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Committ ee on Branch Group & hE..i.n (Jan - ar 1931) Bd.1 ing Banks Branch 4 .D • • END KIND OF MATERIAL OR HUMBER NAME OR SUBJECT SHEET 4 1.11 Committee on Branch Group & Chain Banking DATES (Inclusive) J;:...n - PART HUMBER 6 ar 19.31 • rch 31. 1931 • • 0 1 0 1 ' i 1 o r 1 t ly t or. • • • B . . \.l''H. FEDE t.AL REHEHY E OF CLEYELA..."" 'D .!arch 50, 1951 • • J. H. Riddle, Secretary, Committee on Branch, Group and Chain Banking, Federal Reserve Board, {ashington, D. C. y dear Mr. Riddle: I have your letter of arch 24th but re- gret that I was not in the bank in order to ackno ledge receipt of it earlier. I am very sorry indeed that the error in listing Mr. Riefler as being connected with the Committee on Branch, Group and Chain Bankihg, occurred. I hope it ill not inconvenien ce you any and would suggest that Mr. Riefler's na.:ne be ruled out and your name written above his. If this is not satisfactor y I ill be glad to send you corrected sheets which can be substituted in lieu of the ones shotlng the error. Yours very trul· > F.m > . , p i .l 0 • t • 5. l ty r Go rnor r. or I Governor 11 y' s le ter of • rch 18th to ne o c it liz tio • rul no. our in o yours, t1on co of , l t • ' • 2, 1 .1. o ernor • • roh 24, 19 1. r t ly yo r , ' 2 • 9 1. or r • r C t r , h • 23, 19 1 •arc r r. r s propo i d to 0 0 He '() al. t do t r 0 • oc • ' _ .1 Vil s to t r- o. tl ~ *~~ ~ - o ld it t 1eth r t C . 1 • . 19 tlon tio nt cono ic i ry i b h 0 1 11 t ri 1 1 t 0 , on it if' t 1 in au of A ricult r 1 nd t n a is 1 • to .a.h in 1923 co r. 1nv xp ct se ile of t it ban s ir loan t rdin tion r to t cti 1ch h r. y d ch a tent tive ion 0 ,, .:k..-<- .0-X..., ,, 11 or .c. Fl::iJE.RAL RESERVE: BOARD To 1lr . Hai'JilQ.lld From .....r . ') • Date_ :"rch 23 Subject:_ • •n 2 - 8496 have · ~-~c tar (signed br ...,•• eo.d) to tne Jo.notro 1ler t & office askin or tne c it'on reports on tllo gro1ps of bnnks . One roupJ consists of 225 nationa l ro.n s which s1sr~nde d dirinR 1929 an 1930 , und we reaueste d in e ch se t'1.e l'lst c 11 report nrior to • ilure . r:iss eston unoer ... tal"I s tout the kin of tabul1.ti on~ to be ·tde 1ith tnese reports an can proceed 1ith the corn'1iln tions 1hen thoy come over . The othor groun on ists of 800 ~tional banks nich re in existenc e on rovembe r 15 , 1920, but have since suspende d . ,e :3 ked tor tilese 800 banks the cal 1 report of 1:ovember 15 , 1920 . ne data wnich ve ant to take fron the~e reports wnen t ey come over is the sn~e as that hom on nu es 36 - 38 of lolwne Io the o~ntrol ler' s renort for 1920 . ~his mRtoria l s oula be co.npiled by s !ltes as well as by size of bank, size of co.. t:1Unity , etc • •.•r . Smeud underst na.s the type 'Jf :-nal.;&i s which I have in -nin here . If these r no ts C'1.ne over in y ab ence , nybe you can m ke ar ·ange.en ts to proceed witn the tabul tions . Ir . is enc ing us si.x c rie of nis stu :r on "non-ban king 'Jo:npeti ·on in te o.f Ohio . '' 'Jhen they arrive . 11ill you ple se prepare or Dr . ~ol en eiser t s ~i ature a lotter to each of the eder 1 e serve banks '.!nicago , Kansa ~ity an alla.s asicin the, to prepare si il r studies . ~end to e'1ch of these 'lanl<"s a copy of le. in • s re ort a a ide . Be sure, 10,;ev r , to an•lise them that it i not necessar ;r 1n all respects to be a elabora te ac r.1erelan d 'las . The im"lortan t points ar a statisti cal story of tne growth of co~peti nf inst i tions a~ conpared vith banks, a su.."'?'?lary of the princip al n ovi ions a11s co erin such instit 1tions. and erhg,us co e testi ony from L>nn'k:er. as to the kin of competi t ·on the .. are meeting and its effects . l ming • s stuay is restrict ed almost entirely to buil 1n ano l an a soci tions . In the other i tricts, oNeve, the. sno1la. f!·ve attentio n t0 othAr competi n, instit tions, such a interme iate ere it ar.'k:s , feaeral l n~ b nks , etc . You 1ill probably ant o a r th r carefall y le. in t s re o ·t before you prepare the lett r t0 the other reserve b n,cs in or er t h'lt you y co,ument , ore fully on t e imno r t nt features . ,,iss ~vans ants to take a vacat;on of three rneks, "ithout oay se , beginnin B 'on ay • rcn . 0 h OP uod:nest:19:y if:I3rH 1st I BfA no t su=e::iim;e:i11.._ lea e check :.1 the a.ate· it:, ner ana. notif'< ..:r . qo na ays bf fore the date hat sne wi 11 oe off t e nay roll for t'l ·eeks . I lw'i11 nrobably rn k arr n ment to ay or to - orro~ 1ith nother co:nptom eter operato r to c1:ne i ... nea.iatel ana b 11i t s a , onth . I i11 aa.rise ritn yo r her > ut tnis before lenving so that yo can n re ner put on the nay rol 1 for th month . iss H il 1 can snow ou fro, ~e fi1Ps the nrocedu re in getting peonle on tn ~a roll . I 2,...- •r. Ha ond r. le i r. · istr sp 0 e bout This ill be~ ons o 'lnt t et bul ti0ns clerica l ssi t nee in r nged, but uni er no sched le to su fr . h~- vork. s T If t nd. i io e loy an i cler;c l t1 o l clerk or t be unAcono~ic 1 to is ill will l ok fter it tn tn nroner o~rti s. ~hem ents, etc., sho,1 be u ep ea or vo for ")r. '}ol en1eiser • l/:"Il'lture. ... ince r. 1ickens h the arran ment itnhi, toa nut him on t11 a · ork ve ... l1 o· 11 ·n ,i:r, • i1 n i tribute letter, such a c.tmovle ut all other letters in the ho pi al ev vork ·or the .,o nmit te ~oon as he ell r of t 1ree ff mni 11 t p to have ~0ur~e. t r. ,, o1 en· e i E assistan t o l n n, il ,. e proper n s ch s ts TJl c don ___ , t '3 ·e 1 ci.e h ve not y to o in o .... . k, • In t h /:,rm. NO, 131 - Offi ce Cor resp ond ~nce To ~-t1k - F"EDERAL RESERVE BOARD • • r • ...,mead rrntions Fil Date_ ~r h ... 3 .._ 1931 Subject: From ..:r . :uadle jPe e i< n tentativ f1 sched 1le nrerore d by. n oposes ti send to nctive banks with infonM .tion egar in he view o · thAir loans 'lnd in1estm ents . to talk to you about tnis so .etime uhile I q &. a'I v . • ,ickens wnicn he ettin~ some detaile d :. r . ,l'! ens may vant 'i.'his is, o c-:>ur&e , first r0uph ara t and he exnect s to do scxne ed·t~n~ on it if the iaea seer.is to meet vi th apurovn l . out sirn 1 r ;nriuiry i comp rison o~ mo e i prob11 1 nretty ell 1923 and thn he pe ;ods · ou11 ve should ask fo oul The Bureau of sions for slJlle ears materi al is still vailab le . oubtles s be very interes ting . i'Urther- this info!"'I! :ltion as of the end of 1930, it i ve S'Jme ina.ic• t ior leaned up o gri.cu1 tural Econo.n ics sent s to vhethPr the banks ere n'J v ·hether •;e :ni --ht expect a continu ance of o come . uspen- . • • 1 • • • t • ti • • n • • • • " II " r 2• • • • ----------. re • 1 31 . n , 1 2 0 1. ' • c. 0 1. ly INSTRUCTIONS TO FEDER.AL RES:ERVE BANKS FOR .ANALYZING TYPICAL C.ASES OF MEMBER BANKS WHICH H.AVE SUSP:ENDED OPERATIONS PURPOSE: The purpose of the analysis is to show in concise form the history (gained from comments contained in the reports of Examiners over a period of years) of factors developing in the bank mich u1 timately led to its suspension. The history should commence at a time the bank was in a satisfactory or fairly satisfactory condition and be followed through to its suspension. It is intended that a person reading the report should be able to obtain an understanding of the problems which confronted the bank and to form therefrom an intelligent opinion of how its affairs had been conducted for a few years imnediately preceding its suspension. METHOD: For each of the twenty suspended banks on the attached list prepare an analysis in accordance with the attached examples, Exhibit 12/1 and Exhibit 12/2. In the interest of uniformity these examples should be closely followed. In order that this small sample may be as nearly typical as possible of the suspended banks ir, your district the names have been picked at random without any regard to size, location or cause of failure. Do not write the names of the oanks on the analysis forms, but number them according to the numbers on the attached list. In furnishing the population of the city or town in which the bank was situated, give the census figures for 1910, 1920 and 1930. So that those studying these re:ports my have some idoa of the economic life of the community served by the oank which suspended, a brief reference to the principal crops grown or industries followed should be given. EXAMINERS, 1 co:::•:ENTS: Attention should be devoted to brief com.-nents by the Examiners indicating their impressions of the general affairs of the bank. Examiners in each instance should be designated by letters of tl1e alphabet, merely to inform the reader whether or not the reports had been prepared by the same ma.n. W'nenever reference is made to a certain Examiner, obviously the same letter should be used throughout. The statistical information regarding the condition of the bank, given at the beginning of a report and immediately following the comments of the Examiner, are to ce taken from the examination reports. • - 2 - EARNINGS: 1his information should be compiled for five complete calendar years immediately preceding the bank's suspension. It is to be derived from the Earnings Reports submitted by banks to the Comptroller of the Currency, copies of which arc in the possession of the Federal Reserve Agent. The item 11 Uet Income" comprises the difference between the total debits and credits to Profit and Loss Account exclusive of debits for "Losses Charged Off" and credits representing "Recoveries" on assets previously charged off. 'lhe item "Recoverias 11 represents the collection of items previously charged off the bank's books as losses. The i tern "Losses Charged Off 11 represents the write-off of worthless assets and depreciation on securities, banking house, furniture and fixtures, etc. ASSESSMENTS EEFORE SUSPENSION: The histor~,r should include voluntary assassrnents as well as those paid under statutory levy in order to remove an impairment of ca9ital. 13..l.D .il.SSZTS PURCH..\SED l3Y S IDCKHOLDERS: Inasmuch as this information is not ~iven in Reports of Earnings, but invariabl,r is touched u~Jon in the reports of Ex.a.miners, it will bo necessary to search the latter recora.s to ascertain to what extent, if at all, stockholders have purchased assets directly from tho bank or throU@l a Holding Company, or have otherwise made voluntary contributions to avoid an assossmunt or the reduction of Capital, Surplus or Undivided Profits Accounts. • Federal Reserve Cornr.ii ttee on Branch, C--roup and Chain Bankin; Cour:ients Re,:;arding tl1e Preparation of Form !far ch 20, 1931. !'. Form F sho1:..ld be prepared for each of the twenty suspended banks from the beginnin6 of 1920 till the tine of suspension. Two exar,;.ination reports each ;rear sho,Jld be analyzed and a separate co11;· of Form F :prepared from each report. In case there l1ave been nore than two examination re·L>orts of any bank in a given year, select those nearest April 1st and October 1st of that ;:;ear. A blan..1< form of t:1e exa.:,:iination re iort is attached with narked references to the i tens to be tc:cen off on For;:n F. These are references to the current edition of the examination forn, of course, and certain adjustments vrill have to be made in ta~cing off the data for earlier years. 1. In connection with slow loans, doubtful paper, etc., the earlier ex~ination re-?orts had a colu.r:m 11 0ther undesirable pa-;_:,er II for which no provision is J:1.ade on the analysis forn. This should be classed as 11 slo\v 11 with a footnote indicatin6 the a.r.1ount. 2. Sor:ie of the iter.i.s, as for example, 11 Contracts for deed" (item 23) require considerable scrutiny to see whet:1er anything along this line is shown arwwhere in the exa.:r.ination report. 3. Iter:is 20-22, pertaining to real estate loans, require much care in compiling because t:he fi 67.lres are not available in the desired forr:i in the re..;,orts, and certain combinations are necessary. 4. In the earlier ~rears care i,1Li.st be exercised to see that rediscounts are included in loans and discounts. Furthernore, in obtaining total borrowings, care mu.st be ta.ken to see that rediscounts are added to bills pey-able, for rediscounts are shown on the resource side as a deduction fron gross loans. 5. .After transcribing the fi 6ures fron a given examination re?ort, it should be coopared with the previous report to see that it is on a conparable basis. After compiling the data for each bank for the period fron 19cD till suspension, the fiGl.l.res for the twenty banks should be sUCT!'larized, using the sa;-10 for~ for su;:n:ia.ry re9orts. Since two exanination reports are analyzed for each year tv!O sur:r;;iaries will be made for each year, one for the first exar:,ina.tion reryorts for the year and one for the second re~Jorts of t1.1e ye&. The assur:rption is that these 7/ill be fairly representative of the condition of the banks during the first half and second half of the year respectively. Please show the number of banks entering the su.;7::-1.ry in each case. It is understood, of course, that the absolute figures shown in t~ese s·.1r.1r.nries ,1ill not be cor:rparable fror.1 year to year because of raergers, the drop9ing out of banks t~rough suspensiont etc. This will not affect the data for our purposes, however, as we propose to compute ratios for t~e various iteos and m..1.l::e our comparisons in this form. Bank Organized: Bank Suspended: Population of Town: (1910 census) (1920 census) (1930 census) 9599 14o27 10349 Principal Crops or Industry Served~ Bank: Lumber, fishing, shipping. AA( Ir:rportant Excerpts froo Reports of Exa.i~ination: ( Loans Deposits Borrowings ) 11-16-20 Exru:ri.ner_'..J_: 4oo 2591 50 / Classified Assets Doubtful Loss 82 4 9-12-21 Exa."tliner A: ''Present rna.nage:r.i.ent is considered good. Large aggref;ate of undesirable assets were mostly inherited from former management. There is no question but what present capital is too large. At time of consolidation it was left at this figure in anticipation of r.ia.terial increase of business but owing to depression of business generally bank shows a loss in deposits instead of expected increase. 11 9-12-21 Ex.1Jnner A: 4oo 80 13 1542 2015 195 63 4 2-28-22 Exa.~iner B: "Bank's present condition is probably due to some extent to general slump in prices and business generally, but is mainly due to unwise policy of previous management. Present manageoent is in no wey to blame for present condition. 11 2-28-22 Examiner B: 200 12 1367 1614 507 53 0 10-17-22 Exa."tliner C: "President is not a factor in management but other officers are capable. Tney with the more aggressive r.ieabers of the board will probably be able to solve the problel!lS of bank's present rather undesirable situation. Man3,genent has been too eager for business with result that mny loans are frozen ::md heavy losses are likely to be sustained. Bank is somewhat extended and has e:\Perienced some difficulty in financing seasonal operations of its customers. Directors 3.dvised that they believed worst of difficulties was over ond their future position should be easier." / 10-17-22 Exnoiner C: 200 ~--1 1456 1914 73 33 15 4-10-23 Exa.~ner D: 11 This h.'.ls o.lways been a one man bank. Years ago President__ W.'.ls dominating figure, succeeded by C~shier who recently resigned, and now being succeeded by Vice-President. President~hardly a factor in b.:Ulkls Illl\Ilagement. Pa.st t\..."'ld present management :.re anxious for business nany loans made 1.s a matter of policy." 4--10-23 E:x:.'.l-'Tliner D: 200 4e 17 1421 2073 O 97 20 ' ~.e-/ • _. Jhte Page 2 C.:::i.p. S;,.w.~.· LoMs Deposits Borrowings Classified Assets Doubtful Loss 10-22-23 Ex.:uniner D: "Forner President decen.sed. President _ _ is follO\ving closely in footsteps of predecessors o.nd conducting largely .:::i. one I!1tm bank so far ns he can handle rotters. He appears very e.:::i.sy in eztending credit or making too r.nny l .oans :1s .:::i. nntter of policy ond also very reluctant and timid in enforcing collection on criticised lines apparently being ~fraid he might lose a customer directly or indirectly. This report shows some impr.ovement but as a rule im?roveoent has been ID-'.'lde in reduction or elimination of slow or undesirable assets th1.t were least subject to criticism, while loa.~s most severely criticised have chruiged but little. Directors v,ere advised that unless nnterial improve:-.1ent was shown at next exa.":lination, p~rtic,J.1.a.rly as applied to loans to directors Md concen1s in which director.s _.•.1 ere interested as well as large anount of sto.tu.tory b~d debts, overdue po.per, slm1, doubtful, c3.nd otherwise undesiro.ble p:xper, s:::iecial* (*frequent) eru::uno.tions •,1 ould be recotinended. 11 10-22-23 Ex...'"lniner D: 200 ~ 1$.. 1537 1971 169 69 12 4-28-24 Exru-nner E: '~resident, who domin~tes policy to l3rge extent, is .:::i. good 'business getter 1 , but ra~1er weo.k in making collections, and is endeavoring to hand.le too mu.ch of bank's affairs n.lone. He should have a conservative bank r:nn to assist in nanageraent n.nd this m.1tter was thoroughly discussed with hio. Some general improvenent hn.s been ro.de, D1. though there still re1mins r.1Uch to be done before bank is clean. Slow assets show considerable reduction n.nd a. deal has been made for so.le of Other Reo.1 Esto.te. 11 4-28-24 Examiner E: 200 ¾,s.... J:-4.. 1438 1727 271 52 6 -9-f 11-25-24 EX'.lJ!liner E: "Directors o.nd officers sto.te that large n.;.:1ount of slov1 and doubtful assets were inherited o.t tine of consolido.tion with another b'Ul.k: sever~l years ago. However, it appears trot a number of large lines o.nd slow assets h1,ve ~ccu.r.mlo.ted since then ns a result of 1business getting 1 policy o.nd too free extension of credit. Preside~t is capo.ble but too libero.l n.nd too lenient in n'Jk:ing c.ollections. Besides, he h1,s recently spent too r.u ch tir.ie on personnl natters .:1.nd enterprises. This wo.s also severely criticised by ex:u:iiner and he now pronises to devote all his tir.i.e to bnnk's D,ffairs with o. vieu to gettin 6 b8.i1k in good condition ngo.in. Princi"?nl r.ntter subject to criticism is large n.r.'lount of Overdue P'.lper v1hicl including sto.tutory bn.d debts a 66 regates about 28% of bn,_.,--uc 1 s toto.l lo,::i.ns. This ~~~tter was severely criticised by exar:ri.ner during directors' ne eting. Exai::rl.ner inforr.1ed directors nnd President in po.rtiCul3r that unless decided improvenent in nn.tter of attention to slow o.nd doubtful ').ssets and overdue p'1.per was shovm at an enrly date by correspondence consideration mght be given by office of Chief TocaDiner to I!l3.tter of pl:1cing "'uank on Special List* (*moaning for frequent eL..'\.i--ni.n.::i.tion). 11 11-25-24 Exruniner E: 200 2011 103 58 1435 9 r • m±IB-111 i ~i P'lge 3 Loans Do)osits Borrovn.ngs 6-22-25 Examiner E: 11 12-28-25 Ex-u:u.ner D: 11 Cl'.lssified Assets Doubt~;l Loss A r.nterial ir:1prover.1ent in note pouch is noted in regn.rd to anoun t of overdue paper. Cl;>.s£ ific'.ltion of lO'w.iS, l10vrever, shows no inprove1:1ent. Slor1 locms show '.l decre'1se of $40,000 but doubtf1.c.l i tcrJs show an incre.,,sc of $52,000. Losses ch"l.rged off at fais tine or.1ountod to $17,690 ::i.s cocrp'lrcd i'li th $9,452 o.t h.st ex:min.1.tion. L-irgc a:·.·,ount of L1cro ...,,se in 1xi.per classed doubtful is o.lnost entirely due to change in cl:1ssific'"l.tion durinb exar.u.n;,.tion. :no ner, lonns of slow and doubtful character are b0ing r.nde 1.nd nost of loans criticised ".t this time h'.lve bec:1 in b:m::.: n. nu.;·1ber of ye-u-s o.:1d. ;1.re workout l)roblens. SoDo losses r:ey d.evclop in i ter:1S cl 'J.ssed doubtful out i + i ~ 1-iP.lioved bo.:1k 1 s e::u-ning c~p"l.ci ty ,,ill en'.1ble it to ch2r 6 e off J.osses .'.\S the;-- "C"P on. ifo dividends are to be pud until b'.ld debts '.lnd doubtful i te1:is '.lre eli::iin,..,.ted. '1 6-22-25 E:,car.u.ner E: 200 1:t6. ~ 1283 1555 306 t 150 13 Dircctors C\.S n. YThole co::"Q,'1rC favorably with .'.\VCr'\ge cou:1try bank. They o.re successfl'.l nen in their indivic":.u'J.1 lines of business •1,:1d nould do i7ell if tl1oy ho.d o.n ngbressi vc le"l.cler. l,h,.-i.._1,gc:·.1ent is veriJ '.7eGJ.c, L1.ckinf; force, if not incor:ipetent, ns indic"l.ted fror.1 n"'J.f.J.erous cri ticisns listed. Preside:1t is well :.:o"J.nin6 but ea.sy goinc; , e:1tirely too free i~1 ,.T'l.:1tinG of cr0di t a.nd '\7hilo et. lr>..rge nu.-:1ber of frozen ".l1d qu.estionn.ble -:i.ssots n.re an i:1.heritance fro□ forner r.1.'Ui",i;0:-1ent it is evidel1t t.11-:i.t President docs ;.1ot h:we -:tbili ty or inclin..,,tio:1 to collect or cler.i...11 u.:p those old r:nttcrs. President is believed to hn.ve had little b'l..i.i1.dng experience outside of t~1.is b..,_:1lc. Co.shier is 'ls ov..s~r 2;oinG as Preside:1t ·:ri th even loss initiative. It is, however, perhaps true t:v1.t Presiu.ent ;-10uld. :10t ?Cr:-J. t "1.Ssur.1_fltion of a.iv .:i.uthori t;;,· by 1.--iy other enploy.Jo n.s he x;r:)C.'J.l"s 'lnxious to n..,11n.6 e entire b~il.,;: even includin._; openins of all r.nil _?erso:mlJ.~r. When sug;;estions \/Gre r.1-1,de or cri ticisr.1s directed 1.t sevor'.11 he'.1ds of different dep,..,,rtnents t:10;: co::rnented to ex:,.::1i:10r in effect th-:i. t Prcside:1 t n:1s cq.._l".11;:, to bl::u-.:lG 1.s he would :10 t -_,er--,i t Ct.ny lec,r".;," vl1en they ~7cro C:.is;:>osed to bring 1,bou. t correction of sor.1e of cri tici o.od r.r,ttGrs. Writer e:;::i..::u.ned b..,..:.i::: in 1923 'Uld n. cor1nrison rri th his Jrevios rc~1ort discloses m.1I.1erov.s o.ssets cri ticisod '1.t tir.1e unc~rn6 0d "l.:id ,'11):;_)"..I'Cntl;y no 2tter:ipt m.1.de since then to liquid-1.to V'\rious st.'ltutory b8.d debts 1.:.id other questio;.1::,,ble t:t.-rid frozen "J.ss0ts. Exr-..i::inor reco:'.1·.1onds th"l.t bx1l::: be pl1.ced on list for frequent e:x:.'.1,.·:1.Lntions until cm1w. tion is s-i,.tisf':..ctory '"w.1d t;.1 . . .,t ne:d ex'1.r.:in1.tion be n:1de 90 d-:i;y s fror.1 d1. to. 11 12-28-25 Ex'.lDiner D: 200 1ts., .S-( 1855 2621 316 () 90 52 b... , 4-10-26 Exnniner D: "Writer 0A...._,1:u.;.1ed b::mk in 1923 '1.t ri,ich tine Preside·i1t TT,'1.S tl1en Vice ...Prcsident D.i."'ld .,t ·,-,:-:ich ti,:1e he succeeded to Presidency. B=i.nk l1a.s for i:~y yea.rs been a one-r:n;.1 b::ml:, ::1:1d co11J.i tion {;0:1crn.lly unsn.tisf:1ctory 6 ru,'ltor pCl.rt of tioe. At 0:x:t:tr:-in'\tion in 1923 ex:::i.:-.u.ncr urGod 1:1.'1111.gonent n.nd w.roctors to tD.ke pror.1_Pt nnd O.@bressive steps to collect or sec-:.;.re l"',rgo o.1.1ount of st'"\.ti.1tor;:,bo.d debts nnd other ovord-:.::.e p:-t.per, slov, :1nd q_uostion':1ble n.ssots, c1.nd directors r,cre ,..,_dvised th'J.t unless such ::i.sscts ,1ore given ir.t·1ed.io,t0 1.ttontio:1 b'Ull:: i7:..s certain to sust.'lL:1 l,..,.rgo lassos. E:x:"' 1·.1i11..'"l.ti0:n nf 12-28-25 '>7>cn cor.m.'U'od ',7ith 1923 ~:1ows • I( Cl~ssified Assets Dou tf,:.l Loss :::u:i.jority of l'lrger ci..1d t".Ore undosiro.ble c\ssets still in bn.nk ,-:ith r.nny l-:u- 6 c lonns unch.'.:\.L'1 6ed except th3,t t:1ey \7ere t\70 years r:iore ]?",st due nnd it ·.ns evident th".t mn::.genent h'l.ve m.'.lde little, if n.ny, n.ttoopt to sec1~·e stntus of such pa,er subsequent to 1923 or previous. This st'l.te of 3.ffn.irs ~as rn.ther forccf"Jlly brought to 'lttcntion of directors during 12-28-25 ex'.U:ri.n'.ltion and n. subst'.J.;.1ti'11 n.:.10unt of uncollectible assets of 1923 and previo~s uere listed '.).S estin".tcd lossess. So many promises and so IID.!C:l assurance was given exarniner at previous examin:i.tion that immediate steps wocld be taken to improve CO!ldi tion that the few changes and lack of improvement are most disappointing and discouraging. Special e7.a:ninations at short intervals vdll probably prove useless a.~1d a waste of time as b 1t little improvement can be expected in three to four months' time. Frequent examin'.).tions will undoubtedly create unfavorable comment and gossip to detriment of b'.Ulk. Examiner has lost what little confidence he had in 1923 in President and Castier and it is not believed these two will work the bank out of its most unsatisfactory condition. Without frequent examinations and the present management in charge it is believed ban.'!( will be permitted to drift and it ap1Jea.rs to be a choice of two evils, each reacting unfavorably for bank and its shareholders. Directors were advised t~nt examiner had no authority to demand or request resign~tion of any employee but that it was duty of examiner to make recommendations to directors for good of ban..'!( and it was suggested that if present mnagement did not show a desire or inclination to work with directors that directors should employ someone who would truce ch::l.rge of bank: 1 s loans and wl-10 would be responsible only to bo::u-d ~d not subject to interference by President or C'.J.shier :i.nd it 7t:is further sug5 ested that directors compel officers to compl~,' ,,i t:1 resolutions ~f)'.lssed tlnt no new lo'.llls in exce s of $500 be made wi.thout first being aut:1orized by fin.'1.Ilce committee '.llld that directors compel officers to furnish at Bo3.I'd meetings informntion they desire concerning status of lo3lls and other '.).ssets :md th3.t if ?resent officers ~re not competent in opinion of directors and b3JL1{: 1s ·11elfo.re "oe ir.:iproved by a ch'.Ulge of !Ill3Jlageroont th::i.t they give serious consider['.tion to s .1c. 11 19 118 268 2628 1941 4-10-26 Ex::uniner D: 200 ~ l/-~ \ 8-13-26 Examiner F: "General condition shows very little ch::,.."l.ge. Condition is most unsatisfactory ond unless some c· 1."l.ges '.lre mn.de I do not expect to see ".IlY mn.terial ch:i.nge for some time to come. President ~s Tiell 'lS directors are of opinion th-.t tl1ey s:1ould not be asked to put up rooncy to elimin"'\te O..."lY losses .,nd doubtful priper, contending th'l.t bonk C'.Ul earn its ;ny out in time. Ex·1sci:1cr does not agree :1nd informed them th::l.t the~r r;ould be given until nc;:t ex,'llllin:1tion to provide for losses cstim'l.ted. Examiner informed directors t~~t they TTould be given until next cx.'.lmination to IDc.'\ke some provision to provide for losses n.nd other i terns tot.,.ling $144,819.39. Your exn.r;iiner h.'.J.rdly CAJ)CCts to get e:1o~h m:mey to elimin-.te n.11 t:U.s po.per but thought thn.t by pb.cin.; this progr'.1l1l before them they ·~ould exert themselves to collect this pc;per. ::stir.utcd losses r,ere not ch~ged off for ~bove reason. Ex.::u:uner thought thrit if situ.~tio~ was to be broug.~t he:.1.d it should be done a. t one time. My ide::i. vm.s to pl!'l.Ce them on notice th,, t to • ~ Puge 5 C ~ssifiod Assets Loans Deposits :Borrowings~ Doubtft.1-l Loss some t::.1ing ':'l'Ould h-.:we to be done by time of next ex-u!lination .'.:l,nd perh_:::i.ps some concerted action could be obtained for the better. It is respectfully rocorrrnendcd that bank be not placed on sp0cial list at this time. I do not think Sl?ecial examinations Ymuld be of any value now. 11 59 90 172 2672 1915 / 8-13-26 E::caminer F: 200 )6 1-23-27 Examiner F: "General condition sho,vs some slight improvement a:1d officers and directors promised to continue efforts towards collecting criticised ~a,er. At t:1is season business is very poor and collections slow. Real estate is extremely difficult to sell and a large araount of bank's loans depend on sale of city property, farmland, and timber. With this condition it is extremely difficult for management to collect a.n.y paper predicated on above assets. President is interested in entirely too many civic n.ffairs o...n.d other things and C'lrl::J.Ot ciovo·cc all his time to bank. Durine; e:x.?.!nin1.tio:1 I took p1rticul'U' notice 'Ln.d ho spent rnnjori ty of time out of b.'.:ln!c. T'nis vns forcefully c-illed to his 'l.ttention :1..--id his excuse is that no one els8 will do it. Your eX3I!'liner h~d ~ fr'l.nl~ talk with Prcsitle~t and e:.:1C:e0,vored to sh9,-r hi!!l th'1t he 'ilas doing ,;rrong. 0:.1 ot!1er h"l.i."1.d he S)ends his person-:i.l money for benefit of b.-:t:12.: in wrzy of tr-....sportqtion, etc., 'w."ld t:hore is no question th-:,,t he is doing his best to pl:i.cc b'U'l.lc in "'more s'l.tid'1ctoi-.:r co,1di tion. He is one of mst ple'.lsing non I h:we h:J.d tho ple::i.sure to co:ne in cont'l.ct ·.-,i th but is inclined to let people imi)Ose on hirn x1d sor:ie of his finn.ncing is su"ujoct to criticism. He tries to help people ·1.nd concerns -;,ho do not even do busino:,s with the b'l.nk :md r.l.nyonc cnn t::ike up ~1is time TThcnever facy desire. At prcse,1t b::i.nk h::ts good en.rnii.1 6 en.po.city, ::1.p_9roxir,ntely from $25,000 to $40,000 per ·un-c..::i '1.ftor expenses :.md with "- reduction in interest p'l.icl s'.lvinGs depositors it •wcld me"..11 some $IS, 000 D. ycn.r addi tion'l.l profits. In past fc·:, years 'l-11 C'l.rnings h.ve boor. used to c:1'\rge off losses. In pri..st six yc1.rs b1,1k !1as clvirgcd off over $172,000 in losses ,'1.nd recoveries have o~~,or.nted to over $26,000. This is belicv._,CI. to h:-,vc beo~1 in n.ddi tion to o.sscts elimi:1:'.~ed by .?.. rcciuctio:1 ii.1 Cr.l.pi t.:t.l of $200,000. Pr-,,ctic:illy '1.11 these .'l.sscts 1,7ere i:mcri ted by prese:1 t :1c'Jlla6 cr:-,cnt n.nd t:nt 11.olds t ood Yri tl1 -:,,ssets criticised in this rc~_,ort. This r(,":pOrt shor:s esti;:... ._tcd losses :-,,i:,;.·rug3.tin6 $132,000 ::t.."1.d on Fcbru'\r:· 1l.1.th I ,7ircd yot:.r office sto.tu.s of situ-i.tion • .A.ftcr sever.:11 conferences 1-rcrc hold directors ro.:1Chod conclusio:1 th,t 'Ul 'lssess,Jo:1t ;rould not be proper procodc!re. It ,,,n,s fin::tlly ri.groe th1.t the~r nould. i)erson.:-.,J.ly purchase t:1cse i te,ns 3,;.1d it m:i.s defini tcly u:..1dorstood tl1"..t tl1e,.: ,··ere to be purc~1ased for c,9,sh and 1.mder no circumstances were a.ny notes to be tMen by bank. This t:1.ey agreed to do, but .ra.11ted. 30 ~ s i n ',7hich to coaplete t!leir e1.:na..1ge.:1ents a:1d accordingly your office ·,1as notified. YO'ir \TI.re of Febr'J.3.ry 15th ·;;as received in ·.1:1ich you stated that icrp':..irrne:it notice rrould be vii thheld for 30 d3J"s o.nd I a.ccordin6 ly notified man~e·::e:1t tn:it they -;,ould be {,i ve11 u:.1til M:1rch 15fo i:1 ..,.,hich to co:nplete their pla..s. 132 19 2701 179 1803 1-28-27 Exar:ri.ner F: 200 ~/,(_I 6 ified Assets ~~t_f_u.l~ Loss 8- 2-27 Exa.-:iner F: "Condition remins most unsatisfact ory and mnage;:.ient .::i.ppe'l.rs to be making very little progress in collecting criticised assets. President continues to dominate and apparently directors cannot control him. Bank is overloaned and President continues to make loans that will prove very slow and also continues to try and finance everyone in the community. Regardless of advice he receives fro~ examiners and experienced bankers he does not change his policies. I am afraid that if he does not change his ways he will find bank in a serious condition one of these deys. I had a talk with his principal corresponde nt ban~er on Au.gust 16th and he told me he had talked to President a short time ago mid if he did not cha.,ge they would be inclined to refuse his ba::ik further loans. The Federal Reserve Bank is very reluctant to discount his eli 6 ible pnper and ,'.U'e constn.ntly w3.tching him. I am not .'.lll satisfied with condition or policies and feel th'.lt something must be done to correct situation. In view of this situ3.tion it is respectfull y recommended th~t bank be pl'.3.Ced on speci"l.l list and be .::i.g3.in exnroined in '1.bou.t 90 dtzy-s. 11 l 4o 314 ~ ~ 1950 2512 8- 2-27 Ex..1.!Ili.ner F: 200 1-20-28 Ex'l..rniner F: "As ex:unin.'ltion was made on basis of e;oing bank, it hn.s been difficult to write re?ort, and eX'.lllliner has attempted to cl~ssify .'.lssets as they I a.re cl3.ssified under the receivershi p. It is to be noted that I slow assets rt'1.s been elimin~ted. Examination w.::i.s conmenced on .::i.fternoon of 1-20-28 .'.)Jld W3.S completed 2-11-26. Precarious condition was thoroughly discussed with directors latter part of February at which Chief Examiner was present and ways ::ind me!).:(;l.s to elimin~te esti~ated losses 3..~d frozen ~ssets was topic of conversatio n. It w~s concensus of opinion that efforts should be ma.de to orga..,ize ::i. nen b:mk to assume deposit li'1.bilities nnd truce over a like ,'.:i.mount of assets. With this ti1ought in mind ex'U1l:i.ncr 18ft b~nk but kept in touch with directors as to progress ran.de in this direction. President tendered his resign.::i.tion the l~tter plll't of J.'.)JlU.'.lry and this was publisr-cd in a loc.::i.l ~ewspaper in such a m~nncr ~~at it left a great dc~l of inference vrith result th'.lt a run v,n.s started ,'f::ich re::.ched such proportions th:::i.t cx:l..rniner was requested to return o.nd advise with directors. After ::i. thorough nn'.llysis it vns cicemcd advisable to close the b,'.1,,ik :i.s ru.n had re'1.ched such propor) tions that it ·;,as useless to keep open. 333 810 152 2473 ~ 1745 1-20-28 Ex3.rainer F; 200 s-1 E:i.rni ~ Net Income (Gross E.')r!lings less Expenses) Recoveries Losses Ch~rged Off Assessments before Suspension Bad Assets Purch~sed by Stockholder s Dividends 1924 ~ 1926 ~ Total 34 29 17 36 30 146 0 25 0 0 8 1 19 0 0 0 10 35 6 1 33 G 18 156 0 68 0 8 0 0 0 44 0 0 0 68 • Ban.:.c Organized: :Bank Suspended: 1238 (1910 2957 (1920 2455 (1930 1900 1924 census) census) census) Principal Crops or Industry Served :!?_y Bank: Wheat~ potatoes, livestock, alfalfa, beets, seed-peas. l!!!Portant Excerpts from Reports of Examination: ....,,. 10-13-20 Examiner A: pap. $,ax; 50 '5Q P»ef. Loans De"l')osi t :Borrowings 501 581 Classified Assets Doub tfo.l Loss 0 0 7-14-21 Examiner B: "General condition is rather satisfactory on the whole, e.apecially in the lig.~t of two or three poor crop seasons experienced in L½is community. Ba:nk 1 s condition is extended but fact tl:at proportion of rediscounts is so large speaks well for character of paper. Paper is of good general c1-.Q.!'acter except that some wheat growers on dry land have become involved. With '~oocl. crop returns this year material liquidation ma;y be expected. Management is ca::.•eful Md efficient and gives close attention to paper. :fo one man dominates. 3::uik is situ:1.ted in good agricultural cormro.ni ty, pn.rtly irrigo,ted and partly non-irrigated l:mds. Crop prospects on irrigated land 'lre fine 1:1.nd fair on dr~r lwds. 11 7-14-21 E.x::uniner 13: 50 50 6R 354 403 47 3 0 1-20-22 Examiner C: "In general, a well-m'1nn.6 ed and well-run ins ti tu tion. Personnel appears very capable and considering gener~l conditions here, t~ey h~ve done very well to keep bD.nk in its present shape. C-ener:.ll conditions in t ·1is dry farm country have been very unsatisf:.1ctory on .1,Ccount of :1oor crops n.nd. ·1'o"v-priccs 3.Ild unless conditions improve banks here will be very !ia.rd pressed this co:-:ung year. 11 1-20-22 Examiner C: 50 50 2 671 451 277 17 0 7- 5-22 EX.'.l.miner D: 11:Maru:i.gement has been in the past too lenient in accepting paper for RCCommodation of other b.'.Ulks. Most of the p~per is slow .-md must of necessity be eliminated slowly. This is an element of danger ::ind considern.ble losses may result before paper is eliminated entirely. (They taJ.ce lo'lns to accommod..."l.te other banks, $82,000). Bn.nk is in n. verJ extended condition but crop cond.i tions are very favorable ~s ~ whole. If ~dverse conditions prev~tl problems for bank will be difficult. 11 7- 5-22 Exruniner D: 50 50 2£ 663 394 371 11 7 ' EXHIBIT 12-2 • Page 2 Cap. Sur. Prof. Loans De~osits Borrowings Cl 'lssfied Assets Doubtful Loss 2-10-23 Ex'lminer E: "This b~ is in ::1. rn.ther d:1ngerous concli tion :i.t present due to 11,rge amount of borrowed money n.nd excessive n.mount of slow :md doubtful paper. Surplus is also imp'"rircd by estiJ'!JD.ted losses. Another contributing factor which makes condition dn.ngerous is lsi.ck of confidence by public on -,,ccount of largo number of banks which have closed. As yet t:us feeling h'l.s not been noticeable here but matter should not be overlooked. Some of present stockholders probn.bly could meet a 100% assessment but this applies only to a minor portion. The larger sh/U'eholders are :ure~dy heavily involved. If permission to increase cn.pito.l $50,000 is gr'l.nted it will r.io.terially better b-mk: 1s condition. Directors desire to sell new stock .n. t $150. Premium of $25,000 to be used to cho.rge off losses o.nd doubtful p'.3.per. Examiner recormnends e::mmination in 9G clays. 11 2-10-23 E~niner E: 50 50 2R 617 377 325 12 9 5- 8-23 Examiner E: ''Bank is still in dangerous condition due to large ar;i.ount of borrowed mney and excessive ar.1ount of slow and doubtful assets. At lo.st examination directors desired to increase capital to $100,000 and believed they could seJ:l steel: at $150.n.nd were to use a.mount derived fr01n premium to chc1.rge off estina.ted losses and doubtful paper as far as possible. At this e:mnin-:i.tion capital had not been increased nor could stock be sold at 150 or even p.'U' at this time. Examiner decided it best to clean house. Estimated losses n.ggregating $37,000 were ordered charged off ood entries mn.de during eX3.'.-:1ination. This practically wipes out surplus and as a result ~nny excess loans a.re shoi7Il. Should crops prove poor tl1is ye'.ll' or a1,rket conditions adverse b'.ID.k ·:,ill undoubtedly suffer heavy losses. Confidence of people of comr:runity is none too good. E:i.ch tine examiner visits bank there are so1:1e ,1i thdr3,rr~ls. President be;,1,rs confidence of people but is also president of 'l.noth0r bw~ 1.Ild is obliged to spend most of his time there. C'l.siier's person~lity does not inspire confidence of public in b'.lnk. Stepc; ~re to be tl1ken to '.l.p·Joint one of the nos t influenti -,_1 stockholders as vice-president who is conserv'l.ti ve, a good collector n.nd ·;rill devote nost of his time to bank. It r.:i.3;y be of considerable benefit. E:,cnincr does not recor.1r.1end. t:ll:ing bnnk off speci'.11 list (for frequent ex-u:u.n::i.tion). Should .-:my unusu.1.l conditions arise banl:: would hwe difficulty in r.1eeting der.nnds. 11 5- 8-23 Exar.uner E: 50 50 6Red 614 298 350 42 37 11-12-23 ~.!iner E: "Some ir.iprover.ient ros been ::nde since lo.st e.x.1.r.tlnation. Loans have been reduced $63,000 borroued money $33,000 and deposits increased $13),000. Principol improvenent is in restorn.tion of confidence of co[~unity in b~nlc ::md it is believed th'.l.t danger point has paijsed. A very bood crop of wheat is being harvested '.md mile prices ~re only f~ir, consider~ble liquidation fron this source will be ha.d. People are i;;ottine; in some r.10ney and o.s :1 result a. nu.ch better feclinG ~11 ~rJund prev3,ils. Officers and directors estioate th~t • ' • EXHIBIT 12/2 Cn.p. Sur. Prof. D:.te Cl1.ssified Assets Doubtful Loss Lo.'.lns DG-oosi ts :Borrorrings b'Ul.k mll be o.ble to cut dovm its bills pa.,v1.ble Yri th Feder~ Reserve :S.'1.nk another $100,000 by J::i.nu.'.ll'y .1st. Exnniner b elieves thn.t a further reduction of $50,000 to $75,000 in bills p.:i.yci.ble rrill be a.bout the best they c1.:1 do. This ,rill still le.!1ve b'\IU inn. badly extended condition. It is believed th.'J.t prese:1t conditio:!.ls h".l.ve taught officers o.. lesson and credit ndva.nces here"..iter TTill be c~efu.1 l~r considered before beini; n':l.de. C'1shier is not a very bood banker ,'.l..'t).d ::i. ch:inGe in r:v.m1.ger.1ent ,wuld be of gro'.J.t benefit. President is believ0d C:J.p'l~Jlc ".nd ,'.l!l'.""ious to 6 et ':l.ff~irs in good condition 6~in, but is obliged to spend nen.rly ~11 his tine -i.t anothe r bn.n:i:: \7hich requires his close n.ttention. Iden. of ii.'1cro",sin 6 C";pi t-:,,l h'\s been ,. . _bo...1donod o,s it is believed stock could not be sold. E:or::rl.ner rospoc t f ully recor:nends th;-i,t b:J.n:.-:: be kept under surveillance by reports '.lnd correspondence ra.ther th::m by frequent visits by ex".r.n.ner. Too libero.l gro.nting of credit in pnst is C.'.luse of bn.:nk 1 s present condition. 11 2 16 327 379 551 6REd 13 11-12-23 ~~".:".iner E: 50 °B:3.I'nings: ( 1ili Net Incooe (Gross E".rnings 13 less ~"Penses) 0 Recoveries 3 Losses Ch~r 6 ed Off 0 Assessnents before Suspension 0 E'.J.d Assets Purchased by Stoclr..holdcrs 16 Dividends 1920 14 1 B 0 0 10 ~ 1922 19.g} 16 1 12 9 2 42 0 0 0 0 0 1 0 0 0 3 3 r " Tobl 57 7 ,;;• vI' ,.J 0 0 27 . .. • , Feder al Reserv e C0rnm ittee on :Branc h, Group and Chain :Bankin6 • Ferm F Al!.ALYSIS O? Ns~'I'I03AL :P2..iliX EY_'..MI:T;..TION REPORT Name of bank l)a. te Place Item Where found (page) Amount (L.=L iabilit ies on Page l)(In thousa nds (R.~Re source s on Page 1) and tenths ) 1. Capita l ...... ...... ...... ...... ...... ...... . 2. Surplu s •..... •..... •..... ...... ...... ...... . 3. UncUv ided profit s •...• ...... ...... ...... .... 4. Reserv e for depre ciatio n and loss8s ...... ... . $_ _ _ __ 1 - L.l 1 - L.2 2. - - - - - - 4. 5. ___ l - L.L+ :Banke rs 1 6.epos its ...... ...... ...... ...... .. . Time de_)os its ...... ...... ...... ...... ...... . 7. U. S. de.,1osi ts •..... ...... ...... ...... ...... 8. Total depos its ...... ...... ...... ..•... ...... 1 - 1.13 9a ::.orrov red moYiey •..... ....•. ...... ...... ...... 1 - L.17-2 0 1 - L.8 __ 6. 1 - L.8-14 1 - L. 12. :Banki ng house, furnit ure & fixtur es , •..... .. Lnans to office rs & direct ors (direc t) •..... Loans endors ed or guaran teed by off. & dir ••. Lonns t0 intere sts of off. & dir. (direc t) ..• 18. Par v, lue ('If stock 5-11 1 - R, 12 1 - R. 11+-20 1-Part of R. 24 13. Reserv e, cash, cash items, and. d.u.3 fro.n banLs 15. 8, 16 10. Tote.l loans (inclu din_ redisco u...v1ts ) •..... .... l - R, 1 11. Total loans and invest me:its (incl, redisc ounts) 1-R. l & Excess (if any) of expens es over earni~ gs •.• 7. 1 - L. 14 9b :Borrow ed oonC:s ...... ....•. ...... ...... ...... 14. 1. _ _ _ 3. - 1 - L.). 5. 6. 16. 17. of Repor t _ _ _ _ _ _ 9a ______ _,, b -_ -_ -_ -10 ___ ll _ _ _ _ _ _ 12. ___ ___ 13. - - - - - -14. ___ ___ _15. - - ___ - - -16. ___ 17. 2 2 2 ned by direct ors •..... • 2 - - - - - -l& Fast dt:.e loans ;. & :S •..... .. ...... ...• •..•.. 4 _ _ _ _ _ 19. 20. First mortga ge (Loans vi thout prior liens, except •-here called II contra c t 11 ) • • • • • • • • • • • • 21, Junior rnortga6 es (.All loans with prior liens) 22. Fri or lier:s (to junior mortt;a §_es) •..... ....• 23. Contr acts for deed (:nore often in reca·~J. of inves t:nen ts on Page 7) ••••. ...... ...... ..• 5 5 5 _ _ _ _ _ _ 20. _ _ _ _ _ _ 21. 22. --- 5 ___ ___ 23. 19. 0 111 Liquid Invast ments 24. U.S. bonds 0th~r than those ser,uri ng circvl ati0n 1 Other invest ments not in defau lt (:uarl:e t val1:1~ 25, Foreig n • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 26. Railro ad . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . • . . . 7 27. Public uti.i..i ty • • . . . . . . . . . . . . . . . . . • . . . . . . . . . • 7 28. Indust ri2.l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 29. rf.unici:;,1al bonC:.s • . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 30. W.scel lan.eou s bonds, tax certif icates , \varran ts, and other liquid invest ments , exclud inG foraclosur es, claims , judgm ents an ... defau l tee. oonds 7 Other Real Estate 1 3l. Book value •...• ...... ...... ...... ...... ..... 32. Frio1"' liens ...... ...... ...... ...... ...... ... . 3~. E"'t1·""" f.ed valu ..,, i,;11 ""'..... ... • • • • • • • • • • • • • • • • • • • • • • • • • ••• Slow loans ...... ...... ...... ...... ...... ... . SloV' bon r., ss.ou. ritbs, etc ••...• ••.... ...•• Slow 11 0tll•••r 11 r 1 cataw ...... ...... ...... . . - .......... --- - R.6 & 8 8 7 ___ ___ 25 - - - - - -26. ,_ _ _ _ 27, 2f.< ---- - -29. ___ ___ ______ _, o. _ _ _ _ _ _....,..1. _ _ _ _ _ __,, 2. s _ _ __)3. ll 4. _ _,_ _35. ll --- --- - ll ___ ___36. 11 11 ___ ____,,8. - 3 7. 38. 39. Doubt ful assets end. losses Lo~rns Doubt ful assets a.'1u. losses - Bonds & secur ••. Doubt ful assets e.nd losses - .All ofoer ...... 11 _ _ _ _ __,9. o. Value of assets not shown on books .•••.. ....• 11 - - - - - -4o. 41. Large state, count y~ munic ipal dc1os its subjec t to check ...... ...... ...... ...... .. Yellow Page ). _ _ _ _ _ __, I· ___ ___41. 0 ratiori re 20, 1 31. ,, . . 2 t • o. -· ' I -· INSTRUCTIONS ·I'O FEDERAL RES:ERVE :B.Al~S FOR .ANALYZING TYPICAL C.ASES OF MEMBER BANKS WHICH !{AVE SUSPENDED OPERATIONS -PURPOSE: The purpose of the analysis is to show in concise form the history (gained fro1n comments contained in the reports of Examiners over a period of years) of factors developing in the bank v.ihich u.l tima telJr led to its suspension. The history should coIDIT1ence at a time the bank was in a satisfactory or fairly satisfactory condition and be followed through to _its suspension. It is intended that a person reading the 1eport should be able to obtain an understanding of the problems which confronted the bank and to form therefrom an intelligent opinion of how its affairs had been conducted for a few years immediately preceding its suspension. METHOD: For each of the twenty suspended banks on the attached list prepare an analysis in accordance with the attacned examples, Exhibit 12/1 and Exhibit 12/2. In the interest of uniformity these examples should be closely followed. In order that this small sample may be as nearly typical as possible of the suspended ·oa.nks ir, :row· district the names have been picked at random without any regard to size, location or cause of failure. Do not write the names of the banks on the analysis forms, but nuinDer them according to the numbers on the attached list. In furnishing the population of the city or town in which the bank was situated, give the census figures for 1910, 1920 and 1930. So that those studying these re?orts may have sorue idea of the economic life of the co,mruni ty served by the "'i:lank which suspended, a brief reference to the principal crops gTown or industries followed should be given. EXAMINERS I CO:: :ENTS: Attention should be devoted to brief corn..i:mts b? the Examiners indicating their impressions of the general affairs of the bank. Examiners in each instance should be designated by letters of the alphabet, merely to inform the reader whether or not the reports had beon prepared by the same rran. W'.nenever referenca is made to a certain Examiner, obviously the same letter should be used throughout. The statistical information regarding the condition of the bank, given at the beginnin 6 of a report and immediatel? following t11e cornnmnts of the Examiner, are to ce taken fro1n the examination rupor ts. - 2 - EARNINGS: This information should 0e compiled for five complete calendar years immediately preceding the bank's suspJnsion. It is to Je derived from the Earnings Reports submitted b:, banks to the Comptroller of the Currency, copies of which are in the possession of tho Federal Reserve Agent. The i tern "Net Inco.nc 11 comprises foe difference "uetween the total debits and credits to Profit and Loss ~ccount exclusive of debits for "Losses Charged Off 11 and credits representing "Recoveries" on assets previously chargGd off. 'llle i tern 11 Recoverias" represents the collection of items previously charged off the bank's books as losses. T"nG item "Losses Charged Off 11 represents the write-off of worthless assets and de?reciation on securities, bankin 6 house, furniture and fixtures, etc. ASSESSMENTS 3EFORE SUSPEWSIOH: The history should include voluntar~r assassments as well as those paid under statutory levy in order to remove an impairment 01 ca9ital. B..:\D .A.SSZTS PURCiUSED BY S 'XiCKHOLDERS : Inasmoch as this infor.nation is not 5 iven in Reports of Earnings, but invariabl r is tot:chcd U_)On ir. the reports o:: Examiners, it will bo necessary to search tho latter records to ascertain to wl1at extent, if at all, stock.::oldcrs have purchased assets directly from the tank or throu$l a Holding Co,npany, or have otherwise maei.e volunt2,ry contributions to avoid an assossm,mt or th.J roduc tion of Capi te.l, Surplus or Undivided profits .Accounts. 0 EXHIBIT 12/1 Population of Town: Ba.."'lk Organized: Bank Suspended: 9599 14027 10349 (1910 census) (1920 census) (1930 census) Principal Crops or Industry Served J2iL Bank: Lumber, fishing, shipping. Ir;rportant Exce:r:pts fron Reports of Exar:ri.nation: !ate (000 orai tted) Cap. Sur. Prof. Loans Deposits Borrowings 11-16-20 Exa...nuner..:.J..: 4oo 2591 50 Classified Assets Doubtful Loss 82 4 9-12-21 Exa..-:ri.ner A: "Present ma.nage~ent is considered good. Large aggrebate of undesirable assets were mostly inherited from former management. There is no question but what present capital is too large. At time of consolidation it was left at this figure in anticipation of mterial increase of business but owing to depression of business generally bank shows a loss in deposits instead of expected incren.se. 11 4 63 195 2015 1542 13 80 9-12-21 Exa.'7ri.ner A: 4oo 2-28-22 Exa."':Uner B: "Bank~s present condition is probably due to some extent to general slump in prices and business generally, but is mainly due to unwise policy of previous r:ianagement. Present rna.nager.ient is in no wey to blame for present condi tion. 11 0 53 507 1614 4o 12 1367 2-28-22 Ex.a.miner B: 200 10-17-22 Exa-:ri.ner C: ''President is not a factor in management but other officers are capable. T'ney with the more aggressive me~bers of the board will probably be able to solve the problel!lS of bank's present rather undesirable situation. Manageoent has been too eager for business wi~~ result that mny loans a.re frozen .m d heavy losses are likely to be sustained. Bank is somewhat extended and has experienced some difficulty in financing seo.sonn.l operations of its customers. Directors advised that they believed worst of difficulties wo.s over and their future position should be easier." 15 33 73 1914 4o 17 1456 10-17-22 ExD.oiner C: 200 4-10-23 Exa.-:ri.ner D: 11 This 11.'.ls o.lwn.ys been a one man bank. Years ago President_ was d.omiIUting fi 5ure, succeeded by Cashier_ _ who recently resigned, and now being succeeded by Vice-President. President is hardly a factor in b3.Ilk: 1 s man~ ement. Past ~id present management are a....-uci.ous for business U'UlY loans made ~s a matter of policy." 20 97 0 2073 1421 17 40 4-10--23 Ex3.miner D: 200 -· EXIU:BI T 12/1 P3.ge 2 Cap. Sur. Prof. Loans Deposits Borrowings Classified Assets Doubtful Loss 10-22-23 EX'.1Illiner D: 11 Forner President decea.sed. President __ is following closely in footsteps of predecessors ond conducting largely o. one rxi.n bank so far ns he can hn.ndle mtters. He appears very easy in eztending credit or making too many l .oans :is o. nntter of policy and also very relucto.nt and timid in enforcing collection on criticised lines apparently being ~fraid he might lose a customer directly or indirectly. This report shows some imp~ovement but as a rule im 1rovement has been nnde in reduction or elimination of slow or undesirable assets th'1.t were least subject to criticism, while loans most severely criticised have changed but little. Directors vrere advised that unless nnterin.l iq,rove::.1ent wn.s shown at next exa.'::ri.nation, p~rticularly as applied to loans to directors Md concerns in which director.s .~1ere interested G.S well as large :mount of stc.tutory b~d debts, overdue po.per, slow, doubtful, ~nd otherwise undesirable p~per, special* (*frequent) ex<mino.tions ',1 ould be recot1r:1ended. 11 10-22-23 Ex...'\Oiner D: 200 4o 19 1537 1971 169 69 12 4-28-24 Examiner E: 11President, who domino.tes policy to 13.rge extent, is n f;Ood business getter', but rather wenk in mn.king collections, and is endenvorin£ to hn.ndle too I!lll.Ch of bank's affairs alone. He should have a conservative ba.nk nun to assist in oanagenent and this IIl.'.).tter was thoroughly discussed with hin. Some g~neral improvement hns been r:'lll.de, although there still remn.ins r.mch to be done before bank is clean. SloTT assets show considerable reduction o.nd a deo.l has been made for s:3.le of Other Real Estate. 11 4-28-24 Examiner E: 200 4o 14 1438 1727 271 52 6 1 11-25-24 Ex3.miner E: "Directors and officers sta.te that large a.;:1ount of slow and doubtful assets 'were inherited n.t tir:ie of consolidn.tion with .'.l.Ilother b'll'lk sever,1,l years ~go. However, it appears trot n. number of large lines n.nd slow assets h'l.ve ~ccur;iulated since then as n. result of 'business getting 1 policy ~nd too free extension of credit. Preside~t is capable but too liberal ond too lenient in r1'.lking c,ollections. Besides, he h'l.s recently spent too r:uch tine on personcl oatters -'.lnd enterprises. This was also severely criticised by exXJ.iner n.nd he non prooises to devote all his tifle to bruik's affairs with 3, vieTI to getting b~11k in good condition again. Princi,nl r..ntter subject to criticism is large n.r2ount of Overdue Paper whicl including statutory b'\d debts a,6 gregates about 28% of ba.·1.k: 1 s toto.l loans. This r.iatter was severely criticised by e:x:aruner during directors' neoting. ExaLuner inforr.1ed directors and President in pn.rticul'il' trot unless decided ·improver.1ent in nn.tter of attention to slow and doubtful 'lssets and ovcrd.ue p"l.per wn.s shown :1t an early date by correspondence consideration cight be given by office of Chief Ex~niner to rrntter of placing banlc on Special List* (•meaning for frequent e:m.minntion). 11 11-25-24 Exn.rriner E: 200 4o 29 1435 2011 58 103 9 ... EJGU:BIT 12/1 C.1.p. Sur. Prof. Lo~ns Do)osits Eorronings 011.ssifiod Assets Doubtf~l Loss 6-22-25 Exa.n:i.ner E: "A r-ntorio.l ioprover1ent in note pouch is noted in re 6 :..rd to ~v:iount of overdue p1.1pcr. Cl')srific.1.tion of lo:w;,s, :10rwver, shows no icr_prover:ient. S1011 loa..;,s show '.l decre:?.se of .$40 ,000 but douotftl i t0:.1s s~1ow an incre:-,,sc of $52,000. Losses ch'U'ged off n.t ~1is ti:..1e :i.YJ.ounted to $17,690 1.s co,:ip'.lrod \'Ti th ::P9,452 o.t b.st exarJ.inn.tion. L'1.r 6 e x:.ount of ii.1cro'l.se i::1 p::tper cl1.ssed doubtful is o.lr.iost entirely due to change in cl:1ssific".tion durinb ex.-1.r.1in.1.tion. rTo nerr 10.1.ns of slow n.~1d doubtful cl1arn.c ter r-1.re b0in.; r.11,de 'Uld 1:1os t of lo.-.:1s criticised ".t this tine h.1.ve bee:1 in b:m:: n. nunber of yc".rs 1:.1d ,1,re \70rl:ou t l)roblei.1s. Sor.10 lossos a-zy develop in itc::is cl1.ssed doubtful but it is believed b.'.l.:llc 1 s C'"l..rning c.:,,p:::i.city •:ill en'.lble it to c:1'1rge off losses :is they develop. ::o cliviclends n.re to b0 rn:i.d until b1.d debts ~1d doubtful i te::15 '.1.re cli::rl.n,.,tcd. 11 6-22-25 llicn.r.uner E: 200 4o 16 1283 1555 306 150 13 12-28-25 Ex-1runer D: "Directors ::i.s o. ·ahole co:--r:_:>,'"l.re f::i.vorn.bly \71. th :::1.vor1.ge cou.:1try b:-l.11]:;:. They .'.l.rO successf1.'.l non in their indiviC:::cJ.'\l lines of business '"l,.1cl iiould do 11ell if t!1cy h::i.d t:i..'1 ::i.fbTessivo le:::i.d.cr. ,.1".'-7.'1b'C •.1cnt is very wcxc, 1[1.C!-:inf; force, if not incor.ipetent, ::i.s i:1dic1,ted fror.1 n-.:.r.1orous cri ticis::1s listed. Presid0:1t is well :-.~e1.nin6 but o:-i.sy goin.:; , 0:1tircly too free i!1 .T-i:1tir.G of crvdi t .:i.nd •,1'hil0 .:. l."'..rse nu:1ber of frozen '"l,nd q-!estionn.ble -:tssots n.rc an i::heri t'.Ulce froc:1 forner n:u "-G'-'- ent it is evident t':l.".t President docs :.1ot hwe ".bili t;:,· or inclin"1tio:1 to collect or cle::i.n up these old n'.ltters. President is believed to h~ve h1.d little b--,~~::inf experience outside of t:1is b'\:1.k. Cashier is 1.s C".s:- :;oin,;; as President ·:ti t~1 cvon less ini tin.tive. It is, l10•,1cver, perhnps trae th~t Prcsid.e::1.t ;7ould :1ot "?~r ·it 1.ss-uc":'T_f)tion of a.ny .'.l.u.thori t? by ::i.:-iy ot!1or er:rploy0e .'.'ls he :r,;r})O:U-s :-i.nxious to l:."¼"1,'1,;;e entire b:1.,,7.,k even includin...; ope:iin:; of 3,ll nail j;>erso:1:"..lJ.:,. '.'il1on s%,;;cstions m::re □"de or cri ticis:-.1s cliroctod 'lt scvonJ. l1e1.ds of different dep"rtr.1ents t:10:r co .• e.ited to e:~.'"l!'u:,er in effect tlnt Proside~1t ·.ns eq'..1."..ll:' to bl~r1C 1,s he would :iot ·,:,cr-,i t ony lee,,~, w:1en they •.1oro d.is0osed to brin~ 1.bo::.t correction of so:.1e of c:rit::.ciocd r.1".tt0rs. 7/ri tor e:;:,.1:.u:1ed b--,..:12,~ in 1923 eu1d .,_ coq_)'\riso:.1 Yri th bis :;_:,rovios rc.,ort discloses mmerou.s .'.lsscts criticised .'.\t tir.10 u.."lc:1,.,_ne:;ed 3.nd [1.l)}'U'Ontly :io "tto:.1pt r:11,de si:1ce then to liqu.id1.te v'U'ious sb.tutor~r b1.d debts 'l..i.d oth0r question,'.'-ble rind froz0n -:tsscts. Ex:i ::i.ner reco~10n~s th1,t bx.1l:: be pl"l.Cecl on list for froqi.;.cnt ex~':!i:1-;.tions until co:1w. tion is s.,_tisf':.ctorJ ..,_:d t~1."..t ne:~t ex-:i.::".in1,tion be :. '.ldc 90 d-ws fro:.1 d.1.te. 11 12-28-25 Ex'1!:i.:i.ner D: 200 40 11 1835 2o21 316 90 52 4-10-26 Ex:t."'Jiner D: "Wri tor o:~"l:.u~10d b:ml:: in 1923 1. t w· ich tir.10 President rrn.s then Vicc ...Prcsident i,d ')t y1_:ich ti.:~0 he s·.1cccoded to Presidency. E"U'L-:: h::.s for r.1'.:).ny yc.'.l.rs been a one-tn~1 b:i.."12.-:, ,'1:1d co~1u.i tion so:1crn.lly w1sn.tisf ctory 6 r~.-;.ter p::i.rt of tine. At ex'.lI".in1,tion in 1923 cxa:-.1i:1er urbod r.1.'l:.11.ger.1ent n.nd directors to tx-:e pror:ipt nnd a.&:;rcssive steps to collect or scc·:re l".rgc a,,.1ou."1.t of st'.\t'J.tor;,· ba.d debts o..nd ot er over "..:e p:iper, slorr ::i.nd qt:.cstion:i.ble ::i.ssots, .,_ 1d directors rrere ",dvised th'lt unless such 1.ssets .;ere given ir.ncc:io..te :. tton tio::1 b~: ,1:,,s cert,.,in to sust,-,jn l')..rge losses. Ex""~un,.,ti0n of 12-23-25 rr:cn coz:m'\rcd ·;rith 1923 n:1ow"' EXHIBIT 12/1 Cc.-). Sur, Prof. LonJi.s Deposits Eorroivin.;s Cl~ssifiod Assets Doubtf1..·J. Loss ::J..."l.jori ty of larger .'.lnd core undosira.blo '.\ssets still in bn.nk ,-:i th r.1.'l.Il;y l".1.I'6C lo:1ns unch;1.;"16 ed except th~t t:1ey i7ere ti70 yo11rs r:iore p ..... st d.ue nnd it ·.n.s evident th.,.t I:l.3.!l'lger:.ent h'l.ve m-'lde little, if n.ny, .'.lttoopt to seci.,_re stn.tus of such f)n.:,er subsequent to 1923 or previous. This st"l.te of ::uf~irs ~as rnther forcefully brought to 'i.ttention of directors durin 6 12-28-25 ex:1.r:un~tion and n. subst,...·1tinl x.10unt of • uncollectib le assets of 1923 n.nd previous uere listed '.1S estio'\tcd lossess. So ma.."zy promises and so m~c:i. assurance was given exa.~iner at previous examin3.tion that immediate steps wo\.'..ld be taken to improve condition that the few changes and lack of improvement are most disappointi ng and discouragin g. Special eY.a..ilinations at short intervals will probably prove useless and a waste of time as but little improvement can be e:x:-pected in three to four months' time. Frequent examin~tion s will undoubtedly cre3,te unfavorable cormnent and gossip to detriment of b'Ulk. Examiner has lost what little confidence he had in 1923 in President and Cashier and it is not believed these two will work the bank out of its most unsatisfact ory condition. Without frequent examination s and the present rranagement in charge it is believed bank ?rill be permitted to drift and it appears to be a choice of two evils, each reacting unfavorably for bank and its shareholder s. Directors were advised t.1at e:x,-muner had no authority to demand or request resign~tion of any employee but t~.'.lt it was duty of exa.~iner to make recommenda tions to directors for good of b.::mk and it was suggested that if present man3gement did not sho~ a desire or inclination to work ,ti th directors that directors should e1m.._:>loy someone who would tnlce ch.'.lrge of bank's lo/llls nnd w;io would be responsible only to board and not subject to interferenc e by President or C'\shier .:1nd it ~,~ further suggested that directors compel officers to compl~: r,i th resolutions p'.1ssed th::1.t no new lonns in excess of $500 be mnde wi foout first being aut:i.orized by finnnce committee 'lild thnt directors compel officers to furnish at Bo3.rd meetinbs informD..tion they desire concerning status of 10311s a.~d other ~ssets :md t;i~t if yresent offieers are not competent in opinion of directors 3.Ild ban2.~ 1 s welf~re be improved by a ch'Ulgc of mo.nagement th'.l.t they give serious consider,...ti on to s 10. 11 4-10-26 EX3.miner D: 200 4o 3 1941 2628 268 118 19 8-13-26 Examiner F: "General condition shows very little chn.nge. Condition is most unsatisfact ory ond unless some cn'lilges 'l.re m..~de I do not expect to see ".llY mc.teri.'.ll ch311ge for some time to come. President :is ,1ell ~s di rec tors are of opinion th""..t t!1ey should not be n.sked to put up rr.oney to elimin~te o.ny losses ~-id doubtful p'.:l.per, contending th::l.t b.'.l?lk c,n earn its v1=i.y out in time. Ex: .u.ner does not ::i.gree ~nd informed them that they TTould be given until ne:;:t ex:unin.'.ltion to provide for losses cstim'lted. Exn.roiner informed dircc tors t:1 .... t they rmuld be given until next e;m.minntion to mru;:o some provision to provide for losses o.nd other i terns tot""..ling $144,819.39 . Your examiner lurdly C}..-pccts to get enoue;l1 m:mey to elimin . . . te n.11 this pnper but thought foat by pl:1.cin ~ this pro :un before 6 them they ·.1ould e:::ert themselves to collect this pc;_per. ::stimtcd losses r:erc not ch"l.I'ged off for :.bove re son. Exoniner thought th3.t if si tu:.tio:1 w s to be brCYU ~ t to a hen.d it should be done at one time. 1zy- idc~ vm.s to plo.ce them 011 notice th~t EXHIBIT 12/1 Page C::i.p. Sur. Prof. 5 Lon.ns Deposits Borrom.ngs Cl~ssifi c d Assets Doubtftl Loss some foing would h"..ve to be done by time of next ex'll!linn.tion ,'.:i.nd perh::i,ps some concerted action could be obtained for the better. It is respectfull y rocom;nendcd t~at bank be not placed on spcciaJ. list at this time. I do not think s~ccial examination s ~-rould be of any value now. 11 3-13-26 Ezaminer F: 200 4o 7 1915 2672 172 90 59 1-23-27 Examiner F: "General cond.i tion shOivs some slight improvement a nd. officers and directors promised to continue efforts towards collecting criticised 9ayer. At t:1is season business is v0ry :poor and collections sloi'r. Real cs ta.to is extremely difficult to sell and a large amount of ba.l'lk•s loans depend on sale of cit;:;r property, farmland, and timber. With this condition it is extremely difficult for man~ement to collect a.~y paper predicated on above assets. President is interested in entirely too many civic n.ffairs n.nd other things n.nd cn.nnot dvvot c n.11 his time to ba.'lk. During ex."~m.n'l.tio~1 I took p'l.rticul~,r notice Md he spent mD.jori ty of tine oi.:t of bn..7.l,:, T'nis rns forceft.i_lly C'llled to his 'lttention ::..id his excuse is th~t no one cls8 r1ill do it. Your OX3Inincr had ::l. fr::i.nk t::i.lk with Presicle:'.1.t Md e:ic.euvored to s:19•,7 hi::i th'1t :ie ,1as doing mong. 0,1 ot~1er h-md !le S•? ends :1is person.'J.l money for benefit of b~"1.:.: in VTG;f of tr::...isportr:i. tion, etc., ,..id t h0rc is no question th".t he is doing his best to pl.'1.ce b"U'i!.c in 1- more s'ltisf1.cto:c y coadi tion. He is one of mst pl8'lsing me:i. I ho.ve h.'.1d the ple::i.surc to come in cont-1.ct ·;-ri th but is inclined to let people ii:Ji)Ose on him 3..'ld so:CTe of his finD..~Cing is suojcc t to criticism. He tries to help p0ople ·1.nd concerns -.-,ho do not even do business \!i th the b'1.nk 'llld ::i.nyo:10 cnn take up :1is time ~1henevcr t:1ey cicsire. At prose::\t b:mk h-:ts good en.rnL1,; cn.p~ci ty, :i.pi;,roxim'.\ tely from $25,000 to ~O, 000 per -:tn::·.::...':l ..,_ftcr expenses .:ui.d wit:! ..., reduction i:: interest p'1.id s':l.vin 6 s depositors it r.:ou.ld , e""...."l. some $18,000 D. yeo..r addi tio:ru profits. In p::i.st fe·:r years '\ll 0'11'nings h,.v-3 beer. used to c~1."..rge off losses. In :p:>.st six ye-,,rs bi7.k :1as cl1'1rged off over ~172,000 in losses :u1d recoveries have o.:.o,;.nted to over $25,000. This is beli cvvcl to h';..ve bcc:1 in n.ddi tion to ~sscts elimi~'.:. ~Od by ':. roiiuctio:1 L.1 c::i.pi t .')..l of $200,000. Pr'1.Ctic::illy '.'1.ll these .' 1.ssets 1,7ere inr.ori ted by prcse:1 t :-.,':UlagCi:,c::t and t:1'l.t h olds l,OOd 'Tri t:1 .' )..sscts criticised in this rc:,:ort. This rGport shor;s csti~·.- . . tcd losses ;,,i; •rt..lg3.tin6 $132,000 1.'1d on Fcbru."..r;-,· 1!..:.th I wired yo1:r office status of situ".tion. Af tcr scvern.l conferences rrcrc held directors ro'lchod conclusion th '"'. t '1.11 c1.ssessr::c:1t ;r01.ud not be proper procod,..!.rc. It •.1as finally '"l,f;rced th;1.t t , oy ,1o'JJ.d 'f>Grso;.1-:.J.ly purcl1ase t~.csc i te~~s 1:1.d it m::i.s d.efini tcly mi.dcrstood t}1"..t c:·10~' ···ore to be pi:;.rc~1 sed for cash and i..mder no circumstanc es were &iy notes to be ta.%:en b;r bank. This t:"ey agreed to do, but .1an tee: 30 days ir. ·;1:1ici1 to c o;:rplete t:leir o.1·ra..."1ge;:1en ts a:1d accordingly your office was notified. Y0'.1r \7ire of Febr.J.ary 15th ·;;as received in ·:,:1ich you stated that ir.:rp~rr.,e::t notice ,rould be vrithheld for 30 d¥S n.~d I accordin 6 ly notified mana.i;e ::e:1t foat the:,,· ·:rould be Gi ve:1 u:.1 til M.'1.rch 1.., t: L1 ·,- rhich to co~lete their pla...'1s. 1-23-27 Exar:ti.ner F: 200 ~O 1 1803 2701 179 19 132 1 '" • EXHI:BIT 12/1 Page Date Cap. Sur. Prof. Loans Deposits Borro1;ings 6 Cl'1ssified Assets Doubtful Loss g;_ 2-27 Ex,:,.~nner F: "Condition remains most unsatisfactory and maJ1a.ger.1ent o.ppe':l.rs to be making very little progress in collecting criticised assets. President continues to dominate and apparently directors cannot control him. Bank is overloaned and President continues to make loans that will prove very slow and also continues to try and finance everyone in the community. Regardless of advice he receives from examiners and experienced bankers he does not change his policies. I am afraid that if he does not change his ways he will find bank in a serious condition one of these dey-s. I had a talk with his principal correspondent banker on A11oP"\lst 16th and he told me he had talked to President n. short time ago and if he did not change they would be inclined to refuse his ba:1k further loans. The Federal Reserve Bank is very reluctant to discount his eli 6 ible pnper and are constn.ntly wo.tching him. I am not n.11 satisfied with condition or policies and feel th'.lt something must be done to correct situation. In view of this situ.3.tion it is respectfully recommended that bank be pl'.3.Ced on speci::u list and be again examined in '1DOU t 90 <i.-zys. 11 8- 2-27 Ex::.miner F: 200 4o 12 1950 2512 314 4o l 1-20-28 Ex::tminer F: "As examin::1tion wn.s 1mde on bn.sis of going bnnk, it hn.s baen difficult to write report, and ex.'.lilliner has attempted to cl~ssify n.ssets as they a.re classified under the receivership. It is to be noted that 'slow assets' has been elimin'1ted. Examination was comnenced on n.fternoon of 1-20-28 IJ.l1d was completed 2-11-28. Precarious condition was thoroughly discussed with directors latter part of ~ebruary at which Chief Examiner was present and weys nnd me~s to eliminate estinuted losses 3.,.~d frozen ~ssets was topic of conversation. It was concensus of opinion that efforts should be ma.de to organize a nen b~ to assume deposit li'1bilities ~nd truce over a like ru.nount of assets. With this thought in mind e:x..'1Jlliner 10ft b~nk but kept in touch with directors as to progress :rrndo in this direction. President tendered his resignation the l~tter pn.rt of Jo.nu.o.ry n.nd this wo.s published inn. loc~l newspaper in such a m~nncr L~at it left 1 great do~l of inference vri th result thn.t a run wn.s started vr~iich re::sched such proportions thn.t e:x,.·:i..rniner wo.s requested to return nnd advise with directors. After a thorough o.nG.lysis it v1.'1s deemed o.dvisable to close the bank n.s run hn.d re'1ched such proportions that it ~o.s useless to keep open. 1-20-28 Ex:3..miner F: 200 4o 12 1745 2473 152 810 333 ( 000 omitted) E::i.rnings: ~ Net Income (Gross Earnings less Expenses) Recoveries Losses Charged Off Assessments before Suspension Bad Assets Purclmsed by Stockholders Dividends 1924 19_gs_ 1926 1m. Total 34 29 17 36 30 146 0 25 0 0 8 1 19 0 0 10 35 0 0 0 6 44 0 0 0 1 33 18 156 0 68 8 0 G 68 0 .., • EXHIBIT 12/2 Ban!c Organized: Bank Suspended: ?o~ulation of Town: 1900 1924 1238 2957 2455 (1910 census) (1920 census) (1930 census) Principal Crops or Industry Served~ Bank: Wheat~ potatoes, livestock, alfalfa, beets, seed-peas. l.!!!Pprtant Excerpts from Reports 9f Examination: Date (000 omitted) 10-13-20 Examiner A: Cap. Sur. Prof. 50 50 2 Loans De-r:>osi t Borrowings 501 581 45 Classified Assets Doub tfu.l Loss 0 0 7-14-21 Examiner B: "General condition is rather satisfactory on t:he whole, eapecially in the light of two or three poor cro~ seasons experienced in ~~is community. Bank 1 s condition is extended but fact tl:.at proportion of rediscoun ts is so large speaks well for character of paper. Paper is of good general CD.'.U'acter except that some wheat growers on dry land have beco~ne involved. With ·;ooc1. crop returns this year material liquid'ltion 1 ~ be expected. Management is c3,::.•eful ruid efficient and gives close attention to paper. No one man dominates. 3.'.mk is sitU'lted in good agricultural comrruni ty, :p;:i,rtly irrigo..ted n..".ld partly non-irri 6::i.ted bnds. Crop prospects on irrigated land -ire fine nnd fair on dry l'Ulds. 11 7-14-21 EY..aminer E: 50 50 6R 354 403 47 3 0 1-20-22 Examiner C: "In general, a well-m'l.Ilnr;ed and well-run ins ti tu. tion. Personnel appears very capable and considering gener~l conditions here, t~ey have done very well to keep bank in its present shape. General conditions in t ·1is dry farm country nave been very unsatisfactory on .3 ,ccount of ";?OOr crops o.nd ·1·o"irprices 3.!ld unless conditions improve bo.nks here will be very ha.rd pressed this co::'ling year. 11 1-20-22 Exruniner C: 50 50 2 671 451 277 17 0 7- 5-22 Ex.::iminer D: "Mano.gement h;:i,s been in the past too lenient in accepting paper for accommod'ltion of other b~ks. Most of the p~per is slow 'IDd must of necessity be eliminated slowly. This is an element of danger nnd considera.ble losses nny result before paper is eliminated entirely. (They take lo-ins to accommod.3.te other banks, $82,000). B~1u: is in a very extended conditio~ out crop conditions are very favorable ~s n. whole. If .'J.dverse conditions prev-:-..11 J:>roblems for bank will be difficult. 11 7- 5-22 Examiner D: 50 50 .:IB. 663 394 371 11 7 EXHIBIT 12-2 Page 2 Cap. Sur. Prof. Loans Deuosits Borrowings Cl~ssfied Assets Doubtful Loss 2-10-23 Ex'IDliner E: "This b::ink is in "- ro.thcr d3,ngerous condition :i.t present due to l'lrge amount of borrowed money o.nd cxcessi ve 11IDOun t of slow :md doubtful p'lper. Surplus is 3.lso ir.ip'lircd by estim'J.ted losses. .Another contributing fo,ctor 17hich rrnkes condition dn.ngerous is lack of confidence by public on '7.Ccount of lo.rge number of banks w~ich have closed. As yet t~us feeling h'\s not been noticeable here but matter should not be overlooked. Some of present stockholders probably could meet a 100% o.ssessment but this applies only to a minor portion. The larger shareholders ~re :ure~dy heavily involved. If permission to increase capito.l $50,000 is gr'U'l.ted it will m~terioJ.ly better b'1IJ.k 1 s condition. Directors desire to sell new stock at $150. Premium of $25,000 to be used to chorge off losses o.nd doubtful p:1per. Exn.miner recommends ex::i.mination in 9G clays. 11 2-10-23 EXD.miner E: 50 50 2R 617 377 325 12 9 5- 8-23 Examiner E: ''Bank is still in dangerous condition due to large amount of borrowed r;io;iey Dnd excessive ar.1ount of slow and doubtful assets. At last exanination directors desired to increase capital to $100,000 and believed they could sel:l stocl: at $150.nnd were to use amount derived from premium to charge off estir:ia.ted losses and doubtful paper as far as possible. At this exn.nin.'J.tion capital had not been increased nor could stock be sold at 150 or even p'.ll' at this tine. Examiner decided it best to clean house. Estir.l.'.lted losses aggregating $37,000 were ordered ch'.lrged off and entries 1:i..1.de during CX'.3.'.:iination. This :Practically wipes out surplus and as a result ~nny excess loans a.re shorm. Should crops prove poor t~ds ye'.11' or fil"l.rket conditions adverse b:mk ·:,ill undoubtedly suffer heavy losses. Confidence of people of cor.t..T1U.i.iity is none too 6 ood. E:i.ch tine ex~ner visits ba,,'1.k there are sone wi thdrarnls. Prcsiden t be.1.rs confidence of people but is also president of ~noth8r b'l..nk 'U1.d is obliged to s,end most of his time there. C'lshier's person~lity does not inspire confide~ce of public in b:mk. Stepo..: 'lre to be t/lken to 3,p·,)oint one of the r.iost influenti"..l stockholders !ls vice-president who is conserv'\tive, a good collector '.lnd ·:,ill devote nost of his time to b3Ilk. It r:i.3.Y be of considerable benefit. Exn.r.uncr does not recoor.1end t:i!.:ing b!lll..1< off speci::Q list (for frequent ex'"l.."':'lination). Sb.ould ::!..!lY unusu.'\l conditions arise ba.nk would hwe difficulty in r.1eeting cler.nnds. 11 5- 8-23 Ex::u:uner E: 50 50 6Red 614 298 360 42 37 11-12-23 ~'.ll.1iner E: "Some ir.1prover:ient ros been .~nde since 1[1.st e.A.'.lr.una,tion. Lo.'.l!ls have been reduced $63,000 borrowed money $33,000 and deposits increased $la:J,OOO. Princip'.ll improvenent is in restor~tion of confidence of conr.nnity in bank ~d it is believed th'.1t danger point h.'.ls p~ssed. A ver-1 bood crop of wheat is being ha.rvested 3Ild mile prices nrc only fa.ir, consider.1.ble liquid.n.tion fron this source will be h,'1d. People n.re i;;otting in some r.10ney [Uld ns ::i, result n. nuch better feclin,;; :..11 :1,r')u.nd prev:1ils. Officers n.nd directors estinate th.-:i.t • EXHIBIT 12/ 2 Cap . Sur. Prof. Cl~ssified Assuts Doubtful Loss ~01<1.s D3nosits Eorro~in 6 s b'."I.Ilk lill be o.ble to cut dovm its bills pn,,v::ible ..-Ii th Feder~ Reserve R'1.:1k o..."lother $100,000 °b'J J:irm-iry .1st. Exnniner believes trot n. further reduction of $5(),000 to $75,000 in bills p::i.yn.ble rrill be :::i.bout the best they cn..."'1 do. This ·,'Till still len.ve bCUL:: in n. badly extended condition. It is believed t:1::i.t prescat conditio!1s h'J.ve taught officers o. lesson a.."ld credit n.dv.:mces hcre"..l'tcr \7ill be C'U'efully considered before being n'lde. C"..shicr is not o. very .;ood b~ker .::Llld o. ch.n.nG;e in 1 ::1.'.lil:1.ger:.1ent ';rould be of gro'.lt benefit. Fr0sidont is believvd c::i.p'l. Jlc "..i1d ~dous to 6 et 'lff~irs in good condition ~6 ~in, but is obliged to spend nearly ~11 his tiuu '1.t ::mother bo..n:-: rrhich requires his close o.ttention. Idea. of i:1crc-..sin6 c-..pi t'.:'..l h~s been ",ba..i.doned o..s it is believed stock could 1ot be sold. E:~'1.!':'.incr respvc tfully recor:r::ends t ;,.t b~-:: bo kept under survcilln.ncc by reports ~nd correspondence rather t.'Ul by frequent visits by ex..,r.incr. Too libern.l gr.'.mtin,s of credit in pa.st is cause of bo.~•s present condition." 2 16 327 379 551 6:R.Ed 13 11-12-23 ~:,,__ .iner E: 50 E;1.rnin 6 s: 191:1 ct Incono (Jross E"rnings 13 less E;..--penses) 0 Recoveries 3 Losses Ch3rbud Off 0 Asscssnents before Suspension ::Bn.d Assets Purcho..sed by Stocltlloldors 0 16 Dividends 1920 ~ 14 l 0 3 8 3 0 0 0 0 10 C 1922 16 1 12 0 0 1 19Ki Tot'll 9 2 42 0 0 0 57 7 8 0 0 27 Federal Reserve Cocnittee on Branch, Group and Chain Ba14~in 6 001:i.v:ients Re,;arding the Preparation of Forn ~:arch 20, 1931. .E Form F shoi.::.ld be prepared for each of the twenty s 1.:.spended banks from the beginnin6 of 1920 till the tir:ie of suspension. Two examination reJ?Orts eacl1 year s:10,J.ld be analyzed and a separate cop:,· of Forr.1 F prepared fror:1 each report. In case there :.1ave been r:iore than t\-rn examination re-l)orts of arr:; bank in a given year, select those nearest April 1st and October 1st of that ;:rear. A blank form of t:.1e exa·.:iination re 1ort is attached with t1arked references to the i tens to be t:)lcen off on For:n F. These are references to the current edition of the exa:r.iination forn., of course, and certain adjustments will have to be r.ade in ta:.cing off the data for earlier years. 1. In connection with slow loans, doubtful paper, etc., the earlier exar..ination re.)orts had a colu..':l!l 11 0ther undesirable pa::,er 11 for which no provision is 1:1ade on the analysis forn. This should be classed as 11 slow 11 with a footnote indicatini; the a;.1ount. 2. S01:1e of the itens, as for exa~le, "Contracts for deed" ( item 23) req1.,1.ire considerable scrutiny to see r1het:1er anyt~1ing along this line is shown a~--w:1ere in the exa.:r.ination re:'.)ort. 3. IteDs 20-22, pertaining to real estate loans, require r:JUch care in co~piling because t~e fi 6ures are not available in the desired fo~n in the reJorts, and certain combinations are necessary. 4. In the earlier :rnars care ;;us t be exercised to see that rediscounts are included in loans a11d discounts. Furthernore, in obtaining total borrowings, care r'.11.lst be taken to see that rediscounts are added to bills payable, for redisr.ounts are shown on the resource side as a deduction fron gross loans. 5. After transcribin 6 the fi 6ures froo a given examination re?ort, it should be co;;r_pa.red with the previous report to see that it is on a conparable basis. After compiline:; the dc'l.tD- for each b3n:c for the 11eriod fror.1 198) till suspension, the fii:,-ures for the twenty bo.nlcs should be sun:iarized, using the sa:.10 forn for sur:u:ia.ry re·~)orts. Since two exor.iinci.tion rei1orts a.re analyzed for each year two sur.1riaries will be made for each year, one for the first exru:iinn.tion re·?Orts for the year 3.nd one for the second re::_:>orts of t~e year. The assunption is that these ~ill be fairly representative of the condition of the banks during the first half and second half of the year respectively. Please show the number of banks entering the sw:ir·.-:try in each case. It is 11-~derstood, of course, that t~e absolute figures shown in t~ese s·.u.1r:13.r ies will not be conparable fror,1 year to year because of r.1ergers, the drop::_)ing 0"-1.t of banks t:irough suspension. etc. This will not affect the data for our purposes. however, as we propose to compute ratios for the various iter.1s o.nd r:iake our comparisons in this forra. • • . Federal Reserve Committee on :Branch, Group and Chain Banking K Ferm F A1TALYSIS O? NL'I'IOlJAL RUliK EX.1MI:V5ION REPORT Item Date of Report Place Name of bank ~'here found (pare) .AJOoun t (L.=Liab ilities on Page l)(In thousands (R.~Resou rces on Page 1) and tenths) $_ _ _ _ _ l. l. Capital ......... ......... ......... ......... . 2. Surplus •.....•.. ...•..... ......... ......... . 3•• UndiviQed profits •........ ......... ......... 4 Reserve for depreciat ion anci loss8s ......... . 1 - L,l 1 - L,2 l - L,4- - - - - - - 4. 5. 1 - L.8 1 - 1.13 _ _ _ _ _ 6. :Bankers I ci.eposits ......... ......... ........ . 6. Time de_:,osits •........ ......... ......... .... 7. U. S. de_1osi ts •........ ......... ......... ... B. Total deposits ......... ......... ..•...... ... 9a 9b 10. ll. :::orrovred money •........ .•....... ......... ... :Borrowed bones •........ .•....... ..•...... ... Total loans (includin ~ redisco1.L ~ts) •........ . Total loans and investme:: 1ts (incl. rediscoun ts) 12. :Banking house, furniture & fixtures ........ . 13. Reserve, cash, cash ite:ns, anu. c..ue fro.n banks 14. Excess (if any) of expenses over earnings •.• 15, Ln8ns to officers & directors (direct) •..... 2. _____ _ 3. 1 - L.~ 5. 1 - L. 14 7. l - L.8-14 8, ____ __ 9a 1 - L. 17-20 _ _ _ _ _ _9b 1 - L,lo 1 - R. l 1 - R. l & 5-11 1 - R, 12 1 - R. 11+-20 1-Part of R. _ _ _ _ _ 10 _ _ _ _ _ _11. 12. -_ -_ -_ -_ -l~. __ 24 - - - - -14. _ _ _ _ _ 15. 6 ug,ran teed by off. & dir.,. _ _ _ _ _ _16. 17. Loans t~ interests of off. & dir. (direct) ... 2 2 2 18. Par value ('If stock owned by ciirec tors •...... 2 - - - - - -18'. 16. Loans endorsed or 19. Past due loans ,;,. _ _ _ _ _ _17. ____ __19. & i3 •..•..... ........• ...... 20. First mo1·tgage (Loans vi thout prior liens, except ,·here called II contrac t 11 ) • • • • • • • • • • • • 21. Junior mortgages (All loar,s with prior liens) 22. Frier liens (to junior morteatP.s ) .......... • 23. Con tra.c ts for deed (:nore often in reca9. of invest~en ts on Page 7) ......... ......... . . ---- -- 21. ---- --22. 5 ____ __ 23. Liquid Investmen ts 24. U.S. bo. J.s other than those securing circ1..ua tiun 1 - R,6 & Other investmen ts not in default (:nar~:et valutl 25. Foreign • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 26. Railroad • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . 7 27. Public utility • • . . . • . . . . . . . . . . . . . • . . . . . . . . . • 7 28. Indus tri~l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 29. f.unic iJal bonds , . . . . . . . . . . . • . . . . . . . . . . . . . . . . 7 30. i!.iscella.n eous bends, tax certifica tes, warrar:ts, and other liquid investmen ts, excludi~0 for3closures,c lai~s,jud@ }Ilents an~ efaulte~ oonds 7 Other Real Estate , 31-. Book value •..••... ......... ......... ........ _ _ _ _ _ _20. 5 5 5 7 ____ __25 26. - - .- - -27. ____ - - - - - -2£< - - - - - -29. ----- --- o. g _ _ _ _ _..-1 32. Prial"" liens ......... ......... ......... ..... . 33, Esti ted value . . . . . . . . . . . . . . . . . . . . . . . . . .. . 8 ------.....;3,2. _____ _ 3 • Slow loans •. , ...•....• ......... ......... .... ll 11 ~5•. 8 ____ _31+. _ _ _ _ _35, _____ __..,.36. Slo bondfl, uri ti , etc. • ...•...... ...•• Slow 11 0t1.,.,r' 1 r al estate ......... ......... .. ll 3 7. Doubtful assets an losses - Loans ......... ' 38. Doub ful assets a.."1d losses - Bonds & secur ••. 39. Doubtful assets ana. losses - .All other ...... 11 11 11 _____ __,.~s. _ _ _ _ _ 39. Vcl.ue of assets not shown on books .•••..... . , 11 ---- --4o. 36 o. 41, Large state, county • municipal de1osits subject to check.. .......... ..... . .......• Yellow Page A - _ _ _ _ _ __. I· ---- --41. FEDERAL IlESER"\7E B . . \.NK March 20, 1931 Mr. J. H. Riddle, Secretary, Committee on Branoh, Group and Chain Banking, o/o Federal Rese"e Board, Washington, D. C. Dear Mr. Riddle: e are forwarding you six oopies ot the •survey of Banking Competition Ottered by Non-banking Institutions in Ohio• requested in your ~ e r ot February 26. It will be appreciated if you will return your copy of the nusori tori ina you. There have been some oorreotions made in the bound copies as you no doubt realize that the manuscript was hastily prepared. Member, o on B,anoh, Group and Chain Banking C ti 'Orm ·o. 131 Off.ice Correspon ... To ch 19, 1931 r. ••o 2-8405 or z:.o.1 31 FEDERAL RESERVE Offi ce Correspon To r. $'!lead From r. BOARD Date M ch 16, 1931 ••• You as s b n ich th d rel"' oi OV ~ e branch o 11,w be I) Pr d to escP.rt in ho~ m ny bans d<>r. l re rve di 6tr ct s in a b i tU&t d and, '\.f IJ'P b of <>dPrnl r <>rv<> be.n' s ps ~incl tr t th .. r r cords, oth r Pd ra IJ'P "'r ou rat "P.r than h hei d t f iond r 0 p 0 ,.. 'Phoe ic<> 7 br c South At B brench nth C t Pr h 0 ~ 2- 8496 11 b enc cnF, a t t A tr~ct 12, i ch otner 4 b<>i D a 1npn mb<> riz on ., in l th !)i tri. ct h l ict and 2 in th 12th Distric t. 0 n t Con, 11th Dis D cos it Bank, ra ort, K ntucky, e no m 8 , opPrat 1 branch at Sta ng Ground ct 4. an , anvil no TPnn<>esee, b<>r in o o r ts 2 branch of hich 11 r"' in Di t ict t C8Jllden, T n ess in Di trict 8. 0 , 0 0 • In but court P.nci~ to c iv thP A t b- . e r Prri th cannot b<> co n i.ts st nc ent · ty I b s i rs rv di.scuesi e t inb r- . - 2 - Bord's rP.ply as ritten by Judge ~lliott, thP.n OllDS l oard nd published int JunP. 1918 BullP.ti . P ge 522, con e.r attach09 1922 the auestlon Ag ben the V lley 12th Dis triat took o er th 0 Gila: al o i the 12t Dist \ct but o Tr Governor at th t ti~e r 0 f rr +-ore mimtioned. Perus l of tho 0 or the of hicb s raiG d by lr. ank ad Tr t Co 0 -Ve.11 y enk and Tru t Co r tPd 3 branch c in th _lt d ~i~ speciftcallY., to th d xaminetion reports of b t t 0 ed ral Resorv en no ~ccount of ... tio tr ct ving the 'li'ed r£Ll .esP.rve Bank of Dal a disclos S n Franci co a deral Reserve Ban of Dallas and no th 0 r lley Bank n th md n hp San Francisco r port of any m moer b i t 0 ccount., in anv other dis tr ct. US"' I beli 0 vP the abo o tho omotroll r. fully ns ers th i quiry of r. o th 0 ( "'OPY2 Pr.sh of Branch of St~tP 3 k cc 1 a 11.'l -l"'ffE>r<=>nt it RFJ 1 8. P PdPr r. .,. th· nt b ~e.SP ,.,11 ot • OU ., ,, f • FED ERA L RES ERV E BAN K OF SAN fRA NCI SCO arch 18, 1951 • J. H. Riddl e, Secre tary, Committee on Branc h, Group and Chain Banking, c/o Feder al Reser ve Board , ashin gton, D.C. Dear ir. Ridd l: I as glad to recei ve your lette r of March givin g a review of the tatus of the ork no in proc es. lOt~, accou nt of the many thing s hich have been happe ning since On my retur n from ashin gton, it is only no that I have the oppor tunit y of talcin g up the ork of the Committees. It is som hat urpri aing to find that you have not receiv ed respo nses from Governors Geery, cDougal, Marti n and Talle y, relat ive to tho propo sed study of bank failu res forarded to them under date of Janua ry 24th. I fe r d at the that you had given them too much to dige tat one sittin g, time hich no seems to be the case. In regar d to the cau for bank failu res, I am convi nced that any defin ite statem ent made by our Co ttee 11 be regar ded mor ly aa preju dice. A ut the bet e can hope to do is to set forth a sere of~ udie hich will enabl one desir ing to pproa ch the subje ct serio usly to determ inee e ch hims 1£ what have been the major cause n of su pensi on. At for that, o inion s ·11 diff r. I hav been turnin g over in my rdnd ht dep ble inform ation e could hop to obt ·n in seeki ng speci fic ndrespo ns s to the qu tions to b propound d to tho mang ing ficer s of tho e bank hich have escap ed the fate of their ofpetit or. On hose bank has escap ed u pensi on ould not comconfess that his polic ies had be n almos t ident ical th thos of hi comp etitor , but that he had been mor fortu nat in h ving a group of finan cially stron g stock holde r ho er lling sacri fice their man to vert a suspe nsion . Nor ould any to banke r confe s that he sacri fice safet y for profi t in hi loan and inves tment polic ies. N verth ele s, the los bing au taine d today are large ly fro inves tment s in high- yi ld bonds . r. J. H. Riddle - - 2 I would suggest that, in the study of 11 Economic factors und changes inc. collJilUllity, 11 you include ·th road improvements, other public expenditures such as school, court houses, etc. It is obvious that some communities have been fr too ambitious in these outlays to be arronted. Public improvement in many rural • ections have so added to the tax r te as to absor an exce~~ive amount of the farm income. I ould appr ciate your fo rding to me copies of corre~pondence hen the responses have been receiv d fro th four Gov rnors above mentioned. I I am no eng ged in the revision of the materials r lativo to Branch Banking end bank failures referred to in the last paragraph of your letter of March 10th, so that they may be plac din your hands at an early date. Your. very truly, cc. to Dr. Mr. Mr. ~r. Golden 0iser Sme d Rounds Fleming . 1 , 1931. r i • Ri dl iou 11 hioh h d t 1 o 1 11 to 1th OU b n o loo to t o our r, I J· \ - • • ) / FEDER AL RESER VE BANK OF NEWY ORK Mar.ch 11, 1951 Mr. J. H. Riddle, Secreta ry Committee on Branch, Group and Chain Banking Federal Reserve Board Washineton, D. C. Dear Mr. Riddle: Your letter of the 6th is received advising you have so far heard frora three of the four governo rs addresse d on January 24 asking their assistan ce in the prepara tion of a program for studying the causes of bank failures . I ~ve not given very much thought to the ques- tion, particu larly in relation to the letter you addresse d tot four governo rs. Our experien ce in this distric t with bank failures has fortuna tely been quite limited , but it must be admitted we have been adding to it lately, and this has natural ly resulted in our giving the whole problem conside rably more thought during the past winter than previou sly. I recently dictated a memorandum on the general subject of bank failures , their causes, etc., and I think perhaps the best would be to send you a copy of that memorandum. ey for me to be of help It was dictated about a month ago and since then other work has prevente d doing more with it, but my recollec tion is that there was a paragrap h or tro that I desired to change. I will endeavo r to read this over again within the next day or two, after hich I will send you a copy for what it m~ be rth in this connect ion. Very truly yours, ~1 LAL L. R. Rounds Deputy Governor II rnor r. Ir Cler ch 10, 1931. 2 ri 1 on con oli tion rch 9, 1931. r i 1 ort iv fro t tion ? t it th n nro ay t t d old in en any s C ir i t er n 6 0 ct or If t on s t ? t re ha to lid ' lo tt 10n uidity of 0 or r In ot lio t in th tin I onn re. tion it t 0 nt o. n t 11 in p. .• FEDERAL RESERVE BANK / / OF CLEVELAND March 9, 1951. Mr. J. H. Riddle, Secretary, Committee on Branch, Group and Chain Banking, Federal Reserve Board, ~ashington, D. C. Dear Mr. Riddle: I have your letter of March 6th with reference to the letter which you wrote to Governors of four Federal reserve banks on January 24, 1951. I am not surpirsed that you did not received very much in the way of helpful suggestions. At the time of the receipt of your letter of January 24th we discussed it at some length in this office. In the tabulation which you enclosed with this letter you showed excerpts from the report of examiners. Just this morning I was looking over an analysis of examinations in this District and was surprised to note in one particular case of the great increase in doubtful and loss paper within a period of five months. For example: the set up beginning on page 4 of Mr. Clerk's proposal, under examiner "F" shows doubtful $90,000 and losses at C59,000 on August 15, 1926. The same examiner on January 8, 1927 showed ~19,000 doubtful and $152,000 losses and on August 2, 1927 doubtful $40,000 with $1,000 losses. This report was not so bad up to this time but five months later the same examiner shows doubtful $810,000 and losses $555,000. This shows that either the examiner was incompetent at the time he made his examination of August 1926 and August 1927, or he was trying to clear his skirts against a possible failure of this bank by setting up doubtful figures of $810,000 and ~555,000 in January 1928. I do not see how it is possible for a bank in five months' time to get into the condition that this particular bank was at the time it failed, if the examiner was doing his duty prior to that time. Any scheme that is set up by you, wherein the human element appears as a foot rule in arriving at causes of failures and where the personal equation enters into it in any way, cannot possibly succeed. I am convinced there are three basic reasons for failures of banks - First, Economic reasons beyond the control of the banker; Second, Defalcation (either within the bank or in collusion with borrowers); Third, Incompetent management. w. OF CLEVE:LAND 2. Mr. J. H. Riddle. March 9, 1951. Economic reasons may cover only a local condition. By this I mean that banks located within agricultural, manufacturing or mining territory may be located in such towns which are what might be termed, slowly bleeding to death. I have in mind western Pennsylvania which at one time was a wonderful coal mine and coking region. Banks in that oarticular locality were in excellent condition and apparently well ~anaged as earnings reflected such management. Through poor conditions in the coal business other business in that particular territory has been drying up gradually and the ban.ks were endeavoring to maintain their old earning rate against deposits which were not equal to and which would not permit of loans comparable to the days V1hen the coal business was in a flourishing condition. This, of course, is reflected some~hat in the management. The management should have seen that the economic conditions in that particular territory were getting into such a state that there was not business enough in that particular territory to maintain the ampunt of loans and earnings which the bank had been maintaining for years previous. In the case of state banks, and I suppose somewhat in the case of national banks, here the officers of such institutions found that economic conditions in that particular locality would not permit of carrying along on the same plane, a.sin the old days, they have talked to the supervising authorities and have been told to go back home and run their business as no doubt the bank would be able to weather through. In the case of western Pennsylvania the economic condition in the coal territory has not improved in the last ten years. Result has been, banks which were at onetime high class and good earning institutions, have closed. Defalcations, of course, come as a surprise to the institution where such defalcation occurs, except where defalcations are caused through collusion betv,een the bank and the borrower. This, of course, is beyond anybody's control. We have discussed this matter again today at some length and still believe that when we get beyond facts and get into theories we are treading on dangerous ground. I do not believe that you have, up to this time, gotten away from facts and I am sure that any report or program which is set up, based upon the data of January 24th ( · ich is based upon theory and not facts) will be of no value, in other ords; when you take the bank examiner's opinion without consideration as to his ability or temperament, we are treading on dangerous ground. I am sorry that I am unable to give you any suggestions and this answer is only given to you after consulting with two of our men FEDERA L RESER"V'E B;:\.Nli. OF CLh""''\"EL AND Mr. J. H. Riddle. who are very much intereste d in F.m 1ty Governor, March 9, 1951. • roh 6, ut o 931. rnor. :ooh, - Oivi- Bank Operations File ln 1 ra r ~ - --- • • ( - - - - - - ... - ( - • ( - - - • • • FIi I,.. I/ , , ·- •• t r I'l' 12/1: • • lz!2: lB l2/3: IB 12/4: • 12/5: l m 12/6: lB 12/7• tr io 12/8: 1r 1o rf 12/9: 1o • ' • ' C ifo 1 • ' • ' I B • Or o. • R e f e r r e d by M R. C L E R K to Mr.._.§:=-~ -=AD=- ------ Please destroy 12/2 sent you in my 1 tter of Jan ry 1, 1931, and substit te th attached . R ef u r I} d by M R. C L E R K to ?.Ir ···-···..._.Ell)_________________________________ Please estroy Page 1 of 12/1 sent you ·n my letter o.. Ja1uary 10, 1931, anJ substiu: it the attached . - te 10-22-23 Exlllllilc.er D: 200 • -• ot. 14 69 1971 1438 1721 2 l2 52 • cipal tory u ... 58 103 6-22 2 1 40 16 1283 1555 30 150 18 - - Page3 ie d debts pl o rt 316 52 t 1 ' 18 28,..25 • • • r • erio a co 268 o a TflrY littl 13-2 llll.88.ti oh 19 118 Co • iti • I ~ as well should not t 0 t t emm.1.nat 1 Ti ion to prond tar loa s 4ly •xpeota to get enough ot r lt y t el plao1D8 t 1 pro b tor ,b6Cwu...lia.1.- to ino.t ling all 0 , 9•39• -- la • • 59 90 gly :200 40 "Co ditio r 68 l l ill 179 3 st 1 0 d a o er lo disc unt hia 11g1bl per ar co ohi him. I o 11 1sf1e -· . .- ~ - .§B!:• olici n W - 20 .r.,A,Q.MUUQI; ine 40 classit el 1; 5 Doubtful oorrec ctlbl. e ets A - Loa■ t icn. • lac 1n abo 1950 l2 1-20 28 dittioult Page W Classit "fE..!... Lo ~ el t.ba_t __ uation it is res ag in a A 2512 314 de 1 40 of going er t olas that ' 1 • -20-28 ~""-4,L-t 2-n-28. estime. li opinio •t l oh :pa s ~s 1n eu t ch pr • tter tho r ao d oh propor t it op 200 40 l2 (000 1745 152 2473 itt d) 10 333 _!9_gz 30 46 •• r ~ 34 ~ 29 !fil. l~g6 17 tal 0 l 10 6 1 18 25 1~ 35 44 0 0 0 33 68 156 0 0 0 8 0 0 0 0 68 8 s Pertly irri ted. 2 5- 8- 23 , iner : 11- 12- 23 miner H: "Some improvement have been reduced 63 , 000 borrowed mone i cip 1 irn rove ont is in rester tio be · ed that dan er pint pa sed • . an le pric •t - l.6 3'Z1 2 tpga: ~ 18 3 0 0 D1Tidenb 16 1.4, 0 l 3 3 0 0 10 0 0 1 1 12 0 0 o1iel ' 57 0 0 0 0 0 ~ 2 -42 12/3 Dry :farming. - (000 • 5 -5 -3 • t:. 0 •• 2-13-18 2-13-18 irly 11g 1 ' •• 7 253 235 7-1 18 7-1 18 11 l 246 t : 1 3-19-20 a 15 8- 5--20 8- 5--20 •• • 1v • 1 f tr. '3 311 1t1on. 3 0 tio 355 3-19-20 0 37 24! 2 1 3 0 35 12 rro 245 1 1o • 2 mtlmJI'l' 12/3 3 ) ) 3 2 4 1 34 7 15 1229 (1910 lll2 ( 1920 9 • l : 10 -• 0 ) -Tiana) (1930 ) t. 20 12 9 20 10 ll34 10 10 1 flr3 22 352 2 6s ' 2 ) • • o 0 y or rg , is rt tie. it 3 ,,. IBX 12/4 - . ( ......,. uane __ • Prete 144 52 134 ) ~ 20 1 11 0 0 1921 23 1922 ~ 6 2 7 0 l 1 71 50 21 12 0 0 0 187 ~ 0 0 1 36 13 122 50 IB 12/ 1913 -- -. Pop 1923 297 ( 1910 2372 (1920 2250 (1930 -or • s, Irrigated farming. _( 7- 1-19 . 1- 9-20 •• ~-20 . - • Prot • • 25 35 25 25 50 6o 1 3 351 494 542 '715 525 3 2 ) 17 l 13 20 7 1 4 0 3 2 3 59 19 34 0 0 ,. -ot :i: a: dEZ,_t ' - t ( ley, - 10.30..19 .• 2- 3-20 .• 12 12- 1-20 7 12 r .• 40 12 •• ot ~- - · ...!2!.• 40 u 1 6-2 -20 tarm.in8. 433 2R 30 445 4D6 C U1 poubttul 379 268 144 226 248 224 14,8 l 0 0 0 21 ) • .- • 3 ) -• p t. ta • 5 IBIT 12/ ( 261 : ( 133 4B 122 1 1920 > 2 l l 10 1 3 3 0 0 0 8 0 18 5 0 • 12/7 Irr le; • 11-2 17 1 .• 2- 3 515 375 511 s 7 11- 7- 3 .• l 1 1 27 3 1 0 0 7 1 73 332 1 133 ) C • • 3 ) 27 3 13 5 15 Pgp 2 ( 1910 ~t~::::.·.::n.:z) 1 22 (1920 1003 (1930 •• _( 1-16 4-17-17 ~- - · -2!.• .• 35 7 A: 35 • -27-18 C: 3 35 11-14-19 Di 35 ' 5 ---- 3 15 l 1 l 10 36 5 231 33 250 13 376 365 l 20 11 55 23 2 2 25 1 132 223 359 1 ) ) d) C •• t • 3 ) -• t. 03 u7 t ( ) 0 • -• ~ ) - 2R 0 0 3 d r-- 23 13 l 0 0 0 ~ 0 1~ 37 13 4 EXHIBIT 12/9 iae : ded: • h 12-14-20 1ng. .• d) 5-20-20 P, .• 25 25 • 25 i d 0 - • Prot • 30 3 857 1342 0 9 29 1139 100 931 3 0 l 51 21 ,II 2 d) 0 • -- • Prof. p ) • 3 -• -t. 1 • 47 32 I 1217 31 • ) - t. . . 4 d) ·-· p EXH1tBIT 12/9 t • ) 6 -• t. -- 91 .• ( ) ~ ~ 13 16 27 1 14 23 0 0 1922 0 0 810Jl 1 Stoa ol a 0 2 AW. 7 1 12 1926 1 36 0 0 l 59 9t0 23 0 1 • • • 2 , 1 .. • r. r r. o r l o 0 0 b t 0 0 ln • ... 5, 1 b :n. r • r ·r. C 1. 1 1 1 1 • C • • f FEDER.AL ltE HE RYE ll..:,....~H. February 24, 1931 • J. H. Riddle, Sooretary , Committee on Branoh, Group and Cha.in Banking, c/o Federal Reserve Board, 1 shington, D. C. D a.r • Riddle: You have probably hnd an opportun ·ty of looking over the survey on banking competiti on which s forwarded to you last week. /. our idea s to pl ce the results of the survey in your hands as soon as possible, and we consequen tly ere unable to present it in other than manuscrip t form. Please let us know whether the manuscrip t which you have is sufficien t. If more copies are desired, it will prob bly be a matter of ten days or two weeks before they could be prepared. Very truly/you rs, C.:K / C • FEDER AL RESER VE BANK OF NEwY ORK Februruy 21, 19:31 Mr. J. H. Riddle, Secretar y Committee on Branch, Group and Chain Banking Federal Reserve Board a.shingto n, D. C. Dear r. Riddle: Enclose d herewith I am sending you all of the materia l submitte d by the Marine Midland Group in response to our question naire on group banking . plete ·ob on the They seem to have done a very com- hole. Very truly yours, Enc. LAL lk ~ Deputy Governor FEDERAL PillSERVE BAN:ir. OF CLEVELAND February 20, 1951. Mr. J. H. Riddle, Secretary, Committee on Branch, Group and Chain Banking, Federal Reserve Board, Washington, D. c. Dear Mr. Riddle: I am forwarding to you, under separate cover, a binder covering memoranda relative to "A SURVEY OF BANKING COMPETITION OFFERED BY NON-BANKING INSTITUTIONS IN OHIO. 11 While the contents of this binder does not show considerable work I want to assure you that the data compiled has been a result of friendly help and cooperation on the part of people in the State Banking Department and of certain member banks in the district. Mr. Carter and Mr. Flinkers, of this bank, have been extremely useful in procuring matter entering into this data. I am sure the survey will show that the matter of competition in this district is primarily confined to competition of organizations operating under the Building and Loan Act of the State of Ohio. 7 Yours F.m - ommittee on Branch, and Chain Banking. O, l lo . I ly o • 1 loo 1. S nt to all F. 1. (i • to ' • 0 nt" nds) l , l r. • r r. 1. - 4I B k o erations Filo CUC GO February 16 , 1931 • • Goldenweise r , Chairman Committee on Branch , Group and Chain B nking es re Bo rd Feder ashine;ton , u. c. Dr . de r r . Goldenweise r: i.. • 1. Det iled historic 1 study of nine b nks in this district th th ve be n fore d to cl se. These b Ks rare sale d e intended to show the trend . as typical 2. Conp rison of items in statements of vove mentioned nine b ks, s om.ng ch nges in their reports during th y r of this study . 3. Historical study of six successful b nks selected s ty ic 1 illustration s fort a purpose of this n ysis . ed It is my underst ding th t you are dividing your investig tion into t ,o parts ; that th study of th fi r st part co earning genera economic c uses such s th effect of 1 nd specul tion nd price de by your st ff ; nd th t i t i upon ch nges upon b nk er dit will be th second p rt, consisting largely of the histories of such banks illustr ted by transcripts of t e records of such b nks , th t you ish the ode 1 r serve b nks to furnish infor tion . ile I h vein mind th t you suggest th t the el of land sp cul tion nnd price chan es 1ill be nalyzed b your st those factors e tered into the banking difficulti s so l~rg ly th t i t n.11 be very difficult , if not imoossibl , to an lyze the oth r elements ,hich have c used b nking troubles without recognizing that most of them ere l rgely developed by the general infl tion , which r ched its pe k ho busines of the in 1920 , nd the dr stic defl tion hich follo, ed . tho troubles c nt red d eventh · strict de ends 1 rgely upon agriculture mainly in the land specul tion . ·strict The eventh Reserv Io , and p rts of four other st tes . .r1.s it with reg rd to an entire tate I will to so but the t ndencies re pr ctic 11y the same covers the ntir ia e sir to get e xtent use Io figur s , over the entir district . I/ 7) 2. • .i:... • Goldenweiser -Dr Federal Reserve Bea rd Washington, D. c. According to officie.l reports the price of land in Iowa, without improvements, increased on an average of 125% betv-een 1900 and 1910 and increased approximately 130% between 1910 and 1920 . Between 1920 and 1925 land prices in Iowa decreo.sed approximately 40 • Further decrease crone between 1925 and 19:50 but the census figures for 19 0 a.re not yet available. In 1920 within a few months the prices of all farm products, including live stock, which the farmer h d to sell, and the prices of general comn:odities experienced a very large drop. l~o such rapid increase in prices followed by a large decrease as that ·which occurred in lands and comrr:odities has ever occurred in any kind of property without subsequent disaster. The causes which lie at the root of the trouble were not It is my judgment th t the greatest cause w s the indiscriminate granting of charters to oper te b nks. any of these charters were granted prior to the period under investigation . In many cases they were granted without adequate assurance that he proposed bank would have a reaponsible Board of irectors or experienced officers or a sufficient territory in which to operate'successfullv. One result of this wo.s the org1_3.,_Y1ization in newer sections of a large number of s 11 banks, most of them with smnl 1 prospects of success. /hen business difi'iculties came those States having an excessive nu.r.:tber of banks experienced the largest number of failures. all confined to the pe 'od under ex~.ination. The reatest immedi te cnuse of bank f lures during this period was no doubt due to incompetent management. Bankers found that their ordinary st ndards of credit analysis were not applicable to the situation . pe cul a ti ve fever developed and they could not discriminate bet ·een permanent values and infl.. ted prices. It was during these years of infl tion that banks were loaded up with paper, the ultimate payment of which depended principally upon the profitable sale of f rm lands purchased a.t an exorbitant price . -any of the banks' custo:u.ers who had enjoyed substantial credit became involved in speculations of one for~ or another. large runount of paper resulting from speculative operation or created by the sale of so-c lled "Blue- ky" stock found its way into note c ses. Credit was freely granted; banks ' note cases rapidly filled ith paper that was soon rated as "frozen" and which rapidly developed through classifications of paper into 11 Slow 11 , "Doubtful II and "Loss 11 , -with n strong tendency 11 toward the Loss II column in each successive examination . In the hope of reducing his losses the banker in many c ases endeavored to protect his security by taking junior liens on real estate • ..,.e advanced interest on first mortgages nd truces, most of which was ultimately tot 1 loss. 3. -Dr • ..;. • Goldenvreiser Federal Reserve Board ,nshington, D. c. Other contributing f ctors to bank failures during the period involved, 11 of hich are traceable largely to incompetent m nagement, include the following: !t'ailure to m inta.in adequate credit files. Failure to carry second ry reserves. C pit 1 loans - al rays unliquid. Excessive loans. . Unwarranted loans to directors, officers, and their interest. Excessive r tes paid o time deposit. Unwarranted amounts invested in b nking property. I obaer:ve that you have addressed the governors of three other Federal reserve banks on the subnect under discus ion, also your request for an expression of my opinion as to the dvisability of inviting them to meet with your committee. It is our desire to co-operate with you to the fuli"est possible extent, and if you should decide that such meetir.g is necessa I shall endeavor to be present or to be represented. Ho ever, it seems to me that if such a meeting is called, it would be better to give all of the Federal reserve banks the opportunity of being represented. Very truly yours, (Signed) J.B. Governor cDougal bru ry l , l 31. r. • i h 0 • FEDERAL RESERVE BANK OF NEWYORK February 14, 1951 Mr. J. H. Riddle, Secretary Committee on Branch, Group and Chain Banking Federal Reserve Board ashington, D. C. Dear Jr. Riddle: hen Dr. Golden eiser telephoned me yesterday morning I had not yet read your lett r of Febru ry 12 advising that it seemed desirable to you in Washington to undertake another project hich you have called nba.nk supervisionn. However, on the basis of Dr. Golden eiser's explanation of what it s pro- posed to do, it seemed to me to be entirely desir ble, and I so told him. Since then I have read your letter change the vie expressed over the telephone. nd see no reason to There is no doubt whatever that the dual banking system has many defects, and I think it would be ell orth hile to get at some of the f cts so as to get a. clear picture of just what the situation is in that regard. Very truly yours, LAL j l , l t Tor • C rbon copies to: Dr. Golden eiser r. ead. 1. r. iddl b ' r r. ., 12, 1931. 1 , 19 1. I FEDERAL HESETtYE IlANH:. February 11, 1951. 'Ar. J. H. Riddle, Secretary, Committee on Branch, Group and Chain Banking, Federal Reserve Board, •ashington, D. C. Dear Mr. Riddle: I just finished having a meeting with Mr. Carter, who has been, as you know, really ma.king the survey as to banking competition. e have not gone into the question of competition in the District, but have confined the survey entirely to the competition of Building and Loan Associations and Loan Companies which come under the This is really Building and Loan Act of this State. the only competition, we believe, that amounts to much in this District and is confined entirely to the State We have it in a very minor way in Pennsylvania of Ohio. but not enough to cause any concern to the banking fraternity. It is expected that the study will be sent of next eek at the latestA end you by the ( Yours very truly, r of the Committee on ch Group and Chain Banking. F.m -- ~No,131 Office <;orrespondence To_ • Bl ttner FEDERAL RESERVE BOARD l h 19 1 Subject:_ Pro_ dur ~-~......-..&. Changes • From _ in d er ... , nt s, n of tio t xperi n 2-8495 . the 'Oh tion r nera, he ~ nnd they underto s e in n tion oft k f dy r le o on th t object is to c 1 h ve o re t 1, of 1 ine th te £1 vings b d 1 res t te, fi nc. ri o of he tion 1 lea fore c t te 11 ately pp or not the figures for conversions ri • y do, ve o ot, they must be or reconciled. Conver on go O C as th inod s y t 11. fy tot 1 n of b ks, ut only in th n of or n tional. , o n ic he ind· · red fr , b ry. record r i In r in spit for th h £or k pt ry on, of ould og r for oul h h t l consolid tion izations should b toget er, tc. on t e ork or c d by st te is co leted, tler to 11 b o on fil er, b 11 pritbr -I Office Corresponde nce To 1 tt • FEDERAL RESERVE BOARD Subject:_ r From _ r port d th ir t y • dur in ell 11 F ,.. .u .., L B , 1k Operations fi I K F T. LO U I S February 11, 1901 • .t\• Golden 'weisor, hair an, Coilllllitte , n ranch, Group & C in Foder ,ezerve oard e.shington , • C. y dear an.king r. Goldemreiser: or o. numb r of years now e have been n lyzing report of exarnin tion of all member b nks in nn effort to dis cover the trend to rards dis ster in time to do 1hat we could to have the trond corrected before the inevitable occurred. ie have come to the conclusion th t little more c n be said than that good management makes good banks nnd b d management b d banks. e have s en the proof of this in that rhen to meet critic 1 condition new money has been placed in a badly manged bunk even to the extent of ing it sound again, where the same management conducts the b kit is just a questio of f years before the b nk is right back where it .as when the ne money was placed in it. ,e ha:ve seen good management under the rorst of crop and drought conditions carry on th bank safe y nd s tisfacto:rily, and at such a tie havo lso s n in the s e tolm the results of bad management culmin te and th b nk close. I run nlco inclined to think thtt the principles of good ban manage~ nt o.nd b d bank managem nt are the s et roughout our entir country. It perh ps may bes un rized, fir t, jud@nent in rog rd to credit; second, syste, ,hich keeps th r cords in such sh ne th the b ~ r lly knows its exact condition at ny tim; third, liquidity, which mens th t t e bank understands it has its expansion defir.itely li ·ted by its c pital structur d local d posits and must puruse lo n nd inve tment rolicy suf iciently div rsified tom et the possible demands of th community in normal ti es with nough elasticity in its invest ent policy also to meet bnorraal times; fourth, distinct r lization that the bnn ' first duty is to see that its contract with d ositor is fully lived up to nd th t, while dividends re necess ry, earnings re second ry m tte· to s fety of de osits. Of course, this includ s o..n ttitude of mind on the part of officers nd directors nd their interests th t they h ve no right unduly to borro the b nk's deposits. There is ones tisf ctory thing bout this nnd th tis th t b nk so run, s a rule, is profit ble. uch a n rl.11 lu ys ,ork rlthin the limit oi' its c pital structure nd loc l deposits nd 1rhen for some re son or other, such as good ro ds di vortine; doposi ts to 1 r_ger centers, it beco os ss profit ble s the ays go by, good gm nt ill r cot;nize th t i t is not needed by the comunity nd wil liquidate in n orderly nner ithout loss to d positors. uch a b nk rill tre t I/, ,2 d therefore not sep rate thing froo loc 1 deposits public deposits s of them investment an through make oossibly n c it . . th bid more for tho.:i thoroughly liquid form . in The proposal of r . Clerk gives one method of studying bank exa; in tions, but , unfortun tely , co,llllents of the v rious examiners as to b d ban's re very much the same and the co ents s to good bans s y vary little other than '~1ell managed b nk" or so e such ,ords to th t effect . I h ve also received from ..... r . Po,1ell his studies, ,hie a.re resented in very ttr ctive form . However, hen everything is s id nd done, e ch of these methods of study gets to the same conc:usion th t g~od an gement . . kes good b nks nd bad men ge ent b d b nks . The study of r . Clerk is typic 1 of rh t ould be found by simil r studies in this district and I am sure in ny other district , It study is so typical th t I think it would be useless ·mrk to h ve such continued further or in other districts . A out the only result to be chieved ,ould be to find that this ras a ~ypical study and the conclusions the same . ~he results of the study of r . Po ·ell I lso elieve will study in this district be the same in 11 districts . I feel sure th t of curves, though trend 1 g;ener me s the she.ring phs gr would produce though not much . , , rs dif'ferentye with ry v might peaks and depressions • o ~11 C erk and • of ,ork the that think to In brief, I run inclined worl further and lines these along accomplished be has developed wh t c is not necessar . ich ve use in sending you three studies on for 1S I this of.rice . In eo.ch instance I have had two banks selected loc ted in the some to,m , rhich obviously h ve been subject to the s e economic conditions . fhe figures of the good bank nd those of the bank that eventually filed, for cop r tive purposes, are placed in par llel nk can be studied t columns . In this way the good bank nd the b d the s e time . ~he f ct is though thnt two r tios are sufficient to give the picture . One is tl1e insolvency ratio ( doubtful ssets and est· ted loses to surpl us , :.mdivided profits and r serves) nd the other is the liquidity r tio (slon assets , doubtful assets and estio ted losses to tot 1 ssets) . The mistakes of bnd man gement n.l be indicted in the fact ors th t go to make up these ratios and I a inclined to think th t these studios I send are typical of the results th t ould be obt ined by simil r studies in other districts . Questionn ires sent out to selected successful bnnkers Siers ould would doubtless be interesting, but I doubt hethor the rison of cop a from get to ble re add any inform tion to th t we to judgment , c b right get rill It figur ,s of good s.nks and bad bahks . ' stockholders to system , liquidity , nd priority of depositors ' interests interests . St tistic lly , the itens ra be pie ed out tha sho the na.ge ent and bad management , sis done difference in h ndling b· good 3 in the charts prepared by ,,ir . Po ell , but s banking deals with such st tistical formul int ngibles s judgment and honesty, I am fraid th t for either the good bnnk or the b d bank will be very difficult to express . take it thnt you h ve seen "Banking o.tios 11 by ecrist , in mich he presents a study which my be of interest to bank man gement provided it will ever read it . yin my , of course , will be gl d to help out in any poY1er in regard to this study and will be gle.d to attend any meeting th t you think advisable . Yours very truly , (Signed) Governor c rtin ry 1 , 19 1. puty r. overnor , l o 01 d, d, Ohio. r •r. 1 ing: ry truly o r , on nch, .- FE•J£RAL RE5ERV£ Offic e Carre spond ence To From BOARD i J.le ,·r . II / Date_ ebr..i· 1 Cj31 ·- Subject:_ r. H 2 o,o se cd sub,~ect e~irn. le to e.Hu •• ine to ·id ucca 1:>· , "viout ztu.entc to ·o utt :npt ·~s e rrn E' ..1u econo. ies rn effici nci Ei 1ibnnne red ·n the 1 orth in l thoa to -;iore , o · br nch b·nking it 10ul rs un - nrricnn . r nc~ ban in e th t out •:rw bt· nch bankin mo:mt-- rny in the ... outh it ne·,cr in pr· ctico ·acts n ,e f on ti110 to tLrie b en hese 1 eet the ch in e to waG co.nmon through- ,ar ; seconu , t iut it h - continue nre ent in the ..,Juth . n~ ve ·riterw on trie 11 by P•"'"tic·l l.. te 1 f" rst , thnt hro.nch b n~in one into by the.n : ut not out the country be ore the .,ivil ONn ts t ·of · t has nkin ond. Jhain ·a. ch, Jr)1 our stu · · of o In the cours V' i e v o : t he s e.n that tnewc 11 r- im evi c1ence h ... - boon accu. thi., the ,.,o.ru it t e in r rill justi 1. before they n e if Lult to con hat t e b ·a ch -. stc>. o · :ni:.. e· ct ·t b ur til th e' ntin of r ~ r ..i :Hr d 1 o c, t to b • rcn b nr..i ore se l oy or , vi t b · .me ol . he ..,eicon c n rnt•""tion re,re&ent ed 1,no t f t 1 tion . ecentr li 3. 1098 , exce t t 1r ob~ ction , , c.n i 1 ton ana . i c ho l • E>re too 2. r re ... so ob; ctiou e ncv r nn .hat there v 1 tc the follo•.vin; con lu ions : re~& ~n n~h an in _,ivil ~a ·r , e i tonce , bee u e it n~r 11 n1 at 1 .. t ,n 1nt ~ontinuou rl• n C iCOl mo l~ i ely out of · ... econo ..1ica.l l y ,is vant ...,eous . d tions ere re 'ollo·vin 84.06 i H • le .ond in th .. h t t le hibi e na re~ent rn.tion·l n 1 th ir 1 ·in c>n t, 0 li r ). t. i ' Yor :n. b t 5. e to h br nch b nkin 0 0 i , i tt r '7 rol lEir . 0 h t t ri in lP ~ 1 t i in l iTe1 n to ,o • re~ r. n· l lJ rc>co • 0 n i) pro- effi:-cti10 l fli~ ct n ~ I throu h v s 0 • int<>re..,t A ~ i i n nt bantt- in "' . in in th r~ i t sti 11 t ' i u 0 t h ,.h i U O 0 r. i i1 1 ') t t ·o 1 i t to or i rn t f~ I' t to to ollov·n f Li of r n~ r,ue - t on ·n ri 1. n ir. b i o· A •b cono i 11 onopOli ti .. 1 in 1 mit b etit · on t en •n h bee1 in , li orni ? n I it ' n ·o L, r lit i vant C oro id n':> t rt or t e C cct nit b nk nt 0 r. b t on in i br> n ch r s '? it in by i s p in l .tri'i nee o n ~ n enc oet it on , th ir tl-i , it~ ') 0 •i 0 h t ll t u hi to ic 1 11 1 :n b th t f " 1 f ct t n on inl r b istoric 1 ·n 11 on ,o C r no int., oi r r. itt r 13 co it • • l on outhern b e rin 'h . . t· m hi .• i., beer: r- i l nEl 1· of e i . y .. n r u t of num 1 r ionn i r .. re rn,,., by it.:ner·ry -ho.11 oth o ,l i 9 0 ~ . '.)Ut ,. ) 0 13 o r ion o ,r na 0 i e , ' ol ee 1 i s: ... si r. : 1 0:lt ' in rn ' >P , tin iv ..,ified a tin 0 te. T rllr 1 i i/ J.n J i. ur, ec 0f yste a , oper tin lab r- ol , in e < 1 ni, ' ell i ' . sisai ' -i t • 0 ye r . . ol ") north rn 17 Of i e r rn ...,ouisian he rrer.a oui i,, l ~' ~h nk, L'K on in r 1 r 0 ~OV ollo in : 0 .. . th I') tu :, le s·eu . ti r 1 n l. n en ral, r-e '> 0~ tion t ') t e .., a 10 r.i in .u n b llKin n •h b n in"? b nA~i icon~ - ebru· • iv<'r~ified r •ion r r 1 in no th '1iti .. h fi s eo to n.b:>lt 2· PU .... a.1 ol , lr h, r tin 0 citie . i in up in ' nk of .., tion 1 rr: n .., n o'" Io1i n i :s ') lab i' or in . oint of he C') or n .,i,. b i .tlt of uni+ b n in he i 0 I, • th t •;el 1 ll • 1ho i io 0 T lKu . C 0 'l . In Cl • tion ni ~ ~n t 'l 0 0 0 uninte it e, b tne e ) u vL, blo . i:h i re i ent . bt in tne ly of e ervc 10 'Ii 11 un k, Ii t l 0 t i()n ., J. b r,.;{ ~alle l 0 0 ' ~our ... e , _,al ler b r u .. h e 'i 11 in t . L ui 11 t1 nta i 1ch t ue to f'"1 ni h i ... trict , or • i dle ·r . ·r . Ha ion lt IOU bankin , it i -4 - tn" mrpotP of elieved .nu, 1 -:::'m 1· the trip i ' to invc st i ate branch kin it11 re<pect to bn.nK failure e cic1cea. up the ~o ..lIIlittce ' L other. att rE- th't ~ill be 0f value in ;ritin The ~· e inv~stiN~ti on s 011 ~ rolin, fornia . t n uO ':'he itin°rar• i_.., n t n""h barucin' t outh ~~rol:n in I orth r. in :1ny oth r ttate rnve, li - mrkcd out for the~e t tne attitu~e both of thE .IJ1 t'te . . , .or the taco .• that th ,~rolin~ a tl~ta egerve nk no. of here are , ho~c>ver , three or four i nort .. nt or 1"niz tions in ~orth ~a ol in o• th t '")..i.ld b0 ,isitPd on the return . 01 or-t , fiela in the other ~tates h~f. rea~on t it ·here there is mo e b b~ u ne in nd 11 u tne J'lnk ,o .1 ii ~sioners of these state :'he ~yste:ns in .•ary l ri.nu c n later . f l~o be c lled lforin No. 1a1 Offic e Correspo~d e To_ From r . "Ql Pl" e FEDERAL RESERVE BOARD Subject: •eiser & • r . ...J. Ue_ flf:ir t 1 t ... u!h :~ tion o the ~ount o~osP~ to n h t·on . I hink he~ 011 (' ~tu y br&.n"ri b nkir i o t:on to 1::0 P of o:ir oth r hei·e tion onn in l us8f e ury s) H 2-&195 •• :rnc1 h b, ch oc- i..., "eek . 'hi le> .., , _ c n ~u" the ·e . cso e atten... ·ck , 1931. r. 1 tt r. 1 dl r r or f t i nt r • • r. r 0 lt rn 0 1 io II- o 1 0 lo t FEDERA L RESERV E BANK OF NEWYO RK February 5, 1951 r. J. H. Riddle, Secretary Committee on Branch, Group and Chain Banking Federal Reserve Board Washington, D. C. Dear r. Riddle: Your letter of yesterday is received enclosing photograp hs of the two bank failure charts. These give a very good picture of the situation , and I appreciat e your sending them to me. Very truly yours, P~ . bru 2, 1931. or , r. trul our , • nc . , 1 31. r. co, r. • Correspon cClelland T • Smead ce FEOERAL RESERVE BOARD -· 1/ Date_ Januair_ 27, 1931 Subject: Correspondence and Reports on Caldwell ..:rroup, :BancoKentuclcyld A. :B. :Banke cha1J,/" ~ •·· -M11r• 2 ) In accordan,..e with your telephone request, I am sending you her<>-;;! th correspondence and reports that v,e have recei•.."cd from time to tirre on the above subject. For your convenience, we have divided the material into three par ta c.s follows, and I will appreciate it if/ you will kindly keep it in that form so that we rray be sure tha.t it is all returned to our files, as ,e have no copies of ost of the material: 1. 2. 3. Correspondence with the Federal R.,~erve :Bank of Atlanta re~arding the Rogers Caldwell eroup or chain, orrespondence i th the Federal Reserve Bank ,:,f St. Lo'li s regarding the • B. Banks Chain and the Roge Cald ;ell group and the BancoKent c~. The .American Banker (New York) for November 11, 1930; six newspaper clippings; three copies of newspaper articles: the December 2 daily ne~s~aper bulletin of the Federal Reserve Bonk of St. Louis;and a summary of the Rogers Caldwell -- BcncoXentucky Group. LEGRAM FEDERAL RESERVE SYSTEM (LEASED WIRE SERVICE) 178 b ~ RECEIVED AT WASHINGTON, D. C. nfrancicco Jan 28 1105a Riddle ReseLve Board' ashingtcn . Your le ter t nty fourtn su g~st sending governors , ery mcdougal martin and talley copy reports on typical cases suspended b nlcs prep red in accordanc e with instructio ns both contained my letter tenth so they may det rmine 1hether finished product gives adeouate informatio n Clerk 2?lp ·- For rn, o. llJI HDERAI. RESERVE Offi ce Corr espo n BOARD To Date .~ nur ry 26, 1931 . Subject: ••o r. ounds c lled me uatu day to viev ·ith •r . (}uy G eer and thinks has c ay he had an inter- fovorabl y impre ed 11i th him . He reer cold hanale the ,anadian ~tudy satisfac tor"ly and e ran eroonts for him to co~e to ,ashingt on to- night to be he e to-mo row for an ·ntervle , v·th you •r . nd r . Goldenv elser . reer has had oui te a vi.de experien ce . He 11ent to aris Nith tne Peace ~onferen ce and spent sevor'l ye rs :1eparat ion .,o onaon end isslon . :fe ha erlin ana ha$ re esente Le ith ho Hi gins in both ritten a book on the hr .,oal ltu - t ion . • ~reer has been ac~u~tom d to a substan ti 1 $alar;, but I told him frankly toe to re~eive or tion . H s o it for -r1 ~ s e couldn ' t p y ryh~ h~t he i~ lookin to think he 500 n r nonth . re to hi • heh s been accuspe . nent nosi- for in oald like the vork ·r . ounds did not nd I think would ention a sal rv 2-84116 J Dr. • 1 old ary 26, 19 1. r lddl In o f r tu h ot inn I only tat hie indi 1 prep r to b llo d top th i riod 19"'1-1930. t inn ot rop I in 11 ir ro out 1t oh dul • 0 1r.n t ro p t t oli • rt of t for 0 11 e 1th th ing. ch 1 o t on of of h r 1t oc in ut ot 8 tt r ld t to 1 26-192 • t t r est ion- in ir t cor or tlo I th n cor o ho l t n • • • 0 l 2 2, l 1. • 0 • 0 • • 3 ' l 1. Proposal of Mr. Clark INSTRUCTIONS TO FEDERAL RESERVE J3ANKS FOR SELECTING AND .ANALYZING TYPICAL CASES OF MEMBER BANKS WHICH HAVE SUSPENDED OPERATIONS. THE PURPOSE OF THE .AN.A.LYSIS IS: To show in concise form the history (gained from comments contained in the reports of Examiners over a period of years) of factors developing in the bank which ultimately led to its suspension. The history should commence at a time the bank was in a satisfactory or fairly-satisfactory condition and be followed through to its suspension. It is intended that a person reading the report should be able to obtain an u.~derstanding of the problems which confronted the bank and to form therefrom an intelligent opinion of how its affairs had been conducted for a few years immediately preceding its suspension. NUMBER OF CASES A.HD METHOD OF SELECTION: Each Federal Reserve Bank should select nine typical cases, including, as nearly as possible, the following: Four or five banks which suspended between the years 1923 and 1926; Four or five banks which suspended between the years 1927 and 1931. Of these, thcr;e should be selected; 4 or 5 banks which had resources under $1,000,000; 4 or 5 ba.nks which had resources over $1,000,000 but not exceeding $5,000,000. Inasmuch as the confidential cormnents of E::mminers did not accompany report~ of examin3tion prior to 1921, it is desired (in the absence of this important IIJD.,terial) that banks which suspended prior to 1923 be omitted from the study. Preferably, the banks selected should be those which were situated in tovms of say 15,ODO popul~tion or under. The selection should avoid the inclusion of a b,'.3.nk which could be readily identified through the special or local character of industry in its comnuni ty. Crops such as cotton, wheat, tobacco, rice, sugar beets, citrus fruits, and industries such as lumber, fishing, livestock or coal mining, are so general as not to mtik:e possible the determination of actu,~1 location of b::mk described as serving a comnunity supported by such pursuits. The selection should ~void the inclusion of banks which have consolid~ted with or acquired the business of another bank during the period under review. It is desirable ~lso that banks which had been in operntion much less than -- · - 2 - eight or ten years prior to suspension be not included. Only banks which closed because of mismanagement or because of factors (economic or otherwise) which could not be overcome by m'lllngement, should be selected. Banks in which misappropriation or def~lcation was the main or contributing cause of suspension should be omitted. METHOD OR TREA.TMENT: The attached report is a typical c~se which in form should be closely ndhered to in the interest of uniformity. In furnishing the population of the city or town in which the bank was situated, give the 1910, 1920 and 1930 figures in accord'.Ulce with the publications by the Department of Commerce, Bureau of the Census. So that those studying these reports mew have some idea of the economic life of the cornmuni ty served by the bnnk which suspended, a brief reference to the principal crops grown or industries followed should be given. EXAMINER.$ 1 COMMENTS: Attention should be devoted to brief comments by the Examiners indicating their impressions of the general 3.ff~irs of the bank. Examiners in each instn.nce should be designated by letters of the alphabet, merely to inform the reader whether or not the reports had been prepared by the same mn.n. Whenever reference is ma.de · to a cert~in Examiner, obviously the so.:oe letter should be used throughout. The statistical information reg,'lI'ding the cond.i tion of the bank, given at the beginning of a report n.nd immed.io..tely follovn.ng the comments of the Examiner, nre to be taken from the exruninn.tion reports. EARNINGS: This information should be compiled for five corqplete calendar years i m:..:edio.tely preceding the ba.nk 1 s suspension. It is to be derived from the Earnings Reports submitted by banks to the Comptroller of the Currency or the State Bank Commissioner, copies of which 3.re in the possession of the Feder~l Res erve Agent. The item "Net Income" comprises the difference betvreen the totn1 debits rmd credits to Profit and Loss .A.ccount exclusive of debits for "Losses Chargod Off" and credits representing "Recoveries II on assets previously charged off. The i tern ''Recoveries" represents the collection of i terns previously - 3 - charged off the bank's books .as losses. 'The i tern "Losses Charged Off II represents the ,Jri te-off of worthless assets 3.!ld de:precio.tion on securities, b::i.nking house, furniture nnd fixtures, etc. ASSESSMENTS BEFORE SUSPENSION: T't1e history should include only assessments paid under statutory levy in order to renove an ill!)airment of capital~ B.A.D ASSETS PURCHASED BY STOCKHOLDERS: Inasmuch as t :1is information is not given in Reports of Earnings, but invariably is touched upon in the reports of Examiners, it rri 11 be necessary to search the latter records to ascertain to what extent, if nt all, stockholders hG.ve purch ~sed assets directly from the b.'.lillc or through /l Holding Co~nny, or have otherwise made voluntary contributions to avoid a.n assessment or the reduction of Capital, Surplus or Undivided Profits Accounts. EXHIBIT 12/1 Bank Organized: Bank Suspended: Population of Town: 9599 14o27 10349 (1910 census) (1920 census) (1930 census) Principal Crops or Industry Served .QJC Bank: Lumber, fishing, shipping. Important Excerpts fron Reports of Exar:rination: Date ( 000 orm.. t ted) Cap. Sur. Prof. Loans Deposits Borrowings 11-16-20 E.xaminer_·_,;1__ : 4oo 80 18 2591 50 Classified Ass ets Doubtful Loss 82 4 9-12-21 Exa..tlner A: ''Present rna.nager.ient is considered good. Large aggregate of undesirable assets were mostly inherited from former management. There is no question but \vhat present capital is too large. At time of consolidation it was left at this figure in anticipation of I:Ja.terial increase of business but owing to depression of business generally bank shows a loss in deposits instead of expected increase , .: 9-12-21 Exarnner A: 4oo 80 13 1542 2015 195 63 4 2-28-22 Exa:-.1 iner B: 11Bank 1,s present condition is probably due to some extent to general slu.TTip in prices and business generally, but is mn.inly due to unwise policy of previous r:ia.n:1gement. Present manageoent is in no wey to blame for present condi tion. 11 2-28-22 Examin8:-~ 13: 200 4o 12 1367 1614 507 53 0 10-17-22 Exa:-nn.Jl' C: "President is not a factor in management but other officers are capable. T'ney with the more aggressive meabers of the board will probably be able to solve the probleP.18 of bank's present rather undesirable situation. Manageoent has been too eager for business with result that r.iany loans are frozen ::md heavy losses are likely to be sus ta.ined. Bank is somewhat extended and has e:,..--:perienced some difficulty in financing seasono.l operations of its customers. Directors advised that t::1ey believed worst of difficulties wo.s over and their future position should be eo.sier. 11 10-17-22 Exn.oiner C: 200 4o 17 1456 1914 73 33 15 4-10-23 Exar:riner D: 11 This lus o.lwo.ys been a one r.1£l.n b3llk. Years ago President_ was dominating fi 6ure, succeeded by Cashier who recently resigned, and now being succeeded by Vice-President. President~hardly a factor in bank's !IllUl.."\gement. Past '\:1d present management ,3.re a.'1.Xious for business r:1.-my loans made -is 3. mtter of policy." 4-10-23 Examiner D: 200 4o 17 1421 2073 0 97 20 , EXHIBIT 12/1 Cn.n. Sur. Prof. Loans Deposits Borrowings Classified Assets Doubtful Loss 10-22-23 EX:J.miner D: 11 Foroer President deceased. President __ is follmving closely in footsteps of predecessors and conducting largely n. one r.ia.n bank so fn.r ns he can ho.ndle mtters. He appears very e.'.lsy in eztending credit or making too 1~,any l .oans '.ls .'.l nn.tter of policy and also very reluctant and timid in enforcing collection on criticised lines apparently being n.frn.id he might lose a customer directly or indirectly. This report shows some iq:>~ovement but as a rule im?roveoent has been nn.de in reduction or elimination of slow or undesirable assets th~t were least subject to criticism, while loans most severely criticised have changed but little. Directors were advised that unless rrnterial iq;,rove::1ent wn.s shown at next exa.':'.lination, p~rticularly as applied to loans to directors Bnd concen1s in which director.s ,-;1ere interested as well a.s large ar:iou.7lt of s to.tutory bo..d debts, overdue pa.per, sl0v1, doubtful, 3nd otherwise undesiro.ble p::i.per, s:c,ecial * ( *frequent) ex(J.Oirotions ,1 ould be recor.mended." 10-22-23 Ex...-u:n.ner D: 200 4o 19 1537 1971 169 69 12 1 4-28-24 Examiner E: ''President, who domin.'\tes policy to l::i.rge extent, is n. 6 ood 'business getter 1 , but ra~1er wenk in m,'.).}dng collections, a.nd is endeavoring to handle too much of bank's affairs alone. He should have a conservative ba.nk fil'.l.Il to assist in m.nn.geraent and this z:ntter was thoroughly discussed with hio. Some g~neral improvenent hn.s been m.de, al.though there still remo.ins r.1UCh to be done before bank is clean. Slo~ assets show considerable reduction r.i.nd n. de.'.ll has been made for sn.le of Other Real Estate. 11 14-28-24 Examiner E: 200 4o 14 1438 1727 271 52 6 11-25-24 E:x:.3.ID.iner E: "Directors and officers stn.te that large o;.10unt of slow and doubtful assets were inherited at tine of consolidation with 3.!l.Other b'.l.11.k sever~l years ::1.go. However, it appe::1.rs thn.t n. number of large lines o.nd slov, n.ssets h1.ve ~ccur:iulated since then n.s .'.l result of 1business getting 1 policy ~nd too free extension of credit. Preside~t is capable but too liberal n.nd too lenient in mnking ~ollections. Besides, he h1.s recently spent too ~uch tine on personcl natters and enterprises. This was also severely criticised by exXJ.iner o.nd he now pronises to devote all his tir:1e to bnnk's a.ffairs with n. vieu to getting bank in 6 ood condition .:i.go.in. Princi"?al r.:ntter subject to criticism is large ru1ount of Overdue Paper \7hic1 including statutory bn.d debts ai;i;regates a.bout 23% of bn..--ik 1 s total lo'.lns. This natter was severely criticised by e:x:aniner during directQrs I nee ting. Exai:uner inforr.ied directors n.nd President in particul3.I' that unless decided improver.1e:n.t in on.tter of attention to slow o.nd doubtful 3.ssets and ovcrd.ue p1.per wn.s shovm at an e.:i.rly date by correspondence consideration r.rl.ght be given by office of Chief Ex~niner to matter of pl~cing oanlt on Special List* (*nen.ning for frequent eXt.~lrlnn.tion). 11 11-25-24 Exn.rniner E: 200 4o 29 1435 2011 58 103 9 EJGU:BIT 12/1 C~p. Sur. Prof. 6-22-25 Exa.I:ti.ner E: Lo~ns DoJosits Eorro~7ings 01'1.ssifiod Assets Doubtf~l Loss 11.A. r..ntorin.l ir.iprover.ient in note pouch is noted in re 6 n.rd to ~r.iount of overdue paper. Cl.,,srific'.ltion of lo:u"'ls, :1or1Cver, sho'l7s no irr_provcr.1cnt. Slor1 loa~1s show '.l decrc"..se of $LIO ,000 but doubtf1:.l i tc;:15 show an incre:-,,sc of $52,000. Losses ch'l.rged off n.t fais tiae :1.v:10-intod to $17,690 n.s cot:1p"'l.rod with $9,452 at 13.s t exar:lin'1. ti on. L'lrgc a.::ow1 t of i;1crcnse in p2per cl "..S s ed doubtful is o.lnost entirely due to c:.1SI1f;e in cl::issific"..tion during exar.ti.n!\tion. 1To nev, loo..ns of slow a.~1d douotful character are being r:nde wd 1:10st of lon:1s cri ticisecl -.t this tir.ie h[.l.ve bec:1 in b:m.:: n. nu:·1ber of ye".Is .'.:md n.re vrorJ:out probleas. S0:-.10 losses n:zy cievclop in ito::is cl'.lssed cloubtful but it is believed bo.:1lc 1 s e.'1.I'ning c~:i_:n.city •;ill en'.1blc it to c:1:1.rge off losses .'.).S they develop. i!o di vidend.s are to be pud until b'"l.d debts 'li1d doubtful i tons :l.I'e clL:iin"..tcd. 11 6-22-25 lilicn.ainer E: 200 4o 16 1283 1555 306 150 13 12-28-25 Ex'U·.uner D: "Directors as ::;,, ,,hole co::n.-:irc fr.i.vorn.bly with :wor'1.6e co12:;:1try bCl.Ilk. They o.rc su.ccessfcl non in t:ieir incli vi c:,_nl li nos of bu.sinoss ,,,:icl nould do \7ell if t:1oy hn.d o.n D.f:bTessivo le~cior. 1/i".,;.7.'1bX}.:1ent is vor-J woxc, ln.c}:in.; force, if not incor.ipetent, n.s indic'1.ted fror.1 n--..:r.1crous cri ticis:-.1s listed. Preside:1t is well ,.!c1.nin 6 but u'lsy goinc; , e:1tircly too free i:1 T~...1ti1~G of cr<Jdi t .:i.nd ·.1~ilc .'.1. l,"..r;.s,e nu.·:1."oer of froze.1 "..11d q<1cstion,'1.ble ~ssots '.U'O an i:w.eri to.nee fro::1 fo:::-.?:1er r.1.·1n~.0 u.11,mt it is evido:it ~1:1.t President docs ;1ot h:wc ':'.bili t;t or inclin"..tio:1 to collect er clen...'1. ·ip those old r.nttors. Prcsiclont is believed to h:we h-:1.d little b-,,;"i).::in 6 experience outside of t:iis b"..nk. CCI.shier is "..S O.'.'.S~; GOinf; ,'ls Presidcat ·:ritl1 ovon loss initiative. It is, J.1ormver, perhaps tr..1e th-..t ?rcsid.e::1.t ~70ulu. not ?er i t -..sst::.1_f)tion of ffi"JY o.v.. thori t~; by '1:"JY other er.1_Ploy0c n.s ho n.·J:i)o~s n.nxious to ?":."..Ilt1,6 e entire b:1...J.~ even includin...; ope:::iin:;; of all r.nil :;_:,erso:1!'..lJ.~,. m1cn sug_;es tions 1Gro t1".de or criticis:-.1s diroctod '1.t scv0n.l hc..,ds of different dep ....rtnents t:10:r co:nonted to ex,,,_7i:1er in effect th'lt Prosidcat ',7'.lS oq'..1-:-,lly to bl1I1e -..she vrould not ·_,cr·,it .:iny lee,:'\:· vr:1en they •.-:ere C:.is·)osed to brinb "..bo..:t correction of so:-1e of c::d t:cio..:d r.ntters. Wri tor e:::..._,.,__d.:1e!l b-,~~ in 1923 '.l.."'ld ,, coq_)'1.rison r!i th his :;_:,rovios rc~~ort discloses nu.i-:ierous .'.lsscts cri ticiscd -:tt tir.1t: unc:1 ....ne;ed ~nd ::i.p)"..rC;.1tly :io ".tte:.1_Pt m'1.de si:1ce then to liq11id1.to v'U'ious st'l.tutor~r b'"l..d debts ci...-id other questio;,1;>.,ble ~nd frozen .'.1.Ss.Jts. Ex')J'.:incr roco~r:10nds th':1.t b'"'-'1!:: be pl'1.ced on list for frcqi.:ont ex:i.."Jin'ltions until co:10.i. tion is S'"',.tisfc.ctorJ ,.,:1d t!·nt no:~t ox:u:-in't.tion be n:1.dc 90 d::ws fro,.1 d.'"l.tc. 11 12-28-25 :ZXo.!:'.iner D: 200 40 11 1855 2021 316 95 52 4-10-26 E:x::i."Jincr D: "~ritcr 0A1.;.:i:10d b::1.n.k in 1923 'l.t w.ich tine Pr0sidcnt n,'t.S t:1en Vicc ...Prcsident O.O"'ld '1.t ~-,.-:ich tii:.:e ho s·:.1cccoded to Presidc:icy. E 111':: h'.1s for rc:.w yeo.rs been n. one-0.'.l;.1 b:tnk, '.l:1d. co:1J.i tion go:;:1cro.J.ly unsn.tisf'J.ctory 6Tu."..tcr p'.ll't of tine. At CX'.l:.:in'l.tion in 1923 c;,:a:.ti.ner urt,;ocl :-.1..-:l.n~gcr.1ont n.nd directors to t:l.1::e pror~t nnd 0.6Gressive steps to collect or scc;;.ro l..._rgc ;-·ou.'1.t of sb,tu.tory bo.d debts .'.l!ld other ovcrd~e pri.per, slon ::ind qucstion:ible o.ssots, n.nd directors noro ..,_dviscd th'lt unless such '.1ssets ,mre give:1 i1.t'.1ec.iD..tc '.1ttontio::i b'Ull:: ·.1:1.s certr:1.in to sust'"l.in l,,.rgc losses. Ex--··.tln:-...tirm n~ J.2-28-25 \7:'on CODP'U'Cd ,...,i t:1 1923 ~:1owc: • . EXHI:BI T 12/1 P3.ge CD-•). Sur, Prof. Loans Deposits :Borro-.tin,::;s 4 Cl~ssified Assets Doubtf·d Loss D.'.ljori ty of larger n..1d r:'.ore undosiro.ble ~ssets still in bo.nk r,i th r.nny 1-:i.rge lo.'.1ns uncha.i.--ibed except th3.t t l1ey uere t·,10 yon.rs r:iore p",st due n.nd it ~n.s evident th,.,,t r:nn~enent h~ve :mn.de little, if n.ny, o.ttoopt to seCl'..l'e stntus of such paJer subsequent to 1923 or previous. This st'J.te of 3ff3,irs ~as rather forcefully brought to ~ttention of directors crurin 6 12-28-25 ex~:rl.n~tion nnd a subst'J.ntin.J. o.r.1 0unt of uncollectib le assets of 1923 n.nd previous uere listed 'J.S estin~ted lossess. So many promises and so muc:i. assurance was given exainner at previous examination that immediate steps would be taken to improve condition that the few changes and lack of improvement are most disappointi ng and discouragin g. Special eY. a:ninations at short intervals vfill probably prove useless a:ad a waste of time as but little improvement can be expected in three to four months' time. Frequent examin'J.tion s will undoubtedly cre1te unfavorable comment n.nd gossip to detriment of b~. Examiner has lost what little confidence he had in 1923 in President and Cashier and it is not believed these two will work the bank out of its most unsatisfact ory condition. Without frequent examination s and the present management in charge it is believed ban.le will be permitted to drift and it appe3l's to be a choice of two evils, each reacting unfavorably for bank and its shareholder s. Directors vrere advised that examiner had no authority to demand or request resign3tion of any employee but that it was duty of examiner to make recommenda tions to directors for good of bank and it was suggested that if present ma.nn.gement did not show a desire or inclino.tion to work with directors that directors should employ someone who would toke chn.rge of bank's loans and wl10 would be responsible only to bo'trd :md not subject to interferenc e by President or C'J.shier o.nd it i'I~ further suggested that directors compel officers to compl~:· 'iri th resolutions po.ssed th'J.t no new lo:ms in excess of $500 be mn.de wi tnout first being authorized by finance con:nni ttee '3.Ild tho.t directors compel officers to furnish at :Bo3,rd meetings inforJDD.tion they desire concerning status of loans n..-rid other o.ssets :md t:i.3.t if ·,)resent offieers are not competent in opinion of directors and ba.n..lc•s welfare b e i~roved by a ch'Ulge of management th'.l.t they give serious consid.er.'.'..tion to s11.1e. 11 4-10-26 Ex.'.3.llliner D: 200 4o 3 1941 2628 268 118 19 8-13-aS Examiner F: "General condition shows very little chn...-ige. Condition is most unsatisfact ory ::ind unless some cn'l...-ri6 es .~ e mnde I do not expect to see ".rly rmterio.l change for some time to come. President ns well ~s directors are of opinion th:,.t t:1ey should not be asked to put up m:mey to elimin'\te a.ny losses .:i.nd doubtful po.per, contending that bn.nk c-m earn its vny out in ti me. Ex:ir:ri.ner does not o.gree o.nd informed them that they TTould be given until ncJ:t ex:)J'Ilino.tion to provide for losses estim~ted. Exn.miner informed directors t :nt they r10uld be given until next cx.::i.minntion to m:.'1ke some provision to provide for losses Gnd other items tot:1.ling $144,319.39. Your eXD!lliner h'J.rdly e:;...-p0cts to get e:w1~h money to elimin-,_te all tl'lis pn.per but thought foo.t by pl:1.cin ; t h is progr'.l!Il before them they ·,7ould exert themselves to collect this p.::;_per. J stitu ted losses r,ere not ch~ged off for n.bove reason. Exoniner thought th:it if si t"l:'::1.tio:1 wns to be broug..'1t to a hen.d it should be done n. t one time. ?.zy' idea vrn.s to plDC e them on notice th:i.t . EXHIBIT 12/1 Page Date C.'.lE· Sur. Prof. 5 Lon.ns Deposits Borrowings Cl~ssificd Assets D~Qbtful Loss some t h ing ":70uld h:we to be done by time of next ex31nnn.tion o.nd perl\:::i:ps some concerted action c011ld be obtained for the better. It is respectfully rccorn,nended that baJ:1.lc be not placed on special list at this time. I do not think SP.ccial ~xarninaJions ,1ould be of any value now. 11 8-13-20 Ezaminer F: 200 4o 7 1915 2672 172 90 59 1-28-27 Examiner F: "General condition sho,vs some slight improvement a:id officers and directors promised to continue efforts towards collecting criticised 9aper. At t:1is season business is very ·p oor and collections slow. Real es tatc is extremely difficult to sell and a large amount of bank's loans depend. on sale of city property, farmland, and timber. With this condition it is extremely difficult for management to collect a~y paper predicated on above assets. President is interested in entirely too many civic affairs n.nd other things and C'."1Ilnot dovote all his time to bank. Du.ring e.x:1min"1.tio;1 I took p-u-ticul-:i..r notice 3Ild he spent rnn.jori ty of tine out of bD.nk. Tnis w-:ts forcefully c~lled to his 1.ttention :1,.;d his excuse is that no one els~ vlill do it. Your examiner had ,'l frank t.'.lll:: with Presiclent ruid Ci:lc':.eavored to sh;m hi:n th-:i.t he 'ilas doing TTrong. On ot!1er lnnd he s,)ends h is person::11 money for benefit of b ,XC'2: in wey of tr1.11sportation, etc., .'\i.id t ho rc is no question th').t he is doing his best to plo..ce b'Ul.lc in .'.1 more s.1 .fid-:tcto1~J co;.1 di tion. He is one of most pl0:'lsing men I hr.we h:::i.d tho ple:1.sure to come in cont'1.ct ~-,i th but is inclined to let people im1)ose on him a.-id so!!l.e of his financing is su.ojec t to criticism. He tries to help p0ople 'J.nd concerns ~ho do not even do busincos with the b"l.nk :md anyone cnn tn.ke up :1is time whenever fooy desire. At prcscz1 t bo.nk h'.ls good en.rni:1 5 capo.city, '.lpgroxinntely from $25,000 to $40,000 per 1.11:i.1 wJ ,.,,ftor ex-_pcnsos ,'.JJld wi tn .,_, reduction in interest p"l.id. s0,ving; depositors it ··:ould mer,__'fl some $18,000 o, ye.'.lr addi tion1.l profits. In past fe·:r years "1.ll e3..rnings h-.ve beer. ~sod to c:1.' \rge off losses. In -p:1.s t six ye1,rs b1'ik has ch'.lrgcd off over $172,000 in losses :1.nd recoveries hn.vc 0.:-~.0i.:ntod to over $26,000. This is beli cv..:cl to h'1ve boo:1 in o.ddition to o.sscts elir:ri::l:>.:~od by;?:, roCt.uction in cn,pit.:i.l of $200,000. Pr-:tcticn.lly 't.ll those :is sots rrcre inncri ted by prcscn t :1cm3,€;01:icnt Md t:v1t holds bood vii th ':\ssets cri ticisod i:;:i this re,ort. This r<-".Port shorrs estL:.,.,tod losse s :-:>-b •reg3.tin6 $132,000 1.'1d on Fobru::1.r~· 1l.1.th I \7ircd yo.;.r office stn.ti.ls of si tu'l.tion. Jt:f ter severn.l conferences rrere held directors rco.chod conclusion th ,. ,,t 'Ul :1ssess~e:1t ·,ro'cld not be proper proc0d't.'..re. It ,10,s fin'1.lly ri,grced th.' lt t l1ey Vlo"Jld :person~lly purchase these i terns 3,nd it ,ms definitely un.dorstood th"..t t~cJ ···ere to be purc~1ased for cash and under no circumstances were a..y notes to be ta.Len by bank. This t:1ey agreed to do, but .ranted. 30 days in ';'lhich to c onplete t!leir D.rra.,ge::1en ts a..,d accordingly your office was notified. Your \7ire of Febru.ar-.1 15th ·,ms received in ·.1:1ich you stated that ir.xp3irr:1ent notice would be withheld for 30 d3(fs n,;:1d I accordin 6 ly notified mano.se ·.'.'.e:1t that they 1-rould be t,i. ve:;.1 m1til M'.lrch 15tl1 L1 ·;rhich to CO'.'!!J?lete their plans. 1-28-27 E::caniner F: 200 4D 1 1803 2701 179 19 132 1 " EXHIBIT 12/1 Page 6 Cap. Sur. Prof. Loans Deposits Borrovlings Cl~ssified Assets Doubtful Loss 8- 2-27 Exa:u.ner F: 11 Condi tion remains most '\lllsa.tisfactory and im.nagenent 1:1.ppe-:.rs to be making very little progress in collecting criticised assets. President continues to dominate and apparently directors cannot control him. Bank is overloaned and President continues to make loans that will prove very slow and also continues to try and finance everyone in the community. Regardless of advice he receives from examiners and experienced bankers he does not change his policies. I am afraid that if he does not change his ways he will find bank in a serious condition one of these dtzys. I had a talk with ,hi~ principal correspondent banker on August 16th and he told roe he had talked to President a short time ago and if he did not change they would be inclined to refuse his bank further loans. The Federal Reserve Bank is very reluctant to discount his eligible paper and ,'.ll'e constantly w~tching him. I am not all satisfied with condition or policies and feel th~t something IID.lst be done to correct situation. In view of this situ:i.tion it is respectfully recommended that bank be pl9Ced on speci::u list 3.nd be 3.g~n exnm!ned in 1.bout 90 d.-:zys. 11 8- 2-27 Exn.nrl.ner F: 200 4o 12 1950 2512 314 4o 1 1-20-28 Ex.'.lJlliner F: "As examin~tion was ma.de on b~sis of going bank, it has been difficult to write report, and eX3.miner h...'\S attem,pted to cl~ssify assets as they a.re cl3.ssified under the receivership. It is to be noted that 1 slow ~ssets 1 h.:l.s been elimiMted. Examination wn.s comnenced on n.fternoon of 1-20-28 n.nd W:18 com,.. pletad 2-11-28. Precarious condition was thoroughly discussed with directors latter part of E'ebrua.ry a.t which Chief Examiner was present and weys o.n.d me~s to eliminate estirruted losses n.nd frozen ~ssets was topic of conversation. It w1:1.s concensus of opinion that efforts should be ma.de to orgo.nize a new b~ to assume dcposi t li'lbili ties and take over a like nrnount of assets. With this thought in mind eX'.l.Illi.nor left b:mk but kept in touch wi. th directors o.s to progress made in this direction. President tendered his resign::i.tion the latter part of JruiUD.ry o.nd this was published in a loc~l newspaper in such a manner that it left a great deru. of inference with result that a run mi.s started 'Thich reo.ched such proportions thn.t exa.rniner was requested to return Md advise with directors. After a thorough n.nru.ysis it w.:i.s deemed advis::lble to close the b:i.nk ~s run had re'"l.ched such proportions that it ~as useless to keep open, 1-20-28 Ex3.miner F: 200 4o 12 1745 2473 152 810 333 ( 000 omitted) E:l.rnings: Not Income (Grosij E.'ll"!lin.gs less Expenses) Recoveries Losses Charged Off .A.ssessments before Suspension Bad Assets Purchased by Stockholders Dividends ~ 1924 ~ 19aS 1m. 34 29 17 36 30 146 1 10 35 6 44 1 19 33 18 156 0 68 0 25 0 0 g 0 0 0 0 0 68 0 0 0 0 0 G Total g EXHIBIT 12/2 Ban:.c Organized: Bank Suspended: ?o--:iulation of Town: 1900 1924 1238 2957 2455 (1910 census) (1920 census) (1930 census) Principal Crops or Industry Served~ Bank: fueat. potatoes, livestock, alfalfa, beets, seed-peas. l!!!Portant Excerpts from Reports of Examination: Date ( 000 omitted) 10-13-20 Examiner A: Cap. Sur. Prof. 50 50 2 I,.oans Denosi t 3orrowings 501 581 45 Cl~ssified Assets Doubtfo.l Loss 0 0 7-14-21 Examiner B: "General condition is rather satisfactory on the 'Nhole, enpecially in the lig.~t of two or three poor crop seasons experienced in ~~is comr:mmity. Bank's condition is extended but fact tl:at proportion of rediscounts is so large speaks well for character of pa.per. Paper is of good general ci:1:u-0..c ter except that some wheat growers on dry land have beco.ne involved. Wi tr:. , oocl. crop returns this yeo.r material liquidation ~ be expected. Management is cc..:::cful Md efficient and gives close attention to paper. No one man do:ninates. 3o.nk is situ~tcd in good ogricultural conmunity, partly irrig~ted and partly non-irrignted l'Ulds. Crop prospects on irri 6 ~ted land are fine n.nd fair on clr:r l'"'.llds. 11 O 3 47 403 354 6R 50 7-14-21 Ex::un:iner B: 50 1-20-22 Exn.r:ri.ner C: "In gencrn.l, a well-:n.'Ula&ed and well-run institution. Personnel appears very c:ipable ruid considering gener:,.l conditions here, t::ey have done very well to keep bn.nk in its present sh3.pe. Genern.l conditions in t ·1is dry farm country nave been very unsa. tisfn.c tory on 8-CCount of 1'.)oor cro"9s n.nd. ·1 ·o"'r prices :md unless conditions improve b.'.l:nks here will be very bard pressed this coning year. 11 O 17 277 451 571 2 50 1-20-22 Examiner C: 50 7- 5-22 :&"'C.'.Jminer D: has been in the past too lenient in accepting paper for RCCor:unod'.\tion of other bn.nks. Most of the p:iper is slow nnd rrust of necessity be eliminated slowly. This is ['.n element of danger ~ricl consider:1.ble losses mn.y result before po.per is elimin~ted entirely. (They take lo~ns to accommocb.te other banks, $82,000). B111k is in n. ver-.r extended condition but crop conditions are very favorable ~s a. whole. If .'..ldverse conditions yrev~tl ?roblems for bank \'fill be d.ifficul t. 11 ("/"3 11 00 ~ 50 371 7- 5-22 Exo.miner D: 50 11 Mam.ge:nent EXHIBIT 12-2 Page 2 Cap. Sur. Prof. Loans De )08i ts Borrowings 1 Cl'lssfied Assets Doubtful Loss 2-10-23 Ex'lminer E: "This bonk is in -:i, ra.ther d::mgerous concli tion :tt present due to l<1rge amount of borrowed money a.nd excessive 11mount of slow :md doubtful paper. Surplus is :1lso imp'rircd by estirnn.ted losses. Another contributing factor which makes condition dnngerous is lack of confidence by public on '1CCount of large number of banks which have closed. As yet t :us feeling h'1s not been noticeable here but matter should not be overlooked. Some of present stockholders probn.bly could meet a. 100% a.ssessment but this applies only to a minor portion. The larger shareholders ~re :iJ.re~dy heavily involved. If permission to incre~se c~pitn.l $50,000 is gr'Ulted it will r:in.teriru.ly better b'1IJ.k 1 s condition. Directors desire to sell new stock at $150, Prer..tlum of $25,000 to be used to cb[I.I'ge off losses o.nd daub tful paper. Exo,miner recormnends eX3.mina ti on in 9G clays. 11 2-10-23 Examiner E: 50 50 2R 617 377 325 12 9 5- 8-23 Examiner E: ''Bank is still in dangerous condition due to large ar;iount of borro·.1ed ooney and excessive a.mount of slow and doubtful assets. At last examination directors desired to increase capital to $100,000 and believed they could seJ:l stoc!r at $150.n.nd were to use ar:1om1t derived from l)remium to charge off estir.:ia.ted losses and doubtful paper as fax as possible. At this exonin.1 tion capital had not been increased nor could stock be sold at 150 or even p3l' at this time. Examiner decided it best to cleM house. Estinnted losses aggregating $37,000 were ordered ch'.lrged off and entries mn.de during ex3.::iination. This :practically wipes out surplus and as a result ~nny excess loans are shom1. Should crops prove poor tlii s ye'.lI' or nnrket conditions adverse b'.1Ilk ·:,ill undoubtedly suffer heavy losses. Confidence of people of cor.1!:lUility is none too 6 ood. E~ch tine examiner visits ba,;."lk there are sane withdrawals. President be~rs confidence of people but is also president of ~nothor b!IDk '1nd is obli ged to spend most of his time t~ere. c~shier 1 s persono.lity does not inspire confidence of public in b:m.k. Stepo; ~re to be tnken to '.lppoint one of the most influenti~l stockholders as vice-president who is conserv1,tive, a good collector ,-.:ind ·; fill devote nost of his time to bank. It r.iey be of considern.ble benefit. Ex:u:u::ier does not recor.11:1end to.king bn.nk off speciil. list (for frequent ex-u-:ri.nn.tion). Should ::,,ny unusu:11 conditions axise ban1: would h:we difficulty in r:ieeting der.nnds. 11 5- 8-23 Ex::i.r.uner E: 50 50 6Red 614 293 360 42 37 11-12-23 Ex'.:ll.2iner E: "Some ir.1provenent ms been ::nde since lnst e:.c..1.Lti.nation. Lo.'.l!ls have been reduced $63,000 borrowed money $33,000 and deposits increased $12) ,000. Princip::u ir.1prover.i.ent is in res toro.tion of confidence of cor.u,uni ty in bank ,:md it is believed th-'.lt danger point has po.ssed. A very 6 ood crop of whe,"i.t is being harvested .'.md mile prices are only fair, consi der'.1ble liquicl::i.tion froo this source will be had. People '.lre i;;ottin{:,' in some r.10ney o.nd ns ::i. result a rmch better feolin 6 :-ill n.r-:>und prevails. Officers o.nd directors estinate th::i.t EXHIBIT 12/ 2 Pae;e 3 Ca.p. Sur. Prof. I,o:ms Dep~si ts :Borrorlinr.:;s Cl'\ssified ~ssots Doubtful Loss b~:: nill be able to cut dovm its bills peyn.ble rli th Feder~ Reserve :B~nl:: o.nothcr $100,000 by J.'.lllll.'.:l.r .1st. Exnniner believes trui.t a. further reduction of $50,000 to $75,000 in bills payable r1ill be a.bout the best they cn.n do. This •,7ill still leave b ~ in a. badly extended condition. It is believed th::i.t prese:1t condi tio!1s h~ve taught officers a. lesson and credit a.dv.:mces here~itor TTill be C'1.refully considered before beini; mde. C1.shicr is not o. very good banker .'.l."'ld ::i. chn.nGe in nann.genent :,ould be of gre.' \t benefit. President is believed c3,p1."!:llo -ind a.n..tious to 6 et '.lff"\irs in good condition ~s:\in, but is obliged to spend nearly ~11 his tine 1.t n.nother ba.ri'_;: ,1hich requires his close attention. Idea of incro'.1sin 6 co.pi t'.11 h'.'l.s been .'\bn..r.-idoned n.s it is believed stock could not 1)e sold. E:~:uner respoctfull;r reco:r:r::1ends th:"',t b~:: be kept under survcilln.nce by reports and correspondence rather tho.n by frequent visits by e~cri..runcr. Too libera.l gro.nting of credit in pn.st is en.use of bo.nk 1 s present condition." 2 16 327 379 551 6?.Ed 13 11-12-23 ~:r·iner E: 50 1 Earnings: 1..91.9. Net Incooe (Gross E".rnings 13 less Tocpenses) 0 Recoveries Losses Ch~r 6 ed Off 3 0 Assessnents before Suspension :B~d Assets Purchosed by Stoc~.holdcrs 0 16 Dividends 1920 14 l 8 0 0 10 .im 0 3 3 0 0 r - 1922 16 l 12 0 0 1 1lli 9 2 Tobl 57 7 42 68 0 0 0 0 0 27 J'c..11c of Bank D:" te of Rep crt Flace . Ca.pi tal . ........ .... ..... . ......... .. .. . . ... . .. . Page 2 . Su-I,:111s • •. • . . . .•..• .• • • ..• .. •••• •• •.••••...• •• • F gt"! -· - _- ro!~-1. ts •• .. . ... ..... . ..•.... .•. ... •. . Fage '-' nrl'.1 v:ule .'__ • TT • ~e~erve :or Depreciation and Losses, , .• . ...... , Fage 1-1. 1 1-L. 2 1-L. 3 1-L. 4 ,. ' :r.eoosi ts ••. •. . ..••. .... . .•. .• .. . .. . .•• pa~e =r.:.:r.c and S9.vinP.:s Dcprsi ts ••... ••..•• . . . • ... .. .• Faf;3 7 . D. S , Do,I,o£i ts ••••.•... . ..••..•.... .. . . .. ... . ... :Page 8 . T.J tal Deposits •.•... . ....•.. : .• . ..•.. : . .... : . . ;pa ;e 1-L . 8 l-L.13 l-L . 14 1-L. 8-14 J:-:1.nl -.t .Ar\ 'Shere Fc:und (L . -Li~oilities on ?~ge 1) (" • -Resources on Par;e 1) Item I ( Iri thousa:-id~ • .: and tenths)/ $_ _ ) I ..,I 1, ) 2 3~ ·1 5c 7. 8. "'. P rro\ ed Mo~1.ey I'- 3 e v_roTied :i3onds •••.••• . •. ·; •.. . ;Page l-L . 16-20 9. 10 . ll . 5:ou:;e, Furni tire & Fixtur s ............. Pa,::;e l-R . 12 13.Cash Funds •••.• . ...••....... • .••• , •••.... • • • . . • page 1- F. . 1L1-20 l • :SXt,>cnses in Excess of iarnirigs ••.. ... . • • • •• •. •• Pa,2;e 1-1, rt of R. 24 12 . 15 . Loans to Officers&: Directo.1.·s(Dir8 r,t) •••••••. . •Far;e 2 13 . Lo~ns ~dorsed or Gu~ranteed by Off . & Dir •.•.• Pae 2 7 . : oans to o:ficcrs 1& DirectorG 1 Interests(Dirc t)F be 2 15. 16. 17 . sr share •.•.•• Pa~e 2 18 . ► 19 . Fast Due Loans A & B •••••. . • • •••• • ••• • •• • •••••• Page 4 19 . 20.Fi rst .,16 :-t riges-(T e al of l oo.ns wi hout prior SpociaJ pae:e foll owlie:.is , except where alled 11 contr,3.ct 11 in Col . · ing r.'.' a 5 , Itv: s 1,2,3 21.Junior Mortga6es-(All 1o:tns navin,,. pri or liens)Special pa ,0 f oll owing Fage 5 , Ite:nn 1,2,3 22 . Lie:r.s Prior to Roal l!..St~.te Loa !'.s OWned •• ••• • • •• Special pa e followinG Fags 5 ,ltans 1 , 2 , 3 Specinl pa e followof . fecap in es 23 . Contrncts for deed-(Someti ing Fa;i:e 5,Ite:ns 1,2,3 •• . ... . .... . ••••.•••••. 7) 0 F" on :::nve"tr.lonts 20. 10 .Tnt.a.l Loar.s . . .. . . .. .. .... . .. ... . ..... ... . . .. . ... fa?.::: 1-R. i 11 . ifo·o·tc,.1 Lofl?:S ~ Invest:ncnts ••• • •••.. .... .. . •.... • ra.;e 1- R. l & 5-11 l.J Banki~ 18 . Stock Owned by Directors~ $100 Liquid Invostmcn ts & 7 Valuo , Pa ~e Vnlue , F~~e Valu'J , Fae:e Value,Fa c Value , Page Value , Pa.:--e 2 .u . s . Bon.s other th~n those securiJg circulation ?a6e 1-R. 6 25 . Forei 1 -Inves t,.71.en ts - not in default ••.. • • • • . •.,1nrk. t 26 . Rnilr oad Investments - not in default •••• • • • ,,, Market 27 . I-ubli Utility Investments - not in default .••• Mar}·et 28 . Industriul Investments - not in default ••••.•.• Markct 29 . Municipal Bonds - not in default •••• , •••••••.•• Market 30 . Mi~cellaneous Bondn , Tax Certificate6, Warrants .~arket and other Liq·id Investments , cxcludinu forecl osures , Claims , Jud@nen ts and Defaulted :Bonds 13 . 14. 21 . 22 . 23. 24. 25 . 26 , 27 . 28 . 29 . 30. 7 7 7 7 7 7 Other Real ~state ~. l . 3ock -value •.•....... ,, ....... , .. . . . ............ Page 8 32 . Prior Liens ••••.•.•. ,,~ .•. .. . . . . ••............ , Page 8 33 . Estimated Yalue . ·. ·•••••• • •••••• , ••••• . ..•..••••• Fa ,,e. 8 . 31. ...~?.., 23 , 4 . Sl C\7 ~ a'i'ls .... . •• • ••• • ••••••••••••••• •••••••.•• • Fa :-,e 11 r5.Slow Eons , S ~uriti es , eta •••••••...•.•. •.••• Page 11 ... 6 . Slow 11 0tbcr 11 i::aul Estat;e•·····• ········•·~•·;··P a0 11 :34, 35 37. Doubtful Asse . and Losses - Loans. ; ••••••••••• P.. e 11 38 . D!Jtlbtful As se• ~nd Lossos-nonds & Socurities •• PaP,C 11 e 11 ~d Losses - Al l Other......... 39 . ~oubtf·l Asset 37 . 38. 39 ••••••••••••• Pas 11 48 . r ~D . V luo of Azso ts t shown on Bo~ ~ ~1. state , County & Municipal Deposits •••••.•••••.•• Yellow F c A •~2~Sal n.rios ..,f O.ficero (exclude e.'llplrye s) ••••••• y ll ow Pa e A Preceding Ye.:>r 43 . ll'et ear.,inc.s(befor e' rit, o ffs & rec overies) •••• •_4 . ·,7 i to ffs reinus rocove ios •••••••••• • •••• • ••• • • 45,.Divi.de!lds aid. ••••. :·,. ... . ......... ... ......... . .. . . . ... 6 -.- 41 . ,;2 . 43 • '-'4 . ,;5 . 1. 2. LO • rn • pid r ( lo 5., l lu • • 7. l r 1• • • • • • r. rk, • r 0 1 • • C t 31 • 2 , l 1. r. r • t ly o r , r nc , nc. Januar y r. iddle Guardia n DP-troit Union Group. Inc. ex i that it fill Gro p holds a th list of b n o uestion n ire, I ind ntion 7 ban• in which di Detroi t Union cent intere st. hese 7 b n e b ve always been in1 aorta on grou-o b king with t e 25 n e ich in the r o t. 11 b a, nonm bera of dS t m. r. . ord mention ed them n bia t • ional (See he inge). On T 214, 1931 b a are: ich. II vi • Thomoson S vi e s a of av ng en of B nk ea Stanton e taburg " • II , l 19. 31 FEDERAL RESERVE BANK OF NEWYOR K J i.l <'lQ 19.:,1. olden eis r, Chairm n Co Dear ·tt o urou., Banc and Ch ·n Federal heserv Board , shingto , D. C. r. Golden eiser: r. Rounds he you .in copy of h·s sk o to for etter to lr. Cl rk d·tcd J ~ 19, d to 931. V ry truly your, Secret to r. Roun s . LEGRAM I FED ERA L RES ERV E SYS TEM (LEASE D WIRE SERVIC lt) gy r S r. ,a !Jr n Cid nta l OU• · .. vita tlor: : tt t r t. abo t 0 ('\l e e i 1 i a"C d e + l +- 0 lr tt r " 8<) 11• t. c... 0 ....,,.. ........ ........ , . . . ~ - ... osa . el Q. C ti t f" Li. C 1 , 1931. r r, , 1n accor d nc t o r 0 co 1t or 1 p • 0 t O ct 1 • to r t Cb<f?f, ( 1 enwei ■ er re■• 1 ■ : Alexi ■ Ooldamre1 ■ er .bchatfenburger ■ tr. erlin W30 J'aaD1' 9 l 0 N FILES SECTION Form. No. 131 , • - Office Corresponde nce To FEDERAL RESERVE BOARD tt/ 2 71940 "y ' Subject: Loan N.r. Golden ei er tmen.t of branch From _.Mr. J31attner 2-840/i, , •• ]8.l'Jcs in group <including ch ins), oper ting no branches, r port d total nd inve tments of loan 5,122,000,000 of June 30, 1930; those in group oper ting branches, $6,897,000,000; total for group systems, equalling $12,019,000,000. Banks, not members of ~roups but operating branches, had loans and inve tments of roup 18,264,000,000. Thus branch b nking system hether as oci ted or not reported loans anc inve tment of $25,161,000,000, of which amount about $21,000,000,000 belonged to banks loc ted in state where branches r stricted a to location principally to the he d office city. the country 0 re All banks in of June 30, 1930, reported total loans and inve tments of group and branch systems accounting for $30,283,000,000. ,000,000, th ith 58,✓ The follo ing tabulation hos the number of banking offic sin and outside of branch and roup systems: Bankin~ offic s--tot 1 Sin~le-office b Banks o er tin branches (head office) Br nche June 30, 1930 g/ 27,470 23,035 817 3,618 Dec. 31, 1929 1/ 28,177 23,808 822 3,547 Banking offices in groups-rtotr.l Sin le-offico banks branche (head offices) B nlcs operati Br ches 3,752 2.007 137 1,608 3,620 1,943 122 1,555 not in roups--tot 1 B nlcing offic s ':J./ Single-office b Bank op r tin br nche (he d office) Branche 23,718 21,028 680 2,010 24,557 21,865 700 1,992 !/ Revi ed figure g/ Representing 23,852 banks; on D c. 31, 1929, there were 24,630 b nlc. J/ ndependent in le-office banks. -· -- I anuar y 16, 1931 . FFILI TI0!1S ':'he irrmort r-:: of this exten ion of bra ch and ~ood rPa~o ns vitn thin •s ubjec t i two fold . roun banki n~ is in tock "obbin t e reduc tion of pa ost peo 1 ' nd hi h financ e . •1alue, cha In the It n minds as oci ted for been atton e c cons rvati o oint of viev n~ve been decid edly ohady . of branc h an group bank ng it is nece sary t them in banki ng, ve h ld in th past ill hol nrohi bitea ,tit out f r sorted to . t i instan ce, ha e nd th tall the s b nker ell info i 11 pr mpt the an m he sa~e old uevic e of br nch an gro p , l o pr ctice s that ffecti ve contr ol is ielu, -m king, he re son ed about the me n thin d rear nd if they re of preve ntion than ha of circ~ ~rent ion vill be re- et th t branc h banki ng inter est ot subst antia lly eve ner in or er roup banki ng are pf'nn itted vitho ut ·11 ere tric- tock jobbe r o far , app in the futur e, unle~ ~ ore atten tion to the been of 1i tle ef ect . not n remot er ana e er been the ca e tudy re an.v s~ch merit s . h tions , th nich from the o study such activ it1e In the second pl ce, it mu t be obvio us that tne 1 of In a compr ehenv i1e heir true relati onshi p to the real nrrit uming there by such es of capit al stock , e ch nge snare , and the creat ion of intric te corno rate rel t·ons hios, to irst place , the in 11 ornia , for they wanted in the fir t pl ce, ht consum~d in oppo ition have to he t of effec tin t the uthor ties :ere affil i tions a the br· ch ere . ~till a third con~i derat ion iu that ve are not conii ent vhat effec t upon the eser e yste. contin ued conce ntrati on of banki n seems impo~ sible to be as ill hav . 'nd it red on this point until ve knov bette r th n re o -2- ~hat means are possible for insul ting banking fro:n undisira ble corpora te entan,le ment. In 1ie·1 of these conside rations it is believed that the Committee should lay the ground ~ork for future po1icy, by stu~ying affili tions as such-not only to kno, the extent of banking concent ration, but to get organize d infor:natio n on the differen t types of affiliat ion and tneir relative importan ce. C r troll l . 0 b ot ............................ . .. ... . ... . ....... ... .. ... .... . . .. ... . ... . . ... .. . . .. . . .. .......................................... ................................. 1 ............................................ ................... .............................. 0 1 C 0 l C • - - 0 10 . ol 11 . 0 1 . 11 0 olli (c 11 0 (c 0 ( corol l 0 .., 0 0 0 ............... ) ...... -...... . ............. 0 l L 1, 11 , 00 l l 1 l l l ,1 l 0 1, 0 0 ................................ 1 l I ol , 0 l ) .. • .. • • . • ... • • ...... • • • ..... • .... • 2 ) ••••••••• ••••••••• ••••••••• ••••••••• •••• 0 0 C O' 7 Ov 0 l 1 l 0 0 l 0 0 0 . . 1 t ............................. O, l 30 e 0 i - l . controll 2. 0 • 0 it ot 5. 0 it othe 6. o me 7. ome -- 10. s rho e 12 . 13 . 0 0 e t b ub tot l 14. In e endent b ol i il o OU 1 or ot e affiliate ot e s s ( so ( so om other b r 6 i ( 0 r 17 l.J,000 l 12, 7.J l l (coroll .............. 22 ,278 157 ffili tion •••••••••••• l :JOO 5 ................................ ................................................. ?,:, , ·t om) 2 11 3 9 8 ............................. b 200 othe l 0 1 cu i ie ffili o 2) ••••••••••••••••••••••••••••••••••••••• irector r 7 l ) • • • • . • • • ... • . • . • . • • .... • • . • • • • • • • 0 0 th t o • tion c a fili tions (co oll , 60 ................................ COi ins . .•........•............................•.. C ,o s ••••••••••••••••••••••••••••••••••••••••• ctor ... o icors an 0 con troll in n r b oth r baru s (coroll ~anks controllin l nt ot of icor nlcs o mi ll. b n invest b cont ollin 9. o f ili b • toe .......................... . ........................................................ r b ot d t r ot l f, (co ol D 0 ot r .l'1 of 0 3 .. 'l 0 7 ) ••••••••••••• b jthoat b 13 • 7 600 10?, l,l .:i,22 oh s . ...........•....•..•........ 6 8 1 , 1. r. r. rt t101 0 in I- , ' 0 B I- , I • t n • o r , t t 0 • r. ol 1 dl nd thi t b t e t 11 l 1 tt on to • r. • •u •• r . C . B. ond, on is 1' ~ r • :,las ..:cYn ht r. .rs. • i rzo.h ·arie .r . is tr , on , r, 1 11 B. Ha rd ' . I PER.SO 1-JEL I of C TTEE O~ B1u CH, GROUP, , · D ClL 1 de ~on, Elsie B~rnes, Florenc e lattner , J. i. Brooks, Edith Byers, rtulph ¥., Jr. Cleek, Leolc.. Crossm:::n, Betty 1, • D::_ gcf], Olive P. Dowling , Patricia Drain, Thorpe G• .cvans, arie Ferguso n, Ruth (now· Mrs. Ruth Jones) ·~rlock, ichard H. Gree~ Guy E. Hammill , Caroline (now 11rs. Caroline Cagle) Harrnrnnd, C. Brn.y l!.:m.lon, Marie B. Hayward , "illiam B. Johnson , Carol Kuhn, EJ..izabe tl. L ·e, r·-..:.n Laue, Jet •c,rm, Bernice cKnight , Dolas D. u str, Harold B. Mon ay, Jessie Riddle, J. H. aunders , Barbara Seals, Ciladys Stewo.rt , Clara Thompson, l!ifilth Upha1'1, C. B. l'arburto n, Clark iarrm, Charlot te e.;ton, Janet L. "ickens , David L. 'I ills, Hugh E. 1 Br. Kl JG Io I 01: ') K Operations FEDERAL RESERVE BANK OF SAN fRANCISCO anuary- 10, 1951. Dr. Chai c/o , c. ashington, D. D ar Dr. In with th r ques instrL1Ction to typical cs of osing an op o typ cal T op encl d eu n r difficult to o under th , o mto~ s o ~U..l,,L.l.u. etudi though e t ink, fo udy port, tot to tlft~-·~A t to incl ion ( app I purposely omitted 1 tructiona that only n tional it till 1 s po bl to d upo. e or s I f yo xposing er s onf ich will y lur th B hie • ~ fotmd it our ral R ber i F t t have th standard- Our r aining th co Yo v ry t~, r CAGQ 7- 0 0 1- " 7- n 7 " 7- • n 7 If • 7-7 If Bl Pu 7 • " 7- " • ndi mSTRUCTIONS TO FEDERAL RESERVE BANKS FOR SELECTnm AND ANALYZING TYPICAL CAS OF BANKS fflIICH HAVE SUSP DED OPERATIONS. THE PURPOS O THE .ANALYSIS IS1 To ow in concise fo the hi tory ( ained from comment contain din th r port of Exa.min r o er period of y ars) of factor developing 1n the bank hich ultimately 1 d to it su. p n .ion. Th hi tory houl.d commenc t tim the bank w in a atisfactory or fairly- tisf otory condition end b folio d through to it suspension. It 1 in nd d that per on r tain an und rst ding of he problem ding er port should abl to obich con.fronted th bank and to fo therefrom an intelligent opinion of ho it aff irs had been conduct d for t ye immedi t ly pr c ding its sp n ion. ERO C SF.S CTIO c IOD OF S D s lect nin typical c , includin, ne Four or fiv Four or fiv 1925 end 1926; 1927 d 1951. lect Of ch d ich had s und r ov r 1,0 0,000; 1,0 ,o In smuch a O but ot confid nti comm a of Examin r did not of um1nation prior to 19211 it i d ir d (in th ab c oft i ) that bank hich su pend d prior to 1925 b o tt rom t Pr fer b~, th bank 1 cted of a:y 15,000 popul tion or und r. Th lee ion tifi d through th s cotton, i ommunit d c cco p y. the inc of ich could r atiily c ter it community. cc ic garb t ts, and in, l tock or coal mining, ot on ctu loo tion of d rvh pursuits. t r, fi et rt d d ir bl also s,000,000. ituat din town ould Th 1ection should void th inclu ion of th or cquir d th bul!line of another during th It i XC011::>,.u.1..1L~ t hich h d ch V C riod under in op r tion much 1 i tor of£ tor ould clo 1y C • 1 th condit ot follo r ort. GS1 d C Off" i " co ri • tion of it p ' .,. ch lo d oft • wri off of orthl , fumitu r d fixt ~~::iti~~~TS ~:E}K~R'.E SU SIO Th d in ord r B OLDERS& d r tory 1 "# > ,I IBlT 12/1 . .. 0 s 1&30 192 -- •• 9599 14027 10349 (1910 (1920 (1930 C ) ) C ) p 1 • ~1 i , hip • io: et Ui ~ 000 Cap. ~ • Prot • Loans D!l? 11-1 40 l 1963 2591 50 2 4 13 1542 2 15 195 3 4 1614 507 33 15 97 20 20 d in A: 400 9-12-21 Bo 22 1 1 i () io 2 B: 200 40 12 200 40 17 367 73 0 C • ly or lo liar ous -ror bus poli • 4-10-~ 1 r D: 200 40 17 ct 10 t t tatu ory ial * (~ d qu , nnwina direccto , s , t) :;:~·=:U~ iona would b oubttul reco,J111DEmded • -- • . --> -- 12/2 s : •• l 00 192 . 12 2957 ) 245r.. ) ) .£!: • Z-~8-~1 • 00 0 0 50 2 601 1 0 0 BI ,. 12/2 Clas 1f1 d ( 5-8-2 l L 51 .• 57 920 1 0 3 ol r 0 0 1 32 14 1 0 0 10 ~921 0 3 3 - 1922 7 l 1 12 0 2 2 0 0 l 0 0 0 0 2 0 0 2 ry , 1 31. r. I r r. ry ly yo r, UNITED STATES DEPARTME NT OF AGRICULTU RE BUREAU OF AGRICULTURA L ECONOMICS WASHINGTON, 0. C. J :uary 5, 1930. I lr. J. H. Riddle, C/o F deral Reserve Eo rd, a hington, D. c. Dear • Riddle: You ill recall our convers tion in Clevel nd recently in hich I expl ined to you that the Bureau of ricu.ltur l conomics is planning to hold an informal conference t the Co mo Club on Thur y, J nuary 8, t to o'clock, to di cu s condition in foreign countries which are likely to aff ct the denand for rican agricultura l products of 1931. e shall b g d to ve you participate in thi conf rence. The enclosed st tement giv number of topic as ba i for discussion. Individual from the follo ing organizatio ns re bing invited to attend: t nt of ComIOOrc , F deral F m :Bo rd, d r 1 R erve Bo rd, In titut of conomics, nd partment of State. Sincerely youre, closure. Foreign Ash r Hobson, In C rge, ricultur l Service Divi ion. • • - - u ry 2, 1931 • J • . 0 Oun l 11 t • to • on lunch 0 "CL 0 t C in 0 or o t 1 0 lt r t ion. V t ly your ,