. You have two questions in one, but I will answer them in this way: Our position is this, that we are very anxious—we have even asked, for our own protection, because we are on the level in this undertaking and we recognize that what other people may do will affect us—we would welcome and want some provision made whereby the comptroller's office, if that seems to be the proper place. will have a perfect right and obligation to examine not only our national banks (78 of our banks are national), but all affiliations of any nature with which we are connected, and the holding company included. We know that would be a protection to us and a value and advantaae to us. Mr. IfiLms. And you would also be willing to give up the votes in these banks as provided in the proposed bill? Mr. WAKEFIELD. I would be perfectly willing—the votes of each bank--Mr. For the election Of the Federal Reserve Board directors. Mr. WAKEFIELD. I am willing to do that if they will keep the right people in the reserve bank. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1V 614 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. WILLis. What about the provision in the Glass bill about the voting of stock in the Federal reserve banks? Mr. WAKEFIELD. I am coming to that. That is one of the things that I wanted to say just a word about. The CHAIRMAN. Before you do that, on the question of control, I do not think Doctor Willis has stated the thing fully. You have the absolute power of selection of one-third of the directors Mr. WAKEFIELD. We would, probably, between the two groups. The CHAIRMAN. Then, the Government has one-third, and then you have a very appreciable effect on the remaining thirds. Mr. WAKEFIELD. Yes; I think that is true. This I would like to say, that I regard the Federal reserve bank as the bulwark of the banking business. We recognize its value. I should like to make this statement: That I heard and listened to the criticisms of the Federal reserve bank and the Federal reserve system, and I am not one of those who is willing to subscribe to those criticisms. The Federal reserve bank is a new institution. It may have had some faults. It must learn from experience, and those things could not be thouhgt out in advance. But the Federal reserve bank is the backbone of the business of this country. Without it we would be in a serious situation. I would not want to be in the banking business to-day if we did not have the Federal reserve. The CHAIRMAN. You would not be in it. Mr. WAKEFIELD. I do not believe we would, and so we have never been a critic of the Federal reserve system. We want it to be preserved. We have always said that during the period of inflation when the Federal Reserve Board were issuing statements concerning the situation, which were intended to warn the public, that if the public had listened we would have been a long sight better off than we are to-day. The CHAIRMAN. If one notable bank official had been compelled to listen to the Federal Reserve Board, the Federal Reserve Board would have been better off to-day. Mr. WAKEFIELD. I do not know much about that. But in the so-called Glass bill, which I understand is a tentative proposal, in paragraph 3 you provide that only bona fide individual stockholders of the national banks can vote their stock. It disqualifies all associations, corporations, or partnerships who may own stock, and disqualifies all individuals who are officers, directors, or employees of such corporations, associations, or partnerships. So, it necessarily disqualifies all trusteeships2 whether testamentary or otherwise, holdin bank stocks for beneficiaries. ow, we are in a pgculiar position in that respect. We have the First Bank Stock Corporation, which is a holding company, owning the capital stock of the group of banks which are in our group. There is no means that I know of whereby we can unscramble that particular situation. If a bill of this kind became law, the only way out we would have would be we would be forced to abandon the Federal reserve system, which we would dislike doing, and probably convert our institutions under State law. That we never want to do, but we could be placed by legislation of this kind in a position where we might either have to quit entirely—I do not know of any way we could unscramble the thing— https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis a NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 615 The CHAIRMAN.' Your statement, so far. impresses me in this way : You have emphasized almost exclusively the sound and fine management of your corporation. I have not any question on earth but that you have done that accurately and fairly. But suppose a similar corporation should get into the hands of people who are not fairly disposed and whose acquisitiveness might amount to greed. Suppose your corporation at some time in the future got into the possession of people of that kind. What would happen ? In other words, you are not discussing the system so much as the fine management of your particular corporation. Mr. WAKEFIELD. Of course, all that I know about the system is what I know of my own institution. Now, in answer to your inquiry, we recognize just as well as you do that there is that danger of unscrupulous management. That is why we are urgent in our statement that we would like to have our holaing company and our affiliations of every nature brought in under the comptroller's office in some manner that would make us sure that we could not be damaged or that some future management could not damage our institution by wrongful handling of it, because I know just what you have in mind might happen. This stock collapse and changing conditions have stopped the promotion of schemes at the present. I do not doubt, however, but for that to-day we might be confronted by such situations. Mr. Wm.'s. Has the First National Bank of St. Paul made its exchange of bank stocks the same as the others ? Mr. WAKEFIELD. Yes, sir. Originally the First National Bank of St. Paul and ourselves thought that we were a little smarter than the Northwestern group and we said, "We are not going to put our banks into a holding company, but to do something along that line, we will form a separate corporation which will be owned by the First National of St. Paul and the First National of Minneapolis, and we will go out and buy 51 per cent of the local banks-51 per cent, because when we become connected with it it is our responsibility, and in order to fulfill that responsibility we must be in a position of control." There is no doubt about that--and we went out and operated on that basis for six months and found it would not work at all; 1 hat the local people in the towns affected did not want to continue to own stock in the local bank. They said,"No; we recognize the fact that whatever difficulties may arise in our territory will affect this bank, and what we want to do is to participate in the whole show and diversify and spread our investment and risks in order that we inay be taken care of in a more substantial way," and we were obliged to change our system and adopt the system of the Northwestern Bancorporation. Mr. Wm.'s. Who controls the corporation? Mr. WAKEFIELD. We have 18,000 stockholders. It would take about 1,200 of the largest stockholders to make a control. Mr. Wii.us. What is the largest single holding? Mr. WAKEFIELD. I think the Hill interests in St. Paul, through the ownership of the First National Bank,own the largest amount. That is somewhere around 180,000 shares. Mr. WiLus. That would be what percentage of the total? Mr. WAKEFIELD. There are 3,096,000 shares. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 616 NATIONAL AND FEDERAL RESERVE' BANKING SYSTEMS Mr. WILLIs. Now,take all the shares including those in the hands ef the affiliated group of persons who center around these banks: What degree of control have they, perfectly frankly? Mr. WAKEFIELD. I imagine—I have never sat down or figured that up at all or paid any attention to it—but I presume if you took the stockholders of the First National Bank of St. Paul and the stockholders of the First National Bank of Minneapolis, that they together would be a controlling interest. Mr. WILLIs. But there is no arrangement that enables their stock to be voted as one block ? MI% WAKEFIELD. No. Mr. WILLis. Simply the fact they have worked together for a long time? Mr. WAKEFIELD. We are in a little peculiar situation in this that St. Paul and Minneapolis never did work together until we st'arted this thing. So we are really watching each other. Mr. Wrimis. Now,about the double liability of shareholders. How does that arrangement affect that ? Mr. WAKEFIELD. The stockholders of the Frst Bank Stock Corporation, being a Delaware corporation, do not have a double liability. When we started to organize this institution we did all the work on the theory we would have it a Minnesota corporation. which would have double liability. At the last minute when we found that every stockholder in North Dakota, South Dakota, and Montana would, in case of death, have a double inheritance tax, they complained so strongly about that situation we shifted and put it into a Delaware corporation. Mr. WiLms. Is it fair to say you have practically abolished the double liability of shareholders? Mr. WAKEFIELD. I do not think so. I think the collection of an assessment on the stock of the banks of the First Bank Stock Corporation is much more assured than it was ever under the ownership of the individual people. Mr. WILLIs. If the impossible should happen and the group of banks collapse, their double liability would be ended? MI'. WAKEFIELD. It would not exist, except there is a very large investment in the First Bank Stock Corporation not in bank stock. Mr. WiLms. How do you recommend that some corrective should be applied to a situation in which a Delaware corporation controls a large number of banks all through the Northwest. then operates in Minnesota and practically controls, with the aid of another corporation like it, at least one-third of the directors of the Federal Reserve Bank of Minneapolis and, as the chairman has pointed out, has an interest in the other third and yet is not subject to any public supervision whatsoever? Does not that seem to call for some sort of recognition in law ? Mr. WAKEFIELD. I do not think that it does, and I will tell you why. Mr. Mums. You think there should be no legislation affecting it? Mr. WAKEFIELD. I do not think it necessarily calls for any legislation affecting it as relating to the Federal reserve bank. It is perfectly all right to me that it should, but I want to say this: We have no exclusive franchise in the banking business. There is no business https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis N ATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 1 • • 617 that I know of that can be destroyed by mismanagement as rapidly as the banking business, and it is not possible for me to believe that any control could come into power in our First Bank Stock Corporation and misuse the facilities in the territory in which it must draw its business and continue to exist. I think the business would leave it and go to the other system. Mr. WILLis. Would not this system be a great deal stronger and better if it were definitely recognized in law and subject to the same control as other bank systems? Mr. WAKEFIELD. That is the point I a,m making,that we would like to be. We would like to have every institution of this kind that is started subject to the regulations of the comptroller's office. Mr. WILLis. But your whole argument seems to be against any legislative control. I understood you as saying that no legislation was needed. Mr. WAKEFIELD. You were speakink of this being a Delaware corporation and operating in Minnesota. III% WILLIS. I am talking about the whole situation. Mr. WAKEFIELD. No; we were talking about the matter of control. Mr. WILLis. For example, to put a hypothetical question: You would not object to converting into a Federal corporation if that was possible? Mr. WAKEFIELD. I do not know the legal aspect of anything of that kind, but I would be delighted with the opportunity. Mr. WILLis. It seems to me, if I might suggest that it would be a great forward step, if you were to devise some constructive plan taking in such a scheme as this and fitting it into the banking laws of the country. Mr. WAKEFIELD. I do not think I am smart enough to make a suggestion along that line. Mr. WILLIs. You seem to be smart enough to develop a system outside of the law, and it seems to me it would be easier to fit it into the law. Mr. WAKEFIEI.D. I do not think we are doing anything that is really' outside of the law. Mr. WILLis. I did not mean to suggest that you were indulgino• in anything that was illegal. Like yourself, I have not the known edge or smartness to detect it. The CHAIRMAN. Doctor Willis wants you to substitute your ingenuity for our lack of it. I confess mine. Mr. WAKEFIELD. This has been on my mind all the time, but I do not. know the answer. The main purpose of my wanting to come here and talk with you to-day is because I wanted you, in your effort to find some solution. at least to understand the problems that we were confronted with and the situation that. we are in, in order that you might not do us a great injustice. Mr. Mims. I think we understood those from your very intere.sting hearing of last spring and the testimony of Mr. Decker in the House. The problem, it. seems to me, is that, of finding some satisfactory and constructive way of dealing with it. Mr. WAKEFIELD. There has been some talk about branch banking. I am not in favor of branch banking. I am definitely opposed to it. and I will tell you the reasons why. I have just given you a little https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 618 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS indication of the importance of the business in the ninth Federal reserve district. If that became a part of a nation-wide branchbanking system we do not stand anywhere. The CHAIRMAN. Now, right there: Do you think nation-wide branch banking is in the remotest way possible? Mr. WAKEFIELD. I am afraid that, given a start, the thing ma., develop into that and we feel definitely that the ownership by, and the business interests of, the people that own our institutions—and this is the same thing as all independent banks of a town—that their desire to carry on as it should be carried on, the banking business, is more assured under our system. The CHAIRMAN. You do not want somebody else's system of branch banking, but you prefer your own? Mr. WAKEFIELD. No. The CHAIRMAN. Oh, yes. The correspondent bank is nothing more than a branch bank, in a meastire--nothing more on earth. Mr. WAKEFIELD. I have stated our position on branch banking. We reco(rnize this fact— The CHAIRMAN. Do you mean that to apply to all branch banking, city branch banking or state-wide branch banking? Mr. WAKEFIELD. No; but when it comes to country-wide branch banking, I do noj want to see that in any circumstances. When it comes to sitting down and looking at what we have, that is another thing. There is no doubt but in the changed situations that have taken place some branch-banking privilege of some kind within a limited area is necessary in order that people without banking facilities may be again taken care of. Of course I would not stand in the way of a development of that kind. As Mr. Thomson says, it is coming up in our territory. I hope to see it come on the part of the States. If those laws are put into effect in those States prior to the action of Congress, I can see a chance that somebody may get excited and there may be quite a shift from the national banking system into the State banking system in order to avail themselves of the privileges that they can not enjoy under Federal charters. The CHAIRMAN. Y011 know the provision in the bill we have here takes care of that situation. Mr. WAKEFIELD. Of course, that will not come until another session ) of Cong. .ress. The CHAIRMAN. Of course not. Mr. WAKEFIELD. But in the meantime certain State legislatures are starting off, which will leave an embarrassing situation. The CHAIRMAN. I think Congress would be willing to protect the national system. Mr. WAKEFIELD. I think so, too, but I am only worrying about the i nterim. e HAIRMAN. Oh, well. ADAMS. Senator Glass, I wish u would bring out, whil are he the advantages of a dual syst —State and Natio The C IRMAN. I do not know of any. I should like to serti unified banking sy em in the country because whenever we ha a proposition to do an hing to strengthen the national banking' ystem we are confronted with,the coMplaint that certain privileges—some totally ,insound in my opknpin—prevail in the State banking systein; so, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • • L. E. Takefield — Page 2 )2 7 3/ Senator NORBECK. I think Mr. Wakefield has expressed himselt on a great many matters I wanted to inquire about. You suggested you were opposed to branch banking as such. What are the great advantages or disadvantages? Mr. WAKEFIELD. There are some advantages in making money. You can simplify its management and control very easily, but I claim that the system we have at the time, with its tie-up to the local people, is more responsive. Senator NORBECK. A substantial investment still remaining in the community ? Mr. WAKEFIELD. Yes, sir. Senator NORBECK. And the stockholders' liability in the CO/IIIn unity— Mr. WAKEFIELD. We were just talking about the holding company having no liability— Senator NORBECK. But the 49 per cent that remains in the local • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. WAKEFIELD. No; that does not remain there. The people do not want to have the stock of a single bank in their community. They wanted to hold the stock of the group, and so we own 98 per cent of the stock of all the banks in the system. The CHAIRMAN. How do you explain this, to me, extraordinary phenomenon ? I have been in Congress 30 years, and on the Banking and Currency Committee of one House or the other for the whole period, and I have never known a borrower—a man who wanted credit—to object to a branch-banking system. I do not mean nation-wide branch banking. Mr. WAKEFIELD. 17011 should listen to the people over the radio-the people who are candidates for office in our territory. The CHAIRMAN. I am not talking about candidates, but people • who want credit. I have never,. in that whole period, had people appear and object to branch banking who wanted credit. Mr. WAKEFIELD. The very nature of the banking business is such that their selfish interest—every selfish motive that a banker has— obliges him to do his best to soundly develop the business of the territory in which he operates. If he does not do that The CHAIRMAN. you are talking about sound bankers,but there are excessively acquisitive bankers as well as public-spirited bankers. Mr. WAKEFIELD. I can give my idea on that by repeating what some one at the time of the House hearings asked; namely, what would prevent some Wall Street outfit coming out and buying control of the First Bank Stock Corporation and running it out of New York ? There is nothing to prevent it, unless you want to do some34718-31-PT 4-5 L. E. Wakefield — Page 3 717A-.,-- 622 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis /93/ NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS thing to destroy the negotiability of the stock; but, in my opinion, if somebody in Wall Street bought control of the First Bank Stock Corporation, they would be obliged to run it as it is being run, or they would destroy the value of the very thing they are purchasing, because banking is competitive and they could not continue to come out there and take the money from the Northwest and get away with it. The CHAIRMAN. Under the proposed banking system that I would like to see established, no Wall Street outfit could establish any branch in Minnesota or any other State except New York. Senator NORBECK. The danger is getting the banking situation where it is not competitive ? Mr. WAKEFIELD. Could it ever be ? Senator NORBECK. You say that the protection of the public lies in the competitive feature that exists to-day ? Mr. WAKEFIELD. Yes. Senator NORBECK. The danger would be if we destroyed that competitive feature by having only one bank in the community. Mr. WAKEFIELD. You can only destroy it by passing a law to prevent a bank coming into a community. Senator NORBECK. You realize the tendency in that respect. Now, then, why do you limit yourself to the ninth Federal reserve district ? Mr. WAKEFIELD. Because that is the country in which we feel that our relationships were established. Senator NORBECK. You feel that a group bank, chain bank, or branch-banking system should not in any event be nation-wide ? Mr. WAKEFIELD. It all depends on what relationships existed there. I am not sure whether the Northwest Bank Corporation has banks in Omaha or Des Moines, but we have very close relationships to that territory. It is simply a matter of our judgment as to where we want to confine ourselves. Otto Bremer, Chairman, American Nat. Bank of St. Paul, Minn. Hearings — S. Res. 71 • et- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 0' / The CHAIRMAN. You do not know whether you are in favor of group banking or chain banking or not? Mr. BREMER. You did not ask me about branch banking. I have some ideas about branch banking. I do not think it would be a good thing for our country at large if we had branch banking all over. In a few localities it may be preferable, but as a whole I think it is un-American. The CHAIRMAN. How un-American? Mr. BREMER. In a way a man likes to be independent. Mr. WiLms. Do you mean to say it is German or English? They have branch banking there. Mr. BREMER. Yes; they have branch banking there, Doctor Willis, but I am just about between these two ideas: I consider myself and with my friend Elmer Adams, as an independent banker, although I have interests in other banks. I have just had a report of a large German bank in my home town which has gone out of its way to acquire an interest in two old banks in order to provide better banking facilities at those places. One was established in 1761 and the other in 1794, and it reports in its statements that these small banks served a good purpose, being closely allied with the producing and trading middle class. It is business that the big banks are not familiar with and do not want and it, the Bank of Brunswick, invested some money in those banks in order to keep them functioning as two independent banks. Senator NORBECK. You feel there is a real need of small banks over the country as well as large banks? Mr. BREMER. Yes; and I repeat again that the management of these two groups has done a great deal to help steady the situation in our territory, but it seems to me that at the same time there is a field for the unit banker, but after all I think it is absolutely up to the public. If the public is attracted to large figures—if those big figures are the only attraction then the little unit bank is out of the picture. But I think the unit bank has just as much chance as it ever had to do its business. The CHAIRMAN. You say you have stock in 40 different banks? Mr. BREMER. Yes, sir. Senator NORBECK. You feel the danger of branch banking is too ;much centralized control and too far from the public'? / Mr. BREMER. Yes; and not a good thing for the district in which it operates. Coming back to my idea ibout the home bank: My idea about the banks is this: The home district comes first. The bank that I am interested in are not going outside of their sphere and neither I nor the banks are interested in selling or underwriting any bonds or securities. I may be dead wrong in this and may have foregone a great deal of profit. I do not care for that line of business. I am, if you will permit the expression, an old-fashioned banker who takes deposits from the people who trust us with them and lend them out hrPnd nnd hiittpr return.7 and that is at a slightly larger a 1 •• -• Hearings - S. Res. 71 Appendix Letter to Senator Norbeck from Arndt E. Dahl, V. P., Citizens State Bank, Castlewood, S. Dak., Feb. 4, 1931 / ps9 _ We here at Castlewood are competing with group bankers every day. They have two of them at Watertown, only 16 miles from here. So far they have not hurt us any that we know of, so that I am not writing this because I have any grievance against them. The people do not like the group banking institutions and when they are assured of equal safety in a unit bank they prefer the unit institutions. N'Ve have had deposits come to us because of the fact that they are group institutions. 1 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Personally I am not opposed to all branch flanking. I believe that limited branch banking within a large city is desirable. I believe that limited branch banking within the county would not be so bad, as it would probably be better than the cut-throat competition we had a few years ago in South Dakota. The only bad feature is that if branch bankinig is given a start that the areas will gradually increase. However, I do not believe we should have interstate branch banking or group banking spread over such a large territory as we have in the Northwest now. The worst feature is that trouble in one territory or in one bank may spread over the entire system. We now have in the Northwest one group chain that has a bank way out in Washington, a large bank in Omaha, the largest bank in Iowa, the largest ba.nk in Duluth, the largest bank in South Dakota, the largest bank in North Dakota, and a number of banks in Montana, and the head bank is located in Minneapolis, and its ratio of capital to its deposits is much smaller than most of the large banks, and many of the small ones, too. It is such a vast organization with a number of large banks in the group, that any serious trouble in one of the large group banks might easily spread over the entire system. The deposits of its affiliates totals much larger than the head bank itself, and I do not think that this is a good thing. The other group in the Northwest, I believe, is better situated. I do not think that they are wholly in favor of group banking, but was forced into it by its competitor and they had to form a group of their own or let their competitor take their correspondents away from them. Furthermore, in this group they have two large banks to bear the burden. The deposits of the affiliates outside of the two head banks are in better proportion. In other words, they are in better position to take care of trouble in a part of their group, because the head banks are larger in proportion to the rest of the group. There is another feature of group banking that appears bad to me, and that is pyramiding of deposits. For instance: A bank at Ree Hights, S. Dak., is listed in the Blue Book to use the bank at Miller as a correspondent. A former officer of the Miller bank is now an officer of the bank at Huron recently organized, and undoubtedly the Miller bank uses Huron as a correspondent ; the Huron bank will naturally use the head bank in Minneapolis as a correspondent. All these banks are members of the same group. Now, if a farmer deposits $1,000 in the Ree Hights bank, the Ree Hights bank may deposit this in the Miller bank, and the Miller bank may deposit in the Huron bank, and finally the Huron bank will deposit this in the head bank. Now, the deposits in all these banks have increased each $1,000 from the same deposit. In a consolidated statement of all the members of the group, the original $1,000 will show up as a $4,000 deposit in the group total, and each bank will have increased its cash reserve $1,000, and the group total of cash will also show as $4,000 as the result of the one deposit. Although this may be an extreme case, it shows how deposits and cash reserves may be pyramided by interdeposits within the group. It would therefore be most interesting to see a consolidated statement of the group with all interdeposits, intereash, and interadvances eliminated. Surely it would greatly reduce the footings and total resources now so much advertised. In other words, the totals are not there when intertransactions are eliminated. It shows the possibilities of deception so that statements will not tell the true condition. It is very encouraging, however, to note what the leading bankers of New York say about branch and group banking on a nation-wide scale. I notice many of them do not favor it. It is also encouraging to see what the leading financial magazines say about it. The Financial Chronicle of New York in their June 14th issue, page 4122, certainly did not indorse the group and branch banking, and ended up by saying "it is a false growth—one not in accord with the best banking and business interest." In the November 22d issue, after the failure of the Banco-Kentucky group, it stated, on page 3248,"The ease with which trouble in one of the banks in an affiliated group extended to all the other banks in the same chain or group is evidence that chain or group banking is no protection against disaster ; rather the reverse. The reason is perfectly plain. Suspicion or doubt with reference to one of the members naturally quickly brings other members of the group or affiliation under similar doubt picion. And when this is said the chief argument urged in support and susof collective banking disappears." The New York Journal of Commerce, on November 19 and November 20, 1930, in two editorials condemned group banking. The American Bankers' Association Journal in their last two issues commented editorially on the fact that it was not the form of banking, whether group, chain, or unit which was most important, but pointed out that each class has had failures. Hearings - S. Res. 71 Appendix "Le..-e_eZ ,- / 3/„„) AMERICAN NATIONAL BANK, Santa Monica, Calif., January 22, 1931. HOD. HIRAM JOHNSON, Senator front California, Washington, D. C. DEAR SIR: We wish to call your attention to a matter now before the Congress of the United States—that is, proposed revisions of the national banking act and the legislation dealing with the operation of banks and the Federal reserve system. The independent banker occupies a place in the community that can not uccessfully be replaced by the local manager of a branch or chain organization. No other business comes so close to the vital needs of every community ; ns one has better understanding of the people in a community or their part1cular problems than the local independent banker; who has his own funds invested in the bank and whOse prosperity must be keyed to the community's prosperity. The one element in American life which has given this Nation its greatness has been the individual initiative and enterprise of our independent business man. The American tradition of equal opportunity for every Is 1 • 642 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS boy to become what he chboses is fast perishing and will cease to exist unless the opportunity for the individual with intelligence, integrity, and perseverence to continue a business for himself with relatively small amounts of capital is protected. The Federal reserve system, if it is to be of any benefit to the majority of these smaller independent banks, must be modified. As it operates at present the great majority of the smaller suburban and country banks do not have any opportunity to use the Federal reserve system. The compulsory membership in the Federal reserve system often proves an expense and drain without compensating benefits. A change in the rules of accepting paper for rediscount must be made if these banks are to be able to use the Federal reserve system in the manner in which we believe the founders of the Federal reserve system intended. Paper held by such banks which is safe and liquid sufficient to pass an examiner's approval should be made eligible for rediscount to the Federal reserve bank under some proper rules and regulations. Many small banks with plenty of paper, even better secured than much of that now accepted by the Federal reserve, have been forced to close during a run because of the refusal of the Federal reserve to advance a dollar against these assets. The question of safety of a bank obviously does not depend on mere size— it is rather the relation of quick assets to deposit liabilities and the quality of loans held by the bank. The smaller unit bank given equal opportunity to utilize its resources, with proper supervision and management, should be, we believe, the safest type of financial institution and certainly should not be discriminated against by the Federal reserve in favor of large combinations of the country's finances. We believe this question to be of utmost importance to the welfare and future of the country. Is business by the smaller independent concerns to be allowed to continue and prosper, or shall the children of the great majority have nothing to look forward to save a precarious vassalage to some giant industrial or financial creature of the law, with an ever-diminishing opportunity for any degree of independence in the inevitable extinction of that individual initiative and enterprise that produces a nation of leaders and great men? Undoubtedly you are aware of these circumstances, but the nature of the issue is such that those whose interests lie with the ever-increasing power of the large and monopolistic concerns are in a position to present their view before the Congreas and throughout the press, whereas those whose interests are on the other side of this controversy (and we believe them to be the great majority) can not have their views receive adequate publicity, nor will they so often be presented and insisted upon. Not only as business men but as citizens we feel so sincerely on this question that we would feel we had been guilty of gross negligence of duty as patriotic citizens if we did not express ourselves accordingly. We trust you will find it in accordance with your duty to the Nation and to your constituents to take an actiye part and do what you can toward safeguarding the welfare of the independent bank. Yours very truly, RICHARD K. GANDY. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Leo T. Grorley, Chairman of the Board, Federal Deposit Insurance Corporation Hearings — S. 1715 and H. R. 7617 • April, 1955. Mr. CROWLEY. Well, I think you have got a problem all the way through your whole banking system that you have got to consider in the next few years, and that is how to give these communities banking servicg. There are a great many communities now that need banking service; they have none, and yet they are not able to raise sufficient capital. I think the whole principle of this thing goes back to a correction of your whole banking system and making certain changes that are going to give to your corporation better protection, and strengthening of the banking system. Senator GLASS. Do you think a branch banking system, Statewide, would do that? Mr. CROWLEY. It might. There are something like 17 States that have no branch banking, whereas 30 or 31 do permit it. In my opinion there must eventually be a thorough study of our entire banking system made, at which time the subject of branch banking ought to be impartially discussed. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 Marriner S. Eccles, Governor of the Federal Reserve Board dearings — S. 1715 and H. R. 7617 May, 1955. Senator GLASS. Before you get to that, Governor, and adverting to the question of the small banks, do you believe in branch banking? Governor ECCLES. I do. Senator GLASS. State-wide? BANKING ACT Mr 1935 • • `1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 303 Governor ECCLES. Either state-wide or regional, trade area. I believe in the extension of limited branch banking. Senator GLASS. Do you think that would in a large measure solve the problem of the small banks? Governor ECCLES. I do. Senator TOWNSEND. Is that provided for in this bill ? Governor ECCLES. It is not. Senator TOWNSEND. Would you favor putting it in the bill? Governor ECCLES. Not at the present time. I am expressing, of course, a personal opinion, and I recognize how controversial the question is,the question of State's rights that arises in connection with giving national banks the right to establish branches in States where branch banking is not permitted. The problem raises an issue which I think sooner or later must be met. Senator GLASS. Does that mean to suggest that you do not mind controverting the judgment of, the Senate but you do not like to undertake to controvert the judgment of the House? Governor ECCLES. No; I would not say that. I do not want to consider too many controversial questions. It seems to me that there have already been introduced sufficient, possibly, for one Senator GLASS. Is not that a vital problem ? Governor ECCLES. It is a vital problem, and it is a problem that must be met. I personally have been, in favor of the unification banking and branch banking and have recognized the need for a of good number of years. Senator GLASS. Well, we have been studying that problem, to my personal knowledge, for 35 years. Why need we study it any further ? Why not act? Governor ECCLES. Well, of course, there has been progress in the development of branch banking in the last few years. Even the States have taken some initiative and leadership; and the bill that was passed in 1933 permitting national banks to establish branche in those States where Stat,es permitted it was a step in the right direc-s tion. Progress is being made,I think,in that regard. Senator GLASS. Yes; but you do not want any more made right now ; is that your idea? Governor ECCLES. Well, I can Senator GLASS. You want it made, but you do not want a controversy ? Governor ECCLES. I, personally, am in favor of it, because I believe it is constructive. I think it would serve the public interest . I think it would strengthen the banking system. Senator COUZENS. I think you would find a very consider able diversity of opinion on that. Marriaer S. Eccles — Page 2. Governor ECCLES. I recoanize that. I think that is one reason it may be well to consider it at't some other time. I feel, however, that branch banking should be limited in its scope; and I also feel that where there are communities, small communities, that have banking service, that it should not be--Senator GLASS. That is provided in existing law. Governor EccLEs. Yes. That a bank should not be permitted to go in and establish a bank and drive out an existing bank that is already there and established. 304 BANKING ACT OF 1935 Senator GLASS. Your ideas are more liberal than mine. You want it regional, and I think it ought to be confined to the States. Governor ECCLES. Well, I have thought of it in connection with Federal Reserve district branch areas,from the standpoint of administration, because the banks carry their reserves, and bank examinations are conducted from that area, and it is a logical busine,ss unit, it seems to me. Senator GLASS. I do not dioagree there, but right at that point I join you in not wanting too much controversy. Goverilor ECCLES. I think it would be Senator GLASS. I want to get rid of this talk about States' rights. The Stat,es have no rights left, so far as that is concerned, but I would like to get rid of that much of it. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L. M. Aiggins, President Bank of Hartsville, S. C. Hearings — S. 1715 and H. R. 7617 May, 1955. STATEMENT Or L. M. WIGGINS, PRESIDENT BANK OF HARTSVILLE, S. C. • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. WIGGINS. Mr. Chairman and gentlemen, I testify before you not as a banker nor an economist nor as one"qualified by education or experience or both to participate in the formulation of national economic and monetary policies." I represent the. viewpoint of industry, agriculture,. and commerce in South Carolina and, to a lesser degree, banking; being president of a small State bank, which is a member of the Federal Reserve System. With reference to title r of the proposed banking bill, I am in full accord with its provisions, and urge its prompt adoption, with the exception of one provision. I present the serious objections on the part of bankers and business men in our State to the provision in title I that will discontinue on a fixed future date the insurance of deposits in banks not members of the Federal Reserve System. Although it may be a desirable ultimate objective to have every bank of deposit in the United States a member of the Federal Reserve System, it is a practical impossibility for many of the small banks and cash depositories in our State to meet reasonable membership requirements and to survive the loss of revenue which would follow membership in the Reserve System. The only alternative to the discontinuance of banking facilities in many of our small towns and communities would be a restoration of wide-spread branch banking. South Carolina has sustained such serious losses in the operation of branch banks in the State that it will be many years, if ever, before this type of banking will have the confidence of the people. We believe that the farmers and business men of small communities have the right to provide and use banking facilities so long as the institutions set up are soundly administered a,nd profitably operated, even as that right is enjoyed in the larger centers of population. Senator GLASS. Did you have branch banking or chain banking? Mr. WIGGINS. We had one main bank in the city of Charlesto-n, with branches all over the State-46 of them,I believe. Senator GLASS. Were they exactly branches of that bank, or were the smaller banks owned by that bank ? Mr. WIGGINS. They were branches of that bank. Senator COUZENS. Did they fail? Mr. WIGGINS. They failed, and the depositors, up to now, have received 10 percent of their deposits. Senator BYRNES. The Western Carolina Bank, with 12 branches, failed. BANKING ACT OF 1935 829 Mr. WIGGINS. Yes; it failed. The South Carolina National Bank, with three branches, failed. Senator CorrzENs. Your State law permits branch banking? Mr. WIGGINS. Yes, sir. Senator COUZENS. Anywhere in the State ? Mr. WIGGINS. Yes. The profitable operation of many of the smaller banks in our State under the requirements of Federal Reserve membership would be impossible. We,therefore, urge upon you the postponement if not the present abandonment of the proposal to require banks which have their deposits insured to become members of the Federal Reserve System by a specified date. L. M. Wiggins — Page 2. • Senator COUZENS. What do yo-u think of the proposal to require all those with more than half a million dollars worth of assets to come in and exclude those below that amount? Mr. *imam. I think that would be all right. In fact, I know of no bank in our State of that size that is not a member. Senator GLASS. What do you think of the proposal to defer the matter until 1938, according to one suggestion, and 1940, according to another? Mr. WIGGINS. My idea, sir, is that at the present time it would be I pure speculation to determine a future date, considerably in the future, for that to be brought about. Senator BYRNES. What will be the effect upon your State banks and cash depositories to which you refer if they are not given time ? Mr. WIGGINS. I did not quite get the question. \ Senator BYRNES. If the present plan is carried out, what would be \the effect upon those cash depositories ? Mr. WIGGINS. Most of them will have to go out of business. Senator CouzEws. Because their earnings are not enough or because their assets are not good enough ? Mr. Wiaams. Because their earnings are not enough. Their assets are good. Senator BYRNES. The earnings come from the amount they charge for cashing checks. Mr. WIGGINS. That is true. They are principally capitalized at very small amounts. They are prohibited from lending money. They are safeguarded with every provision for soundness, and they must make their earnings out of various charges which the community is willing to pay. Senator COUZENS. Do I understand you to say that they do not lend any money ? Mr. WicraiNs. No, sir. Senator BYRNES. They opened just after the bank holiday to serve the communities. Mr. WiaGiNs. That is true; when capital was so limite,d that it was impossible to organize an ordinary bank we established a system of cash depositories. Senator CotrzENs. Without capital ? Mr. WiocaNs. No,sir. They have a small capital—$10,000 in some cases. Senator BULKLEY. Do they invest deposited funds? Mr. WIGGINS. No, sir; not without the permission of the depositor. They can invest their own capital, but not the deposits. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis No. 12 Hecrings - S. 4115 Edward Ball Howard Bruce Governor Harrison Robert 0. Lord Eugene Meyer Wilson W. Mills W. R. McQuaid Senator Norbeck John K. Ottley William K. Payne Edmund S. Platt J. W. Pole Thomas R. Preston George F. Rand Charles E. Rieman L. E. Wakefield Charles F. Zimmerman a Edward Ball, Atlantic National Bank, Jacksonville, Fla. Hearings — S. 4115 March 1932 • • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. BALL. Senator, there is one point in the bill on branch banking that we do favor. We believe branch banking would be a good thing, either within the State or throughout the United States. The Senator here spoke just a moment ago of the British system, which is a branch-banking system. Senator BROOKHART. I was not talking about the branch-banking system I was talking about the cooperative system. I am opposed to branch banking. Mr. BALL. Senator, I thought in the British Isles they had branch banking. Senator BROOK HART. You know they had a cooperative system with $4,000,000,000 in it, cooperative, not any of your competitive system, where they let one man vote regardless of how much stock he owns and where the earnings of the capital were absolutely fixed and where the use of credit for speculation is absolutely prohibited. You did not know about that system at all? Mr. BALL. Senator, don't we have a competitive system in the Dominion of Canada which is strictly a branch-banking system, and where they have had so few bank failures since that system was installed? Senator BROOKHART. We just checked that over. They had 11 banks. Of course, they have many more branches, and they havP had 16 failures; so it was about 140 per cent in failures in anada in their system since it started. So I do not know as they are any better off on that than your individuality. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Howard Bruce, Chairman, Baltimore Trust Co., Baltimore Hearings — S. 4115 March 1932 ,,. . Senator GL.ks. The Comptroller of the Currency,' for example, thinks the adoption of branch banking would do something. Mr. BRUCE. fllat iS all right. I have no objection to that. ci____ -,- - - \ r1 .. . - mi. _ 4 : • _ _ c.....,.. , 1 • 1 - .1- • - - 1 • - • 4. I _1 z Memorandum to Committee on Banking and Currency Submitted by Governor Harrison, FEB of NY Dated April 7, 1952 (Included with Hearings — S. 4115) - In conclusion, there do not appear to us to be any parts of the bill for which there is imperative need for immediate passage, although two sections of the bill are, indeed, of a character which might be expected to be helpful in the present emergency. They are the proposal for a liquidating, corporation. section 10 (B), and the proposal for a wider extension of branch banking, section 21. If the liquidating corporation is to prove helpful, however, it would seem to us to he essential that the amendment suggested by the Federal Reserve Board be adopted, since a number of features of the proposal in the pending bill might well be unnecessarily disturbing. The branch-bank proposal would be helpful and useful in providing a mechanism for reorganizing and revitalizing many small banks not now able to render adequate banking service in their eommunities. • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Robert 0. Lord, Pres., Guardian Detroit Union Group Hearings — S. 4115 March 1932 • If branch banking is to be preferred to group ownership ot hanks and trust companies, then the bill should either permit branch banking within State limits or other approved areas, regardless of the laws of the State or States in question; or the bill should permit the existing groups to consolidate their member banks into a single institution and operate such banks which are now members of a group as branches, regardless of the law or the State or States in question, with a further restriction if deemed wise that no new branches shall be permitted except as the State laws may permit. Presumably, the purpose of section 20, subsections (b) and (c), is to prevent the evasion of the double liability on bank stocks through the ownership by a holding company of such bank stocks. In the case of the Guardian Detroit Union Group, we recognized at the time of our incorporation nearly four years ago that the double liability protection to depositors should be preserved. Our charter, and in fact our stock certificate itself includes the following provisions—I would like for the information of this committee to have you see how that is worded [passing specimen stock certificates to members of the committee]. There are some stock certificates, and on the back is that provision, which is a part of the certificate. That provision is as follows: The holders of stock of this corporation shall be individually and severally liable (in proportion to the number of shares of its stock held by them respectively) for any statutory liability imposed upon this corporation by reason of its ownership of shares of the capital stock of any bank or trust companY, and the stockholders of this corporation by the acceptance of their Certificates of stock of this corporation severally agree that such liability may be enforced in the same manner as statutory liability may now or hereafter be enforceable against stockholders of banks or trust companies under the laws of the United States or the State of Michigan. A list of the stockholders of this corporation shall be filed with the banking commissioner of Michigan and the Comptroller of the Currency whenever requested by either of those officers. • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis So long as this double liability is carried through to the holders of the stock of the group company, there is no more reason for a group company to be compelled to carry a reserve to protect that double liability than there is for the national or State banking departments to require the individual holder of stock in a unit bank to deposit cash or securities to cover his own personal double liability in case his bank should become insolvent. The bill includes restrictions against group banking which seem , to me to be both unnecessary and unfair, in view of the record and standing of the group-banking institutions. None have failed to my knowledge where they have been honestly and conscientiously ' run. Dishonesty is just as responsible for the failure of unit banks as it is for group banks or branch banks. Robert O. Lord — Page 2 March 1932 124 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The existing groups have probably contributed vastly more to the stability and safety of the smaller communities throughout this country than have the unit banks, due to their financial strength and to the confidence in which they are held 13y the public. According to the testimony of Governor Young of the Federal Reserve Bank before the Banking and Currency Committee of the House on March 19, 1930, group banking at that time included 2103 banks, or one-twelfth of the total number of banks in the country with total loans and investments of about $11,200,000,000, or nearly onefifth of the aggregate loans and investments of all hanks in the United States. It seems to me especially dangerous at this time to either destroy or impair, by legislation, banking institutions representing so great a percentage of the entire banking resources of this country. The repercussion upon industry and the public would be far more serious than the effect upon the banks themselves. The present is far too critical a period in the financial and industrial life of this Nation to enact legislation which does not have the fully approval of the Treasury Department, the Federal Reserve experts, the department of the Comptroller of the Currency, and the approval of the ablest and soundest banking minds of the United States, as well as the _approval of this committee. • • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis and I have Section 21 refers also to group and branch banking, already stated our position. whole proSenator COITZENS. In other words, you object to that it? that is group; the vision limiting the voting power of s, is it not ? Mr. LORD. Section 21, Senator, is in regard to branche ing the regulat there n provisio a Senator CotrzEics. I mean there is bank. group the of voting power ed to vote Mr. LORD. Senator Couzens, if the banks are permitt am not a I r, behavio good to subject and isions v prounder certain bit afraid of that. We will behave. to prevent Senator GLAss. The purpose of that, as you know, was Federal the ely complet ing controll the holding company from itself. reserve bank perfectly proper, Mr. LORD. I understand that. I think that is not. In our own could they that so division a be should that there because there are district neither of our groups could control it,, that if groups are however feel, do I banks— dent plenty of indepen do a banking business to be limited in any'way as to their power to,got to have some place have we units, the to ng ly, accordi separate memorandum, was that to go. My sug,gestion, as made in this ss of the State laws, for regardle ed permitt be should banking branch take their present national banks, or that the groups be allowed to powers of extension, with s branche as them e organiz and iinits ed it. if it is thought wise, unless the State law permitt banks? national As WiLus. Mr. Mr. LORD. As national banks; yes. sir. Robert O. Lord — Page 3 March 1932 Senator GIASS. I think you would not experience any difficulty in convincing the subcommittee on that point if the subcommittee could feel that it is possible to get such provisions through Congress. C Senator COUZENS. Would you be willing to abandon group banking if branch bankipLwasTermitisid.throughout the State.4 (---Mi•. ---Li5RiiTres, sir • and we_ woukt _put.our banks_into _one,.institution,_a natmal boyar.- Of our institutions the larger ones are all ----national banks, but the Highland Park State Bank and the bank in Flint and two or three small banks are State institutions. Most of them are national institutions. The CHAIRMAN. I am not sure that I understood what you meant there. Of course, each bank is operating under its own charter? Mr. LORD. Each bank is operating under its own charter. Each bank, under the group company's by-laws, must have at least 75 per cent of their directors local men. 1 • 1 132 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The CHAIRMAN. And how much of the stock is held by the holding company in each instance? Mr. LORD. Except for one case, we own all or practically all—in most cases we own all except the directors' shares. The CHAIRMAN. You protest against the suggested provision in this bill of building up a reserve to protect stockholders' liability; is that your feeling, that your stockholders are legally bound for double liability at the present time? Mr. LORD. Absolutely. The CHAIRMAN. Has this form of agreement that they signed been submitted to the attorneys at the Comptroller's office to its binding effect ? Mr. LORD. I believe they have seen it, although the holding company is a State corporation. It was submitted to the attorney general of the State of Michigan and the banking department there, both of whom approved it. The CHAIRMAN. Both of whom held that they could hold them the same as though. they were stockholders in the bank ? Mr. LORD. Y eS, sir. The CHAIRMAN. But your banks are not all in one State ? Mr. LORD. They are ; all in Michigan. The CHAIRMAN. They are all in Michigan ? Mr. LORD. We have no institution of any kind outside of the State. The CHAIRMAN. The liability of nation,a1 banks would be enforced in the Federal court, and the others is the State courts, of course? Mr. Losn. Correct. The CHAIRMAN. Should this not be a matter to be submitted to the comptroller's office for their consideration ? Mr. LORD._ Yes, sir. I think they do know about it, Senator. 1 Robert O. Lord — Page 4 March 1932 • Senator FLETCHER. As a matter of fact, as stockholders in your institution you own all the stock practically in all of those? Mr. LORD. Yes; but the owners of the stock of the company that owns these banks have that double liability through the provision in our stock certificate. Iri other words, you not only have the individual double liability passed on the holders of stock in the holding company, but in addition you have whatever other assets the holding company may have as protection. You have a greater protection than merely the double liability of a unit bank. Senator FLETCHER. The double liability attaches to the stockholders of the holding company ? Mr. LORD. Of the holding company; yes, sir. The CHAIRMAN. Under a form of agreement that they sign and that is indorsed on the certificate. Senator GLASS. There is double liability in many of the unit banks but it does not amount to much, does it ? Air. LoRD. That is very true these days, Senator Glass. The CHAIRMAN. May I ask—there are a dozen or so large groups throughout the country, are there not? Air. LORD. Yes, sir; I think there are more than that. The CHAIRMAN. There is a larger number of large groups than a dozen Mr. LORD. I do not think as large as we are. In our own State there are the two principal groups, and I understand there are others NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 133 covering the northwest section, and there are the groups in Utah and adjacent States, and there is the group in New York and also other groups in the Southeast. The CHAIRMAN. Do you know whether any other groups use this form of certificate, bringing the stockholders in the holding-company under the double liability ? Mr. LORD. The Detroit Bankers, which is in Michigan also, and I believe Wisconsin Bank Shares Corporation. I do not know whether others do or not, Senator. The CHAIRMAN. ill other words, so far as you know, there are just a few of them that follow that. Mr. LORD. I know that some do. Whether they all do, I can not say. The CHAIRMAN. You realize, of course, the effort of the committee to protect was due to the fact that the committee did not believe that it was a general rule to hold the stockholders in the holding company to double liability. In fact, some members of the committee believed the whole purpose of the organization was to evade a good law that provided for stockholders' liability. Air. LORD. That was not ours, because we put it in the charter when we organized. The CHAIRMAN. No; I see, because you stuck to it and carried it film-1i . 1 Robert O. Lord - Page 5 March 1932 The CHAIRMAN. Your suggestion as to the groups would be this, that they would be regulated but not extended? Is that your thought? Air. LORD. Unless the State laws permit it. I think the provision you have in as to that territorial provision is excellent. I think that is fine. The objection I have to the bill as it stands to-day is that there is no branch banking permitted except in States where the laws of those States permit it. NATIONAL AND FEDERAL RESERVE BANIcING SYSTEMS • • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 139 The CHAIRMAN. Would you override the sovereignty of the State in a matter of this kind? Is there not a great deal of danger in doing that? Mr. LORD. Perhaps. The CHAIRMAN. Are you not getting centralized too much now and taking this power and that power away from the States? Mr. LORD. I am in favor of doing it for the national banks. The States have no control over national banks now. Senator GLASS. Now that the exceedingly conservative chairman of this committee suggests an objection of that sort, just what sort of objections may we encounter from the radical members? [Laughter.] Senator GORE. When the reds get after it? Mr. LORD. Senator, the question of branch banking is a very interesting one, and I think that, frankly, it is the ultimate solution of our banking troubles. If it can be handled in such_kway as to prevent a centralization of_power in AmieLplaceLT believe it Ay9_11_(1 be the solution. winAN. 'Well, I think your"if"is the main part of your tre statement. Mr. LORD. All right; su posing that the directors of a bank perthe State must mitted to have branch an -be 90 pet cent fmi etrrliFat State? The CHAIRNI AN. Well. I certainly share your view that it should not be located outside the State but should be owned by the people of the State, if you want to avoid centralization. Mr. Loap..Of course, you can not prevent ownership of stock passing from one locality to another, but you can prevent a directoo7&an Francisco and. attempting to opei'ate rateliving,in New.Uira,corporation elsewhere. The CHAIRMAN. We all know that directors are sometimes just dummies. They are just representatives of some one who lives at a distance. Senator GORE. Would it he feasible tQ, prevent „itockholders who live outside of thtritate ri)in otTitc77 • Yon know that tinirTvas flonf in triiittir Stops hfink,: Mr. Loan. I think it would. That is a legal question. But that would answer your question as to the directors being dummies. Senator GLASS. The subcommittee would not go into mourning altogether if you were to prevail upon Congress to take that view of it. I would not. Mr. LORD. Can you prevail upon Congress to take that view, Senator? Senator GLAss. I do not know. It seems that I can not prevail upon the Bankine Committee to let us pass a reform bankinz bill. c', €101 Eugene Meyer, Governor, Federal Reserve Board Hearings - S. 4115 March 1932 Senator GLAss. Does the board favor- branch banking? Mr. MEYER. The board did not take a vote on branch banking, because it is such a big subject and we did not have very much time for it. We had our experts analyzing the bill and explaining it to us for the best part of a week, and we just had two sessions of about three hours each and we did not get around to a thorough discussion of banking. Senator GLAss. I have had this analysis of your experts on my table for a month. Mr. MEYER. That was another analysis. Senator GLASS. I have not observed any difference in it. Mr. MEYER. On the subject of branch banking I should say the board would not be able to reach a unanimous expression Senator. There are some differences of opinion. Some forms of branch banking might be favored by some of us. We were not able in this document, which is unanimous on the points which are discussed, to express an opinion. Senator GLAss. You want to put the entire responsibility of the solution of this unhappy problem on us, do you? Mr. MEYER. You do not seem to worry about responsibility, and we feel you are amply equipped t,o handle it. • Senator WALcorr. Governor, while we are on that: I do not think it is betraying any confidence to say the members of the subcommittee would go even as far as the districts of the Federal reserve system in making 35 branch districts, but we never could get it through Congress. The subcommittee, I think, would unanimously go as far as States with an exception on border-line towns within a 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 396 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS radius of 50 or a hundred miles such as the bill provides for. There have been witnesses here that have been familiar with and have been very active in the group banking business that have testified unless they could have some provision for branch banking at least statewide, irrespective of State lines, that it would be the doom of the group system; they must have an escape from the group banking. The CHAIRMAN. The Senator will recall that some of the witnesses of the group system a year ago had the opposite view. Senator WALcorr. Yes. The CHAIRMAN. And appeared before this same committee on this same bill. Senator WALcorr. Exactly. The CHAIRMAN. In other words, they told us that 40 years of experience' led to a judgment against branch banks. Now they say they have had 41 and they have changed their minds. [Laughter.] Senator WALCOTT. And they emphasized by saying that they must have the branches. The CHAIRMAN. In other words, they want to abandon experience for_ a theory. They want to try a theory. _ ___ __ ( 1 Wilson W. Mills, Chairman, First Wayne Nat. Bk. of Detroit Hearings — S. 4115 March 1932 1 • • 1 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. MILLs. Now, I realize I am getting on some pretty debatable ground with you gentlemen, particularly Senator Glass. Our bank happens to be a member of a holding company group, no other banks of any large consequence in it except a trust company. We have one state bank outside Wayne County that is owned by the holding company. That is all that we have. Mr. Lord, who will follow me, is also in the holding company. In Michigan at least there are no banks which have been members of holding companies that have closed their doors or had any moratoriums or anything els,e, except paid their depositors when they wanted it. In Michigan we have had 112 banks closed during 193i. Michigan does not permit its State banks to engage in banking beyond corporate limits. My own view is that the drafters of this bill obviously believe in wider than present banking limits. That is, the banking limits should be wider than they now are. It even goes so far as, in certain circumstances, to permit banking to be done in two different States. Senator GLASS. Only to a. very, very limited. extent in extraordinary circumstances. Mr. MILLs. Yes in proper circumstances, but it at least generally contemplates that banking will go to an extent of state-wide bankin nator GLASS. Yes. Mr. Millis. In our case in Michigan I can see no reason, if the drafters of this bill are in favor of state-wide banking for not going sled length and saying: "All right, every national bank can go sled length." Certainly, the results in Michigan have been perfectly splendid. There have been no failures of any banks in Michigan that have been members of the group. There have been no moratoriums of any of those banks. Those banks have met their customers' demands when they have been made, as against the 112 banks that have been closed. Senator GLASS. You would say that regardless of State laws on the subject? Mr. Miu.s. I would, regardless of State laws, because if there is strength, that would solve fully in Michigan, in my judgment, Senator, all objection to group banking. There would not be any group banks left. They will just go out of business. NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 115 Senator GLASS. I understood the committee would say that too, and cheerfully, if they could get the bill through Congress. Mr. MILLs. That is a matter that I can not judge. Senator GLASS. Well, you may judge the future by the past. It took us 16 months to get the limited branch banking facilities that are granted in the McFadden bill. Senator BROOKHART. Some of us think that was too quick. Senator GLASS. Exactly. Mr. MILL& I wanted to make that statement. Now, the holding companies—I know they have been damned up one street and down the other, but all the holding companies in Michigan provide for double liability on the shares of stock of the holding company. Senator GLASS. If that is true, there is no reason why the holding companies in other States should not be required to have that, is there? Mr. MILLs. I do not know of any reason. We have done it voluntarily. Both holding companies in Michigan have done that voluntarily, and there is double liability on holders of stock of holding companies. Wilson W. Mills — Page 2 March 1932 • ) Senator BROOKHART. The fact that your holding companies have done well in Michigan does not mean that they have throughout the United States? Mr. MILLs. No; they have not. So I will say, Senator, I will grant you that in some places they have not. Senator BROOKHART. I was out in Louisville and waked up in the morning and a group bank went down and also carried with it 100 or 150 banks. Mr. MILLs. If the Congress of the United States had passed a law to the effect that you could have had branch banking and branch banking in the future, the provisions as set out by this bill, by a national bank, irrespective of the State, I do not think that you would have had many holding companies in existence at all. The necessity for them would not have been there. Senator BROOKHART. Of course, a holding company may have been a little worse than a branch, but not much. Senator GLASS. Oh, yes. Mr. MILLs. They are open to certain abuses in certain cases that others are not. Before I leave, I just want to make three statements--The CHAIRMAN. There have been some inglorious failures of branch banks, too. Mr. MuLs. There have been, but I think if you look over the history of the failures you will find an infinitesimally small number of failures of branch banks. Senator BROOKHART. How many branches did the Bank of thp United States have up in New York? Mr. MILL& I can not answer that, but I would be surprised if they had more than three or four branches in New York City. I do not know. I would be surprised if there were more than that. The CHAIRMAN. Our committee was informed some 50 or 60. Mr. MILLs. I did not know that. I ani not familiar. But I would doubt if they had that number of branches. 116 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS The CHAIRMAN. One fact was brought out rather strongly: The money involved. in bank failures in the State of South Dakota was not much over $50,000,000, and we have been thoroughly advertised for the large number of bank failures. Here is this big branch bank in New York that went down with over two hundred millions, one single bank, dragged down four tinies as much as all the failures in my State did. And still we are told we. have a poor system out there because we have so many bank failures. Mr. Mail's. Well, taking your own statement, Senator, do you think if the banks there had united so that the strength of each would have been the strength of the other--of course you would have had the weaknesses also—there would have been the same number of failures? Senator BROOKHART. Yes; with the price of corn and hogs and wheat and oats the way they are. . Mr. Miu.s. You would have had the failures anyway, it didn't make any difference, is that it, Senator ? Senator BROOKHART. You are going to have failures of your coinin Michigan, because they will quit buying Fords pretty binations \ \soon. `. Mr. MILLs. The failures there bad no relation to groups. W. R. McQuaid, Pres., Barnett Nat. Bk., Jacksonville Hearings — S. 4115 March 1952 r. McQuAm.\Yes. liates and branch bankinff: I think there should be stricken out of lines 21 and 22 of section21: "If such establishment and operation are at the time permitted to State banks by the law of the State in question." Senator GLASS. You think we ought to go into the States whether they want us or not, with national banks? Mr. McQuAm. Yes, sir. Holding companies were created because Federal law did not, and many States do not, permit state-wide branch banking. As a bank having affiliated banks in our State we would welcome the opportunity to convert these separate affiliated banks into branches and feel that other banks having affiliated banks would do likewise. There would not be any need for any regulation bf any holding corporation so far as we are concerned if you are able to do that. Senator GLASS. You know, one witness only to-day protested against the invasion of State's rights to the extent of :s0 miles across the border from the bank. Mr. McQuAm. My preference, Senator, would be to confine it to State Senator GLASS. Whether the State law permits or not? Mr. McQuAm. Whether they permit it or not. Why should the Federal law, enacted to give a national, uniform system of banking, be modified and hampered by laws of any one of 48 States, or the national banks of 1 State denied the facilities or rights given national banks in another State ? Senator GLASS. I am not disagreeing with you if you could get an assurance that you could get the branch banking through Congress. I do not think this committee would largely disagree with you. Mr. MCQUAID. That would eliminate to a very considerable extent some of these difficulties about holding corporations. Senator GLAss. I would like you to have the job of managing a bill like that through Congress. It took us 16 months to get the small measure of branch banking • in cities and counties. • • • • Under the provisions of section 19 no corporation or partnership owning more than 10 per cent of the capital stock of a bank is permitted to vote the stock unless a permit is received from the Comptroller of the Currency, even though the ownership by the corporation or yartnership is incidental to their real business, and such permit will not be given if they engage in the distribution of securities, and unless, among other things, reports be given periodically to the comptroller and permission be given to an examination by national bank examiners. While it may be desirable to require reports and permit examination of affiliate holding companies of banks owning control of affiliate banks--I have no objection at all to that—these restrictions in other corporations owning more than 10 per cent of a bank's stock are unnecessarily severe, at the most they should only be required to satisfy the Comptroller of the Currency that they had 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis W. R. McQuaid, Page 2 March 1952 292 1 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTE1V1S sufficient other assets to meet any stock assessment that might be levied upon bank stocks held. I am perfectly in accord with the idea of regulating the affiliate holding company such as ours is. We have a corporation whose stock is indorsed upon the stock of our bank. It holds only bank stocks, banks that we are interested in. I am perfectly willing that that corporation be examined as many times as the comptroller wants to examine it, and I am willing to comply with all the regulations you have provided in there, because that is strictly a holding company of bank stocks. I am perfectly willing to create other assets that are sufficient to cover the par value of bank stocks. As a matter of fact, we have cash now for almost the par value of the bank stocks held in that corporation. But when it comes to other corporations where they own bank stock and their ownership is incidental, I think that is pretty severe. Other lines of business are not going to permit examination by Federal examiners. Some of the radical changes and restrictions proposed in the present bill, to which only brief reference can be made here, can work tremendous harm to the banking and business interests of our country. Change,s should be made only after careful consideration, both from the standpoint of actual practice and experience as well as theory. Material submitted by Senator Norbeck for Record Hearings - S. 4115 March 1952 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 355 AND SONE CALL IT "BETTER [American Banker, January 15, 1932] • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Sundry short-sighted gentlemen of the press and of banking point to our 2,300 bank suspensions in 1931 as a convincing "argument" that branch banking is a better system. But the last four months has utterly exploded the validity of their argument. Branch banking as practiced in England and carried on in Canada has faults more glaring and dangerous than any which can be charged against unit banking. If anything, the branch system is even further than unit banking from that ideal of perfect bank responsibility, so desirable, yet, like other dreams of human perfectibility, probably equally unattainable. We have our bank closings. The figures tell the story. But branch-banking systemS, instead of suspending individually when they are faced with a run, pull the monetary standard of their countries crashingly down when they face the crisis of deflation. Branch-banking systems are "too big" to fail or to be permitted to fail. They can not suspend to liquidate, as do our American banks, making way for the reorganization of a sound bank or the organization of a new bank. Their liquidation can not be compartmentized and absorbed locally where their credits were spent. Every Britisher is paying to-day with 30 per cent of his deposits for the "safety" of his branch banking system. Every Canadian is paying for "safety" of his branch-banking system with 20 per cent of his deposits. True, the Britisher and the Canadian have as many pounds sterling or Dominion dollars in the accounts as they had before the crash. However, 20 to 30 per cent of their value has been taken from them by the loss of purchasing power of their funds. True, also, they hope to get full value back. But so do American beneficiaries of individual closed banks, with better reasons, as we see It. Perhaps you can 6°1 the British and Canadian people into thinking that 'such a system of mass confiscation of their banked wealth is better. Concen• trate the money of a Nation into a few large banks through branch banking if you like. Ignore, if you can, the fact that credit administration is thereby taken from sympathetic local hands and put in the hands of distant city money'market manipulators. Forget, if you can, the fact that another field of the individualistic enterprises to which we owe our American progress is thus handed to a monopoly. Ignore such social and economic implications of branch banking, if you can. But you can not escape the truth that mismanagement hig banks is possible, and when it conies its very momentum is likely to be more costly than we have found it under unit-banking systems. Mistakes can be made by branch bankers. They were made in France, where, after some of the smaller branch banks failed, the government was forced to pour billions of fiat francs into the temaining branch-banking systems to keep them alive. rold came simultaneously with this governFrench depositors' demands for , in Cletmany before the moratorium was comment subsidy. The situation ' plicated with branch-bank failures which could only be solved by the use of government guaranties and freezing of deposits. Not only has branch banking given a poor amount of itself to its depositors, but countries which have depended *upon it have fared badly. But do we need to look abroad to see the danger which is inherent in the branch bank idea? Our own Government has had to pledge both money and credit to support at least one branch bankin,g situation where poor management policies in the boom had led to weakened depositors' confidence in the depression. 'Mistakes in banking are being made. And they are bigger and more dangerous in geometric proportion to the scope and size of the banking organizations making them. The fact that the error may hinge upon Government fiscal policy as well as banking, only emphasizes the fact that bigness of banks is a liability to governments rather than an asset in times of crisis. London made such a mistake. It was a banking and credit blunder. Every moneyed person in the British Empire is to-day paying the price of that mistake. The folly was too big to be absorbed in the reorganization or liquidation of one or more banks. Closing even one big branch bank would have precipitated a national smash. instead, the British Government and bankers have charged the cost of their 'mistakes to the entire wealth, of the country.' The banks simPlY went off the gold standard. Unit banking can not exist without Material submitted by Senator Norbeck for Record Hearings - S. 4115 March 1952 Page 2 1 356 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS the implication that some banks will be run better than others. But unit bankers can look forward to the hope that through the cooperative effort toward better bank management as expressed in American Bankers Association work, in Federal reserve membership, local clearing-house associations, and thelike, the percentage of mismanagement and the percentage of victims of Government mismanagement can' be reduced to a smaller and smaller figtire. Branch banking systems can not be operated without facing the danger that mistakes at headquarters will plunge the whole country disastrously off its gold base. Only a fool can delude himself into the belief that any guaranty of bank deposits is possible. flis folly is no less if he worships the guaranty of deposits idea wider the guise of branch banking. FARMERS STATE BANK, Westport, S. Dak., Marc*, 26, 1932. HOD. PETER NORBECK, United States Senate, Washington, D. C. DEAR Ma. NORBECK : The provision in the Glass bill restricting branch banking to those States that permit State branch banking should be sustained. There is going to be a fight on this restriction—the branch, chain, and group banking interests in the country are going to bring their influence to bear against this restriction in the hope that it will provide another wedge into the dream of national branch banking over the entire country. States rights should be held inviolate; the people in each State should have the power to say whether they want branch banking. The big argument in favor and which is being stressed by those interested is in safety, but the record of failures of branch and chain banking in this country the past few years amply demonstrates the fallacy of that theory. Unit banks can be and many are just as safe as a bank should be; they have the interest of their own communities at heart. Witness this bank which in the 12 years under my control has been one of the few in the country that has never had to borrow any money, and to-day we are taking care of the legitimate requirements of our customers. Branch banking in the final analysis will bring on economic stagnation. stifle individual enterprise, and throttle the "little fellows," the farmers and small" tradespeople. Why all this howl about losses to bank depositors? The percentage of loss has been less than to most anY other class_pf investoi: 173Ft's take, for sake of argument, the cases of, say, four people, who three years ago each had $5,000 to invest. One put his money into farm, one into what he had been led to believe were sound bonds, one into a first-class farm or city his into put a last bank. mortgage, and We will say the bank failed. Who was the worst off? The record will show that the man who put his money into. the sustained, in majority of cases, the least loss of any. the bank The big banking interests of the country are simply using the present economic chaos into which the whole world finds itself as an excuse to sieze control of the banking business, to centralize the money power in the East for the benefit of so-called big business and to the exclusion and disregard of the agricultural sections of the country. If this succeeds it will mean ruin to millions of people and the stifling of individual enterprise. If you have any doubt of this you might take a trip into Canada, as I have on two different occasions, and talk with people in that country—a country that is just as wealthy in national resources as we are--you can come to but one conclusion, and that is that their whole economic and individual development has been permanently impaired--due, for the most part, to their system of branch small tradesman, the merchant, and the farmer sim 1 ha n't a banking. chance. If, f1na y,-We liave nation-Wide WiTina-bank ng in s country, t en we are coming to the same condition—just as surely as the sun rises in the morning, and nation-wide branch banking is what we are cgming to unless the people wake up in time. There have been losses under our present form of banking—losses which no system of banking can entirely overcome--but rather those losses than the loss of our individuad initiative and economic progress that is bound to follow the abolition of "independent" banking. I am going to watch with much interest the scrap that is bound to come up, over the restriction in the Glass bill to which I have referred. Yours very truly, DOR W. DE VIM. • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis John K. Ottley, Pres., First Nat. Bank of Atlanta, Ga. Hearings — S. 4115 March 1932 1 • • Group banks: The act would, in my o inion, have a disastrous effect on the group of banks in Georgia a liated with the First National Bank of Atlanta. This group was organized in accordance with the law, and rights have grown up which could not be _protected under the Federal reserve system if this act is passed. Each bank in this group is unquestionably stronger and able to afford better service to the public as a member of the group than it would be if operated independently. As between group banking and branch banking under proper regulations, I have no hesitation in saying that I advocate the latter. Section 21 of the act, page 45, is an approval of branch bankina, but it does not go far enou_gh to save the groups already organizecrsince it is limited to those States which permit branch banking by State law. Georgia permits branches but under such limitations and restrictions as would not be'applicable to our group. The legislature of the State is not scheduled to meet for more than a year and we could not, therefore, reasonably expect to secure the necessary legislation in time to save our group unless this act is amended by permitting groups alrvady organized to be converted into one bank with branches at the places where the established banks are now located. All members of our group are national banks and, therefore, members of the Federal reserve system. They are operated by independent officers, and in every instance care has been exercised to retain the local boards of directors primarily interested in the welfare of their communities and the accommodation of commerce, industry, and agriculture in the contiguous territory. In addition to subscribing their full quota to the National Credit Corporation and aiding in every legitimte way the other financial institutions in Georgia, these banks have retained the confidence of the public and have been able during the depression through which we have passed to afford adequate banking: facilities to their respective localities. Having been organized in full compliance with the laws of both of State a,nd Nation, valid contracts have been raade and relationships have been established affecting extensive property rights. Having done no wrong and having committed no crime,I respectfully submit that we should not be punished because some one else has broken faith or abused a privilege. The many provisions of the act aimed at group banking would affect seriously not only our banks. which represent 30 per cent of the banking capital and deposits of Georgia, but also another sound and well-organized group in the same territory. 111161-32-PT 2-7 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 318 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS ! These two groups furnish to the commerce, industry, and agriculture of Georgia more than half of its banking accommodations. 1 1 _ William K. Payne, Chairman, Auburn—Cayuga Nat. Bk. & Tr. Co., Auburn, N.Y. Hearings — S. 4115 March 1932 On the questioon of the branch bank business: Many of our country banks have long given their community satisfactory service under the unit banking system and view with some apprehension a further extension of chain and branch banking. My own opinion is that this system will grow as, if, and when it suits the business needs. It is a slow and evolutionary growth, and its final form will come through . the trial and error system. Whatever legislation is enacted will not be perfect; there will be defects in it, and during that time of experimentation it will be costly to the banking system, but I think it has got to come. Senator GLASS. What has got to come ? Mr. PAYNE. Experiments as to What is the ultimate form of our banking system. But it seems tt• me that this is not the time to go through those experiments. If you gentlemen feel at all the way I feel about the serious situation we are in now,it seems to me you can agree with me th,at anything in the nature of experimental legislation looking to a change or to new forms of the machinery of business should not be undertaken at the present time. , Senator GLASS. TM we have had witness after witness to tell us that we not only should have branch banking but that we should go into States regardless of State laws. 1 • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 337 Mr. PAYNE. That may be so, Senator. I do not think any of us can predict what the ultimate form is going to evolve out of this system. I think there are going to be changes as there are in practically every other form of business activity, retailing and other things, but it seenis to me this is not the time to begin those experiments. Senator GLASS. Do you favor general banking or group banking? Mr. PAYNE. Do I favor it? Senator GLASS. Yes. Mr. PAYNE. Frankly, I do not know what the solution is. We have grown up under a unit system and we like it. I do not think it is going. to continue. Of course, it is not now the only system. We are going through an evolution, and what the ultimate outcome iS T do not know. I wish I did. .4-- Edmund S. Platt, V. Pres., Marine Midland Corp., Buffalo Hearings — S. 4115 March 1932 1 Governor PLATT. I was moved to remark, in answer to Mr. Zimmerman, that I wondered how the city of Philadelphia has managed to survive all these years with a branch or two located in it across State lines. The Camden National Bank of Camden, N. J., has had a branch in Philadelphia for ahnost 120 years, and Philadelphia is still there. That branch was established in the old days when crops used to be moved from the lower part of New Jersey into Philadelphia and was established about 1813 to help move the crops, and it has been there all these years. It was a State bank originally. Senator BROOKHART. Do you think the idea was that Philadelphia would like to get even with Camden? Governor PLATT. As a mattter of actual fact, branch banking is not a cormorant and does not grow half as fast as its opponents think it will. Maryland, Virginia, North Carolina, and a number of other States have had state-wide branch banking for years, and no bank in Baltimore has got a branch outside the city except in the immediate locality, if I remember right, Senator Glass. I believe that the only way to stop bank failures is to allow banks to consolidate. Why should they be restricted from consolidating if they do not happen to be located within the same limits? The national bank act curiously provides that banks may consolidate within county limits, but if you do consolidate them within county limits and they do not happen to be within the same municipal • NATIONAL AND FEDERAL RESERN'E BANKING SYSTEMS • 1 311 limits, one of them has to be closed, and I do not see any sense in that at all. Senator BROOKHART. Out in my country they consolidated, and both of them failed afterwards. [Laughter.] Governor PLAIT. I know when I was on the Federal Reserve Board we agreed to a consolidation of two banks that were 30 miles apart--in South Dakota, I think—and it was said that there was a good road between the two towns, and therefore there was no reason why the other town should have a bank. It would seem to me 20 miles is quite a long way to go. I have talked a good deal about branch banking at various times, and I now want to say a few words about the Federal reserve parts of the bill. 07,11 1P 1 1 I I , https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Governor PLArr. I do not think that we need to have nation-widebranch banking. Until recently there was a very nice little bank in Saskatchewan with 25 branches, all in one Province, Saskatchewan, the Weyburn Security Bank. All of the agricultural territory was hard hit. They did not fail. They are in an agricultural territory, but good management or some additional spread of risk through branches in different communities kept them from failure._ — _ I https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. W. Pole, Comptroller of the Currency Hearings — S. 4115 March 1952 Mr. POLE. Attention Cs pariicularly directed to the fact that this section is a restriction upon national bank members of the Federal reserve system only and does not apply to State member banks. This is true also of section 20, which places restrictive regulations and reserve requirements upon group bank holding companies which have national banks in their groups. These two sections as they stand would undoubtedly lead to the withdrawal of the great ume of resources now held by national banks in group bank organizations from the national system for the simple reason that any such group organization can escape these burdens by becoming a State bank and still remain within the Federal reserve system. Senator GLASS. You think that group banking is a wholesome system of banking then, do you? Mr. POLE. I have never been in favor of it, Senator, except that. as I have said, before it is legislated against, some provision should be made for that large amount of capital which is invested in group bankina, and that group banking has been extremely beneficial in la number of sections of this country. Section 21 contains the branch banking provisions tof the bill, but :permits national banks to establish branches only in those States ;where the State law permits it and only to the extent permitted by such State lai,v except for the proviso for a 50-mile extension beyond State lines in certain cases. In my judgment, this section will accomplish little or nothing in the way of branch banking, since only a few States permit state-wide branch banking. The particular need for branch banking by national banks is in those States which do not permit branch banking to the State banks. There is a cryina need for banking facilities which can be given by strong city banIL in the rural communities of the United States. I know of no other sound solution of the rural bank question. NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS 433 I need not dwell upon this matter since I have expressed my views at length both before this committee and before the House Committee on Banking and Currency, but I may add that subsequent events have only confirmed me in the recommendations I made for wider branch-banking facilities, in my reports to Congress for the Years 1929, 1930, and 1931. J. W. Pole — Page 2 March 1932 • • 1 Sena-tor TOWN-SEND. I recall some of the witnesses who testified here and indicated that any legislation of this time might be detrimental to the banking interests of the country. What is your judg,ment on that ? Mr. POLE. I think decidedly to the contrary that it would be extremely helpful at this time. In fact,I should say that if Congress would amend this provision of Section 21, I think it is, which has to do with branch banking, leaving the section just as it is, with the amendment "regardless of whether or not the States permit it," it would enable the strong banks to give relief and extend their facilities to the rural communities, which would be of invaluable assistance to the country. Senator GLASS. Are you satisfied, Mr. Pole, that the decisions of the courts certainly ma'ke that constitutional? Mr. POLE. I have been so advised, Senator. Senator GLASS. I put into the record when we had the prolonged hearings last year a summary of court decisions prepared and given to me by Mr. Collins, formerly deputy comptroller, and I would judge from this summary that it would be entirely within the province of Congress to authorize state-wide branch banking regardless of the laws of the States. Mr. POLE. I have been advised so by what I regard as first-class authority. Senator GLASS. But you can not give us any guarantee that Congress would accept our view of it, can you Mr. POLE. I am afraid I can not do that. I think we could make an effort, however. Senator GLASS. As well organized as the effort has been to tear this bill down V Mr. POLE. I think there is a lot of support for that kind of legislation, because there are a great many thinking people who realize that something has to be done for the banking system, something more than this. We have to protect the rural communities. That is what we are not doing now. Senator GLASS. I am very sorry you were not a tutor at the night school, because all of the testimony that we have heard here except Governor Meyer today has been to the effect that it would be a fearful thing to enact any legislation at all at this particular time. Mr. POLE. I think it would be a very good thing. I am not saying there should be any disturbing or drastic legislation, but I do say ,,legislation of proper character would be immensely helpful. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 1 Thomas R. Preston, Pres., Hamilton Nat. Bank, Chattanooga Hearings — S. 4115 March 1952 • _ AI PRESTON. Now, we have a small group, and under the terms of this bill—well, I will first describe the group: We have a group only in our immediate territory. The parent bank is one and there are 16 others. Our total deposits normally are about $40,000,000. There are 4 groups in Tennessee, 2 in Nashville, 1 in Chattanooga, and 1 in West Tennessee, composed wholly of country banks. Not a single one of those banks has had any trouble during this depression, and I will say that I have been in the banking business a good many years, and have gone through five depressions, but I have never seen values melt as they have during this time. The depression of 1893 was bad, but not as bad as- this. None of these banks has failed ot: taken the 60 days' withdrawal notice, and I think all of them have done constructive work, and they have saved a good many weak banks. We have ourselves taken over six in the past year and. a half, and some of those I know would have failed. Another thing we have found, and I think it is true of all sections of our State: The public are not agpin4. branch or _group_ banks. They_iiiie-tsuiu-liusiness • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator GLASS. Well, they are not the same thing, Mr. Preston.. Mr. PRESTON. I know they are not -the same thing. Senator GLAss. They are not the same thing by any means. Mr. PRESTON. 1311t the public have no objection to either kind so far as I have been able to ascertain. Senator GLASS. We have been urged to abolish group banking altogether. Mr. PRESTON. Well,I think it is all right to abolish group banking if we had some place to go. Senator GLASS. Well, we have tried to provide you a place in this bill to go, in the matter of branch banking. Mr. PRESTON. Branch banking would be all right. The bill provides that we can go to branch banking only when the State laws allow the same privilege to State banks. As an example, you gentlemen would follow the Tennessee Legislature, and it looks to me like it would be fairer for the Tennessee Legislature to follow Congress. Senator TOWNSEND. Doesn't the State of Tennessee permit branch banking? Mr. PRESTON. Only within city limits. Senator GLASS. If it permits it at all under this bill a national bank would not be confined to a State. We do not require that. Ai 1 Thomas R. Preston — Page March 1932 328 • 1 • 1 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Mr. PRESTON. You permit only state-wide branch banking or areawide branch banking when the State permits it. Senator GLASS. Yes. Mr. PRESTON. Then some national banks in some States would have a state-wide privilege, while in Tennessee they would not have it. It may be all right, but I don't just quite understand the provision. Senator GLASS. That might put you to the necessity of going to the Tennessee Legislature and getting them to legislate on a sound basis for branch banking. Mr. PRESTON. It would. Senator GLAss. But if you can assure us that Congress will make it otherwise we will be very glad for you to do it. Mr. PRESTON. It 100kS to me like these limits could be put on branch banking. For instance, you could have the groups covert their units into branches and stop there, or you could permit them to extend their branch banking when they bought out an older institution and allow them to go on. I think the unit bank has served a great purpose, and that it should be pre,served and protectea. I do not believe that a large bank should be allowed to put up a branch in any community at will. They might buy an old bank or something like that or absorb one and create a branch. Senator GLASS. Did you ever hear of a borrower at a bank, a business man or merchant, who wanted credit at a bank. who objected to branch banking? Mr. PRESTON. In few instances I have. Senator GLASS. I never have. Mr. PRESTON. In fact, most complaints come from the borrower. Senator GLASS. Well, I have been in Congress 30 years, and I have sat in at many bank hearings, and I have never known a man who wanted credit, who was a borrower at a. bank, to object to branch banking. Mr. PRESTON. It is seldom the case, that is true. Senator BROOKHART. I can bring you some that will make very emphatic objections out of their own experience. Senator GLASS. They might be major stockholders in some bank who wanted to monopolize the community. Senator BROOKHART. No; they are not bankers at all. Mr. PRESTON. I think the key to this whole business is the branch banking feature if it is extended and you allow these groups to convert. I think that will do as much to stabilize the financial situation as anything else, and probably more than anything else I know of. Senator BROOKHART. In branch banking doesn't it often turn out that the local branch has to get authority from a higher place? Mr. PRESTON. Sometimes that is true, but that depends upon managers. Senator BROOKHART. And it is very detrimental to the local community. Mr. PRESTON. Sometimes that is true. And sometimes it would be better if it were true more frequently, to have at least a conference about loans. Senator BROOKHART. You may proceed with your statement. George F. Rand, Pres., Marine Trust Co., Buffalo Hearings — S. 4115 March 1952 • It is an interesting thing to me that so many group banking organizations, with practically no knowledge of each other, sprang up almost simultaneously in different sections of the country as the result of a distinct need for this type of banking. The northwest group, the Michigan group, Atlanta group, our group in western New York developed along very much the same lines, although entirely independent of each other and with no conferences and with no working together in any way. It seems to me that they fill a distinct need in our banking structure. Group banking, during the past two years, has been one of the most constructive features in our whole banking situation. In the provisions of the new Glass bill we hope that the splendid work done by group organizations will be given recognition and encouragement and will not be penalized by burdensome restrictions. I arrived last evening and had the privilege of reading Mr. Wakefield's statement to • your committee yesterday. Mr. Wakefield's statement represents my views in many respects. I concur in his recommendations regarding section 20 in reference to the reserves in assets other than bank stocks to be accumulated by holding companies, in reference to branch banking contained in section 21, in reference to the reserve requirements for national and member banks contained in section 13, in reference to limitation of investments of time _ deposits . . contained in section 14. 1 1 • In closing, I again refer to the constructive work done by our group in western and central New York, and in illustration I would like to cite two concrete instances. In Albion, N. Y., in Orleans County, 11 banks had closed their doors in 27 days, within a radius of 20 miles, including the Citizens National Bank of Albion, leaving our Orleans County Trust Co. the only operating bank in this vicinity. Within 2 months and 11 days of closing of the Citizens National Bank, we had made arrangements with the national banking department and had given iminediate credit of 50 per cent to the depositors of the closed bank, which set a record for speed in liquidation in our territory. At the present time we are planning to open a new bank in Medina, a village of MOO population, where both banks have failed, and at the request of the banking department, we are organizing a new bank there, which will be opened about April 4, and will take over certain assets of the closed banks and give depositors of the closed banks credit for a proportion of their deposits. I cite these two instances, and these are typical, to show the constructive work we are doing, and I might say that rural New York State does not present essentially different problems from the other groups in the West and South. In conclusion, I submit that the record made by group banks throughout the country, during the past two years, has demonstrated beyond doubt, the economic soundness of the principle. upon which 1 482 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AN.D FEDERAL RESERVE BANKING SYSTEMS they have been organized, and their right to recognition and encouragement in any new legislation. George F. Rand - Page 2 March 1952 , • • • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • • Senator BARKLEY. Your group is largely country banks? Air. RAND. No. Our group is built up around the Marine Trust Co. of Buffalo, which is a $250,000,000 bank, and we have a large bank in Rochester and a large bank in New York City, the Marine Midland Trust Co., which is a member of the New York Clearing House Association. Senator GLASS. Mr. Rand, in a sense, then, and in a degree do we not have nation-wide branch banking in this country now ? Mr. RAND. Do we not have nation-wide branch banking? Senator GLASS. In a sense and in a degree, through correspondent banks? In other words, does a bank in Chicago and various banks in New York have as many as 4,000 or 5,000 correspondent banks throughout the country? Is not that in a sense and in a degree branch banking? Mr. RAND. No, I do not see, Senator Glass, how it is. It may be in some sense, in some degree. SellatOr GLASS. That is what I am saying. In other words, the correspondent bank, usually the little country bank that has its -correspondent in New York City or in Chicago or in St. Louis, is in a sense subservient to its big bank, is it not ? Mr. RAND. No; I would not say that, Senator Glass. Senator GLASS. I know you would not, but I would. Mr. RAND. The difference is that the New York bank has no 1./ *urisdiction over its investments. enator Ga§73-.-It litis-ifol-Statutory jurisdiction over it, but it extends its privileges, does it not, for which it is duly' thankful, or gives it advice, does it not, which it usually follows? Air. RAND. I would not say that. It will if it is asked for, probably. It depends on the local situation. I3ut where a New York bank has several thousand correspondents, I do not see how it can take very much interest in the internal affairs of any one of those correspondents. Senator GLASS. It does not extend privileges without knowing something about their business, does it? Mr. RAND. I did not understand that question. Senator FIAETCHER. They do not really extend privileges; they require the correspondent bank to put up the money with them, do they not V Mr. RAND. I am not qualified to answer on that. Senator GLAss. I know, but the reason they put up the money is that they expect the privileges to be extended, and they are extenCled, and the little bank feels under obligation to the big bank. George F. Rand — Page 3 March 1932 484 • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS Senator BROOKHART. There are times when the big bank allots investment issues to the little banks, and they usually take their allotment. The CHAIRMAN. In .confirmation of the statement of Senator Glass, I will say I have noticed that our small bankers in South Da,kota, in conversation, will state,"I have just been down to Sioux City and talked with the big bankers, and so and so." When I am in Sioux City, they say,"We have just been to Chicago and we saw the Chicago banker.' He says he has just been to New York City. Now, it seems where our banks were loaded with poor securities and we have talked to them, they say,"Why, yes. The Sioux City people say it is all right." The Sioux City people say they have talked with Chicago, and Chicago said it was all right. The Chicago people say they have talked with New York, and New York says it is all right. So I quite agree with Senator Glass that we have a branch banking sy-stem now, and, in my opinion, too much of it, and I think the condition of our banks in the country is proof of it. Mr. RAND. I think we have the very opposite of that. The New York banks or the large city correspondents have no control over the purchase of securities or the investments of the smaller ba,nks; and there are so many other agencies that are selling securities to the small bank that I think you will find the proportion of the securities sold to the correspondent banks by their New York bank correspondents is not high .but very small. Letter from Charles E. Rieman, Pres., Western Nat. Bk., Baltimore Presented for Record by Senator Goldsborough Hearings - S. 4115 March 1932 (Letter dated Mar. 22, 1952) - The amendment to national bank act, section 5255, in reference to branch banking does not go far enough. If it is desirable that national banks can have state-wide branch banking In one State, it applies to all States, and if there ever was a need for branch banking it is now, which should be developed under Federal laws and not under State laws. This is the one item in the whole bill that is in the nature of constructive legislation but falls short of nationwide benefit. .11 nif, +hes •.11.t.,n neNirs+o cre, limo. lust 17 tn dicwirmrsive InPrrihprshin thP • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 L. E. Wakefield, Pres., First Nat. Bank of Minneapolis, Minn. Hearings — S. 4115 March 1932 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis _ I shall confine my remarks to the effect of this-bill in its present form on group banking as it exists in the Northwest. I believe that the purpose of the bill is constructive and contains great possibilities for good, but after careful study we in the Northwest are convinced that it should be altered in several particulars to avoid a. harmful result which outweighs helpful features. group By way of introduction I would like to state in a word what are group our of banks the of Most banking, with us, means. holding a by owned is banks these of stock The banks. l nationa the company and for the most part was acquired by exchangingthat so banks, the of stock the for y compan holding the of stock a each original stockholder in an individual bank continues to be of a number over spread s interest stock his with but lder stockho of banks instead of being confined to one single bank. The result a n of creatio the to effect, l practica in s, amount ge exchan this ty of diversi benefit the obtain s partner the partnership, in which all of assets increased efficiency of management, and economy through standardization of banking methods. Inasmuch as the two cities of Minneapolis and St. Paul predominate enormously in population over the rest of our territory, which is largely rural, this partnership. is in reality a partnership existing between the cities and the country out to be a Up to the present time the partnership has turnedgeous one for advanta y ondingl corresp a and cities the for one poor agriand ture agricul in ion depress extreme the the country, because and banks country the to losses heavy in ng resulti values, l cultura it imposmade only not has assets, frozen a great increase in their s of the sible for these banks to produce their share of the earning ies compan holding the for ry necessa it made partnership, but has their impaired restore to money of sums large with them supply to condition. capital and reserves and keep them in a sound and safe proved However expensive this has been for the cities, it has in facthad nuhave We whole. a as district the to of inestimable value no big merous failures of small independent banks, but we have had values, bank failures. In spite of the disappearance of farm lands, cattle, in spite of drastic reductions in the price of farm product ed in etc., and in spite of drought and grasshoppers, we have succeed section, maintaining a sound banking structure for the people of ourwhich is and this success can only be attributed to the strength inherent in the group system of banking. Michigan, remain We did not, as in the case of our friends in that, with the reason simple the for State, one of borders within the our territory in State one no is there ta, Minneso possible exception of make group to es resourc of y diversit nt sufficie affords itself which of pment The safe. develo or le profitab either banking, thus limited, g system bankin group any that clear it makes years two past of the or in North which had attempted to operate in Montana alone the most had have would alone Dakota South in or alone Dakota d any one of involve have y probabl would and disastrous experience re. g structu bankin its of e collaps e complet a in states those Our task is by no means completed. We are willing to accept the responsibility for completing it and hope to do so without ask- L. E. Wakefield — Page 2 March 1952 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 341 I ing any financial assistance from the Reconstruction Finance Corporation, the National Credit Corporation, or any other agency. We only ask that we be not hampered or hindered by the enactment of legislation which would make our task any more onerous than it already is. Naturally that portion of this bill which is of paramount and absolutely vital importance to us is section 20,. which prescribes that group bank holding companies shall maintain certain reserves in assets other than bank stocks for the purpose of protecting any future stockholders' liability. The enactment of this section as written would completely put us out of business, or at least force us out of the Federal reserve system. This is not a threat; it is a plain statement of fact. We do not want to abandon the Federal reserve system, but we are physically unable to comply with these requirements. The assets which would have enabled us to maintain these required reserves have been depleted by contributions to our country banks for the purpose of restoring their capital and reserves. Even if this were not so, we think the reserve requirements are altogether too severe and that they are particularly unwise in that they require the holding company to maintain them in a frozen condition and only permits their use after a bank has failed rather than allowing them to be used to prevent such failure. I understand that an amendment is before the committee which reduces these reserve requirements and makes them available by way of prevention before failure as well as a cure afterwards. If this amendment is adopted,. it will remove our objections to section 20. The other provision of the section, requiring reports and examinations of the holding company and its affiliates, have our hearty approval and support. The next subject of great interest to us as group bankers, and of even greater importance to the communities we serve, is the matter of branch banking, section 21 of the bill. As this section is now drawn, with the limits as to State law included, it accomplishes nothing so far as the Northwest is concerned. If this limitation were removed, it is almost impossible to exaggerate what it would accomplish in our territory. I recognize that, in_adirocallirie-wide brangli_banking. at this time, I am departing from opinions pressed in my testimony before the subcommittee a year ago. I admi that frankly. We have learned by our experience of the last thr years how much more effective branch banking would be than grou bankina. I do not think that a year ago the people in the countr district's were ready to accept branch banking, but this sentiment ha undergone a great change, and I am certain that the majority o these people are not only no longer opposed to branch banking bu anxiously hoping that it will be accomplished with least possibl delay. Aside from the correction of faults and abuses which have de veloped in the banking business during the last few years, it is essential that any banking legislation should be directed toward relieving the emergency which exists at present in the banks of the country, by preservation of the deposits in existing banks, the restoration of confidence by the prevention of further bank failures, and the estab- WI/ L. F. Wakefield - Page 3 March 1932 342 • • 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS lishment of a sound banking structure as the prime requisite to revival of general business. At this time there are a large number of banks open and operating where the capital and surplus have been impaired through depreciation in the value of securities held and losses on loans caused by the general depression. In addition to this there are many places which formerly had banking lacilities,but wL-Ch are not nciiv- Wein-Tg by_an.y banit."-TbeTieve that the only thing that can even partially save or correct this situation is a law which will authorize state-wide branch banking by national banks immediately and without waiting for the State legislatures to meet. I make this stateso ment far the following reasons: At the present time it is not possible to raise capital for the purpose of establishing small banks in connnunities which are not noW .. seriTed.— ' ---The public authorities, the comptroller's office, and the various superintendents of banks, in their anxiety to hold our banking system intact so far as possible, are at present carrying on with a large number of banks whose capital and surplus have been impaired by both depreciation and losses. They are doing this in the hope that banking legislation will provide some means whereby the deposits in these banks can be rescued and taken over into sound banking institutions and be preserved as live deposits instead of turned into the obligations of a closed bank. There are a large number of these institutions which c,ould furnish a sufficient amount of sound assets so that their deposit liabilities could be assumed by another bank as a branch office. The local stockholder has, to a large extent, suffered business reverses; he has paid in additional capital to his bank in the past and is no longer able to supply the founds necessary for recapitalization at this time. For these reasons it seems to me imperative that if there is any desire on the part of Congress to preserve the greatest amount of our present bank deposits, Congress should reco„omize this situation and provide a means immediately which will make this preservation possible. The suggestion is made that Congress is loath to legislate arbitrarily in this matter, preferring to leave the ultimate decision to the legislatures of the various States. To me this is inconsistent with the principles underlying the national banking system. This system was established by Congress without regard to State law, and Congress has jealously retained all rights and supervision over it, so that any amendment to the national bank act could not be legitimately considered as an interference with the sovereign rights of any State. Furthermore, if the matter is left to the States, and national banks are granted the same branch banking privileges as are granted to State banks, we shall have the national banks of the country operating under 48 different branch banking laws. Just as a matter of interest I would like to refer to the fact that the Reconstruction Finance Corporation is experiencing the greatest difficulty in confusion on account of its having to adopt itself to these various State laws-48 different systems, each one .having its own regulations and of a very peculiar nature and the provision authorizing national banks to operate branch banks, as provided by State law, would simply mean the bringing of that same https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L. E. Wakefield - Page 4 March 1932 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 343 confusion of regulation and privilege into the national banking system, which now prevails among the 48 States, and it seems to me to be a very undesirable thing to do. The advantaae of havina the entire system operating under one standard law is'-'too obviounor argument. Aside from all this however, the controlling factor is time. If this matter is delayed for the time necessary to secure State legislative action, the various banking departments will not be able to put off taking the steps necessary to remedy the present ipondition, which can only result in a great increase in the number of closed institutions. A year's delay would be fatal. Every bank which closes _between now and next _year represents a local tragedy. Each one which might have been prevented-by-biana-Valiking at this time will forever stand as a reproach to the legislative body that might have saved it by the exercise of political courao.e when it was most needed. The CHAIRMAN. Woullyou be willing to take over all the banks out there if you could ? Mr. WAKEFIELD. That would have to be done under regulations that would permit it. The CHAIRMAN. Would you take over the solvent and the insolvent also? Mr. WAKEFIELD. As far as it would make possible negotiations. Not all of them by any means. The CHAIRMAN. I suspect, when this would come as a remedy, you would find three classes of banks: First, those you could not buy; second, those you would not buy, and the third, the ones you would dicker for. Mr. WAKEFIELD. I think it is the most favorable time, if there is ever going to be a time, to permit branch banking for this reason The CHAIRMAN. I do not care to go into my argument on that Mr. Wakefield, but I thought your statement was too broad, holding out the hope that branch banking will save the situation the trouble of ours which has an underlying cause. If you advocaled a better price for the farm products up there, the banking situation would respond to something of that kind. Our trouble is agricultural, rather than banking. _ _ That is my view. Mr. WAKEFIELD. I am only seeking to point out the only spot that I know of which we know could be created, which would make possible at this time the rescue and maintenance of a substantial portion of now live deposits and continuing them in that shape. There is probably no man on this committee who does not believe —Wiacts7.144:6that branch banking in some fox,I :lots : table S- ooner or later. If"go, no time could be selected when it would do more-good-than at present. It has been suggested that group banks be permitted to convert their present units into branches, restricted by State boundaries If for political reasons it is impostinwutheitlternatime would+,of sible to obtain branch bank.1 t woul be of enormous help to us in carrying couL§g. e_ ,• olWthe difficult work we are now engaged in, but there is no denying the fact that it would not supply the needs of the rural communities which I have mentioned. It would not enable us to prevent further failures of small banks, nor would it enable us to furnish banking service to communities which now have none. We would respectfully urge that section 21 be amended by striking out from page 45, lines 21 and 22, the clause:"If such establishment and operation are at the time permitted to State banks by the law -.ti-u-e-stion.” o-f the- Sta .- te•- in • • I. • • • er-40, cr Charles F. Zimmerman, Pres., First Nat. Bk. of Huntingdon, Pa. Hearings — S. 4115 March 1932 The particuiar clause which arouses my interest, and I might say, amazement, being a country banker in the State of Pennsylvania, which represents approximately one-tenth of the banking resources of the United States, is the section that has to do with branch banking. In connection with my remarks on that section I should like to say that the bane of our banking system as we have seen it develop during that last six or seven years can be predicated upon the word "promotion." If we had not been given to bank promotion in this country as we had, there would not be so much difficulty in respect to banking, nor would there be so much perplexity facing those who wish to straighten out these difficulties. More than that, the burden of the promotional side of banking, as I have viewed it, has fallen tremendously upon the country banker, so much so that his interests have been assailed on every hand, his position as an economic factor has been belittled; and now it seems that those who have scrambled the eggs of what we have heretofore considered sound banking and sound banking methods, are asking to be defended by new legislation rather than reckoned with in respect to the restoration of those • • 1 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis / methods which have been time tested during our entire previous history. I come here without any prejudice in respect to the specific questions hinging upon the development of a certain branch, group, or chain types of banking. I do come here feeling that it is a mistake that Congress should in any way seek to cater to what I choose to call the go-getter spirit in bank promotion, and that we ought to the best of our ability, right about face in respect to the reestablishment of unit banking so far as that may be done. I have listened to the remarks that have been made before this committee by those who have, on their own initiative and, perhaps, in violation of the more conservative standards in banking, gone ahead and built up these banking structures. I have been impressed with this fact, that they have not been bankers in essence or to the extent which would disallow ihe injection of other than high banking ideals in our banking system. Thor now seek to hold the ground gained through the sacrifice of those standards and wish to have it beconie part and parcel of our thought about Federal legislation. To that extent that we yield, it seems to me, more and more we are going to be led into a maze of difficulty from which we might all seek to be relieved in time to ccane. I have read the hearings that have been held by the Senate subcommittee in respect to the suggestions to be embodied in the Glass bill, and I could not help but feel that very, very little attention was paid to the viewpoint of those who have ardently sought to preserve the best standards in the conduct of he business of banking. With regard to this question of State's rights, I am simply stounded to think that Congress would seriously consider the proposal to grant the right for a national bank to cross State lines in so-called trade areas. I am at a loss to know where any substantial demand of that sort should arise so far as the practical administration of banking is concerned and so far as the service of banking to its constituency is concerned, except as it relates -tUelf to the pro::. ." -Olioniii idea in bankiiig. Now,I lia,Ve not- a- wide experience. I qi have a wide acquainiiinceship with many bankers, not only throughout the State of Pennsylvania but, I should say, throughout the Nation, and I am at a loss to discover where any economic need exists for the Federal Government to grant any branch banking privilege which contravenes the autonomy of our State banking laws_ 1 j I WM& Charles F. Zimmerman — Page 2 March 1952 Senator GLASS. Mr. Zimmerman, I suppose, of course, you have read the report of the Comptroller of the Currency on that program? Mr. ZIMMERMAN. I have read all of them. Senator GLAss. You will have noted there that he does not want to confine us to state-wide branch banking, and he does not want to confine us to Federa,1 reserve zones. He wants us to have branch banking in what he indefinitely defines as trade area..s. Mr. ZIMMERMAN. Senator Glass,I try to be open-minded on these luestions, but I am just as far—after all of my reading and investigation, from believing that proper ground has been established by the Comptroller of the Currency in his various arguments or by any other agency interested in that question—as I have ever laten. 1 NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS • • 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 307 Senator GLASS. Would you advocate state-wide branch banking by national banks in those States that are permitted to have State banks? Mr. ZIMMERMAN. I am a believer in the equalization of the rights and prerogatives of national banks with State banking systems no matter what they may be. Senator GLASS. But you would oppose giving the right to national banks to have branches in States which do not permit branch banking in the State system? Mr. ZIMMERMAN. Unquestionably. Senator GLASS. I may say to you, as to your suggested opposition to crossing State lines, if you will read the bill you will note that that may be done only in extraordinary circumstances. The case is cited to the coinmittee of banks located in cities, that there are very few of them in this country that cross State lines, and to banks located so near the border as that their main business may be across the border. So it is not the thought of the committee that that provision of the bill would be very largely availed of. The text of the bill is that it may be done only in extraordinary circumstances. Mr. ZIMMERMAN. Senator, the provisions in the bill inay be harmless enough, but its significance only comes out in respect to what results from its application. I have a very clear idea as to what would happen with respect to Pennsylvania if such a privilege were to be granted. For instance--not that I think it is even remotely thought of by any bank—in Philadelphia there would have to be . necessarily some compensating privilege granted to the State institution, otherwise, the natural inclination, if there were at least any rivalry between two of the leading institutions in the city, would be to leave the State system, and go into the national system. But the compensating advantage would probably be along the lines of extending branch banking and weakening the regulation of the State bank. That is where I feel the danger lies. Now, we are talking in terms in this country of strengthening administrative practices of banks and the supervisory processes as between the State and national systems. The only basis on which they can be properly coordinated is the common basis on which they operate. To whatever extent through Federal law you draw a distinction between that parity, you ruin the highest standards, it seems to me, that those of us who try to think sanely on banking questions, have, namely the coordination more and more of the two types of systems and the eventual bringing about of conditions which will induce every State chartered institution, to become a member of the Federal reserve system. -r Charles F. Zimmerman — Page 3 March 1932 Senator GLASS. Does Pennsylv'ania permit branch banking at all? Mr. ZIMMERMAN. Oh, no; not beyond city limits. Senator GLASS. Then how could this bill affect you? Mr. ZIMMERMAN. In respect to a possible extension of the right of a Philadelphia bank to establish a branch in New Jersey. Senator GLASS. Do you think that is very likely under the terms of this bill? What would be the extraordinary circumstances? Mr. ZIMMERMAN. I fully gra,sp the significance of your thought; but, Senator, if the experience of recent years have taught us anything, it is that through concentration of banking capital the weight of influence possessed by large banks inevitably brings concussions • 1 308 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis NATIONAL AND FEDERAL RESERVE BANKING SYSTEMS and, perhaps, abuses that never were originally thought of when the law was drafted, And so I think if we have learned. anything we must get away from the appearance of evil in respect to the extension of the branch banking privilege, Senator GLAss. Yes, That has been 'startlingly illustrated in the 15-day provision of the Federal reserve act. Mr. ZIMMERMAN. Quite so. Senator GLASS. I IMISt confeSs I can not see how under the text of this bill any Philadelphia bank would be permitted to establish a branch in New Jersey. . Mr. ZIMMERMAN. I think the right is certainly conceded if the pressure were sufficiently strong to persuade the Federal Reserve Board that it was an extraordinary case. The CHAIRMAN. III other words, it could only be done by the Bank of the State of New Jersey that has made you feel the need of such an extension? Mr. ZIMMERMAN. I have no such thought. Senator GLASS. St ould e not it be done? Mr. ZIMMERMAN. The branch-banking privilege accorded a national bank should . upon a parity with that accorded to the \ State bank, without a single exception or deviation of any kind. 1 Charles F. Zimmerman — Page 4 March 1932 • 1 • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator BROOK HART. 1 was considerably impressed with what you said about this promotion proposition of banking. Did the comptroller and his examiners examining the national banks in Pennsylvania approve investments in listed bonds on the stock exchange? Did he approve that kind of investment as liquid assets? Mr. ZIMMERMAN. 011, yes. I have no thought that in any singlel institution in Pennsylvania the comptroller would have taken strong exception to the method of conducting the bank except in so far as it might ha.ve invested in weak assets. In other words, the finer details of banking, as I think of them, have characterized every banking institution, Now, if you make mistakes Senator BROOKHART. He might describe those bonds as secondary' reserves and recommend them as strongly, as that. Mr. ZIMMERMAN. Oh, yes; there has been a good deal of that; but I would not attribute tO the comptroller's office any supposed management of a local bank through the recommendation of particular types of securities. Senator BROOKHART. Has not that system of banking made the little country banks sustain these big New York promotions all the time? Mr. ZIMMERMAN. I have not a great deal of understanding of the effect of that, intimately -within banks, but my discussion with bankers, unit bankers particularly in Pennsylvania, leads me to believe that many of their securities were bought for the purpose of secondary reserves due to their confidence in the big bank responsible for•issuing them. Senator IiitooKHART. In other words, they greatly depreciated those same securities? Mr. ZIMMERMAN. That is quite true. Senator BROOKHART. And I find in the West that the banks were every:where loaded up with those stock-exchange securities and now they are frozen up worse than the farmers' loans were preceding them. Senator BROOKHART. Yes, I agree with you; internationally; and the comptroller, who used every opportunity he had to put out statements for branch banking, was the same comptroller who loaded up these banks with these securities all over the country, is he not? Mr. ZIMMERMAN. I shall not admit that he loaded them up, Senator. I do not know anything about his official policies or actions. Senator BROOKHART. You know, his bank examiners said that was good banking, to buy those securities. Mr. ZIMMERMAN. I do not think any of them ever said it to me in our bank, but they may have elsewhere. I should like to offer this as a closing thought in respect to branch banking: I feel that ranch banking in that clause is a the mere mention of sta_. - • unit banking I do not feel threat mnrp,ArJess_ta the futurA, its case in America. I has proved banking branch state-wide that , v believe I could produce--The CHAIRMAN. And it will take several years to find out? Mr. ZIMMERMAN. Quite so. And I believe I could produce evidence that would be corroborative of that viewpoint, which I would not care to do; but the mere mention of state-wide branch banking as though it were an ideal for the national bank system, is uncalled for. If that whole clause were amended simply to say in respect to branch banking, as was pronounced in the resolution adopted by the American Bankers' Association, that the autonolny of State should be upheld,_I fee .that (,)Q,Ugrekas EaR answered ban tiun_ so far as tlieileed —foureserving the soundness of ranch banking methods in Ainerica -is concerned. I see no reasQn re—depart from it, Seilittcir. Charles F. Zimmerman — Page 5 March 1932 1 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Senator GLASS. Suppose we were to omit from that provision the authorization with respect to crossing the State line in unusual circumstances. What would be the objection to the provision then ? Mr. ZIMMERMAN. I think there is no inherent objection except the one that I have in my mind as to the inference that state-wide branch banking in itself is a tested system and that national banks are ready to go along in any State that might think it was right. Senator GLAss. Well, do you not think national banks should be permitted to go along in any State that authorizes State banks to have branches ? Mr. ZIMMER3IAN. I do. Now, Senator, you realize, perhaps, very much more than I do, that the mere mention of a type of banking in a bill oftentimes results in the layman getting the wrong idea about the whole thing. I think we need to avoid even the appearance of danger if we can do it satisfactorily by the wording of the clause. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis T. F. T. O'Connor, Comptroller of the Currency; Accompanied by F. G. Awalt, Deputr Comptroller of the Currency Hearings — H. R. 5357 21/41.4/9dv— ---IVI—rThRowx.of Michigan, Now-,the final subject that I have is the question of small'branch banks. I -am speaking for the smaller communities. A great. many of them have been deprived of banking facilities by reason of the dosing of something around one-half of i the banks, and I have the feeling that to reorganize banks in towns of from 800 to 2,000 in population is not for the best interests of the business public. In several States, and the State that I have in mind principally is the State of Wisconsin, provision has been made by State law for the establishment of what they call "receiving and paying stations", where a banking business consisting solely of the receiving of deposits and the, paying out of the deposits is carried on in offices located in those small communities, controlled by banks in larger nearby towns. I think that the Wisconsin statute confines the establishment of such offices to the comity in which the parent bank is located, and I think one State law provides a radius of 30 miles from the home office. Most of those communities had banking service before the collapse, and. it seems to ine that we ought to liberalize the law .to permit the establishment of Aations of that character. with also the authority to receive applications for loans in such banks, both for the purpose of convenience to the public in those communities, and to prevent. the establishment of a. larger number. of .banks with very small. capital. , The collapse that we had largely originated in smaller places. and if we could prevent the .establishment of banks in those smaller places by giving such service, it seems to me that it would be a wise thing. To show you how chary the legislature seemed to be, in the State of Wisconsin, they limited the effect of that law to a period of about 2 years from the time when it was enacted. It expires on July 1, 1935. My attention has been called to a statute somewhat similar in the State of New Jersey. I happen to live in a section of 'Michigan largely given over to the resort business, the island of Mackinac. It had a State bank. It was inadequately capitalized, and it fell down. That communitv has for 9 months of the year, a population of 450 people. For 3 months of the year, in the summertime, it has from 10,000 to 20,000 people. It ought to have banking facilities during that period of time, but you cannot set up a bank there that could make any money, but a branch bank of a national or State bank could be established there for that period, a branch office and business could be conducted that would be reasonably satisfactory for the needs of the people. I discussed it with the chairman of the committee, and I have discussed it with Mr. Goldsborough and some of the other members of the committee, and I would just like to have the reaction of vour Department to such a set-up. Mr. GOLDSBOROUGH. You did not mean to indicate that I approved such a set-up? Mr. BROWN of Michigan. No: I did not say so. I said that I discussed it with you. Mr. DIRIESEN. Do you have in mind a currency exchange, rather than a bank? Mr. BROWN of Michigan. A receiving and paying station. Mr. DnutsEN. There is nothing to prevent anybody from setting up a place to change money. and to do anything except to accept deposits. Mr. BROWN of Michigan. Ye.s: there is. Mr. DIRKSEN. I mean so far as the ordinary medium of exchange in a community is concerned.. I have been through some Of those resort areas in your State, and this is purely a private notion on my part, but it seems to ine that most any one of those chain stores in a little town can fit itself up with a little booth, with some wire netting, and make exchanges there, for you do not need any banking facilities in the ordinary accepted sense of a commercial bank. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis I J.F.T.O'Connor, Comptroller of the Currency; Accompanied by F. G. Awalt, Deputy Comptroller of the Currency -Page 2 • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. BROWN of Michigan. I think that I agree with your philosophy regarding the encouragement of small-town life. I think that there is a need for the kind of legislation that I have proposed here. There are a great many communities having a population from 800 to 1,000, and that, in my judgment, is about the right limitation as to size, where there is not sufficient capital for the establishment of a bank, and yet they ought to have some banking facilities, and I think that the only reason that we have not had them is because of the fear of a great many Congressmen that we would be encouraging the branch-banking business. But it does seem to me that we would be supplying a ne,cessary need, and at the same time be doing what I know your Department thinks should be done, that is, the establishment of banks in communities that are two small to support them with sufficient and adequate capital. As I said, it seems to me that there is need for that kind of legislation, with proper limitations, and I have read a good many of them to you, particularly having in mind that there would be no discouragement to the establishment of a bank if the community is big enough to need one. Mr. FoRD. Is there not another factor in there, Mr. Brown? We will take a community such as you de„scribe. There are a great inany objections that we hear to branch banking, but what is the objection, in a case of that kind, to a strong bank, with a number of branches, that is willing to put a branch in there and to possibly go along at cost for 2 or 3 years, on the assuniption that the banking facilities being afforded to that community will develop the coinAnunity and will bring it up to a point where it will be profitable to, have a bank there. Mr. O'CoNNoR. Mr. Ford, you, of course, have stated the general principle underlying the licensing of a branch wherever we are• permitted to do it, and those are the questions that are investigated and determined before we license the bank. MI'. FORD. Surely, but it seems to me that if a bank with branches goes into a community and finds that there is not enough business there to warrant a bank, but if that institution is willing to go im 1 . there and probably for 3 or 4 years not make their expenses, or just barely make them, and by so doing they will attract enough. business there ultimately to make a branch bank profitable, where a small bank could not afford it or the community could not afford to organize a bank, but the branch bank can give all of the facilities. that a banking institution could afford such a town, they ought to be permitted to do it. M1'. DIRKSEN. You advocate branch banking, I take it ? r. FORD. I do, yes. I think that it is a good thing. Mr. DIRKsEic. I might just as well state my objection rig-ht now ag wen as any other time. I am absolutely and unequivocally averse' to vesting the control of the,se little communities in some group or agency that may be 300, 400, or 500 miles away. Mr. FORD. I do not think that I would let it go that far. The CHAIRMAN. Who is going to say how far it should go? MI'. DIRKSEN. That is right. The CHAIRMAN. Branch banking is either a good thing or a bad thing. If it is a good thing, we ought to say so, and enact it into, law, and let the Federal Reserve System adopt the' best plan for the banking business. If it is vicious, and wrong, and monopolistic,. un-American, and destructive of community life and financial inde- I pendence, we ought to repudiate it, and never allow it to be extended in the United States. We ought to take one position or the othe,r. Of course I have a. very definite view about it myself. S. F. T. O'Connor and F. G. Await Page 3 2N,Ax.e/q3,1" -v • • https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Mr. Bil()\\ N of Michigan. Of course, we have. a good deal of branch banking now, Mr. Chairman. The CHAIRMAN. I know we have, and we are going to have.moreThis is just a repetition of the discussion that we had a long time ago. ()f course, we start with a county, and then as soon as the necessity arises, we extend it beyond the county line.. and after awhile the bridle is off. We have adopted the, policy of letting the States decide whether branch banking is or. is not a good thing for this country, because we have said that we will permit the, establishment of branches by national banks in any State where the legislature of that State decides that branch banking is a good thing. ()f course, while I am not one of them, there are a great many people who take the position that there is not very much intelligence. in the State legislatures with reference to banking or anything else, but we are on record as committing this country to whatever poUcy may be determined upon by the legislature of each particular Statui'ar as branch banking is concerned. I luny be not without shame entirely for having taken that attitude, ,,but it never represented a view of mine. or any desire of mine. Mr. GOLDSBOROUGH. I want to say- that I fought the thing, as far as I could, but I did succeed in keeping Maryland out of the picture, and that is as far as I could get. Mr. CROSS. As far as I see, the branch bank in a little while would . be such that every State could dictate to it,s legislature, through them, and it would spread all over the country, and everybody could dictate to Congress. Mr. HANCOCK. If it were confined to county lines, there would be no serious objection to it, would there, Mr. Chairman'? The CHAIRMAN. There is no way in the world to confine it. That is the history of it. If it is a good thing it ought not to be confined. Mr. GOLDSBOROUGH. I remember the time when there was only one bank in my county, and you had to take off your shoes and carry in in a: petition to get a loan, not a promissory note but a petition. Mr. Form. You have to do that now. Mr. GOLDSBOROUGH. Since we have seven banks there now we have a very much better situation, more democracy in our banking, and in our community life. Mr. FORD. You paid a big price for it. Mr. GOLDSBOROUGH. You cannot pay too much of a price for it. • Mr. FORD. Yes,. you can. Mr. BROWN of Michigan. Let me say, I have been in opposition to general branch banking, and I so voted heretofore, but I do not like an attitude which blindly shuts out consideration of a meritorious proposition. It will, I think, prevent the establishment of a number of under-capitalized State banks. The proposition puts proper limitations around the establishment of these so-called "receiving stations." It would be a good thing, and I am going to do my utmost to bring it about. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - CROSS—REFERENCE SHEETS f; 0:1, 9 i-OLDER waras Better folders for better files 306S Send your Order to the nearcst "Y and E" Repreentatives cr to our Home Office YAWMAN AND 71'77,1t, mr.G. Vaia Factories :oz! Executive Of1;.1.15 ROCHESTER, ?C.V.. Eranches and Agents in all Principal Cities CROSS REFERENCE FILE NO. 12B SUBJECT: "Du Bois, Hollister, Independents, Visit Washington AMERICAN BANKER, December 13, 1937 Chiefs" SEE FILE NO. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7A https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12, CRuSS REFETiENCE , ,SAYS ALL A. B. A. Nut PLEDGED Tu SUPPuRT UNIT BANKING' ' American Banker, uct. 15, 1937 See File # 7 oPPoSE CHANGES IN CLAIPTRuLum,s PuitERSn https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 CROSS REFERBNCE "ECCLES MOLD GIVE F. R. BUARD FINAL AUTHLRITY ALL B_LNKS" American Banker, Nov. 6, 1937 See File # 7 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 CEuSS REFERENCE "SAYS PATMAN BILL CUNTAINS DANG0:1 FuE UNIT BANKEES" American Banker, Nov. 18, 1937 See File 12 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 CRuSS REFhTENCE "ADAMS 'ti,IILD MAKE PUBLIC CuNSCIroUS American Banker, See File # 7 U. S. DEFICIT" 15, 1937 If https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ee da-7-6/fe, /,),7 /elee?.#7 File /I 12 CROrS REFERENCE REPORT OF THE RESEARCH COMMITTEE, Indiana Bankers AFSOC. 19F7. See File 7'./ 7 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • CROSS FILE NO. SUEXECT: SEE FTLE https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis REFERENCE 12B "Brookings Report Would Give FDIC Power to Permit Branch AMERICAN BANKER, August 18, 1937 Banking" NO. #9A • CROSS FILE NO. REFERENCE 12B SUBJECT: "FDIC Urges Branch Extension Be Based on Capital Demands" AMERICAN BANKER, July 21, 1937 SEE FILE NO. #7A https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis L • CROSS REFERENCE File " Y;.B.A. HITS YCADOO BILLS, U.S. CONTROL OF RESERVE BANKS" American Banker, June 24, 1937 See File # 7 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 • CROSS REFERENCE File # 12 "PRESS NATIONAL ORGANIZATION TO DEFEND UNIT BANKS" ArERICAN BANKER, June 25, 1937 See File No. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7 • SIMMINIX FILL. No. SUBIIIC'h Wow tor las Creitare Mama alt lb* hem Ile filareari Banitan, Ansatatleas *Jawlas Iffitkie Paces tbe Patism18 au nu se• https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 B Nay 114 1917. elawart, • CROSS REFI.ENCE FILE NO. SUBJECT: "News from the Viewpoint of the Nation's Capital" AMERICAN BANKER, June 7, 1937 SEE FILE NO. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7A 12B FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. 12 "JERSEY SURVEY corrissim TO AVOID NATIONAL RESEARCH PLAT:" Subject Americpn Banker, May 22, 1937 SEE # 2 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis O. 8. 00V . .. . 111117 • FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. Subject "OVL,R 100 HOUSE FETTERS BACK PATEEL PLA. ON 12 F. R. BANKS" American Banker, April 17, 1937 SEE File No. 7ile 7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 t/ E. OOVERNMENr rnistIno OFFICE' Itrat • FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. Subject "Supervisors Plan Close Watch on Congress" Dr. Luther Harr AMERICA BANKET, December 23, 1936 SEE File No. 9 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. R. 00V.. MM Nr1.111141,10 OFF1Ct: 1921 FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. "Branch Banking and Credit Control" Subject Journal of Commerde, American Banker, Dec.29,1936 SEE File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis V 011V.. ..Nr TIIINTINO orrice. let, FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. Subject "Oklahoma Chief Would Liberalize Loan Powers" H.C.Johnson will urge legislation putting State banks on par with nationals. American Banker,Dec.30,1936 SEE File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U R. 00V RR N KK Nr PRINTINO OFFICL: MV 12 • FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No..42 Subject Clipping from American Banker, January 72 1937 entitled "White Asks Revision of N. Y. Banking Law" SEE File No. #7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. S. GOVIIIINNINT PRINTING OVIPICR: 1911 • FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET 11=•11=MINIIMINI File No. "Keep Yourself, Public and Washington Officials Informed" By U. V. Wilcox Subject American Banker, Nov, 21, 1936 SEE File No. # Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis V. IN onvinmir.r PRINTING • FEDERAL RESERVE BOARD Form 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. StibjeCt "Zimmerman Attacks Research Program" American Banker Nov.16, 1936 SEE File No. Letter o Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. S. °ovum.),/IMMO OrTIC.: 12 • FEDERAL RESERVE BOARD Form. 156 THE FEDERAL RESERVE BOARD CROSS REFERENCE SHEET File No. #1pB Subject Clippj.ng from AMERICAN BANKER, November 7, 1936, entitled "Economists Plan Conference to Frame Legislation" SEE File No. #7A Letter o Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. R 00V RR R PRINTING orrice: int • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. 12 StibjeCrt Clippi,ng from AMERICAN BANKER, September 142 19362 "Independent Bankers' Resolutions Call for Delegation to A. B. A. Convention, Cut in Postal Savings Rate, FDIC Change SEE File No. #7A. Letter of Dated Remarks https://fraser.stlouisfed.org ha. Federal Reserve Bank of St. Louis e. arreeptimrr PRINTING orrice. 1933 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. #12 StibjeCrt Clipping from C & F Chronicle--ABA Cony.--Nov. 17, 1934, "What the Country Wantsu by Clinton B. Axford, Editor American Banker, N. Y. C. SEE File No. #8A Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t B. ramp.oreux 1933 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Statement for the Systan Committee on Legimintivo_Program October 16, 1934 SEE File No. Study # 7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. s. ooviganiurNT ritivrtwo orrtcr: 1933 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Three letters between E. A. Goldenweiser, Geo. J. Schaller and A. A. Elsesser November 1934 re Bank Supervision SEE File No. Study # 8 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis _LL 713RNI1E11.9 PRINTING 09910E: 1933 U. 3. (10, 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Confidential Report NO. 2 *Special Committee on Proposed Revision of Federal Banking Laws* American Bilnkers Assoc. SEE Study # 16 File No._ Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. e. oovicemmerrr riterm(o °FRCP: 1033 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. qnutes of the meeting of the Svstem Committee Subjecf rra-s-h-i-n-gton,---1).---C-"---S-apt-.---6---an-d--7, SEE Study # 7 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis V. S. OOTIRNMENT PITNIING OPTIOlt: 1033 178151 12 on the Recovery Progrrn THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Trytik-tiire- PP-ogrInt tor Retorip- -of--Beilkin-g--Systent io/5.54 SEE File No. , Letter of Dated Remarks IL https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ••• oorenxidswf rammfo orncr: 1933 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Letter to Dr, Goldenweimor from Ira Clark of th.; Fed,ReE, Bk. of sw. L. ..,otOor 251, .- uggestions on bsnking rearm SEE Study i File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. oorranwner uarmaa °mar: loss 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject SEE Supplementary Proposal for Banking Legislation a:1d for changes in Adniiiiistration of- E)dsting -Law. Sti)dy #2 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 o. 00VIRMIECT riummto orncr. um 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. _ Subject "Should America Adopt a Unified Banking Systum"? The "Dual" System vs. the "Unified" System The Branch Banking Controversy Guaranty of Bank Deposits Divorce of AffiIiaies Pro and Con SEE Study # 7 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. oovinprimrr ranrrnro °mar los3 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject art:tr usq. rsaB aura, tub SEE File No. ,1.3A Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u.. aoymaxrcrcr raven.orno. ion 178151 Wore t5r Callas (Chi, irri THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. _ Subject it(Imuld America Adopt a Unified 7 kino, Systomn The "Dual' System vs. t'lq IThifiedi' System The Branch Brking Controv9rsy Guaranty of Bank Deposits Divorce or Affiliates Pro and Con SEE # File No. Letter of Dated Remarks https://fraser.stlouisfed.org k Federal Reserve Bank of St. Louis o. e. 00•11RNIIITIT reivrrno orrice: 1933 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject The Future of Independent Banking by Mr. Geo. V. McLaughlin President;The- Brooklyn'Tr. Go. May 1934 SEE File No. Study # 15 A Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ir v. vovvivivver rancrnee omer: I.33 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Clipping from The Bankers Magazine, June 1935 "Strangulation of Small Banks" SEE File No. #8A Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. e. oovseewewr 11113111310 OTFICZ: 1933 178151 12 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. SlitkieCrt Clawkinga_fx_aa_taatinany_af_a.___a„aach4__Eugane_aay_an"I---__Rala, and Allan Pope on S. 4115 SEE File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 u. s. oontimmurr pRurrnro °mac: 1933 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Meeting held Present: ct, ber 4, 1934 Messrs. Stark, Williams, Kr-st and Eddy Taken fr m file 'f C mmittee -n Legislative Pr-gram-Stark File (fc11 wing discussicn of unified banking) SEE File No. Study #7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. 5. 00VIIINMENT PRIMP.°Meg: 1933 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Irra Publisher Urges Retentin State_Banks" American Banker, May 10, 1933 Cliffc.rd DePuy SEE and_Walt2r Wyatt. Study # 8 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 mom THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Glass and Meyer W'rk to Create Unified Banking" American Banker, ictnber 18, 193 SEE Study # 7 File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. e. oorzenerprr renrrnio orncr. ins 178151 12 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Hecht Tells Part 15 Meet S. Benking la on Way Up" Yune 2.?, 1936 SEE File No. Study 15 Letter o Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u s. ceovinoturrrr rnirrnivo orncs. 1933 178151 Paris, Francs, THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject azarkin===trigivisir-Ite -4--Osphart. SEE File No. rticii #10 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. oeveniterwr rim/Tree orrice: 1933 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Porposal2 l'cr• C 'lePrZM -* Prom file of Neu ea Legislative PrOrAllat SEE File No. study 1Pr D Letter of Dated https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. ooyeamminrr piturrma orricr: Imo 178151 19re Octk THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Clip_pi ng _B.e_2_ut not, given (Library clipping) Re SEE File No. 7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis u. ooveRxmaicr rErNrrna cones: 1933 178151 12 aria -naw-s-pa-1)e-r THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Banking Developments in New York State2 192,7-1K4" Commission for Study of the Banking Structure, N. Y. St. Bkors. Asso. SEE File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 e. 00111RNMENT pairTmo orner: 1933 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Three Seasonal June 18, 1936 encies Open Under Bank Act - Article American Banker SEE File No. Study j6 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 u. 5. oovsturvemr ?Rum.ornce: loss 178131 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. rIIemorandum to Dr. John villiams from George Eddy, on the subject of "Banking Reform" Stilkieet SEE File No. Study #7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis U. S. GOVILRNMUTYT rarriTmo OFFIC.: 30 178151 ept. 19, 19Mi • 6-3-36 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Natiol,a1 versus State Banks by Ray B. The Anna1:7,1 January 19-34 SEE File No. study #7 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis v s. ooTrummENT PRTNTING orricz 1933 178151 csterfield • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject Excerpt from Report on Banks of Deposit t Discount, etc. "Branch Banking" N. Y. 1934 SEE File No. Stucly #9 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 u ooyeemerwr PR 11,1110 orrice. iges 178151 THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. Subject "Gephart cites four low rate factora", Indianapolis, Ind. Indiana Bankers Assoc. convention, May 21 SEE File No. Study 8 Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 12 U. 13 00,337,11131YT raurrnro oilier: 1933 178151 • THE FEDERAL RESERVE BOARD CROSS-REFERENCE SHEET File No. 12, Subject Excerpts from addre_ss by_ ROD, Jo_seph_A. oke_ri_cic_ Savings Banks Association of State of New York, Oct. 18-19, 1934, from Association News Bulletin SEE File No. Letter of Dated Remarks https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis v. is. aoyzwimcwr rRrcnwo orrics: 1933 178151 AILZAllil TIME ?XL 12J3 1--TEXTT: "Wilcox Cites Need for Unit Banking Front in Washington" AMERICAN BANKER, September 20, 1937 sn MX NO'. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 9A AILIAllil FM* summ #12B "The Challenge of Monopoly to Independence in Credit and Banking" by Wright Patman AMERICAN BANKER, August 25, 1937 SEE FILE W. 7A https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis CROSS REFERENCE FILE NO. 12B FUEJECT: "Thomas Complains Bankers Don't Respond" -- Washington, D. C. Banking Angles in the News at the Nation's Capital AMERICAN BANKER, August 12, 1937 SZE FEU NO. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 7A .1.7).LLIZL1.141 FILE TX). FM:13-2CT: "Harr Calls upon Bankers -to Conserve Democracy" AMERICAN BANKER, July 16, 1937 SD WIZ AO, 9A https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis , https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SPEECHES EMPIRE FOLDER Better folders .for better files 306S Send you:. Ci- lcr tho nearest "Y and E" Representatives or to our Home Office YANCtIFIAN AND ERPT, MFG.0. Main Factories and Executive Mins ROCHESTER, N. Y. Eranches and Agents in all Principal Cities 12 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis MISCELLANEOUS EMPIRE FOLDER Better folders for better files 306 •.1 Send your Order to the nearest "Y and E" RepresentativeS or to our Horne Office IAWMAN AND ERBE MFG.O. Main Factories end Executive Maas ROCHESTER, N. Y. Branches and Ai-,ren13 in all iriw7p-1 CL:.3 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis EXCERPTS EMPIRE FOLDER Better folders for better files 3063 Send your Order to t17,2 nearest "Y and E" Representatives or tJ our fionic Office. -YAWP1AN AND FRBE MFG.0. Factories and Executive Ogices ROCHESTER, N. Y. Branches and Agents in all Principal Citics • 1 SOURCE: NORTHWESTERN BANKER---JULY 1956 NEWS AND VIEWS OF THE BANKING WORLD--by Clifford DePuy Page 10 W. S. ELLIOTT, vice president of the Bank of Canton, Canton, Georgia, gave a very effective address aoinst branch banking recently and pointed out that the country was built by unit banks and that objections to branch banking consisted of centralization and control of credit, which was bad and also, that there-ias a danger of political control under a branch banking system. "Unit banking", he said, "was the traditional system of this country because it furnished local capital, local knowledge and local management of conditions which was a decided asset." he also pointed out that 17 branch bank systems had failed with 136 branches during the depression and that they had deposits of 41,611,000,000 which was one-half of all the deposits of all the bank hich closed during this period. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: NORTHWESTERN BANKER—JULY 1956 Page 53 "FRANK WARNER AND BRANCH BANKING"---Fred Figge, Pres. Ossian State Bank The following remarks concerning the part Frank Warner, secretary of the Iowa Bankers Association, had in fighting branch banking at the New Orleans convention of the A.B.A. were made by Fred Figge before the state convention last month: "The matter of unit banks has been mentioned at this convention. I want to bring before you the facts concerning the fight which was had at New Orleans to save the individual banks against branch banking. You all know that there was a fight. That fight was not only brought about by men high in government positions, but also by some of the larger banks. "At New Orleans the fight between the two candidates for second vice president of the A.B.A. seemed to center around this one point of branch banking. The candidate for the independent bankers had virtually given up; as one who was there told me, they had all crawled under the table, they felt whipped. Frank Warner, our secretary, in his quiet and unassuming way, gathered together the boys who had lost courage and at a little luncheon discussed the matter and one by one he brought out his plans, and before that luncheon was over the entire stage was set with the result the candidate representing branch banking withdrew his candidacy and Orval Adams was elected. "Now, Mr. Adams can't do everything alone. That fight at New Orleans would have been entirely lost had it not been for Frank Warner. You all received the advertisement of the Bank of America, California. On one side is the picture of a traveler's check. L'n the other side was the picture of the state of California. There is a line drawn from every town to the outside, showing which points are under the dominance of that bank and under the CONTROL OF ONE MAN. Do we want that system? It will flood our state and every other state if we do not fight it now. "It is needless for me to go back to the records and show what Frank Warner has done to prevent branch banking." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis source; northwestern banker---July 1936 IOWA CONVENTION RESOLUTIONS Page 54 * * * * * ** ** ** (/ We recommend that Iowa banks as they may deem it advisable, establish bank "offices" in communities which are now in need of bEinking facilities. / https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ***** *** * • Z, Ixcerpt from nonsreadum to the Beard by Or. Hommemd (4/30/56) em the subject of "Summery of Bank Relations Reports" attat44, toward IbILLIdWailkingOOLiciAtia The reports ineicate that the prevailing attituee ic one of friendliness. At the same ttne, the amall nonmember hanks in gener al sem te feel that membership in the System would bring no advantage? not already available to them in the correspondent relationship. Moreo ver, MOMMOM— ere *hich now derive important income from axchange charges see positive eisadvart&ges in membership. 1Naslug, swidifilega Banks Are reported os generally concerned because their income is low. In thi? connection the importance of charging excha nge where that practice prevails is all the more emphasized. Banks are also reported am increasingly interested in F. N. A. loans, personal loans, ane instammmt financing, and in making service chomps. ExcernI, taginimo;te *This county (St. Lawrence County, NT% York) one in Which branch banking migbt correct sem et the problems which exist and which are apt to arise in the fttere. Tf there is my nee(' for s hank in certain of the smaller communities which mew have banks, this need could be supplied by a branch hank with Amager menagement and execu tive ability than it is peesible for an independent bank to obtain. The Ogdensburg Truat Compeer is the only institution in t'e county with capital sufficient to operate a branch banking system but its menag ement is unmilling to take over any or the smaller banks although they own an interest in three or four of the small banks and assist them banks with advice and suggestions." (N. Y. report) "Comments of the bankers in thin county (St, Lawrence) indicate that they have a very limited interest in, and understand inz of, the policies of the Federal Reserve System, and that they are primarily interested in the Federal Reserve Bank as a correspondent bank from Which they can obtain ',arise* services Cheaper and of greater efficiency than from the ordinary correspondent. Visits to these boas usually arouse a number of euestions regarding letters, circulars. and regulations received Prom F,deral which the executive officers have been unable to understand fully.' (N. report) *Attitude sd:glogoigpUmnimp Comments were entirely favor able ameng such nonmember banks (Wyoming County, New !ark) as are familiar with the policies and functions of the Federal Reserve Syste m. Reasons expressed for not joining the Federal Reserve System include the fellow'mix https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4:4- -2 a. Objections TAD 4 fmrther supervising authority in addition to the Aeccetetructim Finance Corporativn, Federe41 poAt Insueance Corporation, ane the State Banking Pepartmonte b4 Extra labor involved in furnishing reports and keeping of records. seeomnodatione, c. in the prevent -tbaence of neceptty 411 other services are rendered by correspondent banks without oost.° (N. Y. report) Cleveland report: okt the waeLing of th.oup Six of the Ohl* Bankers Association (meet central section of the stee) a reaoluttos yes adopted onpoming compelmr7 nembertohip in the Itderal Reserve System for insurod state memmemPMS8 resolntiem banks am provided in thd, linking Act of UBE. alee ereorded the dual bunking system and oppoeld agy action which bee lees taken or may be taken looking to unification of the banking ireten under federal supervision." *All of our Field Repreatntatives re?ort that, Ln conversation with member bankers, there has b.en expressed a doubt as to the good faith of the liserdts statement released in oemnection with the recent increase in reserve requirements of member beeks. The idea wee expressed that the &Olen was taken solely for the purpose of leaking mare funds available to Federal reeerve banks for the support of the government bone market. AS indicated above these comments were quite general and cone fres all sections of the district." olgenber bankers, particularly in the southweatern 'action of Ohio, are complaining of undue activity on the part of the Production Credit Corporation which la active in seking loans to farmers particularly in connection with live stock financing. In seme of the smeller manufacturing centers complaint is maee that ctty banke are taking over desirable industrial and commercial accounts at eubstantially lower ratea. The truth of tile metter appears to bn that banks in tNitt eection art still maintaining the level of interest rates prevailing in recent years despite the easy money condition." rimm qicIlmond repart: *Tn discussing membership with nonmember banks it should be remembered that there are mere than 500 nonpar banks in the Fifth Federal Reserve District, the majority of theme institutions being located in the two Carolinae. Their apparent advantage over member banks with reepect to exchange charges and more liberal regUlatiome is a pronounced factor in the consideration of membership in the System by these hanks.° https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ONO :Tram Atlanta rt7.Tort: nithout exception the reports of visite to banks+ reflect a resit.' of friendlinees toward the Federal Reserve Eyetem. The principal re's,* why the rmaller nonmember banks do not join it the importance which they attach to revenues from exchange.° From St. Louis report: "Several bankers coemented on the increase in non-par points, particularly in the State of M.ssouri, and expreesed opinion that the usefulness of the Reserve Bank was being seriovely impaired on that account.' Prom Minneapolis repcala "At vazioue group meetings of the Minnesota Bankers' Association:, the Secretary called attention to the uide difference in exchanv charges made by varies, banks awl urged then to get tegether through county associations or district aseociatiom 'or the perpoole of adopting t fair and reasonable uniform charge. 114 versed them that if they did not do so, customers would probably take some political action which might result in the elinination entirely of such charges.* From Kansas City reportt wrhe cashier of the Firet National Bank of Olathe, (Colorado), reported that he eas very much pleased with the ssr-rice rw lered b7 the Federal Reserve Bank on non cash collection items represented by the usual drafts for the shipment of produce and other like commodities out of the immediate Olathe territory, and representing a gross total of from 1750,000 to q„000,000 in 1955. He said that thie had been the source of considerable ineome to his bank.° "Of the semmember banks visited (in Nebraska) the majority are not on the par flat and their reluctanee to forego the income derived from exchange deductions is one of the rearms for their net being interested in membership. Until conditions change, vim they again have demand for Deane and enable them to offeet, in part at least, the earnings therefrom that is little or no likelihood that they will be there exchange, revenue from is a vital question noreadaye with many Rawson memberehip. interested in to do scarcely more than exist on their able are which banks of these smell few talk of liquidating, stating that the of business. volume present farmers to pay their debts, emebling While green, crop the wheat of avails banks as it sight have hem. Some the bemefits to of productive not as yes operations in debt, in sissies start next would farmers the that me told view of rhich if dreath conditions continue ever next year with anything like the severity of the last, it is difficult to see how same of these snall banks can survivel•m https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: REPORT OF H. C. TIMBERLAKE--during visit through western and southern South Dakota, July 10-40, 1956 (submitted with Mr. Peyton's letter of 7-30-36 Page 14 While all of the banks visited were FDIC members, some of them find it difficult to see any definite advantage of ouch membership. One banker said thet no one had had enough funds since 1933 to make deposit insurance necessary. Another said that FDIC mdmbership may do some good but that the necessary reports increased the amount of clerical work in the office to such an extent that he didn't know whether the benefits were worthwhile. He wagzested that the daily computation of deposits be eliminated and that FDIC name 6 (or even 12) miscellaneous dates throughout the yenr to be averavd in order to determine tl,e net deposit average for assessment purposes. South Dakota laws permit the establishment of branches under certain conditions but as yet no state banks have been authorized to establish thell. White Lake is a bankless town at present and several nearby banks are considering the establishment of a branch or moving there. Some of the stnte bankers feel that some of the examiners are too insistent on liquidation and °there who are "liquidation-minded" are surprised at Toan recommPndations that other examiners make. One banker whose loan limit is t3,300 refuaed to extent a 1,2,200 loan an 200 head of cattle for six months while the examiners were at his institution, and they told him that was the best loan on his books. The banker felt that if feed purch,lses became necessary, the loan would soon become excessive, so told his customer he would carry the balance if he would reduce to 100 head, but if not, he would have to obtain his funds elsewhere. The Saath Dakota Superintendent of Banks used the "standard call report form" for the first time for the June 30 call much to the delight of many bankers who had previously complianed at the multiplicity of reports. On the invitation of Supt. Strain, I attended a session of the Guaranty Fund Commission at Rapid City which gave me a very clear conception of thc close attention thnt is being paid to some of the weaker banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: JOURNAL OF THE CANADIAN BANKERS' ASSOCIATION--JULY 1956 "Lending Money" address by S. C. Norsworthy, Asst. General Manager, Bank of Montreal, Que., at a luncheon of the Kiwanis Club of Montreal on May 7, 1936. Page 407-408 A feature of the branch banking system which is sometimes criticized is that branch managers are required to submit for approval to a central authority all credit applications for more than a stated amount. ":;re Figures compiled some years ago by the Bank of Montreal showed that in point of number, 90% of the loans applied for were within the mbnagers' discretionary limits and could therefore be dealt with promptly. A branch manager, with the customer sitting on the other side of his desk, is under the handicap in judging a loan that he has prominently in his mind his desire not to offend his customer. Unless he is an experienced lender, this might lead him, if he had a wide discretionary power, to make advances which his own judgment would, immediately afterwards, tell him were unwise. The President of a large New York bank which had no branches once said to me, "I envy you your opportunities for training your men. An appointment as branch manager under your system of loaning limits and supervision teaches a sound banker to creep before he is called on to walk." A final argument in favour of loaning limits for branch managers is contained in an incident which occurred during the inspection of our 2exico Branch. The non-current loans contained an item, "Miss Mabel Taylor, $102.76," and this was found to represent he cheque for t100 on Los Angeles plus cost of protest for non-payment. It turned out that Miss Taylor had represented herself as a movie actress. The Inspector expressed the view that the risk should never have been taken. The manager could only reply,--"Ah, but you haven't seen Mabel!" https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis E,A3ICT: hYPOFT OF F. C. Dinlop, Auditor, coverint visits to 47 banks in So. Lak. during week of June 8, 19W--:,ubmitted by linneapoliE office of Res. Bank under date of June 19. * ***** * **** In quite v. number of the smell banks visited, the officere expressed doubt as to the future of the institution. Deposi ts are ehowing little, if any cbonge. Whet smell income the farmer obtain e from creemery deliveriee or other products soid is needed for neceeeities or to retire eeed or feec loam with Government Agencies. There iE also little borrowink-, elthough eome farmere obtained funas for purcheeing brood sows. The fermer het; had hie fill of borroeing for non-eseentiels in advance of expected crops. ihe eanks 5re mighty careful sled about making loens. In many Minnesota banks vieite a, real estate paper found favor, but it wae a rsrity to find the small bank in L'outh Lakota with more than one or two of mach loans. I si:.ould judge there were very few loene: being made under Title II of the Notion al aousing Act. It WEIS also noticeable t&,t g,roup bank membere had a much.lowr_ratio of locel loens to depoeits The ease lack of. eggressiviiiitii-wTres-PPiireiirin the group members locetea iin Southern Ainnevota. /14:14-' t /r +4. " AL , A'A°'' 44`. 5A1 / k * * * * * ** *** it ie quite evident thet talking aembership t'.2, the small South Lekota bunke at thie time wouldnot produce results. k.iarnin gs ore so poor that none woulc; coneider Ovine up_gisiAnge. :Some of-thi-siiiiIr venher-banks --wourle-selcom lypportUnity to r:dd a little exchange to their income. Formerly land sale commissione and insurance helped omt materi ally, but there is little profit from thia source et the present time. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * ** * *** * * * * SOURCE& THE FINANCIaL AGE---JUNL 1956 (Convention no.) N.Y. 6tate Bankers Association ADDRESS Of THE PRESIDENT—S. Sloan Colt Page 445 It is of intereet to note in thie connection that E hundred years ago the banking system in England was suffering from many of the came difficulties which we are facing today. In periods of depressian there were many private bank failuree which repeatedly shook the confidence of the public and led to the gradual development of pint stock banks cad the growth of branch banking. The result s are familiar to you ell. In spite of all the economic diffic ulties of England during the depression no depositor in England hae suffered the loss of a single doller from bank failurea eince in fact only teo 1,anke have failed in England since 1914, and the deposits of thoee two banks, together were leeF than L6,000,000. Iet there hae been no lack of adequate service to the English public. At the preeent time there are aver 10,000 comer ial banking °Meet; in England serving 41,000,00 people, ae contrasted with about 18,500 banking offices in the Unitec kWee serving la,000,000 people. In other words, England, which is muchTt hickly populated then this. country, has a benking office for ever;/. 4,000 people aE compared with a banking office for about every 6,900 people in the United States. If we take the thickly populated State of Mew York we have a commercial banking office for every 9,400 people. If we make ths comperivon on the baeis of area, England hte banking office for about every eix square miles, while New York State has a banking office for about every thirty-four equare milEa. lab. The banking record in Caneda hes been similer to that in EnL land. Canaealr economic problems ere eomewhet similar to those in the United Stetes, and yet in that country no depositor has lost a dollar of his deposits through bank failures since 19k!. In Caneds there is a banking office for every 5,000 people contracted with one for every 6,900 people in the United States. FOR BETTER SERVICE / I point these matters out not by way of suggesting thet we should duplicate the English or the Canadian banking system, but merely to show the type of service which it is possible for a banking eystem to render and which the public in this country mey ultimately demend. Banking is not an end in itself, it is merely an instrumentality for eervin g the public, and if the service we are nor furnishing does not prove to be satisfactory it is likely to demand romething different. Are we ingenious mouth and far-sighted enough to anticipate that demend ? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis A4,e--June 1956 S. Sloan Colt Pup 445(contd.) Legislation which hbts already been emwted permit the development of regional systems of branch,_,E that Aight serve the public effectively. If more banking offices are required in the 6tate the:, should be established not through the chertering of new banka, but rhthir b.y existing banks tt,king - ,anking within kocified districta advantage of laws wllich pe.-mit branch : of the ,..tatP. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: NOTES ON BANK VISIT TRIP OF O. S. POWELL, May 21-28, 1936 (Submitted with letter from Fed. Res. Bk. of Minneapolis, dated June 20, 1936) Page 3 Bank consolidations have occurred in two cases west of the Missouri, thus giving the remaining banks larger trade territories in the ranching country. The new management at Dupree, who formerly ran the bank at Marcus, are stated to be in favor of placing their bank on the par list and they might be interested in joining the Federal Reserve System at a later date. The independent banks are growing in deposits and loans, whereas the group banks appear to be standing still. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: Addresses at the 45d Annual Convention of N.Y. STATE Bankers Asso. June 20-22, 1936 Address of the Pres.-S. Sloan Colt. Pages 9-10 **** ** ** It is of interest to note in this connection that a hundred years ago the banking system in England was suffering from many of the same difficulties which we are facing today. In periods of depression there were many private bank failures whicn repeatedly shook the confidence of the public and led to the gradual development of joint stock banks and the growth of branch banking. The results are familiar to you all. In spite of all the economic difficulties of England during the depression no depositor in England has suffered the loss of a single dollar from bank failures since 1925. In fact, only two banks have failed in England since 1914, and the deposits of those two banks together were less than b5,000,000. Yet there has been no lack of adequate service to the English public. At the present time there are over 10,000 commercial banking offices in England serving 41,000,000 people, as contrasted about 18,500 banking offices in the United States serving 128,000,000 people. In other words, England, which is much more thickly populated than this country, has a banking office for every 4,000 people as compared with a banking office for about every 6,900 people in the United States. If we take the thickly populated State of New York we have a commercial banking office for every 9,400 people. If we make the comparison on the basis of area, England has a banking office for about every six square miles, while New York State has a banking office for about every thirty-four square miles. The banking record in Canada has been similar to that in England. Canada's economic problems are somewhat similar to those in the United States, and yet in that country no depositor has lost a dollar of his deposits through bank failures since 1923. In Canada there is a banking office for every 3,000 people contrasted witn one for every 6,900 people in the United States. I point these matters out not by way of suggesting that we should duplicate the English or the Canadian banking system, but merely to show the type of service which it is possible for a banking system to render and which the public in this country may ultimately demand. Banking is not an end in itself, it is merely an instrumentality for serving the public, and if-the seriice we are now furnishing does not prove to be satisfactory it is likely to demand something different. Are we ingenious enough and farsighted-enough to anticipate that demand? Legislation which has already been enacted permits the development of regional systems of branches that might serve the public effectively. If more banking offices are required in the State they should be established not through the chartering of new banks, but rather by existing banks taking advantage of laws which permit branch banking within specified Districts of the Statkr. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** ** * * • SOURCE: NOTES ON BANK VISIT TRIP OF O. S. POWELL, May 21-28, 1936 (Submitted with letter from Fed. Res. Bk. of Minneapolis, dated June 20, 1936) Page 3 Branch banking is practiced by one of the group banks at Aberdeen. Both the head-office officials of this small branch banking institution and the managers of the various branches seemed well satisfied with their experiment. They stated that branch banking allows bettu_Lervice tQ__1419_ community, especially in a livestock area where the loan limit to individual borrowers should be hia4er than small country banks can supply. This branch banking system Sas developed a simple form of accounting so that the traditional branch banking red tape has been cut to a minimum. They seem to rely largely on government examination of the branches instead of supplementing it by head office supervision. One independent bank near Aberdeen thinks that branch banking is inevitable but not if $50,000 of capital is required per branch. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • -- -____ ,, StFATREih Address delivered -by H. A. BrBankerr-Aeeeeilft-tien, at the annual meeting held in Kansas City, Mo., ( 'N May 5-6, 1936 - Along this same line there is another matter that bankers should be studying and thinking about. In other states and possibly in this state, the county-seat banks, or larger banks in the other towns, have been sending an employ-e to neighboring towns two or three times a week to make change, cash checks and accept deposits. While this may be nuite an accommodation to the small community without banking facilities, at the same time this practice involves many dangerous features. To me.the first danger rould be that such action might be the opening wedge for branch banking in Kansas. This is an expensive operation, and, first of all, if prficticed, should be only on a profitable basis. Then the robbery hazard is involved, the question as to which banks should operate in certain localities would enter into the plan. It is not my intention to endorse or oppose this issue at this time, but it is one of those things that vill be coming up in the near future and should receive careful study from all sides. 4 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SWIM Address of George La Harrison at 804-Annual Dinner liestings,Acedesay of Political Science, New York City, Thursday, April 2, 1956, pp. 11-12. FILE* Study apsed under the So, also, our comm8rcial banking motes which coll , safeeporded in various respects. *train of 1951, 1932, and 1935, has bee* leeks believed to be sound After the banking holiday of 1935, only these s Pere eliminated from were permitted to reopen, so that many veak bank e number of banks have since the banking structure. Furthermore, a larg r some form of national joined the P*415,44 Meeerve Symbee sea are now unde em or the Federal Deposit supervision three. the Pe/ma iseeree Syst cture of underi-capitalized benks beememee Corporation. The capital stru criptione and through the Reconbee heen restored through private subs struction Finance Corporation. still eons fundamental In spite of these steps, however, there are which, to my mind, must some day be shortcomings in our banking system ness. seises4ed if we want to avoid future meek like Topsy. Our commercial bookies oyster grew yr auch At the be- d of about 24,000 separate unit ginning of the depression it easidate ender 49 different sets of laws - the beaks all organised and operating state*. Some of thee* banks were Federal law and the lams of the 18 System but two thirds of them ogre aot. embere of the Federal Reserve superimposed upon this heterogamous Ibmo !Were' Reserve Systme vas without amy subetantial change la the peep of banking institutioes beide whoa ttiat, a "Nebo No central bankimg system ass be fate gystem. Selp shile amay Mope stitato tor a mewed eemmerelal banking be able to boast of a vholll have already beep teheek, we shell net https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2 adequate booking structure un4il such time as it may be possible to develop a more unified commercial banking opotam with greater oemsostration of both authority and responsibility. This inplies a greater uniformity of booking laws tefteem the different states, on the one hand, and betweem the states and the Federal government, on the other. It imaies greater consistency and effectiveness oe banking supervisions responsibility for which is now divided soon too many agencies. It implies the useassity of imprOving the general character of book assegsment through the development of some more liberal system of teem* benikimg within apprepriate areas. It implies Sege eatisfactory disposition et tbe boot* problem of separating the essmercial banking fnmetion from the savings banking function. The combination of these two functions in the same institution has bean one of the apparent causes of our banking troubles of the past. Lastly, it implies the ultimate necessity of brimeingell the commercial banks of the country into the Federal Reserve Systwou The precise answer to these questions difficult to determine either as to time or method. It will require thoroughgoing and thoughtful study, and perhaps a gradual solution; but wit should not rest content until the problem has boom recognised and its solution undertaken. I do not mean to imply that our banking system today endangers the economic etability of the country or the funds of its depositors. But I do mean, that it will never function to the full limit of its usefulness and satoby mail these questions are coomidered and disposed of tn some ootistiebory fashiom. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t --t (f' /Cx, WORM 2111 100110=2 ...- SWAIM of Canada Special Bevie,--London Jan, 16,1iM hirLia VII.--SAME Anr INSURANCE Trends im Oamadian Banking by Pref. J.F. Parkinson The typical Canadian bank is a ossperatively large institution, operating branches across the country amd transacting a traditionally British I/ commercial an4 deposit-banking business. Government regulation of banking in Canada is a matter of Dominion jurisdiction, so that the development of Canadian banks since Confederation hhs boom free from the problems which divided authority creates, in contrast to the situation in the United States. Canadian banks have, therefore, been able to extend their breaches across the Dominiem as fct as the frostier was pushed outwards. The nentralisation of reserves and management which a branch-banking system provides has sinplified the task of keeping assets liquid and diversified. The Bank Act proscribee a minimmn of financial strength which has effectively eliminated the possibility of amy growth of small regional banks comparable to those which grew up in the United btates in the same period. Far from proving a handicap to new communities the systen of large banks, coupled with their note-issuing powers, have enabled banks in the past to provide banking facilitiee for new coo, enmities as soon as they began to be settled. The existence of private note issues to-day appears to some people to be an anomaly. There can be little doubt, however, that this power of the chartered banks—destined for oansiderable reduction over the next fifteen years--has ehimpomed the cost of maintaining till money in remote branches. To that extant it has speeded up tke provision of hanking accommodation. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * *••* * * • QOURCE: THE ECONOMIST—Dominion of Canada Special Review—London Jan. 18, 1956 Page 49 VII.--BANKING AND INSURANCE Trends in Canadian Banking by Prof. J. F. Parkinson The consolidation movement which took place in prewar days, and to some extent after the war, has reduced the number of banks from a maximum of 41 (in 1885) to the present ten. Of these, the four largest together possess roughly 75 per cent. of the total banking assets. The business of these ten banks was carried on at 3,527 branches at the end of 1934; some 550 unprofitable branches have been closed since 1950, including several foreign agencies. Pve 51 The next move came in the spring of 1933, when the banks, not without Government encouragement, reduced the rate paid on savings deposits from 3 per cent. to 2i per cent. Until recent years the rate of interest charged by the banks on good commercial loans has been fairly rigid in good times and bad, being held constant at around 6 per cent. throughout the depression period, with rather high rates prevailing in the western provinces. The reduction in the savings deposit rates in May, 1935, constituted the first change in thirty years, and it was not until Noveuber, 1934, on the occasion of the second reduction in deposit rates, that loan rates were officially lowered. Even at that, the reduction was confined to agricultural and municipal borrowers. The pressure to reduce rates of interest paid on deposits came partly from the fall in the yield from bank investments, and partly as a result of the Government's desire to prepare the capital market for further Government borrowing. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "American Bank Failures" by C. D. Bremer (Columbia University Press, 1935) Chapter VIII, Pages 138-140 The anomalous policy forced upon the federal authorities in connection with branch banking is an outstanding example of the defects inherent in the division of authority over the country's banks. Although, as we have seen, Congress has shown no hesitation to emulating the state authorities in their promotion of unsaund and dangerous legislation, it has carefully refrained from conferring upon the national system any constructive advantages. On the other hand, state banks have been granted the right to partake of the benefits of the deposit guaranty, which, in connection with the fact the minimum requirements for a national charter have been reduced, must necessarily result in the re-establishment of many small state banks, and will enable many uneconomic banks to continue to vegetate on the communities in which they are established. Of course, the revival of the independent unit system was one of the major purposes of Representative Steagalli s Deposit Insurance bills of 1932 and 1933. It is indeed unfortunate that political expediency necessitated the elimination from the earlier Glass bills of those sections which would have permitted national banks to establish branches irrespective of the State statutes, and would have enabled a sounder reconstruction of the banking system. The fact that several states during the past few years have abandoned their exclusive unit-banking policy, while others have liberalized the existing branch banking provisions of their statutes, hardly alters the situation, because of the absurd restrictions on the establishment of branches, in most of these statutes. I It should be apparent that only by unifying legislative control over the country's banks will it be possible to carry through the necessary reconstruction and reorganization of the banking system. Abandonment of dual jurisdiction will do away with the ruinous competition between the national and state authorities which has attended banking legislation in the past, and enable the national government to adopt a uniform branch banking policy for the entire country. This will permit the orderly elimination from the banking system of the multitude of small banks which are at present, and will continue to be, a threat to the safety of the guaranty fund. By closing the loophole through which banks have been able in the past to escape from one jurisdiction, which for one reason or other was obnoxious to them, to another of more leniency, it will be possible to force all banks to adhere to one standard of operation, thus increasing the safety of the institutions. The nature of measures which should raise this standard above the level of the past years, and strengthen the internal condition of the banks, has already been indicated. The assumption that the guaranty-of-deposit plan has disposed of the problem created by the intermixture of deposit and investment banking is entirely unwarranted. On the contrary, this plan calls or closer circumscription of the sphere of operations of commercial banks, and for placing further restrictions on their security investment snd speculative operations, in order that their portfolios may not again become filled with all sorts of securities unfit to provide the bank with the necessary liquidity. If commercial banks are to be permitted to continue their https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 2 savings banking business, provision should be made for the separation of savings deposits from those arising from commercial activities. Thus the law should lay down definite rules regarding the type of investments which should be kept in the savings department. Of course, the task of preventing banks from developing an unsound or embarrassed condition looms larger than ever before among the duties of the superVisory and examining authorities. They should, therefore, be given adequate powers, and be required to make full and effective use of tbem, in order that an incipient unhealthy condition may be immediately corrected, and that uneconomic banks may be closed before they reach a state where liquidation would involve losses. These considerations emphasize the fact that a guaranty-of-deposits plan is itself no solution of the bank-failure problem. However, by combining the beneficent features of the plan with legislation equally applicable to all banks, and adherence to which is enforced by strict supervision end regular, effective examinations, it should be possible to obtain a sounder and stronger banking system, and prevent the recurrence of failure epidemics. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis M. D. Brett (Mississippi) Proceedings of the 34th Annual Convention National Association of Supervisors of State Banks Atlanta, November 1935 ********* * * * * * * * * We have had three bank mergers into larger banks, availing ourselves of the branch office law of 1934, and these banks absorb the small banks and have opened branch offices in the community wherein the smaller bank was located. * * * * * * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ****** * ** • Discussion on the Address of Mr. Crowley Proceedings of the 54th Annual Convention National Association of Supervisors of State Banks Atlanta, November 1935 * * *** * ** Mr. Hood (N. Car.): We have 84 banks with deposits of less than t250,000 with losses in operation the last year, and a discussion has been going on in certain communities to take five, six or eight banks and consolidate them in a new town, it would be the same institution and the large town would be the home office and the smaller towns tellers windows or smaller branches. Would the Corporation look favorably on that with reference to taking care of future operations? Mr. Crowley: Where the states permit that, it is going to be the practical thing for the state to do. It will permit a more central management. Mr. Hood: In other words, we have a group representing six banks with one man as cashier of one bank operating all five banks with cashiers rho are not up to the standard of ability. If these six banks make him the executive head, don't you think that is better than liquidating unprofitable banks? Mr. Crowley: No question about it, and it would be a great contribution to the banking system. We would be very glad to help such a program as that. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ** * ** **** IV Adam A. Lefor (North Dakota) Proceedings of the 34th Annual Convention National Association of Supervisors of State Banks Atlanta, November 1935 ******** * * * * * * We have no large banks, we haven't one state bank with a million dollar footing, they are all small banks and our duty now is consolidating where we_can and moving around_the banks to better centeTt- andthem a chance to make a livipg. We have taken over 175-1-6---ttrts—t-tintr—grirrrainrial banks and are vvorking on three now. We have the so-called "joint banks" -- two groups in the Twin Cities, one is called the "First Group" and the other the "Northwestern Group" and these and similar institutions are taking over the little state banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ****** ** . AAt'' • by Marion D. Brett, State Comptroller, Miss. Proceedings of the 34th Annual Convention National Association of Supervisors of State Banks Atlanta, November, 1935. Address * * ******** New Banking Offices and Mergers Besides pnrmitting branch banks with certain restrictions and limitations as to capital and territory our state law izermits banks to establish branch offices within the county of its d9miqi1e a ...stating muritret7—STEEKrAmen-Corbranch banks reauires the majority vote of the governor, attorney general, and state comptroller on the auestion of public convenience and necessity, while the establishment of branch offices, which may do everything that a bank or branch bank may do except make loans, is wholly within the discretion of the state comptroller. The law also provides as to branch banks that a branch bank may not be established in any town or city of less than 5,500 population where such town or city has one or more going banks. There have been quite a few applications from banks within the state to open branch offices within the territorial limitations allowed by law. In considerIng these applications for branch offices in cities of less than 3,500 population wherein there are banks operating, I have rejected them, feeling a responsibility to the banks and to the cublic generally justified this action because if the Comptroller Tere so inclined he could permit branch offices without number, which could do a complete barfcing business, at least impliedly under the law, except make loans, and thus bring about a very unpleasant and unwholesome situation in banking in our state. Many of these applications for branch offices are the result of certain dissatisfied ones in a particular community against a bank that does not seem to be doing things just PS they would have them do, and therefore invite competition by banks in neighboring towns, cities, and counties. My understanding of the branch office privilege is to furnish banking facilities to a community that will support such branch office with resulting profit to the main office, but which community is Ainable to raise the minimum capital required of an individual or branch bank, and in each case, aside from the question of whether or not there is already a going bank in the town or city, the test of public convenience and economic necessity is made. This branch office privilege has been the means of merging a few small banks with banks of larger size through mergers and decreased operating costs, and at the same time, if the absorbing bank desires it, may maintain a branch office in the community of the merged bank, thus affording banking facilities to the community. In the case of new banks as far as it concerns my office the test of public convenience and economic necessity is followed and showing required to be made that the proposed new bank could be operated profitably and in the case of seeking to organize a new bank in a community where there is already a bank, besides the test mentioned, it is our position that not only the proposed new bank could be operated profitably but that the organization and operation of a new bank would not jeopardize the other banks' existence. Those in authority should proceed very carefully on this matter, for I believe that we have been overbanked in the past and this has been a contributing cause to the situations we have https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • recently gone through, for it brought about a h'gh degree of competition and many unfair and unethical practices contrary to good banking and business rules. our „at4te _laws are vaplx_rlelablg_to aff2rd at least community which has had or pow wants one banking house to eve E' accommodation. seAs grid—Fa=p7o now t which never had-one For more than a -Verfrrivient. ra o"rrieThtirtint-ttrn — riErriTh-gliiMre organized. been has year no new bank https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ********* e-771 SOURCE: 327. PUBLICITY ACTIVITIES - F.R. BANK, MINNEAPOLIS Report of Deputy Governor Ziemer, attached to August 13, 1935. r. Peyton's letter of Page 2 (of the report) * * * BANKERS' ATTITUDE The two banking groups are firmly entrenched in idontana, and of the 58 banks visited, 17 of them belong to one of the two corporations. Most of the group banks are situated in the larger cities.. The banks which are affiliated with the corporations situated in the smaller communities, will be sold to local interests as soon as the corporations are able to dispose of them. The corporations feel the volume does not justify their retaining them. Competition is very keen between independent and group banks, but it is clean and no unfair practices are apparent. Some of the independent banks claim that the group banks are inclined to arbitrarily dictate the interest rate to be paid on deposits. In several instances, the independent banks have emphatically refused to reduce their interest rate to correspond with that paid by the group banks. Another common complaint is that the corporation banks give no consideration to local borrowers. Being familiar with credits, it is my personal opinion that as these banks have an abundance of money to lend, it is not their policy to refuse any v/ applicant entitled to credit. Observations of Otis R. Preston - attached to Air. Peyton's letter of August 7, 1935 Pagf 2 (of the report) ATTITUDE OF BANKERS. A peculiar situation exists in Montana in that the two banking groups are represented either one or the other, or both, in all the larger cities, including county seats. Although keen, the competition with independent banks is clean and follows conservative banking practices. These group banks, in my opinion, maintain a leveling influence on the independent banker, constantly restraining him from practices heretofore resulting to the detriment of the community. The non-member banks are not interested in the pending Banking Act of 1935. Although generally informed as to its provisions, obviously they cannot determine their future course as to Federal Reserve Bank membership until they know what will be written into the law. A number of state banks on the par list are potential members. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis cwth S. Banking Problems' by Sirs daises T. Ourtinheur„ New Tork (Joursal of the Onsatissikeame Mums, *eater, 1935)University ** * * * * * * ** In spite of the houseelemaing *Leh has tube* plume, there number of small institutions *tab hew se place in the Amerie is a large em bunking Armature exempt as bramehee of string esteepelitaa isstit etteess ?he attire benhimg situation mild be greatly beeefited by the temmies of brae& basking sit that all *isolable communities gredsal oz. selld have ede. lest* mei safe basking seretees eitheet taking the cheap that asses ghee small lead institetiess boodle the bustaesm during bed years. Pediro1 Smeermeeet ememet safely assume this berdes through the PIM /he affai rs iat the latter ere going alias very ateely et %weever, Weems. of the recast hessellsamies4 bet all mush schemes their teethe' tine emly after year* have elapse& ** * * * * * * ** This problem of loess is closely esmemited with la* type ef settees required by the Verielli authorities,' Seee bulk seMmin bask eneet. ers it mere difficult for banks to increase lease duets* the past two love awls rears be. ems* of ummeeesearily rigid requirements, Is gemerel State examiners have bees the nest Umlaut, Federal Seserve balk emmmtmors quite strict but not as severe se National bank emmpteerss Sad' a system of matip le examination promote bathe asking oey loses exor2t those 'hid) Are extremely liquid and fikt short derotiset sled it would appear safe now to relax the rules someiheim Stamderdinatios ef Imo* examinations sad coneestration of ft* work sithis see ergenisatioa is imperative. . The Vetted States seed* a meifled booking structure, All State banks should be required te join the Amberol Sessowe Systes, awl as seem as expedient all members of the system Mould be pet maim natiom al Mortars The trend toward unification has bees etas in several respects beams. the preeest dual beikieg erste. ems in se smell may reepensible for banking trouble* shilb led up to the book holiday or about two the state years ape It is significest that greater progress ha* beam mode ia releasiag deposits in ember batiks them in nom.memberes The suggestion that banks sew inideet to Federal resolation eould ovoid atifisatise beeemimg aseposuber Moto beaks is nowise 'duos it night eanse retaliatory memmeres by a Administration, Ala hes mot hesitated to intrednee redisel ladiseml seeseree, end thus precipitate a eemossent for immediate natiomalisation of ell brakes * *• ***** * Me illusion that the partleelar age in Which a Owen banking practice exists is final is one that is eattimeinyteteg disrupted* theor ise mei practises of American hankies ihesld undergo great dimmes . It is nessomm, to resspizo the fact that beaks marry Mike mei stiffer lessee s ?he hesitater for many years of banks to install adequate serviee Charg es mast steps Seeks realise they are entitled to this Mures of inane but seem te fuer lite reaction on the pert ef their ousteeers who might resent the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis banks' change of policy in this respect. Free sondes* have coot the banks of the U. S. as high as $300,000,000 within a single year, Several years ago a natiem-vide survey indicated that if all U. S. egimercial banks a:'opted a small float charge more than 00,000,000 would be added to earnings signally. This, of course, is only one type of service charge. As has beem indicated, on the other hand, costs can best be eut by cooperative sotto& te reduce the meet important expemse item vhieb is interest paid em deposits. Particularly in rural area* many country banks are operating epos earnings insufficient to justify their capital invest. sent bat beam* of eompetitive conditions are paying excessive rates of interest ma time deposits. This must be ohmemed, mei there are indications that a start bee boom made by the beak, in deellei idth all theee problems. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Address by R. E. Reichert, Michigan State Banking Commissioner 49th Annual Convention, Michigan Bankers Asso., June 1935 (Michigan Investor, July 13, 1935) ********** There is one more point that I wish to touch on. That is that our institutions must absolutely be so operated that they show a profit. Consequently it is impossible to try to operate them in too small units. I am and always have been in favor of the unit bank with certain reservations that that unit bank be large enough so that it can be profitably operated. Because of my view on that subject I have been in favor of branch bankinE with certain limitations. I believe that many of these communities thould have banking facilities, and that they should be furnished by a larger bank close to that particular community. If there is not enough business in the community to support the branch, the branch should be closed the same you would close any other bust1-" -ness that proved unprofitable. Only by first making your institution profitable and sound can you have a sound banking structure. I believe that the experience over the past years should teach us not to attempt to operate on any basis except upon a sound and conservative one, keeping at all times in mind the relfare of the people we are attempting to serve. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *********** • From "American Banker" Published in The Hoosier Banker, June, 1935 Eccles Would Limit Branch Banking by Twelve Districts Explains Purpose of Compulsory Reserve Membership for Insured Banks to Committee; Wants National Charter Control In the questions with which senators interrupted Governor Eccles at the hearing on the Banking Bill recently, it was brought out that he personally favored branch banking extensions, noting that the trend was in that direction. "I believe in a state-wide or a regional branch banking," Governor Eccles said, adding that his plans would make the twelve Reserve regions the basis of the control. However, he decliaed to say that such provisions should be placed in the bill and pointed out that it is a disputed matter, involving the controversial nuestion of state rights. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis **** ****** • SOURCE: THE FINANCIAL AGE — June 18, 1935 THE PRESIDENT'S ADDRESS--Edgar A. Jones, Vice Pres. of Scranton—Lacka— wanna Trust Co., Scranton, and Pres. of Pa. Bankers Association Page 419-420 A statement has been issued to our membership relative to the enlcrgement of the scope of branch banking in Pennsylvania. The principles set forth in the stetement were unanimously ap— proved by the members of your executive committee, your committee on legislation, your committee on branch banking, and your officers and, upon submission to the secretary of banking, approved by him. Ledt evening the council of administration, likewise, approved thereof. I assure you that the action taken was necessary and that the interests of our members are protected. I, therefore, ask that all our members whole—heartedly approve and subscribe to the princi-ples set forth in the statement, which are: 1. 1Jranches may be authorized in localities where there are no banking facilities, but not beyond the counties contiguouc to the county in which the home office of the bank establishing the branch is located. It shall be written in the Act that where establishment of any branch is deemed feasible, an applying benk within any county would be given the preference, other things being equal. 2. Branches may be authorized where the local situation should v be strengthened and where the banking assets can best be conserved by merger and retention as branches, but not beyond counties contiguous to the county in which the principal office of the bank establishing the branch is located. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Financial Age -- June 18, 1935 COMMITTEE ON BRANCH BANKING--Harry J. Haas, Chairman Page 421 Any figures that I might give probably would not remain in your thoughts, but I will just say that we sent out 1,064 cuestionnaires and got back 539 replies, over 50 per cent, on the first one. The only question on which there was a close vote was the first one: "Are you opposed to all forms of branch banking?" There were 287 voted "yes" and 233 "no". On the question: "Do you favor national legislation which would permit branches for national banks within the several States on the same basis that branches in any Stete are permitted for State-chartered institutions" the vote was 219 in favor and 266, I presume all the State bankers, said "no". Now, after we had done this work for a year, we hao this meeting at Harrisburg with Dr. harr and he pointed out to us the importance of extended limited branch banking, where it would help Um banking situation apd would not interfere with Any_existing_ bank. It is so worded that it is impossible, if the law is passed, in any way for any branch to interfere with any existing bank. bo, Aith your permission, I will finish this report. 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • The financial Age -- June 18, 1935 COPUITTEE ON LEGISLATION—T. Walter Ulson, Chairman Page 425 EXTENSION OF BRANCH BANKING Second--The other measure to which I wish to call your atten— tion in particular is the one covering the extension of branch banking in Pennsylvania which was also outlined in our letter of June 1st. This important development accepted in a spirit of mutual understanding resulted from conferences of your committee with the secretary of banking. Since it is also an administration measure it is my thought that Secretary Harr will elaborate upon this plan in his address on Thursday morning and there is, therefore, no occasion for me to take more of your time on this point. Suffice it to say that extension of branches under this bill is also made subject to the approval of the banking board and thatia, w/ be established in a community which aireaUTEErgaing facilities. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Financial Age--June 18, 1935 THE CURRENT BANKING SITUATION-Dr. Luther A. Harr, State Secy. of Banking, harrisburg Page 429 ******** Another measure which we believe to be essential to the well-being of the people of the : .itate is our branch banking bill. The bill provides: First, that branches can be extended only in the county in which the parent institution is situated or counties contiguous thereto; second, that no branch can be established in a community which already has banking facilities. One exception is made to this provision, namely, thtt a branch can be established in a community through merger where the comlnunity would be without banking facilities other than the merged institution. The third provision requires each branch to carry as much capital and surplus as it would have to carry were it an independent institution. An exception is made for branches in communities of less than 3,000 where only 50 per cent of the legal capital and surplus will be required. Finally the bill states that no family, chain, or holding company can extend branches from more than one centre. This eliminates the possibility of a family, chain or holding company acquiring banks in widely separated counties and opening up branches from each of the banks so acquired. At the suggestion of your legislative committee we agreed to amend the bill to provide further that extension of branches shall be subject to approval of the Banking Board. With the bill so drawn I cannot see the slightest danger of unfair use of the branch banking privilege. And there are many benefits to be derived therefrom. Let me give you an example. Paes 429-450 There are now throughout the Commonwealth scores of small communities, townships, boroughs that have no bank. The communities do not have the financial resources to support an independent institution. It is doubtful if even were one established it could make money. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • • • -2The Financial Age -- June 18, 1935 Dr. Luther A. Harr Pages 429-430 (contd. But if this branch banking bill passes, end I believe it will, people in these communities will enjoy banking facilities and business in those centres and through the State generally v' will benefit. It will extend the benefits enjoyed by Upper state. entire the to Ardmore Darby and I know that your association has opposed branch banking in the past. Ldany of you still do. But I am sure that as you study our bill you will agree with us that it is a necessary measure and that every precaution to prevent undue extension of branches has been taken. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: THE MISSISSIPPI BANKER - Aay 1n5 ADDRESS OF M. D. BRETT, State Comptroller, Department of Bank Supervision Pages BZ-B4 Sectione 6Z, to 67 of the lew provide for banks with brenchee and "Branch Offices", all within certain limits, es to number concerning branchea, end territorial liaitations as to both. Ectablishment of e brench bank requiree the majority vote of the Governor, Attorney-General Load State Comptroller on the question of public convenience and neceslaity, while the establishment of "Branch Offices", which ma:i do everything that a bank or branch bank Mhy do except nuke loans, ic wholly within the discretion of the State Comptroller. A large capital is required for a brunch benking system because the parent bank must have a capital of ut lebrt il0J,00J.00 and additional capital of at leaet /15,000.00 muet be provided for each branch with limitation of fifteen branchee, yet it is possible for a small bank heretofore establiehed of 410,000.00 cepitul to open an unlimited number of branch officee within the county of ite domicile or adjoining counties, and in a test of this poseibility, I have found thet in one county at leaet within the state where a bank domiciled therein with only 0_0,000.00 capital might, if the Coaptrollkr saw fit, establish ut leest uixteen branch offices within the territorial limitetions, in the small towns end at least two large citis, while a brunch system aaj not have over fifteen banks. The lew also provides as to branch bunks, that a branch bank may not be established in any town or city of less than !,500 population, where such town or city has one or aore banke in operation. There have been quite a few applicatione by banks within the state to open branch offices within the territorial Units allowed by lew. In considering these applications for branch offices in toms or cities less than 3,500 population wherein there are already beaks opereting, I have rejected theat feeling that the groat responsibility to the banks and the public generelly justified this action. If the ComptrollLr were so inclined he could permit breach offices without number Which could do & complete banking business, at least iapliedly under the law, except sake 14ans, which is forbidden, but in which loan applicatione might be taken and forearded to the home office or bank, and thue bring about a very unpleesant anc unwholesome eituetion in banking in our state. In the arguments for "Blanch Offices" and the discussions at the time this pert of the present banking law, it was Section vas proposed as suggested that these would be beneficial in extending banking facilities to communities thut could not support en independent or branch bank. It wee further arguud thet becaure of the fact that capital requirements were raised to U5,000.00 minimum, in many instances it would not be poseible to raise thie and organize a bank or for a parent bank to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis sZI . ‘t. a; S e 41 Ck) itt; a 4111111fr... The Misaissippi Banker - Bay 1935 M. D. Brett Pages 33-54 (contd.) project a breach bank in the smeller oommunities. In many communities where branch banks have lie,uioated or were liquideting for one reason or another it, wee urgued thet thie would uffore u means of extending banking facilities into thetas communitiee; also it was augg,eted that where tLere was onc or more benke in the reetricted locality ellowed by law in which it ma e tusk to ttern enough to pay operating expenses, that a lareer bank in the county limita or adjoining county might ebaorb these and by the "Branch Office" plLn re-extenn banking facilitiee to those communities, thuu dicpensing wite coneiderable overheed and meking more certuin the eerning capacity of the main office. Onder these conditions several brunch ofiiceb have been ulloweo end are meetint with succese enc. making more certain the BUCCOSE of the main bank. And, until I chanie my thought on the purpose of thiu part of the lew, I feel thet I ahould not grant branch officee in the face of alreeny organised and exieting banks. Indeed, I vee a tencency tovard bank extension one way or the other in thie uno othLr states, and the authoritiee charged with the reeponsibility of supervising banke rhould proceed ver carefully, for I believe that we have been "over-banked" in the past an thie, probably more tien any other ene thine, flee brought about the eituation we have recently gone through, for it brought about a high degree of competition, in many instancee unfair and unethical practicee, contrary to gooe bueinees rules. The thought wes prevalent thet everyone wes a banker end thet to go into the buoiness sweat eaey money ahead, and if the profits or earninge were grett the loesee could tuke cere of themseivev, which es we now know, did not work out. This seems to be the thought et this time of governmentel authoritiee hevinE to do with the Eupervision of banks, both State anc National,and I trust that they will maintain thie viewpoint against aver-extension and instead of gratifying the clamor for more banks, thtt we all work together to make those that we luxe better and etronger through volume of businese, decreesed lossee ana expeases,and increased earnings, for if unjustified extension of the National banking system through orgenization of new benks is permitted then the policy of the state authorities gots for naught. Under our State law umple flexibility ia given to afford at least one banking house to every oommunit,y which hab ha6 and nov wante which may never have he'd one, but now seeks such accosnodations. This is the purpoee of the law and thiE ie sufficient. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: ECONOMIC CONDITIONS, GOVERNMENTAL FINANCE, U.S. SECURITIES (The 'lat. City Bank of N.Y.) Page 31 (Feb. 1935) By way of comparison it may be added that the Canadian banking system consists of only ten corporations, but operating about 3,500 branches. According to tint findings of a Banking Commission, which reported about one year ago, the average net earnings of these corporations over the preceding ten years had been 6.36 per cent on their capital funds, and average dividends to stockholders 5.93 per cent. Thq_Ju!anvh banking system undoubtedly lowers both interest rates and capital charel. by reducine both operating and capital costs. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *no Money and Baaktmg Situation in the United States* by Dr. Gaines 1`,. Cartinhonr„ New York University, (Journal of the Studien Bankers. Ansa., ant., 1930 ** ****** * * * * * Bankers who have tees criticised for hesitancy to make loans complain eonflict in govermment policy. The government, they say, has insisted ef that banks make loans, on the one hand, while on the other bank examiners have been making it sore difficult by their rigid recuirememts for safety respecting loans and collateral. Drastic and unfair appraisals are alleged to have been made. In general it seems that State examiners have been most considerate. Federal Reserve Bank examiners have bean somewhat more drastic, but not as severe as National Bank examiners, whom some bankers denounce as having redueed value. ta their institutions to a point where the capital and surplus have been practically wiped out. The American Bankers' Association has loncerned itself with this probaem, and ex-President Law has pointed out that as long as examiners believe it to be their dintr constantly to hammer on loans that are admittedly good, only because the, are slow, it will have the effect not only of forcing banks to Wert unnecessary preesure on such loans but will prevent theI from making agy new loans except those thPt are extremely liquid and of short duratiom. This situation has been admitted br tok. Administration to be a serious problem and standardisation of balk examisetiOn practice and consentration of such work within one organizatioe in lUshiagiam is now advooated. At the time this article is being written, (December 15th), it appears that the Federal Deposit Insurance Cortoratiom will take over all activities along this line being worried on by the Comptroller of the Currency, the Reserve basks, anJ the Nesemstruction Finance Corporation. State banks are else ex,mined by State Smoking Departments in addition. Practically all national banks heme been subjected to examination by at least three Federal agencies, frequently using different yardsticks of value. The result has been that they never could tiLl which of their loess might be questions& For national beaks oue source of examinatiom Should be sufficient; for state banks which are FDIC members joint examinations conducted by State and Federal authorities should be arranged. Fnrthermere, such a rolicy would save the beaks a great deal of espea004 One Wall Street institution estimate. that it empsedi at least $50,000• year supplyieg the desands of baulk examiners. ?he correctioa of this sites* tios will not make possible an immediate flood of new bank loans but will remove one of the obstacles emaftontingAmerican bankers. ** ****** * ***** There have been renewed reports reoently of actioa te vally the American banking system. The Federal Reserve Mord is esdarvieed to have given this proposal consideration lately but its aumbers believe that it is more a poliqy question for the President and Congress to handle. Should there be attempts to unify the system, it could be brought about through coapulsory membership of State banks in the F. R. System, compulsion on State banks to tells sat national charters, or possibly tlrough unification of State laws. The latter would not be as effective as the tomer. Many questions of constitutionality, etc., would arise in the event this type of legislation were recommended to Congress. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis iii.msW.gelrr r - 2* * * * * * * ** * * * * * : ?he satire banking situaties mould aleo be greatly benefited hy the gradual mimeos ef breasb hankie. se that all communities oaa have adeqnste baukiag service vithont taking the abases that oomes when small local institutions handle the business. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * * * *• •*•* * *• • SOURCE: PROCEEDINGS NEW YORK STATE BANKERS ASSOCIATION - 1934 Page 15 (Address of President McLaughlin) * * * * We have heard a great deal about legislation. Let us forget the past. I know many of you were annoyed at the pasgage of the Branch Banking Bill. In my own opinion, it was not the ideal time to pass one, although I have always believed more extensive branch banking would come eventually. But of all the bills proposed, I believe that the one that has been enacted into law is theleast offensive. So I would say that we should give our full co-operation to the authorities who have to do with its administration, because undoubtedly there will be some conflict between national and state banks seeking a branch in the same communities. Pages 150-51 (RECENT BANKING LEGISLATION - Address by Paul G. Reilly, Counsel to the Joint Legislative Committee on Banking) ed tuf: A bill which evolved a great deal of comment and discussion was the Stephens Bill, permitting branch banking in various districts of the State. It represents, on a small scale, the so-called regional or trade area type of branch banking. Much has been said about this subject and probably a great deal more will be said in the future. The operation of this law will be closely watched and may have a great deal to do with future branch banking in this State and in the country. I hope that the licensing authorities will sincerely and earnestly endeavor to exercise the _privilezes_granted under this bill_in_.5uch a manner as to prevent any undue expansion that may bring about a return of the excessive competition that_has been so roundly and justly condemned. I have in mind a situation which may accurately foretell just how nearly possible it is for the state and national systems to co-operate in a so-called gentlemen's agreement. A certain town in this state had two banks a few years ago, a state bank and a national bank. Both of them failed. It may be said that one of the contributing zauses to their demise was the economic inability of the tam to support more than one good institution. Within a week after the Stephens Bill became a law, a national bank located in a large city filed an application for permission to open a branch in the town. At the same time a https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2- • Proceedings New York State Bankers Association - 1954 Pages 150-51 (contd.) state bank from the same city applied for permission to operate a branch in the same town. Here will come the real acid test. Can the systems co-operate intelligently and unselfishly for the best interests of the people of the town and the banking structure as a whole, even though it may require sacrifice will tell. upon the pert of some? Time alont .) Packe 152 * * * It was not possible to produce any such legislation and the best that could be obtained ance of the Comptroller of the Currency that he operate with the Superintendent of Banks in the branch authorizations. * * * limitations by was the assurwould comatter of An idea has recently occurred to me that might provide some of the limitations sought by those who fear competition. I have not fully thought out its feasibility but I believe it to be worthy of consideration. Briefly it is this. Nearly all of the banks in the country, both state and national, are members of the FDIC. They represent nearly all of the banking resources of the country. The FDIC, is not, if it is properly administered, biased in favor of either state or national banks since both are members. It is vitally concerned with the welfare of every bank in the land because the welfare of the whole system is dependent upon the welfare of every individual member. It certainly can have no desire to see the security of its members as individuals or as a whole threatened by an excess of competition. It has a vital interest in seeing that the economic security of its members is maintained to the fullest possible extent. The future of deposit insurance will be largely determined by the presence or absence of a sound banking structure. The present indications are that the FDIC will continue in some form or other as a permanent feature of our banking policy. * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Proceedings of the AIE6UURI BANKERS ASbOGIATION ANNUAL ADDRESS OF Tra PRESIDENT Willis R. Alexander (Page U.) I want to go on record nere and no% as being unequivoca lly opposed to both central and branch banking. No more tangi ble justification of tali:, view needs be citea tnan tae records of our banks during the past several years. Tnrough stress and storm, bunks meusured up to the demands made upon them far better than most other lines of business. Tne independent unit bank nas been the vital force in buildinz up tae community througnout the nation and will continue to do so if individual initiative is not legislated atuy from it. Most American blaks are community-owned insti tutions. Tne men who make tae policies and operate tne banks are perma nent citizens. For this reason Vie welfare of the community is their paramount interest. As a result of this local ownership and local management of the banks, our country has developeo industrially far beyond otner countries saich do not have this type of banking. The independent unit bank is threatened by attempts to extend branch bunking. Shall we permitt the system which nas and is nov contributing 60 largely to the developmen t of our country to be strangled and smothered out of existence? Personally, my answer is no. And I aJa ready to wage incessant turfare for the preservation of our independent unit banking system. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: PROCFEDINCE NEN YOfdi STATE BASKERb ASSOCIPTION- 1954 Ptige 54 (Address by Hon. Leo T. Crowley, Chairman, FDIC - THY BENEFITS OF DEPOSIT INSURANCE) Recently, there hrs. btEm ?erfectee E rlivived form of bftrar exmin;.tion report. This has been accomplished through the =-operotim cf the office of the Com,itroller of tvle Currency, the Federel Reserve Boare and the Federal Deposit Insu:ence Corporztion. The we of the new uniform ..ytmi_ nation report ie but the first step in this fruitful field es far as co-operAiion end improvement of benk supervision ule management is concernd. are in hopet that we will be ablL to makc. further edvslicr,v. tbese lines, particularly with a view to increasink the effectiveness of an exhmination and L.t the same time redue_nt, Liu number of different examiniitions recuiree by the verious supervising withorities. In this matter we invite your co-operatift. We are very pleased thtt con;Aderable proLreev hLe 'Already leen awcle and thLt the authorities concerned are so kinely eisposed to cooperate uiti, us. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOVNegi WORT ON DANES OF DEPOSIT & DISCOUNT, ETC. - BRANCH 1954 BANKINC (Denking Seard) The Stephens Act, dividing the state into nine districts and permitting branch banking by banks and trust companies within such districts, has new been a les for about seWen months. The provisions • of that Act are clear that the Legislature was especially concerned that it should be administered in such. a way as to avoid undue and unsound expansion of banktng under its terms. This principle the Board bas kept constantly in mind in the exercise of its power under the het to approve or disapprove applications for branches. Not only has the Board weighed with the utmost *are all applications which have come before it but it has also aided and approved the policy of the Superintendent in cooperating with the office of the Comptroller of the Currency in an effort to establish a common policy as betweem state and national system's. The continua**. of this polic3, is not only advisable but imperative if branch banking is to develop on a sound basis. For the purposes of determining in *hat communities and. alder what conditions there is to be a further expansion of banking fasilitiee, all the banks of the State must be treated as belonging to one system. The single purpose of providing sealed end adequate banking facilities for all section. of the State sennot be achieved in the absence et cooperation between the two agencies which are authorized to permit the formation of new banks or branches. The belief of the Beard in this principle is reflected in resalstion adopted March 261 1965 pursuant to which the board meserialised Congresa to incorporate in any amendment to the Federal banking laws provisiesn requiring the approval of state authorities for the estabiOhnent of a national bank or branch thereof in any community termed by a state bank or trust company, provlded the State would likewise enact legislation requiring the approval of the Federal authorities for the establiehment of a state bank or trust company or branch thereof in any sonramity serVed by a national bank. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCEs REPORT OF BANKS OF DEPOSIT & DISCOUNT, FTC. — CT. 1934 BRANCH BANhING Page 7 * * * ** * ** The Stephens Branch bunk Act should be helpful not only in providing bunking services in communities where no bhnk is presently loostod, but &leo RB means of strengthening the entire system by the conversion of uneconomic units into branch offices , of other institutions. While some progress in thie direction has already been made, much still remains to be accomplis?led. It should be borne in 11'nd th:,t. no matter how stront an individual unit may be, continued opertion at h loes will eventually jeopardise the securit.) of its depoFitore. A tentative survey indicatts that in various sections of t'r.e State consolidations &re possible which would result in the rendering of improved banking service at lower costs, thus permitting a margin of profit affording bettcr protection , to depositors. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis . . 74 &U4r-i144 :tZr "44 14A2s.44. GoA, Aerite/ • SOURCE: REPORT ON BANKS OF DEPOSIT & DISCOUNT, ETC. - N.Y. 1934 Page 6 BRANCH BANKING The Stephens Act, which divides the State into nine districts and permits branch banking within such districts, became a law on May 16, 1934. Since that date, and pursuant to that Act, branch banks, includinb state and national have been established in_eleven communities which_previously had been without banking facilities for varying periods of time. In the main, this Act has proven satisfactory and workable. While the present Superintendent favors the principle of stkte-wide branch banking, it may be well not to -1W tre—iiiIiiirntErmore experience has been make a further change had under the Stephens Act. Consideration should be given, however, to the recognition of a policy which would permit banks and trust companies to operate branches or stations to be open for two or more days a week in communitirs not large enough to support a full time branch, but in which a need exists for banking service. * * * Page 17 INVESTIGATION BUREAU The passage of the Stephens Act has reulted in an increase in work of the Investigation Bureau, since it has been required, in addition to its other duties, to conduct investigations in connection with each branch application filed with the Banking Department. Such investigations undertake to cover the need of the community for the branch sought to be established and the facilities of the applicant to serve the banking requirements of the community, as well as any other relevant considerations which may affect the particular case. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • DRAFT OF MINUTES OF MEETING OF SYSTEM COMMITTEE ON LEGISLATIVE PROGRAM October 24, 1954 Room 422 Shoreham Building Washington, D. C. Following informal discussion of a tentative draft of the opening portion of the Committee's report, presented by Mr. Goldenweiser, the following members of the Committee met in formal session at about 11:50 A.M. Governor Harrison, Chairman, Mr. Thomas, Vice Governor of the Federal Reserve Board, Governors Black, Norris, and Young, (dhairmen Peyton and Williams, and Messrs. Goldenweiser and Stark. The morning session adjourned at about 1 P.M. The Committee (with Vice Governor Thomas absent) reconvenedat 2:40 P.M. The session was attended by Messrs. Robert Fleming, Tom K. Smith, D. J. Needham and (later) R. S. Hecht of the American Bankers' Association, and Messrs. L. E. Wakefield and Guy Emerson representing the Association of Reserve City Bankers. The Chairman stated the purpose of the System Committee on Legislative Program and summarized its work and its tentative conclusions as follows: 1. Unification is desirable, FDIC is the most practicable lever for accomplishment of substantial unification through membership in the Federal Reserve System. 2. Supervision and examination of all banks doing a commercial business should be centered in one agency. The Federal Reserve System, on account of its regional organization and its long and close contact with the banks of the country, is the agency best adapted to the performance of this function. 3. The coordination of banking functions performed by various Federal agencies is a natural part of a plan for unified and centralized supervision. Mr. Wakefield, President of the Association of Reserve City Bankers, referred briefly to the Association's studies of the Banking Act of 1955, Federal deposit insurance and unified banking, as well as to its active interest in the preservation of the Federal Reserve System https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis As to Governor Black's two points, Mr. Emerson stated that the Association is actively interested in the preservation of the Federal Reserve System and should be in a position to offer effective defense of the System Mr. Smith, Chairman of a sub-committee of the Committee on Legislation of the American Bankers' Association, stated that the sub-committee is agreeable to unification through the extension of membership in the Federal Reserve System. His sub-committee is actively interested in an improved insurance law and an improved omnibus bill to correct the defects of the Banking Act of 1935. It is prepared to act in defense of the Federal Reserve System and in opposition to nationalization of banking. His subcommittee would be in agreement with the Chairman's statements regarding the coordination of Federal agencies and regarding Federal deposit insurance. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: ANNUAL REPORT OF THE COMMISSIONER OF BANKS FOR MASS.PART II - 1934 Page vii ',Rcorkanizationa In the last annual report, it is stated: "Efforts are now being undertaken to further reorganize this whole situation with a view of effecti4 additional releases to depositors of the trust company and by reopening the trust company as a going institution and place the stock of these bankm into individual ownership. The early enactment of the county ?.ide branch banking bill recommended by the Special Commission for the study of the banking structure will materially aseist in the development of such a plan, particularly in so far ae the smaller affiliated banks are concerned." This branch banking legislation was enacted 8nd became law on June 29, 1J!4. On September 19, 1934, a plan was ap)roved by the Federal Reserve authorities, the Supreme Judicial Court and the Commiss ioner of Benks providing for the oombination of the assets of these five banking institutiona into one under the charter of Worcester Bank v TruA Company. Ae a result, Worcester Bank & Truet Company was reopened under the name of "k)rcester County Truat Company" and branches were established under the new branch banking law in the offices formerly occupied by the affiliated banka. Tiv reorganized bank has deposits and trust department businesa aggregating in excess of t70,00J,OW and possesses,sound eapital structure of over $4,000,000. The capital stock consists, of $2,000,000 of Clase "A" preferred and t1,000,000 of common. As part of the plan, each holder of a Class "A" certificate in Worcester Depositors' Corporation reckived an additional cash relehse of 40 per cent of the face of his certificate and received for the balance of his certificate Class "A" preferred stock in the reorganized bank retirable by the trust company for the balance of his certific:,Ite. * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: PROCEEDINGS NEW YORK STATE BANKERS ASSOCIATION - 1934 Page 63 (REPORT OF THE COMgITTEE ON STATE LEGISLATION) k There was, however, one important recommendation of the Superintendent which your Committee did not approve, namely, that relating to branch banking. You will recall that the Superintendent recommended that branches be permitted throughout the county of the main office and adjoining counties, subject to the approval of himself and the Banking Board, provided, however, that no branch be established in towns where banking facilities already existed, except by the taking over of existing institutions or institutions in liquidation. He recommended state-wide branch privileges for banks with capital and surplus funds of $25,000,000 or more. Your committee, in its report submitted at the Mid-Winter geeting, took the position that unless and until the overestablishment - was _______of branch banks, either state oriiarolitil", prope-fIY guarded against by Federal and State law, we were opposed to the extension of branch banking privileges in New York State beyond the territorial limits then permitted. Page 64 We nevertheless realize that excessive branch competition would be detrimental to the interests of sound banking. We have great confidence in the present incumbents of the offices of Superintendent of Banks and Comptroller of the Currency, and we do not believe that excessive branch competition between state and national banks will result from the enactment of the Stephens Bill during their incumbency. However, for the sake of future conditions which we cannot at this time foresee, we believe it would be well to have the Federal banking laws so amended as to provide adequate safeguards against branch competition along the lines recommended by this Committee in its previous report. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Address by L. A. Andrew, Iowa National Asso. of Supervisors of State Banks 35rd Annual Convention, Baltimore, Md., October 1954 We who have fought the unification of banking idea have seen the dangers of that propaganda crystalize in proposals which have gone much farther than any proposed unification of aur banking structure. It has been openly advocated, and may be realized sooner than many of us now think possible, that all banking in this country be done through a branch system of a new Central Bank or the present Federal Reserve Bank, government owned. /n a way it is the natural development of the plan to unify our banking structure by destroying the American dual system of banking. We have seen the advocates of "safety in bigness" try out in succession for public favor, group and chain banking and then concentrate on branch banking, finally themselves being forced into a stand with the unification of banking idea. In their fight, many times during which unfair tactics were used and untrue statistics published, they failed to see that, under the stress of public loss of confidence, such a campaign would naturally lead the proponents of governmeat banking into a favorable light. The arguments used for the unification of our banking system became during the past year the arguments for the taking over by the Government of all banking functions and the operation of branches of a Central Banking System in all sections of the country. In our discussion of the future of the unit bank, we wish to take up a number of points in its favor and then prove that the American Dual Banking System is the best for the future development of this country, as it has been in the past. The unit country banks should be first defined as an institution which is owned in the community and operated for the profit of the stockholders and for the benefit and development of the community in which it exists. We believe that few, if au, will dispute the statement that the unit country bank has been responsible in a large measure for the development of the community life of this country and for the success of individual effort in business. The unit bank is the heart of the community and furnishes the circulation of the life blood of business. When properly managed it provides an ideal set-up for conserving the cash assets of the community and for loaning these assets out safely so that the community roundabout is properly developed and business can have its temporary needs for additional funds supplied by people who are familiar with the commanity problems. Of course, unit bankers have made mistakes. These mistakes, hoWever, have been caused in most cases by a too optimistic belief ia their own community. The losses sustained by the unit bank were those which were brought about by a great economic change over which neither the banker nor the customer had any control. It is now apparent that many of these losses could have been avoided by more carefUl management. However, the mistakes of judgment made by the country unit banker were not nearly so expensive, in total, to the depositors as were those made by larger city bankers. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** ** * * * • - 2The question of whether the State Bank System shall be destroyed and about half the banks of this country put out of business is now right up to a decision. It is unfair that a great economic and financial question, involving the existence of thousands of banks and the financial stability of thousands of American communities should be brought up for decision at this time of depression hysteria. The fight regarding the American Dual System of Banking is a clear-cut issue between those who believe in the sovereignty of our states and home rule, and those who are in favor of a "unification of our banking system" into one Washington bureau. It is also a fight between the unit bankers, both national and state, and the proponents of a foreign system of branch banking. In fact a careful analysis of the issue shows that the ultimate result of this battle, if it should be lost by the state bankers, will be the placing of seven or eight large branch banking organizations in charge of the financial business of this country. In a recent discussion of the reconstruction period in the American Bankers Association Journal, A. A. Berle, Jr., well known as a member of the Brain Trust and for many years an advocate of centralization in banking, wrote a splendid article favoring that side of the question. I was asked to present a plea for the future of the unit bank. It is interesting to note that one of Mr. Berle's conclusions was that a country-wide branch banking system was probably the ideal set-up but unfortunately he said that America had no bankers capable of handling propositions of this size. It is hoped that, until these super-bankers are educated in the improved Berle fashion, this danger will not materialize. Those who are using the propaganda that the unit country bank has been a failure are putting forward the remedy of "Safety in Bigness"; that is, the safest of the foreign system of nation-wide branch banking. Their argument is based upon an absolutely false position. They say that the unit country bank has been a failure, and that the large number of failures among the smaller banks, both national and state, make it necessary to change the American Dual System of Banking to a foreign system. The American unit bank has not been a failure. * * * * * * * * * **** *** * The movement to put all banks under the Federal Reserve System, another angle in attack against the unit country bank, is equally indefensible. The Federal Reserve System should have the support of all large commercial banks, and every bank doing a commercial business with resources of over a million dollars should belong to the system, but any effort to compel all the unit country banks to belong wauld not be wise or even desirable from the Federal Reserve viewpoint. It would add infinitely to the detail and responsibility of the system without material benefit; in fact, the best posted men with a thorough knowledge of the Federal Reserve System have repeatedly said that one-third of the banks in this country have no place in the system. Their wants can be taken care of better by the use of correspondent banks in Reserve centers. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ** * ***** 60UhCE: ASSOCUTION NEWL BULIATIN Ilanks Association of State of New York OCTOBER 18-19, 19Z4 ALDRESE BY HON. EUGENE R. BLACK, Governor, Fed. hes. 3dnk of Atlanta and Former Governor, Fed. Res. Bd. Pse4e f)4. I have watched the trend of banking in America closely for the past ten years. I have seeel developments that were disturbing during that period. remember the race for bigness in Anerich. I remember the period of mergers in America, and without criticizing any merger or commenting upon any merger, I persomlly fcel thht there hes never been a good mergtr in America. When I sa;; that I am speaking from America's standpoint, and not the bank standpoint. Every mercer hec to combine two good banks, and lessen conpetition in the community by tne combination; or every merger had to comoine a good bank and a weak bank and pull down the good bank; Dr every mercer had to combine two wer,k banks and multiply tenfold the weakness of both of them. But ve had peculiar spirit in America at thet time. Ze believed thrt bicness was strength, and that bigness and strength gave power; and there vas a race in AnericE for bigness and for strength and for power. "saw the change in commerci;-.1 bulking. I saw the old 1.enke in Amertca get away largely from commerciEl banking. I saw collateral banking take the pli.ce of commercial banking, iind I saw clerks in / Miry bank checking collateral and not checking chsracter. V https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Proceedings of the 35rd Annual Convention National Asso. of Supervisors of State Banks Baltimore, October 1934 ***** **** Thomas H. Daniel (State Bank Examiner, South Carolina): * * * * * In 1932 the minimum capital stock was reduced with certain conditions to 20% paid in instead of 10% and the prohibition against ownership of real estate and prohibition of dividends until earned surplus equals capital stock. That to some extent has solved the problem of the effort to organize banks in towns where there are scarce1y enough people to support the banks. Our cash depositaries, which we do not thoroughly approve of in that they sometimes perhaps prevent the organization of a bank in a community--on the other hand giving banking facilities in communities where they could not support a bank, and it might be worth consideration of some of you gentlemen to look into the cash depositary law. Briefly, the capital stock requirement is very small, only $2,500.00, and they make no loans under any circumstances, and the funds are invested only in United States securities, bonds of South Carolina or political subdivisions, and in case of voluntary liquidation the depositors are required to accept these bonds at the price paid for them by the bank, so the speculative value of bonds doesn't bother the cash depositor. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ********** Proceedings of the 55rd Annual Convention National Asso. of Supervisors of State Banks Baltimore, October 1934 ********* L. W. Ballau (Bank Commissioner, Rhode Island): Mr. Chairman, I don't know that I can offer you anything very constructive in regard to the banks of Rhode Island, in fact, the banking situation can be passed in just a word. I am not sorry that I have not a long story on the banks, I came here to listen to your stories—Tou men with so many banks. I take no credit for the conditions there, but we have had no failures and the condition of the banks is very saund and strong. Let me say to Mr. Gormley, we feel one good reason for the strength of the banks in Rhode Island is that we believe in branch banking, the big fellows take the little ones under their wings and we like state— wide branch banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ****** * ** Proceedings of the 33rd Annual Convention National Asso. of Supervisors of State Banks Baltimore, October 1934 *** * * *** R. E. Gormely (Superintendent of Banks, Georgia): * * * * ** *** * * *** In regard to the possibilities of legislation, I feel sure no additional legislation will be passed of major importance. Our position is a defensive one--we are constantly in danger of repeal of our present prohibition against branch banking. I expect a simillr attempt will be made at the coming session during the early part of 1935 but I very much doubt it will be successful. The position of the independent banks in Georgia is that they are strong and able to overcome any effort to repeal the nrohibition against branch banking. Like the gentleman from Connecticut, re are .Jpre alarmed over the -possibilities of what mny come from Washington, the possibility of a nationwide branch banking or granting the F. D. I. C. enforcement provisions, and they will undoubtedly seek additional enforcement of the Fedeml Reserve membership in 1937 in order to retain membership in the F. D. I. C. We have two hundred non-member banks, and I have possibly stated to you,,exchange is one of the earninvs_la non-member_state banks and I dg_not uo ilow the av,p,..nge quall_bmk can exist withou-LiI. Any attempt to force Federal Reserve membership on non-mem er banki will result in the withdrawal from the F. D. I. C. of approximately 75% of our banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** ***** • Address by C. B. Axford 38th Annual Convention, Indiana Bankers Asso., May, 1934 (The Hoosier Banker, June, 1934) ** ** **** I seriously indict the American unit banker and his representatives for not having called upon the American Bankers Association to adequately publicise and advertise the American Unit Bank. The ABA would do it if the movement is properly backed by the rank and file. But there has been no such action. The unit banker ii„is ,seen Unself slandered and debased. He has let the critics advance. He has chosen not to fight back. But he can fight back. Locally he should be always ready to fight back. We believe that there is no alternative to a strong, safe bank statement in convincing the local population that it is better to have a self-liquidating local institution than a bank responsible to strangers and distant city financiers. The big bank offers bigness, which to the average Ainerican still means safety. Distance lends enchantment to the view. The local bank xust be able to prove its case for safety In black_and white. I beliiii_fatEgbre tha-the more difkailed statement is the agencylv which the local bank sho-uld be. pze ared to rove that a goo e an a ome s worth more to its loc commun y -tEin—a TD { -b-r'ink—w'ho-s-e—c-grirra —rrr-=n ei arrr;rv-s--away. The proper bank statement, properly presented, can tell the story of the support of local industries and local credits which is a challenge to any outside competitor. It can make clear its freedom from directors' loans, pledged assets for deposits, and other points in its condition which will throw down the gauntlet of both safety and service and guarantee the local good will to the local bank. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * **** * * ** • SOURCE: 7. MINUTES OF FED. RES. AGENTS' CONFERENCE-Wash.May 1954 (Confidential) FUTURE RESPONSIBILITIES.(Mr. I. Newton led discussion.) Topic 7-A. Topic 7-B. Topic 7-C. (27) Future responsibilities in over-banked communities. Future responsibilities in under-banked communities. Form of branch banking for small communities. After discussion of these topics, the following statement was adopted: "This conference of Federal Reserve Agents respectfully directs the attention of the Federal Reserve Board to the fact that group and dhain i banking have proved unsatisfactory and that some deserving communities are without proper banking facilities, while others are served by banks unable to fulfill their functions adeouately through lack of sufficient capitalization. "It is the belief of this conference that these unsatisfactory conditions would be improved by the authorization in the national banking system of branch banking within designated areas, Bnd the repeal of that provision of the lpw limiting branch banking to the States that specifically allow it." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: THE MISSISSIPPI BANKER -- MAY 1934 CHANGES IN MISSISSIPPI BANKING LAWS—by Hon. J.T.Brown, Pres., Capital National Bank in Jackson Page 23 VII. BRANCH BANKING Under the Act of 1934 Branch Banking is expressly authorized. A certificate of public necessity and convenience having been had and obtained from the Comptroller, the Governor and the Attorney Gener71, or any two of such officers, branch banks may be established within a radius of one hundred miles of the parent bank, provided not more than fifteen branches may be estnblished by any one parent bank and that a branch cannot be located in a town of less than thirty-five hundred population in which there iE a going bank. Branch offices may be established by and with the consent of the Comptroller within the limits of the City, or within the limits of the County, or within the limits of a County adjacent to the County within which the main bank is domiciled. Branch offices so set up are not to be permitted to make loans, but may receive and trummit loan applicetions to the main office or to another bank. They are not considered ns branches and no additional capital is required therefor. The name of every brench bank iF required to include the name of the parent bank followed by the name of the municipality in which the branch is located. No branch may be established unless the parent bnnk has an unimpaired capital of at least 0_00,000.00, and this must be increased by an amount not less than the minimum required capital for a unit bank in the municipality in which thebranch is to be located. In arriving at the required minimum of capital in such cases, consideration is given to preferred as well as to common stock. Provision is made whereby going banks may be annexed to or taken over by other banks to be thereafter operated as branches. This may be accomplished by the exchange of stock and is subject to the approval of the Comptroller. Established branches may be moved from one locality to another within the territorial limits of the parent bank, but may not be disoontinued without the consent of the Comptroller. Provision is made for the formuletion by the Comptroller of rules and regulations koverning the exemination of branch bank systems to the end that the parent banks and all its branches shall be examined at one and the same time. When reduced to writing these rules and regulations become law to be enforced by the Comptroller ES other provisions of the Act. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2— The Mississippi Banker -- May 1934 Hon. J. T. Brown Page 23 (contd.) //- Chain banking is prohibited but national banks are granted the authority to establish branch banks with the same rights and subject to the same restrictions as state banks. The provisions of the Act relating to name, territorial limitations and minimum capital are not applicable to branch banks heretofore established. K,._ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Address by C. B. Axford 58th Annual Convention, Indiana Bankers Asso., May 1234. (The Hoosier Banker, June 19M) * * * ********* Are we going to stand idly by and let the illusion that branch banking is synonymous with reform in banking simply because the American public is so incredibly uninformed abuut matters of finance and economics. When the branch bankers come out with clean hands and say that they are going to run better banks than the country has ever had before, we will concede to them some right to public attention. But we know that branch banking has been the tool of ambitious men who did not get along well enough in t/ unit banking to satisfy themselves. We know that this was true in Detroit, in New York City, in Kentucky, in Arkansas, in Ohio, in Massachusetts, and in 1934 alone, 17 branch banking institutions failed to open, tying up 594 branches and over $1,350,000,000 in deposits. We knov, that it was the crash of a multiple banking plant which wrecked Chicago banking in 1930. We know that it was the Cleveland, New Orleans, and Detroit branch banking crisis which brought the 1934 collapse to a head. We know that the greatest branch bank in the United States, an institution with over 400 branches, was saved in 1932 only because of the fact that almost $150,000,000 of Government and other money was available to save it from collapse. ‘ve know that it was the crisis of this bank which underlay the statement of Herbert Hoover that in 1932 we were within two weeks of going off the gold standard. If this branch bank had collapsed, we would have been in even a worse panic than we were when the Detroit branch banks collapsed, a year later to the day: And we know too that the ends of ambitious bankers have been served by a systematic propaganda for branch banking which has deceived a large proportion of our people into the belief that branch banking is in itself better banking. te know that that is bunk. In our American capacity for lack of knowledge about banking, we should listen to the British and Canadian critics of their Canadian systems before we attempt to emulate them. te will see how bitterly they regret the fact that once the eggs are scraTbled in building up a great centralized bralch banking system they can never be unscrambled, and the price of centralization is far greater than the price of local financial indenendence and responsibility which the unit banking system exemplifies. And finally on this matter on branch banking, I have one point to make. In the summer of 1931 a terrific run was in progress on the Big Five British banks. It was clear that if one or two of them should get into difficulty, all would be ruined. Branch bankin is no better guaranty of deposits than any other system. Two of these British banks were at the end of their ability to liquidate. It was Government subsidy or close for them, but the British Treasury was unable to borrow except from the big London banks. Instead, the British ended the run on their banks by going off the gold standard. They saved the illusion that their banking system was solvent by destroying the solvency of their currency. Yet we are deluded, many of us, into thinking that branch banking is a puncture-proof system of banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 2Our problem with branch banking is one of public education. In the face of msss advertisint); and propaganda campaigns from ambitious men to serve their own ends by building vast banking pyramids out of local money as far as they can reach, the only answer is opposition propaganda and advertising. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * * * * * * * * &GUM: PROCITTINGS OF MISSOURI BAIKTTS gTOCIAT/ON—May 14-15-16, 1954 THE FUTURE OF TRF UNIT BANK—address by L. Andrew Pagea 90-91 A discussion of the future of the unit benk must neceesarily become F discussion of thc. future of the Americen community, and, in feet, in the last analysts, it concerns even the future of our country itself. We who have fought to mrintain the inteerity of the unit beak, repreeented for many years in thie country by cur dual bankinK system, both matiomal and state, know thet the past year has been a vital one in the struggle te: preserve the intecrity of our Americen system of banking. At no time in the history of this country n.e therf been sme an unfair fight made on our unit banking system. The proponents of branch banking, chain bankir4, and other forms of multiple office institutions hsve been excessively bus3" but thedr effortr have not been so troublesome as trk well defined propaganda for the teking over of all banking functions by the Government. We who have fought the unification of banking idea have seen the canters of that propaEanda crystallize in proposals wlich have gone much fOrther than any proposed unification of our banking structure. It has bees openly advocated, end came neerer being realized than mask' of ,- as know, thet all benking in thic countr.), should be done throuth a branch slystem of our Federal Reserve Banks. In a wa:, it is the natural development of the plan to unify our bankine etruature by destroying the Americen dual system of bunkinc. We have seen the advocetee of "safety in bigness" try out in succession for public favor, group and chain banking and then c.ncentrate an branch banking, finally themselves being forced into a stand with the unification of banking idea. In their fight, during which they uaed at many times' unfair tactics and published untrue statistics, they failed to see that, under the stress of public loss of confidence, such a campaign would neturally lead the proponents of government blinking into a favorable light. The ergument used for the unification of our banking syetea became during the past year the arguments for the taking over by the Government of all banking functions and the operation of branches of the Federal Reserve System in all sections of the country. Llt a study of this subject about a year ago, I made the suggestion that, if the advocates of ti:e unification of banking were able to succeed, they would nuturally try t; develop the Postal Savings System into government banka of commercial business, givint the customers of these instituptions the right to have checking accounts, loan money, and, in fact, allow the system to conduct a general banking business. Within sixty dap, from https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis aro ...moo I.. A. Andrew Pages 90-91 (contd.) th4A time a bill covering moth a program for the Postal Savings Systeal was introduced in COngress and still is receiving a large &mount of support. It may be seen from this that it is unsafe for those fighting fur the unit bank ovtin to ,aake a satiric&l muigestiaa. .PaRe ** ** 4 4 It aay be that one of the main reasons for this kAropaganda against the unit countri bank is the weiareat eusc with which certain interests could control large groups of branch banks covering large sections of the country. There is positive menace to the financial stability of the United C'tates in tht stock market manipul&tions which may result if we hGve any large concentration of bunking power tarLagh branch bunkine systems. This is U phase of tile subject deserving c&rtful study Elk it iS U real aanger. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: PROCEEDING:: OF dIa,CURI BANKERS ASSOCIATION--NAY 14-15-16, 1934 THE FUTURE OF THE UNIT BANK--eddress by L. A. Andrew Pages 91-9k The advocates of chain banking and group btnking and also of bran& banking have had a grtat deal of trouble during the pest two years, but it has not loomed their fight oa the unit bank. !boy have deplored with great gusto the large nunber of failures of emit booing in the United States, but have not cared to make comparisons of anounto involved nor to discuss at any great leagth the rescue parties Welch halve been necessary to save mow of their own iituations. In our discussiou of the future of the unit bank, we wish to take up a number of points in its favor and then prow* thzit the Ateseican Dual Banisins system is the best for the future devolopuent of this 00wwtry, as it Inei been in the past. The Mit coumtry balk should be first defined as ell in$titutian which is mimed in the communit and operated for the profit of the stockholders and for the benefit and developmest of the oommisnit:i in whict it exists. le believe thst fee, if any, will dispute the statement that the unit country bank has boon responsible in a large measure for the developmeat of the community life of this country and for the smoseas of individual effort in businses. The unit b:..nk is the heert of tnt comommity and fornishfs the circulation of the life blame. of business. 'hen properly managed it provides ea ideal est-op for conserving the ftsh *mutts of the 4011WOmik aaG for lenning these assets out saely so thht the community amd the countrz, roundabout are properly developed an, the business can have its temporary needs for additional turn& eupplied by people who are fanilinr with the community problems. Of ccurse emit bankers have made mistakes. These aistakce, however, have been in most Osseo oausod by a too optimistic belief in their own comnunity. The loolaso amstained by the unit bhnk were those which were brought about by a great *canonic shame over which neither the banker nor the custimar had am, control. It ean be sees now that NNW of these lossee mould have been avoided by more eareful eau gement. Heelever, the mistakes of judgment in the country unit bunk were not neerly so expensive in total to thr depositors es were those in the larger citi a. The Altars of the unit country bank concerns primFrily tile future of Miriam borings*. The question of ebotber the vod borrowers in the overage imoricen community and the farmers in the couatry nearby are to have necessary oredit for the carrying on of their business will bf. det,:,rninod by the future development of this problem. The umit bi-zk in ite daily life represents the success of th(' community in which it exists. It is owned and managed by the pe,iple of the commumity and its suolooss is thrir eucceas and its failure is their failure. The queettos of whether tilt unit bank iv to continue as it hbs in the past with the American Dual Systole of Banking https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ?rafted/no Mistiuri Bankers Associhtion-May 14-16-16, 19B4 A. Andres blies 91-4 (contd.) depends upon better asmagesent in the unit bank. This does set mess that a very large *maker of mnit banks have not had good mesafenest. w/ Incidentally, I as famili.r with a survey made in at least two st-tes by the bank examining forces. They were asked to pic't. out V.v. twenty best bankers in each one of these two states, and you say be surprised to know that 76 per cent ia each state were bankers from the so-called countr.c. towns. However, you us bankers kaew that there iE room for improvement. *my lessons have been lee.rned during the past ten years, lessons that ha-,e oast a greet deEl of mammy sad they ahould be cmsidered carefully ia any future proo'eam for Witt emit beak. I have maintained for years, and I do not, theft there is no rinses sly gait banks cannot be run es safely as any other form of basking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: A CON.SIDERATION OY BANK INVEETIENT POLICIES—Prepared by Prof. B.R. Beckhart for the Commission on Banking Law and Practice, Association of Reserve City Bankers---Aay 1954 Pages 59-60 Ideally the commercial loan portfolio should reflect a wide distribution of risk by industries and by borrowers. Country banks fres/neatly find it impossible to effect euch distribution of riak and this inability on their part kute been an important cause of the failure of the small bankini institution. This zituation could no doubt be remedied if brunch banking were permitted over large geographic areas. The development of extensive branch systems mould veatly stremgthen the comGercial lcmn portfolio of the banking system through the industrial And the geographic distribution of risk effected thereby. AE c.n important by-product of this movement would be the fact thet country sections would benefit from the greater proportion of open-aerket assets held by the .arte city bonks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: PROCEEDINGS OF MISSOURI BANKERS ASSOCIATION--MAY 14-1E-16, 1934 THE FUTURE OF THE UNIT BANK--address by L. A. Andrew Page 99 ******** It is apparent that a strong effort will be made at the next session of Congress to put through a law allowing branch banking by national banks, even in states that prohibit it by statute. /Destruction of state rights by this method should be considered /beyond the possibility of enactment, hut it is going to take the unified effort of all unit bankers, both national and sUte, to p-reiiblit the passage of such legislation. The main advantage claimed , for branch banking by those on the inside is that it makes possible ( the transaction of larger bank operations with less calatia. This ' argument should be considered as against public interest and the tendency should be toward greater safety for deposits through larger , capital structures, rather than smaller. The danger of stock manipulations_in large branch banking groups is evident to all. The danger of an aver-banked condition, which always makes for recklessness, is just as apt to be present in branch banking as in unit banking, and the results are the same. LBranch banking within metropolitan areas or within adjoining counties may have some foundation, butioranch banking cannot extend safely beyond the intimate credit information that the officers of banks may enjoy. It is a well demonstrated fact that the loaning of a bank's money cannot be safely delegated autside of the executive officers of the institution. It has also been quite fully demonstrated during the past few years that any institution with too many paying-tellers windows is seriously handicapped in times of stress. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • "The Lessons of Foreign Experience" by A. S. J. Baster, The Annals, January 1934 Independence of banks Partly due to the individualistic tradition of English business life, to the prudence, generally speaking, of bank administration (which has preserved the country from epidemics of bank failures for nearly a century), and to the degree of popular ignorance, not to say awe, of banking and monetary affairs, the commercial banks in England are remarkably free from any form of state control. They are incorporated under the general Companies' Acts, file no important statutory returns as bankers, are subject to no special restrictions on the scope of their business, and, most important, obey no legal rules as to the proportions of the several items in their balance sheets. But tradition, in accord with the English custom, has shaped for the banks tolerably certain and recognizable norms, particularly as to the amount of cash and easily realizable assets which they keep as reserve against withdrawals on deposit and current account. In fact, the London banks have in the last dozen years maintained remarkably steady proportions between their "Cash in Hand" and "Balances at the Bank of England" and their "Deposit and Current Accounts," of about 6 per cent and 5 per cent respectively. Now, of the two sorts of "bank cash" which the banks use as a base for the creation of credit, their balances at the Bank of England are normally the more elastic and may be extended or contracted at the will of the Bank. It is this most important form of control over their activities that subordinates the power of the commercialbanks to create credit (and so inflate or deflate the currency) entirely to the policy of the Bank of England, and turns the London money market and the banks into a folly integrated system dominated by the Central Bank. The Canadian system is regulated by Federal legislation--the Bank Act of 1871 (the only comprehensive bank act in any country of the British Empire) and its subsequent amendments. The form of this legislation was undoubtedly derived from the British Colonial Banking Regulations of 1844, and has undergone remarkably few essential changes since pioneer days. The system is characterized at present 5y a small group of large banks separately chartered, which are dominated by a "Big Four" group on the English model, and which have reached their present size partly through amalgamations in recent years. Their headquarters are situated in Montreal or Toronto, the two chief commercial centers of the Dominion, and they are supported by a large number of branches and agencies througnout the country. (Table III.) rhe strict legal regulation of banking activities in Canada suggests ideas of importance from the present point of view. The chartering of each https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis bank by the Federal Government is, in the first case, by no means a formal matter, and together with the onerous statutory conditions of incorporation (including a minimum capital of 4,500,000 in each case), presents a formidable obstacle to any increase in the number of the banks except on the initiative of some group of undoubted means and first-class reputation. The intention to discourage the creation of banks except by substantial capitalists has thus been carried out; but the unexpected effect in arousing saspicion—subsequently exacerbated by the postwar mergers--of a "money trust" among the existing well-established banks is noteworthy. The suspicion is supported by the existence of a legally recogni2.ed and extremely influential Bankers' Association, of which all the chartered banks are members, and upon which some criticism has been directed in recent years for an almost fanatical conservatism, especially in relation to sach issues as Government inspection of the banks, and the Canadian Central Bank project. Finally, the Central Bank in England, which is in close touch with each one of the few commercial banks, yet undisputed leader of them all, is unhampered by any direct association with Treasury officials or politicians, and is assured of the willing cooperation of all elements in the banking system in the application of its policy. Its record saggests that while British financial difficulties have been more acute since the war, the Bank of England has been a more effective mechanism for dealing with them. An increase in the comprehensiveness and independence of the Federal Reserve System could not but increase its effectiveness along the same lines. With all the qualifications mentioned in the first part of this paper, the broad significance of these saggestions cannot be missed. Foreign experience was heavily drawn upon once before by the United States, in the investigations which led to the creation of the Federal Reserve System; it will prove to be no less valuable in the solution of the present banking problem. A. S. J. Baster is lecturer on economics at the University College of Southwestern England. He was formerly on the staff of the Barclays Bank in London. He is author of "The Imperial Banks" and "International Banks." Of course, no one tould impute all the virtues which a banking gystem may possess to the legal frametork in which it operates, or to the degree of direct control which the state exercises over it. In Canada this control is confined to the rights of inspection of the recently appointed InspectorGeneral of Banks; in England it is completely absent. A significant point is that in neither case does the lat prescribe a fixed ratio of cash against deposits. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: ANNUAL REPORT ON BANKS OF DEPObIT & Discomfit, ETC.-N.Y. 1933 Page 10 (Recommendations for amendinf the Bunking Law) * * * In submitting the foregoing recommendation, the writer does not wish to foreclose consideration of branch banking on a more restrictA basie. Considerable sup)ort has recently been apparent for an amendment which would permit branch banking within so-called banking or trade areae. The writer desires to make it clear that in his opinion the adoption of such a plan would be extremely helpful and a step forward, provided proper consideretion is given to centers of trade and population in creating such areas or districts within the State. 1 1 Under the Banking Act of 1933, national banks are authorized to maintain branch offices, provided the states in which they are located grant such privilogges to state institutions. In other words, the Congress of the United States hes given its approval to branch banking but out of respect to the various states, has refrained from permitting national banks to exercise such authority except in those states which have also approved the principle for their own institutions. It is fair to assume, however, that if the states decline to adopt the necessary legislation within a reesonable time, that the Congress will go forward with its own plan and prmit nationel baniu, to establish branches without regard to state laws. The insurance of bank deposits is not an enswer to all the banking problems of the United States. The work of strene,thening the basic structure must still go on. In this as in other stktes, there are many banks that cannot afford to hire the neceseary skill to invest their surplus funds safely and with sufficient returns to enable them t- pay operating expenses and remain in business on a profitable basis. Arguments as to whether city or country bankers are the more ethical or competent get us nowhere. The ", facts are that in many communitim.ye have too many banks, while" in_others there are none at all. Branch banking under proper solution- te,o both these problems without in ak supiiiiirdff-uffisrs way jeopardizing the existence of strong, well-managed unit institutions. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: ANNUAL REPORT ON BANKS Oi DEPOEIT & DI6COUN1, FTC.-N.Y. 1955 Page 40 (Bankine Board Resolutions) WHEREAS, It is eenerally recognized that one of the principel weaknesbea of the banking syatem of this countr:y has been the over-establishment and tht competitive establishment as between Facteral and atate authorities of unit bankb, and WaREAb, The potential dangers of the over-establishment of branchea in ani system of branch banking which may be established is equally great, and WHEREAS, It is desirable to have some degree of uniformity in banking practicee and further unification of our credit facilities, and WHLREAL, Congress now hate under consideration a general amendment of the Federal banking laws, now, therefore, be it heaolvid, That this Board memorialize Congress to incorporate in an;y' new legislation with respect to branch banking adequate safeguards against this evil, and furtiler Resolveg, That it is the pease of the Board that such legislation should provide that no national bank or branch theLeof shall be established in an,/ coat.unity aerved by a state bank or trust company without the approval o'titailt .toriptits, if and provided the state will provide by law that no state bank or trust company or oranci, thereof stual bt establisned in any community served by a national bank without the approval of the Federt.1 authoritiis as well No of the proper otate authority, and it is further hes. lved, That we favor the requirement WS soon hS practicable,, of compulsory membership in the Federa.L Reserve System of all V banks and trust companiea of this State. Adopted diarch L3, 1933. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: ANNUAL REPORT ON BANKS OF DEPOSIT & DISCOUNT, ETC.- N.Y. 1933 Page 6_ Another feature of the Banking Act of 1953, which is very distinctly a step forward, is the authorization of branch banking wherever state laws extend such rights to state institutions. The responsibility now rests with the states to determine to whnt extent branch banking shall be allowed to develop throughout the nation. In the case of our own state, we must recognize that changed economic conditions have greatly reduced the legitimate demand for commercial bank credit by local merchants and industries in rural communities and small cities. This condition has forced institutions to seek investments in unfamiliar fields with the hope of realizing an income that will permit profitable operation. The answer to this problem and to a large extent to the problem of inadequate bank capital lies in the demiopqwent of a sensible form of branch banking. Elsewhere in this report, the writer therefore renews his recommendation for the enactment of a law which will authorize branch banking in this state. Page 9 (Recommendations for amending the Banking Law) 1. Branch Banking In the opinion of the writer, as recommended last year, the law should be amended to permit banks and trust companies to establish branch offices anywhere in the counties in which their principal offices are located and in adjoining counties; and to permit banks and trust companies having capital and surplus funds of $25,000,000 or more to establish branch offices in any city or village in the State; prov4ed, however, that no such branch offices should be authorized to7established in cities or villages already served by banking facilities, except through the process of assuming the business and relationships of existing institutions or institutions in liquidation. In all cases the opening of branch offices should be permitted only upon the approval of the Superintendent and the Banking Board. 14. Branch Offices for Savings Banks Savings banks, with the approval of the Superintendent and the Banking Board, should be permitted to maintain deposit and withdrawal stations within county limits; and have the privilege of establishing branches in the county in which their principal offices Eq-e located, and adJoining counties if and when similar power is https://fraser.stlouisfed.org :iven to baftks and trust colu anie Federal Reserve Bank of St. Louis 2Annual report on Banks of Deposit & Discount,etc. - N.Y. 1933 Pages 14-15 Continuing its policy of encouraging consolidations of savings banks, the department has approved three mergers during the past year, making a total of fourteen for the past four years. We are convinced that this policy should be furthered at every opportunity, with the ultimate purpose of reducing the number of savings banks to the point where each of the morlpopulous sections of the State will be served by a few well-managed institutions. Fewer savings banks will undoubtedly result in better management and should insure more adequate earnings for those which remain. Moreover, by eliminating unprofitable units, the entire systeo will be strengthened and the cost of providing savings bank service to the public will be reduced. Page 27 BRANCH BANKING PROBLEMS The Federal Banking Act of 1933 contains numerous provisions regarding the possible extension of branch banking throughout the various states. Inasmuch as the Federal statutes are applicable only in the case of affirmative legislation by State authorities, the Banking Board has made no definite decision regarding necessities in this State. But the Board has been concerned lest Federal legislation be employed at some future time in such a way as to exaggerate some of the evils variously experienced in other states proceeding from failure to regulate closely the extension of this type of banking. It has been recognized in particular that no competition between state and national authorities should be encouraged which might lead to the chartering of uneconomic units. In line with this thought the Board, at its meeting of March 23, approved a resolution containing the following: 11j( /v /// "RESOLVED, That this Board memorialize Congress to incorporate in any new legislation with respect to branch banking adequate safeguards against this evil (over-establishment of branches) and further "RESOLVED, That it is the sense of the Board that such legislation should provide that no national bank or branch thereof shall be established in any community served by a state bank or trust company without the approval of state authorities, if and provided the state will provide by law that no state bank or trust company or branch thereof shall be established in any community served by a nationgfibank without the approval of the Federal authorities as well as7the proper state authorities." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 3- Annual report on Banks of Deposit & Discount, etc.- N.Y. 1933 Page 41 (Banking Board Resolutions) 25. RESOLVED, That the provisions of subdivision 2 of section 245 or any other sections of the Banking Law shall not be deemed to prohibit, and savings banks are hereby authorized in the discretion of the Superintendent of Banks to maintain offices anywhere in the State of New York for the limited purpose of facilitating the supervision and conservation of real estate assets which they hold or in which they are interested as investors. t// Adopted May 11, 1933. Page 77 (Proposals for Amendment to the Banking La% which Failed of Enactment) Senate Int. 74 Senate Print 74 Proposed to amend Section 245 of the Banking Law to permit savings banks to establish deposit and withdrawal stations Aithin county limits. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: THE TARHEEL BANKER - N.C. BANKERS ASSOCIATION PROCEEDINGS October 1953 Report of the Secretary - Paul P. trown - LEGISLATION Another bill (H.B. 1317) provides that banks organized under the Aycock bill with a capital stock of t1,000,000 or more may operate as many branches in the state as the Commissioner of banks may permit without requiring separate capital for each branch, provided the parent institution maintains its capital stock and surplus in the ratio of one to ten of its deposits. Another bill (H.B. 1642) intended to place banking facilities in certain sections, at present without banks, was introduced as a local measure applying only to Guilford County and to Spring Hope in Nash County. This bill was passed as a local measure after similar bills of state-wide application had been reported unfavorably. The first depository under this bill has been established in Greensboro and is now in operation. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: TU TARHEEL BANKER - N.C. Bankers Association Proceedings October 1935 YOUR CUSTOMERS AND YOUR BANK - by Dr. Harold Stonier, National Educational Director A.I.B. PRROS 56-57 *** * * ** * * But people do not sense the stability of American banking. They see only its record of failure. They do not realise that failure in America is a corollary to our speed. We have had k,000 business failure a month in America for the past ten years, and yet we have over 2,000,000 solvent concerns. This is a big country. As Woodrow Wilson once said, "No one mind can comprehend the United States of Americo." When people say, "Well, look at the British eyatea, that is what we should have", they do not realise that we had the British system of banking in this country for forty years. We had it by law. We killed it by law. We didn't want it. At one time we had branches of one bank ranting from New Tork to New Orleans. We had a strong centralised control in the money center of the country. That bank exercised supervision indirectly over every issuance of every other bank in the United States. Yet, we did away with it. We didn't want the British banking system. Why? I think there was a good reason for it. I think that Am:erica would not have L,/ developed as it has developed west of Pittsburgh or south of Washington, D.C., if we had continued with the British banking listem in the United Staten. We wanted quick, rapid, accelerated development of the natural resources of this country, and I believe we would not have secured it had we not evolved the banking system under via Anerica has been operating. Don't let people tell you that the American banking system hes not improved. In 1860 we had sixteen hundred different kinds of money in the United States. We had the most elaborate, intricate, and at the same time probably the weakest financial system we have ever hed. Since then we have evolved a banking system which can still be improved, but improved not so much by law until the custoa and economic objectives of our people are changed. We Americans are gamblers. The British gamble only on horae racee. We gemble in the stock market, the real estate market, the wheat market, the cotton market. We gamble in a way that affects the economic cycle. The average Britisher does not. We want a flexible, accessible banking system. The Inglishman wants his banking system to be inflexible, conservative. The British system never would have worked in America. After all, if we have any critioisa of the banking system of America, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis The Tarheel Banker - Oct. 1933 Dr, Harold Stonier ?twee 6B-37 (contd.) it is the same criticism that we can direct against America herself. If we are ashamed of our banking system, *e have the same right to be :shamed of our country. We have the largest number of banks over 100 years of age of any country in the world. We hcxe the largest number of banks over 50 years of age of 6ny countr, in the world--banks which have gone through things, which are seasoned institutione. We have thousands of others just as liquid, just hki stable as they .3re, which have been serving the American public well for sharter pekiods of tine. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Address by L. A. Andrew. State Bank Commissioner of Iowa, 37th Annual Convention, Indiana Bankers Asso., June 1935 (The Hoosier Banker, July 1933) "Let us consider for a few minutes the statement repeatedly made that the unit country bank has been a failure. It is conceded that a large number of small unit banks thruughout the counLry have been obliged to close, because as we have said, their customers could not pay their obligations on account of a world-wide depression. Let us look at the official figures for 1931. Total banks closed in that year were 2,316. Banks under one million dollars in resources total 1,890, and banks of over one million dollars in resources number 426. These banks had total deposits of .1,814,000,000.00. However, banks under a million dollars in resources have had only t396,237,000.°0 of deposits, while banks over one million dollars had $1,417,798,000.00. In 1032 the record was practically the same. Banks with deposits over a million dollars each accounted for 77 per cent. of the total deposit liability. In 1930 the record was even worse, as nearly half the deposits in closed banks for that year were found in tto organizations, one a branch bank in New York and the other a group in Kentucky. In the face of these official records we have been continually told that banks with less than $50,000.00 capital and in towns of 10,000 and less were really the cause of the depression and had caused all the bank trouble. This has been repeated so many tiaes that a great many neople believe it. The offidal figures show this propaganda to be absolutely untrue. "It is also said that we must have branch banking in order to provide safety. The official records for the pist two years show seventeen banks with 5C7 branches have closed with $1,612,188,000.00 in deposits. If that is large branch hankinE safety, the record is certainly decidedly worse than unit banking. The official records for Federal Reserve member and non-member banks is eoually interesting. In 1932, for 1,125 non-member banks and 331 member banks, nearly the same proportion is shown, the deposits of the member banks were over one-half of the deposits of non-member banks, the figures being $269,000,000.00 for member banks and $446,000,000.00 for non-member banks." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ****** ** "The Future of American Banking" - Address by A. A. Berle, Jr., Professor of Cornoration Finance at Columbia University 40th Annual Convention, New York State Bankers Asso., June 1933 * * Opposition to chain banking is still so great that we shall not have it. Indeed I question whether, at the moment, there is any group in the country able to assume the responsibilities that go with national chain banking. We have, therefore, the great refuge that has been supplied in England, Canada and Australia left on one side. Vwe have to travel some other course. Hence it becomes necessary to think still more deeply to see what we really want. The first thing we want, I think, is to arrive at a situation in which every unit is financially as strong as every other unit--to arrive at a point where there never is any sense in a run on the X Bank so that the money may then be deposited at the Y Bank, because so far as safety is concerned, the X Bank and the Y Bank are equally safe. Next, we want in aubstance a cessation of comnetitive banking either in connection with deposits or in connection with credit. Competitive credit you know all about; also competitive deposits. We all do compete. We have to. It is our job. But is not good banking, it is not sound economics, it is not common sense. Further, and here if heterodox I am unrepentant, we want a cessation of the condition which permits the control of banks to be thrown around from hand to hand with entire irresponsibility. You will be perfectly familiar with that feeling when some day you discover that the "control" of your bank, the controlling stockholders, are negotiating for the sale of a dominant stock interest to a chain company or a holding company whose policies may be quite different. You know exactly what that means to you, to the credit of the bank, to.the community. Or maybe you don't know exactly, but you have every reason to wonder. I say this with entire knowledge of the fact that many of the great holding companies are managing their banks extremely well, have even contributed, in some instances, a great deal of strength. But whole states could bring damning testimony to the contrary; ask any one in the Tennessee Valley. You are perfectly familiar with what it means if a bank which has remained in responsible hands for years is left to the hazards of the market because one or two men die, their heirs are compelled to sell, and some manipulator, who has contrived to get control of an insurance company or a couple of holding companies, uses their funds to acauire control of the bank to further some other activity. I have seen one of New York's oldest and finest banks pass out by that route. It is not a healthy situation. We have met it to some extent by an expedient which may have been better, but which has no great argument to be made for it: that of hasty absorption of banks by other banks; hence, the shotgun mergers with which you are familiar, and the desperate way in which certain interests, when the control of their bank threatened to go to one set of hands, fled to other and stronger hands. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Address of Willis H. Sargent, Chairman, Committee on Banks of the Assembly of New York State 40th Annual Convention, New York State Bankers Asso., June 1933 **** **** Gradually, however, the public will appreciate that for the most part the bankers of this state have shown fortitude, courage, and intelligence, and if there have been any serious mistakes--as I am going to speak to you in a moment--they haven't come, in my opinion, from the small, independent bankers. The trouble has come from other sources, partly, inevitably, because of the economic situation in which v‘e find ourselves, and partly because of what some of the big banks have done to the smaller banks, and I will touch upon that in a minute when I talk about branch banking. ******** Today we are permitted to have in this state, as you know, a chain of banks such as is represented by the Marine Midland. Now the difficulty of that situation from their viewpoint is that each institution is a unit, and while through the holding of stock in those units there is a power and a responsibility granted which can permit the transfer of funds from one bank to another to meet seasonal demands, and while it gives a greater nobility of resources, it does not give, by any means, the same degree of mobility and strategic position which there would be if all these institutions were branches of one great big institution. I presume, too, that their argument is entirely sound, that, if you have branch banking, as you have in Canada, for example, there cannot be a *great profit made by the few and failure by others. So it tends to become what we might call a leveling process. It does the same thing in the banking field that the Industrial Recovery Bill does so far as business is concerned--it regiments to a certain extent the banks. It would mean, I presume, that there would be less failures and certainly there would be fewer banks. It is a kind of bill which all institutions, which have developed to a point where they no longer are interested in private initiative which comes from individual effort, have adopted. It is the kind of system which comes when a country is no lorwer young, but has reached middle age. And the question comes before us in a two-fold manner: Have we, we ask ourselves, reached a point where we are in middle age? I am inclined to think that America is reaching now the end of her youth and the beginning of her middle age, and middle age means the tine when you must begin to conserve what you have. You can no longer recklessly go on living without any regard for the future just because youth is there and will build you up again. To-day, America, in probably both a banking and an industrial sense, has reached the point where she has to begin seriously to conserve, where she has to make some sacrifice of individual effort for security and stability. In other words, security is to be stressed and risk is to be lessened. Therefore I come to that conclusion somewhat reluctantly, but having come to it, I say if branch banking comes and I personally believe that it soon will come, we arrive at the second question--in what form should it come? https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis _ 9 • Now the three proposals, in a nutshell, which we have had before us for some years and which came to a head this year, are, first, that there should be branch banking on a county-wide or adjacent county basis. For example, Erie wants to have not alone branch banking for Erie, but for Niagara County which is right next door and is intimately connected with Erie County in banking matters. Then there is the other extreme which is state-wide branch banking. under that suggestion, if we permitted branches anywhere, a New is, That could come up to Erie and take over institutions. It institution York other place in the state and take over institutions. any to could come The third proposition is what might be called regional branch banking, that is, branch banking where you divide the state into certain natural, geoFfraphically defined trade areas, and you thereby allow branch banking for those particular areas within themselves. Now my mind is entirely open on this subject, but I am inclined to think that probably that has the best chance of any of being adopted as a permanent policy. Of course, the smallest step would be county-wide branch banking, but if you do that, you tend to impede to a certain extent a natural development which might come about if you had regional or trade area branch banking. All of these plans provide, naturally, for the consent of the Banking Department before a branch can be obtained, and that, of course, must necessarily be a provision of any bill. Third, no way has been worked out except through the enforcement of the Department, whereby you can protect those small banks which are going to be in the same community with those that are taken by the big banks. In other words, we know that the competition, which can be given by a well run branch of a large institution with its far greater resources to meet seasonal demands, with better management, if you please, is going to be hard for the small, limited resourced bank to meet, and there ought to be something worked out whereby these other banks will not be ruined in their particular communities. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: THE CALIFORNIA BANKER—JUNE 1933 CAUSES OF THE RECENT BANKING CRISIS AND §UGGESTIONS FOR THEIR AVOILANCE IN THE FUTURE--by Alden Andersoni'Pres., Capital Nat. Bank, Sacramento Page 259 ****** Build Now for the Future I do not think we can do better than to pattern after the banking system and practices of our Canadian neighbors. Their conditions are very similar to oullown, only not so large. They have proved their worth and stability in the fire of experience and have continued their dividends and added to their surpluses. Their banking practices are logically and economically sound and their methods and ways we should have heretofore adopted without having had to have them show us the example. Admitting that our banks that are now open are sound and capably managed, we still must see that it will not be possible for a condition to develop in the future that could produce a repetition of what has happened in the last few years. If we do not do it, because bank services are just as necessary as post-office services, someone else will step in and do it. You know what is going on in Washington V today. * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Report of the Committee on State Legislation 40th Annual Convention, New York State Bankers Asso., June 1933. (Chester R. Dewey, First Citizens Bank & Trust Co., Utica, N.Y.) *********** In his annual report Mr. Joseph A. Broderick, State Superintendent of Banks, recommended two types of branch banking--first, that a bank be permitted to establish branches in its ()van and in adjoining counties by complying with the usual capital requirements, and second, that any bank or trust company having $25,000,000 capital and surplus be permitted to establish branches anywhere within the State. This recommendation was incorporated in a bill introduced by Senator McCall, Chairman of the Senate Committee on Banks. Mr. Robinson of the Assembly Committee on Banks introduced a bill in substantially the same form sponsored by him in previous years, providing for county-wide branch banking. Mr. Moffatt, of the Assembly Committee on Banks, introduced a bill providing for branch banking within any one of the eight Banking Distrj_cts into which the State was to be divided. After full consideration of these various proposals your Committee decided not to approve tny of these bills, but recommended the adoption of a bill, as outlined in the report submitted January 20, providing-1. That no such branch office may be established except through the process of taking over sode existing institution or ..an tV -a—that institution that :nay hereaftei-& closed, or excel branches may be opened in towns or localities not presently served by existing banking institutions. 2. That no such branch be established except with the consent of the Superintendent of Banks and the Banking Board. 3. That the capital of every bank or trust company having branches shall at no time be less than the aggregate minimum capital required by law for the establishment of an equal aumber of trust companies situated in the various places where such bank or trust company and its branches are situated. * ** * ******* * * * * * * Proponents and opponents of branch banking appeared at the hearing before the Assembly Committee on Banks and presented their respective arguments. The Committee decided not to report any of the bills, feeling that the entire question should receive further study in the light of probable enactment of the Glass Bill at Washington. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** *** * *** * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 121. CAGI2, 1-10R.1373T \i/ DR7173MBIS 1.1t. SOLOLION v BLAT.'21:721V FILE: Study / • "New State Banking Laws" - by 0. W. Lundsten Proceedings of 44th Annual Convention of Minnesota Bankers Asso. - June 1955 (In: Commercial West, June 24, 1955) ******** Other bills defeated are as follows: A bill creating a state owned bank, a measure eliminating life sentence for bank robbers, various bills attempting to permit branch banking in this state, either state-wide or of a limited character. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * ****** Unit or Independent Banking Committee of Minn. B. A. Proceedings of 44th Annual Convention of Minnesota Bankers Asso. - June 1933 (In: Commercial West, June 24, 1933) ********** In view of the fact that branch bank legislation was being considered both by our state legislature and Federal government, your committee felt it its duty to send out a questionnaire to find out how the different bankers of the state stood on this question. A questionnaire was sent to every banker of the state and the largest portion of these questionnaires were returned. Upon carefully checking the returns we found that an overwhelming majority of the unit and independent banks were opposed to branch banking in any form. Inasmuch as this committee was to work in the interest of the unit banks we felt it our duty to use our influence to oppose branch bank legislation. Consequently, telegrams were sent to the senators and representatives in Congress in opposition to the Glass bill and which bill lost in the House of Representatives. Members of your committee also appeared at two hearings in St. Paul, one being to favor the bill memorializing Congress to oppose branch banking in any state that did not permit branch banking under its own laws. The other was a committee hearing of the bill introduced in our state legislature for state-wide branch banking. This bill also was defeated. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • "The Branch Banking Problem as Affected by the Glass Bill - The Problem in New York State" Address by Dr. Benjamin M. Anderson, Jr., Economist of The Chase National Bank of N. Y. 40th Annual Convention, New York State Bankers Asso., June 1935 ( The Glass Bill, with its derosit guaranty provisions, has undoubtedly necessitated a great modification of views with respect to the desirability and even the necessity of e very widespread extension of branch banking in the United States. It can be urged with great force that, if the banks in tl'e financial centers are to be responsible for the deposits of banks all over the country, they should also be responsible for management and policies, and this consideration would involve a very widespread application of branch banking indeed. On the other hand, the desirability of preserving local financial independence in a country as great as ours is very real. Yoreover, itls certain that a sudden, sweeping transformation of our system would involve a great many difficulties and undesirable consequences. ********** I do not think that one uniform type of legislation will do for all the States. In some States, it is probably desirable that there should be immediate provision for Statewide branch banking. It is possible that there are some States, where banking capital is very scarce, which might even be well advised to consider the admission of branches from strong institutions from other States. What I have to say here, however, relates to what is desirable in the State of New York. V' ' In New York State, Te have, of course, the immense financial resources of New York City, and, outside New York City, we have a number of very strong financial centers, particularly in the region stretching across the State from Albany to Buffalo. What should we do in New York? I am of the opinion that it would not be desirable, in the immediate future certainly, to have the great banks of New York City engage in a competitive struggle for the purchase of the large, well-managed banks of the large cities of the State outside New York City. On the other hand, I think it very desirable that the great banks of New York City and the great banks in other important cities in New York should be empowered and encouraged to reach out into smaller places, under the supervision of the State banking authorities and the office of the Comptroller of the Currency, and to take linder the protection of their adequate capital an important number of solvent but weaker banks in smaller places. This should be done under terms and conditions approved by the Comptroller or the State Banking Department, with due consideration for local interests, as well as for the interests of the banks in the financial centers. I should not wish the legislation to permit the establishment of new branches in competition with existing institutions in the smaller places, as this would aggravate the difficulties of the situation rather than help them, the only exception being that, if a community has no bank at all, a branch of a bank in a great city might https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2 te in New York prowell be placed there. Instead, therefore, of a statu ng, I should think that the viding for unqualified Statewide branch banki We shoulLkermit_banks of legislation might take the following form: hes in any part of the State, qpi.tain minimum capital to establish branc ation, the maximum being set low in cities of a certain maximum popul York City banks for control of -enough to prevent a competition of New . othei impoitant -fidancial centers in the State t banks of a smaller, but still I think it would be desirable to permi branches, other banks within as over, take substantial, oapitalization to counties. The very small bank in their own county or within two adjoining horse and buggy days, which has very small communities, established in the importance as a result of the lost a great deal of its business and of its lost much of its business to coming of the automobile, which has already if made a branch of a the county seat banks, would be much better off the community would be better strong county seat bank. In not a few cases county seat bank, its assets off if its one small bank were absorbed by the the office closed and liabilities transferred to the county seat and it might remain open one entirely. And there are other cases still where msking cash disburse,ents or two days a week for receiving deposits and for of its business transfor local convenience, with, however, the main body ferred to the main office in the county seat. than as definite proI present these ideas as suggestions, rather be considered anew in posals. The whole subject of branch banking must vies of the new legislation at Washington. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "The Future of American Banking" - Address by A. A. Berle, Jr., Profesaor of Corporation Finance at Columbia University 40th Annual Convention, ger York State Bankers Asso., June 1933 But if you will check back, you will remember that the aggregate of the interests thus at ha%ard is the aggregate monetary supply of the country and that the interest in it is fundamentally national. One can only join the trained Europeans in wondering hor long this kind of system can exist. So I think that aur third desideratum has to be some method of arranging that the control of banks shall be permanently lodged in permanently responaible hands. We must oust the theory which we held not so long ago and which is likely to occur again, that we can play with control of banks as in older days control of railroads was played with, with resulting disaster, as to-day the public utilities are being played with, and as some of the great chains which are already in difficulties were played with. It cannot go on, nor is any one going to allow it to go on. got because there is anythine morally wrong with private ownership, but because responsible ownership flickering into irresponsible ownership and peculiarly into corporate ownership forms a fundamentally unsafe base on which to build the monetary eupply of the country. I h3ve my own reeling as to how that ought to be done, but that is so entirely personal with me that I almost hesitate to auggeat it. The financial ownership in which this country has the greatest confidence is probably thP mutualized ownership of the great eav'ngs banks and of the great insurance companies. PurP mutualization of national and state banks is perhaas not practicable, so that a change in that direction would have to take some other form. But the result could be attained. Control of bank stocka and the sale of bank stocks ought not to be trusted to the hazards of the market, or the stock exchange, but ought to be in the hands of the central authorities in each district, that is to Say, in the hands of the Federal Reserve Banks of the district. There are many ways in which that might be done. It might be done under complete ownership which would effect a virtual mutualization, or it uight be done less drastically under methods which would provide a more elastic form of the same thing. This, or soaething like it, is going to be demanded. As listen to my friends in the outlying parts of the country who come in with their ideas of banking, it is very plain that they have no desire to let the situation rest where it is now. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • George V. McLaughlin, President, Brooklyn Trust Company, Brooklyn, N. Y. 40th Annual Convention, New York State Bankers Asso., June 1933. ******** * * * * * * However, I am not, at the present time, in favor of state—wide branch banking. I am, however, in favor of an extension of the branch banking system and am inclined—to —believe—that It should be confined first tu—trade areas or to the county of the main offiCi—Ehd th-e--twunties. I am satisfied that with the help of—the Siaterintendent of Banks and the data that he has in his possession, we could work out an ideal branch system for this state. I am aure, too, that the present Superintendent of Banks, who gave me my first training not alone in banking but in bank examining, can, in his very diplomatic way, convince the banks outside of the Federal Reserve System that they should join it. It is my opinion that all banks should be Federal Reserve members. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * * -31-* * * • SOURCE: THE MISSISSIPPI BANKER—JUNE 1955 PREEMIENT*6 ANNUAL ALM:ZS, Before tne aississi ppi Bankers CouveMtiom May a, 1953, at Jackson, MiSsissippi, G. U. Pres. Pages .5.4 Reformation ot the banking business is an important part in tnis program. There are inportAat and responsi ble authorities who advocate unificetion of our banking, syste41, ane stAe wice branch banking. bone of these authorities charge thut the fuel bAnkine system is en importlmt contributing fLetor to the deprustAon. I tic, not believe such a chr.re-: 01.43 be sustained by the facts. The experirtnces of the pest fey; yeara havc reve aled weaknesses in both systems. The 8tate Banking Systems of this country have justified their existence, and the systew should be protected ae it constitutes 4n point of rk,sources by fur the major pert of the bankinc cevitel of thc Abtion. Iturcover, unification can be accomplished thiough membership in the Yederal Reserve 6y6tero with out dostroiag tile dual systen. I Lila firmly convinced that unificat ion of our bankiat resources is nut only desixable Lut roAktcitua r4 tO 1.11,0 future progx%-ss Lnd securit.) af the banking business, and I sincerely believe this Convention should memoralise the Congress to give ample protection toisud preserve tile IntegritT of state banks in say bsnkini legislation tht.t it may consider for the. unification of the nations banking resources. I advocate branch biaakinc limitec, to trd e arecs between fiftz, to one hundred milcs as a meaLna of making safe and adequate banking facilities availaule to communities unable to profitab ly support an independent unit bank. If such system hhd been authorized in Aialdeap pi four years aEo, suet, of our banking difficulties since 1.5i.9 evuld have been avoided. I trust the Bank Study COMWiLia 011 authorised by the last Legislature of Mississippi will provide in it revision of our Walking laws authority to 'same in branch banking restricted to definite trade areas. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • O. Howard Wolfe, Pres., Pa. B. A. Speech - Annual Convention, Pa. B. A., May 1933. Source: The Financial Age, May 1933. *********** State-wide Branch Bankini,UnnecessaTy In order that you may not misunderstand what I am trying to say, let me make it clear that I am by no means persuaded that even so radical a departure frow our present banking methods in Pennsylvania as State-wide branch banking is either desirable or necessary; in fact, I am definitely against such a program. We have often had pointed out to us that during these trying years no bank in Canada has failed, and the inference seems to be that this is because our Northern neighbors operate under a branch banking system. In my judgment the strength of the Canadian banking system lies in other factors than the country-wide branch banking privilege. For example, Canadian banks can make no real estate loans whatever, and we might remind ourselves at this point that it was not until 1913 that national banks in this country were permitted to make such loans. Canadian banks may not make loans against bank stock, either their own or the shares of another bank in Canada. Canadian banks enjoy the advantages of a system of preference claims, which is so widely drawn as to its provisions that it practically amounts to making banks preferred creditors in case of bankruptcy on the part of borrorers. No bank in Canada may be organi7ed with less capital than $500,000, and here incidentally is the reason why branch banking is necessary in that country. Finally, one might refer to the fact that in Canada the matter of changes in legislation is in the hands of the Canadian Bankers Association, who ordinarily are able to agree on what is needed, and changes, if any are deemed necessary, are made regularly every ten years. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ** * * * * * **** Editorial Comment - The garch of Events Journal of the Canadian Bunkers' Asso., April 19Z6 ** * * * * * ** Zap United 5Wtee Battking Crisie X * Preeident Roosevelt himself hat, already* made clear that Ae will call for fundseaentel cuunges in the United States banking system. It has been apparent for many years that there exieted definite etructurel weaknesses • ehich have resulted in inordinate numbers of bunk failures vineuever the country *as subjected to economic pressure. the Federel Reserve System itself constituted a great step forward but taet alone could not remedy the weeknesseL$ of national bank legislation and particu/arly of the State banking syeteme chartered under the most varied lats. Colonel Ayres of the Cleveland Trust Company has pointed out three important weaknesses in the United States baneing systems In the first piece, loans on real estate have proved the undoing of very many banks, and suet loans ought to be curbed, if not prohibited, as they are in eanadian baneing law. In Lae second place, tae twelve Federal Reserve banks loosely joined together by'a Federal Reserve Board, have not proved capable of presenting a united front to the forces of panic and depression. Something 'ill probly 4,ve to be done to give more unity to the Feaeral Reserve Bystem, making eech Federal Reeerve Bank sow:thing close to a brancn of a single central benk. In the third place, there is need for sore unity in the entire bunking structure. Colonel Ayres does not go so far as to suggest specifically branch banking, but there iv no doubt taut tue United Stetes eill have to tuke LA lonc .-,tep torard branch banking if it is LID strengthen its badly veakened systen. One muat remember, of course, that to convert a united bunking syem into a branch bunking system in a short space of tine is an exceedingly difficult process ana one fraught with the oTatest danger; mere Kmendment of the banking lee, permitting widespread branch banking, rould probeoly =loom, an orgy of competitive speculation in bank purchases waich would further weaken the system. Probably a system of branch banking within each Federal Reserve district, lith authority given to some public bogy to approve not oaly all bank azalgamatione, but also the terns on which banks might be purceased and absorbed by others, 'ill be I Litocessery. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * * * * * ** r• SPriviary Steps for Banking Reform' W. Lamont, of J. P. Morgan & Co. Paper presented at the meeting of the Academy of Political Beismoo„ Juuary, 193S. Ofteseedisgo of the Academy of Political Science, Vol. XV) * * * * * Today in the Federal Reserve System we have a thoroughlg scientifie and sound foundation. But the System's scope is not yet breed enough, and the ills which the oommonity has mirrored in the 3Jiet three years show clearly enough how mmOb still remains to he remedied. * * * * * Tot whnt aur average citisen very naturally fails to wiriort. steed is why, if the Fe1eml Meer,* has such manifest virtnee, it is unable to prevent the terrific crop of basking ftilures which the ovum*, ham witnessed la the last decade—and especially in the last two year*. * *** * Figures of Bank Failures im that ported (1M-1931) there have been total bemk failures aggregatiag 9,1101, with deposits thus tied up er la part dissipated ef 04,278,000,000. Of this total only 1,800 banks were members of the /Wesel Reserve ani almost four and a half times as many, namely 7,07 bulks, wore outside the *viten. In the years loso-195.1 ales* the bask failures totaled 3,643, and here again the proportion of nowlmember to smOber beaks was almost as four smd a half to ass. It ehould he added that the most of theft, fiailures were of small tanks with extra*, limited oarital. Therefore olio should not be mislecl thee, filmes, bad as they are into *Waft thflt more thee a small pereentage of the oountres banking resemrees was elm. tied up in failure. empervielon which the Federal Icocrve Banks are able •* * * * to exercise over usher banks is of oourse limited. But over memsmember balks the Federal Reserve has mo control ihateoever. These mempomember Ussike are without exception state institutions, subject to greatly verytag degrees and kinds of legislative requirements and of administrative espervisiemo So that it is no wonder that objective students of ear busking system are bewildered and declare it--despite the existemee of the Federal leseree--to be no system at all. ••* *•It is a noteworthy fact that, in number, ninety per cent of the beaks Whisk failed in the deem& of 1921-19Z0 were located in rural semmmaities, subject to all this vicissitudes of crop failures, or of the empansicm mad deflation of business *boonsi" without any of the proteettea afforded tir a parent institution fortified with ample capital and memaged 11, emperiemeed mem. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis p!he Question of Brandh-Banking * *•*•*•• Almost all the failures early this year of small auborbes books around Weep* sod almost all the resultant throats to the goeseel booking situ., time, weld have been avoided if it hod met boon for the ?act that the Illinois statutes permit me trench-booking of any kind within the limits ef the state, It W60 quite impomdbilesmider the law tor the large Mileage basks te attempt le serve, through limeashes. the important sebarbs around lbe eity. The lessees of smihasitnatissi most be glaringly obvious te snoosssrul ohaisAanking the 'hole esmatry. Despite the develeposat in a few smattered isetesseso there is no present effective method 'under the law by which stress institutioas in our looding finaneial centres sea extend the benefit of their emple reserves, their experience and ordinarily *area management to lbe weeker books in tho out4ing district.. itripweloe Different Sets ef Laws Our chief liffleolty, thee, as must be seen, has clearly been, aot leek of aors extended state amstrol, but rather failure of orgosisation Tnti seordinatima. I hove alresit, spokes of the confusion reselling free our varying Moral amd state tmoblog laws. is banking. mar seastry has fortp-mine different sevarelgos. Ando as saor persons lenis *so pointed onto a seselost state of osupstltieu exists belossa the Oompliroller of the Carrels, al lashiugtes mod the forty-4044 Denkieg ilaporintonrients states. Meek one of these fortponine officials is ef our desirous Jo m* geM, lost1tutiens es peseible registered under his is tbs.% beemoms et this emspetitiono emosequerbee !he jurisdiction. laxity creep. in. The oonpetities as smog the vi,rious systole has net boss soh as to make banking requirements sere waservNtive but to stoke then awe liberal. A promotion not of hotter banking but of pourer bunking Imo bona the inevitable result. This warm:titles hue met only foiled en. preemies in liberalisation ef the respective legislative requirements geversiag the various benkiag systoles, but it has also resulted, as I say. to adetaistrolive laxitY La granting charters and in providing adequate sopervisiaa of the ooaduet of banks, Thousands of Walks Lack Proper itafestards As te DOthOde of aortae our troubles, Ouldiniss see spend hundreds dollars in see hearings and publish volumes of toetinews of thousands But it seed hew ne bop. of ever smaing to the rest ef the evil until it realises that se bankisg opts' emus foassidea adequately when it essersheods within it ea4 a limited portion of the bookie' oomsmaity. sloAr per oust Jo somber of the country's basks are eutsile the aftivai Mersa. Beeerve Wilsey amd this sixty per east comprises a https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis r total in benkimaseesseess of over $12,000,000,000. Thew lesser lembing institutions—whose segregate resources ::re nevertheless so eemmidersible-sr* unuhle or unwilling to con* tinier the rules of the Federal Swerve System. Thus thew lash its restrictions and its safegmards6 And the almest unbridled license Shish these small basks in sae Astern apparently bave outside the Fedortl Users, System tempts tbem Freimently, (is the sod sword has proved, to folly sad disaster* The fact is that, despite the meloscholy MOW of eliminations thst hove taken ;Assert the coustry has today far tee seer beaks* Our basking emits should en the average be tar larger than they are today* The small, ill-capitalised institutions 'bead be merged so as te gain the morsel stability, diversity, economy emd sessgemeet of the larger oonceras* One reason for the Teak:mess of tbe smell interior teak is that its overhead expemses are proportionately liss bossy. The benk is tempted te per tee high rates of interest im order te attract deposits* These little looal tellbe have, because of tics rapid gemwOh ef business units, ef cosinsmisatiosa sad of motor treespeit* bees left in a baCkester *ere the better lousiness passes them Iv* limes up-eoustry institutions have no opportunity te diversify sod overage their risks* If geseral emaditions affect their isvesteemts umfavor&b4, the same senditiems are likely to Involve thea in swims looses from their lemallsed lemma, sod at the sees time disastrous depeeit withdrawals. Memeaver, fir lie monY of these 'elk and mosholtered. interior banks b:ve teem salvaged by Inezperiemeed persons desiring tbe satisfaction of beaming 'bankers*. Tee Vital Change& teeeemary I Ingest whet sem, others tome already pointed ant, namely, that no thoreugh-going banking referee ean be brought about until tro vital ohanges have been ansempliShed. The first is to bring sll the commends' hanky of the comstry, small re 'ell Se large, unier the single tegis of the Federal Deserve System* The seemed is to emtablidt seeable provisioes for regional trenebAosking. the seepaPhies1 limits fur each segios to be earefully esslied set end revisited* ?ben se should have semo!thing worth taIkieg abeet* Slosh retorms, beseght about gradually, ought to begin te yield to the country some measure et bankinc There are mamy Osseo of the basal% situation that of opuses have met ettemptei to tomb mem* Ares even this brief review, besever. It meet lie apparent thet the develepmemt of bunking in America has been a podia pr040110 of evolution Aid' has by nemeses seedbed ite sed6 Seeh of the bedding arises to whidi I have allmded has Immght the oes, aunty some ome Imesem, but este new diaastor ales revealed a fresh webmess to be remedied* rudest, beeking development ia this emantry has bees a slow sad paisfv1 grafts 1110 Pilgries mores* mall have bees mere arduous or beset with greater pitfalls* The ?rust tbat is Sepeeed Um Prevost System The preposition to bring sll the comacreial honk* of Ue country into thcs 'wawa" Reserve System has sameidmes been opposed ou the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis " 4 4 0 - -4:••••tE 111 d t W 4 p 06 t4 , /f ... 4 allegation that the System had already proved itself to he allow Trust', amd that its eathority ghoul& be curtailed rather thaw ectended• As to mak eriticism it -my ho fair to point out that, if the System bed astually proved itself to bo anything in the mature of a money trust, it ems eorm. taialy a bomewolent sod eseperative awl for the record Shish / have ousted shows that *visitors ia the beaks mid trurt companies that sere members ef the System were smeeneusly benseited VI such membership; amd that sithin the aystemo.eith Ito save cod asfegoarde.they sejspediamperetive tammeity fres diftlaulty ea asopsred with lepositere in the beeklagusits AAA had railed to table advantage of its stremgth. lho object of basking legislatiee is not to give aimentages te, or to impels* penalties upon, basks or beakers. it is to provide the psblie Igo we mow and credit, and sato dspoeitaries of their fends* im the modems world bank cheeks drama against bask deTosits eirsulatet as sew, emd the gold rtrerves of Ike Podsral lemerre Banks or* the bass ups. *IA feet not only the ?edema lessees wigs issued rir the Todesal le. mom Monks, but the *vette of the mentor books sod of memomember blithe as well, also the Cheeks that cirsulate against thee* de °sites Aftmr the Civil war, state beak motes, which had had euth a deplorablo reamed of repudiation, sere taxed out of calstemee sad uatismal bank notes sih. stiteted is our currency system* ?he reform lee tesemplets, boom,* it dealt say with ame side of the beues fenstisa„ the note-issuing pews?. It iid not deal with the other side of the bunking Fiction, the power to receive depeelts Shish circulate in the fere 0." cheeks end will*, as I say, are supported upon the some gold bass held by the Federal leserve Soaks. We muot some to regard a banking *tarter not ea s privilege ous. rowed upon a 'hoses few, armrest an unseleeted many, in order that they "say wake sow with other people's money; belt ss a public trust, sod im that *onset sod ia that *ease only, as a meow trust% It is the plats duty of the semmmaity to see to it that the interest of the AMONUMB people in the safety of their deporlts, sled elf the viols sosiOry in the saffisiemoy and seandmase of our bookies system, sheeld be pet before the spesial interest or spy beak sr bomber, great or small% The Olsen of the Federal Isseres lystem The hope for towards reel orderlimees and stability lies, as it always dope In matters, ta en aremeed asd intelligent public spinier", and tu constant stutty imir the experts of methods to strengthen the Morel Reserve apotes. No mem or intelligemes„ etude's* llos eeesal werkinrs of this *stew, sea haw* foiled to be impressed siOk the Immeasurable boseito *lib it has buseght to Amorists bolostsir ess. merge* It is hard. tee, to see koo ibo lammenssint scold over Moe serried ea its war amd pest•ear fissmame sithopt tbo sow System. Without it, iaflatioe es en almost disesteems seals (witmess the ememples or the Serepean sountrios) might well hewer been resorted to. To the midst of the distress through Shish portions of the honking esmommit, hews been passing in these last few years, tbe semotrostiv* soospAillo. sem,. of our irederial %serve asaks may. have been semmihnt lest AIM See Yet without the resource. mad 'he prudent, tarsightodtbasoutog of these tostitsilsmo suer plight would ham loss inealculably worse them it hms bees* All twelve ef them have bees like isles of safety, basioro nidst of a violist storm% verso is https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 5of the Pederhl Reserve System Lot es !visit out see reemst development 110 te February of lgrf, ance. e of import immens proved that hes already n powers tb4t it seeded to ism, certai the ludo" d, loehe the Spites still c and cable* Sea peers elasti mere practi s smile reader it. SWOP of GP eed. ?hese. the peoese have ies aligre *vestr ether ef hooks the central in 19!P, early seeselbet law, mll pealed 4teeg elase the of provisions 14 leder those sd the ve !scar 1101441 l l000r poseid Federa gore rovers eimilsr the System now hae the eathority to buttroso the credit situation 'here there is the motes* see& Already these extended peelers have asabiell System te lighten immeasurably the burdens of the communitrs Aided by the previsiems of this Act the ?eland leeerwe Smoke bees nor the last six seethe been pureeing with wisdom emd viper a se-eallot opsa narket policy, *Ma hes already proved itself te be a pest noses, le arreetlog the hiledleme deflation of credit and pri000 thish was beesnies se disestreee6 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * *** * * * * * 10The Straeture of the Banking *Mime, I* Pierre Jay, Chairmen, Fiduciary Trust Oe• of N. T. Paper promoted at the mooting of the Academy of Political Baiones4 Januery, 1935. (Proceedings of tho Academy of Political Science, Vol. IV) ** ** * * ** Over ovary individual bank steads a smpervisis$ national or state, to madosvor to eaters, the law and sorriest shusmo. amok of the entire structure steed* the Federal Seeerve System, a eeeperative organisation of the amber basket te provide currency and a seams of rediscounting paper, sod authorised to exorcise oertain rights et supervision over its ambers. * * * * *• • • Calm* of Tabu*. 'tom the host imformatiom obtainable concerning Oho bank failures of this oleinsorear pe1104, two immoral observations new be me -les First, the vast majority of them were due to aismonagomemt reflected principally in over-lending, in exploitation by offioers and direeters and in same disregard of legal restrictions. The present amsemis dspoossism, followiag closely am thA of 1920-11, has, of course, hod on importmat in"lsonso, and the great reduction of all values has sendirod basktng difficult fee every bank. But the supportive emit homkimg ossno4 point to the depression as em alibi, sines thousands of sepahlr assaged hmoks im all parts of the SSOntry hsve 0600d its strain and remained etromg amd selii. Nor doss depreciation in hood valve* appear to have boon am imperUnt element is actual failures except there inferior securities had beem purshasod for their high yield, vekrtieularly by banks paying high interest rates for savings Upsets. Ths second observation is that about 80 per font of the failures were thoea of very small local honks. having loans and investments of loos than $500,000 sash. Banks so small as this are relatively ex, peasive to operate, their profits ars negligible. They cannot pay for snporiemsed mousgsment, even if it vire leeally available* Moreover, ostcmobiles, psi sles_da and the gmnarel tendency towards business 00*castration are adding to their diffisaltios by taking banking business to larger please, If mismanagement was the primaipal sense of failures, it seems fair that the failure of honk ompervisisa to serroot it should also be assigned eome soommdary share in the responsibility for what has oosnrred. On the other heed, I believe, though of course it amsmot be proved, that the supervisory organisatiess. both national and state, have never hoes so strong as in the p ,st dosed*, lmt in assigntag a Share of the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 'Tr responsibility te supervision, it mist be borme ia mind that neither booking lass nor beib supervision sea ever perform the positive function et assuring seamd bank ammagement. Sisk supervisors do not manage basks sad, at best, they ems slay perform the negative function of criticis ing, after the feet, the looms and investments which bank masagere have medal sad only by extreme measures, *ihich the laws *oldie permit, oan they make their criticism* effective if balk officers and director s are met eeeperstive, in fairness to bank supervision as an effective element la the banking structure, it should also be observed that uoder our eesailed 'dual system', partly natiamml basks and portly state hooka, has been a growing tendency towards sempetitivo relaxation of legal there re. strictions on basking; and towards ssupetitive granting of dberters, often rithout ame regard to the important* of applicants amd to existing basking facilities; thereby creating over-banked places amd umassmd bamking competition. In addition, the ease with wilt* a motional bomb. if criticised toe severely, sam convert itself into state beak. er vino versa—a prOOSOS 'hi& every vaperdiserattsrally likes to easist... has farther teeded lowerds lees strist sepervisioa. Sore broadly, however, resent bankiag failures have emphasised toss inherent verisesses of the unit local beak. 'First, that it is tos ewe Warted tir limax psepperity or adversity, particularly in please 'hers there is a simile interest, agricultural or industrial. Adequate diversification ef portfolio is lacking; there are too many eigv In am* basket. Sewed, that the smaller the place, the less bask officere ere likely to apply the perspeetive of general credit °matt:dams to their local credit problems or to realiTe the necessity of a sibatantial slamest of liquidity to tbe portfolios. That sago city beak effieers bow else been equally short-sighted does not alter the owe. jimods. The various remedies which have been smassted for this sitmation easter about two proposals? (1) greater unifisation; (2) videspread brew* basking. (1) clyeaier ttailissam. The most authoritative proposal for greater unificatles in the tanking structure io that ihisk the rederal Reserve %lard unamimously mods to the banking sommittees af Csagress on March 29„ 1952, as follows *It shaild he reseemised that effective supervisiss of booking Ls this neuntrflies bees seriously' hampered by the competition between member smd usemeember beaks sod that the establishment of a unified system of besikiag soder Illittella sepervisiem is essamtial to fundamental banking reform. , There vin be no doubt that the proposal ef the Federal Rsesrve leard, if it could be brought about, you'd be as impenitent step in ad'emses There are today about 6,086 natiesol books sled 11,520 state banks (other than mated savings beaks). All state beaks with sof. fieient capital have bed the optima far many years of either eemrerting into national banks or of joining the Padirel Deserve Mystaa. /t is obvious, therefore, that unification of a banking structure whom, roots go far back into eur history could be bremaht about only by fore.. to have already' imiss smarted soh faresw-first when the National Desk Act vas passed; and seised, Whoa the Pederal Deserve System wee created. la* aesemplished its immediate objective, but neither bas prevented bank failures, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 5It should also be observed thqt unification within the framework of the Natiomal Bank Act would not react the groat mess of small state, banks akish new have insufficient cajtal to qualify as motional balks, Their number mould be farther increased if the mininso capital ef national basks were increased from #11,000 to $110.000 as the banking bill now before Cameross propeoes. Yet these very small state beaks* as already indirseted. ars the score* of soot of our bank failures., Clearly, there would be advantages is unifieetiaa wader national supervision. It would ressve present compAitias between "sties."' sad State authorities ravening in lowered legal reatrictioas, loss strict amporvisioa and lover stasdsrds in greeting awe dbartors. Nevertheless it appears to ae not to go really to the vest of tho trambla. Tor, as already indicated, supervision is largely sagative sad exerted after the fact. !Yen the prorosal of the bashlme bill to permit the Federal 60.. serve Board to remove offioors said directors of banks which smog* Im unsafe or unsound practices dose not provide safe amd send Wiser* or directors to take their plane, Ihst is really nooded is somothimg posittves mssely better bask ummagmsent. The small banks, an 0416'winced, fun *either find nor stMard better management except through a shame. in tbe bankinp, itructaile skiA will pmrmit tbon to be operated as brandhes of a larger beih• (P) Widespread Branch B4odsg. This leads directly to the aecond proposed moor for the recent flood of bank failures, namely widespread brans* banking. This in itself would doubtless bring about, not by force but by evolution, an important massers of unification. A large bank with brenshos could herdly afford not to bo a member of the Federal Reserve Mystenk Moreover, the umifioatiou mould probably occur largely within the framework e the national tanking welt's, since only the National Bask Aet is capable of permitting brandies freely to arose state lines uslass, indeed, such Federal branch legislation Should stimulate same of the states to offer reciprocal trona bank esortasiaa mommg themselves. AgriallhalbaggiLlokigas (1) /t would offer to smell communitiesos well as largo mos, the lankily; services of institutioss sefieiently large to boo able to hire sompotamt and smperionced memseammst, (4 lb. portfolio.' Is whildh the deposits of small asommmities would los Invested would be diversified luotoad of naisly local; and umder any oeussmobly ussourgrative nomaismost lbw Mould also have a snbstantial olasest of liquidity. (I) In addition to present outside) aparvision, the bresdhoo usuld smbjeet to santimmous internal supervision. This would be really entboritattre imperwisios because it would hwe power instantly to change losal mssaemmast wherever it was provise ussatisfsotory. load,offiee control ever the larger loans should tend to cheek over-imitasoloso of local credit. whist' have proved to be as ruinous for legal borrowers ao for local banks. And Mad-office purchase of securities Should be mere expert sad emnservstive. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .;:;• , k•• - 4(4) Branches eould be "peasd tentatively in small ,.7,lommO sod Uttar withdrawn if they proved napretitable. Un1Pr unit banking. sash small local banks, ones established, seldom vithlrow except by MUM, o/ ObJecttxas to Wideeoread IMIIIIMUNAUst (1) The trnditioaal American prsindiee—one nor almost sey fetish--in fk,vor of the Waiststretion by legal bombers of lima deposits and credits, and against alloving a distant beaker to say *ea and hom 'T,uch e local me war borrow. (r) The fear that lorml deposits mey be draiaed away mad loaned ta larger atlas. These I believe are the objections Issally sasalsod, r.016 they are closely allied. In theory there is much to be said for both of then. In *steal experienso, however, theyUrgely disappear. * * * * * *•• * In the main, however, hanks with bra/aches, like unit banks, are in ts sake money; rates for local credits are nearly always higher *an sew market rntes; and the fastest My branch can grow amd beeves profitable is by making all the pod local loans it can. Nereewer, baMbed by a larger capital, the branch can extol** larger Jodi:44ml aredits than the local bank, and it cart draw as tho head offiee for sdditional funds Then local credit requirements 611000d local deposits. (3) There is this further objection--that if a bank with say aro hundred bramshes were to fail, every one of its offices mold dose* *berms if ea& of its °Memo wore a local bank, probably a firer number of then would fail. This, to sly mind, is the one twadanonta1 objection to brand; banking over a wide area. More is, of *aurae, no way of assuring sound mansgelteat for all banks hawing widespread branches. But to shrink from branch banking became of this risk is to yield to , counsel of despair. Both Great Britain sad Canada, where, as with us, deposit banking prevails, have had failures of banks with branches. Out thp porcentsge of their resources involved has bees as mash less th&n in our unit bank failures that tho answer to this objection is reasonably satisfactory. * * * * * * * Ixperiense above that tbe looding and supervisory organisations which basks doing actsmatre boom* banking have to maintain and eam afford to naistain contribste powerfully in themselves towards earofel samegammit, while the 'ids area covered brini7A diversifioation of risk. * * * * * * * * army groups and Shaine tAkve been formed awaiting the necessary authority te seavert into breaches; the eauree of events has greatly weakened tho opposition of the smaller unit bolts; and the banking sesnittees of COMM, have introduced a bill providing that a national beak nay establish branches within its own state and fifty miles Mood ito borders,. thus, as a remedy for the obvious weaknesses of unit braking. we appear likely soon to embark upon braask banking ;Bide by side with malt basking. If And vibes we take this emadmmeatil step towards a rarmrealhiag Ohmage is oar beating structure, it soma important that we Should take the stop mot teatatively or half-hearted)" but fully convineed of its desirability as a lotions' policy desigaed to afford better protection to deposits. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -s Like magy ether supporters of unit banking, hajlettrittil eleitt events to Change my views, and I now resod brew* balking as the only fesdameatal room* for the demonstrAed seehmeeses of unit baukimg, particularly is the emalleT plass*. put to bosses an effestive isetweeent of national policy branch banki ng should be posultted to develop under countless moot favorable to its sucoss. Moss oonditions involve esestiese el (1) area; (2) oupF,r vision ; (!) easpetities with unit banks. (1) Ares. Under the balking bill, a national Wok may estab lise brougham anywhere within the limits of its own state and vithiu costiptoes territory fifty miles outside. This provision, while a tremesdess step in. advance, still savors of halfheartedness. If vs are willimg te go this far, we sight better recognise at the outset that stets lines ars usually r;,,ther than economic; and that es &ell MOB have to amend the lav to permit brumase over sore natural trade Waage as en4omptreller Pole recestly ressm ussdid. To Shut our buss& tanhisi up in forty-eight separate sompartnouts as if it ogre somethiag us feared, ie to ignore the ouporionee of all tho other coantries of the world Sher% as far as I hasui there is no terri toria l restrictions This does not masa that r would somt late for the e* Unite d States, ovum for the distant fUture, bras& buiting *Joh covered the entire eenstry. Distance sad sectional feelings are spinet it; prep9 r dtworstfloatios does not require it; end obviously there out he sows limits. Bet surely all will agree that a state—plus fifty miles o—will in many eases prove a limitation that has elements of unsafeness. In states over, whelmingly agricultural, for example, state lines will render it difficult to attain that ftumiamastal requisite or branch baski portfolio. The limits, it seems to me, should be suffi ng—a diversified eiently wide, and more than this, sufficiently elastic, to permit of found diversification. The twelve 'Federal Reserve Districts approximete natur al trade areas, in spit* of some arbitnariness„ and they appear to me to be the sest practieable limits within which to work. But the Teder el lisorve Board, which mew the proposed bill is to nothorise ell branches, Ahead, it seems to me, be empowered to allow brenehes to overstep district lines afieseaary to *over tistie amis or to assure diversification. * * * * (2) 403Lpervtplep. Widespread bran& basking introduces into the streeture the possibility net of sore bank failures, but of larger and more serious failures. The balking bill wisely provi that the sotabltihmest of every trigs* Shall be subject to thedes approval of the tederal loosove Beard. lag places both prope rly aei elearely upon the board awe the Weems" Reserve Banks the primary respo nsibility for the sommd ciewelopmost of branch basking. /t goose impor tant that they Should also have authority to provost seek state imeti tatione with brandhes fres becoming members of the Besorve System by Smowersion into or oonsolidatios with sational banks. lhother the brook baaimi institutions shit* are permitted te &visibly &all he stron g and sousd or shall serely represest * crow' ~ties of existing omit book usmag doponds, is thoughts, upon the standards thieh the Federal Reser omost ve Board gots gqp as wide for its action, amd the rigidity and ruthlessne ss with ehich it anilines to authorise brusehoe for any bask *hese past reeord and paistes have aet been sound and seft, Thare &sold be no plea* in bran* balking for officers or digesters silo seek to operate banks ia their OM selfish interest. And there is no cluesties that the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis $ public is in a mood to give full support to rnthleOOMeee emetted is the public interest. ?he supervision of these larger invititutions will Wag heavier mostoosibilities to their supervisors. But on the other beady with tomer units to sopervise, sore concentrated attention emu be given; and the ability of thee* larger institutions, both to find amd to pay for geed emeeprey should remove one of the present difficulties in the empervision of mall lesel banks. csOmad element is the development of brio* tanking is the speed witb libido it proceede; sed it is possible that here again the Federal lieerve Board ger be abie to *moraine a restraining influence. Pieper organisation* te uncrage branch hhnking systems cannot be developed overnight. Selma ImMatisfactory situations would be likely to occur if a competitive sersuble for branches, ouch as has recently token pl,,ce in certain areas, Should be repeated over the seuatry as a whole. Fortunately the present diffieult period fevers eoderntion in the speed of establishing treadoess, A third factor, itth abich no nntional or state supervisor hao yet been sble to asps, tut with which it is to te helped the redorml Reserve Board may find a say to deal, is the eompetitive e high rates of interest on deposits, particularly savimgs deposits. Where not controlled by clearing house or other srreegmematey these rotes have !site generally led directly to the purebase of inferior toads with bid. ssopees, among which, on the law of averages, the mortality to MO, The initial est7,„blishneat (!) competitim with Leal ef branches mill doubtless p the lines of least resistanee by abaorbing local unit toudts. Mew stroag lees' hanks, however, may deeline to become branches and the qaestion will then arise 'tether a larger Institution Should be permitted to 7ut a branch ia ft& places, While the sire of tn. place will beim a bearing on the decision, should like to express a purely pereseal view that as sentimeat in small places 'ill naturally fcvor tie local bask, the willing.*** ef a strong well-managed tank to maintain a brew* alongside the legal teak should at lettst be an important presumption in favor of greeting the application. * * * * * * * * Provided a took has good uemagmumaty it should, in general, be alleged to bring its services med adiemtages to those places where its vesagers think they ean profitably °perste. This closing thought serves to onp‘lasise mr beliAf that Maloof in the bankiag structure &said be approached primarily fro* the steedpoint of safety of deposits rather than from the standpoint of amen* of credit to be outmoded legally. Too often in the ivet the latter has appeared to beth• primer, objective of bamkiag legislation. With full ressgoitien of the fast that loess create derasitsy we shall be on safe ground, nevertheleee, if we paraphrase the familiar English adage, end eay, 'Let us take eare of the deposits aril the loans will take *are of thenselves.* https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis , ' -;ry14, ‘Dltd " SOURCE: k-4,1 7- ' Ave' ) il.A.."4""losird CANADIAN BANKING--by E. L. Stewart Patterson (1932) Chapter I--Historical and Economic Background Pav 12 Joseph French Johnson summed up the outstanding advantages of the Canadian system of branch banking as follors: (a) l'arge capital behind each institution. No matter how small the branch the customers share in the security which a large capital offers. (b) Unity of policy on the part of the leading banks during a stringency, in contrast to the playing at cross purposes which, in the panic of 1893, distinguished the action of the national banks in the central reserve cities of the United States against the smaller country banks. In 1907, if the country banks had been branches of the large F city banks, they would not have withdrawn funds from those banks when they r‘t '14 were so badly needed, and the crisis would not have been so severe. PP .) t\-**- 1)) , )r P • 1..t1.' r ( (c) Power to equip every branch with ample reserves for maintaininE commercial credit by means of notes issued. It iF impossible in Canada for the business needs of any community, no matte/ how remote, to outstrip the banking facilities, as iE often the case with us. The resources of the branch bank are quickly and indefinitely extended. Moreover, when the need for additional facilities has passed, the business of the bank can contract Eccordingly without loss to anyone. (d) Uniformity of interest throughout the whole country which does not vary more than one to two per cent. between the large cities in the East and the newer towns and rapidly expanding cities of the West. In the absence of competition, the necessity of depending upon small local banks for accommodation reouires the business men of western towns in the United States to pay monopoly rates for the use of capital. (e) Expert supervision by the central office prevents bad banking. The boards of directors of the large banks are responsible for all the branches and they ere therefore forced to put into practice a method of examination and supervision which is much more effective than Government examination in the United States. (f) Branches can be maintained in localities where the profits of the business would not justify the establiEhment of a separate bank with independent capital. The city banks can establish branches without any investment in additional capital. Branches can be established where the business is so small as to justify simply the employment of a few clerks in a rented office. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2- Canadian Bankine Page 12 (contd.) To this may be added the opinion expressed in a New York paper: We know of no system that more closely conforms to the best and broadest economic ideals of banking; none better calculated to afford the largest possible public accommodations; none better adapted to insure a safe utilization of the surplusbalances of the people; 8nd none better qualified to supply the daily fluctuating wants of trade with a safe and convenient circulating medium. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "A ( 2‘11141 Ntkiv SOURCE: CANAEIAN BANKING--by E. L. Stewart Patterson (19F2) Chapter II--Canada's Financial Structure Page 20 The important part, played by the branch system with its asset currency and decennial revisions, in a country such as Canada with its great distances, scattered population, seasonal variEtions and lack of working capital, cannot be overestimated. The freedom from panics and crises and the adaptability of the system to every emergency such as war and post-war conditions shoulC also be noted. A branch bank even though housed in a shack or tent, as was often the case, could offer to the industries and settlers at the most isolated point all the facilities of a metropolitan bank. 1.-// Mr. S. H. Logan, present General Manager of the Canadian Bank of Commerce, opened up a branch at Cobalt in a tent, which served both as en office end residence of the staff. The great mining district of the Kootenay and Grand Forks had banking facilities before it was reached by the railAays, as did Dawson City in the YuRon. A bank was established in the Peace River District several years ahead of the railway, necessitating a trip of a week or I ten days by boat and horse. When the railta. finally arrived it found a well-developed settlement with produce ready for transportation. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: NEW YORK STATE BANKERS ASSOCIPTION - 1952 REPORT OF THE COMMITTEE ON FEDERAL LEGISL1TION: Page 83 Creation of a State-Wide Branch Banking System Your Committee approved in principle some form of branch banking, but it was opposed to the establishment of branches in neighboring States; furthermore, as the subject is such a highly controversial one, it urged that this section be divorced from the bill and some form of branch banking legislation be embodied in a separate bill, in order that it might be considered by itself. OUR PROBLEM& - Mr. Harry J. Haas, Pres., American Bankers Asso. Paze 169 Branch Banks: In regard to Section 19 of the bill covering branch banking, we called attention to the resolution of the American Bankers Association adopted at Cleveland in 1930 which reaffirms its belief in the unit bank modified to the extent that community-wide branch banking in metropolitan areas and county-wide branch banking in rural districts, where economically justified, may be desirable, but in every respect we urge the preservation of the autonomy of the laws of the separate states in respect to branch banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: Report of Banks of Deposit & Discount, etc., N.Y. 1931. 114ge C The following are proposala for legislation which we believe have a direct bearing on any effective program of reconetruction: 1. The las be anended to permit a bank or trust company to establish branches sleewhere in thc county in which its piacipal office is located, and/or in en adjoining county; provided, however, that no such branch office may be established except through the pibcess of taking over some exieting institution, or an institution that nay hereaftAr be closed, or except that branchf2s may bc opened in toil= or localities not presc-ntly served bj existing banking instit-tions; no such branch to be establishc-d except with the consent of the Superintendent of Banks and the Banking Board of the Etate of New York. (It ie intended that thc above power shall be in addition to thc present branch pavers not granted by the laws of this State.) 2.. That banks and trust companifs having capital and surplus of twenty-five million dollars or more be permitted to establist a branch or branches in any city or town in tA.s State; provided, however, that no such branch nay be established except through the process of merging with or gurchasing the assets of an ex/stip& institution or the ascets of an institution that may hereafter be cloeed, or in a city or town not then verved by exiating banking facilities; no such branch to be established except with the consent of the Superintendent of Banks and the Banking Board of the State of New 'ark. Pase 7 The writer is a firm believer in the unit banking system and is of the opinion further that where well managed, unit banks will always be a successfUl and continuoue part of our banking system. The recommendation as toaranch banks is made solely because of our belief thatfis an economic necessity and it may provide a means in sone instances of strengthening the banking structure and affording better protection to the depositing public. Legislation proposed at Washington granting branch facilities to National banks in a trade area, or restricting such facilities in such states as vrmit state-wide branch banking of state institutions, will give added inportance to this question. In the past the conpetitive establishment of National and State banks has brought many banking abuses and sone meant; must be found in the event of thir establishsent of a branch banking system, to prevent destructive competition. In our opinion, neither State nor Rational branch banks should be established except on the concurrence of the !Aate, national and Federal Reserve authorities with the view of etrengthening the banking system of the res)ec'Ave stAes. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis \ https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2- L. (Contd.) In thia Statf-, new charters cannot be granted to Ftate institutions eyeept with the approval of the Eupc?rint(7ndent of Banks sno a two-thirds vote of the Banking Board cmposed of nine members. At the rement time all branch applications ere also subaitted to the Bankint Board for its aoproval, and we propose that in the event e branct, banking law be enacted by the legislature, the law be changed to provide by statute, for the approval by the Banking Board of branch applications in the same manner as it ie now required in connection with the chert,r of new institutions. f 17/- SOURCE: CANADIAN BANKING--by Eip L. Stewart Patterson (1952) Chapter II--Canada's Financial Structure Page 21 All Canada and part of the United States are in the northern temperate zone with agricultural activities limited to the duration of a short summer. A great part of the United States, however, is in the southern temperate zone which permits year round cultivation of almost every variety of semi-tropical fruit, cotton, sugar cane, oranges, lemons, olives, etc. The unit_hank system of the United States, though excellent in many respects, was not adapted to the requirements of a growing country with seasonal varf7tions to contend with. The United ttates may be said to have made progress in spite of her banking system rather than because of it. Had Alexander Hamilton's bank not been killed by politics II the country would have been spared many crises and bank failures. Without further comparison a question asked of a group of bankers by Mr. A. B. Stickney, president of the Chicago and Western Railway in 1902, affords a striking comparison of the two banking systems. ''How is it," he asked, "that a narrow fringe of population on the border of the Artie Ocean can not only finance its own crops but advance millions to move ours?" The question was a pertinent one, as the population of Canada at that time was a little over five million and that of the United States over fifteen times more, with a thousand times more wealth. Mr. Stickney referred to the branches of Canadian banks established in Minneapolis and Chicago, which, with the foreign exchange facilities of their head offices and New York agents, became important factors in moving the western crop overseas. Mr. Stickney might have gone further and referred to the assistance rendered by Canadian banks in the development of mining in the State of Washington, to the work done the Pacific coast branches from 1864 on, and by the New Orleans branch in moving the cotton crops, etc. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis it 2 `ry, 4) SOURCE: CANALIAN BAKING---by h. L. Stewart Patterson (19!2) Chapter V--Branch Bunkinz L/ystem ?age €.4 One of the Ao6t valuable assetr of n bank is the personnel of its staff, who zae men treined from their youth up t' their profecaion. In their early ,t0Ving from brrnch to brsuch, thej becAac thoIouihly vereed in local cL;6Loras r?nvironments, and in many cases gban expkixincei in branches sbrw.td. As uccountant and winagers of large city branch:,s they obtain a brobd knowledge of ir%tionl trnde &nd financx until, // geners1 managara or superint6ndent, they are found directinc the administrhtion of their muserous brenches. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SWAM WRICA1 ECOSOCC Arvin, 0 Ek (19S2) '7 BAIR MAW IN ?BR OUTIV STATE26.1alter E. Spahr, N.Y. University 132101PrAin IA Data 114 YIP OS It is inetraetive as well as iateresting to mete that in Cemadn, by my of eemtraat, beak failures appear to have very little relation to sommercial failure** The remmrkably fee failurao which have takes plass ta that country indicate that the branch banking wyetea there is mmah better qualified to resist tht strain of bustmess flumatuationo them emr system of unit banking is sae to with:ANN, tbe Wane of besimeso flucimatisms in this eountry. Her business fluctmatieme are mot as omen as ours amd one contributing fester must he femme in tho fast that her hanks arc able to stand WWI assist business la times Kneed. It mey be noted, also, Oat Usk failuree are almost amberea im Maglamd, although, She has her Inninate fluctuation. It would appear, therefor', that a fnmdamental explanation of the souses of bank failures in this sountry is to be found, partly at least, la the nature of our banking structure. Befort proseeding to a further analysis of thn causes, problems, and possible oerrectivoe of bank failures, it may be halpful to summariae the essential **mansions at IMO, es have arrived after an analysis of our statistical dates (1) Tho heaviest failures, absolutely emd relative/yr are smug the state banks; (L) the failures are greatest among beaks with small capitalisation; (3) tboy are heaviest in small tomes sad villages; (4) thej aro heaviest among honks outside the federal Boom votes; (5) they have bees uniformly heavier them failmrea of commercial enterpriacc eince 1920 bat net doting the period 16944920; (6) they ascompemy very closely the rise omd fall in semmeroial failures novelly reediting tho peak at the same tills; (7) they are mot only sound by bustness recoeolome bat eastribute to nasound byelaw ecaditional amd (e) they ars mere premeuneed them in amy ether soustry in tha world even in fairly normal amd prosperous Usual., *la would saes to Wiest. that there are vole famdamemtal emd organie defects in mr banking structure that require eerreeilem. 40time1911* of tbasegivor bank failing. If the proonlimg acm. elusions are serreet4 disdimed from the available statiatical widens*. it would seem that Logic oempala us to attach the problem of imereaelag bank failures by examining what appear to be the meet outstanding ead https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis v-fo: 10. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis fleinesuMMOLdiefeete of our booking structure shish have contrfbuted to the preseat wham situation, as well as these lectors that lit estside the field elf beshlog* IS shell eneshisr the pillions end possible corrective. eider the rollout's& main Wades 1. Ibis defects Inherent in the organic structure of emir omesorcial basks asd banking systes6 2. Them slue to the imadequate control of our credit structure by the tederal Reserve eyetooth *Leh, in turn, result free two limitatioss, (2) those inherent in the strecture of the Federal Reserve gystem, eed (b) the inability or relustesse of the Reserve setherities to devise and &PAY adequate principles et eredit sestrol. Those amuses lying outside the banking field. have on memeeessery and as swim a national and slate banks with late beaks tarral 1"lia os9 airYll tvis forty-nine legislative bodies regulating mod greeting special privileges to their respective banks. For a loft tine state banks resolved lyrivileges not accorded natiosal banks; them the national basking lee wits liberalised to place satimmal basks ea ma equality with state beaks, with the result that thie competitive liberalisatioe of bulk laws be. led us to permit the crestioa of sessued banks emd the indulgesse of useeend buskin prestioes. Such a system, with its furty.osine differeat jurisdictional authorities and forty-nime sets of laws, by its very mature involves Is* urinal:Comity in legislation, in standards of bookies, la rates of presses., wed in supervision* Them eomditiome have beim permitted to prevail far se better reason time es a senceesies to histerimal presedeet esd the doetrine of states. rights* Romsereial bosklag is, and essaat be egything else then, interstate in nature mad, as a result, there is no logical basis aa 'high to defend the peewit claiesiticstion of cur banks into both tuitional sad state with the orwailimg leek of usiformity in banks and banking prectices. (b) We heive tee espy banks—eirpeeially too mow smell books. The statisties of the failures place this conteation beyesd dispute. Competitive liberalisation of our Tories* state amd national lave hes bees primerily responsible for this situation. The lemlease on the part of our lawmakers doubtless has bees due to the prevelemee el the doctrine of laisses fairs La natters relutiag to business esterprise. As 11. part of this same doctrine, sash community has desired its beak and, prefeesblys more than one bemk in order to sears the full fruits of the sempetitive system. /be securing of ome or neve local beaks was facilitated by the low capital requirements and the ease with mach the laws permitted the charierisg of beaks. Searty half of the banking moires. of the oesatry are in the lunds of 1 per cent of our banks (250 in our metropolitan centers), the other half being spread thinly the other SO per cant. Twoldrfour beaks, national and state, is Sow City alum have e espitalisation almost equal to that 414,10.000 country bunks altusttd in towns of 10,000 population er less.01) (a) Too emmg beaks are outside thsOfederal leservt system with the result that the Miserro outharitieo are mot in a pooitiom to regulate or aid then. Me umfortunate aspeeta resulting from this situation rowel themselves in a striktag aumer during arises like thee. of 2600 sod 11116* Of the 6987 national sad state banks ihish failed Ouring the dosedo, 83 per sent were nonmember sod I? per mat amber bemka. The Imam to be draws from this ewidemee stomed be abalones (d) Small melt basks einem do not or cannot secure the proper diversis, float/on of their portfolios due to the feet, perhaps, that they are In sommusities is which e fee crops or industrial activities prodemiaste and provide thee with as undo, preportioa et paper of a oartela type, with the result thkt the welfare of the komsk &on& almost smtiroly upom the poospority of the looal exemmmitg. llitrtitereore, with the iaereasood of She automobile mmd other, seems et olammmieation, mesh of the important bmelmesa of looal seemunitiee hes gums to the larger asters with the vault thst small town beaks lead to hold only the unimportant local mess, (e) It ears that the proportion of piper eligible for rediesemmt vith the Sieerve beak* is toe small for the safety of the sap. moreial banks in times of stress. * * (f) Closely related to this situation is this fist that *arias reeemt years esmoreial beaks have bees steadily in the properties et their remorse* gives ewer to investments as _with the proportion going into looms sad dissousU. * * * These figures show *hat eommorsial bunks aro shifilug more and sort trim the finammiug ef dommoreial Ammoactions and ere devotimg em imereasieg'preporliem of tkeir ruseurees to the fimonsimg of fixed capital, lbeime shismsimg properties& eastributed to the leek of liquidity in the resemrees of osamandallumdms.mad probably reveal a ofttributimg fester to the imareased member rehash failures. Tkis changing peeportios has sm ewes greater sigmifisamee when oomeidered in eemmeatiom with the small unit banks vbieh invest such a large properties of their resource* in local mortgages. /able II will show semethiag of the trend. (g) tireet4 associated with the (mediae of the increased proportion of investments emg teems on investment paper emd aertgagea by eemmercial beaks ere those qmestiens relating to the imaressed nusiber of invest, sent emit ether mea-oessercial bankimg affiliates *bleb have bean attPched to eammereial banks, partioularly in metropolitan somters, is recent years. *** It was reported that Shea the Beak of the United Stater, is Sew lark City, failed, it had about fifty affiliates with relationships se involved that it la doubtful if they could be disoolameled. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (3) Hearings on Branch, Chain, and Group Saakieg, Vol. I, Pt. I, pp.22.18) wear th) Amefter teeter which has contributed to the weaheming et our emeereial bombing structure has bees the steady iserease is the proportion of time me against demand deposits. ea the bests ef the avenge percentage* for the years 1919.1.5, ve find that deemed deposit, aneested to BO per mat, se* ties deposits to SE.45 per see% st the earning assets of the amber banks et this country, while, es Jens t3, 1010. deemed deposits summated to IS per sent and ties deposits to t8 per 'est of the sarsieg assets. Against these time deposits. shish have tooressed aboeletely and relatively daring recent years, a reserve of only 5 per coat is held despite the fast that the sash derived free these ties depovits is treated like the sash reosieed from demand deposits against shish a mob higher reserve east be kept. This eitmatiem hes presented ma inviting. although a demserems. eppertusity to semmervial hanks. It has been invitieg to semmeroial beaks beeause it hes bees sore profitable for thee to empood their loess as4 inveiglements *ad resp greater profits. It has bees a demgerous Pastor for tits beaks since they have hem led iato making lease sad inv./twat* of * type met appropriate ter basks espied in a saviags bbnkipg besiseee, end aloe in the fast that their reserve ratio against gamine denend liabilitiee has teaded to fall helm that required against mesh liabilitI*14. From the point of view of the =wimp depositor, the situation hi,s been fundamentally bad, although Its has smoolved sone samosaiemses sot afforded by the genuine savimis books. In most isetemess he has been able to withdraw his time deposits without prier motive, mad quite ones, if not usually, his eammercial busk has bees sere esavesiontly looated them the. nearest serum, bank. Against these servieee, heeever, is the fast that roserwss *ad his deposits Imre not bees and are oat properly seemed sa a bask the res of a event inissisonts as well ae the fact that in tho prosiest hie to days time depositor sou be mode to vait at least thirty the °leiter meet to esontor the over claims while his feedle are being paid be *Con— to ere ers stdepositi st the deemed dopositere. It the interests small the if am& failures, beak with sidered seriessly in assnesties sever is to be gives the proper proteotles410. Maio thOS hero Is amtber sod corractiam, problem which, meeds (i) The uhit cootie in our greet noltilmde of small beaks ere relatively high and the met Morse are eery low. the prevelease or meteatatises bsildiage amd equipment is se small factor in this sitmatioa. An esalysis by the sosptroller of the ourresty of bank aerate,. showed that a large properties et the banks outside of aistrmeeliten easter* were set swains eeemgh to justify their existence. ibis vas tree even wed 19t7. Is 1911? is seeh relatively prosperous years as 1924 nearly NS amtiomal beaks were operetta at a lege, amd an miditiomal 2000 were sarming lee, them 5 per seat* This opostitt:ted *boat 36 per eemt of all national beaks in the Mated Otates.vii The aitaatiea saes' the stLte basks use ewes verse* (j) Mother detect of emir mit booking Ostia, sopeeislly of our small bank*, is tend is the peer seasissest Add' immorally Obaracter- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (4) Moorings os Mreseh, Chain, & Gromp banking, Vol. I, Pt. p• 5.) AIINSwo ivies those la gmmarel, the officers are of am inferior *art* Perhaps the ematiers mud a few others in the bask, has bed eome formal training in Waking preeedure mod principles, but the traimimg of the preside* and others respemaible for runniag the bank hes probably hems els./ Ihe leading elitism in meet sonmetitia.'Novelly hope* differmmt to eemplete amd polish off his bmaimesa sereer, Whether b* he the maseeseful grew or buttoner, by besemimg the preeideat of the legal bloke This phamememee ie a treditiemal amid a pearlier ahareeteriatie of Americas life* Sash men ordinarily are individualists emd ~let oameporetioa., They are *pima amall-tems mem, oftee Gana herdAaesded bosiass* mos and the baskhame et our natiem4 La the proper sees. of the term, hemmeer, there...illy are sot beakers. They may %mew momethimg of the technique of beehimg bat little of ite fomdememtal mod farioresehims primeiples. They are mat loll **waisted with the literature es baskimg, with thc tendencies, morreat problems, amd possible solution shish shield be of interest to thms4 The, resist the sellastiag mad filing of data on loaal mad mere immoral bmsimees emmditiume shish affest their Maki they resist medernixisg methods; they atom permit aestimest to play tee large s part in the makiag of leeel leaps; the directorate. usually ere filled witk loeal hmsimese mem who knew little shoat Making mind often are iadiftermat ragerdisi the bees affairs* Swerpeme, et seureep resegnises that there are mem, time emmeptiosa to these gemeraliaatioas; aewertheless *ober reflection met Impress eme with the immoral semerec7 et the platers emd with the fait that the type ef mmmagemeat ehereaterisimg a large part of our emit Waking orate. is au important faster Ls beak faller's. For example, the eamptreller et the aneremsy, is smalysimg the eases of the failures of the national bankaja Omni* et reesivers ea iltsber 51, 1930, listed them as follows* kS) Per *mat ee 38 1esmoes,44.4w A4 Incompetent amassiamast••••••••• eoe,e..04.4,4 1. Dishonesty...* C. Loss/ financial depresoion fres agricultural or isesetrial dianater***.******...................... SO Meseiver appointed te levy sad eollect *tea aesesemeet eseerimg detteiemey La value of assets sold**. S Tempermry smspeasies*.*******...*.....******........*. 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ••••• • *• (k) Finally, es may mention the fact that the problem of imadequate beek auperviaiea is still with es. roe frequestly to the yesth smd relative inexperieace of maw of our beak examiners, it bosom* a fairly simple matter for sharp book offieery to outwit them. Smelly the staffs et examiners aed ef examination departmemte are imadeNuate sod poorly paid* Ihe great number of tenures is outdone. et the fest that they are ,the Pfslamme enable te mope with the situation* IL sdkattina 114, bev arisimg flrem the sesfliet of matioerity, if mot a total lack of authority, with room* te the same...natio' of ghats mad pump hooka mod the mono benkimi WAIN eampories that are sometimes s part of them Systeme. (5) Mosel Report of the Comptroller of the earremir (Dee. 1, Imo), ppaaNsti. • 14 also still find diffieelties in the way et quiek end effective action en tho pert of the comptroller et tbe euiremer in earreeting =mound banking Freetisee due to had ememipeemet es the pert of officer, wed diameters of beaks, 2, blether f tics 1 omr phemememal et is to be toned ia the inadequate control et audit, with pertieelar reteremee to the audiesso cycle, whisk* ehmresterisee ear "Moral Reserve weft*, ibis is 4me to the lisitatinae pissed spew.* peeeibilitiee of aredit sestrol bonus* of the etruetural eharaetarletiee of the Swerve prates end A* the imahility or leek et of these in charge to devise the priesiOlem mod meSbeeimm tbet are effective vithin the lisitx whisk the etreetere et the system permits, II * • The emenat of eredit in use *bleb is beyond the control of the Federal Roserve amtheritice„ end pei. effects busimeee condition* emd the price level, is eutileieat to upset tbeir beet laid plena. le emly need meetien the trenemdeme amount of credit used in the 'took market, the eapeeity of the federal /*re Lees gifts* to extol. tee *eh eredit te farmers, sad the -various other necousemmerelial bembiag systems sod esterprises lyisi eutside the Seserve system to appreelato the simpitleance of this prehlen in the qualities et credit coatrel, Besegmisimg. however, these ergemie limitoticas Wherest is the mature et the limerve attest it is believed that uneh mere mould be demo then bee been dem to eontrol credit in the intermit et price level stsbilitr• •41 * * * Regardless of the present state of individutl opinies OR these points, the feet meat eppareat to ell that sine, the temmpuration of the Sederal fteerve system vs have witmeesed the greatest fIestuntiems in the prise level and the greateet number of bank thilurat for thereat. imvolved %hot this sous*, bee ever ems. Prom these fasts the lessen meet be eloper that the system Le not neeting preeent-dew daseade prep. erly mud that some welle.eemaidered oerrectieme should be mode, 36 AMP,kW etible iladilLitiag••••••• If ee ere to attempt to eurreet the etrueteral detects of our sem. earelel bambini systems the evidence weld emus to imdleete that ell leo. menial hembe should be brought withis the Mural Momerve system if it le to emersise genuine ematrol ever ceneereltel credit, porters its other fmmetiems properly, mad provide the proper aid sad pretesilem to eonmoreiel bombs. Partheinerep eines semmereial basking is isteretate ia mature, it appears pmeterehle to eemvert all eemmereial bombs into no- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Lionel beaks, leaving for the vtate boat the aavings beak emd trust company business in co fer LE possible, although it mild net ueem adviseble to dopy these function& to national oemmercial bombe else, aloe there would be great nuabor of places in whieh there mead be eis savings banks amd trust c,;),;.„,;.nios t,L- provide the nemesery ~vices to the, people. The questions of states' rights cod cometitutimel do not present immenemmtable difficulties* 'ham bumpiness becomes taterstate in mature or beeemee an instrumentality vital to t40 tree eirreesat of interstate commerce, the buaineea ie aetiemal in ehLrtcter mod ehmuld be brought midir matimal jurisdiction* la seek cases the elates hire no rights thet dome protection laR04 the public vell-beieg te at etdis• As to the Semstitntionel c,spect of the question, it is cultr doubtful whether there are amy constitutional difficulties involved. *•* A farther argument ia fever of nttlonalixing, all aoseertial heLnks rests upos the feet th(ct it is hardly rational to expect each program, and oerbelelynoti milers progrese, waitini for forty-nime different legislative bodies to ogre* upon and pcse *Ned and progressive logieletion. A fundamental purpose of the lhoderal Seeerve systole ems to provide us with a national polio). aad gets, but it cannot be made effeetive 'Pith the present organieaties of omr commercial Waking strectire• sea eccomplish these things threngh a setioncl law, linsiame eyeIss *re national in scope es are the priblems of credit control; immerse im state and intereational in satire: the problem of a proper reserve otrucImre are satimal and even intenatimal in their remifleationa, ase sueh quitieme em be dealt with adegmate4, 01'04 by a governmental bed,' with the proper juriadietLemal astherity. It ia an tetoresting feet thet *bile corefUl reflectioa Should hem aesiiiaosd lemg age that a mattes met hove • matimai sommercial beekimg metes amd plias mime ,this Is losmatial to national vell-heimg, we hove aostineed to permit a scattered type of booklmg mith the diffisim of authority that has made am *Motive metiamel Imposeible, Too mesh demerney in haakimg has bees a devastating teeter la our economic life. lt appear* also thut brameh basking should be provided for in arOer to amble hemke to secure the proper divinity in their portfolios; to ellaimate the problems mem associated with mall mit banking; to provide adegeste eapitalisation se that the bombs Oan mime, not only in local financlig, *ion toda4 is oftes berm& the capaeity of the local boobs but is a wider type of commercial fimemeteg; to Insure a better grade of memagemeat; amd to eliatccate some of the demgers am *mistletoe, with Chaim end group backlog+ It seems logical, dee, for rush branch backlog to be as vide Ls the Sidon' Assume districtE, if not netios-wide, la order te secure proper diversificeties, and the ether virtues thrt appear to amempamy well-ergeoised bmneh basking* alder such Pretax., knish office. eculd amd should be *posed there mit bank could, aat exist profitably sad sithout demger to the community. It is intent/Wag te consider the fact that *Ile is are willing to permit our large *Abe to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis area. establish feirache in the fez 0021110110 at the world, SO ball* bees esp. willing to pinged t then eetablieh bremelms withiu the esentry despite the feet that about SO per sent of our trade is natio/el rather theft isterastiemel sad despite the fact that in wild regulate deesetla kremehee aerie affeetively thsn the foreign, Is Ogo ter se mit banking contain**, the einimma eapitalieation limits should be reisods Utedy sheald be siege to the question of the properties of redleementeble piper shish menher beaks Mould hold so well as to the prepmetimmiet ether types et piper, eeposielly inveetmeat sad mertga te paper, *doh eight be imelmded with eatety in thkir portfolios. in a similar massr, *tisk sight be gives profitably to the possibility et devising a ashen* for imereamiag the margia of collateral re‘uired ae securi4 for lemma thee the price level is rising. There else appear, to he c•)usiderobls merit la the propeeals made to aid, three. the erestiem of central mortgage redieeount bloke, the various isstitsitioso which hold reel estate mertgege peper• &lace geed emmhial bamkimg appears to depend upon the malmte mmmee of iicAiidity, =tease ears Ohemld be taken in admittimg any nee type of paw to the pertfoliee of the leeerve beam wbieh mutt impair this liquidity. The attempt to sive * eentral basking erase wide posers of credit control seems to conflict at cartels points eith the attemp to t maintain its licuidity. non-oosmeroial basking uffilletas doubtless mheeld be bremght %oder strict control of sod be suanined by the proper mummereial beaktMS authorities, if, lobbed, the7 should ae4, be severed frem eemmor eial banking tastitutimme, Cereful emnsideratima eheeld be gives also te the possibilities of plowable striet limits epee tho total 'mount of lemma thieb esumercial basks may nske to their affiliates in the event thoy are met mowered fres the osunorcial basks. Time deposits, espeetally thee* of & thrift or sawing, galore, should be umder the amme restrietions es to investment as savings deposits la emeimgs banks see tbe resources segregated, or the reservers agelme t these deposits should be the same ce agmlaitdensatl deposits. Peibmpe an effective combination of both ideas eield be demised* kvery reasonable stop should be tabes to improve tho metes of bank reports, enamiestione, sad sethocs et deallaig with reealeitrant balk directors end offieers. Until & thorough overhauling of eur enmmereial betaking stresture le affected, the Seaptrollerts Office should be given authority to eseelme and meet reports from every mit in the dela and gremp basking systems shish Airo interstate in character or in which a matlemal beak is mme of the emits* https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Steve shonld be taken to remove all obetaeles to Genteel which ere inbersmt Is the structure of the, Federni Rev!rwo ersten4 mod febAcv, now hamper our Misoarve authoritis. That OUT bLnking grates is cut If joist end in need of overhauling seems clear. It is also vial understood that eat of every hominess +=isle SOW deetiads for revision of our banking laws. It a national habit dospite the ftet th.t we know me already, have our )m..,.nkerr in legal straitjeekete 'ram' omparad with th:. freaks /Pm to benkfro in such a eenntry es Ihgltnd. lovortholeat, this eeeas to be the ealy ssy to correct wasting defects, sines we oaaaat aftard to perpetuate our votes of little mat banks, wit Its emeteur bankers, with its isebilit; to cope witb modern business problems satiaftotoril7, and with its tram. momdess slumber of bank failures which hurt ecused usiessurltd lemmas and untold misee for aillioms dopes/tore, :20rrowers, stcekholders, officers, sad directors, shoo hvvo striven -711D.ntly to acclivulete s little surplus 'bleb will afford them security im tht evenint time of their live** The Comptroller of the °wreath, beton: the CUrrerey Committee of tho House of Representative, investigating ifrAp, chain, nod braneh bankimg„ painted thc jeturc vividly when be seid (in February, 1950)t "Mier* no more distressing sight than group of cititens, men and weeem, GloverJag Were the elosod doorr of t bsnk hewtiling the loss of their eavimge• Thom, lessee fall upon the best snd moet substantial eitisens in the comenalty sad *any of them nevar recover their previous fiaaseial somdities, Multiply this local eveat by nearly 6,000 ene scatter it thromithout the groat agriculturyil states of the Onion nod the magnitude of its offests reaches astounding proportiJns. "It is estimated thAt 7,264096? de?ositore hove oontributed to ths great total of mere then $1,70010001000 of deposite in felled hanks+ duriSS the past tine years and that no lsa; than 114,))0 shilreholders hic,v* suffered lospec Waramch these suspessiouse* 1.8)* * * tragedloe of depositors and ethers tear. in e eenstry that is eapp000d to knee semetbing about hor to devise laws to motatct the mooty Against maseued seelal institutions and devites, ars a sarrieleull sooner la themselves to thee* mho imsist that the laws do not need revieion. It is oertainly hizh tint tht-,t those interested in the welfare of the depositors. the imam man and and the public in generel—und this mew tbe legislators, the pees, the social seieatists, end theme outsteuding bombers who see the benkimg business in its proper settimg--Ohemld join braika sot 4o all this's possiible to sorreet present defects so that the losses sled tragedies which characterise our present banking system will speedily smd definitely become events of hiztory without probability of resurrenee* https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (6) Vol, Pt. I, pp. lt-14. PACIWZ9Ss Prederisk A* Bradford-. froircesor apahrms analysis et the owes of bask failures. I fool that be has filled sufficiently to dietinoish betiseen thee* canoes *lob ore of f04%.reeehing imports's. amd these ehieh are of suer or soeesdery signifies*** Thus, ta the dieemeetme et the detests ohleh aro isherent to the orgmais 'trusters et our eammormial hanks and bembimg system. ao particular *trees is laid em amy ose more of the slaves defeats doeuribed. yet it seems apparent to me or that the poor quality of the ammagememt. of the smaller bosh& espesially* is of untainted*" sigmifieemee. While the variety ef juriedidtiem *Lich our bombe operate* the ommemeive melber et books. amd. in e under states. the Worts. brood of balk espervisisse are also more some iapertamt than the ether OWNS defects, if them mostioned eould be remedi ed. the ethers geeld 'array take sere of themselves* I home little sympat fir exesple„ with the notias that it is impossible for a beak los hy. erep roam to diversify its hesiaese* %der sound mmaimplumigt akaallis• balk mould issist on holding a tar properties ot its remoureee is epos merbet pmper and high-swede, marketable beads. While somfluims its lemal loess to tho very beet Amble* I also question the imams, in invest igate. per so. as a legitimate ammo ef beak foiluree. So lemg as the isvootmemte awe in local mertgages, the Welk ilesemet, it is tree. strosgthem ita position. bat probably useheam it. Investment is high-grade. marketable seenrities. however. sersoly belpimg to atteia diveraifisaties, would have tended to diereses rather them to imams, the mumber of small eemstry book failures &rim, the period pcior to 1450* Melly, althou gh I ma quite aware of the deism of investment affiliates of sommer eial bombe. I am, not convineed that they have played emir groat part in the meat detail* of bank failures, except in the ease et the IWO 0 the Omited Stoteelk Inadequate sestrol et credit by the Federal.'Merv, authoritia.-heftiest apehrom semomd major muse of beak fallares....seems to me to hmve bees ommomhat Orefflabuillisd• 41 ** nth regard to the possible esrvectivee of the emeatisfsetert bankJag situatiea is this eoustry. it memo to se that porateoive %roma bemkimg 411 a rather wide esale asd higher capital roquirouesto for emit bombs are mere ompediest them the other ohmage& whieh Professor Spahr has sumgested end eseld probably more the desired reoults• I sever de qmotims *artier Withers to the offeet that *geed baskimg is prodmetire od. mot Wooed lame. tut by geed beaterems Shen the bombers or this anaktry. teams in the aggregate. leers that their first dsty is to their met their borrowers, mad that a* loan or investment which jeopardepositors. dises the esfety of their depoeitowl0 bads is justified* there will bo sompar etively few failures. ahatever the bembiag lava may be* Ah https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Theoretically, the maalleet snit basks ean be soundly run, but often, in practice, they are set. It would seem desirable. therefore to permit branch banking sod to raise the mdmiems eapital rec,uireienta for volt banks as the meet prebablpl and expediest mothede of eecuring tor legislation the type of beak memegement Ohish is esseatial to a good bankiog system. * * *• • • l'es if we insist thvt hanks should be able to weather my sort of coadition that soonest it is only fair to then as it is to otber osehere of our esonestic organisation taut sommd and effective mesbanisms be devised for the stabilisation of business at bone amd thLt the eleeest istersational financial es.operetion be fostered to the sad that external disiewbesses may be radioed to a minimal. quite agree with the two papers, however, that even with a stable ecomarie enviromment our basking sarstes swift ossoiderible inprovemest. we swot not, hemmer, fell to wershippiag moboolons mash as less, regulations, sod totem' supervision. The ooly dopoodoble melbed for achieving better baskimg is to develop bettor Wakiers. Send bunko aro not necessarily member banks, uotioaal beaks ' brossb basks, or large banks. Shen all of the sets of the present booking tragedy have bees written it will be feud that no type or system of bankiag vas free fres the reekieeswies, 'rood, stupidity, amd dishonesty each have bees primmest in the existimg sitnatiea. It gees without goyim' that a bask with larger restore's, more careful supervisions greater opportunity to diversify risks, end abilit3; to command better umooserial talest, other thisgs beteg equal, will be better able te veather storms but eves ersh an instituties will subject tbe stoehbelders end patrons to heavy lessee valeis it ia wisely and homostly umnaged. The ability, oemservatises emd highly developed Seise of obsonwilbip et the leglish banks are emabling then to weather meporterbed storm eves sore violeat than our ova banks are smoommterimg. Shile there in mob to be said for a single national astern or basks the ease is not quite se smem-eided as Dr. bpobr wouLd he's vs believe* We have already duAped upon the central government so many of our local problems that it is iintible to grapple with then attentively. While seme of our state laws sod supervision systems are mot quite up to the stoodarde of the national system I have found that the plane upea which bookies is dons ta mar gives sonswaity is pretty web the same far asthma sad state banks. The mistime ef dual system has permitted better adaptstien to local seeds end. threegh the interchange of ideas, has resulted in greater progress* As has bees the case with state-wide true& bookie', sae 'tate, California, has served as the laboratory vithont the libels ementr, bevimg been subject to the necessity' of emperismating with a sew VP* we beekIME structure. I quite Wee with Dr* Spahr that the small book should be elimiaateds brhnch banking be given a semelhat Drew bend. Shot stricter, as mall as https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -12more seleatifieally devised, mulattos& be made lath rospeet te leers, deposits mad reoerwes, and thst v better type et supervisios be prowided• it iv still desirable to amphaelse the feet, however, thst the best of regulations asd the ablest et supervivion will not sake ear basks failureproof in the fees et stupid and dishoaost masagessat. *r. Spahrie insistease that every sommercial bash &sold belong to the federal Reserve system mete with my epproval provided be wain** the tors *bask* V3 these institutions that are esemereial la fait as well an in name. Amy of thee* beaks that are still outside et the system do est small a volume of easseretal betaking as soareely. to warreut l000roo bent esebereltip• . As tor the stricter reguletios et the irmarhmoWidepostmeste sad Inweetmost &MILO** of basks, I would go a step terlbor sad lasts% that **less this type of fieeeetel movies can he rendered without Waging distrist mpea the thole iustitutiss it eight bettor be denied te mar banks. TIM departmeat store Sims la nesse* is ia iteelf a thoroughly eomosadeble ems sad I see se famdommotal roam tor derivift to either qualified motional or state imetitstioss the right to eagega in the whole genat of fiesacial serviees. provided that a usiforely high standard is maintaised le wary department. if eoselosios le that we sheeld perfect our tusking laws set the quality of supervisies to the highest degree hat thitt we abould regard those as wily of miser importaeoe in our quest for a fallure-preet banking metes* Ihis latter condltioa we eaumet ashisiel yeti' wo have placed 0010. geed buskere chii.rge of 411 of ottr benkiej lastitutions. * * * I think tbet the present soggosted ohmage, is salUsmallika— reserve requiremests of beaks, however bagel they mey be, sae et best be *Ay• temporary relict. The are elAempts to sere toll ose pert of a diseased body, whoa probably the entire system needs wadies' ettemAlos. Professor ipahros paper ea bask fallawes builds a wea7 stress ease ler beak refers. It is Moly that le shall putt through this provost depressian in a, year or se sad shall then feel that our bashing elitists not se bed after all, Seuever, the record of the pas& tea years elail stead as a memusent td costly experiamatatismo hors vitammed thi* lisestamar of our benklag laws to met satioaal 4111111,14641.016 I an well aware that, as has boss pointed oat, banking lows do sot asks good banking, but thht good basking is attributable to the beakers themselves. let we bare drays up for the honkers elaborate codes whisk would stteopt to set strict limits es the bombers. That thaee limits him been overstepped le common knowledge, The ass pareaeuat object to be desired in ear bookie, glisten is adeqsate sad safe basking. It is bard to COMMOMPO low this eau be oilseed eLth forty-eight differeat *apartment station, esch with ita ovn individual la-s, es we have la this country. I an in accord with Professer Spahrta soatenties that e system of bras* hasktog Is a solution. I do mo6 believe that brae& banking is a pusassa, yet I feel that it woad provide• united frost ehishaight offer as opportunity for uniformity of control, Seeking, ss moo serried ca, is essestially isterstate is https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis r: sherseter, ac have been altogether too individualistic end UMWoperative in thic buelmees, ,s is witnessed in practically emery bookine sommity of the entire country. I reel that the price 'high le see Wog paid is altogether too high for perpetuation and eentiguatimi oor present oest4 mutest.•* * H. runs.-* * * It is true, homover, as Protegees Bell bee ao ably breeot out in his analysis of the mature end olaseltiseties of bank deposits, that time depocits ore by fte osilas beestellesea• A NNW sigregstioa law should limit the protect's* to eavioge aosouldsoseml shoal aet include all classes ot time deposits, *Joh may include large **pita' accounts. More thee twenty rars of experieace have eurviesed the public sad meet beakers in California mad °mon of the advantages et see:cooties evem thee hemdicapped by unsatisfactory olessitioattea of Lecowats. * * * * *• • ilte proposal to brims ell evemersial beaks soder estiseel egateaa, Is not mew, but Ise brompht into prosaism,* some momths odir ohm advocated by Owen D. /Oomg before the lomat. esmailloo em keeklog amd Ourreasy. It must be admitted that froshmais low bee operated la the field of honking. /hers hoe beea epee to bookers the 'beim of too codes osier shish they might operate their hanks. Um etten they hew*, Chosen the eme oith lower *spite' requireueote or looser soperviaion. Our overbooked eemdition in memy states sea be attriboted to laxity in laws and the osopetitlea terisedbere seder two erotism. Against this must be set the galas from a davelopmeotol potat et vice et eoperismatation end freod3s from monopolistic control of booking rooftrees. It we wooed. that Cemgreos bee the power to establish a single tasking system. we met still recognise that sook straw most be threshed beers such a fair-reaching proposal am booms the low of the lead. Seantism, as a practical proposition, it osema meet desirabl, to move la the direction of a single syeten through stemderdisatima of state hankies legislattm and supervision. * * ftisting banking codes Is the seven states eseprieleg the Tweifth Federal Meeerve District are barely e oterter of a amatory old. The some asmditioa, with modificatios is typtsal laterally. In roost years the treed of state logislatioa aid supervision has bees teuard deeidedly higher stamdards. The old competitive spirit has disappeared. In ite stead we rtmi trowpsystion with the comptroller's dispertnisat sild a desire to briog the lmoo ap to the beat steadied* of the matimmal temhimg emit. la tbc natter of capital alone, states Isms adopted the mistmem requirements of the national law. In sly onn *tate of lashingtoo the past deeede hoe witaeeme distInct tread tosard oewardimatiea et banking policy. Perhaps d a more real https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 74 ; § progress may be made or ofteantrattog our maw upon bolsging the stamderd of stale booking than in looklog toward the Ideal but someehat dist.nt and emeortala goal of a single natimmel system of °monomial banking. Protemeor Lpahrim proposal for branch banking deserves eapperte, Moreover, we Should establish * natioeal pelic;, upon branch and group bbnxing. the leindden Act in sUbstance deelared against istereemewnity branch banking sod left our national banks subject to state logislatim in the establiahmeat of city branches. The result is that in many e.g., &settle, group bulking cities where branch bsntini. easeeded that brae& generally has beeome the dominant fore. It is The remelt of this prosomt permitted. if ecow,nic basking would be nor* to bosnOboo• are oquivaleat of many whica Imo Jo to give us groups, It in inevitable, however. that the agricultural sectiome of the tatela and limed& ettl hews a iLrger number or banking offices. Mospits the vidoning se the trade area ar improved roods amd the nee ef the automobile, the mall teem is still the seater of Wiliness and nada/ life to a large proportion of our rural population. Oeneda, today. has almoet double the number of Ixasking Wiese per capita that we have in the United Oaten* A bramek Usk cas be neintainad far ears mmagoall7 'ben an tnAmpondootimmiL This palate to branches es a method et providing banking services to small teens. bone etatee, *4*, Loon. boom airoedy authorised brsnek *banklethranehee oily in tome ober. me independent bank is in operttion. While reeogniting the outamalos of bras* banking as Inevitable and dooirable, an anfAysis or the most pest ouggsete that we most prosood 'vitt ceutlon. *each end group systems have boas thrown together boo rapidly. .5ystems heve beer entanded hater thee the elite meld be integrated. Life..leng emit bankers hews boos tempted by high prises for their banks and higher salaries than they have dared to pay themselves to Nicene pert ef a group or breach systeL. But they essomet edinst overnight to the nee order of things. lieday we may find branc*1 systems loaded with henvy ovelhood, nontrolled by absentee owners, unable to unify and co-ordinate the moemeement sad epwatioas. The making ever of a system of unit banking into brash bumble' will bring in its train grave problems. It rill require daesdee, sot years, to asoomplish it suommiefully. loom or later alemerest. must deciCe nItiamal policy regarding breed' sad grasp banking• lbe information obtained at the 1930 end len hearings of the Meese end Senate esemittees will soon be supplemented by the findiegs of the Federel Reserve Beard's Committee em iremok, Group, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -15- and Chain Bxtuking. Tith this and other available inforw,tion a sewed ?olie should be formulated. In the formmlation of this polioy belabor* muiit assist, but not dictate. Senator Glass has skid that all of the opposition to branch banking has comc fro* baster* and beakers' organisations. ••* * * •• first branch beuking quebtion to settle in the eree Pcrhaps over which a bank may sates* its branches. City branches should be &limbo; univerbally without regard to state lev. The dream of natinvids braneki banking is ever. iirobably the first step Should be to limit branches to state lines or contiguous territory. ?rade erea branches ma4 be feasible if tut trade are* is unrroyly defined at first. In any event, brkner. exp&nsion should be subject to restriction and control. Group banking shoulo be brought strictly under the supervision of the comptroller where any member ,f the group is s national bank. Soundly manage:.1 zrJups add etrength. The evils of -..insound management have been deaaastrati7ed iu such groups as tile iiankers' Holdimg Corporation ef Seattle, or the Caldwell group of Nashville. %moo experimmoas demonstrated thkt group membarship may be a disastrous liabilit7 to a nucceusful local bank drawn into weak or speeulative company thmagh gxoui; affiliation. rurally, I would agree heartily with. the pretryus speakers who have • solution of hank failures. ThowAnee of unit stresaed managemest weathered the stomm and stress of 19!0 and 1931 saceasetUlly bank4 huve have brought condewnetion upon our present failures years whose wholesale bran& and Frown system poorly-administered time, the same system. A banking structure aone, changed. results. disastrous Eva, iota*, dovu stability. of a be guarantee not therefor*, The state booking department in Reshingtaa boa adopted a gamaral policy of tamer and stroager basks. (The majority of small boobs Imo state ohortorod.) Workims osastructively ups. this policy, the department has beam able to complete cial7 three intarmammmmity mergers. It would not be a serious hardship in oopr sore mom to morge books so that they would be limited to trade aroma of sufficient sive to support a hank adequately. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: THE NORTH ARERICAN MIES-1951 JULT--DEC. AfE BAKERS INTELLIGENT? by George E. Anderson 100 agars, ef this deProssion 44Xes tt a yaws kortthest amppAgg itiMMUMUNI There seems to be no question of the abmmemi statue of the average booker. Not Lamy years ago he was, dieremeadine sex in metaphors, the omen bee in the community hive. About hin revolved all sorts of 'immunity sotivities from chureh sociable& to the bmildimg ef the new plee factory. On his good will and assistance depended all new enterprises. TO him cane all the secrets of the lems1 business world. Ne controlled the destinies of the church, the local chamber of eemmeree, Iivenis, Notary, tile country elub and all the ihat,sacts of his hems teen. Through such and many other inflmenees he enjoyed an enviable essial pesitioa. He was a power in polities beeemse, from kmeeledge thus &aimed, he knew which strings to pall mmi her to pull them to shape the destimies of his sity, county amd State. Me bossed the city through legal business mommestions. Re bossed the esentry throuvh farm loess sad rural business eonnectians. The attraction of State govermasat dapesits etten led him to dip heavily into the larger affairs of the commemealth with no mean sueeess. In him, accordimg to the prevailing opinion of his eciateaperariee, lay all the beeiness videos of the ages. At all event* he emmtrelled the parse stria's. It would be goimg tee far te eay that all this bas ohamged. Ummy bankere still enjoy the posers smi privileces enumerated. Perhaps ta a large majority of oommunities the UMW,iS still the kin. pin in the legal merks, bay beakers, like espy beaks, hem passed through the (hanging tartness of the past few years mmd have emerged greater, stronger, mere authoritative than ever. Oa an average. hemmer, things have Ohmage* semsiderably. There is no longer the ammo prestige in the banker's position; his authority is not quite eo obviene. laperieacee of the past three years have dememstrated that financial idols in metrepelitaa nosey centres have feet of taw. May have made mistakes *high have oast themselves and the Isometry much. the looal beaker, too, hes made mistake.--shaetly, ealanitoes6 Sams of them have bees such as to paralyse whole semaimities, embarrassing. ghee they have mot reined, thousands of people at one ral sweep. The eggxegate results of these mistakes are overwhelming. There are certaialy logy mama why the average banker has lost his peens emd his prestige ta hie sommmaity--many reasons and all good. It is ammeesemery, of sours*, to rub salt in the beaker's wounds. For the sake et ergemeat, Weever, it is nemeseary to remind him and ourselves that in the past tea leers aae-third or the nattaa's banking institutions hews sliest Voir deers involuntarily* that in itself has https://fraser.stlouisfed.org 1 Federal Reserve Bank of St. Louis 4.1.4.101. Are Booker. latelligentt.Oeorge E. Anderson geed points. there mbre too mamy beaks, esposiall, too mmmy amm12, leak ones. A large wisher of them should never have bees berm* Ole... fOrtemotely these balk suspensioss home involved something mere this the beaks ma the beldam They hems tied imp billies& of Mellow is deposits, hare emberraceed literally millisms of depositors mod thousand, of ocemsmities. working ruin au the Waimea, mms, the wage earimerip the widow, the orphan and, of essree, upsa the lossior himeelf in a preemissa daps,* lhommds of bombers beve lea everythimg they had in tbe world, isoludimg silly tee often thallium ellieh mem prise above rubies. It world seem to a perms of ordinary imtelligesoe that in view of each a state ef things the tanker would be the first to do something about it. 1hat presumption is arromeems. The banker has not auXY dabs aothiag about it but he has preveated smy awe sloe doing amythimg about it, Every ems (salter el* the subjea 'egoist:es the difficulty et bask refers* Changing the fOrm er sdhstamee ef the banking system of a natio* et a hmmdred *an tasty sillies people, resting upon a semplioated belly of lave built up mot slily in the nation itmelf bet also is sash et forty.eicht putative severeigs States, is sot easly. Nevertheless, after years of observatims amd emperiesse, the matborities is leshingtes have evolved certain Woes et progressive refers to Mash they have semght to give reality. Amer these may be mama bras* beshipg, 'high meld enable area( banks to supplest weak lesal basks is rural sommusities; imoreased powers of supervision fOr the Comptroller et the Carrels"; a higher limit for minimum espital in small tasks) membership of all basks in the Tederal Meer, erotism sad mare strict antra of member beaks within that systomo end the separation of savings ma ammososial bulks Vlore the tmo are sombised in am* imatitutios es la se generally the ease at present. Above all is the matter ef the osmtrol of credit amd the elimination of all weak asd tomaleseme small State bombs amd the eashliehmemt of a unified swage for the whole sountry 'oder seise firm ef astiasei supervisies and sostrel. It mmy be admitted that mo eme of thee, reforms vould afford immediate relief frail the primmest acute sitmatiosi asy ewe or all of them would require time nu. beneficent resmItel probably all of thom would sot result in a perfect systesi bet smy eme of thee would have indisatei seme progress teward betterment, Iles the beaker advesated amy of these referee? lle has not. lremob booklet has beem opposed by practically every small bank in the oomstry*am& gamy large IMO, imereased supervisory poser for the Comptroller has bees bitterly resented ir mewl,' every mistime' bask as an inessies ef its prerogatives although eider the present law the Comptroller am net even *afore* existing statutes sigaiset resaleitrest beakers abort of moving for the forfeiture of their 46411144116 Small basks realise to imams. their https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ' •-• -S. Aro aeskoiro lattolligent?-4-George Mums "spite' although admittedly their very existenoe foss dm' te day 140 often endmmored by the inadequaey ef their vetting fonds* lmeteed of increamiag melherehip in the hderal 0001,0 the number neeher banks is deereesimg. Small beaks dela that they een not affOrd to put more mew into their Waimea. or beano meathere of the Federal Mieerve-tee peer to de businees safely but cult, willing to pley with other peoples new at other people's risk. Commereial banks refUse too pert with their swifts departments lest they leee deposits, although they recognise that they ere a senstamt threat to their liquidity* Ma short, not a simgle neemere of beak reform has been proposed by dominant basking interests; met a simile meeenre of such reform prepeeed by othere hove they aocepted. Although the Iimptreller of the Currency, the Federal Meeerve beards the Soots earditbse ea Seinklag amd Cinema mad at least a Urge minority et the Nesse *mattes em the ease sehjest are agreed that no edequate eemtrol of aredit end me safe bemkimg ayatsursaa exist in thie sommtry eneept umder a vattlad system of booking mkt aational control, prebehly minetromime onewhomdredths of tbe twelve tinseled State benke mew doing besimeee ere reedy to faint with horror at the idea. Movie( embalm advaatagee in the possession et State ahmlonso—mactly la the way et loose eemtrol amd the privilege of meat, bembaug practice—they do met promo to give then up, ssmaigtmla amid them some. Merida, indeed, is the milk in the occoamets short-sighted end LOW* anode opelfishmees em the part of the dominant element in Amerieen banking* First of all there is the desire of the seem* small toms beaker, doing Wetness under a State eherters to retain em asfair—ead Imeefe.edventage ever a rivals usselly * national book* Ste motional beak rival testate *VOW the right to met ampstittas ar preetiese equally unfair and meas. this rivalry es& le equally ready te MO the law, if any, ditch woeld provost imessed beskimg* qmder this rivalry sash insists epee the right te control his book aotettbstaadiag law, pmblie policy, or the geed ef the general publie. Admittimg that many of their practices ars eneemmdm-and results dememstrate that they are Imecond *tether it is admitted er met, — they hope memo way or other to got by in se doinv-driftims, drifting, driftimg in a leak, boat in a boisterous sea with a reeky ahem ahead et thee straw with the wreekage of ten thessamd banks deetrerell to 4011704 , 94, lbw, there is the matter of Jobe—jest plain, everpday lobe* V hearts mere ages, all desires keens sad as esereta hid, beer mmmy bashers \\,,, would be femme opposing brush banking, fee, sample, ter fear that brume* ( henkimg or bask meld mallow up their ova positions? Mee Emmy \ beak offisers bake marillingly followed emeafs buskin presticee et the behest of interests which comtrol Jobe is the bean Mee meg, hookers heve lost their , their positiems is their eememmities, their homer, their al1 ard en of nally of their depeeitore Vein effort aire4 to beld their jibe MOorammy big fregs in little puddles km risked ovarr. thimg for themselves emd their elients for few et besides small frege le big peddled https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4M104.1Pli Are Bankers Intelligent?—George 1. Andersen Consider the earreweinded, pareehial outlook of the great onjoritw of small tees beakers *Lek may toe many of their large teen oollesagmes are by way ef shemime if not exceediag. Hew many of the *verge run of bankers operate their institutions as parts of the great eatiemal cracit and fiamasial mates shish they umdeukteAXY are whether so reoognised er ma memy of them have the vision to seep barged the limits of their eon little bailiwicks, the larger nevemeats in trial*, tissues Da Andestry which in reality =Irk the smesees or failure of their eemiermostieme? Of worse toe mach amst matte awaited et Woken spy mere than free any other class of oitissury• Maskers are quite hommag meet of them. in Awl* rather ordisorillyIemess In evaluating Niglio. te ouch questisas se the shove, due regard must be had ter the ussameeses sled foibles ef boson mature in every sulk ef to every eemmtry nod in ever* age. Sere nest of us in bookers, ahem, it Le quite prObable that We would be tend doing exactly what the balker is sow doing. needing the foibles sad veabmesses of human nature, believer, is no justification for a oantinuation et * state of things which threatens the well-beiag et a nation; nor can spy emsuat of explanation as te eby thiags are as they are ternish a satisfactory excuse far their beiog se. loreever, if bombers sore eeteally profit's( by e esatinuemee et preeeat conditions, the explanation siiht be sere sassimeims. Oa the 'bele it le probable that no clams of pimple gaffers mere tram the present state of Marlow& banking than Merton* banker's themselves. the feet As that• continuation of present bamhimg methods under the existiog ememelems system or Leek of system la of advmatege to no one in the isms rum4 itierytedy, in the lemg rm. mould be better Of under c mined. sates motional eyetem. Sae being the ease eae is led to incuire he, emd Why things are allowed to ge on as they have been going. Clan bankers eee what is to their ma best interest? To pet the qualities bamstIla are bashers intelligent, The lomg wares et bankiag disasters in the past tea years, the vast saiority of shish have bed no emsmemties lest. ever with boeimees Aspression, readers the question lees impomlimeat thou sight at fired appear. On the whole, perhaps, we eel sessamde *het the banker ia intelligent, but this moncludea is predicated "peel the coaditift that he change hie liOwS of thing* end his way of thinking and be right quick about it. There ems no larger be spy questisa that there Is semethiag radically wrong with the American beihimg system' 'hien, judging by the se. perigee* of other oemmtries, intelligens. eon losable end correct. It would seem to be the part of intelligence ea the pert of the average banker to sob to it, for his own peace of mind, for the sake of his own investments, his mu tation, his our job, met to oration his duty to tbe pmblic, that wells are eorreeted; aad to saerifioe, if https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -6- Are Beakers Zatelligentt-Aserge 14 Anderson Need be, email preeemt interests for larger and more peruemmet interests. Present reInctamee en the part of the bombers of the limited States to aeeept bank refers not only threatems the momminess of Amerieem fimemeee emd the well-beimg of every nen, woman and child in the country bet also etmmde as a monumental simmplifieation of a crass lack of appreelation of their rim position. Semik reform mill come promptly whoa bunkers agree to it. The beet neessre of bank intelligence at the preeent time is am intellUmmt appreciation ef the fact that the regime of irrespomeible plume bombing must be does away with if tho booking fraternity is met to suffer the epasequesses of the wrath of a lens suffering, outraged and me upper patient people. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Referendum No. 63 on the Report of the Special Committee on Banking, Part TI Chamber of Commerce of the U. S. A. December 9, 1932 Committee Report Branch Banki.ni The Committee presents a number of recommendations with regard to branch banking,mhich tt considers to be one of the most important subjects treated in its report. The recommendations, followed as a group by supporting statements, are: (1) National banks, unlimited by restrictions of state laws, should be permitted by federal statute to establish statewide branches, provided that in any state continuing to prohibit statewide branches of state banks the federal statute should not become effective for a period of six months after its enactment. (2) Any grant of branch banking powers to national banks should be given also to state member banks of the reserve system, subject to concurrence of state laws. (3) Statutory permission to member banks to establish branches should be conditioned upon the approval of administrative authorities, subject to definite requirement that the capital of a branch system be at least the aggregate of the capital that would be required if each banking office in the system were an Independent national bank. (4) Administrative authorities should be granted porer to require a showing in case of the application for a branch that the general condition of the branch system, as well as the conditions under which the branch would operate, indicate the probability of successful maintenance of the proposed branch. (5) The right to establish a branch in any given location within the branching area, should be denied if there is an administrative finding that the banking requirements of the district of the proposed branch are being adequately serviced. (6) There should be legislative grant of discretion to the administrative authorities to require suitable notice of intention to establish a de novo branch or to acquire branches by merger, as well as of discretion to withhold final approval for a reasonable period of time. (7) Subject to the concurrence of the Federal Reserve Board, the authority to permit or deny branches should be given to the Comptroller of the Currency with respect to national banks and to the reserve banks with respect to state member banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ******** • - 2Your Committee believes, however, that one road to improvement of aur td,/ banking situation is the orderly and carefully regulated development of branch banking. The loss of the independent status of some banks, not now in a position to protect fully the safety of the bank depositor or to furnish adequate banking facilities to their communities, would result in benefit if those banks should be converted into branches of strong banks. It has also become generally recognized that there must be careful avoidance of the creation of unnecessary institutions whether they be unit or branch banks. Considerable hardship has been experienced by some communities because of the partial or complete break-down of their banking facilities. In instances it is difficult, if not impossible, for local interests to assume the entire burden of re-establishing needed banks or to protect adequately the capital structure and deposits of existing banks. In a regrettable number of cases, in the absence of branch banking, weak national and state banks continue because no available means offer to affiliate them with strong institutions. Branch banking would provide solution to most of these problems through enabling strong, well-managed institutions to invite existing banks to combine with them and strengthen the facilities offered the public, including the establishment of such offices as might be required in the smaller towns and villages. The Committee has reviewed studies of branch banking made here and abroad, and concludes that doubts as to its broader applicability to our requirements are umarranted and must yield to the needs of the present situation. It believes, moreover, that branch banking, if it is to be effective, must be so devised that each branching area shall include business centers possessing adequate_financial_ strength and shall embrace a_reaeodare diversity of agricultural, business and industrial enterprises. While the most desirable diversification may not be secured in all instances, the Committee believes that state-wide branch banking will greatly strengthen the general situation and will provide in a great many states the means of sufficient banking stability. ******** Because of the prohibitions upon state-wide branch banking by national and state member banks of the federal reserve system, which furnish about sixty per cent of the banking resources of the country, and the fact that either limited or no branching privileges are permitted state banks in many states where relief is needed, it is imperative in the interest of general improvement that branch banking legislation proceed from the Congress of the United States. ******** * * * * * * In particular, it is of high importance that the properly operated unit bank which is adequately serving the financial interests of its community must not be subjected to unnecessary or uneconomical competition from new branch banks established by outside interests. Sound banking requires also that branch systems should not be built by reckless competitive https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 3- • bidding for the shares of existing banks. If the "over-banked" condition which exists in some localities is to be avoided elsewhere, there should be a curb upon any unbridled race for supremacy in both the number and extent of banking offices and upon those forms of competition which compel a bank to enter reluctantly upon branch banking in order to protect its correspondent banking business or to maintain its position in the financial structure. * * * * * * It would be fruitless, therefore, to propose branch banking as a strengthening measure without requiring that there be demonstrated capacity of management to cope with the problems confronting it before any bank is allowed to engage in branch banking. No less important is the requirement that a bank engaging in the operation of branches should have unimpaired capital funds adequate to serve the needs of the communities in which it does business. In requiring the possession of adequate capital, the Committee recognizes also that an effective check would automatically be placed upon undesirable development of branch banking. While favor is found for the proposal that the capital of a branch system should not be less than the aggregate capital that would be required if each branch of the parent bank were an independent national bank, the Committee believes that the additional branch banking powers should be devised with special attention to servicing the requirements of rural communities and of small cities. Some limited grant of discretion might be given to administrative authorities to permit, under exceptional circumstances, the establishment of branches in such communities if, for instance, the parent bank can meet the capital requirements of state law for independent state banks in such particular locations. After its canvass of the situation, the Committee has concluded that the only effective manner in which the above recommendations could be properly carried into effect, excepting those regarding capital requirements, would be to vest broad discretionary powers in responsible supervisory officials to grant or withhold permission to engage in branch banking. In order that there may be uniformity in the development of branch banking within the confines of the federal reserve system, it is proposed that so far es federal legislation is concerned, the authority to prescribe regulations affecting branches of a national bank be vested in the Comptroller of the Currency, and the authority to prescribe regulations affecting branches of a state member bank be vested in the federcl reserve bank, subject in both instances to the review and concurrence of the Federal Reserve Board. The reserve banks and the Federal Reserve Board should maintain consultative relationships with state superintendents of banks and other state banking authorities in the matter of allowing or denying branches to state member banks. * * Messrs. Adams, Johnson, Lonsdale, McLuaas and McWhirter are not in accord with the recommendation that a national bank be granted the power to establish, under limitations, state-wide branches in those states in which state banks are not permitted uuch branches under state laws. They support the principle of state autonomy in relation to branch banks. Mr. Lonsdale records that he takes this position for the reason, among https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 4 Note - Continued others, that since we have a dual state and national banking system, the autonomy of the states should be respected to the extent that national banks competing with state banks should not be given powers prohibited under state laws to state banks. He observes that in recognition of this autonomy Congress in the past has limited the rights of national banks to such as are permitted to competing state banks operating under state legislation. He mentions as examples the enactment of Section 11-k of the Federal Reserve Act, in which it is provided that trust powers shall not be exercised by national banks where such powers will contravene the state laws relative to competing state banks and trust companies, and Section 9 of the Act which permits rather than compels membership of state banks in the federal reserve system and allows such state banks to become members even though they are operating branches to an extent not permitted national banks. Mr. McLuces records that he would have preferred that the Committee report of follow the resolutions on branch banking, adopted by the Executive Council unit that effect the the American Bankers Association in April, 102, to banking laws should be modified only to an extent that would permit, where areas economically justified, community-wide branch banking in metropolitan however, respect, every and county-wide branch banking in rural districts. In branch g governin he believes the autonomy of the laws of the separate states banking should be preserved. * ******* banks Mr. Robinson supports the Committee's recommendation that national whose states in be allowed to establish state-wide branches, after a period, opinion, laws do not permit state banks to have such branches. He records the branch, a h however, that no national bank should be permitted to establis over_an outside the city of location of the parent bank, except by taking branch be existinLunit bank or a bank already affiliated_with it, unless the state or national established in i-City, town or village where there_is no a such . He believes baia rektilgTi-Maiacting customary banking business Bill to the Glass Fe-itintion (much as provided in the Vandenburg-iiendment adopted. be should proposed in April, 1932) Group Banking The Committee recommends that: systems to (1) Provisions of law and supervision should require group member banks, include as far as may be practicable only national and state system, reserve federal the of members ts make all of their eligible componen to systems group within banking branch and facilitate the development of the limit of legislative grants of power to possess branches. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • -5(2) Legislation should prohibit group banking aystems from acquiring additional component banks of more than one federal reserve district, except with special approval of reserve authorities. (3) Legislation should require that the books and records of a holding company owning or controlling a national bank and/or a state member bank, whether acquired prior or subsequent to such legislation, be made subject to examination by the Comptroller of the Currency and/or the federal reserve authorities. Where a group contains both member and non-member banks, the parent corporation and all its components should be subject to examination by federal authorities. (4) Insofar as special regulations may be needed for the purpose of expediting examinations of group systems, federal authorities should be empowered to require adequate reports of condition of the group banking corporation and of each of its components. (5) In the case of a group banking corporation holding shares of stock of one or more member banks of the federal reserve system, there should be statutory requirements for the establishment and maintenance of suitable reserves, invested in readily marketable negotiable assets, other than bank stocks, in order to assist the group system in protecting the solvency of its components. In general, the amount of such reserves should be not less than 25 per cent of the banking capital employed except that in cases where doubleliability attaches directly to the stock of the group banking corporation somewhat smaller reserves might be designated. Such reserves should not be available as security for any form of pledge except for the purposes for which the reserves are required. (6) Legislation should require that after a reasonable time no component of a group banking system could lend upon the security of the stock of the holding company of the group system. (7) A component bank of a group system should be prevented by law from lending to another component of the same group more than 10 per cent, of the lending bank's capital and surplus. Its loans to all components of a group system should be limited by law to a reasonable proportion, say 20 per cent, of its capital and surplus. All loans of one component bank to another component should be required to be secured adequately and fully by readily marketable securities or paper of the type rediscountable by a reserve bank. (8) The capital issues of a holding company of a group banking system should be confined to one class of stock; no debentures or other bond issues should be permitted. (9) Federal law should require that any undertaking to merge or to effect other amalgamation of the stock interests of two or more group banking systems, containing national or state member banks as components, be aubjected to the consent of the federal supervisory authorities. (10) Federal law should require that any group banking system containing national bank or state member bank components, be prohibited from owning or https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • -6controlling the stock of a corporation not engaged in the usual business of banking unless it has the permission of federal authorities vested with power to supervise banking. (11) Upon a finding by the Federal Reserve Board that the components of one or more group systems control the election of directors of a federal reserve bank to the detriment of the interests of other member banks, the board should have power to limit or suspend the voting privileges of such group components. ******** The business of a corporation which controls banks through stock ornership partakes so much of the nature of banking itself that it is proper to subject it to public regulation similar to that imposed upon banking institutions. If such regulation is to be effective, supervisory authorities must have power to inspect each component of a group system in addition to the holding company. A single holding company can control national banks and member and nonmember state banks of the federal reserve system. Its national banks would be subject to the supervision of the Comptroller of the Currency, as well as of the federal reserve authorities, and its state banks to the supervision of the authorities of the states in which the banks are located as well as of reserve authorities if member banks. If its national banks and state member banks are located in more than one federal reserve district, they would be subject to the supervision of the reserve authorities of their respective districts. * * ** ***** To allow group banking to develop under diverse laws and regulations with comnonents subject to examinations by different sets of authorities, federal and state, presents possibilities of grave abuse through shifting of assets and through failure of supervisory authorities to discern the effects of one component's situation upon the safety and strength of other components. It is desirable that all member banks of the federal reserve system and the system itself be protected from weaknesses that might be visited upon them through improper operations of non-member banks not now subject to central supervision. If group bank organizations are to be permitted to include many weak banks, or through diversity of law and regulations to visit upon entire systems in an aggravated manner the weaknesses that may develop in some components, grave harm would result to bank depositors and to large sections in which such systems are operating. Unregulated group banking has such potentialities of abuse that so far as practicable its development should be related in the public interest to the evolution, growth and solidarity of the national banking and federal reserve systems. * * * * * * It is readily apparent that the capital structure of a group banking organization, the methods of obtaining its operating funds, and the establishment and protection of suitable reserves should conform to rigid standards applicable to banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ***** * *** * * * * * * * The prohibitions which generally exist against the making of loans by a bank upon the security of its own stock should be recognized in relation to the stock of a holding company. 4 ******* In its discussion of branch banking, earlier presented, the committee has recommended that administrative authorities should be pernitted to require a showing, in case of the application for the right to establish a branch, that the general conditions of the branch system as well as the conditions under which the branch would operate indicate the probability of its successful maintenance; that the power to establish a branch at any given location within a branching area should be granted only after an administrative finding that another bank, with or without branches, is not adequately servicing the banking requirements of the district of the proposed branch, and that federal supervisory authorities should be vested with power to prescribe regulations with respect to the granting of branch banking privileges. It is only consistent, therefore, to urge that group banking systems should be subject to similar requirements when they undertake to add additional component banks. *** * * * ** In the Committee's judgment it is highly desirable to prevent group banking systems, insofar as they can be made amenable to federal law and regulations, from engaging in extensive, diverse interests outside of the usual field of banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ******** - • *: . lg., C-A-..merce WiFI-tngton, D. C. ILu-1,;.akvr Walton L. Cfc.ck-r, PreS., John Hancock Mut. LifE, Boeton, Mass. M. 7..rb-;,rg, Ohm. of Board, 7.T.t.dttInt-1,11 P.:!ceTr.ln(!e Bank, W-Jc N. 7. David M. Goodrich, Chr,A. of BoArd, The B. F. Goodrich Co., 250 Park Ave., New York, N. 7. 117.: A. Lot-1), ChltirmAn, Tra-.olvents Nc0-.1cnal Bank & (Trust Co. Phiiaielphlh, Alba B. Johnson, 1521 Packard Building, Philadelphia, Pa. IV wvcS! Ara W. M. Baldwin, Pres.) The Union Truat Co., Cleveland, Ohio. loolge T. Ladd, Pres., United Engineering & Foundry Co., Pittsbureh, Pa. J'hn M. Miller, Jr., Pres., First & Merchants Natl. Bank, Richmond, Va Junium P. Fishburn, Pres., Times-World Corporation, Pc.mtnoke, Va. Oliver G. Lucas, Pres., Canal Bank & Traat Co., New Orleans, La. • P. G. Shook, Shook Fletcher Supply Co., Birmingham, Ala. Felix M. McWhirter, Pres.) The Peoples Sta.te Bank, Indianapolis, Ind. J. Paul Clayton, Vice Pres., Central /11inois Public Service Co Springfield, ril. :ohn G. Lonsdaie, Pres., Mercantile-Commerce Bank & (Trust Co. St. Lou's. Mo. Paul Dillard, Prea., Dillard & Coffin 0o., Mcmphib Tenn. E. W. Decker, Pres., Northwestern Bancorporation, Minneapolis, Minn. ffilliam J. Dean, Prea.) Nichols, Dean & Gregg, Pt_ 2aul, W. S. McLucas, Chrm. of Board, Commerce Trust Co., Kansa, City, Mo. W. L. Petrikin, Chairman, The Great Western Sugar Co., Denver, Colo. Nathan Adams, PrOS., American Exchange N.Al. Bank, Dallas, Texas. J. J. Culbertson, Vice Pres. Southland Cotton Oil Co., Faris. Texas. Hem, M. Robinson, Chairman, Security-First Natl. Bank, Los Angeles, Calif. J. B. Levison, Pres., Firemen's FUni Insurtnce Co., San F-ancisco, Calif. L 7.ork V Vi Atlanta VII Chicago St. Louis IX Minneapolis Kansas City Da13.6.8 XII 6en Francisco https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Referendum No. 63 on the Report of the Special Committee on Banking, Part II Chamber of Commerce of the U. S. A. December 9, 1952 Minority Report It is desired to specifically and emphatically dissent from the recommendation of the committee: National banks, unlimited by restrictions of state laws, should be permitted by federal statute to establish statewide branches, provided that in aqy state continuing to prohibit statewide branches of state banks the federal statute should not become effective for a period of six months after its enactment, as well as from certain aupporting statements pertinent to its recommendations. It is obvious that those members of the Committee permitting their names to be affixed as signing the report favor what is now known as Section 19 of the third draft of the Glass Bill, S. 4412. Should their recommendations become effective through legislation national banks would be permitted to establish statewide branches in every state, regardless of the branch powers granted state hanks--even, in fact, in states where it has been specifically declared as the public policy of the sovereign state that branch banking shall be absolutely prohibited. This would be as flagrant an invasion of state rights in the financial field by federal political power as has ever been attempted. It would force almost unrestricted branch banking on the states regardless of local sentiment. It would give auch competitive advantages to national over state banks as to lead definitely in the direction of a single banking system in the country in place of the present system of state and national banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** ***** Felix M. Mahirter, Pres., Peoples State Bank (NM) Indianapolis, Indiana. Referendum No. 65 on the Report of the Special Committee on Banking, Part II Chamber of Commerce of the U. S. A. December 9, 1952 Arguments in the Negative ********* * * * * * * It is now proposed, however, that the larger national banks in each and every state may operate branches throughout their several states, upon obtaining permission from the Federal Reserve Board. That the people of the state had by legislation declared they wanted no branch banking of any kind within their borders could not make any difference; branch banks could be thrust upon them regardless of their wishes. ** ******* * * * * * On October 4, 1952, the State Bank Division of the American Bankers Association adopted resolutions expressing determined opposition to the provisions of the Glass Bill "which would give state-wide branch banking powers to national banks in all states regardless of restrictions as to branch banking on state banks by state laws." The resolution added: "This is a deliberate attempt to overthrow the sovereignty of our states; it is contrary to the policy which has built up this republic and would lead to a system of nation-wide branch banking." Smaller National Banks National banks themselves, particularly the smaller ones and those outside large centers, would be exposed to competition of a destructive kind against which they are now fairly well protected, if the provisions of the Glass Bill were enacted; for a branch of a large national bank of another city might be opened next door. The Committee suggests certain restrictions but, if adopted, these restrictions could not prevent a new form of competition for national banks in smaller cities, with the branches that are set up possibly taking away business from long-established and sound banks. It is to be remeubered that there are diversities in managerial abilities among large national banks as well as in other fields of endeavor, and there is no assurance, and in the nature of things can be no assurance, that the only large national banks to operate branches will be tl,ose that are conservatively and soundly managed. * * * * * * Minority of Senate Committee On opposing the part of the Glass Bill relating to branch banking, the minority members of the Senate Committee on Banking and Currency said: "All things considered, the American system has held up wonderfully well. ... There is a movement on foot to control the banking industry of the United States by centralization. .. Of late years this movement has been becoming more evident. ... Our dual system of banking has been one of the greatest motivating https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • 2 factors in ranking the United States the outstanding country that it is today. Our country is too large, too widely diversified, to expect one banking system to be so versatile as to deal with so complex a situation efficiently. The American people are individualistic and so should be our banking structure. ... The placing of aur banking structure with the now over-burdened bureaucracy in Washington is in direct violation of the principle of state rights." Local Branches Distinrmished It is evident that up to the passaue of the McFadden Act there never had been any disposition to alter the original conception of the national bank system as a unit system. Even the provisions of the McFadden Act allowed only intra-city branches in auch states as permit branch banking under their own laws. The operation of additional offices within the limits of the city in which the parent bank is located is not to be looked upon strictly as branch banking. It is a local issue and contains no elements of danger to the banking system of the country. The home-city branch is simply a means of furnishing a convenient service to customers and gives to national banks a means of competing in customer accommodation with other banks within the city. State-Wide Branches It is in the broader application of the principle of branch banking to state-wide areas that grave dangers arise. A single bank operating a number of branches in many parts of a state is in a position to control the banking facilities of entire communities and bring ruinous competition to the smaller independent banks. ***** * ** Concentration of Control Proposed measures for the extension of branch-banking privileges to national and state member banks will have the effect of materially undermining the unit system of control and consequently the individualism in operation Thich is fundamentally adapted to diversified conditions in the United States. Branch banking is monopolistic in tendency. It furnishes the means of concentrating the resources of a number of localities in the hands of a few individuals, who have in their control the retardation or or the development, as their interests dictate, of individual communities local from business enterprises. It introduces absentee operation, free to be pride or responsibility, and an opportunity for the banking business conducted entirely in the interests of profits to outside concerns. ******* * * * * * * * But it is in this larger and more desirable business that the the competition of branch banking system comes into conflict with readily more grant independent banker. These demands the branch banker can be forced would banker and more directly. The result is that the independent to ultimately or gradually to rely on the smaller and less desirable business go out of existence. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • - 3* *** * * ** The membership of the federal reserve system is composed predominantly of a large number of individual banking units under separate management, situated in all sections of the country. The strength and utility of the system for meeting a wide range of diversified conditions depends on the maintenance of a broad membership and the coordination of widespread individual interests. Any substantial reduction of the number of separate national banks and state banks in the system, through consolidation and conversion into branches, would evidently produce limitations on diversified representation and the voting power in each district. The resort to state-wide branch banking would conceivably have the result of throwing the effective control of the entire system into the hands of a relatively few interests. * * * * * * ***** * ** Group Banking Holding companies do not exist under federal statutes, as do the national banks and the federal reserve banks. Holding companies exist under state law. Under their charter powers as granted by the states they may own capital stock, not only in banks, national and state, but also in other corporations. Group banking occurs when a holding company proceeds to acquire the stock of a series of banks, subjecting them to a general central direction, much as a holding company in the public utility field acquires the stocks of operating companies and subjects them to a common direction. A question at once arises if, whatever the mrposes with which existing holding companies operating banks may have been organi7ed, and whatever the immediate benefits they may have braught in some areas, ownership and control of bank members of the federal reserve system in compatible with the basis of the system--a series of independent banks so owned and managed that personal responsibility can be enforced. ********* Difficulties of Reoulation The provisions of the Glass Bill suggest that there are the same difficulties in regulating the holding companies in the banking field as were encountered with such companies in other fields. The Interstate Commerce Commission has advocated legislation which will make amenable to it holding companies owning stocks in railroads. In the field of public utilities there are outstanding Banking is like enterprises problems of regulation by the state commissions. public utility field, in and in the transportation in the field of railroad authority. Such regularegulation by public that it is properly subjected to and ownership that management tion is necessarily premised upon responsible of a corporate device, intervention The can be readily identified and reached. inconsistent with principle is in ownership and management, both obscuring adequate and proper regulations. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ********** • 4Inadvisability of Legj.slation The differences which appear even in these brief outlines of four groups bring out the circumstance that each has been moulded to meet the conditions in its area. For instance, the group in the northwestern states shows an effort to guard against the effects of adverse conditions in one or more of the states, through inclusion of such a number of states that it is obviously hoped that adverse conditions will not exist in all at the same time. In each case, the conception is of a strong central organization, ably manned with seasoned experience of the highest type afforded in the area, this central organization providing not only advice and expert assistance, but also financial aid. Such a development may well be in its initial stages, and until there are untoward incidents, such as in fact do not seem yet to have happened, legislation should not hamper the benefits which may be brought to an area where banking stability is, under current conditions, most highly desirable. In other words, the alternatives would seem to be either an effort to prevent any holding companies in the banking field, for such reason as has been suggested above, or freedom for the development of group banking in ways that may greatly benefit agricultural and industrial areas which have had troubles of a disastrous kind with wholly independent banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis er—r-10 SOURCE: MINUTES OF THE FED. RES. AGENTS' CONFERENCE*Aash. Nov. 1932 (Confidentid) Page 14 (?)---Pages not numbered. NATIONAL AND STATE BANKING SYSTEMS OF THE COUNTRY. (A discussion of the weaknesses that have developed in the systems during the present period and what can be done to strengthen these systems.) (57) districts in connection with group various of Topic 5-C. Experiences banking. - Mr. Stevens. air. Stevens stated: "I think it may be said that while this system may have had some considerable effect in lessening the number of bank failures, it has not been satisfactory from an operating or an earning standpoint. I am quite sure that all of these groups would welcome a branch bankin.g .law which llould enable them to couvert their group_banks into branches. The group banks under local management and with local boaiTE-ffave not always been amenable to the suggestions of the parent institution and have had their own ideas about how the banks in their own communities should be run, and it has been difficult to bring the various banks into common policy and practice. In numerous cases the parent institution hes been called upon for very substantial sums to save these banks from closing, and on the other hand the benefits to the parent institution have been com,aratively negli6Dle." Mr. Case stated that from his observation of the operations of group banks, several conclusions seemed to be obvious: "(1) For successful operation a group of banks requires management of a quality higher than that necessary for successful management of individual banks. (2) In the majority of cases, but not in all cases, group management has improved the standards of the group members. (3) Considerable advantages in the way of economies and lessened losses can be obtained by group management. (4) Group banks are quite uuccessful in holding deposits and competing on favorable terms with independent institutions. (5) Banking dangers which may result from losses due to poor loL-ms, bad assets, etc., or from bank runs, are greater where they occur in groups than for individual banks, for the reason that if one member of a group loses the confidence of the public, the entire group is likely to be affected. (6) Group banks offer to some extent the advantages which accrue frpm branch banking operations, but the group banks do not obtain a like degree of flexibility or safety." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • A Review of the Proceedings of the Williamstown rnstitute of Politics; 1932 Sessions 0ournal of Canadian Bankers' Asso., Oct., 1932) ******* ** Aserkm_ftkin It was not only in its international field of action that American finance was weighed in the balance and found wanting. Both American end foreign speakers repeatedly referrod to the Inadequate banking system with which the United States is burdened, Professor Gregory outlined sews possible measures of reform. Although the security-issaing subsidiaries or the big Amorican banks night have fulfilled a very valuable function, if they had been managed differently, nevertheless experience had soarinced him that these subsidiaries ought to be abolished. Ns also hoped that, in the fUtnre, the bankers would regard themselves as professional men rather than highly convetitive business nen. Regarding the structure of American honking, the two most necessary changes appeared to Professor Gregory to be, first, the unification of the system by moose of the States revising their banking legislation in line with the National Dank legislation of the Federal Government. A first step in this direction would be the unification of the various systems of inspection, since it is the more rigid inspection requirements twined upon the natiamally chartered hanks and asebsee of the Pectoral Reserve System whieh keep many banks with State &tartars from joining the system, ?he second immoral line of rears which was recommended was the axtension of branch banking, This qp_c_gr banking Diatc.simly weeds rub, but also attracts a better type of man into th..Aeld t1204 cares to t4M1, 1 rt *unit banking' ventures whose capital may be only a few thousand dollars and jih—li_ciasmins may all be tied up in a one-horso town. Unfortunately these isproweents depend upon lngislation by the forty-eight states. It is not likely, therefore, that they will he introdused with a rush, In the UMW while the Ameriems banking system will math as unco-ordinated and as difficult to regulate as it stands today. ( https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *** * * ** * * * • Address by Harry B. McDowell, Vice Pres., McDowell National Bank, Sharon, Pa. 31st Annual Convention of National Asso. of Supervisors of State Banks Philadelphia, July 1932 ** *** *** ** This subject of branch banking--both as a theoretical system in America and as a banking process tending towards further concentration of our money power--has been before bankers and governmental authorities for many years. In 1925 a futile attempt was made to put the American Bankers Association Convention on record in favor of nation-wide branch banking. The subject was then permitted to lie dormant until May, 1928, when the Comptroller of the Currency, Hon. John W. Pole, in an address before the Maryland Bankers Association, stated that five thousand banks had failed, having liabilities of one billion, five hundred millions of dollars. He thereupon recommended enactment of a Federal law permitting Branch Banking within so-called "Trade Areas". In 1930 the A. B. A. again considered this question and again it was "thumbs down" on any and all branch banking independently imposed by Federal law. The Association declared for identical branch banking privileges for state chartered banks and national banks within the boundaries of any state. Also the 1930 resolution referred to community-wide branch banking in metropolitan areas and country-wide branch banking in rural districts where economically justified. We who oppose unified branch banking imposed by Federal law do not object to the terms of this resolution, nor do we object to all forms of branch banking, so long as the form is left to the judgment of the individual states. ****** **** We hear much today of frozen loans. Of course, strictly speaking, loans are nearly always frozen. Very little credit can be liquidated in cash, because there is not that much cash, and most loans are paid by a transfer of credit. Depositors, however, have changed their status, and have demanded cash for their credits, 8nd loanable funds have dried up. The relationship between bank and depositor has changed, and when the local bank fails, the people owe each other without the intervention of the intermediary, the bank. Now if local improvements have been provided by local loans the community has benefitted, and all of the people are the beneficiaries. So even the failure of the bank does not remove all of the benefits that have been created in a given community by its unit bank. A much different picture than we would have if a branch bank gathered up money as deposits, and shipped the money to the head office at another place for investment in pet projects either in this country or abroad. Upon failure of that branch, the community has not only lost its deposits, but has received no compensating advantages. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis **** * * **** — 2 — Those who read the inspired articles now appearing in all classes of magazines and who do not take "setting—up exercises" with the head, may have come to believe that with Group, Chain or Branch Banking established, all banking troubles would disappear. This fallacy doubt— less caused the birth of some of our largPst groups of banks, whose promoters in addition to their craze for bigness, believed that the Feder.J1 Farm Board would be able to stabilize grain prices. They know better now and we know that they did not furnish those "much needed" banking facIlities to small communities, as had been announced in high places. Let us review for a moment, five similar promises now being made bY the advocates of branch banking: 1. They promise a cessation of bank failures because weak banks will be absorbed. 2. They promise that branches will be widely scattered so as to divide the risk caused by the lack of diversification in local business enterprises. 3. They promise expert management—that is, the services of professionals to be substituted for those of amateurs. (By the way, I recently heard the definition of "an expert": some one who knows more and more about less and less until he finally knows everything about nothing.) 4. They promise a sort of super—banker who sees all, hears all, and knows all, and who can never make mistakes or be misled. 5. They promise to restore confidence. ****** ** With regard to the conduct of banking in widely scattered locations, it is well known that a widely scattered business cannot be well managed: And you people know that that sort of bank cannot be properly examined, nor can it be adequately supervised. So promise No. 2 can be dismissed. The third promise has to do writh supplying expert bank management-that is, the services of "professionals" as opposed to the services of amateurs. You will pardon a smile—not too gleeful—on my part. I am the owner of certain stocks in companies managed by experts. My bank owns bonds that were created, recommended, and sold by experts. There— fore, I have some personal knowledge of what expert management costs. When I invested my own funds and those of my bank, I did not know about secret bonuses; about division of profits with the management; and about rights to buy stock at secret prices. Now I know a lot about them and have a better conception of what this word "professional" means in big business. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 3A friend of mine was employed at $50,000.00 a year by a certain corporation. The corporation expanded and with the broadening of my friend's work his nominal salary was increased to $75,000.00 a year--that is, the stockholders believed his salary was t75,000.00. But my friend and his fellow officers participated in a pool of 5% of the net earninus of the corporation and also were permitted to buy corporation stock at 60% of its then market value. Th,t job was worth to my friend one hundred and seventy-five thousand dollars a year. This was "professional" management in one very large corporation, and there have been many such. May the Lord deliver us from "experts"! ********* Let us now inquire as to the actual reason back of this sudden agitation for branch banking. According to an opinion rendered November 6, 1911, by Frederick W. Lehman, Solicitor General of the United States, group and chain organizations owning stock of a national bank, are operating illegally. The opinion follows: "Referring to Section 5133 of the National Banking Act: "Associations for carrying on the business of banking under this title may be formed by any number of Natural Persons not less in any case than five * * * * *. It should be noted that only 'natural persons' may engage in the formation of a bank * * * * *." "Section 5146 provides: "Every director must, during his whole term of service, be a citizen of the United States, and at least three-fourths of the directors must have resided in the State, Territory, or District in which the association is located, for at least one year immediately preceding their election, and must be resident therein during their continuance of office." "Here the local character of the bank is secured." "Section 5197 limits the rate of interest which may be taken to that 'Allowed by the laws of the State, Territory, or District in which the bank is located.'" "This again emphasi7es the local character of the institution." "Quoting from the Court's opinion in Concorn First National Bank vs. Hawkins (174 U. S. 364) and referring to the National Bank Act: "One of the evident purposes of this enactment is to confine the management of each bank to persons who live in the neighborhood, and who may, for that reason, be supposed to know the trustworthiness of those who are to be appointed officers of the bank, and the character and financial ability of those who may seek to borrow its money." "Referring to the control of banks by interests outside the local communities: "The property of the local stockholders, so far as thus invested, would not be managed by directors of their own selection, but by distant and unknown persons. Another evil that might result, if large and wealthy banks were permitted to buy and hold the capital stock of https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -4other banks, would be that in that way the banking capital of a community might be concentrated in one concern, and business men be deprived of the advantages that attend competition between banks. Such accumulation of capital would be in disregard of the policy of the National Banking law, as seen in its numerous provisions regulating the amount of the capital stock and the methods to be pursued in increasing or reducing it. The smaller banks in such a case would be in fact thaugh not in form branches of the larger ones." * * * * * * * * "Referring to Section 5201: "This provision forbidding a national bank to own and hold shares of its own capital stock would, in effect, be defeated if one national bank were permitted to own and hold a controlling interest in the capital stock of another." "Here is an express recognition and assertion of the local and independent character of our national banks and the denial of any power which would tend to create what is in effect a central bank with branches." * * * * * * "From the history of the national banking act, from its terms and provisions, and from the decisions of the Supreme Court construing it, these propositions are derived: "V. The powers of a national banking association are and can be granted only by the United States, and as no grant of such powers is made by the act to any State corroration (i. e. holding company) they may not be exercised by such a corporation. "These propositions relate to matters of substance, and so may be no more evaded than violated. Indirection, if it accomplishes the same purpose, stands upon the same footing with direction." "It is not necessary to consider whether the National Banking Act absolutely prohibits the holding of shares in a national bank by s State corporation to any extent or for any purpose, and it may be conceded that a State corporation may acquire such shares as an incident to securing payment of a debt and hold them to a convenient time for sale, or that an institution like a trust company may hold them in a fiduciary capacity, but certainly there can be no holding of such shares by any corporation when the result is to defeat the policy of the National Banking Act; that is, to destroy the local character of the bank, break down its independence, vest its control in another corporation, and link it in substantial proprietary interest with some other business than national banking. * * * * * * "No authority is given by the Federal statutes to the National Banking Association for assigning their powers and delegating their duties to a corporation created by a State, and which, under its charter from the State, may engage in a business and exercise powers denied to the banking association by the law of its creation. "Here again it is to be observed that if the power in question exists, it exists without limit. The company may extend its power to the rull control of all the banks into which it has made entrance. Nor need it stop with these. As it grows by what it feeds upon it may expand into a great central bank, with branches in every section of the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -5country. It is in incipient stage a holding company with banks, with added power to hold whatever else it may find to be to its advantage. * * "If many enterprises and many banks are brought and bound together in the nexus of a great holding corporation, the failure of one may involve all in a common disaster. And if the plan should prosper it would mean a union of power in the same hands over industry, commerce, and finance, with a resulting power over public affairs, which are the gravamen of objection to the United States Banks." **** Company in its holdings of national "I conclude, the **** bank stock is in usurpation of Federal authority and in violation of Federal law." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Respectfully submitted, Frederick W. Lehman, Solicitor General of the U. S." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis . CAGLE tz' LIR. HORTIRTT . DR?,r.snBis SOL01,101i BLATTTER Stucly • Address by j. S. Love, Superintendent of Banks, Miss. 31st Annnal Convention of National Asso. of Supervisors of State Banks Philadelphia, July 1932 * * * * * * * * ** There appears to be no check upon branch banking extension into territories already adequately served. There are also no limitations to prevent branch banking from springing up promiscuously, and there is no respect for State laws prohibiting branch banking within its borders. In other words, the Glass Bill will force such types of banking in the State, whether it wants it or not. We have all been at a loss to understand the reason for such revolutionary proposals in the banking business, but undoubtedly there is a motive behind it all that is not clear at this time. If this measure becomes a law there will be no choice left for good solvent banks. It either would have to sell to the highest bidding branch system, or it would have to liquidate, or try to establish a branch banking system of its own, provided it is a National institution. ** * *** *** Branch banking, as proposed by the Glass Bill, is undemocratic and un-American. It runs at variance to the well established austom of self-government of local institutions. And in the end we can't get away from the fact that this branch banking idea is being fostered by a few large city bankers who have established large group banking systems and are now desirous of converting them into branch banking systems for reasons we can well understand. **** ** * ** Branch banking with remote control discourages auch outstanding factors in good banking as the employment of community resources for the community's own benefit, and discourages the prevalent idea that has prevailed in America that our leading citizens should have a part in the management of their local institutions. It has been said that this system of brancb banking, if enacted in the law, would merely become a window dressing for the determined drive to destroy our whole unit banking system, end it is admitted that it strikes at the very foundation of American principles. * *** ***** In discussing branch banking we offer no opposition to all forms of branch banking. To the contrary we see merit in some features of branch banking, and to further promote the interest of sound banking and sound unit banking system thousands of smaller banks must go and the capitalization of banks must be materially increased, and small banks located in nearby communities should become branches of large banks in that region. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • - 2Branch banking confined to a State and certain regions in that State should be permitted. It will tend greatly to strengthen the banking situation. For instance, it would be very much more advantageous to have the small banks in one county to be consolilated with the larger banks located in the county site,becoming a branch of that larger institution. I can see good reason in forcing such consolidations, thereby establishing larger and better managed institutions in the various counties or regions. I can go further than that: I favor forcing the stockholders and directors of those institutions to take a substantial loss in order to perfect this kind of organization. Other business units consolidate and scale down in such fashion and orners take losses in order to strengthen their organizations, and banks must do the same thing. Bank depositors now place safety of their deposits above the question of where a bank is located or whether it is a branch or an independent bank. In establishing branches of this nature, the persons applying must be the proper ones to establibh the institution. They must be required to furnish sufficient capital to serve the needs of the community, leaving to the Commissioner of the State the question of how much capital shall be required, bow much territory shall be covered, and how many branches shall be established. No bank should be permitted to establish a branch merely because it has a capital. Tests other than capital are of greater importance. Branch banking within a limited area has great merit, but it is absurd to think about countrywide branches or National banks boiling down our banking structure to a few systems with remote central control located in our larger cities. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis A- if A- it- 41 -OE . IA Ili ) f off-,01 , 4141`` . "h tera-C :ta,„ A4 IkeLoa., e,AA 4.,ta Loa. 7 1-"Avnive 4 .41,140_,OA r 4- dev, 4441 Report of the Resolutions Committee 51st Annual Convention of National Asso. of Supervisors of State Banks Philadelphia, July 1932 **** * **** "(3) BE IT FURnER RESOLVED, That we are opposed to Section 19 of the so-called Glass Bill, which provides that National banks of $500,000 or more capital be granted the right to establish branches in any state, even in states now prohibiting branch banking. We regard this as tending toward the ultimate elimination of the independent unit bank, and is an attempt to destroy the sovereignty of the states-a fundamental principle of our democratic form of government even since the establishment of this Republic. Safe and sound banking must ultimately rest, as it always has, on management, regardless of the form of banking. "This Association has always stood for the continuance of the present dual system of banking--State and National--and we feel that any change in the form of banking, by legislation, either State or National, should preserve in toto the rights of existing institutions, and we believe that by doing so the interests of the public will be best served. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ********** "Recent Federal Banking Legislation" Address by Col. James L. Walsh, Ex. Vice Pres., Guardian Detroit Union Group, Inc. 46th Annual Convention, Michigan Bankers Asso., July, 1932. (Michigan Investor, July 23, 1932) ******** In the face of such indictments, which after all merely serve to bring into sharper focus current conditions of common knowledge, defenders of the status quo in banking are assuming a heavy responsibility not merely to the depositor public rightfully demanding an inherently stronger banking structure for the better protection of their funds, not merely to the bankers who are sincerely endeavoring to provide that stronger structure through branch banking--but ultimately, perhaps, to their own institutions, as suggested in a leading editorial in the "New York Tribune" of June 29, 1932: Chicago and Branch Banking "The Chicago 'neighborhood' banks, in sponsoring the Hull amendment, were fearful lest they be swallowed up if the Loop banks were permitted to establish branches throughout the city's environs. They might have saved themselves these apprehensions for they have been virtually swallowed up even without such a development. Out of 224 institutions in existence in 1929 only ---.1---.1reek the debacle of the 'neighborhood' 1 .3 about sixtz remain. ---7 bank reached its final stage when twenty-two such institutions closed their doors within four days and induced temporary runs even on some of the stronger banks in the city's Loop district. "If it were the weak banks alone that had to pay it would not be so unfortunate, but when weak banks topple they undermine confidence in other institutions, with the results that we have witnessed in the case of Chicago. Chicago's record of more than 100 bank failures in the course of the past year and a half, as contrasted with thirteeu_in_New Yolt .Qity÷_sholald be the 2alTaarii-iiiiiment, if one were needed, _for the adoption of a broad policy of state-wide branch banking throughout the United States." Here we have not only a graphic illustration of the potential danger of the present situation even to the largest and soundest metropolitan institutions and their thousand of correspondent banks--but a constructive suggestion from a disinterested source as to a possible remedy-namely, "state-wide branch banking throughout the United States." This recommendation is concurred in by the report of the Banking Committee of the Chamber of Commerce of the United States, as follows: ,Notwithstanding the problem of overcoming deep-seated ' prejudices in favor of the exclusive development of unit banking, your committee believes that one road to improvement of aur banking situation is the carefully regulated https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2 development of branch banking. The loss of the independent status of some banks not now in a position to protect fully the safety of the bank depositor, to whose welfare all too little attention has been paid, or to furnish ade-mate banking facilities to their communities, would produce benefit if these banks should be converted into branches of strong banks." "Considerable hardship has been experienced by some communities because of the partial or complete break-down of their banking facilities. In such instances it is difficult, if not impossible, for local interests to assume the entire burden of re-establishing needed banks or to protect adeouately the capital structure and denosits of existing banks. In a regrettable number of cases, also, weak national and state banks continue because no available means, in the absence of branch banking, offer to affiliate them with strong institutions. Branch banking would provide a solution to many of these problems through enabling strong, well-managed institutions to invite existing banks to combine with them and strengthen the facilities offered the public, including the establishment of such offices as might be required in outlying towns and villages." ******** e come next to the question of branch banking which has been for a number of years &subject of acute interest in the banking fraternity. As a matter of fact, the authorization of State-wide branch banking for national banks is really of grec'ter interest to the public at large-particularly depositors in small rural banks--than it is to bankers themselves. In this connection, perhaps I will be pardoned if I here quote from an address by Senator Glass in the Senate of the United States, on May 10th, 1932: "Mr. President, I have been now for nearly 32 years a member of the Banking and Currency Committee of the other branch of Congress and of the Senate. I have been an intent listener and observer to all measures of importance that have been considered, and I assert here that never in the whole period has any merchant or business man having relationship with banks ever protested against branch banking. No man who has wanted credit, no man who wanted to borrow funds with which to conduct his business has ever in that whole period raised his voice against branch banking. It has only been done by the bank which wanted a monopoly of credit in its community." In discussing this important gubject of branch banking, it is important to accurately define just what we are talking about. The latest draft of the Glass Bill (Senate 4412), as modified by the Vandenberg amendment, provides: "Section 19. Paragraph (c) of Section 5155, of the Revised Statutes as amended, is amended to read as follows: https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 3national banking association may, with the approval (c) of the Federal Reserve Board, establish and operate new branches within the limits of the city, town or village, or any point within the state in which said association is situated. No such association shall establish a branch outside of the city, town or village in which it is situated unless it has a paid-in and unimpaired capital stock of not less than $500,000. Except in a city, town, or village where there is no national or state bank regularly transacting austomary banking business, no such association shall establish a branch, except by taking over an existing unit bank, or an affiliate of such association." The purpose of Section 19, as quoted above, is, fundamentally, to authorize by law the continuance of banking facilities in communities where, due to economic reasons, a small unit bank is finding it difficult to survive; and to authorize the establishment of some sort of banking facilities in cities, towns or villages which are now without any banking facilities whatsoever. The line of reasoning which has led the Committee on Banking and Currency of the United States Senate, and a large majority of the Senate itself, to approve the limited kind of Branch Banking referred to above, was clearly and comprehensively stated by our own Senator Arthur H. Vandenberg of Grand Rapids, in his masterly address in the Senate of the United States on May 12th, 1932, an extract of which I shall read to you: "I have been one of those, and still am, who feel that the preservation of decentralized community life is absolutely essential to the preservation of the traditional American community character. I feel, furthermore, that decentralized community life is impossible without a practical degree of decentralized commercial and banking independence. Confront Condition, Not Theory "But we confront a condition and not a theory today, and, even in defense of decentralized community life, situations readily may arise in which limited branch banking might be the only community salvation. Certainly it would not protect deceatralized community welfare, Mr. President, to close the door on a banking facility which might prove to be the community's only way of saving the solvency of its banking resources. Branch banking might be this sole available facility. Neither does it protect decentralized community welfare to close the door on a banking facility wnich may be the only such facility available after all other banking facilities have failed or been withdrawn. Indeed, it mi7ht well be argued that under certain circumstances a resource to limited branch banking may well prove to be the means of keeping alive many a decentralized community which otherwise might disintegrate through its very inability to secure any banking facilities whatsoever. It is only in line with that philosophy, https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 4Mr. President, that I have been able to bring myself into harmony with the theory that under existing circumstances limited branch-banking permission might well be authorized in the United States. Indeed, I am persuaded that it has come to be necessary to provide this limited recourse under proper protective restrictions. It is the creation of one more optional emergency reliance for the benefit of communities and bank depositors and bank borrowers. I believe my amendment adeauately protects the option against exploitations." At this juncture, Senator Bulkley supplemented Senator Vandenberg's remarks as follows: "I rise to say, as a member of the subcommittee, that the statement of the Senator from Michigan is entirely in harmony with the views of the subcommittee. His amendment, as he has said, would in practice probably work out just about the same as the committee thought section 19 of the bill would work out under the administration of the Federal Reserve Board; but, in view of the fact that many small-town bankers are very much afraid that they would be injured by potential competition in the form of branch banks, it would undoubtedly be well to adopt the amendment offered by the Senator from Michigan and thus give them statutory assurance that such competition could not be made possible by the provisions of this bill. I sincerely hope the amendment of the Senator from Michigan may be adopted. I may add, too, that I am authorized to say that the Senator from Virginia, Mr. Glass, is in accord with the view I have expressed." The branch banking provisions of the bill, therefore, with the Vandenberg amendment, would permit city banks to protect depositors in country banks by taking over the deposit liabilities but would prohibit the establishment of any de novo branches in rural communities where there are operating banks. Under these provisions there could be no cut-throat competition of city banks with country banks, but there would be afforded an opportunity for co-operation between these two types of banks for the protection of local communities. This is certainly a mild form of branch banking extension and one the primary motive of which is to permit enough flexibility in the banking system to meet some of the existing emergency situations. As Senator Glass clearly stated on the floor of the Senate, there is no ouestion of states rights involved in this feature of the bill. Every state has the right to permit its state banks to adopt a similar branch banking policy if it may see fit. Many of them have already enacted branch banking laws more extensive than the present Federal law. Congress is the creator of the Federal reserve system and has the responsibility and duty to the general public to maintain, promote and conserve it as an instrumentality of the Federal government irrespective of and independent of action by any state legislature. Opponents of branch banking who raise the auestion of states rights put themselves in the position of being accused, on the one hand, of insincerity, or, on the other, of a lack of understanding of the issue involved. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 5 The Chamber of Commerce of the United States, in its Report published in May 1932, takes full cognizance of the theory of "state's rights," but, apparently, feels that present-day conditions demand that the Question of which legislative authority shall make the first move is without merit, as compared to the vital necessity of having authority granted at the earliest possible date, as follows: "Because of the prohibitions upon branch banking outside of restricted areas, by national and state member banks of the Federal Reserve System, which furnish about sixty per cent of the banking resources of the country, and the fact that either insufficient or no branching privileges are permitted state banks in many states where relief is needed, it is imperative in the interest of early general improvement that branch banking legislation proceed from the Congress of the United States." In this connection, it should be borne in mind that the Committee of the Chamber of Commerce of the United States, just referred to, consisted of twelve bankers and twelve business men. Four of the bankers dissented from that part of the recommendation that ". ... a national bank should be permitted, subject to carefully devised administrative regulations but unlimited by restrictions of state law, to establish state-wide branches. Federal legislation should not deny similar powers to state member banks" but all of the business men were in favor of state-wide branch banking unlimited by restrictions of state law. Possibly, by now we have established through testimony of unprejudiced witnesses that our heterogeneous collection of fifty different banking systems is not an unqualified success--at least in the eyes of those who have most at stake, namely, the banks' depositors. Possibly also, we have demonstrated that there is an increasing demand on the part of the public that something be done about it--and done quickly. The present frame of mind and trend of thought in this connection is admirably summed up in an editorial in "The Journal of Commerce of New York City, June 6, 1932, as follows: "-* * * * However, opposition to such legislation outside Congress will apparently delay a sane solution of this question until the logic of circumstances, or perhaps a new series of difficulties, will finally bring a general realization of the need for modernization of the American banking system, through a reduction in the number of appropriate institutions from the present total of almost 20,000 to a small group of strong and as far as possible well-managed branch banking organizations." 1‘..• https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ******** Address by Chas. F. Zimmerman, Secretary, Pa. B. A. 31st Annual Convention National Asso. of Supervisors of State Banks, Philadelphia, July 1932 * **** *** As previously stated the Lehman opinion establishes the illegality of holding company ownership of national bank shares. Since "wrongs cannot have a legal descent," the administration at Tashington faces the necessity either of correcting this wrong as it exists today or of permitting inevitably the growth of "pyramided" bank-share holding companies precisely such as the Insull holding companies in the public utility field. As a natiom, we have either to sit still and see our sound, conservative unit banking system devoured by big interests or we must rise up and smite these enemies of unit banking. ** * ***** The Federal Reserve Board has appointed a special committee to investigate the obviously superficial question of the causes of failures of unit banks, as a presumable substantiation of the immediate need for branch banking federally imposed and for "unified banking." In the light of the foregoing untoward developments, it is suggested that any forthcoming pronouncement by this committee is certain to be the sheerest flubdubbery, as compared with the more salient and significant considerations surrounding the present ownership of shares of bank-share holding companies. After all, it is the unit banks of the United States--or more properly, the country banks and bankers--which are operating in strict observance of this law by which the conditions of ownership of National bank snares are already finally determined. Thus it is that from the unit banks most of all must proceed forthright public sentiment (upholding lawful ownership) strong enough to throw the balance upon the side of right in this simple question. This issue is now squarely drawn. Big business is arrayed against the unit bank both because big business has the absurd notion that the extension of federally imposed branch banking could help big business and because big business men and bankers fear the effects of administering this necessary corrective whereby corporate ownership of shares of National banks shall be annulled. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ******* ** Proceedings of 31st Annual Convention National Asso. of Supervisors of State Banks Philadelphia, July 1932 ********* Peter G. Cameron (Pennsylvania): You all know my attitude towards it. I am not opposed to branch banking--what I am for is the preserva— tion of the economy of state law relating to branch banking. I am for the preservation of the banking system and I think a bigger and better law ought to be made to take care of a situation such as we have in Ardmore, which was spoken of a few minutes ago. Mr. McDowell has made some splendid points in favor of the present banking system. I trust Mr. McDowell's address will be available in printed form so we may be able to digest it. *** * * * * ** L._ A. Andrew (Iowa): ********* Our position has been clear over a term of years and in this present fight--I want to call it a "fight" because it really is--we are trying to be fair and unprejudiced. We believe we are right in this. We be— lieve it is unfair to foster on a state branch banking when the state itself has said it doesnIt want branch banking. It is against all the principles of democratic government. I don't know that it is necessary to take any more time in regard to that, because I believe the members of the Convention are thorowp-hly in accord with that part of the program. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • Report of Legislative Committee 31st Annual Convention National Asso. of Supervisors of State Banks Philadelphia, July 1932 This Association is unalterably opposed to the effort being made to undermine and eventually destroy our dual banking system and supercede the independent unit bank with a branch banking system. The attempt is a direct blow to our principles of democratic government in that it would deprive the states of their right to create and control banks and the use of such institutions that are distinctly their fiscal agents. "The National Association of Supervisors of State Banks has always recognized and respected the rights of National banks and has consistently supported the idea of the dual system of banking. It has been under this system, comprised of indeyendent unit banks, that our nation has developed and now, when we are experiencing the difficulties incident to a world-wide depression, certain powerful interests have seized upon the situat:Ion as an opportunity to attack it. "We, therefore, condemn this attempt to centralize our nation's banking functions and resources under a bureau in Wash:Thgton as contrary to the best interests of our people and distinctly inimical to the welfare of our states." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 'Mere Banks Do Not Fails - by Horace F. Peserey, Nor York (Journal of the Canadian Bankers* Asso., July 1932) ** *** * * * * most distinctive feature of the Oesediee tanking primates is th' t in the case of insolvency the notes of the balk are the fir:,t lien on its assets, and further secured by the Bank Circulation Redemption rund to which all banks subacribe on the basis of 5% of their average circulation not covered by gold or Dominion notes deposited in the central gold reserves established in 1913. This is forward looking bank legislation, and illuminates the fact of Canada's almost total lack of bank failures. Up to 1923, following the failure of the Home Bank, banks' balance sheets were audited and certified only by public chartered accountants. Investigations after the failure of the Home Bank clearly indicated that the chartered acoountant "oho certified their balance sheet vas inoompetent and apparently had been chosen on this account. ?he failure produced such widespread repercussions that the Government obligated itself to pay a certain proo-)ortion of the deposits. To lessen the likelihood of such a situation as was found in the Hoes amok arising again, the Government by legislation made provision for the appointment of an Inspector-General of Balks. Through co-operation and supervision by the Dominion Government, through the *tedium of periodic returns and the regulation of note issues and reserves, a progressive move toward efficiency and a high degree of safety is secured. * * * * * ** **** * * ** How vital, then, becomes the efficiency of a banking system and the integrity of a bank's personnel; the decree of seriousness with which a member of a banes board of directors regards his trustt In Canada the qualifications of a director are defined and records of attendance at board meetings kept ani brought to the attention of the bank's shareholders. *** **** * ** Bet the secret of Canada's beektag soundness lis not *sly in the branch Usk idea, but more in the megbod of training its MOS for positions in them es that as they prOgrees and the time memo, for executive decisions, they mmy have the experience necessary to decide wisely and promptly. When bottom, a manifest, office to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis a young men gets a job In a Canadian husk be starts at the clerk. If intelligence, faithfnlnese sed gsesral ability are he is moved up step by stop. He is thse soot from the hese the breach, say tn Edmonton. From there, after a few yearn, r ArPf`: - 2he mey be transferred to Vannanver; fron there maybe to St. John; fro* there bosh &gain to Calgary, and so on. He acquires an intima te knowledge sof Cseedle amd fiaally reaches the home office again as an execut ive, say assistant memeger, then manager, general manager, vice T.-reside nt, president. This procedure is not practised by a few banks. It is true of all of them. How valuable this man now becomest In some Canadian locali ty, the question of a loan comes up. The executive knows the condit ions of that locality through first hand intimate knowledge; he probab ly knows personally the heeds of the business seeking the loan. /f it be grhnted it is a good bet that the borrower was justified in seeking it amd it will be paid. In etressing some of the advantages of the branch bankin g system, a Canadian bank accountant recently said: Concentration of the surplus fund* of Canada through the system of branch banking makes for the equitable distributism of the loanable funde Of the tuition, with the result that memey is taken fres the semmunities whore buainess doeo not require Its use, and it is loaned where needed through the efficient local bank samegmrs, under the skilled guidons'. of the mature and tried julgment of the heed office offici als, who at all times are watching the pulse of the nation's business. These thins. have helped to an ineatimable degree the development of &made, where the peepLe of the new communities can borrow at the sass interest rates as those of relative finencial standina in tbe business centre s. As practised in Canada branch banking means distribution of the loaning and earning risks not only to all parts of the aatio n, but to foreign countries of good possibilities, which h s resulted not on1y in that highly prised diversification, but in the expansion of the nation's export trade as well. The oo-operation, good management, and safety of del-ositors which are xentioned as highly desirable, *re all attained in Canada, throuiTh the branch banking system and thromgb The Canadian Bankars' Association. Their effects are patemt La the solidity of our banking inetitutions in tlAs time of worldwide eeamamic stress. *** **** ** Canadian bank stocks are regarded in Canada as prise investaents, and ars widely held by people of both large and small aeans for income return. This is evidenced by thP fact that la the past fifteen years *ore than 60 per cent. of the total iesues of Canadian beaks have been sold within Canada. Due to the 'character of investment buying in Canadi an bank stocke, and the fact that practically all Shares are ovned outright, their market is usually verastable. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis r . ' During the post tow years the desirability of Canadian bank stocks as an Investment has beeves more fully aprreciated by United States investors, and the large somber of American shareholders is constantly increasing. Canadian securities represent onf, of the soundest forms of invest,Aent. ?hey have back of them not cali ame of the sounlest banking systems of the world, but they have back of them as well a people of marked integrity, notably free fro& pretense and notably industrious and saviss. nether this state of affairs is inspired and fostered by the confiJemes and nental security with which Canadians regard their banks is not claimed here, but it might well be so. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * ***** * * * • SOURCE: THE CALIFORNIA BANKER--JUNE 1932 ADDRESS OF THE PRESIDENT--Herbert H. Smock ****** Pages218-219 * * * We must also be prepared, both those of us who are branch bankers and those of us who are unit bankers, to consider branch banking eventually on a state-wide, if not nation-wide, scale. No less an authority on banking than Senator Carter Glass has become so much a convert as to provide in the revised version of his pending bill in Congress for state-wide branch banking of national banks irrespective of State laws and to state personally that he would go so far as to make provision for branch banking within Federal Reserve districts./ We may have divergent views on the subject, but as advocates of sound banking and as Eood citizens it is our duty, at whatever personal disadvantage, to assist the country to arrive at a solution of our structural problem. It is not my intention to pursue further the subject of banking structure and attempt to detail to you the proposals that are current for changes in that structure. I shall merely mention while on the subject the plan which has been offered to compel all banks to join the Federal Reserve system and the proposal for the separation of commercial, savings, and investment banking into entirely distinct and unrelated units. The enactment of either or both of these measures would bring about changes of the most important significance. * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis t....&•••••"' • SOURCE: THE CALIFORNIA BANKER--JUNE 1932 OUR BANKING SYSTEM ON TRIAL--by Frank P. Bennett, Jr., Editor U.S. Investor, Boston Pa„ge 294 * ***** Appraisal of bafeguards How then are we to preserve for American banking the desirable features of popular selection of banks and at the same time purge our system of such brutal possibilities as these failures from 1921 to 1931 show it clearly to include? This power of the depositors to take deposits away from banks less skillfully conducted and to reward the more capably managed banks with steady additions to resources is the most effective influence for sound banking that has thus far been discovered.* * * The practical objection to branch banking as the way out for the American banking system, now under indictment before the bar of public opinion for its shortcomings, is that public opinion itself seems not to be ready for branch banking, on that nation-wide scale that probably must be adopted, if the record of the European and Canadian banking systems for freedom from failures is to be duplicated in our own system. The suggestion, also from distinguished sources, that our banking system can be purged of its brutal possibilities, by lifting bank management to a higher plane, seems a more practical alternative. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • SOURCE: THE MISSISSIPPI BANKER—JUNE 1932 SEES BANKING UNIFICATION AS THREAT TO ECONOMIC FREEDOM--by Rudolf S. Hecht Pages 22-23 He also advocated an extension of branch banking in both state and national systems to enable strong_local financial center. banks to extend support to communities now lacking adequate banking facilities, but vigorously opposed the provision in the Glass Banking Bill now pending in Congress to grant national banks, regardless of state bank laws, state-wide branch powers in all states and limited inter-state branches in certain localities. He declared that national banks should be given just as wide branch powers as state banks withing any state but that they shauld not be given greater privileges than are granted state banks in their own territory. ( Mr. Hecht, in opposing nation-wide branch banking, presented a vigorous refutation of comparisons between the Canadian and American systems "making it appear the former has all the virtues, the latter all the vices." It is true, he said, no bank failures occurred in Canada in recent years "while thousands have closed their doors in the United States--but there is far more for banking to do than merely to keep its doors open." He went an to compare the "extraordinary contrast of American progress as against the picture of Canada's development," pointing out that Canadian authority estimates that of 560 million acres there available for agriculture, 200 million lie neglected and that the mineral resources have been hardly scratched. He also brought out that Canada, granting that there are larger waste regions in her gross area which is equal to that of the United States, supports only 10 million people against America's 122 million, that her developed national wealth was only 29 billion dollars in 1926 against this country's 560 billion, and her income but $6,000,000,000 against $82,000,000,000. "These facts are not to say that Canada is a backward country, but they indicate that she has in no way comparable to the United States yet entered into the great adventure of industrial and commercial expansion and exploitation which for all their contributions to human progress are also attendedpy great social and financial hazards," he said. "Without contrasting standards of living, systems of education, world-wide financial responsibilities and other contributions to human progress, the United States has gone to far greater lengths than Canada. "This progress has been made possible under our banking systems and methods for all their detects. The United States has ventured https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -2- The Mississippi Banker—June 1952 Rudolf S. Hecht Pages 22-25 (contd.) greatly and American banks have at all times stood right beside American agriculture, industry, commerce and finance and taken their chances with them." He asked whether Canadiwould not have made greater progress if ninstead of less than a score of banks centralized in the big cities, with four thousand branches reaching out and enforcing cautious, metropolitan financial policies upon the farms and local industries throughout the country, she had the American system of independent local banks, bound upin the welfare, progress and ambitions of their local communities." He also expressed doubt that America's greater progress would have been possible if local development had been dependent upon a few great financial centers instead of receiving aid from thousands of local bankers. One bank in Canada alone, he said, with about a thousand branches, controls 27 per cent of the nation's total commercial banking resources, while the three largest, with 2,400 branches controls 70 per cen. "We do not want any such centralization as L, that," he declared. "How foreign that is to anything this country wants is obvious when we consider that many of our people grow apprehensive because two or three of our great banks each control resources of a billion and a half or two million dollars--about 7 per cent of the nation's total for the three largest combined, as contrasted with the 70 per cent for Canada's three largest." https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCI: PROCEEDINu:; OF MISSOURI BAULK; AEWCIATION-May le-17-18, 19B2 ANNUAL ADDREbS OF THE PELSIDENT—Charles B. Judd Ages 19-W It ia true, I admit, that there are things here ancj there that need revision or elinination, out I believe the proper procedure to accomplish this reform is chiefly through better management and not throuCI exceesive legislation. Legislation cennot make good banker eny more than it can make a good doctor or lawyer. Just now we are eitnessing an attempt in Congrest. to isvose upon the banking world through the Glass Bill further restrictions and regulations, and still another plan is being evolved for nationalisatiom. went to state in no uncertain terms that I aa oppoaed to natiounlisation. I believe now, as I always balm, in the dual system of banking which )ur nation ha. always enjoyed. A nationalisation of our systea, in ny opinion, would lead to but one tLing--an extension of branch banking with a concentrotion of the control of national credit in a few enters (sic) and in the hands of a few nen with dangeroub possibilities to our nation US 6 Wh01114. Permit me to remind you of Vx. resolution adopted by the State Bank Division of the Americt:n Bankers Associetion in Clavelrnd in 1950, which exactly expressef my views. That resolution said: "Inereas, the prevailing dual -fly-stem of banking has contributed substantially to the remarkable economic development of our country, therefore be it resolved thtt we believe our present state and national systemic should continue working in cooperation, thus assuring the endurance and perman,nc of individual initiative and the free play of personalized enterprise which history hes proved so desirable." The question at issue is aimply whether banking and the related ces of the nation are to be left to state autonomy or are to be conc ntrated in one large national organitation of standardized units. I favor state regulatiom but would not be opposed to placing national banks on a psr with state banks by giving- national bankb such branch privileges bEi stet. banks enjoy in an given comaonweslth. In this way brunch bunking would remain a controllable factor within each state. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Proceedings of Missouri Bankers Association--Uay 16-17-18, 1932 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis PRESIDENT-ELECT HOLDLRMESB: PaKe 137 * * ** * ** * Perhaps you expect se to oay something on a moot question, and I have the courage to say it. I haw, never bel,n in favor of group or chLin banking. I have never been in favor of state-wide branch knkinf. I should be very raretful if anything evcr happened in thin state to stifle personal Lnitiative or hamper independent banking. By the same token I should be most regretfUl if any misguided conception of compatabilities should ever blind us to tilt:. desirabilit:y of aret. while wholly unsuitable and undesirable in others. * * * ***** * * * Committee on Banking Chamber of Commerce of the United States Preliminary Material - Meeting in Chicago October 31, 1931 American Bankers Association - The Economic Policy Commission of this important Association has been devoting attention, among other banking subjects, to branch, chain and group banking. It has published one compilation of figures and has influenced the Association to further modify its whole position, which formerly was in opposition to all forms of branch banking. The Association now supports the economic desirability of community-wide branch banking in metropolitan areas and county-wide branch banking in rural areas where economically justified. It is to be expected that as the Congressional situation develops the Association will make announcements from time to time of its position. It appears that prior to 1930, branch bank systems were relatively free from failures. In the nine-year period 1921 to 1929, 41 branch systems operating 80 branches and involving deposits of $48,000,000 closed their doors. These systems for the most part consisted of one home office bank and one out of town branch and the size of the banks was small. In the past two years, however, there have been failures among city branch systems as well as among banks operating extra-city branches, the detailed figures concerning this phase of the matter will be available shortly. Proposals for Branch Banking Legislation Comptroller of the Currency - Outstanding among the branch banking proposals receiving attention is that of the Comptroller of the Currency. The recommendation, in brief, is that national banks, with the permission of the Comptroller of the Currency, be given power to establish branches within the "trade areas of the cities in which such banks are situated." He has proposed that a committee consisting of the Secretary of the Treasury, the Governor of the Federal Reserve Board, and the Comptroller of the Currency be authorized to select the various cities which are commercial centers in the United States and to map out their trade areas. He has suggested that the term "trade area" be defined to embrace the regional floll of business and trade to and from such cities and that state boundary lines not be considered in determining the territorial limits. To prevent undue banking concentration the Comptroller also hes recommended that he be given discretion to approve or disapprove of banking consolidations within the trade area, and that visitorial powers be conferred upon him to examine into the affairs of any corporation owning or controlling a majority of the stock of any national bank. FUrthernore, any national bank would be prohibited from https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • making loans upon the security of the stock of any corporation which may own the majority of the stock of such national bank, and a corporation °ming the majority of the stock of a state bank would not be permitted to own a majority of the stock of a national bank. The minimum capital suggested for a bank engaging in this type of branch banking should not be less than $1,000,000 with power reserved to the Comptroller to require larger capitalization. American Bankers Association - While reaffirming its belief in the unit bank, the Association recognizes that a modificaticn of its former resolutions condemning branch banking in any form is desirable. The Association believes in the desirability of community-wide branch banking in metropolitan areas and county-wide branch banking in rural areas where economically justified. The Association supports the autonomy of the laws of the separate states in respect to banking. No class of banks in the several states should enjoy greater rights in respect to the establishment of branches than banks chartered under the state laws. (Resolution passed at Cleveland Convention, 1930.) Federal Reserve Board - The Federal Reserve Board has withheld any proposals for legislation regarding branch banking. It is possible that some recom&endation based upon the findings of the Board's special committee on banking may be made upon the completion of the Committee's rei,ort. Chamber Position - In Referendum No. 45, April 20, 1925, the Chamber recommended that subject to the regulations of the Comptroller of the Currency, national banks, in states where branch banks may be operated by state banks, should be permitted to establish and operate intra-city branches. The Board of Directors of the Chamber has interpreted this commitment to support metropolitan area branch banking. Miscellaneous - There have been proposals from various sources that branch banking powers of national banks be extended to metropolitan limits, county limits, state limits, and even to the boundaries of the United States. Suggestions also have been made that "tellers windows" operated by city banks be permitted in communities having no banking facilities. One state, Iowa, has recently passed legislation designed to give this privilege to state banks in that state. Group and Chain Banking - Holding Com2fInies Definition - Many definitions have been made of the terms group and chain banking. A distinction proposed by the Comptroller of the Currency, which is being widely adopted, restricts group banks to those systems in which the individual units are controlled by holding corporations through stock ownership. Chain bank systems are more informally put together and include those aggregations in which more than one bank is subject to some form of control by a single individual or group of individuals owning stock in each bank. The term also has been applied in those instances where a particular bank exercises control of other banks by stock ownership or through its officers and directors. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 5- • Location of Group and Chain Systems - By far the greater number of chain and group banks are located in states which prohibit branch banking. Those states accounted for 71% (1520) of all group and chain banks on June 30, 1930. States permitting restricted branch banking had 25% (538), and states allowing state-wide branching had 4% (80 of all grour and chain banks. Less than one-third of the loans and investments of group banks are in non-branch banking states, more than one-half are in states permitting restricted branch banking, and the remainder, about one-third, are in states permitting state-wide branch banking. Class of Banks in Chain and Group Systems - Less than one-half of the P,144 banks belonginE to chains or groups on June 30, 1930, were members of the Federal Reserve System. Loans and investments of the member banks in chains and groups, however, accounted for 83% of the total for all group and chain banks. chain and group banke represent 9 per cent of all banks in The the United States and the $12,019,000,000 of loans investments of such banks represents 20.6 per cent of the loans and investments of all banks. The development of group and chain banking has reached larger proportions in some of the mid-western and western states than elsewhere in the country. For example, of the 1,015 banks in Minnesota, 208, or 27 per cent, were members of groups or chains, while $581,000,000, or 66 per cent, of the total $877,000,000 loans and investments of Minnesota banks were held by groups or chains. In California, 60, or 13 per cent, of the 437 banks, and $1,974,000,000, or 58 per cent, of the total $3,353,000,000 loans and investments belonged to groups or chains. It is apparent, also, that group banking has developed most rapidly in those sections where branch banking is either confined to restricted areas or is prohibited altogether. It is fair to presume that group and chain banking have been entered into in many instances because of the restrictions imposed upon branch banking. It has been pointed out that more than onehalf of the assets of group systems are furnished by branch banking organizations, so that it appears undesirable to separste the two problems - group banking and branch banking - in any general consideration of banking trends. * * * * * * If there should be retroactive or retrospective legislation with regard to group banking it may present important difficulties to existing groups enjoying a considerable measure of local public support because of their apparent success in providing their areas with stronger banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • -4 CHAMBER COMMITMENTS (This is a statement of all present commitments of the Chamber concerning (A) National Banking System, and (B) Federal Reserve System. A. National BankingL System 1. "A national bank should be permitted, under regulation of the Comptroller of the Currency, to have branches within its own city if a state bank in the same city is permitted to have branches." (The Committee recommendation favored "intra-city branches." The Board of Directors has ruled that this commitment is in favor of branches in contiguous territory where, as a matter of fact, the corporate city and its contiguous territory are embraced in an area commonly known as a "metropolitan area," that is, one which taken as a whole constitutes a single commercial community." Comment: The law was changed to permit intra-city branches, but not to permit branches in contiguous territory. This commitment, therefore, is applicable to present discussions of branch banking. 2. "National banks should be given indeterminate charters subject to forfeiture for cause and termination at the will of Congress." Comment: 5. This was adopted in law. "National banks should be authorized to deal in investment securities on a basis not inconsistent with the generally recognized principles of sound banking practice." Comment: The statutes were changed to legalize definitely the dealing in investment securities under regulations prescribed by the Comptroller. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis r ,%:s.:21,;(5r PnEs., Maz Walton L. L;fc,eittr, John Hancock Mut. Lifc Boeton, Masa. U. Warlrarg, Chrm. of Board, ILtern%ti:;n41 A:.ce;t1n-e balk, 40 Wail St., New York, N. 7. David M. Goodrich, Ohm. of Bo The B. F. Goodrich Co., I:50 Park Ave., New York, 1. Y. Howard A. Loeb, Chairman, Tradesrents National Bank & (Trust Co. Philadelphia, Pe. Alba B. Johnson, 1523. Paakard Building, Philadelphia, Pa. W. M. Baldwin, Pres., The Union Trust Co., Clt.velani, Ohio. Gamic, T. Ladd, Pres., United Engineering & Foundry Cdo Pittebure., Pa. Jlian M. Miller, Jr., Pres., First & Merchhnts Natl. Bank, RikIhmond, Va Junius P. Filhburn, Pres., Times-World Corporation, peanoke, Va. Oliver G. Lacas, Pres., Canal Bank & Trust Co., New Orleans, La. P. G. Shook, Shook Yletcher Supply Co., Birmingham, Ala. VTI Chicago Felix M. McWhirter, Pzes., Ths Peoples State Bank, Indianapolis, Ind. J. Paul Clayton, Vice Pres., Central Illinois Public Servics Go., Springfield, Ill. VIII St. Louis :ohn G. Lonsdale, Pres., Mercantile-Commerce Bank & (Trust Co. St. Lous, Mo. Paul Dillard, Pre3.p Dillard & Coffin Co., Memphis, Tenn. IX Minneapolis Z. W. Decker, Pres., Northwestern Bancorporation, Mtnneapolis, Minn. rfilliam J. Dean, Prea., Nichols, Dean & Gregg, S+. Paul, MInn: X Kansas City W. S. McLucas, Chrm. of Board, Commerce Trust Co., Kansas City, Mo. W. L. 7e+rikin. Chairman, The Great Western Sugar Co., Denver, Colo. Nathan Adams, Preb., American Exchange Natl. Bank, Dallas, Texas. J. J. Culbertson, Vice Preq. Southland Cotton Oil Co., Paris, Texas. ;I: :V V Richmoad VI Atla%ta Dallas XII Hem/ M. Robinson, Chairman, 3an Francisco Security-First Natl. Bank, Los Angeles, Calif. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis J. IL Ltvison, Pros., Firemen's PUnd Insurence Co., San Francisco, Calif. SOURCE: THE ECONOMICS OF BRANCH BANKING—Bernhard Ostrolenk (1930) CHAPTER VIII BRANCH BANKING IN THE UNITEL STATES Fake 15:5 The situetion at thet tine wae not far different from the present hanking situation in tilt United States. Today the treglish banking system is in the hands of lerge companies; operating with expert knoeledge of the business intereets of thE Empire; working along lin 5 of well-tried practice which are noted for soundness and conservativeness; and establishing branch banks in edequatel if not excessive, numbers in all perts of the lamd. There hes not been an iaportant bank failure since 1890, notwithstanding that tne banking system was called on, in 1914, to withstend a trial of unusual severity. * * We have already pointed out the large number of recent bank mergers in metropolitan cities of the gaited States that accompanied industrial centralizetion in production and distribution. The amalgamations that took place in England during the past hundred yeers were of precisely the setae neture am were accelerated in the eerly years of the World War when the banks realised that only larger institutions would be able te continue the financial supremacy of the English money market. The consolidations differed from the recent American consolidations in thet the Baglish beaks when merging took over large numbers of private banks mad converted them into branch banks or bank offices and whoa merging with the larger banks alreedy in possession of branch banks theee new banks werc added to the system and consolidated with it. ?aim 1B.4 In the United Statc.s, on the other hand, the mergers made for larger metropolitan institutions and left the large number of unit banks throughout the country untouched. In fact, the eonsolidations were made necessary because businese was shifting from the smaller banks to the metropolitan centere necessitating larger banks there. The unit banks lost business which vent to tht larger cities, which in turn strengthened their position by conselidation, but they ogre prevested, because of the legal restrictione on branch benking, from coming to the assistente of the country banks. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Paces155-136 * * * Incidentally, it may be pertinent to point out whet will be discussed more fully later, thEt it now seems probable that further bunk amalgamation in England will be checked, not by law, but by the uneconomic nature of additional amalgamations; that, in fact, the banks havt. now grown so unwieldy thut earnings have been reduced as tue number of branch banks increased. It is, therefore, not improbable to expect thet in the United Vtates there will be econoaic and administvItive limits to the number of branch banks within a s:,stez even if the law should not limit them. Pakes 14,1-4-4'6-44-0 * * * But it Math* reemphasized that the system of branch banking in England primarily developed as L. consequence of consolidation of independent prink banks elk, only partially by opening of new banks; hence, overlapping bankint services were frecuently the aftermath of the planless groeth of private bank*. In view of the argument advanced that the development of atrong central bankint systems with wide-flunt brench banks w-uld seriously affect the Federal Spites& it may not be amiss to inveatiEate thc effect of the awlgametion of English privste bankr upon the Bank of England. It iv readily grhnted it.t. the outset that the situation is not analogous *hd that the Federal 4stea is in many respects a widely different institution from the Bank of England, yet it iE worthy of notice that one of the argument, brought forward against English bank amalgamation was that it would utterly destroy the fiduciary agent of matter of fact, as these the United Kingdoal the Bank of England. As joint stock banks increased in power &aid in extent, the Bank of England has increasingly withdrawn from the open bunkinc field until today it has become a bankers' bank exclusively and occwies the hub of the banking system of England. Issuing of notee, once the prerogative of scores of banks throuk,hout England, hcs gradually been confined to the Bank of England itself. In 1844, k07 private bankr and ri joint stock banks issued a total of 1.8,6Z1,647. At that tiae the Bank of Englamd issued 4.14,000,000. Between then and 1921 the note issue of the private bank's, hae totally disappeared and the Bank of England has increr,sed its note issue to L19,750,800, thereby replecing the 8.6 million pounds sterling issue of the private benks by 1.5,750,000 issue of the Bank of England. * * * From a omrsory examination of the branch banking development it would seem Obvious, therefore, that its influence an the Bank of https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -5- Pages 141-42-0-44-45 (contd.) England hos been sulutary and that it hmsetrengthened and solidified the influence of the central bank ae an agent and clef...ring hause for the benking eystem of the United Kingdom. Some further attention shoulci be given to the increased aafety of the btnks in Fngland in consequence of the amalgamation and the development of branch bankinE. Prive0, bankers who operate in local spheres uninfluenced by national conditions, unable to appreciate the need for heavy reserves, operated on a totally different bank policy from the centrelized joint stoek hanks which mainteined edequete and accurete public Accounting, aggreseive competition for deposits, disinterestedneve in lending policies, oedulously seeking for safety and with facilities to supply services to a varied industry and a widely distributed public. The wer denonstrated that a small number of large banke can pool their resources more readily then can a large number of small banks and that the netianie finances can be better mobilized through the branch bank eystem. Aert ‘be tAN rr NrY It ie entirely conceivable that fundamentelly also the private banks in England in their day suffered from the sane maledy which to a great extent affects the unit benks in the °kited States, and that is the selection by the banks of investments that are unsound. It is not improbable that the many failureE in the early history of Fngland were the conresuence of lerge feounte of frozen aseets end unsound banking systeme, a condition thst today weighs heevily upon the benking system in the United States. (Ye' ait*A. redt l t, 1;‘ Ax&Afr ce-g One more point needs to be emmaimmd, sod that is the relation of profite to branch banking. An examinatimm of the banking system in Miglano aver a period of years reveele a eurioue eituetion. As aMalgametions decreheed the number of banke end increesed the number of branch banks, grose eypenses continued to mount and net profits steadily declined elthough gross profits continued to grow.(!) The eame condition exieted with branch bemire scattered over the country and with branch banks in the larse metropolitan centers. It had been hoped originally that banks which absorbed others would ehow increased earning powers as yeers went on. This hrs not been the cese. The law of diminishing return has, therefore, set the limits for bank growth amd amalgamatima. The following explanations have been suggested. First, the small banks were accustomed to keep u small percentate of liquid assets sod ' after analgamation they were forced to increese liese assets in accordance with their new rankinge, the incrcese in licuid assets necessarily reducinL earning power. Second, bad end doubtfl debts ma:, have been taken aver with amalgamations and necessitated their being written off. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (5) Cf. Th etatist, Aay lk, 1928, p. 83k. -4- hap, 14-0.43-44-45(contd.) Third, rates allowed on deposits have been growin and de?osits bearing ao iaterest have been diminishing. :ourth, continuPd depres-ioa of investments bac eaten into profits. Fifth, there are busks working on auch finer raseu; therefore, the benefits of large amalgamation or aaslganation whics creates larhe banks revert to the puolic. Euembrissid, the Englisn bankinc system has paralleled the American banking system only during a brief period when private banks to &Oilte extent were as localized bs are the American unit banks, and that branch banking in Itigland developed concurrently with bank amalgamations. The proceae o.s anelgamation centrslized the financisl resources of the countr) into a few strong banks, but dio not stifle competition. In fact, coapetition was inteneifisd hs these oanks sought deposits in all parts of the United Kingdom and ia all types of business enterprises. The evidence clearly inoicates that the developing branch bank system and amalgamation continued to dlsce before ttle country larher and largsr numbers of bank offices and banking services. DepouitE increased steadily and resorvss relative to aeposits am capital also increased. Tileo banks of the United 4ingdon, the joint Stock Basks, few in number with widely distributes branch banks, have hss no failure for almost a quarter of a century and during thst period the horld tar placed upon the banks uaparalleled fihancisl stress. In fact, the mar period demonstrated not only the stability of the English banks, but their ability, be,..auze of their size and their effective power for organization, to mobilise their resources in the interests of the nation. Two adverse development& in the process of amalgamation may be noted here. First the tendenoy of undercapitalizing, subsequently remedied by legislation, and secondly, tus decreased net eorning power of banks Eal amalgamations increased. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis _ .,....-------.. • Annual Report of the Comptroller of the Currency December 1, 1930 Pages 1 to 10 Since the publication of my 1929 annual report the subject of branch, group and chain banking has received considerable attention. Bankers and their associations, both national and State, the press, and the public generally have evidenced an interest in the subject to a greater degree than ever before. This interest has been due largely to the increasing number of country bank failures and the changing conditions which have brought hitherto isolated rural districts into closer touch with the commercial centers. These developments were also important factors in prompting my suggestions to the Seventy-first Congress that section 5155 of the Revised Statutes of the United States be amended to permit national banks, with the approval of the Comptroller of the Currency, to establish branches within the regional trade areas of the commercial centers in which they operate. At the last session of Congress the Banking and Currency Committee of the House of Representatives, under authority of House Resolution 141, conducted extended hearings on the subject of branch, group and chain banking. During the course of these hearings there appeared before the committee a number of prominent Government officials, bankers and others, representing unit as well as the different forms of so-called multiple banking in many sections of the country. They testified from experience in their respective spheres, and thraugh their testimony the committee was placed in possession of a fund of first hand and valuable information. At this date the committee has not rendered its report. Nothing, however, materialized during these hearings nor has anything arisen since to justify any change in my attitude. Developments \of the last year have, on the contrary, strengthened my belief that the type lof branch banking put forward by me is sound and that such an amendment to the law should be enacted. Failures have not abated. During the fiscal year ended June 30, 1930, there were 640 failures, 82 of which were national banks and 558 State banks, as compared to a total of 549 failures during the fiscal year ended June 30, 1929, comprising 69 national banks and 480 state banks. An analysis of the bank failures for the current year shows that the trend toward the gradual elimination of small country banks in the agricultural sections, which has been prevalent during the past decade, is still very pronounced. Nearly 96 per cent of these failures occurred in the agricultural States of the South, Middle West, and West, while in the more densely populated industrial areas of New England and the Eastern and Pacific Coast States, where a greater diversification of business is possible, the number of failures has been negligible. In only one section of the country (the Western States) did the total number of bank failures for the fiscal year 1930 fall below that of the preceding fiscal year. In that section 163 banks failed during the fiscal year 1930 as compared to 183 during 1929. This exception was, however, due solely https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 2to the situation in Nebraska, where, following the collapse of the guaranty of deposits law, 106 State banks closed their doors during the fiscal year of 1929, while only 50 failed during the comparable period of 1950. Illinois, a State wherein antibranch-banking sentiment is quite pronounced, suffered a striking increase in bank failures during the past year. During the fiscal year 1929 only 8 State banks and 1 national bank in Illinois closed their doors, while in 1930 no less than 42 State-chartered institutions and 11 national associations, a total of 53, were placed in receivership. Other States contributing largely to the increase in bank failures during the last fiscal year were Alabama, with only 5 failures in 1929 and 25 in 1930; Oklahoma, also with 5 failures in 1929 and 26 in 1930; and Missouri, with 19 failures in 1929 compared to 50 in 1930. In each of these States, following the general trend for the entire country, the great bulk of the failures was made up of banks with limited capital, located in communities of the type which, in my opinion, can be adequately served only by branches of the larger banks in the nearest large commercial centers. Since I have discussed the subject of bank failures at some length in previous public utterances and in my annual report to Congress for 1929, I shall ask your further indulgence on this occasion merely to point out that the failure of about 5,600 banks in the past 10 years, tying up deposits of nearly t2,000,000,000, constitutes one of the main factors responsible for the crystallization of a strong sentiment in favor of some change in our banking structure which will bring to our rural dlstricts, where more than four-fifths of these failures have occurred, the benefits and protection of the strong well-managed banks now operating in our commercial centers. It should not be overlooked that those who have suffered most in these failures were persons of small means--country business men, farmers, and savings depositors in farming communities. That remedial legislation along this line is of great present importance is strikingly emphasized by the latest -Pigures available,which show that up to October 31 of this year no less than 742 banks, with deposits of about $300,000,000, have closed their doors, as compared to a total of 522 suspensions, with deposits of $200,000,000, during the same period last year. In the absence of legislation permitting the extension of branch banking facilities to these rural communities, a type of multiple banking called group banking, practically unknown at the time of the enactment of the McFadden bill, has been evolved. That the development of group banking has been remarkably rapid during the past two years is attested by the fact that on June 30, 1930, there were in existence in this country 289 group and chain banking organizations, controlling 2,144 banks, with loans aad investments of approximately $17,000,000,000, or nearly 21 per cent of the total loans and investments of all the banks in the country. In not a few instances a highly constructive service has been rendered by group systems in taking over smaller banks which have found themselves in a position where they could no longer function profitably or safely under the conditions with which they were confronted. However, it is a rather significant fact that both group and chain banking have had their greatest development in https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - 3the States where branch banking is prohibited. A recent survey discloses that in the 9 States and the District of Columbia, wherein state-wide branch banking is permitted, there were 86 banks in wroup and chain systems and 847 branches located outside of the head office cities, besides 461 branches located in head office cities. In the 22 States in which state-wide branch banking is prohibited, however, there were 1,242 banks in group and chain systems. In these 22 States there were 25 branches located outside of the head office cities and 27 in head office cities, all of which were established prior to prohibitory legislation. A highly important advantage possessed by branch banking over group banking is the adaptability of the former system for extension into the most remote /hamlets, while, generally speaking, group banking facilities are enjoyed only by those communities which are able to support a well-managed independent bank. My observation has been that group banking, instead of allpviating the rural banking situation, has as a rule taken over only the stronger local banks in prosperous communities, leaving the weaker institutions struggling for a meager existence. Failures of these weaker banks have left many communities wholly without local banking facilities, which, however, could readily be supplied by branches of the larger city banks, with but a minimum of overhead expense to the latter institutions. It doPs not seem desirable to give sufficiently broad branch banking powers to national banks to enable them to embrace in a single branch system the entire geographical area now embraced by several of the larger group bank systems. Group banking in the main is in capable hands, and includes some of the best-managed banks in the country. However, the field of group banking is now open to every type of operator or promoter who may be able to purchase bank stocks. This constitutes a source of potential danger. In order to facilitate the supervision of group banking, in those cases where the Federal Government has any responsibility, it is my view that no national bank should be permitted to become a constituent of such a group, except upon the condition that all other banks in the group are also national banks. The Comptroller of the Currency under these conditions could more effectively examine and supervise the entire group operations. It is therefore my view that group banking should be brought under the visitorial powers of the Federal Government in those cRses where membership in the group is composed in whole or in part of national or State member banks of the Federal reserve system. Legislation along these lines seems to be necessary in the public interest. With reference to my recommendation that national banks situated in important commercial cities be permitted to extend branch banking facilities into the trade area of such cities, it has been suggested that any such national legislation would give to national banks an advantage over State chartered institutions in those cities, the trade areas of which embrace territory in more than one State. There are many such cities in the United States. The proposal has, therefore, been made that national banks be given only those branch banking powers which the State legislatures can give to State banks. Such a procedure would seem to be an abdication of a national branch banking policy in favor of the policies of the various States and is open to two serious objections, one economic and the other constitutional. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 0 -4The theory of trade area branch banking rests upon economic grounds. Its aim is to permit strong city banks to carry their banking facilities to the community surrounding such city to a distance which is governed by the predominant flow of business and trade to and from the city as a trade center. It is designed to give to the rural communities, which have for years been suffering from a lack of safe and adequate banking facilities, the high type of banking and the security from bank failures which rcsidents of the large cities have generally enjoyed. If Congress therefore adopts the policy of withholding from national banks the power to cross State lines with branches in those cases where the trade area of the city clearly does cross the State line, the whole theory and plan of establishing in the rural communities a well-rounded and sound branch banking system is broken down. The State policy theory is objectionable upon the constitutional ground that Congress alone is responsible for the establishment and maintenance of the system of national banks as an instrumentality of the Federal Government. These banks were established purely in the exercise of the legislative power of Congress and solely upon a national policy. It gave to the United States a uniform system of banking beyond the control of the States. It is not a valid objection to the national legislation here proposed that Congress would be conferring upon national banks banking powers more extensive than those which lay within the power of the State legislatures to give to State banks. For many years we have witnessed what may be regarded as the reverse of this situation. While Congress has at all times had the constitutional power to give to the national banks charter advantages which could not be acquired by State banks, it has nevertheless been extremely reluctant to exercise this nower, although to do so in the manner herein recommended would strengthen our whole banking st-ucture. On the other hand, however, State legislatures have conferred upon State chartered institutions, particularly upon trust companies, banking powers which national banks did not at the time enjoy. As a consequence, the national banking system has within recent years declined in size, importance, and influence, and has become thereby relatively less effective as an instrumentality of the Federal Government. Through tne diversion of commercial banking from the national to the various State banking systems, Congress has lost control over the major portion of the commercial banking resources in the United States. Upon the enactment of the McFadden bill the conversion into national banks of several larger State branch banking institutions and the consolidation of several State banks with national banks under the national charter gave rise to the hope that the national banking system would reclaim the most important banks which had left it to operate under State charters. However, this hope was short lived, for there soon followed through State legislative or State judicial action new advantages for State banks, particularly with respect to the operation of the trust business and desertions from the national charter in favor of those offered by the States began to increase. That the disparity between the two systems of banks is pronounced is evidenced by the fact that whereas in 1886 the national banks held 75 per cent of the total commercial banking resources of the country, the latest compiled figures indicate that this proportion has now shrunk to less than 40 per cent. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -5Any advantage therefore which might accrue to the national banking system through trade-area branch banking around those cities situated near State boundary lines could fittingly be taken by Congress as an opportunity to strengthen its control over a nation-wide system of commercial banking such as was established under the original national bank act. In view of the foregoing considerations, it is recommended that the act of February 25, 1927, otherwise known as the McFadden Act, be amended to incorporate the following banking policy: (1) That a committee composed of the Secretary of the Treasury, the Governor of the Federal Reserve Board, and the Comptroller of the Currency be authorized to select the various cities which are commercial centers in the United States and to map out their trade areas. (2) That the term "trade area" be defined to embrace the regional flow of business and trade to and from such cities and that State boundary lines be not considered in determining the territorial limits thereof. (3) That national banks situated in such cities be permitted, with the approval of the Comptroller of the Currency, to establish branches within the limits of such regional trade areas. (4) That the paid-in capital stock of such a national bank shall be not less than $1,000,000 and that the ratio of capital and surplus to deposits shall be maintained at not less than 1 to 10. The Comptroller of the Currency would in his discretion require a larger capitalization. (5) That the national bank consolidation act be amended so as to permit any banks situated within the trade area to consolidate, with the approval of the Comptroller of the Currency, under the national charter, but the Comptroller of the Currency should be specifically empowered to disapprove any such consolidation upon the ground that it might result in an undue concentration of banking capital within the trade area. (6) That there be conferred upon the Comptroller of the Currency such visitorial powers as may enable him to examine into the affairs of any corporation which owns or controls the majority of the stock of any national bank. (7) That no corporation be permitted to own the majority of the stock of any national bank if it at the same time owns the majority of the stock of a State bank. (8) That no national bank be permitted to make a loan upon the security of the stock of a corporation which may own the majority of the stock of such national bank. During the past 12 months I have discussed at length the question of the trade area as the logical basis for the development of branch banking in the rural communities. Particularly at my appearance before the House Committee on Banking and Currency last spring detailed consideration was given to many aspects of the trade area in connection with the question of the extension of the branch banking powers of the national banks. It may be desirable at this time to summarize these discussions. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis - A, 6- In defining the trade area it is essential that we keep in mind the chief purpose of proposed amendments to the national bank act with respect to the establishment of branches. It is not the primary consideration that the large city bank should be placed in a position further to develop its business with attendant greater lorofits and wider influence notwithstanding this would and should follow, as a matter of course, through the extension of branches to the rural sections tributary to the city in which it is located. The primary purpose is the strengthening of rural banking itself through the influence of strongly capitalized and well-managed city bnnks of which the rural bank might become an integral part. It is, therefore, necessary to consider the tradearea question from the point of view of the rural-bank situation rather than from that of the city bank. The difficulty in defining a trade area in the abstract is well recognized. The subject has been studied by experts in many phases. MaxxxxxmlotxTxtxxximasmx xxandimaxicxxxxlmotrximmummxxitxxxxx The country has been laid out into trade areas from the standpoint of the manufacturers of nationally advertised commodities, the manufacturers of more localized products, wholesale distributors, retailers and newspaper circulation. The present problem deals with a different type of trade area--one which requires that the viewpoint be taken from the rim of the area rather than from the hub. The aim is the establishment in the rural communities of a sound system of banking which will give to the country depositor a reasonable assurance of safety and will offer to those requiring banking accommodation more adequate facilities than is at present available to them. Those requirements can be met only through the establishment of branches by city banks into the surrounding communities which have access to such a city as their principal market and financial center. It is this surrounding area which I have termed the regional trade area. It is the zone of the city's predominant economic influence in the sense that in that zone the city is both the trade and credit center. There can be no formula which would determine in advance the exact size of any such trade area, but as has been frequently pointed out there is one economic principle of fundamental and controlling significance. Every city which may be selected as the center of a trade area must be of such importance as a trade center for the surrounding geographical territory as to draw to it a volume and a diversity of trade sufficient to form the potential basis for a well-balanced branch banking system. This is what I have termed the requirement for economic diversification. By this it is meant that the loans made by the bank to its customers in the trade area must rest upon the security of a wide range of business enterprises and industrial pursuits. The bank should be able to draw its business from the production of natural resources, agriculture, livestock, manufacturing, transportation by land and water, distribution, and communication. In each of these activities there would be further subdivisions of diversification as, for example, the production of natural resources would include the various types of mining, oil, gas, timber, hydroelectric power and so on. The essential weakness of rural banking as we now have it lies in the danger of its complete dependence upon just one such economic activity. By virtue of the small geographica; area of its operations its loans rest principally upon one type of security. There is an insufficient economic diversification of its loan portfolio. This objective can be attained in a branch system of banking which taps a number of different types of security. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 0 -7It has been suggested that proper diversification can be obtained through the purchase of investment securities on the general market. This procedure faces two obstacles. It presupposes a technical equipment which the rural bank does not possess and it would draw the funds of the bank in too great a proportion away from the local field of the bankts operations to the detriment of its legitimate borrowers. In some sections of the country where industrial activity is concentrated and where the population is dense there are offered a number of different economic pursuits of relative independence, the one of the other. In auch a case the physical extent of the trade area of a commercial center may be small as compared with another city in the more sparsely settled sections of the country where a greater territory may have to be embraced in order to gain the required diversification. Every city indeed, no matter how small, has a regional or local trade area but every such trade area would not be a suitable field for branch banking. Under the plan herein recommended it would be necessary for trio committee proceeding under a general authority from Congress to select those cities the trade areas of which meet the requirements for economic diversification. In this respect the committee would be dealing with an economic situation very much similar to that presented to the committee which under similar authority laid out the Federal reserve districts. The Federal reserve districts vary in size according to the density of population and the physical concentration of commercial and business activity. It will be recalled that Congress designated the Secretary of the Treasury, the Secretary of Agriculture, and the Comptroller of the Currency as a committee to lay out the Federal reserve districts under instructions to have "due regard to the convenience and customary course of business and shall not necessarily be coterminous with any State or States. The districts thus created may be readjusted and new districts may from time to time be created by the Federal Reserve Board, not to exceed twelve in all." This committee experienced no great difficulty in carrying out these instructions of Congress. There appears no reason to doubt the ability of a similar committee, such as I have recommended, to map out the trade areas around the principal cities in the United States. These trade areas might be termed regional economic or trade zones to distinguish them from the wider geographical area with which the business enterprises of auch city have contact. Banks and business generally in every large city may from tilie to time have trade relations and business transactions extending to every part of the country and indeed over the whole world. In contrast to this wider field there is an immediate geographical territory surrounding every large city and reaching out into the outlying rural communities, a definite area which can be determined by boundary lines embracing a population having customary access to such a city as the principal market. Such a trade area might in some cases overlap an adjacent trade area of another commercial center. If upon a determination of fact it be found that the business of a given community flows in substantial volume to more than one city as a financial and business center, it might be found desirable to put such a community in more than one trade area. It would seem sound to permit the establishment of branches to follow the natural flow of regional commerce and trade, and cases of such overlapping would simply mean that a few communities might have branches emanating from more than one trade area center. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -8As contrasted with the proposal for county-wide branch banking, tradearea branch banking would follow economic rather than political boundary lines. County-wide branch banking could never form a sound economic basis for a national policy in banking. The county seat is often not the most important city in the county and in many cases it is more convenient for trade to flow to an adjoining county. In a few cases it might be found that the county seat is in fact an important center of trade but in such cases it will ordinarily have a stronger trade influence in tne adjoining counties than any city situated within them. County-wide branch banking would force banking into artificial channels and would be economically unsound in those cases where the parent bank was of insufficient size to offer adequate banking facilities and safety to depositors or was situated in a county which did not permit of a diversification in the banking business available to it. There seems, therefore, no escape from the conclusion that rural branch banking, in order to offer an improvement over the present system of rural banking, must proceed from a parent bank situated in a city of sufficient economic importance to sustain, by virtue of the commerce and trade within it and its surrounding economic zone, a well-managed bank of not less than $1,000,000 capital. The suggestion for State-wide branch banking appears also economically unsound as the basis for a national policy. In many States there may be found cities whose regional trade areas are embraced within the boundary lines of the State. On the other hand, however, there will be found a great number of important cities situated in such close proximity to State boundary lines that a prohibition against crossing the State line would result in a one-sided branch-banking system for the banks in such a city. The trade area here under discussion is a geographical area for banking purposes. It has no direct political significance. Business and industry pay no heed to State lines in the use of banking facilities. The normal business of a bank in a city situated near the boundary line of more than one State flows over such lines in response to the impulse of convenient comTunication and transportation. Depositors and borrowers in one State have no prejudices in crossing over the State lines to gain access to their bank. To deny such a bank, under these circumstances, the power to establish branches to meet the convenience of its customers across State lines while at the same time permitting it to establish branches in another direction into the territory of an entire State--in many cases extending far beyond its normal trade area-would set up a system of branch banking under national authority Ahich would appear unworkable and indefensible. In the consideration of the type or size of a city which would be chosen as the center of a trade ares adequate for branch banking purposes, regard must be had for the general banking situation in any given community. If the city be important enough to have strong, successful national banks and is surrounded by a community having a number of country banks whose principal bank correspondent is in such a city, that city might be made the center of a regional trade area. In many such cases the geographical area involved might be not only less than that of a Federal reserve district but less in area than the State in which the city is situated. There may be found a https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -9sufficient economic justification for several trade areas whose principal territory is within a single State. Having regard for the situation that branch banking by national banks began with the branch banking limited to the city in which the bank is situated, it would seem the logical economic development to permit a natural growth of these branch-banking systems into the territory where their influence in banking is predominant rather than to proceed solely from the greatest metropolitan centers of the country, which would give to relatively a few great metropolitan banks the exclusive privilege of branch banking in the country districts and lesser cities. It would be highly desirable to preserve as much as possible the element of local autonomy in the establishment of trade areas provided the areas are not so small as to sacrifice the principle of economic diversification. confined It is not meant to imply that trade area branch banking should be d permitte now is banks national by banking branch to those States in which in be uniform should banking branch of policy new The within the city limits. y communit rural every to giving thereby nation, the its operation throughout an opportunity of access to strong city banking facilities under national supervision and control. to the It may, therefore, be said that the following elements contribute banking: branch area definition of trade (1) The principal objective is to strengthen banking operations in the rural communities. (2) A secondary but not less positive result would be a strengthening of the entire banking structure of the country. a (3) The surrounding geographical territory economically tributary to center, l financia and market chief the city and for which such city provides may be described as its trade area. trade area (4) Every city may be said to have a trade area but not every is suitable for branch banking purposes. branch banking a (5) In order to lay the basis for a sound system of ication of diversif a limits physical trade area should embrace within its ut its througho branches g operatin bank economic activities in order that a for its loans. extent may also acquire a diversification in the security trade areas should (6) For branch banking purposes, therefore, only those commercial center be chosen which surround cities important enough to be the diversification. of a territory sufficient to meet the requirement of economic area for (7)Since the trade area under discussion is a regional economic furnish a guide banking purfloses the status of the banks in a given city will of the to its character and extent, particularly the number and location ndents. bank correspo l principa the are they which for surrounding country banks (8) It would not be a difficult undertaking for a committee composed of and the Secretary of the Treasury, the Governor of the Federal Reserve Board in centers al commerci l principa the select to Ourrency the Comptroller of the the United States for branch banking purposes. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -10(9) Upon the selection of such a city the determination of the boundary limits of its trade area wauld be a question of fact and could easily be discovered through a study of its banking operations and its general trade influence and position. Small country banks need have no fear that they would be driven out of business through theEotablishment in their communities of de novo branches by city banks. Such a procedure would be highly abnormal and it is inconceivable to me that any Comptroller of the Currency would lend his office to its support. The natural development of rural branch banking would occur through the consolidation with or purchase of country banks by the city branch banking institutions upon such terms as would be agreeable to each. The conversion of the local bank into a branch of the city bank in this manner would have no disturbing effect upon the local banking situation. The type of branch banking here recommended would, as compared with the present system of unit banking, lead to a decentralization of banking resources. Within each trade area there wauld be a concentration of local or regional banking capital and the best interests of the branch banking systems would compel the employment of such capital in the various communities throughout the trade area. The present tendency under our system of a large number of very small banks and a small number of very large and strong banks is for the bulk of the banking resources of the country to be concentrated in a few great metropolitan centers. Under trade area branch banking there would undoubtedly arise in the inland commercial centers regional banks of sufficient strength to hold the banking business originating within their trade areas. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis **** * *** .1. SOURCE: THE ECONOMICS OF BRANCH BANKING--Bernhard Ostrolenk (1930) Pore 15Z (contd,) Leveral banka in Canada, other than the Home Bank, did feel the pinen of hard timea from 1920 to 19.24. Duch at appreched a coneition of insolvenc took refuge in amalaamation with a sort poaerful institution. In Canada the brench bank eystea offered attractions ta powerful Eastern banks who were lookink for outlets in tht. aoricultural 4est and the localit4 or bueiness aseets compenvated for the non-liquidity of the bank. Thus. in many eases the amalgamation worked to the benefit of the puelic end to the benefit of the abaorbing bank. bug In the branches of Canadian banks the till money on bead alienate to but a few hundred dealers. i unit baJak in the lilted States could not operate one beer on such a small amount,. est Vie is possible in Canada becauae of the principle of note issue. The notts of banka are not coneidered money until they mre paid out by the teller and there ia no lose of interest on till mammy, whisk in the United &tate. amounts to a conaiderable sum. This provision has been of great benefit to the entire systea and has enabled it to supply banking services to regions where a unit bank could not possibly operate. Many growing regions have not reriched the point where financial stabilization is in sight, yet v powerfUl branch bank can afford to operate with wean loss for some ,years in order to eatablish itself aed grow with the region. The Endson aay is such a region. It is developing and mmy in time beim* a center of activity but no unit bank could possibly operate there at a profit, yet the Royal Bank of Canada has opened a branch in Churchill. It will probably teke a smell lose for some time but in the nc-antine it is firmly establishing itself and Eiving the community the benefit of banking facilities. Supplying adequate banking fadilities to agriculture Mais 0MS important reason for the establishment of the branch system in Canada» Under similar conditions in the United States such regions have been bespered and retarded by the lack of proper banking facilities. Tbe mmit system cannot supply to agricultural regions the credit they seed mad the danger of failure is slew, more Inminent. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -3- Paeee 150-60-61-6k The fluid movement of funds in Canada, as well an the elasticity of currency, hats been a great advantage to the country as a ehole, evpecially to the agricultnral regione. The movement of funds from East to West is of extreme importence especially when the crops are to be exported or moved to sellint centers. Celia& hes been fortunate in thet through its great brench eystem credit ie evailable at all times, funds move reedily from surplus to deficient regions and thet ita currency. iu one of the most delicate Eysteme of ita kind. The elesticity of currency in the United Vtatee cannot and does not meaeure up to the Cenadian eystem, credit is not so available and the movement of funds, although facilitated through the Federal Reserve Syetee end correspondent banks, doer not work smoothly enough and often causes deleys. there hew been easea of complaint ore the pGrt of certain croups in Canada that they do not receive an adequate supply of capital or at reasonable rhtes. Rather than indicating a defect of the eystee, this exhibits one of tne beaefits to the country. The Maritime Provinces have hhd to compete with others nik with more fevorable industrial opportunities and business ham declined, and while a local unit bank would buoy this up for some time the end would be disastrous. The more favorably situated provinces are able to take adventage of the easier credit while credit for less fevoreble reclons becomes tiehter. It ie not a fault of the eystem but workv es an automatic reguletor of credit and prevente overexpansion in territories not suited for ;tame particular industry. rhe Andustriee of the scritine Provinces must compete with industries of the other provinces on ea equal bevis end credit will flow to such centers where the eeeene, is greeteet end accospenied with sound industrial prospects. Not only have Canadian farmere been able to obtain easier credit but rates have been lower than in corresponding regions of the United States. While ratca very and ao definite rate whioh Canadian fermers have to pay ean be (luoted, the range is approximately from 7 to 10 per cent, while the rate to fermers neer the Canaaien border in tIle United EtateE is several per cent higher. The reaeon for these lower rates inherent in the system. It is due to the rapid shifting of funds from the -hest to the West and back again when not needed. The 1,1.0 number of branches facilitates tnis aeweseat, and various induetries in need of credit at different times are paired off against Eq ,ch other. Again, the grett sevinga in the overheed of a branch in Aanitobe compered with a unit bank in Dakota nukes for lower operating caste in Canade. If tnis savings in overhead did not exist many of the branches of Canedien banks could not operete profittbly. Divereifieetion, a ocord that at prevent haa been assuming more and more significence in the United Statea, hee been carried out in practice in the Canadian brench banking system. Banks will not tie their assets in https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -4- rages 159-C:-Cl-p. contd.) any onc induetry nor one locality. The unit beak in the United Ctatee hen little choice. It cannot diversify its aseete to tht extent that a large brunch bank can and is compelled to associate its fortune with the induetry in its particultr locality. If it ie in an ugricultural region with farmere who are land poor and mtking no profita, the bank, males* managed with more than averegi skill, frecNently will find its assets; trona** * * In the past acme benke in Cameea have frecuently had their branches in me region. In the case of the Union Bank this was true, but among the present chertered banks this tendency has precticall,;disappeared. in the ease of the Farmers Bank, which hed all its assets tied op in e mining venture, the lemlay mine, tho failure was re2orted to be due more to inefficient and dishonest mmangement than to a defect of the system. bnoh tendencies are mere prone tc exist in the umit system teceuee a Urge brench system ema ettraot a higher type of camostive. Especially is this true of positions in the head office, where misMagoe sent is likely to te of grettest demege. The teadenci to &sable away Assets of a bank time been corrected through the decennial reviaion of the Bank Act. In the revision of 191! e etookholders' audit was amthorised to reduce the risk of speculation on the pert of the somagement% Nes 43-64 One criticism of the bronch banking system, that is often advanced, is that not enough interest is taken in the industries of a saell con. munity. The proponents of the unit spites point to the fact that in small communities the lOoml industry is financed by the local bank. Viewed fres the standpoint of the individual, th4i Gemmel intereet of e local hank has many advantages. However, viewed from the gomeral economic interests of the country, it will be granted that beak attar bank finances its local industry without any regard to the demends or moods of the nation or the position of the industry from a standpoint other then local. Canadian banks take a wider viewpoint. 2he manager of a locul unit bank has not the facilities at hand or is not so situated as to be in touch with all the factore of a certain industry or view the industry as a whole. A case in the United States where thie local viewpoint was carried to an extreme hes been called to the writeeb attention. Within a radius of eight miles three toems imitated each other in the establishment of & hosiery mill. The bank of each town financed its own local mill with no regard to the needs of the Market or to the demand for this oommodity. * depression hit the industry, two The sonsequPnee ins that as soca * found these loans, 'high of the rectories wont bankrupt and th 1 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis ; -r•; , Er ; 11' -5- Pr*es (contds) amounted to e. considerable sum, frozen. Although there are no definite assumnces that this would mmt happeu under a branch biAking syetel, the probubilitics are that the losn alone, such lino by any branch would prompt4 receive the scrutiny arid reviot of the heed office, which would be in u poeition to ju6ge the need of tilt. county--; for any particulnr commodity. It is interestinc to note that in Canede the bankcrs are in close touch with their duhlic 1...nd with the state of each particular industry. In part this ie because of the small numbers of customer* mod in part cunt)* of say depositor to hews mere time ane because it is mot * * account. * Personal knowledge of its financial public is an import8nt feature of bbnking in Canada and partly dioproves thc allegations that the heae office of a beak has no knowledge or interest in a particulnr community. *** PaKe 16§ Another point in the Canadian system that haa been severely criticised is the decline in the ratio of capital and surplus to total liabilities. Table XVIII shows the extent to which this dceline hes taken place (9) TABLE XVIII EATIO OF CAPITAL ar SURPLUS TO TOTAL LIABILITIES 1885......57.35 1890. 1895......38.76 1900......27.t6 1905......22.48 1916......14.1E 19PE......10.56 1918......10.E6 1919...... 9.46 19C0...... 9.06 19L5...... 9.5ri 1926...... 9.29 1927...... 9.1t 1928...... 8.0 1915......16.76 1922......10.76 Plgefi 166-67 Another criticism that hae been directed against the Canadian branch banking system is that it Weates a semey trust and reduces healthy competition. That competition exists between the lirious banks in %media is difficult to prove stttistically except by the fact that one Ati rum in a small communit;y several branches of vtriour banks. Bmnks ere partie- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis (9) Canada ieer Book, 19E9, source for eapital and liabilities. -6- Lzep 166-C7 (cont4s1 ularl: eser to obtain the accounts of new induztries establishing themselves in Canada, end this is ihere the irezUst oompetition ariseF betweeu bauks. It is, Lowevers tk practice not to persutee customers to switch their accounts. A farther criticism of the system is that the local brula samagers fail to take thE interest in thc community that is said to be shaructEristic of the namager of u unit bank. The complaint ha* bees mode that they are shifted just when they have become acquainted with the needs of thc coanunity and that they are not given sufficient authority but must refer too many matters to the head office. This criticism is not E0 true tt present bs it W/18 when many new branches were opening. It way more difficult f r e bank to chonee the proper aan when it 174s expandiLg ra-Adly. N6turally some inefficient men sere appointed bort these have boon reaoved end it is to thc interest of Ma bank that itt local man dieplay interest in his COM=pity. The bank r,_alizec this am: when a asonger has proved his tbility he is given xore liberty in ths asking of loans. Onse a certain line of credit hue been given a customer it remains operative witc the local branch without rcferaince to hevd office, unless an amount greeter than thi* is needed. * * * https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis * * * ** * * * SOURCE: nIANAGING THE PEOPLE'S MONEY" by Joseph Ernest Goodbar BRANCH BANKING AND BANKING CONTROL Paae 167-168 That the development of branch banking has never been favored by the national banking law is perfectly clear. That branch ba nking is favored in other commercial countries, and has reached e;:traordinary development in England and in Canada, suggests that the policy in this country may perhaps have been unwise. It certainly has increased the difficulty of intelligently managing the people's money. A National bank, prior to 1933, might have branches in its orn city when state law permits a like privilege to State banks, but no branch is permitted in cities of less thsr 25,000 population, nor more than one branch to each 50,000 population in cities of not more than 100,000 inhabitants. In larger cities the number of branches allowed is in the discretion of the Comptroller of the Currency. State ba nks, on being converted into or merged with a National bank, and mergers of two or more National banks, are permitted to retain all branches lawfully in operation at the time the permissive act wasapproved. Unfriendly toward any kind of monopolistic development in banking, the law prohibits alliance between a National bank and any other bank, State or National, through interlocking directorates, employees, or officers when either such bank has "deposits, capital, surplus, and undivided profits aggregating more than t5,000,000." If located in a city of over 200,000 population, no National bank may lawfully have a director, officer, or employee who is also a private banker, or is a director, officer, or employee in any other cumaercialbenk or trust company. Provided, however. that when all stock of not more than one commercial bank is owned by stockholders in anothe-, the above prohibitions do not apply. The Federal Reserve Board is given authority io permit private bankers, or directors of a Federal Reserve bank, to serve as director, officer, or employee of not more than t-o commercial banks. To enforce these prohibitions, the Federal Reserve Board is authorized, on proof of violation, to issue a "cease and desist" order, enforceable in a proper circuit court. Nor is it lawful for a National bank to acnuire branches by stock ownership. As was stated in the early pages of this chapter, accuisition of stock in another bank by direct purchase is Ultra vires. LaTful ownership might be temporarily acouired in protecting a loan, but intentional ownership would probably sustain a proceeding, brought in the name of the United States, to revoke the charter of the owning bank. Officers responsible for illea,a1 ownership of stock in another bank a re liable criminally only if they intended to "injure or defraud" the bank. Statute law and judicial decision have thus combined to circumscribe the development of branches within very narrow limits, to prohibit the alternative growth of interlocking management, and to prevent the indirect attainment of branch banking, other than that expressly permitted, through stock ownership by one bank of another. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis *et • • Page 169_1'70-1'71 With the law as stated above, what do we find in practice? In Michigan, the Guardian Detroit Uhion Group (Inc.), v Michigan corporation, owned all or most of the cepital stock other tha- h directors' qualifying shares, in nine National ba nks, including the Guardian National Bank of Commerce of Detroit, and twelve State banks, all located in Michigan. The group served over 400,000 depositors, and, ak December 31, 1931, held aggregate deposits of $349,398,000. These banks and trust companies came - into the control of the holding company through the exchange of stock on an tppraised book-value basis. None were bought for cash. The holding company's 1,544,844 shares of stock, having a par value of $20 per share, was held by upwa rds of 8,000 shareholders--each being under double liability in case of need to repay depositors in any failed bank. Another holding company, Detroit Bankers Company, controlled 7reater resources thanaid the Detroit Uhion Group; the two together controlling $1,090,000,000 in aggregate banking resources, which was more than 58 per cent of all banking resources in the State. Of this total, $202,000,000 was in State banks and trust companies, and the remaining $888,000,000 was in National banks, this being 832i per cent of the total National bank resources of the entire state of Michigan. It will/E noted that this grouping of National banks is not only astonishingly efficient as a device of controlbut it in no way violates the letter of the Clayton Act (supra). Over the country at large, 230 chains or groups of banks mere operating 1,561 banks, both State and National, on June 30, 1929. On October 14, of the same year 273 chains were operating 1,838 banks, according to the Economic Policy Commission of the American Bankers' Association. kccording to the latter report, three types of control were being exercised. One type, dominated by an independent non-banking holding company, consisted of 28 groups, controlling 380 banks, having aggregate resources of $5,335,100,000. A second type, dominated by a particular bank, consisted of 78 groups controlling 407 banks, having resources of $6,473,000,000. A third type, dominated by persons or groups of persons acting for themselves, consisted of 167 groups, controlling 1,071 banks, with resources of $1,468,000,000. According to the same account, chain or group banking had, in the fall of 1929, developed relatively on a greater scale in Minnesota than in any other state, 435 banks, with total resources in excess of $1,000,000,000 being under outside control. The control centering in New York City, however, affected assets larger than those managed from any other city. Seventeen chains had head offices in New York, with aggregate assets of $4,000,000,000, and controlling important banks in Chicago, Philadelphia, and San Francisco. One of these holding companies, the Transamerica Corporation, of New York, owned the control of the Bank of Italy, now the Bank of America, which carries on a very large branch banking business in California. We have already seen that Michigan had large banking chains. In Illinois there were eleven chains, with in excess of a billion in assets--three of which were dominated by National banks. Just how these National banks exercised control was not statea. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis iihr" * • But an affiliate company could have accomplished that result, despite the statutes against owning stock in other banks, and against interlocking directorates. Another type of group banking is that of the Marine Midlnnd Corporation, chnrtered in Delaware, but operating in New York. This holding company issued 1,000,000 shares in October, 1929, for 1..0 per share, less underwriting commissions, giving it a cash capital of e57,285,236. With the exception of about $19,000,000 this money has been used to buy new bank stocks or to increase the capital and surplus of banks whose stock had been accuired 1)7 original exchange of stock. There is no double liability of stockholders. It controlled, in March, 1932, twenty banks and trust companies, having a total capital of about $32,000,000 (apparently exclusive of surplus). In this particular plan, a "service corporation," the Marine Midland Group (Inc.), was organized under New York lays, with a nominal capital owned by the various banks in the group. This latter company furnished "service and advice to the member banks through central auditing staff, central credit file, standardization of forms and accounting practices, bond investment advice, publicity, advertising, and new business, and so forth." The device of a service corporation is well known to utility holding companies, and has always been an excellent arrangement for boosting profits under the guise of service. Nevertheless, it does have elements of real value to the operating companies, and, with respect to group banks, might possibly supply an adeouate central control, the lack of which is one of the weaknesses of group banking as compared with branch banking. Branch banking itself has made comparatively small headway in this country. State-wide branches are permitted in nine states, including California. In Massachusetts, New Jersey, New York, and Ohio branches arepErmitted within the limits of the city in which the ba nk is located. In three states, the county, or the adjoining county, limits the extension of branches. Limited branch banking is permitted in Michigan, Pennsylvania, and Kentucky. The remaining states, including Illinois, do not permit any branch banks whatever. On June 30, 1929, out of a then total of 25,115 individual State and National banks, 818 were operating some 3,440 branches. Of these, only 1,078 were located beyond the limits of the parent bank's home city. Out of this total, 531 were located in California--the State in which branch banking has attained its greatest development. Most of the branches were established de novo, only 958 having been acouired by the purchase of existing unit banks. Much has been said for and against branch banking. That it has existed in very large degree in England, in France, and in Canada, the three countries whose banks have stood most firmly safe throughout the period fram the end of our own Civil War in 1866 down to the present, is a strong point in its favor. But branch banking is not of itself a panacea. It expands the methods and skill that operate the bank. Government inspection usually has no remedy for faulty manacement, and waits until insolvency occurs before closing a badly run bank, but the head office of a bank can remove the local manager when its own inspectors https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Page 173-174 disclose unsound or inefficient management. It egualizes risks by reason of greater diversity in territory and in customers served. But, as Joseph Stagg Lawrence says "A far more vital difference (between Canadian banking and banking in the United States) is the severe limitation in the number of Canadian banks" If the management of a large system of banks is unsound, then the very magnitude of the institution intensifies the effects of the resulting insolvency. The failure of Bank of United States is a perfect example. The two great groups in Detroit, described at the beginning of this discussion of branch banking, themselves were about to crash, nnd caused the declaration of a moratorium in Michigan, la te in February, 1933, which precipitated the temporary closing of all banks in the United States on March 4. Stockholders' suits asking receiverships for the Detroit Bankers' Company and the Guardian Detroit Union Group (Inc.) were filed on March 25, 1933, in the Circuit Court at Detroit, seeking to prevent a transfer of ,assets to the new National Bank of Detroit, organized to take over and replace the old First National Bank, and the Guardian National Bank of Commerce of Detroit, which had suspended payments. This new National Bnnk of Detroit was organized on the initiative of the Treasury Department, because of the pressi'lg necessity for sound banking facilities in Detroit-412,500,000 of 6 per cent preferred stock having been subscribed by the Reconstruction Finance Corporation und,_ Title III, Section 304, of the Banking Act of March 9, 1933. The $12,500,000 for common stock zas advanced by General :Motors Company; this, however, being intended to be offered to stockholders and depositors of the two failed banks on an equitable basis, the motive being to hasten the eatablishment of a g oina bank. 0 uite clearly, them, mere branch banking is not the way out, although it offers many real advantages. The direct control of the head office over branches is a more effective restraint on unwise banking than the indirect control of a holding company over banks within its 0:roup. In the one case, branches are a part of the whole,and the management is normally in the hands of bankers who have been successful intanking. In the other case, group banks are legal entities, often remaining in the hands of the original local management, which means that they have, in addition to th-e-mansiganaltr-w134-eh-maans ths—thisy-b*Ar.e., in addition to the shortcomings frenuently inherent in small unit banks, the added handicap of absentee control without effective central management. , The investment banker, who too often dixects the activities of group b-nking, is inclined to think of the group in relntion to its value in supplying credit facilities for outside activities, instead of as a commercial banking enterpriee to be controlled and operated as effectively as possible in its own proper field. As between the two, branch banking is far more likely to be carried on with a single-minded interest in commercial banking, whereas group banks are more apt to be managed in the interests of noncommercial banking projects. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis Page 174-175 Group banking has developed as a means of avoiding the regulations imposed on branch banking. I regard it as inferior to branch banking in every aspect. As will appear in part in the summary, which follows section 11, and in the constructive discussion of branch banking that will appear in Chapter VI, the development of branch banking, intelligently carried out, under regulations devised to guide its growth along healthy lines, offers not only a more flexible and more substantial body of banking institutions, but offers at the sPme time a form of oreanization peculiarly adapted -b understand and carry out any wellconceived plan of monetary management that may emanate fram the Congress and from the Monetary Authority. Its business, of course, will have to be restricted to commercial banking. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis SOURCE: "MANAGING THE PEOPLE'S MONEY" by Toseph Ernest Goodbar ADVANTAGES OF BRANCH BANKING Page 306 ************ The flexibility of these branch-banking companies, in bringing banking service, at small expense, to villages and to communities of no great commercial importance, was very impressive. Another striking feature was the long and careful training of bank employees and officers. Banking was a profession. Still another was the flexible freedom with which the branches operated under a constant system of inspection controlled by the head office. Any manager could be removed for mere incompetence, as well as for other cause, without interfering with the conduct of business in the branch. In the United States, prior to 1933, recalcitrant violations of law by unit bankers could be stopped, in too many cases, only by closing the bank. ************ Page 309-310 Present-day English joint-stock banking, then, is characterized, first, by its adherence to the commercial type of banking; and, second, by its extraordinary development in the field of branch banking. The first characteristic is the one to which modern English banking owes its great stability and through which it has contributed so largely to English economic stability and progress. But I strongly doubt if the first characteristic would have become so thoroughly a part of English banking practice had it not been for the continuity of unified control over local branches, through which sound policies have been made effective over the entire country. This development of branch banking must have supplied a superior grade of banking service--for there is no restriction on the opening of small private bnnks in England, save only the practical one of having to campete for business with existing branch banks. The elements of safety, of service tu small communities where sound unit banks could not live, of ample resources for la rge business units, of diversification,' of thoroughly trained personnel, supply advantages to the public which few ' unit banks could even hope to equal—which the American system of unit banking does not even begin to approximate--and this apparently explains the sterility in birth rate of new private banks in England. Such excellence, as compared with a unit-bank system, is, of course, due in the first place to the intelligence, training, and traditions of the management. But these policies of the managing officers are made effective only through a large and scattered personnel of managers and other officers. -Unlike the heads of unit banks, this personnel must follow the traditional policies under pain of removal. It is this power of removing recalcitrant managers, which may be exercised without in any impairing public confidence in the branch, or interfering with the orderly process of its business affairs, which, perhaps more than any other one thing, explains why internallmk control, through a bank's own auditors, has been so conspicuously successful in England, as contrasted with the American method of attempted government control through publicly employed https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis -• 1 r • • • bank examiners. Until Dower of removal over bank officers was granted, in 1933, unsound practices of American uniL banks could be corrected only by closing or threatening to close the bank. Even with Dower of removal in the hands of the Comptroller (or, in case of state member banks, the Federal Reserve agent) and the Board of Governors, who is to succeed such removed officer? The majority of American banks are modest in size. They are largely "one man institutions." Among their employees and directors may often not be found, in a distressingly large proportion of cases, any proper successor for the officer whose removal is believed necessary. In no case can a managing officer be repoved, from a unit bank, without probably impairing public confidence in its soundness. Branch managers may be removed by the central management without disturbance. But the removal of the managing officer of a unit bank by public authority appears little less drastic, in its effect on the bank itself and its service to the community, than closing the bank would be. It seems doubtful if such removal could be accomplished without so injuring the prestige of a bank as sooner or later to compel it to close its doors. The power of,painlessly. removing the manager of a branch bank, constitutes, without doubt, one of the greatest advantlges of branch banking over unit banking. It supplies the means tw which sound banking policies may be imposed throughout a widespread banking system. Page 311 Nevertheless, this characteristic of branch banking can only have resulted so fortunately for England by reason of the fact, as hereinbefore made plain, that English banking experience had ripened into a controlling tradition that loans for speculative purposes, and/or for investment purposes are disastrous for commercial banks, and must therefore be avoided by them as far as possible. laatever faults may be evident to those closely in contact with English banking, the fact remains that in carrying out this traditional policy it has largely prevented the disruptions to economic stability 7:hich the contrary policies have so frecuently induced (or permitted) in the Uhited States, and has thereby spared England much of the economic distress which has developed in the United States since the time of the Civil War. (3ound banks, with economic stability greater than in any other country over more than half a_ century, are tangible results. And these results have accrued only after joint-stock ba nking methods were divorced fram earlier practice of lending freely on speculative enterprise and an the construction of new capital goods. Greater economic stability, and freedam from bank failures, developed in England when English banks turned away fram speculative loans and investmenttype loans in favor of cumuercial loans. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis As suggested at the close of the preceding section, bowever, the unhurried development of branch banking occurs largely by territorial expansion of the more ably conducted institutions, which gradually take over, absorb, or replace less efficient unit banks. During and after times of stress the process is accelerated. Unsound methods, too freely indulaed in, impose their own penalty. Wise and conservative management then comes into its own. Granting the possibility of Basonable unimpeded extension of branches, the weaker units disappear and are largely replaced by branches of the institutions whose strength has proved itself under test. "Survival of the fittest" operates to improve the banking species, just as it does to innrove and tone up the quality of natural species. However, the Banking Act has imposed a restriction on branch banking which destroys a large part of its value, even where permitted. In Scotland, where branch banking thrives, and in England, Alere it has reached extraordinary development, small communities entirely unable to maintain a omAll bank, or even a branch bank, are nevertheless given banking facilities through branch banks that are, in same cases, open but one or two days a week--the manager serving three or four such communities on alternate days. Banking service is thus brought to communities not large enough for a full branch. When full-ttme service can be given, the expense account is kept within reasonable limits, because the name of the bank is a sufficient assurance to the public of its importance and stability. It does not need to put up a costly bank building, such as an individual bank would have to do, es a mere matter of advertising its strength and its importance. The parent bank can adjust the expenses of each branch to the volume of business; can, if it chooses, occupy mdest nuarters without loss of prestige, employs only vliat capital is actually needed in the business of the branch, and feels no neceFsity, ordinarily, of freeziu a lot of capital in an unnecessarily pretentious building, as is customary with balks in the United States. These economies, and this widely distributed public service, is impossible under our bank laws. The specific provision of the Banking Act of 1933 that has this effect was, perhaps, intended merely to prevent banks from doing too large a business on a given capital. The capital of a Nationalbenk shall be not less than the aggregate minimum of capital that would be required if all arancnes were independent National ba king associations. This means that the bank must have, on the average, a capital of rot less than $100,000 for every branch, except that, for branches located in places having less than six thousand population, only $50,000 is required. Additional capital of $200,000 is reauired for each branch in a city of over fifty thousand population, unless located in out-lying districts where, in same cases, $100,000 is sufficient. It is easy to see that the result of this restriction is to destroy entirely what is, perhaps, the greatest utility and value of branches--namely, their flexible adaptability to https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 0 t'I the needs of the community. The difficulty of giving safe banking facilities to communities where an independent National bank could not exist did not entirely escape the attention of the Committee on Banking and Currency. Conseauently, the Act of 1933 provides also that State banks and trust companies, organized prior to the date of the Act (June 16, 1933) located in places having a population not exceeding three thousand, and having a capital of not less than $25,000, or which, prior to July 1, 1936, increase their capital to not less than $25,000, may be rldmitted to membership in the Federal Reserve System. The Banking Act of 1935 has relieved, though apparently in a none too satisfactory manner, a particular difficulty that had been inadvertently imposed on small-town State banks, too small to be members of the Reserve system, by the Federal deposit-insurance provisions of the 1933 Act. By that Act, rtonmember State banks could not have Federal insurnnce for their deposits after July 1, 1936. Those State banks that would have been obliged to remain outside the Reserve system, and also outside the deposit-insurance system, would have found conditions exceedingly difficult. It might readily have happened that few of them would have survived the double handicap--and this, of course, - ould have meant that smallcommunities would either have no bank service fram State banks, or a very precarious type of service. The 1935 Act, however, makes no insurance discrimination against nonmember State banks on account of small size though requiring those whose deposits average $1,000,000 or more to become member banks by July 1, 1942, or cease to participate in Federal insurance. Of course the National banks are unable to give any small community banking service (other than the limited type referred to, previously, for resort localities), because branch expansion is v-ry limited, in any event, and even where permitted each branch requires an allowance of fram $50,000 to $200,000 in capital, depending an its location. Small communities, therefore, will continue to suffer the deficiencies of banking service incident to dependence on small State banks, when it would be perfectly possible, with added strength to our Peserve system, to permit National banks to establish branches in such places, without any such needless capital reauiruments as are now tmposed. 1 In Rhode Island banking law the protection of depositors, from possible overexpansion of bank deposits in relation to size of capital and surplus, has been effectively accomplished without imposing any obstacles to the natural development of brnnches. The statute provided thrit "the total amount of deposits on hand by an (bank), exclusive of deposits in its wrings or participation departments, shall never exceed ten times the combined amount of its unimpaired surylus and capital 1112.9.1_Rakult : Rhode Tsland went through the banking difficulties up to March 4, 1933 (when all banks were closed by presidential order), without bank failures. A similar provision in the Banking Acts of 1933 https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis .41111-1 and 1935 would have given effective protection to the public against overextension of business in relationship to capital, and yet would have permitted the same economical operation of small branches, and the same extraordinary reaching out of banking service into all communities, which is so characteristic of English and of Scotch banking. Instead of safety 731us service, the statute, on this point, has sacrificed service aLmost entirely. The effect, and perhaps the real purpose also, of these restrictions on the establishment of branches is to preserve the unit bank fram competition. The welfare of the unit banker seems to have been put ahead of the kind of bank development that sems prerequisite to the general acceptance of sound banking practices. For the seemingly ostensible purpose of preventing the creation of an easily avoided "money trust," the statute narroTly limits the development of that phase of banking which, in England, has, perhaps more than any other one thing, caused the elimination of bankers who would not or could not carry on the business safely, and caused them tc be succeeded by branches that extend the activities of those who apparehtly knew hor to operate a bank with safety to all concerned. Branch banking--either within a single state, or within a single Federal Reserve District--seems really essential to an adequate unification of safety with service. Limit the amount of deposits tolen times the capital, and overextension is prevented. Limit executive control to directors, officers, and voting stockholders whose residence andflnancial interests are chiefly within the Reserve district in which the bank operates, and protection is given against the creation of a "money trust," under absentee control. Small and inexpensive branches may then bring s-.)rvice to all communities. These need no pretentious not the appearance of its branch bank offices, as the bank's name office, is the source of its prestige. They may have able and competent men as supervisors of the manager, instead of unskilled directors dominated, perhaps, by a small-tmn big-wig who knows merely the pawnbroking features of banking; or may regard the bank as a convenient accessory to his other business interests. 6, 1-\A few large branch-banking systems would seem unquestionably to be 4,- 'more easily held to sound banking principles than are myriads of separate4, banks. By reason of the central-office control over the pay, the tenure, and the advancement of all branch managers, the latter become sensitively reponsive to the spirit, as well as the letter, of regulations imposed ./ by the central office. Valere a man can recognize his own self-interest, there411 his heart be also--and a branch-bank manager's self-interest is served by furthering the plans and methods emanating from his superiors. Regulations laid down by the Board of Governors of the Federal of the Federal Reserve System, or by the Federal Treasury Department, or by Act of Congress, however sound, are too often likely to seem contrary to the unit banker's estimate of his own financial interest. In such case, his observance of them is limited to the letter of the law only, and the real purpose of these regulations is likely to be deliberately circumvented. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis lir. A • -- • SOURCE: "MANAGING THE PEOPLE'S MONET" by Toseph Ernest Goodbar GROUP BANKING AND HOLDING COMPANIES Pages 353-364 Group banking under the control of holding companies received attention in both of the Banking Acts under discussion. From an earlier chapter it will be remembered that this type of banking control does not impress me very favorably, although conducting the banking business through branch banks meets with my entire approval. Some, at least, of the members of the Senate Committee on Banking and Currency, in 1933, are said likewise to have looked with disfavor on holding-campany control over banks, although for reasons unlike my own. Little friendliness was to be found on that Committee, other than on the part of Senator Glass, for any method of bank control other than the traditional independent management of unit banks. It seems to have been thought, by some of the members of the Committee that framed the Act of 1933, that the provisions of that Act would induce the holding companies to dispose of their bank stocks within a period of five years. It 'rould appear to me, however, that if this result should materialize, it would not be because of the restrictions so much as because of economic conditions. Merely reading the Act itself would seem to indicate no motive other than to remedy a few of the unsound financial practices that had developed, and to subject them to Bgulation not unlike that imposed on banks. Certainly the provisions do not seem unreasonable. To begin with, a holding company is defined as any "corporation, business trust, association, or other similar organization" uhich through stock ownership, or through trustees in control of stock, controls the election "of a majority of the directors in any one bank." Any such holding copany may vote the stock it holds in National banks and draw dividends from such stock, provided it secures a votinz permit) which the Board of Governors "may, in its discretion, grant or withhold. . . es the public interest may require." Granting of a permit depends on the good reputation of the applicant therefor, but no holding company may le pranted such permit unless it consents that all banks under its control should submit to examination by the regular bank examiners, end should publish statements of condition if reouired. This Provision was doubtless included because State banks, not subject to Federal supervision, were often included in the controlled group. The holding company must further consent that its officers and employees should be subject to the same penalties that would apply to the corresponding personnel of a bank with regard to false entries in the books and reports of the company. It is further required to be shown that the holding company has no financial or participating connection of any kind with any investment banker or security company. In addition to the above]Tovisions, concerned immediately with bringing the group of banks under government supervision, and separating it fram https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis "". irproper financial connections, there were requirements with regard to the accumulation of a reserve. It must have been these requirements, if any, that were expected t) bring about the dissolution of holding-campany interest in National banks. Inasmuch as a number of holding companies had voluntarily imposed on their stockholders a double liability, for the protection of depositors in controlled banks, in the event of failure, these were burdened more sparingly than the others in regard to this mandatory accumulation of reserve. The Banking Act of 1935, however, has since provided that every National bank may free its shareholders of double liability on July 1, 1937, or at any time thereafter, by giving a statutory public notice six months in advance. Accordingly it was also provided, in 1935, that the less onerous reserve recuirements should apply to all holding companies, in so far as their stock ownership in banks without double stockholder liability is concerned. The favored holding connanies that came either wholly or partially witliin the provisions in the above paragraph are, with respect to holdings of bank stocks within those provisions, reauired, "after five years after" :une 16, 1933, "to establish and maintain out of net earnings over and above 6 per centum per annum on the book value of its own shares outstanding a reserve of readily marketable assets" amounting to not less than 12 per cent of the "aggregate par value of bank stocks controlled by it." With respect to holdings of stocks in bmks that retain the double liability of stockholders, a reserve of 12 per cent on the par value of of all such bank stock, is recuired after five years from June 16, 19F3, and this reserve must be augmented each year, if I understand the none too clear language, by all income over 6 per cent on the company's outstanding stock, and in any even by not less than 2 per cent of the par value of the double-liability bank stock that may be controlled, until a reserve of 25 per cent on such stocks has been accumulated. This would appear to be additional to whatever reserve might be recuired an bank stocks no longer subjecttp double liability. That these conditions ought to be salutary in their effects on the conduct of holding companies in the exercise of control over operating banks cannot reasonable be denied. It would not appear that companies possessed of sufficient capital, and owning stock in banks that can pay a return sufficient to Itermit compliance with the reserve accumulation recuirements, will be induced to rtire from group banking by reason of these enactments. Outside of the elements pertaining to gcvernment supervision, which are consistent with general policy toward the banking business, there is nothing here that a soundly conducted business of the sort should not have done, or started to do, voluntarily and in its own best interests. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis i'&10d44 Nevertheless, it seems only proper to point out that nothing I can /find in the above statutes will prevent many of the more dangerous practi/ ces of the past. A promoter-type management of a group-bank holding / company may use the credit facilities of controlled banks in support of . outside ventures, businesses, and even speculations, in which the management or its associates are interested, almost as freely as could have been done before the Banking Acts of 1933 and 1935 became law. While the holding company must satisfy the Board of Governors of the Federal Reserve System that it has no financial connections with investment banks and security dealers, there is no restriction on its power, so far as I have found, to own and control the stock in as many nonbanking and nonfinancial companies as it may be able to acruire. Nor does there seem to be any restriction on the managing officers with respect to their personal interestsin similar nonbanking and nonfinancial companies. The idea is not foreign to American businessmen, of the ambittous-for-bigness type, that membership on the credit committee of a bank may be worth almost as much to them as ownership of a gold mine. The statute does provide that any single bank under the control of a holding company may not lend more than 10 per cent of its capital and surplus to any one affiliate, nor more than 20 per cent of its capital and surplus, in the aggregate, to all such affiliates. If nonbanking subsidiaries of the holding company are regarded as affiliates of the subsidiary banks, es seams ouite probable, then these would be subject to the 4gregate credit limit of 20 per cent on the capital and surplus of all the banks under the control of the same holding company. This particular set-up, though highly desirable from a promotional and business expansion standpoint, is more restricted than it was. But even with these restrictions the possibility of a continuing flow of bank credit into new capital goods, and/or intospeculation, is greater than the aggregate total of such credit that may be outstanding at any one time. In the case of a very large group of banks extending credit to enterprises located in what might be called the same financial circuit, the principle of self-liauidating capital-goods loans, in the sense discussed in Chapter I, would come into limited operation. But there would be no real need for an ambitious business organizer constantly in need of funds, to submit even to those limitations. Two holding companies, with himself as the dominant influence in each, would not be affiliates under the present law, so far as I have discovered, es long as neither company holds controlling inte-est in the other. In such case each and every controlled bank might extend ordinary loans up to 10 per cent of its capital and surplus to any or all of the subsidiaries of the separate holding company. Until the enactment of the Banking Act of 1935, moreover, each bank was authorized to purchase the bonds of a single obligor, for investment, up to 15 per cent of the capital and 25 per cent of the surplus of such bank, provided that it took not more than 10 per cent of the entire obliga- https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis • • tions of the obligor. But the Act of 1935 has brought the bond-investment situation into line with the loan provisions, on this point, and now no bank may lawfully extend credit to a single obligor, whether directly or in the form of bond purchases, to an amount greater than 10 per cent of its capital and surplus. Even with this modification, however, it would seem that holding-company control of a group of banks, in conjunction with similar control over business corporations by a separate company under the same individual control, offers the possibility of an "inside track" to bank credit that looks but little less inviting than it did before. The technique has changed, but no material change has occurred in the substance. These two Acts, then, have not reached the really fundamental defect that seems to be inherent in the Rrouping of banks under the management of a holding company. Practically none of the advantages of branch banking are gained in the process, and almost all of the weaknesses of the unit-banking system are retained. Group banking does little or nothing to improve the quality of the personnel, which is ordinarily developed in much the usual may for unit banks; it leaves unimproved the weaknesses and favoritisms and improper influences inseparable from a bank under the management of local directors who are engaRed in businesses of their own; and it imposes, in addition, a subservience to the outside management whose knowledge, experience, and interests have often appeared to lie in the direction of business consolidations.and promotions, rather than in commercial banking. The mere ability and training necessary to building up a holdingcompany-controlled group of banks presupposes an investment-banker type of mind, a man whose success has been built on his skill in raising money for his own enterprises, and whose talents lie in that direction, rather than in the important but somewhat prosaic management and development of a commercial bank. Even if inclined to believe that the banks of his group ought tolimit their business to commercial banking--an unlikely supposition--the man who can build up a financial structure of this type is likely to be deficient in the intimate knowledge and special training needed to give reality to the truth he may grasp in principle. Again, if the ambitious-for-bigness type of businessman is financially strong enough as an individual, or in conjunction with an informal group of associates and friends, to acquire a controlling interest in more than one ba-k, there is nothing in this statute that would seem to limit either the size of the group, or the use that might be made of its credit facilities, other than the 10 per cent borrowing limit, previously mentioned, that applies under the National Bank Act. This type of control is not lacking in quantitative importance. In 1929 there were 167 such groups, embracing 1,071 banks, with aggregate resources of $1,468,000,000. One would expect that the prospect of complete personal ruin from a double stockholders' liability that would be personal, in this type of control, to the owner management, would have https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis tended to exert a sobering influence, as doubtless it did--but the accuisition and operation of such a group of banks would normally seem to be motivated in a pramoter-type anbition that is disposed to say: "Damn the torpedoes. Go ahead." Apprehension of bank failure, in booming good times, seems unlikely, in any event, to enter very seriously into the thoughts of men whose nature refuses to acknowledge danger. I do not say this critically, since I am myself an admirer of boldness and courageous disregard for possible danger, are out of place in the banking field. A man may properly be bold, if he chooses, in exposing himself and his own means to great risk in the hopeful expectancy of realizing commensurate gains. But when he involves a part, or all, of the country's banking system in the gamble, while the winnings, if any, are his own, his courage is not a virtue and his ethics are nuestionable. If the public were going to share ecuitably in the winnings, the ethics would, of course, look better—although this vould seam contrary to all the accepted rules. But even in that case, the promoting of the private ventures of the management, through the use of the credit facilities of a group of controlled banks, is a gamble on which no man should be entitled to embark credit facilities that are vital to the entire community. Under the new Acts, the restraining2rospect of double liability, is ended. Is it not entirely too possible that group-bank individual management may henceforth say: "There are no torpedoes. Full steam ahead"? The record of holding-company group-bank control is none too good-even if we look at those which voluntarily imposed double liability on their stockholders, and are accordingly treated with evident favor under these acts. Of this type the most conspicuous examples Ikere doubtless the Guardian Detroit Union Group, Incorporated, and the Detroit Bankers' Company. Under the control of these two holding companies were banks which on December 31, 1931, had aggregate deposits of .t1,090,000,000, of which $888,000,000 was in National banks. The unit banks controlled by both these huge holding companies closed their doors in February, 1933, nearly a month before the general "bank holiday" was declared on March 4. A year later the liouidators of only two units of one of the groups still owed $123,000,000 to unsecured depositors, and $84,000,000 in torrowed money. The owners of the 1,775,465 outstanding shares of Detroit Bankers' Company have been assessed $14.06 per share, while the owners of the 1,544,088 outstanding shares in the Guardian Detroit Union Group, Incorporated, have been assessed $6.44 a share, as a result of company liability on the bank shares of one bank unit only inetch group. Further details as to those two great failures are not material to my purpose, which is merely to illustrate the lack of strength of holdingcompany group-bank cohtrol, even under the conditions most favored by the https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 4 • • law. Double liability to shareholders is supriosed to be a double protection. The additional hazard to shareholders is thought to impose extra care on the management, while whatever additional resources may actually be available in case of failure are a protection to the public. The first was insufficient to preserve these banks from insolvency and the second has always been most disap-Dointing. Assessing a shareholder is not the same thing as collecting from him. Another element of grave importance--at least in the minds of the Senate Committee on Banking and Currency, in 1933--is the possibility that what is commonly termed a "money trust" may develop, with centers in New York, and perhaps also in Chicago, as a form of irresponsible "absentee control" over bank credit. This feared concentration is not wholly a figment of the imagination, as witness the fact that in 1929 the control of seventeen holding companies controlled chains of banks, having total assets of $4,000,000,000, including banks in Chicago, Philadelphia, and San Francisco. The Transamerica Corporation of New York exercised control over the Bank of America, of California, which itself operated a very large branch banking system. It was doubtless the fear of this danger which induced the framers of the Act to impose rigid limitations on the extension of branch banks, which rill be the next subject for discussion. But the actual danger, as at present manifested, lies in the development of holding companies, and it has already been shown that nothing in the holding-company regulations imposes any sufficient restriction to guard against the further development of the centralized banking control, which has already begun. Concentrating banking control in Ner York and in Chicago would apparently tend to divert money flow from remote sections, even if the management of the people's money were effectively opposed to diverting bank credit into peculation and into investment in capital goods. The diversion of bank credit, fran its locality of origin to same other section, would tend to be vastly larger, if absentee management might lawfully use it in support of speculation and in financing new investments. Without directional control over bank credit, absentee control through holding companies seems particularly undesirable. By way of brief summary, then, it seems unlikely that the burdens imposed on holding-company control of banks will cause them to rtire from business, as is believed to have been envisaged by those who framed this section of the Act. There is nothing, apparently, to prevent the promoter-type banker fram acquiring control of a holding company and using its group of banks to supply credit for his own businesses and ventures, nor will it prevent a holding company from having nonbanking subsidiaries which it may largely finance through the subsidiary banks. It appears to do little or nothing to protect the subsidiary banks from lending policies emanating from a promoter-type genius at the top. https://fraser.stlouisfed.org Federal Reserve Bank of St. Louis 1 0 With regard to the individually controlled groups of banks, no additional restrictions of serious moment seem to have been imposed on the management's poRer to use the credit facilities of the controlled banks for personal business purposes. In fact, removing stockholders' double liability has freed the individual, who owns control of a group of banks, from the sobering effect of prospective personal ruin in the event of disaster to his group of banks. His power seems virtually undiminished, while his major personal risk from lawful abuse of power is extinguished. There also remains the possible development of a concentrated money and bank-credit control in New York and in Chicago which, in a country as large and as varied in interests as is the United States, would seem to endanger the free flow of bank credit in the less industrialized sections of the country. Certainly, whatever evils may lurk in the development of a "money trust" are likely to be aggravated under this type of control. It would seem hardly needful to point out that using bank credit for advancing the outside interests of the controlling management, in good times, promotes inflation in capital goods or in speculetion, or in both. Such use of group-bank credit is not only readily possible, under these Acts, but it likewise seems quite probable, if one may judge from the investment-banker skill that has gone into the creation of these groups, in connection with the opportunities they afford. If the effect of this set-up were merely to make credit available more freely to those associated with the management at the expense of outside borrowers, the situation would crente special privileges that are socially deplorable. And to the extent that such special privileges tend to expand new capital investment, and thus to upset economic equilibrium and promote disruption, themrd-deplorable" ceases to describe the situation. To leave the impression that holding-company control over groups of banks is always or necessarily acquired from ulterior motives would not be fair. It was said, for example, at the time of the controvergy over the Banking Act of 1933, that same of these companies had indicated a preference for converting their group-bank systems intoiranch-bank systems, if Congress would enact the necessary law, which Congress failed to do. The legal structure, the methods of finance involved, and the form of control and operation seem to predispose such groups to the defects I have mentioned, but unquestionably these could be, and no doubt are, frequently overcame, in large degree, by able and conservative management. If, however, our ill-conceived and illogical op-)osition, in