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Annual Report 1967

The Administrator of National Banks

William B. Gamp
Comptroller of the Currency
THE UNITED STATES TREASURY, WASHINGTON

For sale by the Superintendent of Documents, TJ.S. Government Printing Office
Washington, D.C. 20402 - Price $1.75

Letter of Transmittal
TREASURY DEPARTMENT,
OFFICE OF THE COMPTROLLER OF THE CURRENCY,
WASHINGTON, D.C.,

AUGUST 15,

1968

SIRS: Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1967 Annual Report of the
Comptroller of the Currency.
Respectfully,
WILLIAM B. CAMP,

Comptroller of the Currency.
T H E PRESIDENT OF THE SENATE
T H E SPEAKER OF THE HOUSE OF REPRESENTATIVES

Contents
Title of Section

I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.

Condition of the National Banking System
Income and Expenses of National Banks
Structural Changes in the National Banking System
Bank Examinations and Related Activities
Litigation
Fiduciary Activities of National Banks
International Banking and Finance
Administrative and Management Developments
Financial Operations of the Office of the Comptroller of the Currency.
Issue and Redemption of Currency

Page

1
3
6
13
14
17
18
20
23
27

Appendices
A. Merger Decisions, 1967
B. Statistical Tables
C. Addresses and Selected Congressional Testimony of William B. Camp,
Comptroller of the Currency
D. Selected Correspondence of the Office of the Comptroller of the
Currency

Index

30
162
220
240

255

Statistical Tables
Page
Table No.
Title
1 Assets, liabilities, and capital account! of National
banks, 1966 and 1967
2 Income and expenses of National banks, calendar
1966 and 1967
3 National banks and banking offices, by States,
December 31, 1967
4 Applications for National bank charters, and charters issued, by States, calendar 1967
5 Applications for conversion to National bank charters, and charters issued, by States, calendar 1967.
6 Branches of National banks, calendar 1967
7 De now hranrh applications of National bank?, by
States, calendar 1967

Table No.

Title

8 De novo branches of National banks opened for
business, by community size and size of bank,
calendar 1967
9 Mergers, calendar 1967
10 Foreign branches of National banks, by region and
country, December 31, 1967
11 Office of the Comptroller of the Currency: balance
sheet, 1966 and 1967
12 Office of the Comptroller of the Currency: statement
of revenue, expenses and Comptroller's equity,
1966 and 1967
13 Office of the Comptroller of the Currency: statement
of source and application of funds, year ended
December 31, 1967

I. Condition of the National Banking System
National banks experienced excellent growth in 1967.
Total assets reached $263.4 billion, an increase of 11.6
percent. This compares with an asset growth of 7.7
percent during 19G6. The gain in liquidity within the
National banking system during 1967 was dramatized
by a larger absolute increase in securities holdings than
in loans: the figures were $12JO billion and $9.9 billion,
respectively. These figures, in turn, represented increases of 20.3 percent for securities and 7.B percent
for loans duiing the year. By year end, securities accounted for 26.5 percent of National banks' total assets, compared with 24.4 percent a year earlier. Meanwhile, the proportion of loans to total assets declined
from 53.8 percent to 51.9 percent The differential
rates of growlh for securities and for loans were in
sharp contrast to the 1966 picture, when loans and
discounts increased by 8.6 percent, while securities increased by only 0.6 of 1 percent.
Within the securities category, for the second straight
year holdings of securities of Federal agencies and corporations showed the highest rate of increase, 59.9
percent in 1967. However, the absolute total of these

holdings, $4.8 billion, remained small relative to year
end totals of $34.3 billion for U.S. Governments and
$29.0 billion for State and local obligations. National
bank holdings of the latter increased by 22-0 percent
duiing 1967, while the increase in U.S. Governments
was 13.0 percent.
Total deposits of National hanks increased by $24.9
billion, or 12.1 percent during 1967. Of this increase,
$10.7 billion was in demand deposits and $14.3 billion
in time and savings deposits. As has been the case in
recent years, the rate of growth in time and savings
deposits. 15.2 percent, exceeded the 9.5 percent figure
for demand deposits. At year end, total time and savings deposits equalled 46.8 percent of total deposits;
the comparable figures were 45.6 percent at the end of
1966, 44.4 percent in 1965, and 41.8 percent in 1964.
The total capital accounts of National banks showed
a 6.9 percent increase during 1967, compared with a
5.9 percent increase in 1966. Total capital of $19.7
billion yielded a capital-to=assets ratio of 7.49 percent
at year end, compared to 7.82 percent at the end of
1966.

TABLE I
Assets, liabilities, and capital accounts of National banks, 1966 and 1967
pDollcir amounts in millions]
Dec. 31, 1966,
4,799 banks
Amount

Percent

Dec. 31, 1967,
4,758 banks
Percent
distribution

Amount

distribution

Change, 1966-67

Amount

Percent

ASSETS

Cash, balances with other banks, and cash items in process
of collection
U.S. Government obligations
Obligations of States and political subdivisions
Securities of Federal agencies and corporations
Other securities
Total securities.,
Federal funds sold and securities purchased under agreements to resell
Direct lease financing
Loans and discounts
Fixed assets
Customers' liability on acceptances outstanding
Other assets
Total assets.

$41, 690

17.67

$46, 634

17.71

$4, 944

11.86

30, 355
23, 778
3,026
509

12.86
10.08
1.28
.22

34,308
29, 002
4,838
1,508

13.03
11.01
1.84
.57

3,953
5,224
1,812
999

13.02
21.97
59.88
196.27

57, 668

24. 44

69, 656

26.45

11, 988

2,301
331
126,881
3,451
1,077
2,597

.97
.14
53.76
1.46
.46
1.10

2,562
412
136, 753
3,876
1, 182
2, 300 i

.97
.16
51.92
1.47
.45
.87

261
81
9,872
425
105
—297

11.34
24.47
7.78
12.32
9.7*
-11.44

235, 996

100.00

27, 379

11.6C

263,375

LIABILITIES

Demand deposits of individuals, partnerships, and
corporations
Time and savings deposits of individuals, partnerships,
and corporations
Deposits of U.S. Government
Deposits of States and political subdivisions
;••;•••
Deposits of foreign governments and official institutions,
central banks, and international institutions
Deposits of commercial banks
Certified and officers' checks, etc.
Total deposits
Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Acceptances executed by or for account of reporting banks '
and outstanding
Other liabilities
Total liabilities.

!
:
84,434 !

35.78

92,686 ;

35.19

8,252

9.77

83,025 !
3,212 !
16, 839

35.18
1.36
7.13

95, 104
3,297
18,511

36.11
1.25
7.03

12, 079
85
1,672

14.55
2.6f
9.92

2,944
12, 595
3,407

1.25
5.34
1.44

3,483
13, 963
4,330

1.32
5.30
1.65

539
1,368
923

18.31
10.86
27.0E

206, 456

87.48

231, 374

87. 85

24, 918 •

112, 377
94, 079

47.62
39.86

123, 038
108, 336

46.72
41.13

10, 661
14, 257

9.41
15.11

2,802
174

1.19
.07

3,182
297

1.21
.11

380
123

13.56
70.6<

1,105
7,000

47
2 97

1,205
7,587

.46
2.88

100
587

9 .0^
8 .3i

217,537

92. 18

243, 645

92.51

26, 108

12 .0(

1,161
29
5,109
8,246
3,350
564

.49
.01
2.17
3.49
1.42
.24

1,235
55
5,312
8,832
3,549
747

.47
.02
2.02
3.35
1.35
.28

74
26
203
586
199
183

18,459

7.82

19,730

7.49

1,271

235,996

100.00

263,375

100.00

27,379

CAPITAL ACCOUNTS

Capital notes and debentures. .
Preferred stock
Common stock
Surplus
Undivided profits
Reserves
Total capital accounts
Total liabilities and capital accounts.

\
i
i
:

6.3;
89.6(
3.9;
7.1]
5.9^
32.41
6.81

II. Income and Expenses of National Banks
The principal influences on 1967 operating results
of National banks were the significant relative shift
from loans to securities, the high rates prevailing on
both securities portfolios and loans, and continued upward pressure on operating expenses, notably interest
paid on time and savings deposits. Net income after
taxes reached $1.76 billion, an increase of 11.1 percent
from 1966.
Current operating revenue showed a 11.9 percent
increase, to $12.7 billion. With current operating expenses rising by 14.2 percent, the gain in net current
operating earnings was pared to 5.0 percent. Of the
major revenue accounts, interest on U.S. Governments
increased by 13.7 percent, while interest and dividends
on other securities spurted by 24.5 percent. The latter
reflected the significant additions to bank holdings,
as well as higher interest received. Interest and discount
on loans moved up by $881.1 million, equalling an
11.6 percent increase. The proportion of National
banks' 1967 current operating revenue accounted for

by loan income declined very slightly from the 1966
figure, 66.9 percent compared to 67.0 percent.
On the expense side, $685 million of the $1.2 billion increase in total operating expenses was accounted
for by interest paid on time and savings deposits. The
fraction of total expenses represented by interest paid
on deposits has increased steadily in recent years; from
38.2 percent in 1964, it has mounted steadily to 41.6
percent in 1965, 44.0 percent in 1966, and 45.6 percent in 1967. Of the other major expense items, employees' salaries and wages increased by 12.3 percent
and officers' salaries by 9.6 percent over the previous
year.
The below-the-line adjustments—recoveries, chargeoffs, profits and losses on securities sales, and transfers
to and from valuation reserves—resulted in a net deduction of $518 million from total net operating earnings of $2.96 billion, leading to before-tax net income
of $2.44 billion. Deduction of $680 million in Federal
and State income taxes led to net income of $1.76
billion.

TABLE 2
Income and expenses of National banks,* calendar 1966 and 1967
[Dollar amounts in millions]
1967

1966
Amount

Number of banks
Current operating revenue:
Interest and dividends on—
U.S. Government obligations
Other securities
Interest and discount on loans t .
Service charges and other fees on banks' loans
Service charges on deposit accounts
Other charges, commissions, and fees
Trust department
Other current operating revenue
Total current operating revenue

Current operating expenses:
Officers' salaries
Employees* salaries and wages
Officer and employee benefits
Fees to directors
Interest on time and savings deposits
Interest and discount on borrowed money %
Net occupancy expense of bank premises
Furniture and equipment—depreciation and other
costs
Other current operating expenses
Total current operating expenses

Net current operating earnings
Recoveries, transfers from valuation reserves, and profits:
On securities:
Profits on securities sold or redeemed
Recoveries
Transfers from valuation reserves.
On loans:
Recoveries
Transfers from valuation reserves
. .
All other
Total recoveries, transfers from valuation reserves, and
profits

Losses, chargeoffs, and transfers to valuation reserves:
On securities:
Losses on securities sold
Chargeoffs on securities not sold
Transfers to valuation reserves
On loans:
Chargeoffs
Transfers to valuation reserves
All other
Total losses, chargeoffs, and transfers to valuation reserves.

Net income before related taxes
Taxes on net income:
Federal
State
Total taxes on net income..

See footnotes at end of table.

Percent
distribution

4,799

Amount

Change,

Percent
distribution

Amount

1966-67
Percent

4,758

$1,231.8
901.1
7, 577. 8
135.2
532.6
194.9
395.3
336.7

10.89
7.97
67.03
1.20
4.71
1.72
3.50
2.98

$1,401.0
1,122.0
8, 458. 9
169.5
576.8
230.0
435.3
257.4

11.07
8.87
66.86
1.34
4.56
1.82
3.44
2.04

$169. 2
220.9
881. 1
34.3
44.2
35. 1
40.0
-79.3

13.74
24.51
11.63
25.37
8.30
18.01
10. 12
- 2 3 . 55

11,305.4

100.00

12, 650. 9

100.00

1, 345. 5

11.90

822.9
1,489. 9
351.2
39.9
3, 733. 0
53.6
449.6

9.69
17.55
4. 13
.47
43.96
.63
5.29

901.7
1 673. 1
391.2
43.3
4, 418. 0
153.8
489.4

9.30
17.26
4.03
.45
45.57
1.58
5.05

78.8
183.2
40.0
3.4
685.0
100.2
39.8

9.58
12.30
11.39
8.52
18.35
186. 94
8.85

271.5
1, 280. 2

3.20
15.08

313. 1
1,311.8

3.23
13.53

41.6
31.6

15.32
2.47

8, 491. 8

100. 00

9, 695. 4

100. 00

2, 955. 5

2,813. 6

1, 203. 6

14. 17

141.9

5.04

38.0
3.3
79.5

16.62
1.44
34.78

91.2
2.6
36.7

36. 10
1.02
14.53

53.2
-.7
-42.8

140.00
-21.21
- 5 3 . 84

7.2
40.2
60.4

3. 15
17.59
26.42

6 7
28.7
86.7

2 64
11.36
34.35

-.5
-11.5
26.3

— 6.94
- 2 8 . 61
43.54

228.6

100.00

252.6

100. 00

24.0

10.50

252.5
4.7
53.5

29.61
.55
6.28

76.0
4.5
52.2

9.86
.58
6.77

-176.5

- 6 9 . 90
-4.26
-2.43

15. 1
435.5
91.3

1.77
51.08
10.71

13.6
519.0
105.4

1.76
67.35
13.68

852.6

100.00

770.7

100.00

-L3
-1.5
83.5
14. 1

-9.93
19. 17
15.44

-81.9

-9.61

2, 189. 6

2, 437. 4

247.8

11.32

545.6
61.4

594 0
85.9

48.4
24.5

8.87
39.90

607.0

679.9

72.9

12.01

Income and expenses of National banks,* calendar 1966 and

1967—Continued
1967

1966
Amount

Net income
Dividends on capital:
Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared

Net income after dividends
Occupancy expense of bank premises:
Officers' salaries
Employees' salaries and wages
Officer and employee benefits
Recurring depreciation on bank premises and leasehold improvements
Maintenance, repair, and uncapitalized alteration
costs of bank premises, and leasehold improvements
Insurance, utilities, etc
Rents paid on bank premises.
. .
Taxes on bank premises and leasehold improvements

Percent
distribution

Amount

Change,

Percent
distribution

Amount

1966-67
Percent

$1, 582. 6

$1, 757. 5

$174. 9

11.05

736 6
1.4

794. 1
2. 1

57.5
.7

7.81
50.00

738.0

796.2

58.2

7.89

844.6

961.3

116.7

13.82

1.9
58.8
7 7

.33
10.39
1.36

2.1
62.1
8. 1

.35
10. 16
1. 33

.2
3.3
.4

10.53
5.61
5. 19

107.4

18.97

115.4

18.88

8.0

7.45

67.4
94.9
143.0

11.90
16.77
25.27

78.4
100.3
156.2

12.82
16.40
25.56

11.0
5.4
13.2

16.32
5.69
9.23

84.9

15.01

88.6

14.50

3.7

4.36

566.0

100. 00

611.2

100.00

45.2

7.99

111.5
4.9

19.69
.88

116.3
5.5

19.04
.90

4.8
.6

4.30
12.24

Total

116.4

20.57

121.8

19.94

5.4

4.64

Net occupancy expense

449.6

79.43

489.4

80.06

39.8

8.85

Gross occupancy expense

Less:
Rental income from bank premises
Other credits

Recoveries credited to valuation reserve (not included in
recoveries above):
On securities
On loans
.
Losses charged to valuation reserves (not included in
losses above):
On securities
Stock dividends (increases in capital stock)

2.3
93.4

3.8
105.8

1.5
12.4

65.22
13.28

45.5
326 4
119. 2

69.1
378.2
160.9

23.6
51.8
41.7

51.87
15.87
34.98

Ratio to current operating revenue:
Interest on time and savings deposits
All other current expenses
Total current expenses

Net current earnings
Employees at year end:
Building occupancy and maintenance:
Officers
Other employees
Banking operations:
Officers
Other employees

Percent

20.81
33.02
21.28

20 70
34. 92
21.02

75.11

76.64

24.89

23.36

Number
179
17 691

Number
274
17, 730

95
39

53.07
.22

72, 092
346,817

75, 808
369, 780

3,716
22, 963

5. 15
6.62

•Includes all banks operating as National banks at year end, and full year data for those State banks converting to National
banks during the year.
flncludes revenues from the sales of Federal funds.
j Includes expenses incurred in purchasing Federal funds.

III. Structural Changes in the National
Banking System
There were 4,758 National banks in operation at the
end of 1967. While this figure was slightly less than
the number of National banks in operation at the end
of 1964, the number of National banking offices
spurted from 12,733 to 14,747 during the same 3 years,
a rise of almost 16 percent. As of December 31, 1967,
the 9,989 branches of National banks were operated
by 1,477 banks, while the remaining 3,281 National
banks were unit banks.
During 1967, charters were issued for 18 newly organized National banks. These were distributed among
nine States, with Wisconsin receiving four, New York
and Florida three each, and Georgia and Kansas two
each. Nine charters were issued allowing the conversion of State banks to National banks. These cases were
scattered among nine different states.
The year saw 650 branches initially opened for busi-

ness as National bank branches. This total included
502 de novo branches and 148 branches of newly converted banks and banks acquired via merger. The net
increase in National bank branches was 583 during
the year, as 67 branches were closed or consolidated.
Of the 502 de novo branches, 295, or about 59 percent,
were located in communities with a population of less
than 25,000, and 139, or 28 percent were in communities with less than 5,000 population. The 502 de
novo branches included 185, or 37 percent, opened by
banks with less than $25 million in total resources.
Banks with $1 billion or more in assets accounted for
103 branches, or 20 percent, of the total.
During 1967, there were 84 bank mergers, consolidations, and purchases in which a National bank was
the resulting bank. This figure may be compared with
75 in 1966 and 76 in 1965.

TABLE 3
National banks and banking offices, by States, Dec. 31,

1967

National banks
Number of

Number of

offices

branches

Total
United States
Alabama
Alaska
Arizona
Arkansas .
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
.

. . .

Maryland
Massachusetts
Minnesota....
Mississippi
Missouri
Montana
Nebraska
Nevada
.
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
West Virginia
Wisconsin
Wyoming
Virgin Islands
District of Columbia—all*

. .

With branches

Unit

4,758

3,281

1,477

9,989

14, 747

88
5
4
67
80
118
30
5
9
200

36
5
3
31
53
0
22
2
8
0

151
41
185
70
1,903
0
189
4
54
0

239
46
189
137
1,983
118
219
9
63
200

137
41
102
8
285
43
25
122
148
76

198
43
111
430
408
145
196
202
195
97

o1
36
27
118
8
3
1
200

61
2
9
422
123
102
171
80
47
21

414
54
65
146
39
15
6

29
2
6
8
69
37
25
41
32
15

48
89
98
195
36
98
48
127
3
52

18
21
31
193
7
79
47
109
1
30

30
68
67
2
29
19
1
18
2
22

207
372
490
6
109
19
1
18
37
29

255
461
588
201
145
117
49
145
40
81

144
34
184
25
42
223
220
12
336
4

36
14
83
7
33
89
190
7
182
0

108
20
101
18
9
134
30
5
154
4

496
59
1,078
292
9
606
30
220
885
56

640
93
1,262
317
51
829
250
232
1,221
60

26
35
77
542
12
27
113
27
80
116
40
1

4
25
20
542
8
13
36
12
80
104
40
0

22
10
57
0
4
14
77
15
0
12
0
1

209
48
242
0
56
38
396
370
0
24
0
3

235
83
319
542
68
65
509
397
80
140
40
4

105

•Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

TABLE 4
Applications for National bank charters,* and charters issued,* by States, calendar 1967
Received}

United States
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Puerto Rico

•Excludes conversions.
flncludes 20 applications pending as of Dec. 31, 1966.

Approved

Rejected

Abandoned

Pending
Dec. 31, 1967

Charters
issued

TABLE 5
Applications for conversion to National bank charters, and charters issued) by States, calendar 1967
Received*

United States
Alabama
Alaska..
Arizona..
Arkansas
California....
Colorado
Connecticut
Delaware.
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa.
Kansas.
Kentucky..
Louisiana. .
Maine

. .

Approved

o
o1

0
2
0
0
0
0

0
1
0

o
o
o
o0

0
0
0
0
0
0
0
0
0
0

1
0
0
1
0

0
0
0
0
1

0
0
0
0
0

0
0
0
0
1
0
0
0
0
0

0
0
0
1
0
0
0
0
0
0
0
0
0
1
0
0
0
1
0
0

0
0
0
0
0
0
0

0
0
0
0
0

0
0

o
o0
0

0
0

4
1
1

0
0
0

0
0
1

0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0

0
0
0
0
0

New Jersey..
New Mexico...
New York
North Carolina
North Dakota
Ohio
Oklahoma.
Oregon.
Pennsylvania
Rhode Island

1
0
1
1
0
1
0

0
0

1
0

0
0

South Carolina
South Dakota
Tennessee
Texas.
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming.

0
1
00

0
0
0

ooooo

— oooo

0
0
0

ooooo

1
01
1
0

o
o

0
0
0

ooooo

0
0
0
1
0
0
4
1
1
0

— oooo

0
0
0
1
0

•Includes four applications pending as of December 31, 1966.

Charters
issued

0
0

Pending
Dec. 3U 1967

o
o0

Maryland
Massachusetts
Michigan. . .
Minnesota
Mississippi
Missouri
Montana....
Nebraska. . .
Nevada
New Hampshire

Abandoned

Rejected

0
0
0

0
0
0
0

0
0
1
1
0
0
0

0
0
0

0
1
00
0
0

0
0
0
0
0

TABLE 6
Branches of National banks, calendar 1967

Branches in
operation
Dec. 31, 1966

United States
Alabama....
Alaska
Arizona
Arkansas
California
Colorado..
.
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas .
Kentucky.
Louisiana
Maine

. .
. .

....

De novo branches Branches ac- Existing branches
opened/or
Branches in
quired through discontinued or
consolidated
operation
business Jan. 1— merger or conJan. 1Dec. 31, 1967
Dec. 31, 1967 version Jan. 1—
Dec. 31, 1967 Dec. 31, 1967

'9,406

502

148

9, 989

137
42
182
62
1,791
0
179
4
53
0

7
106
0
11

1
23

0
1
0
0
17

151
41
185
70
1,903

oo
o
0

o1
o
0

o
189
4
54
0

3
2
0

0
4
4
0
4
0
1
0
0
0

0
3
5
0
0
1
0
2
0
0

207
372
490
6
109
19
1
18
37
29

25
5
32
16
1
31
3
4
33
2

17
0
37
9
0
6

5
0
6
8
0
1
0
1
4
0

496
59
1,078
292
9
606
30
220
885
56

191
42
226

17
2
16

3
4
1

2
0

o
55
33
369
r 352
0
24
0
3

oo
3

209
48
242
0
56
38
396
370
0
24

267
38
25
120
145
71

Maryland
Massachusetts
Michigan......
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

196
351
'459
6
96
19

11
20
32
0
9
1

o
18
36
26

New Jersey...
New Mexico
New York.
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

459
54
1,015
275
8
570
27
217
840
54

. .

South Carolina
South Dakota
Tennessee
Texas....
. .
Utah
Vermont....
Virginia
Washington
West Virginia
Wisconsin.......................
Wyoming
Virgin Islands
District of Columbia—all*

...
...

1
3

2
18
15
0

oo
o
0
2
0
0

0
16

o1
0

o
0
0
0

9
3
0
0
0
0

0
0
0
0

OCO

2
8
19
3
1
5
5
5

137
41
102
8
285
43
25
122
148
76

127
41
101

•Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
r
Revised.

TABLE 7
De novo branch applications of National banks, by States, calendar 1967
Approved

United States

Rejected

Pending
Dec. 31, 1967

1,012
18
2
12
10
153
0
16
0
3
0

2
0
0
1
35
0
3
0
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

11
3
6
26
25
9
3
10
15
6

3
0
2
3
3
3
0
2
3
0

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

35
27
70
0
14
1
0
1
3
9

5
5
13
0
5
0
0
1
0

New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

35
2
110
31
4
59
7
19
75
3

South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin.
Wyoming
Virgin Islands

21
3
11
0
3
0
28
33
0
80
0
0

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida

0
28
12
6
1
8
8
0
4
0
3
0
1
0
7
8
0
74
0
0

District of Columbia—allf
•Includes 263 applications pending as of Dec. 31, 1966.
f Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of
the Currency.

TABLE 8
De novo branches of National banks opened for business, by community size and by size of bank, calendar 1967
Category

Category

In cities with population:
Less than 5,000
5,000 to 24,999
25,000 to 49,999
50,000 to 99,999
100,000 to 249,999
250,000 to 499,999
500,000 to 1,000,000
Over 1,000,000

139
156
69
42
31
28
17
20

Branches

By banks with total resources (in millions of dollars):
Less than 10.0
10.0 to 24.9
25.0 to 4 9 . 9 . . . .
50.0 to 99.9....
100.0 to 999.9..
Over 1,000.0...

502

Total.

502

Total.

TABLE 9
Mergers*

calendar 1967

Applications carried over from 1966
Applications received 1967
Disposition of applications 1967:
Approvedf
Disapproved
Withdrawn
Applications pending December 1967
Transactions completed 1967:
Mergers
Consolidations
Purchase of assets

14
85
75
1
4
19
68
6
10

Total

The aggregate total of capital stock and capital accounts for the certificates issued are as follows:
Charter or
purchasing bank

Capital stock
Capital accounts

$302,209,707
1, 229, 465, 703

Merging, consolidating, or
selling banks

$62,211,285
209, 721, 811

Combined

$350,620,001
1, 413, 856, 951

•Includes mergers, consolidations, and purchase and sale transactions, where the resulting bank
is a National bank.
f Includes three applications approved in 1967, which were abandoned: one in 1967, two in 1968.

83
102
47
37
130
103

IV. Bank Examinations and Related Activities
The National Bank Act requires that each National
bank be examined twice in each calendar year, but the
Comptroller, in the exercise of his discretion, may
waive one such examination in a 2-year period or may
cause such examinations to be made more frequently
if considered necessary. In addition, the District Code
authorizes the Comptroller to examine each nonNational bank and trust company in the District of
Columbia.
During the year ended December 31, 1967, 6,579
examinations of banks, 10,399 examinations of
branches, 1,570 examinations of trust departments and
trust branches, 132 examinations of affiliates, and 286
special examinations and special visitations were conducted. Three State banks were examined in connection with conversions to National banks. Investigations
were conducted in connection with applications for
44 new charters and 651 new branches. Furthermore,
examinations included direct verification of a substantial percentage of loan and deposit accounts in banks
where internal controls were deemed inadequate.
In 1967, the examination division was active in
developing and adopting new examining procedures
in response to the ever changing techniques of modern
banking. To assist in the administration of these new
procedures and to upgrade the quality of our examinations, the Washington reviewing staff was increased
significantly to provide closer supervision over the field
force.
The examination report was enlarged to include sections relating to credit card programs and other revolving credit plans not operated as part of a credit card
program. Another section, dealing with security and
controls against external crimes, was developed late in
1967 and will be included henceforth in the examina-

tion report. New procedures for the examination of
automated banks were adopted, including the implementation of an electronic data processing report of
examination and an examination report for National
banks receiving EDP servicing. The examination staff
was strengthened by the training of 28 specialists whose
primary responsibility is to conduct separate examinations of electronic data processing installations.
On May 1, 1967, the Office of the Comptroller of
the Currency placed into effect an accounting regulation for National banks (formally known as Part
18—Form and Content of Financial Statements).
The regulation requires that every bank under the
jurisdiction of the Comptroller of the Currency must
submit an annual report to its shareholders. The regulation prescribes a detailed format for a balance sheet,
statement of earnings, reconcilement of capital accounts, and reconcilement of reserves which must be
incorporated in the annual report to shareholders. It
also specifies a number of accounting methods and
procedures to be used in maintaining records and preparing reports.
The regulation not only encourages accrual accounting for National banks, but establishes a timetable
which will place all National banks with resources of
$25 million or more on an accrual basis of accounting
by 1970. Accounting authorities are convinced that
accrual accounting offers a more accurate and more
refined picture of a bank's operations than does the
cash accounting method.
The rationale underlying the regulation is that shareholders of all National banks are entitled to obtain that
basic financial information necessary to evaluate the
operations and the condition of the institutions in
which they have invested funds.

V. Litigation
In 1966, Congress enacted the Financial Institutions
Supervisory Act, Public Law 89-695. The provisions
of Title II of that Act, which amended sections 1818
(a), (b), and (c) of Title 12 of the United States
Code, are effective until June 30,1972. By such amendments, Congress expanded the authority of the Federal
banking supervisory authorities to enforce their regulatory determinations. To implement the statute, the
Law Department formulated the "cease and desist"
regulations, which were published on August 1, 1967.
The statute and regulations enable the Comptroller's
Office, subject to judicial review, to enjoin unsafe and
unsound banking practices and to initiate proceedings
to remove bank officers and directors who have engaged
in certain prohibited activities. Forms and documents
have been prepared for use under the cease and desist
procedures.
During calendar year 1967, 16 new cases were
filed challenging administrative actions and rulings of
the Comptroller. Forty-nine such cases were already
pending prior to January 1, 1967, of which 22 had
been decided or otherwise settled as of December 31,
1967. The number of pending cases as of December 31,
1967 totaled 43.

A. Incidental Powers Cases
A significant group of cases involve the incidental
powers of National banks. These powers are derived
from 12 U.S.C. § 24 (seventh) and the Comptroller's
regulations and rulings promulgated pursuant thereto.
Specifically there are court challenges to a National
bank's operation of a travel agency, the sale to its
customers of electronic data processing services, the sale
of insurance incidental to banking transactions, and
to the operation of armored car messenger services.
Arnold Tours v. Camp and South Shore National
Bank (D Mass., Civ. No. 67-372-C) involves the incidental power of a National bank to operate a travel
agency. This case is scheduled for argument before the
District Court in March 1968. The Comptroller is
contending that the plain tiff-travel agencies lack standing to sue because no statute gives them the right to

be free from competition and, even if they do have
standing, undisputed facts establish that the operation
of a travel agency is a historic function as well as an
incidental power of National banks.
Two cases, Association of Data Processing Service
Organizations, Inc. v. Camp and American National
Bank and Trust Co. (USDC D Minn., Civ. No. 3-67165) and Wingate Corporation v. Industrial National
Bank of Rhode Island (USDC D R.I., Civ. No. 3847),
challenged the banks' electronic data processing services as not being properly incidental to the banking
business. These services are made available to bank
customers on the computer time in excess of that required for the completion of the bank's internal check
processing, bookkeeping, payroll and other programs.
As of December 31, 1967, no court had ruled on the
merits of either of these cases.
In Georgia Association of Independent Insurance
Agents, Inc., et al. v. Camp (U.S. Ct. of App., 5th Cir.,
Civ. No. 25060), the lower court rendered a decision
adverse to the Comptroller's position that a bank may
act as agent for the sale of insurance incidental to banking transactions. Mortgage insurance and credit life
typify the kinds of insurance that National banks offer
their customers in connection with making a loan. The
effectiveness of the lower court's judgment has been
stayed pending appeal.
Dickinson v. First National Bank in Plant City and
Camp (U.S. Ct. of App., 5th Cir., Civ. No. 25173)
involves a challenge to the operation by the bank of an
armored car messenger service as illegal branch banking in Florida. The Comptroller authorized such services as a proper incidental power of National banks and
contended that armored car messenger services did not
violate the Florida statutory prohibition against branch
banking. The lower court supported the Comptroller's
position and the State Comptroller has appealed that
decision to the 5th Circuit Court of Appeals.

B. Bond Underwriting
The Comptroller's Investment Securities Regulation
which ruled that certain securities were eligible for pur-

chase, dealing in, underwriting, and unlimited holding
by National banks was challenged by a number of
investment bankers in Baker, Watts & Co., et al. v.
Camp (USDC D.C. Civ. No. 97-66). The district
court granted the investment bankers' motion for summary judgment, and held that the pertinent legislation
was intended to divorce commercial banks from the
business of underwriting and dealing in the securities
in question. By agreement of the parties, the Comptroller's appeal from that decision was dismissed on
May 24, 1967. The Port of New York Authority, intervenor on the side of the Comptroller in the court below,
has continued to prosecute the appeal.

C. Collective Investment Funds
On September 27, 1967, the District Court for the
District of Columbia handed down a decision adverse
to the Comptroller in Investment Company Institute,
et al. v. Camp (U.S. Ct. of App., D.C. Civ. No. 108366). The plaintiff, an association representing openend investment companies and investment advisors,
filed suit to enjoin the Comptroller from authorizing a
National bank collectively to invest funds tendered to
it, as managing agent solely for investment purposes.
The court held that the plaintiffs had standing to sue
the Comptroller and further that relevant statutes prohibited the operation of the funds in question. This
decision is being appealed.

D. New Bank Charter Cases
The following pending cases challenge the exercise of the Comptroller's discretion in approving new
bank charters: Warren Bank v. Camp, (U.S. Ct. of
App., 6th Cir., Civ. No. 17718 and 17719), and First
National Bank of Abbeville, et al. v. Camp, (USDC
WD Louisiana, Civ. No. 12158). In Citizens Bank of
Hattiesburg v. Camp (USDC SD Miss., Civ. No.
1998), the District Court upheld the Comptroller's
position and dismissed the action. On appeal, the 5 th
Circuit Court of Appeals on December 4, 1967,
affirmed.

E. Branch Cases
The U.S. Supreme Court rendered a decision in
Walker Bank & Trust Co. v. Saxon and First National
Bank of Logan and Commercial Security Bank v.
Saxon (384 U.S. 925). The court held that the Utah
statute, prescribing that all banks in the State, with
certain exceptions, may branch only by merger, applied
to National banks and that the Comptroller must, in

approving branches in Utah, follow the State law in
that respect. The broader implications of this decision
are being tested in pending branch cases in the lower
courts throughout the country. A total of 16 cases involving branch approvals by the Comptroller of the
Currency are now pending. The majority of these challenge the Comptroller's action on the grounds that the
Federal branching statute (12 U.S.C. § 36), as it incorporates State law has been violated or that the
Comptroller has abused his discretion in determining that the need and convenience of the community
will be served by the new branch.

F. Merger Litigation
This was the most active year in bank merger litigation in the history of the Comptroller's Office.
The Comptroller was a party to each of five merger
cases involving National banks during 1967. Two cases
were decided by the Supreme Court: one argued before the Supreme Court, with decision pending; one
decided in favor of the banks and the Comptroller by
a three-judge court in San Francisco; and, one tried
before the District Court in Philadelphia, with decision pending. The Comptroller's position in these cases,
generally, was that the Bank Merger Act of 1966 made
substantive changes in the standards to be applied by
the courts to bank mergers, and, specifically, that each
challenged bank merger was not anticompetitive in
effect, and, alternatively, that anticompetitive effects
were clearly outweighed in the public interest by the
probable effects of the transaction in meeting the convenience and needs of the community to be served.
On March 27, 1967, the Supreme Court delivered
its opinion in two bank merger cases which had been
dismissed by the District Courts on the ground that
the Justice Department had failed to plead the Bank
Merger Act of 1966. In remanding both cases, United
States v. First City National Bank of Houston et al.
and United States v. Provident National Bank et al.,
386 U.S. 361, the Court decided that in a suit under
the Bank Merger Act of 1966 the Justice Department
may properly plead a violation of the traditional antitrust laws, but that the affirmative defense of "convenience and needs" under the Bank Merger Act of
1966 is available to the defendants. This means that
after proof of a violation of section 7 of the Clayton
Act, the burden shifts to defendants to prove that the
convenience and needs of the community clearly outweigh any anticompetitive effects of the merger. The
Supreme Court also held that the Comptroller's reasons
for approving a merger may be found to be "well-nigh
15

conclusive" by a District Court, but that the ultimate
judgment as to a merger's legality rested in the court
rather than the agency. United States v. First City
National Bank of Houston, 386 U.S. 361.
Subsequently, in a per curiam opinion the Supreme
Court also remanded to the District Court the case of
U.S. v. Mercantile Trust Company, N.A., and Security
Trust Company (USDC ED Missouri C.A. No.
656-241 (1)) to be tried pursuant to the procedural
rules set forth in the Houston case. This case is calendared for trial on March 11,1968.
The remanded case of United States v. Provident
National Bank et al. (USDC ED Pa. C.A. No.
40032) was the second to be fully tried under the
Bank Merger Act of 1966. The trial lasted approximately 7 weeks, between July 11, 1967 and August
23, 1967. Oral argument was made on December 6,
1967. Two Philadelphia banks are involved in this
case.
On October 30, 1967, a three-judge district court
handed down the decision in United States v. CrockerAnglo National Bank et al, 1967 Trade Cases paragraph 72,258. In upholding the merger, the court
found that no competition existed between the merging banks, and that prospective competition by de novo
branching was improbable. The court stated that all
competing financial institutions must be considered in

evaluating the effect of the merger on competition,
although no anticompetitive effects would occur even
if competition were restricted to commercial banks.
Finally, the court found that the merger would prove
beneficial to the State of California, the community
to be served, and would create a bank better able to
compete with Bank of America, N.A., particularly,
and other statewide banks.
On December 11, 1967, the Supreme Court heard
arguments on the appeal of United States v. Third
National Bank of Nashville et al, 260 F. Supp. 869
(1966), the first case to be fully tried under the Bank
Merger Act of 1966. The District Court had approved
the merger, citing lack of competition between the
merging banks and the overriding benefit to the community to be served by the merger. Among the issues
which will be decided by the Supreme Court, and
which will have a significant impact on all future bank
mergers and those presently in litigation, are the following: (1) whether, in determining the effect of a
merger upon competition, all competing financial institutions must be considered; and, (2) whether a
merging bank is required to seek out and consummate
only the least anticompetitive merger available. It is
expected that the court's decision in this case will be
handed down early in 1968.

VI. Fiduciary Activities of National Banks
The trust departments of the National banks experienced continued growth in numbers of fiduciary accounts in 1967, although market values of assets held
continued to reflect the uncertainties of the stock market. During the year, 50 applications for permits to
exercise fiduciary powers were received from National
banks, and 29 were approved. This increased the number of National banks authorized to exercise fiduciary
powers to 1,908 by year end. The number of fiduciary
accounts, and the diversity of assets held in fiduciary
accounts continued to increase, with a corresponding
rise in the workload in the examinations conducted
by this Office.
In this context, the Comptroller's Office continued
its efforts to improve the quality and efficiency of trust
department examinations. Provision was made to examine extremely small departments simultaneously
with the examination of the commercial side of the
banks, and a short form of examination report was
adapted for use in these departments. Detailed instructions were issued, outlining step-by-step the procedure
for the examination of smaller departments, thus providing a useful supplement to the more general Manual
of Instructions by focusing in specific detail upon those
types of situations most likely to prevail.
Greater efficiency in the handling of trust department examination reports was achieved through
transferring from the regional offices to the Washington Office, responsibility for review and initiation
of corrective actions. This eased implementation of
policy changes and resulted in a more uniform application of existing precedents.
In April, a 2-week school was held in Washington
for new trust examiners. An intensive course of instruction was provided on all facets of trust department
operation through lectures and discussions conducted
by recognized banking authorities. In addition, practical problems were presented by members of the

Comptroller's staff. In response to an invitation extended to the State banking supervisors, examiners
from the States of Michigan, Wisconsin, Iowa, Arizona,
Illinois, New York, North Carolina, and Pennsylvania
attended the school.
A workshop was conducted in Washington in October for the senior trust examiners from each region.
The primary purposes were to achieve greater uniformity in examination procedures, to discuss means
of improving examination techniques, and to share
methods of dealing with novel problems. During 1967,
four persons were promoted to the position of Representative in Trusts, the highest level of qualification for
trust examiners, and eight persons were advanced to
the intermediate position of Associate in Trusts. The
requirements for advancement to the Associate position were made more rigorous, and a new testing procedure was initiated.
This Office noted a continuing trend toward the
wider application of computers and other aspects of
automation technology. Although our trust examiners
must be familiar with the capabilities of those systems
in fiduciary applications, they are assisted in their evaluation by examiners specially trained in automation
techniques, who work with both commercial and trust
examiners. Progress was made during the year toward
the realization of the goal of evaluating all automatic
trust accounting systems as systems. This objective is
supplemental to, but has an important bearing on, the
primary purpose of the examination process, which
is to assure that all fiduciary activities are carried out
in accordance with applicable legal requirements and
sound fiduciary principles.
The Office testified ir favor of legislation which
would authorize National banks to operate collective
investment funds for agency accounts. The effect of
the legislation would be to reverse the District Court
decision in Investment Company Institute v. Camp.

VII. International Banking and Finance
The number of foreign branches of National banks
increased during 1967 from 230 to 278. Their total
resources increased from $9.4 billion on December 31,
1966, to $11.9 billion on December 30, 1967, an
amount which exceeds the total assets of National
banks in each State but five. At the end of 1967, foreign
branches of National banks constituted 95.5 percent
of total foreign branches of U.S. banks. Not only did
the long-established continue to expand at a considerable pace, but several banks made the decision to go
overseas for the first time. At year end, a number of applications were pending, and some were in the approved, unopened category. In addition, two National
banks established Edge Act corporations for the first
time, to bring the total of National banks with such
subsidiaries to 21. Expansion thus continued apace in
a year beset with international economic problems of
the most serious nature. Among those was a worsening
of the deficits in the balance of payments of two of the
world's major economies, those of the United States
and the United Kingdom.
On January 1,1968, a series of measures, including a
new Voluntary Credit Restraint Program for banks,
was announced to deal with our balance of payments.
The Voluntary Credit Restraint Program and the Interest Equalization Tax continued to provide incentive for overseas branches to tap the important Eurodollar markets. Faced with the necessity of curbing
lending to foreigners from home offices, a number of

large American banks have come to view the overseas branch as an essential adjunct to their banks, not
only for the long-run profits from the branch operations per se, but also in order to service adequately the
needs of multinational clients. Some foreign branch expansion was defensive. If a bank did not expand overseas, it faced the possibility of losing some of its prime
domestic and international business to its banking
competitors with overseas facilities.
In response to these developments, 1967 witnessed
a step-up in the efforts of this Office to train a cadre
of specialized examiners-international. In May, our
first annual seminar in international banking, lasting
2 weeks, gave participants an intensive exposure to
the principles and practices of international finance.
The program received the support of several other government departments, universities and leading international banks, both American and foreign. Some examiners were enrolled in the Foreign Service Institute of
the Department of State for in-depth study programs.
Others have been enrolled in foreign language courses
at the same institution and at other institutions around
the country. A monthly compendium, International
Banking News, was inaugurated to keep examiners upto-date on international banking developments. A program of in-bank training was developed to help meet
our current and future requirements.
The year 1967 also witnessed the continuation of the
Office policy of selective, on-the-spot examinations.

TABLE 10
Foreign branches of National banks, by region and country, Dec. 31,
Region and country

Latin America

Number

131

Austria
Belgium
France
Germany
Greece
Italy
Netherlands
Switzerland
Great Britain
Ireland

Region and country

Number

Africa
Liberia

Argentina
Bahamas
Bolivia
Brazil
Chile
Columbia
Dominican Republic..
Ecuador
El Salvador
Guatemala
Guyana
Honduras
Jamaica
Mexico
Nicaragua
Panama
Paraguay
Peru
Trinidad
Uruguay
Venezuela
Virgin Islands (British)
Europe

1967

Nigeria
Near East
Dubai
Lebanon
Saudi Arabia
Far East

Hong Kong
India
Japan
Korea
Malaysia
Okinawa
Pakistan
Philippines
Singapore
Taiwan
Thailand
Viet-Nam
U.S. overseas areas and trust territories
Canal Zone
Guam
Puerto Rico
Truk Islands
Virgin Islands
Total
Military banking facilities

10
8
12
3
5
2
4
5
8
2
2
2

2
2
16
1
10
278
31

VIII. Administrative and Management
Developments
During 1967, the Comptroller of the Currency
initiated a program to revamp and modernize the internal administrative operations of the Office. The
initial step in this program was the appointment of an
experienced certified public acountant to the position of
Deputy Administrative Assistant for Fiscal Management, reporting directly to the Administrative Assistant to the Comptroller. In conjunction with this appointment, there was established the Fiscal Management Division, including a systems staff of experienced
certified public accountants, which has responsibility
for the following areas:
1. Establishing, coordinating, and maintaining
an integrated financial management system;
2. Performing systems analysis and development relating to budgeting, accounting, reporting, and other financial operations;
3. Serving as adviser to the Administrative
Assistant to the Comptroller of the Currency concerning financial operations of the Office;
4. Performing various special projects and
studies relating to financial matters; and
5. Performing studies on other administrative
support operations such as procurement, supply,
automatic data processing, messenger and mail
service, disbursing, and space management.
During the year, the Fiscal Management Division
was able to provide top management with more informative and timely financial information. The accrual accounting system, established on January 1,
1964, was expanded by developing a more extensive
system of account classification and by subjecting additional items to the accrual basis of accounting. In addition, the monthly financial statements were revamped
in format with certain supporting data presented only
on a quarterly basis, coupled with a narrative report
summarizing and analyzing the significant changes and
trends in the financial position of the Office.
Several procedural memorandums were issued re20

lating to travel, education and training expenditures,
purchasing, time and leave reporting, and the establishment of imprest cash funds in regional offices. These
contributed to more coordinated and accurate information, clarification of authorities and responsibilities,
and reduction in paperwork and processing costs.
In addition to the Fiscal Management Division, a
management analyst and computer expert joined the
immediate staff of the Administrative Assistant, and
was given the responsibility to convert all applicable
operations to EDP and EAM equipment. Various
studies were initiated toward this objective during the
latter part of the year and certain program adaptations
will be accomplished in the coming year.
Due to the efforts of the Administrative Assistant
and the Fiscal Management Staff, the Office was able
to report in the government cost reduction-management improvement program total savings of $167,000,
all attributable to actions taken in the second half
of calendar 1967.
Since 1938, this Office has had an independent audit
of its annual financial statements conducted by the
Bureau of Accounts, U.S. Treasury Department. However, for 1967, the Office engaged an independent public accounting firm to perform the annual audit.
Other actions of the Administrative Branch accomplished meaningful improvements in the conduct of
Office affairs. A new publication, the Directory, was
issued to the National banking system in the spring of
1967. It contains the address and telephone number
of every decision-making official in the Office, together
with his picture and a short biographical sketch. This
new work has been well-received as one of our
most useful issuances. The quarterly economic journal,
The National Banking Review, was discontinued in
mid-year. A monograph series is being inaugurated
which will include significant economic and banking
studies. The flexible monograph approach permits
speedy publication of timely studies at greatly reduced
expenditures.

The 4-year program of remodeling all of our 16
headquarters' offices throughout the country was completed in 1967 with the relocation of the Cleveland
office. The product of this program has been the installation of modern, bright office facilities for regional
officials in keeping with their augmented policymaking
and supervisory responsibilities. And after a 2-year
pendency, the Office's comprehensive records retention schedules were given initial Office approval. Consultations with the appraisal service of the National
Archives Records Service have been held.
Personnel administration provided the Office with
additional substantial successes. Like all other employers, this Office is faced with a critical shortage
of qualified personnel in a tight labor market. Our
response has been the selection of a Regional Recruitment Coordinator for each of our 14 National bank
regions. These recruiters were given training, guidance,
and responsibility for recruitment on college and university campuses throughout the multi-State area covered by their region. The last year showed a marked
increase in the activities of these recruiters throughout
the country. As a result, our manpower shortage was
lessened with a net gain of 84 new Assistant National
Bank Examiners and Assistants in Trust. In the fall
of the year, the second annual Recruiters' Conference
was convened in Washington to promote an exchange
of experiences and methods used throughout the
country.
New enthusiasm was injected into additional personnel activities. The Incentive Awards Program was
given special emphasis and the achievements have been
encouraging. All phases of the Office training program
have received new attention. The Trust Division con-

ducted its annual 2-week school for Assistants in Trust,
and the International Division also conducted a seminar for its National Bank Examiners-International.
Eight experienced personnel participated in our Advanced Education Program during 1967 and were
afforded an opportunity to pursue 1 year of study at
an accredited university or college. Special attention
was also paid to the sectional schools program. Under
this program, National bank regions bring together
newly appointed Assistant National Bank Examiners
for a period of instruction on matters relating to commercial bank examinations. A study is being conducted
for the purpose of evaluating instructional techniques
used in the training of Assistant National Bank
Examiners.
Other employee development programs were continued. Seventy-three experienced examiners were selected to attend one of the eight graduate schools of
banking. Credit seminars were conducted at regional
sites for examiners responsible for the evaluation of
bank credits. The Office also sponsored American Institute of Banking correspondence courses for any interested employee. During 1967, there were 148 new
enrollments in these courses, as well as 51 enrollments
in the Dun and Bradstreet course, Credit and Financial
Analysis.
The year-long training program of 28 specialists in
bank EDP systems was completed in 1967 with the
graduation and assignment of the selected personnel.
The primary responsibility of these specialists is the
examination and evaluation of EDP systems in National banks. This has been a necessary and effective
refinement of bank examining procedures, and has
aided in the evaluation of the National banking system.

OFFICE OF THE COMPTROLLER OF THE CURRENCY
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J 1 ^ ADMINISTRATIVE;

I X . Financial Operations of the Office of the
Comptroller of the Currency, 1967
Corresponding to the growth and vitality of the
National banking system during the past several years,
the financial position of the Comptroller's Office continued to show improvement during calendar year
1967.
Receipts for 1967 amounted to $23.8 million, an increase of $1.4 million over 1966. This increase is primarily attributable to the $17 billion rise in total assets
of National banks. Receipts from assessments on National banks amounted to $20.7 million, or 85 percent
of total receipts.
Total income on investments for 1967 amounted to
$808,000, an increase of 20 percent over the prior year.
The increase was accomplished by more timely investment of available funds and by obtaining higher
yielding securities.
Expenditures for 1967 amounted to $21.5 million,
an increase of $1.7 million over 1966. Salaries, related

payroll expenses and travel expenses amounted to $20.1
million.
Increased salary expense, which accounted for 93
percent of the total increase in expenditures, was principally due to (1) the Federal pay increases; (2) the
third year of operation of the improved merit promotion plan; and, (3) a 7 percent increase in the average
number of examining personnel. By scheduling travel
on a priority basis, we were able to reduce travel expenditures by approximately $87,000, despite a net
increase in our examining force for the year.
The Comptroller's equity represents the accumulated excess of receipts over expenditures retained by
the Office for possible future contingencies. At December 31, 1966, the equity account had a balance
of $9,300,000. The increase in 1967 amounted to
$2,312,000, yielding a total in the equity account of
$11,612,000 at year end.

Table 11
OFFICE OF THE COMPTROLLER OF THE CURRENCY
BALANCE SHEET
December 31

1967
Current assets:
Cash
U.S. Government obligations, at cost (approximates market value)
Accounts receivable
Accrued interest
Prepaid expenses and other
Total current assets
U.S. Government obligations, at cost (approximate market value $13,454,068
in 1967 and $11,385,828 in 1966)

1966*

$310, 202
621, 841
58, 952
134,903
37, 736

$324, 867
831, 876
53, 271
110,098
45, 166

1, 163, 634

1, 365, 278

14, 159, 733

11,618,874

Fixed assets, at cost:
Furniture and fixtures
Office machinery and equipment

654, 368
315, 960

555, 582
289, 262

Less accumulated depreciation

970, 328
303, 318

844, 844
217, 122

Total assets

667, 010

627, 722

$15, 990, 377

$13,611,874

$152, 280
77, 531
218, 088

$71, 192
65, 279
279, 000

Liabilities and Comptroller's Equity
Current liabilities:
Accounts payable
Salary deductions and withholdings
Accrued travel and salary
Total current liabilities
Accumulated annual leave
Closed receivership funds
Total liabilities
Comptroller's equity
Total liabilities and Comptroller's equity

447, 899

415,471

1, 225, 628
2, 704, 527

1,191,536
2, 704, 081

4, 378, 054

4,311,088

11,612,323
$15, 990, 377

9, 300, 786
$13,611,874

•Financial statements for 1966 were audited by the Bureau of Accounts of the Treasury Department. Data for 1960-1965 may
be found in Comptroller of the Currency, Statistical Supplement to the 1966 Annual Report.

Table 12
OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENT OF REVENUE, EXPENSES
AND COMPTROLLER'S EQUITY
Year ended December 31
1967

Revenue:
Semi-annual assessments
Examinations and investigations
Examination reports sold
Revenue from investments
Other

Expenses:
Salary
Retirement and other contributions
Per diem
Travel
Rent and maintenance
Supplies
Printing, reproduction and subscriptions
Depreciation
Remodeling
Office machine repairs and rentals
Communications
Moving and shipping
Employees education and training
Other

$19,284,855
1, 785,684
494, 635
675, 982
176,073

23,833, 258

22,417,229

15,633, 374

14,169, 384
1, 079,179
2, 049, 548
1, 325, 133
244, 877
90,200
251, 260
75, 369
51, 538
83,067
194, 322
73, 585
56,843
100, 992

1,181, 144
1, 961,520
1, 326, 106
273,519
80,650
298, 050
92, 983
47, 963
96,471
214,024
82,094
109, 903
123, 920
21,521,721

Excess revenue over expenses

2,311,537

Comptroller's equity at beginning of year

9, 300, 786

Comptroller's equity at end of year

1966*

$20, 651, 935
1, 715, 862
502, 065
807, 647
155, 749

$11,612,323

19,845,297
2, 571, 932
6, 728, 854
$9,300, 786

Table 13
OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENT OF SOURCE AND APPLICATION OF FUNDS
YEAR ENDED DECEMBER 31, 1967
Funds were provided by:
Excess revenue over expenses
Add charges not requiring current outlay of funds
Depreciation
Net increase in accumulated annual leave
Net loss on sales of fixed assets

$2, 311, 537
92,983
34, 092
5, 483

2, 444, 095
Net receipts of closed receivership funds
Total funds provided
Funds were applied to:
Net increase in investment of long term U.S. Government obligations
Purchases of furniture and fixtures
Purchases of machinery and equipment
Total funds applied
Excess of funds applied over funds provided representing a decrease in working capital

OPINION OF INDEPENDENT ACCOUNTANT
To the Comptroller of the Currency
Office of the Comptroller of the Currency
In our opinion, the accompanying balance sheet, the related statement of revenue,
expenses and Comptroller's equity and the statement of source and application of funds
present fairly the financial position of the Office of the Comptroller of the Currency
at December 31, 1967 and the results of its operations and the supplementary information on funds for the year then ended, in conformity with generally accepted accounting
principles applied on a basis consistent with that of the preceding year. Our examination of these statements was made in accordance with generally accepted auditing
standards and accordingly included such tests of the accounting records and such other
auditing procedures as we considered necessary in the circumstances.
Washington, D.C.
PRICE WATERHOUSE & CO.
February 26, 1968

446
2, 444,541
2, 540, 859
109, 494
28, 260
2, 678,613
£234, 072

X . Issue and Redemption of Currency
Public Law 89^27, enacted on May 20, 1966,
transferred the redemption of Federal Reserve notes
from the Comptroller of the Currency to the Treasurer
of the United States. The transfer became operational
on August 1, 1966. During 1967, the Currency Issue
Division of the Comptroller's Office made 1,140 ship-

293-544—68

ments of new Federal Reserve notes (1,993,920,000
notes with an aggregate value of $10,988,400,000) to
Federal Reserve agents. Delivery of 64,260,000 notes
with an aggregate value of $381,700,000 was made to
the Treasurer of the United States.

APPENDIX A

Merger Decisions, 1967

Merger* Decisions, 1967
Approvals

Approvals
Jan. 1, 1967:
First National Bank of Lexington, Lexington, Miss.
Pickens Bank, Pickens, Miss.
Merger
Jan. 1, 1967:
Seaboard Citizens National Bank, Norfolk, Va.
Merchants and Farmers Bank of Franklin, N.A.,
Franklin, Va.
Consolidation
Jan. 13, 1967:
Vermont National Bank, Brattleboro, Vt.
Ludlow Savings Bank and Trust Co., Ludlow, Vt.
Merger
Jan. 13, 1967:
United States National Bank, San Diego, Calif.
Mission National Bank, Los Angeles, Calif.
Purchase

Page
35

Page

Feb. 14, 1967:
The Escanaba National Bank, Escanaba, Mich.
The Bark River State Bank, Bark River, Mich.
Purchase

Feb. 18, 1967:
Farmers & Merchants National Bank, Winchester,
Va.
Middletown State Bank, Inc., Middletown, Va.
Merger

Feb. 21, 1967:
The Planters National Bank & Trust Co., Rocky
Mount, N.C.
The Oxford National Bank, Oxford, N.C.
Merger

Feb. 24, 1967:
Somerville National Bank, Somerville, Mass.
County Bank & Trust Co., Cambridge, Mass.
Merger

Feb. 28, 1967:
First National Bank, New Albany, Miss.
Bank of Blue Mountain, Blue Mountain, Miss.
Merger

Feb. 28, 1967:
The Juniata Valley National Bank, Mifflintown, Pa.
Tuscarora State Bank, Blairs Mills, Pa.
Merger

Mar. 11, 1967:
Southern National Bank of North Carolina, Lumberton, N.C.
The Bank of Mayodan, Mayodan, N.C.
Merger

Jan. 13, 1967:
United States National Bank, San Diego, Calif.
Peoples Bank, Los Angeles, Calif.
Purchase
Jan. 13, 1967:
United States National Bank, San Diego, Calif.
Pioneer National Bank, Los Angeles, Calif.
Purchase

Jan. 31, 1967:
The Howard National Bank & Trust Co., Burlington, Vt.
The Rutland County Bank, Rutland, Vt.
Merger

Jan. 27, 1967:
Trust Company of Morris County, Morristown,
The Boonton National Bank of Parsippany-Troy
Hills, Parsippany-Troy Hills, N J .
Consolidation

Jan. 28, 1967:
National Bank & Trust Co. of Central Pennsylvania,
York, Pa.
The Central National Bank of Columbia, Columbia,
Pa.
Merger

Apr. 10, 1967:
Marine Midland National Bank of Troy, Troy, N.Y.
Unadilla National Bank, Unadilla, N.Y.
Merger

Apr. 28, 1967:
Valley National Bank, Glendale, Calif.
Providencia Bank, Burbank, Calif.
Merger

Apr. 28, 1967:
The First National Iron Bank of New Jersey,
Morristown, N.J.
The First National Bank of Butler, Butler, N.J.
Merger

Jan. 31, 1967:
First National Bank & Trust Co., Ontario, Calif.
The First National Bank of Elsinore, Elsinore, Calif.
Merger
Jan. 31, 1967:
The Grange National Bank of Potter County at
Ulysses, Ulysses, Pa.
The First National Bank of Genesee, Genesee, Pa.
Merger
Jan. 31, 1967:
The Conestoga National Bank of Lancaster, Lancaster, Pa.
The First National Bank of Landisville, Landisville,
Pa.
Merger

•Includes mergers, consolidations, and purchase and sale
transactions where the emerging bank is a National bank.
Decisions are arranged chronologically by effective date.

Approvals
Apr. 28, 1967:
County National Bank, Middletown, N.Y.
The Maybrook National Bank, Maybrook, N.Y.
Merger
Apr. 28, 1967:
Marine National Bank, Erie, Pa.
The Second National Bank of Titusville, Titusville,
Pa.
Merger
May 1, 1967:
Seattle-First National Bank, Seattle, Wash.
Bank of Sumas, Sumas, Wash.
Purchase
May 1, 1967:
Sierra National Bank, Petaluma, Calif.
Tiburon National Bank, Tiburon, Calif.
Purchase
May 8, 1967:
The Meadow Brook National Bank, New York, N.Y.
Bank of North America, New York, N.Y.
Consolidation
May 8, 1967:
The Hocking Valley National Bank of Lancaster,
Lancaster, Ohio.
The First National Bank of Baltimore, Baltimore,
Ohio.
Purchase

Approvals
Page
60

May 16, 1967:
First-City National Bank of Binghamton, Binghamton, N.Y.
First-City National Bank of Southern New York,
Binghamton, N.Y.
Merger
May 16, 1967:
Lincoln National Bank and Trust Co. of Central
New York, Syracuse, N.Y.
Lincoln National Bank of Syracuse, Syracuse, N.Y.
Merger
May 16, 1967:
The First National Bank of Jamestown, Jamestown,
N.Y.
Second National Bank of Jamestown, Jamestown,
N.Y.
Merger
May 19, 1967:
South Shore National Bank, Quincy, Mass.
First Bank & Trust Company of Needham, Needham, Mass.
Merger
June 7, 1967:
National Bank of Chester County & Trust Co.,
West Chester, Pa.
The Atglen National Bank, Atglen, Pa.
Merger
June 16, 1967:
The Wyoming National Bank of Wilkes-Barre,
Wilkes-Barre, Pa.
The First National Bank of Shickshinny, Shickshinny, Pa.
Merger

Page

June 30, 1967:
National Bank of Commerce of Paragould, Paragould, Ark.
First National Bank of Paragould, Paragould, Ark.
Merger

June 30, 1967:
The Fidelity National Bank, Lynchburg, Va.
Union Bank & Trust Co. of Amelia, Amelia Court
House, Va.
Merger

July 15, 1967:
The First National Bank of Racine, Racine, Ohio
The Racine Home Bank, Racine, Ohio
Merger

July 21, 1967:
The First National Bank, Narrows, Va.
First Valley National Bank, Rich Creek, Va.
Consolidation

July 24, 1967:
Santa Clarita National Bank, Newhall, Calif.
Boulevard Bank, Sepulveda, Calif.
Purchase

July 24, 1967:
Southern National Bank of North Carolina, Lumberton, N.C.
The Bank of Mount Gilead, Mount Gilead, N.C.
Merger

July 31, 1967:
The First National Bank of McConnelsville,
McConnelsville, Ohio
The First National Bank of Stockport, Stockport,
Ohio
Merger

Aug. 7, 1967:
The First National Bank of Ebensburg, Ebensburg,
Pa.
The First National Bank of Hastings, Hastings, Pa.
Merger

Aug. 14, 1967:
La Salle National Bank, Chicago, 111.
The Mutual National Bank of Chicago, Chicago, 111.
Merger

Aug. 17, 1967:
First National Bank of San Diego, San Diego, Calif.
Saddleback National Bank, Tustin, Calif.
Merger

Aug. 23, 1967:
First National Bank, Memphis, Tex.
First National Bank, Lakeview, Tex.
Purchase

Aug. 30, 1967:
Union National Bank & Trust Co. of Huntingdon,
Huntingdon, Pa.
The First National Bank of Three Springs, Three
Springs, Pa.
Merger

May 12, 1967:
First National State Bank of New Jersey, Newark,
Bank of Nutley, Nutley, N.J.
Merger

June 30, 1967:
Franklin National Bank, Mineola, N.Y.
Federation Bank & Trust Company, New York,
N.Y.
Merger

Aug. 31, 1967:
Central Valley National Bank, Oakland, Calif.
Concord National Bank, Concord, Calif.
Merger

Approvals

Approvals
Aug. 31, 1967:
First Union National Bank of North Carolina,
Charlotte, N.C.
The Citizens Bank & Trust Co. of Southern Pines,
Southern Pines, N.C.
Merger
Aug. 31, 1967:
The Grayson National Bank, Independence, Va.
The Farmers Bank of Elk Creek, Elk Creek, Va.
Merger
Sept. 14, 1967:
Southern California First National Bank, San
Diego, Calif.
Huntington-Valley Bank, Huntington Beach, Calif.
Merger
Sept. 25, 1967:
The Bank of California, N.A., San Francisco, Calif.
Metropolitan Bank, Hollywood, Los Angeles, Calif.
Merger
Sept. 29, 1967:
National Newark & Essex Bank, Newark, N.J.
Glen Ridge Trust Co., Glen Ridge, N.J.
Merger
Sept. 30, 1967:
Clermont National Bank, Milford, Ohio
Merchants & Farmers Bank, Owensville, Ohio
Purchase
Oct. 2, 1967:
The Harrisburg National Bank & Trust Co.,
Harrisburg, Pa.
First National Bank & Trust Co. of Elizabethtown,
Elizabethtown, Pa.
Merger
Oct. 2, 1967:
The First National Bank of Miami, Miami, Fla.
New National Bank of Miami, Miami, Fla.
Merger

Page

Oct. 9, 1967:
Security National Bank of Contra Costa, Walnut
Creek, Calif.
First National Bank of Oakland, Oakland, Calif.
Merger

114

115

Oct. 25, 1967:
Miners National Bank of Wilkes-Barre, WilkesBarre, Pa.
Citizens Bank of Wilkes-Barre, Wilkes-Barre, Pa.
Merger

117

Oct. 31, 1967:
The Live Stock National Bank of Sioux City, Sioux
City, Iowa
Morningside Savings Bank, Sioux City, Iowa
Merger

119

Oct. 31, 1967:
The First National Bank of Wilkes-Barre, WilkesBarre, Pa.
The First National Bank of Bloomsburg, Bloomsburg, Pa.
Merger

121

Nov. 25, 1967:
The National Bank of Dover, Dover, Ohio
The Peoples Bank & Savings Co., New Philadelphia,
Ohio
Merger

122

Nov. 30, 1967:
Adams County National Bank, Cumberland Township, Gettysburg, Pa.
East Berlin National Bank, East Berlin, Pa.
Merger

123

104

Dec. 4, 1967:
The National Bank of Commerce of Dallas, Tex.
Empire State Bank of Dallas, Dallas, Tex.
Merger

125

106

Dec. 9, 1967:
The Hanover National Bank of Wilkes-Barre,
Wilkes-Barre, Pa.
The Glen Lyon National Bank, Glen Lyon, Pa.
Merger

128

Dec. 14, 1967:
The Canandaigua National Bank & Trust Co.,
Canandaigua, N.Y.
The Hamlin National Bank of Holcomb, Holcomb,
N.Y.
Merger

128

Dec. 15, 1967:
Golden Gate National Bank, San Francisco, Calif.
The First National Bank of Vista, Vista, Calif.
Consolidation

130

Dec. 16, 1967:
First Union National Bank of North Carolina,
Charlotte, N.C.
The Bank of Wendell, Wendell, N.C.
Merger

131

100

101

103

107

Oct. 13, 1967:
The First National Bank of Butte, Butte, Mont.
Daly National Bank of Anaconda, Anaconda, Mont.
Consolidation

108

Oct. 17, 1967:
The Oneida National Bank & Trust Co. of Central
New York, Utica, N.Y.
The National Bank of Waterville, WaterviUe, N.Y.
Merger

109

Oct. 20, 1967:
Haddonfield National Bank, Haddonfield, N.J.
Audubon National Bank, Audubon, N.J.
Merger

Ill

113

Oct. 21, 1967:
The Peoples National Bank, Greenville, S.C.
Farmers Bank of Simpsonville, Simpsonville, S.C.
Mlerger

Oct. 9, 1967:
Commercial National Bank, Buena Park, Calif.
Westminster National Bank, Westminster, Calif.
Merger

Page

Oct. 20, 1967:
National Bank of Washington, Tacoma, Wash.
First National Bank in Montesano, Montesano,
Wash.
Merger

Oct. 5, 1967:
Southern California First National Bank, San Diego,
Heritage-Wilshire National Bank, Los Angeles,
Calif!
Merger

Oct. 20, 1967:
First National Bank of Eastern North Carolina,
Jacksonville, N.C.
Bank of Lillington, Lillington, N.C.
Merger

Approvals

Approvals
Dec. 19, 1967:
The American National Bank & Trust Go. of
Michigan, Kalamazoo, Mich.
First State Bank of Mention, Mendon, Mich.
Merger

Page

Dec. 31, 1967:
Newport National Bank, Newport Beach, Calif.
University National Bank, Fullerton, Calif.
Merger

Page
142

132

Additional Approvals
Dec. 27, 1967:
First National Bank in Indiana, Indiana, Fa.
Conemaugh Valley Bank, Blairsville, Pa.
Merger

134

Dec. 29, 1967:
North Carolina National Bank, Charlotte, N.C.
Commercial & Industrial Bank, Fayetteville, N.C.
Merger

135

Dec. 30, 1967:
Commonwealth National Bank, Boston, Mass.
The Lincoln National Bank of Chelsea, Chelsea,
Mass.
Merger

136

Dec. 31, 1967:
Glens Falls National Bank & Trust Co., Glens Falls,
N.Y.
Chester-Schroon-Horicon Bank, Chestertown, N.Y.
Merger

138

Dec. 31, 1967:
Merchants National Bank & Trust Co. of Indianapolis, Indianapolis, Ind.
Live Stock Exchange Bank, Indianapolis, Ind.
Merger

139

Dec. 31, 1967:
The Northeastern Ohio National Bank, Ashtabula,
Ohio
The Jefferson Banking Co., Jefferson, Ohio
Merger

A. Approved, but in litigation.
Dec. 18, 1967:
Phillipsburg National Bank and Trust Company,
Phillipsburg, N J .
Second National Bank of Phillipsburg, Phillipsburg,
N.J.
Merger

143

B. Approved, but abandoned after litigation.
Sept. 13, 1967:
National Bank & Trust Co. of Central Pennsylvania,
York, Pa.
The Keystone Trust Co., Harrisburg, Pa.
Merger

148

Nov. 17, 1967:
County National Bank, Middletown, N.Y.
Citizens Bank of Monroe, Monroe, N.Y.
Merger

150

Dec. 18, 1967:
New Jersey National Bank and Trust Co., Neptune,
N.J.
Belmar-Wall National Bank, Wall Township, Monmouth County, N.J.
Merger

154

Disapproval

140

Dec. 18, 1967:
First National Bank of Canton, Canton, Ohio
The Canton National Bank, Canton, Ohio
Consolidation

157

/. Approvals
PICKENS BANK, PICKENS, MISS., AND FIRST NATIONAL BANK OF LEXINGTON, LEXINGTON, MISS.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Pickens Bank, Pickens, Miss., with
and First National Bank of Lexington, Lexington, Miss. (13313), which had.
merged Jan. 1, 1967, under charter and title of the latter bank (13313).
The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 30, 1966, the Pickens Bank, Pickens,
Miss., and the First National Bank of Lexington, Lexington, Miss., applied to the Office of the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
Lexington, with a population of 3,000, is the county
seat of Holmes County and the trading center for an
estimated 15,000 people. Agriculture and livestock are
its primary sources of income with weekly livestock
sales averaging between $50,000 and $75,000. It has
a moderate amount of industry and is the home of one
of the largest producers of sand and gravel in this part
of the State. Growth in Lexington has been steady during the last decade and prospects for future growth are
favorable.
Pickens, with a population of 750, is located in the
southeast corner of Holmes County, approximately 18
miles from Lexington. Agriculture, with cotton and
soybeans the leading products is the primary source of
income. Most of the farms in the area are large operations, some cultivating more than 1,000 acres. Other
income is derived from cattle ranches and a minimum
amount of industry.
The First National Bank of Lexington, with IPC
deposits of $3.8 million, was chartered in 1929. It has
not. been involved in any merger and does not operate
any branch offices.
Pirkpm Bank, with TPC deposits of $1.5 million was
organized in 1912. It has not been involved in any
merger and does not operate any branch offices. Pri-

$2,049,048
5,817,458

To be
operated

7, 683,096

mary competition is derived from the $23 million
Delta National Bank in Yazoo City and the $6.7 million First National Bank of Canton.
There is little, if any, competition between the participating banks. Consummation of the proposed
merger will bring to Pickens a bank with greater lending capacity and better able to compete with the banks
located in Yazoo City and Canton. It will, in addition
to solving the management succession problem existing in the merging bank, bring to the Pickens area such
new banking services as trust powers, personal loan,
and installment financing more in keeping with the
needs of the area.
Applying the statutory criteria to the proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
NOVEMBER 7,1966.
SUMMARY OF KEROKT UY ATTORNEY UISXMKRAL

First National Bank of Lexington has assets of
$5,047,000, and deposits of $4,683,000. Its single office
is located in Lexington, a town of 3,000 in north-central Mississippi. It has 26 percent of the total deposits
of the four banks located in its service area.
Pickens Bank has assets of $1,815,000, and deposits
of $1,682,000. Its one office is located in Pickens, a
town of 750, 18 miles southeast of Lexington. It holds
2 percent of the total deposits of the six banks in ils
service area.
There is no competition between the meiging banks.
The proposed merger would not adversely aiTcct competition.

SEABOARD CITIZENS NATIONAL BANK, NORFOLK, VA., AND MERCHANTS & FARMERS BANK OF FRANKLIN,
FRANKLIN, V A .

N.A.,

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
Seaboard Citizens National Bank, Norfolk, Va. (10194), with
and Merchants and Farmers Bank of Franklin, N.A., Franklin, Va. (15613), .
which had
consolidated January 1, 1967, under charter and title of the former bank
(10194). The consolidated bank at date of consolidation had
COMPTROLLER S DECISION

On September 6, 1966, the Merchants & Fanners
Bank of Franklin, N.A., Franklin, Va., with IPG deposits of $6 million, and the Seaboard Citizens National Bank, Norfolk, Va., with IPC deposits of $96
million, filed an application with the Comptroller of
the Currency for permission to consolidate under the
charter and title of the "Seaboard Citizens National
Bank."
The Merchants & Farmers Bank of Franklin, N.A.,
which was organized in 1928 as a State nonmember
bank, has received preliminary approval from the
Comptroller to convert to a National banking association. The bank operates from a single office in Franklin,
a town of 7,700 located in Southampton County about
37 miles southwest of Norfolk. The economy of the
service area is principally dependent on agriculture and
the production of wood, the manufacture of wood
products, and related industries. Farmers and Merchant^ slock is owned by United Virginia Bankshares,
Inc., a registered bank holding company which holds
about 12 percent of total deposits in the State through
subsidiaries in Richmond, Alexandria, Fairfax County,
Lynchbuig, Newport News, Lexington, Ilamsonburg,
and Franklin.
The Seaboard Citizens National Bank was organized in 10G7 and presently operates 15 branches, 10 of
which are located in Norfolk, two in Virginia Beach,
and one each in Chesapeake, Holland and Suffolk. The
Norfolk-Portsmouth metropolitan area, which has a
pupulaliun uf 700,000, is an important financial center,
and ianks second among the major Atlantic ports in
ihe handling of foreign waterbome cargo. There arc
many industries in the area, a rrczinber of which arc
id<d.ed to shipping, while the presence of large permanent military bases provides a major additional
source of employment.
Competition between the two banks is negligible.
The closest branch of the Seaboard National to the
charter bank is in Holland, Va., about 8 miles east
36

$126,325,588
8, 583, 158
134, 908, 746

16
1
17

of Franklin; however, only a very small percentage of
each bank's loans and deposits originate in the service
area of the other bank. Competition is virtually nonexistent between the Seaboard National and the other
subsidiaries of United Virginia Bankshares, Inc., as
none of these are based or have hranches in Norfolk.
The merger will not create an imbalance in banking
competition. The consolidation with Seaboard National will enable the charter bank to compete more
successfully with the Franklin branch of Virginia Nationl Baok, the second largest bank in the State. Affiliation with United Virginia. Bankshares, Tnc, will
improve, the competitive position of Seaboard National in Norfolk, where it. competes with the. largest
banks in the State, viz., the Virginia National Bank,
with deposits of $506 million, and the Norfolk area
branches of First & Merrhants National Bank of Richmond, with deposits of $590 million, a.nrl other large
banks and bank holding company subsidiaries, Tf the
consolidation is effectuated, then UnitfiH Virginia
BankshareSs, Inc., will hold about 14 percent of total
deposits in the State.
The banking public, will benefit in that the consolidation will make available to the customers of Seaboard
National the electronic data processing equipment and
the financial and management services of the bank
holding company. The Seaboard National experts that
affiliation with United Virginia Bankshares, Tnr.., will
justify the establishment of a foreign hanking department specializing in international transactions, as is
fitting to a bank in a large seaport. Through participation by its affiliates, Seaboard National will he ahle to
arrange loans up to $8 million to a single borrower.
Service to the public by the charter bank in Franklin
wiU be improved by the direct availability of additional
trust services, and by an increased lending limit
Applying the statutory criteria to the proposed consolidation, we find that it is in the public interest, and
the application is, therefore, approved.
NOVEMBER 8,

1966.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Seaboard had, as of June 30, 1966, assets
of $120,715,000, deposits of $103,697,000, loans and
discounts of $67,136,000, and capital accounts of
$11,290,000. This bank's history shows two prior
mergers, one in 1963, and the other in 1964.
As of June 30, 1966, Merchants held assets of
$8,205,000, loans and discounts of $3,264,000, deposits of $7,182,000, and capital accounts of $852,000.
It has no history of mergers or consolidations. Merchants is a subsidiary of United Virginia Bankshares,
Inc., and the resulting bank of this consolidation will
also be a Bankshares' subsidiary. Merchants will, prior
to consummation of this transaction, apply for a National charter, and the consolidated bank will operate
under this charter with the title of Seaboard Citizens
National Bank. The result of this consolidation will be

the acquisition by Bankshares of a $120 million bank
in Norfolk, the largest city in Virginia and the only
major financial center in the State in which Bankshares has no subsidiary.
Some competition between Seaboard and Merchants appears to be present, and this competition
would be eliminated by consummation of the proposed
consolidation. There appears to be little present competition between Seaboard and other Bankshares' subsidiaries, but potential competition appears to be present through the possible de novo chartering of a new
bank by Bankshares in Seaboard's service area or
through the acquisition of one of the smaller banks in
that area. Such potential competition would be eliminated by consummation of the proposed consolidation.
Apart from the foregoing, it is not likely that competition in either Seaboard's or Merchants' service area
would be adversely affected by the transaction.

LUDLOW SAVINGS BANK & TRUST CO., LUDLOW, V T . , AND VERMONT NATIONAL BANK, BRATTLEBORO, V T .
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Ludlow Savings Bank and Trust Co., Ludlow, Vt., with
and Vermont National Bank, Brattleboro, Vt. (1430), which had
merged Jan. 13, 1967, under charter and title of the latter bank (1430). The
merged bank at date of merger had
COMPTROLLER'S DECISION

On October 10, 1966, the Vermont National Bank
of Brattleboro, Vt., a bank having IPC deposits of
$46.7 million, and the Ludlow Savings Bank & Trust
Co. of Ludlow, Ludlow, Vt., having IPC deposits of
$3 million, applied to the Comptroller of the Currency
for permission to merge under the charter of and with
the title of "Vermont National Bank."
The charter bank is located in Brattleboro, a city
of 12,000 which is situated in the southeast corner of
Vermont on the New Hampshire border, about 9
miles north of the Massachusetts line. It is the fourth
largest city in Vermont and serves an area of 60,000
people. Its economy is diversified and stable; it has 36
manufacturing establishments that employ over 3,500
people. Tourism is an important economic factor primarily during the winter months. The ski areas nearby
are nationally recognized and make Brattleboro a
winter sports center. The Mount Snow complex alone
often draws over 10,000 people per day and has a

$3, 623, 575
55, 547, 700
59, 169,044

To be
operated

11
12

season's income in excess of $2 million. The surrounding area is devoted to dairy farming but that is on the
decline. Brattleboro has, in brief, experienced moderate economic growth and population increase within
recent years, and future prospects appear good.
Ludlow is a town of 2,400 inhabitants which is situated in the center of the Green Mountains, 49 miles
northwest of Brattleboro and which serves an area of
5,000 people. The town is essentially rural in character, but there is some industry present. Many of the
residents have given up dairy farming and commute to
neighboring towns for employment. The recent development of the Okemo Mountain ski area is having
a decided impact upon the community and the costly
addition of snowmaking equipment is expected to
stabilize attendance and therefore diminish the risk of
a poor season. All in all, Ludlow is a modest country
town with limited industrial potential and will probably remain so for several years to come.
The charter bank, Vermont National, has 10
branches which are largely located in the southern
37

part of the State. Because Vermont is a sparsely populated State and because the terrain is quite rugged, it
is very difficult to define the boundary of the banking
market involved. Nevertheless, it seems that the minimum geographic market should be defined as an area
including the State of Vermont and the northwestern
part of Massachusetts. Vermont National, without the
proposed merger, ranks as the fifth largest bank in
Vermont. It is in direct competition with the Vermont
Bank & Trust, the State's fourth largest bank, which
operates in (lie same service area and which has six
branches.
Excluding the chai ler and merging banks, there arc
58 banking offices in this area. In addition, large banks
from Albany, Boston, and Hartford are active in
seeking loans and deposits in this area. Also not to be
ignored is the competition from local credit unions
and finance companies for the highly lucrative installment loan market.
For Ludlow, the proposed merger would not reduce
competition, since Ludlow Savings is the only bank in
town. The merging bank's unsatisfactory rate of growth
has been largely attributable to the fact that its entire
operation is conducted by only two people. Beyond
these two individuals, there is no management. Significant is the fact that Ludlow Savings has chosen to stay
out of the profitable field of home modernization installment loans. In addition, Ludlow Savings has been
severely restricted by a low lending limit of $30,000
and by an ever-liglrtening availability of funds. There
is some question as to whether or not Ludlow Savings
can cuntinue lo serve the comrrramty in the light of
its present capital structure.
The convenience and needs of the town of Ludlow
are nut being adequately served by the merging institution. Several deserving customers have had to be
turned down for lack of capacity to handle them. All
of these loans would have had a direct and desirable

impact upon the Ludlow community and would have
served to broaden the town's economic base. The charter bank's limit of over $300,000 per loan should be of
great help to Ludlow, and should provide ample funds
for any of the town's growing needs, Tt is clear that
Ludlow Savings has not been giving the community
the banking services it needs, and it has not been competing with the area banks. The merger will furnish
the town of Ludlow with a full-service bank that makes
all varieties of loans, has a trust department, and has a
large loan limit. The proposed merger will stimulate,
rather than suppress competition, and will go far toward satisfying the economic convenience and PPPHS
of the community of Ludlow.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
DECEMBER 12,1966.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Vermont National Bank, Brattleboro, V t , fifth
largest Vermont bank operating 10 branches and with
assets of $54,377,000, proposes to merge the Ludlow
Savings Bank & Trust Co., Ludlow, Vt., with assets
of $3,628,000.
No attempt is made in the application to define the
particular service area or areas of the acquiring or
the merging bank nor is the extent of competition between them described. It is probable, however, that
Ludlow and Vermont National's Proctorsville branch;
located 4 miles to the southeast, compete directly and
substantially. No other banking office is located closer
than 13 miles from Ludlow. Thus the proposed merger,
in addition to elis?iaating zxkting competition between
the merging banks, would eliminate the only alternative source of banking services in the Ludlow-Proctorsville area.

MISSION NATIONAL BANK, LOS ANGELES, CALIF., AND UNITED STATES NATIONAL BANK, SAN DIEGO, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Mission National Bank, Los Angeles, Calif. (15087), with
was purchased Jan. 13, 1967, by United States National Bank, San Diego,
Calif. (10391), which had
After the purchase was effected, the receiving association had

$12,471,004

368, 696, 547
*399, 241, 991

•Includes Peoples Bank, Los Angeles, Calif., and Pioneer National Bank, Los Angeles, Calif.

To be
operated

*49

COMPTROLLER'S DECISION

On September 23, 1966, the United States National
Bank, San Diego, Calif., with IPC deposits of
$265.2 million, applied to the Comptroller of the Currency to purchase the assets and assume the liabilities
of the Mission National Bank, Los Angeles, Calif.,
with IPC deposits of $5.5 million. Concurrent applications were also filed by United States National Bank
to purchase the assets and assume the liabilities of the
Pioneer National Bank, Los Angeles, Calif., with
IPC deposits of $6.4 million, and the Peoples Bank,
Los Angeles, Calif., with IPC deposits of $3.3 million.
United States National Bank, with its main office and
three branches located within the city of San Diego,
has 41 other branch offices located throughout the five
southern California counties of San Diego, Los Angeles, Orange, Riverside, and San Bernardino. In addition, this bank has two approved but unopened
branches.
The economy of the five-county southern California
area served by United States National Bank is highly
diversified in agriculture, industry, foreign and domestic finance, and many commercial and service activities
including fishing, tourism, military establishments, entertainment business, and retail trade. During the past
five-year period, California has added nearly 400,000
people each year to its population, with southern
California receiving the major portion of the increase.
Mission National Bank, organized in March 1963,
has a single office located on Wilshire Boulevard in
the city of Los Angeles. The location of the Mission
National Bank is considered one of the finest in all
metropolitan Los Angeles. Property in this area is very
expensive and, as a result, older dwellings are giving
way to new multiple units and a denser population.
The area contains numerous high rise office buildings
which are fully occupied. There is little, if any, industry within the primary service area.
United States National Bank, which offers a full
range of banking services, including trust services, has
experienced rapid growth in the past 15 years. On the

other hand, in the short period Mission National has
been in existence, its earnings have been unsatisfactory.
Mission National does not have a trust department and
has a lending limit of only $350,000. Due to the
limited expertise of its management, the bank appears
considerably constrained in its ability to provide adequate banking services beyond the acceptance of
deposits.
United States National Bank currently competes
with all the major California branch banking systems
in the southern half of the State and with most of the
small independent systems and unit banks of southern
California. Mission National Bank is in direct competition with four branches of major California banks
and generally competes with all the banking offices located between downtown Los Angeles and Beverly
Hills, as well as with numerous savings and loan associations, credit unions, loan companies, and insurance companies which are active in this area. The two
participating banks do not compete directly with each
other. The nearest branch of the United States National Bank to Mission National Bank is in downtown
Los Angeles approximately 4 miles to the east. Consequently, consummation of the proposed purchase
would not lessen competition between them. The presence of United States National Bank as a viable, aggressive competitor will cause an increase in banking
competition in the Los Angeles market area with no
undue increase in its market share of banking business.
Consummation of this proposal will benefit the public interest by bringing to the residents of the area
now served by the selling bank a new institution with
a larger lending capability and a broader range of
banking services. It will provide an effective solution
to the selling bank's many problems.
Applying the statutory criteria to this proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
DECEMBER 14,

1966.

NOTE.—For summary of Attorney General's report, see
p. 42.

PEOPLES BANK, LOS ANGELES, CALIF., AND UNITED STATES NATTONAT. BANK, SAN DIEGO, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Peoples Bank, Los Angeles, Calif., with
,
was purchased Jan. 13, 1967, by United States National Bank, San Diego,
Calif. (10391), which had.,
After the purchase was effected, the receiving association had.

To be
operated

$8, 196, 017
368, 696, 547
*399, 241, 991

46
*49

•Includes Mission National Bank, Los Angeles. Calif., and Pioneer National Bank, Los Angeles, Calif.
COMPTROLLER S DECISION

On September 23, 1966, the United States National
Bank, San Diego, Calif., with IPC deposits of $265.2
million, applied to the Comptroller of the Currency
to purchase the assets and assume the liabilities of the
Peoples Bank, Los Angeles, Calif., with IPG deposits
of $3.3 million. Concurrent applications were also filed
by United States National Bank to purchase the assets
and assume the liabilities of the Mission National Bank,
Los Angeles, Calif., with IPC deposits of $5.5 million,
and the Pioneer National Bank, Los Angeles, Calif.,
with IPC deposits of $6.3 million.
United States National Bank, with its main office
and three additional branches located within the city
of San Diego, has 41 other branch offices located
throughout the five southern California counties of San
Diego, Los Angeles, Orange, Riverside, and San
Bernardino. In addition, this bank has two approved
but unopened branches.
The economy of the five-county southern California
area served by United States National Bank is highly
diversified in agriculture, industry, foreign and domestic finance, and many commercial and service activities including fishing, tourism, military establishments,
entertainment business, and retail trade. During the
past 5-year period, California has added nearly 400,000 people each year to its population, with southern
California receiving the major portion of the increase.
Peoples Bank was chartered under the banking laws
of the State of California in June 1961, and presently
operates only one office located on West Pico
Boulevard in the city of Los Angeles, Business outlets
in this area, are generally small owner-operated retail
stores that offer a variety of goods and services to local
residents The area has rnnsiriprahle drawing power
because most services are offered at a more reasonable
price than arc found in nearby communities. Many
residents of Beverly Hills, West TJOS Angeles, and the
exclusive Cheviot Hills section of Los Angeles do their
40

everyday shopping in this area. The surrounding area
is fully developed with above average homes that serve
a high-income group of residents^ The area contains
little, if any, industry. While there is no immediate
banking competition, the area is generally very well
banked.
United States National Bank, which offers a full
range of banking services, including trust services, has
experienced rapid growth in the past 15 years. On the
other hand, earnings for Peoples Bank have been declining over the past 3 years and are far below the
average for banks of this size in California. While its
lending limit is adequate for most demands for credit,
the larger limit of the resultant bank will enable it
to service clientele requiring greater limits. Peoples
Bank does not have a trust department, and owing
to the limited depth of its management, there is little
likelihood that the bank could offer such services in the
near future.
United States National Bank currently competes
with all major California branch banking systems in
the southern half of the State, and with most of the
small independent systems and unit banks of southern
California. Peoples Bank has no immediate competition, but generally competes with banking offices located throughout western Los Angeles, as well as
with numerous savings and loan associations, loan companies, credit uniuns, and insurance companies which
are active in this area. The two participating banks do
not compete directly with each other. The nearest
branch of the United Stales National Bank to the Peoples Bank is approximately 5 miles to the southeast.
Consequently, consummation of the proposed purchase
would not lessen conrpetrtion between the two banks.
The effect of tills proposal, when consummated, will be
aii iiiacase in banking coirrpetition W?L1I the larger
banks located in the general area.
The entry of United States National Bank into the
area served by tile selling bank will provide area residents with a bank with a larger lending capacity and

a broader range of services. With its greater managerial resources and staff of skilled technicians* the buying
bank can provide a ready source of financial guidance

merger, we conclude that il is in the public interest,
and the application, therefore* is approved,
DECEMBER 14,1966.

to area residents in need of it.
Applying the statutory criteria to the proposed

NoTE.-For summary of Attorney General's opinion, see
p. 42.

PIONEER NATIONAL BANK, LOS ANGELES, CALIF., AND UNITED STATES NATIONAL BANK, SAN DIEGO, CALIF.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Pioneer National Bank, Los Angeles, Calif. (15240), with
was purchased Jan. 13, 1967, by United States National Bank, San Diego,
Calif. (10391), which had
After the purchase was effected, the receiving association had

$9,878,422
368, 696, 547
*399, 241, 991

*49

•Includes Mission National Bank, Los Angeles, Calif., and Peoples National Bank, Los Angeles, Calif.
COMPTROLLER'S DECISION

On September 23, 1966, the United States National
Bank, San Diego, Calif., with IPC deposits of $265.2
million, applied to the Comptroller of the Currency
to purchase the assets and assume the liabilities of the
Pioneer National Bank, Los Angeles, Calif., with IPC
deposits of $6.4 million. Concurrent applications were
also filed by United States National Bank to purchase
the assets and assume the liabilities of the Peoples
Bank, Los Angeles, Calif., with IPC deposits of $3.3
million, and the Mission National Bank, Los Angeles,
Calif., with IPC deposits of $5.5 million.
United States National Bank, with its main office
and three additional branches located within the city
of San Diego, has 41 other branch offices located
throughout the five southern California counties of
San Diego, Los Angeles, Orange, Riverside, and San
Bernardino. In addition, this bank has two approved
but unopened branches.
The economy of the five-county southern California
area served by United States National Bank is highly
diversified in agriculture, industry, foreign and domestic finance, and many commercial and service activities including fishing, tourism, military establishments, entertainment business, and retail trade. During
the past 5-year period, California has added nearly
400,000 people each year to its population, with southern California receiving the major portion of the
increase.
Pioneer National Ranlf was chartered as a National
hanking association in December 1963> aad presently
operates with only one office located on Wilshirc

Boulevard approximately 5 miles west of the downtown section of Los Angeles and approximately midpoint in the metropolitan Los Angeles trade area.
The surrounding area is comprised of older, but good,
residential dwellings. Commercial activity is devoted
to major offices of insurance companies, oil companies,
and regional offices of other major firms dispersed
along the length of Wilshire Boulevard. Population
density is increasing as many of the older homes on
side streets are being replaced by apartment houses.
United States National Bank, which offers a full
range of banking services, including trust services, has
experienced rapid growth in the past 15 years. On the
other hand, earnings of the Pioneer National Bank have
been unsatisfactory. Pioneer National does not have
a trust department and its lending limit is only
$260,000. Pioneer National has been unable to progress
in its market area.
United States National Bank currently competes
with all the major California branch banking systems
in the southern half of the State and with most of the
small independent systems and unit banks of southern
California. Within a 5-mile radius of Pioneer's office
there are 206 competing banking offices. Competition
is also furnished by numerous savings and loan associations, credit unions, loan companies, and insurance
companies. Competition between the proponents is
insignificant. The nearest branch of the United States
National Bank is approximately 6 miles distant in
downtown Los Angeles. Consequently, while consummation of the proposed ptrrchase will nut lessen uumpctitioR between the two banks, it can serve to inacdac
banking competition with the larger banks located in

•JJLC iuc* withuul wd-rsiyg <
banking resources in the TJ«I Angles area.
Consummation of thp. proposal will bo. in the public
interest by affording the residents in the area of the
Pioneer Baivk a new institution pns«sp«ing efficient
managemftnt With its higher lending capability, fiduciary services, and a broad range of services, it will be
more attuned to the requirements of the community
and better able to serve them.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application, therefore, is approved.
DECEMBER 14,

1966.

SUMMARY OF RKPORT BY ATTORNEY GENERAL

The United Slates National Bank (hereinafter the
Acquiring Bank), a $310 million (deposits) San

THK

with 14 rMnrs, makes application to purdiasH the assets and assuma the liabilities
of the Pioneer National Lank, Peoples Bank, and the
Mission National Bank (hereinafter Pioneer National,
Pbopies DA/A, Mission National, and, collectively, the
Selling Banks), lliree single-office banks located in Los
Angeles (combined total deposits of $21.9 million).
The Acquiring Bank operates 22 branch offices
within Los Angeles County and is in competition with
the Selling Banks in that area. The proposed acquisitions would result in the elimination of competition
among the Selling Banks and between them and the
Acquiring Bank. Although a high level of concentration in commercial banking exists in Los Angeles
County, it would not he significantly increased by the
proposed acquisitions.

BOONTON NATIONAL BANK OF PARSIFPANY-TKOY HII.US. PARSIPTANY-TKOY HIJ.I.S, N.J.,
COMPANY OF MORRIS COUNTY, MORRISTOWN, N.J.

AND TRUST

Banking offices
Total assets

Name of bank and type of transaction

The Boonton National Bank of Parsinnany-Troy Hills. Parsinnany-Troy Hills.
N J . (4274), with
" " . . . . . . . . . . . . V . . . . .T:
and Trust Company of Morris County, Morristown, N.J., which had
consolidated Jan. 27, 1967, under charter of the former bank (4274) and with
title "Trust Company National Bank." The consolidated bank at date of
consolidation had

COMPTROT.T,KH'S

On October 17, 1966, The Boonton National Bank
of Parsippany-Troy Hills, Parsippany-Troy Hills, N.J.,
with IPC deposits of $17 million, and the Trust Company of Morris County, Morristown, N.J., with IPC
deposits of $84 million, applied to the Comptroller of
the Currency for permission to consolidate under the
charter of the former and with the title "Trust Company National Bank," with its main office in Morristown, N.J.
Parsippany-Troy Hills, with a population of 42,500,
is located in northwestern New Jersey, within the
New York metropolitan area. It is estimated that 40
percent of the county's work force is employed in New
York City and Newark, N.J. Morris County, especially
Parsippany-Truy Hills, has enjoyed exlreinely rapid
population growth in recent yeais, and this growth
ljuas Apuiiid i/iukiunil /CskLc/iti&l COZafeZuCtkA.

The

urea is also witnessing a moderate industrial boom,
42

140, 389, 368

principally in light manufacturing. The excellent highway system now being built in Morris County should
result in the continued growth of all segments of its
economy.
Morristown, the county seat of Morris County, has
a population of 20,800, and is located 7 miles southwest of Parsippany-Troy Hills. It is the retail center
of its sector of the county. The estimated dollar value
of such sales in 1965 is $100 million, a figure far in
excess of the purchasing power of Morristown residents. Morristown is also a center for services such as
law and medicine. In other respects, Morristown and
vicinity is much like Parsippany-Troy Hills.
The Boonton National Bank of Parsippany-Troy
Hills has its main office in that city and has four
branches within a 4-mile radius of the main office.
While only one other hank has ofnV^s near a "Rnnntnn
N^ORSl Bank ofSce, there Ml intense rnmppHtfnn frnm
the large banks in Newark and New York. Local

branches of savings and loan institutions also compete for savings and for mortgage loans.
The Trust Company of Morris County, with nine
branches in the surrounding area, is one of three banks
headquartered in Morristown. Each of the other banks
has total resources in excess of $100 million. In addition to competing among themselves, they are all faced
with intense competition from the large Newark and
New York financial institutions.
The principal problems faced by the Boonton bank
stem from its limited size which makes it unable to
modernize and expand its facilities to the extent required by the rapid growth in its service area. For
the same reason, it is unable to offer the sophisticated
trust services demanded by the urbanized middle income residents of its area. Boonton's limited capital
prevents it from competing for the ever larger loans
required by local real estate and industrial developers.
Since the Morris County Trust Company is much
larger than the Boonton National Bank, the above
considerations do not apply directly to it. However,
both banks are confronted by intense competition from
the large Newark and New York financial institutions.
These out-of-town institutions advertise extensively
throughout Morris County, and, as a result, they have
made substantial inroads into both the savings and
lending business of the receiving bank. The competitive position of these out-of-town banks is greatly enhanced by the fact that many Morris County residents
work in Newark and New York.
Culmination of this proposed consolidation will be
in the public interest. It will give residents of the
Parsippany-Troy Hills area access to the efficient trust
department operated by the Morris County Trust Co.
It will also bring about the modernization of banking
facilities and services offered in that area. The increased lending limits will enable area entrepreneurs
to satisfy their credit requirements locally. Most im-

portant, the consolidated bank will be large enough
to advertise and pay interest rates sufficient to stop
the flow of savings from this section of Morris County
to New York. This retention of local money, plus the
ability to make larger loans, will go far toward making
the area financially independent.
Because the service areas of these two banks overlap
only slightly, consummation of this proposed consolidation will have no significant adverse effect on competition but will, on the contrary, promote competition
with the large financial institutions operating throughout the area.
Having considered this consolidation application in
the light of the statutory criteria, this Office has determinated that it is in the public interest, and the application is, therefore, approved.
DECEMBER 22,1966.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Boonton National, chartered in 1890, has five offices
in Morris County, N.J. As of June 30,1966, it had total
assets of $21,569,000, total deposits of $19,163,000,
total loans of $10,695,000, and total capital accounts
of $1,379,000.
Trust Company, chartered in 1892, is the largest
commercial bank in Morris County. It has 10 offices in
Morris County and, as of June 30, 1966, had total assets of $114,004,000, total deposits of $102,259,000,
total loans of $75,509,000, and total capital accounts of
$7,446,000.
Head offices of the two banks are less than 8 miles
apart and a recently established branch of Boonton
National is within 2-3 miles of two offices of Trust
Company. It would appear that the consolidation
would eliminate substantial competition between the
two banks and would increase the already high level
of concentration among commercial banks in the
county.

THE CENTRAL NATIONAL BANK OF COLUMBIA, COLUMBIA, PA., AND NATIONAL BANK & TRUST CO. OF CENTRAL
PENNSYLVANIA, YORK, PA.
Banking offices
Name of bank and type of transaction

Total assets

To be

operation

The Central National Bank of Columbia, Columbia, Pa. (3873), with
and National Bank & Trust Co. of Central Pennsylvania, York, Pa. (694),
which had

$7, 117,903

216, 940, 187

operated

1
18

merged Jan. 28, 1967, under charter and title of the latter bank (694). The

merged bank at date of merger had

224, 058, 089

COMPTROLLER'S DECISION

On November 2, 1966, The Central National Bank
of Columbia, Columbia, Pa., with IPC deposits of $5.6
million and the National Bank & Trust Co. of Central
Pennsylvania, York, Pa., with IPC deposits of $173.8
million, applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter,
Columbia, Pa., located in Lancaster County, Pa.,
has a population of about 12,000 and serves an additional 8,000 persons residing in its immediate trade
area. The city is located in southeastern Pennsylvania
about midway between York, Pa., and Lancaster, Pa.
Employment in Columbia is at a high level with local
manufacturing plants providing work for 3,000. Many
other residents commute to Lancaster for employment.
The Central National Bank of Columbia, Columbia,
Pa., is a single-unit bank which was organized in April
21,1888. This small bank, which has always attempted
to keep up with the financial demands of the locality
it served, has found it increasingly difficult to compete
with other local banks in today's banking market. All
its efforts to obtain young, capable, and aggressive successors to management have failed. The Farmers National Bank of Lancaster, with assets of $120 million
and the American Bank & Trust Co= of Reading, Pa.,
with resources of almost $300 million, now compete in
Columbia.
The city of York is located in York County, Pa.,
which is contiguous to Lancaster County, Pa. While
this area is regarded as primarily industrial, it also
ranks high in agricultural production because some of
the richest farmland in the nation is located in this
region.
The National Bank & Trust Co. of Central Pennsylvania, was originally chartered in 1845 and now operates 18 offices. This bank is highly aggressive and
encounters intense competition from numerous other
banks in York and the surrounding areas. The bank
is capably managed by a full staff of competent officers who provide aggressive leadership.

Competition between the participating banks is
virtually nonexistent. While the National Bank & Trust
Co. has an office within 5 miles of Central National,
the areas are separated by the Susquehanna River.
This natural barrier between the two locations serves
to prevent effective competition between the banks.
The resulting bank will be able to offer a broader
range of services to the customers of the merging bank,
including trust activities, data processing facilities, and
a greater lending capacity. Consummation of the
merger will also resolve the management problems of
the merging bank. It will enable the resulting bank to
compete more effectively with the larger banks now
operating in the area and thus bring to the residents
the full benefits that flow from aggressive competition.
Applying the statutory criteria, we conclude that the
proposal is in the public interest, and the application is,
therefore, approved.
DECEMBER 29,

1966.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank & Trust Co. (hereinafter the Charter
Bank) is the largest commercial bank in a tricounty
area (viz., York, Dauphin, and Cumberland) of central Pennsylvania in which its 18 offices are located.
As of June 30, 1966, the Charter Bank had total assets
of $215,008,000 and total deposits of $185,819,000.
The Central National Bank of Columbia (hereinafter the Merging Bank), a unit bank, as of June 30,
1966, had total assets of $6,926,000 and total deposits of $6,121,000.
The application indicates that competition between
the merging banks is "minimal" even though their
nearest offices are some 4.7 miles apart. However, even
if existing competition between the two banks is not
substantial, the merger would foreclose the development of greater competition between them in the future through the establishment by Charter Bank of
de novo branches, in Merging Bank's service area, as
permitted under Pennsylvania law.

THE

FIRST NATIONAL BANK OF ELSINORE, ELSINORE, CALIF., AND FIRST NATIONAL BANK & TRUST CO.,
ONTARIO, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Elsinore, Elsinore, Calif. (11922), with
and First National Bank& Trust Co., Ontario, Calif. (6268), which had
merged Jan. 31, 1967, under charter and title of the latter bank (6268). The
merged bank at date of merger had

COMPTROLLERS

DECISION

On October 17, 1966, The First National Bank of
Elsinore, Elsinore, Calif., with IPC deposits of $5.8
million, and First National Bank & Trust Co., Ontario,
Calif., with IPC deposits of $36.5 million, applied to
the Comptroller of the Currency to merge under the
charter and with the title of the latter.
Both banks were organized under State charters in
1887. The Ontario bank converted to a National bank
in 1902, and the Elsinore bank became a National
bank in 1922. The charter bank maintains its main
office and two branches in Ontario, and operates six
other branches within a 19-mile radius of Ontario. The
Elsinore bank, with only one office, has applied for
permission to open a branch in Elsinore.
Ontario, with a population of 66,000, is located at
the west end of San Bernardino County, 45 miles east
of Los Angeles. The area is experiencing rapid growth,
both residential and industrial. Its diversified economy
includes agriculture, light and heavy manufacturing,
and residential development. Future prospects are
favorable, especially for industrial expansion.
Elsinore is located 45 miles southeast of Ontario,
and has a population of 2,630. It is situated in a
sparsely populated valley, where a chronic water shortage has threatened its agricultural economy and undermined the town's resort potential. The water difficulties have recently been stabilized, however, and
the town's growth prospects are now favorable.
The closest banking offices of the participating banks
are 23 miles apart. There is little or no competition
between them. Competition with both banks is primarily provided by branches of the large California
banking systems. Three of these, Bank of America,
Security First National Bank of Los Angeles, and
United California Bank, operate 18 branches in the
service area of the charter bank, and three branches
near the Elsinore bank.

$6, 502, 148
46, 277, 837

To be
operated
1
10

52, 779, 986

The merger will have very little effect on the competitive banking structure of San Bernardino and
Riverside counties. The Bank of America holds 46
percent of the deposits in the former county, and Security First National Bank of Los Angeles holds 27.4
percent, while the charter bank holds 7 percent. The
merger will not affect these percentages.
The Elsinore bank is currently the only bank in the
town of Elsinore. Its lending limit of $46,000 is not
adequate to provide agricultural loans or to finance
anticipated resort development. The merger will overcome this banking deficiency in Elsinore and will provide the residents with trust facilities and a broader
range of modern banking conveniences.
Applying the statutory criteria to this proposal, we
conclude that it is in the public interest. The application is therefore approved.
DECEMBER 28,1966.
SUMMARY OF REPORT BY ATTORNEY GENERAL

This is an application to combine the First National
Bank of Ontario, in San Bernardino County, Calif.,
and The First National Bank of Elsinore, in Riverside
County, Calif. The nearest offices of the respective
banks are 23 miles distant from each other, and it does
not appear from the available information that the
two institutions are in significant competition with each
other.
Each of the banks is relatively small in its respective
area. First National of Ontario has only 7 percent
of the bank deposits in San Bernardino County. In
contrast, its leading competitors, Bank of America
and Security First National Bank of Los Angeles, both
of which are large California branch bank institutions,
have 46 percent and 27.4 percent, respectively. First
National of Elsinore has only 1.4 percent of the total
bank deposits in Riverside County, whereas its leading competitors, also Security First National Bank of

Los Angeles and Bank of America, have 50.5 percent
and 31.4 percent, respectively.
In view of the limited amount of direct competition

between the applicant banks and their relatively small
size in their respective areas, it is our view that the
proposed merger will not adversely affect competition.

T H E FIRST NATIONAL BANK OF GENESEE, GENESEE, PA., AND T H E GRANGE NATIONAL BANK OF POTTER COUNTY
AT ULYSSES, ULYSSES, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Genesee, Genesee, Pa. (9783), with
and The Grange National Bank of Potter County at Ulysses, Ulysses, Pa.
(8739), which had
merged Jan. 31, 1967, under charter of the latter bank (8739) and with title
"Grange National Bank of Potter County." The merged bank at date of
merger had

COMPTROLLER S DECISION

On October 25, 1966, The First National Bank of
Genesee, Genesee, Pa., and The Grange National Bank
of Potter County at Ulysses, Ulysses, Pa., applied to
the Comptroller of the Currency to merge under the
charter of the latter and with the title of "Grange National Bank of Potter County."
Both banks are located in Potter County in northcentral Pennsylvania, near the New York border. The
economy of the area consists of dairy and potato farming, and some manufacturing of electric equipment
and wood and leather products. The charter bank
is the only bank in Ulysses, a town of approximately
500, and serves 2,500 persons in its service area. Genesee, which lies 10 miles northwest of Ulysses, has a
population of over 800. The merging bank, as the only
bank in Genesee, serves about 2,500 people in outlying
areas.
The Grange National Bank of Potter County at
Ulysses, which was chartered in 1907, now has IPC
deposits of $2 million. The First National Bank of
Genesee, chartered in 1910, presently has IPC deposits
of $1.5 million. These small banks, though only 10
miles apart, cumpd^ but slightly due largely to the
topography of the terrain that separates them. Their

To be

$1,904,411
2, 716, 210
4, 620, 621

principal competition derives from five larger banks
located within a 20-mile radius.
Through this merger the management problems of
the Genesee bank will be resolved. The charter bank
has had to lend management assistance to the merging bank on different occasions in the past. The union
of these banks will provide the residents of both Ulysses
and Genesee with a bank more able to meet their credit
needs.
Applying the statutory criteria to this proposal, it is
concluded that it is in the public interest. The merger,
therefore, is approved.
DECEMBER 27,

1966.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger of Genesee Bank into Grange
National involves two very small banks, situated at
least 10 miles apart, in an economically depressed area.
The present competition between these banks that
would be eliminated by the merger does not appear to
be significant. Moreover, the five other banks in the
area appear to offer competition to Gcncsec Bank and
Grange National. Also, the presently shrinking economic base of Potter County, Pa., would seem to forestall the development of ar<y siihsta.rrtia.1 potential competition between the two banks in the near future.

THE

FIRST NATIONAL BANK OF LANDISVILLE, LANDISVILLE, PA., AND T H E GONESTOGA NATIONAL BANK OF
LANCASTER, LANCASTER, PA.

Total assets

Name of bank and type of transaction

To be
operated

In
operation
The First National Bank of Landisville, Landisville; Pa. (9312), with
and The Gonestoga National Bank of Lancaster, Lancaster, Pa, (3987), which
had
merged Jan. 31, 1967, under charter of the latter bank (3987) and with title
"The Conestoga National Bank." The merged bank at date of merger had..

COMPTROLLER'S DECISION

On October 18, 1966, The First National Bank of
Landisville, Landisville, Pa., and The Gonestoga National Bank of Lancaster, Lancaster, Pa,, applied to
the Office of the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of "The Gonestoga National Bank."
The charter bank, with IPG deposits of $46.7 million, is headquartered in the city of Lancaster whose
population is 60,000. It operates branches in Millersville, Lititz Springs, and Manheim Township, and has
approval for a branch in Centerville. The charter bank
serves a trade area extending 8 miles east and west of
Lancaster and 12 miles north and south. Lancaster and
the bank's trade area are located in the southeastern
part of the State in the county of Lancaster whose
•population is estimated to be 300,000. The economy of
the area, which has seen considerable activity in recent
years, is mixed and ranges across a broad spectrum
from industrial and residential construction to agricultural activity.
Banking competition in Lancaster County and in
the area of the charter bank is intense. Within the
county there are 24 banks operating 55 offices; within
the trade area of Lancaster there are 16 banks. At the
present time, the American Bank & Trust Co. of
Pennsylvania, Reading, Pa., with deposits of $245 million, operates a branch in Reamstown 12 miles northeast of Lititz where the charter bank has a branch
and is planning a merger with Columbia Trust Co.,
Columbia, Pa., 10 miles west of Lancaster, and the
National Bank & Trust Co. of Central Pennsylvania,
York, Pa., with deposits of $185 million, is planning
to merge with the Central National Bank of Columbia. These two out-of-county banks, both of which are
Harger than the charier bank, now corupete aggressively
in Lancaster Courrly and will, if their mergers are
consummated, intensify the competition with the Lancaster banks to the ultimate benefit of the residents of

$10, 580, 738

59,177,479

69,758,217 I

the area. This merger will not alter the relative standing of the receiving bank in Lancaster in relation to
the size with the Fulton National Bank, which has
deposits of $76 million, and the Lancaster County
Farmers National Bank, which has deposits of $97
million.
The merging bank, with IPG deposits of $8.7 million,
is headquartered in Landisville, 7 miles northwest of
Lancaster, and has one branch located nearby in Rohrerstown. Its service area is primarily limited to East
Hempfield Township which has a population of 8,417,
and is contained within the service area of the charter
bank. Landisville and East Hempfield Township are
residential and agricultural in nature, although some
light industry exists. Though the merging bank has
experienced satisfactory growth over the years, it now
faces a managerial succession problem as no individual appears readily available to replace the bank's
chief executive who is now planning to retire. Competition is afforded the merging bank by offices of the
Fulton National Bank, the Lancaster County Farmers
National Bank, and four offices of other banks located
within 10 miles of Landisville.
The merger will provide additional consumer credit
services for the Landisville area, another source for full
trust facilities which are presently available only from
competing commerical banks, and economies of operation due to the availability of automation and the
consolidation of operations. The prime benefit of this
merger is that it will solve the merging bank's management succession problem. The anticipated increased
credit needs of the area's continually expanding economy will be better met by the greater lending capacity
of the resulting bank.
Although the proposed merger will eliminate some
competition between the merging hanks> this will not
be substantial in relation to the total competition existing among the numerous offices of other banks within
10 miles of Landisville. The merger will not so enlarge
47

ance through merger of nine banks with at least $68
million in assets, $57 million in deposits and $32 million in loans. This acquisition trend would be continued by consummation of the proposed merger.
As Conestoga National's •service area includes that of
Landisville, the banks are in direct competition with
each other. Necessarily, consummation of this merger
would eliminate existing competition between the. two.
Moreover, in the Landisville area only three banks
will compete after the merger, and the only locally
owned bank will be eliminated. In the resulting bank*s
service area, the present high level of concentration
will be further increased.

the receiving bank as to change its position in relation
to the other commercial banks in the area.
Applying the statutory criteria to the proposed
merger, it is concluded that the merger is in the public
interest, and the application is, therefore, approved.
DECEMBER 29,

1966

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger of Conestoga National Bank
and First National Bank of Landkville involves two
banks headquartered in Lancaster County, Pa. This
county, in the last 5 years, has witnessed the disappear*

THE RUTLAND COUNTY BANK, RUTLAND, V T . , AND T H E HOWARD NATIONAL BANK & TRUST CO., BURLINGTON, V T .
Bankin g offices
Total assets

Name of bank and type of transaction

The Rutland County Bank, Rutland, Vt., with
and The Howard National Bank & Trust Co., Burlington, Vt. (1698), which
had
merged Jan. 31, 1967, under charter and title of the latter bank (1698). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On August 25, 1966, The Howard National Bank
& Trust Co., Burlington, Vt., with IPC deposits of
$48 million, and The Rutland County Bank, Rutland,
Vt., with IPC deposits of $15 million, applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
Burlington, with a population of 38,000, is Vermont's largest city. It is located in northwestern Vermont, on the direct route from Montreal to Boston.
The rapidly growing economy of Burlington and its
environs is well balanced and diversified with manufacturing and trade, as well as education and agriculture, making important contributions. Construction of
various kinds is proceeding at a brisk pace. In addition,
the recreation industry contributes substantially to the
economy of the entire region. The fact that Burlington
is adequately served by highways, railroads, and airlines augurs well for the continued growth of all segments of its economy.
Rutland, with a population of 18,325, is Vermont's
second largest city. It is located in central Vermont,

To be
operated

In
operation
$18, 241, 668

65, 776, 326

84, 013, 194

68 miles south of Burlington. Rutland is the trading
center for a population of approximately 110,000. The
area economy is based on agriculture, manufacturing,
recreation, and trade. Until a few years ago, population
and economic growth in this area was quite moderate.
Recently, however, the development of several ski
areas and the establishment of several new manufacturing plants, plus the expansion of existing plants, has
stimulated employment and housing construction.
Higher milk prices have also strengthened the area's
large dairy farming industry.
The charter bank has four offices located within a 7mile radius of Burlington with another branch approved but not yet opened. It competes with the $81
million Chittende.n Trust Co., which is the dominant
bank in the Burlington area. Ten other commercial
banks also compete in the Burlington area. In addition, several large metropolitan banks actively solicit
business there.
The Rutland County Bank, the smallest commercial
bank in Rutland and its immediate vicinity, competes
with two other commercial banks located in the city

and with two mutual savings banks, as well as with a
variety of other financial institutions. Each of these
mutual savings banks has a greater percentage of the
area's loans and deposits than does the merging bank.
The merging bank faces problems common to many
small banks. Its frontline managers are nearing retirement and adequate replacements are not available; its
limited size prevents it from offering specialized banking services and from exploiting the economies of
operation made possible by computers; and its low
lending limits prevent it from competing for the
larger loans required by area businessmen.
Consummation of this proposed merger will be in
the public interest. It will bring to Rutland a banking
institution more capable of serving the community's
banking needs. The Rutland branch of the resulting
bank will offer accounts receivable and warehouse
receipts financing, and specialized trust services, none
of which are now offered by the merging bank, although they are offered by that bank's competitors.
The Rutland branch will have access to the efficient
computerized accounting system of the charter bank
and will offer a broader scope of competitive banking
services to the residents. The increased lending capacity
will enable the Rutland branch to compete vigorously
for large loans.
Because the service areas of the two banks do not
overlap, consummation of the proposed merger will
have no adverse effect on competition but will, to the
contrary, promote competition with the larger banks
operating in the respective cities.
Having considered the merger application in the
light of the statutory criteria, this Office has determined

that it is in the public interest, and the application is,
therefore, approved.
OCTOBER 25,1966.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Howard National Bank & Trust Go. (Charter
Bank) was organized in 1870, and operates from its
head office in Burlington (population 36,400), as well
as seven branches situated throughout the northern
portion of the State. One new office has been approved
but not yet opened. The Charter Bank has had five
mergers or acquisitions within the past 10 years, and
as of April 5, 1966, had total assets of $57,974,000,
total deposits of $50,804,000, total net loans and discounts of $41,978,000, and total capital accounts of
$4,636,000, with a lending limit of $443,000.
The Rutland County Bank (Merging Bank) was
incorporated in 1861, converted to a National bank
in 1864, and again became a State bank in 1960. Its
only office is located in Rutland, Vt. (population
18,325), and it serves an area with a radius of 24 miles
(service area population 110,000). The service area
is experiencing an accelerated rate of growth through
business, industrial, and population expansion. As of
April 5, 1966, the Merging Bank had total assets of
$17,963,000, total deposits fo $16,295,000, total net
loans and discounts of $10,689,000, and total capital
accounts of $1,393,000, with a lending limit of
$108,000.
Although there is presently virtually no competition
between the merging banks, the proposed merger
would have the effect of eliminating potential competition between them through de novo branching.

THE BARK RIVER STATE BANK, BARK RIVER, MICH., AND T H E ESCANABA NATIONAL BANK, ESGANABA, MICH.
Banking offices
Name of bank and type of transaction

Total assets

To be
operated

operation
The Bark River State Bank, Bark River, Mich., with
was purchased Feb. 14, 1967, by The Escanaba National Bank, Escanaba,
Mich. (8496), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On November 1, 1966, The Escanaba National
Bank, Escanaba, Mir.h., applied to the Office of
the Comptroller of the Currency for permission to

$2, 387, 457

15, 362, 764
16, 956, 805

2
3

acquire the assets and assume the liabilities of The
Bark River State Bank, Bark River, Mich.
Esranaba, which has a population of over 15,000,
and is the county seat and trading center of Delta

County, has experienced lillle fluclusdlun in
tiun growth iuid rate of employment. Industry plays a
major role ki the economy of the area, with agriculture
ajul tourism pruviding secondary support. The three
major concerns in Escanaba are the Ilarnischfegcr
Corp., employing 1,000 workers, tlie Mead O*p>, employing 800, and the Birds Eye Veneer Co., employing 200.
The acquiring bai«k, The Escanaba National Bank,
with IPC deposits of $13 million, is the second largest
bank in Delta County. Founded in 1907, the bank
presently operates a branch office in Rapid River, a
town with a population of 207, located 20 miles north
of Escanaba.
Bark River, with a population of 400, is a small
fanning Community located about 11 miles west of
Escanaba. The area is dependent for its livelihood
upon daily fanning and mink ranching. Most of the
fanner* also wcuk in industries located in Escanaha.
The selling bank, The Bark River State Bank, with
IPC deposits of •$? inillmn, is lhe smallest, single-office
bank in the county. Organized in 1910, the hank has a
veiy limited lending capacity of $20,000 and is presently faced with a management succession problem
deriving from its small size.
Commercial banking services and credit needs in
Delta County are provided by several banks- Tn addition to the two participating hanks, the State Bank of
Escanaba and the First National Bank of Escanaba,
bolh in Escanaha, and the First National Bank of
Gladstone and the Gladstone State Savings Bank, both
in Gladstone, compete in lhe county. One savings and
loan association, three insurance companies, 22 credit
unions, four sales finance companies, three personal
loan companies and two direct lending agencies of the
government «rf*u wrivkc lhefiii<uiii<vineeds \A lhe ie5idents.
Consummation of lh»? propose J transaction will
scarcely afTfCt the competitive position of tin; acquiring
bank as it will slill rank second in size in the area.
The First National Bank of Esc-anaba is larger. The
Convenience and needs of this aiea will thus be better
s«five«l by cuiixmiinialkui of this proposal. BusinessHS
within the Bark River area will have a larger local
banking office to serve their credit needs. Additional

hftrrfc services, snr.h a* modern rrtrctp<tex\7ir]?\ servicing
of checking accounts and installment, loans, and the
placing of security purchases and sale orders for the
bank's customers, will be offered to the Bark River
area residents. The purchase will also solve the management succession problem presently faced by the
selling bank.
Considered in the light of the statutory criteria, the
puichase is deterrmried tn h?. in the public, interest and
is, therefore, approved.
JANUARY 10,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The banks involved in this proposal are located in
Delta County, which has a population of 35,000 and
is located in the Upper Michigan Peninsula. This
county is presently served by six cornrmftrcial banks, the
lliree largest of which are located in Escanaba. The
fourth and fiflh largest are located in CrSarktone, which
is 9 miles north of Escanaba. The Bark River State
Bank is headquartered 11 miles west of the latter city.
Escanaba National Bank is the second largest bank
in Delia County. Il presently arrnrmts for 26 and 27.2
percent, respectively, of Delta. County's commercial
banking deposits and loans, while the Bark River State
Bank accounts for 3.7 perrHnL The three Escanaba
banks presently account, for 79-6 and 83.7 percent, respectively, of the county's deposits and loans. As a result of tills transaction^, lhe Fscanaha National Bank
would remain lhe county's second largest hanl^ slightly
smaller than lhe Fir*t National Bank ofTCsranaria.Tn
addition, the three Esr.anaha hanks would have ft3.3
and 87.4 perr.ent^ nftsj-iertively, of the county's deposits
and loans.
The pritposed lrierrap.r would eliminate what, appears
lu tie *o<Yrc. y(CM.nt]f

r.x'intmg ccsmpctiticm Ysc.tvfe.Ln.

Escanaba National Bank and Bark River State Bank,
although the extent of this competition is not clear from
the application. Tt would also increase somewhat the
already high level of banking concentration in the
county. However, in view of Bark River's small size
and its limited capacity to provide effective competition, we conclude that the proposed merger worHri not
substantially affect the structure of crrmrnerr.ial hanking in this area.

MIDDLETOWN

STATE BANK, ING., MIDDLETOWN, VA., AND FARMERS
WINCHESTER, VA.

MERCHANTS

NATIONAL BANK,

Bankin g offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation
Middletown State Bank, Inc., Middletown, Va., with
and Farmers & Merchants National Bank, Winchester, Va. (6084), which had.
merged Feb. 18, 1967, under charter and title of the latter bank (6084). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On November 17,1966, the Middletown State Bank,
Inc., Middletown, Va., and the Farmers & Merchants
National Bank, Winchester, Va., applied to the Office
of the Comptroller of the Currency for permission to
merge under the charter and with the title of the latter.
The charter bank, with IPC deposits of $33.3 million, is located in Winchester, the county seat of Frederick County, the northernmost county in Virginia.
Winchester, 72 miles from Washington, D.C., and 40
miles from the industrial city of Hagerstown, Md., is
located at the northernmost entrance to the Shenandoah Valley. The expanding economy of the area
consists mainly of light industry and agriculture, with
the growing of apples the most important agricultural
activity. Residential construction in Winchester is also
important. Included among the largest manufacturing
concerns operating in the area are the National Fruit
Products Co., the Crown, Cork & Seal Co., the Shenandoah Apple Corp., and the American Brake Shoe
Co., each of which employs more than 100 persons.
The Farmers & Merchants National Bank has been
in continuous existence since 1902. Over the years it
has experienced considerable growth. Three branches
of the bank and its main office are situated in Winchester, while a fourth branch is located in Berryville, a town of 1,700 population, in Clarke County.
The participating banks, which compete within the
limits of the merging bank's competence, receive intensive banking competition from other institutions
located in this northern section of Virginia and in
nearby West Virginia. Of the 24 banks that operate
35 offices in competition with the applying banks, five
are subsidiaries of large bank holding companies. Seven
of thpse banks are situated in West Virginia. The other
12 are headquartered in cities and towns within 37
miles of Winchester.
The merging bank, with IPC deposits of $2.5 million, is headquartered in Middletown, a community

$2, 858, 337
39, 201, 420
42,059, 757

3
5
8

of several hundred population located 13 miles south
of Winchester. The bank operates branches in Stephens
City and the Ward Plaza shopping center, 1 mile south
of Winchester. The economy of the area is mixed, and
is composed principally of farming and some residential construction. In addition, lime and cement plants
owned and operated by the Flintkote Corporation are
located in Middletown and Stephens City. In recent
years, several industrial parks have been located between Middletown and Winchester. The prospects for
the area are good with substantial economic growth
anticipated.
The Middletown State Bank, as presently constituted, can not be expected to contribute to, or share
in, this growth in any significant measure. The bank's
small lending limit will not allow it to meet the expanding credit needs of the area. Its chief executive
officer is in ill health and the bank is otherwise lacking
in depth of operating personnel.
While this merger will eliminate the small amount of
competition that presently exists between the participating banks in and around Winchester, such loss
is clearly outweighted by the benefits to be derived from
the merger. The resulting bank, serving Frederick
County, will be better situated to compete more effectively with holding company subsidiary banks serving
this same general area. Through this proposal, the
management problems of the merging bank will be
resolved and the residents of Middletown will obtain
the services of a broader-based and more aggressive
institution. The resulting bank will serve the public
convenience and needs by providing an alternative
banking source more capable of responding to the
growing needs for larger commercial, construction, industrial, and agricultural credits.
The application having been weighed against the
statutory criteria and die proposal having been found
to be in the public interest, the application is, therefore, approved.
JANUARY 6,1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Farmers & Merchants National Bank with resources
in excess of $39 million is presently over twice the size
uf eilhei of the oilier two banks located in Winchester
and from 2 to 10 times the size of 22 banks outside
of Winchester with which it claims to compete. The

T H E OXFORD NATIONAL BANK, OXFORD, N.C.,

proposed merger with Middletown State Bank, Inc.,
which has resources of $2,912,000, will eliminate competition between the two banks, will increase the size
of Farmers & Merchants National Rank by approximately 7.4 percent and will thereby enhance its already
dominant position in its service area.

AND T H E PLANTERS NATIONAL BANK & TRUST CO., ROCKY
MOUNT, N.G.
Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation
The Oxford National Bank, Oxford, N.C. (13896), with
and The Planters National Bank& Trust Co., Rocky Mount, N.G. (10608),
which had
merged Feb. 21, 1967, under charter and title of the latter bank (10608). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 14,1966, The Oxford National Bank,
Oxford, N . C , with IPG deposits of $7 million, and
The Planters National Bank & Trust Co., Rocky
Mount, N . C , with IPC deposits of $56 million, applied
to the Comptroller of the Currency for permission to
merge under the charter and title of the latter.
Rocky Mount, the home-office city of the charter
bank, is on the eastern edge of Nash County, N . C ,
and had a 1960 population of 32,147. In addition to
possessing a considerable amount of light industry,
Rocky Mount serves as a shopping and commercial
center for the surrounding agricultural area. The city
is also a secondary trade center for a large portion of
northeastern North Carolina. The economy of this area
is slowly changing from total dependence on agricultural income to a more balanced reliance on commerce
and light manufacturing. In addition to its main office
and five branches in Rocky Mount, the charter bank
operates 22 offices in 13 other North Carolina towns
and cities.
Oxford, the county seat of Granville County, is the
location of the merging bank and had a 1960 population of 4,978. Situated approximately 67 miles northwest of Rocky Mount, it is also the commercial trade
center for Granville County. The agricultural economy
of Granville County has traditionally been based primarily on tobacco, but in recent yenrs mannfacturine;
has begun to expand rapidly.
Because the service areas of these two banks do not
52

$9, 905, 043

75 139 953

85,044,996

overlap, consummation of the proposed merger will
have no adverse effect on competition. The closest
branch of the charter bank to Oxford is located approximately 59 miles to the southeast in Nashville, N.C.
This merger will permit the charter bank to meet more
effectively the strong competition faced at all its present locations, especially with the State's largest chain
banks such as the $1.1 billion Wachovia Bank & Trust
Co.
Consummation of this proposed merger will further
the public convenience and needs. The resulting bank
will bring trust services and a farm management program to the Oxford office. The Oxford facilities will
be modernized and expanded, and thus will serve the
public with greater efficiency and convenience. The
larger lending limit and more liberal lending policies
of the resulting bank will facilitate responsive service
to the Oxford area residents.
Having considered the merger application in the
light of the statutory criteria, this Office has determined
that it is in the public interest, and the application is,
therefore, approved.
JANUARY 17,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Oxford National Bank (Merging Bank) was
organized in 1933 and has no merger or acquisition
history. It operates one office in Oxford and has applied for permission to open two de novo branches in
that community. As of June 30, 1966, it had total as-

of $69,710,000, total loans of $33,903,000, and total
capital accounts of $4,728,000.
Since Planters has no offices closer than 59 miles
from the Merging Bank, the two banks probably do
not compete with each other to a significant degree.
The proposed merger would, however, eliminate potential competition. North Carolina banking law permits
unrestricted de novo brandling and Planters has taken
advantage of these provisions several times in the past.
Sixteen of its twenty-five existing and planned offices
arc branches established de novo and tliei e would be no
legal impediment to Planters' establisimiexiL of a de
novo branch in Oxford.

sets of $8,815,000, total deposits of $7,579,000, total
loans of $4,798,000, and total capital accounts of
$954,000.
Planters National Bank & Trust Go. (Planters) was
organized in 1899 and operated one office in Rocky
Mount, N.C., until 1950. It is the ninth largest commercial bank in North Carolina, with 20 offices in 12
communities, three more de novo branches approved
but not yet opened, and two more offices acquired
through two recently approved mergers. Including
these, two offices, Planters has added eight branches
through mergers and acquisitions. As of June 30,1966,
Planters had total assets of $75,801,000, total deposits
*

COUNTY BANK & TRUST CO., CAMBRIDGE, MASS., AND SOMERVILLE NATIONAL BANK, SOMERVILLE, MASS.
Banking offices
Name of bank and type of transaction

Total assets

County Bank & Trust Co., Cambridge, Mass., with
and Somerville National Bank, Somerville, Mass. (4771), which had
merged Feb. 24, 1967, under charter of the latter bank (4771) and with title
"The County Bank, N.A." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 1, 1966, the County Bank & Trust
Co., Cambridge, Mass., with IPC deposits of $13.1
million, and the Somerville National Bank, Somerville,
Mass., with IPC deposits of $21.8 million, applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and title of "The
County Bank, N.A.," with its head office to be located
in Cambridge.
The cities of Cambridge and Somerville are densely
populated residential suburbs of the metropolitan Boston, Mass., area. Both have diversified economies, with
wholesale and retail concerns and industrial development playing significant roles. Urban renewal is being
advanced; new industrial construction will begin in the
immediate future; a new hospital and high school are
planned; and, a large shopping center is being developed in the immediate area of the cities.
Both banks are small institutions competing in the
metropolitan area of Boston wherein a multitude of
banking facilities exist; and both are controlled by a
registered bank holding company.
The merging bank, County Bank & Trust Co., was
organized under the laws of Massachusetts in 1933,

$17, 901, 885
29,367, 338
47,269,223

To be
operated

In
operation
2
3

and ever since its organization has been a subsidiary of
Shawmut Association, Inc. It has shown a steady
growth in loans and earnings and has modernized its
procedures and makes full use of computer services.
County Bank is ably headed by its president, but lacks
depth in its staff. The president anticipates retirement
within the year and the present staff does not include
a qualified successor. County Bank now has less than
1 percent of deposits and loans in the trading area of
1 million people.
The charter bank, Somerville National Bank, was
organized under the National Bank Act in 1892, and
has been a subsidiary of Shawmut Association, Inc.,
since 1947. The charter bank, with its two branches,
has experienced sound growth over the years. Even
with steady growth it still has less than 1 percent of all
deposits and loans in the trading area. It also has
executive staff of well trained and knowledgeable
men.
Because of common ownership by llie Shawmut Association, Inc., this merger will not have any effect on
competition between the two banks.
The competition provided by commercial banks located in the trading area is extremely intense with 22
53

romrneiT.ial banks having 135 rrfnr.es and rlqoosits cif
$4.7 billion, and loans of $3 billion. In addition, there
are mutual savings banks, savings and loan associations, industrial banks, insurance companies, etc.,
within the trading area. Consummation of the merger
will provide the resulting bank with less than 1 percent
of all deposits and all loans in the trading area.
The merger would create a bank with greater lending limits more able to effectively render an expanded
service redounding to the public convenience. It would
certainly foster more effective competition with other
banks in the Boston area.
Applying the statutory criteria to the proposed

mergftr, we mncUnJe ilia I il is in ihe public interest, and
the application is, therefore, approved.
NOVEMBER 14,

1966.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Somerville National Rank, organized in 1892,
and the County Bank & Trust Co., organized in 1933,
are both majority-owned (79.33 and 67.22 percent,
respectively) subsidiaries of Shawmut Association, the
former bank since 1947 and the latter bank since 1933.
For tliis reason, and because they account for a relatively small share of the banking business in their service areas, the proposed merger probably will not
produce significant anticompetitive effects.

BANK OF BLUE MOUNTAIN, BLUE MOUNTAIN, MISS., AND FIRST NATIONAL BANK, N E W ALBANY, MISS.

Total assets

Name of bank and type of transaction

operation
Bank of Blue Mountain, Blue Mountain, Miss., with
and First National Bank, New Albany, Miss. (15519), which had
merged Feb. 28, 1967, under charter and title of the latter bank (15519). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 15,1966, the Bank of Blue Mountain,
Blue Mountain, Miss., with IPC deposits of $4 million,
and the First National Bank, New Albany, Miss., with
IPC deposits of $6.7 million, applied to the Comptroller of the Currency for permission to merge under
the charter and with the title of the latter.
The charter bank operates three offices in New
Albany, which is situated in the north-central section
of Mississippi. New Albany has a population of appror/ffmsrtely 5,600 persons and is the commercial trade
center for a service mea euuumpassiug appiuximalely
42,000 persons. While fanning is the chief activity in
this region, with cotton and soybeans the main crops,
the importance of manufacturing continues to
increase.
Blue Mountain, the hunie-uflice city of the merging
bank, is located 20 miles nurth of New Albany and
has a pupul&liuxi uf approximately 580 persone. Except
for Blue Mountain College, with an enrollment of
Is agil^i/Aui^ly U a u d . Tllu SOU&Ag hutk OpWCMX, «&®

branch in Ashland and one in Hickory Flat, 29 miles
54

To be
operated

$5, 188, 531
8, 450, 636
13,615,913 J

northwest and 10 miles southwest, respectively, of
Blue Mountain.
Competition between the participating banks will
not be adversely affected as the overlap in service
areas is minimal. The merging bank's offices at Hickory
Flat and Blue Mountain are each about 12 miles from
the closest office of the charter bank. The merger
will increase competition by permitting the resulting
bank to compete more effectively with the $33 million
Peoples Bank & Trust Co., which is headquartered in
Tupelo, 25 lYiiV.s sonthpast of New Albany, and which
has branches in rvmth thr. P»fcir. Mountain and the New
Albany service areas.
Consummation of the proposed merger will further
die public convenience and needs. The resulting bank
will be able to offer a broader range of services to the
customers of the merging bank, including par banking, trust services, and dealer loans. The sfin.sonn.1 needs
of the surrounding agricultural preas will be more
effectively met due to a more balanced financial Rtruc\\iH QOOUrS SKft RggPeMive nnd ih}<9 T/^rninifitratinn fnr
the resulting bank in the future.

Applying the statutory criteria, this Office has determinftd that the proposal is in the public interest, and
the application is, therefore, approved.
JANUARY 18,1967.

The closest offices of the participating banks are 12
miles distant, and there is some competition between
the merging banks, although it is termed in the application as "not very strong."

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National Bank, New Albany, Miss., has assets of
$8,571,000 and deposits of $7,767,000. Its three offices
are located in New Albany, a town of 5,600 in northeast Mississippi.
Bank of Blue Mountain, Blue Mountain, Miss., has
assets of $4,676,000, and deposits of $4,356,000. It has
a total of three offices, in Blue Mountain (population
580), Ashland (350), and Hickory Flat (400).

Among the eight banks which would appear to be

P e t i t o r s ^ ^ t h e ™*&* b a j l k s > F i r s t
^eSt W l t h 2 0 ' 5 P e r c e n t of t o t a l de"
P o s l t s h e l d b ? t h e m > a n d B a n k o f B I u e Mountain,
fourth smallest, has 11.4 percent of such deposits.
T h e
merger would eliminate whatever competition
presently exists between the two banks and would
enhance First National's market position in its service
area.

e mOS

com

N a U o n a l 1S t h e l a r

TIISCARORA S T A T E BANK, BT.ATRS MTT.T.S5 P A . , AND T H E JTTNTATA VAT.T.F-Y N A T I O N A L BANK, M I F F L I N T O W N , P A .
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

operation
Tuscarora State Bank, Blairs Mills, Pa., with
and The Juniata Valley National Bank, Mifflintown, Pa. (5147), which had..
merged Feb. 28, 1967, under charter and title of the latter bank (5147). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On November 4, 1966, the Tuscarora State Bank,
Blairs Mills, Pa., and The Juniata Valley National
Bank, Mifflintown, Pa., applied to the Comptroller of
the Currency to merge under the charter and with the
title of the latter.
The Juniata Valley National Bank, with IPC
deposits of $16 million, was organized in 1867 and converted to a National banking association in 1898. It
maintains five banking offices, four of which arc in
Juniata County, and the fifth of which is in Perry
County. The Tuscarora State Bank was organized in
1898 and presently has IPC deposits of less than $1
million. It operates no branches.
Both banks are located in isolated, mountainous
areas of central Pennsylvania. Dairy and poultry farming, and a few related industries, constitute the
economy of the area. Mifflintown, the headquarters of
the receiving bank, has a peculation of 900 and serves
u trading area of over 20,000. Blairs Milk, the home of
the merging bank, is a, town of 100 and serves as the
trading center for approximately 800.
The main offices of the two banks are 33 miles apart

$1,491,859
19, 498, 652
20, 990, 547

1
4
5

and the Tuscarora State Bank is 30 miles southwest of
Juniata Valley National Bank's closest branch. Since
the participating banks serve only small local areas,
they do not compete with each other in any degree.
The receiving bank competes with three large banks in
Juniata County: two branches of Russell National
Bank of Lewistown, The First National Bank of Mifflintown, and a branch of Tri-Gounty National Bank.
The merging bank, the only bank in Blairs Mills, is
losing business because its lending limit of $17,500 is
proving to be inadequate to local credit needs, which
puts it at a competitive disadvantage with the Community State Bank of Orbosonia and the Dry Run
branch of National Valley Bank & Trust Co. of Chambersburg, the other banks serving the area.
This merger will not significantly alter the hanking
structure in this central section of Pennsylvania. Tt will
not reduce the number of banking alternatives available to the public b"t will increase comrmritinn in the
Tuscarora area. The resulting bank will not only provide more extensive farm credit programs, but will
furnish Krwider ranged commercial banking services to
the residents of Tuscarora.
55

The merger appears to be in the public interest and
will not produce an adverse competitive effect. The
application is. therefore, approved.
JANUARY 16,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger would combine the $16 million Juniata Valley National Bank, serving central

rural Juniata County and nearby communities, and
the $1 million Tuscarora State Bank, serving Blairs
Mills, a rural community of 100, 33 miles southwest of
Charter Bank's nearest office. The two banks do not
presently compete with each other, and their joining
together would not adversely affect the structure of
the commercial banking business in this part of Pennsylvania. Consequently, no anticompetitive effects are
likely to result from this merger.

THE BANK OF MAYODAN, MAYODAN, N.C., AND SOUTHERN NATIONAL BANK OF NORTH CAROLINA,

LUMBERTON, N.C.

Name of bank and type of transaction

Total assets

The Bank of Mayodan, Mayodan, N . C , with
|
and Southern National Bank of North Carolina, Lumberton, N.C. (10610), |
which had
merged Mar. 11, 1967, under charter and title of the latter bank (10610).
The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 19, 1966, The Bank of Mayodan,
Mayodan, N . C , and Southern National Bank of North
Carolina, Lumberton, N . C , applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
Southern National Bank of North Carolina, with
IPC deposits of $82 million, was organized in 1897 and
operates 29 offices in the south-central portion of North
Carolina. The main office of Southern National is located in Lumberton, Robeson County, near the heart
of the largest tobacco-growing area of the country.
The fertile farmlands in and around the service area
also produce cotton, grain, fruit, and vegetables. Tobacco processing plants and canneries augment the primarily agricultural economy.
The Bank of Mayodan is a unit bank located in
Mayodan, 137 miles north of Lumberton. It was organized in 1916 and presently has IPC deposits of $3 million. Economic enterprises in Mayodan consist largely
of textiles and related industries such as hosiery mills
and garment manufacturing. Tobacco is grown and
processed in stable quantities in tliis area also.
Sotrthem National Is the seven Lh largest bank in
Nrrt-th Ckirolirm bid h hoM* uniy 2 percent of the total
bank (fejwwks in th« State. The merger will not yJTeei
the competitive position of Southern National in the
56

$4,110, 919
97,357,855
101,468, 773

State's banking structure. It will, however, have a
competitive impact on the Mayodan area.
The merging bank is the only banking office in
Mayodan. Its principal competition derives from the
$260 million Northwest Bank which maintains a
branch in Madison, 2 miles from Mayodan, and from
the Bank of Stoneville, 5 miles to the north. The degree
of competition between the Bank of Mayodan and
die two branches of the charter bank in Leaksville,
15 miles east, is slight.
This merger will redound to the public benefit
by increasing banking competition in the Mayodan
area. The charter bank, with its broader range of services and specialized staff, will be able to offer better
service to the agricultural interests in competition with
the Madison branch of the Northwestern Bank.
Applying the statutory criteria to this proposal, it
is concluded that this merger is in the public interest.
The application to merge is, therefore, approved.
FEBRUARY 9,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Southern National was organised in 1097 and presently operates 31 offices thrcraghoert central North
OftmKrrfi, Kinrft 19fi4 it. KM arquirfid five hflr&x with
15 <vflGc.es, combmed deposits of $36,045,949 arid combined loans of .$22,070,698. As of September 20, 19G6,

Southern National had total assets of $96,594,873, total
loans of $59,722,707, and total deposits of $84,588,405.
The Bank of Mayodan was organized in 1916 and
has no merger or acquisition history. Its only office is in
Mayodan, N.G., which is in the northwestern section
of Rockingham County. As of September 20,1966, the
Bank of Mayodan had total assets of $3y824,346, total
loans of $2,237,192, and total deposits of $3,375,263.

UNADILLA NATIONAL BANK, UNADILLA, N.Y.,

The proposed merger would eliminate existing competition between the merging banks and would reduce from five to four the number of banks competing
in this area. Southern National has entered the Bank
of Mayodan's service area through its December 1966
merger with First National "Sank of Leaksville. The
three offices acquired by Southern National through
that merger are approximately 12 miles from Mayodan.

AND MARINE MIDLAND NATIONAL BANK OF TROY, TROY,
Bankin

Name of bank and type of transaction

Unadilla National Bank, UnadUla, N.Y. (9516), with
and Marine Midland National Bank of Troy, Troy, N.Y. (721), which had...
merged Apr. 10, 1967, under charter and title of the latter bank (721). The
merged bank at date of merger had

COMPTROLLER'S DECISION

g offices

Total assets
In
operation

On December 12,1966, the Unadilla National Bank,
Unadilla, N.Y., with IPG deposits of $6.1 million, and the Marine Midland National Bank of Troy,
Troy, N.Y., with IPG deposits of $81.7 million,
applied to the Comptroller of the Currency for permission to merge under the charter and with the title
of the latter.
Troy, with a population of 66,500, is located in the
"Capital District" of New York, a general trade area
including the cities of Schenectady, Albany, and Troy.
The "Capital District" has a population of over 672,000 and is the third largest trade area in New York
State. This area has a diversified economy, with wholesale and retail concerns and industrial developments
playing significant roles. Urban renewal is being advanced and a new industrial park is being planned in
this immediate area.
The Marine Midland National Bank of Troy is a
member of the Marine Midland Corporation and was
organized on April 22, 1852. Presently operating 12
branches, the bank ranks fifth among the 43 banks located in the Fourth Banking District, thus emphasizing
its aggressive, character anrl r.apahle management
Competition in this area is intense and is provided
primarily by th? $565 million National Commercial
Bank & Trust Co., the $556 million State Bank of
Albany, and the $128 million First Trust Go. of
Albany.

N.Y.

$6,806, 990
108,832,179
115,639,169

To be
operated

1
13
14

Unadilla, with a population of 1,586, is also located
in the Fourth Banking District of New York State and
is approximately 93 miles northeast of Albany. Although traditionally considered a farming area,
Unadilla has demonstrated that it is significantly more
industrial and commercial than agricultural. While
Unadilla boasts nine manufacturing firms that employ local residents, the Scintilla Division of Bendix
Corp. in nearby Sidney is the major employer in the
area.
The Unadilla National Bank, a single-office bank,
was chartered in 1909 and ranks 25th in size in the
District. Because of the bank's relatively small lending
limit, it has been unable to service many of the larger
customers in its service area. The $9 million First National Bank in Sidney, N.Y.; the Franklin office
of the $11 million National Bank of Delaware County,
Walton, N.Y.; two branches of the $54 million National Bank & Trust Co. of Norwich, Norwich, N.Y.;
the $26 million Wilber National Bank of Oneonta;
and two branches of the $565 million National Commercial Bank & Trust Co. provides intense competition
for this small bank.
Competition between the charter and merging banks
is uuiiexislei/t, 111 thai the iieaiesl office uf tlie chattel
bank is 70 miles distant from, the merging bank.
The resulting bank will be able to offer a broader
range of services to the customers of the merging bank,
including trust facilities, data processing facilities, a
greater lending limit, and full-service banking not

presently available to the merging bank's customers.
Consummation of the merger will also resolve the vexing management succession problems of the merging
bank. It will enable the resulting bank to compete
more effectively with the larger banks now operating
in the area and thus bring to the residents of Unadilla
the full benefits that flow from aggressive competition.
Applying the statutory criteria, we conclude that
the proposal is in the public interest, and the application is, therefore, approved.
MARCH 9,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Marine Midland National Bank of Troy was chartered on April 22, 1852. It operates 12 branch offices
in addition to its head office in Troy, N.Y. This bank
had, as of June 30, 1966, assets of $104,775,000, deposits of $92,339,000, loans and discounts of
$58,713,000, and capital accounts of $7,925,000. On

Jufy 19, 1963, it merged National Bank of Cohoes,
Gohoes, N.Y.
Unadilla National Bank, chartered August 23, 1909,
operates a single office in Unadilla, N.Y. Application
by State Bank of Albany, Albany, N.Y., to merge Unadilla was denied on April 26,1963. As of June 30,1966,
this bank had assets of $7,127,000, deposits of
$6,511,000, loans and discounts of $3,257,000, and
capital accounts of $443,000.
The head offices of the respective banks are located
some 98 miles apart; 78 miles separate Unadilla from
Troy's nearest branch office. Substantial competition,
therefore, does not appear to be present. Potential
competition is foreclosed by New York's "home-office"
protection law.
Approval of the proposed merger will eliminate
Unadilla as an independent commercial bank, but the
number of competitors in the area will not be
diminished.

PROVIDENCIA BANK, BURBANK, CALIF., AND VALLEY NATIONAL BANK, GLENDALE, CALIF.
Banking offices
Name of bank and type of transaction

Total assets

Providencia Bank, Burbank, Calif., w i t h . . .
and Valley National Bank, Glendale, Calif. (14823), which had
merged Apr. 28, 1967, under charter and title of the latter bank (14823).
The merged bank at date of merger had

COMPTROLLER'S DECISION

$5, 465, 939
28, 169, 535

In
operation

To be
operated

1
3
4

33, 429, 483

Corp., which employs over 27,000 people at its Burbank plant. Other significant contributors to the local
economy are two major motion picture studios.
The charter bank, Valley National Bank, was organized in 1957 and presently has two branches, one
in Glendale and one in downtown Los Angeles. Its
market area is in one of the most heavily banked sections of California and it is forced to compete with
9 hanks and 31 hranrh offices. Valley National has
always had very capable management and its condi-

On January 31, 1967, the Providencia Bank, Burbank, Calif., a bank having IPC deposits of $4.7 million, and Valley National Bank, Glendale, Calif., a
bank having IPG deposits of $23.6 million, applied to
the Comptroller of the Currency for permission to
merge under the charter of and with the title of the
latter.
Glendale, with a population of 135,600, and Burbank, with a population of 85,200, a/e adjacent cilies
1
located 12 KS&C3 Eiortk cA dcwr/tow/i Lus Augeics. Di/idi tinn has rnn$i«tenfrly hee* r?t*»d JvrrVily hy \h\s Ofik"€L
T h e Prnvtdftnr.ia Bank opened for business early in
of these cities border the Sari Feiiiajidu Valley portion
<.& Lo» Aiigvk* C/ly Aivd b»_4ii i i c u^iiudciod paii \A 106 4 MM! Vrfifrnri taM4r.kr..v Tta grr/w*h K r a h r r n
Anr\ its rAmingK hnvr. ne.vrr ftAGMcA t h e e*p
the T^A Angeks GtAAtlrtid
AlVA« T h o t Aic »r-vrirtl ]

r/f ito Mrgnnixr.r*. As rjqaJtdr. mKnmvf.rnr.nt

thft lf»fj».lft kftyftvl tu ajiciafl piu«JuL"tk»i y.iid ihe Htrru-

drffir.iift to find in thU area, it \s fell lhAt. thft

ir.H-.istry, rf-,v- li

Applying- thy slalulwy criteria lo 1.1 ie. proposed
merger., we conclude that it. is m the: public interest,
and the application is, therefore, approved.
MARCH 24,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL,

The Valley National Bank, Glendale, Calif., proposes to merge with the Providencia Bank, Burbank,
Calif. Each of the applicant banks appears to represent a relatively small factor in a service area
dominated by lour major California banks (Bank of
Ame/ica, Fi/st Security National Bank, United California Bank, and Crockcr-Citiiccns National Bank).
It seems probable that the merger will eliminate

some direct crumpet! lion between TYnvidrrncia's sole
oilkw and the three offices c»f Valley—all of which are
williin a 5-iuile radius from the former. There are at
least 20 other banking offices within this 5-mile area,
but it appears that only one of them is not affiliated with
one of the major banks listed above. The merger would
thus reduce the banking alternatives from seven to six
within this radius.
The merging banks together control only 0.2 percent
of the TPC demand deposits for Los Angeles County as
a whole. The proposed merger would not appear to
involve a significant change in banking concentration
in the already highly concentrated Tos Angeles County
market.

THE FIRST NATIONAL BANK OF BUTLER, BUTLER, N.J., AND T H E FIRST NATIONAL IRON BANK OF N E W JERSEY,
MORRISTOWN, N.J.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Butler, Butler, N J . (6912), with
and The First National Iron Bank of New Jersey, Morristown, N J . (1113),
which had
merged Apr. 28, 1967, under charter and title of the latter bank (1113). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On October 7, 1966, The First National Iron Bank
of New Jersey, Morristown, N.J., with IPC deposits of
-$83 million, and The First National Bank of Butler,
Butler, N J . , with IPG deposits of $14 million, applied
to the Comptroller of the Currency for permission tn
merge under the charter and with the title of the
former.
Morristown, with a present population of 20,800,
is the home-office city of the charter bank, and the
cctsjoty sea£ of Morris County The First National Trrm
Bask of New Jersey has two branches in Mnrristnwn
and 10 other branches in central and southeastern
Morris County, most of them in communities immediately surrounding Morristown.
Morris County is 30 miles from New York City and
S7 miles from Philadelphia. An extensive highway network traverses the county making it possible for 23
percent of the working population to commute outside
the county for employment. The county is mainly resi-

To be
operated

$18, 152, 775

108,475, 333

126,628,108

creased 59 percent between 1950 and 1960, with housing increasing 55 percent during the same period. The
residences recently built range in value from $15,000
to $50,000.
The merging batik is headquartered in Butler, which,
has a population uf G,230. The eomrmxnity is rather old
and static. 11 has not yet realized its potential for industrial growth. The First National Bank of Butler
operates three branches in communities peripheral to
Butler.
The service areas of the participating banks do not
uveiL&p <t/nl, lhc/efo/e, cca&uuuastiem of the proposed
uicigci wiH. ha*e no adverse effect on competition. The
nearest office of The First National Iron Bank is located about 12 miles from the Butler Bank. The Butler
Bank has no business in the area of The First National
Iron Bank and the latter has only several mortgage
loans from the area of the merging bank. On the other
hand, the receiving bank competes actively with such
other Morris County banks as the State-chartered
Trust Company of Morris County which has snhstan-

UCUUdi, b u l 1JUIS C-ApClic.UV.CV.1 a n IiiV,i l«5C i u fir.vr.lfF|ifut\riL

uaWy g i w i i d assets. Thi-.ir i-wi-ripi-.titivT. sit.istiwi-, will he.

of light industry in recent, yeais. The population in-

heightened when the proposed merger is consum-

293-544—68-

mated. The Morris County Savings Bank, the largest
SUMMARY OT REPORT EY ATruRNUY OENERAL
bank in the county, as well as out-of-county and out-ofTrnn
Rank i«s thp wrnnri largest and First Natios&al
State tanks also eozzpete with. The Fiisi N a t i i W Iiuu
the ninth largest of 10 banks in Morris County. This
Bank.
application Hnsely follow? osi^ invcJ\riRrj" the lar^st
Cwraarojiation of this proposed mcigci will be in
and eighth largest hanlrs m the coualy. If both applithe p-afcKe interest. I t Is necessary fox Iiou D<uik Lu
cations are apprnver^ thi« large a*d gr<M*dxig area, w t h
increase its lciic&ing capability in uidci lu <ui&wcx luud
an pstimatprl pr^inlfitinn of 328^170 and a projected
needs and to meet effectively ccuupetHiuu fium b«mks
1980 population of 550,000, will be left with only
eratside the coonty and tlie State. The lesuJiiiig bank
eight cnmmprrial hanV<^ the two largest o£ v.'hich will
vrsH also be able to provide inore cAtc/isivc fiduumy
services in tlic Butler area than ka> icsidcirta tue iiuw acrmint fnr nver fi^ percent of the deposits and loans
held hy all rnmmprrial banks in the county.
receiving. The merger w81 also solve ihc w<uidgeuieul
them b^nVf 72X subject, t
succession p^obkni /a. tlic Bi/du office, tiu^ic it Lu
from banks located in adjacent counties.
raise the interest it pays on time deposits and make
Av«liable die benefit* wf ihc Fii>l Ndliuu>d Iiuu Bank's
tween the merging banks is Hinited by the distance
computer.
Kzr/ifsg er/rarAr.rrd the. mcrgrr nffPAcjAnr/n in Y^ALrriwewu ihtiiJ^ lilt pii.'|X«L<i m v i g t i vi\j\.&& vliuiiiwdc
J
of thr. statrctary rrfarifl, tlvJs Offor Kws < «f.trnw!fM'.ri tVrftf
it in in thn j»ekl<>« intnmtf, nniil tht np^Wentwvn in, thnr«
fore, approved.
further increase the already h i ^ i level of concentration
in commercial banking in Morris County.
MARCH 22,1967.

THIS MAYBROOK NATIONAL BANK, MAYBROOK, N.Y., AND COUNTY NATIONAL BANK, Mmm.KTOWM, N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Maybrook National Bank, Maybrook, N.Y. (11927), with
,
and County National Bank, Middletown, N.Y. (13956), which had
merged Apr. 28, 1967, under charter and title of the latter bank (13956).
The merged bank at date of merger had
•

COMPTROLLER'S DECISION

On January 16, 1967, The Maybrook National
Bank, Maybrook, N.Y., with IPC deposits of $1.9
million, and County National Bank, Middletown, N.Y.,
with IPC deposits of $89.6 million, applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the title of
the latter.
County National Bank, organized in 1934, maintains
its head ofnee in Middletown, Orange County, approximately 40 miles north of New York City. I t
upciAles 23 b/doehes In O/a/ige, Sufllvau, «uul DuUJieft&
A.: . _
UV9

TV
. .
X 1VV

_ J
UU

1. .

$2,462, 223
127,802,066
130,265,090

Orange County, with a population of 184,000 in
1960, has been growing rapidly. Its proximity to New
York City has attracted branch facilities of many businesses and industries. In addition, it has a large and
prosperous dairy farming industry. Economic forecasts
for the county continue to be favorable. Middletown,
with a population of 23,500, is one of the two largest
cities in the county. Its size and location have attracted
much of the expanding manufacturing business moving into the county. While the area around Maybrook,
which is 15 miles northeast of Middletown, is predominantly pgrimitiiral^ MpybrnoV itvif is

. 1.

UCLVVs U U / i l C

for locations in Orange County. Maybruuk National
Bank, also located in Orange County, maintains its sole
office in tlie lowing Maybrwfc, wiiidi has a
of 1,500.

To be

steady growth, particularly in the area of residential
construction.
Many ha lilting altar naAfont mint, hnih within th«
primary service areas of the applicant banks and im-

mediately outside the area. In addition to the charter
bank, there are seven other banks in Orange County,
with deposits in excess of $10 million, and three with
less than $8 million in deposits. Four banks located
outside Orange County also attract business from the
Orange County area. County Trust Co. of White
Plains and the National Bank of Westchester, the two
largest banks in New York's Third Banking District
in which the applicants are located, together hold 47
percent of the deposits in the district. The 5 percent
now held by the charter bank will be increased only
minutely by this merger.
The applicant banks compete with each other to a
limited degree. The office of the charter bank in
Washingtonville is 6.5 miles from Maybrook; there
are three other banking offices located between them.
The competitive position of the small Maybrook bank
is growing weaker in the presence of larger and more
progressive banks that offer a broader range of services
and trust facilities. Although the merger will eliminate
the small amount of competition now existing between
the participating banks, the ultimate result is expected

to be an increase in competition with all the other
banks in and near Orange County.
Applying the statutory criteria to the above proposal,
it is concluded that the enhancement of the convenience and servicing of the needs of the community
clearly outweigh the minimal adverse competitive effects of the proposed merger. It is in the public interest
and, therefore, approved.
MARCH 28,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

County National Bank operates 28 offices in Orange,
Sullivan, and Dutchess counties, N.Y. Maybrook National Bank is a small bank with its only office in Maybrook, N.Y., 6y2 miles distant from the nearest County
National office. According to the application, competition between the two banks is "very limited." In view
of this fact and in view of the narrow range of services
offered by Maybrook National and its alleged management problems, it does not appear that the proposed
merger would have an adverse effect upon competition.

THE SECOND NATIONAL BANK OF TITUSVILLE, TITUSVILLE, PA., AND MARINE NATIONAL BANK, ERIE, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Second National Bank of Titusville, Titusville, Pa. (513), with
and Marine National Bank, Erie, Pa. (870), which had
merged Apr. 28, 1967, under charter and title of the latter bank (870). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 3, 1967, the Marine National Bank,
Erie, Pa., and The Second National Bank of Titusville,
Titusville, Pa., applied to the Office of the Comptroller
of the Currency for permission to merge under the
charter and with the title of the former.
Erie, with an estimated population of 145,000, is
the county seat of Erie County and is situated on the
southeastern shore of Lake Erie, about 100 miles east
of Cleveland, Ohio, 100 miles west of Buffalo, N.Y.,
and 130 miles north of Pittsburgh, Pa. Numerous diversified manufacturing plants and port activities provide
the primary economic support for this area which has
enjoyed steady economic expansion and population
growth over the past several years. There are presently
460 industrial plants in Erie County, of which 238 are

$8, 310,491
69,078,508
77, 388,999

To be
operated
1
7
8

in greater Erie. This large number of industries has
given the city a high ranking nationally in diversity of
manufacturing. The principal factors which contributed to the area's economic growth are the large
population, the inexpensive power (water and fuel),
the four railroads which service the area, and Lake
Erie which, with its port facilities, has made Erie
County an important exporter of products. Erie
County ranks fourth among Pennsylvania counties as
an exporter of products and Erie's harbor is the finest
natural harbor on the Great Lakes. In 1966, Erie's
harbor handled 2,767 arrivals and departures of ships.
In the metropolitan area, there are 1,340 retail establishments employing 10,900 persons and 348 wholesale
establishments employing 2,700 persons. Tourism has
also expanded in this area.
61

The charter bank, with IPG deposits of $49 million,
is the third largest among the banks headquartered in
Erie. The bank, organized in 1864, presently operates
six branch offices: three in Erie; two in Millcreek
Township, a suburb of Erie; and one in Cony, a striving industrial town located 30 miles southeast of Erie.
The bank is a well run institution providing its community with a full range of banking services, including
trust services. Banking competition in Erie is provided
by the First National Bank of Erie with total resources
of about $120 million, The Security Peoples Trust Go.
with total resources of about $110 million, and the
Union Bank & Trust Go. with total resources of about
$52 million. In addition, there are five savings and loan
associations, 21 credit unions, 13 sales finance companies, and 14 personal loan companies. Competition
from insurance companies in the area is moderate.
Titusville, with a population of about 9,000, is located in Crawford County and is about 49 miles southeast of Erie. It serves a retail trade area with an
estimated population of 24,000. The area has a well
diversified mehsstrial and agricultural economy. Thenft
axe presently in excess of 2,000 persons employed in
marmfacturing in Titusville and an expected expansion
of die Lugest manufacturing concern, Cyclops Corp^,
will bring 500 additional jobs to the community- In
llw: a/ca surrounding Titusvillo eKfceneive dairy farming and lumbering provide cash income.
Consummation of the proposed merger will not
lessen banking competition in the areas each serves.
Following the merger, the receiving bank will still rank

third in size in Erie. Because the office of the Marine
National Bank closest to Titusville is in Corry, 23 miles
away, there is no present significant competition between them to be eliminated. The entry of the receiving bank into Titusville will, on the contrary,
stimulate competition with the Pennsylvania Bank &
Trust Co. which has total resources of $62 million.
Consummation of the proposed merger will, in fact,
provide the community of Titusville with a bank better
able to meet the credit needs of its expanding industrial economy. The resulting bank will also provide
expanded and improved banking services to the Titusville community.
Considered in the light of the statutory criteria the
merger is determined to be in the public interest and
is, therefore, approved.
MARCH 14,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Marine National Bank (Marine Bank) with deposits of $56,180,000, is the third largest of fivft banks
in Erie, The Second National Bank of Tifusville with
depoeke of $7,168/)00, and located 49 miles southeast
of Erie, is the smallest of two banks in Titusville.
While the application states on the one hand that
"no competition exists between the participating
banke," it also lists the Cony branch of Marine Bank,
23 miles north of Titusville, as being one with which
Titusville bank does compete. Such competition as
does exist between these banks would, of course, be
eliminated by the proposed merger.

BANK OF SUMAS, SUMAS, WASH., AND SEATTLE-FIRST NATIONAL BANK, SEATTLE, WASH.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Sumas, Sumas, Wash., with
was purchased May 1, 1967, by Seattle-First National Bank, Seattle, Wash.
(11280), which had
After the purchase was effected, the receiving bank had
,

COMPTROLLER'S

DECISION

On April 24, 1967, Seattle-First National Bank,
Seattle, Wash., applied to the Comptroller of the Currency for permission to purchase some of the assets
and to assume the deposit liabilities of the Bank of
Sumas, Sumas, Wash.

To be
operated

$1,449,093

1, 537, 342, 000
1,538, 791,000

118
119

This Office has been advised by the Division of
Banking of the Department of General Administration
of the State of Washington that the Bank of Sumas
is in such grave danger of immediate failure that it
must be taken over by the State pursuant to its laws,
unless this proposed transaction is approved.

In order to protect the depositors, creditors, and
shareholders of the Bank of Sumas. tha Seattle-First
National Bank is authorized to proceed with this purchase and assumption transaction forthwith.

Having reviewed the internal condition of the Bank
of Sumas, and having found that it is in danger of
probable failure within the meaning of 12 U.S.C.
1028 (c), tills Office, therefore, is proceeding to act
immediately.
*

MAY 1,1967.
*

TIBURON NATIONAL BANK, TIBURON, CALIF., AND SIERRA NATIONAL BANK, PETALUMA, CALIF.

Name of bank and type of transaction

Tiburon National Bank, Tiburon, Calif. (15149), with
|
was purchased May 1, 1967, by Sierra National Bank, Petaluma, Calif.
(15174), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On May 1,1967, application was marie to the Comptroller of the Currency for permission for the Sierra
National Bank, Petaluma, Calif., to purchase assets
and assume the deposit liabilities of the Tiburon Nal.ionui Bn.nk, Tilmron, Cnlif., in order to prevent the
probable failure of the selling bank.
Finding that an emergency situation exists v/ithin
the meaning of 12 U.S.C. 181, the Office of the Comptroller of the Currency waives the need for approval by
the shareholders of the Tiburon National Bank of the

purchase and sale agreement as approved by its Board
of Directors. The emergency situation which exists is
of sudi a, nature thai this Office must act immediately
in order to prevent the probable failure of the Tiburon
National Bank within the meaning of 12 U.S.C.
1828(c).
Because of the turi^rg^ricy nature of the situation
and in order to protect the depositors, creditors and
shareholders of the Tiburon National Bank, the Sierra
National Bank is authorized to proceed with the purchase and assumption transaction immediately.
MAY

1, 1967.

BANK OF NORTH AMERICA, N E W YORK, N.Y., AND T H E MEADOW BROOK NATIONAL BANK, N E W YORK, N.Y.
Bankin g offices
Name of bank and type of transaction

Total assets
In
operation

Bank of North America, New York, N.Y., with
and The Meadow Brook National Bank, New York, N.Y. (7703), which had'.
consolidated May 8, 1967, under charter of the latter bank (7703), and under
title of "National Bank of North America." The consolidated bank at date
of consolidation had

COMPTROLLER'S DECISION

On January 20, 19G7, The Meadow Brook National
Bank, New York, Queens County, N.Y., and die Bank
of North America, New York, N.Y. applied to the Office of the Comptroller of the Currency for permission
to consolidate under the charter of the former and with
trie title of "National Bank of North America."

$395, 445, 609
986, 768, 278
1, 382,213,887

To be
operated

16
72
88

The Meadow Brook National Bank, with IPC deposits of $705 million, is a successor to The First National Bank & Trust C a of Freeport, which was organized in 1905. With its main office located in Queens
County, Meadow Brook has three branches in Manhattan, and maintains 46 offices in Nassau County, 12
in Suffolk County, one in Brooklyn, and six in Queens.

The Bank of North America, with IPC deposits of
$274 million, was formed in 1953 as the result of the
conversion of an industrial bank, organized in 1924,
to a trust company under the New York banking laws.
With its head office in Manhattan, Bank of North
America operates five branches in Manhattan, five
branches in Brooklyn, three branches in Queens, one
branch in the Bronx and one branch in Nassau.
Both banks are located in the most highly competitive commercial banking environment in the country,
and both are represented in the mushrooming suburban areas on Long Island. New York City presently
has a population of 8 million, and Nassau and Suffolk
counties together have a population of 2 million. As
a major financial and industrial center, the metropolitan area contains several of the largest commercial
banks in the. world Thege bankg service vast financial
undertakings in both domestic and international markets. Many of the major banks in New York City operate brandies on Long Island, which, although still
primarily a residential area, has experienced conssdcjv
able industrial and commercial growth.
Meadow Brook originated as a suburban retail bank
and concentrated its efforts in Nassau County. In 1960,
it moved into Manhattan in order to expand into national and international banking markets. The rapid
expansion of branch banking offices in Nassau and
Suffolk counties has inhibited its rate of growth in its
primary trade area.
The Bank of North America, which has long specialized in rendering banking services to such selected
customers as tevtiles, apparel, cfee^kal, and durable
goods manufacturers, has found its growth hampered
by its inability to continue to serve its larger customers
and by the increased competition of the larger banks of
the city. Whereas the Bank of North America formerly
competed only with banks of comparable sire in the
textile district, it now competes with four of the largest
banks which have established 26 branches in the
textile district in the last 10 years. Because of its limited
lending capacity, the Bank of North America has been
unable to satisfy the requirements of many of its larger
customers At year end 1966, only 41 of the bank's
100 most, valued customers used it as their principal
bank; the. remaining 59 customers resorted to the larger
city banks for their credit needs.
Both applicant banks suffer similar disadvantages in
this large, metropolitan market, The high cost of real
estate and the relative scarcity of suitable taA eemSr
able branch sites moVq it irsfCGctisfcl to oontG£Rpfc/fc &
sigrnficint entry rs£o CC«k ctifiGB^C U£O&Gc£a6G UX& \ff

this mute. Tn this highly competitive market, then*
64

banks are precluded from the effective use of area communications media to advei Use iheir services by reason
of the high costs involved. Whereas the popular newspapers and radio and television stations reach all
corners of this market and adjust their rates accordingly, the banks, whose business derives from only a
section of this great metropulitau market, cannot reasonably afford to advertise for a market that cannot
be expected to utilize then seivices; (lie banks cannot
afford this advertising waste.
Since the services offered by these consolidating
banks are complementary rather than similar, this
proposal earaiot be said lu reduce competition.
Meadow Brook concentrates primarily on consumer
credit, while the Bank of Noxlh America lends primarily to businesses and industries uf medium size.
In the field of international banking, Meadow Bruuk
deals primarily with Latin America and the Far East,
while the Bank of North America concerns itself
with Europe, the Near East, and Latin America. The
Bank of North America specializes its services for
customers in certain industrial areas tliat Meadow
Brook National Bank does not serve.
No significant competitiun will be eliminated by
this proposal. In only two scctiuns uf tliis vast cuniulex
are their offices in close proximity. In the financial
district of lower Manhattan, the clusest offices are fuur
blocks apart; the Bank of Nuiih America plans to
extend this distance another block by relocating its
office. Every major bank in New York City has an
office in this immediate area. The oilier pair uf competing branches are lucatcd aciuss the blieet from each
other in Long Beach La Nassau County. These branches
also compete with offices uf Fianklin Natiuual Bank,
with deposits of $1.G bHliun, and uf Chemical Bank
New York Trust Co., with deposits of $6 billion.
Among the cornrnercial banks in New York City,
The Meadow Brook National Bank presently ranks
ninth in size, and the Bank uf North America ranks
11th. The resorting bank will cuntinue to rank ninth.
Meadow Brook Naiiunal Bank has only 1.50 percent
of all deposits held by cummercial banks and 1.41 percent of all loans. The Bank uf North America holds
only 0.63 percent of the depusits and 0.G0 percent uf
the loans. The corisulidaiiun, theiefuie, will nut increase the concentration of banking resources to any
significant degree.
This consolidation will, on consuimnaiiun, uruduce
bcacScent effects for the ba/Aiug puUic. The icsufting
boftk vi'JA puGSCM a g/v^u./ uumpilKivi, putwAidi vviuch
n'M IX&juiid tO tlu- bumJX uf UU^UHIUIJ in tLu
ft&le b&rildng mark*! without detriment tu the

13th among all banks in the Ne.w York City-Long
Island area. As of June 30, 1966, it had awmtR of
$411^073,000, deposits of $342,571,000, and loan?, of
$28%llCMX)a It operates 16 office Sine* 1054, it has
acquired four banks through merger. Th« consolidate
ing bank? each offer the s&rnp rnngpi of rommfirda]
bnnMxsg b\lMRGSS> nHVo1^1^1 Tl^-nlr nf TSTnrth Amarir?
emphases commercial nnH inriiiRtrrftl lending while
Meadow Earook National dors an ext^nsivp: retail
business. Mcsdow Brook National hns 1.13 percent of
total deposits in the area and 1.93 percent of total
loam?;, while Bank of North America hns lass than 1
percent in both categories.
The banking structure in the New York City-Long
Island area in which both consolidating banks are
vigorous competitors reflects a high degree of concentration. The five largest banks have approximately
70 percent of the ?.r??.'s deposits ?.nd loan? Thi« rnn.
centration is largely attributable to past merger activity
among th» larger area banks, including both the contwlida.ting banks. None of the entirely new banks estafoli&hed in the auto, since 1950 have achieved or can be
expected to achieve the competitive stature of the
larger banks wliich have been eliminated by merger.
The proposed inoger would not substantially affect
the level of concentration in commercial banking in
the New York City area. It would, however, eliminate
existing competition between MB and SNA, both of
which presently afford significant alternative sources
of credit for medium- and small-size customers.

customers now being served. By combining the compksucubuy services now being furnished by each institution, llie resulting bonk will be broader baaed to
serve mi uxpuiided ruiige of community requirements.
It is concluded in the light of the foregoing analysis
lliut uny udvuniu competitive effects which may reoilt
fiuiii tliu uuiUL/liJutiun LUHJ 6L/fci/G4gl\&d \fj the boMOfttC

to thw public uuuveaieai» aad needs, because of the
uxpuiided lending limit, increase in facilities for retail
juid wholesale banking, EUeagtliened international
banking services, and expanded trust services which
will b« offered by the resulting bank. Having weighed
the application against the statutory criteria and having determined thai the consolidation is in the public
interest, it is, therefore, approved.
APRIL 6,1967.
auxviiuAKx G* KEPORT BY ATTORNEY GENERAL

Meadow Brook National Bank is thp. 10th largest of
the 45 commercial bnnks with hr*nrl nffinw in Nftw
York City and the 11th largest nf the 9fi hanks in the
New York City-Long Island (Nassau County and Suffolk County) area. As of June 30, 1966, it hnH assets of
$928,029,000, deposits of $810,848,000, and loans of
$548,106,000. It operates 69 offices. Since 1950 it has
acquired, through merger or consolidation, 17 banks
with 39 offices and aggregate total deposits in excess of
$350 million. Bank of North America ranks 11th
among banks with he.ad offices in Np.-wr York City and
*

THE FIRST NATTONAT. RANK, BALTIMORE, OHTO, AND T H E HOCKING VALL&Y NATIONAL BANK, LANCASTER, OHIO
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Baltimore, Baltimore, Ohio (7639), with
was purchased May 8, 1967, by The Hocking Valley National Bank of Lancaster, Lancaster, Ohio (1241), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On May 5,19G7, application was made to the Comptroller of the Currency by The Hocking Valley Naliuuai Bank, Lancaster, Ohio, for permission to peaclidsc assets and assuutte the deposit liabilitka of The
First National Bank, Baltimore, Ohio.
As directed by the terms of Subsections 4 6 of
Section 1827 (t) «f Title 12 uf llu: Uuile-J Sl«tf> CVxle,

To be
operated

$10, 406, 864

13, 026, 877
23, 433, 741

2
3

I hereby find that there exists a reasonable probability
that The First National "Rank, Baltimore, Ohio> may
fail; that said reasonable probability of failure is imminent; and that a reas«sably pmHpnt riisrharg* nf
my responsibilities m the maintwianrp. nf a sound Nan
tional banking system requires the immediate action on
this application. I also find that the financial and
managerial iv=snurr.M r/f thft arqwrmg institution will

be adequate to protect the customers, as well as the
public interest of the entire community, and that no
other bank possessing the requisite breadth of financial
and managp.ria.l resources has indicated a willingness
to assume the responsibilities of the selling bank.
I conclude that this transaction, as a matter of law,
will neither occasion a violation of Section 2 of Title 15
of the United States Code nor will it substantially
lessen competition as that concept has been judicially
accorded with the failing company doctrine. On the

contrary, I conclude that the deleterious effect of a
failure of the selling bank on the financial stability of
the geographic market it serves* wuuld significantly
exceed any impact of the transaction upon competition.
In order to protect the depositors, creditors, and
shareholders of The First National Bank of Baltimore,
Ohio, this application is approved and The Hocking
Valley National Bank is authorized to proceed wilii this
purchase and assumption transaction forthwith.
MAY

5, 1967.

BANK OF NUTLEY, N.J., AND FIRST NATIONAL STATE BANK OF N E W JERSEY, NEWARK, N.J.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Nutley, Nutley, N.J., with
and First National State Bank of New Jersey, Newark, N.J. (1452), which had..
merged May 12, 1967, under charter and title of the latter bank (1452). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 13, 1967, the Bank of Nutley, Nutley,
N.J., with IPC deposits of $40 million, and the First
National State Bank of New Jersey, Newark, N.J.,
with IPC deposits of $451.5 million, applied to the
Comptroller of the Currency for permission to merger
under the charter and with the title of the latter.
The First National State Bank, headquartered in
Newark, N.J., has a population of 405,000 and operates 25 offices throughout Essex County. Seventeen
of these offices are within the Newark city limits. The
bank serves an area highly diversified with heavy and
light industry, manufacturing electronic and transportation equipment. Other than its local customers
in Essex County, First National State Bank serves regional accounts located in the five counties contiguous
to Essex County and national accounts doing business
within a 50-mile radius of New York City. The population of its service area is in excess of 1,800,000.
The Bank of Nutley maintains its head office and
operates three branches within the town of Nutley, N.J.
The bank's primary service area encompasses the town
of Nutley, whose population is 29,513, and portions
of the immediately adjacent municipalities. Nutley,
which is primarily a well-developed, middle-income
community with owner-occupied, one-family homes,
serves a trading area with a population estimated at
35,000 to 40,000.

$48, 636, 809
667, 285, 875
712, 742, 898

To be
operated

4c
24

The First National State Bank, which was organized
in 1812, has experienced substantial growth over the
years and its future prospects are favorable. Net current operating income of First National for 1965 was
$6.7 million, which compares satisfactorily with the
average earnings of banks of comparable size and scope.
The capital structure of First National has continued
to keep pace with its loan and deposit growth. The
bank is in good condition and its management is considered very competent.
The Bank of Nutley, incorporated under New Jersey
law in 1905 under its present title, has not experienced
the rate of growth enjoyed by the charter bank. Although its past earnings have been satisfactory, its future earnings picture appears uncertain. While the
Bank of Nutley presently has a satisfactory management team, the absence of any management succession
presents a problem it must soon face. Requests for early
retirement, health problems, and recent resignations
have highlighted the lack of depth in management
ranks.
Competition between the merging banks is minimal.
The closest offices of the merging banks are about 3
miles apart. The community of Belleville, located between these offices, contains a locally headquartered
bank and a branch of the $557 million Fidelity Union
Trust Co. Even in the area from which both banks
derive business, a substantial portion of First National's

accounts are beyond the capacity of the Bank of Nutley
to handle.
Effectuation of this merger will not unsettle the
banking sti uctu/e in tills section of New Jersey nor give
the First National State Bank a marked advantage over
its competitors. While the receiving bank had total
deposits at year end of $607 million, its principal competitor, the Howard Savings Bank of Newark, had
total deposits of $661 million. First National State is
also in direct competition with 19 other commercial
banks headquartered in Essex County. Its largest commercial bank competitors are the $557 million Fidelity
Union Trust Co., Newark, N.J., and the $475
million National Newark & Essex Bank, Newark,
N.J. Further competition derives from 148 savings
and loan associations, 24 insurance companies, and
numerous personal loan compftnies, credit nninnSj and
sales finance companies. First National State Bank also
feels the impact of competition from the large New
York City banks which canvass this area of New Jersey
in quest of business.
Competition is offered the $44 million Bank of Nutley by offices of the $557 million Fidelity Union Trust
Co., the $474 million National Newark & Essex Bank,
the $29 million Peoples National Bank, the $100 million Bank of Passaic & Clifton, the $351 million New
Jersey Bank & Trust Co., the $208 million National
Community Bank of Rutherford, the $150 million
Bloomfield Savings Bank, and the Nutley Savings and
Loan Association.
Should the merger be consummated, the receiving
bank would continue as the second largest financial institution in the combined service area. The increase in
its resources, however, would not be sufficient to effect
adversely the competitive balance of the banking
structure within this section of New Jersey. On the contrary, banking competition will most likely be stimulated among the seven larger banks—six of which have
deposits in excess of $100 million—in the service area
of the Bank of Nutley. Substantial benefits would
accrue to the residents of Nutley from the presence of

293-544—68-

a large, well managed bank offering a broader range
of banking services through local offices.
Applying the statutory criteria to the proposed
merger, we conclude that it i? in the pnhiir. interest,
and the application is, therefore^ approved.
MARCH 28,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The First National State Bank of New Jersey, the
second largest commercial bank in Essex County, N J .
($514.6 million in deposits), proposes to merge with
the Bank of Nutley ($44.2 million in deposits). The
latter is located in Nutley, N.J., (population approximately 29,513) and is the sixth largest commercial
bank in Essex County (1960 population, 943,352).
Concentration in commercial hanking in Essex
County is extoexady high, with the rhrrr: largnst banks
collectively controlling 79.6 percent of total county
deposits, 82 percent of total loans and 63.9 percent
of total banking offices. The Charter Bank alone (second largest of all commercial banks in the county)
controls about one-fourth of total loans, deposits, and
offices held by commercial banks in the county. The
Merging Bank, although only controlling 2.2 percent
and 2 percent of total deposits and loans, respectively,
is larger than six of the smaller banks combined. Even
should mutual savings bank deposit and loan figures
be included, the level of concentration in Essex County
would remain extremely high, with four of the leading banks controlling 71.8 percent of total deposits,
71.5 percent of total loans, and 60.5 percent of total
banking offices.
Competition between the applicant banks exists
particulaxiy for the small- and medium-size loan and
deposit accounts, and this competition would be eliminated by the proposed merger. The merger would
also increase further the level of concentration within
a highly concentrated banking ma.rkp.tj Essex County.
It would, finally, eliminate a well established, independent bank, the only bank (with its branches) in
Nutley, N.J., and one which has been demonstrated
to be a vigorous and growing competitor in the area.

FIRST-CITY NATTPONAT. BANK OF BTNGTTAMTON, BINGHAMTON, N.Y., AND FIRST-CITY NATIONAL BANK ur SUUTHKKN
NEW YORK, BINGHAMTON, N.Y.

Name of bank and type of transaction

Total assets

First-City National Bank of BinghaTnton, Binghamton. N.Y. (202), with
and First-City National Bank of Southern New York, Binghamton, N.Y.
(15625), which had
merged May 16, 1967, under charter of the latter bank (15625) and with
tide "First-City National Bank of Binghamton, N.Y." The merged bank
at date of merger had

COMPTROLLER'S DECISION

On September 19, 1966, the First-City National
Bank of Binghamton, Binghamton, N.Y., with IPC
deposits of $99 million, filed an application for permission to merge with the First-City National Bank
of Southern New York (organizing), Binghamton,
N.Y., under the title of the former and the charter of
the latter.
The First-City National Bank of Binghamton, Binghamton, N.Y.; the Lincoln National Bank & Trust
Co. of Central New York, Syracuse, N.Y.; The First
National Bank of Jamestown, Jamestown, N.Y.; and
the Lincoln Rochester Trust Co., Rochester, N.Y.,
have agreed to form a bank holding company to be
known as the Lincoln First Group, Inc. In order to
transfer stock ownership of the banks to the bank
holdingfifimjsfiffty,thw>c new Nftf<bw«l banks, one corresponding tr, rjurfri r/f tV* orcsring Nation*! barA^ were.
organised wkh thr pvcMvrAnftry approval of the Comptroller of thr. CKrrrrw^y. Tf the T.incohi First Ownp,
Inc., rcoravrs authority from th« Bnmrd of Governor*
of the Fcdr.ral Rrsfcrw. Rystrm xnr\ from the Backing
E&zffd <vf tKf. Fi(»te r/f Nnw V»A tr, hrrr/mc. a ivg\$(>:vcv^
bank holding company, it will then acquire all the
stock of the four hanks, mcrfipt for Srtctcfr's qualifying shares and ax fithr.rwvse iYxiuire."i by law.
The new charter hank will not ripen fouling facili*
tics untH the instant, prnpnml i.i afqwave&y at \H*kh
time it will take over the banking operations of the

$139, 175,480
250,000
139,425,480

existing bank and continue without interruption the
banking services now being offered. Since the new
charter bank is presently a nonoperating bank, the
merger will have no effect on competition. However,
the approval to be granted herein is conditioned upon
all requisite shareholder action being taken and on receipt of approval by the Federal Reserve Board for
the Lincoln First Group, Inc., to become a registered
bank holding company.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application, as conditioned above, is therefore
approved.
NOVEMBER 9,

1966.

SUMMARY OF REPORT BY ATTORNEY GENERAL

These thr«£ pr/oposed iuugci» a^e yml uf a. huidiiig
C0i//p?jiy \Aiii uiidci wiiiiii Lincoln Fiivi Group, Inc.,
a New York ct'i^uiali'jii willi i.U principal office iu
Rochester, would acquite up Lu 100 percent of tiie \»otiiig sliares C"f each «f die lluee rt»ultiiig banks. Accordmg lo Ihc >ipf»!kal2uiis, llie mergers aie a
•VcstitsctiuW ^uui-eduie iuiideuiid lu llie huldiug
company plan."
The acquiring bank in each iniUance is a new institutic«i c re a itd lu iiujjieiueut Uie liuiding company
pfei\ jrrid at the present lime lias no bai^dng facilities.
TTcncc, tl\e p/c«f«c<srd lueigtrii as x'-idi wuuid give riise
to no adverse competitive effects.

LINCOLN NATIONAL BANK & TRUST CO. OT? CENTRAL N E W YOUK, SYBACUSR, N.Y^
BANK OF SYRACUSE, SYRACUSE, N.Y.

AND LINCOLN NATIONAL

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Lincoln National Bank & Trust Co. of Central New York. Syracuse, N.Y.
(13393), with.
and Lincoln National Bank of Syracuse, Syracuse, N.Y. (15627), which h a d . .
merged May 16, 1967, under charter
charter <of the latter bank (15627) and with title
"Lincoln National Bank& Trust Co. of Central New York.'" The merged
bank at date of merger had.

COMPTROLLER'S DECISION

On September 19, 1966, the Lincoln National Bank
& Trust Go. of Central New York, Syracuse, N.Y., with
IPC deposits of $145 million, filed an application to
merge with the Lincoln National Bank of Syracuse,
(organizing) Syracuse, N.Y., under the title of the
former and the charter of the latter.
The First-City National Bank of Binghamton, Binghamton, N.Y.; the Lincoln National Bank & Trust Co.
of Central New York, Syracuse, N.Y.; The First National Bank of Jamestown, Jamestown, N.Y.; and the
Lincoln Rochester Trust Co., Rochester, N.Y., have
agreed to form a bank holding company to be known
as the Lincoln First Group, Inc. In order to transfer
stock ownership of the banks to the bank holding company, three new National banks, one corresponding to
each of the existing National banks, were organized
with the preliminary approval of the Comptroller of
the Currency. If the Lincoln First Group, Inc., receives
authority from the Board of Governors of the Federal
Reserve System and from the Ranking Rnarrf nf the.
State of New York to become a registered bank hold-

$206, 747,093
261, 235

To be
operated

17
1

206, 784,094

ing company, it will then acquire all the stock of the
four banks, except for director's qualifying shares and
as otherwise required by law.
The new charter bank will not open banking facilities until the instant proposal is approved, at which
time it will take over the banking operations of the
existing bank and continue without interruption the
banking services now being offered. Since the new
charter bank is presently a nonoperating bank, the
merger will have no effect on competition. However,
the approval to be granted herein is conditioned upon
all requisite shareholder action being taken and on
receipt of approval by the Federal Reserve Board for
the Lincoln First Group, Inc., to become a registered
bank holding company.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application, as conditioned above, is therefore approved.
NOVEMBER 9,1966.
NoiE.—<Fu/ scuojco&zy of report by Attorney General, see
p. 68.

T H E F I R S T N A T I O N A L B A N K O F J A M E S T O W N , J A M E S T O W N , N . Y . , AND SECOND N A T I O N A L B A N K O F JAMESTOWN,
JAMESTOWN, N . Y .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Jamestown, Jamestown, N.Y. (548), with
and Second National Bank of Jamestown, Jamestown, N.Y. (15656), which
had
. .
merged May 16, 1967, under charter of the latter bank (15656) and with
title "The First National Bank of Jamestown." The merged bank at date
of merger had

To be
operated

$69,427, 658

132,142

69,431,358

COMPTROLLER'S DECISION

On September 19, 1966, The First National Bank
of Jamestown, Jamestown, N.Y., with IPC deposits
of $54 million, filed an application for permission
to merge with the Second National Bank of Jamestown (organizing), New York under the title of the
former and the charter of the latter.
The First-City National Bank of Binghamton, Binghamton, N.Y.; the Lincoln National Bank & Trust
Co. of Central New York, Syracuse, N.Y.; the Lincoln
Rochester Trust Co., Rochester, N.Y.; and The First
National Bank of Jamestown, Jamestown, N.Y., have
agreed to form a bank holding company to be known
as the Lincoln First Group, Inc. In order to transfer
stock ownership of the banks to the bank holding
company, three new National banks, one corresponding to each of the existing National banks, were
organized with the preliminary approval of the Comptroller of the Currency. If the Lincoln First Group,
Inc., receives authority from the Board of Governors
of the Federal Reserve System and from the Banking
Board of the State of New York to become a regis-

tered bank holding company, it will then acquire all of
the stock of the four banks, except for director's
qualifying shares and as otherwise required by law.
The new charter bank will not open banking facilities until the instant proposal is approved, at which
time it will take over the banking operations of the
existing bank and continue without interruption the
banking services now being offered. Since the new
charter bank is presently a nonoperating bank, the
merger will have no effect on competition. However,
the approval to be granted herein is conditioned upon
all requisite shareholder action being taken and on
receipt of approval by the Federal Reserve Board for
the Lincoln First Group, Inc., to become a registered
bank holding company.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application, as conditioned above, is therefore
approved.
NOVEMBER 9,1966.
NOTE.—For summary of report by the Attorney General,
see p. 68.

FIRST BANK & TRUST C O . OF NEEDHAM, NEEDHAM, MASS., AND SOUTH SHORE NATIONAL BANK, QUINGY,
MASS.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First Bank & Trust Company of Needham, Needham, Mass., with
and South Shore National Bank, Quincy, Mass. (14798), which had
merged May 19,1967, under charter and title of the latter bank (14798). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 26, 1967, the First Bank & Trust Co.
of Needham, Needham, Mass., a bank having IPC
deposits of $2.5 million, and the South Shore National
Bank, Quincy, Mass., a bank having IPC deposits of
$94.6 million, applied to the Comptroller of the Currency for permission to merge under the charter of
and with the title of the latter.
The charter bank is located in Quincy, Mass., a city
of 88,000 people that is part of the Boston Standard
Metropolitan Statistical Area. Quincy is geographically
Mtuatfiri 8 miles south of downtown Boston on the
Atiuntfc coast. Along w&k tfca noigfeksrsng t w n a cf
Braintree and Weymouth, it comprises a core that is
the focus for the major industrial complex of Norfolk

$3,448, 627
123, 154, 572
126, 603, 199

To be
operated

2
28
30

County. The largest employer is the Electric Boat Division of General Dynamics which employs 8,000 workers. Other companies having a large impact on the
economy of the city are Procter & Gamble, Raytheon,
Sears Roebuck, and Boston Gear. Norfolk County in
general and Quincy in particular are continuing to
grow and prosper at such an outstanding rate that,
between 1950 and 1960, their pattern of growth was
three times greater than that of the State as a whole.
The merging bank is located in Needham, Mass., a
city of 29,282 which is also part of the Boston metropolitan area. Needham is situated 12 miles west of
dowsiswjfi Boot on tmd. 17 miles /lvi&i wwt uf Quinuy.
Needham, like the rest of Norfolk County, has a solid
and growing industrial base which in tliis case accounts

for 5,000 employees and an annual payroll in excess
«jf $37 niHlkuk Majw eiujjiuyeix aie Wtfiiam Carte/
Co., Microwave Development Labs> Nvribiop
E-leeirynks, RCA, Syivania, and International Equipment Go.
•South Shore National Bank, with its head office, in
Quiiicy and 2G branch offices scHllered ll.iroughout
most of Norfolk County, is the second largest bank in
the county. It is in competition with Norfolk County
Trust Co., the largest commercial bank in the county
and a subsidiary of Baystate Corp., and with Needham
National Bank, a subsidiary of the Shawmut Corp.
Despite the fact that it has been forced to compete
with banks that have the full resources of large bank
holding companies at their disposal, and with the
aggressive policy of large Boston banks such as First
National Bank of Boston, South Shore National has
managed to attract and keep an executive staff of
well trained, knowledgeable men that has enabled
it to establish a sound record of achievement and
growth.
The merging institution, First Bank & Trust, was
chartered in 1960 with its head office in Needham.
Its only branch is in neighboring Westwood. Plunging, as it were, into the vortex of competitive activity
already alluded to, First Bank & Trust has never been
able to establish itself as a firm competitor in Norfolk
County. Jts growth has been insubstantial and not what
was expected of the bank when it was first orga.niyeri.
Today, it is still vainly attempting to compete as a
banking force in a community that is extremely well
banked.
The proposed merger will not result in a .substantial
rcduclujn of alternate diukfjs fur llie public since. Smith
Shore National {jlans to keep both uf Fiisl Bank &
Trust's offices open as branches* The resulting bank

will make it possible, to afford First Bank & Trust's
pi ?.<?«( ciifftarntn^ as w^H AS i+s pntentmil rustMners in
ihe surrounding corrrrnrrmtifts, the typr. of full-hanking
service which is expertrri today. The proposed merger
fully answers the dictates of the banking structure, the
needs of the corrrrmrnrty at large, and will result in
stronger cornpetitiori in the Nftftdharn area.
Applying the statutory criteria to the proposer! merger, we conclude that, it is in thr. public interest and the. application is, therefore, approved.
APRIL 18,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First Bank and Trust Co. of Needham ("First
Bank"), with its main office in Needham and a branch
in nearby Westwood, Norfolk County, Mass., proposes
to merge with South Shore National Bank ("South
Shore"), Quincy, Mass., which operates a main office
in Quincy and 26 branch offices throughout Norfolk
County. As of December 1, 1966, South Shore had
IPC demand deposits of $56.4 million and First Bank
had such deposits of $1.7 million.
The proposed merger would eliminate a certain
amount of direct competition between First Bank's two
offices and six South Shore branches which were from
2 to 4 miles away; it would also increase by about 1
percent South Shore's share of IPC demand deposits in Norfolk Couirly (a liighly concentrated
market)—to 33 percent of the total. Nevertheless, we
conclude that the proposed merger would probably
have relatively little adverse effect on existing competition, because First Bank appears to be a relatively weak
Cympelilor in Needha MI-West wood area, as shown by
\\s operating losses, its declining armrnrrrt of oirtatanding loans, anrl its lark of any participation, of loans in
excess of its legal lending limit of $50,000.

THE. ATOLEJ* NATIONAL. BANK, ATGT.KN, PA., AMI NATIONAL BANK OF CHEKTFTR COITNTY &. TRUST CO., WEST
CHESTER, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Atglen National Bank, Atglen, Pa. (7056), with
and National Bank of Chester County & Trust Co., West Chester, Pa. (552),
which had
merged June 7, 1967, under charter and title of the latter bank (552). The
merged bank at date of merger had.

To be
operated

$3, 088, 385

71,167,478

74, 255, 833

COMPTROLLER'S DECISION

On February 3, 1967, the National Bank of Chester
County & Trust Co., West Chester, Pa., and The Atglen National Bank, Atglen, Pa., applied to the Office
of the Comptroller of the Carreucy for permission to
merge rander the diaiter and willi (lie title of the
former.
Both banks are located in Chester County which
is situated about 30 miles west of Philadelphia in southeastern Pennsylvania. This county, while still economically oriented tnward farmings is beginning to participate in the. rapid industrial and residential growth that
has been sweeping the Delaware Valley.
The National Bank of Chester County & Trust Co.,
having TPC deposits of $57.3 million, is the largest
bank in Chester County and operates four branches
with two more approved but unopened. Its main
oflfio.fi is in West Chester, a city of 16,000 inhabitants,
which is the county seat of Chester County and which
is located about halfway between Philadelphia Pa.,
and Wilmington, Del Although West Chester is primarily a rftsidfintial arpa, it has about 50 small industries. West Chester State College, which has a student
enrollment of somft 4,400 students a k ° n a s a substantial impact upon the economy of the city.
The Atglen National Bank, having IPC deposits of
$2.6 million, is a unit bank located in Atglen, Pa,,
about 24 miles west of West Chester. Atglen is a community of about 2,000 inhabitants that has its economy rooted deeply in the soil. The Atglen National
Bank serves a trade area of a 5-mile radius and it has
no meaningful competition with the National Bank of
Chester whose nearest branch is in Avondale, 14 miles
southeast of Atglen. In brief, the merger will have no
effect upon competition.
The raerger w£H enable the Alglcn office tu compete
inosrt effectively agal/M \1XL couAtuA piusim, of uV
Philadelphia and Wilmington banks. Further, the
mn^ry w<U ftf'/u&i llrt. lOvvu c£. Alglcu w?di UIUIKIV 1
kfS> COjfl$»irtei Services, aud muie uutuLuiliuu lvdii
money. It will also not only solve the pressing problem

of management succession that has effectively hampered Atglen National in its attempt to grow with its
community, but will ultimately result in higher interest
rates on savings deposits and certificates of deposits.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest, and
the application is, therefore, approved.
MAY

5, 1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The National Bank of Chester Gcmnty & Trust Co.
("Chester National"), with its mam office at West
Chester, Pa., and seven branch offices located throughout the southeastern quadrant of Chester County proposes to merge with The Atglen National Bank
("Atglen National"), Atglen, Pa., under the former's
title. As of December 31, 1966, Chester National's deposits were $60.5 million and Atglen NaftiouaT* total
deposits were $2.7 million.
Chester National is the largest bank having its headquarters in Chester County. It has about 27 percent
of the county's IPC demand deposits, according to the
most recently published figures. The foregoing market
e t e e s may somewhat overstate Cluster National's
market power, however, since much of the county's
population is dose to Montgomery and Delaware
counties, in which the Philadelphia-based banks are
permitted to open branches; also, larger banks based
in Montgomery and Berks County have undertaken, or
propose to undertake, banking operations in Chester
County.
There would appear to be relatively little direct
competition between these two banks which operate in
different parts of Chester County. Their main offices
am ajnptrmmatply £4 miles apart; and Chester Ns^
tinnal's rlnsnct hr^nrh (?/. AtfCRdale) k CfpPSSSiSS&tely

14 miles from Atglen National's sole office. Also, the
tim konfa' lnon Ymmrrxk is ir. j/r/rt </v™^-uaiA<uy s»
ifidkatcd by iKffrrr.rarji in thr.ir lvsjwjivt ajsM-t
structure.

T H E FIRST NATIONAL BANK OF SHIGKSHINNY, SHIGKSHINNY, PA., AND T H E WYOMING NATIONAL BANK OF WUJKESBARRE, WILKES-BARRE, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Shickshinny, Shickshinny, Pa. (5573), with
and The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre, Pa. (732),
which had
merged June 16, 1967, under charter and title of the latter bank (732). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 5, 1967, The Wyoming National Bank
of Wilkes-Barre, Wilkes-Barre, Pa., and The First National Bank of Shickshinny, Shickshinny, Pa., applied
to the Office of the Comptroller of the Currency for
permission to merge under the charter and with the
title of the former.
Wilkes-Barre, the county seat of Luzerne County
is located 119 miles northwest of Philadelphia and has
a population of 68,000 in a trade area of about 200,000. The area was once the center of anthracite coal
mining, but that industry has declined to the point that
today it employs only 3 percent of the labor force of
Wilkes-Barre. The decline of the mining industry during the previous decade brought such a diminution in
population and rise in unemployment that WilkesBarre became known as an economically depressed
area. Now manufacturing, predominantly in the
garment trades, employs about 40 percent of the work
force. The number of new industries coming to the
area is increasing, signaling significant improvement in
economic conditions during the 1960's.
The Wyoming National Bank of Wilkes-Barre, with
IPG deposits of $39 million, is the third largest bank
headquartered in Wilkes-Barre. The First National
Bank, with IPC deposits of $99 million, and Miners
National Bank, with IPC deposits of $118 million,
both in Wilkes-Barre, are over twice the size of the
charter bank. The Northeastern Pennsylvania National Bank & Trust Co., with total IPC deposits of
$181 million, has a branch office in Wilkes-Barre. The
charter bank has four branches within 2-8 miles from
Wilkes-Barre, which serve northeastern iAizftrne
County in Edwardsville, Plymouth, Shaverton, and
Exeter. A fifth branch is 27 miles northwest of Wilkes
Barre in Tunkhannock.

To be
operated

$5, 645, 638

51,520, 965

57,166,603

Shickshinny is 17 miles southwest of Wilkes-Barre
and has a population of 1,800, with another 10,000 in
the trading area. The area is rural in character. Dairy
farming is the principal agricultural activity, while
needle trades represent the major industry.
The First National Bank of Shickshinny has IPC
deposits of $4.5 million. This bank, though it. follows
a very conservative lending policy, has not had the
capacity to meet the locally generated demand for
credit during the past year. The charter bank, because
its president was formerly connected with the merging
bank, has been able to attract and serve this Shickshinny business.
The merger will have no adverse competitive effects
as there is virtually no competition between the applicant banks. Nor will there be any effect on the competition between the Shickshinny office and its closest
competitor 1 mile across the river in Mocanaqua.
The convenience and needs of both communities
will be better served by the resulting bank. The Shickshinny office will be able not only to respond to current
lending needs more efficiently, but also to finance the
recreational and manufacturing development expected
in that area. With better trained personnel, installment
lending by the Shickshinny office can expand. Automation services provided by the charter bank can expedite
the bookkeeping of the merging office.
Applying the statutory criteria to the proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
MAY 11,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Wyoming National Bank of Wilkes-Barre, WilkesBarre, Pa., with assets of $48,790,000, proposes to
merge with First National Bank of Shickshmny, Shir.kshinny, Pa., with assets of $5,211,000.

tration in commercial banking within Luzerne County
and would eliminate the potential eompetilkm which
de novo branching by Wyoming could provide.

According to the application actual competition
between Wyoming and First National is insubstantial.
However, the proposed merger would increase concen*

FEDERATION BANK & TRUST COMPANY, N E W YORK, N.Y., AND FRANKLIN NATIONAL BANK, MINEOLA, N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Federation Bank & Trust Company, New York, N.Y., with
and Franklin National Bank, Mineola, N.Y. (12997), which had
merged June 30, 1967, under charter and title of the latter bank (12997). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 6, 1967, Franklin National Bank,
Mineola, Nassau County, N.Y., with IPC deposits of
$1,235 billion, and Federation Bank & Trust Co., New
York, N.Y., with IPC deposits of $204 million, applied
to the Office of the Comptroller of the Currency for
permission to merge under the charter and with the
title of Franklin National Bank.
The offices of the applicant banks are located in New
York City, and Nassau and Suffolk counties on Long
Island. New York City, with almost half of this region's
population and 60 percent of its job opportunities, is
the core of the area. Its economic center is Manhattan
which is not only the hub of world finance but is also
an important area for wholesale trade, insurance, theatrical pursuits, printing, publishing, and garment
manufacturing. Many international and national corporations also maintain headquarters in Manhattan
in order to keep attuned to the pulse of day-to-day
developments in finance, and to keep up with the latest
innovations in their special fields. New York City
personal incomes are estimated at an aggregate of
$27,727 billion in 1964, which is but an indication
of the magnitude of financial services needed by this
great and wealthy city.
The dynamism of New York City is matched by the
astounding growth of its Long Island suburbs since
World War II. With a population of nearly 2.5 million, Nassau and Suffolk are two of the most rapidly
growing counties in the Nation. Since 1960, Nassau
and Suffolk have added $2,693 billion in new construction. In 1965, manufactured goods with value
added of $1.56 billion were produced there, retail trade
amounted to $3,502 billion and wholesale trade totaled
$2,335 billion. Wages and salaries of $3,299 billion
74

$286,883,229
2, 055,462,485
2, 342, 345, 713

To be
operated

14
68
82

were paid in the counties in 1964, an increase of 56
percent over the 1960 figure. This manufacturing employment has removed Long Island from the status of
purely a residential community for workers employed
in New York City.
Projections for the future development of Long
Island indicate continued large-scale growth. Suffolk
County still has 60 percent of its land available for
development as potential living, recreation, and working space. Ambitious mass transit and highway plans
should improve transportation to all parts of the
county. Major public projects such as water supplies
and sewer systems will accelerate its orderly development. Present estimates of Long Island population by
1985 will reach a total of 3.5 million to nearly 4 million. Large sources of capital and financial services will
be increasingly needed on Long Island if the area is
to realize its anticipated potential.
Franklin National Bank was organized in 1926 in a
small Long Island village. Although it has acquired
several banks through mergers since that time, Franklin
has not been involved in a merger for the past 5
years. During the period from 1960 through 1965, its
total resources increased from $801.6 million to $1.7
billion. Franklin entered the New York City market
after 2 years of development at a representative office
there. In 1964, five new offices were opened in the
city. Another Manhattan office was subsequently
added. At the present time, Franklin has a total of 66
offices, 36 of which are located in Nassau County, 20
in Suffolk County, six in Manhattan, two in Queens
and one each in Brooklyn and the Bronx.
Federation was organized in 1923 and was principally owned by trade unions affiliated with the
American Federation of Labor and by individual union

members. The bank closed in 1931 and reopened 11
months later after reorganisation. As new stock was
sold, the general public squired a broader interest in
its development- Although Federation has been a
Manhattan-orientrd hank with its head office and two
branches there, it opened a branch in Flushing in
1954 and acquired a Brooklyn office through merger
in 1958. In the next 7 years, eight additional branches
were established in Queens, Bronx, and Brooklyn.
With a limited number of offices, the applicant banks
operate in the most competitive banking milieu in
the country. Six of the Nation's 10 largest commercial
hanks are located in New York City and all of them
have considerably more resources and more offices than
either of the applicant banks. In fact, Franklin, with
2.6 percent of New York City-Long Island bank deposits and loans, is only the eighth largest bank operating in New York City and is only slightly larger than
the ninth largest, Marine Midland Grace Trust Go.
Moreover, it is only half as large as the seventh-ranked
Irving Trust Co, There is a sharp drop in total resources to 14th place, the position held by Federation,
which has only &5 percent of loans and deposits in New
York City.
After the merger, the resulting bank will still rank
eighth in the New York City-Long Island area and
will have over $1 billion less in deposits than the seventh
largest bank. The 79 offices of the resulting bank will
represent only 7.3 percent of total commercial bank
offices in the entire area and only 3.1 percent of
deposits and 3 percent of loans. Franklin has been
active as an operating bank in New York City for less
than 2 years and is not yet, in many respects, a strong
competitor of the several largest New York City banks.
With its increasing resources, however, the resulting
bank will be in a better position to offer meaningful
competition to these large banks, particularly in the
retail banking area, after the addition of sufficient
New York City branches. We find, therefore, that the
effect of the proposed merger on competition in the
New York City-Long Island area will stimulate and
enhance the competitive structure of banking in the
metropolitan area.
This positive competitive result will be achieved
without eliminating any substantial competition between the applicant banks. Federation has no office on
Long Island where most of Franklin's are located. As
the deposits of Long Island residents which Federation
holds are limited to commuter accounts, competition
is limited to the business drawn from New York City
offices. Federation does not have a national-international division nor engage in money market activi-

ties, as does Franklin; all their New York City business
is not competitive. A fur&ier restriction of uompetilioii
in New York City between the participants is the fact
that offices of Franklin and Federation serve largely
different localities and appeal to different types of business customers.
The only office of Federation in close proximity to
offices of Franklin is its office on 45th Street near Fifth
Avenue (the Grand Central office), which lies about
midway between Franklin's office at 90 Park Avenue,
and its office at Madison Avenue at 48th Street. This
"midtown area" is one of the most highly eoneerrtrated
banking sections in this highly concentrated city and
io ocrvod by many offices of nearly every large bank in
New York City.
Further evidence of the lack of present competition
between the applicant banks is reflected in the fact
that they share only 24 accounts that are not also
shared with other banks. Total deposits in these accounts averaged $436,000 for Franklin and $835,000
for Federation, or 0.03 percent and 0.3 percent of total
deposits, respectively, in a 3-month period ending
October 31, 1966. Loans to these common customers
failed to reach even 1 percent of the total loans of
either bank.
The applicant banks each concentrate on different
types of buckiecc. Slightly over 33 percent of Franklin's
mortgage loans represent construction mortgage loans,
a form of financing in which Federation does not regularly engage. Federation is not active in loans to small
businesses, which represent $31.6 million of Franklin's
loans, nor in charge account loans, brokers' loans and
direct leasing contracts, in which Franklin is involved.
Since all the facts and figures relating to the applicant
banks indicate that they compete principally for
different customers in substantially different markets,
we find that no substantial competition between the
banks now exists which could be eliminated by the
merger.
The convenience and needs of the New York CityLong Island area must also be considered in deciding
this merger. Types of services the Franklin National
Bank offers, although not highly developed, and which
Federation either does not offer, or offers only in a
very limited way, include international banking, corporate and personal trust services (including investment advisory services), correspondent banking and
municipal finance. In all of these activities, the other
large New York City banks dwarf Franklin; e.g., the
other New York City banks have outstanding acceptances of $1,395 billion, while Franklin's total is a mere
$22 million (these figures do not reflect the interna75

tionol bunking activities of numerous branches and
agencies of foreign banks or other Edge Act corpora-

It is concluded in the light of the foregoing analysis
of the proposed merger that the elimination of comnnriTinn
X"""""""""

which has no international department, has been
forced to refer substantial international business to
other New York City banks. By strengthening Franklin w'/Ai lliu u^JuJ luuuiuuuu (A T\sisj^4<&r^/A**vy&*e
can forge uu institution which will not only be &ble to
compete in the international field, but also in the
fields of correspondent banking, corporate and personal
trust service, and municipal finance. The merger will
permit Federation's regular customers to have a broadened raiige of banking swvirM at. the same locations
and with the officers they know.
The principal advantage of die merger to Franklin
is the acquisition of Federation's branches which arc
in some of the prime areas of New York City. These
branches could not feasibly be opened de novo by
Franklin in the foreseeable future because of the expense, difficulty in finding available space and problems of staffing. The New York City community, however, will be better served by having a stronger
competitor in these locations.
Of impui lance to the proposed merger is also the
question of management. Both banks, for difforeat
reasons, huve hud difficulty in recruiting vcr&ot personnel. Franklin has had a. growth more rapid than its
ability tu employ or train r>ffi«.rs; Federation hoe

nnnirnnn
— - - • • - - - -

T"nn

n T1T111 p n TIT
"jri
•

rlTTiirP

TTIITIITTIQI
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OTlfl

the effect of the merge? on the competitive structure
in the New York City-Long Island area will be constructive. It is also concluded that the hmefits to the
pfe\V&£ C^WSSS^SROO p " ^ nnnHn m i l l Vvp rnhrl-inti'ii TT-air.

ing weighed the application againfit the Rtatiitory criteria and havmg determinpH that the merger is in the
public interest, it is. therefore, approved.
MAY

26, 1967.

SUHMASY 'J!F KU-FUKT BY

Franklin National Bank is the eighth largest bank
in the New York City-Long Island (Nassau County
and Suffolk County) area. As of September 20, 1966,
it had assets of $1,790,377,000, deposits of $1,575,089,000 and loans of $990,584,000. Tt operates 66 offices;
its head office and 55 of its hranches are in Long
Island and it has 10 hranches in New York City.
Since 1949 it has acquired 13 other area banks. Federation Bank & Trust Co. is the 15th largest bank in
the area, and> as of September ?/), 1 Qfifi, it had assets
of $28^194,000, deposit? of $?45>660>n0f\ and loans
of ^ISS^/l/JOOL It operates 13 offices, n.ll nf which
are in New York City, and has participa-tsd in one
prior merger. The meigmg barAs each rrffcr the same

[mm»tJ&/A\lA/A\l/r/ |"« J'J"*"" f"« *ivt\r»nnitinnn nrm littla

future in the New York City market for a bank of its
limited resources. At the present time, there is no
replacesae&t for Federation's •«*w»nitivn vice president^
who is nearing retirement, despite vigorous efforts to
recruit from the outside. On the other hand, Federation
has some management personnel who can fill the needs
of Franklin: e.g., the manager of Federation's municipal bond department who is desired as a replacement
for the soon-to-retire manager of Franklin's municipal
bond department. The larger resulting bank will find
the recruitment of men necessary to staff and to lead
a strong bank more feasible than they do separately.

ices. Franklin has 2.6 percent of total deposits in the
area and 2.6 percent of loam, while Federation has
0.5 percent and 0.4 pexcent of deposits and loans,
respectively.
The proposed merger would not substantially affect the level of concentration in commercial banking
in the New York City-Long Island area. It would,
however, eliminate existing competition between
Franklin and Federation which presently provide significant alternative sources of credit for medium- and
small-sized customers.

FIRST NATIONAL. BANK OF PAKAGOUI.D, PARAftrmi.n, ARTK., ANTJ NATIONAL BANK UP CUMMKKHK OF PAKACJUUI.IJ,
PARAGOULD, ARK.
Banking offices
Name of bank and type of transaction

Total assets
:

First National Bank of Paragould ; Paragould, Ark. (13155), with
and National Bank of Commerce of Paragould, Paragould. Ark. (10004),
which had
..merged June 30, 1967, under charter of the latter bank (10004) and title
"First National Bank of Commerce." The merged bank at date of merger
had

COMPTROLLER'S DECISION

On September 24, 1966, the First National Bank
and the National Bank of Commerce, both of Paragould, Ark., applied to the Office of the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of "First National Bank of Commerce."
The merging banks are located in Paragould, the
county seat of Greene County. Paragould is situated
in the northeastern part of the State, approximately
140 miles northeast of Little Rock, 75 miles northwest of Memphis, Tenn., and 9 miles west of the
Missouri State line. The 1960 populations of Greene
County and Paragould were 28,190 and 9,947, respectively. The service areas of both banks are coextensive, reaching a considerable distance beyond the
rity limits of Paragoning and containing a population
of approximately 100,000.
The economy r\f th*» hfljiVV arpa i<5 changing; While
agriculture is rtall the principal source of income, substantial industrial dcvc-SopTncrit has mndc a significant
corrtribratirm. The seven main indiMtriss in ParagrmlH
employ 2,000 persons and 15 srnalW CO"(p*uiics employ up to 50 peisoiis each. The agriculture of the
area is undergoing changes, as the smaller farms are

To be
operated

operation

$10,03?, 408

10,485,306

20,517,714

tive is nearing retirement; there are no younger men
in the bank capable of assuming command.
The National Bank of Commerce, with IPC deposits of $8.7 million, was established in 1901 as a
State bank and converted to a National association
in 1911. It maintains its office across the street from
the main office of the First National Bank and operates a drive-in branch one block west. The bank concentrates its activities in the agricultural lending field.
Although it has trust powers, its crowded and congested facilities have not permitted it to operate an
active trust department or to offer the degree of service
it desires. Over the years, however, its growth rate
has been commensurate with that of the economy in
the area in which it operates and its asset condition
has been sound. With a good pension and retirement
plan, the bank has been able to attract and keep a
number of capable, yuung management personnel.
While the main offices of the two banks are situated
across the street from each other and se/vc Uic s«uuc
general area, they compete with 24 oilier uuiiuiiunabal
bank* in and around Paragould. Of this number, the
merging banks rank sixth and seventh in size, and
they hold 7.3 percent and 9.7 jieivtyil t»f kiaiw and
deposits, respectively. Within the city of Paragmld,
the Sficnrity Rnnk provides the major competition for
tli«» m*»rnnnrr Ko-ntc T h m i r r h K<ariir-iity B?2lk IS ^.^prOXI

units. The already significant resfcl&atial
in the area is increasing.
The First National Bank, with IPC deposits of $9
million, has been in existence since 1889. Its financial
history has been satisfactory and its asset condition is
sound. While its growth has kept pace with the developing economy of the area, the bank has concentrated its activity in the installment and consumer
lending fields. Its banking house is modern and spacious. The First National Bank, however, is faced with
a management succession problem as its chief execu

mately the same size as each of the mergrog bank^ its
$100,000 lending limit gives it a competitive advantage over the merging banks. The Citizens Bank at
Jonesboro, although 19 miles away, is a significant
competitor for much of the business generated in the
area between the two cities. The Citizens Bank of
Jonesboro and the Security Bank are commonly owned
and closely associated in operations. These two banks
together hold 19 percent of loans and deposits in the
service area or twice the total amounts held by the
merging banks. Other Jonesfxuo banks compete to
some extent with the mergmg banks, pulicuiiuly fur

customers living In the area hRt.wf.pm Jnnftshrrro arid
Paragon!'.!. Savings and loan asftomtirrrm, imurancft
companies, finance companies, anil oilier financial
inslilulioris in ilif. nrf3ifl.flTunlsomft competition for
the merging banks,
Tliere is strong eviOencK of newi for a larger hank
In ParaguuM to keep pace with the recent improving
gruwlh Irend in iKrth agiirijlliiif: arid industry. Neither
of ihe iJHiAicipHl-inu banks is prp.seril.ly cif sufficient
size to operate efficienl installment, loan and trust,
departments. The resulting bank, with its greater resources and larger capital base, will be in a better position to develop an agricultural loan department and
generally to provide better service to the people of
Paragould and elsewhere in thp. hank's service area.
Also, the merger will permit, thp. trust powers presently
possessed by the National Bank of Commerce to he
exercised in the facilities of the First. National Bank
when the banks combine.
Consummation of this proposal will not have any
significant adverse effect on competition in the Paragould trade area. Because the services presently heing
offered by the participating banks are more complementary than competitive^ their union will not deprive
the residents of a meaningful hanking alternative.
Whereas the National Bark of Commerce concentrates on real estate loans, commercial and industrial
loans> automobile, loans, and loans to farmery the First.
National Bank stresses personal loans, single-payment
loans and loans on appliances and equipment The
number and dollar amounts of common customers
and shareholders are not significant.
This merger will redound to the public interest by
providing a more, effective competitor for the. Security
Bank. With two banks in Paragould having nearly

equal lending lim'ris, the rfisiilfirrf* desiring larger loans
will have two meaningful alternative sources. The increased size erf the resulting bank will enable it to
compete more;ftfTeri.ivfttywith 1.11ft luanks m Jimeslioro.
It is concluded in the light of the foregoing that
any adverse crrrnpftt.itivft effects which may result frum
the merger are outweighed by the benefits to the
pnhiir. mmrranienre and needs. Having weighed the
apfriiratirm against the slain lory criteria and having
deterrnrnftd that the merger is in the public interest,
it is, therefore, approved.
MARCH 23,

1967.

SUMMARY OF REPORT BY ATTORNEY GRNKRAT,

The National Bank of Commerce (hereinafter the
Charter Bank), the largest of three commercial banks
in Paragould, Ark. ($10.4 million in deposits), proposes to merge First National Bank (hereinafter the
Merging Bank), the second largest with $9.7 million
in total deposits.
Within the city of Faragould the applicant banks
compete with the Security Bank, the only oilier commercial bank. As of December 31,19G5, the three banks
in Paragould appeared to be of courparable size. Deposits of the Paragould Security' Bank, however, include those of the Maraiaduke Security Bank in
Marmaduke, Ark. When such deposits are excluded
from the totals, the merging banks would appeal tu
hold about 90 percent of total IPC demand deposits
(and of total deposits also), of all Greene County,
Ark., banks.
The proposed merger would eliminate substantial
competition between the merging banks, and would
increase concentration to the point of near monopoly
in the resulting bank.

UNTON BANK & TRUST C O . OF AMELIA, AMELIA COURT HOUSE, VA., AND T H E FIDELITY NATIONAL BANK,
LYNGHBURG, VA.
Bankin g offices
Name of bank and type of transaction

Total assets
In
operation

Union Bank & Trust Co. of Amelia. Amelia Court House. Va., with
and The Fidelity National Bank, Lynchburg, Va. (1522), which had
merged June 30, 1967, under charter and title of the latter bank (1522). The
merged bank at date of merger had

$5, 672, 033
145, 549, 695
151,221,038

To be
operated

1
21

COMPTROLLER'S DECISION

On January 30, 1967, the Union Bank & Trust Co.
of Amelia, Amelia Court House, Va., a bank having
IPC deposits of $4.7 million, and The Fidelity National Bank, Lynchburg, Va., a bank having IPC deposits of $120.3 million, applied to the Comptroller
of the Currency for permission to merge under the
charter of and with the title of the latter.
Lynchburg, home office of the charter bank, is a
city of 55,000 inhabitants. It has experienced rapid
industrial growth in recent years, particularly through
the location anrl expansion of national concerns.
Amelia Court. House is a town of some 800 persons,
located sornft 79 miles east of J.ynchbnrg. Situated
in the midst, of agriculturally oriftntad Amelia County,
the town raters to the. needs of the county's 8,000
inhabitants and has little industry to support it
other than farming, two lumber plants^ sawmills, and
a textile mill. Many people in the comity find employment in neighboring counties, in Richmond and in
Petersburg. However, tlift per capita income remains
below thft St.at.ft avftragft and 56 percent of the laborers
of the conrrty have income of less than $3,000 a year.
The merging hank. Union Bank & Trust Co. of
Amelia, is the only bank in the county. Its ultracoiiservative lending policy has resulted in a loss of business doe to its inability to service the credit requirements of tlie local lumber companies^ the three local
auto dealers who pit-se/illy use finance companies, and
thft farmers and small rmsinftssfts surrounding the
community.
Union Bank & Trust operates as a unit bank. It
recently experienced a serious management problem
due to the retirement and resignation of two senior
officials, one of whom supervised the trust activities
of the bank. Although several applicants have been
interviewed recently, none have been found willing to
work for a small bank in a rural community.
While the merging bank is the only bank in Amelia
County, it is surrounded by four branches of the Virginia National Bank and also receives heavy competition from the Bank of Powhatan, located in adjacent
Powhatan County.
The merger will in no way eliminate any competition
since Fidelity National's closest branch is some 23
miles away. On the contrary, it is quite clear that the
merger will cure Union's pressing management problem and, by so doing, will better enable it to compete

effectively with the banks presently seeking business in
its service area. In addition, Fidelity will be strengthened, through an increase in its lending limit and resources, which will enable it to provide a greater range
of service in the Lynchburg area.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
MAY

31, 1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Fidelity National Bank ("Fidelity") operates 21
offices in Lyndmurg ami in seven cuunl.if»: 10 of its
offices are located in the immediate Lyndiburg vicinity, and the remaining 11 are located in 10 towns from
12 to 85 miles from the main office. The counties in
which it operates are Amherst, Appomatlux, Campbell;, Halifax, Luiienburg, Mecklenburg and Nollyway. Fidelity proposes to merge with Union Bank &
Trust Go, of Amelia ("Union Bank") which is the
Only commercial bank in Amelia Gounly.
There appears to be very little direct Competition
between Fidelity and Uniryi Rank. Their head offices
are 79 miles apart; Fidelity's closest branch is located in Biackstone, about 22 miles southwest erf
Amelia Court TTonse in adjacent Nottoway County.
Thft two banks have only one common depositor.
Fidelity is the dominant comrnftrcia] bank in the
area whftre it. operaies. It is thft largest hank having ils
head office in Lynchbiirg; and it Is llie only bank iii
Amherst, Halifax, and Lunenburg counties. Over all,
it has 54 percent of the IPC demand deposits in Lynchburg and the seven counties in which it docs business.
"Thus the effect of the merger would be to extend Fidelity's dominance into one additional adjoining
county.
The competitive situation is to a considerable extent governed by the peculiarities of Virginia branch
banking law—which permits (i) de novo branching
into counties adjacent to the place where a bank has
its head office and (ii) statewide branch hanking by
merger. This law would prevent Fidelity from entering Amelia County by de novo branching (although
it would not prevent Union Bank from entering Nottoway County by this method); thus Fidelity cannot be
regarded as a potential entrant into Amelia County
except by merger.

THE RACINE HOME BANK, RACINE, OHIO, AND THE FIRST NATIONAL BANK OF RACINE, RACINE, OHIO
Banking offices
Name of bank and type of transaction

Total assets

The Racine Home Bank, Racine, Ohio, with
and The First National Bank of Racine, Racine, Ohio (9815), which had
merged July 15, 1967, under charter of the latter bank (9815) and title of "The
Racine Home National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On March 23, 1967, The Racine Home Bank,
Racine, Ohio, with IPC deposits of $1.4 million, and
The First National Bank of Racine, Racine, Ohio, with
IPG deposits of $1.4 million, applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of "The
Racine Home National Bank."
Both institutions are located in the residential community of Racine, Meigs County, Ohio. Racine has a
population of 500 persons and serves an additional
1,800 persons who reside in its immediate trade area.
Meigs County has been designated as a depressed area
by the U.S. Department of Commerce, Fjconomic Development Administration. The population of the
county has decreased since 1900; in fact, it is one of
the few counties in Ohio showing a population decline
between 1950 and 1960. The economy of the area is
primarily agricultural although some business development exists.
Each bank is a single-unit institution established in
1910, and each has displayed slow but steady growth
over the past 10 years. During that time total resources
for the charter bank have shown an increase of 52 percent and 24 percent for the merging bank. Deposits and
loans have increased 57 and 58 percent, respectively,
for the charter bank and 25 and 120 percent for the
merging bank. It would appear, however, that these
two banks have reached the peak of their independent
growth.
Neither bank has been able to serve effectively the
convenience and needs of Racine. Their lending limit
of $11,000 has proved to be inadequate to meet the
credit needs of the area's primarily agricultural
economy. The individual banks are prohibited from
making loans in an amount required by the fanners for
the acquisition of additional land, improvements of
property, the construction of new buildings and silos,
and the acquisition of any significant amount of farm
machinery. In addition, each of the banks involved
80

$1,724,497
1, 760, 825

To be
operated

In
operation
1
1

3, 510, 267

in the merger is faced with a management succession
problem which cannot be alleviated from its present
management staff, nor does it appear that the bank
will be able to attract qualified replacements.
Since the charter and merging banks are the only
banks in Racine, consummation of this proposal will,
by eliminating one, deny the residents a local banking alternative and eliminate whatever slight competition now exists between them. The resulting bank
will, however, be in a better position to meet the aggressive competition deriving from the $6.2 million Citizens
National Bank in Middleport, the $8.4 million
Pomeroy National Bank in Pomeroy, and the $7 million Farmers Bank & Savings Co. in Pomeroy, than
can the participants severally.
Clearly outweighing the slight anticompetitive impact of this proposal are the obvious benefits to the
residents of the Racine community. The larger size of
the resulting bank will permit it to meet more of the
credit needs of the local farmers and give it a broader
earning base. The union of the two institutions will,
by combining the respective staffs, resolve the impending management problems.
Applying the statutory criteria, we conclude that the
proposal is in the public interest, and the application
is, therefore, approved.
JUNE 9,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Racine Bank and The First National Bank of
Racine are the only banks in the town of Racine, Ohio
(population 500). The economic base of the area is
basically agricultural, and the county (Meigs County)
has been designated a depressed area. There are three
other banks in towns located 10 to 15 miles from
Racine; the smallest of the three is about twice the size
of the bank resulting from the proposed merger.
Although the proposed merger will eliminate all
local banking competition in the town of Racine, First
National's market power would appear to be limited

by the presence of other larger banking institutions
within Mcigs Ouu//ty; such banks vwaW be pcrmi&od
under Ohio law to branch into Racine.
First National has 7.9 percent of the county's IPG
demand deposits, while Racine Bank has 5.4 percent
•

of such deposits. The resulting 13.3 percent
cham for the meegtd bank does not se^m n
large in view of the small size of the total county
market (which has only $6.3 million in IPG demand
deposits).
*

FIRST VALLEY NATIONAL BANK, RIGH GREEK, VA., AND T H E FIRST NATIONAL BANK, NARROWS, VA.
Banking offices
Name of bank and type of transaction

•

Total assets
To be
operated

In
operation
First Valley National Bank, Rich Greek, Va. (15139), with
and The First National Bank, Narrows, Va. (11444), which had
consolidated July 21, 1967, under charter of the former bank (15139) and
with title "The First National Bank." The consolidated bank at date of
consolidation had
...

COMPTROLLER'S DECISION

On March 23,1967, the First Valley National Bank,
Rich Greek, Va., a bank having IPG deposits of
$4.4 million and The First National Bank, Narrows,
Va., a bank having IPG deposits of $6.8 million, applied to the Comptroller of the Currency for permission
to consolidate under the charter of the former and with
the title of "The First National Bank."
The First Valley National Bank has its main office
in Rich Greek and has established a branch office in
Pearisburg. This branch was the third banking office
to be established in a town of 2,500 persons, creating
the unusual situation of one banking office per 1,000
inhabitants with an annual income averaging 15 percent below that of the rest of Virginia. The First National Bank operates its main office at Narrows,
situated between Pearisburg and Rich Greek, and has
a branch located in Pearisburg. At the present time,
the bank is experiencing a management problem owing
to the recent retirement, of its former president and
illness of its present president.
Giles County, in which both banks are located, is a
small mountainous county on the western border of
Virginia, with a declining population of approximately
17,000. The county is primarily dependent upon agriculture and one large manufacturing plant operated by
maiely 2,400 people. There are five other ptairix in
the county eudi uf which employs from 75 to 200
peuplc. The yxivuAy is scpsar&tcd by a BMftsstasR rasgc
fiuiu ihc icst KA the Ro&ziokc-^ladferd Economic Sdb
region, bul the degree of isolation may be reduced in

$5,554,527
8,575,875
14,130,403

2
2
4

the near future as a result of major highway improvements. It is expected that these highways will remedy
the slow economic development of this county, as well
as provide a shorter travel time for many who work in
nearby counties.
The four principal towns of the county, each with a
population of less than 2,600, are located in a single
valley in the center of the county. The merging banks
have their home offices in two of these towns with their
branches in the third community of Pearisburg.
At the present time, there are three banking alternatives located within the county which are available to
residents. These are the merging banks with total combined assets of $13.8 million and two offices of the
aggressive First National Exchange Bank in Virginia,
with total resources of $340 million. In addition, competition is also provided by several banks in nearby
West Virginia cities and in adjacent Virginia counties.
The $600 million Virginia National Bank, which has
offices at Pulaski and Radford, communities approximately 25 miles from the merging bank, actively solicits
commercial banking business in Giles County. Several
banks in West Virginia communities have traditionally
received business fruiu residerrts of this eotmty because
of the broader range of services they offer.
Consummation of this merger would affiliate the
First National Bank with the First Virginia Corp., a
of approximately $350 mifiirm. This consummation
would solve serious management difficulties n.t thfc Firat
Natbaal Baak, M w«dl 9£ present a rnnrp halanrpri rnmpet&iv? position vu-fl-vis the Fi*st Natinnal F.vrhange
Bank. Since the resulting bank will be in a position to

offer a broader range of banking services to all segments of Giles County, competition will be enhanced
and the ready availability of services for larger custnmnrB ehnniH iTr^iI^rr^r^ future
k
in Giles County.
While First Virginia Corp. is the fifth largest banking association in the State, its acquisition of the assets
r»f t>ip Fire* TsJo+i^noi ]RoYit o f Narrov/s v.*£Il n e t c h a n g e

its rank among the State's bonking institutions, nor
will it significantly effect its competitive potential.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest, and
the application is5 therefore, approved.
JUNE 14,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposf.H consolidation Involves First Valley
National Rank ("Valley") «nd the First Naticcal D*nk
("National"). These are two of the three commercial
banks in Giles County, Va.—a mountainous, isolated

county on the western Virginia border—with a population of 16,835 in 1964.
The proposed merger would eliminate direct comabout 4 miles apart, with no other bank offices in
between; and their respective brunches III Pearisburg
are only a block apart.
T1!™- —- — - - J — . _ xuu ^lujjuu^u m u g u

u _1_.
. 1 ..
•• n
•
vvuuiu auu auuaiauuauy uu-

crease concentration in an already highly cunuen (.rated
banking market. National presently has about 43 percent of IPC demand deposits in Giles County, and
Valley has another 25 percent of such deposits. Thus,
the effect of the merger would be to place over twothirds of such deposits in the hands of the merged
bank, which would then offer the only banking alternative to a large Roanoke-based bank.
The seriousness of these competitive effects may be
ameliorated setnewkat by SGUJC uuuipetilkw from one
and perhaps more banks located over the border in
West Virginia.

BOULEVARD BANK, SEPULVEDA, CALIF., AND SANTA CLARITA NATIONAL BANK, NEWHALL, CALIF.

Name of bank and type of transaction

Total assets
In
operation

Boulevard Bank, Sepulveda, Calif., with
was purchased July 24, 1967, by Santa Clarita National Bank, Newhall,
Calif. (15547), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On April 17,1967, the Santa Clarita National Bank,
Newhall, Calif., with IPC deposits of $2.9 million,
applied to the Comptroller of the Currency for permission to purchase the assets and assume the liabilities
of the Boulevard Bank, Sepulveda, Calif., which has
IPC deposits of $3.2 million.
Boulevard Bank, organized under the laws of the
State of California, commenced operations in 1963.
This bank, which has no branch offices, has experienced
rather normal growth during its 4 years of existence.
Sepulveda, the home of the Boulevard Bank, is located in the San Fernando Valley about 22 miles northwest of downtown Los Angeles. The service area of
Boulevard Bank, which includes not only Sepulveda,
but. also Panorarrm City, is residential iii nature and
contains a population rstvmfrted at 46,00(1 Decaux of
its proximity to the suburban community of Panorama
82

To be
operated

$5, 212, 690
5, 396, 124
9, 676, 555

City with its large shopping centers and massive housing complexes, the growth of Sepulveda is expected to
be slow. The Sepulveda-Panorama City area contains
approximately 95 firms which employ 3,300 people.
Santa Clarita National Bank was chartered in 1965.
Its sole office is located in Newhall, Calif., which is
about 30 miles northwest of downtown Los Angeles.
Population of the service area of Santa Clarita National Bank, which includes the small surrounding
communities of Sangus, Hornby and Pardee, as well as
Newhall, is estimated at 42,000. This area is primarily
agricultural at the present time, although residential
construction is proceeding at a substantial rate. As
freeways provide ready access into the area from metropolitan Los Angeles, many of the residents of Newhall
commute to Los Angp.ifs and the San Fernando Valley
aira fw crrtplfrfrnerit. Theis: <uc 56 iiikuiudfadminj» suid
research facilities in the area.

The participating banks are of approximately equal
size, although Santa Glarita National Bank has been
in operation less than 2 years and Boulevard Bank
somewhat over 4. Their offices are approximately 12
miles apart serving areas which are separated by a
natural barrier—the sparsely populated Santa Susana
Mountain territory. Because of this factor, the two
banks do not directly compete with one another, but
compete in their respective service areas with major
branch banking offices of the State's largest banks. In
addition to commercial banks, competition for deposits
and loans is furnished by savings and loan associations,
finance companies, insurance companies, and credit
unions. Consequently, consummation of the proposed
purchase would not lessen competition between the
two banks. The effect of this proposal, when consummated, will enable the Santa Glarita National Bank,
with a broader deposit base, to compete more eilec=
tively with the larger banks located in the general area.
Applying the statutory criteria to tfi« proposed purchase, we conclude that it is in the public interest, and
the application is, therefore, approved.
JUNE 22,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Santa Clarita National Bank ("Santa Glarita")
proposes to acquire the Boulevard Bank ("Boulevard"). Both are newly chartered unit banks.
The two banks are located in separate communities
in Los Angeles County, Calif. Sepulveda (location of
Boulevard Bank) is a predominantly residential area of
approximately 5 square miles, with a population of
45,900. The Newhall-Saugus area (approximate population 46,500), in which Santa Clarita is located, is
an unincorporated predominantly agricultural area of
approximately 57 square miles of level land. The two
communities are separated by the San Gabriel Mountain Range, a natural barrier, and are. about 12 miles
apart by road.
The acquisition would not significantly affect the
high degree of banking concentration in the Ix» Angeles area, of Which the applicant banks comprise a
negligible portion; and Uiere would appear to be little
direct competition between the merging banks. Therefore, we believe that the proposed acquisition will
probably not have any adverse competitive effect.

THE BANK OF MOUNT GILEAD, MOUNT GILEAD, N.G., AND SOUTHERN NATIONAL BANK OF NORTH CAROLINA,
LUMBERTON, N . C .
Banking offices
Total assets

Name of bank and type of transaction

The Bank of Mount Gilead, Mount Gilead, N.C., with,
and Southern National Bank of North Carolina, Li
which had
merged July 24, 1967, under charter and title of the
merged bank at date of merger had

rxtxm, N.C. (10610),

$3, 096, 014

106 034,448

r bank (10610). The

COMPTROLLER'S DECISION

On April 17, 1967, The Bank of Mount Gilead,
Mount Gilead, N.G., with IPC deposits of $2.4 million,
and the Southern National Bank of North Carolina,
Lumberton, N . C , with IPG deposits of $79.3 million,
applied to the Comptroller of the Currency for permission to merge under the charter of and with the
title of the latter.
Mount Gilead, with a population of approximately
1,300, is located in south-central North Carolina approximately 40 miles east of Charlotte. Six mediumsize manufacturing concerns are located in ihe town
ajid cortslUule its principal economic bast". Highly pro-

To be
operated

In
operation

109, 130,462

ductive farms in the surrounding countryside also make
a substantial contribution to the area economy. Though
Mount Gilead has experienced no population growth
in the past decade, its well diversified economic base
augurs favorably for the future of the community.
The merging bank has not been meeting the needs
of its community at the present time; the bank's loans
are only 37 percent of its total assets. The relatively
low lending limit precludes the bank from serving the
commercial and large agricultural loan demands of
the area. Its senior management is elderly and there
has not been a management development program to
provide neplacpmnprrrK Thft bank may hr. characterized
83

as a small, ncmnr.rvn&ve^ rvsrai hank in+rrrstecl only in Theie i u o i x u01ixai uf u/mptimg banks luCitted within
serving small customers.
15 miles of Mount Gilead. It appears that this merger
L*imhrrfcnn, hrad nflfwY*. nf the rhnrfvr h*nk, is situwiH bring full baiiiing veiviv&is aggivttively iiiSi/Leted,
ated appmxnTS«ir?y 7(1 rr&r* nr/n*Y<e.x%t nf Mr/swit to all cu*tuu£?rs doid p'jl^iitLd vu£liu&t»x In ' ^ Mouut
Gilead. The city, estimated at 20,000 citizens, has exGilead area.
pcrknrad x 25-^c.rr.nnt pnruilatieffi grewth in the past
The cumptftilive pusilion uf the diaxlw baudt will
7 years. This growth has hern sustaiWr! hy tfcr. prrArciii^in b^iLd^iy iiiicliiiiigcj n* it xnuH cf die iu*/ge/.
pcrous agricultural region, with its attendant foodTile iiiCiease in its size will be minium!, its eulry
proccssing facilities, which nurrrmnAn the riry. Tri
irrto McLiiit Gilead will piuduue a uiure liealQiy bankaddition, lumbering, tobacco, and textile manufacing climate in that area.
turing provide income in this area.
Applying the statutory criteria to the proposed
The charter hank nprratM* office* in 1ft rr/mrnwrHd*; that H is in the jjtdjiic interest,
tics in the south-central section of North Carolma,
and tlie application, tlierefoi-e, is approved.
Though it is the seventh largest bank in the State,
JUNE 23,1967.
it holds only 2 percent of the State's banking assets.
Aggressive marketing nf expanded servir.es »".d a ninn*
U*1 KEtfUKT BY ATiURNKY
ber of small mergers have been responsible for its
Southern
National
Bank, which operates 31 offices
rapid growth in recent years. Among the new services
in central North Carolina, proposes to acquire the
the charter bank will offer in Mount Gilead will be
Bank of Mount Gilead, which is the only bank located
full trust and data processing services, as well as the
in Mount Gilead, N.C. (population 1,300), in the
availability of a farm and forestry counseling departsouth-central portion of the State.
ment. The charter bank also has an active manageFive other relatively small banks (whose total assets
ment development program, which would remedy the
range between $3 and $10 million) are listed as being
impending management succession problems of the
in competition with the Mount Gilead bank; they are
merging bank. Most important, the charter bank
from 11 to 19 miles away.
would bring to the Mount Gilead community and its
It seems clear that there is relatively little direct
manufacturing enterprises a lending limit approxicompetition between the merging banks; the closest
mately 12 times greater than that of the present Mount
office of Southern National is in Rockingham, about 26
Gilead bank.
miles southeast of Mount Gilead.
There appears to be little, if any, competition beNorth Carolina law permits statewide branch banktween the two institutions due to the distance—26
ing and thus Southern National would be permitted to
miles—between the nearest branch of the charter bank
expand in this manner into Mount Gile-ad. Tt may
and the Mount Gilead bank. The merging bank receives loeal ecflripetition piiiii<i/ily fio±n a MiiaH lucal
&£??2ftg& t&A. l&fctfi &3SGO&fck)2i. Tin- mail ufailiu lug IUII-

cerns, located in Mount Gilead, bank primarily with
th* iMge statewide imtilulium in North Guuiiiia.

well hp unrealistic tn awnmp, hnwpvpr, that the SnsaU
rnmmnnity nf A/Trmnt CiiT««ar? ro^^j r""W p^r^nrt tW n
hanks. Therefore, the merger would not appear t o

THF. FIRST N A T I O N A L B A N K U F STUOKF'JRT, STUCKFORT, O H I O , ANTJ THF. FTRST N A T I O N A L B A N K fyp

McCONNELSVILLE, McCONNELSVILLE,

Ohio
Banking offices
Total assets

Name of bank and type of transaction

To be
operated

I
The First National Bank of Stockport, Stockport, Ohio (8042), with
!
and The First National Bank of McConnelsviUe, Mc-Connelsville, Ohio (46),
which had
merged July 31, 1967, under charter and title of the latter bank (46). The
merged bank at date of merger had

$1,087, 682
i
5,974,752 j
!
7,062,434 ;

COMPTROLLER'S DECISION

On April 6,1967, The First National Bank of Stockport, Stockport, Ohio, with IPG deposits of $770,000,
and The First National Bank of McGonnelsville,
McGonnelsville, Ohio, with IPG deposits of $4 million,
filed an application to merge under the charter of the
latter and with the title of "First National Bank,
McGonnelsville, Ohio."
The charter bank was organized in 1863 and operates as a unit bank in McGonnelsville, the seat of
Morgan County. Morgan County is located in southeastern Ohio approximately 30 miles from the Ohio
River, and has a population estimated at 20,000, about
2,300 of wliom live iii McCuiiiiduivHie. The service
area o£ th* charter bank i* mainly devoted to ayriculturs but in recent years a. number uf small industi'ieS
have provided additional support to the economy.
The merging bank was organized in 1933, and operates as a anil bar»&. 11 is the only financial institution
in Stockport, a village witli a, population of some 500
located ahaat 10 miles &ua£& of McGcsrmdsvjSle, In
Morgan County. The seiviue area, of this bank has no
significant industrial development. Most of the residents are either engaged in agricultural activity or
commute to work in neighboring communities.
No significant competition exists between the merging banks. The addition of the resources of the merging
bank to those of the charter bank will only slightly
increase the resulting hank's share of total county
flvspts and thp resulting Hank MdU COntmue tQ face
ctrrmrr
frnm
o rwmTV»tit?rm
x
•

The merger will enable the resulting bank to offer
improved service to the public in the Stockport area
by expanding the lending limit of the merging bank
and assuring it of management continuity. Internal
economies and improved efficiency are expected from
the centralization of bookkeeping functions at
McConnelsville.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest.
The application, therefore, is approved.
JUNE 13,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed mrrgcr involves two very small hanks
in a largely rural mnnty in srnithr.a.sfeiTi Ohio—nsrrwty,
The First National Bank of MrConnrisvillft and The
First National Bank of Stockport.
The offices of the two merging institutions are 10
miles apart, and, except for a. smnnH ha.nl: in Mrdnnnftlsvillft, thare are no other banks in the intervening
area Tn the rirnimrtaTJoe?, *h? pmpived rnprgpr will
inpvitahly eliminate a certain amount of oxmperition
between the two banks, particularly for the business of persons who live in Stockport and work in
McConnelsville.
The merger will also significantly increase concentration in Morgan County, while reducing the number
of banking alternatives from five to four. The McConnelsville and Stockport banks now hold 37 and 6
percent of the courit/s IPC demand deposits, respectively ; thus the merging ba/*k wuuld huld 43 percent of

Thf* Hiti-Mme
P o. . n V
. .
- _ TVotirmol
.
_ ,

Mr.Connelsviliftj Ohio, with resources of $6.6 million,
and Thft Malta. National Bank, located antwx ihfi

The significance of this high concentration ratio may
be reduced suuiewfaal by (a) ihe disUmcu Lnrlwix-u the

sources of $2.1 million.

at the Stockport bank.

THR Framr NATIONAL TJANK OF HASTINGSJ HASIINGS, PA., AND THK FIKSI 1 NATIONAL BANK o r
EBENSBURG, PA.
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
The First National Bank of Hastings. Hastings, Pa. (11227), with.
and The First National Bank of Ebensburg, F<bensburg( Pa. (5084), which had..
merged Aug. 7, 1967, under charter and title of the latter bank (5084). The
merged bank at date of merger had

$3,019,139
25,131,283
28- 150,422

1
3
4

COMPTROLLER'S DECISION

On April 27, 1967, The First National Bank of
Ebensbetrg, Ebensbnrg, Pa., and The Fiist National
Bank of Hastings, Hastings, Pa., applied tu die Office
of the Comptroller of the Currency for pexwission to
merge under the diarter and with die title of the
former.
All the offices of both banks are located in Cambria
Ceranty, which is in central Pennsylvania about 70 miles
east of Pittsburgh. Though Cambria Cuunly has a,
population of 202,000, die 19G0 census disclosed a
3-percent decline in populaliun during the pxiur decade. Due to die hilly terrain of die county, the amount
of agriculture in die aiea is limited. Most employmexit
is in coal mines and industrial enterprises.
Ebensburg, which is centrally located in Cambria
County, is the county seat. It has a population of 4,100,
widi 5,G00 in die surrounding trade area. The Ebensburg area has shown steady growth during the last
4 years. The First National Bank of Ebensburg, with
IPC deposits of $19.5 million, has been growing with
the area. During the present decade, it has acquired
one branch in Barnesboro, a town 16 miles north with
a population nf ^flfifX, and o»e branch in Cresses 9
miles east with a population of 2,700. It also has one
branch in Erjp.nshurg and has approval to open one in
Park Hills.
The Borough of Hastings, the home of the merging
bank, is 15 miles north of Ehfinshurrj and has a population of 1,800. The coal industry was predominant
in Hastings until recently when four coal companies
ceased operations. Sirica then many workers have found
employment in Altoona. and Johnstown. The merging First National Bank of Hastings, with IPC deposits of $2-5 million, has failed to show any significant
growth during the last decade. Its very conservative
policies have resulted in a loan to deposit ratio of only
25 percent.
Although the Bameshoro branch of the Ebensbtirg
bank is 3 miles west of Hastings, there is only a small

amount of competition between the two. There are
adequate hanking alternatives in the area. Within 10
miles of Hastings are seven banks with nine offices including two offires of the United States National Bank
in Johnstown which is the largest bank in the region.
This mergfir will increase the Ebensburg bank's share
of county banking business by a relatively small
amount.
This merger will serve the public interest in both
the Ehenshurg and Hastings sectors of the county. It
will bring to Hastings a more aggressive banking institution offering a hmader range of convenient services including, but not limited to, trust and data processing services. Tt will also enable the Ebensburg bank
to meet competition from larger banks in Cambria
and Blair counties.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest, and
the application is, therefore, approved.
JULY 6,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Both institutions are located in Cambria County, an
area, of doc&niEg popok^icn in AcrffcuMtciu PbmAyivania. Ebensburg (population 5,000) is the county
seat and lies 14 miles to the south of Hastings (population 1,700).
The proposed merger would eliminate existing competition between Hastings Bank and die Buniesboro
office of Ebensburg Bank, 3 miles to the west of Hastings. There are, however, two other banks with offices
within 3 miles of Hastings; and seven banks with nine
offices within 10 miles of Hastings Bank—including
two offices of the region's largest bank.
The proposed merger would involve only a slight
increase in concentration in Cambria County. Ebensburg Bank has 10.4 percent and Hastings Bank has
1.3 percent of total bank deposits in the county. The
two banks have ll.G percent and 1.6 percent of the
county's IPC demand deposits.

T H E MUTUAL NATTONAT. BANK OF CHICAGO, CHICAGO, TT.T.., AND T,A SAT.T.E NATIONAL BANK, CHICAGO, I I I .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Mutual National Bank of Chicago, Chicago, 111. (11092), with
and La Salle National Bank, Chicago, 111. (13146), which had
merged Aug. 14, 1967, under charter and title of the latter bank (13146).
The merged bank at date of merger had
86

To be
operated

$57, 707, 249
370,421,782
428,129,031

COMPTROLLER'S DECISION

On May 5, 1967, The Mutual National Bank of
Chicago, Chicago, 111., with IPC deposits of $67 million, and the La Salle National Bank, Chicago, 111.,
with IPC deposits of $266 million, applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the title
of the latter.
The city of Chicago, where both La Salle and Mutual are located, is the major trading center of the
Alidwestern States. The eight-county metropolitan
trade area of Chicago contains a population of approximately 7.3 million, an increase of 7.7 percent
over the 1960 population. In contrast, Chicago's population of 3.5 million has decreased during the period
due to a major shift in population. The Chicago metropolitan area, with a strong and diversified economic
base, operates as a center for transportation, manufacturing, finance, wholesale and retail trade, communications, and professional services.
La Salle, the charter bank, was organized in 1927
under the name "National Builders Bank of Chicago."
In 1940, the present name was adopted and the bank
acquired offices at its present location on La Salle
Street in the Chicago Loop area. The bank has had a
favorable financial growth, because of sound lending
and investment policies, which have enabled it to more
than double its size during the past 10 years without
merger or acquisition.
Mutual, chartered in 1917, is located approximately
9 miles south of the charter bank. Mutual's early years
were marked by steady growth, and, by 1956, it was
considered one of the leading banks on Chicago's
South Side. Since that time, however, the merging
bank has suffered a net loss of longstanding depositors,
who have moved to other parts of the city, because of
the economic deterioration of the area.
La Salle National Bank, which offers a full range
of banking services, is located in the highly competitive
financial district of Chicago's Loop area. The charter
bank competes with, among others, the following Loop
area banks: the $4.1 billion Continental Illinois National Bank; the $3.9 billion First National Bank of
Chicago; the $1.4 billion Harris Trust & Savings Bank;
and the $1.1 billion Northern Trust Co. The resulting bank, with a mere 2.3 percent of the total deposits within the Chicago metropolitan area, would
not create an imbalance in banking competition. La
Salle also competes for business in areas extending beyond the city, including the immediate metropolitan
area and a broader regional area encompassing the

States of Iowa, Illinois, Indiana, Wisconsin, and Michigan. Each of the merging banks derives only a limited
amount of business from the other's trade area. Therefore, consummation of the merger would eliminate relatively little competition between the two banks.
As a result of the merger, La Salle's lending limit
would increase to approximately $2.5 million, a gain
of $500,000. The larger limit of the resultant bank will
enable it to be more responsive to the larger loan applications, which it is presently unable to service.
Consummation of the proposed merger will eliminate
the problems created by the diversity of interests and
investment objectives of Mutual's principal shareholders. Further, it should resolve the serious problem
of bank deposit outflow caused by the economic decline
in Mutual's trade area. The resulting bank's larger
staff would provide a full range of specialized services,
including EDP accounting, to the larger commercial
and trust department customers of Mutual.
Although the proposed merger would eliminate a
unit bank by reason of the State of Illinois' prohibition
on branch banking, those residents of Mutual's trade
area who prefer to conduct their banking locally would
continue to be served by some 12 commercial banks,
including the $120 million Chicago City Bank & Trust
Co. and $62 million South East National Bank of
Chicago, and savings and loan associations in the
trade area. Furthermore, an application has been filed
to establish a banking institution at Mutual's present
location which will provide an additional banking
facility for the area.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest, and
the application is, therefore, approved.
JULY 14,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The offices of La Salle and Mutual are approximately 9 miles distant from each other in different
sections of Chicago, with many other banks in the
intervening area. Also, data in the application on the
geographic derivation of loans and deposits suggests
that each bank derives only limited amounts of business from the other's predominant service areas. Therefore, the proposed merger would appear to eliminate
relatively little direct competition between the two
banks.
Since Illinois' prohibition on branch banking makes
it necessary to close mutual's office upon consummation
of the merger, the South Side neighborhood currently
served by it would necessarily lose a competitive banking outlet. Seven banks will still be available in the
87

area; and, in addition, as noted in the application, a
new group has already made application to the State
banking aulhuiitiws lu open a new bank in the pressures
to be vacated by Mutual should the merger be
approved.
The parties to the merger have quite small shares
of the Chicago market. La Salle has abwrt 1.5 percent
of the $6.5 biiiiun in UAid IPC rfeuidiid dcpusifo held
by the 134 banks in Guuk Cuuiiiy, 111. (iu whidi Clliicago is located); the merger with Mutual would add

another 0.3 percent to its share. The market shares
arc only very slightly lower, if mqmasnc\ in terms of
shares of the $7 hillinn in tntnl IPC. rlnmanri rieporiis
in the whole Chicago Standard Metropolitan Area.
Use of the city of Chicago alone as the relevant market would increase these shares somewhat.
In view of the distance of the artplirtant hanks from
«tch itfaT, jmc! thrir wnrirH rnnrWt nhnrn^ V#R rmviudc
tlirtt. the effect of the priYpiVird rur.rgr.r r#n rrirnpr.uucn
among commercial hanks would be slight.

SADDLEBACK NATIONAL BANK, TUSTIN, CALIF., AND FIRST NATIONAL BANK OF SAN DTRRO, SAN DTEOO, CALTF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Saddleback National Bank, Tustin, Calif. (15336), with
and First National Bank of San Diego, San Diego, Calif. (3050), which had. .
merged Aug. 17, 1967, under charter of the latter bank (3050) and title of
"Southern California First National Bank." The merged bank at date of
merger had

COMPTROLLER'S DECISION

On April 7,1967, First National Bank of San Diego,
San Diego, Calif., applied to the Office of the Comptroller of the Currency for permission to merge with
Saddleback National Bank, Tustin, Calif., and Huntington Valley Bank, Huntington Beach, Calif., under
the charter of First National Bank of San Diego and
with the title "Southern California First National
Bank."
San Diego, with a population of 683,000, has been
one of the fastest growing cities in the country. Its
economy is primarily based on manufacturing, military payrolls, tourism, and agriculture. More than 800
manufacturing companies are located in San Diego
County and are concentrated primarily in the following industries: food processing, printing and publishing, electrical and nonelectrical machinery, shipbuilding, fabricated metals, and wearing apparel. The importance of the San Diego military installations is
illustrated by the fact that San Diego has the greatest
concentration of military personnel of any area in the
country* and that approximately 35 pprrent of the total
population depends directly upon military activities.
Expenditures for military construction now average
about $20 million annually, and the Navy Department
estimates that its krfal jiayrriH to military pflrsonnel
based in the county HX«JHHIJS $400 million annually,

$15,417,559
412, 678, 910
428,096, 469

To be
operated
1
32
33

with 80 percent of this sum spent in the county. Tourism is also a major industry; a daily average of 78,082
visitors to San Diego spent an estimated $676 million
during 1965. Although San Diego has become increasingly urbanized, the value of agricultural production
has maintained a rising trend with an increase of 75
percent from 1950. With a diversity of high-income,
high-yield crops which include tomatoes, oranges,
avocados, and rare nursery stock, San Diego County
ranked among the top 20 counties in the Nation in the
value of agricultural production in 1965.
Economic prospects for the San Diego area are
favorable. Projections of the San Diego City Council
estimate a growth rate between 1960 and 1980 of 74
percent. The employment structure is in the process of
change from primarily agricultural and aircraft employment to a greater proportion of employment in
service industries, particularly those associated with
tourism and scientific research. The five largest employment categories in 1985 are expected to be government, services, retail trade, manufacturing, and
construction. A liighly developed educational and reicdidi cunipicA is d. fur (Lex indication that the San
Diego area will be able to keep abreast of the increasing demands of modern industry.
The two merging banks are located in Orange
CWf.rly, w?iii4i inljuim RHII T)\t>gn fSnurrfy on H* nOi.lliwftst hernndary. Orange Genmty, whirh is the mewl

rapidly growing large county in the Nation, ranks 13th
in population among all counties in the country. Once
agricultural, the county's economy has developed a
large diversified industrial base which accounts for the
second highest manufacturing employment in California. Between 1%0 and 1964, 424 new manufacturing firms were, established in the county. The 10
largest employers in the county have over 49,000 employees, and there are more than 179 major industrial
firms, each with 100 or more employees. Taxable retail sales exreed $1J? billion* tourists and visitors spend
more than $250 million^ mineral production exceeds
$100 million, and agricultural production amounts to
approximately $90 million. It has been predicted that
the population of Orange County will reach 2.280 million by 19R0, an increase of 90 percent over the present
population. Tf this growth follows the pattern of the
past, the increased population will be characterized by
relatively high home valuation? and an unusually high
proportion of high-income families with education
above the national average.
Tustin is located 8ft.5 roUes from San Diego and has
a population of 11,00Cl Though one of the oldest communities in Orange. County, it has only recently experienrerl population growth. Prisaarily a residential
town, Tustin has a median home valuation of $17.^>QG>
and two adjacent unincorporated areas have median
home valuations of $25,600 and $29,300. Approximately one-half of the heads of households in the
service area are in the high-income categories either
of the professions, including engineers and scientists,
or as managers and proprietors of service establishments, Tt is estimated that population growth will be
rapid in the future owing to the development of the
nearby University of California Irvine Campus. The
Irvine Industrial Park, which borders Tustin on the
south, eventually will be a major industrial complex
of 2,600 acres specializing in research facilities and
related manufacturing. It is expected that wage levels
will be high.
Huntington Beach, with its population of 86,000,
and the neighboring city of Fountain Valley, a community of 17,000, which the Huntington Valley Bank
also serves, are located on flat land extending inland
from the Pacific Ocean. This land was originally devoted to farms and oilfields, but it now is being used
increasingly for residential development. Located 88.5
miles from San Diego, 35 miles from Los Angeles, and
12 miles from Tustin, the Huntington Beach-Fountain
Valley area expects extensive future expansion; a little
more than one-half of its total acreage is now developed. The major industrial development in Hunting-

ton Beach is the Douglas Space Systems Center which,
when completed in 1970, will contain 17 buildings and
represent an investment of $75 million. The Iluiitington Beach oil field continues to be the second laiges.1
producing field in California. Southern California
Edifm has a 900,000-kilowatt steaxapberd in llxc city.
While the past few years have brought spectacular
growth to this area, the future promises coirtinued
economic progress.
The charter bank, organized in 1883, has total resources of $393 million and 31 branches, all in Saa
Diego County. It competes directly with San Diego
County offices of the multibillion-dollar Bank of
America (50 branches), Security First National (33
branches), and United California Bank (3 branches).
It also competes with the San Diego branch of the
$1.63 billion Union Bank, and the 12 offices of the
$362 million United States National Bank, San Diego,
which is only slightly smaller than the First National.
In addition, Beveral smaller banks and several poweiful savings and loan associations, with a total of over
$1 billion in deposits, arc located in San Diego Comity.
The Saddleback National Bank was organized in
1964 and now has $13 million in total resources. It has
oae approved but unopesed ©ffiee in GarMa Ana. Saddleback National also competes with the Bank of
America, which has 11 branches in its area, Security
First National, which has six branches, and United
California Bank, which has three branches. United
States National Bank, San Diego, also has two offices
in Oranga County. In addition, there are several other
offices of other regional and local banks in the Tustin
area as well as a savings and loan office within a few
bloclcs of Saddleback's main office. Savings and luaii offices in San Diego also solicit business in Orange
County.
The Huntington Valley Bank is, like Saddleback National Bank, a relatively new bank, having been organized in 1963. It now has $10.6 million in resources
and one branch at Huntington Beach. It competes with
five offices of the Bank of America, six offices of Security First National, and two offices of United California
Bank. The San Diego-based United States National
Bank also has an office in Huntington Beach, as does
Crocker-Citizens National Bank. First Western Bank
and Westminister National Bank are other competitors
of Huntington Valley Bank.
The effect of the merger on competition will be
minimal. All of the applicant banks encounter the
previously described extensive competition of larger
institutions. The strengthening of all the applicants
by their union will make available alternate resources
89

of a larger bank to the public in the areas of the merging banks, and will give First National of San Diego
an opportunity to expand into Orange County and
thereby increase its competitive strength. No competition will be eliminated by the merger as the First
National does not now have offices in Orange County;
its closest office to an office of Huntington Valley Bank
is 53 miles and no offices will be discontinued. Saddleback and Huntington Valley Bank are 12 miles apart,
and, as purely local banks, they do not serve the same
customers.
The convenience and needs of the Tustin and
Huntington Beach public will be substantially improved. In both of these a r e ^ thciv is a trcmcttdous
demand for funds because of continuing residential,
commercial, and industrial construction, as well as
growth in established business firms. With maximum
individual loan limits of $75,000 and $100,000, respectively, Saddleback National Bank and Huntington
Valley Bank do not have the opportunity to serve
many potential caste/ram's. With a maximum singlclo*£i lkuh uf $3U million, the. charter bank will provide another source of substantially increased randit
; n Clrxntrp. County. Both
that loam at. their offices wiH
be considerably expanded after merger.
An additional benefit to the public will be the
ofTeiing u£ Unit j^vw.<*.< tri thr. mrrgmg banks' customerE. Neither birnk, hnrxntv. of limited size, presently
ha* 'i. trust department, rifspitft thr. fart that the rd&
tiveiy hiyL-i^cwn^ gror^n living in thr.ar. arras Qre
likely customers. The charter bank has a large and
weH (sUdiiialied tm«t H ^ A I l.niriit, the services of which
will be available to thr. merging banks' customers.
The credit analysis department of the charter bank
will materially aid rhft mrrgjng hanks' lending activities through quality control, as well as the processing
of unusual «_«• specialized loan requests. The borrowers
in the area will increasingly need more sophisticated
financing which small banks cannot offer but which
the resulting bank can provide on a competitive basis.
Other important conveniences will be offered the
Tustin-Huiitington Beach public. These additional
services include a larger and more experienced credit
collection depart™ wit, ar> internal audit department,
an mvetslu&eujL service rjfyartmf.nt, and experienced
real estate appraisers. The charter bank's international
department will also be available to issue letters of
credit, execute foreign collections and credit inquiries.
Since the Saddleback National Bank and Huntington
Valley Bank perform none of these services at present,
the public in this progressive area will benefit sub-

stantially from their availability. Although these services are available from branches of some of the California banking giants, the competition of the resulting
Southern California First National Bank will provide
a stimulus for better services and give the public an
alternate choice they do not now have.
Tt is concluded in the light of the. foregoing analysis
of the. proposed nwgp.r that not. only will there be no
elimination of mm petition as a result of the merger,
but that the. effect of the merger on the banking structure in San Diego and Orange counties will be competitively beneficial. It is also concluded that the benefits
to the public convp.nienr.ft and needs will he substantial.
Having weighed thefljipftr.at.irmngaimt t.hs statutory
criteria and having determiner! that the merger is in
the public, interest, it is, therefore, approved.
JULY 12,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

First National, a major southern California bank
lucaled m San Diegu, piuposes to acquire tv^o very
itCeirily eSlaUiihed and jjicsptfing independent Iwnfai
in Giants Comity—wLidx is a i-apidly expanding
«•£«;•

?.d'?.C^rit l v L.-OS _4.£"*'l**e n>^irVr+»< (rvn t i l * v\r*r\\\\

and S»ii Dingu CouiUy (cvsa the south). First National'*
operalions are confmed to San Diego County—where
it is a major factor in the local banking market. It has
Abotrf 22 f/eiLciri uf the bduklug v<SI<:es A"d 25 p^iTrnt
c£ IPC deuiaiid 'Jeposils iu the courrty; it afqieflrs to be
the laigevt 1>ajftk—wHh its lirti'J c<ffice la Sari Dipgr^
itnvl 0»f fcttwnd lviig^kl bviijik i«j lennf v£ t<^ftl ryrirrxt'irm*

in San Diego County.
TLwv wuuld upptrux- lu btr lilllt: (if any) present
diiert compdHiGu btlwffii Fix si National *md eHher
of the banks il propuses lo Hcquire in neighboring
Orvmge County. Saddleback Na«!c»rifjl T^anli and TTiintiiiglon Valley Dank are,re<pt%tiv«ly,52 and 53 miles
from First National** do&exl c*ffic« in San Diegri County.
On the ijthei hand, the pioposed mergers might well
diminate some present direct competition between
Saddleback National Bank and Huntington Valley
Bank, wiiicfa would becume brandies of the same banking system. The two banks would appear to be about
12 miles apart. There are, however, other banks in. the
area, and U appears thai Saddleback Nation*! Bank
and IIu"li<J«low Valley B&JL& atccuind Tor a ldallvtiy
small proportion of Orange County's IPC demand
deposits (1 and 0.7 percent, respectively).
First National appears to be the largest San Diego
bank which has not already expanded northward! into
Orange County. It would be permitted by California
law to enter Orange County by dp. nova branching, and

in view of that area's growth, this seems a realistic possibility; also expansion by First National in other directions is not possible, since Mexico lies to the south and
a desert to the east of San Diego County. That First
National is generally interested in expansion into
Orange County is suggested by its act of acquiring two
growing Orange County banks at the same time.
Accordingly, we find that the proposed mergers in-

volve some loss of potential competition, flowing from
the elimination of First National as a potential independent entrant into Orange County. However, we
are not able to evaluate the seriousness of this effect,
since the application does not provide information on
the degree of market concentration in Orange County,
or the possibility of other independent entry by other
banks located in Los Angeles or elsewhere in California.

FIRST NATIONAL BANK, LAKEVIEW, TEX., AND FIRST NATIONAL BANK, MEMPHIS, TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank, Lakeview, Tex., with
was purchased Aug. 23, 1967, by First National Bank, Memphis, Tex.,
which had
After the purchase was effected the receiving bank had

COMPTROLLER S DECISION

On August 18, 1967, application was made to the
Comptroller of the Currency for permission for the
First National Bank, Memphis, Tex., to purchase the
assets and assume the deposit liabilities of the First
National Bank, Lakeview, Tex.
As directed by the terms of Subsections 4-6 of Section 1828 (c) of Title 12 of the United States Code, I
hereby find that there exists a reasonable probability
that the First National Bank, Lakeview, Tex., may fail;
that said reasonable probability of failure is imminent;
and that a reasonably prudent discharge of my responsibilities in the maintenance of a sound National
banking system requires the immediate action on this
application. I also find that the financial and managerial resources of the acquiring institution will be adequate to protect the customers as well as the public
interest of the entire community and that no other

To be
operated

$791, 193

8, 150, 926
8,942, 119

bank possessing the requisite breadth of financial and
managerial resources has indicated a willingness to
assume the responsibilities of the selling bank.
I conclude that this transaction, as a matter of law,
will neither occasion a violation of Section 2 of Title
15 of the United States Code nor will it substantially
lessen competition as that concept has been judicially
accorded with the failing company doctrine. On the
contrary, I conclude that the deleterious effect of a
failure of the selling bank on the financial stability of
the geographic market it serves would significantly
exceed any impact of the transaction upon competition.
In order to protect the depositors, creditors, and
shareholders of the First National Bank, Lakeview,
Tex., this application is approved and the First National Bank, Memphis, Tex., is authorized to proceed
with this purchase and assume transaction forthwith.
AUGUST 23,

1967.

T H E FIRST NATIONAL BANK OF THREE SPRINGS, THREE SPRINGS, PA., AND UNION NATIONAL BANK & TRUST
Co. OF HUNTINGDON, HUNTINGDON, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Three
and Union National Bank &
(4965), which had
merged Aug. 30, 1967, under
title "Union National Bank
bank at date of merger had

Springs, Three Springs, Pa. (10183), with....
Trust Go. of Huntingdon, Huntingdon, Pa.

To be
operated

$2, 507, 613

20, 351, 663

charter of the latter bank (4965) and with
& Trust Go. of Huntingdon." The merged
22, 859, 277

COMPTROLLER'S DECISION

On April 14, 1967, The First National Bank of
Three Springs, Three Springs, Pa., with IPG deposits
of $2 million, and the Union National Bank & Trust
Co. of Huntingdon, Huntingdon, Pa., with IPG deposits of $15.1 million, applied to the Comptroller of
the Currency to merge under the charter and with the
title of the latter.
The First National Bank of Three Springs is located
in a small rural community with a population of 450
in southern Huntingdon County. The local economy is
based on marginal farming, some lumbering, anrl a.
few minor bituminous coal stripping operations.
The charter bank, located in Huntingdon, with a
population of 7,500 is in the central section of Huntingdon County. The county has a population of approximately 40,000 and is in the south-central section
of Pennsylvania which is part of the Appalachian
Mountain chain. The economic base of the area is
supported by diversified industrial and commercial
activity, and by important agricultural pursuits with
dairy farming predominating.
Consummation of this merger will have no cognizable adverse effect on banking competition in the area.
The merging bank is 25 miles south of the mam office
of the charter bank and is separated from it by very
mountainous terrain. Eighteen miles of mountains
separate the merging bank from the charter bank's
closest office at Mount Union.
This merger will stimulate banking competition in
the county to the ultimate benefit of the residents and
customers. In the vicinity of Three Springs, the $4
million Community State Bank of Orbisonia, and the
$4 million First National Bank of Sexton will be given
a new competitive diaHciige. Neither the Pcnn Central
National Bank in Huntingdon, with IPC deposits of
$25 million, nor the First National Bank of Mapleton

Depot, with IPC deposits of $3.2 million, both of which
now compete with the charter bank, should be disturbed
by this merger.
Consummation of this proposal will resolve management succession problems for the merging bank. It will
also enable the resulting bank to serve the credit requirements of the customers of the merging bank whose
needs presently exceed the local lending limit. Other
benefits will also accrue to the customers of the merging bank in the form of trust services and lower install ment loan costs due to data processing.
Applying the statutory criteria to the proposed mer
ger, we conclude that it is in the public interest, and the
application is, therefore, approved.
JULY 27, 1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger involves two banks in Huntingdon County, Pa.
Huntingdon County is an area of declining population in west-central Pennsylvania about 25 miles east
of Altoona. Its 1960 population of 39,457 represents a
3-percent decline from 1950.
The proposed merger of the second largest and the
smallest of seven banks in Huntingdon County would
eliminate whatever direct competition presently exists
between the two banks. The extent of this competition
may be comparatively small since (i) two other banks
have offices in the area intervening between First National and the closest branch office of Union National,
and (ii) small unit banks, such as First National, tend
to derive most of their business from their immediate
neighborhood.
The proposed merger would increase Union National's share of Huntingdon County's TPC demand deposits by about 4 percent, from 34 to 38 percent of the
total.

CONCORD NATIONAL BANK, CONCORD, CALIF., AND CENTRAL VALLEY NATIONAL BANK, OAKLAND, CALIF.
Banking offices
Name of bank and type of transaction

Concord National Bank, Concord, Calif. (15394), with
and Central Valley National Bank, Oakland, Calif. (6919), which had
merged Aug. 31, 1967, under charter and title of the latter bank (6919). The
merged bank at date of merger had

Total assets
In
operation
$9, 427, 330
198, 625, 859
208, 153, 189

To be
operated

1
31
32

COMPTROLLERS DECISION

On May 23,1967, the Concord National Bank, Concord, Calif., with IPC deposits of $5.4 million, and the
Central Valley National Bank, Oakland, Calif., with
IPC deposits of $141 million, applied to the Comptroller of the Currency for permission to merge under
the charter and with the title of the latter.
The San Francisco-Oakland metropolitan area is
composed of five counties surrounding the San Francisco Bay, which is one of the world's largest landlocked harbors and a major economic, recreational,
and scenic source. The coastal plain along both sides
of San Fancisco Bay is especially suited for heavy industry because of convenient rail, air, and port service.
The Golden Gate divides the western portion of coastal
plain into two peninsulas, the southern arm of which
is occupied by the highly developed countries of San
Francisco and San Mateo. Across the bay from San
Francisco on the east or mainland side are the East
Bay counties of Alameda and Contra Costa.
Central Valley National Bank, the charter bank, is
located in Oakland, the seat of Alameda County and
the fourth largest city in the State of California. It is
the principal commercial center of the county and the
entire East Bay region. Oakland is served by a network
of State and transcontinental highways, a number of
truck and steamship lines, an international airport, and
a deepwater harbor. These have made the city a logical choice as a main office for national manufacturing
and distribution firms. Oakland ranks second only to
San Francisco as the major retail center in the Bay area.
Charter bank was organized in 1956 and, because of
aggressive and capable management, now operates 27
branches. Competition in this area is intense and is
dominated by the major California banks, i.e., Bank
of America, Wells Fargo Bank, Crocker-Citizens National Bank, United California Bank, and Bank of
California, N.A.
Concord National Bank, the merging bank, is located
in Concord in Contra Costa County, Calif. Concord,
with a population of 82,500, is located in the San
Francisco-Oakland metropolitan area. Concord is a
residential community which has experienced considerable growth during the past 15 years and whose
prospects for continued growth are considered excellent because of its close proximity to the Bay Area
Rapid Transit System presently under construction.
Five industrial parks have recently been established
in Concord to attract manufacturing plants and to
brighten the area's economic prospects generally.
The merging bank, a single-unit institution, was

organized in 1964. While it has experienced good
growth since its inception, it presently faces intense
competition from the Standard Savings & Loan Association which has share accounts totaling $42.5 million, from 10 finance company offices, six mortgage
company offices, one industrial loan company office,
and three credit unions.
The merging Concord National Bank is located
approximately 20 miles northeast of the main office
of the charter bank, 12 miles northeast of the Orinda
office of charter bank, and 6.4 miles northeast and
18 miles southwest, respectively, from the approved but
unopened branches of the charter bank in Walnut
Creek and Antioch. The closest offices of the banks are
separated by two suburban communities and a number
of intervening banking offices. Thus, there would appear to be only a minimal, if any, amount of direct
competition between merging and charter banks. The
competitive picture in the San Francisco-Oakland
area will remain relatively unchanged by the merger
and the only significant impact which will be felt will
be in Concord where the results will be favorable.
Consummation of this merger will promote the
public interest in all the communities served by the
resulting bank. It will increase competition among the
financial institutions in Concord by introducing a bank
with a greater lending capacity and better able to
meet the needs of the community. The resulting bank
will offer expanded services including a trust department, a credit card operation, computer services, and
specialists in the fields of real estate construction,
mortgage servicing, and commercial loans. Coordinated marketing and advertising programs will also
augment the resulting bank's competitive position in
relation to the larger banks now operating in the Bay
area.
Applying the statutory criteria, we conclude that the
proposal is in the public interest, and the application
is, therefore, approved.
JULY 31,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Central, while somewhat smaller than the leading
California branch banking systems is a relatively sizable institution with 30 branches located primarily in
the San Francisco Bay area and San Joaquin and
Stanislaus counties to the east. It proposes to acquire
Concord National, a new unit bank chartered in 1964
in the city of Concord in Contra Costa County, a part
of the San Francisco metropolitan area.
It would appear, however, that there is at present
only a limited amount of competition between the two

banks since their nearest offices are 12.4 miles from
each other. The relative attractiveness of the Concord
area, and its recent marked population growth, would
appear to favor de novo branching by the Central
system, were the alternative of merger not made available to it.
Central has received permission to open a branch
at Walnut Valley, approximately 5 miles away from
Concord National's sole office. This branch would be
a direct competitor to Concord National, and such
competition would be foreclosed by the merger.

In this case, the entire San Francisco-Oakland metropolitan area is probably too broad to be considered
the appropriate market; the two counties directly involved (Alameda and Contra Costa counties, which
between them have about 60 percent of the San
Francisco area's total deposits) would seem a more
appropriate limited area for analysis. Within these two
counties, Central has less than 6 percent of total I PC
demand deposits, and its acquisition of the newly created Concord National would add only about another
0.4 percent to its market share there.

THE CITIZENS BANK & TRUST C O . OF SOUTHERN PINES, SOUTHERN PINES, N.C., AND FIRST UNION NATIONAL
BANK OF NORTH CAROLINA, CHARLOTTE, N.C.
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
The Citizens Bank & Trust Go. of Southern Pines, Southern Pines, N . C , with.,
and First Union National Bank of North Carolina, Charlotte, N.C. (9164),
which had
merged Aug. 31, 1967, under charter and title of the latter bank (9164). The
merged bank at date of merger had

COMPTROLLER S DECISION

On May 8, 1967, The Citizens Bank & Trust Co.
of Southern Pines, Southern Pines, N . C , with IPC
deposits of $9.4 million, and the First Union National
Bank of North Carolina, Charlotte, N . C , with IPC
deposits of $466.5 million, filed an application with
the Comptroller of the Currency for permission to
merge under the charter and title of the latter.
The merging bank, organized in Southern Pines in
1905, now operates a drive-in facility in addition to
its main office. Southern Pines, located in the southern
portion of Moore County, with a population estimated at 5,200, is renowned as a winter resort offering
a variety of recreational activities with special emphasis on golf. Many successful but now retired businessmen have established residences in this area. The
vitality of this resort community is reflected in its high
level of per capita income and the number of retail
Establishments offering a variety of high-grade, highcost goods. Moore County also derives additional economic support from the manufacture of textiles and
from the production of tobacco.
The charter bank, which was organized in 1908
with headquarters in Charlotte, Mecklenburg County
now operates 75 offices located in 43 communities in

$13,436,483

709, 027, 699

722, 479,074

various sections of the State. Mecklenburg County has
a population estimated at 300,000, largely concentrated
in Charlotte which is not only the largest urban center
in the Carolinas but is also one of the fastest growing
cities in the southeast. Although Mecklenburg County
is a leading industrial center, its distribution and transportation facilities are even more important in terms
of employment. The service area of the charter bank
covers principal areas of the State, including the mountainous area in the west, the industrial Piedmont area
in the center of the State, and the portions of the
predominantly agricultural coastal plain. Competition
is received primarily from three statewide institutions,
two of which are substantially larger than the charter
bank, and from various regional and unit banks.
There is no competition between charter and merging bank as the nearest office of the charter bank to
the merging bank is the Red Springs Branch in Robson
County, 30 miles to the southeast of Southern Pines.
In addition, it appears that charter bank has been
unsuccessful in attracting any significant business in
Moore County. The entry of First Union National
Bank into Southern Pines by means of a de novo branch
is not economically feasible. Although this small, but
affluent community is able, to support both the merg-

ing bank and a branch of the $90 million Southern
National Bank, there is no demonstrable need at this
time for a third banking alternative.
Consummation of this merger will benefit Southern
Pines and its residents. By replacing Citizens Bank &
Trust Co. with First Union National, banking competition with Southern National will be stimulated. These
competing banks, with their substantial resources, will
be ideally situated to induce new industry to locate
in the area and to assist in further development of local
recreational facilities. The advent of First Union National Bank will bring to the residents the specialized
trust services they demand, the benefits of a credit
card operation, computer services, a more sophisticated
lending program, and the benefits of a management
training program.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest, and
the application is, therefore, approved.
JULY 27,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

North Carolina's third largest commercial bank
("First Union"), proposes to acquire one of the two
banks in Southern Pines, Moore County, N.C. The
latter ("Citizens") holds total deposits of $10,930,000
in its two banking offices, as compared with
$584,466,000 in 97 offices for First Union.
The principal area affected by the proposed merger
is Southern Pines and the surrounding country in
Moore County, N.C. This area lies in the south-central
part of North Carolina, about 100 miles east of Charlotte (where First Union has its head office). The
1960 population of Southern Pines was 5,198, and
that of Moore County as a whole was 61,002; both
were growing gradually.
According to the application, Southern Pines is
primarily a vacation center: "by far the most important industry is tourism and golf." Southern Pines is,
however, said to be attracting more and more yearround residents. Moore County also has some agriculture and commercial poultry production.

There are four banks with eight banking offices in
Moore County. Citizens is a substantial factor in that
market, controlling about 36 percent of total deposits
and 31 percent of I PC demand deposits in the county.
Its principal source of competition is said to be the
Southern Pines branch of the Southern National Bank
of North Carolina (total deposits from all offices:
$86.3 million).
A distance of about 30 miles separates Citizens from
the closest branch of First Union, located in another
county (a second First Union office is 36 miles away);
therefore, the merger would not appear to foreclose
significant amounts of direct competition between the
two banks.
The proposed merger would continue the trend toward concentration of banking resources in the hands
of North Carolina's five largest banks, which already
control about two-thirds of the State's deposits. The
actual increase in this case is slight, however.
North Carolina law permits statewide branch banking; and thus First Union would be permitted to enter
Moore County by de novo branching. It would appear
First Union is an aggressive, expanding bank—as
shown by the fact that it has six new branches approved (but not yet opened) and applications pending for two more, in various parts of the State. First
Union, which operates extensively in the central part
of the State and is the State's third largest bank, is
thus one of the most probable entrants into the Moore
County area by de novo branching. The proposed
merger would foreclose this possibility of independent
entry, while at the same time eliminating a thriving
independent bank from the local market and hence it
would have an adverse effect on potential competition.
Moreover, the proposed merger would continue a
significant trend of acquisitions and mergers by North
Carolina's largest commercial banks—to which First
Union has contributed heavily by 14 acquisitions since
1956. This acquisition trend has doubtless had a general impact on potential competition, by reducing the
establishment of de novo branches by the largest banks,
and thereby inhibiting the development of a more
competitive banking structure within the State.

T H E FARMERS BANK OF ELK GREEK, ELK GREEK, V A . , AND T H E GRAYSON NATIONAL BANK, INDEPENDENCE, V A .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Farmers Bank of Elk Greek, Elk Creek, Va., with
and The Grayson National Bank, Independence, Va. (10834), which had
merged Aug. 31, 1967, under charter of the latter bank (10834) and with
title "The Grayson National Bank." The merged bank at date of merger
had

COMPTROLLER'S DECISION

On May 2, 1967, The Fanners Bank of Elk Creek,
Elk Greek, Va., with IPG deposits of $1.5 million and
The Grayson National Bank, Independence, Va^ with
IPG deposits of $5.5 million, applied to the Office of
the Comptroller of the Ck*?rescy for permiEeion to
merge under the charter and title of the latter.
Elk Occk, with a population of 150, and Independence, with a population of 750, are located 10 miles
apart in Grayson County, Va. Grayson County, with
a declining population presently estimated at 17,200, is
located in the southwestern part of the State, approximately 100 miles southwest of Roanoke. The town of
Independence is the county seat. The service areas of
the merging banks comprise most of the county which
has a mountainous terrain including large sections of
woodland. The economy of the area is largely devoted
to raising livestock, but there are a few milk processing plants in the county, and several manufacturing
eslabiiislimtjiits centered arortnd Indq^ndcnfy.. The
largest population center in tbr ai-a is Galax, a city
uf 5,200 wiiich is located afoemt 1ft milftx to the cast
of the merging banks on the eastern hnrdfr of Grayson
County.
The charter bank was organized in 1900, and remains a single-office bank. It has shown a healthy
growth in deposits in racm* years, and has had good
earnings based on a, icr^Vng limi* which is high ciiough
tu b? responsive to moat <vf the credit needs of its
comnninity. The merging hank was organised in 1915
and continues to operate, from nn<« hanking office. This
bank's earning* hxvn hern pmvr, its Icrrding limit is
ver/ lovft and its potential for future growth and improved profitability as an independent bank seems
limited.
There arc five banks located in the general service
area of the merging banks, which includes the rity of
GHIHX. The charter and the merging banks rank third
and fif tli in size, respectively, of this group. The result96

$1, 730, 881
6,911,773

To be
operated
1
1

8, 642, 063

ing bank will be better able to compete with the two
larger Galax banks. While consummation of the
merger will eliminate some competition between the
meiging banks, nevertheless, because of the small sice
of The Farmers Bank of Elk Occk, this bank has not
been a significant competitive factor in Grayson
County. The iirf usiun of sUeugth fiom the alliance wkh
the charter bank, the increased lending limit of the
resulting bank, and the economies to be realised from
a centralization of bookkeeping functions at independence, are expected to produce improved service to
the public, especially in the Elk Creek area.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest, and
the application, therefore, is approved.
JULY 31,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The jHyposed merger involve* the first and third
largest out of three banks in Grayson Ommtf, Va.—an
area uf declining population in thn .vm+hwr.sfcr.m part
uf Virgin!", y.puicvum?rtely 100 rnilfts Mvn+hwrst. of Ros.uuke. Tills j-uedoimnarxtly rural conrrty KM an estimated population of 17,200; and the two small communities of Independence and Elk Creek—10 miles
apart—have populations of 750 and 150, respectively.
The proposed merger would eliminate dfreet earnpetition biJtwuc-n tin; twu bauis—which are 10 mifes
apart with no other banks in the irrtrrverving area. I t
would leave the county with only two banks: in addition, there would be twu banks, both larger, in tKc
adjaceui md^j^ud^uL tily v£ Odlax (popt>lation 5,^00),
and twu odust banks uulsiJc the county bcrt withsn
30 miles of Independence.
The proposed merger would also increase concentration in the area. Grayson National has about 60
percent uf the IPO ikumnd riepcmits in Grayson
Gouiily, anJ the mfrgw with Farmers would add 15
percent to its market share. The shares would be very

much lower, however, if the independent city of Galax
wcic Aau included in the market: Oaysoa National
would have about 17 percent of the IPG demand

the market more accurately, in view of the size of
Galax cuad ite proxiBaiiy to GrayEos Coimty, a primarily
rural area.
ucLJUMts HI tiic L/iOaviCi" v-ijTcivsori v^ovin^v uuituC niuiuCv*
The small size of Farmers and it? -rn*A\iy>r* r*»rnrH
and ihe proposed merger would add about 4 percent
(as indicated by its operating loss in 1966) are likely to
Lu its nidAa aiiaic. \ W belli, vc tl\fift this W/cuAcr rradazA. roduOO tba RStkc«BipC45^'«>SSgKsJfic?"'%» nf rhf*
covering Grayson County and Galax probably states
merger.

HUNTINGTON-VALLEY BANK, HUNTINGTON BEACH, CALIF., AND SOUTHERN CALIFORNIA FIRST NATIONAL BANK,
SAN DIEGO, CALIF**
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Huntington-Valley
and Southern
which had
merged Sept.
The merged

Bank, Huntington Beach, Calif., with
California First National Bank, San Diego, Calif. (3050),
14, 1967, under charter and title of the latter bank (3050).
bank at date of merger had

To be
operated

$10,903,871

439, 458, 735

33
35

450, 362,606

"•The GuuipliuiiciSs opinion a/xd the Attorney Ctaseral's opinion treated thio merger jointly wkh the acquisition
National Bank by Southern California First National Bank. See p. 88.

METROPOLITAN BANK, HOLLYWOOD, LOS ANGELES, CALIF., AND T H E BANK OF CALIFORNIA, N.A.,
SAN FRANCISCO, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Metropolitan Bank, Hollywood, Los Angeles, Calif., with
and The Bank of California, N.A., San Francisco, Calif. (9655), which h a d . . .
merged Sept. 25, 1967, under charter and title of the latter bank (9655). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On June 19, 1967, the Metropolitan Bank, Hollywood, Calif., with IPC deposits of $16 million, and
The Bank of California, N.A., San Francisco, Calif.,
with IPC deposits of $964.6 million, applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Bank of California was established on July 5,
1864, in San Francisco. It presently operates 64 offices in 42 communities in all sections of California,
except the San Diego area, and is the sixth largest
bank in California. The economy of the State of California is well diversified, and has enjoyed substantial
growth during the past decade. The population of the
State has doubled since 1950 and now exceeds 19 million. California is the leading State in the Nation in

$23,077, 029
1,446,689,151
1,467,444,996

To be
operated

4
65
69

agricultural production, and third in oil production.
The economic growth has been accompanied by similar growth in all major industries including banking.
During the past 5 years, from December 1962 to March
1967, charter bank's deposits have increased $445 million; however, it encounters rigorous competition from
the multitude of financial institutions serving the State
of California.
The merging Metropolitan Bank, established on
December 18, 1959, is headquartered in Los Angeles,
Calif., and operates three branches within 5 miles of
its main office. The primary market area of the merging bank is in Hollywood, situated in the western
portion of the greater metropolitan Los Angeles trade
area. Hollywood, whose population is estimated at
154,000, is closely associated with and depends in

large degree upon the film and television industries.
While the merging bank provides most of the usual
banking services, it does not have a trust department
nor does it provide some of the more sophisticated
services that would be beneficial to its customers. This
bank encounters very aggressive competition from the
Bank of America, National Trust & Savings Association, the Security First National Bank, the CrockerCitizens National Bank, the United California Bank,
the Union Bank, the First Western Bank & Trust Co.,
the United States National Bank, and the City National Bank. In addition, there are 295 savings and
loan association offices, mortgage firms, insurance
agencies, and credit unions, serving Los Angeles
County.
There is little overlap of the service areas of the
subject banks. The nearest branch of the merging bank
is approximately 5 miles from the southern California
headquarters of the charter bank. In view of the minimal amount of common borrowers and depositors, it
is clear that there is no significant amount of competition between the two banks.
The principal new service to be offered by the resulting bank will be a greater lending capacity and more
diversity in the different types of lending programs
and experience available, e.g., automobile installment
loans through dealers, special loan programs for education, doctors, dentists, and credit analyses. In addition to the above, full trust services, a new and simplified service charge program, and many advisory services pertaining to payroll, accounting procedures,
public relations, advertising, and computer services
will be offered by the resulting bank. The merger will
enable the resulting bank to compete more effectively
in the area with the larger banks now operating there
and thus will bring to the residents the full benefits
that flow from aggressive competition.
Applying the statutory criteria, we conclude that the
proposal is in the public interest, and the application is,
therefore, approved.
AUGUST 25,1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Bank of California is a large branch banking organization with 56 offices in California and one each in
Portland, Oreg., and Seattle and Tacoma, Wash. It
is the sixth largest commercial bank in California and
the 32d largest in the Nation. It has at the present time
three offices in Los Angeles, consisting of its main
southern California headquarters in the central business section opened by de novo branching in 1963, and
two branches in Long Beach acquired by merger in
1965. It has approval, acquired as a result of such acquisition, to open an additional branch in Long Beach.
It also has eight branches in the nearby San Bernadino
metropolitan area acquired through merger in 1964.
Metropolitan Bank is a recently organized and
rapidly growing institution in the Hollywood-Beverly
Hills section with four offices located 5-8 miles from
Bank of California's downtown Los Angeles office.
The proposed merger would eliminate some direct
competition between the merging banks, which are
separated by a 5-mile distance within title greater Los
Angeles market. However, within this broader market,
the effects upon concentration are not substantial. In
terms of the entire Los Angeles metropolitan area,
the Bank of California (with about 3.25 percent of
total deposits) is proposing to acquire a bank (Metropolitan) which has only 0.05 percent of the present
market share.
The acquiring bank seems in this case a likely
potential entrant into the narrower market of the bank
with which it seeks to merge. The fact that Bank of
California is actively interested in entering the Hollywood-Beverly Hills area served by Metropolitan is
noted in the application. In view of such interest, there
is considerable likelihood that Bank of California
would enter the area, only 5 miles away from its downtown headquarters, by de novo branching. This
potential competition would, of course, be eliminated
by the proposed merger.

GLEN RIDGE TRUST CO., GLEN RIDGE, N.J., AND NATIONAL NEWARK & ESSEX BANK, NEWARK, N.J.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Glen Ridge Trust Co., Glen Ridge, N.J., with
and National Newark & Essex Bank, Newark, N J . (1316), which had
merged Sept. 29, 1967, under charter and title of the latter bank (1316). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On June 28, 1967, the National Newark & Essex
Bank, Newark, N.J., and the Glen Ridge Trust Co.,
Glen Ridge, N. J., filed an application with the Comptroller of the Currency for permission to merge under
the charter and with the title of the former.
The National Newark & Essex Bank, organized in
1804 and converted into a National bank in 1865, was
the first bank to be established in New Jersey. The
bank now holds IPC deposits of $442.5 million and
operates 29 branches in Essex County, including 10
in Newark. Essex County, the service area of the
charter bank, has a population of approximately 950,000, with an estimated 400,000 people residing in the
city of Newark. Essex County lies in the heavily industrialized northeastern part of New Jersey, within
easy reach of New York City, and is blessed with
excellent transportation facilities, including a large airport and a deepwater port at Port Newark. Manufacturing is the single most important activity, but
substantial numbers of people find employment in
service industries, retail activity, transportation and
government work. The southeastern portion of the
county, in which most of the industry is concentrated,
Is gradually declining in population, while the western,
predominantly residential section, is experiencing rapid
growth. Many of the county residents commute to work
in Newark and in New York City.
The Glen Ridge Trust Co. is a unit bank, chartered
in 1912, with its office located approximately 4.5 miles
from the main office of the charter bank. The merging bank holds IPC deposits of $13.1 million and is
the only commercial bank in Glen Ridge, which is
located in Essex County just northwest of Newark.
It is a residential community with a population of
8,800, most of whom commute to work in nearby
Newark or New York City.
If the merger is approved, little direct competition
will be eliminated, as less than one-half of 1 percent
of the charter bank's checking accounts and install293-544—68-

$15,026,627
566, 382, 592

To be
operated

1
31

581,408,785

ment loans, and less than 1 percent of its savings accounts, come from the Glen Ridge area. Consummation of the merger will not significantly increase the
degree of concentration of banking assets in Essex
County, as the resulting bank will retain the charter
bank's present rank as third in size among commercial
banks in the county, and its share of commercial bank
assets will increase only from 23.2 to 23.8 percent. The
resulting institution will continue to face intensive competition from the larger county banks headquartered in
Newark, including The First National State Bank of
New Jersey, with deposits of $650 million, the Fidelity
Union Trust Co., with deposits of $557 million, and the
Howard Savings Institution, a mutual savings bank
with deposits of $694 million. Additional competition
is felt from the New York City banks, as many commuters find it more convenient to bank where they
work.
Approval of this merger will benefit the public in
Glen Ridge by bringing to them a full-service bank,
with expanded trust services, a larger lending limit,
and more efficient, economical service through computer servicing of accounts. Management continuity
will be assured through the recruitment program of the
charter bank. Residents who work in Essex County
outside the Glen Ridge area will have branch offices
of their bank readily available to them.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest, and
the application, therefore, is approved.
AUGUST 30,1967.
SUMMARY O F REPORT BY ATTORNEY GENERAL

National Newark, with total deposits of $491.4 million and 24 offices, is the third largest bank in Essex
County. Glen Ridge Trust has total deposits of $13.7
million. Its single office is located in Glen Ridge, a
community about 4.5 miles from downtown Newark.
National Newark and Glen Ridge Trust both operate
within Essex County. But whereas National Newark's
services are readily accessible throughout most of the

county, including the communities surrounding Glen
Ridge, it would appear that the business of Glen Ridge
Trust is derived mainly from Glen Ridge and the
immediately adjacent area.
National Newark has six offices or drive-in facilities
located 0.5-1.4 miles from the office of Glen Ridge
Trust, in the nearby communities of Bloomfield and
Montclair. Therefore, it seems clear that the proposed
merger would eliminate a substantial amount of direct
competition between the merging banks.
Commercial banking in Essex County as well as in
Newark is highly concentrated. There are 18 banks
located in Essex County having a total of 113 offices
(including drive-in facilities). Three Newark banks—
National Newark, Fidelity Union Trust Co., and First
National State Bank—account for most of the county's
banking business, holding 23.6,26.8, and 31.25 percent,
respectively, of total deposits of all county banks. The
three banks together hold 81.6 percent of the total
deposits of all county banks and approximately 95 percent of the deposits of banks in Newark. They operate

74 of the county's 113 banking offices. The next largest
county bank, Montclair National Bank & Trust Co.,
has assets of $135.8 million and holds 5.7 percent of
deposits of county banks. Thus, four banks account for
87.3 percent of the market, and the 14 smaller ones
vie for the remaining 12.7 percent. In such a highly
concentrated market, Glen Ridge Trust's 0.65 percent
share assumes more importance than it would in a
more fragmented setting.
The merger would eliminate existing competition
between National Newark and Glen Ridge Trust. In
addition, commercial banking in Newark and throughout Essex County is highly concentrated in the hands
of National Newark and two other Newark banks.
This concentration is largely the result of several mergers and acquisitions made by these banks in the 1950's.
The proposed merger will add to this concentration
and will eliminate a well established and growing independent institution. Therefore, we conclude that the
proposed merger would have a significant adverse
effect on banking competition in Essex County.

MERCHANTS & FARMERS BANK, OWENSVILLE, OHIO, AND CLERMONT NATIONAL BANK, MILFORD, OHIO
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Merchants & Farmers Bank, Owensville, Ohio, with
was purchased Sept. 30, 1967, by Clermont National Bank, Milford, Ohio
(3234), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On April 10, 1967, the Clermont National Bank,
Milford, Ohio, with IPC deposits of $18.8 million, filed an application to purchase the assets and
assume the liabilities of the Merchants & Farmers Bank,
Owensville, Ohio, with IPC deposits of $1.6 million.
The purchasing bank was organized in 1884 and
has its main office in Milford, a town of 4,000 located
in Clermont County. The bank also operates five
branches throughout Clermont County. The city of
Cincinnati, in Hamilton County, adjoins Clermont
County on the west. The service area of the participating banks is predominately residential, containing
many inhabitants who commute to work in Cincinnati.
There are some agricultural areas remaining in Clermont County and a considerable amount of light industry and commerce exists in the eastern portion of

100

To be
operated

$2,112,678

23, 521, 948
25,634,626

Hamilton County, which also lies within the service
area of the purchasing bank. Clermont County has
experienced rapid growth in recent years, nearly doubling in population in one decade to reach approximately 80,000 in 1960. The growth of the purchasing
bank during the past few years has been exceptional,
in keeping with that of its community.
The selling bank was organized in 1909 and operates as a unit bank in Owensville, a village with a
population of 700, located 10 miles east of Milford in
Clermont County. This bank has not shared in the general economic expansion of the area and is especially
handicapped by its lending limit of $17,500, which is
not responsive to the credit needs of its community.
Because of its limited resources, this bank has found
it difficult to acquire needed equipment, to undertake
expansion of its physical plant, and to attract
competent management.

There is no significant competition between the
participating banks. The small size of the selling bank
necessarily limits the amount of competition that
it can offer to the purchasing bank. There is, however,
intense competition in this area deriving from banks
located in the eastern part of Hamilton County, and
from Cincinnati banks which have branches placed
within a few miles of the offices of the participating
banks. Thus, while approval of this application will
eliminate one independent source of retail banking
facilities and increase slightly the degree of concentration of banking assets in Clermont County, the overall
effect of the transaction will be to intensify banking
competition, especially in the Owensville area. The
resulting institution will be better able to compete for
business of the commuting population who have available a broad choice of alternative financial institutions
in downtown Cincinnati and in the suburban branches.
Approval of this transaction will benefit the Owensville community by making available a broader range
of banking services and an expanded lending limit.
Management continuity will be provided by the recruiting and training programs of the purchasing bank,
while the availability of electronic data processing
equipment will provide better service to the public
at a lower cost. In addition, the transaction will enable the selling bank to accomplish a needed expansion
of quarters.
Applying the statutory criteria to this proposal, we
find that it is in the public interest, and the application,
therefore, is approved.
JULY 3,1967.
SUMMARY OP REPORT BY ATTORNEY GENERAL

The Clermont National Bank ("Clermont Bank")
proposes to purchase the assets and assume the liabilities of Merchants & Farmers Bank ("Merchants &
Farmers"). These are two of the five banks in Cler-

FIRST NATIONAL BANK

mont County, Ohio, which is predominantly residential and has experienced a large increase in population
during the past 10 years. It is part of the CincinnatiKentucky-Indiana Standard Metropolitan Area.
The proposed merger would eliminate direct competition between the two banks. Their head offices are
12 miles apart, and Merchants & Farmers sole office is
7 miles from Clermont Bank's closest branch. The application states that Merchants & Farmers operates in
a relatively small area around Owensville; however,
Clermont Bank, which operates throughout the
county, receives a substantial number of loan requests
from Owensville and derives some deposits from this
area.
Clermont Bank is the largest banking institution in
Clermont County—with six of the county's 11 banking offices and about 73 percent of its IPC demand
deposits. The proposed merger with Merchants &
Farmers would add one additional office and about 5
percent in IPC demand deposits to these totals.
The foregoing figures may overstate the degree of
market power involved, in view of the proximity of
western Clermont County to the city of Cincinnati, in
adjoining Hamilton County. The merging institutions
account for less than 2 percent of the IPC demand
deposits of the entire Cincinnati-Kentucky-Indiana
Standard Metropolitan Area.
This suggests that the merger is likely to have somewhat varied effects on competition, depending on the
particular class of customers involved. Smaller Clermont County business borrowers, whose markets tend
to be restricted to the local area, would therefore tend
to find their borrowing alternatives significantly restricted by the merger. On the other hand, commuters
and borrowers seeking installment and mortgage loans
would not appear to be seriously affected, since they
would continue to have access to credit facilities of
banks and other financial institutions in Cincinnati.

& TRUST CO. OF ELIZABETHTOWN, ELIZABETHTOWN, PA., AND T H E HARRISBURG
NATIONAL BANK & TRUST CO., HARRISBURG, PA.
Banking offices

Name of bank and type of transaction

Total assets
To be
operated

In
operation
First National Bank & Trust Co. of Elizabethtown, Elizabethtown, Pa. (3335),
with
and The Harrisburg National Bank & Trust Co., Harrisburg, Pa. (580),
which had..
merged Oct. 2, 1967, under charter and title of the latter bank (580). The
merged bank at date of merger had

$13, 307, 439

159, 887, 914

173,195,353

101

COMPTROLLER S DECISION

On June 30, 1967, The Harrisburg National Bank
& Trust Co., Harrisburg, Pa., and the First National
Bank & Trust Go. of Elizabethtown, Elizabethtown,
Pa., filed an application with the Comptroller of the
Currency for permission to merge under the charter
and with the title of the former.
The Harrisburg National Bank & Trust Co.,
founded in 1814 and converted into a National bank
in 1864, holds I PC deposits of $118 million and operates 11 branches in Dauphin, Cumberland, Perry,
and York counties, the four counties which surround
Harrisburg. The head office is located in Harrisburg,
which is the State capital and which has a population of 80,000. The trade area of the charter bank includes a population estimated at 500,000, and a
widely diversified economy ranging from heavy and
light industry to agriculture. Some of the major steel
companies and other manufacturing concerns of local
and national stature have plants located in this area.
Distribution and transportation industries are major
employers, owing to the highly developed highway system of south-central Pennsylvania. In addition, the
Federal Government, with military installations at
Middletown, Mechanicsburg, and New Cumberland,
and the State government at Harrisburg, employ
thousands of people.
The First National Bank & Trust Go. of Elizabethtown was chartered in 1885 and remains a unit operation, holding I PC deposits of approximately $11.2
million. Elizabethtown, with a population estimated
at 7,500, is located in northwestern Lancaster County,
approximately 18 miles to the southeast of Harrisburg.
The service area of the merging bank has a population
of approximately 20,000 and derives economic support from light industry, agriculture, and service businesses. The Hershey Medical Center, to be located in
the Hershey area in nearby Dauphin County, is expected to benefit the Elizabethtown area in various
ways, including the development of industries related
to the medical center.
The earnings of the merging bank have been below
average, and the bank has been unable to provide electronic data processing equipment and the expanded
trust services which it feels are necessary for more
economical and profitable operation.
Although the service areas of the two banks overlap
slightly, competition between them is insignificant. The
charter bank, which ranks third in size among the 32
banking units in the Harrisburg trade area, is smaller
than both the National Bank & Trust Co. of Central

102

Pennsylvania, headquartered in York, with deposits
of $191 million, and the Dauphin Deposit Trust Co.
of Harrisburg, with deposits of $168 million. Consummation of the merger will not change this competitive
relationship as the resulting bank will remain third
in size and hold 10.6 percent of area IPC deposits
and 10.2 percent of area loans. As a branch of the
resulting bank, the bank in Elizabethtown will be able
to compete more effectively with the Lancaster County
branches of such larger regional banks as the National Bank & Trust Co. of Central Pennsylvania,
with deposits of $191 million, the Lancaster County
Farmers National Bank, with deposits of $99 million,
and the Fulton National Bank of Lancaster, with deposits of $77 million.
Approval of the merger will benefit the public,
especially in the Elizabethtown service area, through
expansion of the scope of banking services available
to them. The resulting bank will offer full trust services, a larger lending limit, electronic data processing
services, and dealer financing. Affiliation with the
charter bank will make possible an adequate audit
control and will assure management succession in the
future.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest, and
the application is, therefore, approved.
AUGUST 30,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Harrisburg National Bank & Trust Co. ("Harrisburg Bank") is the second largest bank in Dauphin
County, with total deposits of $136,675,000. First National Bank & Trust Co. of Elizabethtown ("Elizabethtown Bank") is a smaller bank in neighboring Lancaster County, with total deposits of $11,627,000.
The head offices of the participating banks are 18
miles apart. The closest branch of Harrisburg Bank
to the sole office of the Elizabethtown Bank is at Middletown in Dauphin County, approximately 7 miles
north of Elizabethtown. There would appear to be
some existing competition between the two banks which
would be eliminated by the proposed merger.
Harrisburg Bank is the fourth largest banking institution in operation within Dauphin and its seven
contiguous counties. Larger banks in the order of their
size are: (1) American Bank & Trust Co. of Pennsylvania, (2) National Bank & Trust Co. of Central
Pennsylvania, and (3) Dauphin Deposit Trust Co. All
are headquartered outside Lancaster County and have
expanded into that county in recent years. This pro-

posed merger would represent the Harrisburg Bank's
initial entry into Lancaster County.
In view of the recent geographic expansion by
Harrisburg Bank and the other large banks in central

THE

Pennsylvania, it appears that the Harrisburg Bank
would be a likely entrant into Lancaster County by
means of de novo branching. This potential competition would be eliminated by the proposed merger.

FIRST NATIONAL BANK OF MIAMI, MIAMI, FLA., AND NEW NATIONAL BANK OF MIAMI, MIAMI, FLA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Miami, Miami, Fla. (6370), with
and New National Bank of Miami, Miami, Fla. (15638), which had
merged Oct. 2, 1967, under charter of the latter bank (15638) and with title
"The First National Bank of Miami." The merged bank at date of merger
had

COMPTROLLER S DECISION

On July 12, 1967, The First National Bank of
Miami, Miami, Fla., with IPC deposits of $349 million, filed an application for permission to merge with
the New National Bank of Miami (organizing), Miami, Fla., under the title of the former and the charter
of the latter. The subject application is an integral
part of a proposal embodied in the application filed
with the Board of Governors of the Federal Reserve
System on July 11, 1967, by Southeast Bancorporation,
Inc., Miami, Fla., under the Bank Holding Company
Act of 1956, as amended, for prior approval of its
plan to acquire all of the voting stock, except for directors' qualifying shares, of the New National Bank
of Miami (organizing), Miami, Fla.; Coral Way National Bank, Miami, Fla., and Curtiss National Bank
of Miami Springs, Miami Springs, Fla. In order to
transfer stock ownership of The First National Bank of
Miami to the bank holding company, a new National
bank, with the title "New National Bank of Miami,"
Miami, Fla., was organized with the preliminary approval of the Comptroller of the Currency.
The new charter bank will not open banking facilities until the instant proposal is approved by the Board
of Governors of the Federal Reserve System, at which
time it will take over the banking operations of the
existing First National Bank of Miami, Miami, Fla.,
and continue without interruption the banking services

$558,019,116
350, 000

To be
operated

558,019,116

now being offered. Since the new charter bank is presently a nonoperating bank, the merger will have no
effect on competition. However, the approval to be
granted herein is conditioned upon all requisite shareholder action being taken and upon receipt of approval by the Federal Reserve Board for Southeast
Bancorporation, Inc., to become a registered bank
holding company.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application, as conditioned above, is therefore
approved.
AUGUST 30,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The New National Bank of Miami is a newly organized and chartered bank which has not yet engaged in any banking operations. Accordingly, the
proposed merger, standing alone, would have no effect
on competition.
We understand, however, that the subject application is an integral part of a proposal by Southeast
Bancorporation, Inc., to acquire substantially all the
voting stock of the New National Bank of Miami,
Coral Way National Bank, and Curtiss National Bank.
We have not considered in this report the possible
competitive effects of this proposal.

103

HERITAGE-WILSHIRE NATIONAL BANK, LOS ANGELES, CALIF., AND SOUTHERN CALIFORNIA FIRST NATIONAL
BANK, SAN DIEGO, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

operation
Heritage-WUshire National Bank, Los Angeles, Calif. (15463), with
and Southern California First National Bank, San Diego, Calif. (3050), which
had
merged Oct. 5, 1967, under charter and title of the latter bank (3050). The

$18, 650, 581

447, 017,083

465, 667, 663

COMPTROLLER'S DECISION

On July 20, 1967, the Southern California First National Bank, San Diego, Calif., and the Heritage-Wilshire National Bank, Los Angeles, Calif., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
The charter institution, with IPC deposits of $312
million, operates 33 offices in San Diego County. It has
been able to grow and to retain its relative position in
the area banking structure even though faced with the
very aggressive competition of considerably larger statewide institutions. Recently, this bank merged with two
small banks with offices in Orange County in an effort
to strengthen its competitive position and to resist takeover attempts by institutions not yet represented in San
Diego County. This application represents the initial
entry into Los Angeles County by the charter bank.
The merging bank, with IPC deposits of $11.8 million, operates three offices in Los Angeles and has received approval for a fourth office. The immediate
area served by the merging bank is primarily residential
in nature, although commercial activity is present and
appears to be rapidly expanding.
San Diego County on the Pacific Coast, with a population of 1,200,000, is the second most populous county
in California. The principal factors of its economy are
manufacturing (primarily defense and space), military
payrolls, tourism, and agriculture. In addition, investments in institutions of higher learning and research
facilities are growing rapidly. While this county has
experienced an economic slowdown over the past 6
years because of a cutback in this Nation's space program and to overbuilding in the construction industry, indicators now point to a resumption of the economic growth of the county.
Orange County, where the charter bank recently obtained representation, is the third largest county in
population in California and has been the most rapidly
104

growing large county in the Nation. Manufacturing,
tourism, mineral production, and agriculture provide
the economic base in this county. It is predicted that
Orange County will double in population by 1980.
Entry by the charter bank into this area will enhance
banking competition and constitutes a logical move by
applicant in developing a regional banking system.
Los Angeles County, with a population of approximately 7 million, is the third largest county in the Nation. Manufacturing, agriculture, and mineral production provide the basis of its economy. Projections for
the future indicate continued growth for this county
in both population and income. The merging bank
is located in the western portion of the Los Angeles
County, an area primarily residential in nature in
which commercial activity is rapidly expanding.
Southern California First National Bank currently
competes with all the major California branch banking systems in the southern half of the State and with
all of the small independent systems and unit banks in
San Diego County. Heritage-Wilshire National Bank
is in direct competition with 38 branches of 12 California banks including five of the six largest banks in
the State. Among its chief competitors are numerous
large savings and loan associations, credit unions, sales
finance companies, and insurance companies.
The merging banks do not compete with each other.
The nearest branch of the Southern California First
National Bank to the Heritage-Wilshire National Bank
is approximately 40 miles to the south in Orange
County. Consequently, consummation of the proposed
merger will not lessen competition between them.
Moreover, it does not appear to be practical for the
bank to locate branches in this area through the establishment of de novo branches, since the availability of
adequate locations is severely limited and the cost
would be prohibitive. Indeed, the presence of the
Southern California First National Bank will create
an increase in competition among the larger banks in

the western Los Angeles County marketing area while
not unduly increasing its market share of banking
business.
Consummation of this proposal will benefit the
public interest by bringing to the residents of the area
now served by the merging bank another institution
with a larger lending capacity and extensive range of
banking services not presently offered by the merging
bank. These services include a well experienced trust
division, a management training program and a more
sophisticated lending program based upon the credit
analysis division, the credit collection division, and an
internal independent auditing staff.
Applying the statutory criteria to this proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
AUGUST 30,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

First National, a major southern California branch
bank system located in San Diego, proposes to acquire
Heritage-Wilshire, a recently established bank operating in the western part of Los Angeles County.
According to the application, the main offices of the
two banks are approximately 130 miles apart and their
closest existing branches approximately 95 miles from
each other. However, upon consummation of First
National's two Orange County acquisitions, then its
closest brandies would be some 40 and 45 miles dietant
from Heritage-Wilshire. Even on these facts, the
amount of direct competition between First National
and Heritage-Wilshire would be slight, if any.
First National's present operations are confined to
San Diego County—where it is a major factor in the
local banking market. It has about 22 percent of the
banking offices and 25 percent of the IPC demand deposits in the county; it appears to be the largest bank
with its head office in San Diego, and the second largest
bank in terms of total operations in San Diego County.
In addition, upon consummation of its two Orange
County acquisitions, First National will also have become at least a minor factor in Orange County—with

four offices accounting for less than 2 percent of that
county's IPC demand deposits.
First National is proposing to acquire a bank which
is a very small factor in the much larger Los Angeles
market. Heritage-Wilshire accounts for only 0.1 percent of IPC demand deposits among all banks in
Los Angeles County. (We believe a more appropriate geographic market would undoubtedly be smaller
than Los Angeles County in view of the sprawling
nature of the whole Los Angeles community and the
local nature of Heritage-Wilshire's operations; however, it is not possible to derive any market share within
the Westwood Village, Brentwood, and Bel-Air sections from which the bank actually appears to derive
the bulk of its business,) Los Angeles County is, of
course, a highly concentrated market, with 81.5 percent of all deposits being held by the five largest statewide and regional branch bank networks operating
there.
That First National is interested in expanding into
the economically promising areas north of San Diego
County is apparent from its submission, within a short
space of time, of applications to acquire two banks in
Orange County and now one bank in Los Angeles
County. All three acquisitions involve recently established banks, with promising growth opportunities.
Under these circumstances there is every reasonable
expectation that First National is a likely potential
entrant into the Los Angdcs area by de novo branching, as permitted by California law.
First National's acquisition of Heritage-Wilshire
might therefore involve some loss of potential competition within Los Angeles County, because First
National would be eliminated as an independent entrant into that market by de novo branching. However, in view of the very small market share First
National would be acquiring by merger with HeritageWilshire, and the existing strong banks with which
it would be competing, we find the merger unlikely
to affect significantly the level of competition within
the Los Angeles market

105

SECURITY NATIONAL BANK OF CONTRA COSTA, WALNUT CREEK, CALIF., AND FIRST NATIONAL BANK OF OAKLAND,
OAKLAND, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Security National Bank of Contra Costa, Walnut Creek, Calif. (15092), with
and First National Bank of Oakland, Oakland, Calif. (15180), which had
merged Oct. 9, 1967, under charter of the latter bank (15180) and with title
"Security National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

Oakland, the third largest city in California with
a population of 385,700, is a major West Coast trade
center. The city's heavy industrialization includes
manufacturing, warehousing, and extensive shipping
along its 19-mile waterfront.
Walnut Creek, located 30 miles northeast of San
Francisco and 15 miles northeast of Oakland, is a
primarily residential community with a population
of 24,000. Most local workers commute to the Oakland-San Francisco area for employment.
First National Bank of Oakland, with deposits of
$16.9 million, is a unit bank which was opened for
business in October 1963. The charter bank's trade
area, which is confined to a 2-mile radius from its
main office in downtown Oakland, contains 27 offices
of 10 commercial banks with aggregate deposits of
$940 million. With only 1.8 percent of the area's deposits, it appears that the charter bank's competitive
impact has been slight.
Security National Bank of Contra Costa, with deposits of $20.7 million, opened for business in May
1963. Subsequently, it established its only branch facility 19 miles northeast of the main office in an agricultural and industrial area with a market population
of 23,000. Although the merging bank has been aggressive and has demonstrated good deposit growth,
it presently possesses only 8.4 percent of the $225 million in commercial bank deposits in its main and
branch office service areas.
The 15-mile distance between the merging banks
obviates any competition between them. The number
of common customers, if any, is insignificant.
Consummation of the merger will resolve the capital

106

$26,446,717
22,054, 094

To be
operated
2
1

48,499, 988

inadequacy of the merging bank. The resulting bank,
with a larger lending limit, will be able to compete
more effectively in the highly competitive OaklandWalnut Creek commercial banking market. Moreover, the resulting bank will benefit considerably from
the pooling of the managerial resources of the two
banks.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
SEPTEMBER 8,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The First National Bank of Oakland ("First National") proposes to merge with the Security National
Bank of Contra Costa ("Security"). Both banks were
organized in 1963. Security has one branch in Antioch.
Oakland (which is in Alameda County) is a major
Pacific Coast transportation and trading area. Walnut
Creek is a suburban residential community in adjacent
Contra Costa County. Antioch is located in an industrial area in the northeastern part of Contra Costa
County.
The main offices of both banks are 18 miles apart and
separated by the Oakland-Berkeley Hills. First National competes with 50 offices of 10 banks in metropolitan Oakland. Security competes with 38 offices of
10 banks in Walnut Creek and 9 offices of 6 banks in
Antioch. Each of the banks holds only about 1 percent of the total IPC demand deposits in the twocounty area.
It appears the merger would foreclose little direct
competition between the two banks and would have a
de minimis effect upon concentration in the area.

WESTMINSTER NATIONAL BANK, WESTMINSTER, CALIF., AND COMMERCIAL NATIONAL BANK, BUENA PARK, CALIF.
Banking offices
Name of bank and type of transaction

Total assets

Westminster National Bank, Westminster, Calif. (15412), with
and Commercial National Bank, Buena Park, Calif. (15434), which had
merged Oct. 9, 1967, under charter and title of the latter bank (15434). The
merged bank at date of merger had

COMPTROLLERS

DECISION

On June 6, 1967, the Commercial National Bank,
Buena Park, Calif., and the Westminster National
Bank, Westminster, Calif., applied to the Office of the
Comptroller of the Currency for permission to merge
under the charter and title of the former.
Both merging banks opened in 1964 in communities located in rapidly growing Orange County,
Calif. Since the 1950s, Orange County, due to its ideal
climate and excellent beaches, has experienced steady
conversion of its farm land to residential use, accompanied by an explosive population buildup. Excellent
freeways and other routes have been constructed to
carry residents to work in Los Angeles and Long Beach.
Most of the county communities are residential with
shopping centers the most important commercial
activity. Electronics is the chief industry in Orange
County.
Commercial National Bank is located in Buena Park,
a community 22 miles southeast of Los Angeles and 10
miles northwest of Santa Ana. The population is
62,000, having increased from 5,500 since 1953 when
Buena Park was incorporated. The city is essentially
residential with the usual pattern of scattered shopping
centers. About 2,000 residents now work in local industrial firms and the community has areas reserved
for further industrial development.
Since it opened in 1964, the Commercial National
Bank has established a branch in Anaheim, 7 miles
east of the head office. It has approval to open another
branch in Santa Ana, about 10 miles away. Applicant
bank, with IPC deposits of $4.1 million, holds not
quite 9 percent of the local deposits and loans.
Westminster, about 35 miles southeast of Los Angeles, has a population of 53,000; when the city was
incorporated in 1957, it was 10,800. It also is a residential community with many residents who commute
to work in northwest Orange County and southern
Los Angeles County.
The Westminster National Bank, with IPC deposits

$4, 299, 964
7, 935, 016

In
operation

To be
operated
1
2

12, 234, 980

of $2.7 million, has only 3.5 percent of the deposits and
loans in its area. Its earnings have been poor due to
excessive loan losses and heavy occupancy expenses.
There has been a deficiency of executive management
in the bank.
The head offices of the merging banks are about
6.5 miles apart and the branches of the applicant
bank will be 9-11 miles away from the merging office.
There is little or no competition between the offices
since numerous offices of other banks are located between them. One or more branches of billion-dollar
banks are situated within a mile of all the offices of the
resulting bank. All banks in direct competition with
the subject banks are larger than the resulting bank.
The resultant bank will have about 6 percent of the
deposits and loans in the combined service area, which
has a population of about 335,000. It will also face
competition from nonbank financial institutions which
are active in the area.
More services can be provided by the merged bank
which will enable it to continue the attraction of the
applicant bank for the small household account.
About 90 percent of the deposit structure of both
banks is made up of such accounts and it is in this area
that they can compete most effectively against large
chain banks. The loan portfolios of both banks will
complement each other. The Commercial National
Bank will expand its auto leasing plan to the new office and acquire an escrow department from it. It will
also be able to provide much needed qualified and responsible executive management.
Applying the statutory criteria to the proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
SEPTEMBER 8,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Commercial National Bank ("Commercial")
proposes to merge with the Westminster National Bank
("Westminster"). Both banks were organized in 1964.
107

Commercial has one branch in Anaheim and an approved but unopened branch in Santa Ana. Westminster has been denied permission to open a branch.
The banks are located in primarily residential communities in Orange County, which is an area south of
Los Angeles, undergoing transformation from an agricultural to an industrial based economy.
The main (and closest) offices of Commercial and
Westminster are about 6 miles apart. There are 27
offices of eight banks in the immediate vicinity of Commercial's head office in Buena Park. Westminster competes with 22 offices of eight banks in the environs of
its locale.

The business of each bank consists primarily of individual household accounts and mortgage and commercial and industrial loans. Considering their geographical proximity and the general nature of their
business, it appears that some direct competition between the two banks will be eliminated by the proposed
merger.
On the other hand, Commercial and Westminster
combined hold only about 1 percent of the total IPC
demand deposits within Orange County, the relevant
geographic market for analysis. The effect of this
merger upon banking concentration in Orange County
would, therefore, appear to be slight.

THE FIRST NATIONAL BANK OF BUTTE, BUTTE, MONT., AND DALY NATIONAL BANK OF ANACONDA, ANACONDA,
MONT.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Butte, Butte, Mont. (2566), with
and Daly National Bank of Anaconda, Anaconda, Mont. (15540), which had.
consolidated Oct. 13, 1967, under charter of Daly National Bank of Anaconda
and with title "First National Bank." The consolidated bank at date of
consolidation had

COMPTROLLER'S DECISION

On October 1, 1966, The First National Bank of
Butte, Butte, Mont., and the Daly National Bank
of Anaconda, Anaconda, Mont, applied to the Office
of the Comptroller of the Currency for permission to
consolidate under the charter of the latter and with
the title "First National Bank."
Butte, with a population of 27,500, is the county
seat of Silver Bow County which has a population of
46,000. Mining, with copper and zinc the leading extracts, is the primary source of income. Agriculture
and increasing tourism contribute heavily to the
economy of the area.
Anaconda, with a population of 12,000, is the county
seat of Deer Lodge County which has a population
of 19,000. It is located 25 miles northwest of Butte
in the same mountainous area. Its economy depends
primarily on the mining industry but the county also
contains a substantial number of farms and ranches
averaging over 2,000 acres in size.
The First NatioR^l Ba&k of Butto, with IPC deposits
of $16.2 million, was organized in 1877 as a private
bank and received a National charter in 1881. It does
108

$18, 187,497
11, 708, 987
30, 041,401

To be
operated
1
1
2

not operate any branch offices. Primary competition
is derived from the $44 million Metals Bank & Trust
Co. of Butte, the $11.4 million Miners Bank of
Montana, and the $4.7 million Security Bank of Butte,
all located in Butte. The $186.3 million Prudential
Federal Savings & Loan Association of Salt Lake,
Utah, which operates a branch office in Butte, must
also be considered a strong competitor.
Daly National Bank of Anaconda, with IPC deposits
of $9.9 million, was chartered as a State bank in 1883
and converted to a National bank in 1965. It does not
operate any branch offices. It is a subsidiary of Northwest Bancorporation and is the only bank located in
Anaconda.
The First National Bank of Butte is presently faced
with the problem of providing competent management succession* The present management team is of
advanced years and is contemplating retirement; no
competent succession is available within the present
ranks of the bank's personnel. Aggressive candidates
for managesacsst positions Yacft been discuiuaged due
to the bank's ultraconservative policies and lack of
modern operating procedures.

Loan volume and deposit growth of The First National Bank of Butte reflects its lack of aggressiveness
and is evidence of its weak competitive position in
Silver Bow County. Ranked second in total resources,
it is fourth in loan volume with 22.5 percent of total
deposits represented by loans, as compared to 60.4,
59 and 58.2 percent of the other Butte banks.
About three-fourths of First National's loan volume
is from outside the State. During the last 5 calendar
years it has experienced the smallest deposit growth
of any of the Butte banks.
The present lending policies of the First National
Bank of Butte leave the consumer wholly unserved. It
seldom makes auto loans, home improvement loans^
personal loans, retail consumer loans, and real estate
mortgage loans. All of these factors lead to the conclusion that the First National Bank of Butte is reluctant to serve adequately the needs of the public
and to compete effectively with the other area banks.
Daly National Bank has a competent and energetic
staff, balanced by age, experience, and knowledge of
the area. The volume, diversity, and types of loans offered by this bank indicate service to all classes of the
banking public in its area. Its deposit growth has been
steady and the loan-to-deposit ratio compares favorably to banking industry averages.
Due to their geographical location there is little, if
any, competition between the participating banks. Because Daly is the only bank in Anaconda, effectuation
of the consolidation would not have any adverse competitive effect in the area now served by that bank.
On consummation of this consolidation, the resulting
bank plans to operate the office of the First National
Bank of Butte as a branch. By this means, the resulting
bank will bring to the area a new banking institution
with higher lending limits which will permit the offering of larger credit lines to the community. Home and
installment loans, not now offered by The First National Bank of Butte, will be among the services to be

offered by the resulting bank and will intensify the
competition among the banks located in Butte.
This proposal is not without its opponents who have
challenged the right of the resulting; bank to continue
to operate the office of the Butte bank as a branch.
On November 23, 19665 the Superintendent of Banks
of the State of Montana, the Security Bank and the
Miners Bank of Montana, N.A., filed a complaint
(G.A. No. 1444) in the U.S. District Court for the
District of Montana, Butte Division, against the
Comptroller of the Currency to enjoin the issuance of
a certificate for and the operation of The First National
Bank of Butte. as a branch of the resulting bank after
consummation of the proposal On November 25,
1966, a stipulation was filed in the court whereby
the Comptroller agreed to give plaintiffs 7 days
notice prior to the issuance of the certificate evidencing
his approval. The legal memoranda submitted by the
applicants and prote-stants on the issue presented by
the pending litigation have been considered.
Applying the statutory criteria to this proposal,
which appears to be lawful under Federal and State
statutes, it is concluded that the proposal is in the puhlic interest, and the. application is, therefore, approved.
MARCH 16,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Daly National Bank of Anaconda, Anaconda,
Mont., with assets of $12,416,000, proposed to consolidate with The First National Bank of Butte, Butte,
Mont., with assets of $19,353,000.
The business of the banks, with minor exceptions,
is restricted to their home counties. Apparently no significant competition exists between them.
It is concluded that the proposed consolidation will
not materially alter the competitive situation in either
of the areas served by the applicant banks and will
not have an adverse effect on competition.

THE NATIONAL BANK OF WATERVILLE, WATERVILLE, N.Y., AND T H E ONEIDA NATIONAL BANK & TRUST C O .
OF CENTRAL N E W YORK, UTICA, N.Y.
Banking offices
Name of bank and type of transaction

The National Bank of Waterville, Waterville, N.Y. (1361), with
and The Oneida National Bank & Trust Co. of Central New York, Utica, N.Y.
(1392), which had
merged Oct. 17, 1967, under charter and title of the latter bank (1392). The
merged bank at date of merger had

Total assets
In
operation

To be
operated

$5,626, 571

253, 977, 318

259, 603, 889

109

COMPTROLLERS DECISION

On July 6, 1967, the $219 million The Oneida National Bank & Trust Co. of Central New York, Utica,
N.Y., and the $5 million The National Bank of Waterville, Waterville, N.Y., applied to the Office of the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
The charter bank, organized in 1836, presently operates 21 offices in the Utica-Rome Standard Metropolitan Statistical Area, which is comprised of Oneida
and Herkimer counties. Fourteen of the offices are
located in Oneida County and seven are located in
Herkimer County. The bank, the largest commercial
bank in this two-county area, is a soundly managed
institution, well experienced in branch operations. It
offers a broad range of banking services, including
trust and computer services, which would be made
available to the banking public in Waterville through
the operation of the merging bank as a branch office.
The two aforementioned counties comprise only onethird of New York State's Sixth Banking District and
in this area the bank is the third largest commercial
bank with about 15 percent of total area deposits.
The economy of the Utica-Rome Standard Metropolitan Statistical Area is well diversified between industry and agriculture. There are over 400 industries
located in the area which is one of the leading dairy
farming regions in the State and in the country. Utica,
with a population of about 100,000, is the county seat
and largest city in Oneida County. Two divisions of
General Electrical Corp. are located in Utica along
with other sizable industrial concerns, which play an
important role in the economy of the area. In the field
of agriculture, although dairy farming plays the major
role, poultry and cash crops are also important. Rome,
with a population of approximately 52,000, is about 15
miles west of Utica. Some of the area's major industrial
concerns are located here, including Griffiss Air Force
Base, which is the largest employer in the Upper Mohawk Valley area and one of the most important in
the State. The Oneida County Airport is midway between Utica and Rome and is the home base of Mohawk Airlines, the largest regional airline in the United
States. The Oneida County Industrial Development
Corp. has a plot of 250 acres of land available for
development adjoining the Oneida County Airport,
with another 250 acres to be made available in the
future. The area has also enjoyed excellent population
growth and the outlook for the future is very good.
The merging bank, organized in 1838, is a singleunit bank offering limited services to its small rural
110

community. The bank is presently faced with a serious
management succession problem because its president,
the only active executive officer, has recently resigned.
The bank, because of its limited earning base, is having
difficulty in attracting new and competent management. Due to its limited lending capabilities, the bank
has been unable to adequately provide for the credit
needs of its community. Its number of farm loans has
declined even though the bank is located in a generally prosperous agricultural area. Earnings have also
suffered.
Waterville, with a population of about 1,900, is a
village located in the southwest corner of Oneida
County and approximately 16 miles from Utica. It is
a small country community situated in an excellent
agricultural area. There are a number of small businesses and retail stores located in or near Waterville.
The main industry in the community is the Waterville
Knitting Mill, Inc., a division of Barclay Knitwear,
Inc., of New York City. As the average capital investment in dairy farms in this area is usually large, and
the National Bank of Waterville cannot provide the
resulting credit needs, the farmers are forced to seek
credit from other lending institutions located elsewhere. Moreover, the credit needs of area farmers are
going to become increasingly greater as more farms and
farm operations are mechanized and as the size of
farm operations grows.
Competition in the two-county area is provided by
other commercial banks and particularly by the $148
million Marine Midland Trust Co. of the Mohawk
Valley, Utica, N.Y., operating 11 branch offices, which
is a subsidiary of the Marine Midland Corp., the third
largest bank holding company in the country. Mutual
savings banks in the area, particularly the $195 million
Savings Bank of Utica, strongly compete for both
savings deposits and mortgage loans. Intensive competition for the savings dollar is also provided by the
many savings and loan associations, credit unions, sales
finance companies, and personal loan companies operating in the area.
The addition of $5 million in assets to the charter
bank will have no competitive effect upon other financial institutions. Although the service areas of the
two participating banks overlap, there is no effective
competition between them due to the difference in
size and the type of services provided. The merging
bank offers very restricted services and, with its limited banking capability, is unable to provide adequately
for the credit needs of its community. The branch of
the charter bank closest to the merging bank is in
Sauquiot, 9 miles to the northeast. Other commercial

banks near to Waterville are the First Trust & Deposit
Co. in Oriskany Falls, approximately 4 miles west,
and the Hayes National Bank in Clinton, about 11
miles north.
Consummation of this merger, in addition to solving
the management succession problem in the merging
bank, will provide Waterville with a bank better able
to serve the needs and conveniences of the community. The greater lending limit and more extensive
range of banking services to be made conveniently
available to Waterville residents is clearly in the public
interest.
Considered in the light of the statutory criteria, this
merger is judged to be in the public interest and is,
therefore, approved.
SEPTEMBER 14,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Oneida National Bank & Trust Co. of Central
New York, Utica, Oneida County, N.Y., proposes to
merge the National Bank of Waterville, Waterville,
Oneida County, N.Y.
The level of concentration in the Oneida-Herkimer

County market is high, with Oneida Bank and its next
largest competitor controlling about 83 percent of total
area deposits and loans.
The merger or acquisition of 11 banks in this twocounty area by Oneida Bank (9) and Marine Midland
Trust Co. of the Mohawk Valley (2) over the past
12 years has contributed significantly to the present
high level of concentration in the area. The planned
consolidation of Waterville with Oneida Bank would
further increase such concentration, although the percentage increase would not be large. Expressed in
terms of IPC demand deposits within the two-county
area, the market share of Oneida Bank would increase
from 55^2 to about 57 percent as a result of the proposed merger.
Waterville Bank's single office is situated within 9-12
miles of three of Oneida Bank's 20 branch offices,
which are located in both Oneida and Herkimer
counties. There is undoubtedly some existing competition between these offices of the two banks which
would be eliminated by the proposed merger, although
each bank specializes in somewhat different types of
loan business.

AUDUBON NATIONAL BANK, AUDUBON, N.J., AND HADDONFIELD NATIONAL BANK, HADDONFIELD, N.J.
Banking offices
Total assets

Name of bank and type of transaction

Audubon National Bank, Audubon, N J . (11446), with
and Haddonfield National Bank, Haddonfield, N.J. (14457), which had
merged Oct. 20, 1967, under charter of the latter bank (14457) and with title
"Colonial National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On July 17, 1967, the $65 million Haddonfield National Bank, Haddonfield, N.J., and the $19 million
Audubon National Bank, Audubon, N.J., applied to
the Office of the Comptroller of the Currency for permission to merge under the charter of the former and
with the title of "Colonial National Bank."
Both banks are located in Camden County, which
is part of the large Philadelphia-Camden metropolitan
district. The communities of Haddonfield and Audubon in Camden County, where the participating banks
are located, adjoin each other and are segments of the
suburban area surrounding the city of Camden. These
areas have been historically and economically linked

Tro be
opeated

In
operation
$19, 733, 636
67,316,202
87, 049, 838

1
5
6

to each other. For many years, the county was mostly
undeveloped, with primary reliance on agriculture.
However, agriculture has been on the decline over the
years as industrial development took place along the
Delaware River, with Camden and Philadelphia at the
center of this growth. The major industries in the
county are food packaging, electronics, shipbuilding,
transport equipment, fabricated metal products,
chemicals, and paper. In this wide range of economic
growth, residential development has been the fastest
growing activity and has followed the population shift
to the suburbs, which has been experienced in the
county since World War II. Contributing to the progress of this area and to southern New Jersey as a whole
is the mass transit development now underway.
Ill

Haddonfield, with a population of about 13,000, is
entirely residential, with a fine retail shopping area.
The population of Haddonfield has increased by less
than 500 in the last 10 years. Since the new high-speed
rail line from southern New Jersey to Philadelphia will
have one of its major stops in Haddonfield, it is expected that the area will share in the anticipated
growth of business activities to result from the mass
transit development.
The charter bank, organized in 1942, presently operates five offices. It ranks third in size among the
commercial banks located in Camden County, with 9.6
percent of total deposits and 8 percent of total loans.
The bank, which is almost completely automated and
effectively departmentalized, offers a complete line of
banking services, including trust services. It makes all
types of mortgage loans, including FHA and VA
guaranteed loans, as well as college tuition loans under the New Jersey Higher Education Financing
Plan—a type of loan not made by the merging institution. The bank, which has pioneered in a number of
customer bank services, is community oriented and
participates in many civic activities. The bank has a
good management-training program and a full-time
auditing staff, both of which are lacking at the merging bank.
Audubon, with a population of about 10,000, is
almost completely residential. While it has the usual
business and service facilities of a suburban community, they are not as extensive as those in Haddonfield.
The merging bank, organized in 1919, is a singleunit bank offering limited services. It is a relatively
small institution conservatively run. It has done little
to attract new business and does not take part in community activities. The bank has a low loan volume, its
checking accounts are neither numbered nor are its
checks magnetically encoded. Its trust department is
relatively inactive and no attempts have been made to
attract additional business. Although it is a well-managed bank, it will eventually suffer from changing
conditions unless it is able to expand its services to the
community and to increase its lending ability. If it is
to remain independent, it must modernize its facilities
and expand its space which will entail a significant
expense and reduction in profits. The bank presently
ranks seventh in size among the commercial banks
located in Camden County with 2.9 percent of total
deposits and 1.7 percent of total loans. The bank is
also faced with a management succession problem as
its chief executive officer is due to retire. This situation
will be remedied if the banks merge.
Camden County is served by 10 commercial banks
112

with a total of 54 offices. The two largest banks are
the $251 million Camden Trust Co., with 16 offices,
37.9 percent of total deposits and 43.3 percent of total
loans in the county, and the $222 million First Camden
National Bank & Trust Co., with 18 offices, 33.9 percent of total deposits and 33.8 percent of total loans
in the county. The participating banks feel the strong
competition provided by these two large banks, whose
offices are well located throughout the county. Since
most of the residents of Haddonfield and Audubon are
employed in Philadelphia, competition is also provided
by the large banks located there. These banks actively
solicit business in Camden County. Additionally, in
Camden County, there are nine savings and loan associations, 32 credit unions, four sales finance company offices, and 22 offices of personal loan companies
competing for the savings dollar.
Consummation of the proposed merger will have a
minimal effect on overall competition. The resulting
banks, with 12.5 percent of total deposits and 9.7
percent of total loans, will still rank third in size among
the banks in Camden County. It will be, however, in
a better position to compete with the large banks and
to utilize more efficiently the resources of the combined institutions. The increased volume of business
placed in automation will reduce the unit cost to
process items resulting in a more efficient overall
operation.
Although the service areas of the two participating
banks overlap, there is no effective competition between them. The merging bank offers very restricted
services and with its limited lending ability is unable
to attract new business; nor has it actively solicited any.
On the other hand, consummation of this merger, in
addition to solving the management succession problem in the merging bank, will provide Audubon with
a bank better able to serve the needs and convenience
of the community. The greater lending limit and more
extensive range of banking services to be made conveniently available in Audubon is clearly in the public
interest.
Considered in the light of the statutory criteria, this
merger is judged to be in the public interest and is,
therefore, approved.
SEPTEMBER 12,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger would consolidate Haddonfield National Bank with Audubon National Bank, both
in Camden County, N.J.
It is evident that Audubon National and Haddonfield National are direct competitors since their nearest

offices are only 1J-4 miles apart. The proposed merger
would, of course, eliminate this competition.
Within Camden County, the merger would result
in an LiuLCctec ki the market share (expressed in terms
of IPC demand deposits) of Haddonfield National

BANK OF LILLINGTON, LILLINGTON, N.G.,

Bank from 8 to 11 percent, and the bank's market share
would be greater within the narrower HaddonfieldAudubon area. Thus, the merger would further increase cejsocjstration in an ak»ady highly concentrated
area.

AND FIRST NATIONAL BANK OF EASTERN NORTH
JACKSONVILLE, N.C.

Name of bank and type of transaction

CAROLINA,

Total assets
To be
operated

Bank of Lillington, Lillington, N . C , with
and First National Bank of Eastern North Carolina, Jacksonville, N . C
(14676), which had
merged Oct. 20, 1967, under charter and title of the latter bank (14676).
The merged bank at date of merger had
,

COMPTROLLER'S DECISION

On July 19, 1967, the First National Bank of Eastern North Carolina, Jacksonville, N . C , and the Bank
of Lillington, Lillington, N . C , applied to the Office
of the Comptroller of the Currency for permission to
merge under the charter and with the title of the
former.
The First National Bank of Eastern North Carolina
was organized in 1952 in Jacksonville, the county seat
of Onslow County, which is in the southeastern section
of North Carolina. Jacksonville has a population of
19,000, having grown from a population of 3,900 in
1950. The diversified economy around Jacksonville includes Marine Corps operations at Camp Lejeune, agriculture, seafood processing, textiles, and diversified
manufacturing.
The charter bank, which has IPC deposits of $39.6
million, has its head office and three branches in Jacksonville and 17 other branches outside the Jacksonville
area. Sixteen of these branches are in 11 other counties.
Most of the offices, only two of which were acquired
through merger, are in the eastern and central parts
of the State in agricultural communities with populations of less than 5,000. Since 1962 the First National
Bank of Eastern North Carolina has more than tripled
the size of its resources, deposits, and loans.
The Bank of Lillington was organized in 1903 in
LillingLun, a community in the center of thr. State and
105 miles northwest of Jacksonville. Lillington, with a
population of 1,242, and the county seat of Harnett
County, is devoted principally to agriculture with flue-

$3, 908, 384
66, 862, 921
70, 771, 305

cured tobacco, corn, small grains, truck crops, and livestock as the principal products. Though Lillington itself has no industry, there is some industrial activity
elsewhere in the county.
The Bank of Lillington, with IPC deposits of $2.7
million, is a unit bank. The only other banking office
in Lillington is a branch of Southern National Bank
of North Carolina, Lumberton, N.C. The Bank of
Lillington also competes directly with branches of two
other large banks. The resources and deposits of the
merging bank have declined since 1952. This problem
has been coupled with a lack of continuity of management which was recently aggravated by the death of
its chief executive officer.
The First National Bank of Eastern North Carolina
has a branch in Dunn, which, though located in Harnett County, is 18 miles from Lillington. This branch
competes with the merging bank only for public deposits of the county. The degree of competition between the banks is otherwise limited because of the
distances separating them and the availability of several other banks in the intervening area. Clearly the
merger will have no appreciable effect on competition in the entire trade area. The resultant bank, with
only 1.5 percent of the deposits and loans in the entire trade area, will have a smaller percentage of the
total deposits and loans in the county than two other
larger banks. It will also face significant competition
from savings and loan association? and other financial
institutions in the county.
Since the economy is expanding in Harnett County,
the resulting bank can better serve the commercial

113

and agricultural needs of Lillington, with its larger
lending limit, and with the influence of a capable and
aggressive management.
Applying the statutory criteria to the proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
SEPTEMBER 20,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The First National Bank of Eastern North Carolina
("First National") proposes to merge with the Bank
of Lillington, Lillington, N.G.
The Lillington area still is principally devoted to
agriculture—including flue-cured tobacco, corn, small
grain, truck crops, and livestock. Lillington (population, 1,242) is the county seat of Harnett County
(population, 48,236), a county with six banks and 10
banking offices located in the central section of the
State.

First National maintains a branch at Dunn in Harnett County, 18 miles from Bank of Lillington. According to the application, the Dunn branch holds $2.7
million of total deposits and competes with Bank of
Lillington for public deposits by the county. Otherwise,
the degree of competition between these banks is apparently limited because of the distances involved and
the availability of several banks in the intervening
areas. Thus, the proposed merger would eliminate a
very small independent bank, which has recently suffered from some management and financial problems,
and which only competes with the acquiring bank to a
limited degree.
The proposed merger would involve a significant
increase in banking concentration in Karnett County.
First National's Dunn branch accounts for about 12
percent of the county's total deposits and Bank of
Lillington accounts for about 13 percent.

FIRST NATIONAL BANK OF MONTESANO, MONTESANO, WASH., AND NATIONAL BANK OF WASHINGTON, TACOMA,
WASH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank in Montesano, Montesano, Wash. (5472), with
National Bank of Washington, Tacoma, Wash. (3417), which had
merged Oct. 20, 1967, under charter and title of the latter bank (3417). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On July 17, 1967, the First National Bank of Montesano, Montesano, Wash., with IPC deposits of $1.6
million, and the National Bank of Washington,
Tacoma, Wash., with IPC deposits of $102.4 million,
applied to the Comptroller of the Currency to merge
under the charter and with the title of the latter.
Montesano, with an estimated population of 2,660
is located on the Olympic peninsula, approximately 70
miles southwest of Tacoma, Wash. The economy of
the area is based chiefly on lumber and lumber
products.
Tacoma, the third largest city in Washington, with
a population in excess of 150,000, is located on Puget
Sound about 33 miles south of Seattle. Traditionally
its economic base has been derived from the forest
products industry but more recently has been expanded
1.1.4

$6, 273, 796
369, 156, 153
375, 397, 696

To be
operated

1
39
40

to include food processing and various manufacturing
industries.
The National Bank of Washington, a statewide system, has 40 branches. Its nearest office to the First
National Bank of Montesano is located in Hoquiam,
14 miles west of Montesano.
The principal competition to the charter bank is provided by the three largest banks in the State, each of
which operates a statewide branching system; the
Seattle-First National Bank, with $1,650 million in
assets, the National Bank of Commerce of Seattle, with
$898 million in assets, and the Peoples National Bank
of Washington, with $363 million in assets. While there
would be a slight increase in the level of banking concentration in the State of Washington as a result of this
merger, the overall effect on banking concentration
would be minimal.

Competition in the service area of the merging bank
is provided by a branch in Montesano of the National
Bank of Seattle as well as by two other branches of
this bank within a 10-mile radius. Also providing competition are a branch of the Seattle-First National
Bank located within a 10-mile radius and a branch
office of the Capital Savings & Loan Association,
Olympia, Wash., with branch office deposits of $1.2
million. Since there are virtually no common depositors
or borrowers, consummation of the proposed merger
will result in only n minimal lessening of competition.
The lending capacity of the resulting bank will enable it to be more responsive to the credit needs of the
Montesano area, which the merging bank is presently
unable to meet. In addition, the people of the Montesano area will benefit from the charter bank's trust
department, investment department, and data processing facilities. Furthermore, the charter bank will
infuse more dynamic and experienced leadership into
the Montesano office and will provide for management
succession.
Applying the statutory criteria to the proposed
merger, we conclude it is in the public interest, and
the application is, therefore, approved.
SEPTEMBER, 15,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank of Washington ("Tacoma Bank"),
a large branch bank, proposes to acquire First National
Bank in Montesano ("Montesano Bank"), a unit
bank.
The area principally affected by the proposed
merger is Grays Harbor County, which is situated in
the Olympic Peninsula approximately 70 miles west of
Tacoma, where Tacoma Bank's head office is located.

Montesano (population 2,468), where Montesano
Bank has its only office, is the county seat of Grays
Harbor County. The county has a population of
56,990—with the largest centers being Aberdeen (population 18,741) and Hoquiam (population 10,762),
two adjoining communities approximately 10 and 14
miles from Montesano. The county's principal industry
is forestry and wood products, but agriculture is important also.
Six banks operate 10 offices in Grays Harbor County.
These include three large Seattle-based banks. In Montesano there are two banking offices: Montesano Bank's
sole office and a branch of the State's largest bank, National Bank of Commerce. Thus the proposed merger
would eliminate the only remaining independent bank
in Montesano.
Tacoma Bank has a branch (acquired by merger
in December 1966) located in Hoquiam, 14 miles west
of Montesano; this is one of the two banks in Hoquiam.
The amount of direct competition between it and Montesano Bank may well be somewhat limited in view of
the distance and the presence of Aberdeen (with two
banks) in between Hoquiam and Montesano.
The proposed merger would significantly increase
the concentration of banking resources in Grays Harbor County. Tacoma Bank's Hoquiam branch accounts
for about 8 percent of both total deposits and IPC
demand deposits in the county. Acquisition of Montesano Bank would increase Tacoma Bank's share of total
deposits by about 8 percent and IPC demand deposits
by about 6 percent.
In summary, the proposed merger, involving the
State's fourth largest bank, would eliminate some
direct competition between the merging banks and
would significantly increase banking concentration in
Grays Harbor County.

FARMERS BANK OF SIMPSONVILLE, SIMPSONVILLE, S.C., AND T H E PEOPLES NATIONAL BANK OF GREENVILLE,
GREENVILLE, S.C.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Farmers Bank of Simpsonville, Simpsonville, S.C, with
and The Peoples National Bank, Greenville, S.C. (10635), which had
merged Oct. 21, 1967, under charter and title of the latter bank (10635). The
merged bank at date of merger had

$4, 643, 493
67,975,417
71,943,098

To be
operated
2
11
13

115

COMPTROLLER'S DECISION

On July 24, 1967, the Farmers Bank of Simpsonville, Simpsonville, S.G., with IPC deposits of $3.3
million, and The Peoples National Bank of Greenville,
Greenville, S.C., with IPC deposits of $48.1 million,
applied to the Comptroller of the Currency for permission to merge under the charter and with the title
of the latter.
Greenville, S.C., home of the charter bank, is the
county seat of Greenville County and the trading and
supply center for the western portion of the State.
The city has a population of approximately 66,188 and
serves a trade area with an estimated population of
140,000. Greenville is the second largest city in the
State and is the leading industrial metropolitan area
with numerous textiles and other diversified manufacturing plants. Unemployment iii the area is low
and there is evidence of a stable and expanding
economy.
The charter bank, which commenced business in
1887, under a State charter, converted tu a National
bank in 1914. It presently operates nine branches. The
bank has been aggressive and alert to its responsibility
to furnish the legitimate credit needs and other banking
services to the people in its area. Competition in this
area is intense and is provided primarily by the Citizens
and Southern National Bank of South Carolina, with
total resources of $227.9 million; the South Carolina
National Bank, with total resources of $446 million;
and the Southern Bank & Trust Co., a State-chartered
institution with resources of $30 million. The city is
now served by four banks with 23 banking offices. In
addition, the competition from savings and loan associations is strong throughout die area. Greenville
is the home of the largest savings and loan association
in the State, Fidelity Federal Savings & Loan Association, with total resources in excess of $70 million.
Simpsonvillnj S H , with a population of approximately 6/)00j is located in the lower pail uf Greenville
County, approximately 7 miles from Greenville, 8 miles
south of Interstate Highway 85 and 5 miles west of
U S . Highway 276. This town serves an immediate
area with a radius of approximately 5 miles and a secondary area with % radiuo of about 8 sales with «ui
estimated population of 11,000.
The merging bank was organized on August 14,
1914, and presently operates one branch. Growth has
been unimpressive and the bank has failed to take advantage of the many new opportunities available in
the expanding local economy. Practically all of the
corporate and industrial business near Simpsonvillc is
116

being served by competing statewide branch banks.
The bank presently encounters vigorous competition
from two branches of the Southern Bank & Trust Co.
and one branch of the South Carolina National Bank.
Since the trade area of the merging bank does not
extend beyond the immediate trade area of Simpsonville and, because the charter bank does not maintain
any offices in that community, there is no competition
which may be affected adversely by consummation
of the proposed merger.
The proposal would provide aggressive and progressive management to the merging bank's area in adequate strength and depth. The convenience and needs
of the people in the Simpsonville area would be better
served by the proposal in that convenient, modern
banking facilities would be provided by the resulting
bank. Larger installment loan services, full trust services, a larger lending limit and in general, more sophisticated banking services will be made available as
a result of this merger.
Applying the statutory criteria, we conclude that the
proposal is in the public interest, and the application
is, therefore, approved.
SEPTEMBER 20,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Peoples National Bank ("Peoples") is the fifth largest commercial bank in terms of deposits, in South
Carolina, and it currently operates 11 offices. Farmers
Bank of Simpsonville ("Farmers") operates its head
office in Simpsonville and has one branch office located
in Mauldin.
Seven commercial banks now compete in Greenville County (an expanding area with a 1966 population of 234,600), with Peoples ranking second in size
and Farmers sixth.
Thr rimrst hranribes of the merging banks (in Mauldin and Greenville) are some 5 miles apait, and their
head offices abwrt 0 miles apart. Sinrpsuiiville and
Mauldin are connected with Greenville by a major
highway; there are no intervening towns. Fur lesideirts
of Simpsonville and Mauldin, Peoples and Fanners
vfwulel appear to represent Altez/ralivc &uiuu» feu iuus»l
commercial bank services. Approval of the proposed
merger would result in the elimination of this direct
competition between the two banks.
Also, 3ince South Carolina law permits statewide
branch banking, the proposed merger would eliminate the possibility of de novo branching by Peoples
into Simpsormlle or Mauldin. Sack branching would

not cause any loss of competitive alternatives in these
expanding banking- markets, in contrast to the proposed merger.
Banking concentration has been rising in Greenville
County, and the number of banking alternatives systematically reduced, through successive continuous acquisitions of small but growing banks. Thus, as of June
30, 1964, 10 banks had offices in Greenville County,
with the largest three banks (including Peoples) holding 77 percent of the total deposits. Now there are
only seven separate banks in the county and the same

three banks hold about 81.5 percent of total county
deposits.
The proposed merger would increase the already
high level of banking concentration within the county
and reduce the number of banks in the county to six.
The merger would also increase Peoples' share of total
county deposits from 27 to 28.9 percent and its share
of IPC demand deposits from 28.8 to 30.6 percent.
We believe, accordingly, that the proposed merger
would have adverse effects upon banking competition
in Greenville County.

CITIZENS BANK OF WILKES-BARRE, WILKES-BARRE, PA., AND MINERS NATIONAL BANK OF WILKES-BARRE,
WILKES-BARRE, PA.
Banking offices
Name of bank and type of transaction

Total assets

Citizens Bank of Wilkes-Barre, Wilkes-Barre, Pa., with
and Miners National Bank of Wilkes-Barre, Wilkes-Barre, Pa. (13852), which
had
merged Oct. 25, 1967, under charter and title of the latter bank (13852). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On April 18, 1967, the Citizens Bank of WilkesBarre, Wilkes-Barre, Pa., with IPC deposits of $5.76
million, and the Miners National Bank of WilkesBarre, Wilkes-Barre, Pa., with IPC deposits of $117.8
million, applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter. A hearing was held on this application in Wilkes-Barre on July 19, 1967.
Wilkes-Barre is located in northeastern Pennsylvania,
approximately 120 miles north-northwest of Philadelphia and about the same distance west of New York
City. The population of Wilkes-Barre, which reached
a high of 86,626 in 1930, has declined to its present
63,000. Together with the city of Scranton, 18 miles
north, Wilkes-Barre is the physical and economic hub
of northeastern Pennsylvania, an area with more than
1 million inhabitants.
Once the anthracite center of the world, the northeastern Pennsylvania area has been in a serious economic decline, which started with the depression in the
1930s, was briefly interrupted by World War II, and
continued until 1960. The anthracite coal industry,
which once provided the major source of employment
in the entire region, has declined due to the competi-

In
operation

$7, 637, 305

157,536,594

165, 183,405

To be
operated

tion of oil and natural gas. As a reminder of coal's
dominance over the area, the entire valley in which
Wilkes-Barre is located was dotted with "culm banks,"
which are small mountains of coal dust, slate, and mine
waste. Though the decline in mine employment was
somewhat offset by the introduction of a large number
of textile and garment factories which utilized female
labor almost exclusively, Wilkes-Barre continued to be
recognized officially as a depressed area with a serious
labor oversupply and substantial unemployment.
Under the aegis of the Greater Wilkes-Barre Chamber of Commerce, several corporations were created to
attract new industry to Wyoming Valley by providing
ready financing. Beginning in 1939, the Wyoming
Valley Industrial Fund, Inc., was the first attempt by
local leaders to cure the area's economic blight. The
Wyoming Valley Industrial Building Fund, Inc., was
chartered in 1940. These two corporations merged in
1953 under the title of the Greater Wilkes-Barre Industrial Fund, Inc. This corporation continues to function today in cooperation with the Pennsylvania Industrial Development Authority, which was established
in 1956. The local Development Fund conducts solicitations every 3 years and, to date, has collected $4.2
million—a public contribution to the financing of new
117

industries. With the cooperation of the larger WilkesBarre and Srrantrm hanks and the Pennsylvania Tndustrial Development Authority, the local Chamber
of Cf/mmerr.e has been ahte to attract to the area such
substantial national firms as Leslie Fay, RCA, Rberhard Fabcr, and Tops, among others. These, firms have
provided the solid employment base that has enabled the area, for the brzt time since the depression,
to look forward and to project an increase in population, jobs and overall economic activity.
After the coal companies sold their culm banks, the
complexion of the area changed. The development
of the northeast extension of the Pennsylvania Turnpike and the announcement of plans for the construction on intersections of two major interstate highways No. 80 and No. 81—made this area of culm
banks commercially valuable. The culm banks were leveled and the land was graded. Within this area are now
industrial plants, several large motels, nightclubs, warehouses, wholesale firms, service companies, and a shopping center which have, in the last 6 years alone,
contributed to an increase in real values of about $11
million. Most of this development is within 1 Va miles
of the Citizens Bank.
Citizens Bank of Wilkes-Barre, which commenced
business in 1910, is, in effect, a family-dominated bank.
Originally located in a low- to medium-income neighborhood in the Parsons section of the city, the bank
functioned for many years as a depository. It is a commercial bank only in regard to a few very small businesses in that area, such as a grocery store, a tavern,
and other similar enterprises. Its type of operation is
graphically demonstrated by the fact that this office,
which is now operating as a branch, is closed at lunchdine for its three employees' convenience.
The owners of Citizens Bank purchased a site in the
culm bank section when the coal companies were selling. In 1956, Citizens Bank opened its Kidder Street
branch at this location; it is adjacent to the shopping
center which is the focal point of the current industrial
expansion. The branch was later converted to the main
office of Citizens. Because of its location, and despite its
undisputed inability to service any of the commercial
enterprises in the area. Citizens' deposits increased from
$3.5 million to $6 million in a 10-ycar period. There
is no evidence in the record, nor docs this Office know
of any fact to indicate that anything other than location and total lack of competition in the area has been
responsible for this growth.
Citizens Bank has a serious management succession
problem. Not a single one of iIs five directors has ever
•been a banker by profession, ami none have H-t.teuijrt.ed
118

to manage a full-service institution which the convenience and needs of the new business, large and
small, located m tliis area require. This board has
served as a. part-time and unpaid officei staff of the
bank. Its top-paid officer and only full-time ewciitiva
is the cashier; a lady who is expected to handle all operational details, no matter how small, 52 weeks of the
year, fur $9,000. Despite her excellent banking ednc*lion and proven competence, her lending responsibility
is limited to unsecured loans of less than $1,000. This
woman, who has had serious illness, is probably irreplaceable. Substantially all of the other members «f the
staff are paid only the minimum wage thereby causing
an exceptionally high rate of turnover.
There is little question that Citizens Bank is not a
competitive force either in the northeast Pennsylvania
banking market or in Wilkes-Barre itself. Its inability
to compete derives wholly from internal causes; its
smallness in size, its conservative policies, its lack of
officers and experienced staff, and its limited services.
Because its lending limit is only $40,000, Citizens Bank
would have had difficulty meeting the needs of its
customers even if the management had been disposed
to do so. The conservative lending policies of the institution, concentrated on purchased paper and participations and sales of Federal funds, is of little, or no,
assistance to the growing economy. Its profits are illusory, for they have been squeezed out of overhead.
Its lack of credit files reflects its indisposition to function competitively in the commercial arena. It has no
internal audit procedure. Without reciting the many
statistics available, it is clear that one of the primary
functions of Citizens has been the cashing of checks,
primarily paychecks of employees of nearby industries
from which it derives about 12 percent of its income.
Citizens Bank, then, is a small savings-type instituuon, located in a section of Wilkes-Barre which has
no other convenient banking offices to afford it
deposit competition. The nearest banking office is
more than a mile away in Plains Township. It is accessible only over a very poor road that crosses railway tracks which are responsible for frequent traffic
delays of up to 30 minutes; it is not a ready nor acceptable alternative. Anyone in the community requiring commercial bank services is required to pass Citizens and to drive to one of the four full-service banks
in the downtown area that is marked by narrow and
congested streets. By virtue uf its monopoly position in
a prime growth location, the deposits of Citizens have
grown.
Miners National, on the other hand, is an aggressive.
rnnipeii(.ivf% full-service bank which has craitributed

substantially to the community development. Its officers and directors have been prime movants in the
creation of the Industrial Development Fund and in
obtaining the many new industries which have been
induced to locate in the area. The bank itself has been
a contributor to this activity and has accepted its
share of the responsibility for meeting the financial
needs of these job-creating industries. The other three
banks in Wilkes-Barre—Northeastern National, the
largest bank in the region, must necessarily be included
in any computations—and the $110 million savings
and loan industry have also contributed to these projects. Citizens, because of size and the character of the
institution itself, cannot be considered a factor in the
past or future economic development of the region.
The merger will free its deposits for use in active real
estate development, construction, and commercial
lending which the area will require, in constantly increasing volume, for at least 13 years into the foreseeable future.
Finally, branches in the immediate area have been
approved for First National Bank and Wyoming National Bank. The former is in the same shopping area
in which Citizens is located. The other, though 5 miles
away, is essentially within the same industrial complex;
it will be accessible via a high-speed, nonstop modern
highway and will clearly compete for the business
generated in the complex. Accordingly, this merger,
when consummated, will, together with branch approvals, change the area into a competitive arena featuring three modern, aggressive and full-service banks.
It will, moreover, solve the serious management problem facing Citizens Bank, correct its internal banking
procedures, better utilize the deposits for the benefit
of the community, and give increased service to Parsons residents. It will protect the Citizens Bank's main

office from the deterioration which would occur if its
present management were confronted with a branch of
a full-service bank across the street.
Accordingly, on the facts before this Office, it is
concluded that this proposed merger will provide the
area served by Citizens with substantially better banking services; and that, together with the aforementioned branches, the benefits to the public deriving
from the increase in actual competition and service will
clearly justify the elimination of a noncompetitive
entity which is not functioning as a full-service commercial bank and which has no prospects, from the
record developed, of ever becoming one.
Accordingly, this proposal clearly meets the statutory
criteria; the public interest dictates its approval. The
application to merge is, therefore, approved.
SEPTEMBER 22,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger of Miners National and
Citizens Bank would unite two banks located only 1J4
miles apart in Wilkes-Barre, Pa., and eliminate a vigorous and rapidly growing independent competitor.
There would also be a rise in concentration of commercial banking in the area. Miners National now has
about 27 percent of I PC demand deposits in Luzerne
County (i.e., the Wilkes-Barre-Hazleton Standard
Metropolitan Statistical Area). Its merger with Citizens Bank would add another 1 percent to Miners National's market share. The rise in concentration within the city of Wilkes-Barre alone would be higher,
and the number of banking alternatives following the
merger would be reduced from six to five in the city.
Accordingly, we believe the proposed merger would
have an adverse effect upon competition in the area of
Wilkes-Barre, Pa.

MORNINGSIDE SAVINGS BANK, SlOUX ClTY, IOWA, AND THE LlVE STOCK NATIONAL BANK OF SlOUX ClTY,
Sioux CITY, IOWA
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Morningside Savings Bank, Sioux City, Iowa, with
and The Live Stock National Bank of Sioux City, Sioux City, Iowa (5022),
which had .
merged Oct. 31, 1967, under charter of the latter bank (5022) and title of
"Northwestern National Bank of Sioux City." The merged bank at date of

To be
operated

$8, 489, 509

34, 096, 918

42,674,611

119

COMPTROLLER'S DECISION

On July 24,1967, Morningside Savings Bank, Sioux
City, Iowa, and The Live Stock National Bank of
Sioux City, Sioux City, Iowa, applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of "Northwestern National Bank of Sioux City."
Sioux City, Iowa, with a population of 89,159, is the
seat of Woodbury County located at the confluence of
the Big Sioux and Missouri rivers in the northwest
part of the State. It is an luipurlaut retail trade center
and livestock marketing point for northwest Iowa,
northeast Nebraska, and southeast South Dakota. The
five-county area comprising the relevant market is also
heavily dependent upon agriculture and related industry.
The Live Stock National Bank of Sioux City, with
IPC deposits of $16.3 million, was organized in 1895
and is a subsidiary of Northwest Bancorporation,
Minneapolis, Minn. Operating its sole office in the
heart of the Sioux City stockyards area, it serves
primarily customers transacting business in this vicinity,
as well as conducting a substantial correspondent bank
business, as an outgrowth of their close association
with the central livestock market. The Live Stock
National Bank of Sioux City has a strong earnings
record, a. substantial capital structure and possesses
reasonable depth in experienced and competent management personnel.
Morningside Savings Bank, with IPC deposits of
$7.2 million was established in 1919. It operates its
head office 2 miles southwest of the charter bank in one
of the largest residential sections of Sioux City and
has a branch office located in Bronson, Iowa, a small
farming community located some 10 miles southeast
of the Morningside. area. Earnings of the Morningside
Savings Bank have been fair; its capital structure is
considered marginal and its management resources
appear to be thin.
The charter bank presently is and will continue to
be after this merger the fourth largest, both in deposits
and loans, of the 40 banks serving the five-county
market area. With its business geared to activities
in the stockyards area and correspondent banking, it

120

has not competed successfully for commercial business
with the three larger downtown banks. Neither has
it competed with the merging bank which, although
located in one of the most desirable residential areas
in the city, has pursued a cautious lending policy.
The major competitive impact of the proposed
merger would be in the Morningside area and the
farming community of Bronson where the merging
bank operates the town's only banking office. However, since the resulting bank will continue to operate
the Morningside Savings Bank office and their Bronson, Iowa, office as branches, there will be no
diminution of banking offices and the ultimate result
is expected to be an increase in competition in the
Morningside area.
Applying the statutory criteria to this proposal, it
is concluded that it is in the public interest. The
merger, therefore, is approved.
SEPTEMBER 12,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Morningside Savings' main office in the Siuux City
euburb of Mormngsidc is 2 miles seratheast of National***
head office in the stockyards district of Sioux City;
however, the amount of direct competition between
them may be limited because the type of business conducted by each bank is fairly distinct. Neither bank is
located in the downtown Sioux Cky business district.
National has historically served the packing industry,
while Morningside Savings is a basically retail bank
located in a suburban area.
National has 12 percent of both the total deposits and
IPC demand deposits of the 18 banks operating in
Woodbury County, la., where Sioux City is located.
Morningside Savings has 3.4 percent of the county's
total deposits, and 3 percent of its IPG demand deposits. Thus, the proposed merger involves a significant
increase in concentration in Woodbury County.
The proposed merger between the fourth and fifth
largest banks in the Sioux City area would eliminate
whatever direct competition exists between them and
would increase concentration in Woodbury County by
at least 3 percent. Its effect on banking competition in
the area would be adverse.

THE

FIRST NATIONAL BANK OF BLOOMSBTIRPT, BLOOMSBURG, PA., AND THTC FIRST NATIONAL BANK OF WILKESBARRE, WILKES-BARRE, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Bloomsburg, Bloomsburg, Pa. (293), with
and The First National Bank of Wilkes-Barre, Wilkes-Barre, Pa. (30), which
had
merged Oct. 31, 1967, under charter and title of the latter bank (30). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On July 20, 1967, The First National Bank of
Bloomsburg, Bloomsburg, Pa., with IPG deposits of
$8.7 million, and The First National Bank of WilkesBarre, Wilkes-Barre, Pa., with IPG deposits of $83.3
million, applied to the Comptroller of the Currency to
merge under the charter and with the title of the
latter.
The First National Bank of Bloomsburg is located
in a community of 11,000 people, situated in the northeastern quadrant of Pennsylvania some 40 miles south
of Wilkes-Barre, the home of the charter bank, and
approximately 75 miles north of Harrisburg. The
economy of the area is a well balanced mixture of industry and agriculture, complemented by the presence of Bloomsburg Slate College. Although not located
in the coal mining region, the economy of the community is inextricably bound to that of Wilkes-Barre,
which is the closest community of any substantial size.
The charter bank, as indicated by its name, is located in Wilkes-Baue, wlnVh is the cwvtfrr ctf the
anthracite imining industry. As has bften noted in the
decision of the proposed merger of Miners National
Bank and Citizens Bank of Wilkes-Barre, this region
has made a successful transition from dependence
upon coal mining to a more broadly baspH industrial
economy. The area is the. fastest growing in Pennsylvania due to the fortuitous location there of the intersection of Interstate Highways 80 and 81.
The major competition in the Wilkes-Barre region
is provided by Miners National Bank, Wyoming National Bank, and the largest regional bank, Northeastern Pennsylvania National. There is no competition
existing between the charter bank and the merging
bank whose headquarters are separated by a distance
of 41 miles and the closest office of either by 21
miles. As will be noted later, the probability of future
competition between the two banks is remote.

To be
operated

$10, 653, 505
121, 572, 121
131,906,675 |

Bloomsburg has witnessed a rather remarkable
growth during the past 10 years due to a number of
factors. The presence of Bloomsburg State College
in this community with an enrollment of 3,800 students
and a capital and operational budget in excess of $2
million is one of the major factors contributing to this
growth. In addition, the town, in close proximity to
major super highways and railroads, is fortunate in
having a substantial amount of vacant land available
for future plant construction and expansion.
The First National Bank of Bloomsburg has attempted to meet the banking needs of this community
but has reached the point where the available loanable
money has been depleted. It has been able to meet
the demand for mortgage money only by selling participations in the various mortgages to other banks. A
portion of these participations are held by the First
National Bank of Wilkes-Barre. The present loan and
deposit ratio of the First National Bank of Bloomsburg
is 73 percent, which severely limits its ability to meet
even the rrirmirrral futurerifimamdsfor mortgage- money
arid! which substantially piecludes its partiiripalkui in
the financing and servicing of new a/id expanded industries in its area.
Although the bank has attempted to increase its
capital position by the sale of additional common stuck
on two occasions and the floating of a $150,000 debenture note, the growth of tile area and the demand for
loans has rendered the capital position of the Bloomsburg bank marginal.
Within the Bloomsburg trade area the number of
competitive banking entities would remain the same
as a result of this merger. At present Bloomsburg
is served by a branch of the Miners National Bank,
a State-chartered institution, and the merging hank.
The merger, if consummated, would make available to
the Bloomsburg area not only the larger lending limits

121

of the charter bank, but a substantial amount of lendable funds which could be utilized to further the
economic growth of the community. Tn addition, the
merger wmild make available lo the customers of the
merging bank the modern automated services of the
Wilkes-Barre institution; it would fill the void now
existing because of the meigiiig bank's lack of trust
powers, travel department, investment counseling, and
EDP programs.
As the charter bank is not now located in the
Bloomsburg trading area, there would not appear to
be any diminution of competition resulting from this
merger, nor any lessening of probable future competition. On the other hand, the merger would introduce
a new source of funds for both residential construction and for commercial enterprises located in and
around Bloomshurg which the merging bank is unable
to supply and which the community seriously requires.
We believe that this factor together with the additional services which the First National Bank of
Wilkes-Barre can supply dictate the approval of this
merger to serve the public interest.
The statutory criteria having been met, the application to merge is, therefore, approved.
SEPTEMBER 22,

THE

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National Bank of Wilkes-Barre ("WilkesBarre Bank") operates a main office and four branches
in or near Wilkes-Barre. the couuly seat of Luzerne
County. It has four other branches 7-22 miles away
in Luzerne County. The First National Bank of
Bloomsburg ("Bloomsburg Bank") operates two offices
in and around Bloomsburg, a community 41 miles
southwest of Wilkes-Barre, in Columbia County. The
latter county is a largely rural area located in eastcentral Pennsylvania, contiguous to Luzerne County's
western border.
Because their closest offices are separated by 21
miles, Wilkes-Barre Bank does not appear to be a substantial direct competitor for Bloomsburg Bank and,
accordingly, the proposed merger would involve the
elimination of very little, if any, direct competition.
The Wilkes-Barre Bank has consolidated and extended its market position in the western part of
Luzerne County through acquisitions in 1964 and
1967. It would be logical to expect Wilkes-Barre Bank
to continue this westward expansion into cuiiliguous
Columbia County, either by merger or de novo
branching as is permitted under Pennsylvania law.
The proposed merger would eliminate this possibility
of independent entry by a major bank in a neighboring county.

PEOPLES BANK & SAVINGS CO., N E W PHILADELPHIA, OHIO, AND T H E NATIONAL BANK OF DOVER,
DOVER, OHIO
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Peoples Bank & Savings Co., New Philadelphia, Ohio, with
and The National Bank of Dover, Dover, Ohio (4293), which had
merged Nov. 25, 1967, under charter of the latter bank (4293) and title of
"The Peoples National Bank& Trust Go." The merged bank at date of
merger had

COMPTROLLER'S DECISION

On July 27,1967, The Peoples Bank & Savings Co.,
New Philadelphia, Ohio, with IPC deposits of $5.7 million, and The National Bank of Dover, Dover, Ohio,
with IPC deposits of $22 million, applied to the Comptroller of the Currency to merge under the charter of
the latter and with the title of "The Peoples National
Bank & Trust Co."
The National Bank of Dover, the charter bank, was

122

$6, 966, 106
28,060,416
35,026, 523

To be
operated
1
3
4

formed in 1947 through a merger involving three
banks. Its main office is located in Dover, Ohio, a town
of approximately 12,000. The merging bank, The Peoples Bank & Savings Co., was chartered in 1921 and
has never undergone a reorganization. It is a unit bank,
located 3 miles south of Dover in New Philadelphia,
Ohio, which has a population of 14,600.
The Dover-New Philadelphia area is centrally located in Tuscarawas County, Ohio, approximately 30
miles south of Canton. The two communities, serving

an area of approximately 40,000 residents, arp. siippoiled by H diversified eiwituny based on agriculture
and industry. Twelve national iiiaiiufackuers have
established industrial plants wilhin llus ai«i ami employ approximately 4y5GQ people, while locally owned
industries employ roughly 500. It is anticipated that
llie. loral economy and the number of aien lesiderrts
will further increase with the completion of Interstate
Highway 77, which will link Dover and New Philadelphia with Canton.
The charter bank, which has experienced steady
growth, operates a branch in Dover and one in Newcomerstown, 20 miles southwest. The single-unit office
of Peoples Bank, which has shown only modest deposit
growth in the last 5 years, will become a branch of the
resulting institution. Thus, a minimal degree of competition between the merging banks will be eliminated.
Consummation of the proposed merger will not significantly affect the banking services offered in Dover
since the increase in assets resulting from the merger
will have only a slight effect on the charter bank and
its position in relation to its competitors in the area.
Following consummation of the proposed merger, the
resulting institution will be approximately 42 percent
smaller in deposit structure than its main competitor,
The Reeves Bank & Trust Co., which controls 42.4 and
41.5 percent of the deposits and loans, respectively, in
the service area. The five remaining banks in Tuscarawas County, including the $17.5 million Ohio Savings
& Trust Co. and the $9 million United Bank, will continue to provide competition. Other nonbanking financial institutions including sales finance companies,
personal loan companies, and government agencies
provide competition in the trade area to a considerable
degree.
Alung with the addition of piogressive management,
dddkioA&l tanking Evicts v*4H be m&fk «7tt£2&fek to
depositors of the merging institution. These benefits

inciiiffo a lending limit capacity of $180,000, an inrrreise of $33,000, FT)P ar.rryiirrt.ingj trmt services, and
a farm department. Th* resulting bank will offer more
ftfTer*!ve campH H \cm to ihe largnr TltvMf* Bank & Trust
Co. ajid provide more, adequate hanking sftrvir.es for
the developing needs of area residents.
Applying the statutory mtftria to th« proposed merger, we conclude that it is in the public, interest, and
the application is, therefore, approved.
OCTOBER 11,

1967.

SUMMARY OF REPORT RY ATTORNEY GENERAL

The National Bank of Dover ("National Bank") is
the second largest of four banks which primarily serve
the Dover-New Philadelphia area in Tuscarawas
County, Ohio. Peoples Bank & Savings Co. ("Peoples") is the smallest bank within this area.
The existence of considerable present competition
between National Bank and Peoples seems apparent
and is indicated in the application. Loan portfolios at
each of the merging institutions indicate that both are
active in the same fields of credit. These facts, along
with the close proximity, both of the head offices and
nearest branches (3.5 and 1.5 miles, respectively), indicates a substantial degree of direct competition between the merging banks, which would be eliminated
by the proposed merger.
In Tuscarawas County, as a whole, the proposed
merger would result in an increase in National Bank's
share of total deposits from 20.8 to 26.2 percent, and
its share of IPC demand deposits from 17.7 percent
to 22.8 percent.
In summary, the proposed merger would eliminate
direct competition between two banks within a short
di«tance from each other, ^"d would significantly increase ba^ii^g rnncpntratinn in T\l«carawa« Cnnnty
and the Dover-New Philadelphia area.

EAST BERLIN NATIONAL BANK, EAST BERLIN, PA., AND ADAMS COUNTY NATIONAL. BANK, LITTLESTOWN, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

East Berlin National Bank, East Berlin, Pa. (14091), with
and Adams County National Bank, Cumberland Township, Gettysburg, Pa.
(311), which had
merged Nov. 30, 1967, under charter and title of the latter bank (311). The
merged bank at date of merger had

To be
operated

$3,447, 598

34, 055, 893

37,503,491

123

COMPTROLLER'S DECISION

On August 10, 1967, the Adams County National
Bank, Littlestown, Pa., with IPC deposits of $28 mil:iion, and the East Berlin National Bank, East Berlin,
Pa., with IPC deposits of $3 million, filed an application with the Comptroller of the Currency for per:cnission to merge under the charter and with the title
of the former.
The merging banks are both located in Adams
County which lies on Pennsylvania's southern border
adjacent to the Maryland line. Though the economy
of this area is well diversified, agriculture plays a predominant role. The dairy farms in the area, an important source of income, send their products to the
Washington and Baltimore metropolitan markets.
Light industry is now assuming an increasingly significant role in terms of local employment. The historical
Gettysburg Battlefield and its shrines, which draw 3
million visitors a year, makes tourism a major component in the local economy. Shoe and garment factories
account for much local employment. Additionally, it
should be noted, many residents of the area commute
to their employment sites in York, Harrisburg, and
Hanover in Pennsylvania.
The Adams County National Bank, chartered as a
State bank in 1857, was converted to a National charter in 1864. Its head office is in Littlestown, a community of 2,800 located 9 miles southeast of Gettysburg.
This bank, with two branches in Gettysburg, has
pending an application to relocate its head office in
Gettysburg. Its third branch is in McSherrystown, a
community of 3,500 located 13 miles southeast of
Gettysburg.* This bank has shown good growth in recent years but has felt the need for an office in the
northern part of the county.
The East Berlin National Bank was organized in
1934. It is a single-unit operation with its office in East
Berlin, a town with a population of 1,100. In contrast
to the charter bank, this merging bank has grown little
in recent years and offers a limited range of banking
services.
There is no significant competition between the
participating banks. The closest branch of the charter
bank to the merging bank is its McSherrystown
branch, which is located about 12 miles south of
East Berlin. If the merger is consummated, the resulting bank will hold only a slightly higher percentage of the total county commercial banking
•On Oct. 17, 1967, this bank relocated its main office to
Cumberland Township (post office, Gettysburg, Pa.).
124

assets than are presently held by the charter bank.
This will not result in a competitive imbalance.
In Gettysburg the resulting bank will continue to face
"intense competition from The Gettysburg National
Bank, which has total resources of $35.5 million. The
Hanover branches of both the Dauphin Deposit Trust
Co., Harrisburg, Pa., with total resources of $188
million, and the National Bank & Trust Co. of Central
Pennsylvania, York, Pa., with total resources of $238
million, are active competitors of the merging banks.
It is anticipated that the resulting bank will be able
to compete more effectively with The Peoples State
Bank, East Berlin, Pa., with total resources of $4.3
million, than did the merging bank.
If the application is granted, the public in the East
Berlin area will benefit from the increased lending
limit of the resulting bank, and from the availability
of a wide range of banking services which are presently
not offered by the merging bank, including trust department services, installment lending, Small Business
Administration loans, and student loans. Bookkeeping
functions will be centralized and the electronic data
processing facilities of the charter bank, including a
computer soon to be delivered, will be available to the
customers of the merging bank. Through the union
with the charter bank, the management succession
problems of the merging institution will be solved.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest, and
the application is, therefore, approved.
OCTOBER 23,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Adams County National (total deposits, $29 million), is headquartered in Littlestown, Pa., 9 miles
south of Gettysburg; it operates two branches in
Gettysburg and one in McSherrystown. East Berlin
National's single office is located in East Berlin, Pa.,
a town 16 miles north of Littlestown. Both banks' deposit business consists largely of time deposits.
The office of Adams County National closest to
East Berlin National is 10 miles away (in McSherrystown), and Adams County National's other offices
are 16-18 miles away. There would seem to be little
significant direct competition between the two banks,
a fact probably accounted for at least in part by this
distance factor.
In Adams County, Adams County National now
has a substantial 30.2 percent of total deposits, a
share which would rise to 33.3 percent following the
merger.

Thus, following the merger, Adams County National
would become the largest bank headquartered in
Adams County, although it would continue to be in

competition with substantially larger banks having
branches in Adams County or Hanover, just over the
county line in York County.

EMPIRE STATE BANK OF DALLAS, DALLAS, TEX., AND T H E NATIONAL BANK OF COMMERCE OF DALLAS,
DALLAS, TEX.

Name of bank and type of transaction

Total assets
In
operation

Empire State Bank of Dallas, Dallas, Tex., with
and The National Bank of Commerce of Dallas, Dallas, Tex. (3985), which
had
merged Dec. 4, 1967, under charter of the latter bank (3985) and title of
"National Bank of Commerce of Dallas." The merged bank at date of
merger had

COMPTROLLER'S DECISION

On July 3, 1967, Empire State Bank of Dallas, Dallas, Tex., with deposits of $34 million, and The National Bank of Commerce of Dallas, Dallas, Tex.,
with deposits of $64.5 million, applied to the Office of
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of "National Bank of Commerce of Dallas."
Dallas, with an estimated population of 840,000, has
a highly diversified economic ha.se and is the leading
financial, industrial and trade center for the region
comprised of Oklahoma, northeast and central Texas,
western Arkansas, and northwestern Louisiana. Dallas
County, of which the city is the seat of government,
has a population of 1,225,000. The Dallas Standard
Metropolitan Statistical Area, comprised of Collin,
Denton, Ellis, Kaufman, and Rockwall counties in
addition to Dallas County, has a total population of
1,500,000. The growth rate throughout this Metropolitan Statistical Area has been rapid in the last 25
years; the county grew 54 percent from 1940 to 1950
and 55 percent from 1950 to 1960 as against figures of
14.4 and 18.4 percent for the country as a whole. The
growth rate in the last 6 years has exceeded that of any
other metropolitan area. There is every reason to expect this growth to continue; 18,000 new homes are
being constructed each year.
Industry and trade in the Dallas area are keeping
pace with its population. It has 2,000 manufacturing
concerns and 3,000 wholesale firms contributing to its
economic vitality. Retail sales approximate $2 billion
annually. Its work force of 600,000 has increased from

To be
operated

$34,095,321
94, 066, 341
128, 161, 662

444,619 in 1960. Of this work force, government and
services employ 22 percent, wholesale and retail firms
28 percent, finance and real estate 8 percent, and
manufacturing and construction 32 percent. The buying power of this metropolitan area now exceeds $3
billion per year. Deposits in the metropolitan area
banks have increased by $1 billion since the beginning
of 1964.
The intensity of competition among the financial
institutions in this area is immediately evident from a
survey of their numbers. Within the Standard Metropolitan Statistical Area there are 102 commercial
banks, with total deposits in excess of $4 billion; within
Dallas County alone there are 67 commercial banks,
with IPC deposits in excess of $3 billion. The two largest banks in the southwest United States, the Republic
National Bank of Dallas, with total deposits of $1,293
million, and The First National Bank of Dallas, with
total deposits of $1,244.5 million, are located in Dallas.
Other large banks include the Mercantile National
Bank, with total deposits of $514.5 million, and the
Texas Bank & Trust Co., with total deposits of $174
million. Competition is also provided by 23 savings and
loan associations which operate 52 offices, by 111 insurance companies, and by more than 200 credit
unions. The merging banks have 1.5 and 0.8 percent of
the metropolitan area's commercial bank deposits.
Together they would have 2.3 percent, an increase in
concentration among the seven largest area banks of
0.8 percent.
The union of the participating banks will not significantly affect deposit concentrations in the largest area
banks. As the following table demonstrates, the portion

125

of total deposits held by the larger banks in Dallas has
shown an absolute decrease, in the last 10 years.
Number of Banks
1.
2

1957
35.6
70.9

1966
32.8
64.3

3
85.3
77.3
4
88.8
81.7
5
90.4
83.9
7
92.6
87.1
This decline indicates a trend which the marked
exodus of industry and population from center cities
to suburbs throughout the country can only intensify
in unit-banking States. This merger, of itself, will not
either reverse, or substantially retard, this trend in
Dallas.
The National Bank of Commerce, the charter bank,
was organized in 1878. It experienced only nominal
growth until a change in ownership in 1963 and a
change in location in 1964 resulted in the adoption of
more progressive policies under aggressive leadership.
The new ownership, through farming business ties,
was able to stimulate the bank's deposit growth and
to attract a significant number of prime credit customers. Although deposits have grown from $31 million in 1963 to $64 million at the end of 1966, they
still represented but 1.5 percent of the $4,180 million
commercial bank deposits in the Dallas Statistical
Area. During this period, the bank failed to develop
a management staff capable of keeping abreast of
the changes its rapid growth produced. With its most
recent change in ownership early this year, a new top
management team has been obtained to direct the
bank's affairs. This new supervision has already demonstrated its competence by solving a significant number of the internal problems it inherited. It has not,
however, been able to solve its space problem; it has
too much expensive space for a bank of its size. The
only present, feasible solution to this problem is to
expand the size of its operations as soon as possible.
This merger offers a satisfactory solution.
The National Bank of Commerce is now located
in Dallas' central business district, an area of approximately 30 square blocks encompassing 10 commercial
banks. In the next block to the east is located the
Republic National Bank of Dallas, and immediately
to the west, the First National Bank in Dallas. Although the charter bank is seventh in size among the
10 banks located in the central business district, it
holds less than 3 percent of the banking assets of these
10 banks. Tn addition tn its competition in central Dal
las, the charter bank seeks business in areas extending
beyond the metropolitan area in the broader regional
126

market encompassing portions of Arkansas, Oklahoma, Louisiana, Kansas, New Mexico, and Texas.
Empire State Bank, chartered in 1948, is also located in the Dallas central business district, 2.5 blocks
from the charter bank. This bank, which has never
participated in a merger or consolidation, has experienced a slow but steady deposit growth in this burgeoning market. It has been beset by a myriad of
small problems which, because of lack of sufficient
numbers of experienced and capable men in the top
management level, now coalesce into a matter of no
little concern. Inexperienced, though promising, young
men have allowed an asset problem to develop which
has been reflected in a poor earning record. The
capital structure of this bank has not kept pace with
its deposit growth; attempts to raise new capital
have been unsuccessful. Empire State also has a housing problem. When its present leases expire in 1973,
it will be forced to relocate in new quarters in this
central Dallas location. Whether it can obtain adequate space at a cost within its ability to pay is a
specter that now worries its management.
Despite their proximity in the central business district, the participating banks have not substantially
competed with each other for specific customers.
Though both banks are available to walk-in customers, the Empire State Bank has traditionally looked to
business establishments on the eastern end of the business district and has depended on associates of its
officers and directors. Before its change in ownership
in 1963, the National Bank of Commerce relied on
depositors in the western sector of the business district for support. Following 1963, when it became an
aggressive institution, National Bank of Commerce
directed its competitive thrust toward the expanding
manufacturing and commercial concerns and toward
the tenants of the new office buildings near it. Its
sights were principally aimed at promoting and developing competition with the larger banks in the
area. The slight competition that occasionally developed between these participants for correspondent
bank accounts, consumer credit accounts, and a few
personal and business deposits is hardly sufficient to
be classified as substantial. Their joint participation
in loans reflects the fact that they took a noncompetitive attitude toward each other.
To view these virtually noncompeting banks as potential competitors is unwarranted. Not only have they
effectively demonstrated that they do not now desire
to compete, the circumstances indicate that they could
not compete if they did so desire. Because of State
laws, they cannot follow the expanding population into

the suburbs and compete for retail deposits through
branch offices. If they are to compete for this class of
busiiiua, ?L must be through use oi cssnvcajeat drive up
windows; National Bank of Commerce has such a
service but Empire State cannot provide it in its preserxt quailcis. Furthermore, without deposit growth to
broaden its earning base and strengthen its capital
sUuCtuid tliiOugli ictoincd earnings, neither bank can
SuC^Caafull)' uOmpctc fui" tliC ioi'gCi" aCCOUIito £LT±d tuClT

compensating balances. Until the law on branching
changes, their competitive potential remains only a
lemote possibility «tnd not a presently existing probability.
This merger will alter slightly, but not disrupt, the
banking structure in Dallas, Dallas County, and the
Dallas Standard Metropolitan Statistical Area. The
union of these banks will elevate the National Bank
of Commerce from its present rank as seventh largest
in the area to fifth. The two largest banks continue to
be 12 and 13 times as large as the resulting bank. Nor
can the elimination of Empire State Bank be deemed
a significant loss for small- and middle-size customers;
11 banks in the $20-$35 million category will remain
to serve them. Whatever competitive impart this merger may have will be felt by the four larger Dallas banks.
Consummation of this merger will he of direct benefit to the participating banks and, thereby, indirectly
beneficial to the public. By uniting these banks the
respective space problems will be resolved. Empire
State Bank will close, its doors, thereby avoiding the
problems that prospective relocation poses. National
Bank of Commerce, on absorbing Empire State Bank,
can more profitably utilize the excess space it now possesses and thereby reduce this overhead drain on its
earnings. This union will also allow a more effective
utilization of the automation and computer operations
of National Bank of Commerce. By combining the
staffs, an officer corps of greater diversity, specialization, and depth will be created than either existing
bank can afford to support.
The growth of population^ income, manufacturing,
and commercial activity in the Dallas Statistical Area
has created a public need for expanding financial institution? and a broader range of hanking sprvir.es.
Whi^£ this dsm^nd h?.s be?" r n ^t ?™ ***** ^v *hp pntrv
of 30 new banks and 23 new savings and loan offices
betw.m lOfiO and 1966, thr. nejeA for larger instituliuiis tontin nftv Tim meigw rftjymrift to the poblie
need by giving lu the Dallas iroiiuuuiuty a fifth l«arrk
in the $100 million and larger range. The resulting

bank will be able to offer an expanded range of services truly competitive with the four larger banks. The
tni£t dep2£toettt of National R%&k of rinmmerre will
be expanded and a bond department, not now available at either bank, will be established.
In light of the foregoing analysis of the Dallas metropolitan area market, the place of the participating
bcinks in that niarket, the problem? farprl hy these
Vincr rnmnetibanks, the im^s-ct of this i
tion and the banking structure in that market, and
the benefits to be derived by these banks and by the
public from this merger, this Office finds the proposal
to be in the public interest. The application to merge
is, therefore, approved.
NOVEMBER 2,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank uf Commerce is the seventh largest
of 67 banks in Dallas County, with assets of $79,871,000, total deposits of $64,478,000, and loans and discounts of $46,758,000. Empire State is the 10th largest
Dallas County bank, with assets of $36,527,000, total
deposits of $34,048,000, and loans and discounts of
$20,598,000. The participating banks are both located
in the central business district of Dallas, within two
city blocks of one another, and are in direct competition with' each utliex- for a wide range of commercial
banking services.
Concentration in commercial banking in the city
of Dallas and in Dallas County is extremely high. Approximately ihree-fuurths of the area's total deposits
are concentrated in the three largest banks, and the
10 largest hold approximately 90 percent of the
total deposits of the 44 banks located in Dallas and
about 85 percent of the total deposits of all banks in
Dallas County. In addition, the three largest banks own
or control stock in approximately 32 of the smaller
banks in the county, including at least 14 of the 34
new banks chartered in the area since 1957, thus making it probable that actual concentration is even
higher, and the number uf independent competitors
even less, than the number of separately-chartered
institutions would indicate. National Bank of Comniexce holds <tbout 1.5 percent of all ctep©3its in Dallas
Cuuiily, wlniC IjiiipiiC Stu.tC holuS «bout 0.8 pCTCCnt.
The proposed merger would eliminate the existing
competition between the participating banks and
wuui'J eliminate m a viaWe co/flpfttitftr f/ne <& the 10
largest banks in an area r<f extremf^y high concentration.

127

THE GLEN LYON NATIONAL BANK, GLEN LYON, PA., AND T H E HANOVER NATIONAL BANK OF WILKES-BARRE,
WILKES-BARRE, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Glen Lyon National Bank, Glen Lyon, Pa. (13160), with
and The Hanover National Bank of Wilkes-Barre, Wilkes-Barre, Pa. (14344),
which had
merged Dec. 9, 1967, under charter and title of the latter bank (14344). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On August 25,1967, The Glen Lyon National Bank,
Glen Lyon, Pa., and The Hanover National Bank of
Wilkes-Barre, Wilkes-Barre, Pa., submitted to the
Comptroller of the Currency an application to merge
under the charter and with the title of the latter.
The charter bank, with IPC deposits of $14.2 million, ranks fifth in size of the six banks serving WilkesBarre. It operates one branch in Wilkes-Barre, which
lies in the area of northeastern Pennsylvania presently
recovering from the economic setback suffered during
the decline of the anthracite industry.
The Glen Lyon National Bank, with IPC deposits
of $2.7 million, is located 14 miles south of WilkesBarre. Glen Lyon, with a population of 4,000, has
not yet experienced the recent economic growth seen
elsewhere in this area of the State.
Competition between the applicant banks has been
very limited. The Glen Lyon bank has served only its
own locality. Five branches of banks based in WilkesBarre, as well as two independent banks, are located
closer to Glen Lyon than is the charter bank. The
iw.rgr.r will net, therefore^ diminale *n active competitor, nor wiH it concentrate banking resources significantly, as the resulting bank will hold only 3.3

To be
operated

$3, 173, 952

19, 274,573

22,448,525

percent of the IPC deposits in the county and only
3.4 percent of loans.
Affirmative benefits will accrue to the residents of
Glen Lyon as a result of the merger. Modernized banking services and trust facilities will be introduced, and
competent management will be assured for the future.
The application is hereby approved.
NOVEMBER 7,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Hanover National Bank ("Hanover") and the
Glen Lyon National Bank ("Glen Lyon Bank") are
two relatively small banks located in Luzerne County,
Pa. Hanover is a successful competitor while Glen
Lyon Bank's deposits have shrunk since 1962.
The head offices of Hanover and Glen Lyon Bank
are about 10 miles apart, Hanover competes with
banks that, are more distant from it than Glen Lyon
and thus there may be some direct competition between the merging banks.
In Luzerne County, the effect of the proposed
merger r/n rnnr^ntratioA shutrl'J nut be significant,
hewevrr, in vkw of the ickrtivdy small size and market share of the merging banks.

THE HAMTJN NATIONAL BANK OF HOLCOMB, HOLCOMB, N.Y., AND T H E CANANDAIGUA NATIONAL BANK & TRUST
Co., CANANDAIGUA, N.Y.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Hamlin National Bank of Holcomb, Holcomb, N.Y. (10046), with
and The Canandaigua National Bank & Trust Co., Canandaigua, N.Y. (3817),
which had
merged Dec. 14, 1967, under charter and title of the latter bank (3817). The
merged bank at date of merger had

128

To be
operated

$5, 268, 883

31, 852, 432

37,121,314

COMPTROLLER'S DECISION

On September 7, 1967, The Hamlin National Bank
of Holcomb, Holcomb, N.Y., with IPG deposits of $3.9
million, and The Canandaigua National Bank & Trust
Co., Canandaigua, N.Y., with IPC deposits of $26.5
million, applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter.
Canandaigua, the county seat of Ontario County,
with a population of 10,000, is located 28 miles southeast of Rochester. With the exception of a U.S. Veterans' Hospital, which employs 1,000, and the summer
resort trade, local industry is limited. Most of the residents of the community commute to employment in
Rochester.
Holcomb, essentially a dairy farming community
located 8 miles west of Canandaigua, has a population
of 700. Its trade area population is 5,000. Some industry is beginning to move into the area resulting in moderate but steady economic growth.
The charter bank was established in 1878 and acquired one branch in Victor in 1957. The bank's
service area covers much of the western portion of
Ontario County, which has an estimated population
of 50,000. The charter bank's largest commercial bank
competitors in the area arc the $617 million Lincoln
Rochester Trust Co., the $329 million Marine Midland Trust Co. of Rochester and the $276 million
Security Trust Co. of Rochester.
The merging bank, organized as a private bank in
1878 and as a National bank in 1911, operates its single office in the Village of Holcomb in Ontario County. Its nearest competitor is the Canandaigua National, although only 2 percent of Canandaigua National's
total deposits are derived from the area served by the
Hamlin National. It, too, faces strong competition
from the surrounding branches of the much larger
banks located in Rochester.
The two banks are controlled by a single family.
This close relationship has stifled competition between
the banks despite the short distance of 8 miles between
the two communities. Virtually no competition be-

tween the applicants will be eliminated by the proposed
merger. The merger will not significantly alter the
charter bank's position among its competitors. It will,
however, enable the resulting bank to meet more effectively the strong competition from the much larger
Rochester commercial banks and mutual savings institutions.
Approval of this merger will be substantially beneficial to both banks and to both communities. The additional resources to be acquired by the charter bank
will enable it to handle, to the extent of $300,000, the
larger loan applications, as well as to take care of the
increasing credit needs of the growing community of
Holcomb. Effectuation of the proposal will also provide a solution to the management succession problems facing both banks, make available trust services
to present customers of Hamlin National and resolve
the long-range capital problems of the merging bank.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest.
The application is, therefore, approved.
NOVEMBER 8,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

This proposed merger involves two Ontario County
banks which are linked by a long-standing stock affiliation said to go back to their founding in the late 19th
century.
The distance between the closest offices of the merging banks is 6 miles and that between their head offices is 8. In view of the proximity of the two banks
in this primarily rural county, they would appear to be
direct competitors; the proposed merger would, of
course, eliminate this competition between them.
Based on the most recently available published
data, Canandaigua National has 24.2 percent of IPC
demand deposits in Ontario County and Hamlin has
4.7 percent of such deposits. The banks' share of total
deposits in the county is slightly higher. Accordingly,
the merger would raise the level of banking concentration within the county by almost 5 percent.

129

THE FIRST NATIONAL BANK OF VISTA, VISTA, CALIF., AND GOLDEN GATE NATIONAL BANK, SAN FRANCISCO,
CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Vista, Vista, Calif. (13178), with
and Golden Gate National Bank, San Francisco, Calif. (14939), which had...
consolidated Dec. 15, 1967, under charter of the former bank (13178) and
with title "Liberty National Bank." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On September 15, 1967, The First National Bank
of Vista, Vista, Calif., and Golden Gate National
Bank, San Francisco, Calif., applied to the Comptroller of the Currency for permission to consolidate
under the charter of the former and with the title
of "Liberty National Bank."
The First National Bank of Vista, organized in 1928,
operates, in addition to its main office, one branch and
a drive-in office in the southern California city of
Vista, and one branch at Lake San Marcos, 7 miles
southeast of Vista. In addition, it has an administrative office in San Francisco, which supervises bank
operations and performs principal accounting functions, including operations connected with an insurance premium financing program.
Vista, Calif., located 40 miles north of San Diego
and 420 miles southeast of San Francisco, is in a farm
community, which has experienced substantial urban
development during the past two decades. The population of Vista has increased from 1,700 in 1950 to
nearly 15,000 in 1960, and is presently estimated at
20,000. There is virtually no industry in Vista and
the economy is still based on agriculture, as well as
the commercial needs of a growing residential population.
Golden Gate National Bank, organized in 1961, operates four offices in the city of San Francisco and one
branch in Los Altos, 39 miles southeast of San Francisco. San Francisco is the State's second largest city
with a population of 750,000, and is the focal point
for a metropolitan area containing close to 3 million
inhabitants. It is a major seaport and one of the major
financial centers on the west coast.
The condition, management, and future prospects
of The First National Bank of Vista are considered to
be good and its earnings have been excellent. As of
June 30, 1967, it had resources of $27.3 million, IPC

130

$29,623,856
44,446, 859

To be
operated
4
5

73, 170, 715

deposits of $19.8 million, loans aggregating $17.1 million, and capital of $2.6 million. On the other hand,
Golden Gate National Bank has experienced a poor
record of earnings. Excessive loan losses have impaired
its capital and its future prospects appear to be dim.
As of June 30, 1967, the Golden Gate National Bank
had resources of $46.7 million, IPG deposits of $37.6
million, loans totaling $28.7 million, and capital of
$2.9 million.
As a result of the distance between their respective
service areas, as well as distinct differences in the
character of their banking activity, there is presently
no competition between these two banks which would
be eliminated by this consolidation. Neither would the
consolidation have an adverse effect on the competitive situation in the communities served by these banks.
The Golden Gate National Bank presently competes
with numerous banking offices in San Francisco, as
well as many offices of savings and loan associations,
government lending agencies, sales finance companies,
and credit unions. The First National Bank of Vista
competes with a branch of the Security First National
Bank, Los Angeles, and a recently opened branch of
the Bank of America National Trust & Savings Association, the two largest banks in the State.
Consummation of this proposal would eliminate the
problems of Golden Gate National Bank by providing
a more efficient and profitable operation. In addition,
the consolidation would enable the Vista area branches
of the resulting bank to provide trust services not presently offered by The First National Bank of Vista.
Applying the statutory criteria to this proposal, it is
concluded that it is in the public interest. The merger,
therefore, is approved.
NOVEMBER 14,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

This is a proposal to merge the First National Bank
of Vista, Vista, Calif. (3 offices with deposits of $23.3

million) and the Golden Gate National Bank, San
Fnujcitsw, Chftllf. (5 offices with deposits of $42 R milliuii). The milling bank i*c«W he eaWrA the. Vihr.vtf
National Bank.
Tho mw§kfig h£ua&£ £#rve f«po*Ot« ITSQE nf tha St-atn
of California Soaae 450 miles apart. Vitht maintains
offices in San Francisco, but this is administrative only
and does not provide competition for the. Golden Gate
Bank. Vista does have a statewide lending business as a
result of the 1963 acquisition of Commonwealth Thrift
Co.; however, this is a premium finance business and
Golden Gate is not engaged in any such activities.
There would appear to be little, if any, direct competition between the two banks.

The proposed merger will produce, no significant impart wi the banking stmrtiim in any of the cities affected. Vit£a faces vuumrlHktt from tine-. 1am largest
banks in the State, while Golden Gate is in the financial
t u A u i/f Dan Ruiiiubu VJA niuot Ltxup&x> wilk wa*?/j
KjjubidcL<AAy larger banks, including E&nk of Amoiioa,
Weils Fargu, docker-Citizens, and United California
Bank. Golden Gate's Los Altos branch faces similar
competition.
Due to the distance between the two banks and the
substantial competition each faces in its own community from considerably larger banks, the proposed
merger will not have an adverse effect on competition.

THE BANK OF WENDELL, WENDELL, N.C., AND FIRST UNION NATIONAL BANK OF NORTH CAROLINA, CHARLOTTE,

N.C.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Bank of Wendell, Wendell, N . C , with
and First Union National Bank of North Carolina, Charlotte, N.C. (9164),
which had
merged Dec. 16, 1967, under charter and title of the latter bank (9164). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On September 1, 1967, The Bank of Wendell, Wendell, N . C , with IPC deposits of $5.4 million, and
the First Union National Bank of North Carolina,
Charlotte, N . C , with IPC deposits of $498 million,
applied to the Comptroller of the Currency for permission to merge under the charter and with the title
of the latter.
The First Union National Bank of North Carolina
is headquartered in Charlotte, N . C , which is the
county seat of Mecklenburg County and is in the
south-central Piedmont section of the State. This $702
million charter bank presently operates 96 offices in
44 communities and is the third la.rgp.st commercial
bank in the State. Its service area is considered to he. the
entire State and its principal competitors are the. $1.2
billion Wachovia Bank & Trust Co., which operates 98
dikes in 36 comrmmittes, the $064 million North Carolina National Bank with 78 offices in 13 communities,
and the $522 million First Citizens Bank & Trust
Co., which operates 100 offices in 48 communities.
The State of North Garuiliia presently has 137 banks

To be
operated

$8, 220, 662

779, 937, 909

101

788, 115,653

103

operating 749 branches with total resources of more
than $5.5 billion. Statistics supplied indicate that
little change will take place in the State's banking structure if the proposal is approved. Charter
bank's percentage of assets in the State will only increase from 12.7 to 12.8 percent and its percentage of
banking offices in the State will increase from 8.1 to 8.3
percent..
The Bank of Wendell, merging bank, is headquartered in Wendell, N . C , approximately 155 miles
west-southwest of the charter bank's head office in
Charlotte. Wendell has a population of 1,620 people
and a service area population of approximately 7,500
people. The service area is rural in nature with its principal economic suppoi I deriving from tobacco growing.
Tubaccu piueessing, textile production, and furniture
manufacturing also provide major employment for
the area.
The merging bank was established in 1933 and
opened its only branch in 1950 in Knightdale, N . C ,
located 8.5 miles west of Wendell. The branch is also
approximately 8.5 miles from the charter bank's
nearest banking office in Raleigh, N.C!. Merging bank
131

faces intense competition from a branch of the $80
million Peoples Bank & Trust Co., a branch of the
$522 million First Citizens Bank & Trust Co., and a
branch of the $90 million Central Carolina Bank &
Trust Co, Although economic conditions arc described
as genera lly favorable in the service area of the merging
hank, grnwtfc has been slow and proopeofez o*o only
fair since expansion of Raleigh has generally been
directed to the north and south rather than toward
the two banking locations of Wendell to the east.
It appears that little, if any, competition would be
eliminated by the merger because there is little overlapping in the areas presently &erved by the part42tp&&$3
and no banking offices will be eliminated.
The resulting bank will be able to offer a broader
range of services to the customers of the merging
hank, inrluditig trust facilities, data processing fadli
ties, a greater lending limit, and full-service banking
not presently available to the merging bank's customers. It will enable the resulting bank to compete
more effectively with the larger banks now operating
in the area and thus bring to the residente of Wendell
the full hpnpfit? tKat flow frosa aggrereive cosapettteGa.
Applying th<» statutory criteria, wa ceackade tfeot
the proposal is in the public interest and the application is, therefore, approved.
NOVEMBER 14,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First Union is thr. third largest eoi.'miercuil b»»A iu
NsrSh CBTOINML WWI Qfi hnmcixj in 44 Komimi£&jitt
throughout the State. Bank of Wendell, with deposits

of $5.5 million, operates two offices in die eastern portion of Wake County.
The Bank of Wendell is the only bank in the small
town of Wendell (population, 1,620), in the eastern
portion of Wake Comity located in the nuith-cenlial
part of North CaroHnft. The area is basically agiaiiaa
or A tehtatco producing. RdldgU (pupuktfJbu, S3,S31)
is the principal city in Wake Courtly, wiiidi is the Raleigh Standard Metropolitan Area; the counLy had a
population in 1960 of 169,082, which represented a
24-percent increase over the 1950 figure.
There are presently 11 banks operating 45 offices in
Wake Oisfrty, with three, including Dduk i/f Weudcdi,
headquartered in the county. The four largest banks in
North Carolina have offices in Raleigh: Wachovia
Bank & Trust Co. (seven offices), North Carolina
National Bank (one office), First Citizens Bank &
Trust Co. (nine offices) and First Union (two offices).
First Union's two branches in Raleigh have deposits
of $26.4 million.
First Union's main branch in Raleigh is 17 miles
from Bank of Wendell's mam office and OJ/a miles fiuui
its brassch in KnsgistdftSc. There wiH Joi/i/tlcss* be &unic
direct competition eliminated between die iwu hasAj>
because of this proximity.
Banking is highly concentrated in Wake County,
with the three largest banks accounting for over 75
percent of all deposits and the five leading banks accounting for just over 90 percent. First Union accounts
fw nhemti 6 percent c<f total cumrly depusilx and the
prr4vMr.fl mrrgrr WOIKM iuCicftsc jt> uuu&el divuc by
about 1.4 percent.

FIRST STATE BANK OF MENDON, MENDON, MICH., AND T H E AMERICANTNATIONAL BANK & TRUST C O . OP
MICHIGAN, KALAMAZOO, MICH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
First State Bank of Mendon, Mendon, Mich., with
and The American National Bank & Trust Go. of Michigan,! Kalamazoo,
Mich. (13820), which had
merged Dec. 19, 1967, under charter and title of the latter bank (13820).
The merged bank at date of merger had

COMPTROLLER S DECISION

On August 25, 1967, The American National Bank
& Trust Go. of Michigan, Kalamazor^ Mich., and First
State Bank of Mendon, Mrndon, Mich., applied to
the Office, of the Comptroller of the Currency for per-

132

To be
operated

$5, 300, 503

141,807,188

146,575, 548

mission to merge under the charter and with the title
of the former.
Thfi American National Bank & Trust Co* «f Michigan was chartered in 1S33 in Kalamazoo, the county
sc&t of Kalamazoo Cotmty, wliich is located in the

southwest part of lower Michigan. Kalamazoo has a
population of 82,100 and the county has a population
of 169,700. The Kalamazoo economy is one of the most
stable of any important urban area in the Midwest.
It is predominantly industrial with diversified manufacturing and is also supported by one of the prfmft
farming areas of Michigan's lower peninsula.
The charter bank, with IPC deposits of $102-8 million, began to expand through IiranHiino in 1951 and
now has 10 in-town branches and five branches outside Kalniuazoo at RidM.aiid, Pfairiwill, Allfigan, Lawrence and OtiteuiG. Three of these branches are
outside Kalamazoo County thereby increasing the trade
area to include a population of 240,000. American National Bank & Trust Co. of Michigan has not yet
branched to the south of Kalamazoo.
First State Bank of Mendon is located in Mendon,
Mich., which is 22 miles southeast of Kalamazoo. The
town, with a population of 900, has two key industries,
each of which employs about 250 people. The area
surrounding Mendon is devoted to grain and dairy
farming.
The merging bank, which was organized in 1894,
has IPC deposits of $4.1 million. It has one branch
at Athens, a rural community of 1,000 situated 22 miles
southeast of Kalamazoo. In July 1967, it established
a branch at Fisher Lake, 21 miles southeast of Kalamazoo. Fisher Lake is a residential and resort area with
a population of 350.
This merger will have no adverse effect on banking
competition in the Kalamazoo area. At this time the
subject banks do not compete because of the distance
that separates them and the presence of other banks
in the intervening space. Because of the size of Mendon, it is most unlikely that another bank would be
permitted a de novo branch entry into the town. Nor
is the First State Bank of Mendon likely to begin de
novo branching in competition with the larger banks
in the area. This merger, therefore, cannot reasonably
be deemed as having an adverse effect on potential
competition.
The competitive impact of this merger on the area's
banking structure will be beneficial. Acquisition of the
bank in Mendon by the American National Bank will
enable it to extend its trade area southeast of Kalamazoo and promote more direct and immediate competition with the $00 million Security National Bank
of Battle Crcxk, which has a branch at Leomdas, 5
miles east of Mendon. It will further stimulate com-

petition between the charter bank and its present principal competitors, the $197 million First National
Bank and the $80 million Industrial State Bank &
Trust Co., both of Kalamazoo.
The merger will fill a need for management depth
and specia.li7.ftd bank sftrvirra at the merging bank's
offices. Besides trust services, the. Mendon office will
be able to piovirle a larger consumer loan department
as wHl as better agnr.ult.ural, bnsfnftss, andrealftst.at.ft
loan services.
Applying the statutory criteria to the proposal, we
conclude that it is in the public interest, and the application is, therefore, approved.
NOVEMBER 15,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger involves two banks in the adjoining counties of Kalamazoo and St. Joseph, Mich.
Kalamazoo, where American National has its head
office is the hub of a traditionally prosperous trading
area with about 240,000 inhabitants. The city of Kalamazoo itself has 95,000 inhabitants. The area's population growth exceeds the national average.
Mendon, where the head office of First State is located, is approximately 29 miles south of Kalamazoo
in St. Joseph County. It is a village with about 1,000
people and the center of a predominantly agricultural
area of about 50,000 people. The increase of the population of St. Joseph County was about 20 percent between 1950 and 1960.
There would appear to be relatively little direct
competition between the merging banks. Their head
offices are 29 miles apart. American National's office at
Richland is approximately 12 miles from the closest
First State office.
The proposed merger may involve some loss of potential competition between the two banks. American
National could not branch de novo into the town of
Mendon itself under present Michigan law, but it
could open a branch elsewhere in this growing county
in a town not already served by a banking office. Since
its largest competitor in Kalamazoo County—First
National Bank & Trust—has done exactly that, American National (the second largest bank in Kalamazoo
County) must be considered also to be a. likely potential entrant into St. Joseph County. The proposed
merger would eliminate this possibility of independent
entry.

133

CONEMAUGH VALLEY BANK, BLAIRSVILLE, P A . , AND FlRST NATIONAL BANK OF INDIANA, INDIANA, P A .

Name of bank and type of transaction

Conemaugh Valley Bank, Blairsville, Pa., with
and First National Bank of Indiana, Indiana, Pa. (14098), which had
merged Dec. 27, 1967, under charter and title of the latter bank (14098). The
merged bank at date of merger had

COMPTROLLER S DECISION

Indiana, with a population of 13,005, is the county
seat of, and the largest city in, Indiana County. The
city has been sharing in the county's recent economic
revival which is largely predicated upon the construction of three multimillion-dollar power plants. This
development promises to revitalize the area's coal industry, the area's single most important economic factor, and to create an upswing in the population trend
which has been declining in recent years. In addition
to the recently established and expanding industry,
other important economic factors include nurseries
(the area is known as the Christmas Tree Capital of
the World) and dairy farming.
The economic outlook for Blairsville and its population of 4,390 is favorable. This community has been
selected as the site for one of the proposed power
plants. Located only 15 miles south of Indiana, Blairsville expects to share in the county's economic development and benefit from the revitalization of its coal
industry.
The First National Bank in Indiana, with deposits
of $22 million, is the county's second largest bank. This
bank, which presently operates iom branches, has
demonstrated good growth. It competes with the
Farmers Bank & Trust Co. of Indiana, with deposits
of $18.7 million, with The Savings & Trust Co. of
Indiana, with deposits of $22.3 million, and with a
branch of the Homer City State Bank, with deposits
of $10.2 million.
The Conemaugh Valley Bank, which was chartered
in 1963 and presently operates one branch, has total

134

deposits of $3.3 million. Although the bank's growth
has been favorable, 80 percent of its deposits are time,
and half of these are represented by certificates. The
Blairsville area is dominated by the Blairsville National
Bank, with deposits of $13.1 million.
The amount of direct competition between the two
institutions is minimal as the distance between the
closest offices of the merging banks is 15 miles. The
charter bank's entry into Blairsville will stimulate competition by reason of its more aggressive and sophisticated services. It will serve the public more effectively
and efficiently than the merging bank does at present.
The merger will also resolve certain management problems of the merging bank and will strengthen the
capital structure of the charter bank.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
OCTOBER 31,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The head (and closest) offices of the two merging
institutions are approximately 15 miles apart. There
arc several intervening banking offices. In the circumstances, the amount of direct competition between
the two banks would appear to be limited.
The merger, if approved, would reduce the number of banks in Indiana County from 10 to nine, and
would result in some increase in concentration. The
merger would increase the resulting bank's share of
total deposits from 21.3 to 24.2 percent and its share
of total loans from 23.9 to 27.6 percent.

GOMMKRCIAI. & TNUUSTRTAI. BANK, FAYFTTEVUXE, N.C., AND NORTH CAROLINA NATIONAL BANK,
CHARLOTTE, N.C.
Banking offices
Name of bank and type of transaction
To be
operated
Commercial & Industrial Bank. Fayetteville, N . C , with
and North Carolina National Rank. Charlotte. N.C. (13761), which had
merged Dec. 29, 1967, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On August 29, 19G7, llie North Carolina National
Bank, Charlotte, N . C , applied to the Comptroller of
the Currency fur permisskm Lo merge with the Commercial & Industrial Bank, Fayetteville, N . C , under
die charter and with the title of the former.
Charlotte, with a population of approximately
230,000, is the county seat of, and largest city in,
Mecklenburg County. It is not only Noith Carolina's
largest urban aiea but is also one of the fastest growing cities in the southeastern United Stales. Although
the Charlotte area contains 550 industxial firms, the
largest eurployers aie transportation and distribution
companies.
Fayetteville, with a population of 47,106, serves as
the county seat of Cumberland County which has a
population of 148,000. Only 16 percent of the work
force of the county is employed in agriculture and
manufacturing. The reason for this unusual employment structure is the picsence of the Fort Bragg military complex which supports 54,000 soldiers and at
least an equal number of dependents. The county is
served by 27 offices of six banks for an average of less
than 5,500 persons per banking office, well under the
national average of 6,800 per office. Because of the
relatively heavy branching structure and the limited
manufacturing base in the county, the Fayetteville
metropolitan area, comprised of the county, has the
lowest ratio of IPC deposits per banking office of any
large North Carolina metropolitan area.
North Carolina National Bank, with IPC deposits
of $625 million, operates 78 offices. Although it is
often referred to as a statewide institution, it does not
opeiate in every section of the State. Its offices are
largely conciliated in or near the crescent formed
by Raleigh, Greensboro, and Charlotte in the center of
the State. Except for offices in Tarboro and Wilmington in the east and in Polk County in the west,
North Carolina National lacks representation in thf
remaining portions of the State. It operates no offices

$17, 370, 726
1,075,341,611

1,092,712,337

in Cumberland County—of which Fayetteville is the
county seat—nor does it have any office within a radius
of 50 miles of any of Commercial's five hranr.hp.Rj all
of which are located in the headquarters county.
The merging bank, with IPC deposits of $12-8 million, was organized in 1938. This bank, which has
shown favorable growth and has established five
branches, remains the smallest of the five banks in
Fayetteville. The other four banks, which are third,
fourth, sixth, and seventh in size in the State and have
a. total nf 19 oflRr.es within a 10-mile radius of Fayettevilie, are the First Union National Bank, Charlotte,
with deposits of $580 million. First Giri/ens Rank &
Trust Co., Smithfield, with deposits of $461 million,
Branch Banking & Trust Co., Wilson, with deposits
of $150 million, and the Southern National Bank of
North Carolina, Lumherton, with deposits of $103
million. This well banked area does not appear to be
open to de novo branching at this time.
Commerr.ia.1 ft Industrial Bark does not, as its name
would indicate, engage in the customary commercial
banking business. At the time of filing this application, 92 percent of its loan portfolio was devoted to
real estate mortgages and consumer financing; only
4.8 percent of its loans w^re of an industrial nature.
The merging bank appears to be more competitive
with savings and loan institutions than with the commercial banks now in the Fayetteville area. Even if
North Carolina. National Bank could enter this well
banked area by the de novo route, it is clear that it,
like the other commercial banks in Fayetteville, would
not be really competitive with the merging bank.
Since the closest offices of the participating banks
are over 50 miles apart, no competition now exists between them. This merger will not eliminate a banking
alternative for the residents of Fayetteville; it will, in
fact, give them another highly competitive alternative
with a broad range of banking services. On consummation, the resulting bank will ha^e gained but 0.2 percent of the State's total deposits.
135

Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
NOVEMBER 17,1967.
SUMMARY OF REPORT BY ATTORNEY GKNERAL

North Carolina National Bank ("NCNB"), the
second largest bank in North Carolina ($836.3 million
of total deposits), proposes to merge Commercial &
Industrial Bank ("C. & I."), the third largest bank
($13.8 million of total deposits) in Cumberland County, N.C. (Fayetteville SMSA).
NCNB, headquartered in Charlotte, operates 78
branch offices in all the principal sections of the State,
and it is authorized to operate four additional offices
in the Winston-Salem area during the tobacco season.
C. & I.'s head office and three of its five branch offices
are situated in Fayetteville, and its other two branches
are located in nearby Spring Lake.
The closest office of NCNB is about 59 miles from
any office of C. & I.; moreover, numerous offices of
other banks are located between the applicant banks.
Therefore, the merger would not appear to eliminate
any significant amount of existing competition between
the two banks.
Since North Carolina law permits statewide branch
banking, however, the merger would eliminate the
potential for substantial competition between the applicant banks by NCNB's establishment of a de novo
branch in Cumberland County. NCNB has demonstrated aggressive internal expansion by establishing
17 new branch offices in the last 6 yeais, and it has
pending applications to establish two additional
branch offices. In view of such performance and the
excej/tiunai ccunumic And pqf/aiafcsGZi gfG\f*Ji potcr/tial
Li OuuiU,Jciuii<i GUUJ/LJ (f/iuch i&x> tc/f/ateakui the
Fayetteville SMSA), it would appear that NCNB is

one of the most likely potential entrants into that
market.
Within Cumberland County, six banks operate 27
offices. C. & I. competes directly with three of the six
major branch banks in the State; neither NCNB or
the State's largest bank (Wachovia Bank & Trust Co.)
operates in the county. C. & I. operates six offices and
ranks third largest in the area, accounting for about
16 percent of Cumberland County total deposits and
about 14 percent of IPC demand deposits. The dominant bank in the area, First-Citizens Bank & Trust
Co. (total deposits from all offices $460.7 million),
controls about 48 percent of total area deposits, and
the two largest banks together account for about 66
percent of such deposits. Cumberland County is thus
quite a concentrated banking market.
C. & I. has grown steadily over the past 6 years;
both its loans and deposits have more than doubled
during that period; this growth record surpasses that
of NCNB during that timespan. C. & I.'s percentage
share of area deposits has remained relatively steady
during that period, although it competes directly with
the third, fourth, sixth, and seventh largest branch
banks in North Carolina. Accordingly, it is the view of
the Department that the proposed merger would involve a significant loss of potential competition in a
growing but concentrated banking market
Moreover, the proposed merger is part of a continuing trend of acquisitions and mergers by North
Carolina's largest commercial banks. This merger
trend has already had an adverse effect on potential
competition in the State hy inhibiting the establishment
of de novo branches hy the largest banks, thereby retarding the development of a more competitive bank
ing stnirhiTTp in Nnrth Carolina (a State in wfcask tfoe
fiira Ii^goct tvinV

total deposits).

THE LINCOLN NATIONAL BANK OF CHELSEA, CHELSEA, MASS., AND COMMONWEALTH NATIONAL RANK, BOSTON,

Banking offices
Name of bank and type of transaction

The Lincoln National Bank of Chelsea, Chelsea, Mass. (14087), with
and Commonwealth National Bank, Boston, Mass. (15399), which had
merged Dec." 30, 1967, under charter and title of the latter bank (15399). The
merged bank at date of merger had

136

Total assets
In
operation

$17,432,092
27,715,523
43, 796, 911

To be
operated

COMPTROLLER'S DECISION

On August 31, 1967, the Commonwealth National
Bank, Boston, Mass., wilh IPG deposits of $21 million, and The Lincoln National Bank of Chelsea, Chelsea, Mass., with IPC deposits of $14 million, applied to
the Office of the Comptroller of the Currency for permission to merge under the charter and with the title
of the former.
The participating banks aits located in Suffolk
County, one of the five counties constituting the Boston
Standard Metropolitan Statistical Area. The Boston
metropolitan area, which covers approximately 990
square miles, is second only to New York in density of
population. Within a 25-mile radius of Boston there
are 78 separate towns and cities with a 1965 estimated
population of 2.6 million. The 1960 Census of Manufactures indicated that there were 5,386 manufacturing
plants in the metropolitan area employing about
296,000 workers and generating an annual payroll of
close to $1.8 billion. Manufacturing accounts for 39
percent of the total business payroll generated by all
firms in the area.
Boston, where Commonwealth National Bank is located, constitutes the region's core and contains about
25 percent of the aitafs population. It is the commercial and distribution center of New England, a major
supplier of financial resources to the Nation*s economy,
and a woild leader in medical and nuclear science and
space technology. Although the economy of Boston
suffered a slowing down throughout the 1950's, since
1960, through a combination of public and private
efforts, Boston has dedicated itself to an ambitious program of rebuilding and revitalization.
Chelsea, with an estimated population of 28,000
is the home of The Lincoln National Bank of Chelsea.
It is primarily ail industrial and business center located in the center of the greater Boston metivpoiilan
area and less than 4.5 miles from the market centers
of Boston. After almost four decades of decline in population and industry, Chelsea, through the efforts of
civic, private, and public agencies, is becoming one of
the most rapidly developing ievidential and industrial
areas in the northeast.
The charter bank, organized in 1964, is headquartered in Boston and presently operates two branch
offices. The bank provides a fall range of services and
has established satisfactory coxiespoiideirt-bauk relations with many of the large banks in Boston and New
York. Emphasizing loans to individuals and small businesses, CGHsnonwealth National Bank lias played an
important part in the redevelopment of the metropolitan area. Occasionally, it has been unable to meet

the financial demands of its customers due to its limited
lending ability.
The merging bank, organized in 1934, has its home
office in Chelsea, and presently operates two branch
offices in Boston. It operates as a full-service commercial bank primarily for business enterprises and residents of the city of Chelsea. The bank is presently faced
with a management succession problem; one of its
executive officers is near, anH another past, retirement
age. Although the customers of the bank are primarily
small businesses and individuals, its lending ability is
such that at times it has heen unable to meet the credit
needs of its customers.
In the resultant service, area covering Boston and
Chelsea, there are 18 commercial barks operating a
total of 120 offices, with total assets of $5.4 billion, deposits of $4.7 billion and loans of $3 billion. In addition, there are 19 savings banks in the metropolitan
area with more than .55 offices in Boston and Chelsea
having assets of $8.3 billion, loans of $5.1 billion and
deposits of $7.3 billion. Competition is also provided by
27 cooperative banks, nine savings and loan associations, one industrial bank, 113 credit unions, and various factors and insurance companies.
Although the service areas of tbe participating banks
may overlap to some degree, the extent of competition hetween them is negligible Hue to the distance
between the offices of the hanks and the strong competition provided by other large area banks. Furthermore, the banks principally serve different areas and
classes of businesses and individuals.
Consummation of the proposed merger will not have
an adverse effect on overall competition as the resulting bank will still he less than one-fiftieth the size of
the largest bank in Boston and will hold less than 1
percent of total assets, loan.^ anH deposits of all commercial hanks in the Boston-Chelsea area. The effect
of the minimal increase in the relevant market position of the hanks in Boston and Chelsea will be to increase competition in the local service areas.
This merger, in addition to solving the management
succession pmhlem in the merging bank, will provide
the communities served by the banks with a bank better
able to serve the needs and conveniences of these everexpanding communities. The greater lending limit and
more extensive range of banking services to be made
available hy the resulting bank to the residents of this
area are clearly in the public interest.
Considered in the light of the statutory criteria, this
merger is jnHgerl to he \n the public interest and k,
therefore, approved.
NOVEMBER 29,1967.
137

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger would combine two threeoffice banks located in the adjoining cities of Boston
and Chelsea, in Suffolk County, Mass.
Since the distances between offices of the two banks
are not great (ranging from J^ to 5 miles), the proposed merger undoubtedly will eliminate some degree
of direct competition between them. Both banks are,
however, relatively small and face direct competition

close by from offices of the large Boston banks (the
First National Bank of Boston, National Shawmut
Bank, State Street Bank & Trust Co., and New England Merchants National Bank).
In the entire Boston metropolitan area—an area
which clearly overstates the realistic market of the
merging banks—the applicants together have only
0.17 percent of the total deposits. In Suffolk County
alone, they have only about 0.9 and 0.8 percent of
total deposits and IPG demand deposits.

CHESTRR-SCHROON-HORICON BANK, CHESTERTOWN, N.Y., AND GLENS FALLS NATIONAL BANK & TRUST CO.J
GLENS FALLS, N.Y.
Banhn g offices
Name of bank and type of transaction

Total assets
In
operation

Chester-Schroon-Horicon Bank, Chestertown, N.Y., with
and Glens Falls National Bank & Trust Co., Glens Falls, N.Y. (7699), which
had
merged Dec. 31, 1967, under charter and title of the latter bank (7699).
The merged bank at date of merger had
.-

COMPTROLLER'S DECISION

On September IS, 1967, the Chester-Schroon-Horicon Bank, Chestertown, N.Y., with IPC deposits of
$4.6 million, and the Glens Falls National Bank &
Trust Co., Glens Falls, N.Y., with IPC deposits of
$43.2 million, applied to the Comptroller of the Currency to merge under the charier and title of ihe latter.
Glens Falls, located approximately 50 miles north
of thft State capital of Albany, N.Y., has an estimated
pngmlatirm of 20,000, Tt is a diversified residential and
industrial dty which serves as the principal shopping
area for the eastern Adirondack region.
The charter hank was nrganiyed in 1851. It services
an area with a population in excess of 100,000 through
a network of six banking offices, viz., two in Glens
Falls, two in Fort Edward, and one each in Lake
George and South Glens Falls. None of its branches
are located more than 9 miles from its head office. Its
branch nearest to the merging bank is the Lake George
branch office, which is approximately 20 miles south
of the head office of the merging bank.
The merging bank, chartered in 1930, operates two
banking offices, including the head office in Chestertown, population 500, and a branch in Schroon Lake.
Through these offices, it services an area consisting
primarily of small resort communities in the Adirondack Mountains north of Lake George mid having an
estimated population of 10,000.
138

$5,691,565

60, 320, 330

66,027, 895

To be
operated

Consummation of the merger will increase rather
than lessen competition in the Chestertown area. The
resulting bank will be in a better position to compete
with the $694 million State Bank of Albany into Warrensburg, 13 miles south of Ghestertown, and the $160
million First Trust Co. of Albany in North Creek,
14 miles to the west, as well as the continued presence
of the Bolton office of the $80 million First National
Bank of Glens Falls, fl miles to the southeast. Competition in the. area is also provided by the National
Commercial Bank # Trust Co. of Albany and the
Marine Midland National Bank of Troy. In addition,
there arc numerous insurance companies, sales finance
companies, personal loan companies, and twu savings
and loan associations with assets of $16 million competing for the savings dollars of the area residents.
There is no competition between the two merging
institutions since the merging bank services an area
north of Lake George consisting principally of resort
communities while the charter bank services an area
south of Lake George consisting of residential, industrial, and resort communities between Lake George
and Saratoga.
Consummation of the merger will provide Chestertown and its immediate surroundings with a larger,
well-managed, aggressive institution. The resulting
bank will offer interest rates competitive with branches

of the Albany-based banks as well as trust facilities and
will expand installment lending not. presently offered
by the merging bank. In addition, the management
of the charter bank will infuse mom aggressive leadership into the Ghestertown office.
Applying the statutory criteria to the proposed
merger we conclude that it is in the puhlir. interest,
and the application is, therefore, approved.
NOVEMBER 21,

1967.

SUMMARY O? FFPORT BY ATTORNEY OENERAL

This prupused merger woald eliminate whatever
direct competition exists between these two banks
wliuse home offices are 20 miles apart and closest offices are 16 miles apart in a resort area of upper
New York State. Il would also increase concentration
in Warren County where the acquiring bank presently has about 34 percent of total deposits, and would
after the merger have about 38 percent.

LIVE STOCK EXCHANGE BANK, INDIANAPOLIS, IND., AND MERCHANTS NATIONAL BANK
INDIANAPOLIS, IND.

& TRUST CO. OF

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Live Stock Exchange Bank, Indianapolis, Ind., with
and Merchants National Bank & Trust Co. of Indianapolis, Indianapolis,
Ind. (869), which had
merged Dec. 31, 1967, under charter and title of the latter bank (869). The
merged bank at date of merger had

COMPTROLLER S DECISION

On September 18, 1967, the Live Stock Exchange
Bank, Indianapolis, Ind., with IPC deposits of $4
million, and the Merchants National Bank & Trust
Co. of Indianapolis, Ind., with IPG deposits of $271
million, applied to the Office of the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
Both participating banks are located in Indianapolis,
which is the county seat of Marion County and the
largest municipality in the State. Marion County,
which constitutes the service area of the charter bank,
has a population of about 850,000 and is situated
approximately in the geographical center of the State.
It is a highly industrialized area as is evidenced by the
1,100 manufacturing firms located in the metropolitan
area which produce 1,200 different products. The
labor force employed by the major industries and
commercial establishments in the area is 320,000 and
is expected to grow to approximately 430,000 by 1984.
The Merchants National Bank & Trust Co. of
Indianapolis, chartered in 1865, presently operates 26
banking offices throughout the greater Indianapolis
metropolitan area. The bank serves the downtown
Indianapolis business district, consisting almost entirely
of retail businesses, and, through its many branches, it
serves various industrial areas throughout the county.

To be
operated

$7, 280, 769

425, 198,271

432, 383, 502

It is a well managed institution offering full banking
services. With 17.7 percent of total loans and 17.5
percent of total deposits in its service area, it ranks
third in size among the six competing commercial
banks. These include, besides the participating banks,
American Fletcher National Bank & Trust Co., The
Indiana National Bank of Indianapolis, Peoples Bank
& Trust Co., and First Bank & Trust Co. Also operating
in the area are 15 savings and loan associations which
strongly compete for the savings dollar and real estate
mortgage loans and a number of credit unions, sales
finance companies, and personal loan outlets.
The Live Stock Exchange Bank of Indianapolis,
chartered in 1913, is a single-office bank located in
the Indianapolis stockyards district. Although located
in a highly industrial area, it does not serve the needs
of businesses in the area but specializes in serving the
needs of cattlemen and livestock commission agents.
This bank is the smallest bank operating in Marion
County. Because of its size and the specialized services, it does not compete in any material way with the
other banks operating in the county. In addition, the
bank presently faces a management succession
problem.
The addition of $4 million of deposits to the charter bank through this merger will have no effect on
overall competition. The resulting bank will continue
139

to rank as the third largest in the area, with 17.8 percent of total loans and 17.8 percent of total deposits;
an increase of only 0.1 percent in total loans and 0.3
percent in total deposits over what the charter bank
nrvur hnirlo Th? in.1*?"?? will eliminate c ncnccmpcti
tive institution and replace it with a full service institution capable nf meeting the diversified needs of a
number of business and individual borrowers located
in the highly industrial section of Indianapolis. Furthermore, the management succession problem in the
merging bank will be solved as capable officers in the
charter bank will be available to replace the merging
bank's chief executive officer when he retires.
Considered in the light of the statutory criteria,
this merger is judged to be in the public interest, and
is, therefore, approved.
NOVEMBER 13,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

This is a proposal to merge the Merchants National
Bank (30 offices with deposits of $329.3 million) and
the Live Stock Exchange Bank (one office with deposits
of $5.7 million). Both banks are located in Marion
O/M«4y xntWsr, the A
Ind.

Live Stock Exchange's clientele is presently limited
to the neighboring stockyard commission houses and
livestock feeders. Ten accounts provide two-thirds of
all d e m a n d balances a n d one-half of all loans. H o w ever, .ulVC utCCn. xxuS iilCiCuoCCi. ita i'n^L vspv^iauilg JU1V.U1HC

considerably over the past 5 years.
Live Stock Exchange is pieseiitly competitive with
Merchants. The closest offices of Merchants are V/%,
V/2, and 2l/% miles from Live Stock Exchange; in all,
eight offices of Merchants are within three miles of
Live Stock Exchange. While these offices offer a much
larger line of banking services than does Live Stock
Exchange, both banks compete for loans and demand
deposits. This competition would, of course, be eliminated by the proposed merger.
Banking in Marion County is highly concentrated.
The three largest banks account for over 95 percent of
total deposits in tlie cuunly. Within Marion County,
Tnd., thfi proposed merger wrmid increase Merchants
National's share of IPC demand deposits by 0*3 percent from 20.7 to 21.0 percent. In such a highly concentrated market, any further increase in the concentrwfrwvn rX hnricing iv*«/r«s in the hands ci tin laig«t
banks is likely to have an adverse effect on competition.

THE JEFFERSON BANKING CO., JEFFRRSON, OHIO, AND T H E NuK-rHKACTRim OHIO NATIONAL BANK, ASHTABULA,

Omo
Banking offices
Total assets

Name of bank and type of transaction

The Jefferson Banking Co., Jefferson, Ohio, with
and The Northeastern Ohio National Bank, Ashtabula, Ohio (5075), which
had
merged Dec. 31, 1967, under charter and title of the latter bank (5075). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On April 14,1967, The Northeastern Ohio National
Bank, Ashtabula, Ohio, with deposits of $32.5 million,
and The Jefferson Banking Co., Jefferson, Ohio, with
deposits of $10.2 million, applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the former. A hearing on
this application was held in Ashtabula, Ohio, on
July 25,1967.
Ashtabula, Ohio, the largest city in Ashtabula
County, is in the extreme northeast corner of the State,
140

$13,437,866
39, 733, 678
53,171,544

To be
operated

In
operation
2
7

56 miles east of Cleveland and 52 miles west of EriePa. The present population is about 24,800, a significant increase over the 1960 population. It is situated
in the center of a triangle formed by the cities of Cleveland, Pittsburgh, and Youngstown—all areas of 250,000 people or more. Ashtabula, lying just a few
miles south of Lake Erie, has one of the finest harbors on the Great Lakes and is the most active poit
on the St. Lawrence Seaway. It ranks number one
among all the Great Lakes ports in tonnage of general cargo moved. In 1966 it loaded for shipment over
11 million gross tons of iron ore. Its port facilities in-

elude railroad-operated docks, commercial docks with
open and covered storage, finger piers extending 2,000
feet, and gantry cranes for loading and unloading
heavy freight.
Jefferson, Ohio, with a population of 2,360, is die
county scat of Ashtabula County and the home office
of the merging bank. It is located in the southern
part of the county some 10 miles from Ashtabula.
Although the economy is primarily agricultural and
residential, some light industry has recently moved into
the area.
Ashtabula County, covering 706 square miles, is the
largest in the Stule. The county's population in I960
was approximately 100,000; 40 percent of which was
iionfami residents, 8 percent veere rural farm residents
and 52 percent resided in the urban areas. Industrial
plants in the county, numbering 154, manufacture a
variety of items such as electrical machinery, rubber,
chemicals, and paper. Some of the larger plants among
Ashtabula's 63 industries are Sherwm-Williams, Union
Carbide Metals, and True Temper. Retail sales in the
city of Ashtabula were $63 million in 1966, a $9 million increase over 1965.
The charter bank has seven offices located in the
northern pint of the county. The merging bank's only
branch is in Rock Creek, Ohio, which is 10 miles southwest of its muin office and 20 miles southwest of the
main office of the charter bank. The nearest offices of
the two banks are about 10 miles apart.
The present service area of the charter bank extends along the luke, including the cities of Cornieaut,
Ashtabula, Geneva, and Geneva on-the-Lake, and
south to Harpersfield. The county is divided by Interstate 90 which runs east and west. This toll-free, fourlane, divided expressway which connects with the New
York Thruway, creates a natural and reasonable separation between the service areas of the two banks.
Testimony at the hearing established that for all prao
tica.1 purposes there is uo existing competition between
the puilicipaliiig bunks. Witnesses testified that less
than 2 percent of Nortlieastern'e deposit and loan volume came from Jefferson's trade area and less than 1
percent of JeflWsuir's deposit and loan volume came
from Northeastern's trade area.
The merging bank, situated in an agricultural environment, has traditionally been a leader in the field
of farm loans and farm real estate financing. Due to
tills* expertise, it has engendered a loan demand from
the farm eermmemity that has absorbed most of its
lendable funds leaving little available for installment
or mortgage loans. The charter bank should be able
to minimize this problem by making funds available

from the more urban areas to serve the rural customers
of the merging bank.
Typical of many small country banks, The Jefferson
Banking Co. is faced with a severe management succession problem. It has suffered serious losses in experienced officer strength over the past several years
by death and retirement. The testimony reveals that
the president must personally handle every important
loan application and credit matter in view of the lack
of experienced personnel. The merging bank has been
unsuccessful in its attempts to hire general supervisory
talent. Due in large part to the management shortage,
certain problems have been created in the hank's loan
portfolio. The charter bank, on the other hand, is well
staffed with a balanced combination of youth, experience, and education. The Superintendent of Banks of
the State of Ohio testified regarding the management
and staffing problems of the merging bank and the
difficulty it faced in obtaining qualified officers because of the competition and higher salaries offered
in the nearby communities of Youngstown, Cleveland,
Akron, Canton, and Pittsburgh. Tt was also his view
that the management succession problem as well as
others could be readily solved by the merger of these
two banks. He further testified that h« halieved that
should the charter bank enter Jefferson by opening a
de novo branch in Jefferson rather than hy merger, it
would endanger the merging bank.
Consummation of this merger will clearly serve the
convenience and needs of the residents in and around
Jefferson. The lending limit of t.h« merging bank is
$75,000 as compared with $300,000 limit, of The Farmers National Bank & Trust Co. of Ashtabula which
maintains an office in Jefferson. The resultant bank will
have a competitive lending capacity. Trust services
will be offered by the resultant bank to the people in
and around Jefferson where there is a substantial demand since Jefferson enjoys the second highest per
capita income in the county. The resultant hank will
actively seek instpJlment loan burinem in the Jefferson
bank's trade area, which to data thft merging hank has
been unable to do; thus bringing it into competition
with the county's largest hank. The. merger would also
bring to the customers of the merging bank special
checking accounts, automobile, dealer floor-plan financing and Ohio Higher Education Assistance Commission loans. The receiving bank, following the merger,
would not only be large enough to consider the installation of computerized equipment, so important in
modern banking today, but large enough to retain
those of its customers whose credit demands appear
to be outgrowing the bank's capacity.

141

The Jefferson bank, because of the shortage in top
management, has been unable to devote the time and
the talent to community civic activities which it should.
The resulting bank, with an officer devoting full time
to business development, would alleviate this situation and promote the continued growth of Jefferson.
In view of the record before this Office and applying
the statutory criteria, we find that the benefits to the
convenience and needs of the community clearly outweigh the anticompetitive aspects involved in this proposal. Accordingly, the application to merge, being
in the public interest, is, therefore, approved.
OCTOBER 5,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger involves the second and third
largest (out of five) banks in Ashtabula County, Ohio:
The Northeastern Ohio National Bank ("Northeastern") and the Jefferson Banking Co. ("Jefferson
Bank").
Ashtabula County is a growing community in the
northeastern corner of Ohio, adjacent to Lake Erie
and western Pennsylvania; it is 40-65 miles from
Cleveland. The county had a population in 1960 of
93,067 which represented an 10 percent iiiLieast; uver
1950 and its population in 1966 was approximately
100,000.

The proposed merger would eliminate direct competition between Jefferson Bank's head office and the
three Northeastern offices in Ashtabula, 10 miles to
the north. It may also eliminate some direct competition with two of Northeastern's offices in Geneva,
which are approximately 20 miles from Jefferson.
There are no other banks lying between Jefferson and
either of the northern communities; and, moreover,
as the application states, "Being the largest metropolis
in Ashtabula County, Ashtabula City, to some extent,
draws customers from the entire county."
The proposed merger would also significantly increase concentration in the already concentrated Ashtabula County banking market. Northeastern presently holds 31.5 percent of the county's total bank
deposits; and its acquisition of Jefferson Bank would
add another 9.6 percent to its market share. Similarly,
the two banks, respectively, hold about 37 percent and
10 percent of the county's I PC demand deposits.
Thus, the proposed merger would reduce the banking alternatives in this growing county from six to
five, and result in a situation where over 75 percent
of the county's total bank deposits are in the hands of
the two largrst hanks* Thcwf«re, we conclude dial the
proposed merger would have a significant adverse effect on competition in Ashtabula County.

UNIVERSITY NATIONAL BANK, FULLERTON, CALIF., AND NEWPORT NATIONAL BANK, NEWPORT BEACH, CALIF.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

University National Bank, Fullerton, Calif. (15515), with
and Newport National Bank, Newport Beach, Calif. (15235), which had
merged Dec. 31, 1967, under charter and title of the latter bank (15235). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On October 6, 1967, the University National Bank,
Fullerton, Calif., with IPC deposits of $4.8 million,
and the Newport National Bank, Newport Beach,
Calif., with IPC deposits of $22.8 million, applied to
the Comptroller of the Currency to merge under the
charter and title of the latter.
Newport Beach, with a population of 40,000, is located 13 miles southeast of downtown Los Angeles
in the extreme southern part of Orange County. It is
a wealthy coastal community which will greatly bene142

$8, 151, 683
32, 683, 049
40, 834, 732

To be
operated
4
3

fit from the orderly development of the 35,000-acre
Irvine Ranch immediately inland from the town. In
addition to an annual population increase of 12,000
per year, the Irvine Ranch will contain the 4,000-acre
Irvine industrial complex to provide employment for
an estimated 16,000 persons.
The Newport National Bank was organized in 1964.
In addition to its head office, it has two branches plus
a prnding appliestion for an additional office. Its head
office of the charter bank is lucaled approximately 21
miles from the main office of the merging bank.

The University National Bank, chartered in 1965,
operates its main office and two branches within the
city of Fullerton. Located 26 miles southeast of downtown Los Angeles, Fullerton is primarily a residential
community with a present population of approximately
80,000. In Llie seivice area of the merging bank, which
is in the extreme northern portion of Orange County,
can be found a California state college with an enrollment of 9,000 and several industrial firms employing in excess of 48,000.
In the service area of the charter, competition is
provided by nine branches of the Bank of America
NT & SA, five branches of Security First National
Bank, four branches of United California Bank, two
offices of Crocker-Citizens National Bank, as well as
branch offices of five other local and regional banks.
Within the service area of the merging bank are 12
branches of the Bank of America NT & SA, seven
branches of the Security First National Bank, four
branches of the United California Bank, as well as
eight other branches of local and regional banks.
Consummation of the merger will increase rather than
lessen competition in the service areas of both banks.
Since each bank operates in a different section of
Orange County, there is no overlap of service areas.
Consequently, there appears to be no evidence of
common depositor or common borrower relationships.
The resulting bank will be able to compete more
actively with branches of the major statewide banks.

Consummation of the merger will enable the resulting bank to expand its travel services and possibly
justify the future granting of trust powers. The larger
bank will be better able to service the convenience and
needs of clients in its service area through resulting
increased depth in management, larger tending limits,
and added services.
Applying the statutory criteria to the proposed
merger we conclude that it is in the public interest, and
the application is, therefore, approved.
DECEMBER 1,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Newport National Bank, organized in 1963, with
present deposits of $25.6 million, proposes to merge
University National Bank, organized in 1965, with
present deposits of $6.3 million. Both these banks
operate in Orange County, a rapidly growing area
in southern California.
The closest offices of the merging banks are 18
miles apart in a heavily populated part of Orange
County. Between these offices of the merging banks
there are many offices of competing banks, including
the largest in California. The amount of direct competition between the merging banks would appear
to be limited. The two merging banks account for
less than 3 percent of Orange County's IPC demand
deposits; and, therefore, the effect of the proposed
merger upon banking concentration in Orange County does not appear to be substantial.

//. Additional Approvals
A. Approved, but in litigation.
PHILLIPSBURG NATIONAL BANK & TRUST CO., PHILLIPSBURG, N.J., AND SECOND NATIONAL BANK OF
PHILLIPSBURG, PHILLIPSBURG, N.J.
Total assets

Name of bank and type of transaction

The Phillipsburg National Bank & Trust Co., Phillipsburg, N.J. (1239), with
and The Second National Bank of Pbillipsburg, Phillipsburg, N.J. (5556), which had
Applied for permission to merge May 1, 1967, under the charter and with the title of the
former bank (1239). The application was approved Dec. 18, 1967. The pending merger
was challenged by Justice Department, Jan. 16, 1968, and is presently in litigation.

COMPTROLLER S DECISION

On May 1, 1967, the Phillipsburg National Bank &
Trust Co., Phillipsburg, N.J., with deposits of $20
million and the Second National Bank of Phillipsburg,
Phillipsburg, N.J., with deposits of $15.2 million, applied to the Comptroller of the Currency for permis-

$21, 529, 000
15, 867, 000

Banking offices
in operation
3
2

sion to merge under the charter and tide of the former. A public hearing was held on this application on
August 14, 1967.
Phillipsburg is located on the eastern bank of the
Delaware River in Warren County in northwest New
Jersey in the area frequently referred to as the Lehigh
143

Valley section. This city, covering 3.7 square miles, had
a 1960 population of 18,500 reflecting a 2.2 percent
decline from the 1950 census and 5,700 households
with an annual average income of $6,520. For many
years, Phillipsburg has been a railroad and industrial
center; five railroads now serve it, and five local industries employ 4,900 persons. This city is not only the
trading center for Warren County but is also the largest
city in the New Jersey area comprised of Warren,
Hunterdon and Sussex counties.
Warren County, which surrounds Phillipsburg, is
one of the last areas in the State to feel the impact of
the burgeoning economic and population growth that
has marked the eastern counties. Apart from Phillipsburg and its environs, Warren County is primarily
agricultural depending upon dairy farming and related
activities. The slowly increasing industrial activity of
the county is being centered around Phillipsburg, which
is economically linked to the other Lehigh Valley industrial towns of Allentown, Bethlehem and Easton.
Directly across the Delaware River from Phillipsburg is the City of Easton in Northampton County,
Pa. Easton, with a 1960 population of 32,000, is connected with Phillipsburg by two well travelled highway
bridges, one of which carries U.S. Highway 22 up the
Lehigh Valley. Because of the close proximity and ease
of travel between these cities, so much economic intercourse has developed that they must be treated as one
economic, unit. Some 3,552 Warren County, N.J., residents commute daily to jobs in Pennsylvania, while
3,432 Pennsylvania residents come into Warren Comity
to work. The commingled life of these two cities is
further demonstrated by the fact that Orr's retail department store in Easton derives 43 percent of its
charge customers from New Jersey, while its Lopatcong, N.J., store derives 37 percent of its charge customers from Pennsylvania* This close relationship is
further evidenced by the fact that the three Phillipsburg banks and the four Easton banks operate a common Hearing house for their mutual convenience. Further, fully half the 5,000 employees of Ingersol Rand,
Phillipsburg's largest employer arc Pennsylvarna
residents.
Because of the large daily movement of population
throughout this Lebigh Valley area with its consequent
social and economic integration, the U.S. Bureau of
the Census has designated it as a Standard Metropolitan Statistical Area. This statistical area has been
defined to embrace all of Lehigh and Northampton
counties in Pennsylvania and all of Warren County in
New Jersey. Because this definition includes the cities
of Allentown, Bethlehem and Easton in Pennsylvania
144

and Phillipsburg in New Jersey, it is referred to as the
Allentown-Bethlehem-Easton Metropolitan Statistical
Area. The applicant banks operate within this area
and compete with other banks located therein. For
example, Phillipsburg National's retail auto loan business is divided with 60 percent in Jersey and 40 percent
in Pennsylvania. Thirty percent of home improvement
loans are made to Pennsylvania customers.
The impact of this proposed merger is difficult to
assess because of conflicting definitions of the market
served by the applicant banks. In view of the location
of Phillipsburg in the eastern end of Lehigh Valley
and its close economic ties with Easton, Bethlehem and
Allentown farther up the Valley, it is proper to accept
the entire statistical area as the section of the country
in which these banks do business. The social and
economic interchange of these cities and the mobility
of so many of their residents throughout the entire area
supports this view. Radio, television and newspaper
companies operating in each of the component cities
accept the statistical area as an appropriate market
in solicitation of advertising. The four principal cities
of the SMSA are only 18 miles apart through the valley.
They are linked by Highway 22 and the new Interstate
78 as well as by two major railroads. Intercity rapid
transit via bus connects them within a 20-minute drive
and they share the same airport facilities.
The participating banks, however, suggest in their
application that the market they serve is not coexlensive
with the statistical area. They would exclude all of
Lehigh County except the City of Allentown, wliicli lies
on its eastern edge. In lieu of Lehigh County, they
would include the northwest corner of Hunterdon
County in New Jersey, because of its close proximity
to Phillipsburg.
At the hearing on this application, the banks' witness
further narrowed the geographic reach of the market
by a line running north from the midpoint between
Easton and Bethlehem to Nazareth, thence easterly,
to include Stockertown, to the Delaware River, up the
river to Belvidere, N.J., east again to encompass
Oxford Furnace, then south to the Warren-Kunterdon
county line and then westward in an arc about 5
miles south of Phillipstmrgh to the starting point. This
definition wa3 justified on the grounds that it contained
that section of the country from which the merging
banks derive 93 percent of their deposits and 85 percent
of their loans. This narrow definition of the market
served by the participating banks for the purpose of
assessing the competitive impact of this proposal is as
unrealistic as would be a market circumscribed by a
10-mile radius about Phillipsburg. Such a definition

serves only to point out where the merging banks now
do business with their present customers. It does not
truly indicate with what other banks outside the area
they are competing to get new customers and to retain
their present customers. The record clearly demonstrates that banks located in Allentown and Bethlehem
solicit banking business originating in Phiilipshnrg and
throughout Warren County. Fur this reason, the competitive force of this proposal will be viewed in the
context of the geographic market set forth in the
application. In addition, of course, hanks situated as
far away as Philadelphia, Newark and Nfrw York are
active in the area. For example, between 1961 and
19G6, the Howard Savings Institutirm of Newark and
the Morris Guunly Savings Bank of Morristmm took
134 mortgages in Warren County.
Within the competitive market described by the
applicant banks, there are 35 banks operating 57
offices, with aggregate deposits of $966.5 million and
loans of $566.5 million. The market varies little from
the Standard Metropolitan Statistical Area itself
which has 37 banks, 88 offices and $936 million deposits on June 30, 19G& The largest bank in this market is tlie First National Bank of Allentown with
deposits of $170 million. Two other banks in Allentown have deposits substantially in excess of the
combined total of the merging banks, Merchants National Bank and Lehigh Valley Trust Co., with deposits of $105.8 and $85.2 million, respectively.
Bethlehem also has two banks with larger deposits,
First National Bank, with $87.8 million, and Union
Bank & Trust Co. of Eastern Pennsylvania, with $70.4
million. Easton National Bank, one of the three banks
immediately across the river and one-half mile from
the merging institutions, would still have twice the
deposits. The resulting bank would rank eighth in
size iii the market; second in 'the twin cities of Easton
and Phillipsburg ahead of Lafayette Trust Co.,
Northampton National Bank and Phillipsburg Trust
Co., with $21, $19, and $11 million, respectively.
The Phillipsburg National Bank was organized as
a State institution in 1856 and was converted to a
National Association in 1865. This bank, which has
never been party to an amalgamation, operates its
main office in the old central business district of
Pliillipsbuig and a branch in the Tlillerest Shopping
Mall in Lopatcong Township in the new and expanding noilheast section of Phillipsburg. Its second
branch is situated in Alpha, a suburban community
2.5 miles south of Phillipsburg. This bank is relatively
small fox an active industrial eomnrnnity. It has not
been dUc tu idAm earnings cccGauennsMrte xritk its

growth, nor has it been able, on its limited earning
base, to develop the management reserves it now needs.
With its restricted resources, it has not been feasible
for this bank to modernize its operations to provide
the broader services possible through use of automatic
data processing techniques.
The Second National Bank of Phillipsburg was organized under its present charter in 1900. This bank,
whose deposits have increased from $5.9 million in
1947 to $15.4 at the end of 1966, operates its main
office 100 feel from the main offint of thr charter bank.
Although its one branch office is situated in the northeast sector of Phillipsburg on Route 24 directly opposite tlie Hillcresl Branch of the charter bank, the
two brandies serve different markets because the
heavy commercial traffic on Route 24 forms an effective barrier to pedestrian traffic. Like its proposed
partner in this merger, the Second National Bank
has not been able to grow with the community, to
modernize its operations, or to bolster its management
staff with adequately trained persons.
The third and only other bank in Phillipsburg is
the Phillipsburg Trust Company. This bank, with total
deposits of $11.3 million, has enjoyed marked growth
over the last 10 years. Whereas its deposits have increased by 107.4 percent, its loans have gone up 77
percent.
It cannot be doubted that the participating banks
compete with each other. The application states:
An analysis of the participating banks' business shows
that they are presently in direct competition against each
other in many ways as might be expected from their similarity in size and location of offices.

Because each bank operates its main office and a
branch office in such close proximity to the main
office and branch of the other, they must be deemed
to seive coextensive markets. The following tabulation
indicates that they compete in this market for the
same customers by offering substantially identical
banking services.
Tlie competitive posture of these banks vis-a-vis
each, oilier is further indicated by their lending capabilities; Fhillipsburg National Bank has a lending limit
of $115,000, whereas the Second National Bank may
lend up to $105,000.
Analysis of the table indicates the problems they face
as small banks in a growing industrial community
and explains their desire to merge despite the prevailing climate. Time and the expanding economy arecatching up with them. Time deposits, upon which
they pay high intereet coeU, constitute the bulk of thp
depssk bare of each. Neither has been «WP tn offset

145

Percent of total
Phillipsburg
National
Bank
Loans:
Real estate
Consumer installment
Single payment to individuals..
Commercial and industrial....
Other

Deposits:
Demand
Time

....

Second
National
Bank

56
24
10
8
2

76
10
6
3
5

100

29
71

23
77

100

these high deposit-interest costs to any significant degree through profitable commercial and industrial
loanfi. By mnrpsitrRting their 1C-*SMI in real estate murt
gagp/. and ronraimrr irntsllsncnt lenc&sg, lfe*y hove
encountered direct competition from the savings and
loan associations and from the credit unions, small
loan companies and sales finance corripatiies. Phillipsburg is an industrial city, but with only 8 percent
and 3 percent, respectively, of loan portfolio in the
commercial and industrial category, it is plain that the
subject inetitutionB arc not servicing those comrflu/iity
needs. They have testified that they do intend to compete in that market in the event that the merger is
approved.
Whether the existing competition between the participating banks which will be eliminated by this merger
is substantial or not depends upon the definition of the
product and geographic market to which it is referenced. Since several different geographic markets have
been suggested for assessing the competitive impact
of this merger, the following table, based on approximate total deposits and limited to cormrjiercial banks
as a product market, clearly demonstrates the relative competitive impact for that product market in each
suggested geographic area.

Suggested market area

City of Phillipsburg (3 banks). . .
Phillipsburg-Easton (7 banks). . .
Warren Co.-Easton-N.W.
Hunterdon Go. (16 banks). . . .
Modified Statistical Area of
Application (35 banks)

146

Total
deposits
(millions)

Percent
deposits

$45.6
147.8

75.7
23.3

278.0

13.0

966.6

3.6

Because it is manifest that the competitive impact
of any bank merger decreases as the number of competitor banks increases, it is incumbent on the interested
supervisory authorities to use utmost care in selecting
the real area from which competition derives, if the
public interest is to be truly protected. In the light of
the foregoing analysis of the economic complex of
this area of the country known as the Lehigh Valley
section, there is no warrant for assessing tills proposal
in the context of a market comprised only of Phillipsburg or of Phillipsburg and Easton. A broader market,
in tune with the realities of the economics of the area
and the facts of banking competition, is clearly needed
in this case. As counsel for the Department of Justice
argued in a similar situation "banks may be said to
be in competition if they are convenient alternatives
for a customer."
Even in the wider market suggested by the applirnnt^ it is ck?_r that this merger will have wjme udversc
rflWf* on banking C0KS$€titkrn. It wiU elimiiiutc one
hnnk from the Phillif«*?»3rg«Ea*fcGsa cumpltj* \\4JCNJ the
local retail customer may be said to have his convmienre alternatives, although its impact on liie intermediatc-siscd and the quite-large customers may be
concluded to be marginal at best. In the context of the
broader market, this adverse competitive effect is not
truly significant. The residents of Phillipsburg still
have ready access to frve other banking instiluliuns in
their town and in Easton. With 20 minutes driving
time, they can reach the larger institutions in Hunterdon County, in Bethlehem and in Allentown.
The savings and loan institutions with which these
banks most directly compete are 13 in number with
deposits of $68.4 million on December 31, 19GG. There
are 34 finance companies in the market offering direct
competition in tfec field of consumer financing, and,
as was testified to by an officer of Phillipsbuig National
Bank with 11 years experience in finance companies,
80 90 percent of finance company customers would
qualify for bank loans. More than 90 percent of the
business of these two banks is in consumer financing
and real estate loans. Yet, in these markets, commercial
banks play a minor role. Nationally, savings and loan
institutions and insurance companies account for the
bulk of real estate loans with commercial banks accounting for less than 20 percent of institutional purchases. The partial statistics available in this market
support the conclusion that the local pattern follows
the national trend.
Counterbalancing and clearly outweighing whatever
anticompetitive effects this merger will have are the
benefits which the resulting bank can contribute di-

rcctly and indirectly to the public it now serves and the
broader range of customers it seeks, competitively, U»
serve. By this merger the resources, deposits and capital
of the participating hanks will he ccmrbined to provide
rhe resulting institutirvn wflh a broader naming bnik*
and a greater capacity to meet and serve the convenience and needs of its actual and potential
customers.
The day has passed when, in an industrial community, a hank whir.h pays ils tup management $11,000
per year ran at.tra.rrt and retain talented people. Today,
the typical nianagemeiil Iraiuw;—in any business—
with a Master ofTCiisiritssAduiinisU-atiuu degree from
one of the better schools can command $11,000 to
start. Tf a bank cannot acjonuiuxlale the adjustments
to its salary schedules that these prices would entail,
it must, abandon the competitive struggle for excelLf.nr.f;. P«rrt banking is luu central to the economic wellbeing of a ccamnunrty Lu relegate it to the rag-tag, bottom of the barrel remanents in the interindustry
struggle for qualified management personnel. If a
community is too small to support more than one bank
which can compete on an approximately equal basis
with industry for qualified executive trainees, then it
should have but one bank. For, it is true in banking as
it is in all business that the prospect of a sound and
vigorous venture bears a direct, one-to-one correlation
to the relative capabilities of its leaders. While we are
aware mat many competing units in an industry is an
end to be desired, if we must chose between some
theoretical competitive injury and a sound banking
system, then this office opts for the latter.
The union of these banks will remove many of the
problems that each now faces as a small bank. The
resulting bank, with its grenter lending limit, will be
better positir/ned to bid frrr and sei ve industrial interests
moving into its home: office environs. As it increases its
Industrial and commercial loans, acquiring compensating balances in the process, ils earnings will improve. With improved earnings, it will be able to
acquire competent and capable senior management to
fill anticipated gaps at existing competitive prices. With
the combined capital of the participating banks, the
resulting bank can prudently undertake lo modernize
its operation by acquiring data processing equipment.
An obvious benefit to be derived from this merger is
in the area of trust services. At. this time, the charier
bank has only 31 trust accounts whose assets total
$1,734,000, and the merging hank has six accounts
valued at $631,500. While norther bank tan now afturd
a specialized trust officer tn provide services commen-

surate with the needs of area residents, their combined total affords greater justification for such a
specialist.
Tn summary, it appears that the Competitive impact
of this merger on the banking structure in this Leiiigh
Valley area will not be significant. Even its impact on
the Phillipsbtirg Trust Go. should be beneficial. Outweighing the competitive effects of this merger are
the henftfks to the public, including the managerial
and earning prospects to the resulting bank, which
will follow. As a $37 million institution, the resulting
bank will be able to overcome many of the handicaps
endured by the participating hanks because <jf their
size.
Having weighed the subject application to meige
against the statutory criteria in the context of the
market from which competition for banking business
is derived, it is concluded that this proposal is so clearly
in the public interest that its slight anticompetitive impact must be accepted. The application is, therefore,
approved.
DECEMBER 18,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger involves the two largest banks
in Phillipsburg, N.J.: Phillipsburg National Bank &
Trust Co. ("Phillipsburg National") and Second National Bank of Phillipsburg ("Second National").
Phillipsburg is a town of 18,500 located in Warren
County along the Delaware River, which serves as the
New Jersey-Pennsylvania boundary. Easton, Pa. (population 31,955) is just across the river less than a half
mile from Phillipsburg. There is a great deal of mobility among the people of New Jersey and Pennsylvania
in the Phiilipskirrer-TCaston area, both as to t?mploynit?nt
and changing «f residences; And lh.tr Ea&tuu banks ait:
said to derive about 25 percent erf their total deposits
from Warren County.
There are six hanks with a total uf 10 banking offices
in the TMiiliipsbiirg-Eastcm area. Three of these banks
with seven r/ffires are located m PliillipKljuig. The
merging hanks operate a total of five t»f these offices.
Phillinsrnrrg National and Second National are, respectively, the largest two banks in Piiillipsbui'g and
the third arid fifth Im^esl hanks in the combined
Phillipsburg-Easton area.
The proposed merger would eliminate substantial
direct competition between the two largest Phillipshiirg hank&, leaving only one oilier banking alternative
In the. town; and W would induce the nunrliei «yf banks
in the Phniipshurg-Rastori area, from six to five. It

147

would also incTYi&fsr. hanking rntir<intratic<ri in the «\>eaPhillipsburg National has 13.6 percent and Second
National has 9.9 percent of thr. $147 miliirir! in trrfal
deposits hdd hy thfi six hanks Yn the FfiiilipxhnrrgEaston area. AltrniAtrvdy, if thn rrnmfy in whirh both
banks ars located (Warrr.n dnriivry, N.J.) were found
to he thf. rcfcvsnt. lYwirkrt1, th* tw« hwrAs wopkl haw.
18.1 percent and 9.7 pr.rrftnt, respectively, of the $?8lO
million in IPC demand deposits held by the county's
10 banks.
Tf thr. rnkvwwit. lwwkrt. wf.re KapxnAeA to mrlude the

mnrh less signifkaM. We think, however, thai use «f
such a broad market—in which Pliillisburg is on the
fringe of the main population centers—undoubtedly
linrieeslfrtes ihe eofiooipciilive sigjirfk-Hiice \£ lA»s
for the oalrnaiy U&jrikiriu cu>lwi»?r in
Fiiiilipsbiirg Naflioiial and SeciKid Natiwial have,
/rtyeUivcdy, 2J3 ^"ritcin HUJ ID pHiceiil wf QIH $?6§.5
million of IPO dwiiyjid deposits ixi tills bivader
market.
,
In the circumstances, we believe that the proposed
may hdvc d vi^iiifiL^irl advcike effevi. iui L'ii^k-

r.rtr/e* AWrrArr/m T\r.tVArV<crr,J?fj*r/r, %M/rJ/t/rA TVfcfcw

politan Area, the applicants' market shares would be

broader Phillipsburg-Eastoii area.

B. Approved, but abandoned after litigation.
T H E KF.YXTONK TRTTST

A^ ANTI NATIONAL BA^^EC & TKU?T CVX OK CICNTIUZ.
YORK, PA.
Name of bank and type of transaction
Total assets

The Keystone Trust Co., Harrisburg, Pa., with
and National Bank & Trust C a of Central Pennsylvania, York, Pa. (694), which had
applied for permission to merge Mar. 22, 1967, under title and charter of the latter bank
(694). Application was approved Sent. 13, 1967, but was abandoned by the banks Dec.
19, 1967, after filing of antitrust suit by the Justice Department.

COMPTROLLER'S DECISION

On March 22, 19G7, the Keystone Trust Co., Karrisburg, Pa., with IPG deposits of $9.7 million, and
National Sank & Trust Co. of Central Pennsylvania,
York, Pa., with IPG deposits of $189 million, applied
to the Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter. A public hearing on this application was held
in Harrisburg, Pa., on June 8, 1967.
Harrisburg, the State capital with a population of
approximately 80,000 is strategically located on the
Susquehanna River in central Pennsylvania approximately midway between Philadelphia and Pittsburgh.
Harrisburg's population gain in the period, 1950 to
1960, exceeded 18 percent, one of the highest in the
country and the largest percentage gain in Pennsylvania. It is a billion dollar trade center and ranks
first in marketing among the 29 cities in the United
States with a population of 75,000 to 85,000. It is
endowed with an excellent network of highways and
airline*, Aiid the Pe^irj<Eyivani& and Readiuy laihu
The aiey., prlm-diily industrial, is engaged in
rramrnfartiim of goods mch »& slee^ wire, wnc
148

$11,586,000
221,930,000

Banking offices
in operation

1
20

food, and garments. In addition, agriculture contributes heavily to local employment and income,
The city of York, population 54,000, is located
about 25 miles southeast of Harrishurg in York County
and is about 40 miles north of Baltimore, Md. The
economy is supported primarily by diversified manufacturing and broad-based agricultural production.
Economic conditions are stable and prospects for
continued growth appear very favorable.
The National Bank & Trust Go. of Central Pennsylvania was founded as a State institution in 1845
and became a National bank in 1865. This bank serves
the York-Harrisburg area with a total of 18 branches,
six located in the immediate Harrisburg area, five in the
York area, and the remainder within close proximity
to the main banking location. It is a highly aggressive
bank with above-average earnings, sound management,
and very favorable future prospects.
Through its Harrisburg offices, the National Rank &.
Trust O(\ of rientrgi Pennsylvania rnmr»pfp«! vf»ry vig*
orow?ly with the Hauphin Deposit T"«$ f1", ^rhirh hue
total deposits of $168 million, nnd thrt Hnrrishurg Na
Rank And Tnwt G«., whtfth has total detf $137 inilliuii. Though [here, are sornft 12

smaller hanks operating in Dauphin Gmirrly, only the
Ilurrrrnftlstryvrn hank, w'rih a branch un the outskirts uf
ITarridiurg, and Thft Keystone Trust Go. In uptown
Ilarrishiirg ran prwsiMy be viewed as competitors. Iu
fart, hr/wever, these; small baJnks, because c»f their internal liniitftfrwvra^ rki f*cA IMASAHAL \\J thv vAun/nClrfim.
dswafeft r/f WuHfakmru and AiC UCA vkvv^d 5</iousfy
as significant rr/rnpnf'drug by the. three large lumkik The
real hanking rr/rrrpfttriKin in TTaiil-sbiug derives from
the much largfrr institutions in Pittsburgh and Philadrlprria, whir.h an?, rrmstantly canvassing the area in
search of new customers.
The Keystone Trust Co,, originally organized in
191fi,operate* its rrnly office in the city c»f Karrisburg
whmrA H. is tlift smallest erf four banks. It has experienced
moderately steady growth and U is pxvxenlly in sound
condition. However, the bank's earnings have d*>
r.ir.A.M.d iri thr. past yftAr rtnd futuic earning piu^prcla
do not ajifieai good. Although the bank's management
has been .successful in the pasi, present management
is at ur near retirement age, and management succession presents a problem.
The problems presently facing The Keystone Trust
Co. derive in part from its very conservative approach
to banking and in part from circumstances beyond its
control. A decade or so ago, when its present management was younger, The Keystone Trust did not
expand through branches because it was considered
too costly. Today, its single office, now totally inadequate, is located in a blighted and declining area. It
faces the prospect of being obliterated as urban renewal moves into the area or relocating in new quarters
at a cost of $600,000, which is well above its capacity.
The earning history of The Keystone Trust Co. in
recent years is a story of sacrifice. When competitive
pressures affected normal income, Keystone's management tried various devices to maintain earnings for the
protection of its shareholders. First, it maintained a low
salary scale for its senior officers equal to, or slightly
less than, that paid to the junior officers of the receiving
bank. Secondly, it shifted its assets to concentrate
heavily on tax-free municipal bonds. Recently it has
been selling funds for lack of loan demand in its area.
These efforts to maintain earnings have been bolstered
by Keystone's reluctance to replace its obsolete posting
machines and to employ young executives, both of
which are becoming increasingly expensive.
The management facet of The Keystone Trust Co.
is a worrisome problem for its director* and owners.
Ai picacut, rt» uic ici_vid shuwa, ilic baiik is lii^uiageu
by tlucc L$LkciJ. it* whdliuiAii^picudciii, wiiu iiiflii>
ipates xciiitMiieiii in it vcxy few yuan;

vnf-piesidexitj who JS a year closer to reihrfimftnt than
is llie juesideirt; a younger' vice-piftsident, wrin farwft
emiy retirement by leasum uf a progressing disability;
and a teller who grrves as trust officer 'm his spare
moments and Overtime hours. Efforts t.0 employ
jKTiuikgi i v * n . i 4 i « ^ » k i » l i k i i ^ n / i

thi.nAriAgr.iAr.irf

liJhiA

'irtitL liCC/i dli^i^Ailciiiiig; ihcii siAaly dLlfrfLfvAs rxdnn^

lliv- salnry now paid to the president. Tti arrede to these
dfjMMnds would necessitate an uveiatt upward adjirstineril of the payitJl for the present staff and wrmiri,
necessarily, cut snl>slaiitiHlly intn the «trnrngs <A Thft
Keystone Trust Co.
While there is no donlrt that The Keystone Trnrt
Co, is now a srmnil 1 nan It and will rorrtinnft to he. sound
as long as its present dedicated managfirnfimt anH staff
lenmins with ii, the fact is dear that. it. must enter into
union with another and larger haul* if its shareholdfrrs,
flr^trArtrnft, /iirfl rnrst.rirrirf.es AW: tn hr. jYrr/t.r.r.t.r.ri in the
fnttrre. FareH with tlrw rnftvrtahlft far.t, managftrnftnt,
with proper ccmcern far ihft wftlfan* nf its prftsemt staff,
has selerlftrf the i"ftr.ftiviflg hank as thft most r.rmTrpatihlft
partner for a union. Through this merger Keystone's
^resent staff will not only be retained by the receiving
hank, hn,t thp.ir salaries will hf. upgraded and they will
receive the benefits of a profit-sharing plan.
The Keystone Trust Go.'s ability to serve its customers is also being impaired by reason of its conserva:ivc operating policies and changing conditions. After
.50 years of operation, this bank has only $10 million
:
.n deposits and a lending limit of $100,000. Its loanto-deposit ratio is hclow 50 percent and it still docs
not make mortgage loans for more than two-thirds of
the valuation and extending beyond 15 years. Though
}t has not been able to attract any new industrial acrounts in this manufacturing area, it steadfastly refuses
TO advertise or to solicit aggressively. Many of its old
customers have moved from t.h« vicinity of this bank
as the community declined. Some old customers,
through loyalty to its staff, continue to do business
with it at great inconvenience to themselves. Of these
loyal customers, a few have been compelled to sever
connections with The Keystone Trust Co. when, as a
result of their own growth, their financial requirements
outstripped the capabilities of the bank.
Whatever competitive impact this proposal will have
will he in Harrisburg where the participating banks
operate offices but one block apart The anticompetitive
effect of eliminating The Keystone Trust Co. from the
Harrisburg banking scene, is more, illusory than real.
As long «.s thfi remaining r™idf,r.ts in the vicinity of
thtsc two c/flfi^r^ hwf. /m rqypr/rturfArftorhftftfflft hr&wftr.n
them, some cowujwitition, at lftast in theory, can be said

149

to exist. Though tins COM ipet.il ion will be eliminated by
the merger, its passing will not be sufficiently serious to
warrant the other risks which are foreseeable if thft
merger fails. All knowledgeable persons concede that
The Keystone Trust Go's contribution to banking
ciniipelUiuu in Hanislung is, at best, very slight and
is constantly declining. When this miniscule contribution to competition is measured against ihe total
competitive force of Harrisliiirg's three laige buries
and ifo manyfiVi4iiu<fiimUtutiuii*, not lu mcirfiort \he.
imp<ti4 of the FS'U*buigh and rhiLiildpliia l*ir*s it.
is clear that its preservation., in the circumstances of
this application, is warranted only by a stringent adhcicni-c lu fl dutliliifcli.e. dtvOtlftn lu ihu^CtkAl rr/ncepts of competition.
XTaving considered all the evident adduced in
support uf lliis api^Icitlicwi, h appears that thft banking
coinpetilion whirfi will be eliminated by this inmrgKT
is so slight that it is deariy outweighed by the piihKrfo
interest in hxvmg the irmrrmeiYfc prmMfrm ftf The
Keystone Trust C a resolved before they mature. Thft
application of these hanks to mergft is, therefore,
approved.
SEPTEMBER 13,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Rank & Trust Co. of Central Pennsylvania
("National Central") is the largest hank with operations centered in the Warn ^nrg-York-Lancaster region of south-central Pennsylvania. Six of its 10 offices
are in the city of Harrisburg and 32 percent of its

CITIZENS BANK OF MONROE, MONROE, N.Y.,

p
are derived from this city. Tt proposes to acquire Keystone. Trust. Co. ("Keystone"), a smaller
hank whose sole rrfficft is located in TTarrisbiirg.
There are four corrrrriftrrial banks in the city of
Narrishwg: (a) Dauphin Deposit Tnist Co., (b)
The TTarrishiirg National Bank & Trust Co., (e) National Central, and (d) Keystone.
Since Keystone's sole ofTim is hut erne block from
NHIIIH.IHI Orrir^l*s frfHr.ft rn dowrrrtowri TTan-isbiirg, it
I?. incvli<x1<1c thai the pinpr*rd mM^gr.r wniiM r.iirmri&feR
diic^t conq^ifttWir/n between the two ha/irVs for the type
of business now Acme by Keystone. This involves primarily peisoriHi and smaller business arrmrnts, for
wiiidi the lu* c/T OIK. (A four liKv^ Itfi^lr^g a1ifYn«feivrj
is apt to be particularly serious.
The proposed merger would also significantly incie-«se cuiiC«rrirHliiiii in the r.ity rif TTairkhurg as wf^l
ys in the I-Ta.riishuig Slflridaid Metroprilltan Area..
If the merger is rrmsumrnated, there will be only
ihi-ee 'j'jmmtficial banks IHLL in llie city of Hanisbuig.
National GenlralSi six Ilauisbuig c»(TIr-.es acrourrt. for
18.R percent of the total deposits of commercial banks
in Dauphin County, where Harrisburg is located.
Keystone accounts for 2.8 percent of such deposits.
In the Harrisburg Metropolitan Area as a whole,
eight National Central branches account for 12.4 percent of total deposits of commercial banks. Keystone's
sol? ofifke accounts for 1.9 percent, of such deposits.
We bdieve that the proposed merger would have
a significantly adverse died on competition, particularly in the city of Harrisburg.

AND COUNTY NATIONAL BANK, MIDDLETOWN,

Name of bank and type of transaction

Total assets

Citizens Bank of Monroe, Monroe, N.Y., with
and County National Bank, Middletown, N.Y. (13956), which had
applied for permission to merge May 2, 1967, under charter and title of the latter bank
(13956). Application was approved Nov. 17, 1967, but was abandoned by the banks
Mar. 12, 1968, after filing of antitrust suit by the Justice Department.

COMPTROLLER'S DECISION

On May 2, 1967, Citizens Bank of Monroe, Monroe, N.Y., with IPC deposits of $11 million, and
County National Bank, Middletown, N.Y., with IPC
deposits \& $10013 uuttiuu* appdied lo the Oflke of the
CtmfrtrrXW.T eX thr. flnirr.nry Un p^niiKSaluu lu inngc
under the charter and with the title of the latter. A
150

$12, 183, 000
121, 306, 000

N.Y.

Banking offices
in operation
2
22

public hearing was held on this application in the
Main Post Office in Middletown, N.Y., on July 27,
1967.
Both participating banks are headquartered in
Orangf. Owrrty, vrhirh lir^ in thft Third' DAflVing DI*.
fcrif.t. Thr/ngfc thft Grftftr law prmulk «iiy b«mk dijuiiL^rd
in the district to branch into any community in the

seven counties, which comprise the district, unless
the community is closed by reason of the presence of
the main office of another bank, the County National
Bank operates its 23 branches in only three of these
counties. It has 12 branches in Orange County, 10 in
Dutch ess County and one in Sullivan County; it has
no offices in Westchester, Rockland, Wester or Putnam counties. Under the law, the presence of Citizens
Bank in Monroe closes the city to branching by banks
headquartered elsewhere in the district.
The three counties in which County National Bank
operates are the northern suburbs of metropolitan
New York. Orange County lies on the west side of the
Hudson River contiguous to New Jersey's northern
border. To the southeast of Orange County, but still
on the west side of the Hudson River, is Rockland
County. On the east side of the river immediately
opposite Orange and Rockland counties are Dutchess,
Putnam and Westchester counties. Immediately to the
west of Orange County is Sullivan County.
Orange County, in which the County National Bank
has its main office and 12 branches, is comprised of
530,560 acres. The population of the county, which
has grown from some 152,000 in 1950 to 206,000 today, is principally centered in three cities, namely Middletown, with a population of 22,586, Newburgh, with
a population of 31,956, and Port Jervis with a population of 9,372. While the economy of the area depends principally on agriculture, tourism and industry
are making ever greater contributions. Though total
farm acreage in the county declined from 273,820
acres in 1954 to 202,089 acres in 1964, with the size
of the average farm increasing from 92.6 acres to 131.5
acres during the period, the value of farm products
rose from $20.8 million to $29.9 million.
Industrial activity in Orange County is steadily increasing. Nonagricultural workers in the county increased in number from 35,936 in 1961 to 41,546 by
the end of 1965. This total reflects 17,047 employed in
386 manufacturing concerns and 24,499 employed by
3,528 nonmanufacturing companies. Of the five leading industries in the county, apparel manufacturers
employed 3,607, textiles, 2,203, chemicals, 1,400, electrical machinery, 1,364, and food processing, 1,215. By
1963, there were 2,058 retail establishments located in
the county with annual sales of $283 million, an increase of $74 million over 1950 sales. Wholesale outlets numbered 278 in 1963 and reported total annual
sales of $175 million. There were, at the same date,
some 1,167 service establishments reporting sales of
$33.3 million. The estimated income of Orange County
has risen from $227 million in 1950 to $516 million

in 1964. Between 1960 and 1965, 4,464 new homes
priced between $15,000 and $50,000 have been constructed in the county. When the rapid transit lines of
metropolitan New York are extended into the county
as now planned, the residential growth of the area will
be vigorously stimulated.
Dutchess County, in which County National Bank
operates 10 branch offices, consists of 522,240 acres on
the eastern side of the Hudson River. The population
of this county has increased from 120,542 in 1950 to
176,008 in 1960. Today it is estimated at 213,650. The
economy of this county depends primarily on light industry, agriculture and residential areas. Of the manufacturing concerns situated in this county, one employs 5,000 persons, three employ between 1,000 and
5,000, and 33 others employ between 100 and 500.
The average manufacturer in Dutchess County employs
260 persons at an annual average wage of $7,000.
Personal income in the county increased from $203
million in 1950 to $435 million in 1962. The median
family income for 1964 was $7,875. Most homes are
owned by one or two families and are within a $15,000
to $50,000 price range.
Sullivan County, in which County National Bank
has one office, lies to the west of Orange County. The
663,040 acres, which comprise this county, are very
hilly and dotted with lakes making it an ideal resort and
vacation area. Its population, most of whom reside in
the eastern section of the county, has grown from
37,901 in 1940 to 45,272 in 1960, with a presently
estimated population of 48,667. The economy of this
county depends primarily on agriculture and tourism.
In addition to its famous dairly farms, Sullivan County
ranks 10th in the Nation for its production of poultry
and eggs. Its summer resorts have extended their operations to provide winter sports facilities. The gross income from tourism in 1962 was calculated to be $77
million, with $13 million paid out to hotel employees.
That banking competition in the Third Banking
District is very intense is demonstrated by an analysis
of these three counties. In Orange County, there are
16 commercial banks, operating 51 offices, five savings
banks, with as many offices, and 11 savings and loan associations. Only four of the commercial banks have
resources of $100 million or more to meet the growing
credit needs of the county's rapidly expanding economy; three are headquartered outside die county and
one, County National Bank, within the county. These
three are the $109 million Rockland National Bank,
Suffern, the $130 million Marine Midland National
Bank of Southeastern New York of Poughkcepsie, and
the $837 million County Trust Company of White
151

Plains. The other 12 commercial banks, which operate
17 brandies, range in asset size from $3 million to $40
million. The competitive vitality of the savings banks
in the area is demonstrated by the fact that both the
Goshen Savings Bank and the Warwick Savings Bank
are nearing $20 million, and the Middletown Savings
Bank has $52 million and the Ncwburgh Savings Bank
$82 million in deposits.
The banking needs of Dutchess County are now
served by 13 commercial banks operating through 37
offices, six savings banks, with seven offices and four
savings and loan association. County National Bank,
the only out-of-county bank, maintain 10 of the 37
offices as branches. The other 12 commercial banks,
doing business in the county, are headquartered there.
Nine of these banks, ranging in asset size from $3.5
million to $16.5 million, operate a total of 14 offices.
The remaining three banks, all located in Poughkeepsie,
operate 10 branch offices. They are the $32 million
Dutchess Bank and Trust Company, with three
branches, now approved as a subsidiary of the $2.3 billion Charter New York Corporation, the $17.7 million
Fallkill Bank and Trust Company, a subsidiary of the
$5 billion Bankers Trust New York Corporation, with
one branch, and the $130 million Marine Midland Naional Bank of Southeastern New York, with six
branches. The largest bank situated in this county is the
$177 million Poughkeepsie Savings Bank.
Sullivan County is well served by 19 offices of commercial banks competing to serve its residents, both
permanent and itinerant. Of this number, 12 offices
are operated by five banks, whose main offices are
located in the county. The largest of these is the $32
million Sullivan County National Bank with five offices. The other seven commercial banking offices in
the county are operated by four banks, with main
offices in Poughkeepsie, Middletown, Chester and
White Plains. Included in this latter group is the charter bank and the $19.6 million Chester National Bank.
Also included is the $130 million Marine Midland National Bank of Southeastern New York, a subsidiary
of the $3.8 billion ubiquitous Marine Midland Corporation, which also operates the $44 million Marine
Midland Trust Company of Rockland County in this
banking district and the $837 million County Trust
Company.
A very significant factor contributing to the intense
competition in this banking district and in these three
counties is the aggressiveness of the major Manhattan-based banks located 50 miles to the south. Although
it is difficult to make a quantitative assessment of the
competitive impact of these large metropolitan banks,

152

their contribution to local banking competition is a
reality that all alert bankers in the area recognize. The
excellent highways tying the Third Ranking District
communities to New York City, make it equally easy
for borrowers in the area to go to the Manhattan
banks and for the banks to send their representative to
potential customers in the area. The same highways
carry many area residents to work in the city where
they can conveniently do their banking. The ultimate
development of the rapid transit system into this northern suburban area will stimulate commuting, will promote the economic growth of the Third Banking District, and will promote the competitive thrust of the
Manhattan banks into the area.
The city of Middletown is located in the northwest
sector of Orange County and, with an estimated
present population somewhat in excess of 25,000,
rightfully claims to be the second largest city in the
county. It has now become the trading center for
some 110,000 persons living in the surrounding areas.
The city has been the principal beneficiary of the rapid
economic growth that has marked Orange County's
recent history.
County National Bank, organized in 1934 and headquartered in Middletown, has been striving to keep
abreast of the surging development in the county. It
is now a full-service bank operating offices in three
counties in the Third Banking District. Of its 22
branches, 10 were opened as de novo ventures and 12
were acquired through three mergers in the last 5
years. County National's policy of expansion through
merger constitutes its response to the competitive incursions being made into the area by the large New
York City and Westchester County banks. Through
its acquisitions, County National Bank has become a
competitive force in Orange, Sullivan and Dutchess
counties, while preserving locally oriented offices to
serve community needs more effectively. But for this
foresighted policy, County National Bank could well
be searching out a buyer at this time rather than facing up to, and grappling with, its keen out-of-county
competition.
Monroe is a village of nearly 4,000 population and
is located in the town of Monroe in the southeastern
section of Orange County. Because of its location in
the midst of many small lakes, which dot the region,
its permanent population is increased by the influx of
several thousand tourists each summer. As the population of the town grew by 89.5 percent between 1950
and 1960 and by 13.2 percent since 1960, home construction in the $15,000- to $35,000-range kept apace.
In 1965 alone, 117 homes were built Retail sales, like

the population, have increased from $6.8 million in
1958 to $9.7 million in 1963. Not only is this a 42 percent growth in retail sales in the town, but it means
that the town's share of retail sales in the county increased from 3 to 3.4 percent in the same period.
Citizens Bank, located in the village of Monroe, has
a virtual monopoly in this burgeoning market; State
law precludes another bank from opening a branch.
Despite its preferred position, its growth has not kept
apace with community demands for credit. Though it
has 73 percent of its deposits on loan, it does not have
sufficient deposits, nor capital, to satisfy all the locally
generated credit demands, particularly for mortgage
money. Its lack of loanable funds has forced it to forego
many desirable credits and lose its customers to banks
located in other counties and in New York City. The
very conservative attitude of the directors of this bank
preclude it from competing for deposits with the Chester National Bank and the Central Valley National
Bank, both of which offer more generous terms on time
and demand deposit accounts. The convenience factor,
which Citizens Bank offers to local residents through
its two offices, is offset by the more attractive rates and
terms of its competitors and the ease of banking by
mail.
There is no immediate management problem confronting Citizens Bank. The passage of time, however,
will create serious succession problems, unless capable
and experienced persons are found to assume the lead,
when the present executives retire. Finding such successors is a difficult task for a small bank; retaining
capable young successors in a small bank is a more difficult task. A conservative, nonaggresive board not inclined to encounter the competitive rigors of today's
banking market make it even more difficult to retain
capable, aggressive, young executives.
The effect of this merger, when consummated, upon
the competition between the participating banks and
upon competition in the Third Banking District will
be minimal. Though Citizens Bank in Monroe is only
14 miles southeast of County National Bank in Middletown, and both are located just off New York Route
17, they are separated by Goshen, with four banking
offices, and Chester, with two. The closest branches of
County National Bank to Citizens Bank are located in
Washingtonville, 7 miles north of Monroe, and Greenwood Lake, 9 miles southwest of Monroe. This geographical dispersion of banking offices explains the
low volume of deposit accounts with Monroe addresses
now held by County National Bank. Ignoring the fact
that many of these customers actually reside in or near
Greenwood Lake and assuming, in the face of known

competition by Chester National Bank and Central
Valley National Bank in Monroe, that all deposits
generated in Monroe rest in the participating banks,
County National Bank has only 2.4 percent of the total.
This is not now, nor likely to become, significant
competition.
The impact of this merger on banking competition
in the Third Banking District, or even in the three
counties where County National Bank now has offices,
is too slight to consider. The addition of Citizens Bank's
deposits to those of County National Bank will not
noticeably alter the fact that County National now
holds only 2.6 percent of the total commercial bank deposits in the district. Even this low figure ignores the
present competition deriving from other financial institutions competing in the district for savings dollars
and credit accounts.
The benefits to be derived from this merger are sufficiently significant to both the participating banks and
to the public to warrant its approval. By this merger,
the problems of Citizens Bank in competing for deposits, in meeting the credit demands of the residents
of Monroe, in providing competent management succession, and in providing adequate capital will be resolved. County National Bank's position in the district
will be strengthened to the extent its deposit and capital structure are enlarged and its branch system is expanded by Citizens Bank's contribution. This strengthened position of County National will enable it to
compete that much more effectively with larger banks
ever more aggressively canvassing the district. It implements the policy of County National Bank to provide a locally oriented institution capable of serving
the financial needs of district residents.
The residents of the town and village of Monroe
will be the immediate beneficiaries of this merger; long
range benefits will accrue to all within the Third Banking District. Upon consummation of this merger,
County National Bank will enter Monroe and bring
with it a broader range of banking services available
at highly competitive rates. It will, as in other communities it has entered, provide a more convenient
and congenial banking house in which to do business.
It will also provide a ready source of mortgage credit
to meet the demands of recent construction. By this
merger, Monroe will be open to branch banking,
thereby, giving the residents an alternative choice of
banking services; Marine Midland National Bank of
Southeastern New York has already received approval
to open a branch in Monroe if, and when, this merger
is completed. This new competition which will be
153

promoted by the merger will, if competition ever can,
serve the public interest.
In the light of the foregoing analysis, the merger
of the Citizens Bank into the County National Bank
will not have an adverse effect upon competition but
will, on the contrary, promote the public interest. The
application is, therefore, approved.
NOVEMBER 17,

1967.

SUMMARY OF REPORT BY ATTORNEY GENERAL

County National, the largest bank headquartered
in Orange County, N.Y., proposes to acquire Citizens
Bank, the 11th largest bank operating in the county.
County National Bank, with deposits of $108.4 million, has, since 1954, acquired eight other banks, having aggregate deposits of over $60 million, and 17
banking offices in Orange County and two adjacent
counties in southeastern New York.
Citizens Bank, with deposits of $11,037,000, has
three offices in three small communities in the rapidly
growing southeastern part of Orange County—the
incorporated Village of Monroe (population 3,763);
the unincorporated Town of Monroe (population
2,341); and the Village of Harriman (population

N E W JERSEY

812), about 2.6 miles southeast of the Monroe Village.
The last of these offices has been authorized, but not
yet opened.
The proposed merger would foreclose direct, competition between Citizens, as the sole, hank in Monroe,
and County National Bank, which operates (or has
authorized) branch offices in nearby communities to
the north, east, and south of Monroe. Moreover, it is
clear that the amount of existing competition between
the merging banks should substantially be increased,
when County National opens its authorized Highland
Mills branch (which would then become Citizens'
closest competitor), and, to a lesser extent, when Citizens opens its authorized Harriman branch.
The proposed merger would significantly increase
banking concentration in Orange County. It would
add about 4 percent to the 30 percent share of the
county's total deposits, which County National Bank,
the county's largest bank by a substantial margin,
already holds. It would also increase by about 3.6
percent thai baiikSs shaie of the covmt/s I PC demand
deposits.
In summary, we believe that the proposed merger
would have a signifiranlly adverse effect on banking
competition in Orange County.

NATIONAL BANK AND TRUST CO., NEPTUNE, N.J., AND BELMAR-WALT. NATIONAL BANK,
WALL TOWNSHIP, MONMOUTH COUNTY, N.J.
Name of bank and type of transaction

Total assets

New Jersey National Bank and Trust Co., Neptune, N.J. (15297), with
and Belmar-Wall National Bank, Wall Township, Monmouth County, N.J. (13848),
which had.
applied for permission to merge Sept. 22, 1967, under charter and title of the former bank
(15297). Application was approved Dec. 18, 1967, but was abandoned by the banks
Feb. 7, 1968, after filing of antitrust suit by the Justice Department.

COMPTROLLER S DECISION

On September 22, 1967, the New Jersey National
Bank and Trust Company, Neptune, Monmouth
County, N.J., with deposits of $105 million, and the
Belmar-Wall National Bank, Wall Township, Monmoutli County, N.J., with deposits of $26.7 million,
applied to the Comptroller of the Currency for permission to merge under the charter and with the title of
the former.
Monmouth County is located in central New Jersey
on its Atlantic coast. This county, the southernmost of
the tier of urbanized counties surrounding metropoli154

Banking offices
in operation

$113,713,000

28,717,000

tan New York, is within the "New York Standard Consolidated Area," an area designated by the U.S. Bureau
of the Census to include Bergen. Essex. Hudson, Monmouth, Middlesex, Morris, Passaic. Somerset, and
Union counties in New Jersey, and Dutches?, Nassau,
Orange5 Putnam, Queens3 Rockland, Suffolk, and
Westchester counties in New York and Fair-field
County in Connecticut Though Monmouth County
traditionally has been agriculturally oriented, because
of its location on the coast it has become an important recreational area attracting tourists from New
York City, 50 miles to the north, and Philadelphia,

60 miles to the west. The bulk of the county's growth
and economic development has been along its eastern
fringe in a corridor that parallels the coast. This corridor extends from the Navesink River on the north
to the Manasquan River on the south. It is 18 miles
long and 6 miles wide. The western half of the county
looks on this coastal region as the social, cultural,
commercial, and economic hub.
Monmouth County has changed considerably since
World War II. Around the key military installation at
Fort Monmouth, there has developed an important
electronics industry complex. Monmouth College has
grown rapidly making an ever greater contribution to
the economic life of the area. In compliment to
the partial industrialization of the county, 30 percent of
its work force is employed outside; it has become a bedroom area for technical and professional workers in the
New York-New Jersey megalopolis. In recent years, the
county as a whole has grown at three times the rate of
the average national growth. This rate of growth can
be expected to continue as the central and western sections of the county, still devoted to agriculture, provide
ample open land for future development.
The financial needs of Monmouth County are effectively served by 12 commercial banks through 72
offices, 13 savings and loan associations, and 16 credit
unions. Among the commercial banks, the Monmouth
County National Bank of Red Bank, with total deposits
of $161.2 million and 14 offices, is the largest. Central
Jersey Bank and Trust Company of Freehold, with
deposits of $144.7 million and 16 offices, is second in
size. If and when its proposed merger with the Sea
Bright National Bank is concluded, it will have 18
offices. The third largest bank is First Merchants National Bank of Asbury Park, which has deposits of
$112.6 million and operates 11 offices. The applicant,
New Jersey National Bank, ranks fourth in size in the
county. The $35 million Keansburg-Middletown National Bank is fifth and the Belmar-Wall National
Bank sixth. The remaining six banks in the county
have aggregate deposits of $75 million.
The New Jersey National Bank, with deposits of
$105 million, operates its main office and eight
branches in the northern sector of the coastal corridor.
Approval has been given to it to open two additional
offices in the same area. Its southernmost branch is
north of the Shark River, which separates it from the
branches of the Belmar-Wall National Bank. New Jersey National Bank, with ample management resources
in its capable corps of young and well trained executives, has enjoyed excellent growth in recent years as a
result of its aggressive policies. It offers a full range of
293-544—68-

banking services within the limits of its capabilities
many of which it pioneered in the county.
The Belmar-Wall National Bank, with total deposits of $25 million, operates three offices in the southern end of the coastal corridor south of the Shark River
in the municipalities of Belmar, West Belmar, and
Wall Township. None of these three offices is closer
than 2 miles to the southernmost office of the New
Jersey National Bank. This bank, dating from 1933,
has followed very conservative policies and has largely
confined its operations to serving persons residing
within the immediate vicinity of its offices. Though
its lending limit is almost $140,000, it has no commercial loans in excess of $50,000. Its total loan portfolio
represents less than 40 percent of deposits and is
limited, in the main, to mortgages and consumer installment loans. Thirty percent of the total loans are purchased from a Philadelphia Bank. Of its commercial loans, the five largest are to municipalities. The
conservative approach of this bank is also manifest in
its past failure to recruit, train, and have available a
cadre of young and capable men to replace its present
senior executives, who now contemplate retirement.
The president of the bank is 67 and in poor health;
his executive vice president and designated successor
is 61. Successor management for these capable bankers
is not available within the bank's ranks. The Board
has no other member under 70 years of age. Finally,
the physical facilities and equipment of the bank have
not kept pace with its growth.
One difficulty in assessing the competitive impact
of this merger, as in so many cases, arises from disagreement over the definition of the section of the country
to be considered. Because the economic activity of
Monmouth County is concentrated in the coastal corridor described above, it does not follow that this
merger must be viewed in reference to so limited a market. This coastal corridor is the mecca for the rest of
the county. Banks in all corners of the county, and
beyond the county, compete for the business of persons who travel to the coast. The largest banks in the
county, and the principal competitors to be considered,
are Monmouth County National Bank and the Central Jersey Bank and Trust Company, both with offices
as far away as Freehold, the county seat, 12.5 miles
west of the coast and near as a few thousand feet to
one or more of New Jersey National Bank's offices.
These factors, together with the New Jersey statutes
that restrict branch banking within county lines, indicate that Monmouth County is the smallest geographic area that may reasonably be considered in
evaluating this merger proposal.

155

Because of their location mklway belween New
Yor-k nil.y and Philadelphia and Uie rp.lat.ivft proximity of these cities^ it is difficult to ass^s precisely the
position these banks hold in their market aiea. Though
all bankers, and persons seeking banks' assistance, in
this section of New Jersey know with certainty that
mudi of the local business u«aj to banks located in
Philadelphia, Newark, and New York City, they cannot measure ihe volume* Tlus means that any evaluation of competition among these banks that rests on
reported figures of business done in the county is overstated, Finthftr overstatement results from failure lo
include within the Overall Competitive financial pinture
the volume of local business done by out-of-atea insnranr.fi companies, savings banks, savings and loan associations, credit uninris^ and finance companies.
The. competitive impart, of this merger iu MVmmonth County will be substantially more beneficial
than harmful. The central and dominant factor to be
evaluated in testing merger proposals in New Jersey is
the Stale banking law. In this Stalf^ no bank may
branch outside its home county, nor, within that county,
may it branch into a municipality where a bank already has a branch, except by merger. In theory, a
competitive- maiket system rewards the more efficient
company by permit ling it lo grow ihiough internal expajision, in reaction ly the increased demand for ils
S"ivk"^j attendant upon ciiMomcr satisfaction. In practice, in a xegulaled industry such as banking, lliis competitive dcsidcirfiiuii L<UI be fi ustirfted by lAw* degigtw.d
to protect other consideration* that the legislature
might deem more mipuitaut. Thu^ it is an operative
fact in our analysis of this merger that—absent
merger—there is no way in which either bank can
materially expand ils service area no matter how well
it serves the public.
There are 477.9 square miles in Moninouth County
oubiuc ilic fcdcicil facilities a! Foil MoiiuiOuili. Of
this total yxea, muiiicipy.hlies ;ep resenting only 2.0
square miles are not already preempted by the presence
of one or more banking offices. Of this total, New Jersey National Bank has facilities in municipalities comprising only 33 square miles, thus effectively limiting its branching capabilities to only 7 percent of the
land area of the cormty. Belrnar-Wall's branching area
is even smaller. The three largest banks in the comity,
on the other hand, have ronsiderably larger marketing
areas, 130, 94, and 145 square mileSj respectively.
Among commercial barnks hi the county, New Jersey
National Rank ranks fourth, with a June .9i03 13fi7 share
of 15.fi4 percent, and Relrnar-Wall Natirmal Rank
ranked sixth^ with a market share of 3.98 percent. To-

156

gether they would rank third, with a market share of
19.62 percent, Unresl.rid.ed use of these figures, of
course, subsumes the premise thai hanks throughout
the county are in competition with one another, or are
potentially so. This premise is false, Recanse rrf the State
branch hanking laws, the two hanks are not now and
can never he m competition for retail, neighborhood
hi i si ness. Nor are they now in competition for the interiYiediate-.«ii/.ed customer; H mar-kt-f. whiili "Relmar-Wall
National Bank plainly has refrained from entering.
That is not to say that it never could do so. Gnnceivahly, wilh the passing of ihe pifsent lioard and present
management, a new giOuri could decide to enrler this
arena. Such a course % however, neilher necessary, nor
Cveri likerly. With HO way to grow beyond ils present
Ura.iicli sysiem, it seems reasonable that a bank policy
that has been effective in. terms of si-ockholdei-s return
would not he aha.ndo/ieil and the risks of a maiitet. for
which the bank's deposit bust*, is quile thin would he
voluntarily assumed. The potentiality of competition
between these two banks, theiefore, is too remote and
speculative to support a "reasona.ble probability" of
a substantial lessening rrf competition.
By uniting the capabilities and capital of the participating hanks, ihe resulting New Jersey National
Bank will have a broader earningfoa.sewith which to
work. With the additional si/,e lo lie gained, it can compete more aggressively for the growing midjllr-.-sr/.e customers and expand ite range of services to the retail
tradr.. ThiY»ugJi thr. thivy. nr.w nffoc.\ in be arquimrt, the
New Jersey National Bank will make all the public
benefits it now offers its customers conveniently awAilahle to the present customers of the Bel mar-Wall National Bank. This merger will be publicly beneficial in
that it will further stimulate the already keen competition between the resulting bank and the larger banks
doing or seeking business in the county. With its adequate reserv™ of managv-Anmrrl personnel, it can assure
rontirming, efficient banking in Belrnar, West Beirnar,
and Wall Township.
This merger is not only consouaut with the public
policy as defined by the Slale of New Jersey in its
branching stalules, but will promote the convenience,
needs and public interest of the county. The New
Jersey National Bank, with an earned reputation for
"leadership and banking innovation^, has been a forceful &fi<\ progressive factor in piuiuuliiiu ih^ fCOIIOiuic
growth of the county. Through this merger, the deposits held by the Beirnar-Wall National Bank will he
more nxtensivdy utilized to meet ihe needs yf the iissiderrts of Morrmoirth County, rather than those of curtof-county honoweii5. The inci-eased earning base of

the resulting bank would speed the occasion for the
New Jersey Bank's adoption of in-house computers
to reduce costs; cost savings which the bank's past performance indicates will be passed on to its customers.
The computers will also permit an expansion of competitive services to the ultimate benefit of the community. The final benefit to be achieved by this proposal is the fact that the management problems now
confronting the Belmar-Wall National Bank will be
satisfactorily resolved without disruption in the local
banking structure.
Having considered all the competitive aspects of this
merger proposal, it is concluded that not only do its
procompetitive results overbalance its slightly adverse
effect on competition, but also that it clearly promotes
the convenience and needs of the community and is in
the public interest. The application to merge is, therefore, approved.
DECEMBER 18,1967.
SUMMARY OF REPORT OF ATTORNEY GENERAL

New Jersey National is the fourth largest of 12
commercial banks in Monmouth County and operates
eight offices in the eastern portion of the county. Belmar-Wall is one of eight smaller banks in the county
and operates three offices immediately south of those
of its prospective merger partner. New Jersey National
is already the dominant bank in this portion of Monmouth County.
The closest offices of the merging banks are less than
2 miles apart: the Belmar office of Belmar-Wall and

the head office of New Jersey National. Two other
branches of New Jersey National (at Asbury Park
and Ocean Grove) are also about 2 miles away from
this Belmar office. Both banks do a similar type of loan
and deposit business, and they would appear to be in
direct competition with one another, both for loans
and for demand and time deposits.
Within Monmouth County as a wholes—an area
which may overstate the relevant market here—the
proposed merger would increase New Jersey National's
share of total deposits from about 18.3 to 22.9 percent.
The resulting bank would be third largest in the county,
and the market share of the four largest banks in the
county would be raised to about 82 percent.
In Eastern Monmouth County, New Jersey National
is already the largest bank in terms of number of
offices; the proposed merger would enhance that position. The resulting bank would operate 13 offices in
this area (including the two approved, but unopened,
offices of New Jersey National), or 40.6 percent of
the total.
We believe that the proposed merger would have a
significantly adverse effect upon competition within
Monmouth County and, especially, its eastern part. It
would eliminate existing competition between New
Jersey National and Belmar-Wall and enhance New
Jersey National's existing strong position in the eastern part of the county. It would also significantly increase the already high level of concentration in the
county.

///. Disapproval
FIRST NATIONAL BANK OF CANTON, CANTON, OHIO, AND T H E CANTON NATIONAL BANK, CANTON, OHIO
Total assets

Name of bank and type of transaction

First National Bank of Canton, Canton, Ohio (76), with
and The Canton National Bank, Canton, Ohio (14501), which had
were denied permission to consolidate Dec. 18, 1967, under charter and title of the former
bank (76).

COMPTROLLER S DECISION

On October 11, 1967, the First National Bank of
Canton, Canton, Ohio, with deposits of $104.9 million, and the Canton National Bank, Canton, Ohio,
with deposits of $45 million, applied to the Comptroller of the Currency for permission to merge under the
charter and with the title of the former.

$122, 189,000
49, 584, 000

Banking offices
in operation
9
3

Canton, the county seat of Stark County, and its
satellite city of Massillon, constitute one of the State's
principal metal manufacturing centers. It is noted
for its iron and steel fabrications, roller bearings, farm
equipment, and petrochemicals. While the population
of the city has remained relatively stable in recent
years, growing from 108,401 in 1940 to 113,631 in

157

1960, its suburban development has been marked. The
Canton Standard Metropolitan Statistical Area, which
is coextensive with the boundaries of Stark County,
had a 1960 population of 340,345. Its population is
now put at 369,300. The rate of growth in this county
since 1950 has been slightly higher than the national
average. Median family income in Stark County is
now $6,358; an increase of 16 percent over State
averages. Between 1958 and 1963 the manufacturing
payroll in the county increased by 30 percent.
Stark County is located in the northeast quadrant
of the State. It is surrounded by eight contiguous
counties. To the north is Summit County which, with
the city of Akron, has a population of 513,569 and
Portage County, with a population of 91,798. On the
east is Mahoning County which, including the City of
Youngstown, has a population of 300,480 and Columbiana County with 107,004. Carroll County, with
20,857 residents, and Tuscarawas County, with 76,789, are south of Stark County. On the west are
Holmes County, with 21,591 population, and Wayne
County, with 75,497. The counties to the north and
east are heavily industrial, while those to the south
are less industrially oriented.
The competitive impact of this merger must be assessed not only in view of the market these banks serve
but also against other banks which lie beyond Canton
but seek to serve the same market. While the U.S.
Bureau of the Census has determined that Stark County is a socially and economically integrated unit for
statistical purposes, the applicant banks assert that
their actual market extends beyond the county lines.
They would include as part of their geographic market
Summit and Portage counties on the north and Carroll and Tuscarawas counties to the south; contiguous
counties to the east and west are excluded. This market,
comprised of five counties, would constitute a corridor
along a north-south axis with Canton in the center.
It is questionable whether this market definition by
the applicants is realistic.
On the basis of the interchange of wage earners between Stark County and its northern neighbors, applicant's market definition appears tenuous. As of the
1960 census only 0.6 percent of the labor force in
Summit County commuted to work in Stary County,
while only 1.9 percent of the employed in Summit
County resided in Stark County. It is not demonstrated
that the recent completion of U.S. Interstate Highway
77 between Canton and Akron has caused a significant
increase in the employee interchange figures. There is
158

even less reason for including Portage County, which
has no substantial new highway connections with Stark
County and which had only 1.9 percent of its labor
force employed in Stark County in 1960.
There appears to be sound reasons to include Carroll
County in the applicants' banking market. In 1960,
27.9 percent of the nonagricultural labor force of Carroll County was employed in Stark County. Since Carroll County has no cities or towns with as many as 3,000
persons, Canton, as the nearest large city, is a natural
trading center for Carroll County residents. A regular
trading center is as much a convenience location for
banking as are places of employment and residence.
Tuscarawas County stands in a different relation to
Stark County than does Carroll County and Summit
and Portage counties. In 1960, 8.9 percent of its working population commuted to places of employment in
Stark County. Whether this degree of worker interchange has increased since completion of Route 77 is
not shown. With two towns over 10,000 population
in Tuscarawas County—the contiguous communities of
Dover and New Philadelphia—there is less reason for
its residents to travel to Canton to trade than there is
for the residents of Carroll County.
Against the foregoing background, it appears proper
to confine the geographic market served by the participating banks to Stark and Carroll counties. The scant
evidence of social and economic integration of Summit, Portage, and Tuscarawas counties with Stark
County does not now warrant their inclusion in this
market. Within this geographic market there is keen
competition for both the savings dollar and the profitable loan.
Within Stark County are 15 commercial banks,
operating 47 offices and controlling total deposits of
$505.7 million. While there are no mutual savings
banks or industrial banks, there are 13 savings and loan
associations with 23 offices accounting for aggregate
assets of $442.4 million. Some 44 credit unions and 66
finance company offices also compete within the county
for small and personal loans and sales-financing services. The overall figures indicate that only 15 percent
of the savings dollars in the county reside in commercial banks.
Of the 17 commercial banks operating in Stark and
Carroll counties, five are headquartered in Canton,
two in Massillon, two in Alliance and the remaining
eight are dispersed in small communities throughout
the area. In Canton, the Harter Bank & Trust Co.,
with total deposits of $123.6 million and 10 offices, is
the largest. The charter bank is second in size. The

Peoples-Merchants Trust Co., with deposits of $82.7
million in its four offices, is third in rank. The merging
bank is fourth in size with the First National City
Bank of Alliance, whose deposits are $43 million, fifth.
The Dime Bank, which has deposits of $23.4 million
in two offices, is sixth. The seventh-ranked bank is in
Massillon and the eighth is in Alliance. All the other
banks in the two counties have $10 million or less in
deposits.
The First National Bank of Canton, under whose
charter this merger is proposed, operates nine offices.
Six of these offices are in or near Canton. The other
three are dispersed: one is located in the northernmost
area on the main highway to Akron, one is in Minerva
in the southern sector and adjacent to the Carroll
County boundary line, and one branch is in Carroll
County. The Canton National Bank operates three
offices in Canton. Both of these banks, whose main
offices are located side by side in the central business
district of Canton, have obtained approval to open
new branch offices in the Belden Village Shopping
Center located 5.5 miles northeast of their main offices.
While some differences between the participating
banks have developed with respect to the classes of
customers served and size of accounts, both banks
compete in rendering substantially the same services.
First National Bank has 49 percent of its deposits on
loan and Canton National Bank has 42 percent on
loan. Of the total loans outstanding in these banks,
the greatest variation appears among the commercial
and industrial loans and consumer installment loans.
First National Bank has 44 percent of its loans in
the commercial and industrial category, whereas Canton National Bank has only 11 percent. Consumer
installment loans account for 16 percent of First National Bank's total loans but 51 percent of Canton
National Bank's. Though these figures reflect an orientation in each bank toward a different class of customer (a consequence of their size), they also indicate
that the same service is available at each bank.
On the basis of demand deposits alone, this merger
appears to be anticompetitive. As of June 30, 1966,
total IPC demand deposits in Stark and Carroll counties were $160 million. The merging banks together
had approximately $50.9 million of these deposits, or a
market share of 31.75 percent. This appears sufficiently
large to condemn the merger as substantially lessening
competition.
The anticompetitive effect of this merger must condemn it unless the benefits which will redound to the
public interest on its consummation redeem it. Both

participating banks are sound, viable institutions.
Each has grown apace with the city. The First National Bank has grown 134 percent between 1950 and
1963, while the Canton National Bank, during the
same period, grew 144 percent. However, growth
through a merger that does little more than deny a
community a desirable banking alternative is not in
the public interest. Both banks have capable, aggressive, and well-esteemed senior management teams.
Though their successor management may appear
somewhat thin, they are of a size and suitably located
to secure promising young men at attractive salaries.
While Canton National Bank does not now offer all
the services available at the First National Bank, there
is no indication in the record that the public is thereby
deprived.
Having weighed this merger against the statutory
criteria, this Office concludes that its effect will be
substantially to lessen banking competition in the Canton market without producing sufficient countervailing benefits for the public's convenience and needs to
redeem it. The application to merge is, therefore,
denied.
DECEMBER 18,1967.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger would unite the second ("First
National") and fourth ("Canton National") largest
banks in Canton, Ohio, and in Stark County (the
Canton SMS A). The resulting bank would hold about
40 percent of total deposits, demand deposits, and total
loans held by banks located in the city of Canton.
The main offices of the merging banks are both
located close by on the same street in Canton, Ohio.
The proposed merger would clearly eliminate considerable direct competition between these neighboring
banks which do similar types of banking business (although in somewhat different proportions), within the
same market. More generally, it would eliminate from
the Canton market a bank whose potential capacity
for future growth and competitive vigor now seems
especially promising (as indicated, by the fact that its
earnings have grown by 60 percent between 1962 and
1966).
Banking concentration, already high in the city of
Canton and in Stark County, would be substantially increased by the proposed merger. Within Stark County,
First National is the second largest bank, in terms
of total deposits, with a 21.4-percent share; and Canton National is the fourth largest, with a 9-percent

159

share. The merger would create a bank with 30.4 percent of total deposits and 29.6 percent of loans in
Stark County. The top five banks in the county prescntly possess 79.8 percent of total deposits, and would
after the proposed merger control 04.0 percent. Within
the city of Canton, the market shares would be even
higher.

160

We conclude that the proposed merger would eliminate substantial direct competition between the two
banks, and would significantly increase the already
high levels of concentration in commercial banking in
Canton, Ohio, and Stark County (the Canton SMSA).
The effect of the merger upon competition would be
significantly adverse.

APPENDIX B

Statistical Tables

Statistical Tables
Table No.
B-l
B-2

B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-l 2
B-l3
B-l 4
B-l 5
B-l 6

B-l 7
B-l 8

Title

Page

Comptrollers of the Currency, 1863 to the
present
Administrative Assistants to the Comptroller of
the Currency and Deputy Comptrollers of the
Currency
Regional Administrators of National banks
Changes in the structure of the National banking
system, by States, 1863-1967
Charters, liquidations, and changes in issued
capital stock of National banks, calendar 1967.
Applications for National bank charters, approved and rejected, by States, calendar 1967..
Newly organized National banks, by States,
calendar 1967
State chartered banks converted to National
banks, calendar 1967
National banks reported in voluntary liquidation, calendar 1967
National banks merged or consolidated with
State banks, calendar 1967
National banks converted into State banks,
calendar 1967
Purchases of State banks by National banks,
calendar 1967
Consolidations of National banks, or National
and State banks, calendar 1967..Mergers of National banks, or National and
State banks, by States, calendar 1967
Mergers resulting in National banks, by size of
acquiring and acquired banks, 1960-67
Domestic branches entering the National banking
system, by de novo opening, merger or conversion, by States, calendar 1967
Domestic branches of National banks closed, by
States, calendar 1967
Principal assets, liabilities, and capital accounts
of National banks, by deposit size, year end
1966 and 1967

162

163

164
165
166
167
168
169
170
170
171
171
172
172
173
179

180
188

190

Table No.

Title

B-l 9 Dates of reports of condition of National banks,
1914-67
B-20 Total and principal assets of National banks, by
States, June 30, 1967
B-21 Total and principal liabilities of National banks,
by States, June 30, 1967
B-22 Capital accounts of National banks, by States,
June 30, 1967
B-23 Total and principal assets of National banks, by
States, December 30, 1967
B-24 Total and principal liabilities of National banks,
by States, December 30, 1967
B-25 Capital accounts of National banks, by States,
December 30, 1967
B—26 Loans and discounts of National banks, by States,
December 30, 1967
B-27 Income and expenses of National banks, by
States, year ended December 31, 1967
B-28 Income and expenses of National banks, by deposit size, year ended December 31, 1967
B-29 Capital accounts, net profits, and dividends of
National banks, 1944-67
B-30 Loan losses and recoveries of National banks,
1945-67
B-31 Secur i ties losses and recoveries of National banks,
1945-67
B-32 Total assets of foreign branches of National banks,
year end 1953-67
B-33 Foreign branches of National banks, 1960-67....
B-34 Assets and liabilities of foreign branches and
military facilities of National banks, December 30, 1967: consolidated statement
B-35 Assets and liabilities of National banks, date of
last report of condition, 1950-67
B-36 Common trust funds, by States, 1966 and 1967..
B-37 Trust assets and income of National banks, by
States, calendar 1967

Page
191
193
194
195
196
197
198
199
200
209
212
213
214
214
215

215
216
217
218

TABLE

B-l

Comptrollers of the Currency, 1863 to the present
No.

Name

McGuUoch, Hugh
Clarke, Freeman
Hulburd, Hiland R
Knox, John Jay
Gannon, Henry W
Trenholm, William L . . .
Lacey, Edward S
Hepburn, A. Barton....
Eckels, James H
Dawes, Charles G
Ridgely, William Barret,
Murray, Lawrence O . . .
Williams, John Skelton.
Crissinger, D. R
Dawes, Henry M
Mclntosh, Joseph W . . .
Pole, John W
O'Connor, J. F. T
Delano, Preston
Gidney, Ray M
Saxon, James J
Camp, William B

Date of
appointment
May
Mar.
Feb.
Apr.
May
Apr.
May
Aug.
Apr.

Jan.

Oct.
Apr.
Feb.
Mar.
May
Dec.
Nov.
May
Oct.
Nov.
Nov.

Date of

State

T€St£TlQ,tl OH

9,1863 Mar. 8,1865
21,1865 July 24, 1866
1,1867 Apr. 3, 1872
25, 1872 Apr. 30,1884
12,1884 Mar. 1,1886
20,1886 Apr. 30, 1889
1, 1889 June 30, 1892
2, 1892 Apr. 25, 1893
26,1893 Dec. 31, 1897
1, 1898 Sept. 30,1901
1, 1901 Mar. 28,1908
27, 1908 Apr. 27,1913
2,1914 Mar. 2,1921
17, 1921 Apr. 30, 1923
1,1923 Dec. 17, 1924
20, 1924 Nov. 20,1928
21, 1928 Sept. 20, 1932
11,1933 Apr. 16,1938
24, 1938 Feb. 15,1953
16, 1953 Nov. 15, 1961
16,1961 Nov. 15, 1966
16, 1966

Indiana
New York
Ohio
Minnesota
Minnesota
South Carolina
Michigan
New York
Illinois
Illinois
Illinois
New York
Virginia
Ohio
Illinois
Illinois
Ohio
California
Massachusetts
Ohio
Illinois
Texas

163

TABLE
Administrative

Assistants

B-2

to Uie Comptroller of t/ie Currency and Deputy Comptrollers of the Currency

No.

State

Dates of tenure

ADMINISTRATIVE ASSISTANTS TO THE COMPTROLLER

Larsen, Arnold E
Faulstich,
Albert J"
"
Chase, Anthony G
Wickman, Wayne G

Dec. 24, 1961
July
2,
_ - lg62
July 21,
Feb. 27,

[uly 1,1962
[uly 18,1965
^eb. 25,1967

Nebraska
Louisiana
Washington
Texas

DEPUTY COMPTROLLERS OF THE CURRENCY

Howard, Samuel T
Hulburd, Hiland R
Knox, John Jay
Langworthy, John S
Snyder, V. P .
Abrahams, J. D
Nixon, R. M
Tucker, Oliver P
Coffin, George M
Murray, Lawrence O
Kane, Thomas P
Fowler, Willis J .
Mclntosh, Joseph W
Collins, Charles W
Stearns, E. W
Await, F. G
Gough, E . H
Proctor, John L
Lyons, Gibbs
iErentiss, William, J r
Diggs, Marshall R

28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44

Upham, C. B
Mulroney, A. J
McCandless, R. B
Sedlacek, L. H
Robertson, J . L
I; Hudspeth,J. W
Jennings, L. A
^Taylor, W. M
Garwood, G. W
Fleming, Chapman C
Haggard, Hollis S
Camp, William B
Redman, Clarence B
Watson, Justin T
Miller, Dean E
DeShazo, Thomas G
Egertson, R. Coleman
Blanchard, Richard J
Park, Radcliffe
Faulstich, Albert J
Motter, David G
Gwin,JohnD

164

Aug.
Jan.
Apr.
Jan.
Jan.
May
Mar.
Mar.
Aug.
Tune
Mar.
Feb.
Dec.
Tune
Nov.
Feb.
Oct.
Tan.
Tan.
"[an.
Sept.
Sept
Dec.
Aug.
Mar.
Sept.
Feb.
Aug.
May
Apr.
Dec.
Aug.
Aug.
Nov.
Oct.

1, 1865
31,1867
24,1872
3, 1886
3, 1887
25, 1890
16,1893
11,1896
31, 1898
27,1899
2, 1923
14, 1927
19, 1924
30, 1927
30,1928
15, 1936
16,1941
23, 1933
15,1938
15,1938
30,1938
30,1938
31, 1948
31,1941
1,1951
30, 1944
17, 1952
31,1950
16, 1960
1, 1962
31,1962
31, 1962
3, 1962
15, 1966
26, 1963

New York
Ohio
Minnesota
New York
New York
Virginia
Indiana
Kentucky
South Carolina
Mar. J
New York
Sept.
Dist. of Columbia
J June 5
Indiana
Illinois
Illinois
Virginia
Maryland
Indiana
Washington
Georgia
California
Texas
California
Iowa
Iowa
Iowa
Nebraska
Nebraska
Texas
New York
Virginia
Colorado
Ohio
Missouri
Texas
Connecticut
Ohio
Iowa
Virginia
June 30, 1966 Iowa
Massachusetts
:. 1, 1964 ' J u n e l't "1*967 ' Wisconsin
Louisiana
19, 1965
1, 1966
Ohio
Mississippi
21, 1967

TABLE

B-3

jional Administrators of National
Region

Name

Headquarters

Elmer J . Peterman

Boston, Mass

2
3
4
5

Charles M. Van Horn
R. Goleman Egertson
John W. Shaffer, Jr
Page Cranford

New York, N.Y
Philadelphia, Pa
Cleveland, Ohio
Richmond, Va

6
7
8

Joseph M. Ream
Joseph G. Lutz
William A. Robson

Atlanta, Ga
Chicago, 111
Memphis, Tenn

9
10
11
12
13
14

banks
States

Douglas T. Bushman

Minneapolis, Minn

Paul L. Ross*
John R. Burtf
Norman R. Dunn
John R. Thomas
Kenneth W. Leaf
Arnold E. Larsen

Kansas City, Mo

Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont.
New Jersey, New York.
Pennsylvania, Delaware.
Indiana, Kentucky, Ohio.
District of Columbia, Maryland, North Carolina,
Virginia, West Virginia.
Florida, Georgia, South Carolina.
Illinois, Michigan.
Alabama, Arkansas, Louisiana, Mississippi,
Tennessee.
Minnesota, North Dakota, South Dakota, Wisconsin.
Iowa, Kansas, Missouri, Nebraska.

Dallas, Tex
Denver, Colo
Portland, Oreg
San Francisco, Calif

Oklahoma, Texas.
Arizona, Colorado, New Mexico, Utah, Wyoming.
Alaska, Idaho, Montana, Oregon, Washington.
California, Hawaii, Nevada.

*Retired on Jan. 13, 1968.
fAppointed to succeed Mr. Ross.

165

TABLE

B-4

Changes in the structure of the National banking system, by States, 1863-1967
12 U.S.C. 214

15, 646

689

309

2,819

6,721

273

4,758

Alabama
Alaska
Arizona
Arkansas
California
Colorado...
Connecticut.
Delaware
District of Columbia
Florida

201
8
32
163
602
265
136
32
37
287

4
0
1
1
20
5
11
0
8
2

2
0
0
1
27
0
6
0
0

45
0
6
39
66
56
7
1
7
43

62
2
21
55
389
86
69
18
13
41

0
0
0
0
3
0
0
0
0
0

0
1
0
0
17
13
8
0
0

88
5
4
67
80
118
30
5
9
200

Georgia
Hawaii
Idaho..
Illinois
Indiana....
Iowa
Kansas
Kentucky
.Louisiana
Maine

203
7
112
972
445
562
456
250
120
127

8
1
0
19
14
4
6
11
4
8

0
0
1
4
0
0
2
0
5

42
0
35
227
98
205
77
37
16
13

87
4
65
296
205
243
198
110
53
79

5
0
0
3
0
7
4
8
0
0

0
0
2
1
4
1
0
2
0
1

61
2
9
422
123
102
171
80
47
21

Maryland
Massachusetts.
Michigan
Minnesota
Mississippi
Missouri...
Montana. . .
Nebraska
Nevada... .
New Hampshire

156
382
350
512
94
321
205
412
17
84

3
40
11
8
5
12
4
2
1
3

10
7
3
0
3
1
1
0
0
1

17
28
77
116
16
58
76
83
4
5

69
207
157
192
34
148
76
199
8
23

0
0
0
1
0
3
0
1
0
0

9
11
4
0
0
1
0
0
1
0

48
89
98
195
36
98
48
127
3
52

New Jersey
New Mexico
New York.. .
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

438
97
1 017
158
263
719
775
152
1,286
67

49
1
123
8
3
32
12
2
98
3

16
0
59
14
0
12
0
2
79
0

59
25
130
44
100
112
85
31
211
2

151
37
441
58
118
334
454
102
491
58

1
0
8
0
0
1
4
0
2
0

18
0
72
9
0
5
0
3
69
0

144
34
184
25
42
223
220
12
336
4

South Carolina.
South Dakota
Tennessee
Texas
Utah
Vermont...
Virginia...
Washington. . .
West Virginia. .
Wisconsin

134
224
219
1,325
45
85
278
243
197
294
78
1
1

8
13
8
45
4
3
23
18
11
Q

8
0
0
0
0
2
33
8
0
0

43
93
36
142
6
17
28
51
38
54
12
0
0

49
81
94
574
19
29
74
138
68
115
26
0
1

0
2
2
19
2
1
0
0
0
0

0
0
2
3
2
6
7
1
0
0

ooo

In
operation
Merged
or
Dec.
31,
Converted consolidated
1967
to State
with
State
banks
banks

ooo

Liquidated

OOO

Consolidated and merged
Organized under 12 U.S.C. 215
and opened
Insolfor business
vencies
1863-1967
ConsoliMerged
dated

26
35
77
542
12
27
113
27
80
116
40
1
0

United States

WyOTnrnpr

Virgin Islands
Puerto Rico. .

166

TABLE B-5
Charters, liquidations, and changes in issued capital stock of National banks, calendar 1967
Capital stock

Number of
banks

Capital notes and
debentures
Preferred

KjOtTHTlOTl

Increases:
Banks newly chartered:
Primary organizations
Reorganizations
Conversion of State banks
Capital stock:
Preferred* 4 cases by new issue
Common:
361 cases by statutory sale
553 cases by statutory stock dividends
5 cases by statutory consolidation
46 cases by statutory merger
Total increases
Decreases:
Banks ceasing operations:
Voluntary liquidations:
Succeeded by National banks
Succeeded by State banks
Conservatorship: Absorbed by State bank
Statutory consolidations
Statutory mergers
Converted into State banks
Merged or consolidated with State banks
Insolvent
Capital stock:
Preferred* 5 cases by retirement
Common:
13 cases by statutory reduction
1 case by statutory consolidation
15 cases by statutory merger

$4, 620, 000

5, 550, 000

$300,000
$21, 423,475

26, 204, 157
159, 269, 528
8, 713, 760
20, 241,458

5, 200, 000

8, 740,500
822, 000
81, 703, 950

224, 598, 903

26,623,475

91, 566, 450

5
2

3, 575, 000
400, 000

100, 000

1
3
36
5
14
1

50, 000

i, 483, 666

2, 974, 400
25, 000

302,000
1,442,651
1, 090, 728
5, 339, 355

150,000
17,756,421

16,380,134

402, 000

17, 906,421

Charters in force Dec. 31, 1966, and issued captial

-40
4,796

208, 218, 769
5,113,527,836

26, 221,475
29, 156,400

73, 660, 029
1,161,455, 556

Charters in force Dec. 31, 1967, and issued capital

4,756

5, 321, 746, 605

55, 377, 875

1, 235,115, 585

Total decreases

•Excludes two banks which opened in 1967, but were chartered in 1966.
NOTE: Premium on sale of common stock $59,962,612 (348 cases).

167

TABLE B-6
Applications for National bank charters,
Approved

rejected, by States, calendar 1967*
Approved

Rejected
MISSISSIPPI

ALABAMA

Hcflin
Chatom
Roanokc

Apr. 10
Nov. 6
Dec. 20

First National Bank of Ocean Springs,
Ocean Springs
June 27
Corinth

Sept. 20

COLORADO

Brighton

Oct. 10

NEBRASKA

Omaha

CONNECTICUT

Simsbury

Sept. 6
FLORIDA

Inverness
Pensacola
Port St. Joe
Winter Park
New National Bank of Miami
Aug. 29
Beach National Bank, Fort Myers Beach.. Sept. 6
Fort Myers Beach
Deerfield Beach

Feb.
Feb.
Mar.
Aug.

9
23
27
8

Sept. 11
Oct. 19

GEORGIA

First National Bank of Trion, Trion
Fairmont
Columbus

July 19
NEW HAMPSHIRE

The Community National Bank of Rochester, Rochester

Apr. 13

NEW JERSEY

Mendham

Feb. 17
OHIO

Cleveland
Napoleon

Mar. 13
May 9
PENNSYLVANIA

Feb. 23
Mar. 10
Mar. 28

York

June 27
TEXAS

ILLINOIS

Chicago
Loves Park
Des Plaines
Mount Prospect

Feb.
May
Dec.
Dec.

24
24
20
20

KANSAS

Dodge City

June 29

Houston
Rockport
Pasadena
UTAH

Pioneer National Bank
Pullman
South Sound National Bank, Lacey
Kennewick

Nov. 29

MASSACHUSETTS

Belmont
Wellesley

Feb. 27
July 13

Feb. 20
Mar. 8
Sept. 6

WEST VIRGINIA

Huntington

Oct.

WISCONSIN

MICHIGAN

Negaunee
Flint
Walled Lake

Nov. 16

WASHINGTON

LOUISIANA

First National Bank of Port Allen, Port
Allen

Feb. 14
Mar. 8
July 14

Feb. 17
July 25
Dec. 18

First Wisconsin National Bank of Greenfield
Dec. 18

Feb. 17
June 19
Oct. 17

Sheridan

WYOMING
MINNESOTA

New Hope
Oak Park Heights
Olivia
•Excludes conversions.

168

Dec. 20
PUERTO RICO

San Juan

Feb.

TABLE B-7
Newly organized National banks, by States, calendar 1967
Charter
No.

Title and location of bank
$8, 970, 125

Total, United States: 18 banks
COLORADO

200,000

Fort Carson National Bank, Fort Carson
FLORIDA
15621
15638
15622

400, 000
350,000
504,000

First National Bank of Brooksville, Brooksville
New National Bank of Miami, Miami
Capital City Second National Bank, Tallahassee

1, 254, 000

Total: 3 banks
15616
15632

GEORGIA

600, 000
600,000

Security National Bank, Unincorporated area in Cobb County
, 200, 000

The Citizens and Southern Park National Bank, Unincorporated area in DeKalb County
15637
15629

Total: 2 banks

375,000
300, 000
KANSAS
675, 000

Fort Riley National Bank, Fort Riley
The Northgate National Bank of Hutchinson, Hutchinson
15625
15626
15627

Total: 2 banks
NEW YORK

First City National Bank of Southern New York, Binghamton
Second National Bank of Jamestown, Jamestown
15619

Lincoln National Bank of Syracuse, Syracuse

250, 000
125, 500
250,000
625, 500

2, 000, 000

Total: 3 banks
15630

15640

SOUTH CAROLINA

National Bank of Commerce of Spartanburg, Spartanburg

390, 625

500, 000

TEXAS
15634
15618
15633
15624

University National Bank, Galveston
WASHINGTON

South Sound National Bank, Lacey
WISCONSIN

Mequon National Bank, Mequon
Security National Bank of Racine, Racine
First National Bank of Sturgeon Bay, Sturgeon Bay
Central National Bank of Wausau, Wausau
Total: 4 banks

600,000
625,000
500, 000
400,000
2, 125, 000

169

TABLE B-8
State chartered banks converted to National banks, calendar 1967

Charter
No.

State

Title and location of bank

Effective
date of
charter
1967

15614
15615
15617
15623
15628
15631
15635
15636
15639
15641

Surplus, undivided
profits and
reserves

Total assets

$6, 525, 000 $11,135,945 $244, 284, 296

Total* 11 banks
15613

Outstanding
capital stock

Merchants & Farmers Bank of Franklin, National
Association
The First National Bank of Wayne County, Jesup.
State National Bank, Evanston
Continental National Bank, Englewood
First National Bank, Schuyler
First Northwestern National Bank, Redwood Falls.
First National Bank Searcy
First Colbert National Bank, Leighton
City National Bank, Charlotte
United National Bank of Vermillion
The Fallkill National Bank & Trust Co., Pough-

Ark
Ala
N. C
S. Dak.

Jan.
Jan.
Jan.
Feb.
Apr.
Apr.
June
Aug.
Aug.
Oct.

1
3
18
14
1
24
30
21
23
31

275, 000
400, 000
2, 500, 000
*800,000
200,000
200,000
500, 000
150, 000
500, 000
400, 000

615, 222
329, 619
3, 637, 689
1, 034, 574
268, 865
527, 309
753, 530
193, 590
1,658,179
537, 500

8, 583, 158
5,459, 589
120, 696,453
23, 137, 098
6, 927, 609
9, 465,018
14, 770, 250
3,989,311
14, 676, 372
14, 528, 239

N Y

Dec. 11

600,000

1, 579, 868

22, 051,199

Va
Ga
111.
Colo
Nebr

*Includes $300,000 capital notes.

TABLE B-9
National banks reported in voluntary* liquidation, calendar 1967

Title and location of bank

Date of
liquidation

Total capital
accounts of
liquidated

Total: 7 National banks.
Mission National Bank of Los Angeles, Los Angeles, Calif. (15087), absorbed by United States National
Bank, San Diego, Calif. (10391)
Pioneer National Bank, Los Angeles, Calif. (15340), absorbed by United States National Bank, San Diego,
Calif. (10391)
.
The First National Bank of Saltsburg, Saltsburg, Pa. (2609), absorbed by The Savings and Trust Co. of
Indiana, Indiana, Pa
Tiburon National Bank, Tiburon, Calif. (15149), absorbed by Sierra National Bank, Petaluma, Calif.
The First National Bank of Baltimore, Baltimore, Ohio (7639), absorbed by The Hocking Vailey National
Bank of Lancaster, Ohio (1241)
Valley National Bank, Littleton, Colo. (15121), absorbed by Arapahoe Bank, Littleton, Colo
First National Bank, Lakeview, Tex. (12835), absorbed by First National Bank, Memphis, Tex. (6107)..

$3, 737, 599
2,717,517

262, 761
470, 870
310, 216
615, 614
96, 931

•Wellsville Naliuiial Bank, Wellsvillc, Pa. (8498) sold by conservator to Bank of Hanover and Trust C a , Hanover, Pa., Jan. 28,

170

TABLE B-10
National banks merged or consolidated with State banks, calendar 1967

tive
date,
1967

Title and location of bank

Total: 14 banks..

Total
caf)ital
accounts of
National
banks
$9, 680,491

First National Bank of Allen Park, Allen Park, Mich. (14981) merged into Security Bank & Trust Co.,
Lincoln Park, Mich
National Bank of Oak Cliff in Dallas, Dallas, Tex. (15322), merged into South Oak Cliff State Bank,
Dallas, Tex
The Southern Maryland National Bank of La Plata, La Plata, Md. (8456), merged into the Hughesville
Savings Bank, Inc., Hughesville, Md., and under the title "Bank of Southern Maryland," La Plata, M d . ,
The First National Bank of Morganton, Morganton, N.C. (5450), merged into Wachovia Bank & Trust
Co., Winston-Salem, N.C
The First National Bank of South Plainfield, South Plainfield, N.J. (11847), merged into The Edison
Bank, Edison, N J
Emerald National Bank, Eugene, Oreg. (15163), merged into Citizens Bank, Eugene, Oreg
The Emerson National Bank of Warrensburgh, Warrensburg, N.Y. (9135), merged into State Bank of
Albany, Albany, N.Y
The Elkins Park National Bank, Elkins Park, Pa. (5043), merged into Industrial Valley Bank & Trust
Co., Jenkintown, Pa
National Bank of Union City, Union City, Pa. (14993), merged into the Pennsylvania Bank & Trust Co.,
Titusville, Pa
The North Creek National Bank, North Creek, N.Y. (9716), merged into First Trust Co. of Albany,
Albany N.Y
The Farmers National Bank & Trust Co. of Boyertown, Boyertown, Pa. (2900), merged into Peoples
Trust City Bank, Reading, Pa
Highlands National Bank of Renton, Renton, Wash. (15517), merged into the Bank of the West, Bellevue,
Wash..
The Orange National Bank, Orange, Mass. (2255), merged into Franklin County Trust Co., Greenfield,
Mass
The Sea Bright National Bank, Sea Bright, N.J. (14177), merged into The Central Jersey Bank & Trust
Co., Freehold, N J

TABLE

Jan. 17

367,437

Jan. 20

511,207

Mar. 14

978,684

Apr. 17

2, 018, 669

Apr. 28
May 1

495, 103
300, 242

May 19

1,093, 534

May 29

206, 262

May 31

513, 892

July 31
Nov. 1

596, 953
1, 345, 035

Dec. 15

431, 103

Dec. 18

438, 001

Dec. 27

384, 369

B-ll

National banks converted into State banks, calendar 1967

Title and location of bank

Effective
date 1967

$2, 566, 069

Total: 5 banks.
Casitas National Bank, Carpinteria, Calif. (15525), converted into the County Bank, Santa Barbara, Calif.
Piano National Bank, Piano, Tex. (15129), converted into Piano Bank & Trust, Piano
Stonewall National Bank of Corpus Christi, Tex. (15034), converted into Stonewall Bank, Corpus Christi..
South Davis First National Bank, Bountiful, Tex. (15202), converted into South Davis Security Bank
First National Bank of Carrollton, Tex. (15099), converted into First Security Bank & Trust Co

Total capital
accounts of
National
banks

May
Aug.
Sept.
Oct.
Dec.

31
1
1
4
15

824, 605
345, 795
340, 096
290,015
765, 558

171

TABLE B-12
Purchases of State banks by National banks, calendar 1967

Title and location of banks
1967
Total: 5 banks.

Total capital
accounts of
State banks
$5, 331,124

United States National Bank, San Diego, Calif. (10391), purchased the Peoples Bank, Los Angeles, Calif.
The Escanaba National Bank, Escanaba, Mich. (8496), purchased the Bark River State Bank, Bark
River, Mich
Seattle-First National Bank, Seattle, Wash. (11280), purchased the Bank of Sumas, Sumas, Wash
Santa Clarita National 3ank, Newhall, Calif. (15547), purchased the Boulevard Bank, Sepulveda, Calif.
Clermont National Bank, Milford, Ohio (3234), purchased the Merchants & Farmers Bank, Owensville,
Ohio

Jan. 13

2, 350, 091

Feb. 14
May 1
July 24

196, 664
56,221
1, 039, 725

Sept. 30

1, 688,423

TABLE B-13
Consolidations of National banks, or National and State banks, calendar 1967
Effective
date

Consolidating banks

Undivided
profits and
reserves

Outstanding
capital
stock

Surplus

$831, 600
2,095, 080

$857, 000
513, 030

$609, 328
0

$29, 623,856
44, 446,859

1, 835, 952

1,835, 952

1,397,490

73,170,715

300, 000
300, 000

450, 000
450, 000

102, 960
945, 757

11,708,986
18, 187,497

750, 000

1, 016,404

30, 041,400

Trust Company of Morris County, Morristown

400, 000
2, 449, 040

600, 000
3, 050, 960

364, 835
2, 187, 151

23, 180, 119
117,209,248

Trust Company National Bank, Morristown (4274)

3, 289, 040

3, 650, 960

2,111,986

140, 389, 368

Bank of North America, New York
The Meadow Brook National Bank, New York (7703)

5, 075, 375
19, 341, 215

7,820,687
16, 358,020

5, 385, 254
18, 370,224

394,445, 609
986, 768,278

National Bank of North America, New York (7703)

24, 995, 835

35, 004,165

12, 350, 775

1, 382,213,887

275, 000
2, 434, 500

500,000
7, 785, 500

115,221
969,987

8,583,158
126, 325, 587

6, 000, 000

5, 000, 000

1,079, 885

134,908,746

180, 000
299, 900

360, 000
330, 000

42, 776
375,871

5, 554, 527
8, 575,875

500, 000

669, 900

398, 718

14, 130,403

Resulting bank

Total assets

Total: 6 consolidations
CALIFORNIA

Dec. 15 The First National Bank ofVista, Vista (13178)
Golden Gate National Bank, San Francisco (14939)
Liberty National Bank, San Francisco (13178)
MONTANA

Oct. 13 Daly National Bank of Anaconda, Anaconda (15540)
The First National Bank of Butte, Butte (2566)
First National Bank, Anaconda (15540)
NEW JERSEY

Jan. 27 The Boonton National Bank of Parsippany-Troy Hills

NEW YORK

May

VIRGINIA

Tan.

1 Merchants and Farmers Bank of Franklin, N.A., Franklin
(15613)
Seaboard Citizens National Bank, Norfolk (10194)
Seaboard Citizens National Bank, Norfolk (10194)

July 21 First Valley National Bank, Rich Creek (15139)
The First National Bank, Narrows (11444)
The First National Bank, Narrows (15139)

172

TABLE B-14
Mergers of National banks, or National and State banks, by States, calendar 1967
Merging

banks

Resulting bank

Outstanding
capital
stock

Surplus

Undivided
projits and
reserves

Total assets

Total: 68 merger actions
June 30 First National Bank of Paragould, Paragould (13155)
National Bank of Commerce of Paragould, Paragould
(10004)
First National Bank of Commerce, Paragould (10004)

$200, 000
200,000

$359, 244
363, 556

$10,032, 408
10,485,306

500, 000

522, 800

20, 517, 714

100, 000
735, 085

300, 000
1, 040, 000

19,008
834, 852

6, 502, 148
46,277,837

CALIFORNIA

Jan. 31 The First National Bank of Elsinore, Elsinore (11922)
First National Bank & Trust Co., Ontario (6268)

797, 585

1, 377, 500

913, 860

52, 779, 986

840, 000
831, 600

326, 000
445, 000

0
203,143

5,465, 939
28,169,535

831, 600

445, 000

109, 878

33,429,483

404, 250
5, 280, 000

267, 250
9, 720, 000

141, 308
11,517,658

15,417,559
412, 678, 910

First National Bank of San Diego, San Diego (3050)

5,562, 975

10, 240, 000

11,527,491

428,096,469

Southern California First National Bank, San Diego (3050)

1,000, 000
4, 356, 000

250, 000
5, 953, 200

254, 869
2, 077, 245

9,427, 330
198, 625, 859

4, 356, 000

5, 953, 200

1, 937, 104

208, 153, 189

617, 265
5, 562, 975

384, 880
10, 240, 000

50,021
11,747,511

10, 903, 871
439,458, 735

5,816,050

10, 683, 950

12, 102, 652

450, 362, 606

1, 077, 540
18, 591, 800

574, 960
38,408, 200

0
11,095,564

23,077,029
1, 446, 689, 151

18, 983, 630

39, 665, 870

11,095,564

1, 467, 444, 996

The Bank of California N.A., San Francisco (9655)

2, 009, 620
5,816,050

431, 324
11,931,778

66, 788
10, 755, 102

18, 650, 581
447, 017, 083

The Bank of California N.A., San Francisco (9655)

6, 321, 970

11,578,030

13, 110,662

465, 667, 663

Oct. 5 Heritage-Wilshire National Bank, Los Angeles (15463)
Southern California First National Bank, San Diego (3050)
Southern California First National Bank, San Diego (3050)
Oct. 9 First National Bank of Oakland, Oakland (15180)
Security National Bank of Contra Costra, Walnut Creek
(15092i)
Security National Bank, Oakland (15180)
Oct. 9 Westminster National Bank, Westminster (15412)
Commercial National Bank, Buena Park (15434)
Commercial National Bank, Buena Park (15434)
j
Dec. 31 University National Bank, Fullerton (15515)

1, 500, 000

842, 728

22, 054, 094

500, 000

335,000

336, 216

26,446, 717

1, 500, 000

500, 000

313, 121

48, 499, 988

1,000,000
1, 025,000

250, 000
250, 000

58, 326
315,833

4, 299, 964
7, 935,016

1,025, 000

250, 000

324, 159

12, 234, 980

802, 000
1, 013, 450

201, 000
309, 775

63,430
562, 638

8, 151, 683
32, 683,049

1, 548, 120

570, 500

828, 673

40, 834, 732

100,000
10, 000, 000

200,000
14, 650,000

50, 000
9, 579, 769

350, 000
558,019,116

10, 000, 000

15, 000, 000

9, 579, 769

558,019,116

First National Bank & Trust Co., Ontario (6268)
April 28 Providencia Bank, Burbank
Valley National Bank, Glendale (14823)
Valley National Bank, Glendale (14823)
Aug. 17 Saddleback National Bank, Tustin (15336)

Aug. 31 Concord National Bank, Concord (15394)
Central Valley National Bank, Oakland (6919)
Central Valley National Bank, Oakland (6919)
Sept. 14 Huntington-Valley Bank, Huntington Beach
Southern California First National Bank, San Diego (3050)
Southern California First National Bank, San Diego (3050)
Sept. 25 Metropolitan Bank, Hollywood, Los Angeles

Newport National Bank, Newport Beach (15235)
Newport National Bank, Newport Beach (15235)
FLORIDA

Oct.

2 New National Bank of Miami, Miami (15638)
The First National Bank of Miami, Miami (6370)
The First National Bank of Miami, Miami (15638)

173

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967
Effective
date

Merging

banks

Resulting bank

Aug. 14 The Mutual National Bank of Chicago, Chicago (11092)
La Salle National Bank, Chicago (13146)
La Salle National Bank, Chicago (13146)

Outstanding
capital
stock

Undivided
profits and
reserves

Total assets

$4, 500, 000
7, 500,000

$755, 920
3,070,617

$57, 707, 249
370,421,782

9, 352, 500 ! 6, 500, 000

1, 726, 536

428, 129, 031

$1, 000, 000
6, 352, 500

INDIANA

Dec. 31 Livestock Exchange Bank, Indianapolis
Merchants National Bank & Trust Co. of Indianapolis,
Indianapolis (869)

200, 000

600, 000

397, 126

7, 280, 769

5,000,000

15,000,000

13,384,619

425,198, 272

Merchants National Bank & Trust Co. of Indianapolis,
Indianapolis (869)

5, 202, 500

15, 599, 520

13, 733, 823 ;

432, 383, 502

Oct. 31 Morningside Savings Bank, Sioux City
The Live Stock National Bank of Sioux City, Sioux City
(5022)

100, 000

150, 000

281, 058

8, 489, 509

800, 000

1, 200, 000

1, 197, 240

34, 096, 918

Northwestern National Bank of Sioux City, Sioux City
(5022)

900,000

1,350,000

1,482,013 I

42,674,611

600,000 :
500, 000

775, 000
1, 500, 000

283, 299
720,311

17, 901, 885
29, 367, 338

1, 600, 000

2, 000, 000

778, 610

47, 269, 223

307, 175
2, 380, 406

113,450
4, 619, 594

0
728, 327

3,448, 627
123, 154, 572

2, 487, 919

4, 944, 256

716, 777

126,603,199

625, 000
1, 628, 798

625, 000
1, 630, 886

339, 366
365, 633

17, 432, 092
27, 715, 523

1, 628, 798

1, 630, 886

4,749

43,796,911

MASSACHUSETTS

Feb. 24 The County Bank & Trust Co., Cambridge
Somerville National Bank, Somerville (4771)
The County Bank N.A., Somerville (4771)
May 19 First Bank & Trust Co. of Needham, Needham
Southshore National Bank, Quincy (14798)
Southshore National Bank, Quincy (14798)
Dec. 30 Lincoln National Bank of Chelsea, Chelsea (14087)
Commonwealth National Bank, Boston, (15399)
Commonwealth National Bank, Boston, (15399)
MICHIGAN

Dec. 19 First State Bank of Mendon, Mendon
The American National Bank and Trust Co. of Michigan,
Kalamazoo (13820)

250, 000

50, 000

66, 018

5, 300, 503

2, 880, 000

3, 600, 000

1,404, 099

141, 807, 188

The American National Bank & Trust Co. of Michigan,
Kalamazoo (13820)

3, 000, 000

3, 700, 000

1,550,117

146, 575, 548

1 Pickens Bank, Pickens
First National Bank of Lexington, Lexington (13313)

30, 000
75,000

95, 000
220, 000

1,015
597

2, 049, 048
5, 817,458

First National Bank of Lexington, Lexington (13313)

Jan.

105, 000

315,000

34, 186

7, 683, 096

Feb. 28 The Bank of Blue Mountain, Blue Mountain
The First National Bank, New Albany (15519)

50, 000
125, 000

169, 500
375, 000

25,408
182,817

5, 188, 531
8,450,636

The First National Bank, New Albany (15519)

168, 750

551, 250

121, 639

13, 615, 913

174

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967
Effective
date

Merging

banks

Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW JERSEY

Apr. 28 First National Bank of Butler, Butler (6912)
The First National Iron Bank of New Jersey, Morristown
(1113)

$271,000

$300, 000

$765, 681

$18, 152, 775

2, 880, 000

2, 340, 000

1,271,013

108,475, 333

The First National Bank of New Jersey, Morristown
(1113)

3, 489, 750

3,489, 750

848, 194

126, 628, 108

May 12 Bank of Nutley, Nutley
First National State Bank of New Jersey, Newark (1452)

1, 290, 000
9, 500, 000

1, 625, 000
33, 000, 000

861,614
7, 989, 369

48, 636, 809
667, 285, 875

First National State Bank of New Jersey, Newark (1452)

11, 112,500

35, 000, 000

8, 153,482

712, 742, 899

Sept. 29 Glen Ridge Trust Co., Glen Ridge
National Newark and Essex Bank, Newark (1316)

300, 000
13, 948, 700

700, 000
21, 051, 300

410, 648
8, 935, 338

15,026, 628
566, 382, 593

National Newark and Essex Bank, Newark (1316)

14, 641, 700

22, 858, 300

7, 845, 987

581,408,786

Oct. 20 Audubon National Bank, Audubon (11446)
Haddonfield National Bank, Haddonfield (14457)

450, 000
1, 610, 510

90, 000
1, 789, 490

392, 814
535, 132

19, 733, 636
67,316,202

2, 285, 510

2,714,490

677, 946

87, 049, 838

Apr. 10 The Unadilla National Bank, Unadilla(9516)
Marine Midland National Bank of Troy, Troy (721)

112,500
1, 918, 750

150, 000
3, 081, 250

177,975
3, 461, 930

6, 806, 990
108, 832, 179

Marine Midland National Bank of Troy, Troy (721)

2, 033, 750

3, 266, 250

3, 602, 404

115,639, 169

50, 000
2, 621, 205

120, 000
2,815,000

49, 307
1, 243, 302

2, 462, 223
127, 802, 866

Colonial National Bank, Haddonfield (14457)
NEW YORK

Apr, 28 The Maybrook National Bank, Maybrook (11927)
County National Bank, Middletown (13956)

2, 689, 955

2, 995, 000

1, 273, 859

130,265,090

May 16 First City National Bank of Southern New York, Binghamton (15625)
First City National Bank of Binghamton, Binghamton (202)

200, 000
3, 850, 000

40,000
6, 150, 000

10, 000
2, 421, 541

250, 000
139, 175, 480

First City National Bank of Binghamton, Binghamton
(15625)

County National Bank, Middletown (13956)

4, 050, 000

5, 190, 000

2,431,541

139, 425, 480

May 16 Second National Bank of Jamestown, Jamestown (15626)
The First National Bank of Jamestown, Jamestown (548)

100, 000
1, 500, 000

20, 000
1, 500, 000

5,500
1, 851, 900

132, 142
69, 427, 658

The First National Bank of Jamestown, Jamestown (15626)

1, 600, 000

1, 520, 000

1, 854, 458

69,431,358

May 16 Lincoln National Bank of Syracuse, Syracuse (15627)
Lincoln National Bank and Trust Co. of Central New York,
Syracuse (13393)

200, 000

40,000

10, 000

261, 235

3, 053, 590

7, 000 000

3, 032, 401

206, 747, 093

Lincoln National Bank and Trust Co. of Central New York,
Syracuse (15627)

3, 253, 590

7, 040, 000

3, 042, 401

206, 784, 094

June 30 Federation Bank & Trust Co., New York
Franklin National Bank, Mineola (12997)

8, 209, 390
39, 907, 250

10, 548, 621
50, 000, 000

3, 287, 180
14, 361, 952

286, 883, 229
2, 055, 462, 485

Franklin National Bank, Mineola (12997)

60, 430, 725

2, 342, 345, 713

50, 000, 000

15, 903, 568

Oct. 17 The National Bank of Waterville, Waterville (1361)
The Oneida National Bank & Trust Co. of Central New
York, Utica (1392)

65, 000

235, 000

149, 979

5, 626, 577

3, 825, 980

9, 325,000

4, 959, 713

253, 997, 318

The Oneida National Bank & Trust Co. of Central New
York, Utica (1392)

3, 897, 480

9, 560, 000

5, 103, 192

259, 603, 889

175

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967
Effective
date

Merging

banks

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW YORK—continued
$100, 000

$100,000

$185, 757

$5,268, 883

700, 000

1, 100, 000

1, 109, 340

31,852,432

The Canandaigua National Bank & Trust Co., Canandaigua (3817)

800, 000

1, 200, 000

1, 295, 097

37, 121,314

Dec. 31 Chester-Schroon-Horicon Bank, Chestertown
Glens Falls National Bank & Trust Co., Glens Falls (7699)

100, 000
1, 122, 188

200, 000
1, 500, 000

116, 022
1, 023, 058

5, 691, 565
60, 320, 330

1, 397, 188

1, 700, 000

980, 080

66,027,895

Dec. 14 The Hamlin National Bank of Holcomb, Holcomb (10046)
The Canandaigua National Bank & Trust Co., Canandaigua (3817)

Glens Falls National Bank
(7699)

& Trust Co.. Glens Falls

NORTH CAROLINA

Feb. 21 The Oxford National Bank, Oxford (13896)
The Planters National Bank & Trust Co., Rocky Mount
(10608)

200, 000

400, 000

376, 315

9, 905, 043

1,416, 935

2, 733, 065

742, 171

75, 139, 953

The Planters National Bank & Trust Co., Rocky Mount
(10608)

1, 816, 935

85, 044, 996

3, 183, 065

868, 486

Mar. 11 The Bank of Mayodan, Mayodan
Southern National Bank of North Carolina, Lumberton
(10610)

66, 915

238, 532

56, 243

4,110,919

2, 701, 485

3, 668, 485

1, 020, 425

97, 357, 855

Southern National Bank of North Carolina, Lumberton
(10610)

2,821,930

101,468, 773

3, 853, 486

1, 076, 668

July 24 The Bank of Mount Gilead, Mount Gilead
Southern National Bank of North Carolina, Lumberton
(10610)

26,600

300,000

351, 941

3, 096, 014

2, 992, 890

3, 862, 973

715, 937

106,034,448

Southern National Bank of North Carolina, Lumberton
(10610)

3, 165, 790

4, 016, 673

1, 067, 878

109, 130,462

Aug. 31 The Citizens Bank and Trust Co. of Southern Pines,
Southern Pines
First Union National Bank of North Carolina, Charlotte
(9164)

154, 615

700, 000

169, 536

13,436,483

14, 673, 585

22, 764, 231

51,21,583

709,027,699

First Union National Bank of North Carolina, Charlotte
(9164)

15, 098, 780

722,479, 074

23, 193, 651

5, 386, 685

Oct. 20 Bank of Lillington, Lillington
First National Bank of Eastern North Carolina, Jacksonville (14676)

100,000

200, 000

95, 201

3, 908, 384

1, 950, 000

213, 463

66, 862, 921

First National Bank of Eastern North Carolina, Jacksonville (14676)

2,175,000

70, 771, 305

2, 110,000

223, 665

Dec. 16 The Bank of Wendell, Wendell
First Union National Bank of North Carolina, Charlotte
(9164)

100,000

650, 000

235, 610

8, 220, 662

15,101,905

23, 193, 651

6, 693, 704

779, 937,909

First Union National Bank of North Carolina, Charlotte
(9164)

15, 351, 905

23,843, 651

6, 652, 455

788,115,653

Dec. 29 Commercial and Industrial Bank, Fayetteville
North Carolina National Bank, Charlotte (13761)

358,460
13, 915, 250

370, 072
40, 200, 890

395, 941
11, 143,312

17, 370, 726
1,075,341,611

North Carolina National Bank, Charlotte (13761)

14, 381, 250

40, 570, 962

11,431,714

1,092, 712,238

176

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967
Merging

banks

Resulting bank

July 15 The Racine Home Bank, Racine
The First National Bank of Racine, Racine (9815)

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

$55, 000
50, 000

$55, 000
60, 000

$51, 634
76, 760

$1,724,497
1, 760,825

125, 000

115,000

108, 921

3, 510, 267

50, 000

44,343

1, 087, 682
5, 974, 752

The Racine Home National Bank, Racine (9815)
July 31 The First National Bank of Stockport, Stockport (8042)
The First National Bank of McConnelsville, McConnelsville (46)
The First National Bank of McConnelsville, McConnelsville (46)

200, 000

329, 848

285,000

285, 000

301, 637

7,062, 434

Nov. 25 The Peoples Bank and Savings Co., New Philadelphia
The National Bank of Dover, Dover (4293)

150, 000
472, 000

180, 195
628, 000

177,373
837, 077

6, 966, 106
28, 060, 416

652, 000

1, 148, 000

644, 645

35, 026, 523

375, 000
750, 000

375, 000
1, 000, 000

389, 675
672, 996

13, 437, 866
39, 733, 679

1, 781, 250

562, 671

53, 171, 545

The Peoples National Bank & Trust Co., Dover (4293)
Dec. 31 The Jefferson Banking Co., Jefferson
The Northeastern Ohio National Bank, Ashtabula (5075)

1, 218, 750

The Northeastern Ohio National Bank, Ashtabula (5075)
PENNSYLVANIA

Jan. 28 The Central National Bank of Columbia, Columbia (3873)
National Bank & Trust Co. of Central Pennsylvania,
York (694)

350, 000

136, 197

7,117,903

7, 067, 000

8, 932, 980

4, 874, 781

216, 940, 187

National Bank & Trust Co. of Central Pennsylvania,
York (694)

7, 367,020

224,058, 089

Jan. 31 The First National Bank of Genesee, Genesee, (9783)
The Grange National Bank of Potter County at Ulysses,
Ulysses (8739)
Grange National Bank of Potter County, Ulysses (8739)

200,000

9, 282, 980

4, 910, 978

50,000

100,000

89,043

1,904,411

75,000

120,000

31,603

2, 716, 210

155, 000

195, 000

115,645

4, 620, 621

280,000

420, 000

214, 912

10, 580, 738

Jan. 31 The First National Bank of Landisville, Landisville (9312)
The Conestoga National Bank of Lancaster, Lancaster
(3987)

1, 270, 000

2, 730, 000

2, 082, 836

59,177,479

The Conestoga National Bank, Lancaster (3987)

1, 550, 000

3, 150, 000

2, 297, 749

69, 758, 217

Feb. 28 Tuscarora State Bank, Blairs Mill
The Juniata Valley National Bank, Mifflintown (5147)

50, 000
377, 000

125, 000
1, 153, 000

31, 597
942, 826

1,491, 895
19, 498, 652

The Juniata Valley National Bank, Mifflintown (5147)

412, 000

Apr. 28 The Second National Bank of Titusville, Titusville (879)
Marine National Bank, Erie (870)
Marine National Bank, Erie (870)
June

7 The Atglen National Bank, Atglen (7056)
National Bank of Chester County & Trust Co., West
Chester (552)

1, 278, 000

989, 424

20, 990, 547

300, 000
1, 000, 000

400, 000
2, 400, 000

172, 907
766, 292

8,310,491
69, 078, 508

1, 300, 000

77, 388, 999

2, 800, 000

939, 199

40,000

160, 000

164, 583

3, 088, 385

966, 500

4, 033, 500

1, 339, 035

71,167,478

4, 281, 500

1, 403, 588

74, 255, 833

National Bank of Chester County & Trust Co., West
Chester (552)

1, 018, 500

June 16 The First National Bank of Shickshinny, Shickshinny
(5573)
The Wyoming National of Wilkes-Barre, Wilkes-Barrc
(732)

125,000

252, 214

5, 645, 638

1, 200, 600

2, 000, 000

943, 841

51, 520, 965

The Wvoming National Bank of Wilkes-Barre, Wilkcs-Barre
(732)'

1, 300, 600

2, 150,000

1, 196, 055

57, 166, 603

125, 000

177

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967

Effective

Merging

banks

Undivided

Outstanding

date

capital
stock

Resulting bank

Surplus

profits and

Total assets

reserves

PENNSYLVANIA—continued
Aug.

7 The First National Bank of Hastings, Hastings (11227)
The First National Bank of Ebensburg, Ebensburg (5084)

$50, 000
190, 000

$100,000
760,000

$127,049
578, 627

$3, 019, 139
25, 131, 283

The First National Bank of Ebensburg, Ebensburg (5084)

227, 500

872, 500

712, 369

28, 150, 422

Aug. 30 The First National Bank of Three Springs, Three Springs
(10183)
Union National Bank & Trust Co. of Huntingdon, Huntingdon (4965)

75,000

1, 050, 000

64, 762

2, 507, 613

334, 960

965,040

260, 394

20, 351, 663

Union National Bank & Trust Co. of Huntingdon, Huntingdon (4965)

391,210

1,088, 790

325, 156

22, 859, 277

2 First National Bank & Trust Co. of Elizabethtown, Elizabethtown (3335)
The Harrisburg National Bank & Trust Co., Harrisburg
(580)

125, 000

925,000

132, 729

13,307,439

3, 651, 250

8, 825, 000

3, 041, 796

159, 887, 914

The Harrisburg National Bank & Trust Co., Harrisburg
(580)

4, 088, 750

9, 750, 000

2, 862, 025

173,195,353

140, 000

260, 000

251, 769

7, 637, 305

3, 025, 000

6, 000,000

3, 021, 098

157, 536, 594

Oct.

Oct. 25 Citizens Bank of Wilkes-Barre, Wilkes-Barre
Miners National Bank of Wilkes-Barre, Wilkes-Barre
(13852)
Miners National Bank of Wilkes-Barre,
(13852)

Wilkes-Barre
3, 249,000

6, 760,000

2, 660, 506

165, 183, 405

Oct. 31 The First National Bank of Bloomsburg, Bloomsburg (293)
The First National Bank of Wilkes-Barre, Wilkes-Barre (30)

156, 250
2, 600, 000

243, 750
4, 000, 000

247, 613
2, 055, 310

10, 653, 505
121,572, 121
131,906,675

The First National Bank of Wilkes-Barre, Wilkes-Barre (30)

2, 800, 000

4, 700, 000

1, 806, 645

Nov. 30 East Berlin National Bank, East Berlin (14091)
Adams County National Bank, Cumberland Township
(311)

50, 000

275,000

30, 274

3,447, 598

850, 000

1, 510, 000

607, 737

34, 055, 893

Adams County National Bank, Cumberland Township
(311)

975, 000

37, 503, 491

Dec.

1, 710, 000

638, 010

9 The Glen Lyon National Bank, Glen Lyon (13160)
The Hanover National Bank of Wilkes-Barre, Wilkes-Barre
(14344)

100,000

150, 000

150, 035

3, 173, 952

200, 000

800, 000

406, 039

19, 274, 573

The Hanover National Bank of Wilkes-Barre, Wilkes-Barre
(14344)

256, 000

994, 000

556, 074

22, 448, 525

Dec. 27 Conemaugh Valley Bank, Blairsville
First National Bank in Indiana, Indiana (14098)

200, 000
525, 000

103,000
525, 000

65, 776
778, 938

4, 013, 905
24,600,698

First National Bank in Indiana, Indiana (14098)

685, 000

823, 450

28, 609, 339

Oct. 21 Farmers Bank of Simpsonville, Simpsonville
The Peoples National Bank, Greenville (10635)

135, 000
1, 650, 000

175,000
2, 660, 000

62, 123
1, 928, 451

4, 643, 493
67,975,417

The Peoples National Bank, Greenville (10635)

1, 737, 750

2, 835, 000

1, 985, 824

71, 943, 098

4 Empire State Bank of Dallas, Dallas
The National Bank of Commerce of Dallas, Dallas (3985)

1, 000, 000
2, 355, 060

635, 956
2, 085, 000

0
1,048, 399

34, 095, 321
94,066, 341

National Bank of Commerce of Dallas, Dallas (3985)

4, 555, 060

1, 525, 000

1, 044, 355

128, 161, 663

SOUTH CAROLINA

TEXAS

Dec.

178

TABLE B-14—Continued
Mergers of National banks, or National and State banks, by States, calendar 1967
Effective
date

Merging banks
Resulting bank

Undivided
profits and
reserves

Outstanding
capital
stock

Surplus

$50, 000
1, 080, 000

$110,500
1, 260, 000

$76, 603
932, 621

$3, 623, 575
55, 547, 700

1, 215, 000

59, 169,044

Total assets

VERMONT

Jan.

13 Ludlow Savings Bank and Trust Co., Ludlow
Vermont National Bank, Brattleborb (1430)

1, 370, 500

921, 983

Jan.

31 The Rutland County Bank, Rutland
The Howard National Bank & Trust Co., Burlington
(1698)

330, 000

650, 000

636, 749

18, 241, 668

1, 732, 500

1, 280, 821

65, 776, 326

The Howard National Bank & Trust Co., Burlington
(1698)

2, 310, 000

2,310,000

1, 753, 186

84,013, 194

Feb. 18 Middletown State Bank, Inc., Middletown
Farmers & Merchants National Bank, Winchester (6084)

100, 000
1, 347, 500

100, 000
1, 361, 125

76, 589
410, 780

2, 858, 337
39,201,420

Farmers & Merchants National Bank, Winchester (6084)

1, 510, 000

1, 400, 000

485, 995

42,059, 757

June 30 Union Bank & Trust Co. of Amelia, Amelia Court House
The Fidelity National Bank, Lynchburg (1522)

100, 000
3, 736, 900

200, 000
4, 900, 000

175, 199
2, 244, 388

5, 672, 033
145, 549, 695

The Fidelity National Bank, Lynchburg (1522)

Vermont National Bank, Brattleboro (1430)

VIRGINIA

3, 904, 900

5, 100, 000

2, 353, 079

151,221,038

Aug. 31 The Farmers Bank of Elk Creek, Elk Creek
The Grayson National Bank, Independence (10834).

40,000
100, 000

60, 000
300, 000

23, 266
127, 684

1, 730, 881
6,911,773

The Grayson National Bank, Independence (10834)

121,000

360, 000

169, 649

8, 642, 063

150, 000
6,014,513

150, 000
8, 985,488

109, 726
5, 688, 963

6, 273, 796
369, 156, 153

6, 015, 213

9, 284, 787

4, 885, 855

375, 397,696

WASHINGTON

Oct. 20 First National Bank in Montesano, Montesano (5472)
National Bank of Washington, Tacoma (3417)
National Bank of Washington, Tacoma (3417)

TABLE B-15
Mergers* resulting in National banks, by size of acquiring and acquired banks,

1960-67

Assets of acquired bank

Less than $10 million.
$10 million to $24.9 million
$25 million to $49.9 million
$50 million to $99.9 million
$100 million and over
Total

Less than $10 $10 million to $25 million to $50 million to $100 million
and over
99.9
49.9
24.9
million
million
million
million

Total

71
86
69
75
152

0
10
22
25
89

0
0
5
11
29

0
0
0
1
15

71
96
96
112
296

453

146

J671

oooo

Assets of acquiring bank^

•Includes all forms of acquisitions since the effective date of the Bank Merger Act, May 13, 1960.
fin each transaction, the bank with larger total assets was considered to be the acquiring bank,
j Includes 650 transactions, 6 involving 3 banks, 6 involving 4 banks, and 1 involving 5 banks.

179

TABLE

B-16

Domestic branches entering the National banking system, by de now opening, merger, or conversion, by States, calendar 1967
Branches openedfor
Charter
No.

Title and location of bank
Local

Total.,

14414
5249
10377
8765
4319
15635
13414
8963
9855
6173
1853
14160
7568

State National Bank of Alabama, Decatur
The First National Bank of Dothan, Dothan
The First National Bank of Fayette, Fayette
The Henderson National Bank of Huntsville, Huntsville
The First National Bank of Jacksonville, Jacksonville
First Colbert National Bank, Leighton
The American National Bank & Trust Co. of Mobile, Mobile..
The First National Bank of Scottsboro, Scottsboro
The First National Bank of Stevenson, Stevenson
The City National Bank of Tuscaloosa, Tuscaloosa
The First National Bank of Tuscaloosa, Tuscaloosa
First National Bank in Tuscumbia, Tuscumbia
The First National Bank of Wetumpka, Wetumpka

3728
14324

First National Bank of Arizona, Phoenix
The Valley National Bank of Arizona, Phoenix.,

14389
14000
13958
10004
6680
14631
15608

The First National Bank of Blytheville, Blytheville
The Commercial National Bank of Little Rock, Little Rock.
Union National Bank of Little Rock, Little Rock
First National Bank of Commerce, Paragould
Simmons First National Bank of Pine Bluff, Pine Bluff
Citizens National Bank of Walnut Ridge, Walnut Ridge
Fidelity National Bank of West Memphis, West Memphis...

15347
15437
14670
15484
14695
15398
15434
11282
15450
15557
15329
15515
14823
15495
2491
15388
15182
15547
6919
15180
15220
6268
15532
15174
15032
15349
3050
10391
13044
9655
1741
13178

Alameda First National Bank, Alameda.
Bakersfield National Bank, Bakersfield...
Bellflower National Bank, Bellflower.
City National Bank, Beverly Hills
Inyo-Mono National Bank, Bishop
Commercial National Bank, Buena Park
The First National Bank of Cloverdale, Cloverdale
National Bank of Agriculture, Delano
Imperial Valley National Bank, El Ccntro
Humboldt National Bank, Eureka
University National Bank, Fullerton
Valley National Bank, Glendale, Glendale
Mid-cal National Bank, Lodi
Security First National Bank, Los Angeles
Silverlakc National Bank, Los Angeles
Community National Bank of Fresno County, Mendota
Santa Clarita National Bank, Newhall
Central Valley National Bank, Oakland
Security National Bank, Oakland
Oceanside National Bank, Oceanside
First National Bank & Trust Co., Ontario
Commercial & Farmers National Bank, Oxnard
Sierra National Bank, Petaluma
Rocklin-Sunset National Bank, Rocklin
Valley National Bank, Salinas
Southern California First National Bank, San Diego
United States National Bank, San Diego
Bank of America National Trust & Savings Association, San Francisco.
The Bank of California, National Association, San Francisco
Crocker-Citizens National Bank, San Francisco
Liberty National Bank, San Francisco

180

224

Other than
local

business

TABLE B-l 6—Continued
Domestic branches entering the National banking system, by de novo opening, merger, or conversion, by States, calendar 1967
Branches openedfor business
Charter
No.

Title and location of bank
Other than
local
CALIFORNIA—continued

2158
14891
14903
15357
13178

The First National Bank of San Jose, San Jose. .
Santa Barbara National Bank, Santa Barbara...
Valley National Bank, Sunnymead, Sunnymead.
San Joaquin Valley National Bank, Tulare
The First National' Bank of Vista, Vista

335
1338
720
1184
2
227
15584
780

The Connecticut National Bank, Bridgeport
Hartford National Bank & Trust Co., Hartford
The Home National Bank & Trust Co., of Meriden, Meriden.
The New Britain National Bank, New Britain
The First New Haven National Bank, New Haven
The Second National Bank of New Haven, New Haven
The Atlantic National Bank, Stamford
The Waterbury National Bank, Waterbury

15127

Public National Bank, Washington

9617
15541
4691
3907
10270
7969
14046
13068
13472
9302

The Fulton National Bank of Atlanta, Atlanta
The National Bank of Georgia, Atlanta
The Fourth National Bank of Columbus, Columbus
The First National Bank of Dalton, Dalton
The First National Bank & Trust Co. in Macon, Macon
First National Bank of McDonough, McDonough
The National Bank of Monroe, Monroe
The Citizens & Southern National Bank, Savannah
The Liberty National Bank & Trust Co. of Savannah, Savannah.
The First National Bank of Thomson, Thomson

1668
14444

The Idaho First National Bank, Boise
First Security Bank of Idaho, National Association, Boise.

14331
12870
3303
2584
4576
1881
14610
14453

National Bank of Aledo, Aledo
The First National Bank, of Antioch, Antioch.. . .
The Old National Bank of Centralia, Centralia. .
The Second National Bank of Danville, Danville.
The Citizens National Bank of Decatur, Dccatur.
Dixon National Bank, Dixon
National Bank of Joliet, Joliet
Melrose Park National Bank, Melrose Park

699
14813
11671
12444
14529
13759
984
869
2747
13816
8956

The First National Bank of Aurora, Aurora
The First National Bank of Cedar Lake, Cedar Lake.
First-Farmers National Bank, Converse
Old National Bank in Evansville, Evansville
Mercantile National Bank of Hammond, Hammond. ,
American Fletcher National Bank & Trust Co., Indian
The Indiana National Bank of Indianapolis, Indianapt
Merchants National Bank& Trust Co. of Indianapolis, Indianapolis...
The First-Merchants National Bank of Michigan City, Michigan City.
First National Bank in New Castle, New Castle
The Colonial National Bank, Tennyson

CONNECTICUT

DISTRICT O F COLUMBIA

ILLINOIS

181

TABLE B-16—Continued
Domestic branches entering the National banking system, by de novo opening, merger, or conversion, by States, calendar 1967
Branches opened for business
Charter
JVo.

Title and location of bank
Other than
local

10408
13817
15085
5022

First National Bank, Ames
The Citizens National Bank of Boone, Boone
East Des Moines National Bank, Des Monies
Northwestern National Bank of Sioux City, Sioux City.

The Condon National Bank of Coffeyville, Coffeyville.

5900
718
109
14320
3832

The Citizens National Bank of Bowling Green, Bowling Green..
The First National Bank & Trust Co. of Covington, Covington.
First National Lincoln Bank of Louisville, Louisville
Liberty National Bank & Trust Co. of Louisville, Louisville
The First & Farmers National Bank of Somerset, Somerset

4154
4524
13689
13648

The First National Bank of Lake Charles, Lake Charles
The Peoples National Bank of New Iberia, New Iberia
The National Bank of Commerce in New Orleans, New Orleans.
Commercial National Bank in Shreveport, Shreveport

498
3941
2260
4128

First National Granite Bank of Augusta, Augusta
The First National Bank of Bar Harbor, Bar Harbor
First-Manufacturers National Bank of Lewiston and Auburn, Lewiston.
First National Bank of Portland, Portland

1413
13745
15102
15365
13747
13776
15497

The First National Bank of Maryland, Baltimore
Maryland National Bank, Baltimore
National City Bank of Baltimore, Baltimore
University National Bank, College Park
Frederick County National Bank of Frederick, Frederick..
The Garrett National Bank in Oakland, Oakland
The Old Line National Bank, Rockville

15399
200
2504
13222
4771
614
484
1129
13395
383
1082
1260
14798
726
308
1135
79

Commonwealth National Bank, Boston
The First National Bank of Boston, Boston
First County National Bank, Brockton
The Buzzards Bay National Bank, Buzzards Bay
The County Bank National Association, Cambridge..
Middlesex County National Bank, Everett
The Haverhill National Bank, Haverhill
Merrimack Valley National Bank, Haverhill.
The Barnstable County National Bank of Hyannis, Hyannis.
The First National Bank of Northampton, Northampton....
First Agricultural National Bank of Berkshire County, Pittsfield.
Pittsfield National Bank, Pittsfield
South Shore National Bank, Quincy
Merchants-Warren National Bank of Salem, Salem
Third National Bank of Hampden County, Springfield
,
The Mechanics National Bank of Worcester, Worcester
Worcester County National Bank, Worcester

MASSACHUSETTS

182

Total

TABLE B-l 6—Continued
Domestic branches entering the National banking system, by de novo opening, merger, or conversion, by States, calendar 1967
Branches opened for business
Charter
No.

Title and location of bank
Local

3948
14925
13738
14948
13671
8496
15049
15575
7676
13741
13820
14032
12971
5607
13739
14773
15403
3378
15527
15008
13874
13807

Security National Bank of Battle Greek, Battle Greek
First National Bank of Calumet-Lake Linden, Calumet
City National Bank of Detroit, Detroit
Manufacturers National Bank of Detroit, Detroit
Michigan Bank, National Association, Detroit
National Bank of Detroit, Detroit
Northern Michigan National Bank, Escanaba
Metropolitan National Bank of Farmington, Farmington
Union Bank & Trust Co. (National Association), Grand Rapids
The Houghton National Bank, Houghton
The National Bank of Jackson, Jackson
The American National Bank & Trust Co. of Michigan, Kalamazoo...
Michigan National Bank, Lansing
First National Bank in Mount Clemens, Mount Clemens
The First National Bank of Petoskey, Petoskey
Community National Bank of Pontiac, Pontiac
National Bank of Royal Oak, Royal Oak
Valley National Bank of Saginaw, Saginaw
Clinton National Bank & Trust Co., St. Johns
Oakland National Bank, Southfield
Troy National Bank, Troy
The National Bank of Wyandotte, Wyandotte
The National Bank of Ypsilanti, Ypsilanti

10738
3765
15539
10523
11898
13313
13722
15519
14592
3258

First-Columbus National Bank, Columbus
The First National Bank of Greenville, Greenville
Southern National Bank of Hattiesburg, Hattiesburg
First National Bank of Jackson, Jackson
The Commercial National Bank & Trust Co. of Laurel, Laurel.
First National Bank of Lexington, Lexington
Britton & Koontz National First Bank, Natchez
First National Bank, New Albany
First National Bank of Picayune, Picayune
First National Bank of Vicksburg, Vicksburg

14185

Other than

Total

MISSOURI

4079

The First National Bank of Carrollton, Carrollton..

First National Bank, Anaconda..

13408
15379

First National Bank& Trust Co. of Fremont, Fremont..
Security National Bank of Omaha, Omaha
NEVADA

Security National Bank of Nevada, Reno
NEW HAMPSHIRE

14835
4740
1070

Hampton National Bank, Hampton
The Lakeport National Bank of Laconia, Laconia.
The Souhegan National Bank of Milford, Milford..

183

TABLE B-16—Continued
Domestic branches entering the National banking system, by de novo openings merger, or conversion, by States, calendar 1967
Branches openedfor
Charter
No.

Title and location of bank

Local
NEW JERSEY

13363
11653
9268
13855
1346
12?2
1209
13893
15430
14457
12646
374
4147
12022
1113
4274
2343
1452
1316
15505
4724
12524
3922
15327
6692
14189
2918
7265

..
Springs..
A
The First National Iron Bank of New Jersey, Morristown..
Trust Company National Bank, Morristown
Union National Bank & Trust Co., Mount Holly
Fisrt National State Bank of New Jersey, Newark
National Newark & Essex Bank, Newark
Security National Bank, Newark
The Second National Bank of Orange, Orange
,
Perth Amboy National Bank, Perth Amboy
The City National Bank & Trust Co. of Salem, Salem
First National Bank of Scotch Plains, Scotch Plains
Citizens National Bank of Morris County, Succasunna
The First National Bank of Tuckahoe, Tuckahoe
The Vineland National Bank & Trust Co., Vineland
The First National Bank of Williamstown, Williamstown

13814
6597
8767
14971
6183

First National Bank in Albuquerque, Albuquerque .
The First National Bank of Belen, Belen
The Clovis National Bank, Clovis.
Deming National Bank, Deming
The First National Bank of Farmington, Farmington.,

10029
3817
1198
1349
2272
11511
980
7703
548
10456
13121
13956
12997
13314
2370
15428
15558
1461
15029
14734
12788
15641
4230

First National Bank of Bay Shore, Bay Shore
The Canandaigua National Bank & Trust Co., Canandaigua
The Tanners National Bank of Catskill, Catskill
The Chester National Bank, Chester
First National Bank of Cortland, Cortland
Tinker National Bank, East Setauket
The First National Bank of Glens Falls, Glens Falls
National Bank of North America, Jamaica,
The First National Bank of Jamestown, Jamestown
The First National Bank of Jeffersonville, Jeffersonville
The Mahopac National Bank, Mahopac
County National Bank, Middletown
Franklin National Bank, Mineola
Nanuet National Bank, Nanuet
The Chase Manhattan Bank (National Association), New York
Chelsea National Bank, New York
Community National Bank & Trust Co. of Richmond, New York (Staten Island)
First National City Bank, New York
Royal National Bank of New York, New York
Tappan Zee National Bank, Nyack
The Peoples National Bank of Long Island, Patchogue
The Fallkill National Bank & Trust Co., Poughkeepsie
The Suffolk County National Bank of Riverhead, Riverhead

First Merchants National Bank, Asbury Park
Beach Haven National Bank & Trust Co., Beach Haven
The First National Bank of Bordentown, Bordentown
The National Bank of Sussex County, Branchville
The Cumberland National Bank of Bridgeton, Bridgeton
Mechanics National Bank of Burlington County, Burlington
.First Camden National Bank & Trust Co., Camden
The Edgewater National Bank, Edgewater
' ELariton Valley National Bank, Edison Township
Colonial National Bank, Haddonfield
The First National Bank of Hamilton Square, Hamilton Square.

NEW

184

MEXICO

Other than

business

TABLE B-16—Continued
Domestic brandies entering the- National banking system, by de nmo opening, mergert rtr conversion, hy States, calendar 1967
Branches opened for business
Charter
No.

Title and location of bank
Local

Other than
local

Total

NEW YORK—continued
The Merchants National Bank & Trust Co. of Syracuse, Syracuse
Marine Midland National Bank of Troy, Troy
The Oneida National Bank & Trust Co. of Central New York, Utica..
First National Bank of Waterloo, Waterloo
The National Bank of Northern New York, Watertown
Seaway National Bank, Watertown

1342
721
1392
368
2657
8158

NORTH CAROLINA

First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
The Concord National Bank, Concord
First National Bank of Eastern North Carolina, Jacksonville..
Southern National Bank of North Carolina, Lumberton.
The First National Bank of Mount Airy, Mount Airy. . . .
The Planters National Bank & Trust Co., Rocky Mount.

9164
13761
3903
14676
10610
4896
10608

NORTH DAKOTA

4384

The First National Bank of Dickinson, Dickinson.

First National Bank of Akron, Akron
The Athens National Bank, Athens
The First National Bank of Bellevue, Bellevue
First National Bank, Bowling Green
First National Bank of Canton, Canton
Central National Bank of Cleveland, Cleveland
The National City Bank of Cleveland, Cleveland
Society National Bank of Cleveland, Cleveland
The Ohio National Bank of Columbus, Columbus
The Third National Bank & Trust Co. of Dayton, Dayton...
The Winters National Bank & Trust Co. of Dayton, Dayton.
The Peoples National Bank & Trust Co., Dover
Elyria Savings & Trust National Bank, Elyria
Euclid National Bank, Euclid
The Peoples National Bank of Greenfield, Greenfield
Greenville National Bank, Greenville
The Portage National Bank, Kent
The Hocking Valley National Bank, Lancaster
First National Bank & Trust Co. of Lima, Lima
The Lorain National Bank, Lorain
The National City Bank of Marion, Marion
First National Bank, McConnelsville
The Old Phoenix National Bank of Medina, Medina
Clermont National Bank, Milford
The Lake County National Bank of Painesville, Painesville...
The Miami Citizens National Bank & Trust Co., Piqua
The Piqua National Bank & Trust Co., Piqua

14579
7744
2302
15416
76
4318
786
14761
5065
10
2604
4293
15577
15573
10105
13944
652
1241
13767
14290
11831
46
4842
3234
14686
1061
1006

OKLAHOMA

7386 ! The Cleveland National Bank, Cleveland
12065 i The Security National Bank of Duncan, Duncan
12016 ; The Fidelity National Bank & Trust Co. of Oklahoma City, Oklahoma City.
!
8554
1553
4514

The Forest Grove National Bank, Forest Grove
First National Bank of Oregon, Portland
United States National Bank of Oregon, Portland.

185

TABLE B-16—Continued
Domestic branches entering the National banking system, by de novo opening, merger, or conversion, by States, calendar 1967
Branches opened for business
Charter
No.

Title and location of bank
Other than
local
PENNSYLVANIA

2137
575
311
5084
2515
870
580
3893
12688
31
4965
14098
12098
5073
3987
240
311
5147
10275

14542
8499
324
2581
9149
539
6301
252
705
2222
39
4355
8739
552
30
14344
13852
732
1464

694

The National Bank of Boyertown, Boyertown
The National Bank of Chester Valley, Coatesville
Adams County National Bank, Cumberland Township
The First National Bank of Ebensburg, Ebensburg
The Ephrata National Bank, Ephrata
Marine National Bank, Erie
The Harrisburg National Bank & Trust Co., Harrisburg
Peoples First National Bank & Trust Co., Hazleton
The Hershey National Bank, Hershey
Penn Central National Bank, Huntingdon
Union National Bank & Trust Co. of Huntingdon, Huntingdon
First National Bank in Indiana, Indiana
The Moxham National Bank of Johnstown, Johnstown
The Merchants National Bank of Kittanning, Kittanning
The Conestoga National Bank, Lancaster
The First National Bank of Lebanon, Lebanon
Adams County National Bank, Littlestown
The Juniata Valley National Bank, Mifflintown
The First National Bank of Milford, Milford
Cumberland County National Bank & Trust Co., New Cumberland
The Farmers National Bank & Trust Co. of New Holland, New Holland
The First National Bank & Trust Co. of Newtown, Newtown
I The Peoples National Bank& Trust Co. of Norristown, Norristown.
I The National Bank of North East, North East
The Philadelphia National Bank, Philadelphia.
Mellon National Bank & Trust Co., Pittsburgh
Pittsburgh National Bank, Pittsburgh
The Union National Bank of Pittsburgh, Pittsburgh
Western Pennsylvania National Bank, Pittsburgh
The First National Bank of Towanda, Towanda
First Biair County National Bank of Tyrone, Tyrone
Grange National Bank of Potter County, Ulysses
National Bank of Chester County & Trust Co., West Chester
The First National Bank of Wilkes-Barre,
Wilkes-Barre
The Hanover National Bank of W7ilkes-Barre, Wilkes-Barre
Miners National Bank of Wilkes-Barre, Wilkes-Barre
The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre
Williamsport National Bank, Williamsport
National Bank & Trust Co. of Central Pennsylvania, York
RHODE ISLAND

1302 i Industrial National Bank of Rhode Island, Providence..
SOUTH CAROLINA

14425
2044
13720
14784
10635
14967
15025

The Citizens & Southern National Bank of South Carolina, Charleston.
The South Carolina National Bank of Charleston, Charleston
The First National Bank of South Carolina, Columbia
Carolina National Bank of Easley, Easley
The Peoples National Bank, Greenville
The First National Bank of Lancaster, Lancaster
First National Bank of St. George, St. George
SOUTH DAKOTA

4631 First National Bank of the Black Hills, Rapid City
10592 ! Northwestern National Bank of Sioux Falls, Sioux Falls..
15636 | United National Bank of Vermillion, Vermillion

186

TABLE B-16—Continued
Domestic branches entering the National banking system, by de novo opening, merger, or conversion, by States, calendar 1967
Branches opened for business
Charter
No.

3341
7848
9667
5263
12790
10842
14657
13539
5528
336
13681
13349
3032
13103
3530

Title and location of bank

The First National Bank of McMinn County, Athens
The Hamilton National Bank of Chattanooga, Chattanooga..
The First National Bank of Cookeville, Cookeville
First Citizens National Bank of Dyersburg, Dyersburg
The National Bank of Commerce of Jackson, Jackson
The First National Bank of Sullivan County, Kingsport
The Kingsport National Bank, Kingsport
The Hamilton National Bank of Knoxville, Knoxville
The First National Bank of Manchester, Manchester
The First National Bank of Memphis, Memphis
National Bank of Commerce in Memphis, Memphis
Union Planters National Bank of Memphis, Memphis
First American National Bank of Nashville, Nashville
Third National Bank in Nashville, Nashville
The Peoples National Bank of Shelbyville, Shelbyville

Zions First National Bank, Salt Lake City..

1430
1698
1195

Vermont National Bank, Brattleboro
The Howard National Bank & Trust Co., Burlington.,
The National Bank of Middlebury, Middlebury

14893
15254
14904
5591
8688
6389
1572
5261
11694
13880
10834
1522
6748
15139
10194
11381
11387
10080
15530
11817
6084
1635

Mount Vernon National Bank & Trust Co. of Fairfax, Annandale. . .
Fidelity National Bank, Arlington
Security National Bank, Baileys Cross Roads
The Culpeper National Bank, Culpeper
The First National Bank of Emporia, Emporia
The National Bank of Fairfax, Fairfax
The First National Bank of Harrisonburg, Harrisonburg.
The Rockingham National Bank of Harrisonburg, Harrisonburg...
Valley National Bank, Harrisonburg
Russell County National Bank, Honaker
The Grayson National Bank, Independence
The Fidelity National Bank, Lynchburg
The Peoples National Bank of Manassas, Manassas
The First National Bank, Narrows
Seaboard Citizens National Bank, Norfolk
American National Bank, Portsmouth
The Peoples National Bank of Pulaski, Pulaski
The Central National Bank of Richmond, Richmond
Metropolitan National Bank, Richmond
The Colonial-American National Bank of Roanoke, Roanoke
Farmers and Merchants National Bank, Winchester
The Shenandoah Valley National Bank of Winchester, Winchester.

15233
7474
4375
13230
14394
11280
4668
3417
12292

Valley National Bank of Auburn, Auburn
The Bellingham National Bank, Bellingham
The National Bank of Commerce of Seattle, Seattle
The Pacific National Bank of Seattle, Seattle
Peoples National Bank of Washington, Seattle
Seattle-First National Bank, Seattle
Old National Bank of Washington, Spokane
National Bank of Washington, Tacoma
Puget Sound National Bank, Tacoma

WASHINGTON

187

TABLE B-17
Domestic branches of National banks closed, by States, calendar 1967
Branches closed
Charter
No.

Title and location of bank
Local

Total.

49
ALASKA

14651

National Bank of Alaska, Anchorage

6268
10391
13044
1741
15149

First National Bank & Trust Co., Ontario
United States National Bank, San Diego
Bank of America National Trust & Savings Association, San Francisco.
Crocker-Citizens National Bank, San Francisco
Tiburon National Bank, Tiburon

CALIFORNIA

CONNECTICUT

The First New Haven National Bank, New Haven
GEORGIA

The First National Bank of Atlanta, Atlanta
IDAHO

1668 The Idaho First National Bank, Boise
INDIANA

The First Merchants National Bank of Michigan City, Michigan City.
KANSAS

11707

First National Bank in Great Bend, Great Bend
KENTUCKY

14894 Fort Knox National Bank, Fort Knox
109 First National Lincoln Bank of Louisville, Louisville
5132
The Lincoln County National Bank of Stanford, Stanford
LOUISIANA

14977

Whitney National Bank of New Orleans, New Orleans
MASSACHUSETTS

1129 Merrimack Valley National Bank, Haverhill
13395 The Barnstable County National Bank of Hyannis, Hyannis.
14798 South Shore National Bank, Quincy
13738
15575
191
12697
13739

Manufacturers National Bank of Detroit, Detroit
Union Bank & Trust Co., (National Association), Grand Rapids..
The First National Bank & Trust Co., of Kalamazoo, Kalamazoo.
The Dart National Bank of Mason, Mason
Community National Bank of Pontiac, Pontiac

188

Total

TABLE B-17—Continued
Domestic branches of National banks closed, by States, calendar 1967

Charter
No.

Title and location of bank

local

MISSOURI

4157

The First National Bank of Independence, Independence.
NEBRASKA

13408
3496

First National Bank& Trust Co. of Fremont, Fremont.,
The First National Bank of North Platte, North Platte..

4274
1316
14177
11847

Trust Company National Bank, Morristown.
National Newark & Essex Bank, Newark
The Sea Bright National Bank, Sea Bright
The First National Bank of South Plainfield, South Plainfield..

12997
2370
9716
13393
9135

Franklin National Bank, Mineola
The Chase Mahattan Bank (National Association), New York
The North Creek National Bank, North Creek
Lincoln National Bank & Trust Co. of Central New York, Syracuse.
The Emerson National Bank of Warrensburgh, Warrensburg

9164
13761
10610
5450

First Union National Bank of North Carolina, Charlotte.,
North Carolina National Bank, Charlotte
Southern National Bank of North Carolina, Lumberton..
The First National Bank of Morganton, Morganton

NEW JERSEY

NORTH CAROLINA

OHIO

7639 The First National Bank of Baltimore, Baltimore.
OREGON

15163

Emerald National Bank, Bethel-Danebo

3147
5496
252
14093

The National Bank of Malvern, Malvern...
The First National Bank of Milford, Milford.
Pittsburgh National Bank, Pittsburgh
National Bank of Union City, Union City. . .

PENNSYLVANIA

SOUTH CAROLINA

2044 The South Carolina National Bank of Charleston, Charleston.
14211 The First National Bank of South Carolina, Columbia
TENNESSEE

The First National Bank of McMinn County, Athens.

189

TABLE

B-18

Principal assets, liabilities, and capital accounts of National banks, by deposit size, year end 1966 and 1967
[Dollar amounts in millions]
Securities
Number
of banks

Total
assets

Cash and Loans and
cash items discounts

Total

U.S. Government
obligations

Deposits
Fixed
assets

Total

Demand

Time and
savings

Capital
stock

Surplus,
undivided
Capital
notes and profits,
debentures
and
reserves

1967
4,758 $263, 375

Total
Banks with deposits of—
Less than $1.0
1.0 to 1.9
2.0 to 4.9
5.0 to 9.9
10 0 to 24 9
25.0 to 49.9 . .
50.0 to 99.9
100 0 to 499 9
Over 500.0

$46, 634 $136, 753 $69, 656

$34, 308

$3, 876 $231, 374 $123,038 $108, 336

$5, 367

$1, 235

$13, 128

32
195
1, 000
1, 279
1,254
472
230
226
70

29
350
3, 964
10, 323
21, 789
18, 007
17, 315
51, 542
140, 055

7
60
593
1,422
2,906
2,431
2,486
9, 339
27, 389

11
153
1,874
4, 923
10, 695
8,895
8,635
26, 317
75, 250

11
130
1,400
3,687
7,517
6,001
5, 594
14, 143
31, 173

9
99
929
2, 139
4,032
3,056
2,888
6, 952
14,204

0
4
64
177
381
309
288
838
1,816

26
304
3,528
9, 315
19, 697
16, 254
15, 647
46, 118
120,485

21
183
1,883
4,622
9,455
7,934
7, 761
25, 874
65, 305

5
121
1,645
4,693
10, 241
8, 320
7,886
20, 244
55, 181

1
12
105
236
458
372
372
1, 104
2, 707

0
0
0
1
16
28
29
147
1,014

31
286
620
1, 198
906
812
2,496
6, 777

4, 799

235, 996

41, 690

128, 609

57, 668

30, 355

3,451

206, 456

112,377

94, 079

5, 138

1, 161

12, 160

45
244
1, 152
1, 299
1, 172
416
205
201
65

42
436
4,531
10,340
20, 290
15, 912
15, 632
46, 019
122, 794

9
78
695
1,481
2,797
2,267
2,345
8,733
23, 285

17
194
2, 162
4,940
10, 121
8,015
8,094
24, 247
70, 819

14
156
1, 562
3,633
6, 738
5,081
4,688
11,552
24,244

11
122
1,065
2, 191
3, 781
2, 752
2, 538
6, 141
11, 754

1
8
78
174
357
274
253
729
1,577

35
376
4,015
9, 305
18, 341
14,318
14, 096
41, 135
104, 838

27
227
2,206
4, 772
9,065
7,267
7, 152
23, 738
57, 926

8
149
1,812
4,533
9, 276
7,051
6, 941
17,397
46, 912

2
17
137
252
446
357
350
1,015
2, 562

0
0
1
2
16
24
27
134
957

4
39
326
644
1, 132
818
770
2,283
6, 144

1966
Total
Banks with deposits of—
Less than $10
1 0 to 1 9
2.0 to 4.9.
5.0 to 9.9. . .
10.0 to 24.9 .
25.0 to 49.9
50.0 to 99.9
100.0 to 499 9
Over 500.0

NOTE : Data may not add to totals because of rounding.

TABLE B-19
Dates of reports of condition of National banks, 1914-67
[For dates of previous calls, see Annual Report for 1920, vol. 2, table No. 42, p. 150]
Jan.

Tear
"914
915
"916
1917
C
J8
919

. .

Feb.

Mar.Apr.
4
4
7
5
4
4
:

28
21

• Q20

921
922

• 926

...

..
28

6'
12

23
27
27
25
5
4
4
31
7
29
26
4
4
13
20

"c>50

.. .
31

20
15
11
10
14
4
12
15

12
26
18
15
26
5
25

30
23
30
20
29
30
30 i
30
30
30
30
30
30
30
30
29
30
30
30
30
30
29
30
30
30
30
29
30
30
30 =
30 •

30
29
30
30
30
30
30
30
30
30
30
30
6
23
10
15
30
30
29
30
30
30
30

July

Aug.

"si

Sept.

Oct.

12
2
12
11

Nov.

10
17
20
1
17
15

12
8
6
15
14

31
31
27
31
31
31
29
31
29
31

10
10
3
4

31
31
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
30
31
31
31
31

24
29
30
25
17
1
28
2
24
!
!

Dec.

18
30
6
1
4
10
5
30
7
5
26
11
24
6
3
27
28
30
1
13
20
4

coco?

12
11
24
9

June

eoeoef

" 925

1951
1952
1953
1
954
1955
1
956
'957
1958
ig59
I960
1961
1962
1963
1964
1965
1966
1967

5
3

1
1
1
10
12
4

" c»23
• 024

927
928
"929
"930
Cl
31
932
"933
1934
l c ^5
Ici36
1937 ..
1938
1939
:c40
lci41
1942
1943
[Q44
l c 45
I C 46
1947
1948
-Q49

May

31
31
31
31
31
31
31
31
31
30
28
20
31
31
31
30

191

NOTES

Act of Feb. 25, 1863, provided for reports of condition on
the 1st of each quarter before commencement of business.
Act of June 3, 1864—1st Monday of January, April, July,
and October, before commencement of business, on form prescribed by Comptroller (in addition to reports on 1st Tuesday of each month showing condition at commencement of
business in respect to certain items; i.e., loans, specie, deposits,
and circulation).
Act of Mar. 3, 1869, not less than 5 reports per year, on
form prescribed by Comptroller, at close of business on any
past date by him specified.
Act of Dec. 28, 1922, minimum number of calls reduced
from 5 to 3 per year.
Act of Feb. 25, 1927, authorized a vice president or an
assistant cashier designated by the board of directors to verify
reports of condition in absence of president and cashier.
Act of June 16, 1933, requires each National bank to
furnish and publish not less than 3 reports each year of
affiliates other than member banks, as of dates identical with
those for which the Comptroller shall during such year
require reports of condition of the bank. The report of each
affiliate shall contain such information as in the judgment of
the Comptroller shall be necessary to disclose fully the relations between the affiliate and the bank and to enable the
Comptroller to inform himself as to the effect of such relations upon the affairs of the bank.
Sec. 21 (a) of the Banking Act of 1933 provided, in part,
that after June 16, 1934, it would be unlawful for any private
bank not under State supervision to continue the transaction

192

of business unless it submitted to periodic examination by
the Comptroller of the Currency or the Federal Reserve bank
of the district, and made and published periodic reports of
conditions the same as required of National banks under
sec. 5211, U.S.R.S. Sec. 21 (a) of the Banking Act of 1933,
however, was amended by sec. 303 of the Banking Act of
1935, approved Aug. 23, 1935, under the provisions of which
private banks are no longer required to submit to examination by the Comptroller or Federal Reserve bank, nor are they
required to make to the Comptroller and publish periodic
reports of condition. (Five calls for reports of condition of
private banks were made by the Comptroller, the first one
For June 30, 1934, and the last one for June 29, 1935.)
Sec. 7(a) (3) of the Federal Deposit Insurance Act (Title
12, U.S.C., sec. 1817(a)) of July 14, 1960, provides, in part
that, effective Jan. 1, 1961, each insured National bank shall
make to the Comptroller of the Currency 4 reports of condition annually upon dates to be selected by the Comptroller,
the Chairman of the Board of Governors of the Federal Reserve System, and the Chairman of the Board of Directors of
the Federal Deposit Insurance Corporation, or a majority
thereof. Two dates shall be selected within the semiannual
period of January to June, inclusive, and 2 within the semiannual period of July to December, inclusive. Sec. 161 of
Title 12 also provides that the Comptroller of the Currency
may call for additional reports of condition, in such form and
containing such information as he may prescribe, on dates to
be fixed by him, and may call for special reports from any particular association whenever in his judgment the same are
necessary for use in the performance of his supervisory duties.

TABLE

B-20

Total and principal assets of National banks, by States, June 30,

1967

[Dollar amounts in millions]
US.
Number
of banks

Total
assets

Cash
assets*

Government
obligations,
net

net

Other
bonds,
notes,
net\

State
and local
securities,

Loans

and
discounts

Federal
funds
sold

Direct
lease
financing

net

United States.

4,780

$242, 039

$39,462

$29, 544

$27, 660

$5, 409

$130,082

$2, 643

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida

87
5
4
67
86
118
30
5
9
200

2,714
289
1,964
1,215
30,485
2,511
2,210
28
1,778
6,224

454
41
229
215
4,172
427
347
3
314
1,132

424
46
187
160
2,807
316
180
8
375
990

338
30
171
157
4,002
236
327
—
96
717

87
8
62
31
799
34
49
2
23
252

1,344
152
1,217
609
17,277
1,401
1,226
14
864
2,841

10
0
13
13
161
16
12
69
88

0
1
—
135
4
1
0
0
1

Georgia. . .
Hawaii....
Maho
Illinois
Indiana.. .
Iowa
Kansas....
Kentucky..
Louisiana..
Maine

60
2
9
423
123
102
171
80
47
21

3,266
471
747
21, 007
5,337
1,720
2,123
1,670
3,079
507

588
77
89
3,050
967
340
342
286
576
65

305
51
89
3,127
902
262
387
280
504
58

320
58
93
2,241
492
166
248
190
344
73

82
18
16
577
141
54
80
26
52
9

1,821
247
441
11,174
2,575
856
1,007
825
1,488
284

30
0
—
275
157
11
25
30
48
5

10
1
—
53
7
1
—
1
1
0

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire..

48
90
98
195
36
98
49
127
3
52

2,199
6,537
9,719
4,929
1, 168
4,459
698
1,882
515
552

407
1,223
1,362
849
205
873
90
333
71
78

260
565
1,410
607
155
560
114
234
73
60

214
756
1, 103
551
137
469
79
178
66
52

49
60
241
132
23
86
12
93
17
3

1, 175
3,619
5,358
2,675
604
2,319
378
985
262
337

53
113
28
15
10
58
4
18
1
12

2
5
9
5
—
12
—
1
—
0

New Jersey
New Mexico
New York
North Carolina...
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

146
34
186
24
42
224
220
12
343
4

7,620
782
39, 045
2,227
597
10, 805
3,585
2,981
15, 957
889

907
124
7,607
403
69
1,465
687
455
2,136
108

977
125
3,469
180
107
1,602
565
347
1,978
64

1,203
75
3,717
300
69
1,483
397
343
2,147
143

165
18
530
56
16
271
117
52
278
7

4,115
386
21,623
1,214
316
5,649
1,680
1,675
8,862
550

92
31
485
7
3
131
63
2
219
1

2
—.
53

South Carolina.,
South Dakota. ..
Tennessee
Texas
,
Utah
Vermont
Virginia
Washington
West Virginia...
Wisconsin
Wyoming
,
Virgin Islands..,

26
34
77
546
13
27
114
28
80
114
40
1

1,092
673
4, 118
15, 493
787
350
3,830
4, 145
1, 154
3,402
454
48

207
84
757 ;
3,069
128
33
531
708
157
557
61
3

151
128
565
1,906
62
42
508
430
281
465
85
13

95
58
423
1,701
123
40
436
453
124
377
40
7

22
15
66
389
14
6
81
75
25
75
12
—

572
369
2,168
7,772
432
217
2,165
2,331
519
1,826
241
24

16
1
37
186
9
5
20
19
23
17
1
0

0
—
0
1
2
0
1
3
2
3
—
0

2,691

449

543

160

1,377

District of Columbia-all %

$360

0
16
4
4
19
0

•Cash, balances with other banks, a i d cash items in process of collection.
fEffective June 30, 1967, includes stock of Federal Reserve and other corporate stock.
JIndudfs National and iiuri-Natioriiil banks in the District of Columbia, all of whiV.h are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

193

TABLE

B-21

Total and principal liabilities of National banks, by States, June 30,

1967

[Dollar amounts in millions]
Total
liabilities

United States.

Total
deposits

$222, 941

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
[Delaware
District of Columbia.
Florida

2,487
271
1, 824
1,112
28, 520
2,312
2,036
26
1,651
5,737

Georgia
[Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky....
[Louisiana. . .
Maine

2,982
421
695
19, 385
4, 945
1, 586
1,926
1, 527
2,807
459

Demand
deposits,
total

Time and
savings deposits, total

$103, 503

Demand
deposits,
IPC*

$80,208

Time
deposits,
IPC

$90,488 j

Federal
funds
purchased

$3, 140

$211,098

$107,595

2,429
268
1,717
1,088
27, 241
2,255
1,950
26
1,611
5,581

1,404
138
742
655
10, 591
1,142
1,078
12
968
3,033

1,025
130
975
433
16, 650
1, 113
872
14
643
2,548

1,045
108
596
487
8,796
894
946
11
856
2,269

963
82
919
402
13,831
996
777
14
633
2,250

6
0
60
5
181
17
3
0
12
33

2,833
414
683
18, 300
4, 687
1,546
1,900
1,504
2, 755
439

1,733
209
333
9,290
2,560
894
1,161
904
1, 710
235

1, 100
205
350
9,010
2,127
652
739
600
1,045
204

1,240
159
252
6,932
1,788
630
747
735
1,215
209

978
168
349
7,950
1,935
621
686
565
881
194

53
0
0
280
98
18
5
1
9
3

772
1, 952
5, 259
2, 190
377
1,502 •
330 j
645
232
187 ;

912
2,741
2,787
1,474
408
1,634
228
732 i
166 i
242 -

729
1,718
4,622
2,018
362
1,357 ,
308 I
630 I
221 !
172

26
69
88
107
26
108
7
33
1
2

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
N e w Hampshire

2, 026
5,974
9, 104
4, 553
1, 070
4, 060
648
1,721
474
499

1,945
5, 635
8, 822
4, 358
1,021
3,877
623
1, 669 :
465 :
474

1, 173
3,683
3, 563
2, 168
644
2, 375
293
1, 024
233
287

New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

7, 053
722
35, 785
2, 059
554
9, 946
3, 253
2, 779
14, 455
827

6,807
705
31,495=
1,956 •
543
9, 586
3, 185
2, 680
13, 842
782

3, 115
400
17,430
1,081
241
4,406
1,878
1,118
6,267
282

3, 692
305
14, 065
875
302
5, 180
1, 307
1, 562
7, 575
500

South Carolina.
South Dakota...
Tennessee
Texas
Utah
Vermont
Virginia
Washington. . . .
West Virginia...
Wisconsin
Wyoming
Virgin Islands. .

1, 000
623
3, 782
14, 181
728
322 I
3,519
3,854
1,043
3, 158
414
45

952
609
3,641
13, 594
706
314
3,397
3,661
1,019
3,057
403
44

735
285
2,034
8, 020
296
114
1,576
1,874
542
1,459
189
19

217
324
1, 607
5, 574
410
200
1,821
1,787
477
1,598
214
25

District of Columbia—all f.

981

2,614
298
11, 192
838
197
3,463
1,344
920
5,097
217
605
216
1, 349
5,798
224
100 •
1,283
1,515
409
1, 141
139
9

3,549
249
11,220
721
282
4,759
1,174
1,281
6,874
469
198
295
1,379
4,608
339
194
1,706
1,765
473
1,407
197 ,
15 I

959
29
98
24
25
207
22
7
3
22
301
9
0
31
88
1
23
3
0

960 j

*IPC deposits are those of individuals, partnerships, and corporations.
flncludee National and non-National banks in the District of Columbia, all of which are supervised by ihc CuinpLjuller of the
Currency.
NOTE : Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000'.

194

TABLE

B-22

Capital accounts of National banks, by States, June 30,

1967

[Dollar amounts in millions]
Total capital
accounts

Debentures

Preferred
stock

Surplus

Common
stock

Undivided

Reserves

profits

$1,227

$30

$5, 252

$8, 465

$3, 539

$585

227
18
140
103
1,965
199
174
2
127
487

0
0

71
5

26
1
144
4
11
0
0
23

0
0
0

63
46
1
35
184

93
5
58
43
846
91
92
1
65
199

51
7
21
26
431
40
24

12
1
2
2
22
1
1

26
67

1
14

Georgia... .
Hawaii
Idaho
Illinois
Indiana
Iowa

284
50
52
1,622
392
134
197
143
272
48

61
9
16
537
94
36
57
31
62
18

103
18
28
771
182
59
88
74
155
18

37
9
8
250
94
37
47
35
43
11

26
2

46
151
160
119
25
108
19
43
17
10

80
298
264
154
61
158
19
62
16
29

40
99
109
82
5
98
11
49
5
13

5
5
32
5
1
9

160
20
810
39
14
236
92
71
306
16

263
20
1,222
85
17
423
132
78
787
31

105
9
435
26
11
169
86
48
284
14

11
11
199
3

50
21
156
547
30
11
152
126
56
109
20
1

18
12
69
240
10
7
59
78
26
45
12
1

1
1
8
38
0
1
1
2
5
8
1

100

....

South Carolina
South Dakota
Tennessee
Texas .
Utah
Vermont
Virginia .
Washington
West Virginia
Wisconsin. . . .
Wyoming
Virgin Islands
District of Columbia—all*

173
563
615
376
98
399
50
161
41
53
567
60
3,260
168
43
859
332
202
1,502
62
92
50
336
1 312
59
28
311
291
111
244
40
3
205

57
12
0
11
13
0
9

o
o

10
47
16
6
26
1
3

o
28
0
574
15
1
27
18
0
61
1

0
0
0

0
3
0
0
0
0

o0
0
20

oo
0
O—OI

New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

. ..

2
0
0
3
1
0

0
1
0
0
0
0
0
0

23
16
84
435
19
8
97
85
24
79
6
1

0
19
52
0

OOOI

Maryland...
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

oeo c

Kentucky
Louisiana
Maine

ocoo

United States

CO CO CM

$19, 098

Alabama
Alaska
Arizona
Arkansas
California
Colorado..
Connecticut
Delaware...
District of Columbia
Florida

53
9
2
3
3
1
1

4
3
1

4
4
5
63
0

*Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE : Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

293-544—68-

195

TABLE

B-23

Total and principal assets of National banks, by States, Dec. 30,

1967

[Dollar amounts in millions]
US. GovNumber
of banks

United States.

Cash
assets*

Total

i
88
5
4
67
80
118
30
5
9
200

Georgia...
Hawaii....
Idaho
Illinois
Indiana...
Iowa
Kansas
Kentucky..
Louisiana..
Maine

9
422
123
102
171
80
47
21

Maryland
Massachusetts...
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire.

48
89
98
195
36
98
48
127
3
52

New Jersey
New Mexico
New York
North Carolina..
North Dakota...
Ohio
Oklahoma
Oregon
Pennsylvania....
Rhode Island. . .

144
34
184
25
42
223
220
12
336
4

South Carolina..
South Dakota. .,
Tennessee
Texas
Utah
Vermont
Virginia
Washington....
West Virginia..
Wisconsin
Wyoming
Virgin Islands..

26
35
77
542
12
27
113
27
80
116
40
1

District of Columbia—all t.

State
and local
securities,
net

Other
Loans and
securities, discounts,
net
net

Federal
funds
sold\

4, 758 { $263,375

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia.
Florida

obligations,
net

2,951
317
2,087
1,356
32, 233
2,786
2,339
30
1,900
7,100
3, 513 |

484
828
22, 553
5,677
1,923
2,341
1,891
3,405

535
2,311
7,196
10,482
5,396
1,261
5,023

754
2, 103

531
602
8,269

824
42, 964
2,567

660
11,714

4, 110
3, 195
17, 091

957
1,216

742
4,521
17,202

825
372
4,212
4,522
1,230
3,721

504
49
2,869

$6,346

$136, 753

$2, 562

35
192
171
3,482
255
347
0
97
761

44
796
38
39
1
27
313

1,409
156
1,246
639
18, 177
1,466
1,302
14
891
3,062

16
3
7
4
277
19
25
1
57
118

337
56
121
3,287
997
304
440
330
568
71

316
72
102
2,341
498
183
272
209
360
71

85
20
11
892
142
73
110
31
54
6

257
459
11, 546
2,672
896
1,044
886
1,567
292

2
4
216
98
10
25
55
50
4

413
1,466
1,582
988
211
1,117
101
436
72
87

294
797
1,469
698
177
697
139
261
76
97

272
775
1,099
603
156
497
89
195
69
48

42
66
245
168
26
166
18
108
13
4

1,189
3,797
5,809
2,826
652
2,380
379
1,054
276
337

50
67
47
13
4
60
7
8
1
17

1,012
138
8,665
494
79
1,767
910
489
2,420
98

1,142
139
4,340
262
132
1,988
626
416
2,351
90

1,322
90
4,202
309
79
1,560
453
352
2,322
175

214
17
611
68

4,338
23, 021
1,358

324

238
152
86
334

5,798
1,832
1,742
9,061

566

69
24
392
7
2
151
58
2
219
0

238
97
916
3,775
133
37
592
763
178
656
89

162
151
617
2,190
73
53
562
521
299
554
101
3

108
68
428
1,824
119
34
467
543
137
424
43

28
23
67
466
14
7
98
81
34
88
12

623
382
2,319
8,266
460
230
2,333
2,452
537
1,887
243
27

26
2
43
164
4
4
63
14
18
23

514

605

175

1,413

$46,634

$34,308 \ $29,002

541
45
291
271
5,037
545
371
4
354
1,467

466
57
230
194
3,202
380
179
9
436
1,167 |

747
54
112
3,618
1,157
421
411
347
738
78

392

Direct
lease
financing

$412
0
1
162
4
1
0
0
1
10
1
61
6

2
5
11
5

62
1
0
16
4
4
20
0

*Cash, balances with other banks, and cash items in process of collection,
f Includes securities purchased under eigreements to resell.
jlncludes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of
the Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

196

TABLE

B-24

Total and principal liabilities of National banks, by States, Dec. 30,

1967

[Dollar amounts in millions]
Total
liabilities

Total
deposits

Demand
deposits,

Time and
savings deposits, total

Demand
deposits,
IPC*

Time
deposits,
IPC

Federal
funds
purchased^

$3, 182

United States. .

$243, 645

$231, 374

$123, 038

$108, 336

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia.
Florida

2,718
298
1,947
1,245
30, 223
2,580
2, 160
28
1,769
6,595

2,648
295
1,827
1,218
28, 732
2,530
2,070
27
1,727
6,413

1,541
153
792
761
11, 946
1,380
1,186
13
1,062
3,696

1,107
142
1,035
457
16, 786
1,150
884
14
665
2,717

1,129
125
647
573
10, 023
1,092
1,050
12
913
2,617

1,027
88
965
421
13, 932
1,053
798
15
654
2,414

7
0
74
6
394

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

3,215
433
775
20, 799
5,269
1,783
2, 138
1,743
3, 125
486

3, 107
428
760
19, 729
5,020
1,753
2, 111
1,715
3,061
469

1,953
211
382
10, 269
2,872
1,037
1,291
1,075
1,972
262

1,154
217
378
9,460
2,148
716
820
640
1,089
207

1,406
164
287
7,867
2,031
735
855
879
1,414
220

1,040
173
378

24
0
0
328
93
2
4
4
16

2, 134
6,585
9,854
5,013
1, 161
4,611
702
1,937
489
547

2,052
6, 153
9,558
4,844
1,099
4,436
680
1,886
478
515

1,252
4,135
4,024
2,528
703
2,849
334
1,194
235
322

800
2,018
5,534
2,316
396
1,587
346
692
243
193

996
3,082
3,220
1,758
475
1,860
263
837
180
257

758
1,810
4,894
2,152
377
1,459
324
677
230
186

24
105
101
71
36
97
2
27
1
2

New Jersey
New Mexico
New York
North Carolina..
North Dakota...
Ohio
Oklahoma
Oregon
Pennsylvania....
Rhode Island. . .

7,683
762
39, 628
2,392
615
10,831
3,768
2,989
15, 559
886

7,430
746
35, 428
2,257
601
10, 468
3,654
2,886
14, 893
837

3,582
432
20, 280
1,285
268
5,072
2,280
1,239
6,942
311

3,848
314
15, 148
972
333
5,396
1,374
1,647
7,951
526

2,943
336
13, 588
1,000
228
4,044
1,714
1,047
5,775
250

3,692
263
12, 243
799
315
4,987
1,247
1,351
7,182
481

23
1
855
50
1
63
60
34
213
23

South Carolina.
South Dakota...
Tennessee
Texas
Utah
Vermont
,
Virginia
Washington
West Virginia...
Wisconsin
,
Wyoming
Virgin Islands..,

1, 122
689
4, 173 '
15,866 i
764
344
3,894
4,222
1, 116
3,469
463
46

1,066
674
3,971
15, 254
737
335
3,770
4,061
1,084
3,383
455
43

840
325
2,352
9,452
323
123
1,831
2,109
586
1,729
231
16

226
349
1,619
5,802
414
212
1,939
1,952
498
1,654
224
27

683
263
1,493
6,821
243
105
1,468
1,751
438
1,355
166
II

208
318
1,440
4,862
345
205
1,817
1,920
493
1,499
204
16

2,591

1,578

1,013

1,373

987

Maryland
Massachusetts..
Michigan
,
Minnesota.
Missouri. t
Montana
Nebraska
Nevada
New Hampshire.,

District of Columbia—all %

2,658

$92, 686 1

$95, 104

1,996
664
724
604
918
200

0
9
43

43
261
15
18
30
5
0
2
13

*IPC deposits are those of individuals, partnerships, and corporations.
•(•Includes securities sold under agreements to repurchase.
jlncludes National and non-National banks in the District of Columbia, all of which are supervised by the Compitroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

197

TABLE

B-25

Capital accounts of National banks, by States, Dec. 30,

1967

[Dollar amounts in millions]
Total capital
accounts

Common
stock

Preferred
stock

Debentures

Undivided
profits

Surplus

Reserves

$1, 235

$55

$5, 312

$8, 832

$3, 549

$747

233
19
140
111
2,010
206
179
2
131
505

0
25
5
139
4
11
0

0
0
0
0

12
1
2
4
29
1
1

95
7
58
45
941
93
93
1
69
204

54
5
22
26
383
44
27

72
6
33
31
518
64
47
1
36
190

298
51
53
1,754
407
140
203
148
280
49

60
12
0
12
13
0
3
0
8
0

0
0

61
9
16
541
95
37
57
32
64
18

105
18
29
782
186
62
90
75
159
18

42
10
8
277
105
37
50
37
45
12

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana..
Nebraska
Nevada
New Hampshire

177
611
628
383
100
412
52
166
42
55

2
12
46
16
6
26
1
3
0

0
0
3

46
151
161
121
26
108
19
44
17
10

80
320
283
154
66
164
19
63
17
30

43
94
95
86
1
104
13
52
6
13

6
34
40
6
1
10

New Jersey
New Mexico...
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

586
62
3,336
175
45
883
342
206
1,532
71

28
1
571
15
1
27
20
0
61

164
20
817
43
14
239
93
71
308
18

279
20
1,298
89
18
452
133
78
806
32

103
9
406
25
11
160
93
52
295
14

12
12
203
3
1
5
3
5
61
7

South Carolina
South Dakota
Tennessee
Texas
Utah.
Vermont
Virginia..
Washington
West Virginia
Wisconsin. .
Wyoming..
Virgin Islands

94
53
348
1,336
61
28
318
300
114
252
41
3

23
17
89
442
19
8
98
86
25
81
6

51
22
158
559
32
11
154
127
58
112
20
2

19
13
73
237
10
8
63
84
26
48
13
1

1
1
9
42
0

104

. . . .

District of Columbia—all*

211

0
19
54
0
2
0
0
3
1
0
13

o3
0
0

0
3
0

oooo

Georgia
Hawaii
Idaho
Illinois . .
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

ooo 1 o

$19, 730

United States
Alabama
Alaska....
Arizona....
. .
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida

0
0
41

0
0
0

1
0
0
0
2
0
1
0
0
0

o0
0
0

25
71

j o a N a ! bants in the Dktrict of Ccl'^nsfeiaj all of which arc supervised by the
the Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

198

15
30
2
139
8
4
3
4
1
1

4
2
2

1
3
5
8
1

TABLE

B-26

Loans and discounts of National banks, by States, Dec. 30,

1967

[Dollar amounts in millions]
Loans

Loans
to jvnanrial institutions

Loans
to purchase
or carry
securities

Loans
to
farmers

\jOnvnercial and
individual
loans

Personal
loans to
individuals

Other
loans

$2, 841 $139, 594 $32, 944

$8, 574

$4, 700

$4, 591

$55, 163

$29, 974

$3,648

13
227
34
18

173
48
603
200
3

476
56
418
198
7,292
440
393
3
235
1,099

524
33
310
200
3,444
406
386
4
200

77
1
4
8
306
18
49

Loans
discounts,
gross

United States

$136, 753

Loans
secured
by real
estate

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida

1,409
156
1,246
639
18, 177
1,466
1,302
14
891
3,062

34
5
16
11
321
24
25
0
16
50

1,443
161
1,262
650
18, 498
1,490
1,327
14
907
3, 112

237
71
313
164
5,720
294
434
7
320
646

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

1,882
257
459
11,546
2,672
896
1,044
886
1,567
292

34
4
8
309
52
18
16
16
27
6

1,916
261
467
11,855
2,724
914
1,060
902
1,594
298

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

1,189
3,797
5,809
2,826
652
2,380
379
1,054
276
337

23
85
109
46
16
40
8
20
3
6

New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

4,338
392
23,021
1,358
324
5,798
1,832
1,742
9,061
566

South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Virgin Islands

623
382
2,319
8,266
460
230
2,333
2,452
537
1,887
243
27

District of Columbia—all*,

1,413

36
19
906

27
84

107
136

18
106

361
115
151
2,034
887
241
152
239
267
97

140
4
8
1,026
161
30
41
54
116
6

27
5
8
670
44
16
15
17
55
3

18
5
75
325
75
194
252
51
19
10

740
66
98
5,719
693
214
341
231
708
93

594
52
121
1,840
786
198
250
284
373
85

36
14
6
241
78
21
9
26
56
4

1,212
3,882
5,918
2,872
668
2,420
387
1,074
279
343

372
542
2,333
727
125
469
107
128
102
85

75
270
356
214
19
218
2
28
10

29
37
106
71
15
94
2
40
5
3

17
5
49
157
31
105
80
369
6
5

363
2, 141
1,618
1,052
249
958
90
293
76
108

335
768
1,262
570
206
528
104
203
77
128

21
119
194
81
23
48
2
13
3
6

96
11
603
27
8
114
32
25
180
7

4,434
403
23, 624
1,385
332
5,912
1,864
1,767
9,241
573

1,809
73
3,709
217
108
1,745
322
455
2,554
282

212
15
1,850
61
2
297
82
113
487
30

93
5
1,858
29
3
130
13
17
138
1

20
43
79
23
67
81
175
91
121

1,044
136
12,640
587
80
1,603
758
726
3,498
135

1,150
120
2,835
440
69
1,845
449
345
2,049
97

106
11
653
28
3
211
65
20
394
28

12
12
46
157
7
3
39
50
11
43
4

635
394
2,365
8,423
467
233
2,372
2,502
548
1,930
247
27

88
102
346
912
171
108
695
586
192
653
63
15

25
7
165
610
26
1
92
177
14
100
3
0

19
1
57
498
22
3
47
27
5
31
3

14
125
44
415
20
8
53
135
11
49
49
0

230
82
894
3,731
138
45
627
960
119
586
74
9

235
73
810
1,994
82
66
795
559
200
435
54
3

24
4
49
263
8
2
63
58
7
76
1

346

354

1,434

178

•Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of
the Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts of less than $500,000.

199

TABLE

B-27

Income and expenses of National banks, * by States, year ended Dec. 31, 1967
[Dollar amounts in thousands]
United
States

Alabama

88
4,758
Number of banks
Current operating revenue:
Interest and dividends on—
$1,400, 999 $19, 669
U.S. Government obligations
1, 121,994 12, 843
Other securities
8, 458, 936 94, 890
Interest and discount on loans \
Service charges and other fees on banks'
169, 483 1,483
loans
576, 770 9,318
Service charges on deposit accounts
Other service charges, commissions, fees,
229, 992 1,942
and collection and exchange charges.....
435, 331 4,052
Trust department
257, 438 2,211
Other current operating revenue

Total current operating revenue

Current operating expenses:
Salaries and wages:%
Officers
Employees other than officers

Number of officers
Number of employees other than officers

Officer and employee benefits—pensions, hospitalization, social security, insurance, etc.
Fees paid to directors and members of executive, discount and other committees
Interest on time and savings deposits
Interest and discount on borrowed money § .
Net occupancy expense of bank premises. . .
Furniture and equipment—depreciation,
rents, servicing, uncapitalized costs, etc. . .
Other current operating expenses
Total current operating expenses

Net current operating earnings

Alaska

Arizona

Arkan-

California

Colorado

118

Connecticut

741
148
329

District
of Columbia

Florida
200

$2, 079 $9, 586 $7, 812 $143, 045 $15, 792 $7, 943
6,689
7,611
164,060 9,242 12, 547
1,290
11, 862 83, 873 42, 228 1, 182, 916 96, 021 82, 668
1,249
1,590

Delaware

Georgia

Hawaii

$396 $17, 696 $46, 036 $15, 486 $2, 247
3,453 34, 196 11,916 2,415
27
893 54, 360 194
~"3 112 126, 830 18, 034

2,287
7,978

201
3,646

37, 045
113,068

2,480
9, 701

1,233
7,616

42
71

2, 161 5,895 3,935
4, 383 19, 396 13,000

2, 950
3, 137
1,250

1,095
804
577

26, 456
48, 856
52, 496

2, 689
8,336
4,345

2,243
8,668
1,510

13
0
23

5,559 10, 126
877
4, 156 12, 904 6,688
8,338 3,486
541

1,408
1, 185
492
781
859

12, 650, 943146, 408 19, 288 118,672 63, 052 1, 767, 942 148, 606 124, 428 1,465 87, 627 326, 436 191, 46727,421

901, 734
1, 673, 051
75, 808
369, 780
391, 192

12, 675 2,037 9,446 6,516
20, 677 3,559 19, 057 8,062
615
855
1, 075
130
5, 448
4, 162 2, 102
652
5,045

562

3,815

1,959

127, 649 13,320 11,238
250, 365 20, 766 21, 313
11, 466 /, 147
842
50, 466 10, 144 4, 502
53, 448

4,408

5,312

136 6,766 27, 261 15, 405 2, 354
253 12,022 46, 461 30, 352 4, 120
207
475
2, 389 1, 212
19
807
74 2, 404 11, 252 6, 535
35

1,926

9, 299

7,849

1,554

43, 286
692
4,418,031 40, 331
306
153, 825
489, 366 5, 117

35
117
518
4,826 41, 463 17,340
18
545
1, 531
974 5,405 2, 753

1,061
831
602
727, 882 46, 578 33, 614
874
24, 673
521
76, 455 7, 194 6,644

1, 798
766
15
387
486 26, 052 104, 920 47, 993
2
540 2,655
1,928
79
3,506 12, 283 9,864

94
8,256
70
1, 181

313, 130 4,421
1, 311,831 16, 205

851
1,981

37, 258 5,628 4,491
139, 273 17,281 14, 765

61
198

1,065
3,052

4, 132
12, 376

1,748
8, 107

9, 695, 446 105, 46914, 843 97, 342 47, 548 1,438,064 116,880 98, 500
2, 955, 497 40, 939

4,445 21,330 15, 504

329, 878 31, 726 25, 928

2,392 11, 978 7,046
8,396 41,871 26, 155

1,265 61, 987 258, 526 147, 35821, 746
200 25, 640 67, 910 44, 109

5,675

Recoveries, transfers from valuation reserves, and
profits
O n securities:
Profits and securities sold or redeemed. . .
Recoveries
Transfers from valuation r e s e r v e s . . . . .
O n loans:
Recoveries
Transfers from valuation reserves
All other
Total recoveries, transfers from valuation reserves
and profits
Losses, chargeoffs, and transfers to valuation
reserves:
On securities:
Losses on securities sold
Chargeoffs on securities not sold
Transfers to valuation reserves
On loans:
Losses and chargeoffs
Transfers to valuation reserves
All other
Total losses, chargeoffs, and transfers to valuation reserves
Net income before related taxes
Taxes on net income:
Federal
State
Total taxes on net income
Net income before dividends
Cash dividends declared:
On common stock
On preferred stock
Total cash dividends declared

91, 181
2,570
36, 704

2, 741
1
120

1,264
0
0

382
2
24

14,411
3
3,494

1,410
32
384

369
0
334

877
0
0

1,600
59
263

1,249
2
0

6,670
28, 705
86, 769

87
481
312

0
0
254

99
183
344

437
337
16, 924

235
46
554

3
82
702

63
0
2,205

215
329
2,523

21
2,964
705

1,034

35, 606

2,661

1,490

3, 145 4,989

4, 941

486
36
55

99
0
86

252, 599

3, 742

1, 518

75, 963
4,483
52, 179

414
21
163

0
0
0

786
0
0

321
95
123

1, 720
25
12,445

13, 563
519, 044
105, 434

248
7,065
1,000

0
1,040
129

0
8,643
1,638

128
2, 736
550

931
57, 299
15, 832

800
5,013
1, 103

0
4,396
2,071

1, 169 11,067

3, 953

88, 252

7,493

6,652

770, 666
2, 437, 430
594, 047
85, 892

8, 911
35, 770
9,441
1,658

679, 939 11, 099
1,757,491
794, 056
2, 124
796, 180
961,311

3, 735 11, 781 12, 585
1, 108 2,860
5
282

2,950
0

1, 113 3, 142 2, 950

52, 724
28, 702

6,530
1,519

3, 170
2, 162

81, 426

8,049

5, 332

2,622

8,639

9,635

195, 806 18, 845 15, 434

9,595
0

483
0

6,305
0

3,045
0

102, 883
0

8,456
0

7,890
0

6,305

3,045

102, 883

8,456

7, 890

2, 334

6,590

92, 923 10, 389

7,544

9,595

483
2, 139

2,648
4
211

152
16
124

431
1,259
5, 523 13, 771
673
2,938

19
9,380
3,659

6, 690 20, 831

13, 350

22, 095 52, 068 35, 700

277, 232 26, 894 20, 766

24, 671

15,076

9
0
54

9,050 11,870
0
0

10, 639
0

9,050 11, 870 10, 639
13,045 40, 198 25,061
40
0

6,011
0

14, 550 10, 270
0
0

6,011

14, 550 10, 270

7,034 25, 648 14, 791

Net income after dividends
19, 095, 324 225, 330 17,959 139, 593 104, 308 1, 969, 466198, 920 174, 178 2,236 127, 060 485, 877 278, 942 49, 702
Capital accountsjj
•
Ratios:
Net income before dividends to capital accounts
5.81
10. 27
8.86
9.47
9.20
(percent)
9.94
10.95
8.27
8. 98
14.60
6. 19 9.24

Total current operating expenses to total current
operating revenue (percent)
See footnotes at end of table.

76.64

72.04

76. 95

82.03

75.41

81. 34

78.65

79. 16 86. 35

70. 74

79.20

76.96

TABLE B-27—Continued

Income and expenses of National banks, * by States, year ended Dec. 31, 1967
[Dollar amounts in thousands]
Idaho

Number of banks
Current operating revenue:
Interest and dividends c
U.S. Government obligations
Other securities
Interest and discount on loans f
Service charges and other fees on banks' loans. .
Service charges on deposit accounts
Other service charges, commissions, fees and
collection and exchange charges
Trust department
Other current operating revenue
Total current operating revenue

Current operating expenses:
Salaries and wages: %
Officers
Employees other than officers

Number of officers
Number of employees other than officers

Officer and employee benefits—pensions, hospitalization, social security, insurance, etc. . . .
Fees paid to directors and members of executive,
discount and other committees
Interest on time and savings deposits
Interest and discount on borrowed money §. . ..
Net occupancy expense of bank premises
Furniture and equipment—depreciation, rents,
servicing, uncapitalized costs, etc.
Other current operating expenses
Total current operating expenses

Net current operating earnings

Illinois

Indiana
123

Iowa

Kansas Kentucky Louisiana
80

102

$4, 925 $138,532 $42, 141 $12,541 $19, 78&$13, 234 $24,
^,232
3,325 101,755 "" ; 816 7, 128 9, 987 7,238
- - - -12, 428
30, 209 688, 732 173, 392 56, 084 66, 947 55, 816 97, 861
877
854
519
946
628
9,000 2,966
3,395
25, 625 12,023 4,360 5,697 3,839 7,957
14, 100 6,834
1,395
1,910 2,053
704 2,935
347
2, 188 2,023 1,975 1,804
46, 955 8,814
452
2,237
23, 205 3, 399 1, 355 1,224
1,057

Alaryland

Massa- Michigan
chusetts

Minnesota

Mississippi

$2, 746 $13, 402 $29, 354 $67, 308 $29,
$7, 588
2, 344 8, 540 24, 810 43,061 24, 152 5, 654
19,990 76, 769 237, 690 346, 003170,712 41, 985
381
2, 969 3,844
196
2,729
5,925
1,623
6, 818 17,942 18, 657 11, 221 4,004
318
1,492
349

9,785
1,322 18, 634 7,591
2,925 17, 177 14, 692 10,431
949 9,762 7, 797 2,954

2,462
933
869

44, 925 1, 047, 904 269, 38586, 194 108,235 84, 717 150,400 29, 243 113, 694 359, 213 511, 034 261, 29663, 691

62, 908 22, 249 9,439 11,847 7,557 10, 834
4, 178
6, 184 119,796 37, 432 10,446 11,410 10, 923 19, 702
4, 575 /, 818 7, 046 1, 069
851
370
784
1, 479 24, 305 8, 679 2, 750 2, 817 2, 869 4,502
1,520
80
14,615
33
1,246
1,430
4,854

30,021

7,496

2,380

2, 753

2,422

4, 158

8,210 25, 518 25, 110 19, 881 5,438
2,530
4,689 17, 626 58, 764 71, 137 29, 545 8,422
239
745
/, 994 1, 857 /, 698
474
1, 166 4, 124 12, 435 15, 084 6, 994 2, 106
995

3,520

12, 355 15, 181

7, 705

2, 207

3,660
503
555
714
1,221
848
394, 523 74, 835 25, 549 29, 570 23, 559 41, 959
16, 495 4, 376
500
716
103
1,479
29, 518 10, 901 3,232
3,604
3,337
6,388

398
545
227
1,047
1,223
1,092
7, 192 28, 193 82, 523 224, 930 95, 005 14, 726
1,912
101
7,990 6,470 3, 129 1,379
1,443
5, 719 15, 983 19, 890 8,866
1, 790

20, 006 8,356 2,874
3,018
103, 210 34, 026 10, 682 10,651

6, 180 2, 751
3,508
9, 784 11,371
941
3, 956 13, 370 39, 284 50,440 28, 335 8,833

2, 719 4, 765
9, 795 18, 959

34, 140

780, 137 200, 892 65, 821 74, 201 60, 970 108, 958 22, 074 82, 603 253, 248 425, 752199, 738 45, 944

10, 785

267, 767 68, 493 20, 373 34, 034 23, 747 41,442

7, 169 31,091 105, 965 85, 282 61, 558 17, 747

Recoveries, transfers from valuation reserves and
profits:
On securities:
Profits and securities sold or redeemed
Recoveries
Transfers from valuation reserves
On loans:
Recoveries
Transfers from valuation reserves
All other
Total reco
Profits

36>
2
122

7,532
725
1,691

2,607
14
3, 677

839
0
1

946
6
249

613
2
213

2,827
0
572

353
0
48

3, 597
1,276
0
38
173 12, 527

1, 196
6
738

595
262
12

506
0
117

8
0
62

346
960
3, 228

205
146
4,406

58
805
274

159
46
691

52
315
915

1111
85
339

16
36
86

66
103
6 8, 591
364 21,439

30
924
1, 740

242
171
620

44
264
501

14,482

11,055

1,977

2,097

2, HO

3,934

539

1,885 46,295

4,634

1,902 1,432

339
60
21

364
95
113

219
117
681

407
62
1, 913

137
8
0

3, 320
11
334

1, 744
310
15

130
2, 634
835

399
4, 938
964

219
7, 653
1, 542

0
1,218
421

s, transfers from valuation reserves and

Losses, chargeoffs, and transfers to valuation
reserves:
On securities:
Losses on securities sold
Chargeoffs on securities not sold
Transfers to valuation reserves
On loans:
Losses and chargeoffs
Transfers to valuation reserves
All other

1,259
0
0

6, 290
1,003
6,289

6
1,409
209

637
37, 728
7,256

Total lossesy chargeoffs, and transfers to valuation
reserves

2,883

Net income before related taxes

8, 132

Taxes on net income:
Federal
State

2,092
582

1, 109"
105
5,298
321
11, 903
1, 932

59, 203, 20, 668|
223,046

58,880

4,019
18,331

6,873
29,258

178
4, 329
1, 554

7,078 11,796
18,779 33,580

67,256 17, 104 4,996
0
0
0

8, 255
866

67,256

9,121

5,317 10,528

13,335 20,137

13,462 23,052

13,758

5,704
13,475

1,420

8,872 33,616

8,673 15,573

3, 702

2, 791
0

62, 398 13, 798
70
0

5,069
0

7,098
9

4, 812
0

8, 553
146

2,059
0

2, 791

62,468

5,069

7, 107

4,812

8,699

2,667

93, 322 27, 978

8, 650 14, 353

Net income after dividends

29,052

3, 702
0

Cash dividends declared:
On common stock

8, 266 13, 030

7,811 30,818

46
4,228
708

8,673 11,009
0
4, 564

Net income before dividends

13, 798

61
90
230
156
4,
4, 408 16, 695. 23, 816 10, 735
131 1,481
724
2, 533

8, 872 25, 576
0
8,040

5,458

Total cash dividends declared

223
51
448

1,420
0

2,674

155,790 41,776

4,996

10,528
0

578
8
1, 545

5,924 25,165 121,442 60,864 49,702

Total taxes on net income

On preferred stock

17,104

5,317
0

1,784

477
27
210

4,504 16,293 87,826 52,191

34,129

9, 773

7, 390 27, 784 22, 800
0
0
174

16, 935 4,252
0
0

2,059

7, 390

16, 935

2, 445

8,903 60,042 29,217 17,194

27, 784

22, 974

4, 252
5,521

51, 794 1, 650, 587 392, 507 134, 449 196, 553 143, 420 271, 296 47, 401 172, 981 573, 626 613, 388 374, 020 97, 004

Capital accounts ||
Ratios:
Net income before dividends to capital accounts
(percent)
Total current operating expenses to total current
operating revenue (percent)
See footnotes at end of table.

10.54

10.64

9.92

10.25

9.39

8.50

9.50

9.42

15.31

8.51

9.12

10.07

74.57

76.36

68.56

71.97

72.45

75.48

72.65

70.50

83.31

76.44

72.14

TABLE B-27—Continued

Income and expenses of National banksi * by States, year ended Dec. 31, 1967
[Dollar amounts in thousands]
Missouri

Number of banks

Aion-

Nevada

127

Current operating revenue:
Interest and dividends on—
U.S. Government obligations . . . . $27,
757
17, 806 3, 276
Other securities
042
Interest and discount on loans f
, 145, , 207 25, 937
320
Service charges and other fees on
461
banks' loans
, 508
582
Service charges on deposit accounts. .
, 107 2, 747
270
Other service charges, commissions,
fees, and collection and exchangecharges
505 1,003
756
466
Trust department
274| 2 859
Other current operating revenue
697
338 1 775
'Total operating revenue

4, 158 11,496
4, 258 11, 097
376
966
998
2, 818

Officer and employee benefits—pensions, hospitalization, social security, insurance, etc
5, 598 1,278 3, 314
Fees paid to directors and members
of executive, discount and other
243
688
832
committees
Interest on time and savings deposits. 63, 876 12, 502 27, 551
Interest and discount on borrowed
654
4, 128
823
money §
Net occupancy expense of bank
7,667 1,408 3, 411
premises
Furniture and equipment—depreciation, rents, servicing, uncapital3, 440
5, 286
ized costs, etc
909
Other current operating expenses
23, 375 5, 632 11,017
current

operating

New I
Mexico |

New
York

144

, 5/3
,671
, 638

North
Carolina

212
,604

,715
829

400
, 006
470

516
62'
517

389
913
034

360
3, 090
.094
'823
688

22,
51,

728

26, 491
75, 187
61, 883

4-80
736
919

2, 798
4, 136
297
974
694

4, 404
3, 203 28, 521
4, 550 60', 059 6, 295
288
382
2, 361
1, 202 13. 494
1, 473
L 022 13, 933

1,061;

Ohio

223

Oklahoma

Oregon

336

$5, 464
$26, 299 $16, 763
3, 253 56, 935 16, 350 14, 210
20, 803
306 112, 508

$92, 825
78, 853
555, 414

220

2, 937
13,426

8, 779
21, 760

1,716
4, 355
3, 469

9, 356
40, 581
12, 162

33, 504 546, 962 179,836 169, 384

819, 730

250
2,031
984
436
283

,286
, 377
,427
,896
,900

059
813
447

87, 232 11, 664 3, 082 35, 079 19,486 15, 748
239, 053 20, 186
3,214 68, 562 20, 878 23,912
5. 893 1, 054
295
2, 780
1, 757 1,527
44, 198
4, 991
881 15, 489
J, 051
5, 113
67, 846

4, 118

Pennsylvania

184

$5, 607 $152,
086
154-, 690
036
2, 891
592
264, 747 28, 760 1, 321, 167 84, 699

620
, 954

North
Dakota

896

13, 382

4, 948

53,
98,
4,
21,

105
172
828
944

5, 118

25, 116

227
2,026
2,428
464
981
174
730, 955 40, 302 13, 174 186, 638 53,491 66, 688

4, 203
297, 203

45
9, 252

306
2, 295
277
7, 855 138,042 Il3 760
64

1, 166

22, 962

1,657

5,007

1,899

1,064

9,418

1,442

1,495

19, 378

1, 757

74, 547

5, 141

1,274

17, 639

6, 636

6, 931

29, 111

1, 008
2, 89S:

1,002 10, 788
4, 366 45, 207

l,46i
5, 957

30, 306
174, 160

4, 400
16, 634

784 12,043
3, 472 64, 683

5,251
19, 226

4,473
14, 056

20, 693
82, 304

e x p e n s e s . . . . . . . 1 5 4 , 1 0 0 31,042 72,837 22,268 23,863 319,389 33, 075 1, 429, 489104, 566 26, 181 405, 059 132, 796 138, 164

619, 325

Net current operating earnings.

Jersey

214,861 39, 867 99, 240 29, 332 32, 243 403, 945 43,319 1, 866, 042

Current operating expenses:
Salaries and wages: %
15,406
Officers
Employees other t h a n officers . . . . 27, 932
Number of officers
1, 229
Number of employees other than officers. 6, 333

Total

New
Hampshire

60, 761

8, 825

26, 4031 7, 064

8, 380 84, 5561

102

10, 244

436, 553 25, 625

7, 323 141,903 47, 040 31,220

200, 405

Recoveries, transfers from valuation reserves and profits:
On securities:
Profits and securities sold or redeemed
Recoveries. . ,
Transfers from valuation reserves.
On loans:
Recoveries.
Transfers from valuation reserves. .
All other
Total recoveries, transfers from
ation reserves and profits. . ,

2, 476

201

77
2, 544

177
165

61
276

105
759
235

255
72
104

72
254
296

6, 196

978

2, 548

130

1,64
121
3

3 76
17
33C

446
334
796

810
0
394

485
7,627
786

36.R
817
355

69
3, 757
703

0
2, 145
327

0
928

659

107

5, 118

1, 599

360
2, 023

1,065

8
0

92
327

20
667

2
0

57
606

49
201
476

328
615
10, 187

11
165
224

8
0
108

97
3, 249
2,013

640
70
427

3
4
466

233
587
2, 475

22, 391

2, 129

231

10, 896

3, 423

1,031

8, 277

1,867
119
6, 997

457
56
574

269
0
0

13, 207
248
877

183
747
19, 035 10, 660
2. 182
1, 005

52
5, 920
4. 341

331
35. 524
5,244

1, 306 30, 383 13, 499

10, 582

55,431

6, 248 122,416 36, 964 21,669

153,251

2, 287

8,878

53
500;

80
89

45
556

5oi

185
1,600
2,066

1, 446

7, 109

1, 589

4, 319

valu-

Losses, chargeofFs, and transfers to valuation reserves:
On securities:
Losses on secutities sold
Chargeoffs on securities not sold. . .
Transfers to valuation reserves. > .
On loans:
Losses and chargeofFs.
Transfers to valuation reserves. . .
All other
Total losses, chargeqffs, and transfers n
valuation reserves

3, 049
87
326

426
5
53

17,286
256
1, 852

916
46
25

288
23
0

78
1.238
214

411
12,805
2.863

64
1, 344
406

128
05, 737
9, 921

76
6, 118
1, 246

62
865
68

10, 703

2, 069;

6, 105

3,676

1, 679

19, 539

2, 298

115, 180

8,427

Net income before related taxes

56, 254

7, 734 22, 846

4, 518

8, 147 72, 126

8, 904

343, 764

19, 327

Taxes on net income:
Federal
State

16, 256
1, 369

2, 118
0

717
0

2,610
0

13, 003
0

2, 389
0

64, 510
28, 288

3, 543
622

2,610

1.460 35, 889
' 171
0

9,481
1,263

1, 631 35, 889

10, 744

6,583

33, 385

4,617 86, 527 26, 220

15, 086

119,866

4,404
2, 179

33, 385
0

Total taxes on net income

17,625

2, 118

717

13, 008

2, 389

92, 798

4, 165

Net income before dividends

38, 629

5,616

3, 801

5, 537 59, 118

6, 515

250, 966

15, 162

Cash dividends declared:
On common stock

15, 930

3, 937
0

2, 480
0

1,842 25, 772
8
0

2.414
0

122,514
1,595

8,019
0

2, 145 36, 105
0
0

12, 606
21

9,809
0

63, 794
61

3, 937

2,480

1, 842 25, 780

2, 414

124, 109

8,019

2, 145 36, 105

12, 627

9, 809

63, 855

I, 679

1, 321

3, 695 33, 338

4, 101

126, 857

7, 143

2,472 50, 422

13, 593

5,277

56, 011

On preferred stock
Total cash dividends declared
Net income after dividends
Capital accounts 1|
Ratios:
Net income before dividends to capita!
accounts (percent)
Total current operating expenses to
total current operating revenue
(percent).
.....
Bee footnotes at end of table.

(]

15, 930
22, 69C
400, 42

71. 72

50, 587 161,016 41, 729 52, 526 563, 014 59, 349 3, 249, 055 168, 213 43, 292 856, 238 332, 936 203, 098 1, 491, 267

11. 10

9. 78

9. 11

10.54

10.50

10.98

7.7^

9.01

10.66

10. 11

7.88

7.43

8.04

77. 8(

73. 39

75. 92

74. 01

79. 07

76. 35

76. 61

80. 32

78. 14

74. 06

73. 84

81.57

75. 55

TABLE B-27—Continued
Income and expenses of National banks, * by States, year ended Dec. 37, 1967
[Dollar amounts in thousands]
Rhode South South
Island Carolina Dakota

Number of banks
Current operating revenue:
Interest and dividends on—
U.S. Government obligations....
Other securities
Interest and discount on loans|
Service charges and other fees on
banks' loans
Service charges on deposit accounts. .
Other service charges, commissions, fees,
and collection and exchange charges
Trust department
Other current operating revenue
Total current operating revenue

Ten-

'Total current operating expenses

Utah

Vermont Virginia

542

WashWest
ington Virginia

Wis-

116

Wyoming

District
Virgin of CoIslands lumbia—
allA

1, 696 $89, 323 $3,310 $2, 036 $24, 676 $21, 330 $12, 277 $21, 669 $4, 100 $327 $25, 083
$3, 194 $6, 857 $6, 418 $25.
72, 280 4,684 1, 344 17, 249 19, 772 4, 708 14, 194 1, 746
295
5,903
5,302 4, 165 2,867 17,589
34, 968 41, 058 25, 877 139,444 510,476 29, 027 14, 548 147, 172 160, 263 35, 252 114, 553 17,245 1,743 86, 376
571
1,810

304
4,830

257
2,367

2,637
7,908

6,989
29, 907

1,300
2,836

260
1,963
931

1,637
1,867
556

1,412
602
530

5,339
5,623
1,311

12, 650
21,098
10, 984

1,472
936
316

274 4, 149 4,489
1,241 11,213 18, 895

401
1,669

1,413
6,021

329
1,501

409
45

3,809
7,257
2,251

647
1,541
843

3,413
4,223
3,947

753
315
278

79
0
71

139
289
201

6,980
7,359
3,063

2,476
7,241
1,330
7,443
1, 184

48, 999 61,274 40, 330 205, 547 753, 707 43, 881 20,072 217, 776 242, 151 57, 338 169, 433 26, 267 2,969 137,036

Current operating expenses:
Salaries and wages: %
2,478 7,247 4,262 15, 126
Officers
5,386 11,935 4, 158 26, 859
Employees other than officers
660
402 1,355
214
Number of officers
Number of employees other than officers.1, 348 3, 107 1,077 6,588
Officer and employee benefits—pensions, hospitalization, social security,
1,835 2,563 1,309 6, 120
insurance, etc
Fees paid to directors and members of
executive, discount and other com602
354
124
mittees
211
Interest on time and savings deposits. . 20, 880 7,413 13, 260 61, 144
Interest and discount on borrowed
103 5, 144
260
430
money§
Net occupancy expense of bank prem1,556 2,474 1,542 7,137
ises
Furniture and equipment—depreciation, rents, servicing, uncapitalized
932 2,492 1,081 6, 159
costs, etc
3,724 8,083 3,680 23, 669
Other current operating expenses

Net current operating earnings

Texas

62, 989
80, 720
5,474
18, 933

2,508
4, 760
248
1,266

19, 140

1, 143

155
4,096
233, 869 17,403

1,765 18, 177 19, 309 4,972 13, 934 2,851
2,628 29, 036 40, 542 6,476 21, 680 2,922
186 1, 707 1, 728
476 /, 091
263
705 7,413 8,393 1, 61. 5,665
720

232
562
19
136

9,902
18, 393
697
3, 783

622

125

3, 101

186 1,320
345
518
291
856
7,814 74, 092 75, 359 16, 884 63, 667 8,991

10
1,046

582
39, 664

6,725

8,673

4,731

16, 862

381

1, 147 1,272

114

532

159

818

25, 772

1,460

807

7,797 10, 466

1,755

6,267

1,058

6, 022

19, 399
91, 734

1, 139
4,573

457 5,835 7,400 1,215 5,556
801
1,871 22, 939 24, 258 6,562 18, 396 2, 967

46
339

3,459
14, 468

37, 345 42,821 29, 606 151,960

554,581 33,522 16, 106167,068 187, 624

11,654 18, 453 10, 724

199, 126 10, 359

53, 587

1,406

3,966 50, 708 54, 527

, 902 135,

20, 662 2,470
5,605

499

96, 409
40, 627

Recoveries, transfers from valuation reserves and profits:
On securities:
Profits and securities sold or redeemed
Recoveries
Transfers from valuation reserves. .
On loans:
Recoveries
Transfers from valuation reserves. .
All other
Total recoveries, transfers from valuation
reserves and profits
Losses, chargeoffs, and transfers to valuaation reserves:
On securities:
Losses on securities sold
Ghargeoffs on securities not sold. . .
Transfers to valuation reserves. . . .
On loans:
Losses and chargeoffs
Transfers to valuation reserves. . . .
All other

2,605
301
132

407
6
90

1, 172
3
94

93
3
50

1
0
0

928
8
O

18
1, 330

55
2, 550
870

92
25
146

26
325
962

91
8
133

0
0
103

69
40
2,236

231

3, 951

6, 513

766

2, 582

378

104

3,281

308
13
0

851
54
2, 281

1,597
10
293

888
30
63

1, 557
104
41

49
5
43

2
0
0

724
2
54

184
959
60

0
172
29

431
7,494
852

2, 545
55
887

70
4
0

121
0
0

1,835
26
515

59
31
270

1,406
1, 125
3, 122

7
15
17

21
0
89

410

6,495

9, 140

113

465
1
226

152
16
0

2,954
567
1,234

2, 161
311
5,544

795
0
0

15
1,870
826

17
1,011
189

68
6,454
1, 182

3, 118
34, 203
4,858

0
1, 931
149
2,875

24
0
0

211
0
15

162
1
37

3
0
154

4
205
278

24
11
175

181

713

134
0
0
0
2,547
624

Total losses, chargeoffs^ and transfers to
3, 305 3,403
valuation reserves

5, 977
25
133

227

27
559
92

117
352
10, 185 10, 546
2, 158 2,217

234
1, 266
185

49
5,824
1, 360

999

15, 881 14, 780

2,666

8, 935

1, 385 12, 459

50, 195

1, 300

203

9,557

Net income before related taxes

8, 530 15, 763

9, 749 47, 623

158, 071

7, 597

3, 198 38, 778 46, 260 15, 536 27, 461

4,683

400

34, 351

Taxes on net income:
Federal
State

1, 408
505

6,062
272

3, 222 13, 796
0
297

47, 088
0

1, 376
254

1,012
79

10, 814 14, 546
0
0

5,270
0

5,403
1,866

1,384
0

13, 885
0

1, 913

6,334

3, 519 13, 796

47, 088

1, 630

1,091

10, 814 14, 546

5, 270

7,269

1, 384

13, 885

6,617

9,429

6, 230 33, 827

110, 983

5, 967

2, 107 27, 964 31, 714 10, 266 20, 192

3, 299

353

20, 466

Total taxes on net income
Net income before dividends
See footnotes at end of table.

TABLE B-27—Continued

Income and expenses of National banks,* by States,year ended Dec. 31, 1967
[Dollar amounts in thousands]
Rhode

Gash dividends declared:
On common stock. . . .
On preferred stock. . . .
Total cash dividends declared.

Net income after dividends
Capital accounts] |
Ratios:
Net income before dividends to capital
accounts (percent)
Total current operating expenses to
total current operating revenue
(percent)

South

% 122 $4, 632 $2, 884 $10, 788
1
0

$54,976 $3,860
0
0

3, 122

4,633

2,884 10, 788

54,976

3,860

3,495

4,796

3,346 23, 039

56, 007

2, 107

$963 $14, 185 $12, 551 $3, 556
0
0
996

14, 185 12, 551

1, 111 13, 779 19, 163

3,556

Wisconsin

Wyoming

10.29
76.22

^Tnrlnrffff nil h-anVs- n p p n t i n g in TSTitio^iil b™>(7

District
Virgin
of CoIslands lumbia—
allA

9, 757 $1,517
0
0
9,757

1,517

6, 710 10, 435

1, 782

64, 319 90,883 50,273 336, 118 1, 303, 016 59, 407 27, 387 309, 590 290, 835 110, 678 244, 632 40,024

$10,005
0
10, 065
$353

10, 401

2,818 205, 007

10.37

12.39

10.06

8. 52

10.04

7.69

9.03

10.90

9.28

8.25

8.24

12. 53

9. 98

69.88

73.41

73.93

73. 58

76. 39

80.24

76.72

77.48

69.59

80.04

78.66

83. 19

70. 35

t y»nj

Rfi&d full

flncludes revenues from the sales of Federal funds.
fNumber of employees at year end excluding building employees.
§Includes expenses incurred in purchasing Federal funds.
[(TnrlllH«-e the Iggjrffg^ta Hnnir i n l n a nf rlaH an tiling p«^>"»9d

&wht^

da£a Saw

iiiuiml t>unkj iXii

QGCKMKKft

December call dates in the year indicated a n d the previous December call date.
ATnrlnHw TSTat^nral ar«ri i->on_'NToticr>?.! b?.nks in the District ef Cclumbiaj all of which arc sup

WashWest
ington Virginia

Vermont Virginia

Texas

iiiptiull^x u£ il«- G

TABLE

B-28

Income and expenses of National banks, * by deposit size, year ended Dec. 31, 1967
[Dollar amounts in thousands]
Banks operating full year with deposits in December 196?\ of—
$2,000.0
I and under
4, 758
Number of banks
Total deposits
$231, 374, 000 $330, 000
Capital stock (par value)
5,367,000
13,000
Capital accountsf
19,730,000
47,000
Current operating revenue:
Interest and dividends on—
U.S. Government obligations. .
$4, 540
$1,400,999
Other securities
963
1, 121, 994
Interest and discount on loans { . . . .
11, 393
8, 458, 936
Service charges and other fees on
94
169, 483
banks* loans
Service charges on deposit accounts.
576, 770
1,065
Other service charges, commissions
fees, and collection and exchange
charges
229, 992
378
Trust department
435, 331
1
Other current operating revenue. . .
257, 438
198
Total current operating revenue
12, 650, 943
18, 632

See footnotes at end of table.

$25,000.1
$10,000.1
$5,000.1
$2,000.1
to $5,000.0 to $10,000.0 to $25,000.0 to $50,000.0
,000

Over
$50,000.1
$100,000.1
to $100,000.0 to $500,000.0 $500,000.0

70
472
1,254
226
230
1,279
$9,315,000 $19, 697,000 $16, 254, 000 $15,647,000 $46, 118,000 $120,485,000
1, 104, 000 ' 2, 707, 000
372, 000
372, 000
458, 000
236, 000
3, 747, 000
10, 497, 000
I, 213, 000
1, 672, 000 1, 306, 000
857, 000

11,968

$92, 506
46, 333
331, 167
4,239
32, 493

$168,567
104,611
702, 848
11,937
68, 094

$126, 928
88,411
575, 587
11, 187
52, 651

$116, 125
80, 012
551, 177
10, 529
44,391

$281, 268
220, 104
1, 639, 935
32, 009
122, 197

$571, 334
567, 638
4, 521, 520
98, 210
243,911

4, 175
203
1,982
198, 568

9,251
1,087
6,009
523, 085

18, 498
7,335
12, 588
1, 094, 478

13,644
17, 177
11, 574
897, 159

13,459
23,511
12, 709
851,913

45, 947
96, 187
37, 149
2, 474, 796

124, 640
289, 830
175, 229
6, 592, 312

$39, 731
13, 922
125, 309
1,278

TABLE B-28—Continued

Income and expenses of National banks, * by deposit size, year ended Dec. 31, 1967
[Dollar amounts in thousands]
Banks operating full year with deposits in December 19671 of—
$2,000.0
and under

Current operating expenses:
Salaries and. wages: §
Officers
Kmployees other than officers. . .
Number of officers
Number of employees other than
officers

Officer and employee benefits—pensions, hospitalization, social security, insurance, etc
Fees paid to directors and members
of executive, discount and other
committees
Interest on time and savings deposits. .
Interest and discount on borrowed
money j |
Net occupancy expense of bank premises
Furniture and equipment—depreciation, rents, servicing, uncapitalized costs, etc
Other current operating expenses. . . .
Total current operating expenses

Net current operating earnings
Recoveries, transfers from valuation reserves and profits:
On securities:
Profits and securities sold or redeemed
Recoveries
•••I
Transfers from valuation reserves
|

$901, 734
1,673,051
75, 808
369, 780
391, 192

$4,048
1, 653
684

422

$2,000.1
$5,000.1
to $5,000.0 to $10,000.0

$30, 651
21, 147
3,598
5, 971

$10,000.1
$25,000.1
$50,000.1
$100,000.1
Over
to $25,000.0 to $50,000.0 to $100,000.0 to $500,000.0 $500,000.0

$61, 728
60, 525
6, 386

$106, 714
131, 176
10, 261

$79, 203
114, 232
63 846

$70, 679
110,711
5, 707

$187, 626
350, 988
14, 795

$361, 085
882, 619
27, 531

16, 155

34, 504

28, 710

27, 058

79, 007

177, 760

4,604

13,074

29, 115

25, 433

24, 687

80, 132

213, 725

3,301
56, 678

6,681
168, 013

10, 206
369, 491

5, 724
304, 045

4,067
295, 578

7, 123
781,031

5, 765
2, 439, 043

43, 286
4,418,031
153,825
489, 366

419
4, 152

825

1,609

3, 111

3,602

22, 218

122, 143

877

8, 507

22, 402

45, 422

37, 296

37, 170

100, 583

237, 109

313, 130
1, 311,831
9, 695, 446
2, 955, 497

418
2,405

4,916
24, 264

12, 782
61,831

26, 597
129, 429

23, 769
106, 223

25, 400
97, 095

81,483
275, 366

137, 765
615,218

14,452

154, 327

407, 861

849, 759

699, 036

668, 989,

4, 180

44,241

115,224

244, 719

198, 123

182, 924

91, 181
2,570

59
1

957
68

2,926
199

8,010
580

7,333
359

7,096
357

19, 603
285

45, 197
721

36,704

197

1,838

2, 396

1, 527

6,757

23, 950

259

1, 886, 550
588, 246

5, 014, 472
1, 577, 840

On loans:
Transfers
serves
All other .

6,670

280

1, 765

1, 910

1, 255

461

141

294

564

28, 705
86, 769

17
32

324
928

1,021
2,285

2,677
4, 906

1, 015
5, 583

2,065
4, 118

5, 577
10, 623

16,009
58, 294

Total recoveries, transfers from valuation reserves and profits

252, 599

389

4,081

8,538

19, 266

17, 147

15, 304

43, 139

144, 735

Losses, chargeoffs, and transfers to valuation reserves:
On securities:
Losses on securities sold
Chargeoffs on securities not sold. .
Transfers to valuation reserves. . . .
On loans:
Losses and chargeoffs
Transfers to valuation reserves
All other

75, 963
4,483
52, 179

99
5
10

1,037
226
106

3, 173
710
488

6, 565
1,273
2,280

6, 511
405
3, 262

4, 388
246
1, 903

16, 108
490
7,660

38, 082
1, 128
36, 470

13, 563
519, 044
105, 434

572
482
96

4,088
7,684
1, 137

4,200
23, 411
4,094

2, 726
47, 441
8, 337

1, 275
37, 252
6,893

162
34, 604
7, 700

402
96, 531
16, 868

138
271,639
60, 309

from

valuation

re-

Total losses, chargeoffs, and transfers to
Net income before related taxes
Taxes on net income:
Federal
State

. .

770, 666

1,264

14, 278

36, 076

68, 622

55, 598

49, 003

138, 059

407, 766

2, 437, 430

3, 305

34, 044

87, 686

195, 363

159, 672

149, 225

493, 326

1, 314, 809

594, 047
85, 892

652
67

7, 191
675

19, 689
1, 736

46, 093
3, 223

38, 232
2,751

37, 750
1, 995

132,478
8,475

311,962
66, 970

Total taxes on net income

679, 939

719

7,866

21,425

49, 316

40, 983

39, 745

140, 953

378, 932

Net income before dividends

1, 757,491

2, 586

26, 178

66, 261

146, 047

118, 689

109, 480

352, 373

935, 877

794, 056
2, 124

991

9, 609
0

24, 041
32

52, 464
58

45, 659
8

154, 968
211

462,717
1, 740

155, 179

464, 457

197, 194

471,420

Cash dividends declared:
On common stock
On preferred stock

•.

Total cask dividends declared
Net income after dividends

796, 180

992

9, 609

24, 073

52, 522

45, 667

43, 607
74
43, 681

961, 311

1, 594

16, 569

42, 188

93, 525

73, 022

65, 799

^Includes newly organized National banks opened during 1967.
fThis includes the aggregate book value of debentures, preferred stock, common stock, surplus, undivided profits, and reserves.
{Includes revenues from the sales of Federal funds.
§Number of employees at year end excluding building employees.
|j Includes expenses incurred in purchasing Federal funds.

TABLE

B-29

Capital accounts, net profits, and dividends of National banks, 1944—67
[Dollar amounts in thousands]
Capital stock (par value)*
Tear (last call)

1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
I960
1961
1962
1963
1964
1965
1966
1967

....

. ..

Number
of banks

Preferred

5, 031 $110,597
5,023
80, 672
5,013
53, 202
5, Oil
32, 529
4,997
25, 128
4, 981
20, 979
4,965
16, 079
4,946
12, 032
4,916
6,862
4,864
5,512
4, 796
4, 797
4, 700
4, 167
4,659
3, 944
4,627
3, 786
4,585
3,332
4,542
3,225
4,530
2, 050
4,513
2, 040
4,503
9,852
4,615
24, 304
4,773
27, 281
4,815
28, 697
4,799
29, 120
4,758
38, 081

Cash dividends

Common

Total

Total
capital
accounts*

Net profits
before
dividends

$1,440,519
1,536,212
1, 646, 631
1, 736, 676
1, 779, 362
1, 863, 373
1, 949, 898
2, 046, 018
2, 171,026
2, 258, 234
2, 381, 429
2, 456, 454
2,558, 111
2, 713, 145
2, 871, 785
3, 063, 407
3, 257, 208
3,464, 126
3, 662, 603
3, 861, 738
4, 135, 789
4, 600, 390
5, 035, 685
5, 224, 214

$1,551, 116
1, 616, 884
1, 699, 833
1, 769,205
1,804,490
1, 884, 352
1, 965, 977
2, 058, 050
2, 177,888
2, 263, 746
2, 386, 226
2, 460, 621
2, 562, 055
2, 716, 931
2, 875, 117
3, 066, 632
3, 259, 258
3,466, 166
3, 672, 455
3, 886, 042
4, 163, 070
4, 629, 087
5, 064, 805
5, 262, 295

$4, 114,972
4,467,618
4, 893, 038
5, 293, 267
5, 545, 993
5,811,044
6, 152, 799
6, 506, 378
6, 875, 134
7, 235, 820
7, 739, 553
7,924,719
8, 220, 620
8, 769, 839
9, 412, 557
10, 003,852
10, 695, 539
11,470,899
12, 289, 305
13, 102, 085
14, 297, 834
16, 111, 704
17,971,372
19,095, 324

$411,844
490, 133
494, 898
452, 983
423, 757
474, 881
537,610
506, 695
561,481
573, 287
741, 065
643, 149
647, 141
729, 857
889, 120
800, 311
1,046,419
1, 042, 201
1, 068, 843
1,205,917
1,213,284
1, 387, 228
1, 582, 535
1, 757,491

Ratios (percent)

On
Preferred
stock

On
common
stock

Net profits
before
dividends
to capital
accounts

Cash dividends to
net profits
before
dividends

Cash dividends on
preferred
stock to
preferred
capital

Total cash
dividends
to capital
accounts

$5, 296
4, 131
2,427
1,372
1,304
1, 100
712
615
400
332
264
203
177
171
169
165
99
119
202
1, 126
1,319
1,453
1,348
2, 124

$139,012
151, 525
167, 702
182, 147
192,603
203, 644
228, 792
247, 230
258, 663
274, 884
299, 841
309, 532
329, 777
363, 699
392, 822
422, 703
450, 830
485, 960
517, 546
547, 060
591,491
681, 802
736, 591
794, 056

10. 01
10. 97
10. 11
8.56
7. 64
8. 17
8.74
7.79
8. 17
7.92
9. 58
8. 12
7.87
8.32
9.45
8. 00
9. 78
9. 09
8. 70
9.20
8.49
8.61
8.81
9.20

35. 04
31. 76
34. 38
40.51
45. 76
43. 11
42.69
49.04
46. 14
48.01
40. 50
48. 16
50. 99
49.85
44.20
52.84
43.09
46.64
48.44
45.46
48.86
49. 15
46.63
45.30

4.79
5. 12
4. 56
4.22
5. 19
5.24
4.43
5. 11
5.83
6.02
5. 5O
4.87
4.49
4.52
5.07
5. 12
4.83
5. 83
2. 05
4. 63
4.83
5.06
4.63
5.58

3.51
3.48
3.48
3.47
3.50
3.52
3. 73
3.81
3. 77
3.80
3. 88
3. 91
4. 01
4. 15
4. 18
4.23
4. 22
4.24
4.21
4. 18
4. 15
4.24
4. 11
4. 17

*Xhese are averages of data from the Reports of Condition of the previous December, and June and December of the respective years.
NOTE: For earlier data, see Annual Reports of the Comptroller of the Currency, 1938, p. 115, and 1963, p. 306.

TABLE B-30
Loan losses and recoveries of National banks, 1945-67
[Dollar amounts in thousands]

Tear

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958,
1959
1960
1961.
1962
1963
1964
1965
1966
1967

Total loans end
of year

. . .

Average for 1945-67

Losses and
chargeqffs*

Recoveries]

Net losses or
recoveries ( + )

Ratio of net
losses or net
recoveries ( + )
to loans
Percent

$13,948,042
17,309,767
21,480,457
23,818,513
23, 928, 293
29, 277,480
32, 423, 777
36,119,673
37, 944,146
39, 827, 678
43, 559, 726
48, 248, 332
50, 502, 277
52, 796, 224
59, 961, 989
63, 693, 668
67, 308, 734
75,548,316
83, 388, 446
95, 577, 392
116,833,479
126, 881, 261
136,752,887

$29, 652
44,520
73,542
50,482
59,482
45, 970
53, 940
52, 322
68, 533
67,198
68, 951
78, 355
74,437
88, 378
80, 507
181, 683
164, 765
157, 040
190,188
239,319
276, 737
341, 505
391,691

$37, 392
41,313
43,629
31,133
26,283
31,525
31, 832
32, 996
36, 332
41, 524
39,473
37, 349
39, 009
50, 205
54, 740
51, 506
52, 353
59,423
68,464
113,635
86,911
100, 625
112,434

+$7, 740
3,207
29,913
19, 349
33,199
14,445
22,108
19, 326
32,201
25, 674
29,478
41,006
35,428
38,173
25, 767
130,177
112,412
97,617
121, 724
125, 684
189,826
240, 880
279, 257

+0.06
.02
.14
.08
.14
.05
.07
.05
.08
.06
.07
.08
.07
.07
.04
.20
.17
. 13
.15
.13
.16
.19
.20

56, 396, 981

125, 182

53, 047

79, 135

.13

* Excludes transfers to valuation reserves beginning in 1948.
fExcludes transfers from valuation reserves beginning in 1948.
N O T E : F o r earlier d a t a , see Annual Report of the Comptroller of the Currency, 1947, p . 100.

213

TABLE

B-31

Securities losses and recoveries of National banks,

1945-67

[Dollar amounts in thousands]

Tear

Total securities
end of year

ZJOSS0S GTld

Recoveries^

Net losses or
recoveries ( + )

chargeoffs*

Ratio of net
losses to
securities

Percent

1945
1946
1947
1948
1949
1950
1951
1952
1953.
1954
1955
1956
1957 .
1958
1959
1960
1961
1962.
. .
1963
1964
1965
1966 .
1967

...

. . .

Average for 1945-67

$55,611,609
46,642,816
44,009,966
40, 228, 353
44, 207, 750
43,022,623
43,043,617
44, 292, 285
44, 210, 233
48, 932,258
42, 857, 330
40, 503, 392
40, 981, 709
46, 788, 224
42,652,855
43, 852, 194
49, 093, 539
51,705,503
52, 601,949
54, 366, 781
57, 309, 892
57,667,429
69,656,371

$74, 627
74,620
69, 785
55, 369
23, 595
26, 825
57,546
76, 524
119,124
49,469
152, 858
238,997
151,152
67,455
483, 526
154, 372
51,236
47, 949
45, 923
86, 500
67, 898
302, 656
149, 545

$54, 153
33, 816
25,571
25,264
7,516
11,509
6,712
9,259
8,325
9,286
15, 758
13,027
5,806
12,402
18,344
21,198
10,604
6,350
7,646
4,117
4,650
5,635
6,400

$20,474
40,804
44,214
30,105
16,079
15,316
50,834
67,265
110,799
40, 183
137,100
225, 970
145, 346
55, 053
465, 182
133, 174
40,632
41,599
38, 277
82, 383
63, 248
297,021
143, 145

0.04
.09
.10
.07
.04
.04
.12
.15
.25
.08
.32
.56
.35
.12
1.09
.30
.08
.08
.07
.15
.11
.52
.21

48, 010, 377

114,241

14, 059

100, 183

.21

•Excludes transfers to valuation reserves beginning in 1948.
f Excludes transfers from valuation reserves beginning in 1948.
N O T E : For earlier data, see Annual Report of the Comptroller of the Currency, 1947, p . 100.

TABLE

B-32

Total assets of foreign branches* of National banks, year end

1953-67

[Dollar amounts in thousands]
1953
$1, 682, 919
1961
1954
1, 556, 326
1962
1955
1, 116, 003
1963
1956
1, 301, 883
1964
1957
1, 342, 616
1965
1958
1, 405, 020
1966
1959
1, 543, 985
1967
1960
1, 628, 510
•Includes military facilities operated abroad by National banks in 1966 and thereafter.

214

$1, 780, 926
2, 008,478
2, 678, 717
3,319,879
7, 241, 068
9, 364, 278
11,856,316

TABLE

B-33

Foreign branches of National banks,

End of year

National bank
Number of branches branches as a peroperated by National centage of total foreign
branches of U.S.
banks
banks
93
102
111
124

1960
1961
1962
1963

75.0
75.6
76.6
77.5

TABLE
Assets and liabilities of foreign branches and military facilities

1960-67

End of year

National bank
Number of branches branches as a peroperated by National centage of total
foreign branches of
banks
US. banks
138
196
230
278

1964
1965
1966
1967

76.7
93.5
94.3
95.5

B-34
of National banks, Dec. 30, 1967: consolidated statement

[Dollar amounts in thousands]
Cash and cash items
Due from banks (time and demand)
Securities
Loans and discounts
Customers' liability on acceptances
Fixed assets
Other assets
Due from head office and branches (gross)
Total

$199, 943
1, 534, 568
262, 312
4, 723, 091
586, 086
63,460
127, 094
4, 359, 762
11, 856, 316

Total demand deposits
$1, 982, 708
Total time deposits
6, 604, 741
U.S. Government deposits
234, 981
Certified checks, officers' checks, official checks. .
77, 500
Total deposits
Other liabilities and borrowed funds
Liabilities on acceptances
Due to head office and branches (gross, including
capital)
Total

8, 899, 930
290, 266
587, 239
2,078, 881
11, 856, 316

215

TABLE

B-35

Assets and liabilities of National banks, date of last report of condition, 1950—67
[Dollar amounts in thousands]
Tear

Number
of banks

1950...
1951...
1952...
1953...
1954...
1955...
1956...
1957...
1958...
1959...
1960...
1961...
1962...
1963...
1964...
1965...
1966...
1967...

4,965
4,946
4,916
4,864
4, 796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,505
4,615
4,773
4,815
4, 799
4,758

Total assets

Cash and
due from
banks

U.S. Government
obligations

Other
securities

Loans and
discounts, net

Other assets

Total
deposits

Liabilities
for
borrowed
money

Other
liabilities

Capital

Surplus,
undivided
profits and
reserves

$97, 240, 093 $23, 813, 435 $35, 691, 560 $7,331,063 $29, 277, 480 $1, 126,555 $89, 529, 632
$76, 644 $1,304,828 $2, 001, 650 $4, 327, 339
102, 738, 560 26, 012, 158 35, 156,343 7, 887, 274 32, 423, 777 1, 259, 008 94,431,561
15,484 1,621,397 2, 105, 345 4, 564, 773
108, 132, 743 26, 399, 403 35, 936, 442 8, 355, 843 36, 119,673 1,321,382 99, 257, 776
75,921
1, 739, 825 2, 224, 852 4, 834, 369
110, 116, 699 26, 545, 518 35, 588, 763 8,621,470 37, 944, 146 1, 416, 802 100, 947, 233
14, 851 1, 745, 099 2, 301, 757 5, 107, 759
116, 150,569 25, 721,897 39, 506, 999 9, 425, 259 39, 827, 678 1, 668, 736 106, 145, 813
11, 098 1, 889, 416 2, 485, 844 5, 618, 398
113,750,287 25, 763, 440 33, 690, 806 9, 166, 524 43, 559, 726 1, 569, 791 104,217, 989
107, 796 1, 488, 573 2, 472, 624 5, 463, 305
117, 701,982 27, 082, 497 31,680,085 8, 823, 307 48, 248, 332 1, 867, 761 107, 494, 823
18,654 1, 716, 373 2, 638, 108 5, 834, 024
120, 522, 640 26, 865, 134 31,338,076 9, 643, 633 50, 502, 277 2, 173, 520 109,436, 311
38, 324 1, 954, 788 2, 806, 213 6, 278, 004
128, 796, 966 26, 864, 820 35, 824, 760 10, 963, 464 52, 796, 224 2, 347, 698 117,086, 128
43, 035 1, 999, 002 2, 951, 279 6, 717,522
132,636, 113 27, 464, 245 31, 760,970 10,891,885 59, 961, 989 2, 557, 024 119,637,677
340, 362 2, 355, 957 3, 169, 742 7, 132,375
139, 260, 867 28, 674, 506 32, 711, 723 11, 140,471 63, 693, 668 3, 040, 499 124,910,851
110,590 3, 141, 088 3, 342, 850 7, 755, 488
150, 809, 052 31,078,445 36, 087, 678 13,005,861 67, 308, 734 3, 328, 334 135,510,617
224,615 3, 198, 514 3, 577, 244 8, 298, 062
160, 657, 006 29, 683, 580 35, 663, 248 16, 042, 255 75, 548, 316 3, 719,607 142, 824, 891 1, 635, 593 3, 446, 772 3, 757, 646 8, 992, 104
170, 233, 363 28, 634, 500 33, 383, 886 19,218,063 83, 388, 446 5, 608, 468 150, 823, 412
395, 201 5, 466, 572 4, 029, 243 9,518,935
190, 112, 705 34, 065, 854 33, 537, 250 20, 829, 531 95, 577, 392 6, 102, 678 169, 616, 780
299, 308 5, 148, 422 4, 789, 943 10, 258, 252
219, 102,608 36, 880, 248 31, 895, 565 25, 414, 327 116, 833, 479 8, 078, 989 193,859, 973
172, 087 7, 636, 524 6, 089, 792 11,334,232
235, 996, 034 41, 689, 580 30, 354, 996 27, 312,433 127, 453, 846 9, 185, 179 206, 456, 287 1, 105, 147 9, 975, 692 6,299, 133 12, 159, 775
263, 374, 709 46, 633, 658 34, 307, 948 35, 348, 423 136, 752, 887 10, 331, 793 231,374,420
296,821 11, 973, 852 6, 602, 519 13, 127, 097

NOTE: For earlier data, revised for certain years and made comparable to those in this table, references should be made as follows: Years 1863 to 1913, inclusive,
Comptroller's Annual Report for 1913; figures 1914 to 1919, inclusive, report for 1936; figures 1920 to 1939, inclusive, report for 1939; and figures 1936 to 1949, inclusive,
report for 1966.

TABLE B-36
Common trust funds, by States, 1966 and 1967*
Number of banks
with common
trustfunds

Number of
common trust
funds

Number of account
participations

Total assets offunds
{millions)

1966

1967

1966

1967

1966

1967

1966

1967

Percent change
in assets

1965-66

1966-67

497

539

1,089

1, 195

295, 325

316, 947

$7,612.0

$8,347.5

1.1

9.7

Alabama
Alaska
Arizona
. .
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia

6
1
4
3
11
13
12
3
4

7
1
4
3
11
14
16
3
6

10
1
13
4
35
25
26
10
7

13
1
13
4
36
30
34
9
12

1,841
45
2,606
985
24, 042
6,325
5,990
3,381
2,736

2, 118
51
2,858
1,026
25, 949
6,304
7,338
3, 169
3,109

19.3
.4
71.2
10.2
521.2
166.2
169.3
91.7
84.5

22.6
.6
82.4
11.9
613.0
199.8
200.7
83.1
99.1

6.6
7.7
6.3
1.9
5.5
-4.8
21.9
1.2

17.1
50.0
15.7
16.7
17.6
20.2
18.5
—9.4
17.3

Florida
Georgia
Hawaii
Idaho.
Illinois
Indiana
Iowa
Kansas
Kentucky .
Louisiana .
Maine

17
8
3
3
13
13
2
4
7
2
7

16
10
3
3
16
15
3
6
7
2
8

31
19
7
5
32
26
4
8
12
2
17

31
22
7
5
38
34
7
12
16
2
19

3,916
4,967
1,429
339
9,449
3,881
627
589
2,514
275
2,342

4,009
5,214
1,617
677
10, 999
4,646
948
770
2,788
314
2,688

73.4
106.5
22.9
3.5
404.8
67.2
15.8
9.5
43.0
3.7
61.8

85.5
119.1
27.4
7.5
455.9
83.7
21.6
13.9
50.6
3.9
66.9

3.5
-7.5
1.3
52.2
10.4
-16.4
29.5
8.0
-1.4
8.8
1.1

16.5
11.8
19.6
214.3
12.6
24.6
36.7
46.3
17.7
5.4
8.3

Maryland
Massachusetts
Minnesota
Mississippi.
Missouri....
Montana
Nebraska . .
Nevada
New Hampshire

6
23
14
9
2
10
3
4
1
4

7
24
13
10
2
10
3
4
1
4

14
46
43
23
5
25
5
7
3
6

17
54
40
27
5
26
5
7
3
6

6,345
12, 842
9,060
5,716
1,090
10,512
614
1,490
471
314

6,991
14, 029
8,653
6,513
1,403
11,287
672
1,731
508
339

167.2
475.5
231.7
97.3
11.6
275.6
6.4
29.8
7.1
10.2

179.2
513.0
216.0
124.6
19.5
295.8
7.6
37.7
8.5
11.4

-2.4
-3.9
22.7
-6.9
.9
—6.6
6.7
18.3
7.6
-8.1

-6.8
28.1
68.1
7.3
18.7
26.5
19.7
11.8

New Jersey..
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma. .
Oregon
Pennsylvania
Rhode Island..

17
2
24
10
3
25
6
4
75
3

19
4
25
11
3
28
6
4
83
3

36
6
79
21
6
66
16
12
140
10

39
8
80
24
8
75
16
13
154
10

6,981
1, 192
28, 009
8,960
563
10, 232
1,465
4,949
63, 680
1,924

7,659
1,362
28, 575
9,599
751
12,194
1,570
5,236
64, 008
2,065

109.6
21.1
1,416.3
165.4
3.4
280.7
29.8
85.2
1,425.4
45.4

127.1
26.3
1.530.4
191.0
6.5
348.1
38.0
98.2
1,372.3
51.7

3.3
12.2
.1
14.7
— 17.1
-10.6
10.0
-6.7
.2
7.1

15.5
91.2
24.0
27.5
15.3
-3.7
13.9

2
5
10
31
5
7
23
7
9
17
0

3
5
10
33
5
7
25
7
9
17
0

4
9
15
61
10
12
45
24
10
36
0

7
9
15
63
10
12
50
21
10
36
0

1,589
705
2,614
8,566
2,367
863
8,315
6,273
1, 100
8,245
0

2,298
757
2,657
10,419
2,550
941
8,589
6,529
1,338
9,132
0

14.5
6.5
48.5
238.2
25.0
8.6
180.3
119.7
14.1
115.9
0

27.4
7.4
54.5
287.6
29.3
9.5
194.6
137.7
17.1
132.3
0

-32.2
12.1
3.4
-1.9
83.8
11.7
4.0
9.2
10.8
9.0
0

89.0
13.8
12.4
20.7
17.2
10.5
7.9
15.0
21.3
14.2
0

Total United States. . .

South Carolina
South Dakota
Tennessee
Texas
Utah.
Vermont....
Virginia
Washington
West Virginia
Wisconsin
Wyoming

. . . . .

7.2
7.9

16.0
24.6
8.1

•These figures wcic dciived froza a survey of banks and truet companies operating common trust funds. Data are for the last
valuation date in 1966 and 1967.
NOTE : Data may not add to totals because of rounding.

217

TABLE B-37
Trust assets and income of National banks, by States, calendar 1967
(Dollar amounts in millions)
Number
of banks
United States.
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia §.
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire...
New Jersey...
New Mexico.
New York.
North Carolina..
North Dakota...
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode I s l a n d . . .
South Carolina..
South Dakota...
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia...
Wisconsin
Wyoming

1,651
28
4
3
29
16
28
13
0
6
77
26
1
3
149
95
45
43
50
19
18
11
57
33
19
17
35
11
19
2
20
89
16
80
15
8
53
36
2
142
2
8
9
28
134
2
11
52
11
28
35
13

Employee
benefit
accounts \

$34, 748
233
6
26
16
2,691
157
231
0
222
233
223
20
10
5,371
278
50
33
32
94
24
76
1, 141
2,828
742
37
602
2
81
4
6
182
13
11,106
172
8
1,166
165
170
4,171
161
76
13
111
1,085
57
5
137
274
13
192
2

Other trust
accounts %

$60, 729
662
11
380
216
4,324
1,028
1,393
0
1,093
2,136
864
99
39
5,386
1,800
340
397
359
194
216
482
2,352
1,925
1,513
157
1,853
38
413
122
109
1,411
170
7,898
650
52
3, 148
688
545
8, 116
333
349
60
1, 126
3,156
127
40
1,058
1,034
283
532
52

Total trust
accounts

$95, 467
885
17
406
232
7,015
1,185
1,624
0
1,315
2,369
1,087
119
49
10, 757
2,078
390
430
391
288
240
558
3, 493
4,753
2,255
194
2,455
40
494
126
115
1,593
183
19, 004
822
60
4,314
853
715
12, 287
494
425
73
1,237
4,241
184
45
1,195
1,308
296
724
54

Trust department income
(Dollar
amounts in
thousands)

$438, 618
4,052
148
3,137
804
48, 856
8,336
8,668
0
7,443
12,904
6,688
781
347
46, 955
8,814
2,188
2,023
1,975
1,804
1,492
2,925
17, 177
14, 692
10,431
933
10, 466
274
2,859
1,006
627
11,913
823
75, 187
3,736
436
15, 896
3,813
4,355
40,581
1,963
1,867
602
5,623
21, 098
936
289
7,257
7,359
1,541
4,223
315

*As of December 1967.
fEmployee benefit accounts include all accounts where the bank acts as trustee, regardless of whether investments are partially,
or wholly, directed by others. Insured plans or portions of plans funded by insurance are omitted, as are employee benefit accounts
held as agent.
^Includes all accounts, except employee benefit accounts and corporate accounts, in which the bank acts in the following, or
similar, capacities: Trustee (regardless of whether investments are directed by others), executor, administrator, guardian; omits
all agency accounts and accounts where the bank acts as registrar of stocks and bonds, assignees, receiver, safekeeping agent, custodian,
escrow agent, or in similar capacities.
§Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

218

APPENDIX G

Addresses and Selected Congressional Testimony of
WILLIAM B. GAMP
Comptroller of the Currency

293-544—68

Addresses and Selected Congressional Testimony of William B. Camp,
Comptroller of the Currency
Date and Topic
Page

May 4, 1967, "Our Common Purposes": remarks hrforft the: 70th Annual Cnnventimi, Oklahoma Rankers Assudaliuii, Tulsa,
Okla
July 7, 1967, before the Texas Bar Association in Convention, Dallas, Tex
July 29, 1967, "Bank Management arid Comrrmrrrty Development": remains before the West Virginia Bankers Awtuc-ialiun al
the Greenbriar Hotel, Homestead, W. Va
Sept. 26, 1967, hefore the Oemeral $K«inm nf thr. 93rd Annual Convention of the American Bankers A»«odHliun, N^w York,
N.Y
Mar. 20, 1967, hHVwr: thft Committee on Banking and Currency, TTrnise of Represeirtativtrs, Wiwliiiigton. D.C
Apr. 13, 1967, before the Senate Committee on Banking and Currency, Washington, D.C
Aug. 2(5. 1967, before the Siihcommrttftr. on Financial Institutions of the Senate Banking and Currency CumimUee, Wellington, D.C
Nov. 16, 1967, Testimony by Deari Miller, Deputy Comptroller of the Currency for Trusts, before ihe Senate Banking and
Currency Committee. Washington, D.G

220

221
224
227
230
232
233
234
236

REMARKS OF WILLIAM B. GAMP, COMPTROLLER OF THE CURRENCY, BEFORE THE 70TH ANNUAL CONVENTION,
OKLAHOMA BANKERS ASSOCIATION, TULSA, OKLA., MAY 4,

Our Common Purposes
Looking back over my 30 years with the Comptroller's Office, one of the continuing pleasures has
been meeting with bankers such as yourselves. These
meetings not only provide opportunities for renewing
friendships, but also stimulate thoughts on our common purposes.
Similar meetings of bankers' groups were held long
before any of us attended our first, and we know that
their objectives were little different from our own.
Fortunately, the proceedings of these meetings were
often recorded and they remind us of some of the
parallels between ourselves and bankers several years
ago. Shortly after my appointment as Comptroller, a
friend sent me the July 15, 1905, issue of The American Banker.
This issue featured a report of a meeting of the
Tennessee Banker's Association, including copies of
some of the speeches that were made at their 1905
convention on top of Lookout Mountain. Reading
these speeches, I was impressed with the enduring
nature of some of the fundamental principles and
problems of banking; only the reactions in response
to the world about us change and therein lies the
touchstone of successful, meaningful and useful bank
supervision. Put simply, in order to exploit emerging
opportunities, we must meet present circumstances and
developing conditions in new and imaginative fashion.
Indeed, the commercial bankers have pioneered and
led in many of the modern innovations that are commonly accepted by business today.
Banking is a changing field—a dynamic field—and
I encourage the young men entering the profession,
just as I encourage you today, to stay abreast of modern
needs and opportunities. But we must, at the same
time, be sure our reactions and practices are consistent
with prudent and sound banking operations. Our ultimate goal is, after all, the preservation of a viable and
sound banking system.
This is not an easy task in today's world of computers, satellites, and supersonic jets; nor was it in
years past. According to the July 1905 American
Banker, we were in "an age of wonderful advance-

1967

ments, startling discoveries, and fast transportation like
the 'Pennsylvania Flyer,' a train which could go from
New York to Chicago, some 900 miles, in 18 hours—
wireless telegraphy, the automobile, (and) the flying
machine."
The speakers before the Tennessee bankers were
fully aware of the difficulties in following "safe,
prudent banking" practices while adapting to existing needs. In lauding the virtues of "conservative
banking" one speaker observed that "Conservatism as
commonly interpreted is a very desirable element in
the makeup of the executive officers and directors of a
bank, but conservative banking that opposes change because it is change has no place among the progressive
and successful bankers of today."
The man who carries a half bushel of corn in one
end of the bag and a large stone in the other end to
balance it as he rides horseback to the mill, because his
father did it that way, is out of harmony with this age
of progress and development. And yet, the man who
grasps at every new fad and change that comes along
and adopts it because it is change, without first carefully and patiently considering its suitability and desirability, thinking only how brilliantly he may outstrip his more plodding competitors, is an unsafe
leader.
Fads are easy to follow; often too easy, not because
bankers are given to fads and fashions but rather, I
think, because fads are often imprudent, well meaning
reactions to a rapidly shifting environment.
Never before have we been in the midst of an economic climate undergoing such rapid and pervasive
changes: industries appear almost to arise fullblown
out of Minerva's head; the activities of others are
transformed almost as readily; business and household
locations shift from central-city to suburbs, from East
to West, from North to South, from rural to urban
and back, almost in disregard of traditional locational
ties.
These changes are not always predictable and sometimes follow patterns that are quite unexpected. All of
you present are aware of industries or of centers of
residential construction in your own communities,

221

which once seemingly promised a prosperous and extended growth, but ultimately faded away. No doubt
we could compile a long list of such disappointments.
The future course of your communities' industrial
and residential growth is by no means the only difficulty in adapting tn A rh^r^rtv world. Mcst C<f these
conditions rail for new practices, for new credit techniques, for r«fw Ytxrik services., or for expansion c£ eAisting practices. Tn my rupfrricm, banks in recent years
have donr. a truly iwrtstanrling and imaginative jdu uf
df.vrl«fwng mA adapting then piuceduic* in ic*}.n.vri!^
to thrar. drrmmffcij and, as stated earlier, iri exploiting
and Irarivrtg the way fr/r mr*dem business techruMueK
The initial intrndnriion of new services;, no matter
how carefully thought out in advance, is only one step
in the ultimate, exparwirim of a bank's services tu the
pnhlir. T JivfeH wf. lwvr. r.xpr.r?cr?o% it is difficult lo judge
thft rffrrts and th*. hr.nefi+s of p/ope«ed new pidiliccs.
Onfi vital asport. r/f irmrA^fir/r^ especially by banks^
i.i the contirmai and mnst careful appraisal of mfcarnation concerning the ccM& anrl hewefrls—both to the
bssik and to iti mstomr.rji—r/f «r<y newly introduced
service. T WCTHM rr.rtainfy nwt quarrel with any sincere
banker striving to be of maximum service to his community. I would only caution him to have his homework done, and to first explore a new course as fully
as possible with all thr. mansgrenent techniques and
tools at his command.
The p r e s e t rush hy Ytxrrkz to irrtmduce credit cards
may atrvc. an A raar. in pntnt. On the whole* it jtj^ean
that by vf.r&arr\ng into this aiTA, ha/rV« deserve high
marks fevr aggrrsswrfy sr.rving rJr.^r and legitimate
public needs. Tn «. ncmtiniiing effort to keep <fca £>>
amination procfidurrs mrrrrv*, v«i are a&tfng a spef ial
section in the report, dealing r^rchisively with credit
cards. This should prove especially valuable to banks
currently offering credit cards and to those of you
contemplating the same.
Some 20 years ago, installment lending by banks
was approximately at the same point in development
that credit cards are today. Many forecasted doom if
banks were to enter the consumer credit field. Yet
today, the installment loan function is the "bread and
butter" of many banking operations. This was not
accomplished without problems being encountered,
but these obstacles were solved by the banking system,
one that allowed itself the flexibility and foresight to
adapt under the most negative and pressing conditions.
No doubt many of you present helped to make installment credit the profitable business it is today.
The credit card is simply another means of extending
credit. The banker who extends credit, whether it be

222

in large or small amounts, has the responsibility to his
borrower, to his bank, and to his community to exercise prudent judgment. Credit is a positive and constructive force when administered with intelligence.
Tndccd, I know of no business or businessman in our
prrsmt. errmrany who could siuvive and build without
some fnrrm of credit being available to him.
Orcxiit is f/nt of the i/idiftUio wiiidi lias staved U>
makn our country strong. When abused, it can be
dcstmrtiv£j nr/t onty to the icLipic-irt", bul in raUrezne
rirrur*sfom*r.s U, \\\t c r d h gidirfiu, and idiiinaldy U>
the nation*] economy. Like «lcu«ii«j energy, it miut be
hiumeMrA frrr the good uf the Naliuu* h^aAWi wheu
perverted, ahtnftd or cai~elessiy administered, it has
latent power for destruction.
OflrtAin studies which are now underway, coupled
v«#i thf. n*w Kcticwi in uui cjuumiuidluii icpuiL, huptv
fiilly will pmpciirK any iuiicieid puAAaw in llii« activity and prmrirle sound guidelines fur future upeiatioiiB.
Frir each of us> vnex-aliug banker and bank mpervisr/r, this seems lo be a lime fur thuruugii analysis. This
is not to imply ihdi \hs CS-MiiptiuiieiSs OIIic«, during my
tenswe, i/rteii-Is lu m l uu paui giuiuidwoii^-oidy, tliat
change just for the sake of change is not always the
most prudent road to travel. It is just as necessary
today, as in years past, to maintain the proper perspective in choosing between iririuva!iuns and traditional
methods.
During my career with the Office of the Comptroller
r/f tkft Onn-ency, one of my must iignifiuAiit ubservalions
hfks Keen the eiTui I* uf the bdijkliig system lu meet the
rrceris of thel/ coiiuiiuiilties and uui greal Nation. This
has been accoArplivhed, butli al the Stale and National
levels^ through the exlaWiiimieiit of new banks and
branches, and thix>ugh llie extaUudimtsnl of new supervisfflry ?nd management teclmiques lu aid llie banks in
helping to develop their communities.
It should be pointed out that this Office does not, of
comse, select any new sites fur piupused banking facilities, as this determination must rest with llie applicants. Applications for new charters and branches
should represent well-meaning efforts to respond to
the growth, to the changing geographic distribution,
and to the changing population and industrial composition of towns and cities. However, we frequently
find, in reviewing branch and charter applications,
that these applications are not always well conceived
and even today's high level of income and giowlli du
not guarantee the prospects of a poorly located bank
or branch any more than they guarantee an overextended line of credit.
The banking system's structural response to the dial-

lenges that have faced it has been widely discussed.
Much of this discussion has, in my opinion, been misdirected to the alleged conflicts between the various
regulatory and supervisory agencies. To me, the reputed conflict has been overdrawn.
As a member of the Board of Directors of the FDIG,
I have not missed a single meeting since becoming
Comptroller. Nor have I missed a meeting of the Coordinating Committee on Bank Supervision, of which I
am currently Chairman.
I do not envision anything other than a very smooth
operation of the Coordinating Committee. Certainly,
in a great democratic process such as we have in this
country, there are bound to arise differing views from
time to time. But that's healthy, and those differing
views will in no way bring about any cleavage in the
Committee.
The common objectives of the bank regulatory
agencies have brought forth productive results in the
past few months. For example, the agencies devised a
formula which was inserted in the December 1966
report of condition in order to obtain the liquidity position on a given dulc of (lie commercial banking EyEtexn.
Each insured bank, as a supplement to its report of
condition, was requested to supply uniform information with respect to its volume of liquid assets. While
the formula employed is by no means perfect, it nevermclcas was llic first tiiiic the bank supervisory agencies
icccivcd uniform liqmeftty dftta on the b&nkmg system.
We initiated a procedure for dealing with the transfer uf information involving changes of ownership of
insuied banks, loans to executive officers, and loans on
bank stock. This information is especially helpful to
each agency in discharging its supervisory responsibilities. In addition, when the occasion warrants, the
agencies have conducted simultaneous examinations.
The advertising guidelines are another example. Other
mallei* pivseiilly under study are a uniform report
of condition, accounting regulations and capital
adequacy.
I am happy to report, in short, that the climate
among the regulatory agencies has reached a high
point from the slaiidpuiul of cooperation and assistance in all matters of mutual interest, and I am confident this will redound to the benefit of commercial
banking throughout this country.
The structure of commercial banking in the United
States has been shaped by the existence of both State
and National supervisory agencies. Some critics have
held that the dual banking system is a vehicle for
opposing change.

This is unfortunate, and, quite frankly, wrong! To
my mind, the dual banking system is well suited for
facilitating change and for generally pursuing our
common purposes.
As I have stressed, our common purposes stem from
the necessity, and benefits, of adapting our banking
practices and institutions to the changes that. America's
dynamic, and sometimes erratic, development thrusts
upon the banking system. This development is complex and varied; some aspects of the changes in the
economy of Oklahoma and of your own communities
often differ widely from that of other States and of
other communities. So, too, must the responses of
banking in Oklahoma and in other States vary if local
banks are to best serve their own communities. For individual bankers, this sometimes involves an aggressive,
yet judicious offering of modified or new services that
are permitted under existing ground rules, our various
State and Federal banking laws.
But, as we are all well aware, ground rules which
were considered adequate, or even liberal, a few decades ago may now strangle legitimate, efforts of banks
to best serve their communities. Moreover, ground rules
that suffice for one State may smother the. operations
of banks that face very different challenges in another
State.
The dual banking system^ above all else, provides the
freedom to mold the gro iir| d mlp« tn he«it SPT-VP the
circumstances of indudHinal States Looting at hanking
in all States^ as I must, I am forred to consider regulatory policy in terms of its effect on all National hanks
which operate under many and varied rirnimsta.nr.es.
But for individual States, it seems to me that the dual
banking system permits a smooth evolution of hacking
legislation—a particular experiment can be confined
initially to one State, and individual States are able
to draw on the results of other States. It also places
the responsibility for initiating changes in many ground
rules with the States' banking community, bank supervisors, and legislature.
But we must be ever vigilant—we must constantly
reexamine our ground rules and their restraints on
services to our communities- and we must he constantly
prepared to initiate, those, changes which studies show
to be necessary and in the public interest. Only by
continual reexamination of our policies, can we meet
the challenges of today's dynamic economy with aggressiveness and imagination. Whenever any of us
neglects the continual review of our policies, be they
operating, supervisory, or legislative, we neglect our
responsibilities in pursuit of our common purposes.

223

BEFORE THE TEXAS BAR ASSOCIATION IN CONVENTION,
DALLAS, TEX., JULY 7,

1967

I am honored and pleased to have the opportunity
to address this distinguished gathering of attorneys
from my home State of Texas. It is not often that a
client gets an opportunity to talk back to this many
lawyers at once, so I accepted the invitation to speak
to you with special pleasure.
I think I more than qualify as a client. When I took
office as Comptroller of the Currency early this year,
I probably inherited more lawsuits than any Comptroller in history. Fortunately, I also inherited an able
staff of attorneys. Many of these suits involve important issues which may be of interest to you, and if
you will excuse a layman's presentation of these issues,
I shall be glad to summarize some of them a little
later.
Long before the involvement of our Office in extensive litigation, the attorneys on our staff were considered a highly important element of our team of
professionals. That team is made up of our Deputy
Comptrollers, Bank Examiners, Economists and Administrative experts in addition to our attorneys. Together they make up what we think is one of the most
competent professional staffs of any agency in Washington. Their specialty is banking in all its aspects.
The function of our Office is the supervision and regular examination of all National banks and the enforcement of all Federal laws and regulations which apply
to National banks. In cooperation with the other Federal and State agencies concerned with financial
institutions, our sole aim is the furtherance of the
soundness and liquidity of our entire banking system.
My title, Comptroller of the Currency, is no longer
descriptive in any material way, of our functions. As
all of you I am sure are aware, the National banks
ceased issuing currency of circulation many years ago.
The term Administrator of National Banks is much
more descriptive of our actual operation.
In the performance of its functions, any banking
agency must depend heavily upon its lawyers. Banking is an industry which touches law in all its forms,
perhaps more so than any other business. Each banker
and bank supervisor must thread his way through an
intricate network of State and Federal statutes, case
law and regulations. This network is constantly being
revised to meet the everchanging nature of our business environment. Indeed, in too many cases, the
change in law and regulation has not been rapid
enough, and our attorneys must try to fit new forms of
224

banking activity into statutory and regulatory molds
which were formed to fit earlier technologies.
As an example, the development of automation is
having a tremendous effect on bank operations and our
lawyers and other staff people are constantly being
asked whether this or that activity made possible by
use of computers is permissible under present law and
regulation. In the larger institutions, the computer
has virtually revolutionized bank operations and has
opened up many new opportunities for service to the
public. Our latest lawsuit covers just this question—
the scope of the permissible activity by banks in the
computer field.
We think that the function of an agency, such as
ours, is not to obstruct new activities by banks, but
only to watch carefully the effect of such activities on
the financial soundness and liquidity of each particular
bank. Today, the rush is on for banks to finance consumer purchases by the use of credit cards. On the
whole, it appears that by venturing into this area,
banks deserve high marks for aggressively serving clear
and legitimate public needs. We, in turn, have added
a special section in our regular examination which
deals exclusively with the credit card operation.
If the public continues to accept the concept of
revolving credit and credit cards as a convenient means
of financing its purchases of goods and services, it
may be necessary for you, as lawyers, to urge upon the
courts and legislatures such changes in State and Federal statutes or precedents as may be necessary to adapt
current law to current lending practices.
This is just one of the many types of legal questions
which we have to deal with daily. I think one of the
reasons we have been able to attract top law students,
as well as experienced attorneys to our staff is the
great variety of legal work in our Office. Although we
deal with only one industry—banking, on the law
side we have, to cover all three branches of government. Our attorneys may be in court in the morning,
before a Congressional committee in the afternoon
and, of course, dealing with the Executive Branch all
day long.
One of the most important, and apparently growing activities of our lawyers is participation in administrative hearings on applications for new National bank
charters, new branches of existing National banks and
mergers. The final adoption of a practical, fair and
expeditious hearing procedure for such applications
is a task which is absorbing our attorneys, as well as
those of other Federal and State banking agencies.
It would seem that the hearing procedures for
handling such applications should by now be set, but

thft fact, is that, for almost. 100 years from the founding
of our Office, in 1863 until about 1963, the licensing
functions of our Office were conducted on an entirely
informal coirfefrenc.fi basis without adversary proceedings. An authority on administrative law, Professor
Kenneth Davis, in his Treatise on Adminut.raJ.ive T.aw,
described these proceedings a.s follows:
The striking fact is that whereas the ncmfeariking agencies
adTmrrister (heir Systems uf requiring license and approvals by
conducting formal ndjudications in most cases involving controversies, the hanking agencies use methods of informal supervision, almost always without formal adjudication, even for
the determination of controversies. The contrast is a striking one with respect to each parallel problem; for instance,
the problem of the extent of community need is about the
same whether the application is for establishment of a bank,
a television station, or an airline, and yet the problem is handled in the banking field by the methods of the business man
and in the other fields by the methods of the judge in his
courtroom.
The informal conference method referred to by
Davis, of course, could not have been utilized for almost a century without the approval of the industry
affected, the courts and the Congress.
With respect to the general feeling of bankers on
this question, I think it is a safe assumption that the
great majority of them favor the conference method
over the adversary approach. If this were not so, I
think that there would have been legislation on the
point long before now.
Every court considering the question, has held that
there is no statutory or constitutional requirement for
a formal adversary hearing prior to our action on an
application. There are quite a few cases on the point,
the latest appellate case being Webster Groves Trust
Co. v. Saxon, decided by the Eighth Circuit Court of
Appeals in December 1966.
Despite this long history of acceptance of our informal approach to licensing matters, there has been
considerable push toward more formality in recent
years. The competition for choice locations in rapidly
developing suburban areas has become increasingly intense with a corresponding increase in protests by
competing institutions and conflicting applications for
the same location. Other causes include an increasing
number of applications for new bank charters with
corresponding increased opposition by existing banks,
as well as developments in the law concerning bank
mergers.
There are also other factors which have led us recently to a ree.xami nation of our administrative processes. One such factor was the decision of the Fourth
Circuit Court of Appeals in the First National Bank of

Smithfield v. Saxon, The court, while upholding the
general rule that neither due process nor any statute,
required our Office lo Wold adversary proceedings, held
that in the absence of such proceedings the district
court must receive evidence on and decide de nuvo the
question of whether the 'joimiiuiiity needed a new
branch bank. There have also been some bills introducer! in the Congress which would require our Office
to hold full scale Administrative. Procedure Act hearings prior to the chartering of new banks or brandies.
Thus, the traditional informal conference methods
of handling matters is coming under scrutiny from
various directions. I wish to underline with all the emphasis I can, the fact that under our traditional informal procedures, all parties, whether applicants or
protestants, have equal access to those people in our
Office who are responsible for making recommendations and decisions.
First, our Examiners visit the community to be affected, interview the applicant, competing bankers and
others representing a wide cross-section of the business
and civic life of the community. The State Supervisor
of Banking is contacted for his views. After the application has been thoroughly investigated and a recommendation made by the Regional Administrator, it is
forwarded to Washington for consideration by Deputy
Comptrollers, Law, Economics, and other departments. At any time during the process, any officer
responsible in the field or in Washington, is free to
telephone or call in any person interested in the application, whether for it or against it. Similarly, any
protestant could ask for and receive an opportunity
to express his objections to the application to our
people. However, the procedure was essentially investigative, rather than adversary, and opposing interests were not called in at the same time.
This same procedure is still being used in the
handling of uncontested applications. In certain cases,
however, on the request of an applicant or a protesting
party, we now schedule adversary hearings held usually
in the regional office. While these hearings are not conducted with the full formality of an APA hearing, a
verbatim transcript of the proceedings is taken and
cross-examination by opposing parties is permitted.
In the near future it is our expectation that a final
format for these adversary hearings will be published
in the Federal Register. In these procedural regulations, we will do our best to serve the interests of fairness to all parties and, at the same time, not bog down
the growth of the industry in a morass of administrative and judicial proceedings. It will do neither protestants nor applicants any good if a procedure is

225

adopted voluntarily by our Office or forced upon us
by the courts or the Gungres^ which will prevent any
bank from using a contested location for the two, three
C'x UJVPIC ycrciiB xl la.&c-> Iw ics>_'ivc A H ' I U W I C U

ttuzuiiiisiiii-

iive px-oceediiig held in accordyjice wilh the Admiii"*Itn live Pic* eduxvs Ad. That would be akin to throwing
mit the baby with the bath water and, in this case
ill* baby could be the besst iiiteit»ls» uf the biuxking system. I kuxi cuiifidwil tliiit Qxxuugh llxe appiicaliuxx uf
ihe best principles of admixiixlialive law, uur agency
and the other Federal and Slate banking agencies
which are enocmrjiteiirig tin* pxoWeixx, can cuxxxe up wilh
a practical solution which will be sxippoiled by the
courts and Congress.
In the time remaining, I will summarize as best I
can tin? iv>iies ixxvuived in some v£ our muie inipLulairt
recent litigation.
I would like to start with a case that we lo»l x-ecen tly.
I refer to the so-called "revenue bond" case. Baker
Waits, et al. v. Saxon and tlie New York Fori Aullwrily.
The plaintiffs in Baker Watts were a group of investment bankers who challenged (lie legality of our position on the types uf public securities National banks
can underwrite.
The Federal District Count for the District of Columbia, held that under applicable statutes, National
banks cannot underwrite any bonds which are not directly or indirectly backed by tlie full faith and credit
of a political entity possessing general taxing power,
including tlie power to tax real estate within its borders. The statute in question, 12 U.S.C. 24 uses the
words "gfejaearal obligations uf any Slate ur of afiy political subdivision thereof," and we ai^ued to the court
that the concept uf taxing power is iiowiiexe coxxlaixxed
in the statute.
Uxifortunately, not oxxly did tlxe distxici couxl disagree witli us,fcaitalso tlxe Federal Reserve Boaxd axxd
the Solicitor General. The Solicitor General has llxe
power of decision whether to appeal such mailers and,
contrary to our recommendations, tlie decision was
made that tlie government not appeal tlxe case, although we understand that llxe Poxt of New York
Authority is pressing its appeal.
As a result, tlie arena for this rather loxxg-standixxg
controversy lias shifted in part fxom llxe couxls to tlie
Congress, where a bill, Sv lSQG, is pendixxg which would
pexxxxil cu/rime/cial banks to uxxdexwiile llxe boxxds in
question. As we see it, ihe. only issue involved in the
revenue1. honH matter is th« atrirtly legal fine, Tt is Txti
longer true, if it ever was, that public bonds payable
out of specific sources of revenue, present greater underwriting risks than do the so-called general obligation

226

honds. Many revenue hnnrls are rated higher than
wmft general obligations and, in r.hfc ra.se of rrth<*r i
the reverse could be true.
nrii"iSf.fjiii".riii.iy it. rl,-n" nc,[. opptAJ" thai

t."

int.ftrpmtat.iori nM.fiif-.rl by the. cenrrt^ will resnlt. m any
Rigrrinrarit safftgiiarris against, hariks taking nnrftift underwriting risks. Tt could result, however, in appreciably higher c.riSH to t.lir/se pnWic iwurr.i \A\ci are ekrAeA
thft Kf.rit4i+. erf V/irin f m m cr/rnmcrrAa.] Yamk

urntorwritr.n.

At the. raqiintt of t.hp. Rp-.n»te r^mmittrr. ronskfcnng
F>. 1306, our Offir.fi, in cooperation with tha Federal
'Reserve, is stlTmpting to gathrr sigrsificant. pn«r. data
on the underwriting costs of honds on which commercial banks have been permitted to bid, as compared
with those issnrs em which commercial bank participatir/ri Vrfw hftftn prohihtted. Our Offifft regards rftvenue
bond underwriting as a legitimate and prudent activity
for National banks, anrl we support the pending legislation to permit this activity.
The most significant recent ca.se involving our Office
"s the one brought in Minnesota three weeks ago by
the Association of Data Processing Service Organizations against the American National Bank and Trust
Company of St. Paul and our Office. It challenges the
right of National banks to contract for the performance
of computer services for customers and for others. As
T mentioned earlier, hanking is rapidly heeoming heavily computerised. Tn view of the rapid technological
developments in this area, this case is certainly one
of our most important pending pieces of litigation,
American State Bank v. Saxon and the Kenosha
National Rank is in F^fl.-.r«.l District. Cnnrt fnr thr. District of Columbia. Thft issue is whftthr.r a Wisconsin
Kfatft stAtntr, which authorizes savings anrl loan associations to have branches in Wisconsin, may be
interpreted as permitting the establishment of branches
hy National banks in Wisconsin. I understand that a
similar faet situation exists here in Texas, The former
Comptroller, Mr. Saxon, gave tentative approval to
the defendant Kenasha National P»ank to open a
branch on the theory that the National Bank Act (12
"{J.S.C. 36) permits National hanks to hrarirh at locations where State banks are permitted to branch. The
basis of the defendant's position is that the definition
of State hank in .section 36 includes any "institution
carrying on the business of ha.nking" and that, savings
and loan «,ssoeia.tions are, in fact, r>ssenfm.Hy engaged
in carrying cm the rmsiriftss of hanking- The plainlifl1,
A Slate lw*k, made a motiua for suuumu-y judgxxxent
enjoining tlie opening of the branch. The District
Court refused to rule that, as a matter of law, tlxe
plaintiff was entitled to his injuncliun and has set tlie

case for trial on the mixed question of fact and law
of what constitutes the business of hanking. The trial
has not yet been held.
Arnold Tours Inc. v. The Comptroller and the
South. Shore. National Bank- is a recent case, pending
in Fftdfcra.1 Distrrr.! Court m Massachusetts. It involves
the issue of whfithrr a National bank may legally offer
travel services. It has long been the position of our
Office, and this antedates Comptroller Saxon, that
providing travel agency services for its customers historically has been a part of commercial banking and
within the incidental powers of National banks. The
plaintiffs, a group of independent travel agents^ are
challenging the correctness of our ruling and the activities being conducted pursuant to i t The case is in
an early stage and no decision has been rendered.
First Citizens Bank and Trust Company v. Saxon,
pending in the Eastern District of North Carolina^, is
representative of a group of branch cases filed in the
Fourth Circuit. In these cases, competitor banks are
seeking to enjoin the opening of National bank
branches on the ground, among others, that hearings
afforded to protesting parties by the Comptroller are
inadequate. Some of these suits were filed following
the decision of the Fourth Circuit Court of Appeals in
First National Bank of Smithfield v. Saxon discussed
earlier. As I said before, we regard the issue of administrative law involved in the North Carolina cases as
a most important one not only for our Office, but for
the whole banking industry and all State and Federal
agencies with authority to license new banks and
branches.
Some of the North Carolina cases involve another
unresolved issue of importance. That is the extent of
the reach of the Supreme Court decision in Walker
Bank and Trust Company v. Saxon, the Utah case.
You will recall that the Supreme Court held specifically
in Walker that a provision of the Utah law, permitting branching only by acquisition of an existing bank,
was binding on National banks, but it did so in rather
general language. The application of the Walker rule
to other types of State law provisions, such as provisions
requiring determinations by Stale administrative officials, will probably require f uilher clarification by the
courts.
Georgia Association of Independent
Insurance
Agents v. Saxon is a challenge to our ruling which
permits National banks to sell credit life and other types
of insurance coverage incidental to the lending function. The district court for the Northern District of
Georgia held against us. However, an appeal is being
taken to the Circuit Court of Appeals.

Investment Company Institute v. Saxon challenges
our ruling permitting a National bank to sell participations in a pool of securities managed by the bank as
a fiduciary. The suit is based on the Glass-Steagall
Act which had as one of its purposes the separation
of investment Hanking from commercial banking. The
case was argufid last week in the Federal District Cuurt
for the District of Columbia, and we are awaiting
decision.
I will end with a case which we won recently in the
district court for the Northern District of Florida, First
National. Bank in Plant City and Camp v. Dickinson.
The issue was whether the use by a National bank of
an armored car to pick up money for deposit from
stated locations, constituted unauthorized branch
banking. Our position is that it did not. The court
granted our motion for summary judgment on this
issue, and the other side has filed a notice of appeal.
I think you will agree with me after listening to the
brief summary of some of our recent activities, that law
and banking are closely interwoven. Lawyers are an
integral part of our team. In conjunction with the rest
of our staff, they perform a vital function in the
carrying out of our basic mission—the protection and
furtherance of a viable and sound banking system.
BEFORE THE W E S T VIRGINIA BANKERS ASSOCIATION
AT THE GREENBRIAR HOTEL, HOMESTEAD, W. VA.,
SATURDAY, JULY 29, 1967

Bank Management and Community

Development

No one who traverses the rolling hills, the fertile
valleys and the lofty mountains of this State can fail
to be moved by the grandeur of its beauty. Many have
learned the joys you offer to vacationers. Some, like
myself, look forward to pleasant years of retirement
within your borders.
Your material resources are rich and enormously
varied. Near at hand lie the burgeoning markets of the
metropolitan East as well as the South and Midwest.
Opportunities abound for an accelerating pace of
development.
But this future has to be created—it will not emerge
without foresighted policies and dedicated efforts. No
group will play a more critical role than you, the leading bankers of the State.
Throughout modern history, those nations have advanced most which have been blessed with bankers
of vision and enterprise. The same has been true of
areas within nations.
Our country's economic development is going forward so rapidly—and in so many directions at once—

227

that its most constant aspect is change, itself. Products
and services which were unknown a few years ago are
commonplace commodities today. In this restless ferment of growth, entire industries migrate from one site
to another, and those they employ either move with
their old jobs to new locations or find work in still
different areas of enlarged opportunity.
It is not uncommon to ask a new acquaintance where
he is from and have him reel off half a dozen localities
in which he has lived and worked over the past decade.
The reasons are not difficult to understand. Societies
progress by mastering their environments, improving
their technologies, and making the best and fullest use
of their human and material resources. In an age of
far-flung markets and highly-technical and large-scale
enterprise, an essential ingredient for success is capital.
The banking system is the chief instrument for the
gathering and distribution of capital resources, and the
skill and energy which bankers display in performing
tills function will critically determine the rate of economic advance. In my opinion, banks in recent years
have done a truly outstanding and imaginative job in
developing and adapting their procedures in response
to these demands. But this is only the beginning and
banks must remain alert to the opportunities which
present themselves almost daily.
This high responsibility of bankers for community
development is often obscured by the nature of the
public controls applied to banking. Those of us who
have the task of supervising the banking system often
appear to be more concerned with what bankers should
not do than with what they should do. And, in a
democratic society, it is right that this should be so. The
discretionary authority of bank management should not
be limited except where bank solvency and liquidity
are threatened. In such instances, when bank management has obviously failed, we have an obligation to
step in and carry out our supervisory responsibility.
But banking, nevertheless, remains in a unique position in terms of its public role and its public responsibilities. In most other industries, we rely on freedom to
compete as the principal safeguard of the public interest. Bankers, in contrast, enjoy a large measure of freedom from competition. More significantly, they stand
alone in their publicly-conferred authority to create
credit.
A less tangible, but equally real factor, is the position
of trust and confidence which bankers enjoy as community leaders. The spirit which motivates the banks
of a community will intimately influence its entire outlook. Show me outstanding bankers doing a real job
in their area, and I'll show you a striving, exuberant,

228

industrious community. This is especially true of
smaller communities; where the sources of leadership
are ordinarily fewer and outside influences usually are
not as pronounced.
There was a time when bankers, and those who supervised banks, were seemingly not overly interested
in seeking new methods of assuring the most effective
use of their resources. Indeed, this was true for a long
period following the bank holiday of 1933, and it has
not entirely disappeared. But now there is a growing
awareness that banks should be more than mere repositories of savings.
They are—as they are described—true financial intermediaries between those who save and those who
spend and invest. Banks are the source of finance for
much of the industry and commerce of the Nation—
for businesses both large and small, those now in operation and those in prospect for the future.
The manner in which banks draw upon and utilize
the resources at their command—more than any other
single factor—will set the pace and direction of industrial and commercial development throughout the Nation. Indeed, I know of no business or businessman
in our present economy who could survive and huild
without some form of credit being ava.ila.hle to him.
Credit is one of the industries which has served to
make our country strong. When abused,, it can be
destructive, not only to the recipient, but in extreme
circumstances to the credit grantor, and ultimately to
the national economy.
Banks are living institutions with great and often
unrealized capacities to serve their communities. I
know there are some who fear that if banks expand
their functions they will tread on the toes of established competitors in related fields. But so long as their
activities remain essentially financial in nature, and
do not imperil their solvency and liquidity, I see no
valid criterion of public policy which can justify withholding their services to the communities in which they
operate.
This is a matter of the highest importance, particularly in States which are on the threshold of a new level
of development. It is often the case in these States,
that capital and enterprise are deficient in terms of
the prospects which confront them.
What is essential is a vital, vibrant core of initiative,
coupled with the skill, experience and resources to conceive new ideas and make them a reality. This need is
likely to be the greatest where the population of a
State is widely scattered and low in concentration, and
particularly where a unit banking system prevails.
In these circumstances, it is often true that a single

local bank represents the principal—or even the only—
source for nurturing and conceiving plans for community development. The local banker has the knowledge
and the experience to appraise new prospects and new
opportunities; his leadership is respected in the community; he represents a vital source of needed initial
financing; and he can call more readily on required outside assistance.
Perhaps, most important of all, where small and
less well-known businesses are involved, the local
banker's judgment and willingness to assist is often the
controlling factor determining the future of these enterprises.
This concern with the best use of resources transcends both local and State boundaries. Wherever any
community in the Nation fails to develop its full potential, it impoverishes the entire Nation in that degree.
If all our resources were fully mobile, the problem
would be less difficult. But it is obvious that many material resources are highly immobile. And even labor
and entrepreneurial skill are often tied closely to local
areas.
It is thus of the utmost importance to the national
welfare that, in every community, there should be
forces at work to develop its full potential. This is a
local responsibility fully in keeping with our national
ideals and traditions. In this endeavor, the banking system has a vital role to play.
Not all communities are alike in the opportunities
which present themselves. But the immensely widened
range of activities which banks in many cities have undertaken in recent years does afford an example of the
prospects for banking services in community development. Both in ordering its internal operations, and in
conceiving new ways to bring its services to the public,
the banking industry is constantly undergoing a rebirth
of enterprise.
Change and awareness are the words today. We
must constantly reexamine our methods of doing business and be prepared to initiate those changes which
studies show are necessary and in the public interest.
Only by this policy can we meet the challenges of
today's dynamic economy and not be neglectful of the
contributions each of us should make to our community. State and Nation.
Such efforts bear fruit not only in the constantly increasing profitability of banking operations, which in
each subsequent period has reached record levels, but
also in imparting the necessary vitality to the industry
and commerce of the Nation.
There are some who are concerned that this new
spirit manifested in the banking industry is not in keep-

ing with its prudent traditions. But I find nothing imprudent in seeking new methods to better serve the
public. These new services, provided they are soundly
conceived and administered, will redound to the benefit
of the banks and the public. As I have stated earlier,
the bankers who are willing to pioneer, to employ the
capital, and have the vision and, yes, the courage, will
be the leaders of tomorrow.
The greater risk is that these opportunities will be
imprudently neglected out of a narrow view of the
banker's proper role in the development of his community. The public franchise, which bankers enjoy,
places upon them a special responsibility of trust to
see that the mechanism of finance is soundly employed.
This responsibility calls for nothing less than a constant alertness to community needs; the vision to see
the prospects which lie ahead; and the leadership to
convert prospects to full reality.
You, as taxpayers, and, certainly the National bankers among you who so enthusiastically contribute to the
annual cost of our operations, may be waiting for a few
words concerning our own responsibilities and how we
intend to carry them out in the future.
I would describe the primary assignment and function of our Office as the examination of banks to the
best of our ability. As I have stated on several occasions,
one of the principal emphases during my tenure as
Comptroller will be on better examinations. This is not
to say that examinations have not been good in the
past, only to say that we shall continually strive to make
them better; and I hope whoever follows me as Comptroller will endeavor to improve the examining and
other functions of our Office to the same extent. When
I became Comptroller, we set about to augment our
examining personnel by at least 200 new examiners.
In this connection, we have 14 men throughout the
United States who visit the colleges and universities on
a continuing basis, in an endeavor to recruit the top
graduates. Up to the present time, we have been able
to recruit, in a highly competitive market, about 150
new examiners. I have discussed the examining functions with President Johnson and I know of his deep
interest in this area of the operations of our Office.
I should point out that I use the word "examine"
in its broadest sense. I believe the word "analyze"
would be better to describe the work of a National
Bank Examiner. We insist that our examiners review
all facets of bank operations. In doing so, we require
the examiner to assess thoroughly the capacity of management and of operations and procedures. Here, I
would stress good internal control procedures, because
a bank with a sound system of internal checks and

229

balances is less likely to suffer serious losses. With this
in mind, we have for some time placed additional emphasis on internal audit controls and verification procedures. And, our examiners are required, in those
banks* winch the/ determine to lack adequate intcrml
controls, to perform whatever additional audit functions they deem essential to get a complete picture of
the banks' operaliuns. Our aim is not to routinely provide an additional audit, but to bring about the adoption of satisfactory internal controls within the bank.
We believe that our experience since the issuance of
uur directive has sustained its value to the banking
industry. The overwhelming majority of banks, especially in the medium- and larger-sized institutions, had
adequate internal controls prior to our directive. All
but a, very few of the remaining banks have instituted
adequate internal control systems since the issuance of
our directive.
I would like to reemphasize that our responsibility
is largely supervision. In this connection I wish to say
again thai I do not believe it is my duty to keep out
competition resulting from any function that a bank, in
uur judgment, can legally perform directly so long as
these functions are soundly conceived and operated.
It hat, been our experience that bankers do not need
government supervisors to tell them how to go after
new business or to initiate new activities. We are confident in yuur ability to icspond to the challenges of our
changing times.
BEFOKE THE GENERAL SESSIUN OK THE 9SD ANNUAL
CONVENTION OF THE AMERICAN BANKERS ASSOCIATION, N E W YORK, N.Y., TUESDAY, SEPTEMBER

26, 1967
The history of banking in our country has paralleled
the rise in stature of the Nation to the greatest among
the world's industrial powers. Tt has reflected our
struggles and our advances—our pnlit.ir.aJ as well as
our economic, development from a loose association of
States to a vigorous and forceful Federal union. And
it has borne, the mark of the vicissitudes which have
thr. dcvrvloping relationships among the
wHfr (he Federal grurtwnment, the a1t.em«t>
ing cycles of boom and bust which we experienced for
many geumalionftj and the changing conceptions of the
proper role of government in relation to business.
Through the years, banking policies often have been
the object of public controversy and political action.
Operating practices, which in other industries are solely
the responsibility of management, have, in banking,
been mailers of public concern and public control.
230

The competition for banking markets has thus been
transferred in some degree to the political sphere.
Where political action replaces market competition as
the instrument of business rivalry, policy differences
are likely to be easpiiaEized and to attract greater pnhlir.
notice.
Our concern should be to find, beneath these differences, some common ground—a unifying principle—
upon which we can agree and which will furnish a
better perspective of the challenge we now face.
Many of the disputes of recent years have been
merely jurkdictional Banks are chartered and regulated both by the Federal Government and by the
States. The course of political events has- in turn,
favored one and then the other class of banks.
Within the Federal Government, banking is r e f lated by three agencies with basically different, responsibilities and thus different outlooks on banking policies. ThiE has produced varying attitudes concerning
the proper function and purpose of bank regulation.
I regard the jurisdictional issues as the least important of the questions we face. When we consider
that any set of banking laws and regulations is quickly
outmoded in the dynamic world in which we live,
there are significant advantages in having more than
one agency involved.
The truly important questions relate to the. proper
functions of banks and the appropriate, range, of their
operations. These are issues which would not arise in
the unregulated sectors of the economy—because there
we rely principally on private competition to safeguard
the public interest. Nevertheless, it is in the unregulated industries that we are likely to find some guide to
the limits that should be placed on bank regulation.
I say this because, in the traditions of our private enterprise system, any deviation from freedom of competition must be clearly defined and clearly justified.
Bank regulation is designed for the purpose of establishing and maintaining public confidence in the solvency and liquidity of banks. These controls arc re
garded as necessary in order that banks may perform
effectively as the principal channel through which financial resources are directed to productive uses, as
reposilories of a. laigt- JMIL t*f the N^ti/vrA jumnngs, and
as the major source, of our money supply.
As I have stated on earlier occasions, banking is a
changing field—a dynamic field—the achievement of
community and national growth calls for new practices; for new credit techniques, for new banking services and for expansion of existing practices. Banks in
recent years have done a truly outstanding and imaginative job in developing and adapting their procedures

in response to these demands and in exploring and
in leading the way for modem hnsfness techniques.
If we are to respect our traditional reliance on private initiative and freely competitive markets, banks
should be entirely free to compete in the performance
of any financial function which does not impair their
solvency or liquidity. Indeed, they should be encouraged to do so as the institutions best equipped to
serve their communities in this respect.
It is clear, when we examine recent banking history
in this perspective, that many of the controversies relate not to the capacity of banks safely and prudently
to extend and diversify their operations in response to
emerging public needs, as they should—but to the very
different and much narrower issues of State versus
National banks, large versus small banks, and banks
versus nonbank financial institutions. There is little
hope that a banking system fully capable of taking its
place within the most dynamic and most forwardmoving economy in the world, can be sustained if we
center our attention on issues such as these.
The broad interest of the public is in making certain
that all banking needs are efficiently served as they
arise, and that the fullest and most effective use is made
of all banking facilities.
Indeed, the structure of commercial banks in the
United States has been shaped by the existence of both
State and National supervisory agencies. Some critics
have held that the dual banking system is a vehicle for
opposing change. This is unfortunate, and, quite
frankly, wrong! To my mind the dual banking system
is well suited for facilitating change and for generally
pursuing a greater unity of purpose.
If all banking authorities charter new banks and
authorize new branches independently, on the basis of
the unfulfilled needs which exist at the time of application, the broadest scope will be preserved for initiative
by banking groups, and there will be the least risk of
overbanking or underbanking. The chance will be
maximized that the most enterprising and the most
efficient banks of all sizes and in all jurisdictions will
prosper and grow, and that the public will be served to
best advantage.
The manner in which banks draw upon and utilize
the resources at their command—more than any other
single factor—will set the pace and direction of industrial and commercial development throughout the
Nation.
In the past, the limitations placed upon the range of
banking functions have encouraged the rise of nonbank
financial institutions, and thus produced new groups
with competitive interests to be served through political

action. Here again, the. public interest would best be
.served by insuring the fullest use of the great potential
of the bariking system to serve- consumer needs—within
the limitations of bank solvency and liquidity.
Some seek assurance that the added competition of
banks in performing new functions will produce measurable benefits. But it is the restriction of competition,
and not its furtherance, which requires defense and
justification. In financial, as in other markets, the presumption lies in favor of maximizing competition—and
banks should not be excluded from any financial market
which they may safely and prudently serve.
Since it seems desirable to maintain a broad scope
for private initiative in banking, it may appear that it
is also desirable to employ the antitrust laws to assure
the proper degree of competition as we do in other
industries. But the problem is not that simple.
Through their chartering and branching powers,
the banking authorities regulate the competitive structure of the banking industry. The banking structure,
however, is also affected by mergers—and to administer this structural factor by different standards,
diminishes the effectiveness both of bank regulation
and banking operations.
I have no illusion that the public welfare is always
easy to discern. And I realize that reasonable men may
differ on what is good and proper. But I do believe that
if our efforts are directed to this objective, rather than
the narrower considerations which underlie most of
the controversies of the past, we shall find a greater
unity of purpose, and we shall be better able to fashion
a banking structure equal to the tasks which lie ahead
for our expanding population and our growing industry and commerce.
In each community, large and small, throughout the
Nation, new vistas for growth and development may
be opened through the leadership of bankers. We
face, in the years before us, tasks, both domestic and
international, which will challenge to the utmost our
resolve, our ingenuity, and our energy and initiative.
These challenges will have to be met by both the public
and private sectors. You, as individuals, as well as
representatives of your institutions, have not hesitated
in the past to become involved in public sector activities.
One of the most significant aspects of community
service is the part banks play in local planning and
development programs, ranging from urban renewal
projects to planning the conservation and development
of the natural resources of an entire region.
Apart from their contributions in the economic
sphere and civic affairs, banks have become increas-

231

ingly involved in a variety of social problems which
not many years ago would have been considered outside their purview.
A survey made by a large National bank indicates
that not. all bankers by any means agree that the bank
as an institution should involve itself with social problems. They say that while these causes are fine for
bankers to work for as individual citizens, (hey are
too controversial for participation by the bank as a
corporation.
On the other hand, more than two-thirds of the
medium-sized and large banks participating in the
survey stated that it would be appropriate for their mRtitntiorffi to concern themselves with vital social
problems swch as the retraining erf workers displaced
by antornation, problems confronting public schools
and associated with school droponts, and low income
housing.
Rewarding employment must be. found for a growing labor force more highly trained in eadi new genei ation. Our rising aspirations call for continued, and even
accelerated advances in technology to produce more
and better products and distribute them with greater
efficiency. The Nation's political and economic goals,
both at home and abroad, will test our productive
powers with increasing intensity.
Tn the performance of these vital tasks, the banking
industry is critically involved at every point. The essential element of finance3 so largely provided by the
banking industry, is an indispensable ingredient for
the progress of the economy—and the vision which
bankers display in selecting and supporting productive,
enterprises will be a crucial factor determining the
level of our achievements.
I am pleased to report that the commercial banking
system of this country is healthy, sound, and growing
dramatically. Although the economy slowed somewhat in the first half of 1967, we have not experienced
any broad troubles. Personal income and employment
keep rising. Although there have, of course, been adjustments in certain areas of the economy, it should be
pointed out that the economic up-tum in the country
is now approximately 7 years old. This matches the
80-month expansion which spans World War II. The
record period of growth and expansion cannot be
attributed to sheer luck. Weight, must be given to the
contributions of the anti-recession policies adopted by
the Federal Government, and to the underlying
strength in the private sectors erf the economy.
Let's compare consumer price increases during the
first 18 month periods of the last three conflicts the
United States has been involved in. During the first
232

18 months of World War II, we experienced a 12
percent, consumer price increase. During the first. 18
months of Korea, we experienced an 8 percent consumer price increase, while during the first 18 inontlis
erf major buikl-up in Vietnam we experienced a S,S
percent increase. This low figure of 3.3 percent is
even more remarkable when you consider that we
have not. had any wage and price controls as we had in
both Korea and World War II.
In closing, I would like to reemphasize that our
sights should be set on our opportunities and our obligations—on constructive measures to improve performance, and broaden the horizon.!} of all our banks.
This is a joint responsibility which calls for an understanding relationship between the regulatory authorities and I he baiiklrj" industry. The stakes are high and
the aim is worthy of the full energies and thought of
this industry which has contributed so much in the
past and holds so much promise for the future,
I am ronfid«nt that, working together, we can meftt
this challenge.
BEFORE THE COMMITTEE ON BANKING AND CURRENCY,
HOUSE OF REPRESENTATIVES, WASHINGTON,
MARCH 20,

D.C.,

1967

Mr. Chairman and Members of the House Committee on Banking and Currency: This is my first appearance before your committee as Comptroller of the
Currency, and I, together with members of our staff,
welcome this opportunity to meet with you today.
While most of you are, of course, fully familial1 with
the scope and operations of our Office, I thought it
might be helpful to some of the newer members of
the committee, if I briefly outlined some of the history
and functions of our Office.
The Office of the Comptroller of the Currency was
created pursuant to the National Bank Act of 1863.
Our Office is charged by statute with the authority
to charter new National banks, pass upon their applications to branch, merge, and consolidate, and to examine, supervise, and regulate the operations of our
4,800 National banks, their 9,400 domestic branches
and 235 foreign branches.
As of December 31, 1966, National banks had approximately $935.9 billion in total assets, $126.8 billion in total loans, .$206.4 billion in total deposits and
$18,6 billion In total capital accounts. In addition, on
the basis of latest available data5 National banks had
investment responsibility over $89.5 billion in trust
accounts.
Ry statute, all National banks are required to be
members of the Federal Reserve System.

I consider the examination function to be the primary responsibility of our Office, In carrying out this
responsibility, we have presently 14 regional offices
and 114 subregional offices throughout the. United
States. Attached to these offices are 1,1 33 commercial
examiners and 87 trust examiners. The scope of a National bank examination embraces every phase of banking activity found in the particular bank under examination. Tts primary purpose is to assess the quality
of the bank's assets and the quality of its management,
in an effort to maintain the liquidity and solvency of
the banking system. The examiner also determines
whether the bank under examination is operating
within applicable banking laws and regulations.
We strive to maintain the highest level of competency in our examining personnel. Toward this end,
we have assigned one man in each of our 14 regions
to recruit the best graduates we can get from the
country's colleges and universities. Because the work
of an examiner involves a considerable amount of
travel, the Office has always had to contend with a
fairly high turnover, as younger men get married and
establish their families. Our recruiting efforts have
been generally successful, however, as the percentage
of examiners with college degrees has increased markedly in recent years. We encourage all of our examiners to enroll in graduate schools of banking and we
advance various internal training programs for our domestic, international, and trust examiners.
Members of this committee have expressed interest
in the past in the matter of cooperation and coordination among the various banking agencies. I believe
there has been significant improvement in recent
months in this area. As you know, the Comptroller sits
as an ex ofEcio member of the FDIC. In that capacity,
I have attended every Board meeting of the FDIG
without exception since my nomination. In addition, I
attend regularly with members of my staff, approximately every two weeks, meetings of the informal Interagency Coordinating Committee set up last year.
The meetings are attended by Mr. Randall and Mr.
Home, of the FDIC and the Home Loan Bank Board,
as well as Governor Robertson of the Federal Reserve.
The chairmanship of the Committee is rotated every
three months. Governor Robertson has been Chairman for the past quarter, and I shall assume the role
of Chairman commencing April 1. In my opinion,
these meetings are proving to be most constructive.
Any topic of mutual interest may be placed on the
agenda by any member, and a full and frank discussion is held.
In the few months since November, concrete results

in several areas have been achieved by this Committee.
In December, the Committee worked out a set of guidelines on the subject of the advertising of rates paid on
deposits and share accounts. These guidelines, in identical form, were sent by each agency to the institutions
under its jurisdiction on December 16, 1966. The
results so far have been good in that we have seen a
marked improvement in the clarity of bank advertising—and on the part of savings and loans—of interest
rates on deposits.
The banking agencies have also joined in requesting
all banks to complete liquidity analysis forms to provide more current information on the vital matter of
bank liquidity. After consultation, the FDIC and the
Federal Reserve have agreed to request the same figures
from commercial banks under their supervision as of
year-end 1966. We expect to seek liquidity information
in the same form in connection with our request for the
spring call reports of condition.
Several staff committees have been set up to work
on individual problems such as achieving uniformity
in the various financial reports required to be submitted
by State and National banks. We regard this goal as
being especially important in view of the increasing use
of data processing machines by our agencies. We are
hopeful that the synchronization of our reporting requirements in conjunction with automation will produce valuable additional information for use both by
the agencies and the industry.
We think that the results of coordination show not
only in the positive actions enumerated, but, perhaps,
even more significantly in the absence of unilateral
actions at variance with positions taken by other
agencies.
BEFORE THE SENATE COMMITTEE ON BANKING AND
CURRENCY, WASHINGTON, D.C.,

APRIL 13,

1967

Mr. Chairman and Members of the Committee:
The Office of the Comptroller of the Currency appreciates this opportunity to express its views regarding
S. 5, the Truth-in-Lending Act of 1967.
Our Office has long believed that the American consumer is entitled to be told what his cost for credit will
be. And he is entitled to have this information in a way
which not only sets out his absolute cost, but also
enables him to decide who is offering the best terms
and what type of credit best fits his resources and needs.
Because we state our position directly, please do not
conclude that we believe all persons who extend credit
do so with a design to mislead or confuse the credit
user. Let me say that the complaints we receive against
233

National banks regarding trulh-m-lending problems
have been minuscule in number. We believe banks generally have always tried to portray fairly to their customers what it will cost them for credit.
The need for this truth-in-lending legislation, in our
view, results primarily from the far*, that there are so
many ways hy which credit is extended today that the
ordinary citizen finds it very difficult to make a meaningful rrnnpariKon and rational choice regarding thft
credit program which best meets his needs.
Thft Comptroller's Office believes that S. 5 will help
a great, deal to meet, the needs of the consumer. The
bill would require every individual and firm, which is
enraged in the business of extending credit, to furnish
to each prospective credit, user a clear written statement
of the amount of finance charge to be paid for l.he extension en* use of credit Also, to enable the user to cornpane the relative cost of credit, creditors would be
required to stale finance charges in terms of an annual
percentage rate.
Many Stales today regulate consumer credit and call
for l.he disclosure of certain kinds of credit, information
for certain kinds of credit transaction. The overall
picture in this field, however, is widely diver-gent and,
from the viewpoint of the consumer, does not provide
the uniform bases he needs fur comparing finance
r.harges made from different credit sources. It is appropriate for the Federal Government to fill this need and,
in this regard, we are pleased to note that the bill
permits exemption fur any dass of credit transactions
which are effectively regulated by Stale law.
For these reasons, this Office supports the position
of the Treasury Department in urging that S. 5, the
Truth-in-Lending Act of 1967, be enacted.
BEFORK TIIK SUBCOMMITTEE ON FINANCIAL INSTITUTIONS OF THE SENATE BANKING AND CURRENCY
COMMITTEE, WASHINGTON, D.C.,
GUST 28,

MONDAY, A U -

1967

Mr. Chairman and Members of the Subcommittee:
The Office of Comptroller of the Currency appreciates
this opportunity to lend its support to S. 1306. We
strongly urge its enactment into law.
As we see it, the basic question before this subcommittee is whether National and State-member banks
should have the power to deal in and underwrite
revenue bonds issued by State and local governments.
They now have this authority with respect to other
general obligations of the same entities. This question
raises two basic considerations of policy: First, what
benefits will flow to the public from the underwriting
234

of revenue bonds by National and State-member banks?
Second, what risks are there for National and Statemember banks in engaging in this activity?
Public Benefit
Today, our State and local governments face ever
increasing demands fur new and expanded public services. These demands are rooted in the myriad social arid
economic problems of our time. New and better roads
are needed. New and better schools are needed. New
and better mass transportation is needed. New and
better public housing is needed. New and better medical
facilities are needed. The list is almost endless.
These public needs are acute. Indeed, the newspapers of this summer, headlining tlie "crisis in cmr
cities/' dramatically demonstrate wlial happens when
vital public needs go unsatisfied. Our Stale and local
governments must sumehow find the money to satisfy
the requirements of their citizens. And they must do so
at the lowest possible cost.
Since World War TT, annual borrowing by State
and local governinrriis -lo finnnr.fi the development of
urgently needed public, services has increased tremendously. In 1941, State and local governments
spent less than $8 billion for goods and services. Today, tliey spend over $95 billion. The outstanding
long-term obligations of Stale and local governments
havft risen propor1.ional.ely. Today, such obligations
total around $110 billion. In 1966, alone, State and
local governments sold over $11 billion of securities.
And this year it is expected they will sell between $13
and $14 billion.
Revenue bonds have become a favored method for
State and local governments to obtain financing. In
the early 1930's, the amount of revenue bonds issued
annually was negligible. In the late 1940's, the figure
rose to $500 million. By 1966, the total climbed to
about $4 billion. In the late 1940's, revenue bonds accounted for less than 20 percent of new State and
local bond issues. In 1966, they represented about 37
percent.
Many reasons account for this substantial growth.
Revenue bonds are extremely well suited to financing
public projects which produce income to repay the
bonds. The theory is that those who directly benefit
from a public project, and not the general public,
should pay for it. In many instances, revenue bonds are
the most practical way for a heavily taxed community
to solve pressing money problems on a sound financial
basis. Sometimes revenue bonds may be the only way
for a ccmrmmity faced with a statutory debt limit to
obtain funds to provide services.

Because revenue bond financing is vitally important
to State and local governments, any measure which
would lower the cost of such financing to these governments would be beneficial. In our opinion, S. 1306
will afford substantial savings to State and local governments, and ultimately to their taxpayers.
We have given the subcommittee our study of the
savings which we foresee. The study, made at your request, shows that the entry of National and State-member banks into revenue bond underwriting will achieve
large dollar savings for State and local governments.
We find that the savings to the public on new issues
for 1968 alone would be $12.5 million. By 1975, the
savings would likely exceed $27 million per year. The
total savings on new revenue bond issues from 1968 to
1975 should reach $182.5 million. How our study was
conducted and the basis for our conclusions are explained in the text of the study.
We believe that, if S. 1306 were adopted, it would
increase competition in the bidding for and the distribution of revenue bonds. It would broaden and strengthen
the market for revenue bonds. The resulting enlarged
market would enhance their attractiveness as investments. Even small banks, intimately familiar with local
needs, could provide essential assistance in the preparation and marketing of revenue bond issues of their
communities. Throughout the country, investors, who
customarily rely on their bank for information concerning tax-exempt securities, would become more interested in sound revenue bonds. Finally, permitting the
banks to trade in and make markets in revenue bonds
would improve their marketability and character as
liquid investments suitable for bank portfolios and
fiduciaries generally.
In this connection, perhaps one further point should
be made. We expect that other witnesses will attempt
to deprecate the benefits we find will flow from the underwriting of revenue bonds by National and Statemember banks. And, as in thr past, they will probably
assert a presumption for preserving the status quo in
the absence of overwhelming public benefit to ihe contrary. We hope this assertion will he rejected. In our
view, restrictions on competition are unwarranted, unless justified by overriding considerations of public interest. This would be consistent with our nation's
theory of free enterprisfi. As we shall now point oul, we
S££ no public interest to bar rrrrmriercial banks from
revenue bond underwriting.
Banking Risks
Opponents of S. 1306, particularly those who desire
to preserve their privileged competitive position, may

be quick to conjure up arguments against this bill. They
have done so previously with respect lo similar legislative proposals. Their contentions should be critically
examined.
One argument is that Congress, in the Banking Acts
of 1933 and 1935, took pains to divorce commercial
banking from investment banking. Therefore, to enact
S. 1306 would be a reversal of policy, since commercial
banks would be returned to the investment banking
business. This argument is just plain wrong. In the McFadden Act of 1927, Congress approved the authority
of National banks to underwrite general obligations of
States and their political subdivisions. This authority
was reaffirmed, without change, in the 1933 and 1935
Acts.
We acknowledge that Congress, in the early 1930's,
desired to separate commercial from investment banking. Yet clearly, this attitude did not affect in any way
the authority of National banks to underwrite general
obligations of State and local governments. Such authority preexisted and was constant and unchanged
during the banking legislation which followed the
depression.
Congress has always recognized that obligations of
State and local governments have a special status. It
would hardly be a reversal of policy to reaffirm this fact
in the light of modern financing techniques. And that
is all this Bill would do. It would merely recognize that
revenue bonds enjoy the same special status as other
State and local securities.
In this connection, it is not irrelevant to point out
that when Congress creates a new federal security and
wishes to establish a market for the same, it does not
hesitate to authorize commercial banks to underwrite
and deal in that security. Some examples are obligations issued under the Federal Farm Loan Act, obligations issued by Fanny May, and obligations of the
International Bank for Reconstruction and Development, the Inter-American Development Bank, and the
TVA.
A second argument is that ijummerclal bank underwriting yf revenue bonds would entail substantially increased risks for bank*. This argument is not persuasive for two reasons.
First, S. 1306 would permit National and Stateineniber banks lo deal in and underwrite only the
same seoirilies wliicli, al present, they are allowed to
purchase for their own accounts. The bill would limit
the securities of any one issuer which such banks could
hold at any one time, whether in their dealer or investment accotmts or as a result of an underwriting,
lo a total amount not in e-xcess of 10 percent of the

235

bank's capital slock and surplus. Accordingly, no imderwriliug bank could acquire invesffine.nl. securities of
lesser qua-lily or in greater amount ihan ihat wlildi it.
is now permitted lo acquire for ils invest men I port folio.
Second, today the default record for revenue bonds
and the ratings ihey receive from the bond rating services clearly show that such bonds are not inherently
riskier than obligations backed by general laxing powers« In fact, many revenue bonds enjoy a higher rating
than some obligations backed by general lax revenues.
The present situation 1* anomalous in that, it is asseiied
by some, the law permits commercial banks lo underwrite any of the- latter securities, but prohibits underwriting of all revenue bonds. Many revenue bonds are
far sirperior in credit quality to some other general
obligation bonds.
The third argument is that conflicts of interest,
arising from the underwriting function and ihe deposit,
investment, and trust functions of banks, are likely
to result. For example, a hank underwriting a revenue
bond issue would have an interest in selling the bonds
to depositors and correspondents. Therefore, its interest would impair its ability to give disinterested
advice. Four answers serve to refrut ihis contention.
First, an underwriting bank will develop increased
knowledge concerning the issuers and the market.
This knowledge will greatly enhance its ability to give
accurate and helpful investment advice. Second, providing correspondent services, of which investment
portfolio advice is but a part, is a highly competitive
business. To contend that an underwriting bank would
recommend inferior securities to its customers, because
it underwrote such securities, is unrealistic. The risk of
losing correspondents will afford adequate assurance
that the underwriting bank will give the best possihle
advice to its correspondents. Third, the bill would
require an underwriting bank to disclose to its correspondents that it is marketing the securities in its
capacity as an underwriter or dealer. Thus, the correspondent is on notice and can, if necessary, take appropriate measures to guard its interests. Fourth, there
is no evidence of such self-dealing on the part of commercial hanks engaged in marketing other government obligations they now underwrite. There is no
reason why this problem will suddenly arise in the case
of revenue bonds.
A variation of the same argument suggests that banks
might he tempted to sell securities which they have
underwritten to their trust accounts. However, any
such possibility'has been obviated by the. bill itself. It
provides that the purchase of revenue honds by a hank
as fiduciary, from itself as an underwriter or dealer,
236

shall not. he permitted, unless lawfully directed by court
order. Of course, the hank, as a trustee, is limited to
buying securities set forth in the legal list of securities
held eligible for fiduciary investment, unless it. is given
discretion or other authority in the trust indenture.
Even without this provision, the possibility of selfdealing is obviated hy our Regulation 9 and by applicable examination procedures of this Office. Regulation
9, governing our supervision of trust departments, expressly prohibits the use of fiduciary funds to prnrrhase.
property or oWio-ations from the hank, unless lawfully
artrthori7ed hy the governing instrument, by court order,
or hy local law. This is a fudarnerrtal precept of fiduciary law which is widely recognized in the courts. We
enforce this rule irrespective of the intrinsic qualities
of the property or obligations involved.
We helieve that S. 1306 will enable National and
Slale-uieiuhrY hanks lo make a substantial crml.iifoui.Ion
fAward assisting State and local governments. Our past
efforts have permitted National hanks to perform in
some degree their functions in this area of puhlic
finance, TTowever, hoth National hanks and Statemember banks need S. 1306 to achieve the full participation in this market, and thereby allow the public
to obtain the full benefit of such participation. We
strongly endorse S. 1306.
TESTIMONY BY DKAN MTTJ/RR, DEPUTY COMPTROLLER
OF THE CURRENCY FOR TRUSTS, BEFORE THE SENATE BANKING AND CURRENCY COMMITTEE, W A S H INGTON, D.C., NOVEMBER 16,

1967

Mr. Chairman and Members uf the Committee: We
are pleased to have been invited to appear here today
to present the views of the Comptroller of the Currency
on the amendments proposed by Senator Mclntrye to
S. 1659.
Briefly stated, the amendments would make clear
that die Banking Act of 1933 does not preclude the
operation by banks of collective investment funds for
monies held by them in fiduciary capacities in their
trust departments. It would also clarify the question
of the application of the federal securities laws to these
funds. The Comptroller of the Currency believes
that these ends are desirable and can be effected consistently with the maintenance of the solvency and
liquidity of the banks.
The pooling by banks of small fiduciary accounts
into more economically manageable units, however one
chooses to label it, is nothing more than the combination of two financial services which banks have made
available to their customers for many year*. These are
the management of investment portfolios, and the

operation of commingled funds for the more economical investment of monies held as fiduciary. We have
supervised these activities for years and believe that
the record shows that no abusive practices have developed. We are confident that the extension of these
services to cover additional types of accounts, including self-employed pension accounts, can be done
without danger of abuse developing. In any event,
the proposed amendments provide ample safeguards
against the possibility of abuse.
The proposed amendments to S. 1659 would subject
the proposed extensions of bank activities to the full
protection afforded the public by the securities laws.
Further, the amendments do not lessen the responsibility of the bank supervisors in this area. For example,
if S. 1659 were amended as proposed, we would continue to maintain regulations governing bank operation
of collective funds and would continue to require,
among other things, that our prior approval be obtained before a National bank may establish a managing agency fund. We believe that, by enabling banks
to make their vast investment expertise more available
to their customers, the amendments would accomplish
a highly desirable end.

The amendments would also subject the operation
by banks of pooled pension and profit sharing trusts,
established by self-employed persons to the securities
laws, subject to the regulation of the banking agencies.
They would clear up the legal questions which have
interfered with bank implementation of the selfemployed retirement plans which Congress sought to
promote in H.R. 10. These trusts are little different
from those which banks have been administering and
pooling for their corporate customers, under our supervision, for many years. Because of the intensive scrutiny
of these operations which is presently being carried out
by the banking agencies, it is logical to place the administration of the securities laws applicable to such funds
with these supervisory bodies. In addition, it follows
the precedent and format set by the Securities Act
Amendments of 1964 with respect to bank securities.
We are confident that our agency can assume the responsibilities which the amendments would add, and
believe that, here too, they will serve a most desirable
end.
For the foregoing reasons we favor adoption of the
amendments offered by Senator Mclntyre.

237

APPENDIX D

Selected Correspondence
of
the Office of
Comptroller of the Currency

Selected Correspondence of the Office of the Comptroller of
the Currency
Subject

Agricultural Credit Corporation—Acquisition
Bank Mergers
Bank Service Corporation
Charter Actions
Check Guaranty Plans
Deposit Machines
Electronic Data Processing Services
Examination Reports
Guidelines for Advertising
Industrial Development Authority
Interlocking Directorates
Investment Securities
Real Estate Loans
Securities Loans
Travel Services
Truth-in-Lending
Underwriting Revenue Bonds
Voting of Bank Stock

240

Page

241
241
242
243
244
244
245
245
246
247
247
248
250
250
251
252
253
254

AGRICULTURAL CREDIT CORPORATION—ACQUISITION
DECEMBER 21,

1966.

Your letter of October 10, 1966, to our Regional
Administrator has been forwarded to lliis Office for
reply. You ask whether a National bank may acquire,
for $343,000, all of the stock of an agricultural credit
corporation from the parent corporation. You note
that you are the president of the agricultural credit
corporation, the foregoing National bank, and the
parent corporation, of which the agricultural credit
corporation is a subsidiary.
This Office understands that agricultural credit corporations arc examined on a regular basis by the Faroi
Credit Administration, an agency of the United States.
We further understand that the various laws under
which agricultural credit corporations operate limit
both the term and the amount of credit that may be
extended to any one borrower, as well as the amount
that may be extended to all borrowers in aggregate.
You stated in a conversation with a member of the
Law Department that, during its last examination, the
agricultural credit corporation had no assets classified
and that, at this time, the corporation is in a highly
liquid condition.
As provided in paragraph 7376 of the Comptroller's
Manual for National Banks, a National bank may engage in activities which are a part of the business of
banking or incidental thereto through a department
of the bank or through a subsidiary corporation, the
controlling stock of which is owned by the bank.
Clearly, the business of an agricultural credit corporation is part of the business of banking. Your bank,
therefore, may acquire the stock of a corporation engaged in such business.
Although the third paragraph of 12 U.S.C. 371c
exempts from the limitations of that section investment
in or extension of credit to a bank subsidiary engaged
solely in the business of an agricultural credit corporation, it is the policy of this Office to require National
banks to obtain our approval of such investments or
extensions of credit that exceed 10 percent of the parent bank's capital and surplus. Under the circumstances described above in the second paragraph, this
Office has no objection to an investment by the
National bank in the agricultural corporation of an

amount not to exceed the book value of such corporation (not more than $367,500), which is an amount
equivalent to approximately one-third of the bank's
capital and surplus. See paragraph 1100 of the Comptroller's Manual for National Banks).
Your attention is also directed to paragraph 7380 (b)
of the Comptroller's Manual for National Banks,
which provides that origination of loans by a National
bank's subsidiary at locations other than the main office
or a branch office of the bank does not violate 12
U.S.C. 36 and 81, provided that the loans are approved
and made at that main office or branch office, or at
an office of the subsidiary located on the premises of
or contiguous to that main office or branch office.
At the present time, Wyoming does not permit branch
banking. Accordingly, if the subsidiary is to approve
and, therefore, make loans, the office of the subsidiary
at which such loans will be approved must be located
on the premises of, or contiguous to, the main office
of the National bank.

BANK MERGERS
JANUARY 23,
Hon.

1967.

JOHN TOWER,

Committee on Banking and Currency,
United States Senate, Washington, D.C.:
I thank you for your courtesy and consideration at
my rx/rrftrrnatirm hearing on January 18, 1967. During
the healing, you submitted two written questions and
requested my written response thereto. Your first question was as follows:
It is my understanding that you have expressed a policy of
following at least to some extent the program of your predecessor.
I noted two interviews, one with you and one with Mr.
Saxon which appeared in Banking Magazine recently.
In the December issue, Mr. Saxon said, speaking of the
need for additional bank mergers:
"There is a crying need for larger aggregates of banking
resources and bigger pools of capital- Tn Florida today there
is no bank hig enough to meet a mere fraction of the State's
banking needs. Houston is another case in point; it hasn't
a single billion-dollar bank. The biggest bank they have
there is totally inadequate and must draw capital from

241

Chicago and other distant centers. Dallas, too, lacks a bank of
adequate size. We need more larger banks."
In the January issue of Banking Magazine, you seemed to
agree with Mr. Saxon's statement when you said:
"Some metropolitan areas need bigger banks in order to
attract and retain valuable business which is presently going
to other financial centers."
Gould you elaborate somewhat on your thinking and perhaps Mr. Saxon's thinking on the Houston and Dallas situations?

Major metropolitan areas require banks which are
capable of satisfying the financial requirements of
local residents and businesses. An ideal structure would
allow all such requirements to be satisfied locally. The
degree to which local banking needs can be met by
local banks varies substantially from area to area. Some
cities, however, have no bank which has the capital
and deposit structure necessary to meet most or all of
the credit needs of every class of bank customer within
their trade areas. Many of these banks are further
handicapped because they cannot afford to hire trained
and experienced personnel to service specialized customer requirements. Consequently, much valuable
banking business which originates in these localities
goes to other cities, often hundreds of miles away.
Assessing the reasons why certain metropolitan areas
have not produced larger banks is an exercise which
usually results in heated discussion of the merits of
branch, group, and chain banking. Whatever the reasons, however, it is undoubtedly true thai some localities have an urgent need for some Increase in concentration of banking resources.
Whether or not there is a need for increased banking concentration in a particular area and whether
or not a proposed bank merger will respond to such
need are inquiries not easily answered. Because each
merger application presents unique questions, every
decision to appruve ur disapprove requires careful investigation and deliberation and, not infrequently,
some prognostication.
I believe I should not attempt to speak for Mr.
Saxon or to explain or interpret to you his thinking
with regard to the Houston and Dallas areas. Also,
dnce I may be required lu decide fuUue merger winch
may come from ihese areas, T do not. think it would
be apiMnfrriatft for vnr-. to prr.judgr. any application by
speculating as to the condition of any given market.
Your second question was as follows:
In December, mention was made in a periodical issued by
an important element of thefinancialindustry that the FDIG
has continued to refuse the Government Accounting Office
access to Federal Deposit Insurance Corporation bank examination reports, whereas the Federal Savings and Loan
'iiamoM.cc Corporation has given full cooperation to the
242

GAO in connection with the files of the Home Loan Bank
Board.
I read the explanation given by Joe Barr of the FDIG
position, but I thought perhaps you might give us your
thinking about the issue as a new member of the FDIG
board.
The FDIG does not give the GAO access to reports
of examination of open banks because the FDIG believes that preserving the basic concept of absolute confidentiality of such reports is essential to proper bank
supervision and to the functioning of deposit insurance
in the public interest. The FDIC's position is based on
its total experience, its understanding of the intent of
Congress and the special nature of bank examination
and supervisory proceedings. Only recently, a judicial
decision upheld this basic concept, stressing the latter
point.
The GAO, on the other hand, believes that it should
have access to all FDIC records, including open bank
examination reports, because the financial condition of
the FDTG is inseparably linked with the banks it insures.
Apparently, this viewpoint also extends to independent
verification of examiner findings through separate bank
examination.
We can appreciate the desire of the GAO to carry
out its mandate to audit the financial transactions of
the FDIC. We concur, however, in the FDIG's position.
The FDIC, in performing its functions, acquires a
very large body of data, about banks and bank management This information traditionally has been furnished
freely by bankers on the understanding that it would
not be made available to anyone other than those
agencies directly concerned with hank supervision. By
its very nature, much of this information could not be
obtained on other than a confidentia.1 basis, for it is
necessarily a mixture of fart, judgment., and personal
opinion. Tf the Federal and State supervisors of banks
had not clearly treated most of this material in strict
confidence through the years, the sources of essential
information would be denied them and effective hank
supervision would be severely inhibited. Tn that context, a public interest and public confidence issue of
same magm+Fidft is at staler., rathftr than the sanctity of
ihe FDICSs recuixls during an audit, limitfid hy statutory
language lo records pertaining lo financial transacticrrmi.
BANK SERVICE CORPORATION
OCTOBER 30,

1967.

This is in reply to your letter of October 6, 1967,
which relates to the proposed bank service corporation in which a National Hank plans in invest Yon

specifically inquire whether a bank presently owning
automated data processing equipment could lease such
equipment to the service corporation and yet continue
to service its own customers on the equipment. You
state, in a subsequent telephone conversation with a
member of our Law Department, that the proposed
lessor hank will purchase an interest in the service
corporation.
Under 12 U.S.C. 1864, a bank service corporation
is restricted to "the performance of bank services for
banks." Comptrollers Manual, paragraph 7390, interprets that phrase as including the direct performance by
the service corporation for a shareholder bank's customers of services which the shareholder bank has
agreed to perform for its customer. Accordingly, if a
bank undertakes to handle the payroll accounts or the
accounts receivable of a customer, a bank service, corporation may perform for the bank the service necessary to enable the bank to fulfill its undertaking. It
should be noted, however, that the basic proposition
that a bank may perform data processing services for
hire is under attack in two cases filed in Federal District
Courts in Minnesota and Rhode Island.
You further state that the proposed corporation
would act as agent for the participating banks in the
processing and servicing of participation loans. This
Office concurs with your opinion that the role of agent
for the purpose of processing and servicing participation loans is a proper function for a bank service
corporation.
Your third question relates to a proposed increase
in the capitalization in the bank service corporation.
This Office has no objection to such an increase other
than to point out that 12 U.S.C. 1862 (a) limits the
investment of any one bank in a bank service corporation to an amount not greater than 10 percent of the
bank's capital and surplus.
CHARTER ACTIONS
NOVEMBER 15,
Hon.

1967.

WRIGHT PATMAN,

Committee on Banking and Currency,
House ofRe present atives3 Washington, D.C.:
This is in reference to your letter of October 18,1967,
referring Lo lh« present general policy of this Office with
respect to the chartering of new National banks, and to
a particular application for a new bank m Atlanta, G&,,
wliit.ii has been disapproved. The applicants in the
Atlanta case have as&ed tiiat wr. reconsider thai decision and we are in the process of doing so.

With respect to our general policy on chartering, I
must respectfully disagree with your conclusion that it
has been unduly tight since I assumed office. In the
first nine months of this year, 17 new National banks
were chartered. This is not out of line with the figures
for previous years going back to 1952, with the exception of the years 1962, 1963 and 1964, when there was
a substantial increase in the number of State and National banks chartered. As you know, Mr. Saxon was
of the view that the chartering policy of the Office in
previous years had been unduly restrictive, and that
there were numerous areas of the country which were
then underbanked. As you cite in your letter, Mr. Saxon
implemented that belief by approving a comparatively
large number of applications during the first years of
his term. He recognized, however, that a period of
digestion was necessary in order to give the new institutions time to grow and, in 1966, granted only 24
new charters.
As I have testified before your committee, we
evaluate each application strictly on the banking,
economic, and other related facts which are applicable
to the particular service area in question. Since the
Atlanta application is being reconsidered, I do not
think it would be appropriate for me to go into detail
as to the reasons which led to the initial rejection of it.
It is a matter of public knowledge, however, that Atlanta constitutes one of the most competitive banking
markets in the country. In this connection, banks such
as The Citizens and Southern, The First National
Bank of Atlanta and the Trust Company of Georgia
compete very vigorously with each other.
With respect to your statement that our policies
raise "serious questions of law" as well as of policy,
our attorneys advise that the decisional law under our
enabling statutes definitely establishes a discretion in
this Office to disapprove, as well as to approve, charter
applications. These decisions establish that there is
no "right" to a bank charter in the sense that any
reputable group with the necessary capital is entitled
to receive one merely by filing an application.
We recognize that the exercise of this discretion often
involves very close and difficult decisions, especially
where competing applications are received for the
same area. It is not at all uncommon for competing applicants to be of equally good repute and financial
capability. We can only exercise our best, judgment in
each case in light of the existing competitive needs of
the comrrmnity and the other factors set forth in Section 6 of the FDI Act.
243

CHECK GUARANTY PLANS
JUNE 28,1967.
This is in reply to your letter of June 2, 1967, in
which you raise certain questions in connection with
the proposed issuance of check guaranty cards to certain credit-worthy customers of a National bank. Under the terms of the check guaranty plan, issued in
conjunction with a prearranged credit plan by Which
the hank would agree to honor a customer's overdrafts
to a maximum of $5,00(1, the hank would guarantee
payment of checki drawn by a cardholder in amounts
up to $100 provided certain procedural conditions are
complied with. Your questions are as follows:
(1) Whether the ruling in paragraph 7015 of the Gamp~
trolles's Manual for National Banks was based on s check
guaranty plan, wherein the banVs liability was limited or,
as in the. case in the plan proposed by the subject bank, its
potential liability was virtually unlimited?
(2) In assuming that cardholders would draw guaranty
checks in excess of their maximum prearranged credit linft,
would the bank be in violation of 12 U.S.G. 501 and, tharfifore, subject to the penalties imposed by 18 U.S.C. 1004?
As stated in paragraph 7015 of the Comptroller's
Manual, an arrangement whereby a bank holds out
to the public that it will honor checks drawn on it up
to a certain amount, by a depositor displaying a "check
guaranty card," is. in essence, an agreement by the
bank with its depositor to extend credit to the depositor, if necessary, to honor his checks. Such an arrangement is essentially a commitment to lend and is
within the power of a National bank. In issuing the
ruling set forth in Paragraph 7015, this Office recognized that a bank's potential liability under a check
guaranty plan could be virtually unlimited. Indeed,
under a check guaranty plan of the nature you propose, which is similar to other plans now operating,
tliis Office cannot be certain that a bank's liability
would be limited. The nay^e of a guaranty ch?ck would
be unaware erf the reirdhrridftr having readied his
maximum overdraft limit and might accept, theoretically, a check drawn in excess of that limit resulting,

banking and not of corporate authority. In other words,
the bank is best protecting its unlimited liability potential by initially placing the card only with these
credit-worthy customers who may not have the propensity to exceed their credit line.
In answer to question two, since a cheek guaranty
plan is an arrangement by the bank with its depo&itoi
to lend its credit, if necessary, to honor his checks
drawn and cashed by a merchant in accordance wkli
established procedures, the practice does not involve
a certification by the bank that the depositor has on
deposit an amount of money not less than the «miuuirt
specified, in stsch check. The plan does not piesuppuse
that a drawer will have sufficient funds on deposit
to cover the check. The hank, if necessary, will lend
its credit to the depositor, which is the essence of
"guaranty" the plan is designed to provide. The provisions of 12 U.S.C 501 and 18 U.S.C 1004 are,
therefore, not applicable.
It is the opinion of the Comptroller's Office that a
National bank has sufficient interest in facilitating the
cashing of checks by its depositors so that it may, under
its corporate powers as enumerated in paragraph
Seventh of 12 UJS.C 24, guarantee checks drawn upon
it and cashed by a merchant in accordance with established procedures. See The National Banking Review, June 1965, pp. 576-577. There is, therefore, no
objection to the adoption of such a plan as outlined in
your letter of June 2,1967.

DEPOSIT MACHINES
FEBRUARY 15,

1967.

This is in reference to your letter of January 4,1967,
our acknowledgement of January 13, 1967, and previous correspondence with our Regional Office. You state
that you are concerned with the ruling, stated in paragraph 7491 of Ihf Cimipbolhr's Mantuil fin National
Banks, which permits National banks to utilize at any
location a machine that receives checks, currency, or
#

n<=>^7(artVif>lf>cs i n fhp> Kanlr'c Vifi-nrr rJhliorated tr\ n a v th*»

__:_

item. As you expressed in your letter, a depositor may
exceed his credit line and cause the bank to become
obligated to pay to third parties more than the bank
would consider it prudent to lend to that customer.
The overdraft risk would, however, come to the bank's
attention immediately, allowing it to minimize losses
and reduce its unlimited liability. According, it should
be noted that the manner in which potential credit
risks of this nature are evaluated, and the means which
are used to minimise, them are questions of prudent

the use of these automatic machines by a National
bank and ask if their use does not raise questions of
unauthorized branch banking and competitive unfairness to smaller banks.
Sections 36(f) of Title 12, United States Code, defines the term "branch" as follows:
"(f). The term 'branch' as used in this section shall
be held to include any branch bank, branch office, branch
agency, additional office, or any branch place uf business
located in any State or Territory of the United States or in

244

'±. c

•f-.n

»i-

the District of Columbia at which deposits are received, or
checks, paid, or money lent."

It has been and still is the position of this Office that
the deposit machine does not violate, or come within
the scope of, applicable branching laws inasmuch as
the bank does not accept funds for deposit until they
have reached the bank's premises. The machine issues
a slip which provides evidence of the transaction and
states expressly that the transaction will become a
deposit upon verification and crediting at the bank.
Accordingly, the transaction at the site of the machine
does not fall within the purview of 12 U.S.C. 36 (f).
An agency relationship is created between the customer
and the person transporting the funds to the bank. This
position is analogous to our ruling in paragraph 7490
of the Comptroller's Manual for National Banks which
states that a National bank, to meet the requirements
of its customers, may furnish armored car messenger
service if there is an agreement that the messenger is
the agent of the customer rather than of the bank. It
is our opinion that whether a messenger collects money
and checks on foot, in an armored car, or by means of
a deposit machine, the nature of services being performed is essentially the same. The important factor
is that the messenger is expressly understood to be an
agent for the customer, not for the bank.
I am sure you would agree that this Office cannot
prohibit new developments in banking simply because
the possibility exists that some institutions would be
put at a competitive disadvantage. In keeping with
our supervisory authority, a proposal cannot be viewed
solely in terms of its cost. We must consider primarily
its conformity to law and its effect upon the financial
condition and soundness of the banks.
The National bank, in utilizing deposit machines at
locations off the bank's premises, acted in conformity
to paragraph 7491 of the Comptroller's Manual. This
action, in our view, is not in violation of Federal law
or at variance with sound banking practices.
We trust that this is fully responsive to your inquiries.

which commercial banks and savings and loan associations give to the data processing industry.
A National bank may own and operate data processing equipment as is necessary or convenient for it to
carry on its business. If the bank is to achieve full utilization of its investment in or cost for such equipment,
it should be permitted to make the equipment available for the use of others when not engaged for the
bank's own work. Accordingly, it is our position that a
National bank which owns or otherwise holds data
processing equipment for its own present or future
needs may, for compensation, make such equipment
available to others at times when the equipment is not
in use for the bank.
Our conclusion is supported by the analogous right
of a National bank to own or lease a building for banking purposes, even though it occupies only a part
thereof and rents out the remainder to achieve maximum return on its investment.
Those who would bar banks from providing data
processing services would attempt to separate out certain customer services as "nonbanking functions" and
call them impermissible. The error of this approach
is that data processing services are essentially new developments, not only for banks but for nonbanking
companies as well. The issue is not one of banks straying into unrelated fields. It is rather one of the changing face of the banking function.
Electronic data processing machines are making it
possible for banks and other companies to offer on a
mass marketing basis services previously available to
only a few. In the tradition of the free competitive system, those companies, be they banks or nonbanks,
which are best able to offer these services at the lowest
price to their customers will prevail. At this comparatively early stage of the competitive race, we do not
think some of the contestants should be permitted to
impose handicaps on or disqualify altogether an
important contender.

EXAMINATION REPORTS
ELECTRONIC DATA PROCESSING SERVICES
DECEMBER 14,1967.
FEBRUARY 1,
Hon.

1967.

DANTE B. FASCELL,

Legal and Monetary Affairs Subcommittee of the
Committee on Government Operations,
House of Representatives,
Washington, D.C.:
Thank you for your letter of January 9, 1967, requesting the views and comments r/f this Office with
rrspr.rt to a lrttrr r/f rr/mjd*mt agairrst the. competition

HON. K . A . R A N D A L L ,

Federal Deposit Insurance Corporation,
Washington, B.C.:
This is in reference to your letter of November 15,
1967, containing the latest proposal by the General
Accounting Office on the. matter of its access to examlnfk+iVdn reports and iciaieJ Jala. uxi upeii insured banks.
In view of the lac I thai the GAO request covers Na245

tional as well as State banks, you have asked for our
comments before preparing the reply of the Corporation to the GAO proposal.
The proposal is to give GAO unrHslriuted access to
the examination reports and related data, but with
the use of a code identification system, so that each
bank would be identified by code number instead of
by name.
We understand that the matter of GAO access to
examination results has been a pom I of disagreement
between F.D.I.G. and GAO for some time. The positions of the two agencies are set forth in the Report
of Audit of F.D.I.G. for the fiscal year ended
June 30, 1965.
The position of GAO as set forth in the 1965 Report is that they consider it a part of their audit function to "evaluate the contingent adverse effect upon
the financial condition of the Corporation of specific
situations which may have been identified at insured
banks," and also "to evaluate the effectiveness of bank
examinations performed and the degree of reliability
that can be placed upon such examinations to disclose
problems at insured banks." GAO concludes that they
have been "unable to fully discharge (their) audit
responsibility," because the F.D.I.C. has not given
them access to examination reports, files and other
records regarding open banks.
The F.D.I.C, on the other hand, takes the position:
(1) That the information obtained from banks by
examiners is received in confidence and with the express understanding that it will not be made available
to persons other than those charged with responsibility
for bank supervision; that the whole examiner-banker
relationship is based on this confidentiality and would
be seriously impaired, if not destroyed by the GAO proposal; (2) that the Congress has never evidenced any
intention to permit GAO access to bank examinations;
and, (3) that, in any event, the GAO does not have
responsibility for either assessing the sufficiency of the
F.D.I.C. fund or reviewing the performance of bank
examiners. The F.D.I.C. cites in support of its position, 12 U.S.C. 1827 which states that "The financial
transactions of the Corporation shall be audited by the
General Accounting Office, etc." (Italic supplied)
It is my understanding that, while this Office has
not been asked before to express a view on this matter, previous Comptrollers of the Currency, in their
capacities as directors of F.D.I.C, have always been
in agreement with the F.D.I.C. position. Since you
have appaxeiitly addiessed your inquiry to me in my
capacity as Comptroller, I asked our own Law Department to look into the matter and advise me.
246

The advice given to me by our Chief Counsel, supports the F.D.T.C. position in all respects. Tn addition,
he advises that insofar as examination reports prepared
by employees of this Office are concerned, that there
are additional legal considerations which prevent
access by GAO.
The Congress by permitting Reorganization Plan
No. 26, section 1, to become effective on July 31, 1950,
15 F.R. 4935, 64 Stat 1280, specifically excepted the
bank examination functions and records of thr. Comptroller of the Currency from the centralization of authority intended by the series of Reorganization plans,
effected in 1950. At no time, before or after 1950, has
this Office been subject to audit by the Comptroller
General.
Aside from legal considerations, we do not see how
any useful purpose would be served by GAO review of
open bank examination reports. Since the GAO has no
expertise in the field of bank supervision, we do not sec
how access to the reports would enable them to judge
either the adequacy of the insurance fund or the adequacy of any bank examiner. For the above cited reasons, we would not favor any abrogation of the present
arrangements between the Corporation and the GAO.

GUIDELINES FOR ADVERTISING
OCTOBER 9,

1967.

We are in receipt of an advertisement recently
placed by your bank in a newspaper publicizing your
"5 percent passbook savings account." The advertisement fails to meet the standards enumerated in the
Comptroller's letter of December 16, 1966, to all National bank presidents, and it misstates some of the
provisions of Federal Reserve Regulation Q. For your
convenience, a copy of both the advertisement and the
letter is attached.
The advertisement violates standards (1), (3) and
(4). It does not state whether the 5 percent rate is
simple or compounded; it does not clearly and affirmatively state that the deposit must be held 90 days in
order to earn 5 percent interest; and, it erroneously
states that the account, rather than the depositor, is
insured by the F.D.I.C. up to $15,000.
The first paragraph of the section captioned "Your
money is readily available" is erroneous. First, interest
rates on time and savings accounts are governed by the
Federal Reserve Board rather than the F.T.D.C. Second, Regulation Q does not normally "require 90 days
written notice before you withdraw your money."
Only time deposits earning 5 percent or 5^4 percent

interest must be held 90 days, and payment may be
made either 90 days after deposit or 90 days after
written nnl.ir.ft. Third, payment may be made before
maturity only to prevent a hardship under the circumsta.nr.fiR described iii Section 2l7.4(d) of Regulation Q.
This is a very limited situation and does not make a
depositors money "readily available."
We note that a letter was sent to you on April 13,
19G7, to the efleet that your advertisement concerning
your 30-day savings certificates was in violation of
Regulation Q. On September 5, 1967, our Regional
Gmmsel noli lied you that your billboard advertisement
concerning your 5 percent passbook savings was in
violation of standards (1) and (3) of our advertising
guidelines.
We will expect your compliance with the letter and
spirit of the advertising guidelines of this Office, as
well as accuracy in your explanation of any provisions
of Regulation Q mentioned in your advertisements.

INDUSTRIAL DEVELOPMENT AUTHORITY
FEBRUARY 7,

1967.

This refers to your letter of December 0, 1966, requesting the views of this Office with respect to paragraph 1181 in the Comptroller's Manual for National
Banks, relating to loans to an industrial development
authority. Since you recently advised this Office that
the proposed loan which impelled your request has not
developed, we will limit our comments to a short discussion of that paragraph.
Paragraph 1181 sets forth certain conditions which
must be complied with in order for a loan or other
extension of credit to an industrial development authority or similar public entity not to be deemed an
obligation of the authority under 12 U.S.G 84. The
borrowing authority or similar public entity must have
been created for the purpose of constructing and leasing a plant facility to an industrial occupant. In addition, the bank must rely on the credit of the industrial
occupant; the authority's liability with respect to the
loan must be limited solely to whatever interest it has
in the particular facility; the authority's interest must
be assigned to the bank as security for the loan; and
the industrial occupant's lease rentals must be assigned
and paid directly to the bank.
ThprP: Via? bppn a trpnd in recent years toward the
de.velopment of local industrial facilities through the
use of local development entities. These entities have3
for the most part, been created as political subdivisions
of States or municipalities. The increasing sums re-

quired by those entities in order to develop industrial
sites were available, to a great extent, only from commercial banks. In recognizing that the sums advanced
to such en lilies were actually for the benefit of the industrial occupants, this Office prnrmilga.tftd paragraph
1181 in order to ensure that upon compliance with
stated conditions, such loans would not be deemed obligations of such entities under 12 U.S.G. 84. Basic to
this paragraph is the requirement that the entity or
authority be a public entity, a political subdivision of
the State or municipality. It does not appear that a
nonprofit insiit.irt.icrn organized under a State membership corporation law would qualify as an industrial
development authority for the purpose of paragraph
1181.
However, your bank may wish to give consideration
to paragraph 1175 in the Comptroller's Manual for
possible application to the foregoing situation. That
paragraph provides that where the obligation of a customer to repay a loan is limited to the proceeds of a
contract or to an asset transferred as security, therefore, and his obligation with respect to the collateral
is limited to a warranty of validity, as of the date of
its transfer, neither the described obligations of the
customer nor the collateral represent obligations of die
customer subject to the lending limit under 12 U.S.G.
84. As a matter of prudent judgment, a bank should
take appropriate action to assure that there will no I
be an undue concentration of underlying collateral
substantially dependent upon a limited area of economic activity. This ruling, in effect, provides that the
liability of the borrower shall be in rem, so that the
recourse, collection and effect of the debt under the.
obligation shall be restricted and limited to and be had
only against the real estate described in the accompanying mortgage.
INTERLOCKING DIRECTORATES
JUNE 30,

1967.

Hon. EMANUEL CELLER,

Committee on the Judiciary,
House of Representatives,
Washington, D.C. :
Thank you for your letter of February 10, 1967,
requesting the views of the Comptroller of the Currency relative to the proposed legislation H.R. 2509,
which proposes to amend Section 8 of the Clayton Act
to prohibit certain management interlocking relationships, and for other purposes. The effect of this proposed amendment would be the substitution, in its entirety, for the present language of Section 8.

247

The bill, in substance, prevents interlocking relationships, unless approved by the Attorney General, where
a person who is a director, officer, or employee with
management functions, holds, at the same time, the
position of director, officer, or employee with management functions in any other entity which is an actual
or potential competitor, customer, supplier, source of
credit or capital, or whose principal business is the
holding of stock in, or control of, any entity in commerce. Said provisions of the bill apply to entities engaged in commerce having capital, surplus, and undivided profits aggregating more than $1 million. The
provisions do not apply when one of the entities owns
more than 50 percent of the voting stock of the other
or others, or where 50 percent or more of the voting
stock of each of the entities is directly or indirectly
owned by the same entity.
Banks of all sizes throughout the country have
boards of directors composed of business leaders with
expertise in various fields of endeavor. These persons
give specialized and technical knowledge that otherwise would not be available to the banks. In order to
cope with the intricacies of business today, it is necessary to have the best advice available. To eliminate
from the boards of directors such qualified persons
would place banking under a serious handicap. The
banks would have to undergo a complete reshuffling of
their directorates and be compelled to draw from
within for their directors. Such action would force the
banks to forgo the invaluable contributions of the
businessmen who are so knowledgeable in their respective fields. We feel that this loss to the banking
Industry would far exceed any good that could be derived from this bill.
The proposed bill would have the effect of preventing lawfully constituted holding companies, with 50
percent or less stock interest in a bank, from having
representation on the board of directors of such affiliate
in which it has control or a substantial investment. The
prohibitions would thwart the very purpose for the
existence of bank holding companies by fettering their
ability to place loans among their affiliates.
Additionally, it would prevent a person engaged in
doing business with a bank from serving on a bank's
board, even if such person had supplied capital or invested in a particular bank. Such provisions would
severely handicap banks in obtaining the capital and
deposits they need to grow and to serve the community.
Substantial depositors would not be interested in investing money in an organization where they were precluded from having representation and no opportunity
248

to voice an opinion in the bank's operations, which
vitally concern their investments.
While presently there may be opportunities for
abuses and self-dealing in corpora lions having interlocking directorates, we have not seen significant
evidence of abuses by directors with ties in both business and banking. We regard the present statutory
regulation of banking as sufficient to prevent the type
of abuse which H.R. 2509 is designed to prevent. The
banking industry is under constant scrutiny because
of its multiple examinations conducted by the various
governmental agencies. These examinations prevent,
deter and, if necessary, ferret out any and all of the
abuses at which the bill is aimed.
One of the most notable features of Section 8 of the
Clayton Act, as presently written, is the fact that it has
been amended five times since its passage in 1914.
Each of these amendments was based upon a recognition that the more sweeping general rule of Section 8
could not practicably be applied in toto to the banking
industry. As a result, the amendments carved out
significant exceptions which today comprise the greater
part of the Section. The rationale advanced in the
preceding paragraphs, therefore, has been proven
historically valid. If Congress were now to repeal
Section 8 and substitute the broad proposal contained
in H.R. 2509, it later would be faced, as have five
Congresses since 1914, with the necessity for amending
the new Act in order to permit the banking industry
to perform its essential role in our economy.
It is, therefore, our sincere belief that applying
the operative provisions of H.R. 2509 to banks would
not be in the public interest. Its provisions would deprive the Nation's banking system of invaluable advice
and experience; its passage would make it extremely
difficult to banks to progress and keep pace with our
growing economy; and, its exclusionary provisions
could cause substantial and harmful turmoil in an
industry in which stability is essential. Accordingly,
this Office would be strongly opposed to applying the
provisions of the proposed legislation to the commercial banking industry.

INVESTMENT SECURITIES
AUGUST 31,1967.
Hon.

WILLIAM PROXMIRE,

Subcommittee on Financial Institutions,
United States Senate, Washington, D.C.
This letter is in reference to the testimony of our
Office, before the Subcommittee on Financial Institu-

tions of the Senate Committee on Banking and Currency, with respect to S. 1306 (90th Cong., 1st sess.).
Upon reflection, it has occurred to us that perhaps
some of our testimony may need clarification. We refer
to the colloquy relating to the procedures by which this
Office dctcrminr.s that National banks invest in or
underwrite and deal in securities of good quality.
At the outset, it should be clearly understood that
our Office does not, on its own initiative, rule on the
eligibility of every security issue in which National
banks may ho interested. The number of security issues
each year would make this a burdensome task. Clearly,
our present staff could not undertake this responsibility
and we now see no need to hire additional personnel
to do so.
This does not mean, however, that National banks
may freely invest in or underwrite and deal in security
issues as they will. Our Office has three methods to
supervise this activity.
The first method is the imposition by our Office of
a quality standard. Our Regulation 1 (12 CFR 1) establishes this standard pursuant to our authority to
further define the term "investment security." We
believe that this standard also applies to general obligations of States and political subdivisions thereof. In
our view, such obligations are not a class of security
separate and distinct from investment securities, as
defined in 12 U.S.C. 24(7). We consider State and
local obligations tr> hp. a type of investment security, as
to which, however, the limitations regarding underwriting and dealing are inapplicable.
Our quality standard is reflected in Regulation
1.3(e) and 1.5 (a) and (b). It is there provided, in
pertinent part, as follows:
(e) The phrase "general obligation of any State or of any
political subdivision thereof" means an obligation supported
by the full faith and credit of the obligor. It includes an obligation payable from a special fund when the full faith and
credit of a State or any political subdivision thereof is obligated
for payments into the fund of amounts which will be sufficient
to provide for all required payments in connection with the
obligation. It implies an obligor possessing resources sufficient
to justify faith and credit.
(a) . . . A bank may purchase an investment security for
its own account when in its prudent banking judgment (which
may be based in part upon estimates which it believes to be
reliable), it determines that there is adequate evidence that
the obligor will be able to perform all that it undertakes to
perform in connection with the security, including all debt
service requirements, and that the security may be sold with
reasonable promptness at a price which corresponds reasonably
to its fair value.
(b) . . . A bank may, subject to limitations sftt forth in

§ 1.6 (b), purchase an investment security for its own account
although its judgment with respect to the obligor's ability to
perform is based predominantly upon estimates which it
believes to be reliable. Although the appraisal of the prospects
of any obligor will usually be based in part upon estimates, it
is the purpose of this paragraph to permit a bank lo exercise
a. somewhat broader range of judgment with respect to a more
restricted portion of its investment portfolio. It is expected that
this authority may be exercised not only in the absence of a
record of performance but also when there are prospects for
improved performance. It is also expected that an investment
security purchased pursuant to this paragraph may by the
catahlishrriMvt nf a satisfactory financial reevrd become eligible
for purchase under paragraph (a) of this section.
Thus, each National bank, in the exercise of prudent
banking judgment, must apply this quality standard
before purchase of any investment or public security.
The second method is the prior ruling procedure of
our Office. As provided in Regulation 1.5 (a) and 1.9,
a National bank may request a ruling of this Office of
its own volition. Although National banks are not
obliged to obtain our prior clearance, they frequently
do so.
The third and most important method is our examination process. The instructions of our Office to
our examiners and to all National banks, as set forth in
the Comptroller's Policy Guidelines For National Bank
Directors, provide, in pertinent part, as follows:
Careful credit analysis is as essential in making sound investments as it is in granting sound loans. The responsibility
for prudent maiiagfiiiiKiit uf v bank's investment account cannot be delegated to a correspondent, brokerage house, or
rating service.
Paragraph 1.8 of the Investment Securities Regulation Section of the Comptroller's Manual for National Banks requires
every bank to maintain complete credit information for all
investment securities. Public securities, except United States
Government and Federal Agency Obligations, are not exempt
from the above requirement. In determining the soundness
of a public security, the following information should be
obtained and analyzed:
1. Statement of total debt including all related obligations.
2. Assessed valuation, including basis of assessment.
3. Property tax rates.
4. Tax collection record.
5. Receipts and disbursements.
6. Sinking fund operation and requirement.
7. Future debt service requirement.
8. Population.
9. Economic background.
10. Default record.
11. Per capita debt.
Appropriate credit information should also be obtained for
investment securities as defined in Paragraph 1.3 (b) of the
Investment Securities Regulation.
In reviewing an investment account, the Examiner should
determine the quality, market value, and liquidity of the
249

account and whether the bank is complying with related
laws and regulations.
In addition to making a credit analysis of all securities
held for resale, the Examiner should carefully review the
bank's underwriting and trading activities fur any indication
of a possible conflict of interest with the bank's trust
activities.

Although our examination process is an after-thefact investigation, this is not a handicap in properly
supervising the quality of securities in the investment
and underwriting portfolios of National banks. Occasionally, a loss is sustained by a National bank which
fails to observe our quality standard. But we know of
no case in recent years where such a loss has been an
important consequence to the bank's solvency.
Finally, it should be said that we exercise the same
supervisory function over security portfolios of National banks as we do over the loan portfolios of such
banks. We do not have authority for prior approval or
disapproval of loans made by National banks. We
would not ask for such authority. Similarly, we would
not seek authority to approve or disapprove in advance
securities purchased by National banks for their investment or underwriting portfolios.

tained in the third paragraph of 12 U.S.G. 371 that
such loans have maturities not to exceed 24 months.
Although there is no specific restriction as to the period of time, over which such takeout commitments
may extend, they must be made for a definite or determinable date subsequent to completion of construction. A minimum rental or percentage occupancy requirement would make uncertain the date at which the
takeout commitment would become effective. Accordingly, a takeout commitment, subject to such conditions, would not constitute a valid and binding commitment with the meaning of 12 U.S.G. 371. It should
be noted, however, that in situations where the permanent lender agrees to advance a partial amount
upon completion of the building and conditions a further advance upon a minimum occupancy requirement,
only that part of the loan which is supported by a takeout commitment, subject to the occupancy requirement,
is classified as a real estate loan under 12 U.S.G. 371.

SECURITIES LOANS
OCTOBER 18,
Hon.

1967.

DANTE B. FASCELL,

Legal and Monetary Affairs Subcommittee of the
Committee on Government Operations,
House of Representatives,
APRIL 18,1967.
Washington, D.C.:
This is in reply to your letter of March 6, 1967, in
Thank you for your letter of September 28, 1967,
which you inquire whether a minimum rental or percalling the attention of this Office to an article in the
centage occupancy requirement, made as a condition
Wall Street Journal of the same date. The article reto a takeout commitment by a permanent lender, will
ports that certain lenders, which it describes as "unlender the commitment unsatisfactory under 12 U.S.G.
regulated lenders/' make loans to speculators for the
371. You note thai the Comptroller, as reported cm
purpose of permiuiiig them to purchase or carry regpage 215 of the December 1966 issue of The Notional
istered stocks without regard for the margin requireHanking Ticviaro, has ruled that a cormmrritrnerrt to adments of Regulation U of the Federal Reserve Board
vance the full amount of the loan at the end of 29
(12 CFR 221). It also states that some banks make
months, on condition that ilie building be at least 80
loans to the so-called unregulated lenders, knowing
percent occupied, did not constitute a valid and bindthat such lenders will itduan the nnjeeeds in circuming agreement, by a financially raxprwwiMe lender, to
vention of Regulation U.
advance the full amount of the bank's loan upon
Authority to issue. Regulation U is vested exclusively
the completion of the building, as is required by
in the Federal Reserve Board by the Securities Ex12 U.S.C. 371.
As is stated in paragraph 2400 (c) of the Comptrolchange Act of 1934, particularly section 7 therreof (15
ler's Manual for National Banks, if a National bank,
UJS.G. 78). Accordingly, this Office rloes not. haw. a
in extending 'intern m credit to finance llie constiuctinu policy position wilh regard lo the suhsi.arri.ivft proviof an industrial or Cjcrrnmerria] building, relies pxi- sions of such regulation. This Office does, however,
rnarily for repayment of the loan <w\ a commrfmenl. by have llit? limited ltsspoiis'ruilily lo ascertain if National
a financially responsible lender lo lake up ihf? loan
banks are complying willi the retirements of Reguupon completion of construction, llie loan is not a real
lation U, including section 221-3(q) thereof. This wft
estate loan and is not subject to the limitation condo in the course of our regular examinations of NaREAL ESTATE LOANS

250

tional banks. If a violation is discovered, we promptly
bring the matter to the attention of the National bank
involved for correction.
In our examinations of National banks, we have not
found patterns of loans made to so-called unregulated
lenders with knowledge of their intent to reloan the
same to finance the purchase or carrying of registered
stock. And the violations we occasionally discover provide no basis for suspecting that such patterns do exist.
This is not to say, however, that each violation of
Regulation U by a National bank is uncovered by this
Office.
Many times a National bank does not know that its
loan to a so-called unregulated lender is a violation of
section 221.3(q). If the unregulated lender, who is
also engaged in other lending activities, informs the
bank that he does not intend to reloan the money for
the purpose of financing or carrying a registered stock,
and the bank has no reason to suspect otherwise, the
loan will be an unknowing violation of subsection
221.3 (q) on the part of the bank. In this regard, it
should be noted that section 7(d) of the Securities
Exchange Act of 1934 prescribes a subjective test,
namely the purpose of the so-called unregulated lender,
as the standard for determining whether that statute
is violated. Such a standard is not always susceptible
to easy application.
Even if the bank's lending officer has knowledge
that a loan is in violation of section 221.3 (q), this
Office may not discover the violation during our examination, for two reasons. First, the credit file of the
bank may not disclose, or otherwise suggest, the violation. Thus, the examiner reviewing that file will have
no way of knowing of the impropriety, unless told by
the lending officer. Second, if the loan in question is
not in arrears, is otherwise in good standing, and the
amount thereof is below the amount set as the standard for reviewing loans in the course of a particular
examination, the examiner may have no occasion to
review the credit file and speak to a bank official regarding the loan.
Although, as indicated, we have no reason to believe
that a substantial number of loans in violation of Regulation U are now made by National banks, in order
to guard against such possibility this Office intends to
remind our examiners to follow our instructions in this
area and be especially alert to violations of such regulation, including section 221.3 (q). We expect these instructions to go forward to our field personnel in the
very near future.

TRAVEL SERVICES
OCTOBER 4,

1967.

Hon. EMMANUEL CELLER,

Committee on the Judiciary,
House of Representatives,
Washington, D.C.:
Reference is made to your letter of September 26,
1967, in which you request our comments with respect
to a letter from a travel-agency president. He presents
several arguments in support of pending legislation
designed to prevent National banks from operating
travel agencies, Tn substance, he feels the operation by
National banks of travel services is illegal, is not in the
public interest, represents unfair competition, will drive
the independent travel agent out of business, and permits the bank to pressure its depositors and horrowers
to utilize such service.
The. position of this Office in regard to National
banks acting as travel agents is set forth in Paragraph
7475 of the Comptroller's Manual for National Banks,
as follows:
Incident to those powers vested in them under 12 U.S.G.
24, National banks may provide travel services for their customers and may receive compensation therefor. Such services
may include the sale of trip insurance and the rental of automobiles as agent for a local rental service. In connection
therewith, National banks may advertise, develop, and extend
such travel services for the purpose of attracting customers
to the bank.

There are several bases for this ruling. First, both
State and National banks have a long history of service
as travel agents. In the period between the Civil War
and the 1920's, the banks in some sections of the country played a large role in arranging travel accommodations for immigrants. Thus, banks are not "entering"
the travel business. Some have been in the Held for
nearly 100 years.
The second basis for the ruling was determination
by this Office that the furnishing of travel services as
the agent of a carrier is a proper banking function. It
complements many established banking services such
as the issuance of traveler's letters of credit and traveler's checks, the providing of custody accounts, safe
deposit facilities, and the entire range of bank credits
employed in international trade and investment. Also,
although the activities of a travel agent have become
formalized in recent years, the basic function continues
to be the delivery of documents—the tickets—against
payment of the price. This function, of course, is identical to that performed by banks in connection with several areas of domestic and international commerce.
For example, in commercial transactions between dis-

251

tHQt jfiailitMSj sellers customarily inake batiks their agents
for the delivery of documents and the collection of
drafts.
Rule 67, (o which the travel-agency president refers
in his letter, was a lefledion of certain advertising and
profitability restrictions imposed after World War I I
on travel departments operated by National hanks.
This "rule" was neither published in thft Code, of Federal RegidiUions nor contained in the Comptroller's
Digest of Opinions, the forerunner of the Comptroller's
Manual for National Bards. In 1959, after an extensive 2-year study conducted by this Office at the behest
of the American Society of Travel Agents, these restrictions were lifted.
As previously noted, National banks and independent travel agents have been offering travel services,
side by side, for nearly 100 years. We. have been unable
to discover a single instance in which an independent
travel agent has been driven out of business as a result
of competition from a National bank, or in which a
National bank has applied pressure on a customer,
through its lending and borrowing relationship, to
utilize the bank's travel services. We are strongly of ths
opinion, especially during these times of increased demand by the general public for travel services, that it
would be adverse to the public interest to eliminate, as
the agency president, suggests, National banks as
competitors in this area.
Finally, it should be noted, that although he objects
to the participation of National banks in the travel
service area, the New York legislature has added to its
"banking powers" statute, which controls the activities
of New York State banks, the following provision, in
pertinent part:
§ 96 Every bank and trust company shall * * * have the
following powers.
13. To reserve or order transportation, travel accommodations or other travel services.
Consolidated Laws of New York
Banking Laws, § 96

TRUTH-IN-LENDING
APRIL 25,
Hon.

1967.

WALLACE F. BENNETT,

Committee on Banking and Currency,
United States Senate,
Washington, D.C.:
We are pleased to submit the following as our answers, for the record, to the questions you asked at the
conclusion of our testimony on April 13, 1967, concerning S. 5, the Truth-In-Lending Act of 1967.
252

(1) "Can you tell how a bank check credit program
would comply with S. 5?"
We assume the question refers to the activity wherein
a bank agrees to honor, up to a maximum amount,
checks written by a depositor in excess of lhe balance
in his account. The bank, in effect, upon being satisfied wilh the depositor's credit standing, makes a commitment to lend the maximum amount to the
depositor. The depositor receives the proceeds of his
loan by writing checks in excess of his accounl. ha.lance.
We believe that, it is the intent of the bill that this
type of credit extension be treated siiiiilaiiy to the revolving credit, account. No credit is extended until the
borrower overdraws his account and, at that time, a
finance charge, usually at a monthly rate of 1 percent
to 1^4 percent., is charged. We believe it is the intent
of the bill that this would be disclosed as an annual
rate of 12 percent to 18 percent.
(2) "Can you tell how a bank credit card program
would comply with S. 5?"
A bank's credit card program, for purposes of S- 5,
is, at least as far as the customer Is concerned, essentially the Same as a retailer's revolving credit, program.
The difference, which is-not. significant, is that the bank
takes lhe position which the merchant or seller of goods
or services would occupy in a revolving credit program.
Thus, a bank credit card program should not present,
any unique problems with respect to S. 5. If the imposed rate is V/2 percent per mouth, the annual rate
would be 12 times V/t percent, or 13 percent Whatever method is adopted by S. 5 regarding revolving
credit programs would also be applicable to bank credit
card programs.
(3) "What about credit card programs where a fee
is paid to get the card?"
A fee paid to obtain a credit card can, as the regulators choose, be viewed either as a cost incident to
obtaining credit, such as the cost of a credit investigation report, or a one-time cost spread over an indefinite
lifetime of the card. If the former view is adopted, this
fee will enter into the computation of the aggregate
finance charge to be paid by the borrower for the extension or use of credit. If the latter view is taken, the
fee for obtaining the card should not be included in
the rate.
(4) "How would a variable interest rate contract
comply with S. 5?"
We are not sure what is meant in the question by
"variable rate contract." If the reference is to a graduated rate cuiilracl wilh a fixed term and a definite
payment schedule, a single rate equivalent may be obtained through the use of tables.

In the case of an open-end contract, with graduated
rates, a single rate can only be obtained by hypothesizing in regard to the length and terms of the loan.
Rules could be established by the regulating agency.
In the case of a really variable rate, where the rale
is subject to unpredictable change, the annual rate
could only be given on the basis of the rate in effect
at the time the contract is drawn. Additional information regarding the events which would cause change
in the rate, overall maximum rate, etc., could be given
in narrative.
UNDERWRITING REVENUE BONDS
SEPTEMBER 1,
Hon.

1967.

J O H N SPARKMAN,

Committee on Banking and Currency,
United States Senate^ Washington, D.C.:
Reference is made to your request for the views of
this Office on S. 1306, a bill "To assist cities and States
by amending section 513G of the Revised Statutes, as
amended, with respect to the authority of National
banks to underwrite and deal in securities issued by
States and local governments, and for other purposes."
The Glass-Steagall Act of 1933 authorized commercial banks to underwrite general obligations of States
and their political subdivisions, although it also forbade
banks to underwrite other securities. The effect of die
law was to assure States and local governments that
they would have the benefit of effective competition
between commercial banks and investment bankers in
the marketing of their obligations.
Since the depression years, public needs have grown
extensively, and State and local governments in planning methods of financing their needs have been increasingly faced with antiquated statutory debt limits.
Consequently, in order to raise funds to finance their
public needs, these political entities have had to raise
revenues through other means than property taxation
to which debt limits are principally keyed. The practice developed of allocating revenues from specific
sources to specific purposes. Bonds to be paid from
revenues thus allocated have come to be known as
revenue bonds. This type of bond now constitutes
nearly half of the bonds issued by State and local governments. In practice, these bonds have proved to be
just as sound as general obligations, and there is no
basis whatever for asserting as a generality that general
obligation bonds are sounder than revenue bonds.
There is no less need for effective competition between commercial banks and investment bankers in

the marketing of revenue bonds than in the marketing of general obligation bonds. Moreover, there is no
basis for making a distinction between general obligation and revenue bonds with respect to bank participation in their marketing. No such distinction was
ever written into law, and it exists today only because
of the historical accident that the general mode of
State and local government financing when the law
was enacted was through the issuance of general
obligations.
Indeed, this Office has interpreted the term "general obligation" in the existing law as covering certain
kinds of sound issues which had been previously considered revenue bonds. The Board of Governors of the
Federal Reserve System, although it testified before
your Committee in favor of enactment of S. 1306, has
not accepted the Comptroller's interpretation of the
powers of National banks in this regard, but has taken
the position that only bonds backed hy the full faith
and credit of a political subdivision possessing full
powers of taxation may be underwritten under existing
law. The question is involved in litigation now pending in the Court of Appeals for the District of
Columbia.
S. 1306 is limited in scope and would not go so far
as to authorize National banks to deal in and underwrite revenue bonds which do not have the requisite
soundness, nor would it authorize such banks to do so
in unlimited amounts. Tt would authorize banks to
deal in and underwrite only those revenue bonds now
eligible for purchase by National banks, and only in
amounts not exceeding 10 percent of the bank's capital and surplus, for any single issuer. Thus, there
would be little, if any, additional risk to a bank over
that which it may have under existing law. Moreover,
S. 1306 would specifically exclude industrial revenue
and special assessment bonds.
The only other possible objection to the proposed
legislation is the possibility of conflict of interest abuse
on the part of individual banks. This objection seems
hardly tenable in view of the fact that substantively
there is little, if any, difference between revenue bonds
and general obligation bonds, which banks have long
been permitted to deal in and underwrite, in view also
of the fact that conflict of interest abuse has not been
a problem in the administration of the laws which permit bank underwriting of general obligations.
The proposed legislation would merely modernize
the powers of National banks in light of modern methods of public financing, and would provide for local
governments a greater competitive market than they
now have in which to finance badly needed public im253

provcments. This Office, therefore, strongly urges the
enactment of S. 1306.

VOTING OF BANK STOCK
DECEMBER 18,
Hon.

1967

WRIGHT PATMAN,

Committee on Banking and Currency,
House of Representatives,
Washington, D.C.:
Thank you for your letter of November 17, 1967,
which requests a report from this Office on H.R.
13884 (90th Cong., 1st sess.).
H.R. 13884 deals with two subjects. First, it would
prohibit any insured bank from controlling the voting
of any of its own stock, and, secondly, it would extend
the present requirements for mandatory cumulative
voting now imposed on National banks to cover all
insured banks.
First. The provisions of H.R. 13884 which would
prohibit insured banks from voting their own capital
stock apparently refer to situations where such banks
hold their stock as trustees. National banks are presently prohibited from holding their own stock, beneficially (12 U.S.C. 83), and we believe most State
banks are similarly restricted.
National banks presently may not vote their own
stock, which they hold as trustee, at elections of directors, "unless under the terms of the trust the manner in which such shares shall be voted may be
determined by a donor or beneficiary of the trust and
unless such donor or beneficiary actually directs how
such shares shall be voted * * *." (12 U.S.C. 61).
H.R. 13884 would repeal the above provision and,
in its place, write an absolute prohibition forbidding
any insured bank to "directly or indirectly exercise or
control the exercise of the voting rights of its capital
stock."
Although this Office has heard of one recent complaint concerning a State bank, respecting its voting
of its stock held in trust, similar complaints cannot,
however, be levied against any National bank. For
National banks, the above-quoted provisions of 12
U.S.C. 61 contain a completely flflf.qnaift safeguard.
Since this provision now fully protects against i;"proprieties by National hanks, we see no necessity for ihe
more stringent rule of H.R. 13884.
If, arguendo, some Federal legislation is considered

254

necessary and proper with regard to Stale banks, we
believe that the above-quoted provision of 12 U.S.C.
61 should serve as the standard.
H.R. 13884 would also have undesirable side effects
upon all banks. One effect would be its disruptive impact. H.R. 13884 would render each insured bank,
both State and National, practically incapable of acting as trustee of a trust, the assets of which include
stock of such bank. Thus, every trust containing stock
of an insured bank would have to be lodged with a
different bank. This would disrupt many trusts now
in existence. And this would be true whether such
stock was, in terms of value, a substantial portion of
the trust's assets.
H.R. 13884 would also foster the creation of interbank influence. If a bank, as trustee, holds substantial
stock in another bank, the former could, through cumulative voting, obtain representation on the tatter's
board of directors. The trustee bank could, with justification, insist that such representation is necessary to
fulfill its fiduciary duty to oversee the management of
its trust assets and to preserve and enhance their value.
While some such situations exist today, H.R. 13884
would serve to greatly enlarge the number of cases in
which this would occur.
Second. The second provision of H.R. 13884 would
extend the present mandatory cumulative voting requirements on National banks to cover the election of
directors of every insured bank.
This Office has had mixed experiences with regard
to the subject of cumulative voting. The desirability
of cumulative voting is a matter of disagreement
among many knowledgeable and respected legal
commentators.
This Office recognizes that cumulative voting is considered a means of achieving corporate democracy.
Indeed, on occasion, cumulative voting has enabled us
to work toward the solution of supervisory problems
through minority interests. On the other hand, we
have seen many instances where cumulative voting has
been used and abused by fractious and disruptive elements leading to supervisory problems. A rather important drawback to cumulative voting is that it sometimes enables a competitor bank to place a director on
its rival's board, an dbvkwsly undesirable situation.
Accordingly this Office has no itx-.uminendaliori to
make with regard to that part of the bill which would
subject State banks to the cumulative voting
requirement.

INDEX
Page
Accounting regulation for National banks
13
Addresses of William B. Camp
220-236
Administration of Comptroller's Office
20-22
Administrative Assistants to the Comptrollers, listed . .
164
Advertising guidelines
246-247
Agricultural Credit Corporation
241
Assets of National banks:
By deposit size, 1966 and 1967
190
Of foreign branches
214-215
At last condition report, 1950-67
216
In 1966 and 1967
1-2
By States, June 30, 1967
193
By States, Dec. 30, 1967
196
Of trust accounts
218
Bank charters. (See Charters and chartering.)
Bank examination
13,245-246
Bank mergers. (See Mergers.)
Bank service corporations
242-243
Bank stock, voting of
254
Banks. (See National banks; State banks.)
Bond underwriting
14-15,253-254
Branches of National banks:
Closed in 1967
188-189
Denovo
6, 11-12
Entering system in 1967, by States
180-187
Foreign
18-19, 214-215
Litigation on
15
Opened in 1967
6
By States
10-11
Call dates
191-192
Camp, William B.:
Addresses and Congressional testimony of . . . . 220-236
Selected correspondence of
241-254
Capital accounts of National banks:
By deposit size, 1966 and 1967
190
From 1944 to 1967
212
In 1966 and 1967
1-2
By States, June 30, 1967
195
By States, Dec. 30, 1967
198
Capital stock of National banks:
In 1967
167
From 1944 to 1967
212
Cases in litigation
14—16
"Cease and desist" regulations
14
Charters and chartering:
Applications by states, 1967
168
Changes in during 1967
167
Comptroller's letter on
243
And conversion of State to National banks
9
Issued in 1967
6, 8
Pending litigation on
15
Check guaranty plans
244

Page
Common trust funds
217
Comptroller of the Currency, Office of:
Administration of
20-52
Administrative Assistants to the Comptrollers, listed .
164
Comptroller's addresses and Congressional testimony
220-236
Comptrollers listed
163
Correspondence of
240-254
Deputy Comptrollers listed
164
Financial operations of
23-26
Organization of
22
Comptroller's equity
23-25
Condition reports, dates of
191-192
Congressional testimony:
Of William B. Camp
220-236
Of Dean Miller
236-237
Consolidations. (See Mergers.)
Conversions:
Of National to State banks
171
Of State to National banks
9,170
Correspondence of Office of the Comptroller of the
Currency
240-254
Currency, issue and redemption of
27
Data processing services
245
De novo branching
6,11-12
Deposit machines
244-245
Deposits of National banks. (See Assets of National
banks.)
Deputy Comptrollers of the Currency, listed
164
Directorates, interlocking
247-248
Directory
20
Discounts of National banks
199
Dividends of National banks
212
EDP systems
20-21
Electronic data processing services
245
Employee development programs
21
Entry. (See Charters and chartering.)
Equity, Comptroller's
23-25
Examination reports
13,245-246
Expenses of National banks:
By deposit size, 1967
; . . . . 209-211
In 1966 and 1967
;
3-5
By States, year ended Dec. 31, 1967
200-208
Fiduciary activities
17
Financial operations of Comptroller's Office
23-26
Fiscal Management Division
20
Foreign branches:
Assets and liabilities of . . .
214-215
Condition summarized
18-19
Listed by region and country
19
Number of, 1960-67
215
255

Page
Incidental powers, litigation on
14
Income of National banks:
By deposit size
209-211
In 1966 and 1967
4-5
By States
200-208
Summarized
3
Industrial development authorities
247
Interlocking directorates
247-248
International banking. (See also Foreign branches.) . . . 18—19
Investment securities
248-250
Investments, litigation on
14-15
Issue of currency
27
Liabilities of National banks:
At date of last condition report, 1950-67
216
By deposit size, 1966 and 1967
190
Of foreign branches
215
In 1966 and 1967
2
By States, June 30, 1967
194
By States, Dec. 30, 1967
197
Liquidations of National banks
167,170
Litigation
14-16
Loans of National banks:
To industrial development authority
247
Losses and recoveries of
213
Real estate
250
On securities
250-251
By States, Dec. 30, 1967
199
Management of Comptroller's Office
20-22
Mergers, 30-160:
Approvals describe in detail
35-157
Comptroller's letter on
241-242
Disapprovals described in detail
157-160
Litigation on
15-18
Of National banks with State banks
171,172
In 1967
12
By size of banks involved, 1960-67
179
By States, in 1967
173-179
Summarized
30-33
Military facilities of National banks
215
Miller, Dean, Congressional testimony of
236-237
National banks:
Accounting regulation for
13
Assets at date of last condition report, 1950-67 . . .
216
Assets by deposit size, 1966 and 1967
190
Assets by States, June 30, 1967
193
Assets by States, Dec. 30, 1967
196
Assets in 1966 and 1967
1-2
Assets of foreign branches
214-215
Branches closed in 1967
188-189
Branches entering system in 1967
180-187
Branches by States
10-11
Capital accounts by deposit size, 1966 and 1967. . .
190
Capital accounts, 1944-67
212
Capital accounts, by States, June 30, 1967
195
Capital accounts, by States, Dec. 30, 1967
198
Capital accounts in 1966 and 1967
1-2
Capital stock of
167, 212
Charter applications by States
168
Charters issued in 1967
6,8, 167
Common trust funds of
217
Condition of
1-2

256

National Banks—Continued
Page
Consolidations of
172
Conversion of State to
9,170
Converted to State
171
^Discounts of
199
Dividends of, 1944-67
212
Examination of
13,245-246
Expenses by deposit size, 1967
209-211
Expenses by States
200-208
Expenses in 1966 and 1967
3-5
Fiduciary activities of
17
Foreign branches of
18-19,214-215
Income by deposit size, 1967
. 209-211
Income in 1966 and 1967
3-5
Income by States
200-208
Liabilities at date of last condition report, 1950-67 .
216
Liabilities by deposit size, 1966 and 1967
190
Liabilities by States, June 30, 1967
194
Liabilities by States, Dec. 30, 1967
197
Liabilities in 1966 and 1967
2
Liabilities of foreign branches
215
Liquidations in 1967
167,170
Listed by size of banks, 1960-67
179
Listed by States
7
Loans of
199,213,247,250-251
Mergers of
30-160,171,173-179
Net profits of, 1944-67
212
Newly organized in 1967, by States
169
Purchase of State banks by
172
Regional Administrators of
165
Reports of condition of
191-192
Security losses and recoveries by
214
Structural changes in
6-12, 166
Trust activities of
17,217-218
Net profits of National banks
212
Ofice of the Comptroller of the Currency. (See Comptroller of the Currency.)
Peisonnel administration
21
Publications of Comptroller's Office
20
Purchase of State banks by National . . . . . . . . .
172
Real estate loans
250
Redemption of currency
27
Regional Administrators of National Banks, listed . .
165
Reports of condition, dates of
191-192
Revenue bonds, underwriting
14-15, 253-254
Securities:
Investments in
248-250
Loans on
250-251
Losses and recoveries of National banks on . . . . .
214
Service corporations, bank
242-243
State banks:
Consolidations of
172
Merged with National
171
Mergers in 1967, by States
173-179
National banks converted into
170
Purchased by National
172
Stock, bank
254
Travel services
251-252
Trust assets and income of National banks
217-218
Trust departments
17
Tn.ith-In-Lending Act
252-253
Underwriting of bonds
14-15,253-254

Full text of Annual Report of the Comptroller of the Currency : 1967

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