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Annual Report 1972
Comptroller of the Currency




The Administrator of National Banks

James E. Smith
Comptroller of the Currency




For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C. 20402 - Price $2.75
Stock Number 4801-0009

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

SEPTEMBER 28,

1973.

SIRS: Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1972 Annual Report of
the Comptroller of the Currency.
Respectfully,
JAMES E. SMITH,

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.

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

Page

1
3
5
13
15
21
23
25
29

Appendices
A. Merger Decisions, 1972
B. Statistical Tables
C. Addresses and Selected Congressional Testimony of the Comptroller of the Currency

35
187
263

Index

287




Statistical Tables
Table No.
Title
Page
1 Assets, liabilities, and capital accounts of National
banks, 1971 and 1972
2
2 Income and expenses of National banks, 1971 and
4
1972
3 National banks and banking offices, by States,
g
Dec. 31, 1972
4 Applications for National bank charters, and
charters issued, by States, calendar 1972
5 Applications for National bank charters to be issued
pursuant to corporate reorganizations, and
charters issued, by States, calendar 1972
8
6 Applications for conversion to National bank
charters, and charters issued, by States, calendar
9
1972

VI




Table No.
Title
Page
7 Branches of National banks, by States, calendar
1972
10
8 De novo branch applications of National banks, by
States, calendar 1972
11
9 De novo branches of National banks opened for
business, by community size and by size of bank,
calendar 1972
12
10 Mergers, calendar 1972
12
11 Office of the Comptroller of the Currency: balance
sheets, 1971 and 1972
30
12 Office of the Comptroller of the Currency: statements of revenue, expenses, and Comptroller's
equity
31
13 Office of the Comptroller of the Currency: statement of changes in financial position
32

I. Condition of the National Banking System
The year 1972 saw a rather steady increase in shortterm interest rates. Levels were such, however, that
banks were able to compete vigorously and sucessfully for individual savings and for money market
funds. That, coupled with a steadily growing demand
for loanable funds, led to a 14.4 percent increase in
total deposits of National banks. Unlike the situation
in 1971, when time deposits grew at a rate almost four
times greater than that of demand deposits, the respective rates were more nearly comparable in 1972:
demand deposits increased by 13.5 percent and time
deposits, 15.2 percent. At the end of 1972, time deposits represented 52.0 percent of total deposits of
$359.4 billion.
Total assets of National banks reached $434.9 billion on December 31, 1972, a figure higher by 15.5
percent than that for year-end 1971. Total loans stood
at $230.5 billion, reflecting an 18.7 percent increase in
1972. The sharp rise in the demand for bank loans
led to a relative shift within banks' asset portfolios




from securities to loans. Holdings of investment securities by National banks showed an 8.0 percent increase, totalling $103.7 billion at year-end. The proportion of total assets made up of loans increased from
51.6 percent in 1971 to 53.0 percent in 1972, while a
similar figure for investment securities declined from
25.5 percent to 23.9 percent.
Within the investment securities category, National
bank holdings of agencies and municipals continued to
increase relative to U.S. Treasuries. Bank municipal
portfolios increased by 8.4 percent, to reach a total of
$52.7 billion, while holdings of Treasuries increased 2.2
percent, to $37.2 billion.
Total capital accounts of National banks increased
by 12.1 percent during 1972, moving from $27.1 billion to $30.4 billion. Capital notes and debentures increased by 46.9 percent, from $1.4 billion to $2.1 billion. Total reserves on loans and securities advanced
by 6.7 percent, from $3.9 billion to $4.2 billion.

TABLE

1

Assets, liabilities, and capital accounts of National banks, 1971 and 1972
[Dollar amounts in millions]
Dec. 31, 1971
4,600 banks
Amount

Percent
distribution

Dec. 31, 1972
4,614 banks
Amount

Change 1971-1972

Percent
distribution

Amount

ASSETS

Cash and due from banks
U.S. Treasury securities
Obligations of other U.S. Government agencies and
corporations
Obligations of States and political subdivisions
Other securities
Total securities
Federal funds sold and securities purchased under agreements to resell
Direct lease financing
Loans
Fixed assets
Customers' liability on acceptances outstanding
Other assets
Total assets

59, 201
36, 396

15.73
9.67

67, 401

15.50
8.55

8,200

37, 200

8,634
48, 648
2,351
96, 029

2.29
12.92
.62
25.51

10, 666
52, 716
3, 154
103, 736

2.45
12. 12
.73
23.85

2,032
4,069
803
7,708

12, 705
871
194, 145
6,611
2,197
4,697
376, 456

3.37
.23
51.57
1.76
.58
1.25
100. 00

16, 672
1,073
230, 456
7,333
2,007
6,268
434, 947

3.83
.25
52.98
1.69
.46
1.44
100. 00

3,966
201
36,311
722
—190
1,571
58,491

113,210

30.07

130,376

29.98

17, 167

138,222
6,389
29, 036

36.72
1.70
7.71

157, 663
7,062
33, 445

36.25
1.62
7.69

19,442
672
4,408

3,390
18, 620
5,346
314,212
151,985
162, 227

.90
4.95
1.42
83.47
40.37
43.09

4,362
20, 526
5,993
359, 427
172,565
186, 862

1.00
4.72
1.38
82.64
39.67
42.96

971
1,906
646
45,215
20, 579
24, 635

17,302
866

4.60
.23

24, 349
2,370

5.60
.54

7,047
1,504

2,242
10, 842

.60
2.88
91.77

2,062
12, 204
400,413

.47
2.81
92.06

—180
1,363
54, 948

804

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
Cfther liabilities
Total liabilities
Minority interest in consolidated subsidiaries.

345, 465

1

1

RESERVES ON LOANS AND SECURITIES
Reserves o n l o a n s . . . .
Reserves o n securities.

3,837
80

1.02
.02

4, 101
78

.94
.02

1,449
43
6,785
11,818
6,300
676

.38
.01
1.80
3. 14
1.67
.18
7. 19
100. 00

2,129
42
7,458
12,717
7,524
482

.49
.01
1.71
2.92
1.73
. 11

264
—2

CAPITAL ACCOUNTS

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

27, 072
376, 456

30, 352

6.98

434, 947

100. 00

680
—1
673
899
1,224
—194
3,280
58, 491

NOTE : Data may not add to totals because of rounding.
The 1971 and 1972 data reflect consolidation of all majority-owned bank premises, subsidiaries, and all significant domestic
majority-owned subsidiaries, with the exception of Edge Act subsidiaries.




II. Income and Expenses of National Banks
Both operating income and net income of National
banks increased significantly in 1972, but the rates of
increase were well below the rates of increase in total
assets and total loans, and slightly below the rate of
increase of total capital. As a result, rates of return on
earning assets and on capital were somewhat lower in
1972 than in 1971.
Operating income of National banks rose 10.5 percent in 1972, totalling $23.5 billion compared to $21.3
billion in 1971. The proportionate shares of the major
sources of operating income did not shift substantially
in 1972. Interest and fees on loans of $15.1 billion accounted for 64.1 percent of operating income in 1972,
just as in 1971. Interest on investments of $4.6 billion
contributed 19.7 percent of operating income in 1972,
down slightly from 20.0 percent in 1971. Gains were
registered in 1972 in the relative contribution of income on Federal funds sold and "other income" to op-




erating income, while the relative contribution of trust
department income remained virtually unchanged.
Total operating expense of National banks was $19.3
billion in 1972, a 10.8 percent increase over the 1971
figure. Interest on deposits climbed 11.8 percent,
reaching $8.1 billion and accounting for 41.9 percent
of operating expense. That share of expenses is almost
twice as great as that of the next highest expense
item, salaries and wages, which accounted for 23.1
percent of the total.
Income after applicable income taxes but before
securities transactions totalled $3.2 billion for National banks in 1972, a 10.5 percent increase over 1971's
$2.9 billion. With net gains on securities transactions
lower in 1972 than in 1971, net income of National
banks showed a smaller percentage increase of 8.8
percent, totalling $3.3 billion in 1972.

TABLE 2

Income and expenses of National banks*, 1971 and 1972
[Dollar amounts in millions]
Dec. 31, 1971

Amount

Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
....
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges,
commissions, and fees
Other operating income
Total operating income

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities
sold under agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental
costs servicing etc
Provision for loan losses (or actual net loan losses). .
Other operating expenses
Total operating expense

Income before income taxes and securities gains or
losses
Applicable income taxes
Income before securities gains or losses
Net securities gains (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income
Gash dividends declared:
On common stock
On preferred stock
Total cash dividends declared

Ratio to income before income taxes and securities:
AnDlicable income taxes
Net securities gains
. ..
Extraordinary charges or credits
Ratio to total operating income:
Salaries and waffes
Interest on deDOsits
All other operating expenses
Total operating expenses

Net income

Percent
distribution

Dec. 31, 1972

Amount

Percent
distribution

4,614

4,600

Change, 1971-1972

Amount

Percent

14

.30

13,668.1

64. 14

15, 084. 9

64.07

1,416.8

10.37

533.8

2.50

641.8

2.73

108.0

20.23

1, 849. 5

8.68

1, 844. 5

7.84

-5.0

-.27

442.9

2.08

567.2

2.41

124.3

28.07

1,841.0
137.8
700.9
709.7

8.64
.65
3.29
3.33

2, 039. 7
175.6
770.9
718.3

8.66
.75
3.27
3.05

198.7
37.8
70.0
8.6

10.79
27.43
9.99
1.21

624.6
801.2
21, 309. 5

2.93
3.76
100. 00

695.8
1, 003. 9
23, 542. 7

2.96
4.26
100. 00

71.2
202.7
2, 233. 2

11.40
25.30
10.48

4, 140. 2
698.4
7, 228. 7

23.75
4.01
41.47

4,461.0
778.7
8, 084. 7

23. 10
4.03
41.86

320.8
80.3
856.0

7.75
11.50
11.84

739.6
80.7
67.8
811.0

4.24
.46
.39
4.65

976.2
77.9
111.3
903.6

5.05
.40
.58
4.68

236.6
-2.8
43.5
92.6

31.99
-3.47
64. 16
11.42

606.6
514.1
2, 543. 3
17,430.4

3.48
2.95
14.59
100. 00

651.2
584.3
2, 685. 8
19, 314. 7

3.37
3.02
13.91
100. 00

44.6
70.2
142.5
1, 884. 3

7.35
13.65
5.60
10.81

3, 879. 1
942.7
2, 936. 3
106.9
3, 043. 3
-1.8

4, 228. 0
982.2
3, 245. 8
54.1
3, 299. 9
8.3

348.9
39.5
309.5
-52.8
256.6
10. 1

8.99
4. 19
10.54
- 4 9 . 39
8.43
561. 11

3,041.3

3, 307. 9

266.6

8.77

1, 386. 2

1, 307. 6
2.7
1,310.3

-78.6
-1.3
-79.9

-5.67
-32.50
-5.75

4.0

1, 390. 2
24.30
2.76
.05

23.23
1.28
.20

19.43
33.92
11.94
81.80
14.27

18.95
34.34
11.41
82.04
14.05

•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.
NOTE : Dashes indicate amounts of less than $500,000. Data may not add to totals because of rounding.




III. Structural Changes in the National
Banking System
The 4,614 National banks in operation at the end
of 1972 represented a net increase of 14 during the
year. The total number of branches in the National
Banking System increased by 693, or 5.3 percent,
reaching 13,799 at year-end. As a result, the total
number of National banking offices serving the public (excluding foreign branches) reached 18,413. The
first National bank in many years to be based in Puerto
Rico opened during the year. California, New York,
and Pennsylvania continued to lead in total number of
National banking offices, with 2,585, 1,560, and 1,404
respectively, while the unit banking states of Texas and
Illinois accounted for the largest number of National
banks, with 538 and 415 respectively.
Branch activity was highlighted by the opening of
704 de novo branches during 1972. These are new
offices offering banking services to the public for the
first time at their specific sites. Also joining the National
Banking System were 158 branches via conversions and
mergers, while 169 branches left the system through
closings, mergers and conversions.




Of the 704 de novo branches, 403, or 57 percent,
were located in communities with fewer than 25,000
people. Only 22 were located in cities of over one million in population. Banks with total resources of less
than $100 million opened 307 or about 44 percent, of
the de novo branches. Banks with total resources exceeding $1 billion accounted for 174 de novo branches,
or about 25 percent of the total. New York, California,
and Pennsylvania led the states in de novo branches,
with 77, 70, and 45 respectively.
Charters issued for newly organized National banks
totalled 54 in 1972, compared with 38 in 1971. Preliminary approval was granted to 84 charter applications; that compares with 55 in 1971. In addition, 62
charters were issued pursuant to corporate reorganizations and 16 pursuant to the conversion of State banks.
During 1972, 57 merger, consolidation, or purchase
transactions involving two or more operating banks
were consummated in which a National bank was the
resulting bank. The 1971 total was 55. In addition, 64
transactions were completed involving only one operating bank, pursuant to corporate reorganizations.

TABLE 3

National banks and banking offices; by States, December 31, 1972
National banks
Number of
branches
Total

Unit

Number of
offices

With
branches

United States

4,614

2,862

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

89
5
3
70
55
124
26
5
11
244

41
0
1
29
6
110
5
3
1
244

48
5
2
41
49
14
21
2
10
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

61
1
7
415
122
100
171
80
50
19

21
0
2
336
43
57
139
32
11
3

40
1
5
79
79
43
32
48
39
16

248
10
115
79
381
63
32
162
202
112

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

39
82
106
199
38
102
54
123
4
48

11
17
27
196
4
68
51
97
1
22

28
65
79
3
34
34
3
26
3
26

284
457
625
7
158
35
3
27
66
63

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

121
33
163
23
43
218
192
8
276
5

19
5
59
3
31
64
144
1
118
0

102
28
104
20
12
154
48
7
158
5

800
86

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

1,752

13, 799

225
57
239
100
2,530

14
247
4
74
0

1,397

676
12
815
48
270
1,128

96

19
32
73
538
10
24
101
23
88
127
42
1
1

4
22
13
538
6
11
21
6
87
89
42
0
1

15
10
60
0
4
13
80
17
1
38
0
1
0

262
62
318
0
80
39
537
470
1
75
0
8
0

14

1

13

110

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

6



TABLE 4

Applications for National bank charters*, and charters issued*, by States, calendar 1972
Approved

Received f

Rejected

Abandoned

Pending
Dec. 31, 1972

United States

280

84

60

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

7
0
1
4
10
9
0
0
1
58

2
0
0
1
5
2
0
0
0
18

0
0
1
0
2
6
0
0
0
18

5
0
0
3
3
1
0
0
1
19

2
1
0
7
2
0
2
1
3
0

0
1
0
2
1
0
1
0
0
0

2
0
0
0
0
0
0
0
0
0

0
0
0
4
1
0
1
1
3
0

2
0
10
5
3

0
0
0
0
1
1
0
0
0
0

2
0
6
2
1
9
0
0
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

,
,
,
,

10

126

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

14
0
0
0
0

0
0
1
3
1
3
0
0
0
0

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

19
4
4
7
0
0
4
0
2
0

8
1
1
3
0
0
3
0
1
0

2
0
1
3
0
0
0
0
0
0

9
3
2
1
0
0
1
0
1
0

South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West V i r g i n i a . . . . . .
Wisconsin
Wyoming
Virgin Islands
Puerto Rico

0
0
3
72
9
0
4
2
6
1
1
0
0

0
0
1
18
3
0
0
1
2
1
0
0
0

0
0
1
17
3
0
0
0
2
0
0
0
0

0
0
1
36
2
0
4
1
2
0
1
0
0

*Excludes conversions and corporate reorganizations.
•(•Includes 71 applications pending as of December 31, 1971.




Charters
issued

TABLE 5

Applications for National bank charters to be issued pursuant to corporate reorganizations, and charters issued, by States,
calendar 1972
Approved

Received*

Rejected

Abandoned

Pending
Dec. 31, 1972

United States

89

80

0

9

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

8
0
0
0
0
0
1
0
0
1

7
0
0
0
0
0
1
0
0
1

0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
0
0
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

0
0
0
4
0
0
1
0
1
1

0
0
0
3
0
0
1
0
1
1

0
0
0
0
0
0
0
0
0
0

0
0
0
1
0
0
0
0
0
0

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

0
3
12
0
0
0
0
1
0
0

0
3
11
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
1
0
0
0
0
1
0
0

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

7
1
14
0
0
6
1
0
1
0

5
1
13
0
0
6
1
0
1
0

0

2

0

0
1
0
0
0
0
0
0
0

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

0
0
4
19
0
0
2
0
0
1
0
0
0

0
0
4
17
0
0
2
0
0
1
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0
0

0
0

* Includes 5 applications pending as of December 31, 1971.

8



0
0
0
0
0
0
0
0

6
2

0
0
0
0
0
0
0
0
0

Charters

TABLE 6

Applications for conversion to National bank charters, and charters issued, by States, calendar 1972
Approved

Received*

Rejected

Abandoned

Pending
Dec. 31, 1972

Chartered

United States

19

15

3

0

1

16

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

0
0
0
1
0
0
1
0
0
3

0
0
0
1
0
0
0
0
0
3

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
1
0
0
0

0
0
0
1
0
0
0
0
0
3

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

1
0
0
1
0
0
0
0
0
0

1
0
0
1
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
0
0
0
0

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

0
0
1
1
0
1

0
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
0
0

0
0
1
1
0

0
0
0

0
0
1
1
0
1
1
0
0
0

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

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

0
0
0
0
0
0
0
0
0
0

0
0
0
0
1
0
0
0
0
0

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

1
1
0
1
0
0
0
0

0
0
0
1
0
0
0
0
1
2
0
0

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

0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
2
2
0
0

2

1
2
0
0

•Includes two applications pending as of December 31, 1971.




2

2
0
0
0

TABLE 7

Branches of National banks^ by States^ calendar 1972
De novo branches Branches acquired Existing branches
through merger or discontinued or
opened for
consolidated
conversion, Jan. 1
business Jan. 1
to Dec. 31, 1972 Jan. 1, to Dec. 31,
to Dec. 31, 1972
1972

Branches in
operation
Dec. 30, 1971

Branches in
operation
Dec. 31, 1972

United States

13, 106

704

158

169

13, 799

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

209
53

16
3
15
4

0
1
0
9
6
0
0
0
0
0

0
0
1
0
19
1
17
0
1
0

225
57
239
100

0
0
0
0
1
0
0
1
4
1

CMO

0
2

0
7

225
87
2,473
13
250
4
71
0

70
2
14
0
4
0

150
185
107

CM CO

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraksa
Nevada
New Hampshire

268
441
581
7
145
24

16
21
38
0
11
10
0
1

54

9

0

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

741
79
1 337
'606

42
7
77
42
1
38
6
11
45
3

32
0

District of Columbia—allf

3
26
64

10

772
42

259
1,087
96

22
3
0
7

2

1
0
1

2
1
1
0
3

2
1

0
0
0
0
0
0

0
0
0

11
37
1
9
0

0
9
0

15
0
28
9
0
4
0
0
13
3

3
34

0
0
0
1
1
9

460
0
69

CD —•« CO

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

113
66
359
62
33

29
1
3
13

ooo

221
9

CMO

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

9
0
3

0
8

0

0

0
0

0
1
4
0
1
15
12
5*
0
0
0
0

106

5

0

1

251
63

292
0
75
50
506

11
0
30
0

5

0

2,530

14
247
4
74
0
248
10
115
79
381
63
32
162
202
112
284
457
625
7
158
35
3

27
66
63

800
86

1,397

676
12
815
48
270

1,128

96

262

110

62
318
0
80
39
537
470

1
75
0
8

•Includes 4 adjustments from prior year.
•[•Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

10



TABLE 8

De novo branch applications of National banks; by States, calendar 1972
Received*

Approved

Rejected

Abandoned

United States

1,349

925

116

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

31
2
21
10
160
4
20
1
5
0

23
2
10
6
96
3
11
1
3
0

3
0
0
0
33
0
1
0
1
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

47
1
11
18
48
10
0
18
18
6

36
1
5
13
27
6
0
14
14
4

3
0
1
1
9
0
0
0
1
1

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

39
29
96
6
23
19
0
1
2
14

28
22
41
5
16
12
0
1
2
10

1
1
16
0
4
2
0
0
0
0

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

83
15
139
71
4
63
1
20
114
18

49
12
106
50
2
49
1
14
93
17

2
1
9
1
1
6
0
3
7
0

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

29
4
29
0
9
9
59
9
6
7
0
0

22
4
17
0
7
7
47
7
5
4
0
0

Pending
Dec. 31, 1972

1
0
2
0
0
0
3
1
0
1
0
0

29

District of Columbia—allf
*Includes 241 applications pending as of Dec. 31, 1971.
f Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

501-017 0—73



11

TABLE 9

De novo branches of National banks opened for business, by community size and size of bank, calendar 1972

Population of cities

Total resources of banks
[millions of dollars]

Branches

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

115
288
96
62
55
31
35
22

Total

Branches

Less than 10.0
10.0 to 24.9
25.0 to 49.9
50.0 to 99.9
100.0 to 999.9
Over 1,000

44
113
90
60
223
174

704

Total

704

TABLE 10

Mergers,* calendar 1972
Transactions
involving
two or more
operating banks
Applications carried over from 1971
Applications received, 1972
Disposition of applications 1972:
Approved
Withdrawn
Applications pending December 31, 1972
Transactions completed 1972:
Mergers
Consolidations
Purchases of assets
Total completed

Other, pursuant
to corporate
reorganization

12
69

19
88

61
3
17

67
2
38

39
7
11

62
0
2

57

64

•Includes mergers, consolidations, and purchase and sale transactions where the resulting bank is a National bank.

12



IV. Bank Examinations and Related Activities
The National Bank Act requires that all National
banks 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 non-National bank and trust company in the District of
Columbia.
For the year ended December 31, 1972, the Office
examined 6,743 banks, 15,480 branches and facilities,
1,749 trust departments, and 191 affiliates and subsidiaries, as well as conducting 329 special examinations
and visitations. In addition, the Office received 293
applications to establish new banks; those included
84 corporate reorganizations. The Office also received
1,108 applications to establish de novo branches, and
17 applications to convert State banks to National
banking associations.
National bank examinations are designed to determine the condition and performance of banks, the
quality of their operations, the capacity of management, and whether the banks are complying with Federal laws. All facets of an examination have, as their
end result, the determination of liquidity and solvency,
present and prospective, and the determination of
whether the bank is operating within the framework of
applicable banking laws and regulations. The appraisal
of a bank's loans and lending policies, investments and
investment policies, and the ability and capacity of its
management constitute the most exacting phases of
the examination process.
As of December 31, 1972, the Office employed 1,639
examining personnel, 1,524 commercial examiners and
115 trust examiners. Reviews are constantly being made




to improve the quality and efficiency of examinations.
The National Bank Examiner's school continues to
occupy a key role in the career development program
of examining personnel. The school is attended by all
recently-commissioned National Bank Examiners, and
the curriculum covers all aspects of commercial examinations. Loan and investment analysis, determination
of asset quality, and evaluation of bank management
receive the greatest emphasis. Considerable time is also
devoted to diversification of risk, liquidity, capital adequacy, earnings, bank operations, investment in fixed
assets, borrowings, future prospects, and review of the
various laws and regulations affecting National banks.
The more senior National Bank Examiners began
attending 5-day EDP seminars during 1970. During
1972, the Office conducted eleven 5-day seminars in the
regions. Instruction covers the capabilities and the limitations of EDP systems in commercial banks. The program will continue until all examining personnel receive that necessary training. In addition, examiners
from each region have been selected for specialized instruction in Advanced Electronic Data Processing, those
examiners generally work independently of the commercial or trust examiner and prepare the EDP Report
of Examination, copies of which are sent to the banks
examined.
Finally, and in keeping with past practice, the Office encourages its examiners to attend the various
graduate schools of banking, and to participate in the
host of courses offered by the American Institute of
Banking and Dun and Bradstreet. We will continue to
review and update training programs and examining
techniques and to keep abreast of the ever changing
world of banking.

V. Litigation
New litigation challenging administrative actions or
rulings of the Comptroller of the Currency increased
sharply during 1972. Thirty-two new cases were filed
during 1972; 28 were pending on January 1, 1972; 26
cases were terminated during the year; and 34 cases
were pending at the end of the year. The litigation
during 1972 was characterized particularly by an increase in the number of lower court decisions appealed.
The Comptroller's ruling was overturned in only one
of the 26 cases terminated. The more significant cases
involved the following subjects:

A. Administrative Enforcement
Authority
In a case of first impression, a plaintiff sought to
enjoin the Comptroller from enforcing provisions of
the Financial Institutions Supervisory Act of 1966
which permit the summary suspension of a person indicted or convicted of certain felonies from participation in the affairs of an insured bank. Manges v. Camp,
Civil No. SA-71-CA-362, W.D. Texas. Plaintiff in
the Manges case asked that a 3-judge court be convened to declare the provisions of the Supervisory Act
permitting the Comptroller to exercise summary suspension authority, 12 U.S.C. 1818 (g) (1), unconstitutional as an ex post facto law, bill of attainder, unconstitutional delegation of legislative power, and denial
of due process. At year-end 1972, plaintiff's action had
been dismissed by the U.S. District Court and plaintiff
had appealed to the U.S. Court of Appeals for the
Fifth Circuit in New Orleans.

B. Performance of Data
Processing Services by
National Banks
Two cases which allege that the data processing
activities of particular National banks exceed the authority contained in the incidental powers clause of the
National Bank Act (12 U.S.C. 24 (Seventh)) were




pending during 1972. Hallmark Data Systems, Inc. v.
Central National Bank, et aL, Civil No. 72C-1586,
N.D. I l l ; National Retailers Corp. of America
(NRCA) v. Valley National Bank, et aL, Civil No.
71_410-PHX-WCF, D. Ariz. The complainants in
both cases, independent data processing service bureaus, challenge the Comptroller's ruling, 12 C.F.R.
7.3500, permitting National banks to perform certain
data processing services. In the Hallmark case, plaintiff
contends that the performance of reader services and
subscription fulfillment services by Central National
Bank, Chicago, 111., is improper. In the NRCA case,
plaintiff challenges the authority of Valley National
Bank, Phoenix, Ariz., to perform sales, inventory, and
accounts receivable analyses and processing for businesses. At year-end 1972, a preliminary injunction had
been denied in the NRCA case, and no proceedings had
taken place in Hallmark, other than the filing of the
complaint.
By notice published in the Federal Register on August 16, 1972 (37 F.R. 16556), the Comptroller stated
that he is considering a revision of 12 C.F.R. 7.3500,
and requested the views, comments, and suggestions
of the banking and data processing industries, as well
as other interested persons, as to whether 12 C.F.R.
7.3500 should be revised to delineate more clearly the
role of National banks in the utilization of data processing equipment and the furnishing of data processing services. Comments were received from 60 individuals or organizations, including 36 National banks
representing a wide diversity in size, structure, and
geographical location.
At year-end 1972 the comments received were being analyzed by the Comptroller's staff.

C. Performance of Travel
Agency Services by
National Banks
A lawsuit challenging the authority of National
banks to perform travel agency services resulted in

15

opinions by a district and appellate court during 1972.
Arnold Tours, Inc. v. Camp, Civil No. 67-372-C,
modified and affirmed, Court of Appeals Nos. 72-1142
and 72-1143 (1st Cir. 1972). The district court held
on February 22, 1972, that the operation of a fullblown travel agency by a National bank is not incidental to its banking business, and that the Comptroller's
ruling permitting such activity (12 C.F.R. 7.7475) was
invalid. The district court reasoned that an "incidental power" means a power which is a sine qua non to
the carrying on of the business of banking. The
court directed the defendant National bank to divest
itself of its travel agency within 6 months.
On appeal, the Court of Appeals for the First Circuit
rejected that portion of the district court's opinion
which appeared to hold that a National bank's incidental powers are to be measured by what is indispensable to carry on the business of banking. The
appellate court concluded, however, that a travel
agency operation of the range and type of that operated
by the defendant bank was not a legitimate exercise of
the bank's incidental power. The Court of Appeals
thus invalidated the Comptroller's ruling only to the
"extent that it may be construed by the Comptroller
as authorizing a National bank to operate a full-scale
travel agency." The court also directed that the district
court reconsider its divestiture order directed to the
National bank, and that the district court "entertain
and seriously consider any factual presentation [the
defendant bank] wishes to make in the direction of
lengthening the time for divestiture." At year-end
1972, no decision had been made as to whether to seek
Supreme Court review of the Court of Appeals'
decision.

D. Other Banking Powers
Interest permissible to National banks under 12
U.S.C. 85. At the request of the Comptroller, the
Department of Justice continued its appearance as
amicus curiae in a case filed against a National bank in
Michigan that challenged the bank's reliance upon the
Comptroller's Interpretative Ruling 7.7310 (12 C.F.R.
7.7310) to the effect that a National bank is permitted
by 12 U.S.C. 85 to charge interest on equivalent transactions at the maximum rate permitted by State law
to any competing State-licensed institution. Northway
Lanes v. Hackley Union National Bank, Civil No.
6072, W.D. Mich., aff'd., 464 F.2d 855 (6th Cir. 1972).
The U.S. Court of Appeals in Cincinnati filed an
opinion July 18, 1972, specifically agreeing with the

16



Comptroller's interpretation. The appellate court thus
ruled that the specific charges made by the defendant
bank, which, in the case, were attacked as usurious,
were permissible under 12 U.S.C. 85, because such
charges could be made by State savings and loan
associations, although they could not be made by State
commercial banks.

E. New Banks
1. Cases brought by competitors. Eight suits involving competitor challenges to the Comptroller's approvals of new banks were before federal courts during
1972. Somerset Trust Co. v. Camp, Civil No. 659-70,
D. N.J.; Wood County Bank v. Camp, Civil No. 127772, D. D.C., 348 F. Supp. 1321, appeal pending; Missouri State Bank & Trust Co. v. Camp, Civil No. 72C
436 (1), E.D. Mo.; Lewis & Clark State Bank v. Camp,
Civil No. 72C 402(2), E.D. Mo.; Bank of Utah v.
Camp, Civil No. NC 15-72, D. Utah; First National
Bank of Shawnee Mission v. Roeland Park State Bank
& Trust Co., Civil No. 3669, D. Kan.; Roeland Park
State Bank & Trust Co. v. Camp, Civil No. 2563-72,
D. D.C.; Bank of Commerce of Laredo v. Camp, Civil
No. 72-L-25, S.D. Texas. One case, Somerset, resulted
in a final order upholding the Comptroller's decision;
one case was voluntarily dismissed by plaintiff shortly
after filing, Bank of Utah; two cases were dismissed by
separate federal district courts for lack of jurisdiction,
Missouri State Bank and Lewis & Clark; and four
cases, Wood County, Shawnee Mission, Laredo, and
Roeland Park, were pending at year-end 1972. In
Somerset, a district court order granting judgment for
the Comptroller and rejecting contentions that New
Jersey State law prohibited the chartering of new National banks under the circumstances involved, became
final during 1972, when plaintiff did not pursue an
appeal. In the Wood County case, the district court
entered a preliminary injunction preventing the Comptroller from issuing a charter, upon the theory that the
Comptroller's hearings are "adjudicatory" rather than
"investigatory", and that the Comptroller's approval
of the application there involved without formal findings, consequently amounted to a denial of due process.
The Comptroller's appeal from the district court's preliminary injunction order was pending at the end of
the year. In the Bank of Commerce case, the plaintiff
bank alleged that the Comptroller's approval of a
charter for a new National bank which proposed to be
affiliated with an existing bank was unlawful. At
year-end, the case was pending on the Comptroller's
motion for summary judgment.

The Comptroller's approval of a charter for a new
National bank in Fairway, Kans., resulted in two lawsuits in 1972. Upon receiving information that two
competing banks planned to seek an injunction that
would prevent the new bank, on the eve of its opening,
from commencing business, the applicant bank, First
National Bank of Shawnee Mission, filed a complaint in
the U.S. District Court in Kansas against the competing banks for declaratory and injunctive relief affirming the right of the new bank to conduct its banking
business pursuant to the Comptroller's approval. Subsequently, the two competing banks, which had threatened to prevent the bank from commencing business,
filed a lawsuit, Roeland Park, against the Comptroller
only, in the District of Columbia, alleging that the
Comptroller's approval was invalid. At year-end 1972,
no proceedings had taken place in either of those cases
other than the filing of the complaints.
2. Cases brought by applicants. At the end of 1972,
three cases were pending by organizers of proposed
National banks, challenging the Comptroller's denial
of their charter applications. Pitts, et al. v. Camp, 329
F. Supp. 1302, reversed and remanded, 463 F.2d 632
(4th Cir. 1972), petition for certiorari pending;
Meisel v. Camp, Civil No. 71-C-437(4), E.D. Mo.;
Schwartz, et al. v. Camp, Civil No. 4655, S.D. N.Y.
In Pitts, the district court granted judgment for the
Comptroller on the ground that his administrative
record demonstrated that his denial was rational and
in accordance with law. On appeal, the court of appeals
reversed and remanded the case to the district court
for receipt of additional evidence as to the issue of lack
of need for the new bank. Because the rationale of the
court of appeals' opinion conflicted with decisions of
other courts of appeals, previous decisions of the same
court, and decisions of the Supreme Court, the Solicitor General filed a petition for certiorari, seeking Supreme Court review of the appellate decision. The Supreme Court had not acted upon the petition by yearend. The Meisel case was pending in the district court
at year-end, on the Comptroller's motion for summary
judgment; while no proceedings had taken place in
the Schwartz case other than the filing of the complaint.

F. Main Office Relocations
A decision of a federal district court in Mississippi,
granting judgment for the Comptroller in a case
wherein a rejected applicant sought to have the court
compel the Comptroller to approve applicant's simultaneous applications to relocate its main office and to




retain its former main office structure as a branch, was
upheld in a brief order by the U.S. Court of Appeals for
the Fifth Circuit during 1972. First National Bank of
Southaven v. Camp, Civil No. DC 7074K, N.D. Miss.,
affirmed C.A. No. 71-3507 (5th Cir. 1972). The district court had ruled that the Comptroller had a rational basis for disapproving the application even
though he had received recommendations for approval
from each of his reviewing subordinates.

G. Branches
Branch litigation resulted in a number of significant
district and appellate court decisions during 1972. In
First National Bank of Fairbanks v. Camp, 326 F.
Supp. 541 (D. D.C. 1971), aff'd., 465 F.2d 586 (D.C.
Cir. 1972), petition for certiorari pending, the court
of appeals affirmed the district court's granting of
judgment for the Comptroller in a lengthy opinion
which (1) rejected plaintiff's charges that the Comptroller's proceedings denied due process, (2) rejected
the contention that the Comptroller was bound to follow the Alaska State banking supervisor's views as to
the application of State law to the branch application,
and (3) observed that the Comptroller was not bound
to deny National bank branch applications in order to
achieve quantitative asset balance between State and
National banks. At year-end, plaintiffs had asked the
Supreme Court to review and reverse the court of appeals' opinion.
In Commonwealth of Virginia ex rel State Corporation Commission v. Camp, 333 F. Supp. 847 (E.D.
Va. 1971), appeal dismissed, the district court had
ruled that the Comptroller was not bound to follow
an interpretation advanced by the Virginia State Corporation Commission with regard to the Virginia
branching statute, and that the Comptroller's interpretation and application of the statute to the National bank application before him was reasonable.
The Virginia State Corporation Commission appealed
that decision during 1972, but later voluntarily abandoned the appeal.
Three other cases involving challenges by state
banking supervisors to the Comptroller's decisions
on National bank branch applications resulted in
judgments for the Comptroller during 1972. Dunn v.
First National Bank of Cartersville and Camp, Civil
No. 2375, N.D. Ga.; First National Bank of Southaven
v. Camp and Coahoma National Bank, Civil No. 7145K, N.D. Miss., appeal pending; Driscoll v. Northwestern National Bank of St. Paul and Camp, Civil No.
3-72-Civ-42, D. Minn., appeal pending. In Dunn,

17

the district court upheld the Comptroller's approval
of an additional branch for the First National Bank
of Cartersville, Ga., and rejected the contention of the
Superintendent of Banks for the State of Georgia that
the Comptroller's approval gave First National one
more branch than was permitted to State banks in
Georgia.
The sole issue presented by the case was whether
the Comptroller had correctly concluded that an
installment loan building, operated by First National
across the street from its main office, was a mere extension of the main office and not a branch bank
within the meaning of 12 U.S.C. § 36 (f). After reviewing the factors considered by the Comptroller, which
included such matters as the distance separating the
main banking house and the installment loan building,
the number of intervening structures, the types of physical connection between the main banking house and
the installment loan building, and the economic effect
of the installment loan building on the balance of
competition in the community, the court "found as a
matter of law that the installment loan building does
not constitute a branch bank as contemplated by 12
U.S.C. §36(f)." The state supervisor's appeal from
that decision was pending before the U.S. Court of
Appeals for the Fifth Circuit at year-end.
In Southaven, the district court held, contrary to the
contentions of the state banking supervisor, that the
Comptroller had reasonably construed the branch
banking statutes of Mississippi to permit establishment
of branches within 100 miles of the parent bank. At
year-end, the case was pending on the appeal of ths
plaintiff bank. The state banking supervisor declined
to appeal.
In Driscoll, the state banking supervisor disputed
the Comptroller's refusal to be bound by a State definition of "detached facilities", in determining what constitutes a "branch" for a National bank under federal
law. The district court agreed with the Comptroller's
determination, and granted judgment for the Comptroller, observing:
To permit the Minnesota Legislature to define the Skyway facility as a branch or "detached"
facility and to obligate the Comptroller to apply
that law would permit the legislature to overrule
the prior decision of the Comptroller that it was
not a branch under federal law. Then state, not
federal, law would govern the content of the term
"branch." This would be contrary to the teachings
of [the Supreme Court in First National Bank in
Plant City v.] Dickinson,
The state supervisor has appealed the decision.

18



In First National Bank of Crown Point v. Camp,
463 F.2d 595 (7th Cir. 1972), the court of appeals
affirmed the judgment of the district court in Hammond, Ind., which had upheld the Comptroller's approval of an application by a National bank to establish a branch in an unincorporated town near
Crown Point, Ind. In ruling for the Comptroller, the
Court of Appeals emphasized that the Comptroller's
interpretation of State statutes must be upheld, if reasonable, and that the district court was correct in
declining to conduct a trial de novo on the questions
presented to the Comptroller.
Several issues were raised for the first time in suits
challenging the Comptroller's approvals of branch applications during the year. In Independent Bankers of
Oregon v. Camp, Civil No. 71-528, D. Ore., and Olin
v. Camp, Civil No. 72-535, D. Ore., plaintiffs requested
the district court to invalidate the Comptroller's approval of an automated teller facility established by a
National bank in Oregon, on the theory that Oregon
law does not affirmatively authorize, and consequently
prohibits, such automated tellers at any location other
than the main office of a bank. In Billings v. Camp,
Civil No. 1366-72, D. D.C., and Grenada Bank v.
Camp, Civil No. EC-72-119 S, N.D. Miss., plaintiffs
ask that the Comptroller's approval of branch applications be overturned upon the grounds that the Comptroller allegedly failed to comply with the National
Environmental Policy Act. At year-end, the Independent Bankers and Olin cases were pending on the Comptroller's motion for summary judgment; the Billings
case was pending on appeal by the Comptroller from
an adverse district court determination; and no proceedings had taken place in the Grenada Bank case,
other than the filing of the complaint.
A case challenging the Comptroller's authority to
grant a branch application for a National bank while
there was pending an application to merge that bank
into another bank that would not have authority to
branch at the location proposed, resulted in a district
court judgment for the Comptroller during the year.
Fidelity Trust Co. v. Camp, D. Conn., 337 F. Supp.
1396, appeal pending. The district court concluded that
the Comptroller did not act unreasonably in granting
the branch application without regard to whether or
not the merger should be consummated; and that the
Comptroller's subsequent approval of both the merger
and the retention of the new branch office by the new
bank was likewise not unlawful. At year-end, plaintiff
had appealed the district court judgment to the U.S.
Court of Appeals for the Second Circuit.

H. Authority of Comptroller To
Appraise Value of National
Bank Shares
In Karpf, et al. v. First National Bank of South Jersey and Camp, Civil No. 1020-72, D. N.J., plaintiffs
who had dissented to a merger and received an appraisal of the value of their stock and a payment from
the receiving bank pursuant to 12 U.S.C. § 215a(d),
disagreed with the Comptroller's appraisal and sought
to have the court make a new appraisal. The district
court dismissed the lawsuit, ruling that the Comptroller's appraisal, made "final and binding" by statute, was not subject to judicial review.

/. Bank Merger Act Cases
In 1972, the Comptroller was involved in the litigation of three bank merger cases based on the "potential competition" theory, and also submitted an amicus
curiae brief to the Supreme Court in United States v.
First National Bancorporation, No. 71-703, which also
involved the same theory.
In United States v. United Virginia Bankshares,
Civil No. 85-70-A (D. Va. 1972), Judge Oren R.
Lewis upheld the Comptroller's decision that the acquisition was not violative of the antitrust laws. The
Court held that the acquiring bank holding company
was not a potential entrant into the market except by
the acquisition, and did not exert any influence from
the edge of the market, particularly in light of the
existing competition. Moreover, Judge Lewis said that
it was "somewhat debatable whether the 'potential
competition' theory is applicable to banking." Although
the memorandum opinion was filed on September 8,
1972, the judgment is being held open pending submission of further findings of fact and conclusions of
law, to be argued early next year.
In United States v. The Connecticut National Bank,
Civil No. 14583 (D. Conn.), filed in 1971, the Justice
Department sought to block the consolidation of The
Connecticut National Bank, Bridgeport, Conn., and
The First New Haven National Bank, New Haven,
Conn., alleging that the consolidation would eliminate
both actual and potential competition in violation of
§ 7 of the Clayton Act. The trial in this case lasted from
October 10, 1972, until November 15, 1972, and closing oral arguments are to be heard in early 1973.
In United States v. Marine Bancorporation, Civil




No. 237-71C2 (D. Wash.), also filed in 1971, the Justice Department again sought to block a merger
thought to eliminate potential competition. In that
case, the Department of Justice alleged that the National Bank of Commerce of Seattle, Seattle, Wash.,
was a "potential entrant" into the Spokane area, and
therefore, could not be permitted to acquire Washington Trust Bank, Spokane, Wash. The Comptroller and
the defendant banks maintained that the National
Bank of Commerce was only a "potential entrant"
through the merger, and that de novo entry, suggested
by the Justice Department as a less anticompetitive
means of entry, was not permitted by the State branching law. Furthermore, the Comptroller and the defendants asserted that the procompetitive benefits of
this merger, as considered under the affirmative defense
of convenience and needs provided by the Bank Merger
Act of 1966, clearly outweighed the alleged anticompetitive effects. The trial date has been set for January 8,
1973.
The Comptroller submitted an amicus curiae brief to
the Supreme Court in United States v. First National
Bancorporation, No. 71-703. That case involved the
proposed acquisition of The First National Bank of
Greeley, Greeley, Colo., by the First National Bancorporation, Inc. of Denver, Colo. The Justice Department sought to prevent the merger on the grounds that
the holding company, First National Bancorporation,
was a "potential competitor" of the Greeley bank. Oral
arguments were heard in mid-October and a decision
is expected in early 1973.
By the end of 1972, the Justice Department had lost
all six of its attempts to apply the theory of potential
competition to the banking business. The Comptroller
had intervened in five cases where he had approved
the acquisition, and in each case a Federal District
Judge upheld the Comptroller's decision and dismissed
the Justice Department's complaint.
In another antitrust case where potential competition was not involved, United States v. County National Bank of Bennington, Civil No. 6088 (D. V t ) ,
the parties stipulated all material facts save the sole
legal issue of whether the "Bennington area" is or is
not too insignificant economically, demographically,
and geographically to be a section of the country in a
§ 7 Clayton Act case. On cross motions for summary
judgment, the Court, on January 27, 1972, at 330 F.
Supp. 85, ruled that the "Bennington area" constituted
a "section of the country" for § 7 Clayton Act purposes.
The banks thereafter chose to abandon the merger and
the case became moot.

19

VI. Fiduciary Activities of National Banks
The trust departments of National banks experienced continued growth in numbers of fiduciary accounts and in market value of assets held in 1972. During the year, 37 applications for permits to exercise
fiduciary powers were received from National banks,
and 20 were approved. In addition, six State banks
with trust departments converted to National charters.
Taking into account losses through mergers and consolidations, the number of National banks authorized
to exercise fiduciary powers had, by year-end, risen to
1950.
Against that background, the Comptroller's Office
continued its efforts to carry out its responsibilities in
the most effective manner possible. Training of personnel continued to have a high priority. In May, a
1-week workshop was held for the Representatives-inTrusts, in Washington, D. C. Forty-two representatives
attended from the various regions. The course was divided into two parts, the first was designed to enable
the representatives to keep abreast of regulatory developments, and the second dealt with the supervisory
policies and procedures whereby the responsibilities of
this Office are brought to bear. The first portion drew
upon the assistance of a number of specialists on various topics. The second was conducted by Dr. Henry
Herrell, Management Consultant and Training
Specialist.
Plans were made for a school for Assistants-in-Trusts
and Associates-in-Trusts, early in 1973. It is projected
that there will be a two-part curriculum. The first will
deal with regulatory matters, and will be available to
assistants and associates who have never before attended an Office school. The second will deal with
management supervision, along the lines of the corresponding part of the representatives' workshop, and
will be attended only by the associates. Consistent with
the practice at prior schools, it is expected that State
banking departments will be invited to send examiners
to attend.
During the year, Regulation 9 was amended. Proposed amendments had been published in the Federal
Register in 1971, and were the subject of numerous




comments and criticisms on the part of interested parties. Extensive study was given to the issues raised by
those comments, and, after some modification, the proposals were put into effect in November. Many of the
revisions incorporate, into regulatory form, preexisting
interpretations of the Regulation. Definitions of "fiduciary powers" and "trust department" were amended
to correspond with rulings that had been made as to
permissible activities of National banks. The amendment also made it clear that the Regulation does not
provide any bank the authority to utilize personnel of
other departments to perform fiduciary functions, or
vice versa, where the law prohibits such usage. Another
amendment made clear that a bank can buy an asset
from a trust account where requested to do so by the
Comptroller. Use of a central certificate service was
permitted.
Several changes pertained to collective investment
funds. A general statement of the bank's investment
policy with respect to such funds is now required. In
addition, valuations must, under usual circumstances,
be made within 10 business days. Clarifications of
the requirements necessary for a bank to obtain taxexemption status for its collective investment funds
under the dissimilar requirements of Section 584 of
the Internal Revenue Code and of Revenue Ruling
56-267 were made. Sections referring to common trust
funds for managing agency accounts were deleted to
reflect the fact that the authority for those types of
funds no longer exists. Although the action was not
required by the Supreme Court's holding in the case
of Investment Company Institute vs. Camp, it was
decided that it would be desirable to avoid confusion.
Certain changes in the Regulation were substantive
in nature, primarily those relating to promotion and
advertisement of collective investment funds. Under
the revised rules, a distinction is provided between
traditional common trust funds and pooled employeebenefit trusts, with stricter standards being imposed
upon the former. At the same time, banks were reminded that in the promotion of their collective invest-

21

ment funds they must keep in mind the anti-fraud provisions of the securities laws which are applicable to
such funds, and accordingly they and their counsel
should be alert to avoid any infringement of the standards provided by those laws.
Not adopted, but still under consideration by this
Office, are a number of proposed revisions. Those
include provisions relating to best execution of securities purchases and sales, the application of the common trust fund 10 percent limitations where exceeded
because of withdrawals or market appreciation, and

22



a requirement that requests for admissions and withdrawals be accepted up to the valuation date.
Close attention was given by this Office to the proposed legislation that would enact several substantive
requirements as to transfer agent activity. As that legislation, in the form passed by the Senate, would have
placed a measure of responsibility for its application to
National banks in this Office, preliminary plans were
made for its implementation. Although the bill died
in the closing days of the Congress, it is anticipated that
similar legislation will be enacted in 1973.

VII. International Banking and Finance
Epidemic European inflation, Japanese recession,
the appearance of exchange controls in E.E.C. countries, political uncertainties in Latin America and the
Far East, and rising nationalism in third world countries were only some of the factors National banks had
to contend with in their 1972 international activities.
Also, during that period, the international banking
environment witnessed a soaring of the price of gold,
while the value of pound sterling floated downward.
London branch overhead increased, while loan spreads
narrowed, and Japan's surplus burgeoned as the U.S.
trade deficit widened. Against that background, a variety of adjustments were effected by National banks in
order that their international activities might continue to expand in a profitable manner.
During 1972, 24 National banks opened 56 foreign
branches, and three banks closed 18 branches; a net
increase of 38 branches. The greatest activity continued to be in Nassau, where 16 branches were established, compared to 9 openings during 1971. Since
1966, the total number of National bank foreign
branches has increased from 230 to 566. At year-end,
there were 28 approved, but unopened, branches,
most of which had Cayman Islands locations.
A major method of international expansion by National banks during 1972 was the investment in foreign
financial institutions, either directly, or indirectly
through Edge Act corporations. Such investments were
made on a 100 percent basis, on a consortium basis, or
by partnership agreement. The ownership limitations
in foreign banking laws, as well as the nature of the
market to be served, generally determined the avenue
of investment. At year-end, 48 National banks held
such investments in foreign financial entities.
The International Division also had to adjust in
order to keep abreast of the changes in the international banking environment. Most significant was the
establishment of a London Embassy office staffed by




three National Bank Examiners who are primarily responsible for examining the branches of 20 National
banks operating in London, the United Kingdom, and
on the continent. The greatest concentration of National bank foreign assets continues to be in the U.K.,
and the London office offers the International Division
a more economic and efficient method by which to supervise those branch activities.
In addition to the London effort, 58 men travelled
to 24 countries during 1972 in order to examine the
branches of 16 banks, 184 foreign branch reports of examination were completed during the year. In several
locations, examiners met with the host country's banking officials for mutually beneficial discussions concerning examining techniques and philosophies. In one instance the Italian Central Bank examiners and National Bank Examiners conducted a joint examination.
Finally, a National Bank Examiner, specializing in
electronic data processing, travelled overseas this year
to examine foreign branch computer functions.
During 1972, the International Division also continued to play an educational role in international banking supervision. As in previous years, foreign bankers
and foreign bank supervisors visited the division seeking information on examining procedures, legal matters, and international trends and developments. Copies
of the Comptroller's Manual for National Banks, and
the Comptroller's Handbook of Examination Procedures were sent to several foreign banking supervisors
in response to their requests. In the spring the International Division began the "International Report,"
which contains media clippings, trade articles, and
treatises on international financial affairs. That publication is circulated weekly to field examiners as well
as to staff members of the Federal Reserve System and
this Office. During July, four examiners received intensive training at the American Bankers Association
school for International Banking.

23

V I I I . Administrative and Management
Developments
During 1972, many actions were taken to strengthen
the internal administrative operations of the Office.
Efforts to streamline procedures and maintain reasonable employment and cost figures contributed to realizing significant improvements.
The cost of operating the Comptroller's Office continued to be a matter of concern to management in
view of the general economic environment. The Fiscal
Management Division provided the necessary cost data
that allowed management to continue the cost control
program and assess its effectiveness. As a result, expenses for 1972 rose only 6.65 percent over 1971, which
is significantly below the 1971 and 1970 increases of
11.03 percent and 18.84 percent, respectively.
The change in the method of investing assessment
funds initiated in July 1971 produced additional interest income of $194,000 through December 1972. While
only small gains were realized in total interest income
during 1971 and 1972 due to lower Treasury bill yields,
the Office would have experienced decreases in those
years had there not been a change in investment policy.
Further refinements were made to the cost accounting system during 1972; more definite guidelines were
established for the allocation of operating costs to the
various organizational segments. Additionally, fixed
asset records were computerized to provide more comprehensive data with respect to depreciation and identication of individual items.
Late in 1972, the Fiscal Management Division began
converting its manual record of total branches by bank
to an automated record. That automated record, scheduled for completion early in 1973, will facilitate the
audit of branch assessments paid by National banks.
Through a reorganization in mid-1972, the travel
expense voucher payment and audit functions were
combined to provide for more efficient and expeditious
processing of travel claims.
Through the Comptroller's personnel management
evaluation program, several personnel practices were
improved in 1972. Efforts were concentrated in the




areas of staffing and manpower utilization, equal employment opportunity, communications, and training.
The personnel management evaluation system is intended to assess and improve personnel programs and
systems. It also is intended to identify and resolve basic
personnel management issues. The evaluation activities
have had a favorable impact on our personnel management, primarily at the regional level, as a direct result
of on-site visits.
The Office continued to operate under personnel
ceilings in 1972, thus creating the necessity for quality
staffing and effective manpower utilization. In an
effort to determine bank examiner positions, staffing
patterns were developed for several additional regions.
Based upon a systematic analysis of workload, manpower and skill requirements were projected for those
regions.
Results of the cooperative-education program have
been excellent. There were approximately 110 financial
interns on the rolls at the end of 1972. Approximately
25 percent of the financial interns are minority group
members. The program is designed to train and develop college students for future bank examiner positions, and has proved to be an effective means of
recruiting minority personnel.
Dramatic results were realized in the equal employment opportunity program. Our 1972 survey showed
we had approximately 180 minority employees on the
rolls. We experienced an increase of 55 percent in total
minority examiner personnel, and an increase of 21
percent in field minority support personnel, during
1972. Approximately 90 women are employed in examiner positions. Forty percent of all employees in the
Washington headquarters office are minority group
members and 50 percent are females.
The need for a more uniform and equitable program
for appointing, testing, and promoting assistant associate examiners was realized during the personnel
management evaluation process. To correct those problems, guidelines were issued recently. Implementation

25

of those guidelines on a uniform basis throughout all
regions will provide a career ladder for examiners from
entrance level to commissioned level, and will create
a uniform policy for appointing, testing, and promoting all assistant and associate examiners. It also will
shorten the normal time requirement for commissioning, and grade promotions will be related to progress
demonstrated by each examiner in assuming increased
responsibilities.
To improve communication channels between management and examiners, several regional administrators
conducted periodic visits to banks with examinations
in progress. Those visits included informal interviews
and discussions with groups of examiners.
Significant progress also was made in meeting new
priorities established in 1972. Special emphasis was
given the grade de-escalation program. In an effort to
reduce the average grade, positions were filled at lower
grade levels, jobs were left vacant unless absolutely
necessary, and jobs were combined wherever possible.
Effort was made during the year to reduce the time
required to prepare various statistical reports by simplifying worksheets, organizing base data more effectively, and refining terminology. Better internal
reconcilement procedures and controls made more
accurate reporting possible. Greater productivity was
made possible by introduction of a pre-appointment
package system, providing new employees with necessary appointment forms and orientation material before their entrance on duty.
Surveys were conducted reviewing individual positions in a number of divisions throughout the year, particularly in the Bank Organization Division. Regional
positions also were evaluated and a formal review of
official titling practices for headquarters was completed
for the first time.
A cost reduction resulted from changing the rate of
pay for new assistant examiners from grade 6 to 5, prior
to 1972. Tangible and measurable cost reductions as a
result of the incentive awards program saved $47,838.
Thirty-one awards were granted for adopted suggestions and special achievements. High quality increases
were approved for 96 employees in recognition of their
superior performance.
High priority continues to be given to the training
and development of examiners. After an initial orientation program, formal training is given to assistant examiners and financial interns. Training is given in accrual accounting, bank investments, monetary and
fiscal policies, and related topics. That is supplemented
through correspondence courses. Specialized schools
are held in the EDP and trust areas. Examiners are re-

26



ceiving training in electronic data processing to enable
them to examine automated banks more efficiently.
The course reviews basic principles of data processing
and analyzes potential problem areas in bank data
centers in order to help the examiners gain a better
understanding of automated bank applications. A trust
school was held in the fall of 1972 for all Representatives-in-Trust, to review trust examination procedures.
Topics included proposed amendments to Regulation
9, current developments, restricted securities, stock
transfer problems, reports of examination, and supervision. The National Bank Examiner school continues
to be of prime importance to the career development
of newly-commissioned National Bank Examiners.
Those schools cover all aspects of commercial bank
examinations. To enhance their effectiveness, selected
examiners also attend graduate schools of banking.
The administrative responsibilities of Representatives-in-Trust and National Bank Examiners in such
areas as performance evaluation, grievances, employee
development, leave, pay recommendations, counseling, training, etc., were defined by developing supervisory handbooks. In one region a supervisory training course was held for National Bank Examiners. As
part of a Representatives-in-Trust workshop held in
the fall of 1972, a week of supervisory training was
conducted to clearly define their role as supervisors.
Through those efforts, participants examined the
principles and practices of supervising employees and
the managerial functions of planning, scheduling, organizing, and controlling. Those concepts were then
related to practical supervisory and management experience.
Better quality of service to employees is expected as
a result of hiring an employee relations specialist and
issuing a formal grievance system and leave policy for
Washington employees.
In 1972, the Administrative Services Division continued to meet the organization's needs for support
services in an efficient manner. A major task has been
the search for suitable office space in which to relocate
and consolidate all Washington offices and personnel.
That project is of great significance, and the ultimate
relocation should increase the effectiveness of operations in headquarters. Space management in the field
also continued active, with the relocation of four subregional offices, the establishment of two additional offices, and the elimination of one.
The staff of the Records Management Branch completed a program of visiting each regional headquarters office in 1972. The purpose of the program was to

assist field personnel in a continuing effort to tighten
control of records and correspondence and to better
utilize space and file equipment. Considerable success
and progress was achieved.
The Supply, Printing, and Services Branch underwent a significant reorganization during the year. As
a result of an extensive survey, personnel classifications
were re-evaluated and redesigned to more realistically
reflect work assignments, and the organizational structure was modified to reflect the changed responsibilities.
A preliminary effort was made to evaluate the Office's internal capability of furnishing more information
to the public. If developments occur as anticipated, it
is probable that additional capability will be necessary.
Procurement activity consisted primarily of upgrading much of the office machine inventory, principally
in the regions, and changing several copying machines
to accommodate a need for greater and faster output.
Also, initial steps were taken to introduce electronic
calculators into our equipment inventory on a large
scale.

501-017 0—73

a




The Internal Audit Division made comprehensive
reviews in five regional offices *and one of the six computerized payroll centers in addition to operational
and management reviews in Washington. The audit
reports contained 62 recommendations of which 50
were accepted.
The program of professional development initiated
in 1969 for the Internal Audit staff was continued in
1972 through attendance at seminars sponsored by
professional associations. The staff attended five different seminars relating to concepts and techniques of
the modern audit function.
In 1972, the Management Services Division participated in several government-wide programs, among
them a revised management review and improvement
program and a feasibility study of measuring productivity in the federal sector. Additionally, data processing support for other functional areas continued to
increase in scope and variety of applications. The
Office's management improvement program contributed substantial tangible savings and improved operations procedures.

27

I X . Financial Operations of the Office of the
Comptroller of the Currency
Total income for the year was $44.9 million, an increase of 10.76 percent over 1971. The percentage
increase in income approximates the 1971 increase,
when the growth rate was 10.08 percent. The increase
in total income is primarily due to the $3.4 million
rise in assessment income, resulting from a $35.5 billion
rise in National bank assets. National bank assets affecting 1972 assessment income rose 10.43 percent, compared to an increase of 8.55 percent in the previous
year.
Revenues from trust examinations totaled $2,323,000, for an increase of $88,000. There were 1,660 examinations made in 1972, compared to 1,665 in 1971.
Branch investigations were up sharply, with an increase
in income of $104,000. One thousand one hundred and
eight branch applications were received in 1972, compared to 872 in 1971. New bank charter revenues increased by $295,000, while merger and consolidation
fees increased by $169,000. There were 293 new bank
charter applications in 1972, compared to 182 in 1971,
and the number of bank merger applications increased
to 155, compared to 103 in 1971.
Interest on investments increased only $20,000 to a
total of $1,886,000, but continues to be a prominent
income factor. The substantial decline in Treasury bill
yields prior to 1971 continued to have its effect on
interest income through 1972. However, a change in
our investment policy has yielded rewarding results to
the extent that if that policy had not been instituted,
interest income would have declined during the last 2
years.
As a result of hurricane Agnes, during the summer
of 1972, some of the bank regulatory agencies provided
assistance, on a reimbursable basis, to the Small Business Administration in processing applications under
the flood disaster program. The assistance provided




by the Comptrollers' Office resulted in the SBA reimbursing this Office for $344,000 for costs incurred by us.
All other income categories remained at substantially
the same levels when compared to 1971.
Total expenses amounted to $40.5 million, compared
to $38.0 million for 1971, an increase of $2.5 million.
That amounts to a 6.65 percent increase for 1972.
That significant decrease in the percentage growth of
expenditures represents a reduction of more than 4
percent, compared to 1971, and 12 percent, compared
to 1970. Moreover, this is the first time in several
years that the percentage growth in expenditures has
not exceeded the percentage growth in revenues, and
represents the culmination of management's conscious
efforts to control expenditures.
Salaries, personnel benefits, and travel expenses
amounted to $38.2 million, or 94.4 percent of the total
expenses for the year. Those same expenses amounted
to $35.7 million, in 1971. A 5.5 percent across-theboard pay raise, effective January 1972, was the principal reason for the rise in those expenses. Travel
expense totaled $5.7 million, and remained at the same
level as 1971. Several new subregional offices were
established during 1971 and 1972, and provided some
cost savings which offset what would otherwise have
been an increase in travel expense.
The remaining expenses totaled $2,249,000, an increase of $33,000 over the previous year. The most
significant increase in that area is the result of liberalizing allowances paid to employees when they relocate
for the benefit of the office.
The equity account is in reality a reserve for contingencies. Transfers of $4.4 million increased the
equity to $27.0 million at year-end. That represents
7.8 months' reserve for operating expenses, based on
the level of expenses over the last 6 months of 1972.

29

TABLE 11
OFFICE OF THE COMPTROLLER OF THE CURRENCY
BALANCE SHEETS
Assets
Current assets:
Cash
Obligations of U.S. Government, at cost adjusted for amortization of discount and premium
(approximates market value)
Accrued interest on investments
Accounts receivable (Note 4)
Travel advances
Prepaid expenses and other assets

December 31
1972
1971

21, 667, 965

20, 742, 646
863, 620
424, 288
1,287,908
671, 564

593, 106

616, 344

$33, 085, 311

Total assets

8, 177, 159

718, 946

Less accumulated depreciation

6, 737, 958
516, 399
169, 056
406, 105
82, 655

1,312,052

Fixed assets, at cost (Note 1):
Furniture and fixtures
Office machinery and equipment

9, 089, 412
562, 287
499, 139
435, 817
74, 822

868, 440
443, 612

Long-term obligations of U.S. Government, at cost adjusted for amortization of discount and
premium (approximates market value)

$264,986

10, 824, 240

Total current assets

$162,763

$29, 536, 149

$193, 194
133, 536
857, 838

$178, 452
83, 279
1, 973, 677

1, 184, 568
2, 208, 146
2, 706, 358

2, 235, 408
2, 050, 012
2, 705, 391

6, 099, 072
26, 986, 239

6, 990, 811
22, 545, 338

$33, 085, 311

$29, 536, 149

Liabilities and Comptroller's Equity
Current liabilities:
Accounts payable and other accruals
Taxes and other payroll deductions
Accrued travel and salaries
Total current liabilities
Accumulated annual leave
Closed receivership funds (Note 2)
Total liabilities
Comptroller's equity commitments and contingencies (Note 3)
Total liabilities and Comptroller's equity

See Notes at end of Section.

30



TABLE

12

OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENTS OF REVENUE, EXPENSES AND COMPTROLLER'S EQUITY
Year Ended December 31
1972
1971*
Revenue (Note 1):
Semi-annual assessments
Examinations and investigations
Investment income
Examination reports sold
Other (Note 4)

$37, 824, 450 $34, 439, 052
4, 335, 914
3, 661, 012
1, 886, 494
1, 866, 431
490, 355
517, 680
380, 501
69, 741

Excess of revenue over expenses
Comptroller's equity at beginning of year
Comptroller's equity at end of year

44, 917, 714

40, 553, 916

29, 998, 319
3, 840, 710
2, 538, 394
1, 850, 070
608, 819
445, 849
248, 478
205, 521
204, 012
129, 458
124, 937
80, 953
18, 202
183, 091

27, 705, 837
3, 862, 031
2, 336, 534
1, 832, 729
495, 313
408, 988
139, 127
233, 225
274, 440
121, 807
128, 722
92, 254
42, 787
122, 000
157, 573

40,476,813

Expenses:
Salaries
Per diem
Retirement and other contributions (Note 3)
Travel
Rent and maintenance (Note 3)
Communications
Moving and shipping
Employee education and training
Printing, reproduction and subscriptions
Office machine repairs and rentals
Depreciation
Supplies
Remodeling
Grant to Presidential Commission on Financial Structure and Regulation
Other

37,953,367

4, 440, 901
22, 545, 338

2, 600, 549
19, 944, 789

$26, 986, 239 $22, 545, 338

See Notes at end of Section.
•Reclassified to conform with 1972 presentation.




31

TABLE 13
OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENTS OF CHANGES IN FINANCIAL POSITION
Year Ended December 31
1972
1971
Financial resources were provided by:
Excess of revenue over expenses
Add charges and credits not affecting working capital in the period:
Additions to accumulated annual leave
Depreciation
Amortization of premium and accretion of discount on long-term U.S. Government
obligations (net)
Net loss on sales of fixed assets
Working capital provided by operations for the period
Long-term U.S. Government obligations:
Redeemed
Transferred to current assets
Proceeds received on sales of fixed assets

$4, 440, 901

$2, 600, 549

369, 635
124, 937

347, 562
128, 722

(4, 066)
2, 111

17, 923
12, 656

Increase (decrease) in working capital

218, 881

3, 331, 030

12, 830, 323
211, 501
106, 129
(967)

3, 695, 032
137, 793
72, 255
1, 292
3, 906, 372

$3, 697, 921

Total

7, 848, 067
4, 061, 003
2, 319

13, 146, 986

Financial resources were used for:
Purchase of long-term U.S. Government obligations
Payments of accrued annual leave
Purchase of fixed assets
Net receivership fund disbursements (receipts)

3, 107, 412

16, 844, 907

Total

4, 933, 518

($575, 342)

4, 737

Analysis of Changes in Working Capital
Increase (decrease) in current assets:
Cash
Obligations of U.S. Government
Accrued interest
Accounts receivable
Travel advances
Prepaid expenses and other assets

32



(347, 828)

(14, 742)
(50, 257)
1, 115, 839

33, 171
(11, 664)
(249, 021)

1,050,840
Increase (decrease) in working capital

$197, 111
(505, 457)
61, 329
(111, 383)
(2, 047)
12, 619

2, 647, 081
(Increase) decrease in current liabilities:
Accounts payable and other accruals
Taxes and other payroll deductions
Accrued travel and salaries

($102,223)
2, 351, 454
45, 888
330, 083
29, 712
(7, 833)

(227,514)

S3, 697, 921

($575, 342)

OPINION OF INDEPENDENT ACCOUNTANT
To the Comptroller of the Currency
Office of the Comptroller of the Currency
In our opinion, the accompanying balance sheets, the related statements of
revenue, expenses and Comptroller's equity and the statements of changes in financial
position present fairly the financial position of the Office of the Comptroller of the
Currency at December 31, 1972 and 1971, the results of its operations and the changes
in financial position for the years then ended, in conformity with generally accepted
accounting principles consistently applied. Our examinations of these statements were
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, including confirmation of securities
owned by correspondence with the depositary.
PRICE WATERHOUSE & CO.
WASHINGTON,

D.C.

January 31, 1973.

Note 3—Commitments and Contingencies

NOTES TO FINANCIAL STATEMENTS

Note 1—Organization

and Accounting

Policies

The Office of the Comptroller of the Currency was created
for the purpose of establishing and regulating a National
Banking System. The National Currency Act of 1863, rewritten and reenacted as The National Banking Act of 1864,
created the Comptroller's Office, provided for its supervisory
functions and the chartering of banks. The revenue of the
Comptroller's Office is derived principally from assessments
paid by the National banks and interest on investments in
U.S. Government obligations. Assessments paid by National
banks are not construed to be government funds. No funds
derived from taxes or Federal appropriations are allocated to
or used by the Comptroller's Office in any of its operations.
The accounts of the Comptroller's Office are maintained on
the accrual basis. Fixed assets are depreciated on the
straight-line basis principally over an estimated useful life
of 10 years.
Note 2—Closed Receivership Funds
This amount represents a liability for unclaimed depositors'
account balances, resulting principally from the failure and
closing of certain National banks during the 1930's. At such
time the assets of the banks were transferred to the custody
of the Comptroller's Office to be held in trust for their
depositors. These funds have been invested in government
securities pending claim by depositors.




Regional and sub-regional offices of the Comptroller of
the Currency lease office space under agreements which
expire at varying dates through 1981. As of December 31,
1972, total lease commitments for these offices approximated
$600,000 annually. The Washington, D.C. office and certain
regional offices located in Federal Government facilities are
occupied on a rent-free basis.
The Comptroller's Office contributes to the Civil Service
Retirement plan for the benefit of all of its eligible employees.
Contributions aggregated $2,037,847 and $1,903,601, respectively, in 1972 and 1971. The plan is participatory, with
7% of salary being contributed by each party.
Various banks in the District of Columbia have deposited
securities with the Comptroller's Office as collateral for those
banks entering into and administering trust activities. These
securities are not assets of the Comptroller's Office and
accordingly are not included in the accompanying financial
statements.
Note 4—Assistance to the U.S. Small Business

Administration

During 1972 the Comptroller's Office assisted the Small
Business Administration in the processing of flood disaster
loan applications. The Small Business Administration has
agreed to reimburse the Comptroller's Office for salaries and
other expenses of approximately $344,000 relating to this
assistance.

33




APPENDIX A

Merger Decisions, 1972

Merger* Decisions, 1972
/. Mergers consummated, involving two or more operating banks
Jan. 1, 1972:
National Bank of Alaska, Anchorage, Alaska
Bank of Petersburg, Petersburg, Alaska
Merger
Jan. 3, 1972:
Wachovia Bank and Trust Company, N.A.,
Winston-Salem, N.C.
First State Bank, Reidsville, N.C.
Merger
Jan, 14, 1972:
The Bridgeton National Bank, Bridgeton, N.J.
Citizens National Bank of South Jersey, Woodbine,

N.J.
Merger
Jan. 21, 1972:
North Carolina National Bank, Charlotte, N.C.
The Banner Elk Bank, Banner Elk, N.C.
Merger
Feb. 25, 1972:
The National State Bank, Elizabeth, N.J.
Trenton Trust Company, Trenton, N.J.
Merger
Mar. 10, 1972:
American National Bank, Bakersfield, Calif.
San Joaquin Valley National Bank, Tulare, Calif.
Merger
Mar. 17, 1972:
The First-Hardin National Bank of Elizabeth town,
Elizabethtown, Ky.
Bank of Sonora, Sonora, Ky.
Purchase
Mar. 17, 1972:
Peoples National Bank of New Jersey, Westmont,

Page
41

42

44

45

46

48

50

N.J.
The First National Bank of Woodstown, Woodstown, N.J.
Consolidation
Mar. 17, 1972:
Peoples National Bank of Washington, Seattle,
Wash.
Olympic National Bank, Port Angeles, Wash.
Purchase
Mar. 17, 1972:
The St. Lawrence County National Bank, Canton,
N.Y.
Bank of Gouverneur, Gouverneur, N.Y.
Merger
Mar. 20, 1972:
National Bank of Commerce of Seattle, Seattle,
Wash.
Oroville State Bank, Oroville, Wash.
Purchase
Mar. 31, 1972:
First City National Bank of Binghamton, N.Y.,
Binghamton, N.Y.
The Chenango County National Bank and Trust
Company, Norwich, N.Y.
Merger

51

52

54

55

56

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

36




May 1, 1972:
Page
Citizens & Northern National Bank and Trust
Company, Towanda, Pa.
The First National Bank of Ralston, Ralston, Pa.
Consolidation
57
May 1, 1972:
Bellefontaine National Bank, Bellefontaine, Ohio
The Belle Center Bank Company, Belle Center,
Ohio
Purchase
59
May 1, 1972:
The First National Bank of San Jose, San Jose,
Calif.
Commercial National Bank of San Leandro, San
Leandro, Calif.
Merger
60
May 5, 1972:
Bank of North Carolina, National Association,
Jacksonville, N.C.
Bank of Winston-Salem, Winston-Salem, N.C.
Merger
61
May 5, 1972:
North Carolina National Bank, Charlotte, N.C.
Carolina Bank of Commerce, Eden, N.C.
Merger
62
May 5, 1972:
Security National Bank, Huntington, N.Y.
Royal National Bank of New York, New York,
N.Y.
Merger
64
May 6, 1972:
Western Pennsylvania National Bank, Pittsburgh,
Pa.
Economy Bank of Ambridge, Ambridge, Pa.
Purchase
66
May 19, 1972:
Crocker National Bank, San Francisco, Calif.
The First National Bank of Upland, Upland, Calif.
Purchase
67
June 5, 1972:
The Farmers National Bank of Lititz, Lititz, Pa.
The First National Bank of Intercourse, Intercourse,
Pa.
Consolidation
68
June 9, 1972:
First National Bank & Trust Co., Washington, Pa.
Community Bank of Pittsburgh, Pittsburgh, Pa.
Purchase
69
June 23, 1972:
First National State Bank of North Jersey, Hackensack, N.J.
Ridgefield Park Trust Company, Ridgefield, N.J.
Merger
70
June 27, 1972:
The Union National Bank of Youngstown, Youngstown, Ohio
The North Bloomfield Banking Company, North
Bloomfield, Ohio
Merger
72

June 30, 1972:
Central National Bank, Canajoharie, Canajoharie,
N.Y.
The First National Bank of Edmeston, Edmeston,
N.Y.
Merger
June 30, 1972:
Jefferson National Bank, LaFargeville, N.Y.
The Waddington Bank, Waddington, N.Y.
Bank of Philadelphia, Philadelphia, N.Y.
Merger
June 30, 1972:
The National Bank of Boyertown, Boyertown, Pa.
The First National Bank of Oley, Oley, Pa.
Merger
July 14, 1972:
United States National Bank, San Diego, Calif.
Beverly Hills Fidelity Bank, Beverly Hills, Calif.
Purchase
July 15, 1972:
Peoples National Bank of Washington, Seattle,
Wash.
Bothell State Bank, Bothell, Wash.
Merger
July 17, 1972:
Farmers First National Bank, Lititz, Pa.
The Farmers National Bank of Ephrata, Ephrata,
Pa.
Merger
July 28, 1972:
North Carolina National Bank, Charlotte, N.C.
The Farmers Bank, Woodland, N.C.
Merger
Aug. 15, 1972:
The First National Bank of Newark, Newark,
Ohio
The Johnstown Bank, Johnstown, Ohio
Merger
Aug. 18, 1972:
The Monmouth County National Bank, Red Bank,
Red Bank, N J .
The First National Bank of Hightstown, Hightstown, N.J.
Merger
Aug. 31, 1972:
Colonial National Bank, Haddonfield, N.J.
Elmer Bank & Trust Company, Elmer, N.J.
Consolidation
Aug. 31, 1972:
First Mississippi National Bank, Hattiesburg, Miss.
Lumberton State Bank, Lumber ton, Miss.
Merger
Sept. 5, 1972:
First Security Bank of Utah, National Association,
Ogden, Utah
North Davis Bank, Lay ton, Utah
Merger
Sept. 8, 1972:
Bank of North Carolina, National Association,
Jacksonville, N.C.
Bank of Hobbsville, Hobbsville, N.C.
Merger
Sept. 11, 1972:
National Bank of the Commonwealth, Indiana, Pa.
Farmers & Merchants Bank of Cherry Tree,
Cherry Tree, Pa.
Purchase
Sept. 20, 1972:
National Bank of Commerce in Superior, Superior,
Wis.
Poplar State Bank, Poplar, Wis.
Purchase
Sept. 29, 1972:
First National Bank of Central Jersey, Somerville,

Page

73

74

76

77

71

79

80

82

83

85

87

89

90

92

93




Page

96

97

99

101

102

103

105

106

107

108

110

Ill

112

114

NJ.

N.J.
First Clinton National Bank, Clinton, N.J.
Consolidation

Sept. 29, 1972:
Maine National Bank, Portland, Me.
The Kezar Falls National Bank, Parsonsfield (P.O.
Kezar Falls), Me.
Merger
Sept. 29, 1972:
Old National Bank of Washington, Spokane,
Wash.
The First National Bank of Ferndale, Ferndale,
Wash.
Purchase
Sept. 30, 1972:
First National Bank of Mercer County, Celina,
Ohio
The Rockford National Bank, Rockford, Ohio
Merger
Sept. 30, 1972:
The Canton National Bank, Canton, Ohio
The Mount Union Bank, Alliance, Ohio
Merger
Sept. 30, 1972:
The First National Bank of Aurora, Aurora, Ind.
Dillsboro State Bank, Dillsboro, Ind.
Merger
Oct. 2, 1972:
The First National Bank of Sunbury, Sunbury, Pa.
The First National Bank of Mount Carmel, Mount
Carmel, Pa.
Merger
Oct. 16, 1972:
National Bank of North America, New York
(Jamaica), N.Y.
The National Bank of Far Rockaway, New York
(Far Rockaway), N.Y.
Consolidation
Oct. 18, 1972:
First Union National Bank of North Carolina,
Charlotte, N.C.
North Mecklenburg Bank, Cornelius, N.C.
Merger
Oct. 20, 1972:
Bank of North Carolina, National Association,
Jacksonville, N.C.
The Farmers Bank of Seaboard, Seaboard, N.C.
Merger
Oct. 20, 1972:
The Oneida National Bank and Trust Company of
Central New York, Utica, N.Y.
The First National Bank of Central Square,
Central Square, N.Y.
Merger
Nov. 24, 1972:
Vermont National Bank, Brattleboro, Vt.
Ethan Allen National Bank, Fair Haven, Vt.
Merger
Nov. 29, 1972:
The Citizens National Bank of Urbana, Urbana,
Ohio
The Bank of North Lewisburg Company, North
Lewisburg, Ohio
Merger
Dec. 1, 1972:
First National Bank, Slidell, La.
Commercial Bank & Trust Company, Covington,
La.
Consolidation
Dec. 15, 1972:
North Carolina National Bank, Charlotte, N.C.
The Bank of New Bern, New Bern, N.C.
Merger
Dec. 22, 1972:
The National Bank of New Jersey, New Brunswick,

94

Suburban Trust Company, Westfield, N J .
Merger

115

37

Dec. 28, 1972:
Bank of North Carolina, National Association,
Jacksonville, N.G.
North State Bank, Burlington, N.C.
Merger

Page

117

Dec. 29, 1972:
Bay State National Bank, Lawrence, Mass.
First Bank and Trust Company of Haverhill,
Haverhill, Mass.
Second Bay State National Bank, Lawrence, Mass.
Merger

Page

119

/ / . Mergers consummated, pursuant to corporate reorganization
Jan. 1, 1972:
American National Bank & Trust, Montclair, N.J.
The Second American National Bank, Montclair,

N.J.
Merger
Jan. 1, 1972:
Third National Bank in Nashville, Nashville,
Tenn.
Fourth and Church Street National Bank, Nashville,
Tenn.
Merger
Jan. 3, 1972:
Merchants National Bank & Trust Company of
Indianapolis, Indianapolis, Ind.
Meridian National Bank, Indianapolis, Ind.
Merger
Jan. 5, 1972:
The Alamo National Bank of San Antonio, San
Antonio, Tex.
Alamo Bank, National Association, San Antonio,
Tex.
Merger
Jan. 18, 1972:
The Union National Bank of Troy, Troy, N.Y.
Union National Bank, Albany, N.Y.
Merger
Jan. 31, 1972:
Tappan Zee National Bank, Nyack, N.Y.
The Bank of Tappan Zee, N.A., Nyack, N.Y.
Merger
Jan. 31, 1972:
The American National Bank in Portage, Portage,
Mich.
The Portage Branch of The American National
Bank and Trust Company, Kalamazoo, Mich.
Purchase . .
Jan. 31, 1972:
The American National Bank and Trust Company
of Michigan, Kalamazoo, Mich.
The American Bank of Michigan, National Association, Kalamazoo, Mich.
Merger
Feb. 3, 1972:
The First National Bank of Birmingham, Birmingham, Ala.
Jefferson County National Bank, Birmingham,
Ala.
Merger
Feb. 15, 1972:
Hutchinson National Bank and Trust Company,
Hutchinson, Kans.
Polaris National Bank, Hutchinson, Kans.
Merger
Mar. 3, 1972:
Eastern National Bank of Long Island, Smithtown,
N.Y.
East Bank, N.A., Smithtown, N.Y.
Merger
Mar. 31, 1972:
The First National Bank of Grand Island, Grand
Island, Nebr.
First National Bank in Grand Island, Grand
Island, Nebr.
Merger

38



121

122

122

123

124

124

125

126

127

127

128

129

Apr. 3, 1972:
National Bank of Commerce of San Antonio, San
Antonio, Tex.
Bank of Commerce, National Association, San
Antonio, Tex.
Merger
Apr. 3, 1972:
The State National Bank of El Paso, El Paso, Tex.
State Bank, National Association, El Paso, Tex.
Merger
Apr. 7, 1972:
Zions First National Bank, Salt Lake Citv, Utah
Zions Bank, N.A., Salt Lake City, Utah
Merger
Apr. 10, 1972:
The Silver Creek National Bank, Silver Creek, N.Y.
Citibank (Western), National Association, Silver
Creek, N.Y.
Merger
Apr. 13, 1972:
New Jersey Bank (National Association), Clifton,

129

130

131

131

N.J.
Second New Jersey Bank (National Association),
Clifton, N.J.
Merger
Apr. 28, 1972:
The City National Bank of Millville, Millville, N.J.
The Second National Bank of Millville, Millville,

1$2

NJ.

Merger
May 1, 1972:
Clermont National Bank, Milford, Ohio
The F.B.G. National Bank of Milford, Milford,
Ohio
Merger
May 1, 1972:
Madison National Bank, Madison, N.J.
New Madison National Bank (Madison, N.J.),
Madison, N.J.
Merger
May 1, 1972:
The Bank of California, National Association, San
Francisco, Calif.
B.C. National Bank, San Francisco, Calif.
Merger
May 18, 1972:
Long Point National Bank of Houston, Houston,
Tex.
Long Bank, National Association, Houston, Tex.
Merger
June 8, 1972:
State Bank of Honeoye Falls, Honeoye Falls, N.Y.
Citibank (Mid-Western), National Association,
Honeoye Falls, N.Y.
Merger
June 26, 1972:
Continental National Bank of Fort Worth, Fort
Worth, Tex.
Continental Bank, National Association, Fort
Worth, Tex.
Merger
June 30, 1972:
Citizens National Bank, Englcwood, N.J.
New Citizens National Bank, Englewood, N.J.,
Englewood, N.J.
Merger

133

134

134

136

136

137

138

139

June 30, 1972:
Security Pacific National Bank, Los Angeles, Calif.
SECPAC National Bank, Los Angeles, Calif.
Merger
June 30, 1972:
The South Carolina National Bank of Charleston,
Charleston, S.C.
Security National Bank, Charleston, S.C.
Merger
July 1,1972:
Rockingham National Bank, Harrisonburg, Va.
Rockingham Bank, N.A., Harrisonburg, Va.
Merger
July 1,1972:
Union Planters National Bank of Memphis,
Memphis, Tenn.
Union Planters Bank, National Association,
Memphis, Tenn.
Merger
July 3, 1972:
First & Merchants National Bank of the Peninsula,
York County (P.O. Williamsburg), Va.
Six Branches of First & Merchants National Bank,
Richmond, Va.
Purchase
July 10, 1972:
Virginia National Bank, Norfolk, Va.
Virginia Bank, N.A., Norfolk, Va.
Merger
July 14, 1972:
The Security National Bank of Trenton, Trenton,
N.J.
First National State Bank of Central Jersey,
Trenton, N.J.
Merger
July 24, 1972:
The Kingsport National Bank, Kingsport, Tenn.
The National Bank of Kingsport, Kingsport,
Tenn.
Merger
Aug. 7, 1972:
The First National Bank of Fort Worth, Fort
Worth, Tex.
Burnett Plaza National Bank of Fort Worth, Fort
Worth, Tex.
Merger
Aug. 8, 1972:
The Livestock National Bank of Kansas City,
Kansas City, Mo.
Livestock Bank of Kansas City, National Association, Kansas City, Mo.
Merger
Aug. 31,1972:
First National Bank of Bay Shore, Bay Shore, N.Y.
First Bank of Bay Shore, National Association, Bay
Shore, N.Y.
Merger
Aug. 31, 1972:
Northeast National Bank of Fort Worth, North
Richland Hills (P.O. Fort Worth), Tex.
First National Bank of North Richland Hills,
North Richland Hills, Tex.
Merger
Sept. 2, 1972:
Inter National Bank of Miami, Miami, Fla.
INB National Bank of Miami, Miami, Fla.
™C\%r2
s
kept.oiy/^.
The National Exchange Bank of Castleton-onHudson, Castleton-on-Hudson, N.Y.
Citibank (Eastern), National Association, Castletonon-Hudson, N.Y.
Merger
Sept. 14, 1972:
Douglas National Bank, Roseburg, Oreg.
D.B. National Bank, Roseburg, Oreg.
Merger



Page
139

140

141

141

142

143

144

145

146

147

148

149
149

150

151

Sept. 25, 1972:
Page
The Central National Bank at Cambridge, Cambridge, Ohio
Cambridge National Bank, Cambridge, Ohio
Merger
152
Sept. 29, 1972:
The First National Bank and Trust Company of
Ravenna, Ravenna, Ohio
The F.B.G. National Bank of Ravenna, Ravenna,
Ohio
Merger
153
Sept. 29, 1972:
The Liberty National Bank of Fremont, Fremont,
Ohio
F.B.G. National Bank of Fremont, Fremont, Ohio
Merger
154
Sept. 30, 1972:
First National Bank of Decatur, Decatur, Ala.
Decatur National Bank, Decatur, Ala.
Merger
155
Sept. 30, 1972:
American National Bank & Trust Company of
Mobile, Mobile, Ala.
Mobile County National Bank, Mobile, Ala.
Merger
156
Oct. 10, 1972:
The First National Bank of Port Arthur, Port
Arthur, Tex.
First Bank, National Association, Port Arthur, Tex.
Merger
157
Oct. 12, 1972:
The American National Bank of Beaumont, Beaumont, Tex.
Park Street Bank National Association, Beaumont,
Tex.
Merger
158
Oct. 17, 1972:
Third National Bank of Hampden County, Springfield, Mass.
Third Bank of Hampden County (National Association), Springfield, Mass.
Merger
159
Oct. 31, 1972:
City National Bank of Detroit, Detroit, Mich.
CNB National Bank, Detroit, Mich.
Merger
159
Oct. 31, 1972:
First National Bank of Canton, Canton, Ohio
The Stark County National Bank, Canton, Ohio
Merger
160
Nov. 1 1972:
' T he Second National Bank of Orange, Orange,
N.J.
The Third National Bank of Orange, Orange,
N.J.
Merger
161
N o v . 2 1972:
Citizens National Bank of South Jersey, Bridgeton,
N.J.
Second Citizens National Bank of South Jersey,
Bridgeton, N.J.
Merger
162
N o v . 2 , 1972:
The First National Bank of Marlton, Marlton, N.J.
Second National Bank of Marlton, Marlton, N.J.
Merger
163
Nov. 10, 1972:'
Trust Company of Ocean County, Lakewood, N J .
-c- * TT *• i c* * -D I c r\
V
.
r* ± T i
Flrst l
State Bank
^ ™f
°f ° C e a n G ° U n t y ' L ^ '
wooa
x>l
_
< J•
Merger
164
Nov. 28, 1972:
Mellon National Bank and Trust Company,
Pittsburgh, Pa.
Mellon Bank, N.A., Pittsburgh, Pa.
Merger
165

39

Nov. 30, 1972:

Highland National Bank of Newburgh, Newburgh,
N.Y.
385 Broadway National Bank, Newburgh, N.Y.
Merger
Dec. 4, 1972:
Jefferson National Bank, Lynchburg, Va.
Jefferson Bank, N.A., Lynchburg, Va.
Merger
Dec. 7, 1972:
Peoples National Bank of Huntsville, Huntsville,
Ala.
Alabama National Bank of Huntsville, Huntsville,
Ala.
Merger
Dec. 22, 1972:
The First National Bank of Dothan, Dothan, Ala.
Alabama National Bank of Dothan, Dothan, Ala.
Merger
Dec. 28, 1972:
First National Bank in Orange, Orange, Tex.

Page

166

167

168

169

Page

New National Bank in Orange, Orange, Tex.
Merger
Dec. 29, 1972:
Bank of Caledonia, Caledonia, N.Y.
Chase Manhattan Bank of Greater Rochester
(National Association), Caledonia, N.Y.
Merger
Dec. 31, 1972:
Exchange National Bank of Chicago, Chicago, 111.
Exchange Chicago Bank, National Association,
Chicago, 111.
Merger
Dec. 31, 1972:
First National Bank in Dallas, Dallas, Tex.
First Bank, National Association, Dallas, Tex.
Merger
Dec. 31, 1972:
National Central Bank, Lancaster, Pa.
The King Street Bank, N.A., Lancaster, Pa.
Merger

170

170

172

172

173

///. Additional approvals
A. Approved, but in litigation
June 12, 1972:
The Peoples National Bank, Greenville, S.C.
Bankers Trust Co. of South Carolina, Columbia,
S.C.
Consolidation
B. Approved, but abandoned after litigation
Dec. 20, 1971:
Wells Fargo Bank, National Association, San Francisco, Calif.

174

First Western Bank and Trust Company, Los
Angeles, Calif.
Merger
Jan. 11, 1972:
The National Bank of Georgia, Atlanta, Ga.
Bank of Fulton County, East Point, Ga.
Merger
Nov. 3, 1972:
Wachovia Bank and Trust Company, N.A.,
Winston-Salem, N.C.
Bank of Granite, Granite Falls, N.C.
Merger
'

176

179

181

NOTE.—The 1970 Annual Report carried the Comptroller's decision approving the proposed consolidation of Catamount National Bank, North Bennington, Vt., and the County National Bank of Bennington, Bennington, Vt., under the heading "Approved,
but in litigation". After the filing of an action against the consolidation by the Justice Department in 1970, the banks abandoned
their consolidation plans on December 8, 1972.
The 1971 Annual Report carried the Comptroller's decision approving the proposed purchase of the First National Bank of
Ferndale, Ferndale, Wash., by Seattle-First National Bank, Seattle, Wash., under the heading "Approved, but in litigation". After
the filing of an action against the purchase by the Justice Department in 1971, the banks abandoned their purchase plans on January 4, 1972.
That Annual Report also carried the Comptroller's decision approving the proposed merger of The First National Bank of Tucker,
Tucker, Ga., and The First National Bank of Atlanta, Atlanta, Ga., under that same heading. After the filing of an action against
the merger by the Justice Department in 1971, the banks abandoned their merger plans on April 18, 1972.

40



/. Mergers consummated, involving two or more operating banks
NATIONAL BANK OF ALASKA, ANCHORAGE, ALASKA, AND BANK OF PETERSBURG, PETERSBURG, ALASKA
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Petersburg, Petersburg, Alaska, with
and National Bank of Alaska, Anchorage, Alaska (14651), which had
merged Jan. 1, 1972, under charter and title of the latter bank (14651). The merged
bank at date of merger had

COMPTROLLER S DECISION

On January 6, 1971, the Bank of Petersburg, Petersburg, Alaska, and the National Bank of Alaska, Anchorage, Alaska, applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
Anchorage, with a population of over 53,000 is the
financial, commercial, and communications center of
Alaska. The greater Anchorage borough has a 1970
estimated population of 117,500, and is one of the most
rapidly growing metropolitan areas in the Nation. Construction is a leading industry in the area and various
forms of new construction are evident throughout the
borough. Most of the major oil companies maintain
offices in Anchorage, and its international airport serves
as one of the major supply terminals for oil companies
and their employees who are working the north slope
of the State, an area where large deposits of oil were
recently discovered. Economic prospects for the entire
State appear promising.
The National Bank of Alaska, with total deposits of
$185 million, is the largest commercial bank in Alaska
and presently operates 26 banking offices in various
sections of the State. The bank, which was originally
organized in 1916, is a well run, full-service institution.
Other banks headquartered in Anchorage are the First
National Bank of Anchorage, with deposits of $153 million; the Alaska State Bank, with deposits of $54 million ; the Matanuska Valley Bank, with deposits of $44
million; and the Peoples Bank and Trust Company,
with deposits of $6 million. In addition, the $29 million
First Federal Savings and Loan Association of Anchorage, the $29 million Alaska Mutual Savings Bank, and
several credit unions are located in Anchorage.
Petersburg, with a present population of about 2,015,
is a relatively isolated community. It is located in the
central portion of the southeastern "panhandle" of
Alaska approximately 680 air miles to the south-




$7, 496, 743
238,887, 138
246, 245, 666

To be
operated

1
26
27

east of Anchorage. Since transportation overland is
nearly impossible, the movement of people and goods
is accomplished by boat or airplane. Fishing and logging are the backbone of Petersburg's economy. Economic prospects for the area do not appear promising.
The merging bank, the Bank of Petersburg, with total
deposits of $7 million, was originally organized in 1912
and is a single-office institution. It remains the only uninsured bank in the State. Because of its size, it has not
been able to adequately meet the credit needs of its
community. Since 1968, when the Rasmuson family acquired control of the merging bank, the charter bank
has closely supervised the merging bank and supplied
it with management.
The subject proposal will have no adverse competitive effects. The merging bank has no close competitor.
The closest office of the charter bank to the merging
bank is located on the Island of Wrangell, about 30 air
miles to the southeast of Petersburg. The next closest
banking offices are over 100 air miles distant. Because
of the distance between the participating banks there
is no competition between them which will be eliminated by consummation of this merger. The addition
of $7 million in deposits to the charter bank will have
no significant effect on the overall banking structure in
the State. On the other hand, approval of this merger
will solve the problems at the merging bank and introduce into Petersburg a modern banking institution
able to meet adequately the needs of that community.
The resulting bank will provide the banking public
of Petersburg with new and improved banking services
including expertise in the vital industries of that area.
Further, the depositors of the merging bank will be protected by federal deposit insurance.
Considered in the light of the statutory criteria, this
merger is deemed to be in the public interest. The application is, therefore, approved.
NOVEMBER 30,1971.

41

SUMMARY OF REPORT BY ATTORNEY GENERAL

Generally, banking competition is evaluated within
fairly limited geographic areas because of the desire
and need of most ordinary customers to have easy
access to their bank. However, when a bank has the
only office within an area, its customers must of necessity go beyond that area to find any alternative to the
local monopolist. When two banks which enjoy such
local monopoly, checked only by competitive alternatives in adjacent areas, propose to merge and thus
eliminate the only remaining check on monopoly
power, it is relevant to consider a larger area in appraising the competitive effects of a merger. Furthermore, the comparatively low deposit level of the exist-

ing banking offices in the area and lack of rapid population growth mean that entry of other banks into this
area in the future is extremely unlikely.
In this case, National Bank of Alaska's Wrangell
office is the only alternative banking facility within 100
miles of Bank of Petersburg. These offices, located on
separate islands, are 30 miles apart. Hence, this merger
would create an absolute regional monopoly of commercial banking offices in the Wrangell-Petersburg
area, under the control of the largest bank in the State.
It would also reinforce and entrench National Bank
of Alaska's dominant position in the entire southeastern area of Alaska. Therefore, we conclude that this
merger would have an adverse effect on competition.

WACHOVIA BANK AND TRUST COMPANY, N.A., WINSTON-SALEM, N.C., AND FIRST STATE BANK, REIDSVILLE, N.C.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

First State Bank Reidsville N G with
and Wachovia Bank and Trust Company, N. A., Winston-Salem, N.G. (15673),
which had.
. .
merged Jan. 3, 1972, under charter and title of the latter bank (15673). The
merged bank at date of merger had

COMPTROLLER S DECISION

On September 29, 1971, First State Bank, Reidsville,
N.G. and Wachovia Bank and Trust Company, N.A.,
Winston-Salem, N.C. applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the former.
Wachovia Bank and Trust Company, N.A., WinstonSalem, N.C, the charter bank, was organized in 1879
at Winston-Salem. Its 155 offices serve 54 North Carolina communities. Its IPC deposits of $1.2 billion exceed those of any other bank in the State. The charter
bank is the principal component of the Wachovia Corporation, a registered one-bank holding company
which engages, through several subsidiaries, in a number of bank-related activities.
The charter bank generates the majority of its business from the Piedmont Crescent which begins at
Charlotte, on the west, and extends through the Piedmont Corridor to Winston-Salem, the location of its
head office, and eastward to the Raleigh-Durham area.
Wachovia competes in one way or another with every
major bank in the southeastern United States. In North
Carolina, its primary competitors are the $1.6 billion

42



To be
operated

$25, 928, 414

7

2,013,049,917

164

2, 037, 667, 546

171

Carolina National Bank, the $1.2 billion First Uni&n
National Bank of North Carolina; the $788 million First
Citizens Bank and Trust Company, and the $622 million Northwestern Bank. North Carolina National Bank
has 80 offices in communities served by Wachovia;
First Union National Bank of North Carolina has 65;
First Citizens, 54; and the Northwestern Bank, 28.
First State Bank, the merging bank, with IPC
deposits of $17.2 million, was organized in 1882. It
operates its main office and three branches in Reidsville and single offices in Eden and Ruffin in Rockingham County, and in Yanceyville in neighboring Caswell County. The merging bank has been conservative
through the years though generally well managed and
operated. The bank is now facing very acute present
and prospective management problems due to the age
of upper management and the lack of a recruiting
program to assure adequate, experienced successor
management.
This bank, sorely needing to replace its aged banking house, lacks the resources to undertake an adequate building program.
The merging bank serves Caswell and Rockingham

counties. Caswell County has a population of 19,055
and Rockingham County has a population of 72,402.
Eden and Reidsville are the two largest communities
in Rockingham County and contain populations of
15,871 and 16,636, respectively. The economy of Caswell County is based mainly on agriculture and the
economy of Rockingham County is based mainly on
the manufacture of textiles and apparel.
Banking competition in the area of the head office of
the merging bank in Reidsville is offered by one office
of the $23 million Carolina National Bank of Commerce, four offices of the $19 million First National
Bank, and one office of the First Citizens Bank and
Trust Company. In Eden, where the merging bank
has a single office, the Carolina Bank of Commerce
has five offices and the Southern National Bank of
North Carolina has three offices. In Yanceyville, where
the merging bank has a single office, the Northwestern
Bank also has an office.
This merger will be in the public interest by benefiting the convenience and needs of the merging bank's
service area. That economically static area should be
stimulated by the introduction of the charter bank
and the many and varied services which it offers and
which will be made available in the area. In addition,
the management succession problem of the merging
bank will be solved by the ready availability of a pool
of management talent upon which to draw. Also,
needed capital improvements which the merging bank
is not presently in a position to undertake can be made
from the resources of the charter bank after the merger.
Competition will not be adversely affected. Because
the nearest offices of the two banks are 24 miles apart,
there is little, if any, present competition between
them. Statewide and in the local service areas of the
charter bank, the addition of the much smaller merging
bank will have little effect on the charter bank's competitive position.
It is not probable that charter bank would enter
either Caswell or Rockingham County with a de novo
branch in the reasonably foreseeable future. Neither
Caswell nor Rockingham County constitutes an attractive area for de novo entry by charter bank. Caswell County has a very poor economic base. It is losing
population and presently ranks substantially below the
State averages in such economic measures as per capita

501-017 0—73


income, retail and wholesale sales, and total bank
deposits, among others.
Some eight banks and 25 banking offices now operate
in Rockingham County. While economically somewhat stronger than Caswell County, Rockingham suffers from the trend toward urbanization of the four
large cities immediately to its north and south; Danville
and Martinsville, in Virginia, and Burlington and
Greensboro, in North Carolina. The textile and apparel
industry, the mainstay of the county's economy, has
recently experienced difficulties because of increasing imports which have caused the closing of numerous
plants in the State, including one in Reidsville. The
tobacco industry, the country's second largest industry,
likewise faces an uncertain future, and has evidenced
little or no growth in recent years.
Because of the size and ability to compete,
Wachovia's presence can aid the growth of the economy of these counties and should have a positive effect
on competition.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
DECEMBER 3,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of Wachovia to any of those
of First State Bank are in Greensboro, about 24 miles
from the main office of First State Bank. In the four
towns serviced by First State Bank, Wachovia holds
only minimal amounts of small retail loans and deposits.
Although Wachovia does have a significant amount of
other deposits and loans from the service area of First
State Bank, these are apparently commercial deposits
and loans of such a size that First State Bank would
be unable to service them. The proposed merger, therefore, would not appear to eliminate any significant
amount of direct competition between the two banks.
Since North Carolina law permits statewide de novo
branching, Wachovia, the largest bank in North Carolina and with offices in adjacent Guilford County,
must be considered a significant potential entrant into
Rockingham and/or Caswell counties. However, the
economic prospects of the area lessens the likelihood of
such de novo entry in the foreseeable future.

43

T H E BRIDGETON NATIONAL BANK, BRIDGETON, N.J., AND CITIZENS NATIONAL BANK OF SOUTH JERSEY,
WOODBINE, N.J.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Citizens National Bank of South Jersey, Woodbine, N J . (12977), with
and The Bridgeton National Bank, Bridgeton, N.J. (2999), which had
merged Jan. 14, 1972, under charter of the latter bank (2999) and title "Citizens
National Bank of South Jersey." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 6, 1971, the Citizens National Bank of
South Jersey, Woodbine, N.J., and The Bridgeton National Bank, Bridgeton, N.J., applied to the Office of
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title "Citizens National Bank of South Jersey."
The Bridgeton National Bank, the charter bank,
with total IPC deposits of $7.1 million, was organized
in 1883 under its present title. The charter bank operates one in-town branch which began de novo in
March 1970. During 1971, a substantial change took
place in the composition of the board of directors of
the charter bank when four of its eight directors resigned and five new directors were appointed, three
of whom were also directors of the merging bank. During the period January 1971 to July 1971, as a direct
result of the management reorganization which established an aggressive, coordinated direction of the charter bank's policies, the total assets of the bank expanded
from $7.9 million to $9.1 million.
The service area of the charter bank is confined to
Cumberland County, in the south central portion of
New Jersey and in the Third Banking District. Traditionally, that area has been primarily agricultural, but
recent development has made the county a center of
the plastics and glass manufacturing industry. There
are also several nationally-known food processing plants
and numerous locally owned businesses and service
establishments. In addition, the building of a new
bridge and highway system in adjacent Salem County
as a part of the Ameri-Port Complex is increasing the
residential and industrial growth potential of the charter bank's service area.
The Citizens National Bank of South Jersey, the
merging bank, with total IPC deposits of $4.1 million,
was originally organized as The Woodbine National
Bank in 1926. It subsequently changed to its present
name in July 1969. The merging bank, located in

44



$8, 274, 284
10,662,876
18, 937, 122

To be
operated
2
2
4

Cape May County, operates one branch which began
operations in March 1971. Prior to March 1969, when
a change in the management structure took place, the
merging bank experienced a slow, conservative rate
of growth. As a result of that management change
which was intimately connected with the management
reorganization in the charter bank, a rapid increase
in the assets of the merging bank, from $2.4 million
to $6.6 million, took place. Then, on May 6, 1971, a
further tie between the managements of the two banks
occurred when a director of the charter bank was
appointed to the board of directors of the Citizens
National Bank of South Jersey. The number of dirrectors common to the two banks involved in this transaction was brought to four.
Adjoining the eastern border of Cumberland County
is Cape May County, the service area of the merging
bank. That county, located along the South Jersey
shore, is primarily devoted to farming, fishing, and
seafood processing. Tourism and retirement living are
also becoming important to the economic base of the
area. A proposed industrial park, a considerable
amount of construction of vacation and year-round
living units, and large tracts of still undeveloped land
insure the continued growth of the area which already
has a good system of bridges and highways which
allow easy access.
*
At present, competition between the applicant banks
has been insignificant, primarily due to the old State
banking law which did not permit branching across
county lines. The nearest office of the charter bank,
located in Bridgeton, is approximately 34 miles northwest of Woodbine, with 13 banking alternatives between. As of the date of application, the charter and
merging banks were participating in only two loans.
This merger will not substantially reduce competition. The resulting bank will be the smallest of three
banks located in Bridgeton and will be the fourth
largest bank headquartered in Cumberland County. It

will also be the fifth largest bank in Cape May County.
The trade area of the resulting bank will contain many
banking alternatives; 12 commercial banks with 33
offices and total resources of $281 million. The four
largest banks in the Third Banking District have a total
of 15 offices in the trade area. In addition, there are 19
savings and loan or building and loan associations with
total assets of $139 million as well as various mortgage
companies, credit unions, and personal loan companies.
The abundance of banking alternatives is sufficient to
foster competition in this growing area.
Approval of the proposed merger will allow the
resulting bank to offer new and more complete services to its customers. Trust services, the future introduction of a credit card plan and a check credit overdraft plan, as well as an increased loan limit will place
the bank in a better competitive position from which to
serve the existing and future business needs of the area.

NORTH CAROLINA NATIONAL BANK, CHARLOTTE, N . C ,

Applying the statutory criteria to this application, it
is concluded that the proposed merger is in the public
interest. The application is, therefore, approved.
DECEMBER 15,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Bridgeton is located about 30 miles west of Woodbine and about 50 miles northwest of Citizens National's branch in West Cape May. There are several
intervening banks and competition between the merging banks appears to be negligible.
Home office protection would prevent either bank
from branching into the immediate service area of the
other. In view of this fact and the size and relative
market position of both banks, their proposed merger
would be unlikely to have any adverse effect on potential competition.

AND THE BANNER ELK BANK, BANNER ELK,

N.C.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Banner Elk Bank, Banner Elk, N.C, with
and North Carolina National Bank, Charlotte, N.C, (13761), which had
merged Jan. 21, 1972, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 1, 1971, North Carolina National Bank
Charlotte, N.C, applied to the Office of the Comptroller of the Currency for permission to merge with
The Banner Elk Bank, Banner Elk, N . C , under the
charter and title of the former.
North Carolina National Bank, the charter bank,
has I PC deposits of $979.4 million. It operates 109
offices in 33 communities in North Carolina. Although
it is essentially a statewide bank, the major part of its
business is generated in the piedmont section, where
most of the State's industry is situated. In total assets,
the charter bank is the second largest bank in the
State; in number of offices and number of communities
served, it ranks fifth.
The bank is highly competitive with other institutions in the fields of commercial lending, consumer
credit, computerization, business development, and
correspondent banking. It is the principal component
of NCNB Corporation, a registered one-bank holding



$4, 375, 735
1, 746, 667, 642
1,751,048,916

To be
operated

1
113
114

company which, through several subsidiaries, engages
in various bank-related activities.
The Banner Elk Bank, which was established in
1919, has IPC deposits of $3.2 million. The conservative operation of the bank, indicated by its 33 percent
loan-deposit ratio, has been adequate for the community up to now, but more capital and managerial energy will be needed to meet the community's growing
needs.
Avery County, where Banner Elk is located, is in the
northwest section of North Carolina. The county is
sparsely settled, 75 percent of the area is National parkland. The population has fallen from 13,561 in 1940,
to 12,155 in 1970. The county's principal towns are
Banner Elk, with a population of 754, and Newton,
with a population of 524. Manufacturing and agriculture have produced the bulk of the economic activity.
Tourism has recently become an important economic
factor through the construction of tourist attractions,
skiing facilities, and seasonal and retirement homes.

45

Credit needs for that development have had to come
from large regional or statewide banks outside the area.
The merger will enable the resulting branch office to
start meeting those needs locally, through a larger lending limit, trust services that can be used by retired
people who move to the area, and other specialized
services. The management capability that the charter
bank can provide, will better local service.
The Avery County Bank, which is twice the size of
the merging bank, is located 12 miles southwest in Newland, and is the merging bank's main competition
in Avery County. The Northwestern Bank, in North
Wilkesboro, has offices in the larger communities in
the region and has an application pending for a branch
in Newland. Its deposits are in excess of $500 million.
The head office of North Carolina National Bank in
Charlotte is about 100 miles southeast of Banner Elk.
The nearest offices are in Boone and Spruce Pine, 15
and 25 miles away, respectively. Because of the distance
and the merged bank's competition with all major

banks in the State, this merger is more likely to increase
than eliminate competition. As, in addition, it will
also provide for increased needs and conveniences to
Avery County, the application to merge is approved.
DECEMBER 16,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

North Carolina National Bank has six offices in the
counties which border Avery County, the area where
Banner Elk Bank derives the preponderance of its
business. These offices are from 15 to 50 miles from
Banner Elk and only derive a small amount of their
business from Avery County. Thus, it appears that
the proposed merger will not eliminate any significant
existing competition. Considering the unattractive economic condition and outlook of Avery County, and the
number of large banks capable of branching de novo
into the county, it does not appear likely that the proposed merger will eliminate significant potential
competition.

T H E NATIONAL STATE BANK, ELIZABETH, N.J., ELIZABETH, N.J., AND TRENTON TRUST COMPANY, TRENTON,

N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Trenton Trust Company, Trenton, N.J., with
and The National State Bank, Elizabeth, N.J., Elizabeth, N.J. (1436) which had. .
merged Feb. 25, 1972, under charter and title of the latter bank (1436). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 27, 1971, The National State Bank,
Elizabeth, N.J., Elizabeth, N.J. and the Trenton Trust
Company, Trenton, N.J., applied to the Office of the
Comptroller of the Currency for permission to merge
under the charter and title of the former.
The National State Bank, Elizabeth, N.J., the charter bank, with IPC deposits of $319.9 million, was originally incorporated in 1812 and joined the National
Bank System in 1865. The charter bank has become
the second largest of the 65 commercial banks headquartered in the Second Banking District of New Jersey. The National State Bank operates 17 branches
in Union County, 11 branches in Middlesex County,
and four branches in Hunterdon County. Its main office is located in Union County.
Competition for the charter bank is provided by
virtually all of the commercial banks operating in

46



$170,830,080
449,219,093
613,327,744

To be
operated

10
33
43

Union, Middlesex, and Hunterdon counties. Among
the largest of those competitors are the Central Jersey
Bank and Trust Company, Freehold, with deposits of
$281 million; the Union County Trust Company, Elizabeth, with deposits of $213 million; the Summit and
Elizabeth Trust Company, Summit, with deposits of
$161 million; and the First National Bank of Central
Jersey, Somerville, with deposits of $130 million. Additional competition is furnished by banks which are
affiliated with the large, multi-bank holding companies
in New Jersey, such as the National Bank of New
Jersey, New Brunswick, with deposits of $68 million, a
member of Fidelity Union Bancorporation which controls deposits of $762 million; the Edison Bank, National Association, South Plainfield, with deposits of
$67 million, a member of First National State Bancorporation which controls deposits of $941 million;
and the Central Home Trust Company of Elizabeth,

Elizabeth, with deposits of $41 million, a member of
United Jersey Banks which holds deposits of $940
million. Competition is also provided by the multimillion dollar banks based in Newark and the multibillion dollar banks based in New York.
The Trenton Trust Company, Trenton, the merging
bank, with total I PC deposits of $117.6 million, was
originally incorporated in 1887 as The Real Estate,
Safe Deposit, Trust and Investment Company of New
Jersey. The merging bank has expanded in the past by
merging with two banks in 1928, and by purchasing
an additional bank in 1958. It currently ranks sixth
among the 65 commercial banks located in the Second Banking District of New Jersey. The Trenton Trust
Company operates six branches in the city of Trenton,
the State capital, and one branch each in Hopewell
Township and Lawrence Township, two of the thirteen municipalities that comprise Mercer County. In
addition, the merging bank has pending applications
to establish another branch in Lawrence Township
and one in the city of Trenton.
Competition for the merging bank is provided by
all of the commercial banks operating in Mercer
County. Those competitors include the New Jersey
National Bank, Trenton, with deposits of $519 million;
First Merchants National Bank, Neptune Township,
with deposits of $171 million; and the First Charter
National Bank, Monroe Township, with deposits of
$105 million. Additional competition is furnished by
banks which are affiliated with large, multi-bank holding companies such as the First National Bank of
Princeton, Princeton, with deposits of $81 million, a
member of United Jersey Banks which controls deposits
of $940 million; and the Princeton Bank and Trust
Company, Princeton Township, with deposits of $78
million, a proposed member of American Holding Corporation of New Jersey, a planned multi-bank holding
company. Competition is also provided by two small
banks headquartered in Bucks County, Pa., and by
branches of the billion-dollar banks based in Philadelphia, Pa.
The service area of the Trenton Trust Company
consists primarily of Mercer County, which is located
in the southern portion of the Second Banking District
of New Jersey, and also a portion of Bucks County, Pa.,
located directly across the Delaware River. The economy of the area is based on many factors, including
large-scale commercial and manufacturing industries,
residential communities, and large-scale government
employment.
The diversified trade area from which The National
State Bank draws its trade includes Union, Middlesex,




and Hunterdon counties in the Second Banking District
and the southern portion of Essex County, which is
located in the First Banking District of New Jersey.
That service area reflects the varied economic characteristics of residential, commercial, industrial, and agricultural activity. In addition, Union County is the location of the Elizabeth Marine Terminal of the Port of
New York Authority, which is considered the container
shipping center of the world. The charter bank serves
a population in excess of 1.3 million people.
At present, there is no significant competition between the charter and merging banks. The main offices
of the two banks are 44 miles apart, and the nearest
branch of The National State Bank is approximately
25 miles from an office of the Trenton Trust Company.
In addition, there are numerous banking offices located
between the two banks involved in this transaction
which further dilutes the competitive effect that the
two banks have on each other.
Upon consummation of the proposed merger, there
will be no adverse competitive effects in the Second
Banking District of New Jersey. The $648 million resulting bank will become the largest commercial bank
in the Second Banking District and will be the fifth
largest commercial banking organization, including
the multi-bank holding companies, operating in the
district. The resulting bank will operate 44 existing
and approved offices located in four of the six counties
that comprise that district. Yet the proposed merger
will have a favorable effect on competition, especially
in the Mercer County area where the resulting bank
will provide a more aggressive and effective competitor
to the large banks already operating in that county.
In addition, the resulting bank will introduce additional and expanded services to the residents and
businessmen of Mercer County, including a substantially larger lending limit, data processing facilities, trust services, and specilized lending services.
Applying the statutory criteria to this application,
it is concluded that the proposed merger is in the
public interest. The application is, therefore, approved.
JANUARY 26,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of National State and Trenton
Trust are about 44 miles apart, their closest offices are
about 25 miles apart, and there are a number of offices
of other banks in the intervening areas. Thus, although
the banks operate in contiguous counties, it does not
appear that the proposed merger would eliminate any
significant amount of competition between them.

47

New Jersey law permits banks to branch throughout
their respective banking districts, except that home
office protection is provided for all communities, and
branch office protection is provided for municipalities
with populations of 7,500 or less. In addition, bank
holding companies are permitted to operate bank subsidiaries throughout the State.
With total deposits of about $200 million, Trenton
Trust should be considered capable of establishing de
novo branches in areas of the Second Banking District
which it does not already serve. Trenton Trust is the
sixth largest bank located in the Second Banking District, but a number of the other larger district banks
already serve those areas served by National State to a
greater or lesser extent. Thus, Trenton Trust is a source
of potential competition in National State's service
area, either through de novo entry, or through acquisition of a smaller, "foothold" bank. Also providing
potential competition in these areas are other larger
banking institutions, some of which have formed multibank holding companies with existing subsidiaries in
the Second Banking District.
As the second largest bank in the district, and the
largest not serving Trenton or Mercer County, National State is clearly a significant source of potential
competition in this area. Potential competition is also
provided by the other larger banking institutions referred to in the preceding paragraph. The city of
Trenton and the adjoining townships of Ewing and
Hamilton are closed to de novo branching by virtue
of home office protection. However, Lawrence, the

third township contiguous to Trenton, as well as the
nearby townships of Hopewell and East Windsor are
"open"; these municipalities, which are the only ones
open at the present time among the 13 in Mercer
County, have a combined population of over 41,000,
are presently served by 15 banking offices, and appear
to be growing steadily.
Commercial banking in the Trenton Metropolitan
Area and Mercer County is highly concentrated. New
Jersey National Bank and Trenton Trust, the two
largest of the 11 banks headquartered in Mercer
County and the 13 banks operating there, held, as of
June 30, 1970, about 77 percent of IPC demand deposits in the Trenton area and about 57 percent of
such deposits in the county as a whole. Trenton Trust
held about 35 percent and 22 percent of such deposits
in the Trenton area and the county, respectively.
The proposed merger would eliminate each bank
as a source of potential competition in those areas
served by the other. The more serious effect would
be the elimination of National State as a de novo or
"foothold" entrant into Trenton and Mercer County.
While there are a number of other sources of potential competition, the fact that the merging banks
are the second and sixth largest banks in the Second
Banking District indicates that the proposed merger,
and others of a similar nature which its approval may
trigger, could ultimately lead to undue concentration
of banking resources in the district in a few banks.
We conclude that the overall effect of the proposed
merger on competition would be adverse.

AMERICAN NATIONAL BANK, BAKERSFIELD, CALIF., AND SAN JOAQUIN VALLEY NATIONAL BANK, TULARE, CALIF.
Banking offices
Total assets

Name of bank and type of transaction

San Joaquin Valley National Bank, Tulare, Calif. (15357), with
and American National Bank, Bakersfield, Calif. (15437), which had
merged Mar. 10, 1972, under charter and title of the latter bank (15437). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 10, 1971, the San Joaquin Valley
National Bank, Tulare, Calif., and the American National Bank, Bakersfield, Calif., 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 American National Bank, the charter bank,

48



To be
operated

In
operation

$20, 768, 741
56, 264, 565
79, 095, 779

6
9
15

with IPC deposits of $39.9 million, opened for business on December 4, 1964. It operates seven branches
and has an application pending for an eighth.
The charter bank serves three separate areas including the Greater Metropolitan Bakersfield Area,
with a population of 200,000; the Antelope Valley
in Northern Los Angeles County; and the Santa Ynez

Valley, located in the central coastal section of the
State. The economy of those three areas is agriculturally oriented. Bakersfield, although located in an
agriculturally dependent area, has a diverse economy
which includes significant oil production. The Santa
Ynez Valley is tourist oriented. The aerospace industry
and government installations contribute significantly
to the Antelope Valley area, and industry is rapidly
moving in.
The area served by the charter bank contains 49
banking offices of 11 banks including offices of the
seven largest banks in the State. Bank of America,
National Trust and Savings Association, San Francisco,
has 12 offices in the area; Security Pacific National
Bank, Los Angeles, has seven offices; Crocker National
Bank, San Francisco, has five offices; and United California Bank, Los Angeles, has four. The area also
contains offices of a number of savings and loan
associations.
The San Joaquin Valley National Bank, the merging
institution, with IPC deposits of $15.5 million, opened
for business in 1964. It presently operates four branches
in central San Joaquin Valley. In addition, it operates
a seasonal branch at the Tulare County Fairgrounds,
and has received approval to establish a branch in
Fresno County. The bank has been subject to an increased number of problems due primarily to depressed farm prices.
The merging bank serves an agricultural area situated in the central San Joaquin Valley. Tulare County,
the location of three offices of the bank, is the leading
county in the United States in dollar volume of farm
products produced. Merced and Madera counties,
where the other offices are located, are also large farm
product producers. The central valley area is growing
rapidly and the subject bank has been able to share in
that growth.
The merging bank competes with 21 offices of large
statewide banking institutions. Among those are Bank
of America, National Trust and Savings Association;
Crocker National Bank; Security Pacific National
Bank; United California Bank; and Wells Fargo Bank,
National Association. It also competes with numerous
offices of savings and loan associations.
The merger will aid the resulting offices of both
banks by strengthening their capital and adding needed




depth to management. Services to be offered will be
improved and streamlined and the lending limit will
be increased.
Competition will not be adversely affected. Because
their service areas do not overlap, there is no competition between the two merging banks. Their closest
offices are 50 miles apart and they have no common
depositors or borrowers. In the combined service area
of the two banks, the resulting bank will be a more
effective competitor to the large statewide banks without adversely affecting smaller competitors. Statewide,
the merger will have little effect since the resulting
bank will continue as essentially a regional institution.
Applying the statutory criteria it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
FEBRUARY 8,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the two banks are more than
40 miles apart in the communities of Bakersfield and
Porterville. There are several banking offices located
in the intervening area. It seems unlikely that substantial existing competition between the two banks will
be eliminated.
Banking in the three counties in which San Joaquin
Bank presently competes is highly concentrated with
the two largest organizations holding 82 percent of
deposits in Tulare County, 71 percent of deposits in
Merced County, and 84 percent of deposits in Madera
County. San Joaquin Bank is the fourth largest of
seven banks in Tulare County with 4 percent of the
county's deposits, the smallest of six banks in Merced
County with less than 1 percent of county deposits,
and the smallest of five banks in Madera County with
3 percent of county deposits. Thus, San Joaquin Bank
constitutes a foothold acquisition for any banking
organization seeking entry into its markets by merger.
In terms of deposits, American Bank ranked 47th
among California commercial banks at mid-1971. In
light of its relatively small size and the numerous
larger banks outside the market, its acquisition of
San Joaquin Bank should not result in the loss of
any significant potential competition in the central
San Joaquin Valley.

49

T H E FIRST-HARDIN NATIONAL BANK OF ELIZABETHTOWN, ELIZABETHTOWN, KY., AND BANK OF SONORA,
SONORA, K Y .
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Bank of Sonora, Sonora, Ky., with
was purchased Mar. 17, 1972, by The First-Hardin National Bank of Elizabethtown, Elizabethtown, Ky. (6028), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On October 14, 1971, The First-Hardin National
Bank of Elizabethtown, Elizabethtown, Ky., applied to
the Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of the
Bank of Sonora, Sonora, Ky.
The First-Hardin National Bank of Elizabethtown,
the purchasing bank, was chartered in 1833. With IPC
deposits of $32.7 million, the bank operates five
branches: two in Elizabethtown, two in Radcliff, and
one in Upton, Ky. Elizabethtown, headquarters of the
purchasing bank, is the seat of Hardin County and has
a population of 11,700. The economy of Elizabethtown
is based upon several small industrial plants employing
about 2,200 workers, and upon the payroll of residents
commuting to work at the Fort Knox military base, 14
miles to the northwest. Elizabethtown is served by only
one other commercial institution, a bank approximately
one-third the size of the applicant.
The Bank of Sonora was chartered in 1895, and is a
single office institution with IPC deposits of $1 million.
Located about 13 miles south of Elizabethtown, the
Bank of Sonora is the only bank in the village of Sonora,
which has a population of 270. As Sonora's population
has been declining in recent years, the Bank of Sonora
has grown little and its earnings have been modest. The
bank has a management succession problem which is
made difficult to solve by the bank's small size and
village location.

50



To be
operated

$1,296,618

1

46,051,619
47, 348, 237

6

7

The applicant's service area includes contiguous portions of Bullitt, Grayson, Hart, Larue, Meade, and
Nelson counties. That area contains 14 banks of which
the applicant presently holds 22.7 percent of deposits.
Although the applicant and selling banks are located
about 13 miles apart, there is very little present competition between them as the selling bank is not an aggressive and effective competitor in its region. However, its acquisition by the applicant will insure the
continuance of a local banking outlet in Sonora and,
in addition, will bring an increased lending limit, more
efficient and new services, and needed management
resources to the selling bank. Consummation of the proposed acquisition will not reduce the number of banking outlets available to the public, but will substitute
for the selling bank one better able to serve the public
and compete in its region.
Applying the statutory criteria to the proposed acquisition, we conclude that it will serve the public. The
application is, therefore, approved.
FEBRUARY 15,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First-Hardin is Hardin County's largest bank. Sonora
is the smallest of the seven banks in Hardin County,
and is located 4 miles north of First-Hardin's branch
in Upton (population 552). The proposed acquisition
would eliminate existing competition and would add
to First-Hardin's dominant county position.

PEOPLES NATIONAL BANK OF NEW JERSEY, WESTMONT, N J., AND THE FIRST NATIONAL BANK OF WOODSTOWN,
WOODSTOWN, N.J.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Peoples National Bank of New Jersey, Westmont, N.J. (12022), with
and The First National Bank of Woodstown, Woodstown, N.J. (399), which had.
consolidated Mar. 17, 1972, under charter of the latter bank (399) and title
"Peoples National Bank of New Jersey." The consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On October 19, 1971, The First National Bank of
Woodstown, Woodstown, N.J., and the Peoples National Bank of New Jersey, Westmont, Haddon Township, N J., applied to the Comptroller of the Currency
for permission to consolidate under the charter of the
former and with the title of the latter, with headquarters in Westmont, Haddon Township, N.J.
Peoples National Bank of New Jersey, with $202.9
million in total deposits, was organized in 1921. It
has 23 branches and four approved but unopened
branches.
The First National Bank of Woodstown, with total
deposits of $8.7 million, was organized in 1864, and is
a unit bank.
The service area of the resulting bank will be the
Third Banking District of New Jersey with the exception of Cape May County. The area encompasses
Camden, Gloucester, and Cumberland counties, and
parts of Atlantic, Burlington, Ocean, and Salem
counties. It has a population of 1.5 million. Along the
area's western extreme, on the Delaware River, are
42 of the Nation's largest industrial concerns. The
Port of Philadelphia Industrial Complex, the second
largest such facility in the United States, is in the
area and extends from Trenton to the Delaware Bay.
Moving eastward, there are suburban areas and farm
land. Farther east are ocean resort areas and housing
developments for retired people.
Camden County, where Peoples National Bank
operates its home office and nine branches, is the
smallest county in the district, but it is highly industrialized along its western border. The city of Camden
is located there, and the county's population at yearend 1970 was 456,291. Salem County, where The First
National Bank of Woodstown operates a single office,
has a population of 60,346, and is the least populated of
the area's counties. The economy of Salem County is




$247, 114, 722
10, 248, 140
257, 294, 688

To be
operated

25
1
26

substantially agricultural, but a large number of county
residents are employed by the industries located along
the Delaware.
The People's National is the third largest of the nine
banks headquartered in Camden County and the
fourth largest of the 60 commercial banks located in the
Third Banking District. Its competition includes the
Bank of New Jersey, Camden, with $348 million in
deposits; South Jersey National Bank, Camden, with
$337 million in deposits; First National Bank of South
Jersey, Egg Harbor Township, with $258 million in
deposits; Colonial National Bank, Haddonfield, with
$155 million in deposits; and National Bank and Trust
Company of Gloucester County, Woodbury, with $86
million in deposits. Through affiliation with registered
bank holding companies, competition is also provided
by the Third National Bank of New Jersey, Camden,
with $27 million in deposits, and the Cumberland National Bank of Bridgeton, with deposits of $29 million,
both members of the $600 million deposit United
Jersey Banks, Inc.; and the Bank of West Jersey, Delran Township, with deposits of $26 million, a member
of the $913 million deposit Fidelity Union Bancorporation. Competition is also provided by the large billiondollar Philadelphia, Pa., banks.
The First National Bank of Woodstown ranks sixth
in size among seven commercial banks headquartered
in Salem County. It ranks 54th in size among the
banks in the Third Banking District. Competition includes the City National Bank and Trust Company of
Salem, with deposits of $21 million; the Penns Grove
National Bank and Trust Company, with deposits of
$19 million; the Elmer Bank and Trust Company, a
member of the $904 million deposit Midlantic Banks
Holding Company, with deposits of $10 million; the
First National Bank of Elmer, with deposits of $9 million; and the Woodstown National Bank and Trust
Company, with deposits of $9 million.
Consummation of the proposal will benefit residents

51

and businessmen of the Woodstown area by introducing additional and expanded services, including
a substantially larger lending limit, customer electronic
data processing facilities, and trust investment advisory
services. It will provide a credit card program, specialized lending services and higher interest rates on
several types of savings plans, and community rooms
for the use of local non-profit and civic organizations.
Competition will not be adversely affected. Because
the home offices of the banks are 25 miles apart and
their nearest existing branches 16 miles apart, there is
little, if any, competition between them to be eliminated. Within a 10-mile radius of Woodstown are 22
banking offices of ten different commercial banks, and
replacing the home office of The First National Bank
of Woodstown with an office of the Peoples National
Bank will not eliminate a banking alternative and
should have no negative effect. In the Third Banking
District, the resulting bank will continue the charter
bank's size ranking of fourth largest. It would be substantially more capable of competing with its larger
competitors without disadvantaging its smaller ones.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
FEBRUARY 2,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The main offices of the merging banks are about 30
miles apart. Peoples Bank operates closer offices, however, particularly in Gloucester County. The closest
branches are located in Pitman, at a distance of approximately 14 miles. In view of the distances involved
and the existence of intervening competing banking
offices, it is likely that the proposed merger would
eliminate only a limited amount of direct competition.
Peoples Bank is among the larger banks in the Third
Banking District, and must be considered a potential
entrant into Salem County. It has the resources to
open de novo branches in attractive areas; although
many of Salem County's more populous areas are presently closed to de novo branching, growth projections
and coming economic changes indicate that attractive
branching sites will develop in the not too distant
future. However, there are a number of other large
potential entrants into the area, including other larger
banks in the third district, as well as bank holding
companies with principal resources in other districts.
Woodstown Bank is among the smaller banks located in Salem County, and holds about 8 percent of
total county deposits.
We conclude that the proposed merger is unlikely
to have a significantly adverse effect on competition.

PEOPLES NATIONAL BANK OF WASHINGTON, SEATTLE, WASH., AND OLYMPIC NATIONAL BANK, PORT ANGELES,
WASH.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Olympic National Bank, Port Angeles, Wash. (15906), with
was purchased Mar. 17, 1972, by Peoples National Bank of Washington, Seattle,
Wash. (14394), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On December 6, 1971, the Peoples National Bank
of Washington, Seattle, Wash., applied to the Office
of the Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of the
Olympic National Bank, Port Angeles, Wash.
The Peoples National Bank of Washington, the purchasing bank, was organized in 1889 as a savings bank.
The bank became a commercial bank in 1926 and
obtained a National charter in 1937. The purchasing

52



To be
operated

$13,083,680

3

516,544,122
529, 627, 802

53
56

bank is the fourth largest commercial bank in the State
of Washington, with total assets of $507 million and
IPC deposits of $382.4 million. It operates 52 branches
throughout the State, 23 of which are in the Seattle
Metropolitan Area.
Competition is provided by larger commercial banks
headquartered in Seattle. The major competitors include the Seattle-First National Bank, with deposits
of $1.9 billion; the National Bank of Commerce of
Seattle, with deposits of $1.2 billion; the Pacific Na-

tional Bank of Washington, with deposits of $623 million; and the Seattle branch of the Bank of California,
National Association, with deposits of $129 million in
the Seattle area.
The Olympic National Bank, the selling bank, was
organized as a State bank in 1941 and converted to a
National charter late in 1971. This bank is the 36th
largest bank in the State of Washington, with total
assets of $13.3 million and IPC deposits of $11.5 million. The selling bank operates two branches, a depository in Port Angeles and a new full-service facility
in Sequim, 15 miles east of the main office.
Competition for the Olympic National Bank is provided by three local banks. The largest of these is the
First National Bank in Port Angeles which operates
five offices and has total deposits of $25 million. The
other two smaller banks are the Bank of Sequim, with
deposits of $10 million and the Forks State Bank, with
deposits of $5 million.
The principal service area of the Peoples National
Bank of Washington is Seattle, the leading commercial,
industrial, and financial center in the Pacific Northwest. That metropolitan area, which includes King and
Snohomish counties, has a total population of 1.3 million. The economy of the area is closely related to the
aerospace and lumber industries, both of which have
experienced decline. The service area of the selling
bank is Port Angeles, situated on the northern coast
of the Olympic peninsula across the Strait of San Juan
De Fuca from Vancouver Island. Port Angeles is the
seat of Clallam County and is the only sizable city in
the sparsely settled region. That isolation has limited
industrial growth to lumbering and related industries.
However, the scenic beauty of the area has stimulated
tourism which provides most of the current development for the area.
At present, there is no competition between the
purchasing and selling banks. The closest branches of
the two banks are separated by Puget Sound and 68
miles of narrow highway. The two banks operate in
two distinct service areas. In addition, control of the




Olympic National Bank was recently acquired by the
shareholders of the Peoples National Bank of Washington, the purchasing bank. In view of this close affiliation, the subject application represents a corporate
reorganization of commonly owned assets, primarily
for the convenience of the two banks, and will not
adversely affect competition.
Consummation of the proposed transaction will bring
improved and expanded services to the present offices
of the Olympic National Bank. A larger lending limit,
trust services, investment and computer services, and
adequate management succession will all benefit and
aid the development of Clallam County. In addition,
the relative size of the resulting bank will remain unchanged in the State.
Accordingly, it is the view of this Office, that the
proposed transaction is in the public interest and will
not produce any adverse competitive results. The application is, therefore, approved.
FEBRUARY 15,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Since the nearest offices of the banks are 68 miles
apart, the proposed merger will not foreclose significant
existing competition.
Washington law prohibits State-chartered commercial banks headquartered outside Clallam County from
branching into most areas of the county; but since
Peoples National is a National bank it is questionable
whether that rule applies to it. In any event, Peoples
National could enter by other means including chartering a new bank through nominees and subsequently
acquiring that bank. As the State's fourth largest bank,
and the fourth largest bank in the State, not serving
this area, Peoples National must be considered a significant potential entrant into Clallam County. However, considering that the county's economy is not likely
to expand significantly, the proposed merger's effect on
potential competition is not likely to be significantly
adverse.

53

T H E ST. LAWRENCE COUNTY NATIONAL BANK, CANTON, N.Y., AND BANK OF GOUVERNEUR, GOUVERNEUR, N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Bank of Gouverneur, Gouverneur, N.Y., with
and The St. Lawrence County National Bank, Canton, N.Y. (8531), which had. .
merged Mar. 17, 1972, under charter of the latter bank (8531) and title "The St.
Lawrence National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On December 1, 1971, the Bank of Gouverneur,
Gouverneur, N.Y., and The St. Lawrence County
National Bank, Canton, N.Y., 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 St. Lawrence National Bank."
The St. Lawrence County National Bank, Canton,
N.Y., the charter bank, was originally organized in
1866, and currently has assets of $44.6 million and IPC
deposits of $32.3 million. The charter bank has applications pending for de novo branches in Potsdam and
Massena.
The charter bank, which operates seven branches in
St. Lawrence County and one in Lewis County, is the
third largest of the 23 commercial banks operating 58
offices in the trade area of The St. Lawrence County
National Bank. While the charter bank also ranks as
the largest bank in St. Lawrence County, its competition includes the Marine Midland-Northern, Watertown, with deposits of $148.8 million, which is a member of the $6.4 billion Marine Midland Banks, Inc., a
registered bank holding company; the National Bank
of Northern New York, Watertown, with deposits of
$92.8 million; and the Farmers National Bank of
Malone, Malone, with deposits of $30.6 million.
The Bank of Gouverneur, N.Y., the merging bank,
was originally formed in 1860, and currently has assets
of $12.1 million and IPC deposits of $8.7 million. The
merging bank was incorporated in 1879, and is headquartered in St. Lawrence County. The Bank of
Gouverneur is the fourth largest bank headquartered
in St. Lawrence County and is the ninth largest of the
23 commercial banks in the Fifth Banking District of
New York.
The merging bank operates no branches and has not
been involved in any previous mergers. Competition is
provided it by the First National Bank of Gouverneur,
with deposits of $8.4 million. Additional competition

54



$12,633,834

48, 545, 161
61,246,870

To be
operated

1
9

10

comes from branches of Marine Midland-Northern,
the National Bank of Northern New York in Watertown, and the Lewis County Trust Company in
Lewisville.
The service area of the charter bank consists of portions of the four counties comprising the Fifth Banking
District of New York State, and includes a population
of approximately 268,000. The area is on the northern
boundary of New York State. The economy of Canton,
the city in which the charter bank is headquartered,
is closely related to the institutions of higher education
located there. The remainder of the Fifth Banking
District is highly agricultural with dairy farming the
major activity. By contrast, the service area of the
Bank of Gouverneur is closely tied to mining, manufacturing, and recreation, with only a limited amount
of agriculture. The economy of that area is tied to local
firms, many of which are subsidiaries of nationallyknown companies. The area serves a population of
approximately 5,000 people.
* At present, there is no significant competition
between the charter and merging banks. The main
offices of the two banks are 24 miles apart and the
nearest office of The St. Lawrence County National
Bank to the merging bank is in Edwards, 14 miles
distant.
Consummation of the proposed merger will have no
adverse competitive effects in the Fifth Banking District of New York. The merger will not significantly
increase the deposits of the charter bank nor will the
transaction eliminate a competitor. The resulting bank
will be able to provide improved and expanded services
to the residents of the Gouverneur area including a
larger lending limit, electronic data processing, credit
card services and an expanded trust department. The
proposed merger will also allow the charter bank to
provide the management personnel who will be needed
when the president and two senior officers, all over 70
years old, retire from the Bank of Gouverneur.
Accordingly, it is the view of this Office that the pro-

posed merger is in the public interest. The application,
therefore, is approved.
FEBRUARY 9, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Bank of Gouverneur is located 24 miles from the
home office of St. Lawrence Bank. A major highway
connects the towns in which these two offices are
located and no other bank lies along this highway
in the intervening distance. Only one other bank,
located in Hermon, and holding total deposits of
about $2.5 million, serves the rural areas of St.
Lawrence County between Canton and Gouverneur.
The office of St. Lawrence Bank closest to Gouverneur
is located in Edwards at a distance of about 14 miles,
with no competing banks in the intervening area,
and a total of five St. Lawrence County Bank offices
lie within 30 miles of Gouverneur.
According to the application and to supplemental
data supplied by St. Lawrence Bank, 9.7 percent and
6.3 percent of Bank of Gouverneur's deposits and
loans, respectively, originate in the service area of

St. Lawrence Bank, while less than 1 percent and
about 1.2 percent of the deposits and loans of St.
Lawrence Bank originate in the service area of Bank
of Gouverneur.
It would appear that a limited amount of existing
competition would be eliminated by the proposed
merger.
While two of the banks doing business in St.
Lawrence County are larger overall than St. Lawrence
Bank, the latter holds the largest share, about 23
percent, of total commercial bank deposits in St.
Lawrence County. The proposed merger would increase this share to about 30 percent and would increase the shares of the four leading banks from about
71 percent to about 78 percent.
St. Lawrence Bank presently draws only a limited
amount of business from the area served by Bank of
Gouverneur. However, in view of its leading position
in St. Lawrence County, and the number and proximity of its offices to that of Bank of Gouverneur, we believe that the proposed merger would have an adverse
effect on competition.

T H E NATIONAL BANK OF COMMERCE OF SEATTLE, SEATTLE, WASH., AND OROVILLE STATE BANK, OROVILLE,
WASH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Oroville State Bank, Oroville, Wash., with
was purchased Mar. 20, 1972, by The National Bank of Commerce of Seattle,
Seattle, Wash. (4375), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On March 7, 1972, application was made to the
Comptroller of the Currency by The National Bank of
Commerce, Seattle, Wash., for permission to purchase
the assets and assume deposit liabilities of the Oroville
State Bank, Oroville, Wash.
In accordance with the provisions of 12 U.S.C. 1828
(c) (6), it is found that an emergency exists and that




$7,214,061
1, 436, 205, 404
1,443,419,465

To be
operated

1
106

107

this Office must act immediately to prevent the probable failure of the Oroville State Bank and to protect
its depositors, creditors, and shareholders.
Accordingly, the application of The National Bank
of Commerce to purchase the assets and assume the deposit liability of the Oroville State Bank is approved.
MARCH 7,

1972.

NOTE.—Due to the emergency nature of the situation, a

report on competitive factors was not requested.

55

FIRST-CITY NATIONAL BANK OF BINGHAMTON, N.Y., BINGHAMTON, N.Y., AND T H E CHENANGO COUNTY NATIONAL
BANK AND TRUST COMPANY OF NORWICH, NORWICH, N.Y.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Chenago County National Bank and Trust Company of Norwich, Norwich,
N.Y., (3011), with
and First-City National Bank of Binghamton, N.Y., Binghamton, N.Y. (15625),
which had
merged Mar. 31, 1972, under charter and title of the latter bank (15625). The
merged bank at date of merger had

COMPTROLLER S DECISION

On December 2, 1971, The Chenango County National Bank and Trust Company of Norwich, Norwich,
N.Y., and the First-City National Bank of Binghamton,
N.Y., Binghamton, 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 latter with
headquarters in Binghamton.
The First-City National Bank of Binghamton, the
charter bank, was originally organized in 1863, and
currently holds IPC deposits of $140.6 million. In May
1967, the charter bank assumed its present title and
became a subsidiary of Lincoln First Banks, Inc., a registered bank holding company, which, with aggregate
deposits of $1.7 billion, is the 12th largest commercial
banking organization in New York State. At present,
the charter bank is the second largest of the 33 commercial banks in the Seventh Banking District of New
York.
The First-City National Bank of Binghamton operates 12 offices in Broome County and one in the town
of Owego, Tioga County, which defines a service area
with an estimated population of 250,000. Strong competition is provided by the Marine Midland BankSouthern, Elmira, with total deposits of $246 million,
which is a member of the $6.4 billion Marine Midland
Banks, Inc.; The Endicott Trust Company, Endicott,
with total deposits of $75 million, which is a member
of the $4.6 billion Charter New York Corporation; the
Endicott Bank of New York, with total deposits of $40
million, which is a member of the $2.5 billion Bank of
New York Company; and the Bankers Trust of Binghamton, Binghamton, with total deposits of $20 million, which is a member of the $6.7 billion Bankers
Trust New York Corporation.
The Chenango County National Bank and Trust
Company of Norwich, the merging bank, was originally
chartered in 1883, and currently has IPC deposits

56



To be
operated

$12,767,713

1

198,857,489

14

211,625,203

15

of $9.4 million. In 1925, the merging bank assumed
its present title. The Chenango County National Bank
and Trust Company is currently the 20th largest of
the 33 commercial banks in the Seventh Banking
District.
The merging bank operates no branches. Its primary competitor is the National Bank and Trust
Company of Norwich, Norwich, with total deposits
of $85.6 million. The National Bank of Oxford, Oxford, with total deposits of $5.7 million, is located 9
miles south of Norwich and is the only other competitor for the merging bank.
The primary service area of the merging bank has
an estimated population of 8,850 and is centered in
the city of Norwich, the county seat of Chenango
County. Industry in the area consists of farming, milk
processing, and the manufacture of drugs, shoes, aerospace equipment, and food products. The trade area
of the First-City National Bank of Binghamton is
Broome County and the town of Owego in Tioga
County. The city of Binghamton is the county seat
of Broome County, and, together with the villages of
Endicott and Johnson City, account for the majority of
industrial growth and employment in the area.
At present, there is no competition between the
charter and merging banks nor between any other
subsidiary of Lincoln First Banks, Inc. The main offices of the two banks are situated 43 miles apart and
the nearest office of First-City National is 33 miles
distant at Whitney Point.
The resulting bank, with total deposits of $175
million, will continue to rank second both in its immediate trade area and in the Seventh Banking District of New York. The remaining 32 banks in the
Seventh Banking District will provide adequate competition for the resulting bank. In addition, the parent
holding company of the resulting bank, Lincoln First
Banks, Inc., will continue to rank 12th in size among

all of the commercial banking organizations in New
York State.
The resulting bank will be able to provide expanded
services to residents of the Norwich area, including
a larger lending limit, data processing services, the
introduction of a credit card, and improved trust facilities. The resulting bank will also serve the community by providing a realistic alternative to the
Norwich National Bank.
Accordingly, it is the view of this Office that the
proposed merger is in the public interest and, therefore, is approved.
FEBRUARY 23,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of First-City and Chenango National are about 43 miles apart, the closest office of
First-City to the sole Chenango National office is 33
miles distant, and there are several offices of three
other banks in the intervening areas. Thus, although
the merging banks operate in contiguous counties and
although First-City draws some loan business from
Chenango County, it appears the proposed merger
would eliminate only a limited amount of competition
between the participating banks.
New York law permits banks to branch throughout
their respective banking districts, except that home
office protection is provided for all communities with
populations of 75,000 or less (by 1976, when statewide

branching will be permitted, this ceiling will be reduced to 50,000). In addition, bank holding companies
are permitted to operate bank subsidiaries throughout
the State and to establish one de novo bank in each of
the existing nine banking districts (this latter limitation
will be eliminated in 1976).
As the second largest of the 34 banks in the Seventh
Banking District of New York, First-City represents a
significant source of potential competition in the Norwich area and Chenango County. Although Norwich
is closed to de novo entry by virtue of home office protection, First-City could be permitted to establish a
branch near that city, and, in addition, its parent,
Lincoln First Banks, Inc., could be permitted to establish a de novo bank in Chenango County. Potential
competition is also provided in this area by other large
bank holding companies which presently do not have
subsidiaries in Chenango County.
Four banks operate 12 offices in Chenango County.
Chenango National, the 18th largest bank in the seventh district and the third largest in Chenango County,
holds about 13 percent of total deposits in the county.
The largest county bank holds about 67 percent of such
deposits.
The proposed merger would eliminate First-City
and the Lincoln First Banks group as significant sources
of potential competition in the Norwick area and
Chenango County, where banking is highly concentrated and dominated by one bank.

CITIZENS & NORTHERN NATIONAL BANK AND TRUST COMPANY, TOWANDA, PA., AND THE FIRST NATIONAL BANK
OF RALSTON, RALSTON, PA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Ralston, Ralston, Pa. (9508), with
and Citizens & Northern National Bank and Trust Company, Towanda, Pa.
(328), which had
consolidated May 1, 1972, under charter and title of the latter bank (328). The
consolidated bank at date of consolidation had

COMPTROLLER S DECISIONS

On November 26, 1971, the Citizens & Northern
National Bank and Trust Company, Towanda, Pa.,
and The First National Bank of Ralston, Ralston, Pa.,
applied to the Office of the Comptroller of the Currency for permission to consolidate under the charter




To be
operated

$2, 160,046

1

56,674,731

9

58,906,816

10

and with the title of the former, with headquarters in
Ralston.
The Citizens & Northern National Bank and Trust
Company, Towanda, the charter bank, was originally
organized in 1864, and currently has assets of $52.2
million and IPC deposits of $44.3 million. The charter
bank is headquartered in Bradford County. Since 1964,

57

the charter bank has grown larger through purchase or
merger of four banks, making Citizens & Northern
National Bank and Trust Company the second largest
bank in its trade area.
The charter bank operates eight branches in Tioga
and Bradford counties. The major competitors of the
charter bank include the Commonwealth Bank and
Trust Company, Muncy, with total deposits of $58 million; the County National Bank of Montrose, Montrose, with deposits of $27.2 million; the First National
Bank of Towanda, Towanda, with deposits of $20.5
million; and the First National Bank of Troy, Troy,
with deposits of $15.7 million. Additional competition
is provided by seven smaller banks in Bradford County,
each of which has deposits of less than $10 million.
The First National Bank of Ralston, the consolidating bank, was originally organized in 1909 and has
remained a unit bank since that time. The bank has
assets of $2.1 million and IPC deposits of $1.6 million.
Competition is provided by the Northern Central Bank
and Trust Company, Williamsport, with deposits of
$74.4 million, and the First National Bank of Canton,
Canton, with deposits of $9.8 million.
The service area of the consolidating bank consists
of the town of Ralston and several nearby villages. The
economy of the area, once dependent on logging, is
now static. Many residents must commute long distances to industrialized cities in neighboring counties
for employment. The economy of the charter bank's
service area is based on light industry and agriculture,
with an emphasis on dairy farming. A large portion of
the area which is forestland is devoted to recreational
sports such as hunting and fishing.
At present, no significant competition exists between
the two principal banks in the transaction. The nearest
office of the charter bank to The First National Bank
of Ralston is in Liberty, located 10 miles from Ralston.
The isolated, rural setting of the consolidating bank
prevents it from competing significantly with any of
the banks in the area. That any banks hold deposits
from the Ralston area is due to the fact that many of
its residents commute to the larger cities of Canton,
Blossburg, and Williamsport for employment, and

58



chose to open accounts with the larger banks based in
those cities.
Upon consummation, an office of a large bank will
be established in the town of Ralston providing modern
banking services and a greatly expanded lending limit.
The consolidation will not eliminate any competition
in the service area of the charter bank.
Accordingly, it is the view of this office that the proposed consolidation is in the public interest and is,
therefore, approved.
MARCH 9,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The two offices of Citizens & Northern nearest Ralston are located at Liberty in Tioga County and at
Troy in Bradford County. The Troy office is 23 miles
from Ralston; the First National Bank of Canton (total
deposits of $10 million) is located in the intervening
area. The Liberty office of Citizens & Northern is located on the opposite side of a mountain range from
Ralston, and is about 28 road miles away. First National obtains most of its business from customers living
in an area extending south from the town of Canton,
15 miles northeast of Ralston, to Williamsport. Citizens
& Northern's offices obtain very little business from
this area. Thus, it would appear that the proposed
consolidation would eliminate only a limited amount
of direct competition.
Under Pennsylvania law, Citizens & Northern could
branch into Lycoming County and First National could
branch into Tioga and Bradford counties. However,
in view of the size of First National and the static economic conditions of the areas involved, it does not
appear that potential competition would be adversely
effected by the proposed consolidation. First National
is the smallest of 11 commercial banks operating offices
in Lycoming County, and holds only about 1 percent
of total deposits of such banks.
While a number of recent mergers have increased
concentration in banking generally in largely rural
north central Pennsylvania, the small size of First
National indicates that this proposed consolidation
would not substantially contribute to this trend.

BELLEFONTAINE NATIONAL BANK, BELLEFONTAINE, OHIO, AND THE BELLE CENTER BANK COMPANY, BELLE
CENTER, OHIO
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Belle Center Bank Company, Belle Center, Ohio, with
was purchased May 1, 1972, by Bellefontaine National Bank, Bellefontaine, Ohio
(13749), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On January 16, 1972, the Bellefontaine National
Bank, Bellefontaine, Ohio, applied to the Office of the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of The Belle
Center Bank Company, Belle Center, Ohio.
The Bellefontaine National Bank, the purchasing
bank, was originally organized in 1933. That bank, the
largest of the eight commercial banks in Logan County
and second among the 14 commercial banks that
compete in the bank's tri-county service area, has total
assets of $16.7 million and IPC deposits of $13.1 million. It operates two branches; one an in-town drive-in
facility, the other an independent branch located 8
miles south of Bellefontaine in West Liberty.
The major competitors of the Bellefontaine National
Bank include the Citizens National Bank of Urbana,
with deposits of $17 million; the Champaign National
Bank, with deposits of $15 million; and the First National Bank of Ken ton, with deposits of $14 million.
In addition, two other competing institutions in the
service area are affiliated with multi-bank holding companies and a third bank has announced its intention
to become affiliated.
The Belle Center Bank Company, the selling bank,
was organized in 1886 and absorbed The Farmers and
Merchants Bank, Belle Center, in 1900. No subsequent
mergers have taken place since that time and the
selling bank currently operates as a unit bank. The
Belle Center Bank Company has total assets of $2.6
million and IPC deposits of $1.8 million.
The major competitors of the selling bank include
the First National Bank, Kenton, with deposits of
$14 million; the Logan County Bank, Bellefontaine,
with deposits of $11.2 million; and the Kenton National Bank, Kenton, with deposits of $11 million.
Additional competition is provided by several savings
banks, the largest among which is the Kenton Savings
Bank, with deposits of $16 million.
501-017 O—73



To be
operated

$2,917,256

1

20,712,753
23, 630, 009

3
4

The service area of the selling bank consists of the
village of Belle Center which is located on the northern
border of Logan County. The village has a population
of 1,000 people and derives the basis of its economic
activity from agricultural pursuits in the surrounding
area. By contrast, the service area of the purchasing
bank consists of the three counties of Logan, Champaign, and Hardin. The local economy of Bellefontaine
is supported by several manufacturing and assembly
facilities which employ approximately 2,200 persons.
The entire area is also heavily dependent on agricultural enterprises which include grain, livestock, and
dairy farms.
At present, there is no significant competition between the purchasing and selling banks. Although some
overlap does exist north of Bellefontaine, a statistical
examination of deposits in that area shows that the
competitive factor between these two institutions is
minimal. The relatively sparse population and the wide
open farmland separating the two banks reinforces
that conclusion. In addition, a history of very conservative management at The Belle Center Bank Company has restricted the service area of the bank to its
own community and the established farms immediately
surrounding the bank's headquarters.
Upon consummation, the proposed transactions will
produce no adverse competitive effects in Logan
County. Improved and expanded services such as the
introduction of monthly bank statements for individual
checking accounts, a greatly increased lending limit
which will enable the bank to meet the expanding
needs of neighboring farmers, and adequate management succession will all benefit and aid the development
of northern Logan County. In addition, the relative
size of the resulting bank will remain unchanged in
Logan County. The resulting bank will become the
largest bank in its service area, but only by an insignificant amount. Adequate banking alternatives will
remain in Logan County to prevent any adverse competitive effects from developing.

59

Accordingly, it is the view of this Office that the
proposed transaction is in the public interest. The
application is therefore, approved.
MARCH 24,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Although the merging banks are located only 11 miles
apart, there is one intervening banking office between
them, and there is only a slight degree of overlap in
service areas. The existing competition, which would
be eliminated by this merger, is therefore, limited.
Bellefontaine National Bank is by far the largest of
the eight banks with offices in Logan County, being
50 percent larger than its nearest competitor. It holds
about 33 percent of deposits attributable to Logan
County commercial banking offices, and the three larg-

est banks in the county account for 73 percent of such
deposits. Belle Center Bank, the seventh largest bank
in the county, currently holds about 5 percent of the
county's deposits. Thus, if this merger is approved,
the share of Logan County deposits controlled by
Bellefontaine National Bank would increase from the
present level of 33 percent to 38 percent, and the share
of the three largest banks in the county would grow
from the present level of 73 percent to 78 percent.
Also, the approval of this merger would remove Belle
Center Bank as an alternative banking organization in
Logan County and as a vehicle by which banking organizations not now operating in Logan County might
enter that market.
We therefore conclude that the proposed merger
would have an adverse effect on banking competition
in Logan County.

T H E FIRST NATIONAL BANK OF SAN JOSE, SAN JOSE, CALIF., AND COMMERCIAL NATIONAL BANK OF SAN LEANDRO,
SAN LEANDRO, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Commercial National Bank of San Leandro, San Leandro, Calif. (15451), with..
and The First National Bank of San Jose, San Jose, Calif. (2158), which had. .. ,
merged May 1, 1972, under charter and title of the latter bank (2158). The merged
bank at date of merger had

COMPTROLLER'S DECISION

On January 21, 1972, The First National Bank of
San Jose, San Jose, Calif., applied to the Comptroller
of the Currency for permission to merge with the Commercial National Bank of San Leandro, San Leandro,
Calif., under charter and title of the former.
The First National Bank of San Jose, the charter
bank, was originally organized in 1874, under the title,
"The Farmers National Gold Bank of San Jose." The
bank changed to its present name in 1880. The charter
bank, with total assets of $226.9 million and IPC deposits of $190 million, operated as a unit bank until
1947. Since that time it has established 23 branch
offices, all but one of which are located in Santa Clara
County.
The service area of the charter bank consists of Santa
Clara County and a portion of San Mateo County on
the San Francisco Peninsula. This area has experienced
dynamic residential growth in the past 20 years. The
economy of Santa Clara County is based on diverse

60



$15, 808, 944
237,417,758
253, 226, 702

To be
operated

2
24
26

industrial activities concentrated in highly skilled technological and electronic firms. Agriculture, food processing, and related pursuits also contribute to the local
economy.
Competition is provided by 171 banking offices of 18
banks in Santa Clara County, including all of the large
California banks. At present, the charter bank is the
13th largest in size. Competing banks include branches
of the Bank of America, the Wells Fargo Bank, the
Crocker National Bank, and the United California
Bank.
The Commercial National Bank of San Leandro, the
merging bank, was organized in 1964. Since that time,
the bank has established one branch in nearby San
Lorenzo, and has received approval for a second
branch in San Leandro. It has total assets of $15.7
million and IPC deposits of $10.7 million.
The service area of the merging bank is limited to
the city of San Leandro and the unincorporated area
of Alameda County known as San Lorenzo. This area,

located across the bay approximately 20 miles from
San Francisco, contains a population of approximately
105,000 people and has both residential and industrial
sections. The Commercial National Bank of San Leandro has concentrated its efforts toward serving the
smaller commercial and industrial firms in its market
area.
Competition for the merging bank is provided by 17
banks, many of which are branches of such large
California banks as the Bank of America, the Wells
Fargo Bank, and the Crocker National Bank. Local
competition is provided by the First State Bank of
Northern California, San Leandro, which has deposits
of $30.8 million.
At present, there is no competition between the
charter and merging banks. The closest branches of
both banks, located in Milpitas and San Lorenzo, are
over 25 miles apart. Both the distance that separates
the two banks and the heavy concentration of competing banks in the intervening area further emphasize

the non-competitive situation existing between the two
banks.
Consummation of the proposed merger will not have
any adverse competitive effects in the service areas of
the charter and merging banks. The merger will allow
both banks to offer expanded services and thus to become more viable competitors to the local branches of
the large California banks. The two banks complement
each other in that The First National Bank of San
Jose is a retail bank strongly oriented toward services
for the individual customer while the Commercial National Bank of San Leandro has emphasized service to
commercial and industrial businesses. In addition, the
resulting merger will remedy a potential management
succession problem at the Commercial National Bank
of San Leandro.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 23,

1972.

NOTE.—No Attorney General's report received.

BANK OF NORTH CAROLINA, NATIONAL ASSOCIATION, JACKSONVILLE, N.C.,
WINSTON-SALEM,

AND BANK OF WINSTON-SALEM,

N.C.
Banking offices

Name of bank and type of transaction

Total assets
To be
operated

In
operation

Bank of Winston-Salem, Winston-Salem, N.C., with
and Bank of North Carolina, National Association, Jacksonville, N.C. (14676),
which had
merged May 5, 1972, under charter and title of the latter bank (14676). The
merged bank at date of merger had

COMPTROLLER S DECISION

On February 11, 1972, the Bank of Winston-Salem,
Winston-Salem, N.C, and the Bank of North Carolina,
National Association, Jacksonville, N . C , applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Bank of North Carolina, National Association,
the charter bank is seventh largest bank in North Carolina. The bank was originally organized in 1952, and
currently has assets of $250 million and 1PC deposits
of $150 million. It operates 49 offices in 30 communities throughout North Carolina. The Bank of North
Carolina, N.A., is the principal subsidiary of Baneshares of North Carolina, Inc., a recently organized
one-bank holding company.




$4,217,332

2

287,718,384

48

291,935,716

50

Although the charter bank is becoming a statewide
financial institution, it still generates the majority of
its business from the eastern section of the State, where
most of the bank's offices are located in small agriculturally oriented towns and communities. The bank
has recently established offices in Charlotte, Greensboro, and Raleigh in the piedmont section of the State
where the major portion of the State's industry is
located.
The Bank of North Carolina, National Association,
is generally in competition with every major bank in
North Carolina. Its principal competitors include the
Wachovia Bank and Trust Company, National Association, with deposits of $1.6 billion; the North Carolina National Bank, with deposits of $1.5 billion; the

61

First Union National Bank of North Carolina, with
deposits of $1.1 billion; and the First Citizens Bank
and Trust Company, with deposits of $715 million.
The Bank of Winston-Salem, the merging bank, was
established in 1925 as an industrial bank and subsequently became a commercial bank in 1958. The bank
operates three offices in Winston-Salem, and has total
assets of $4.8 million and IPC deposits of $3.4 million.
The economic activity in Winston-Salem and in
Forsyth County, which is situated in the upper piedmont section of North Carolina and has a population
of approximately 214,000 people, is generally well diversified and growing. Forsyth County has about 439
industrial employers, and its total employment was
approximately 190,000 in 1970. The unemployment
figure in the area is generally well below the National
average.
Banking competition in the Winston-Salem area includes the main office and branches of the Wachovia
Bank and Trust Company, National Association, and
branches of the North Carolina National Bank and
the First Union National Bank of North Carolina.
There is no competition between the charter and
merging banks. The closest office of the charter bank
to Winston-Salem is in Greensboro, approximately 25
miles to the east. The next closest office is in Charlotte,
85 miles southwest of the merging bank.
Consummation of the proposed merger will result
in no adverse competitive effects in Forsyth County.
The merger will not materially alter the charter bank's
position in the statewide market. The resulting bank

NORTH CAROLINA NATIONAL BANK, CHARLOTTE, N.C.,

will be in competition with the five largest banks in
North Carolina, all of which have offices in the Winston-Salem area. In addition, the resulting bank will
provide an expanded range of services, many of which
are not presently available from the merging bank,
and will therefore stimulate competition in the area.
Applying the statutory criteria to this application,
it is the view of this Office that the proposed merger
is in the public interest. It is, therefore, approved.
APRIL 4,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest office of Bank of North Carolina, N.A.
to an office of Bank of Winston-Salem is located in
Greensboro, N.C., in adjacent Guilford County, about
30 miles east of Winston-Salem. Due to the distance
between these offices and the small size of Bank of
Winston-Salem, it does not appear that the proposed
merger will eliminate significant existing competition
between the two banks.
The Bank of North Carolina, N.A. is the seventh
largest bank in North Carolina, and the third largest
bank not already operating an office in Winston-Salem.
The Bank of Winston-Salem is the smallest bank in
Winston-Salem, and competes against offices of four
of the five largest banks in North Carolina, one of
which is headquartered in Winston-Salem. The Bank
of Winston-Salem's share of Forsyth County total
deposits is very small, less than 1 percent. Its acquisition by Bank of North Carolina, N.A. will not, therefore, eliminate significant potential competition.

AND CAROLINA BANK OF COMMERCE, EDEN,

)
Name of bank and type of transaction

Total assets

Carolina Bank of Commerce, Eden, N. C , with
and North Carolina National Bank, Charlotte, N.C. (13761), which had
merged May 5, 1972, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER S DECISION

On January 25, 1972, the Carolina Bank of Commerce, Eden, N . C , and the North Carolina National
Bank, Charlotte, N.C, applied to the Comptroller of
the Currency for permission to merge under the charter and with the title of the latter.
The North Carolina National Bank, the charter bank,

62



$30,314,680
1,883,287,655
1,913,684,553

N.C.

Banking offices
In
operation

To be
operated

8
117

125

was organized in 1933. At present, the bank is the
second largest commercial bank in the State, and ranks
fifth in the number of branches it operates. The charter
bank operates 110 offices in 33 communities in North
Carolina, and has assets of $1.7 billion and IPC deposits of $1.01 billion. The bank is highly competitive
in the fields of commercial lending, consumer credit,

business development, and correspondent banking. The
charter bank is the principal subsidiary of the North
Carolina National Bank Corporation, a leading bank
holding company in the State.
The major competitors of the North Carolina National Bank include the Wachovia Bank and Trust
Company, National Association, with deposits of $1.6
billion; the First Union National Bank of North Carolina, with deposits of $1.1 billion; the First Citizens
Bank and Trust Company, with deposits of $715 million ; and the Northwestern Bank, with deposits of $631
million.
The Carolina Bank of Commerce, Eden, N.C., the
merging bank, was established in 1889. This bank
serves the town of Eden and surrounding Rockingham
County through its main office and four branches in
Eden and through its single offices situated in Wentworth, Reidsville, and Elon College. The Elon College
office is approximately 3 miles from Burlington, where
the charter, bank maintains an office, and incident to
the consummation of this proposal, the physical assets
of the Elon College office will be sold by the resulting
bank to the Bank of North Carolina, National Association. The Wentworth office is approximately 8 miles
south of Eden, and the Reidsville office, also in Rockingham County, is 13 miles southeast of Eden. The
merging bank has assets of $26.7 million and IPC deposits of $20.8 million.
Banking competition in Rockingham County derives
from eight banks with 27 banking offices. The major
competitors for the merging bank include offices of the
Wachovia Bank and Trust Company, National Association; the First Citizens Bank and Trust Company,
the Southern National Bank of North Carolina; and
the First National Bank of Reidsville.
The economy of the service area of the merging
bank is relatively static in comparison with the economic growth of the rest of the State. Of the 36 industrial plants in Rockingham County that employ 50
or more people, 25 are engaged in the manufacture of
textiles or apparel. The textile industry has experienced
difficulties in recent years which have caused the closing of several textile firms in the Reidsville area. That
indicates a need for diversification to broaden the economic base of Rockingham County. In contrast, the
charter bank is essentially a statewide institution which
generates the majority of its business from the piedmont section of the State, wherein the major portion
of the State's industry is located.
At present there is minimal competition between the
charter and merging banks because of the distance




separating the two banks and the adequate number of
competitors operating in the intervening space. The
head office of the North Carolina National Bank, in
Charlotte, is situated approximately 120 miles southwest of the head office of the Carolina Bank of Commerce. Assuming the sale of the Elon College office of
the merging bank, the nearest office of the charter
bank to an office of the Carolina Bank of Commerce
is at Greensboro, approximately 35 miles south.
Consummation of the subject proposal will not result in any adverse competitive effects within Rockingham County. The proposed merger will allow the resulting bank to offer an expanded range of services to
the residents of the county and will make it a more
meaningful competitor to the local branches of the
large banks in the area. In addition, the merger will
solve the management succession problem at the Carolina Bank of Commerce created by recent loss of both
its president and its chief executive officer.
Applying the statutory criteria it is the view of this
Office that the proposed merger is in the public interest and is, therefore, approved.
APRIL 4,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

North Carolina National Bank operates no banking
offices in Rockingham County. Its closest offices are in
Greensboro, about 22 miles southwest of Reidsville,
and in Burlington, about 25 miles southeast of Reidsville. According to the application, North Carolina
National Bank draws about $200,000 in demand deposits from the service area of Carolina Bank, an
amount equal to about 3.5 percent of the latter's demand deposits. No data is available with respect to
other types of business (time and savings deposits,
loans) drawn by North Carolina National Bank from
this area. However, North Carolina National Bank in
all probability makes some types of loans in this area.
For instance, NCNB may make direct or indirect automobile loan to residents of Rockingham County which,
in the aggregate, may be substantial enough to warrant
competitive concern. Since the application supplies no
information on which to assess this competition, the
department is seeking additional information from
NCNB about its operations in this line with respect to
Rockingham County. In any event, it would appear
that the proposed merger would eliminate some existing competition.
North Carolina National Bank's Burlington offices
would appear to compete more directly with the Carolina Bank branch at Elon College. However, the appli-

63

cation states that North Carolina National Bank has
entered into an agreement with Bank of North Carolina, N. A., for the purchase of the physical assets of this
branch. If this agreement is consummated Bank of
North Carolina, N. A., will in part replace Carolina
Bank as a competitive alternative in the Burlington
area.
Under North Carolina law, North Carolina National
Bank could be permitted to establish de novo branches
in Rockingham County and become a new competitive
banking alternative. North Carolina National Bank is
the largest bank in North Carolina not presently operating offices in this county, and is clearly capable of
establishing de novo branches. Rockingham County,
however, has not been an area of extensive growth,
which diminishes the possibilities for extensive short
term de novo branching. Nonetheless, North Carolina
National Bank would appear to have powerful incentives to enter Rockingham County, in order to keep
abreast of its major statewide competitors, and to protect its existing customer relationships, as well as compete for new business. And in that respect, it is relevant
that a small independent bank (with deposits of about
$7 million) also operates in the county, a situation
which raises the possibility that NCNB could gain a
foothold in the county by a merger which might well
be pro-competitive and, in any event, would be substantially less anticompetitive than would be its combination with the county's largest bank.
As of June 30, 1970, eight banks operated offices in

SECURITY NATIONAL BANK, HUNTINGTON, N.Y.,

Rockingham County. Carolina Bank held the largest
share of deposits in the county, about 21.4 percent.
The three leading banks in the county (including a
bank recently merged into Wachovia Bank and Trust
Company, N. A.) held about 57 percent. The proposed
acquisition would tend to perpetuate concentration in
this county and, taken in the context of the recent
merger of First State Bank, Reidsville, into Wachovia,
could deter entry into the county by other less capable
potential entrants.
In a very realistic sense, the situation presented in
Rockingham County by the proposed acquisition is
characteristic of statewide developments in North
Carolina over the past several years. In the last 5 years,
the five largest banks in the State have acquired at
least seven banks with deposits in the $15-25 million
range, thus acquiring in the aggregate about $140 million in deposits. These banks have been eliminated as
potential element in newly developing regional and
statewide banks which present the greatest possibility of
effective statewide competition to existing banking
giants such as North Carolina National Bank. By acquiring banks of this size, and their leading positions in
localized banking markets, rather than entering de novo
or through smaller mergers, the largest banks in the
State have continued to extend their dominance.
In view of this statewide trend, and of its clear demonstration of Rockingham County, we conclude that
the proposed acquisition would have an adverse effect
on competition.

AND ROYAL NATIONAL BANK OF N E W YORK, N E W YORK,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Royal National Bank of New York, New York, N.Y. (15029), with
and Security National Bank, Huntington, N.Y. (6587), which had
merged May 5, 1972, under charter and title of the latter bank (6587). The
merged bank at date of merger had

COMPTROLLER S DECISION

On December 30, 1971, Security National Bank,
Huntington, N.Y., and Royal National Bank of New
York, New York, N.Y., applied to the Comptroller
of the Currency for permission to merge under the
charter and title of the former with the head office
of the resulting bank to be located at 31 Main Street,
Hempstead, Nassau County, N.Y.

64



$283, 329, 958
1,401,513,359
1,684,379,988

To be
operated

12
71
83

Security National Bank, the charter bank, was
organized in 1903 as the First National Bank of Huntington, and assumed its present name in 1968. This
bank, which is the largest of 15 banks headquartered
in Suffolk County, Long Island, has deposits of $1.1
billion. It has 70 offices, 16 of which are located in
Nassau County, 53 in Suffolk County, and one in
Queens County. Security National Bank also main-

tains a New York City office which is not a branch.
In addition to existing branches, the charter bank
has obtained approval to establish eight additional
branch offices in Suffolk County and three in Nassau
County.
Royal National Bank, the merging bank, was organized on November 5, 1925, under the name Royal
Investment Finance Corporation. On November 30,
1962, after a number of name changes and reorganizations, it was chartered as a National bank and, on
February 1, 1963, it assumed its present name. The
bank, with deposits of $234 million, ranks 15th in size
among the 47 banks headquartered in New York City.
Competition between the charter bank and the
merging bank is negligible. The head offices of these
banks are approximately 40 miles apart. Their nearest offices are the charter bank's Long Island City
branch and the merging bank's head office which are
3.2 miles apart. While the primary area served by the
charter bank is Suffolk County and southeastern
Nassau County, the merging bank serves selected areas
of Manhattan, Brooklyn, Queens, and the Bronx.
Indeed, the proposed merger will not eliminate
existing competition but will enable the resulting bank
to compete more effectively for local and National
customers in the New York City area. It is anticipated that the resulting bank will emerge as a particularly aggressive competitor for the business of metropolitan area firms which have loan requirements up
to $5 million and whose executives prefer to deal with
a bank's senior management. Upon completion of the
proposed transaction, the resulting bank, with deposits
in excess of $1 billion, will be 12th in size of all commercial banks in the New York-Long Island area. Its
capital funds will exceed $118 million and its lending
limit will be more than $12 million.
In addition to serving the convenience and needs
of the community by adding an additional competitor
for medium-sized New York City firms, the proposed
merger will resolve a potential management succession
problem at the merging bank. Furthermore, existing
customers of the merging bank will have a larger lend-




ing limit and other important services such as overdraft checking available to them.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
APRIL 5,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the two banks are about 40 miles
apart. Security Bank operates only one banking office
in New York City while Royal Bank operates no offices
outside the city. Security Bank's office in Queens, however, is located directly across the East River from
Mid town Manhattan. Security Bank obtains 4.3 percent of its deposits and 22.9 percent of its loans from
New York City, while Royal Bank obtains smaller,
but significant, proportions of its business from Nassau
and Suffolk counties. Thus, it appears that despite the
significant distances which separate most of the offices
of the two banks the merger would eliminate some
existing competition between them.
The New York branching laws would permit Royal
Bank to branch de novo into Nassau County in competition with Security Bank, and Security Bank to
branch into Queens County (Queens Borough) and
Kings County (Brooklyn Borough) in competition with
Royal Bank. Should Security Bank change the location of its head office to Nassau County, as it is applying to do concurrently with this merger, Security Bank
could branch de novo throughout New York City.
In recent years Security Bank has significantly increased its commercial business obtained from New
York City customers, an indication that Security Bank
is a potential de novo entrant into the city. Security
Bank has already begun such expansion through its
office in Queens and its commercial lending office in
the city. Thus, to the extent the two banks are not now
competing with each other because of the distances
between most of their offices, the merger would eliminate potential competition between them. Because of
the relatively small market position held by Royal Bank
in New York City, however, the effect of the merger
on competition would not be significantly adverse.

65

WESTERN PENNSYLVANIA NATIONAL BANK, PITTSBURGH, PA., AND ECONOMY BANK OF AMBRIDGE, AMBRIDGE, PA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Economy Bank of Ambridge, Ambridge, Pa., with
was purchased May 6, 1972, by Western Pennsylvania National Bank, Pittsburgh,
Pa. (2222), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On January 11, 1972, the Western Pennsylvania
National Bank, Pittsburgh, Pa., applied to the Office
of the Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of the
Economy Bank of Ambridge, Ambridge, Pa.
The Western Pennsylvania National Bank, the purchasing bank, is the third largest of all commercial
banks operating in the metropolitan Pittsburgh area.
The bank has assets of $1.2 billion and IPC deposits
of $791.8 million. The bank, headquartered in downtown Pittsburgh, operates 79 branches in five of the
six counties that surround its headquarters city. That
network of branches covers an area of approximately
4,500 square miles.
In the five-county area where the purchasing bank
has established community offices, there are 46 commercial banks with aggregate deposits in excess of $9
billion. Those banks offer a full range of services
through 428 offices. The major competitors for the
purchasing bank include the Mellon National Bank
and Trust Company, Pittsburgh, with total deposits
of $4.9 billion; the Pittsburgh National Bank, Pittsburgh, with total deposits of $1.5 billion; and the
Union National Bank of Pittsburgh, with total deposits of $716 million.
The Economy Bank of Ambridge, the selling bank,
is the 28th largest commercial bank in the six-county
area which surrounds Pittsburgh. This bank, originally
founded in 1900 and later reorganized in 1934, has
total assets of $16.7 million and IPC deposits of $14.1
million.
The topography of the six-county trade area that
surrounds Pittsburgh has caused the development of
myriad isolated and distinct communities. That in
turn has caused localization of very distinct and separate banking areas. As a result, the deposits and loans
of the Economy Bank of Ambridge originate within a
2-mile radius of its office. The selling bank is located in
Beaver County at a point 16.5 miles from downtown

66



$17,206,575
1, 177, 151,272
1, 194, 357, 847

To be
operated
1

77
78

Pittsburgh. The trade area of the bank consisting of
the land within a 2-mile radius of Ambridge, includes
Ambridge Borough, Leetsdale Borough, Leet Township, Bell Acres Borough, Harmony Township, and a
portion of Economy Borough. That area, which contains 19,000 people and is economically depressed, is
a small segment of the overall trade area of the purchasing bank. The banks most competitive with the
selling bank are local branches of the Mellon National
Bank and Trust Company, situated one block northwest, and the Pittsburgh National Bank, situated two
blocks northwest of the sole office of the Economy
Bank of Ambridge.
In contrast to the restricted service area of the selling bank, the Western Pennsylvania National Bank
stretches its resources across six counties, including
Allegheny, Armstrong, Beaver, Butler, Washington,
and Westmoreland counties. By means of its large network of branch offices, the purchasing bank surmounts
the geographical barriers that divide those counties
into isolated communities. The heart of this trade area
is a vital center of heavy industry, commerce, and
business.
At present, there is no significant competition between the purchasing and selling banks. The closest
offices of the selling bank and the Western Pennsylvania National Bank are 2.35 miles apart. Although
the selling bank is located in a small segment of the
overall trade area of the purchasing bank, the market
areas are separated and clearly defined by natural
physical barriers and outmoded traffic patterns. This
isolation negates any interchange between the two
banking markets and prevents common depositors.
Upon consummation, the proposed purchase will not
produce any adverse competitive effects. The selling
bank is located in a geographical pocket of retarded
economic activity and competes against branches of
much larger banking organizations headquartered in
Pittsburgh. The purchase of this bank by Western
Pennsylvania National will enable the resulting unit in

Ambridge to offer an expanded range of services that
will enable it to compete more effectively with neighboring banks. Those improved services will include revolving credit programs, check cashing services, computer services, a broad range of savings programs, and
the introduction of a trust department.
Applying the statutory criteria, it is the view of this
Office that the proposed purchase is in the public
interest and it is therefore approved.
APRIL 6,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Western Pennsylvania National Bank is the third
leading bank in the Pittsburgh area, and operates banking offices throughout this area, including offices in
Beaver County and in areas of adjoining Allegheny
County near Ambridge. The closest office of Western

Pennsylvania National Bank to Ambridge is its Quaker
Valley office, located in Leetsdale Borough, Allegheny
County, at a distance of about 2.3 miles. In view of
this proximity, and of the area-wide significance of
Western Pennsylvania National Bank, it is likely that
the proposed merger would eliminate existing competition between the parties for banking business originating in the area presently served by Economy.
Four banks operate a total of five banking offices
in those boroughs and townships listed in the application as totally or partially within the service area of
Economy. Economy holds about 30 percent of deposits
in these offices, while Western Pennsylvania National
Bank holds almost 5 percent. While this area may
understate the relevant market affected by the proposed
merger, we conclude that this merger would have an
adverse effect on competition.

CROCKER NATIONAL BANK, SAN FRANCISCO, CALIF., AND THE FIRST NATIONAL BANK OF UPLAND, UPLAND,
CALIF.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The First National Bank of Upland, Upland, Calif. (8266), with
was purchased May 19, 1972, by Crocker National Bank, San Francisco, Calif.
(1741), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On May 19, 1972, application was made to the
Comptroller of the Currency by the Crocker National
Bank, San Francisco, Calif., for permission to purchase
the assets and assume deposit liabilities of The First
National Bank of Upland, Upland, Calif.
In accordance with the provisions of 12 U.S.C.
1828(c) (6), it is found that an emergency exists and
that this Office must act immediately to prevent the




$12,322,431
5, 593, 438, 496
5, 605, 760, 927

1
286
287

probable failure of The First National Bank of Upland
and to protect its depositors, creditors, and
shareholders.
Accordingly, the application of the Crocker National
Bank to purchase the assets and assume the deposit
liability of The First National Bank of Upland is
approved.
MAY 19, 1972.
NOTE.—Due to the emergency nature of the situation, a

report on competitive factors was not requested.

67

T H E FARMERS NATIONAL BANK OF LITITZ, LITITZ, PA., AND T H E FIRST NATIONAL BANK OF INTERCOURSE, INTERCOURSE, PA.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The First National Bank of Intercourse, Intercourse, Pa. (9216), with
and The Farmers National Bank of Lititz, Lititz, Pa. (5773), which had
consolidated June 5, 1972, under charter of the latter bank (5773) and title
"Farmers First National Bank." The consolidated bank at date of consolidation had.

COMPTROLLERS DECISION

On October 14, 1971, The Farmers National Bank
of Lititz, Lititz, Pa., and The First National Bank of
Intercourse, Intercourse, Pa., applied to the Office of
the Comptroller of the Currency for permission to consolidate under the charter of The Farmers National
Bank of Lititz, and with the title "Farmers First National Bank."
The Farmers National Bank of Lititz, the charter
bank, was chartered in 1901, and currently has assets
of $52.6 million and IPC deposits of $45,3 million.
The charter bank has established three de novo branch
offices and its 10-year record reflects an aggressive
growth in total assets from $12 million, in 1960, to
over $50 million, today. Although the charter bank is
headquartered in Lititz, a community with a population
of 7,000 people, it is only 9 miles from Lancaster city,
a large commercial area. The charter bank, through its
branching activity, has penetrated into the Lancaster
city limits, and thus has come into direct competition
with the largest banks in Lancaster. The service area
of The Farmers National Bank of Lititz must be defined in terms of the entire county of Lancaster.
The major competitiors of the charter bank include
the National Central Bank, Lancaster, with total deposits of $532 million; the Fulton National Bank of
Lancaster, Lancaster, with total deposits of $145.6 million; and the Commonwealth National Bank, Lancaster, with total deposits of $92.9 million.
The First National Bank of Intercourse is located in
a small town with a population of approximately 1,300
people, and can be described as a conservative, locallyoriented, country bank. The bank was chartered in
1908, and currently has total assets of $10 million and
IPC deposits of $8.8 million. The bank has no branches
and its service area is restricted to the surrounding
community. The First National Bank of Intercourse
has only one active executive officer who holds the title
of cashier and who acts in all capacities, both man-

68



$11,301,452
62, 553, 643
74,000, 162

1
4

5

agerial and clerical. The proposed consolidation will,
therefore, provide a solution to the bank's management
succession problem arising from its inability to attract
personnel to succeed the present cashier. The town of
Intercourse is a one-bank town and, therefore, The
First National Bank of Intercourse faces virtually no
competition.
Both the charter bank and the consolidating bank
share a common economic base in their respective service areas. Of primary importance are both light and
heavy industry, agriculture, and tourism. There are
643 widely diversified industries in Lancaster County
with production of nearly $1.4 billion. In addition, agricultural crops, dairy farming, and livestock contributed
$178 million to the economy of the county in 1970.
The Amish people provide Lancaster County with a
tourist industry of approximately $90 million. The
growth prospects for the county in all three areas are
considered excellent.
At present, competition between the consolidating
banks is negligible since each bank has developed a separate and distinct trade area. The Farmers National
Bank of Lititz has directed its trade from Lititz toward
Lancaster to the south and west. The First National
Bank of Intercourse has restricted its trade to the town
of Intercourse, located several miles to the east of the
service area of the charter bank. Any common customers are due primarily to the small loan limit of the consolidating bank which has caused local customers with
large credit requirements to seek the resources of larger
banks.
Consummation of the proposed consolidation will
not have an adverse effect upon competition in Lancaster County. The impact of the consolidation will
primarily be felt in the Intercourse community. The
resulting bank's office in Intercourse will be in a much
better competitive position to serve the needs of its community. The expanded loan limit will allow the bank
to retain the larger local customers who previously
were forced to seek the services of nearby banks for ex-

tended credit needs. The resulting bank will also be
able to offer a wide variety of services previously not
available to local customers, such as installment loans,
trust services, the introduction of a major credit card,
advanced auditing techniques, and computerized services. The remaining 20 commercial banks in Lancaster
County will insure adequate banking alternatives to the
residents of the area.
Accordingly, it is the view of this Office that the proposed consolidation is in the public interest and will
have no adverse competitive effects. It is, therefore,
approved.
DECEMBER 17,1971.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Lititz Bank has its main office in Lititz, 8 'niles north
of the city of Lancaster, and three branches between

Lititz and Lancaster. Intercourse Bank is 12 miles east
of Lancaster.
Intercourse Bank lies about 15 miles east of the
nearest branch of Lititz Bank, and is within 20 miles
of all four offices of Lititz Bank. Competitive banking
offices intervene between Intercourse Bank and Lititz
Bank. It would appear that some competition between
Lititz Bank and Intercourse Bank would be eliminated
by the proposed consolidation.
As of June 30, 1970, 21 banks operated offices in
Lancaster County. The three leading banks held 52.4
percent of total deposits in county commercial banks.
Lititz Bank, the fourth leading bank, held 6.0 percent
of such deposits, and Intercourse Bank held 1.3 percent. The consolidated bank would hold 7.3 percent of
total county commercial bank deposits.

FIRST NATIONAL BANK & TRUST CO., WASHINGTON, PA., WASHINGTON, PA., AND COMMUNITY BANK OF PITTSBURGH,
PITTSBURGH, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Community Bank of Pittsburgh, Pittsburgh, Pa., with
was purchased June 9, 1972, by First National Bank & Trust Co., Washington,
Pa., Washington, Pa. (5920), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On February 28, 1972, the First National Bank &
Trust Co., Washington, Pa., Washington, Pa., applied
to the Office of the Comptroller of the Currency for
permission to purchase the assets and assume the liabilities of the Community Bank of Pittsburgh, Pittsburgh, Pa.
The First National Bank & Trust Co., the purchasing bank, is headquartered in Washington, Pa.,
and through a network of 11 offices, serves Washington
County, eastern Greene County, western Fayette
County, and southwest Allegheny County. The bank
was established in 1901, and currently has assets of
$99.4 million and IPC deposits of $78.9 million. The
economy of the service area of this bank is supported
by a wide variety of businesses and industries ranging
from coal mining in Fayette and Greene counties to
light and heavy manufacturing in Washington and
Allegheny counties. The bank serves an estimated
180,000 people.




To be
operated

$5, 159,913

1

107, 478, 276
112,638, 189

11

12

The purchasing bank is the only independent bank
headquartered in Washington County and thus competes with branches of all the large Pittsburgh-based
banks. These competitors include the Mellon National
Bank and Trust Company, with deposits of $4.9 billion; the Pittsburgh National Bank, with deposits of
$1.5 billion; and the Union National Bank, with deposits of $716 million.
The Community Bank of Pittsburgh, the selling
bank, was incorporated in November 1967, and currently has assets of $4.6 million and IPC deposits of
$3.5 million. Since its inception, the selling bank has
encountered managerial and operating problems that
have become more acute in the last year. Through its
single office, the bank serves the primarily residential
community that surrounds its location and which has
a population of approximately 10,000 people.
The major competitors of the selling bank consist
of local branches of the Mellon National Bank and
Trust Company, the Pittsburgh National Bank, and

69

the Union National Bank, all of which are headquartered in downtown Pittsburgh, approximately 5 miles
from Community Bank of Pittsburgh. Within a 2-mile
radius of the selling bank are 11 savings and loan
associations.
Competition between the purchasing and selling
banks is nonexistent. The closest branch of the purchasing bank is its Carnegie office, 7 miles from the
selling bank. Natural boundaries as well as the adequate number of large competitors in the intervening
distance preclude the possibility of any competition
between the two banks.
Consummation of the proposed transaction will not
result in any adverse competitive effects in the service
area of the selling bank. The selling bank, which is the
smallest bank in Allegheny County, will be replaced
by an office of a larger, aggressive bank which will

compete near the headquarters of the large multibillion dollar Pittsburgh banks. Thus this proposal will
act to stimulate banking competition in the service
area of the selling bank. The resulting unit in Pittsburgh will offer an expanded range of services including an increased lending limit, trust services, credit
card services, data processing, and more flexible savings programs to its customers. In addition to offering
more services to local residents, consummation of the
subject proposal will ameliorate the operating difficulties of the selling bank.
Applying the statutory criteria, it is the view of this
Office that the proposed transaction is in the public
interest and is, therefore, approved.
MAY 9, 1972.
NOTE.—No Attorney General's report received.

FIRST NATIONAL STATE BANK OF NORTH JERSEY, HACKENSACK, N.J.,

AND RIDGEFIELD PARK TRUST COMPANY

RlDGEFIELD PARK, N.J.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Ridgefield Park Trust Company, Ridgefield Park, N.J., with
and First National State Bank of North Jersey, Hackensack, N.J. (12014), which
had
merged June 23, 1972, under charter and title of the latter bank (12014). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 8, 1971, the Ridgefield Park Trust
Company, Ridgefield Park, N. J., and the First National
State Bank of North Jersey, Hackensack, N.J., 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 First National State Bank of North Jersey,
Hackensack, N.J., the charter bank, was organized in
1921, and currently holds IPC deposits of $43.9 million. In December 1970, the charter bank assumed its
present title and became a subsidiary of First National
State Bancorporation, Newark, the largest registered
bank holding company in the State, which has total deposits of $984 million. At present, the charter bank is
24th largest of the 85 commercial banks in the First
Banking District of New Jersey, and ranks seventh in
size of the 29 commercial banks in Bergen County.
The First National State Bank of North Jersey

70



To be
operated

$19,379, 193
57,719,663
77, 098, 856

operates four offices, and has one approved but as yet
unopened branch, all in Bergen County, which has a
population of 900,000 people. Competition comes
from Bergen County-based banks including Peoples
Trust of New Jersey, Hackensack, with total deposits
of $726 million, a member of United Jersey Banks,
a registered bank holding company with total deposits of $940 million; the National Community Bank
of Rutherford, Rutherford, with total deposits of $430
million; and the Garden State National Bank, Hackensack, with total deposits of $341 million. Additional
banks operating branches in the county include New
Jersey Bank, National Association, Clifton, with total
deposits of $513 million; and Commercial Trust Company of New Jersey, Jersey City, with total deposits
of $216 million. Keen competition is also offered by
multi-billion dollar banks located in New York City,
where many Bergen County residents commute daily.
The Ridgefield Park Trust Company, Ridgefield
Park, N.J., the merging bank, was originally chartered

in 1910, and currently has IPC deposits of $14.4 million. The bank is currently the 60th in size of the 85
commercial banks in the First Banking District of New
Jersey, and is the 22nd largest of the 29 commercial
banks located in Bergen County.
The merging bank operates one office in Ridgefield
Park, a town with a population of 14,000 people. Competition in the area of the merging bank derives from
the Peoples Trust of New Jersey, Hackensack; National Community Bank of Rutherford, Rutherford;
and the Garden State National Bank, Hackensack.
Competition is also furnished by large New York City
banks.
The service area of the First National State Bank
of North Jersey consists of all of Bergen County, a residential, commercial, and industrial area which has experienced rapid growth in the recent past. The county
has a population of 900,000 people. The merging bank
primarily serves Ridgefield Park and its environs, a
residential community located in Bergen County which
has many residents who are employed in New York
City. The service area of the merging bank is approximately 109,000.
At present, the service areas of the charter and
merging banks overlap to a limited degree. The nearest
office of the First National State Bank of North Jersey
is in Little Ferry, 1.8 miles from Ridgefield Park. The
two offices are separated by the Hackensack River,
which acts as a natural barrier between the two banks;
Route 46 provides limited access between the two
communities. In spite of the close proximity of the
two banks, consummation of the proposed merger will
stimulate competition since it will open Ridgefield
Park to de novo branching by elimination of the "head
office protection" which the merging bank currently
enjoys. As evidence of that, Peoples Trust of New Jersey, Hackensack, has filed an application for a branch
in Ridgefield Park contingent upon consummation of
the proposed merger.
The $73 million resulting bank, with deposits of $66
million, will rank 23rd in size of the 84 remaining
commercial banks in the First Banking District, and
will still rank 7th in size of the 28 commercial banks
in Bergen County. The merger will not significantly
alter the size of the First National State Bancorporation, the parent company of the charter bank. Competition from other registered bank holding companies
will be provided by United Jersey Banks, Hackensack,
with total deposits of $940 million; Midlantic Banks,
Inc., Newark, with total deposits of $773 million; and
Fidelity Union Bancorporation, Newark, with total
deposits of $762 million.




The resulting bank will be able to provide expanded
services to the residents and businessmen of Ridgefield
Park, including drive-in facilities, an increased loan
limit, international banking facilities, and trust services. In addition, a management succession problem
which now threatens the Ridgefield Park Trust Company will be solved by the merger.
Accordingly, it is the view of this Office that the
proposed merger is in the public interest and will not
adversely affect competition. The application is therefore approved.
MAY 23, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

North Jersey's closest office to Ridgefield Bank is
located about 1.8 miles distant in Little Ferry. There
are no offices of other commercial banks in the intervening area. According to the application, North
Jersey's primary service area does not encompass Ridgefield Park. However, in view of its proximity to this
area, it seems clear that North Jersey, along with other
banks in the Hackensack area, is a convenient alternative for banking services for customers which also look
to Ridgefield Bank.
While Ridgefield Bank draws over half of its deposits
from Ridgefield Park, its service area also includes the
nearby communities of Teaneck, Bogota, Little Ferry,
and Hackensack, three of which are also within the
service area of North Jersey. It is apparent that the
proposed merger would eliminate existing direct competition between the merging banks.
Seven commercial banks operate 22 banking offices
in the service area of Ridgefield Bank as defined in the
application. The three offices of North Jersey in this
area hold about 8 percent of total commercial bank
deposits in these offices; Ridgefield Bank holds about
3 percent. While these percentages do not take account
of deposits which originate in this area and are held
by outside banks, (and so may overstate the market
shares of the merging banks), they do include all
deposits in the head offices of two of the larger banks
in Bergen County, Peoples Trust of New Jersey, and
Garden State National Bank, a great deal of which
may well originate outside the area.
The proposed merger is First National State Bancorporation's second acquisition of a bank serving the
Greater Hackensack Area within 1 year. Permitting
large banking institutions to make repeated acquisitions
in the same market areas would not only eliminate competition between the banks that are acquired; it would

71

also eliminate entry vehicles for other banks which
might seek to enter the market. Therefore, while the
proposed merger would eliminate home office protec-

tion presently accorded the community of Ridgefield
Park, we conclude that its overall effect on competition
would be adverse.

T H E UNION NATIONAL BANK OF YOUNGSTOWN, YOUNGSTOWN, OHIO, AND T H E NORTH BLOOMFIELD BANKING
COMPANY, NORTH BLOOMFIELD, OHIO
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The North Bloomfield Banking Company, North Bloomfield, Ohio, with
and The Union National Bank of Youngstown, Youngstown, Ohio (13586), which
had
merged June 27, 1972, under charter and title of the latter bank (13586). The
merged bank at date of merger had

COMPTROLLER S DECISION

On February 3, 1972, The Union National Bank of
Youngstown, Youngstown, Ohio, applied to the Comptroller of the Currency for permission to merge with
The North Bloomfield Banking Company, North
Bloomfield, Ohio, under the charter and with the title
of the former.
The Union National Bank of Youngstown, the charter bank, was chartered in 1931. This bank has total
assets of $149 million and IPC deposits of $102.2
million. Because Youngstown, the location of the charter bank's main office, lies in both Mahoning and
Trumbull counties, The Union National Bank of
Youngstown may branch into both counties. At present
the bank has seven branch offices in Mahoning County
and one branch in Trumbull County. Five of those
branches are located in Youngstown, and one each in
Austintown, Canfield, and Poland.
The major competitors for the charter bank in
Mahoning County include the Dollar Savings and
Trust Company in Youngstown, with deposits of $207
million; the Mahoning National Bank of Youngstown,
with deposits of $138 million; The Peoples Bank of
Youngstown, with deposits of $33 million; and the
Farmers National Bank of Canfield, with deposits of
$30 million.
The North Bloomfield Banking Company, the merging bank, was originally organized in 1903. This bank,
with assets of $14.3 million and IPC deposits of $12.4
million, operates one branch, opened in 1955, in
Campion, a suburb of Warren. It has two major problems at the present tune, viz., the members of the bank's
management group are approaching the retirement

72



To be
operated

$15, 760, 951

2

158,026,680

9

175,472,146

11

age, and no provisions have been made for their succession, and the bank lacks sufficient capital.
The merging bank's major competitors in Trumbull County include the Second National Bank of
Warren, with total deposits of $102 million; the Union
Savings and Trust Company, Warren, with deposits
of $130 million; and the Niles Bank Company, Niles,
with deposits of $25 million.
Mahoning and Trumbull counties, wherein the
charter and merging bank are headquartered, have
long been considered major producing areas of steel
and other primary metals. Consequently, the economy
of the area is heavily dependent on those industries.
During the past decade a decline in steel oriented
manufacturing has produced adverse economic effects
in the Youngstown area. In contrast, Trumbull
County has benefited from diversification in its industrial base and has continued to show growth in
population, as well as in wholesale and retail trade.
The closest branches of the charter and merging
banks are situated approximately 20 miles apart. That
distance precludes significant direct competition.
Consummation of the proposed merger will not produce any adverse competitive effects in Mahoning
and Trumbull counties. At present, 14 commercial
banks in the two-county area operate a total of 65
branch offices. The charter bank is the fourth largest
in terms of total deposits and the fifth largest in terms
of total loans; the merging bank is the 12th largest in
terms of both deposits and loans. The resulting bank
will be the third largest in deposits and the fourth
largest in loans in the two-county trade area. Thus,
the total competitive impact will be negligible in view

of the alternative banking facilities that will remain
in the area. In addition, the subject merger will add
management depth to the merging bank, will rectify
the capitalization problem, and will result in a broader
range of services for the residents of North Bloomfield, including a larger lending limit and the introduction of complete trust services.
Applying the statutory criteria, it is the view of this
Office that the proposed merger is in the public interest, and is, therefore, approved.
MAY 8, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The merging banks' main offices are 28 miles apart.
Bloomfield Bank's Champion Heights branch is approximately 14 miles northwest of four branches of
Union Bank; six banks have offices intervening between

the closest branches of the merging banks. It therefore
appears that the merging banks are not substantial
competitors to one another and that the merger would
not eliminate any significant existing competition.
As of June 30, 1970, Bloomfield Bank held approximately 4 percent of total deposits in the nine banks in
Trumbull County. As of June 30, 1971, Union Bank
held 24 percent of Mahoning County total bank deposits, the third largest share held by any of the seven
banks in the county. Their respective shares of deposits
in the Youngstown-Warren Standard Metropolitan
Statistical Area ("SMSA") are about 12 percent and
2 percent. Although Union Bank is the largest bank
without offices in Trumbull County which can legally
branch into that county, its acquisition of the relatively
small Bloomfield Bank would not have a significantly
adverse effect on potential competition.

CENTRAL NATIONAL BANK, CANAJOHARIE, CANAJOHARIE, N.Y., AND T H E FIRST NATIONAL BANK OF EDMESTON,
EDMESTON,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Edmeston, Edmeston, N.Y. (3681), with
and Central National Bank, Canajoharie, Canajoharie, N.Y. (1122), which had. .
merged June 30, 1972, under charter and title of the latter bank (1122). The
merged bank at date of merger had

COMPTROLLER S DECISION

On January 25, 1972, The First National Bank of
Edmeston, Edmeston, N.Y., and the Central National
Bank, Canajoharie, Canajoharie, N.Y., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Central National Bank, Canajoharie, the charter bank, was originally organized in 1885. The bank,
with assets of $58 million and IPC deposits of $44.3
million, operates seven offices and has one additional,
but as yet unopened, branch in Cobleskill. The charter
bank is the 10th largest of the 35 commercial banks
headquartered in the Fourth Banking District of New
York.
The Central National Bank, with total deposits of
$50 million, is the third largest of the 10 commercial
banks headquartered in the four-county area in which
the charter bank operates. Competition is provided by
the National Commercial Bank and Trust Company,
Albany, with total deposits of $917 million; the State




$6, 390, 209
61,707,611
68, 138,012

To be
operated
1
9
10

Bank of Albany, Albany, with deposits of $747 million;
the Albany Savings Bank, with deposits of $384 million; and the Mechanics Exchange Savings Bank,
Albany, with deposits of $120 million.
The First National Bank of Edmeston, the merging
bank, was chartered in 1887. The bank, with assets of
$6.4 million and IPC deposits of $5.1 million, has operated as a unit bank since its inception. The active
management of the bank is supervised by its cashier,
who is 68 years old. There is, at present, no middle level
management personnel who can take control of the
daily functions of the bank when the cashier retires.
The First National Bank of Edmeston is the 34th
largest of the 35 commercial banks in the Fourth
Banking District of New York. Competition includes
the Oneida National Bank and Trust Company of
Central New York, Utica, with deposits of $287 million; the National Bank and Trust Company of Norwich, with deposits of $86 million; the Wilber National Bank of Oneonta, with deposits of $40 million;

73

and the First National Bank of Cooperstown, with
deposits of $10 million.
The primary service area of the merging bank is
limited to the city of Edmeston and its immediate environs, which contain an estimated population of 8,000
people. The area is almost entirely devoted to dairy
farming. Similar in nature, but on a larger scale, the
trade area of the charter bank consists of the fourcounty area of Montgomery, Otsego, Schenectady, and
Schoharie counties. This area serves an estimated
population of 50,000 people. Although the economy of
this area is primarily supported by dairy farming, local
industrial employment is approximately 2,000 and
substantial numbers of people commute to Albany
and Schenectady for employment.
At present, competition between The First National
Bank of Edmeston and the Central National Bank,
Canajoharie, is insignificant. The main offices of the
two banks are 45 miles apart. The nearest office of the
charter bank is located 25 miles from Edmeston. Those
large distances, as well as the large number of financial
institutions located in the intervening area, insure that
very little competition now exists between the charter
and merging banks.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank. The resulting bank will offer improved and expanded services to the residents of the Edmeston area,
including a larger lending limit, higher interest rates
for savings deposits, and the introduction of trust services. The merger will also solve the problem of management succession at The First National Bank of Edmeston. In addition, the resulting bank will not increase
its ranking among competing banks nor will it significantly increase its position among other commercial
banks operating in the Fourth Banking District.

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The application is, therefore, approved.
MAY 23, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Edmeston Bank is the only bank in Edmeston. It is
situated approximately 45 miles southwest of the main
office of Central National in Canajoharie and is approximately 30 miles southwest of the nearest branch
of Central National, which is located in the village of
Cherry Valley, Otsego County, N.Y.
There are several other banks in the intervening
area, including three branches of National Commercial
Bank and Trust Co. of Albany (total deposits of $916.9
million, as of June 30, 1971) in Cooperstown, Hartwick, and Oneonta. The State Bank of Albany (total
deposits of $747.0 million, as of June 30, 1971), maintains a branch in Richfield Springs, approximately 15
miles from Edmeston. It does not appear that the proposed merger would eliminate substantial existing
competition.
The three leading banks in Otsego County hold
about 73.6 percent of total deposits. Edmeston Bank
is the fifth largest of eight in Otsego County and holds
4.3 percent of total deposits in the county, while Central National holds about 3 percent.
Although located within the same branching district,
Central National is prohibited by law from entering
de novo into Edmeston because of home office
protection.
In view of the relative size of Edmeston Bank and
its service area, we do not believe the proposed merger
would have a significantly adverse effect on potential
competition.

JEFFERSON NATIONAL BANK, LAFARGEVILLE, N.Y., AND T H E WADDINGTON BANK, WADDINGTON, N.Y.,
BANK OF PHILADELPHIA, PHILADELPHIA, N.Y.

AND

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Philadelphia, Philadelphia, N.Y., with
The Waddington Bank, Waddington, N.Y., with
and Jefferson National Bank, LaFargeville, N.Y. (13365), which had
merged June 30, 1972, under charter and title of the latter bank (13365). The
merged bank at date of merger had

74



$2,056,210
2, 163, 152
3, 154, 290
7, 373, 652

To be
operated

1
1
1

3

COMPTROLLER S DECISION

On February 15, 1972, the Jefferson National Bank,
LaFargeville, N.Y., the Bank of Philadelphia, Philadelphia, N.Y., and The Waddington Bank, Waddington, N.Y., applied to the Comptroller of the Currency
for permission to merge under the charter and title of
Jefferson National Bank.
The charter bank, with total IPC deposits of $2.2
million, is a single-office bank offering limited banking
services. The bank is faced with problems common
to the other participating banks such as an inadequate lending limit, increasing complexities of bank
operations, difficulty of assuring continuity of management, and increasing competition from larger
banks. The bank ranks sixth in size among the eight
commercial banks headquartered in Jefferson County
which banks have total aggregate deposits of $262 million. It ranks 20th among the 24 commercial banks
located in the Fifth Banking District with about 1 percent of the total bank deposits in the district. Competition in the immediate service area of the bank is
provided by the Marine Midland Trust Company of
Northern New York, Watertown, with seven banking
offices and $149 million in deposits, a subsidiary of the
Marine Midland Banks, Inc.; the National Bank of
Northern New York, Watertown, with seven banking
offices and $93 million in deposits; and the Seaway National Bank of Watertown, with three banking offices
and $7 million in deposits.
LaFargeville, home of the charter bank, is a small
unincorporated hamlet with a population of 581,
located in Jefferson County. Its economy is almost
entirely agricultural. A good many people in LaFargeville are currently employed in Watertown, the largest
city in the county with an estimated population of
30,787. Watertown is located approximately 20 miles
to the south of LaFargeville.
Jefferson County, with an estimated population of
88,508, is predominantly a rural area dotted with
small villages and hamlets. The principal economic
activities of the area are farming, logging, mining, and
service industries related to the St. Lawrence Seaway.
The main industrial and commercial businesses are
centered in Watertown.
The Bank of Philadelphia, with total IPC deposits
of $1.1 million, is the smallest bank in Jefferson County.
It ranks 24th among the 24 commercial banks located
in the banking district, with about 0.3 percent of the
total bank deposits in the district. Direct banking competition is provided by offices of the above-mentioned
banks headquartered in Watertown.
501-017 O—T3


Philadelphia, a small incorporated village with a
population of 858, is located approximately 18 miles to
the east of LaFargeville. Its economy is likewise almost
entirely agricultural with some of its residents traveling 17 miles to Watertown for work.
The Waddington Bank, with total IPC deposits of
$1.8 million, is a small single-office bank located in the
village of Waddington in St. Lawrence County. The
bank ranks 10th in size among the 11 commercial banks
headquartered in the county which together have deposits of $106 million. It ranks 22nd among the 24
commercial banks located in the Fifth Banking District,
with about 0.5 percent of the total bank deposits in the
district. Competition in the immediate service area of
the bank is provided by the St. Lawrence National
Bank of Canton, with nine banking offices and $32
million in deposits; the Ogdensburg Trust Company,
with two banking offices and $25 million in deposits;
the First National Bank of Norfolk, a single-office bank
with $4 million in deposits; and the First National Bank
of Lisbon, a single-office bank with $3 million in deposits.
Waddington is a small incorporated village with a
population of 955. It is located approximately 65 miles
to the northeast of LaFargeville and 63 miles to the
northeast of Philadelphia. Its economy is almost entirely agricultural. Area residents not engaged in farming find employment in Ogdensburg and Massena, the
largest cities in the county with populations of 14,554
and 14,042, respectively. Those cities are approximately
20 miles distant from Waddington.
St. Lawrence County, with an estimated population
of 11,991, is predominantly a rural area. The principal
economic activities, like those of neighboring Jefferson
County, are farming, logging, mining, service-related
industries, and vacation resorts along the St. Lawrence
River. The industrial and commercial businesses of the
area are centered in Ogdensburg and Massena.
The applicant banks do not directly compete with
each other. They operate in different service areas and
competition is provided by intervening offices of other
banks. The participating banks are presently under
common ownership. The merger will not eliminate
potential competition among the participating banks
because of the size of these institutions and the home
office protection under New York State law. The
effect of this merger on overall competition in the
area will not be significant.
Consummation of the proposed merger will bring
together the resources of three small banks and provide for economies of operation and more effective
use of personnel. The resulting bank will be better

75

able to meet the convenience and needs of the communities served by the participants and to compete
with the other banks in the area.
In accordance with the statutory criteria, this merger
is deemed in the public interest. The application is,
therefore, approved.
MAY 30, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

LaFargeville, where Jefferson Bank is located, is

18 miles from Philadelphia and 60 miles from Waddington. The application states that the three banks
are presently under common ownership but does not
reveal sufficient data as to the facts surrounding such
ownership as to lead to firm conclusions^n the weight
to be afforded to this fact. In any case, however, the
distances involved, the presence of intervening banking offices, and the relative size of the merging banks
indicate that no substantial existing or potential competition would be eliminated by the proposed merger.

T H E NATIONAL BANK OF BOYERTOWN, BOYERTOWN, PA., AND T H E FIRST NATIONAL BANK OF OLEY, OLEY, PA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Oley, Oley, Pa. (8858), with
and The National Bank of Boyertown, Boyertcwn, Pa. (2137), which had
merged June 30, 1972, under charter of the latter bank (2137) and title "National
Bank of Boyertown." The merged bank at date of merger had

COMPTROLLER S DECISION

On February 11, 1972, The First National Bank of
Oley, Oley, Pa., and The National Bank of Boyertown, Boyertown, Pa., applied to the Comptroller of
the Currency for permission to merge under the charter
and with the title of the latter.
The National Bank of Boyertown, the charter bank,
was organized in 1874. The bank, with assets of $56.8
million and IPC deposits of $44.7 million, is headquartered in Berks County, and through four branches,
serves northwestern Montgomery County, northern
Chester County, and eastern Berks County. It has one
additional approved branch in Pottstown which is
scheduled to open in June 1972.
The charter bank is the 10th largest of the 13
commercial banks in its trade area. The largest of
those competitors consist of branches of very large
banks headquartered in Philadelphia, Lancaster, and
Reading. Those competitors include the Philadelphia
National Bank, with deposits of $2 billion; the Fidelity
Bank, Philadelphia, with deposits of $1.4 billion;
the American Bank and Trust Company, Reading, with
deposits of $631 million; and the National Central
Bank, Lancaster, with deposits of $576 million.
The charter bank serves an estimated population
of 27,000 people in seven townships. The borough of
Boyertown is essentially industrial while the surrounding area is basically agricultural. Within the trade area

76



$11,526,647
64, 502, 935
76, 029, 581

To be
operated

1
5

6

of the charter bank are 81 businesses that employ
approximately 6,400 people.
The First National Bank of Oley, the merging bank,
was chartered in 1907, and has not participated in
any previous mergers. The bank, with assets of $10.5
million and IPC deposits of $8.8 million, operates as a
unit facility in an isolated rural area where there are
10 businesses employing 77 persons. The bank, drawing
most of its accounts from the village of Oley and environs, serves a population of approximately 3,000.
There are no direct financial competitors in the area.
Indirectly, the merging bank competes with the same
large Philadelphia, Reading, and Lancaster banks
whose extensive banking structures border the trade
area of The First National Bank of Oley.
At present, there is very little competition between
the charter and merging banks. The closest office of
the charter bank to Oley is 10 miles away. That distance, coupled with the self-imposed limitations of the
merging bank on its trade area, minimizes the competitive impact between these two banks.
Consummation of the proposed merger will not have
any adverse competitive effects in Berks County. The
proposed merger will enable the resulting bank to better
serve the eastern portion of Berks County and will
allow the bank to more readily meet the competition
of the large Philadelphia and Reading banks which
have moved into the area. In addition, the merger

will solve the management succession problem at the
merging bank which could become serious.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MAY 8, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the two banks are 10 miles apart,
and the Exeter office of Boyertown Bank is only about
6 miles from Oley. No banking offices intervene between Oley and the Berks County offices of Boyer-

town Bank. Thus, the merger would eliminate some
competition between the two banks.
Boyertown Bank is the fourth largest of 14 banks
operating in Berks County, holding 5.0 percent of
total county deposits on June 30, 1970. The three
largest banks in the county are substantially larger
than Boyertown Bank, holding 82.4 percent of total
county deposits between them. Oley Bank is the 10th
largest bank in the county, holding 1.1 percent of total
county deposits. The proposed merger would not substantially increase concentration in commercial banking in Berks County.

UNITED STATES NATIONAL BANK, SAN DIEGO, CALIF., AND BEVERLY HILLS FIDELITY BANK, BEVERLY HILLS,
CALIF.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Beverly Hills Fidelity Bank, Beverly Hills, Calif., with
was purchased July 14, 1972, by United States National Bank, San Diego, Calif.
(10391), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On July 14, 1972, application was made to the
Comptroller of the Currency by the United States
National Bank, San Diego, Calif., for permission to
purchase the assets and assume deposit liabilities of
the Beverly Hills Fidelity Bank, Beverly Hills, Calif.
In accordance with the provisions of 12 U.S.C.
1828 (c) (6), it is found that an emergency exists and
that this Office must act immediately to prevent the

To be
operated

$88,261,934

3

747, 542, 466
835, 804, 400

62

65

probable failure of the Beverly Hills Fidelity Bank,
Beverly Hills, Calif., and to protect its depositors,
creditors, and shareholders.
Accordingly, the application of the United States
National Bank to purchase the assets and assume the
deposit liabilities of the Beverly Hills Fidelity Bank is
approved.
JULY 14,

1972.

NOTE.—Due to the emergency nature of the situation, a
report on competitive factors was not requested.

PEOPLES NATIONAL BANK OF WASHINGTON, SEATTLE, WASH., AND BOTHELL STATE BANK, BOTHELL, WASH.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bothell State Bank, Bothell, Wash., with
and Peoples National Bank of Washington, Seattle, Wash. (14394), which had. . .
merged July 15, 1972, under charter and title of the latter bank (14394). The
merged bank at date of merger had




$18,654,553
561, 390, 669
574,786,617

To be
operated

4
56

60

77

COMPTROLLER'S DECISION

On March 16, 1972, the Bothell State Bank, Bothell,
Wash., and the Peoples National Bank of Washington,
Seattle, Wash., applied to the Comptroller of the Currency for permission to merge under the charter and
with the title of the latter.
The Peoples National Bank of Washington, the charter bank, was organized in 1889, and is currently the
fourth largest bank in the State of Washington. The
bank, with total assets of $507 million and IPC deposits
of $382.4 million, operates 53 branches, 39 of which
lie in the Puget Sound area of western Washington. Of
the remaining branches, 12 are concentrated in eastern
Washington and the Columbia Basin, and only two are
located in isolated market areas.
The charter bank is one of 10 banks in Seattle and
18 in King County. Competition is provided by the
State's largest bank, Seattle-First National Bank, with
total deposits of $2.3 billion; The National Bank of
Commerce, the second largest bank with total deposits
of $1.6 billion; and the Pacific National Bank of Washington, the third largest bank in the State, with total
deposits of $643 million.
The Bothell State Bank, the merging bank, was organized in 1908, and currently has assets of $16.8 million
and IPC deposits of $13.3 million. The merging bank
operates three branches, two of which are in the adjoining unincorporated communities of Kenmore and
Woodinville, the third is a drive-in facility across the
street from the bank's main office.
Competition for the merging bank is provided by numerous banks located within a 5-mile radius of Bothell.
Those include three branches of the Seattle-First National Bank; three branches of the National Bank of
Commerce, Seattle; the Juanita Branch of the Bank of
the West; and the head offices of the Commercial Bank
of Seattle, Northshore First National Bank, and the
Evergreen State Bank.
Seattle, the head office city of the charter bank and
the center of its service area, is the heart of the Puget
Sound area and has a population of approximately 1.8
million. The economy of the area is based on lumber
and wood products, the manufacture of transportation
equipment, several major utilities, and the retail and
wholesale trade industry. The area is advancing after
an economic decline which reached its nadir in 1969. In
contrast to the statewide character of the service area
of the charter bank, the merging bank primarily serves
a residential market in a "bedroom community" near
Seattle and Everett in Snohomish County. Bothell lies
in a sparsely populated area of King County where

78



future growth is dependent both on the reversal of the
previous economic decline and on strip-type commercial developments intended to meet the needs of local
residents.
There are no branches of the charter bank within
the trade area of the Bothell State Bank, and competition between the two banks is almost nonexistent. The
closest branch of the Peoples National Bank of Washington is located in Kirkland, approximately 8 miles
from the merging bank. The intervening distance is
sparsely populated and is connected by a poor network
of secondary roads hindering travel to Bothell. In addition, sufficient numbers of alternate banking facilities,
in close proximity to the merging bank, prevent the
Kirkland Branch of the charter bank from becoming
a viable competitor.
Consummation of the proposed merger will result in
no adverse competitive effects in the State of Washington. The effect of the merger will be to allow the entry
of a more competitive financial institution into the
Bothell market area; one that offers a greater lending
limit and makes services not now provided more readily available. The merger will also eliminate the immediate problem of management succession now being
experienced at the merging bank. The two separate
and distinct service areas of the charter and merging
banks attest to the fact that no competition will be
eliminated by the proposed merger. On a statewide
basis, the merger will not materially change the present
banking structure but will allow the resulting bank to
compete more effectively with the largest commercial
banks in the State.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore approved.
JUNE 12,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Peoples National was the third largest bank, in terms
of deposits, in King County as of June 30, 1970. As of
that date it held almost 14 percent of total deposits,
and the four largest banks held over 78 percent of
such deposits. Peoples National operates offices in most
urbanized areas of the county as well as offices in
Snohomish County which is directly north of King
County and adjacent to the Bothell area. Because of
this distribution of retail oriented offices, and because
many residents of the Bothell area work in other areas
of King or Snohomish County, Peoples National does
provide an alternative source of banking services to
residents of this area. It presently holds over $1.3 mil-

lion in deposits from residents of the Bothell area and
has almost $1 million in loans outstanding in this area.
The Bothell area is presently served by the offices of
four banks, including the two largest banks in King
County and the State. A fifth bank has an application
pending for a new branch office in this area. Bothell
Bank has the largest share of deposits in banking offices
in this area (over 50 percent) and the largest number
of branches. This merger will eliminate Peoples National as one of only three substantial banks with significant office systems in the region which presently
provide some competitive alternative to the very limited banking choices located within the Bothell area
itself. The proposed merger would eliminate significant existing competition in the Bothell area and increase by almost 1 percent the already very high level
of concentration of banking resources in King County.
Peoples National is the second largest bank in the

State which does not operate an office in the Bothell
area. Under Washington law. Peoples National may
clearly open offices in the Kenmore and Woodinville
portions of the Bothell area, and it may be lawful for
National banks to open offices in Bothell itself. Banking in the Bothell area is highly concentrated and
Bothell Bank holds over 50 percent of deposits in offices
in this area. Thus, the proposed merger would eliminate a substantial potential for increased competition
in the developing areas of King County, in the general
vicinity of Bothell.
This merger would eliminate existing competition
for banking business in the Bothell area and the substantial potential for increased competition. Also, the
proposed merger would continue the concentration
of the State's banking resources in its very largest banks.
We conclude that the proposed merger will have an
adverse effect on competition.

FARMERS FIRST NATIONAL BANK, LITITZ, PA., AND T H E FARMERS NATIONAL BANK OF EPHRATA, EPHRATA, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Farmers National Bank of Ephrata, Ephrata, Pa. (4923), with
and Farmers First National Bank, Lititz, Pa. (5773), which had
merged July 17, 1972, under charter and title of the latter bank (5773). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 24, 1972, The Farmers National Bank of
Ephrata, Ephrata, Pa., and The Farmers National
Bank of Lititz, Lititz, Pa., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title, "Farmers First
National Bank."
The Farmers National Bank of Lititz, the charter
bank, was organized in 1901, and is headquartered in
Lititz, 8 miles north of Lancaster. The bank has assets
of $71.3 million and IPC deposits of $58.8 million. The
charter bank operates four branch offices.
The market area of the charter bank is in central
Lancaster County, covering an area from the city of
Lititz to Lancaster city. The area enjoys an active and
growing economy predicated on light and heavy industry, agricultural pursuits, and tourism. Competitors of
the charter bank include National Central Bank, Lancaster, with deposits of $511 million; The Commonwealth National Bank, Harrisburg, with deposits of




$32,971,030
74, 955, 286
108, 092, 670

To be
operated

3
5

8

$353 million; Fulton National Bank of Lancaster, with
deposits of $130 million; and Dauphin Deposit Trust
Company, Harrisburg, with deposits of $236 million.
The Farmers National Bank of Ephrata, the merging
bank, was organized in 1901, and is headquartered in
Ephrata, approximately 7 miles northeast of Lititz.
This bank has assets of $33.2 million and IPC deposits
of $27.8 million. The merging bank operates two
branch offices both of which are located in Ephrata.
This bank has an elderly management whose policies
have, in the past, been based on conservative banking
principles. Those senior officers will retire soon and
new personnel will be needed to replace them.
The service area of the merging bank is primarily
confined to the city of Ephrata and its immediate environs. Ephrata's economy is adequately supported by
a mixture of light industry and agriculture, similar
to the service area of the charter bank. Competitors
of the merging bank include the locally-based Ephrata
National Bank, with deposits of $37.3 million; a

79

branch of The Fulton National Bank of Lancaster; a
branch of American Bank and Trust Company of
Pennsylvania, Reading, with deposits of $594 million;
and three smaller independent banks in Blue Ball,
Brownstown, and New Holland, which have aggregate
resources of $79 million.
In spite of the close proximity of the charter and
merging banks, a minimum of competition exists between the two banks as they serve separate and distinct
banking markets. The charter bank's market has traditionally extended southward toward Lancaster city
because that is where the bulk of Lancaster County's
banking business is located. In contrast, the merging
bank has voluntarily limited itself to the city of
Ephrata, a policy reflected in the restrictive branching
practice of The Farmers National Bank of Ephrata.
In addition, the communities of Lititz and Ephrata are
separated by farmland and are connected, indirectly,
only by secondary country roads. That further serves
to isolate the service areas of the two banks.
Consummation of the proposed merger will result
in a beneficial competitive impact in the service areas
of both the charter and merging banks. In each of
those respective service areas, the resulting bank will
have a significantly increased lending limit and will,
therefore, become a stronger competitor for the large
financial institutions with which it competes. Yet even
with this significant increase in size, the resulting bank
will remain small as compared to many of its competitors, and so will not upset the competitive posture of
banks in Lancaster County even though it will become

a more effective competitor. The increased competition in Lancaster County, a direct result of the proposed merger, will immediately cause increased benefits
for the banking public in the area. In addition, the
merger will supply the resulting units in Ephrata with
the needed personnel depth to insure their continuity.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JUNE 16,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

FNB Lititz has its main office in Lititz, 7 miles southeast of FNB Ephrata's main office in Ephrata. While
the application indicates that the parties to the proposed merger draw most of their business from different
parts of Lancaster County, they are alternatives for
some customers, primarily in the area between Lititz,
Lancaster, and Ephrata. It would appear that some
competition would be eliminated by the proposed
merger.
As of June 30, 1970, 21 banks operated offices in
Lancaster County. The three leading banks (all located
in the city of Lancaster) held 52.4 percent of total
county deposits. FNB Lititz and another bank which
it has been authorized to acquire would together have
been the county's fourth leading bank and held 7.3
percent of total county deposits, while FNB Ephrata
held 3.8 percent. The consolidated bank, using June 30,
1970 deposit data, would hold 11.1 percent of total
county commercial bank deposits.

NORTH CAROLINA NATIONAL BANK, CHARLOTTE, N.C., AND T H E FARMERS BANK, WOODLAND, N.C.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Farmers Bank, Woodland, N . C , with
and North Carolina National Bank, Charlotte, N.C. (13761), which had
merged July 28, 1972, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 27, 1972, The Fanners Bank, Woodland,
N . C , and the North Carolina National Bank, Charlotte, N . C , applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter.
The North Carolina National Bank, the charter

80



$16,886, 190
1,955, 172,481
1,972,125,047

To be
operated

3
128
131

bank, was organized in 1933. This bank with assets of
$1.9 billion and IPC deposits of $1.2 billion, operates
110 offices in 34 communities throughout North Carolina, ranging from Washington and Wilmington, in
the east, to Tyron and Spruce Pine, in the west. Although essentially a statewide commercial bank, the
North Carolina National Bank generates the majority

of its business from the piedmont section of the State
wherein the major portion of the industry of the State
is situated. In Charlotte and Greensboro, the first and
second largest cities in the State, it is the leading commercial bank. The charter bank is the principal component of NCNB Corporation, a one-bank holding
company.
The North Carolina National Bank is in competition
for certain services with every major bank in the southeast. In North Carolina, the primary competitors for
the charter bank include the Wachovia Bank and
Trust Company, N.A., with deposits of $1.6 billion, and
the First Union National Bank of North Carolina, with
deposits of $1.1 billion, which ranks as the third largest
bank in North Carolina. Other principal competitors
of the charter bank are the First Citizens Bank and
Trust Company, with deposits of $715 million; The
Northwestern Bank, with deposits of $631 million; and
the Branch Banking and Trust Company, with deposits of $263 million.
The Farmers Bank, the merging bank, was organized
in 1906, and is headquartered in Northampton County.
This bank has assets of $18 million and IPC deposits
of $14.2 million. In 1934 and 1958, the merging bank
established two offices in Murfreesboro, located approximately 11 miles northeast of Woodland in Hertford County. The service area of the merging bank
consists of the northeastern portion of Northampton
County and the northwestern section of Hertford
County. The economy of that area is relatively static,
and is primarily dependent on agricultural pursuits
with peanuts, corn, soybeans, and cotton as the principal cash crops.
Although the merging bank is the sole commercial
bank in the town of Woodland, it has strong competition from offices of The Planters National Bank and
Trust Company and the Wachovia Bank and Trust
Company, N.A., as well as from the Bank of Conway.
Those banks are located within a radius of 8 miles
from the Woodland office of the merging bank. The
offices of The Farmers Bank in Murfreesboro are in
direct competition with The Tarheel Bank and Trust
Company.
There is no competition between the charter and
merging banks because large distances separate them
and an adequate number of competitors operate in the
intervening area. The main office of the North Carolina National Bank is located approximately 230 miles
southwest of Woodland. The nearest office of the
charter bank to an office of the Farmers Bank is at




Tarboro, approximately 40 miles south of the merging
bank.
Consummation of the proposed merger will not result in any adverse competitive effects. The merger
will not eliminate any competition and there will remain the same number of banking alternatives located
throughout that portion of the two-county area that
is the service area of the merging bank. Further, the
merger will not significantly increase the statewide deposit structure of the North Carolina National Bank.
The entry of the charter bank into this area should
bring with it the resources necessary to aid in the economic development of the two counties and to promote
the needed diversification of industry. The resulting
branches in Northampton and Hertford counties will
offer increased banking services which will stimulate
competition in the area. That will directly benefit the
banking public within the service area of the merging
bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JUNE 21,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

NCNB does not have any branches in Northampton
or Hertford counties, or in the counties immediately
adjacent to them. Its branch closest to a Farmers Bank
office is more than 40 road miles south in Tarboro.
However, a consumer loan office of Stephenson Finance Company, a NCNB Corporation subsidiary,
operates in Ahoskie which is about 16 miles south
of Murfreesboro and about the same distance east
of Woodland. Its volume of loans is stated to be
$343,877, an amount equal to only about 4.4 percent
of Farmers Bank's total loans, but about 25 percent
of its consumer loans. There are three banks serving
Ahoskie and one bank other than Farmers Bank in
Murfreesboro, but no other banks intervene directly
between Woodland, Murfreesboro, and Ahoskie. It
would appear, therefore, that some existing competition may be eliminated as a result of this proposed
merger.
Since North Carolina law permits statewide branching either de novo or by merger, NCNB could establish
de novo branches in both Northampton and Hertford counties, thus creating additional banking alternatives. NCNB is the largest North Carolina bank not
presently operating in the Northampton-Hertford
area, and clearly possesses the resources and capability for establishing de novo branches. Admittedly,

81

however, the area as a whole has been one of below
average growth which diminishes the attractiveness
of entry by de novo branching.
Eight banks operate 15 banking offices in Northampton and Hertford counties. As of June 30, 1970,
Farmers Bank held 29 percent of the commercial bank
deposits in the two-county area
the largest share
held by any bank. Wachovia Bank and Trust, the
State's largest bank, and Planters National Bank and
Trust, the 10th largest bank, held 25 percent and 21
percent, respectively, of bank deposits in the two
counties. Thus the three largest banks operating in
the two counties held 75 percent of total deposits
a highly concentrated condition. This proposed acquisition of the leading bank in the NorthamptonHertford counties area by the State's second largest
bank would tend to perpetuate the present degree of
concentration existing in the two counties, and, given

the current growth prospects for the area, could deter
any entry into the area by other less capable potential
entrants.
If approved and consummated, this merger would
be the second recent acquisition by NCNB of a bank
with deposits exceeding $15 million, and the ninth acquisition within the last 5 years of a bank in the $15-25
million deposit range by one of the State's five largest
banks. This statewide trend in North Carolina is of
concern because such banks have been eliminated as
potential elements in newly developing regional or
statewide banks, which present the greatest possibility
of effective statewide competition to such existing banking giants as NCNB. By acquiring banks of this size,
and their leading positions in local markets, rather than
by entering de novo or through smaller mergers, the
largest banks in the State continue to extend their
dominance.

T H E FIRST NATIONAL BANK OF NEWARK, NEWARK, OHIO, AND T H E JOHNSTOWN BANK, JOHNSTOWN, OHIO
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
The Johnstown Bank, Johnstown, Ohio, with
and The First National Bank of Newark, Newark, Ohio (858), which had
merged Aug. 15, 1972, under charter and title of the latter bank (858). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On April 7, 1972, The First National Bank of
Newark, Newark, Ohio, and The Johnstown Bank,
Johnstown, Ohio, applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the former.
The First National Bank of Newark, the charter
bank, was organized in 1865, and is situated in the
county seat of Licking County. The charter bank has
assets of $55.8 million and IPC deposits of $41.4 million. The bank currently operates five branch offices all
of which are located in well-populated communities
within Licking County. In addition, the charter bank
is a member of Ohio's largest multi-bank holding company, BancOhio Corporation, which operates subsidiaries in Franklin, Delaware, and Pickaway counties.
The charter bank is currently the third largest of
eight banks in Licking County, all of which operate
an aggregate of 24 banking offices. The primary com-

82



$6, 560, 340
54, 690, 902
61,251,243

1
6
7

petitors for the bank include the Park National Bank,
Newark, with total deposits of $89 million, and The
Newark Trust Company, Newark, with deposits of
$46.8 million. The charter bank also faces limited competition from large banks in Columbus which compete
actively in the large loan market.
The Johnstown Bank, the merging bank, was organized in 1883, and has operated to the present time
as a unit institution. The merging bank has assets of
$5.9 million and IPC deposits of $4.7 million. In the
near future the bank will face a crisis in the continuity
of its management unless action is taken to insure more
depth of personnel.
At the present time there are no other banking
institutions located in Johnstown, however, The Newark Trust Company, one of the charter bank's primary competitors, has an application pending for
permission to establish a branch in Johnstown within
one block of the merging bank's sole office.

The economic characteristics of Newark and
Johnstown, both of which are located in Licking
County, are essentially the same, although Newark,
with a population of 42,000 people, is larger and has
a stronger economic foundation. The economic base
of the county is predicated upon a mixture of agricultural pursuits and small- to medium-sized industrial concerns. Both Newark and Johnstown have a
combination of those two types of activities.
There is no competition between the charter and
merging bank, due to the relatively large distances
which separate the two banks as well as the close
proximity of Johnstown to Columbus, the trade center
for central Ohio.
Consummation of the proposed merger will result
in no adverse competitive effects in Licking County. Although one independent bank will be eliminated, there
will remain an abundance of alternatives available to
the banking public in the service area. Furthermore,
the resulting bank will not be in a position to dominate
the banking community in the area nor will the merger
eliminate any competition. Should The Newark Trust
Company's application to establish a branch in Johnstown be approved, the resulting bank will be able to
provide more active competition to the new branch. In
addition, the consummation of this transaction will resolve the management succession problem at the merging bank. The Johnstown banking public will benefit
from the merger by virtue of a substantially increased
lending limit and the introduction of a number of new,
improved, and more efficient services that are not now
available nor are within the merging bank's capacity to
provide in the near future.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 10, 1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of Newark Bank and Johnstown
Bank are 17 miles apart. The office of Newark Bank
closest to Johnstown is in Granville, about 10 miles
from Johnstown. One other banking office intervenes
between these two offices. The application indicates
that both banks derive relatively little business from
the areas served by the other. Newark Bank's Johnstown area deposits, however, are equivalent to about
6 percent of Johnstown Bank's deposits derived from
that area (Johnstown Bank is the only commercial
bank operating in Johnstown). Assuming that the
other Newark banks derive comparable amounts of
business from Johnstown, it appears that Newark and
Johnstown can be considered to be in the same banking
market.
Eight commercial banks operate in Licking County.
(Ohio law limits branching to the headquarters
county). Three of the eight are headquartered in Newark and control most of the county deposits, 91.0 percent. Newark Bank is third largest in the county, controlling 23.5 percent of county deposits, slightly behind
the second largest bank, which controls 23.9 percent.
Johnstown Bank is fourth largest, but controls only
2.5 percent of county deposits. Thus, the merger would
increase Newark Bank's share to 26.0 percent, second
largest in the county, and it would increase the share
held by the three largest banks to 93.5 percent. This
increase in concentration may be somewhat overstated,
in view of the distance between the offices of the two
banks, as well as the competitive influence which may
exist in the Johnstown area from nearby banking offices
in Delaware and Franklin counties.
Nevertheless, we conclude that the proposed merger
would unduly increase concentration in the already
highly concentrated Licking County banking market,
and would thus have an adverse effect on competition.

T H E M O N M O U T H COUNTY NATIONAL BANK, R E D BANK, RED BANK, N.J., AND T H E FIRST NATIONAL BANK OF
HlGHTSTOWN, HTGHTSTOWN, N J .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Hightstown, Hightstown, N J . (1737), with
and The Monmouth County National Bank, Red Bank, Red Bank, N J . (2257),
which had
merged Aug. 18, 1972, under charter of the latter bank (2257) and title "Colonial
First National Bank." The merged bank at date of merger had




To be
operated

$31, 105, 142

2

271, 134,779

16

302, 176,433

18

83

COMPTROLLER S DECISION

On May 8,1972, The First National Bank of Hightstown, Hightstown, N.J., and The Monmouth County
National Bank, Red Bank, Red Bank, N.J., applied
to the Comptroller of the Currency for permission
to merge under the charter of the latter and with the
title "Colonial First National Bank".
The Monmouth County National Bank, Red Bank,
Red Bank, N.J., the charter bank, was organized in
1875 and is currently the fifth largest commercial bank
in the Second Banking District of New Jersey. The
bank, with assets of $256 million and IPC deposits
of $208 million, is headquartered in Red 'Bank, and
operates 16 offices throughout Monmouth County. It
has approval for three additional offices. Monmouth
County, the service area of the charter bank, is a
rapidly growing residential, recreational, agricultural,
and industrial area.
The Monmouth County National Bank is competing for certain services with the large Newark,
N.J., banks and the multi-billion dollar banks of New
York City, in addition to competing with banks located
in Monmouth County. Competition from Monmouth
County-based banks includes Central Jersey Bank and
Trust Company, Freehold, with deposits of $301 million; First Mechants National Bank, Neptune Township, with deposits of $174 million; Peoples National
Bank of Monmouth County, Hazlet, with total deposits of $38 million, which is a member of United
Jersey Banks, a multi-bank holding company with
total deposits of $1.1 billion; and First National State
Bank of Spring Lake, Spring Lake, with deposits of
$26 million, which is a member of First National State
Bancorporation, a multi-bank holding company with
total deposits of $1.2 billion. Other keen competition
in Monmouth County is provided by offices of New
Jersey National Bank, Trenton, with total deposits of
$579 million.
The First National Bank of Hightstown, the merging
bank, was organized in 1870. The merging bank operates one office in Hightstown and one office in East
Windsor Township where it also has an approval for
an additional office. The bank's service area is in
Mercer County which is a residential, industrial, and
agricultural area experiencing rapid growth. The First
National Bank of Hightstown has assets of $30 million
and IPC deposits of $24.8 million.
The merging bank ranked 38th in size of deposits
among the 62 commercial banks in the Second Banking
District. It ranked eighth in size of aggregate deposits
held by the 10 banks headquartered in Mercer County.

84



Competition from Mercer County-based banks includes New Jersey National Bank, Trenton, with deposits of $579 million; Princeton Bank and Trust Company, Princeton, with total deposits of $89 million,
which is a member of Princeton American Bancorporation, a multi-bank holding company with total deposits
of $447 million; The First National Bank of Princeton,
Princeton, with total deposits of $85 million, which is
a member of United Jersey Banks, a multi-bank holding company with total deposits of $1.1 billion; The
Broad Street National Bank of Trenton, Trenton, with
total deposits of $84 million; and The First National
Bank of Hamilton Square, Hamilton Square, with deposits of $39 million.
Consummation of the proposed merger will not produce any adverse competitive effects as competition
between the charter and merging banks appears insignificant. The nearest offices of the two banks are
approximately 13.6 miles apart. The large number of
competitors in the Mercer County area precludes any
decrease in over-all banking competition because of
the merger.
The resulting bank will continue to rank fifth in size
of deposits held by the 61 commercial banks in the
Second Banking District. It will also provide Hightstown with improved and expanded banking services.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 19,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the applicant banks are 28.1 miles
apart; the closest offices are 9.9 miles distant. Two offices of competing banks lie between these closest offices. (Upon completion of the FNBH branch in Twin
Rivers, it will be 9 miles distant from MCNB's branch
in Englishtown, with no banks in the intervening territory.) MCNB derives seven deposit accounts from
Mercer County; FNBH has no accounts in Monmouth.
Thus, the merger would not appear to eliminate any
significant amount of existing competition between
the two banks.
Under New Jersey banking law, commercial banks
may establish branches anywhere throughout the banking districts in which they are located. De novo branching is limited, however, by complete home office protection and branch office protection in communities
of less than 7,500 population. The Monmouth County
National Bank and First National Bank of Hightstown

are both located in the Second Banking District, comprised of six counties in the middle of the State.
Monmouth County National Bank is the second
largest bank in Monmouth County and the fourth largest in the Second Banking District. Monmouth County
National Bank has demonstrated the capability and
incentive to expand its service area. Although several
communities in Mercer County are closed to de novo
branching, there are open sites, notably in the townships of West Windsor and Washington, directly west

of Hightstown, into which Monmouth County National
Bank logically could expand.
First National Bank of Hightstown, however, is
among the smaller banks in its service area, and in
Mercer County as a whole. Thus, while Monmouth
County National Bank is one of the largest potential
entrants into Mercer County, we conclude that its
merger with First National Bank of Hightstown would
be unlikely to have a significantly adverse effect on
potential competition.

COLONIAL NATIONAL BANK, HADDONFIELD, N.J., AND ELMER BANK & TRUST COMPANY, ELMER, N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Elmer Bank & Trust Company, Elmer, N.J., with
and Colonial National Bank, Haddonfield, N.J. (14457), which had
consolidated Aug. 31, 1972, under charter and title of the latter bank (14457). The
consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On April 4, 1972, the Colonial National Bank, Haddonfield, N.J., and the Elmer Bank & Trust Company,
Elmer, N.J., applied to the Comptroller of the Currency for permission to consolidate under the charter
and with the title of the former.
The Colonial National Bank, the charter bank, was
organized in 1889, and is the sixth largest of the 59
commercial banks in the Third Banking District of
New Jersey. The bank, with assets of $195 million and
IPC deposits of $149.6 million, operates 11 offices in
Camden and Gloucester counties and serves a population of approximately 630,000 persons. The area served
by the Colonial National Bank is a residential, commercial, and industrial section of the State which has
experienced rapid growth and development in recent
years. Prospects for continued growth in this area appear favorable. Furthermore, due to its location, many
of the residents in this service area commute to nearby
Philadelphia for employment.
The Colonial National Bank is the fourth largest of
the nine banks headquartered in Camden County.
Primary competitors for the charter bank include the
Bank of New Jersey, Camden, with deposits of $348
million; the South Jersey National Bank, Camden,
which has deposits of $337 million and is a member
of Heritage Bancorporation, a multi-bank holding
company; and the Peoples National Bank of New Jer-




$17,249,371
194,554,578
211,803,949

To be
operated

2
11

13

sey, Westmont, with deposits of $192 million. Keen
competition is also offered by the billion-dollar banks
headquartered in Philadelphia.
The Elmer Bank & Trust Company, the consolidating bank, was organized in 1923, and is the 49th
largest of the commercial banks in the Third Banking
District. The consolidating bank, with assets of $14
million and IPC deposits of $10.7 million, operates two
offices in Elmer. The service area of this bank is
limited to Elmer and its immediate environs which
includes a population of approximately 1,600 persons.
In June 1970, the Elmer Bank & Trust Company
became a subsidiary of Midlantic Banks, Inc., a Newark-based multi-bank holding company that is the third
largest bank group in New Jersey. As a result of this
transaction, the Colonial National Bank will become
a subsidiary of Midlantic Banks, Inc.
The consolidating bank is the third largest of the
seven commercial banks headquartered in Salem
County. Competition is provided by The City National
Bank and Trust Company of Salem, with deposits of
$22 million; Penn's Grove National Bank and Trust
Company, with deposits of $20 million; and The First
National Bank of Elmer, with deposits of $9 million.
Additional competition is furnished by branches of the
large district-wide branching systems headquartered in
the Third Banking District.
Competition between the charter and consolidating

85

banks is negligible and there is no overlapping of the
service areas of the two banks. The nearest office of the
Colonial National Bank to a branch of the consolidating bank is approximately 20 miles. Furthermore, no
subsidiary of the Midlantic Banks, Inc., competes with
the Colonial National Bank since its nearest banking
subsidiary, excluding the Elmer Bank & Trust Company, is over 60 miles north of the charter bank.
Consummation of the proposed consolidation will
cause no adverse competitive effects in either the Third
Banking District or in New Jersey as a whole. No competition will be eliminated as a result of this transaction
and an adequate number of alternative banking facilities will remain to serve the banking public. The resulting bank will have assets of $209 million and will
become the fifth largest bank in the Third Banking District; it will remain the fourth largest in size of the
nine commercial banks based in Camden County. In
addition, the proposed consolidation will not significantly affect the size of Midlantic Banks in relation to
the other New Jersey holding companies. Through its
affiliation with this holding company, the resulting bank
will be able to provide expanded and improved services
to residents of its trade area, including international
banking, an expanded trust department, computer services, and municipal financing. As a result, the bank will
stimulate competition within its service area and will
become a more effective competitor for the large banks
in Camden and Philadelphia.
Applying the statutory criteria, it is concluded that
the proposed consolidation is in the public interest and
the application is, therefore, approved.
JULY 25,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

According to the application, the nearest offices of
the consolidating banks are 15 miles apart; Elmer
Bank's two offices are within approximately 17 miles of
two other Colonial branches. Although the application states that the banks do not compete directly, it
is likely that some limited existing competition between
the banks will be eliminated if the proposed consolidation is approved.
Although New Jersey law permits intra-district de
novo branching, de novo branches for communities of
7,500 or less are permitted only when no office of another bank is already located therein; and, for communities of more than 7,500, de novo branches are permitted only when there is no main office of another
bank therein. Hence, neither bank is a potential de

86



novo entrant via branching into the home office of each
other.
However, despite the difficulties presented by home
and branch office protection, Midlantic is clearly identifiable as a significant potential entrant into those areas
in the Camden vicinity served by Colonial. Alternative
means of entry for Midlantic would include the chartering of de novo holding company banking subsidiaries, or acquisition (direct or indirect) of a smaller
bank. Because of its size, resources, long standing position as one of the largest banking organizations in the
State, and apparent incentive to become a statewide
banking organization, Midlantic stands as one of the
most significant potential entrants into the important
and growing Camden area served by Colonial.
Colonial is the sixth largest commercial bank located
in the entire Third Banking District, with about 5.4
percent of total commercial bank deposits therein. It is
even more of a significant competitive factor in that
part of the Camden area which comprises its apparent
service area, since two of the larger banks in the district, the First National Bank of South Jersey and the
First National Bank of Toms River, derive substantially
the larger part of their business from areas in the eastern part of the district, outside of the vicinity of
Camden.
As of June 30, 1970, Colonial held the third largest
share of Camden County commercial bank deposits,
about 15 percent. Commercial banking in the county
is highly concentrated, the three leading banks holding
about 79 percent of such deposits. On the same date,
Colonial held about 7 percent of Gloucester County
deposits. It is apparent that Midlantic's entry into the
Camden area through acquisition of Colonial involves
the absorption of one of the few banks of substantial
size in the Camden area and the entire third district
as well.
Viewed in this light, the proposed consolidation
represents a clear step toward the evolution of commercial banking in New Jersey toward a statewide
structure that would be characterized by dominance
in all major markets by a few giant banking institutions. Since the relaxation of New Jersey's banking and
bank holding company restrictions in 1968, a large
number of mergers and holding company affiliations
have taken place. All four of the State's largest banking
institutions, headquartered in northern New Jersey,
have begun to expand. Should these institutions, and
others somewhat smaller, continue to expand through
acquisition of leading local banks, concentration
throughout the State and in its local markets would

be unjustifiably increased. On the other hand, if the
State's largest institutions are prevented from acquiring intermediate-sized banks, such as Colonial (and
Midlantic's most recent acquisition, Citizens National
Bank of Englewood) the opportunity for development
of additional statewide competitors will be preserved,
since banks of this size are clearly important elements
of new organizations.

Therefore, while several other smaller potential entrants into the Camden area would remain if the proposed consolidation is approved, we conclude that
Midlantic's acquisition of Colonial would have a significantly adverse effect on potential competition in
the areas served by Colonial and would be a dangerous
precedent for anticompetitive expansion in the State
as a whole.

FIRST MISSISSIPPI NATIONAL BANK, HATTIESBURG, MISS., AND LUMBERTON STATE BANK, LUMBERTON, MISS.
Banking offices

Total assets

Name of bank and type of transaction

To be
operated

In
operation

COMPTROLLER S DECISION

In April 1972, the Lumberton State Bank, Lumberton, Miss., and the First Mississippi National Bank,
Hattiesburg, Miss., applied to the Comptroller of the
Currency for permission to merge under the charter
and title of the latter.
The First Mississippi National Bank, the charter
bank, was organized in 1895. With assets of $107.9
million and IPC deposits of $73.2 million, the bank
ranks fifth among the 176 banks in the State and is
headquartered in Hattiesburg, Forrest County. It presently operates three local and eight outside branch
offices, and has three other approved, but unopened,
branches within 100 miles of the main office.
Hattiesburg has a population of about 38,000 and
is the general trade center for Forrest County. Though
the city is industrialized to a large extent, the surrounding area remains dependent upon agriculture.
Cattle and poultry farming and processing are the
chief industries. The Gulf Coast, where the charter
bank presently operates six offices, is characterized by
substantial heavy industry. The economic outlook of
the charter bank's service area appears generally
favorable.
The city of Hattiesburg is also served by the Citizens,
Bank, Hattiesburg, Miss., with deposits of $25.4 million, and the Southern National Bank, Hattiesburg,,
Miss., with deposits of $19.5 million. The merger will
have no noticeable effect, economically or otherwise,




$8, 723, 642
119, 164,988
128,087,692

(N CO

Lumberton State Bank, Lumberton, Miss., with
and First Mississippi National Bank, Hattiesburg, Miss. (5176), which had
merged Aug. 31, 1972, under charter and title of the latter bank (5176). The
merged bank at date of merger had

15

on any community now being served by the charter
bank.
Lumberton State Bank, the merging bank, was organized in 1947. Headquartered in Lumberton, Lamar
County, and operating a single branch in Bassfield,
Jefferson Davis County, the bank has $8.2 million in
assets and $7 million in IPC deposits. Both Lumberton,
with a population of 2,100, and Bassfield with a population of 310, are agricultural communities with downtrends in population in the last few years. Besides
lumbering, which is the chief industry, and three manufacturers in Lumberton who employ some 500 workers,
the area is chiefly characterized by small, tired farms.
Prospects for significant economic growth within the
reasonably foreseeable future are bleak.
The merging bank's principal competitor is the
Lamar County Bank, Purvis, Miss., with $7.7 million
in deposits and offices situated in the intervening areas
between each of the merging bank's offices and the
charter bank's offices in Hattiesburg. The two banks
are not strong competitors. The Lamar County Bank,
which is also locally-oriented, will not be adversely affected by consummation of this merger.
At present, there is virtually no competition between
the charter bank and the merging bank. Both Lumberton Bank's main office and its Bassfield branch serve
primarily the areas of their immediate locations.
Neither of the merger proponents derives any significant portion of its business from the service area of
the other.

87

This merger will have no effect on First Mississippi
National Bank's rank by size in the State. It will remain
the fifth largest bank, with total deposits of $99.5 million, ranking after Deposit Guaranty N. B., Jackson,
with $499 million total deposits; First National Bank,
Jackson, with $406 million deposits; Hancock Bank,
Gulfport, with $108.8 million deposits; and Grenada
Bank, Grenada, with $102.5 million deposits. The resulting bank will have only a minimally increased share
of the State's banking market.
This merger will make available to Lumberton and
Bassfield area residents increased and more efficient
banking services. Management of the charter bank is
aggressive and capable of solving the myriad problems
now besetting the merging bank: a serious management succession problem; and inadequate lending and
collection policies, internal controls, and audit procedures. Further, funds which presently lie dormant in
the merging bank will be put to productive use by the
resulting bank, generating better earnings and greater
dividend return to shareholders. The extension of better services is expected to stimulate competition with
banks in the surrounding communities to improve their
own services to the public's benefit. Such services and
banking policies will be increasingly in demand if this
area is to attract business and grow at a rate comparable to the State in general.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. It is,
therefore, approved.
JULY 26,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The distance separating the closest offices of First
Mississippi and Lumberton State is about 25 miles
between their offices in Hattiesburg and Lumberton.
Banking offices of Lamar County Bank intervene directly between both of Lumberton State's offices and
any office of First Mississippi. The application states
that neither bank draws a substantial share of its de-

88



posits from the service areas of the other. The application provides no data with respect to loans drawn
by either bank from the service areas of the other. On
the basis of information provided, however, the existing competition between the banks which would be
eliminated by the proposed merger does not appear to
be substantial.
Under Mississippi law, First Mississippi would not
be permitted to establish a branch office or bank in
Lumberton. It could, however, establish a branch office
or bank in any other Lamar County community not
already served by a bank operating there. It could also
establish a branch bank in Bassfield, or in any other
Jefferson Davis County community not already served
by a bank operating there. Such branching could put
First Mississippi into more direct competition with
Lumberton State. However, considering the size of
Bassfield and the other communities available for such
de novo expansion, and the other relevant conditions
and considerations prevailing, such de novo expansion
would not appear to be attractive. Furthermore,
though First Mississippi is the closest major bank capable of expanding into either county, almost all of the
two-county area is located within 100 miles of the
State's first, second, third, and eighth largest banks.
Each of those banks, therefore, could (within the 100mile limit and subject only to the same restrictions
applicable to First Mississippi) also establish a branch
bank in either or both counties.
Lumberton State holds approximately 29 percent of
the deposits held by the three banks operating in
Lamar and Jefferson Davis counties. In each of these
two counties where it maintains an office, only one
other bank operates. Lumberton State is the smaller
of the banks in each case, and is the smallest bank in
the vicinity surrounding each of its offices which might
reasonably be defined as its service area. The substitution of First Mississippi for Lumberton State would
not appear to materially affect the level of concentration existing in the two-county area.

FIRST SECURITY BANK OF UTAH, NATIONAL ASSOCIATION, OGDEN, UTAH, AND NORTH DAVIS BANK, LAYTON,
UTAH
Banking offices
, Name of bank and type of transaction

Total assets
In
operation

North Davis Bank, Layton, Utah, with
and First Security Bank of Utah, National Association, Ogden, Utah (2597), which
had
merged Sept. 5, 1972, under charter and title of the latter bank (2597). The
merged bank at ate of merger had

COMPTROLLER S DECISION

On April 17, 1972, the North Davis Bank, Layton,
Utah, and the First Security Bank of Utah, National
Association, Ogden, Utah, applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
The First Security Bank of Utah, National Association, the charter bank, was organized in 1871, and is
currently the largest commercial bank in Utah. The
bank is a member of a registered bank holding company, First Security Corporation. First Security Corporation, also operates in Idaho and in Wyoming. The
bank has assets of $697 million and IPC deposits of
$470 million. The First Security Bank of Utah operates
48 offices throughout the State. Its major offices are
in Salt Lake, Ogden, and Provo, and in other areas
along the so-called "Wasatch Front". The charter bank
has no branches in Layton, Utah, or in that general
area of Davis County, despite the fact that Davis
County is the fourth largest county in the State in
population, following the three other Wasatch Front
counties of Salt Lake, Weber, and Utah.
The First Security Bank of Utah is in competition
for certain services with every major bank in Utah.
The primary competitors in Utah include the Zions
First National Bank, the second largest bank in the
State, with deposits of $339 million, and the Walker
Bank and Trust Company, with deposits of $319 million, which ranks as the third largest bank in Utah.
Other principal competitors for the charter bank are
the Commercial Security Bank, with deposits of $136
million, and The Continental Bank and Trust
Company, with deposits of $128 million.
The North Davis Bank, the merging bank, was organized in 1964 in Layton, Utah, and operates only
one office. This bank has assets of $6.1 million and IPC
deposits of $4.2 million. The economy of the area is
primarily that of a major center of retail trade. The




$5,858,331
725, 887, 290
731, 770, 109

To be
operated

1
49
50

area is largely residential but is adjacent to some major
industrial areas. Layton is one of the fastest growing
communities in Utah. It is the second largest city in
Davis County and the 10th largest city in Utah.
The trade area of the merging bank is served only
by small banks. There are five banks located in the
north half of Davis County within a 5-mile radius
of the merging bank. All five of those banks are small,
with loan limits ranging from $45,000 to $151,000.
Both of the Layton banks have lending limits just above
$50,000, and customers with large credit demands must
go to Salt Lake City or Ogden banks to obtain their
loans.
There is little competition between the charter and
merging banks because of the distance that separates
the main branches of the charter bank and the merging bank and because of the adequate number of competitors in the Layton area. Although the charter
bank operates two bank facilities located on Hill Air
Force Base, within 5 miles of the merging bank, the
presence of four other banks in the area, after the
merger, would ensure adequate competition.
Consummation of the proposed merger will not result in any adverse competitive effects. The merger
will not eliminate any competition and the same
number of banking alternatives will remain in North
Davis County, the service area of the merging bank.
The resulting bank will offer broader banking services
and increased loan capacities to the area. The banking
competition could be enhanced and the customers benefited by the ability of First Security in Layton to provide
a larger loan accessibility on*a local basis. With the
entry of First Security into Layton, the other banks
could become more aggressive in the mortgage loan
market, with First Security actually serving to inject a
competitive spirit and filling many needs not presently
satisfied. The new branch in Layton will provide the resources necessary to aid in the development of Davis
County. That will directly benefit the banking public

89

within the service area of the merging bank. The
merger will not significantly increase the statewide deposit structure of First Security.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 4,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First Security operates two banking facilities at Hill
Air Force Base which accept deposits and transfer
funds from customers on the base. In addition, First
Security Corporation caused a new banking subsidiary
to be chartered in the southern Davis County community of Bountiful late in 1971. North Davis and this new
bank are about 15 road miles apart with banking
alternatives in the intervening area. Furthermore, as of
mid-1970, First Security Corporation subsidiaries held
the largest share of commercial bank deposits in Weber
County to the north (where Ogden is located) and Salt
Lake County to the south. The application states
that First Security extends a "considerable amount" of
credit to the firms located in Freeport Center and
"small amounts" of individual credit to residents of
north Davis County. It also states that First Security
has provided more mortgage credit in the county than
any other bank, a statement which may even understate
First Security Corporation's mortgage financing in
Davis County since it omits the (relatively modest)
credit made available by Security State and the considerable funds supplied by Utah Mortgage Loan Corporation, another subsidiary. Counting all of its
subsidaries, First Security Corporation is Davis County's leading source of mortgage financing or close to it.

North Davis' mortgage activities are limited to some
extent by its small size.
In sum, there is competition for deposits between
North Davis and First Security's Hill Air Force Base
facilities as well as its offices in Ogden, Salt Lake City,
and Bountiful. Although North Davis has not been as
active in mortgage financing as the other banks headquartered in the northern half of Davis County, it
would appear that the proposed merger would eliminate existing competition in this area. In addition,
North Davis is a competitor with First Security for
other types of personal and commercial lending in this
area.
In the light of the existing competition between
First Security and North Davis, it is not surprising
that the application fails to provide any information
on the amount of deposits First Security and its subsidiary banks draw from the northern half of Davis
County. It is known that only six banks, including
North Davis and First Security, operate offices in the
area. Moreover, First Security Corporation is the leading banking organization in Salt Lake County and
enjoys a dominant position in Weber County. There
are very few other major banking organizations in the
State.
Given these structural factors, we believe that the
share of deposits of residents of north Davis County
held by First Security and First Security Corporation
are not insubstantial and that the acquisition of North
Davis by First Security will result in a significant increase in concentration in northern Davis County.
Given the size of the acquired bank, we conclude
that the effect of this merger on competition will be
adverse.

BANK OF NORTH CAROLINA, NATIONAL ASSOCIATION, JACKSONVILLE, N.C.,
VILLE, N.C.

AND BANK OF HOBBSVILLE, HOBBS-

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Hobbsville, Hobbsville, N.C, with
and Bank of North Carolina, National Association, Jacksonville, N.C (14676),
which had
merged Sept. 8, 1972, under charter and title of the latter bank (14676). The
merged bank at date of merger had

90



To be
operated

$5, 151,850

1

315,919,750

53

321,071,599

54

COMPTROLLER'S DECISION

On May 8,1972, the Bank of Hobbsville, Hobbsville,
N.C., and the Bank of North Carolina, National Association, Jacksonville, N.C., applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
The Bank of North Carolina, National Association,
the charter bank, was organized in 1952, and is currently the seventh largest commercial bank in North
Carolina. Although the bank operates 51 offices located
throughout the State, the majority of its business is
generated in the eastern part of North Carolina. The
charter bank is a principal component of Bankshares
of North Carolina Inc., a bank holding company, which
also operates several small insurance companies and
has received approval to acquire a finance company.
The Bank of North Carolina, N.A., has assets of $255.3
million and IPC deposits of $154.3 million.
The Bank of North Carolina, N.A., is in competition
for certain services with every major bank in North
Carolina. Principal competitors are Wachovia Bank
and Trust Company, N.A., the largest bank in the
State, with deposits of $1.6 billion; North Carolina
National Bank, with $1.5 billion in deposits; First
Union Bank of North Carolina, with deposits of $1.1
billion; First Citizens Bank and Trust Company, with
deposits of $715 million; The Northwestern Bank,
with deposits of $631 million; and, Branch Banking
and Trust Company, with deposits of $263 million.
The Bank of Hobbsville, Hobbsville, N.C., the
merging bank, was organized in 1911 and operates only
one office but has approval to establish a branch at
Hertford, approximately 18 miles south of Hobbsville.
The merging bank has assets of $5 million and IPC
deposits of $4.1 million. The economy of the area in
which Hobbsville and Hertford are located is primarily
agricultural and has been relatively static in economic
growth in the past. The only area served by the merging bank that has prospects of economic growth is the
Hertford area, where an industrial park and expanded
retail facilities have been built.
Banking competition in the area served by the Bank
of Hobbsville is furnished by the Farmers Bank of
Sunbury, located 8 miles north of Hobbsville, which
has deposits of $7.8 million; and the Tarheel Bank and
Trust Company at Gatesville, located approximately
12 miles northwest of Hobbsville, which has deposits
of $10.3 million. The merging bank also competes
with the Peoples Bank and Trust Company of Rocky
Mount in the vicinity of Hertford. The Peoples Bank
501-017 O—73

7




and Trust Company of Rocky Mount has deposits of
$117 million.
The nearest office of the charter bank is located at
Edenton, approximately 25 miles south of Hobbsville.
Edenton is also 14 miles southwest of Hertford, where
the merging bank has approval to establish an office.
There is little if any present competition between the
charter and merging banks because of the distance that
separates their branches, and because of the adequate
number of competitors in the Hobbsville and Hertford areas. Therefore, the proposed merger will have
no adverse effect on competition between the charter
bank and merging bank.
Consummation of the proposed merger will not
result in any adverse competitive effect. The merger
will not eliminate any competition and there will remain the same number of banking alternatives available to the customers of the service area of the merging
bank. The resulting bank would offer broader banking
and increased loan capacities to the area. The addition
of the merging bank's $4.1 million in deposits will not
materially affect the charter bank's totals nor its position in the statewide market. The proposed merger
will replace a relatively ineffective competitor with
one of greater size, more aggressiveness, a greater lending capacity, and a greater variety of services. The
resulting bank would bring the resources necessary to
act in the development of the merging bank's service
area and thereby benefit the banking public.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 3,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Bank of North Carolina office closest to an
office of Bank is located in Edenton in adjacent
Chowan County, about 22 miles south of Hobbsville.
While there is one other bank operating in Edenton,
no other banking offices intervene directly between
Hobbsville and Edenton. The application does not
supply any figures; however, on the basis of information provided, it would not appear that either bank
draws a significant share of its deposit, demand, or
loan accounts from the service area of the other.
Bank of Hobbsville is the smallest of the three banks
operating (and headquartered) in Gates County and
accounts for about 18.3 percent of total deposits. The
application also states that Bank of Hobbsville draws
approximately 25 percent of its total deposits from the
Hertford area (where it has approval to open a
branch) which is currently served by an office of

91

Peoples Bank and Trust of Rocky Mount—the only
banking office in Perquimans County.
Under North Carolina law, Bank of North Carolina
could establish a de novo branch in either Hobbsville
or Hertford. However, considering the size of Hobbsville and the fact that the area as a whole has been

one of below average growth, the prospect of such
de novo entry in the near term is diminished. Additionally, there are six other banks larger than Bank of
North Carolina already operating branches in northeastern North Carolina which may also be considered
prospective potential entrants.

NATIONAL BANK OF THE COMMONWEALTH, INDIANA, PA., AND FARMERS & MERCHANTS BANK OF CHERRY TREE,
CHERRY TREE, PA.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
Farmers & Merchants Bank of Cherry Tree, Cherry Tree, Pa., with
was purchased Sept. 11, 1972, by National Bank of the Commonwealth, Indiana,
Pa., (14098), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On June 5,1972, the National Bank of the Commonwealth, Indiana, Pa., applied to the Office of the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of the
Farmers & Merchants Bank of Cherry Tree, Cherry
Tree, Pa.
The purchasing bank, National Bank of the Commonwealth, was organized in 1934. This bank ranks
second in size of the nine commercial banks operating
in Indiana County and 13th among the 63 banks in
the six-county permissible expansion area. The purchasing bank has total assets of $74 million and I PC
deposits of $65.9 million. It operates six offices in
Indiana County, two in Cambria County, and one
each in Jefferson and Vandergrift counties.
The major competitors of the National Bank of
the Commonwealth in Indiana County include the
Savings and Trust Company of Indiana, with deposits
of $59 million; the Farmers Bank and Trust Company, with deposits of $27.9 million; and the Homer
City State Bank, with deposits of $19.7 million. In
addition, the four branch offices of the National Bank
of the Commonwealth located outside Indiana County
also compete vigorously with a large number of banks
and bank branches.
The Farmers & Merchants Bank of Cherry Tree,
the selling bank, was organized in 1923, and has remained a unit bank from the time of its organization.
The selling bank has total assets of $5 million and

92



$5,241,190

1

85, 796, 772
91, 037, 962

10
11

IPC deposits of $3.8 million. This bank ranks as the
55th in deposits of the 63 banks in the six-county area.
The major competitors of the selling bank include
a branch of the United States National Bank of Johnstown, at Carroll town, with deposits of $154.3 million;
a branch of Johnstown Bank and Trust, at Elmora,
with deposits of $59.6 million; a branch of the First
National Bank of Ebensbury, at Barnesboro, with deposits of $46.2 million; and the First National Bank
of Spangler, Spangler, with deposits of $3 million.
The service area of the Farmers & Merchants
Bank of Cherry Tree consists of the town of Cherry
Tree, which is located 21 miles northeast of Indiana
near the extreme eastern boundary of Indiana County.
Cherry Tree has a population of 485. Workers in the
area are employed mainly in mining or by railroads
operating in the area. In contrast with the small service
area of the selling bank, the service area of the purchasing bank consists of Cambria County, Indiana
County, and the southern portions of Armstrong and
Jefferson counties. The city of Indiana, where the
headquarters of the purchasing bank is located, is, with
its population of 16,100, the largest community in the
county.
At present, there is no significant competition between the purchasing and selling banks. The National
Bank of the Commonwealth's nearest office to the
Farmers & Merchants Bank of Cherry Tree is approximately 17 road miles southeast of Cherry Tree.
There are five banking offices of four banks competing
in the area between the nearest offices of the appli-

cants. The adequate number of competitors, the relatively sparse population, and the intervening distance
indicate a lack of competition between the purchasing
and selling banks. In addition, the conservative management of the Farmers & Merchants Bank of Cherry
Tree has restricted the service area of that bank to
its own community.
Consummation of the proposed purchase will produce no adverse competitive effects in Indiana County.
Competition will be substantially increased because the
proposed branch in Cherry Tree will be able to offer
full-service banking which is now offered by the selling
bank's competition. The selling bank has not, and
cannot expect, within the foreseeable future, to offer
many of the new services being demanded by the banking public.
Accordingly, it is the view of this Office that the
proposed transaction is in the public interest. The application is, therefore, approved.
AUGUST 9,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Farmers & Merchants Bank of Cherry Tree's office
in Cherry Tree is about 20 miles northeast of Indiana,
with one bank in the intervening area, but only about
12 miles northwest of Commonwealth's branch office
in Patton, which was recently opened through acquisition of the First National Bank at Patton. Although

there are relatively few banks in this sparsely populated
region, the application indicates that the parties to the
proposed transaction draw only limited banking business from each other's service area. Thus, the proposed
transaction would eliminate only a limited amount of
existing competition.
Under Pennsylvania law, either bank could be permitted to open de novo branches in areas served by the
other. While Farmers & Merchants of Cherry Tree's
modest size precludes its consideration as a likely de
novo entrant into areas served by Commonwealth, the
latter has recently demonstrated its apparent capability
and incentive to expand in this manner. Cherry Tree
itself is a small community, in which opportunities for
de novo branching appear limited, but in view of its
established foothold in northern Cambria County at
Patton, Commonwealth may have some incentive to
open an additional office in the Spangler-Barnesboro
area, particularly to compete more directly with its
major rivals in Indiana and Cambria counties, United
States National Bank of Johnstown, Johnstown Bank
and Trust, and First National Bank of Ebensburg. In
recent years, expansion by these four leading area banks
has included a number of mergers with small banks in
Indiana and Cambria counties, indicating a change in
the pattern of competition toward a more regionallyoriented structure. Accordingly, the proposed transaction may eliminate some potential competition.

NATIONAL BANK OF COMMERCE IN SUPERIOR, SUPERIOR, WIS., AND POPLAR STATE BANK, POPLAR, WIS.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Poplar State Bank, Poplar, Wis., with
was purchased Sept. 20, 1972, by National Bank of Commerce in Superior,
Superior, Wis. (14109), which had.
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On April 6, 1972, National Bank of Commerce in
Superior, Superior, Wis., applied to the Office of the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of Poplar
State Bank, Poplar, Wis.
The National Bank of Commerce in Superior, the
purchasing bank, with IPC deposits of $24.8 million,
was organized in 1934, and is a unit bank. The bank
is adequately capitalized and soundly managed.




To be
operated

$4, 635, 393
29, 952, 602
34, 587, 995

Superior, with a population of 32,237, is a part of
the larger Duluth (Minn.)-Superior market, which
has a combined population of approximately 150,000.
That area, to a great extent, is economically dependent upon the shipping industry, both rail and boat, because of its strategic location at the head of the Great
Lakes-St. Lawrence Seaway system. The two cities are
on opposite sides of the port facilities, but are conveniently connected by several bridges and many residents reside in one city and work in the other.

93

Although the purchasing bank is the largest of the
five banks headquartered in Superior, when the larger
combined Duluth-Superior market is considered, it is
a much smaller and less effective competitor. That
combined market is dominated by two large Duluth
banks, the Northern City National Bank and First
American National Bank, both of which are subsidiaries
of large Minneapolis-based bank holding companies,
and which together hold over 60 percent of the $376.6
million in commercial bank deposits generated by the
Duluth-Superior area.
The Poplar State Bank, the selling bank, with IPG
deposits of $4.1 million, was established in 1919, and
operates one branch at Solon Springs in addition to its
head office. The bank is unable to meet the financial
needs of its area because of both its small size and its
extremely conservative policies.
Poplar, with a population of 455, and Solon Springs,
with a population of 598, are small rural communities,
respectively located 18 miles east and 32 miles southeast of Superior. Those communities provide modest
retail shopping facilities and the only banking services in an area devoted to agriculture and logging.
Consummation of this transaction will benefit the
service area of the selling bank by opening it up to
branching by the buying bank and by substituting for
the selling bank an office of an institution with realistic,
aggressive, and progressive policies.
Competition should not be adversely affected. In
the Poplar Springs market area, since the selling bank
is the only operating bank there, consummation of the

transaction should have no material effect. In the
Duluth-Superior area, a slightly larger bank will result.
In Superior, the purchasing bank's position as largest
bank would not be materially enhanced.
Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
the application is, therefore, approved.
AUGUST 9,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

State Bank's home office and its branch at Solon
Springs are located 19 and 32 miles, respectively, southeast of Superior. However, there are no intervening
banking alternatives, and there appears to be some
small amount of direct competition between the two
banks.
National Bank is the largest of six commercial banks
operating in Douglas County, accounting for about 39.5
percent of the deposits held by Douglas County commercial banks. The three largest Douglas County banks
hold 83 percent of such deposits. State Bank ranks
fifth with about 6 percent of deposits in the market.
The proposed acquisition will increase the level of
concentration in this part of the Duluth-Superior
SMSA.
The proposed acquisition will eliminate a small
amount of existing competition and increase the level
of concentration in Douglas County. For these reasons,
we conclude that approval of this proposal would have
some adverse effect on banking competition.

FIRST NATIONAL BANK OF CENTRAL JERSEY, SOMERVILLE, N.J.,

AND FIRST CLINTON NATIONAL BANK, CLINTON,

NJ.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First Clinton National Bank, Clinton, N J. (1114), with
and First National Bank of Central Jersey, Somerville, NJ. (3866), which had
consolidated Sept. 29, 1972, under charter and title of the latter bank (3866). The
consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On April 5, 1972, the First National Bank of Central
Jersey, Somerville, N.J., and the First Clinton National Bank, Clinton, N.J., applied to the Comptroller
of the Currency for permission to consolidate under
the charter and with the title of the former.

94



$33, 741, 235
169, 038, 930
202, 780, 165

To be
operated

4
11

15

The charter bank, with total IPC deposits of $109
million, was organized in 1888, and presently operates
nine banking offices in Somerset County and two banking offices in the town of Roselle, in adjacent Union
County. The bank ranks second in size among the
eight commercial banks headquartered in Somerset

County and 10th among the 65 commercial banks
located in the Second Banking District which together
have total aggregate deposits of $4.5 billion. The bank
is faced with strong competition from local subsidiaries
of statewide bank holding companies and from the large
commercial banks and other financial institutions based
in the cities of Newark, Elizabeth, and Trenton.
The area served by the charter bank includes all of
Somerset County and several communities located in
adjacent counties. It also includes a separate trade
area surrounding the town of Roselle in Union County.
The Somerset County area, with an estimated population of 434,000 has experienced rapid industrial, commercial, and residential expansion in recent years.
Due to Somerset County's strategic location between
New York and Philadelphia, it is expected that the area
will continue to enjoy excellent economic growth.
Roselle is located in the heart of Union County.
Union County, with a population of about 577,000,
is one of the smaller counties in the State and is located
in the extreme eastern portion of New Jersey adjacent
to the harbors serving the port of New York and the
immediate New York Metropolitan Area. In contrast
to Somerset County, Union County is substantially developed and there is little vacant land remaining for
additional development. Although Union County has
substantial industries of its own, its proximity to New
York places it within the orbit of that metropolitan
area.
The trade area served by the First Clinton National
Bank, located in the north-central part of Hunterdon
County, has a population of about 21,000, and includes Clinton Township, Lebanon Township, Franklin Township, and the extreme western portion of
Readington Township. That area is located along the
Route 22 and Interstate 78 corridor and is only 20
minutes away from the heart of the Easton-AllentownBethlehem area in Pennsylvania. With the completion of Interstates 78 and 287 to the east, the Clinton
area will be within a one-hour traveling distance from
the eastern port areas of New Jersey and New York
City. Because of its convenient location, the area has
a high potential for major commercial development.
The Hunterdon County Planning Board has estimated
that the communities along the 1-78 corridor will grow
at a faster pace than the rest of the county in general.
Hunterdon County, with an estimated population
of 69,700, has been predominantly a rural area served
by small business centers. The county has experienced
rapid commercial and residential expansion in recent
years and is expected to continue to enjoy excellent




economic growth. The Hunterdon County Planning
Board has estimated that, by 1985, the county's population will have increased to approximately 200,000,
and that 39 percent of the county's land will have
been developed, as compared to 22 percent in 1965,
an increase of 77 percent.
The First Clinton National Bank, with total IPC
deposits of $27 million, was organized in 1856, and
presently operates four banking offices in Hunterdon
County. The bank ranks third in size among the five
commercial banks headquartered in the county which
together have total aggregate deposits of $187 million. It ranks 40th among the 65 commercial banks
located in the banking district, with about 0.7 percent of the total bank deposits in the district. In
addition to the banks headquartered in the county,
the bank is faced with competition from local branches
of the large National State Bank of Elizabeth, with
$588 million in deposits, and New Jersey National
Bank of Trenton, with $518 million in deposits. Competition in Hunterdon County is also provided by
several savings and loan associations, savings banks,
home finance companies, small loan companies, and
credit unions. The bank is presently faced with a serious management succession problem.
There is no significant competition presently existing
between the participating banks. The charter bank
has no offices in Hunterdon County and its closest office
to the First Clinton National Bank is 10 miles distant.
The elimination of whatever competition may now
exist between those banks can readily be outweighed
by the benefits to follow. The combination of the two
banks will not have a significant effect on concentration of banking resources in the district. After consolidation, the resulting bank will rank ninth in size
among the commercial banks located in the Second
Banking District and will still be substantially smaller
than some of the competing banks.
Besides solving the management problem at the First
Clinton National Bank, consummation of the proposed
consolidation will introduce into the area now served
by each bank a more viable, competitive institution with
greater resources and ability to provide a full line of
banking services. The resulting bank with its greater
resources will be in a better position to aid in the economic growth of the area of Hunterdon County by
making available the needed capital funds.
Considered in the light of the statutory criteria, this
consolidation is deemed in the public interest. The application is, therefore, approved.
JUNE 16,

1972.

95

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the consolidating banks are
approximately 12 miles apart, with several banking
offices in the intervening area. The application indicates that the merging banks draw insignificant deposit
and loan business from each other's service area. It
does not appear that the proposed consolidation will
eliminate substantial existing competition.
Under New Jersey law, either of the consolidating
banks may be permitted to establish de novo branches
in the home county of the other, subject to home
and certain branch office protection restrictions. How-

ever, in view of its size, First Clinton is not among
the more significant sources of potential competition
in those areas served by Central Jersey Bank.
Central Jersey Bank, the 10th largest bank in the
Second Banking District, does appear to have the
resources to establish de novo branches in other attractive areas. However, in view of the number of other
larger potential entrants into the service area of First
Clinton, and the fact that First Clinton, while having
13.7 percent of total Hunterdon County deposits, is
not a dominant bank in the county, we conclude that
the proposed merger would not have a significantly
adverse effect on competition.

MAINE NATIONAL BANK, PORTLAND, M E . , AND T H E KEZAR FALLS NATIONAL BANK, PARSONSFIELD (P.O.
FALLS), M E .

KEZAR

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Kezar Falls National Bank, Parsonsfield (P.O. Kezar Falls), Me. (9826), with,
and Maine National Bank, Portland, Me. (4128), which had
merged Sept. 29, 1972, under charter and title of the latter bank (4128). The
merged bank at date of merger had

COMPTROLLER S DECISION

On June 26, 1972, The Kezar Falls National Bank,
Parsonsfield (P.O. Kezar Falls), Me., applied to the
Comptroller of the Currency for permission to merge
with Maine National Bank, Portland, Me., under the
charter and with the title of the latter.
The Kezar Falls National Bank, the merging bank,
with total resources of $4.6 million, was organized in
1910 and maintains no branch offices.
The merging bank is located in the Kezar Falls section of the town of Parsonsfield. Its service area encompasses the six surrounding towns in York and Cumberland counties, supporting an estimated population of
12,678. The area's economy is dependent upon farming,
lumbering, wood products, and vacation and travel
facilities. Manufacturing provides approximately 1,503
jobs, the largest employer being the Lamp Division of
ITT with less than 200 employees.
Competition with the merging bank is provided by
four commercial bank offices in the Kezar Falls area;
three are branches of Casco Bank and Trust Company, which has total resources of $157 million, and one

96



$4,918,293
236,704,821
241,623,114

To be
operated

1
29
30

is a branch of Canal National Bank, which has total
resources of $133 million.
Maine National Bank, the charter bank, with total
resources of $217.8 million, was organized in 1889 as
the Portland National Bank. It maintains a total of 29
branch offices in the counties of Sagadohoc, Knox,
York, Oxford, Somerset, Franklin, and Cumberland. It
also has two approved, but unopened, branches in
Cumberland County.
The charter bank is headquartered in Portland, the
largest city and the transportation and banking center
of Maine. Approximately 13,166 of the 65,116 persons
located in the Portland area work in small manufacturing firms producing paper, food, fabricated metal, and
leather products. In addition to manufacturing, the
merging bank's economy is dependent on agriculture,
marine products, and tourism.
Competition with the charter bank is provided by 15
commercial banks, with total assets of $792 million;
14 savings banks, with combined resources of $653
million; and 12 savings and loan associations, with
approximately $147 million total resources. Additional
local competitors for the charter bank consist of sev-

eral industrial banks, insurance companies, credit
unions, loan offices, sales finance companies, and governmental lending agencies.
Competition will not be adversely affected by consummation of the proposed merger. The service areas
of subject banks are distinct and do not overlap. Common customers are minimal and common borrowers
are merely the result of participations by the small
merging bank. The proposed merger will result in
minimal change of the current holdings of charter bank
in the deposits and loans of the service areas. The main
offices of subject banks are 36 miles apart and charter
bank's nearest branch is 32 miles distant.
Consummation of the proposed merger will enable
resulting bank to offer the Kezar Falls service area
additional and expanded services such as trust and
computer services, installment loan plans, and Bank
Americard and American Express credit card programs
The proposed transaction will, in effect, enhance competition in the merging bank's service area by enabling
the resulting bank to compete with services offered by
the $157 million Casco Bank and Trust Company and
the $133 million Canal National Bank.
Accordingly, applying the statutory criteria to this
application, it is concluded that the proposed merger
is in the public interest. The application, therefore, is
approved.
AUGUST 215

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest office of Maine National to Kezar Falls
Bank is located in Westbrook, 32 miles east of Kezar
Falls. There are numerous banks in the intervening
area. The existing competition eliminated by the proposed merger would be de minimis.
Maine law permits banks to branch de novo within
their headquarters county and adjacent counties. Thus,
Main National could establish de novo branches in
Kezar Falls and throughout York County. The attractiveness of the area from the standpoint of new entry
is doubtful, however. The southern portion of York
County is more populous and more prosperous than the
northern section of the county. Despite the fact that the
nearest competing bank is 15 miles away and that there
are only four banking offices within a 25-mile radius,
Kezar Falls Bank remains the second smallest commercial bank in the State. There appears to be virtually no
competition from other financial institutions. The fact
that Kezar Falls Bank has been able to attract so little
money from such an insulated market suggests the market's limited possibilities from the standpoint of de novo
branching. Thus, although Maine National must be regarded as a significant potential entrant into any suitably attractive Maine banking market, the proposed acquisition would not appear to result in the loss of substantial potential competition.

OLD NATIONAL BANK OF WASHINGTON, SPOKANE, WASH., AND THE FIRST NATIONAL BANK OF FERNDALE, FERNDALE, WASH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Ferndale, Ferndale, Wash. (11667), with
was purchased Sept. 29, 1972, by Old National Bank of Washington, Spokane,
Wash, (4668), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On June 23, 1972, the Old National Bank of Washington, Spokane, Wash., applied to the Comptroller of
the Currency for permission to purchase the assets and
assume the liabilities of The First National Bank of
Ferndale, Ferndale, Wash.
Old National Bank of Washington, the purchasing
bank, was organized in 1891, and holds assets of $368.4
million. It operates 45 branches with combined IPC de-




To be
operated

$12,412,404

1

384, 556, 199
396, 968, 603

46
47

posits of $291.4 million; except for two branches in
Seattle, all are located east of the Cascade Mountains.
The purchasing bank, an aggressive competitor, is controlled by Washington Bancshares, Inc., Spokane, a
registered bank holding company which owns 98.5 percent of its outstanding shares.
Spokane, home of the purchasing bank and the center of its service area in eastern Washington, is the
recognized capital of, and, with a population of

97

170,516, the largest city in the Inland Empire, an area
encompassing eastern Washington, northern Idaho,
and western Montana. The Inland Empire, with a
population of almost 1.2 million, is a unique area,
bounded on the west by the Cascade Mountain Range,
on the north by the Canadian border, on the east by the
Rockies and Bitterroot Mountains, and on the south by
the Blue Mountains. The nucleus of the economy is
provided by forest products, mining, and agriculture.
Manufacturing is important to metropolitan Spokane
with 350 manufacturing establishments in the area.
There are a number of retail trade outlets and wholesale establishments in Spokane. Because Spokane and
the Inland Empire are not dependent upon any single
industry, modest but continued sound economic growth
is anticipated. In Seattle, where two of the purchasing
bank's branches are located, the aerospace and aircraft
industries are important; however, due to cutbacks in
those industries, the economy is depressed.
Statewide, the purchasing bank is the fifth largest
commercial bank, ranking behind the Seattle-First National Bank, which has $2.3 billion in total deposits;
The National Bank of Commerce of Seattle, which
has $1.2 billion in deposits; Pacific National Bank of
Washington, which has $643 million in deposits; and
the People's National Bank of Washington, which has
$441 million in deposits. All four are headquartered
in Seattle, in the western third of the State. The Puget
Sound National Bank, Tacoma, is the State's sixth
largest bank, with total deposits of $217 million. In
Spokane, the purchasing bank competes with offices of
the Seattle-First National Bank; Washington Trust
Bank, Spokane; First National Bank in Spokane; Pacific National Bank of Washington, Seattle; and the
American Commercial Bank, Spokane. Numerous other
financial institutions also compete in the purchasing
bank's primary service area and in the State.
The First National Bank of Ferndale, Ferndale,
Wash., the selling bank, was organized in 1904. With
assets of $11.6 million and IPC deposits of $9.6 million,
the bank is considered to be financially sound. The single office of the selling bank is located approximately
110 miles north of Seattle in Ferndale, a town of 2,200
inhabitants. Since 1950, the opening of an aluminum
plant and two oil refineries have provided the base for
appreciable growth in the area, and that has been reflected in the growth of the bank. However, agriculture, especially milk producing, remains dominant
among the 10,000 inhabitants of the estimated trade
area.
The selling bank competes with one office of Bel-

98



lingham National Bank, Bellingham, with total deposits of $34.2 million; an office of the National Bank
of Commerce, Seattle, located 14 miles northwest in
Blaine; and the Bellingham First Federal Savings and
Loan Association, with $36 million in assets.
There is no existing competition between the subject
banks as their nearest offices are over 100 miles distant.
There is no likelihood of potential competition as Washington's restrictive branching laws permit statewide
branching only through merger, and permit de novo
branching only within the county in which the bank's
headquarters are located, or in unbanked cities and
towns. Therefore, Ferndale is not presently open to
de novo entry.
The proposed acquisition will not have any adverse
effect on competition in the areas involved. There
will be little or no impact upon banking in Spokane,
and the purchasing bank will increase its share of statewide deposits by only 9.2 percent, leaving unchanged
its present ranking among State banking institutions.
The resulting bank in Ferndale, with its broader lending limits and additional resources, will be in a position
to better serve the community, as well as to meet the
credit needs of the industrial firms which have moved
or are moving into the area. Furthermore, the proposed
acquisition of the selling bank will solve that bank's
management succession problems.
To the purchasing bank, the acquisition means
further penetration into the western part of the State
where most of the State's population, commerce, and
industry are located, and a stronger competitive position with respect to the State's larger banks. To Ferndale, the transaction means the removal of home office
protection and the consequent opening of the town to
de novo entry. It provides for the immediate emergence
of an overall stronger bank able to offer more effectively the services and support needed for the development of an expanding community.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
AUGUST 23,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest Old National Bank of Washington office
to First National Bank of Ferndale is some 100 miles
distant in Seattle. The proposed acquisition will not
eliminate substantial existing competition.
Six commercial banks operate 15 banking offices in
Whatcom County. As of June 30, 1970, First National

Bank of Ferndale ranked fifth of these six banks, with
7.3 percent of county deposits. Although Old National Bank of Washington is the third largest potential entrant into commercial banking in Whatcom
County, due to the small relative size of First National
Bank of Ferndale, the proposed acquisition will not
have a significantly adverse effect on potential
competition.
The proposed transaction differs significantly in
competitive effect from the attempted consolidation of

First National Bank of Ferndale with Seattle-First
National Bank, the largest bank in the State, and a
leading bank in Whatcom County. This consolidation
was abandoned after being challenged under the antitrust laws by the Department of Justice, which contended that First National Bank of Ferndale could
serve as a foothold entry for another bank not already
serving Whatcom County. The instant transaction in
fact represents such foothold entry into the county by
Old National Bank of Washington.

FIRST NATIONAL BANK OF MERCER COUNTY, CELINA, OHIO, AND T H E ROCKFORD NATIONAL BANK, ROCKFORD,
OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Rockford National Bank, Rockford, Ohio (11804), with
and First National Bank of Mercer County, Celina, Ohio (5523), which had
merged Sept. 30, 1972, under charter and title of the latter bank (5523). The
merged bank at date of merger had

COMPTROLLER S DECISION

On May 4, 1972, The Rockford National Bank,
Rockford, Ohio, and The First National Bank of
Celina, Celina, Ohio, applied to the Comptroller of
the Currency for permission to merge under the charter of the latter and with the title, "First National Bank
of Mercer County."
The First National Bank of Celina, the charter
bank, was organized in 1900, and is currently the largest bank in Mercer County. The bank has total assets
of $29.5 million and IPC deposits of $24.8 million. It
operates two branches, one in Celina itself, the other
in the village of Mendon which is 11 miles northeast
of the head office. In addition, the charter institution
has submitted an application for a branch in Coldwater, 9 miles southwest of the head office.
The Rockford National Bank, the merging bank,
was organized in 1920, and operates as a unit institution. The bank, with assets of $8.7 million and IPC
deposits of $7.8 million, is located in a small rural
village in Mercer County, 12 miles northwest of Celina.
At present, because of the bank's relatively small size,
its isolated location, and the unwillingness of the present directorate to pay competitive salaries, the merging
bank is experiencing difficulty in attracting successor
management for its aging chief executive officer. In




$9, 293, 053
33, 386, 519
42, 747, 466

To be
operated

1
3

4

addition, the merging bank is unable to satisfy the
increasingly large credit needs of the large farms which
surround Rockford.
Mercer County is served by three additional commercial banks, all of which compete, to some extent,
with the charter bank. Those banks, all of which are
unit institutions, consist of The Peoples Bank Company, Cold water, with deposits of $17.4 million; the St.
Henry Bank, St. Henry, with deposits of $9 million;
and The Fort Recovery Banking Company, Fort Recovery, with deposits of $7.4 million. Additional competition for the charter bank is provided by commercial banks in adjoining counties, situated in cities to
which residents of Mercer County commute. The
merging bank is located in an isolated section of Mercer County and competes with no other banks, except
in respect to the commuting habits of its residents.
The market area of the charter bank includes all of
Mercer County and portions of Auglaize, Van Wert,
Allen, and Darke counties. The economy of this area
is well diversified, being equally dependent upon agriculture, industry, and locally-based service businesses.
The farms in the market area are generally large; the
major produce from them include dairy products, corn,
wheat, soybeans, and livestock. In addition, there are
47 major manufacturers which aggregately employ

99

1,500 people. In contrast to that, the service area of
the merging bank is much more restricted, consisting
only of Rockford and its immediate environs. That
area has a very small industrial base and is dependent
primarily on the agricultural pursuits of nearby farms.
A lack of industrial development in Rockford has had
a deleterious effect upon the growth of the city and has
had a negative impact on the commercial and wholesale foundation of the community. There is only one
industrial manufacturer in the area, employing 40
people. Consequently, it is the pattern of many residents of Rockford to commute long distances daily to
industrial employment.
There is minimal competition between the charter
and merging banks because relatively large distances
separate the two banks and an adequate number of
competitors operate in the continued service areas of
the two financial institutions. Although one independent bank will be eliminated when this merger is consummated, there will remain adequate alternatives for
the banking public. Because of the 12 miles that separate the two applicants and the unaggressive policies
and restricted service area of the merging bank, no
significant competition will be eliminated, and the resulting bank will be able to stimulate competition
within its multi-county market area. The successful
completion of this transaction will also resolve a management succession problem at the merging bank and
will, therefore, insure its continuity and the benefit of
the community. Furthermore, benefits will accrue to
the Rockford community by virtue of the availability
of a lending limit nearly five times larger than the present capability of the merging bank, by the introduction
of a greater variety of services and loan types, and by
direct financial assistance in community development.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 2,1972.

100



SUMMARY OF REPORT BY ATTORNEY GENERAL

Rockford is 12 miles northwest of Celina and 12
miles west of Mendon, where Gelina Bank has a
branch. The application indicates that there is a good
deal of commuting by Rockford residents to Gelina,
both for employment and shopping. However, the
actual volume of loans and deposits derived by each of
the merging banks from the home office town of the
other bank is not large. The proposed merger would
appear to eliminate only a limited amount of existing
competition.
The application indicates that the two banks in the
proposed merger draw the overwhelming bulk of their
business from a highly localized area. Therefore, the
area in which the effects of the proposed merger will
be most direct must be considered to be Mercer County,
and even this description may overstate the relevant
market.
The acquiring bank is the largest and the acquired
bank is the fifth largest of seven in Mercer County. The
merger will increase the acquiring bank's share of
deposits in the county from 26 percent to 33.9 percent.
The share of the two largest banks in the county will
increase from 51 percent to 59 percent. If the county's
second largest bank's proposal to acquire another
Mercer County bank is consummated, the concentration of commercial banking deposits in the hands of the
two largest banks in the county will increase additionally to 66 percent of county deposits.
In addition to the elimination of one of only a few
alternative sources of banking services for a significant
number of customers in Mercer County, the proposed
merger would increase the degree of concentration of
banking resources in this localized market to a level
that can be expected to dampen the vigor of banking
competition in that market.
We conclude that the proposed merger would have
an adverse effect upon competition which could be
compounded by consummation of the other proposed
merger.

T H E CANTON NATIONAL BANK, CANTON, OHIO, AND T H E MOUNT UNION BANK, ALLIANCE, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Mount Union Bank, Alliance, Ohio, with
and The Canton National Bank, Canton, Ohio (14501), which had
merged Sept. 30, 1972, under charter of the latter bank (14501) and title "The
United National Bank & Trust Company." The merged bank at date of merger
had

COMPTROLLER S DECISION

On June 23, 1972, The Mount Union Bank, Alliance, Ohio, and The Canton National Bank, Canton, Ohio, applied to the Comptroller of the Currency
for permission to merge under the charter of the latter
and with the title of "The United National Bank &
Trust Company."
The Canton National Bank, the charter bank, was
organized in 1854. The bank, with assets of $62.8 million and I PC deposits of $48.6 million, is headquartered
in Canton and, through five branch offices, serves the
entire city and suburbs of Canton.
The charter bank is the fifth largest of 14 commercial banks in Stark County, the area it considers to be
its trade area. Competitors include the Harter Bank
and Trust Company, Canton, with deposits of $234
million; the $124 million deposit Peoples-Merchants
Trust Company, Canton; and the $181 million deposit
First National Bank of Canton, which has become affilated with The Central Bancorporation, Cincinnati,
the 10th largest banking organization in the State.
The charter bank serves an estimated population of
110,000 in the Canton area. Approximately 75 percent
of those employed in Canton are engaged in the basic
steel and fabricated metal fields or in machine production. The charter bank services both the industry
located in the city of Canton and the residents of the
outlying Canton suburbs.
The Mount Union Bank, Alliance, Ohio, the merging bank, was chartered in 1930. The bank, with assets of $27.4 million and IPC deposits of $22.8 million,
operates one branch in Alliance in addition to its main
office. The bank, drawing most of its accounts from the
town of Alliance and surrounding environs, serves a
population of approximately 27,000. Competitors of
the merging bank include the First National City Bank
of Alliance, with deposits of $64 million. The Harter
Bank and Trust Company, Canton, with deposits of




$26, 392, 208
62, 738, 793

To be
operated

2
6

89,131,000

8

$234 million, has recently received approval to open a
branch office in Alliance.
At present, there is very little competition between
the charter and merging banks. The closest office of
the charter bank to the Mount Union Bank is 15.5
miles away. That distance, combined with the number
and size of competitors located between them,
minimizes any possibility of competition between the
two banks.
Consummation of the proposed merger will not produce any adverse competitive effects in Stark County.
The merger will make available to the Alliance banking community a number of more sophisticated services in the area of lending and a considerably increased
lending limit.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 21,1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the two banks are approximately 10 miles apart; the head offices are 16 miles
apart. A divided highway connects the cities of Canton and Alliance. Two offices of competing banks are
located in the generally intervening community of
Louisville. The application indicates no overlap of
primary service areas between the merging banks,
and only a slight account derivation overlap for certain
types of banking business. However, in view of the
geographic proximity of Canton and Alliance it is
likely that the proposed merger will eliminate some
existing competition and the potential for greater direct competition in the future between the two banks.
Commercial banking in Stark County is highly concentrated. As of December 31, 1971, there were 14
commercial banks serving Stark County. At that time,
Canton National, fourth largest in the county, accounted for 7.6 percent of total county commercial

bank deposits, while Union Bank's share was 3.1 percent. The four largest banks in Stark County account
for 73.3 percent of the total deposits held by county
banks. If the proposed merger is consummated, Canton
National, while remaining the fourth largest bank in
the county, will increase its share of deposits to 10.8
percent, and the share held by the four largest county
banks will increase to about 76.5 percent.
The proposed merger is likely to result in the elimi-

nation of some direct competition between the merging
institutions, and would increase the level of banking
concentration in Stark County.
Although the application indicates that the parties
to the proposed merger do not presently draw substantial banking business from each other's primary service
areas, we conclude that the proposed merger would
have some adverse competitive effect on commercial
banking in Stark County.

T H E FIRST NATIONAL BANK OF AURORA, AURORA, IND. , AND DILLSBORO STATE BANK , DILLSBORO, IND.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Dillsboro State Bank, Dillsboro, Ind., with
and The First National Bank of Aurora, Aurora, Inc . (699), which had
merged Sept. 30, 1972, under charter and title of the latter bank (699). The
merged bank at date of merger had

COMPTROLLER S DECISION

On May 3, 1972, The First National Bank of Aurora,
Aurora, Ind., and the Dillsboro State Bank, Dillsboro,
Ind., applied to the Comptroller of the Currency for
permission to merge under the charter and with the title
of the former.
The First National Bank of Aurora, the charter bank,
was organized in 1864, and is currently the second
largest bank in Dearborn County. The bank has assets
of $12.7 million and IPC deposits of $9.8 million. The
charter bank operates one in-town branch and is the
only commercial financial institution located in Aurora.
The service area of the charter bank has an economy
based on a mixture of diversified industrial and agricultural pursuits. Farm products include tobacco, corn,
and soybeans. Some dairy and beef cattle are raised,
although no particular agricultural product predominates. Industry within the service area includes a
casket company, a manufacturer of corrugated paper
boxes, a cast iron foundry, and a furniture manufacturer. In general, residents of Aurora commute to
nearby Cincinnati for employment and a smaller number are employed in the enumerated industries.
The Dillsboro State Bank, the merging bank, was
organized in 1901, and operates as a unit bank in Dillsboro. The bank has assets of $5.7 million and IPC
deposits of $4.5 million. The merging bank is a locallyoriented financial institution. Because of its isolated
geographic location the merging bank serves only the




$6,291,368
13,573,402
19, 864, 770

To be
operated

1

2
3

residents of Dillsboro and the immediately surrounding rural area.
Dillsboro is a small farm community with no local
industry. Surrounding farms are generally small, ranging from 50 to 150 acres in size. The primary crops
produced in this area are tobacco, corn, and soybeans.
In addition, many residents of Dillsboro commute
daily to Lawrence, Aurora, or Cincinnati for employment. The village has a population of 840 people, as
recorded in 1970.
At present there are five banks in Dearborn County.
The charter bank is the second largest in terms of
deposits and loans, and the merging bank is the smallest in the county. The small merging bank is a locallyoriented unit bank which does not compete significantly with any other bank in the county. A branch
of a Lawrenceburg-based bank, in Moores Hill, is
the closest bank in the county to the merging bank,
and is approximately 6 miles away. The charter bank
receives competition from American State Bank, with
deposits of $6.3 million, and Peoples National Bank,
with deposits of $15.1 million, both of which are headquartered in Lawrenceburg.
Competition between the charter and merging banks
is minimal since the natural barriers of distance and
geography prevent any significant competition between
them. In spite of the fact that many Dillsboro residents
commute daily either to Lawrenceburg or Aurora, or

through those communities to Cincinnati, few Dillsboro residents were found to be customers of the
charter bank, as revealed by a sampling of the bank's
records. The charter and merging banks are located
10 miles apart.
Consummation of the proposed merger will not
result in any adverse competitive effects in Dearborn
County. The merger will not eliminate any competition and an adequate number of banking alternatives
will remain in the county to serve the banking public.
Although the resulting bank will become the largest
financial institution in the county, in terms of deposits,
and the second largest, in terms of loans, the margin
over the next largest commercial bank, The Peoples
National Bank of Lawrenceburg, will be so slight as to
be insignificant. Furthermore, the proposed merger will
resolve a management succession problem within the
merging bank which, because of the small size of the
bank, is unlikely to be corrected by its present Board.
Residents of Dillsboro will benefit directly from the
resulting bank's expanded lending limit, additional

and more efficient services, and the retention of a
local and convenient banking outlet.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 10,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The First National Bank of Aurora and Dillsboro
State Bank are two small banks located 10 miles apart,
with no intervening banking offices; the proposed
merger may therefore be expected to eliminate some
existing competition between them. In addition, the
merger of the two banks may eliminate the potential
for increased competition between them that can be
expected as the area between them is developed. Of
the five commercial banks in Dearborn County, First
National Bank of Aurora ranks second, and Dillsboro
State Bank ranks fifth in terms of total deposits, holding 25 percent and 11 percent of the county's deposits,
respectively.

T H E FIRST NATIONAL BANK OF SUNBURY, SUNBURY, PA., AND T H E FIRST NATIONAL BANK OF MOUNT CARMEL,
MOUNT CARMEL, PA.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The First National Bank of Mount Carmel, Mount Carmel, Pa. (3980), with
and The First National Bank of Sunbury, Sunbury, Pa. (1237), which had
merged Oct. 2, 1972, under charter of the latter bank (1237) and title "First
National Trust Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On May 26, 1972, The First National Bank of
Mount Carmel, Mount Carmel, Pa., and The First
National Bank of Sunbury, Sunbury, Pa., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of "First National Trust Bank."
The First National Bank of Sunbury, the charter
bank, with deposits of $38.5 million, was established in
1831, and operates two branches.
Sunbury, home of the charter bank, is located 52
miles north of Harrisburg, Pa. It has a population of
13,000 and is the county seat of Northumberland
County. Its economy is presently stable and is supported
by a wide variety of small and light industry, plus




$25, 668, 570
51,887,864
77, 825, 040

2
3

5

Selinsgrove State School and Hospital and Susquehanna University, both located in Selinsgrove. The
charter bank serves west-central Northumberland
County, northeastern Snyder County, and a portion
of southeast Union County.
The charter bank's direct competitors include the
Susquehanna Valley Bank and Trust Co., Sunbury,
with $10.1 million in deposits; Northumberland National Bank, Northumberland, with $10.2 million in
deposits; Snyder County Trust Co., Selinsgrove, with
$25.7 million in deposits; Tri-County National Bank,
Middleburg, with $34.9 million in deposits; and Swineford National Bank, Middleburg, with $11.3 million
in deposits.
The First National Bank of Mount Carmel, the
merging bank, with deposits of $22.2 million, was estab-

SUMMARY OF REPORT BY ATTORNEY GENERAL

The two closest branches of National Bank of
North America to National Bank of Far Rockaway
are the Lawrence-Cedarhurst branch, approximately
2 miles from National Bank of Far Rockaway, and the
Hewlett-Woodmere branch, approximately 4 miles
from National Bank of Far Rockaway. Several offices
of competing commercial banks lie in the intervening
areas. According to the application, National Bank of
North America draws about $500,000-$600,000 in
deposits from the immediate service area of National
Bank of Far Rockaway, and a very small amount of
loan business from the same area. While these sums are
not large in comparison to the total banking business
done by all banking offices serving the Far Rockaway
area, this deposit business would approximate 10 percent of National Bank of Far Rockaway's total de-

posits. In view of the proximity of the offices and the
strong overall competitive position of National Bank
of North America on Long Island, it appears that the
proposed merger would eliminate some existing
competition.
The application identifies 25 banking offices of nine
commercial banks within approximately a 4-mile radius
of National Bank of Far Rockaway. In view of the size
and limited service area of National Bank of Far Rockaway, even this limited area may overstate the relevant
market in which to assess the competitive effects of the
proposed merger. In this area, National Bank of North
America holds the fourth leading share of commercial
bank deposits, about 13 percent, while National Bank
of Far Rockaway holds the smallest share, about 2.7
percent. The proposed merger may have some adverse
competitive effect.

FIRST UNION NATIONAL BANK OF NORTH CAROLINA, CHARLOTTE, N.C.,
CORNELIUS, N.C.

Name of bank and type of transaction

AND NORTH MECKLENBURG BANK

Total assets
In
operation

North Mecklenburg Bank, Cornelius, N . C , with
and First Union National Bank of North Carolina, Charlotte, N.C. (15650),
which had
merged Oct. 18, 1972, under charter and title of the latter bank (15650). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 13, 1972, application was made to the
Comptroller of the Currency for permission for First
Union National Bank, Charlotte, N . C , and the North
Mecklenburg Bank, Cornelius, N . C , to merge under
the charter and with the title of the former.
In accordance with the provisions of 12 U.S.C.
1828 (c) it is found that an emergency exists and that




To be
operated

$8, 177, 358

3

1, 444, 982, 363

163

1,452,020, 945

166

this Office must act immediately to prevent the probable failure of the North Mecklenburg Bank in Cornelius and to protect its depositors, creditors, and
shareholders.
Accordingly, the application to merge is approved.
OCTOBER 18,

1972.

NOTE.—Due to the emergency nature of the situation, a
report on competitive factors was not requested.

BANK OF NORTH CAROLINA, NATIONAL ASSOCIATION, JACKSONVILLE, N.C., AND T H E FARMERS BANK OF SEABOARD,
SEABOARD, N.C.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Farmers Bank of Seaboard, Seaboard, N.C, with
and Bank of North Carolina, National Association, Jacksonville, N.C (14676),
which had
merged Oct. 20, 1972, under charter and title of the latter bank (14676). The
merged bank at date of merger had

COMPTROLLER S DECISION

On May 18, 1972, The Farmers Bank of Seaboard,
Seaboard, N.C, and the Bank of North Carolina,
National Association, Jacksonville, N . C , applied to
the Comptroller of the Currency for permission to
merge under the charter and title of the latter.
The Bank of North Carolina, National Association,
Jacksonville, N.C, the charter bank, was organized in
1952> and is currently the seventh largest bank in
North Carolina. The bank, with $250 million in assets
and $154.2 million in I PC deposits, is headquartered
in Jacksonville, and operates 51 offices in 31 communities in North Carolina. While it is rapidly becoming
a statewide bank, it still generates most of its business
from the eastern portion of the State, wherein the
majority of its offices are located. Through statewide
expansion, it is attempting to compete on a more favorable level with the larger North Carolina banks which
are acquiring office locations in various areas of the
State. The charter bank is a principal component, and
sole bank subsidiary of Bankshares of North Carolina,
Inc., a bank holding company.
Bank of North Carolina, N.A., is generally in competition with every major bank in North Carolina.
Throughout most of the area served by the charter
bank are offices of Wachovia Bank and Trust Company, N.A., with total deposits of $1.6 billion; North
Carolina National Bank, with $1.5 billion in deposits;
First Union National Bank of North Carolina, with deposits of $1.1 billion; First Citizens Bank and Trust
Company, with $715 million in deposits; Northwestern Bank, with deposits of $631 million; and Branch
Banking and Trust Company, with $263 million in
deposits.
The Farmers Bank of Seaboard, Seaboard, N.C, the
merging bank, was organized in 1906. As an independent, single-office bank, it has $3.8 million in assets and $3.3 million in IPC deposits. The bank's serv501-D17 O—73



To be
operated

$3, 482, 290

1

324, 860, 673

55

328, 310, 716

56

ice area is considered to be Northampton County which
has a total population of 25,000 persons. The merging
bank is the sole bank in the small community of Seaboard, a rural trading center with a population of approximately 611 persons. The area is economically
dependent upon agriculture, with peanuts and cotton
the principal crops. There are also various small businesses and light industrial operations within the area.
Banking competition in the service area of the
merging bank is provided by an office of the $1 billion
Virginia National Bank in nearby Boykins, Va.; by the
Bank of Northampton, located 10 miles south, with
deposits of $4.2 million; by the Bank of Conway, with
$2.2 million in deposits; by two offices of the Planters
National Bank and Trust Company, with $117.2 million in deposits; and by The Farmers Bank at Woodland, 20 miles southeast, which has just merged with
the North Carolina National Bank, the second largest
bank in the State.
There is presently no competition between the charter bank and the merging bank. The charter bank operates no branches within Northampton County or in
the surrounding contiguous counties. The closest existing office of Bank of North Carolina is 60 miles southeast of Edenton. An application is now pending for a
merger with the Bank of Hobbsville, in Hobbsville,
which is 50 miles east.
From a statewide view, this merger is quite insignificant as there will only be a marginal increase of the
charter bank's assets. The charter bank holds only 1.4
percent of the total deposits in North Carolina and
the merging bank holds but 2.7 percent of the charter
bank's total deposits. Neither will there be any anticompetitive effects in Northampton County. In fact,
the combining of the two banks will intensify competition in that area.
The capital and managerial resources of the charter
bank will help solve the merging bank's serious management succession problem. Making available sophis-

107

fore, that the proposed merger will eliminate substantial existing competition between Bank of North Carolina, National Association and Farmers.
Farmers is the third largest of five banks serving
Northampton County, and accounts for about 11 percent of total bank deposits in the county. The largest
bank in the county is in the process of merging with
North Carolina National Bank, the second largest bank
in the State. Additionally, Planters National Bank and
Trust Co., the State's 10th largest bank, headquartered
in Rocky Mount, operates two branches in the county.
North Carolina banking law permits statewide
branching. Bank of North Carolina, National Association, therefore, could expand into Seaboard de novo.
However, because of Seaboard's size and the fact that
the area has experienced below average growth, de
novo entry into the area would not appear to be attractive. In addition, there are five banks larger than the
acquiring bank which could enter by opening a new
branch, and which may also be considered prospective
potential entrants.
We conclude that the proposed merger would not
have any significantly adverse effect on competition.

ticated banking services, including fiduciary services
and more diversified local financing, should prove
beneficial to industry, commercial businesses, and the
general banking public. The area, especially in the
vicinity of Interstate 95, will be made more economically attractive to new and diverse business inputs.
The merger will replace the small Farmers Bank of
Seaboard with a more formidable competitor in an
area served by larger banks, and will facilitate the
Bank of North Carolina's attempts to extend its sphere
of operations in serving the banking needs of a growing
economy.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. It is,
therefore, approved.
SEPTEMBER 18, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The Bank of North Carolina, National Association,
office closest to Farmers is located 65 miles southeast
of Seaboard in Edenton, Chowan County, and several
banking facilities intervene. It would not appear, there*

*

*

T H E ONEIDA NATIONAL BANK AND TRUST COMPANY OF CENTRAL N E W YORK, UTICA, N.Y., AND T H E FIRST
NATIONAL BANK OF CENTRAL SQUARE, CENTRAL SQUARE, N.Y.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Central Square, Central Square, N.Y. (10109), with..
and The Oneida National Bank and Trust Company of Central New York, Utica,
N.Y. (1392), which had
merged Oct. 20, 1972, under charter and title of the latter bank (1392). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On July 7, 1972, The First National Bank of Central
Square, Central Square, N.Y., and The Oneida National Bank and Trust Company of Central New York,
Utica, N.Y., applied to the Comptroller of the Currency for permission to merge under the charter and
with the title of the latter.
The Oneida National Bank and Trust Company of
Central New York, with total resources of $339 million
as of December 31, 1971, was incorporated in 1836 as
The Oneida Bank. In 1865, the bank converted to a
National bank and, after a series of name changes, its
current name was adopted in 1959. The most recent

108



To be
operated

$17,866,296

3

358, 761, 262

24

376, 627, 558

27

merger of the bank, and the only merger during the last
5 years, was effected in October 1967 when The National Bank of Waterville, with $5 million in deposits,
was acquired by applicant. The bank presently operates
22 offices centered in the counties of Herkimer and
Oneida, which are located in the eastern section of the
Sixth Banking District of New York.
The primary trade are of The Oneida National Bank
and Trust Company of Central New York extends in a
radius of about 50 miles from its head office town of
Utica, and serves an estimated population of 350,000
persons. The economy of the area is generally rural and
devoted to farming in the outlying areas; however,

Utica, the center of the largest metropolitan area in the
two-county area, is the home of many industries, including General Electric, Chicago Pneumatic Tool, Sperry
Rand, Bendix Corporation, Special Metals, Inc., and
Kelsey-Hayes Company. Each of those is said to employ over 1,000 workers. The other large city in the
trade area, Rome, is the site of Griffiss Air Force Base,
the largest employer in the upper Mohawk Valley and
one of the most important military installations in the
northeast United States, which employs 4,000 military
and 3,900 civilian personnel at a payroll in excess of $80
million.
As of December 31,1971, The Oneida National Bank
and Trust Company held $300 million in deposits
and ranked first in size among eight commercial banks
headquartered in the two-county area in which it operates, holding 75 percent of the $400 million deposits.
It ranked third in size and held 15.1 percent of the
$2 billion in total deposits held by 24 commercial banks
in the Sixth Banking District of New York. Primary
competition is provided by Marine Midland BankCentral, Syracuse, with total deposits of $532 million,
and a member of Marine Midland Banks, Inc., a multibank holding company with total deposits of $6.4 billion. Additional competition is provided by The Savings Bank of Utica, Utica, with deposits of $282 million, and Homestead Savings and Loan, with deposits
of $65 million.
The First National Bank of Central Square, Central
Square, with total resources of $16 million at December 31, 1971, was organized in 1912, and has not been
party to any merger, consolidation, or purchase of
assets since its inception. The bank operates two
branches in Oswego County which had a 1970 population of 100,897, and serves an estimated population of
7,000 persons. The economy is generally devoted to
farming; however, the majority of residents commute
to the Metropolitan Syracuse Area, located 16 miles
south of Central Square, for employment.
As of December 31, 1971, The First National Bank
of Central Square ranked 16th in size and held $14
million, or 0.7 percent, of the total deposits of $2 billion
held by the 24 commercial banks in the Sixth Banking
District. There are no competing banks in the immediate vicinity; however, all of the large Syracuse-based
banks, with their extensive branch systems, offer a moderate degree of competition. The last report of examination of the bank, dated March 6, 1972, revealed the
overall condition to be good, although management was
rated fair due to the lack of management succession as
President LeFaivre, at 65 years of age, is looking to
retirement.




The $355 million resulting bank would hold $314
million in total deposits, or 15.8 percent of the total
deposits of $2 billion in the Sixth Banking District.
It would not significantly increase its ranking among
competing banks nor would it increase its position
among other commercial banks operating in the Sixth
Banking District.
The resulting bank will provide improved and expanded services to the residents and customers served
by The First National Bank of Central Square, including a larger lending limit, various consumer savings
plans, credit card services, a qualified staff of agricultural department personnel, and trust department
services. The resulting bank would also benefit the
communities served through financing of municipal
bond issues. It would also solve the management succession problem of the merging bank,
cultural department personnel, and trust department
Competition between The First National Bank of
Central Square and The Oneida National Bank and
Trust Company of Central New York appears insignificant. The head offices of the two banks are approximately 50 miles apart. The nearest office of Oneida
National is its Sylvan Beach Branch, which is 17 miles
from the Constantia Branch of the Central Square
bank, and the area in between is sparsely populated.
Consummation of the merger would have a favorable
effect upon competition in the Central Square service
area as the residents will have another realistic alternative to the branches of the several large, full-service
Syracuse-based banks now serving the area.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and therefore is approved.
SEPTEMBER 7,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest branch offices of Oneida Bank to any
office of First National are its Sylvan Beach branch,
recently opened, which is 17 miles from the Constantia
branch of First National, and its Camden branch, which
is 24 miles from the Constantia branch. There are no
other competing banks in the directly intervening area.
Sylvan Beach is on the eastern shore of Oneida Lake
and Constantia is on its northwestern shore. The area
along the northern shore of Oneida Lake between these
communities is not densely populated, but both banks
draw some business from the residents of Bernhards Bay
and Cleveland, which intervene between Sylvan Beach
and Constantia. Thus, it would appear that the proposed merger would eliminate some direct competition.
The service areas of the two banks can be most accu-

rately described as adjoining and to some extent overlapping.
Under New York law, a bank may branch de novo
within its banking district but communities of less than
75,000 are afforded "home office protection." While
Central Square itself it closed to de novo branching,
Oneida Bank could enter the general area in this
manner.
As of June 30, 1970, First National, the sixth largest
of seven banks operating in Oswego County, held
slightly less than 10 percent of the commercial bank
deposits in Oswego County and northern Onondaga

County banking offices. This area generally is dominated by banks based in Syracuse.
Oneida Bank is the largest commercial bank operating in district six (a seven-county area in the State of
New York wherein it can legally branch) which is not
presently operating in the service area of First National
a prosperous and growing area. Thus, the proposed
merger would eliminate some potential competition.
However, potential entry into the Greater Syracuse
Area by institutions outside the sixth district and the
size of First National relative to the leading banks in
the area ameliorates this loss.

VERMONT NATIONAL BANK, BRATTLEBORO, V T . , AND ETHAN ALLEN NATIONAL BANK, FAIR HAVEN, V T .

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Ethan Allen National Bank, Fair Haven, Vt. (2422), with
and Vermont National Bank, Brattleboro, Vt. (1430), which had
merged Nov. 24, 1972, under charter and title of the latter bank (1430). The
merged bank at date of merger had

COMPTROLLERS DECISION

On July 24, 1972, the Vermont National Bank,
Brattleboro, Vt., and the Ethan Allen National Bank,
Fair Haven, Vt., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the former.
The Vermont National Bank, the charter bank, was
organized as a State bank in 1821, and became a
National bank in May 1865. The bank, with assets of
$89.7 million and IPC deposits of $73.8 million, operates its 11 branches in the southeastern portion of the
State and ranks as the fifth largest bank in Vermont.
The charter bank competes with several other banks
in the cities in which its branches are located, including
the Vermont Bank and Trust Company, Brattleboro,
with deposits of $83 million; the Catamount National
Bank, North Bennington, with deposits of $22 million;
the First National Bank of Springfield, with deposits of
$21 million; and the County National Bank of Bennington, with deposits of $16 million.
The Ethan Allen National Bank, the merging bank,
was organized in 1879, and operated as a family-run
institution until 1965 when the controlling interest in
the bank was sold. A branch office established in Rut-




$9, 490, 771
91, 406, 456
100, 905, 977

To be
operated

1
14
15

land in 1966 has stretched the resources of the merging
bank. In spite of the bank's entry into the Rutland
market, the Ethan Allen National Bank has been unable to offer the banking services that are available
from their competition. Even though the economy of
the area is rapidly expanding, the bank's commercial
business has not been developed because of its small
size and the limitation of its resources and service capabilities. To meet the challenge of competition the
merging bank must strengthen its capital base and develop a more extensive staff of management personnel.
At present, the Ethan Allen National Bank has assets
of $8.8 million and IPC deposits of $7.6 million.
Although the main office of the merging bank has
direct competition from only one small commercial
bank, its branch in Rutland is situated in a highly competitive area where branches of several major Vermont
banks compete for the developing business. The Ethan
Allen National Bank is overshadowed in this area by
The Howard Bank, the second largest commercial bank
in the State, which has deposits of $142 million and
four offices in Rutland, and by First Vermont Bank,
the third largest bank in the State which also operates
four offices in Rutland, and by First Vermont Bank,
single storefront shopping center office is competing

with 10 banking offices in Rutland, all of which are
operated by substantially larger banks. Its ability to add
additional services and additional offices in order to
compete successfully are limited.
There is minimal competition between the charter
and merging banks because larger distances separate
the two banks and an adequate number of competitors
operate in the intervening distances. The Woodstock
office of the Vermont National Bank is 20 miles from
the Rutland office of the merging bank. Virtually no
competition exists between those two offices since the
Green Mountain Range serves as a natural barrier
separating the Ethan Allen National Bank from the
Woodstock office as well as from the remaining
branches of the charter bank.
Consummation of the proposed merger will stimulate
competition in southern Vermont since the resulting
bank will be in a better position from which to compete
with the other large banks in the area. The resulting
bank will be able to expand its services and will increase its competitive capability, especially in the Rutland area. Its new services will include a larger loan
limit, complete fiduciary facilities, expanded loan facilities, and data processing. The proposed merger will
not eliminate any competition but will provide a
stimulus for the charter bank to substantially increase
competition.
Applying the statutory criteria it is concluded that

the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 19,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are 26 miles
apart. Because of employment patterns, however, there
is some slight overlap in service areas. The amount of
direct competition that would be eliminated due to
the proposed merger does not appear to be significant.
A total of six commercial banks maintain offices in
Rutland County, accounting for $88.8 million in total
deposits. Ethan Allen Bank is the larger of the two
banks in Fair Haven, with 53 percent of deposits. Its
Rutland office accounts for about 7 percent of the
deposits held by the commercial bank offices in Rutland. Among its competitors there are two of Vermont's three largest banks.
Vermont law would permit Vermont National to
establish a branch office in Fair Haven or Rutland.
Although Fair Haven has shown good growth, the
presence of two banks there reduces its attractiveness
to de novo entry. While Vermont National, the fourth
largest bank in the State, stands as one of only two or
three banks with the resources necessary to expand into
Rutland on a de novo basis, its acquisition of Ethan
Allen Bank, the smallest competitor in the market, with
7 percent of deposits, would not appear to have a significantly adverse effect on competition.

THE CITIZENS NATIONAL BANK OF URBAN A, URBAN A, OHIO, AND T H E BANK OF NORTH LEWISBURG COMPANY,
NORTH LEWISBURG, OHIO
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The Bank of North Lewisburg Company, North Lewisburg, Ohio, with
and the Citizens National Bank of Urbana, Urbana, Ohio (863), which had
merged Nov. 29, 1972, under charter and title of the latter bank (863) The
merged bank at date of merger had

COMPTROLLER S DECISION

On July 11, 1972, The Bank of North Lewisburg
Company, North Lewisburg, Ohio, and The Citizens
National Bank of Urbana, Urbana, Ohio, applied to
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.




$3,315,595
19,774,260
23, 064, 855

To be
operated
1
2

3

The Citizens National Bank of Urbana, the charter
bank, was organized in 1865. That bank, with assets of
$18.4 million and IPC deposits of $13.7 million, operates a main office and one branch, both located in
Urbana. The charter bank serves a population of
11,850 in Urbana and, to a lesser degree, all of Champaign County and portions of Union, Logan, and
Clark counties. The economy of the market area is

primarily dependent on agriculture and related business, with manufacturing increasing in importance.
Prospects for future population growth and expansion
of business activity in the trade area are excellent.
The charter bank is the seventh largest of the 15
banks headquartered in its trade area. Keen competition is furnished by the Champaign National Bank of
Urbana, with deposits of $15 million. Additional competition includes the First National Bank of Springfield, with deposits of $75.5 million; the Springfield
Bank, with deposits of $78.8 million; the First Central
National Bank, Saint Paris, with deposits of $6.4 million ; and the Farmers and Merchants Bank Christiansburg, with deposits of $2 million. The large and highly
departmentalized banks of Columbus, Dayton, Marion,
Lima, and Cincinnati also compete with the applicant
because they solicit loans and deposits from the Urbana
area.
The Bank of North Lewisburg Company, North
Lewisburg, Ohio, the merging bank, was organized in
1872, and currently operates as a unit bank. That
bank, with assets of $3 million and IPC deposits of $2.5
million, draws most of its accounts from the village of
North Lewisburg, which has a population of 920, and
the surrounding environs. Economic activity in the
area is largely agricultural. Competitors of the merging
bank include The First National Bank of Marysville,
with deposits of $19 million, and the Farmers and
Merchants Bank, Milford Center, with deposits of $7.4
million.
At present, there is little, if any, competition between
the charter and merging banks. The closest office of the
charter bank to North Lewisburg is 15 miles away.

That distance, combined with the number of banks
competing in the intervening distance, and combined
with the competitive limitations resulting from the
small size of the merging bank, minimizes the competitive impact of a merger between the two banks.
Consummation of the proposed merger will not
cause any adverse competitive effects in the trade area
of either bank. The proposed merger will enable the
resulting bank to better serve the eastern part of Champaign County and will stimulate competition among
the other banks located in that area. In addition, the
merger will solve the management succession problem
at the merging bank which could become serious, if left
as it is.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 4,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The two banks are about 15 miles apart with no
major highway connecting them. Existing competition
between them appears to be de minimus.
While Ohio law would permit Citizens National
Bank of Urbana to branch de novo into North Lewisburg, the town's small size and lack of growth make
this an unlikely possibility. Citizens National Bank of
Urbana is only one of several potential entrants into
this community; consequently, the proposed merger
would not adversely affect potential competition.
The overall effect of the proposed merger would
not be adverse.

FIRST NATIONAL BANK, SLIDELL, LA., AND COMMERCIAL BANK & TRUST COMPANY, COVINGTON, LA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Commercial Bank & Trust Company, Covington, La., with
and First National Bank, Slidell, La. (14989), which had
consolidated Dec. 1, 1972, under charter of the latter bank (14989) and title "Commercial National Bank." The consolidated bank at date of consolidation had

112



$30, 100, 757
11,332,642
41,433,399

To be
operated
4
3

7

COMPTROLLER S DECISION

On July 12, 1972, First National Bank, Slidell, La.,
and Commercial Bank & Trust Company, Covington,
La., applied to the Office of the Comptroller of the
Currency for permission to consolidate under the charter of the former and with the title "Commercial
National Bank," the main office to be located in Covington, La.
First National Bank, the charter bank, with deposits
of $9.1 million, was organized in 1962. In addition to
its main office, the charter bank also maintains a
branch office in Pearl River and another in Lacombe.
The service area of the charter bank, narrowly defined, is the town of Slidell; more broadly defined, the
service area is St. Tammany Parish. St. Tammany
Parish is located approximately 5 miles north of New
Orleans and 65 miles east of the State capital at Baton
Rouge. The economy of the area is chiefly agricultural with some light industry. Many of the residents
of St. Tammany Parish commute to jobs in New
Orleans with most of the residents of Slidell working
in New Orleans.
Commercial Bank & Trust Company, the consolidating bank, with deposits of $25.4 million, was established in 1905. The consolidating bank, operating four
offices, is headquartered in Covington, the county seat
of St. Tammany Parish. Covington is about 38 miles
northwest of Slidell and has a population of approximately 9,300.
The service area of the consolidating bank is specifically the town of Covington, and more generally
St. Tammany Parish. The economy is also agriculturally oriented with some light industry present.
Among the five banks in St. Tammany Parish, the
charter and consolidating banks rank fourth and first,
respectively, in deposits. However, because many of the
residents commute to or otherwise choose to bank in
New Orleans, the larger banks in New Orleans must
realistically be considered to provide significant competition for the St. Tammany Parish banks. Direct
competition between the two banks is virtually nonexistent. Because of geographical and traditional cohesiveness as well as adequate banking resources in each
town, neither bank has seriously considered branching de novo into the other's town. Consequently, the
proposed consolidation will have no adverse competitive effect.
The consummation of the proposed consolidation
will benefit the residents of both Slidell and Covington
by introducing a local institution more capable of competing with the larger New Orleans banks. Further-




more, the resulting bank has plans to provide the first
local trust department services. Also, the proposed consolidation will solve a rather critical management succession problem at the charter bank.
Applying the statutory criteria, the proposed consolidation is in the public interest and is, therefore,
approved.
SEPTEMBER 7,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the two banks are Commercial
Bank's Mandeville branch and First National's Lacombe branch which are about 10 miles apart. The
principal offices of the two banks are separated by
about 30 miles. The application states that neither bank
draws more than an insignificant share of its deposits
or loans from the principal service areas of the other.
On the basis of information submitted, it would appear
that the proposed consolidation will not eliminate a
significant amount of competition presently existing
between the two banks.
Five banks operating 14 offices presently serve the
parish. On the basis of June 30, 1971, figures Commercial Bank was the largest bank and held about 40
percent of the deposits held by all banks in the parish.
First National, the second largest and fastest growing
of the three Slidell banks, was the fourth largest bank
in the parish with about 15 percent of deposits. The
parish's second largest bank, in Covington, and the
third largest, in Slidell, each accounted for about 18
percent of total deposits. If this proposed consolidation is consummated, the resulting bank would hold
more than 55 percent of the deposits held by banks
operating in the parish and control half of all the banking offices. The number of banking alternatives available in the parish would be reduced from five to four,
with the two largest banks accounting for over 73 percent of the deposits held by parish banks.
At the present time, Louisiana banking law permits
banks to branch only within the limits of their home
parish. Either bank, therefore, may be considered a potential entrant into areas now served by the other
particularly Commercial Bank into the Slidell area.
Thus, the proposed consolidation would eliminate
potential competition between the participants.
The approval of this application would result in the
consolidation of the first and fourth largest banks in
St. Tammany Parish, the two banks in the parish which
have registered the most impressive growth records of
all parish banks. This consolidation would permanently
eliminate any potential for increased competition be-

tween the two banks in the future, reduce the number
of banking alternatives available to parish residents,
and substantially increase concentration of deposits
among the banks operating in the parish. In the context of the record of substantial growth in Slidell and

NORTH CAROLINA NATIONAL BANK, CHARLOTTE, N.C.,

the parish, and the prospects for further population
growth and economic development, we conclude that
clearly the proposed consolidation would have an
adverse effect on banking competition in St. Tammany
Parish.

AND T H E BANK OF N E W BERN, NEW BERN,

N.C.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Bank of New Bern, New Bern, N . C , with
••
and North Carolina National Bank, Charlotte, N.C. (13761), which had
merged Dec. 15, 1972, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On September 29, 1972, North Carolina National
Bank, Charlotte, N.C, and The Bank of New Bern,
New Bern, N.C, applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the former.
North Carolina National Bank, the charter bank,
was organized in 1933, and is currently the second
largest commercial bank in North Carolina, with assets
of $2.2 billion and IPC deposits of $1.2 billion. The
bank operates 110 offices in 34 communities in various
parts of North Carolina, a majority of which are
located in the western portion of the State.
The charter bank competes both with the other
statewide financial systems in North Carolina and with
the smaller regional and local banks situated within the
individual service areas of various branches of North
Carolina National Bank. The larger statewide competitors include Wachovia Bank and Trust Company,
National Association, Winston-Salem, with deposits of
$1.6 billion; First Union National Bank of North Carolina, Charlotte, with deposits of $1.1 billion; and FirstCitizens Bank and Trust Company, Smithfield, with
deposits of $715 million.
The Bank of New Bern, the merging bank, was
organized in 1917, and is the smallest of three commercial banks maintaining offices in New Bern. It has
assets of $12.3 million and IPC deposits of $9 million.
The bank operates one branch office in New Bern
and the overwhelming majority of its deposit and loan
accounts originate in the city where it maintains its
two offices and in the immediate environs. The merging
bank, therefore, has a relatively restricted service area.




$13,274,782
2, 146, 544, 229
2, 159, 619, 294

To be
operated

2
134
136

The Bank of New Bern competes directly with First
Citizens Bank and Trust Company, the fourth largest
bank in the State, which maintains three offices in
New Bern Township and is the dominant bank in
Craven County, and with Branch Banking and Trust
Company, Wilson, the sixth largest bank in North
Carolina, which maintains two offices in New Bern
and has total deposits of $234 million. A secondary
level of competition is provided by a branch of
Wachovia Bank and Trust Company at Vanceboro
and Bank of North Carolina, National Association,
which maintains an office in nearby Havelock.
New Bern is a coastal city located in Craven County,
approximately 30 miles east of Kingston. Its position
on the Neuse Waterway, far behind the barrier beaches
of the Outer Banks, has effectively extinguished the
development of any major maritime business at the
port with the exception of a small amount of intercoastal activity. The economy of New Bern is dependent on lumber and plywood mills, small boat yards,
several clothing factories, and a large government military installation which employs many local residents in
a civilian capacity. The total work force of Craven
County is approximately 22,700, and the employment
patterns of the residents of this area are diversified with
the largest single segment employed at the Cherry
Point Marine Air Station. New Bern acts as a trading
and service center for the nearby military men and
their families.
There is minimal competition between the charter
and merging banks because relatively large distances
separate the closest two offices of those banks and an

resulting bank, which will remain the second largest
commercial bank in North Carolina.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 9,1972.

adequate number of competitors operate in the intervening distances. The nearest offices of North Carolina
National Bank to the offices of the merging bank are
at Jacksonville, 30 miles southwest of New Bern, and
at Washington, 36 miles to the north of the offices of
The Bank of New Bern. An analysis of the business
done by each bank in the service area of the other
further evidences the minimal character of the competition between the two proponents of this application. Furthermore, it is unlikely that the charter bank
would be able to enter New Bern through a de novo
branch application in view of the fact that a Federal
District Court has previously enjoined Wachovia Bank
and Trust Company from establishing a branch in that
city on the basis that the evidence in that application
fell short of establishing that the entry of a new bank
into the New Bern market was necessary or desirable.
That decision was rendered in June 1972.
Consummation of the proposed merger will directly
benefit the residents of New Bern by replacing a weak,
ineffective competitor with a branch of a large, dynamic bank which will be able to offer strong competition to the two other banks that now maintain
offices in that city. The merging bank has recently
experienced fiscal and managerial difficulties which
will be ameliorated by the proposed transaction. The
resulting bank will be able to offer a wider range of
services including trust facilities, financial advisory
services, installment loans, and a greatly increased lending limit which could help to stimulate industrial development in this area. The proposed transaction will
not affect the statewide competitive position of the

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of North Carolina National Bank
to Bank's offices are about 30 and 36 miles distant,
with other banks' offices intervening. An analysis of the
accounts of the offices of both banks shows only minor
competitive overlap in terms of deposits and loans
drawn by each from areas served by the other. The
proposed merger would not, therefore, appear to eliminate a substantial amount of actual competition
presently existing between the two banks.
Bank is the third largest of the live banks in Craven
County, with 15.2 percent of the county's bank deposits,
and the smallest of the three banks currently serving
New Bern. Commercial banking in Craven County is
highly concentrated with the three leading banks in
the county accounting for 90.5 percent of county
deposits.
North Carolina banking laws permit statewide
branching; thus, North Carolina National Bank could
establish a branch in New Bern and Craven County
de novo. The proposed acquisition would, therefore,
eliminate some potential competition. However, considering the below average growth in New Bern and
Craven County, and the existence of other potential
entrants, the loss of potential competition noted above
would be somewhat mitigated.

T H E NATIONAL BANK OF NEW JERSEY, NEW BRUNSWICK, N.J.,

AND SUBURBAN TRUST COMPANY, WESTFIELD,

NJ.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Suburban Trust Company, Westfield, N.J., with
and The National Bank of New Jersey, New Brunswick, N J . (587), which had. . . .
merged Dec. 22, 1972, under charter and title of the latter bank (587). The merged
bank at date of merger had

COMPTROLLER S DECISION

On September 22, 1972, Suburban Trust Company,
Westfield, N.J., and The National Bank of New Jersey,




$115,531,849
106, 633, 978
216,080,833

To be
operated

11
6

17

New Brunswick, N.J., applied to the Comptroller of
the Currency for permission to merge under the charter
and with the title of the latter.
The National Bank of New Jersey, the charter bank,

115

was organized in 1808 and now, with assets of $94.9
million and IPC deposits of $67.2 million, is 19th in
size of the 60 commercial banks in the Second Banking
District of New Jersey. The charter bank operates five
branches in Middlesex County and competes with virtually all of the commercial banks operating in that
county. In January 1971, all of the shares of The National Bank of New Jersey were acquired by Fidelity
Union Bancorporation, a registered multi-bank holding
company controlling aggregate deposits of $792 million.
The charter bank is the second largest of 20 commercial banks headquartered in Middlesex County and
competes with First Charter National Bank, Monroe
Township, which has deposits of $112 million and
which is the largest bank headquartered in Middlesex
County. The charter bank also competes directly with
local offices of many banks which are headquartered
elsewhere in the Second Banking District, including
The National State Bank, Elizabeth, with deposits of
$588 million; New Jersey National Bank, Trenton,
with deposits of $579 million; Franklin State Bank,
Somerset, with deposits of $149 million; and First
National Bank of Princeton, with deposits of $85 million, which is a member of United Jersey Banks, a
multi-bank holding company with aggregate deposits
of $1.1 billion. Additional competition is provided by
many other banks operating in that county as well as
the multi-million dollar banks based in Newark and
the multi-billion dollar banks headquartered in New
York City.
Suburban Trust Company, the merging bank, was
organized in 1952 as the result of a merger between
Westfield Trust Company and Cranford Trust Company. The merging bank, which operates 10 offices in
Union County, currently has assets of $112.9 million
and IPC deposits of $87.2 million and is the fifth largest of the 11 commercial banks headquartered in Union
County.
Competition for the merging bank is provided by
all 11 banks headquartered in Union County, including
The National State Bank, Elizabeth, with deposits of
$588 million; United Counties Trust Company, Elizabeth, with deposits of $294 million; Summit and
Elizabeth Bank and Trust Company, Summit, with
deposits of $175 million; and United National Bank
of Central Jersey, Plainfield, with deposits of $133
million. Additional competition is furnished by many
other banks which operate branches in Union County
and are headquartered elsewhere in the Second Banking District.
The service area of The National Bank of New Jersey
consists of all of Middlesex County where the economy

116



is highly industrialized. Because of that industrialization the charter bank has particularly emphasized its
wholesale financing activities for many nationallyknown corporations which maintain offices and manufacturing plants within the county. In contrast, the
merging bank is a retail-oriented institution whose
principal service area is Union County which has a diversified economy containing some industry and large
affluent residential communities.
There is only minimal competition between the charter and merging banks because of the distances that
separate their closest offices and the adequate number
of competitors operating in the intervening area. The
main offices of the principal banks are more than 15
miles apart and their nearest offices are separated by
5.3 miles, with six commercial banks operating 13 offices serving the intervening distance. That minimizes
any slight competitive effect which the two banks might
exercise upon each other.
Consummation of the proposed merger will result
in no adverse competitive effects in the Second Banking District of New Jersey because the resulting bank
will bring increased benefits to the residents of both
Union and Middlesex counties which are the respective service areas of the merging and charter banks.
The merger will have a favorable effect upon competition in Westfield, where the charter bank maintains
its head office, by opening it to de novo branching not
previously allowed because of head office protection.
The merger will also produce a favorable effect in
Middlesex County because the merging bank will bring
its expertise in the retail function of banking to the
service area of the National Bank of New Jersey. Affiliation with Fidelity Union Bancorporation will bring
expanded and improved services to the trade area of
Suburban Trust Company such as access to large loan
participation, data processing, international banking
services, complete trust services, and other specialized
functions usually offered only by the larger commercial
banks in the State. The resulting bank, with deposits of
$178 million, will become the sixth largest bank in the
Second Banking District and will continue to operate
all 16 offices of the two principal banks. The proposed
merger will not alter the statewide competitive position of Fidelity Union Bancorporation which will remain the fourth largest banking institution in the State;
with Midlantic Banks, Inc., First National State Bancorporation, and United Jersey Banks remaining
larger, each with deposits in excess of $1 billion.
Applying the statutory criteria, it is concluded that

the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank of New Jersey ("National Bank") is
a subsidiary of Fidelity Union Bancorporation, one of
New Jersey's largest multiple bank holding companies.
Total deposits of Fidelity, as of December 31, 1971,
were $792.2 million.
The closest office of Suburban Trust Company
("Suburban") to National Bank is the former's Plainfield office, 5.3 miles from National Bank's Middlesex
office, and 6.7 miles from National Bank's Metuchen
office. Although there are a number of intervening
banking alternatives, some competitive overlap does
exist between these two banks; the application indicates that Suburban had $3.8 million (or 4.4 percent
of its total) in IPC deposits and $0.8 million (or 3.5
percent of its total) in loans originating in Middlesex
County. National Bank does less than 1 percent of its
business in Union County. The service areas of these
two banks can best be described as adjoining and to a
limited extent overlapping. Fidelity Union Trust Co.,
Fidelity's lead bank, does draw some banking business
from Union County. While most of this business appears to be from the eastern segments of Union County,
some competition between this bank and Suburban
would be eliminated by the proposed merger.
New Jersey law permits district-wide branching
(subject to complete home office protection and branch
office protection in communities of less than 7,500

population) and allows statewide operations by bank
holding companies. The major effect on potential competition presented by the proposed merger would be
the elimination of Fidelity as a potential entrant into
the service area of Suburban. While many communities
in Suburban's service area are closed to de novo
branching, several are not, including Scotch Plains
and Cranford, where Suburban offices are located.
Moreover, home or branch office protection does not
appear to be a barrier to the chartering of de novo
holding company affiliates, and as one of the largest
New Jersey holding companies, Fidelity clearly has
the resources to effect entry into attractive areas. Communities within the western Union County service area
of Suburban have a total population of about 200,000
representing approximately a 15 percent increase since
1960.
Suburban is the fifth largest bank headquartered in
Union County, and the eighth largest bank operating
offices within the county. As of June 30, 1970, it held
about 7.5 percent of total county commercial bank deposits; however, this percentage would understate the
market position of Suburban in its more limited western
Union County service area. It is the 12th largest bank
in the Second Banking District.
In view of the resources and capability of Fidelity,
and the existing overlap between the service areas of
its present subsidiaries and that of Suburban, we conclude that its acquisition of another substantial Second
District bank in close proximity to its existing subsidiary would have at least some adverse effect on existing and potential competition.

BANK OF NORTH CAROLINA, NATIONAL ASSOCIATION, JACKSONVILLE, N.C.,

AND NORTH STATE BANK, BURLINGTON,

N.C.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

North State Bank, Burlington, N.G., with
and Bank of North Carolina, National Association, Jacksonville, N.G. (14676),
which had
merged Dec. 28, 1972, under charter and title of the latter bank (14676). The
merged bank at date of merger had

COMPTROLLER'S

DECISION

On September 12, 1972, North State Bank, Burlingtion, N.C., and Bank of North Carolina, National
Association, Jacksonville, N.C., applied to the Comp-




$25, 555, 565
348,815,525
369, 659, 404

To be
operated
6

57
63

troller of the Currency for permission to merge under
the charter and with the title of the latter.
Bank of North Carolina, National Association, the
charter bank, was organized in 1952 and, today, with

assets of $316 million and IPC deposits of $173.4 million, is the sixth largest commercial bank in North
Carolina. The charter bank operates 54 offices in 36
communities throughout North Carolina but maintains the majority of those in the eastern section of the
State. The bank is a principal component of Bankshares of North Carolina, which is a one-bank holding
company. Although the charter bank is rapidly becoming a statewide financial institution, it still generates
the majority of its business from the eastern section
of the State where many of the bank's offices are located
in small agriculturally oriented towns and communities. The bank has recently established offices in Charlotte, Raleigh, and Winston-Salem, which are among
the State's most heavily industrialized cities and are
located in the piedmont section of North Carolina.
The charter bank is generally in competition with
every major bank in North Carolina as well as with
the smaller, locally-based banks situated in close proximity to the individual branches of Bank of North
Carolina. The major statewide competitors for the
bank include Wachovia Bank and Trust Company, National Association, with deposits of $1.6 billion; North
Carolina National Bank, with deposits of $1.5 billion;
First Union National Bank, with deposits of $1.1 billion; First-Citizens Bank and Trust Company, with
deposits of $715 million; and The Northwestern Bank,
with deposits of $631 million.
North State Bank, the merging bank, was organized
in 1911 and curently has assets of $23.6 million and
IPC deposits of $16.5 million. The bank operates five
offices in Burlington and three nearby communities
in Alamance County, with one additional office in
Stoneville, located in Rockingham County. The Stoneville office, which is approximately 45 miles from Burlington, was acquired by merger in 1970, while the
remaining offices of the merging bank were opened as
de novo branches. Recently, the merging bank has suffered from a severe asset problem.
The principal service area of North State Bank
consists of the city of Burlington and its immediate environs in Alamance County where five of the six offices
of the merging bank are located. Alamance County,
which is in the northern Piedmont area, is one of the
leading industrial counties in North Carolina, the textile and apparel industries are the primary economic
forces. The other area in which the merging bank
operates is northwestern Rockingham County, which
is agriculturally-oriented with a small amount of industrial employment from plants in nearby towns. Within
that area, tobacco is the major crop and the textile
industry is the dominant industrial employer.




Banking competition in the city of Burlington and
in Alamance County is furnished by offices of four of
the five largest banks in North Carolina, as well as by
a small industrial bank headquartered in downtown
Burlington. In Rockingham County, where the merging bank operates a single office, there are 25 banking
offices of eight banks.
The charter and merging banks are not significant
competitors. The nearest office of the charter bank to
North State Bank is located at Elon College, approximately 4 miles west of Burlington, which was purchased from North Carolina National Bank in 1972.
The service area of the Elon College branch of the
charter bank, which has deposits of only $500,000, is
restricted to the town in which it is situated because
there is virtually no commercial activity except that
which is necessary to support Elon College, the primary
economic force in that city. The small amount of
banking activity in Elon College, its limited growth
prospects, and the limited service area of this branch,
have foreclosed any significant competition between
the charter bank and the nearby branches of the merging bank in Alamance County. The same factors that
have restricted competition in the past will also limit
the development of competition in the future.
Consummation of the proposed merger will stimulate competition in Alamance and northwestern Rockingham counties by replacing a small, poorly-managed
bank with branches of the sixth largest commercial
bank in North Carolina. The resulting branches will
offer many increased services currently unavailable
from the merging bank and will, therefore, be able to
provide more effective competition to the larger banks
operating within its service area. The merger will also
remedy the asset problem at North State Bank while
reinforcing the management at the resulting branches.
At present, North Carolina's five largest banks provide keen competition through 30 branch offices in the
two-county area served by the merging bank. The
existence of those strong competitors will insure adequate competition in the future. The proposed merger
will not affect the statewide competitive position of the
charter bank, which will remain the sixth largest commercial bank in the State.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 28,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Bank of North Carolina, National Association does
not presently have any offices in Rockingham County.

Its branch nearest the North State office in Stoneville
(that community's only banking facility) is located
about 40 miles south in Greensboro in adjacent Guilford County, with a number of other banking offices
intervening. The Stoneville branch of North State accounts for about 5 percent of county bank deposits
the smallest share of any of the eight banks in the
county.
Bank of North Carolina, National Association, does
however, operate one office in Alamance County, in
the community of Elon College (population 2,150).
This office was originally established by Carolina Bank
of Commerce and was acquired by Bank of North
Carolina, National Association, this year. It is only some
3 miles west, and virtually adjacent to the upper income suburban expansion of Burlington proper, where
North State operates two offices. Moreover, the only
banking office located in the area intervening between
Elon College and Burlington is North State's branch at
Glen Raven (population 2,848), just 2 miles slightly
northeast of Elon College. On the basis of information
supplied it would appear that North State draws some
deposit and loan accounts from Elon College and
vicinity. This proposed merger would, therefore,
eliminate direct competition presently existing between
the two institutions in Alamance County.
Seven commercial banks currently serve Alamance
County and five banks serve Burlington
including
in both instances four of the State's five largest banks.

Banking in Alamance County is highly concentrated.
The three largest banks operating in the county account for almost 75 percent of commercial bank
deposits in the county. North State is the fourth largest
bank in the county, with slightly more than 10 percent
of such deposits. The banking office in Elon College,
only recently acquired by Bank of North Carolina, National Association, has experienced significant growth
in total deposits since its establishment in 1970. The
deposits attributable to the Elon College office have
increased from about $182,000, at mid-year 1970, to
approximately $1.5 million, at present (about 1 percent
of the deposits held by banks in Alamance County)
with a substantial amount of that growth occurring within the last year.
This proposed merger would combine the State's
sixth largest bank, which already operates one branch
in the rapidly growing area of Alamance County immediately west of Burlington, with the county's fourth
largest bank, which also operates branches in that area,
including the nearest alternative banking office. This
proposed merger would thus eliminate direct competition presently existing between the two banks and the
potential for increased competition in the future which
can be expected as a result of the above average growth
immediately west of Burlington. Accordingly, we conclude that it would have an adverse effect on competition in Alamance County.

BAY STATE NATIONAL BANK, LAWRENCE, MASS., AND FIRST BANK AND TRUST COMPANY OF

HAVERHILL,

HAVERHILL, MASS., AND SECOND BAY STATE NATIONAL BANK, LAWRENCE, MASS.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Bay State National Bank, Lawrence, Mass. (1014), with
First Bank and Trust Company of Haverhill, Haverhill, Mass., with
and Second Bay State National Bank, Lawrence, Mass. (1014), which had
merged Dec. 29, 1972, under charter of the latter bank (1014) and title "Bay State
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 5, 1972, the Bay State National Bank,
Lawrence, Mass., the First Bank and Trust Company
of Haverhill, Haverhill, Mass., and the Second Bay
State National Bank (organizing), Lawrence, Mass.,
applied to the Comptroller of the Currency for per-




$71,853,399
5, 259, 610
240, 000
77, 120,209

To be
operated

8
1
0

9

mission to merge under the charter of the latter and
with the title of "Bay State National Bank."
Second Bay State National Bank, Lawrence, Mass.,
the charter bank, is being organized to provide a vehicle to transfer ownership of the two other banks to
the recently organized Massachusetts Bay Bancorp,

119

Inc. The charter bank will not be operating as a commercial bank prior to consummation of the merger.
Bay State National Bank, Lawrence, Mass., one of
the merging banks, was organized in 1865, and currently has assets of $63.9 million and IPC deposits of
$35.5 million. With seven branches in operation, that
bank competes with 10 offices of the Arlington Trust
Company, the eighth largest commercial bank in the
State, with $202.8 million in deposits; and with six
offices of the Merrimack Valley Bank, with $60.6 million in deposits, owned by Bay State Corporation, the
third largest banking organization in Massachusetts,
which has aggregate deposits of $1.4 billion.
First Bank and Trust Company of Haverhill, Haverhill, Mass., the other merging bank, is a single-office
Massachusetts trust company which was organized in
1963. With assets of $5.7 million and IPC deposits of
$4.2 million, it competes with five offices of the Merrimack Valley Bank; one office of the Arlington Trust
Company; and six offices of the Haverhill National
Bank, which has deposits of $31.2 million.
Though the service areas of the two merging banks
are contiguous, together comprising what is known as
the Lawrence-Haverhill Metropolitan Statistical Area,
competition between those two banks has been insignificant. Bay State National Bank presently draws only
1 percent of its deposits and 3 percent of its loans from
First Bank and Trust Company's service area; and
First Bank and Trust Company holds only 2 percent of
the total commercial bank loans and 1 percent of the
total deposits in the Lawrence-Haverhill Metropolitan
Statistical Area. On the other hand, competition provided by the other commercial banks in the area is
quite intense.
Though it has experienced an unsettled economy,
due in part to the decline of the shoe industry, Haverhill now appears to be forming a new economic base
which may well be the beginning of new growth.
Especially significant to the area is the recent development of two interstate highways affording easy access
to Boston. A well-regarded labor force, industriallyzoned vacant land, and proximity to major markets
all promise well for future growth.
The proposed merger will not affect Bay State National Bank's rank in total deposits in the resulting
service area, and will affect its rank in loans only marginally. The resulting bank will continue to receive
competition in the Lawrence-Haverhill Metropolitan
Statistical Area from the Merrimack Valley Bank
which is approximately equal in size; Haverhill Na-




tional Bank which is about half the size; and Arlington
Trust which will continue to enjoy more than half of
the total banking business in the area. Additional competition will continue to be provided by three savings
bank offices, two cooperative banks, and credit unions
in Haverhill.
The resulting bank will be able to offer the full range
of commercial banking services including computer,
credit card, and fiduciary services not now offered by
First Bank and Trust Company, managerial depth and
aggressiveness, and greater lending limits, thus replacing a relatively ineffective competitor with an aggressive, full-service institution willing to serve the
community.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The
application is, therefore, approved.
NOVEMBER 28,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed transaction is a step toward the creation of a bank holding company, to be known as
Massachusetts Bay Bancorp, Inc. The holding company will result from what amounts to the merger of
Bay State National Bank and First Bank and Trust
Company of Haverhill.
The closest offices of the merging banks are 6 miles
apart, with one competing banking office intervening.
The bulk of both of the participants' deposits and
loans are attributed to localized areas, but Bay State
National Bank draws a significant amount of business
from the city of Haverhill. For example, Bay State
National Bank holds $576,000 in deposits from Haverhill customers, and it does almost as much loan business
in Haverhill as does First Bank and Trust Company
of Haverhill (approximately $2.1 million). Consequently, the merger of Bay State National Bank and
First Bank and Trust Company of Haverhill would
eliminate some existing competition.
Bay State National Bank is the third largest of five
Massachusetts commercial banks with offices in the
Lawrence-Haverhill area. It holds about 16 percent
of the total deposits. The two largest banks serving the
area account for about 74 percent of total deposits;
the three largest about 90 percent. The proposed transaction would make the resulting bank about equal in
size to the second largest bank in the area, and the
share of deposits held by the three leading banking
organizations in the SMS A would increase to about 91

percent. An independent banking organization would
be eliminated, leaving the Lawrence-Haverhill area
with only four commercial banking organizations.
Because of the elimination of some existing compe-

tition between the participating banks and the incremental increase in concentration in banking resources
that would result from this transaction, we conclude
that it would have some adverse effect on competition.

/ / . Mergers consummated, pursuant to corporate reorganization
AMERICAN NATIONAL BANK & TRUST, MONTCLAIR, N.J., AND T H E SECOND AMERICAN NATIONAL BANK,
MONTCLAIR, N J .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

American National Bank & Trust, Montclair, N J . (4274), with
and The Second American National Bank, Montclair, N.J. (4274), which had. . . .
merged Jan. 1, 1972, under charter of the latter bank (4274) and title "American
National Bank & Trust of New Jersey." The merged bank at date of merger had . .

COMPTROLLER S DECISION

On August 24, 1971, American National Bank &
Trust, Montclair, N.J., and The Second American
National Bank (organizing), Montclair, N.J., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of "American National Bank & Trust of New
Jersey."
American National Bank & Trust, the merging bank,
is headquartered in Montclair. The bank, with total
resources of $406.7 million and IPC deposits of $308.8
million, was chartered in 1890.
The Second American National Bank, the charter
bank, is being organized to provide a vehicle to transfer ownership of the merging bank to the American
Holding Corporation of New Jersey. The charter bank
will not be operating as a commercial bank prior to
the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no




$416,088,784
125, 000

To be
operated

33
0

416,213,784

33

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct its banking business at the same locations
presently used by the merging bank, and with the
name of "American National Bank & Trust of New
Jersey."
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 12,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Second American National Bank (org.) would become
a subsidiary of American Holding Corporation of New
Jersey, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by American Holding Corporation of New Jersey, it would have
no effect on competition.

121

THIRD NATIONAL BANK IN NASHVILLE, NASHVILLE, TENN., AND FOURTH AND CHURCH STREET NATIONAL BANK,
NASHVILLE, TENN.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Third National Bank in Nashville, Nashville, Tenn. (13103), with
and Fourth and Church Street National Bank, Nashville, Tenn. (13103), which
had
merged Jan. 1, 1972, under charter of the latter bank (13103) and title "Third
National Bank in Nashville." The merged bank at date of merger had

COMPTROLLER S DECISION

On October 14, 1971, the Third National Bank in
Nashville, Nashville, Tenn., and the Fourth and
Church Street National Bank (organizing), Nashville,
Tenn., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter and
with the title of the former.
Third National Bank in Nashville, the merging
bank, is headquartered in Nashville, which has a
metropolitan area population of 541,108 people. The
bank, with IPC deposits of $380.1 million, was chartered originally in 1927.
Fourth and Church Street National Bank, the charter bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the Third
National Corporation. The charter bank will not be
operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

$677, 549, 295

19

247, 200

To be
operated

0

677, 796, 495

19

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 30,1971.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Fourth and Church Street National Bank (org.)
would become a subsidiary of Third National Corporation, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Third
National Corporation, it would have no effect on
competition.

MERCHANTS NATIONAL BANK & TRUST COMPANY OF INDIANAPOLIS, INDIANAPOLIS, IND., AND MERIDIAN NATIONAL
BANK, INDIANAPOLIS, IND.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Merchants National Bank & Trust Company of Indianapolis, Indianapolis, Ind.
(869), with
and Meridian National Bank, Indianapolis, Ind. (869), which had
merged Jan. 3, 1972, under charter of the latter bank (869) and title "Merchants
National Bank & Trust Company of Indianapolis." The merged bank at date of
merger had

122



$648, 968, 186
240, 000
648, 979, 886

To be
operated

36
0
36

COMPTROLLER S

DECISION

On September 13, 1971, the Merchants National
Bank & Trust Company of Indianapolis, Indianapolis,
Ind., and the Meridian National Bank (organizing),
Indianapolis, Ind., applied to the Comptroller of the
Currency for permission to merge under the charter of
the latter and with the title of the former.
Merchants National Bank & Trust Company, the
merging bank, is headquartered in Indianapolis, and
has 35 offices located throughout the city. The bank,
with total resources of $573.2 million and IPC deposits
of $371.7 million, was chartered in 1865.
Meridian National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership of
the merging bank to the Merchants National Corporation. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct its banking business at the same locations and
with the same name as presently used by the merging
bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 29,1971.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Meridian National Bank (org.) would become a subsidiary of Merchants National Corporation, a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such and without regard to the acquisition of the surviving bank by Merchants National Corporation, it would have no effect on competition.

T H E ALAMO NATIONAL BANK OF SAN ANTONIO, SAN ANTONIO, TEX., AND ALAMO BANK, NATIONAL ASSOCIATION,
SAN ANTONIO, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Alamo National Bank of San Antonio, San Antonio, Tex. (4525), with
and Alamo Bank, National Association, San Antonio, Tex. (4525), which had.. . .
merged Jan. 5, 1972, under charter of the latter bank (4525) and title "The Alamo
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On April 15, 1971, the Alamo Bank, National Association (organizing), San Antonio, Tex., applied to
the Office of the Comptroller of the Currency for permission to merge with The Alamo National Bank of
San Antonio, San Antonio, Tex., under the charter of
the former and with the title of The Alamo National
Bank.
The Alamo National Bank of San Antonio, the merging bank, is located in San Antonio, Tex., a city of
795,495. The bank was chartered in 1801, and presently has IPC deposits of $123 million.
The Alamo Bank, National Association, owned by
Alamo Bancshares, Inc., is being organized as a means
to transfer ownership of The Alamo National Bank
of San Antonio to the holding company. Prior to the
merger, the organizing bank will not be operational.




$227, 620, 412
236, 435

To be
operated

1
0

224, 190, 129

1

With the exception of the directors' qualifying shares,
all of the shares of the resulting bank will be owned by
Alamo Bancshares, Inc.
Because The Alamo National Bank of San Antonio
is the only operating bank in the proposed transaction,
there can be no adverse effect on competition resulting
from consummation of the proposed merger. The resulting bank will continue to conduct the merging
bank's business at the present location under the title of
"The Alamo National Bank." The application is,
therefore, approved.
AUGUST 31,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Alamo Bank, N.A. (org.) would become a subsidiary
of Alamo Bancshares, Inc., a bank holding company.
The instant merger, however, would merely combine

an existing bank with a non-operating institution; as
such and without regard to the acquisition of the sur*

viving bank by Alamo Bancshares, Inc., it would have
no effect on competition.
#

#

THE UNION NATIONAL BANK OF TROY, TROY, N.Y.,

AND UNION NATIONAL BANK, ALBANY,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Union National Bank of Troy, Troy, N.Y. (963) with
and Union National Bank, Albany, N.Y. (963), which had
merged Jan. 18, 1972, under charter and title of the latter bank (963). The merged
bank at date of merger had

COMPTROLLER'S DECISION

On July 13, 1971, Union National Bank (organizing) , Albany, N.Y., and The Union National Bank of
Troy, Troy, 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 Union National Bank of Troy, Troy, N.Y., the
smaller of the two banks headquartered in Troy, is the
ninth largest of the 36 banks located in New York's
Fourth Banking District. The resulting bank will become the fourth largest of the six banks headquartered
in Albany.
Union National Bank, Albany, N.Y., the charter
bank, is being organized to provide a vehicle to transfer ownership of the merging bank to Charter New
York Corporation, New York, N.Y. The charter bank
will not be acting as a commercial bank prior to
the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the merger. With the exception of the new
head office in Albany, N.Y., the resulting bank will

TAPPAN ZEE NATIONAL BANK, NYACK, N.Y.,

$80, 279, 693
258, 002

To be
operated
1
0

80, 537, 695

conduct the same banking business at the same locations as are presently used by the merging bank. None
of Charter New York Corporation's other subsidiaries
compete to any significant degree with the merging
bank in the Troy area or with the Albany banks. The
nearest branch of a subsidiary of the holding company
is 40 miles from the merging bank, and 35 miles from
Albany, so that the geographical barrier forecloses an
anticompetitive effect of the proposed merger.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. Therefore,
the application is approved.
DECEMBER 7,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Union National Bank (org.) would become a subsidiary of Charter New York Corporation, a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by Charter New York Corporation,
it would have no effect on competition.

AND THE BANK OF TAPPAN ZEE, N.A.,

NYACK,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

Tappan Zee National Bank, Nyack, N.Y. (14734), with
and The Bank of Tappan Zee, N.A., Nyack, N.Y. (14734), which had
merged Jan. 31, 1972, under charter of the latter bank (14734) and title "Tappan
Zee National Bank." The merged bank at date of merger had




$57, 952, 977
132,000
58, 084, 977

7
0

7

COMPTROLLER S DECISION

On September 21, 1971, the Tappan Zee National
Bank, Nyack, N.Y., and The Bank of Tappen Zee,
N.A. (organizing), Nyack, N.Y., applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of the former.
The Tappan Zee National Bank, the merging bank,
is headquartered in Nyack, and has seven offices located
throughout Rockland County. The bank, with total
resources of $49.8 million and IPC deposits of $33.7
million, was chartered in 1955.
The Bank of Tappan Zee, the charter bank, is being
organized to provide a vehicle to transfer ownership of the merging bank to the Chemical New York
Corporation. The charter bank will not be operating as
a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct its banking business at the same locations and
with the same name as presently used by the merging
bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
DECEMBER 27,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
The Bank of Tappan Zee, N.A. (org.) would become a
subsidiary of Chemical New York Corporation, a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Chemical New York Corporation, it would have no effect on competition.

T H E AMERICAN NATIONAL BANK IN PORTAGE, PORTAGE, MICH., AND THE PORTAGE BRANCH OF T H E AMERICAN
NATIONAL BANK AND TRUST COMPANY OF MICHIGAN, KALAMAZOO, MICH.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Portage Branch of The American National Bank and Trust Company of Michigan, Kalamazoo, Mich. (13820), with
was purchased Jan. 31, 1972, by The American National Bank in Portage, Portage,
Mich. (15938), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On October 19, 1971, The American National Bank
in Portage (organizing), Portage, Mich., applied to the
Office of the Comptroller of the Currency for permission to purchase some of the assets and assume some of
the liabilities of the Portage branch of The American
National Bank and Trust Company of Michigan, Kalamazoo, Mich., under the charter and with the title
of the former.
The American National Bank and Trust Company
of Michigan, the selling bank, is located in Kalamazoo,
Mich., a city of 85,555. The bank was chartered in
1933, and presently has IPC deposits of $149.2 million.
At the time of the application, it had 25 active branches.
On August 19, 1971, the Board of Governors of the
Federal Reserve System approved the acquisition of




To be
operated

$3,523,152
403, 000
3, 926, 152

100 percent of the voting stock of the bank by American Financial Corporation of Michigan, a registered
bank holding company.
The American National Bank in Portage, which is
newly organized and will be purchased by the American Financial Corporation, has been set up for the
purpose of acquiring the demand checking accounts
and savings book deposit liabilities, the cash assets, and
the building lease of the selling bank's Portage branch.
Prior to the acquisition of the Portage branch, The
American National Bank in Portage will not be operational.
Acquisition of the Portage branch by The American
National Bank in Portage has two competitive ramifications. First, it ensures continued bank services to
the inhabitants of Portage which services would other-

wise have been lost since Michigan branch law will
not permit The American National Bank and Trust.
Company of Michigan to maintain the branch following its reorganization as a subsidiary of the holding
company. Secondly, approval of the application introduces a bank which will be headquartered in Portage, thereby permitting it, under Michigan bank law,
to branch throughout the city of Portage. Noting that
the First National Bank and Trust Company of Michigan and the Industrial State Bank of Kalamazoo each
operate two branches in Portage, approval of the application is in the interest of competition.
DECEMBER 29,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

According to the application, American National
Bank and Trust Company of Michigan is required to
divest its Portage branch as part of its reorganization
as a bank holding company (American Financial Corporation of Michigan). This branch is being transferred to a new bank, which is not presently an operating institution. The application further indicates
the likelihood that the new bank will ultimately become a subsidiary of American Financial Corporation.
Since the proposed transaction is essentially an interim step in a corporate reorganization, it would appear to present no adverse competitive effects.

T H E AMERICAN NATIONAL BANK AND TRUST COMPANY OF MICHIGAN, KALAMAZOO, MICH., AND T H E AMERICAN
BANK OF MICHIGAN, NATIONAL ASSOCIATION, KALAMAZOO, MICH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The American National Bank and Trust Company of Michigan, Kalamazoo, Mich.
(13820), with
and The American Bank of Michigan, National Association, Kalamazoo, Mich.
(13820), which had
merged Jan. 31, 1972, under charter of the latter bank (13820) and title "The
American National Bank and Trust Company of Michigan." The merged bank at
at date of merger had

COMPTROLLER S DECISION

On October 27, 1971, The American Bank of Michigan, National Association (organizing), Kalamazoo,
Mich., applied to the Office of the Comptroller of the
Currency for permission to merge with The American
National Bank and Trust Company, Kalamazoo,
Mich., under the charter of the former and with the
title of the latter.
The American National Bank and Trust Company,
the merging bank, is located in Kalamazoo, Mich., a
city of 85,555. The bank was chartered in 1933, and
presently has IPC deposits of $149.2 million. At the
time of the application it had 16 branches.
The American Bank of Michigan, National Association, owned by The American Bancshares of Michigan*, is being organized as a means to transfer ownership of the merging bank to the holding company.
Prior to the merger, the organizing bank will not be
*Now American Financial Corporation of Michigan.




To be
operated

$195, 205, 834

17

250, 000

0

195,213,034

17

operational. With the exception of the directors' qualifying shares, all of the shares of the resulting bank will
be owned by the holding company.
Because the merging bank is the only operating bank
in the proposed transaction, there can be no adverse
effect on competition resulting from consummation
of the proposed merger. The resulting bank will continue to conduct the merging bank's business at the
present locations under the title of The American National Bank and Trust Company of Michigan.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
DECEMBER 29,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
American Bank of Michigan, N.A. (org.) would become a subsidiary of American Bancshares of Michigan, Inc., a bank holding company. The instant merger,
however, would merely combine and existing bank with

a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Ameri-

can Bancshares of Michigan, Inc., it would have no
effect on competition.

T H E FIRST NATIONAL BANK OF BIRMINGHAM, BIRMINGHAM, ALA., AND JEFFERSON COUNTY NATIONAL BANK,
BIRMINGHAM, ALA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Birmingham, Birmingham, Ala. (3185), with
and Jefferson County National Bank, Birmingham, Ala. (3185), which had
merged Feb. 3, 1972, under charter of the latter bank (3185) and title "The First
National Bank of Birmingham." The merged bank at date of merger had

COMPTROLLER S DECISION

On September 8, 1971, The First National Bank
of Birmingham, Birmingham, Ala., and the Jefferson
County National Bank (organizing), Birmingham,
Ala., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter
and with the title of the former.
The First National Bank of Birmingham, the merging bank, is headquartered in Birmingham and has a
number of branches. The bank, with total resources
of $732.2 million and IPC deposits of $496.2 million,
was chartered originally in 1873.
Jefferson County National Bank, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the Alabama Bancorporation. The charter bank will not be operating
as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be

$833, 115,240
240, 000

To be
operated

21
0

833, 355, 240

21

no adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JANUARY 3,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Jefferson County National Bank (org.) would
become a subsidiary of Alabama Bancorporation, a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such and without regard to
the acquisition of the surviving bank by Alabama Bancorporation, it would have no effect on competition.

HUTCHINSON NATIONAL BANK AND TRUST COMPANY, HUTCHINSON, KANS., AND POLARIS NATIONAL BANK,
HUTCHINSON, KANS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Hutchinson National Bank and Trust Company, Hutchinson, Kans. (10765), with,
and Polaris National Bank, Hutchinson, Kans. (10765), which had
merged Feb. 15, 1972, under charter of the latter bank (10765) and title "Hutchinson National Bank and Trust Company." The merged bank at date of merger had.




$88,658,617
130,000
88,788,617

To be
operated

1
0
1

127

COMPTROLLER S DECISION

On October 8, 1971, the Hutchinson National Bank
and Trust Company, Hutchinson, Kans., and the
Polaris National Bank (organizing), Hutchinson,
Kans., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter
and with the title of the former.
Hutchinson National Bank and Trust Company, the
merging bank, is headquartered in Hutchinson, and
is a unit bank. The bank, with total resources of $60.3
million and IPC deposits of $37.2 million, was chartered originally in 1915.
Polaris National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the United Financial Corporation. The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
location and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JANUARY 14,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Polaris National Bank (org.) would become a subsidiary of United Financial Corporation, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by United Financial Corporation, it would have no effect on competition.

EASTERN NATIONAL BANK OF LONG ISLAND, SMITHTOWN, N.Y.,

AND EAST BANK, N.A.,

SMITHTOWN,

N.Y.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Eastern National Bank of Long Island, Smithtown, N.Y. (14763), with
and East Bank, N.A., Smithtown, N.Y. (14763), which had
merged Mar. 3, 1972, under charter of the latter bank (14763) and title "Eastern
National Bank of Long Island." The merged bank at date of merger had

COMPTROLLER S DECISION

In October 1971, the Eastern National Bank of Long
Island, Smithtown, N.Y., and the East Bank, N.A.
(organizing), Smithtown, N.Y., applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of the
former.
Eastern National Bank of Long Island, the merging
bank, is headquartered in Smithtown, a city of 85,000
people. The bank, with IPC deposits of $38.3 million,
was chartered in 1956.
East Bank, N.A., the charter bank, is being organized to provide a vehicle to transfer ownership of the
merging bank to the Chemical New York Corporation.
The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

128



$78, 655, 878
129, 500

To be
operated
6
0

78, 987, 962

6

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JANUARY 31,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
East Bank, N.A., would become a subsidiary of Chemical New York Corporation, a bank holding company.
The instant merger, however, would merely combine
an existing bank with a non-operating institution; as
such, and without regard to the acquisition of the surviving bank by Chemical New York Corporation, it
would have no effect on competition.

T H E FIRST NATIONAL BANK OF GRAND ISLAND, GRAND ISLAND, NEBR., AND FIRST NATIONAL BANK IN GRAND
ISLAND, GRAND ISLAND, NEBR.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

$56, 143, 209
109, 884

The First National Bank of Grand Island, Grand Island, Nebr. (2779), with
and First National Bank in Grand Island, Grand Island, Nebr. (2779), which had.
merged Mar. 31, 1972, under charter of the latter bank (2779) and title "The
First National Bank of Grand Island." The merged bank at date of merger had. .

COMPTROLLER'S DECISION

On December 30, 1971, The First National Bank of
Grand Island, Grand Island, Nebr., and the First National Bank in Grand Island (organizing), Grand Island, Nebr., applied to the Comptroller of the Currency
for permission to merge under the charter of the latter
and with the title of the former.
The First National Bank of Grand Island, the merging bank, is headquartered in Grand Island, Nebr., and
has one additional office located in Hall County. The
bank has total resources of $50.7 million and IPC deposits of $40.3.
First National Bank in Grand Island, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to Bankshares of Nebraska, Inc. The charter bank will not be operating as
a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

To be
operated

2
0

2

56, 256, 694

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the application is, therefore, approved.
FEBRUARY 23,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank in Grand Island (org.) would become a subsidiary of Bankshares of Nebraska, Inc., a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Bankshares
of Nebraska, Inc., it would have no effect on competition.

NATIONAL BANK OF COMMERCE OF SAN ANTONIO, SAN ANTONIO, TEX., AND BANK OF COMMERCE, NATIONAL
ASSOCIATION, SAN ANTONIO, TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

National Bank of Commerce of San Antonio, San Antonio, Tex. (6956), w i t h . . . .
and Bank of Commerce, National Association, San Antonio, Tex. (6956), which
had
merged Apr. 3, 1972, under charter of the latter bank (6956) and title "National
Bank of Commerce of San Antonio." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 13, 1971, the National Bank of Commerce of San Antonio, San Antonio, Tex., and the
Bank of Commerce, National Association (organizing),




To be
operated

$355,176,244

1

250, 000

0

355,176,244

1

San Antonio, Tex., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
National Bank of Commerce of San Antonio, the

129

merging bank, is headquartered in San Antonio and is
a unit bank. The bank, with total resources of $324
million and IPG deposits of $214.8 million, was chartered in 1903.
Bank of Commerce, National Association, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to the National Baneshares Corporation of Texas. The charter bank will not
be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct its banking business at the same location and
with the same name as presently used by the merging
bank.

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
FEBRUARY 14,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Bank of Commerce, National Association (org.) would
become a subsidiary of National Bancshares Corporation of Texas, a bank holding company. The instant
merger, however, would merely combine an existing
bank with a non-operating institution; as such, and
without regard to the acquisition of the surviving bank
by National Bancshares Corporation of Texas, it would
have no effect on competition.

T H E STATE NATIONAL BANK OF E L PASO, E L PASO, TEX., AND STATE BANK, NATIONAL ASSOCIATION, E L PASO
TEX.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The State National Bank of El Paso, El Paso, Tex. (2521), with
and State Bank, National Association, El Paso, Tex. (2521), which had
merged Apr. 3, 1972, under charter of the latter bank (2521) and tide "The State
National Bank of El Paso." The merged bank at date of merger had

COMPTROLLER S

DECISION

On August 25, 1971, The State National Bank of
El Paso, El Paso, Tex., and the State Bank, National
Association (organizing), El Paso, Tex., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
The State National Bank of El Paso, the merging
bank, is headquartered in El Paso, Tex., a city of 322,000 people. The bank, with IPC deposits of $142 million, was chartered originally in 1881.
State Bank, National Association, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the State National
Bancshares, Inc. The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

130



$259, 004, 881
250, 000

To be
operated
1
0

259, 012, 081

1

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
location and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 3,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which State Bank, N. A. (org.) would become a subsidiary of State National Bancshares, Inc., a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such and without regard to the acquisition of the surviving bank by State National Bancshares, Inc., it would have no effect on competition.

ZIONS FIRST NATIONAL BANK, SALT LAKE CITY, UTAH, AND ZIONS BANK, N.A.,

SALT LAKE CITY, UTAH

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Zions First National Bank, Salt Lake City, Utah (4341), with
and Zions Bank, N.A., Salt Lake City, Utah (4341), which had
merged Apr. 7, 1972, under charter of the latter bank (4341) and title "Zions
First National Bank." The merged bank at date of merger had

$366, 839, 367
240, 952

To be
operated

26
0

366, 839, 367

26

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used
by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.

COMPTROLLER S DECISION

On January 4, 1972, the Zions First National Bank,
Salt Lake City, Utah, and the Zions Bank, N.A. (organizing) , Salt Lake City, Utah, applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of the
former.
Zions First National Bank, the merging bank, is
headquartered in Salt Lake City, a city of 190,000
people. The bank, with IPC deposits of $101.0 million,
was chartered originally in 1890.
Zions Bank, N.A., the charter bank, is being organized to provide a vehicle to transfer complete ownership of the merging bank to the Zions Utah
Bancorporation. The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

MARCH 18,

1972.

SUMMARY OF REPORT BY ATTORNEY

GENERAL

The proposed merger is part of a plan through
which Zions Bank, N.A. would become a subsidiary
of Zions Utah Bancorporation, a bank holding company. The instant merger, however, would merely combine an existing bank with a non-operating institution;
as such, and without regard to the acquisition of the
surviving bank by Zions Utah Bancorporation, it
would have no effect on competition.

T H E SILVER CREEK NATIONAL BANK, SILVER CREEK, N.Y.,
SILVER CREEK,

AND CITIBANK (WESTERN), NATIONAL ASSOCIATION,
N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Silver Creek National Bank, Silver Creek, N.Y. (10258), with
and Citibank (Western), National Association, Silver Creek, N.Y. (10258), which
had
merged Apr. 10, 1972, under charter of the latter bank (10258) and title "Citibank
(Western), National Association." The merged bank at date of merger had

COMPTROLLER'S

DECISION

On November 16, 1971, the Citibank (Western),
National Association (organizing), Silver Creek, N.Y.,
applied to the Office of the Comptroller of the Currency for permission to merge with The Silver Creek




To be
operated

$13,458,243

1

60,000

0

13,518,243

1

National Bank, Silver Creek, N.Y., under the charter
and with the title of the former.
The Silver Creek National Bank, the merging bank,
is located in Silver Creek, N.Y., a city of 3,182. The
bank was chartered in 1912, and presently has IPC

131

deposits of $10.1 million. At the time of the application, it had no active branches.
The Citibank (Western), N.A., owned by First National City Corporation, is being organized as a means
to transfer ownership of the merging bank to the holding company. Prior to the merger, the organizing bank
will not be operational. With the exception of the directors' qualifying shares, all of the shares of the resulting bank will be owned by First National City
Corporation.
Because The Silver Creek National Bank is the only
operating bank in the proposed transaction, there can
be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting
bank will continue to conduct the merging bank's busi-

ness at the present locations under title of Citibank
(Western), National Association. The application is,
therefore, approved.
MARCH 9,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Citibank (Western), N.A. (org.) would become
a subsidiary of First National City Corporation, a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by First National City Corporation, it would have no effect on competition.

NEW JERSEY BANK (NATIONAL ASSOCIATION), CLIFTON, N J., AND SECOND NEW JERSEY BANK (NATIONAL ASSOCIATION), CLIFTON, N.J.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

New Jersey Bank (National Association), Clifton, N.J. (15709), with
and Second New Jersey Bank (National Association), Clifton, N.J. (15709), which
had
merged Apr. 13, 1972, under charter of the latter bank (15709) and title "New
Jersey Bank (National Association)." The merged bank at date of merger had....

COMPTROLLER S DECISION

On December 21, 1971, the New Jersey Bank (National Association), Clifton, N.J., and the Second New
Jersey Bank (National Association) (organizing),
Clifton, N.J., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
New Jersey Bank (National Association), the merging bank, is headquartered in Clifton, and has 28
offices located in northern New Jersey. The bank has
total resources of $607.9 million and IPC deposits of
$443.6 million.
Second New Jersey Bank (National Association),
the charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to the Greater Jersey Bancorporation. The charter
bank will not be operating as a commercial bank prior
to the merger.
Because the merging bank is the only operating bank

132



$661, 583, 152

29

244,200

To be
operated

0

661, 593, 362

29

involved in the proposed transaction, there can be no
adverse effect on competition resulting from the consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used
by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
FEBRUARY 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Second New Jersey Bank (N.A.) would become
a subsidiary of Greater Jersey Bancorp., a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Greater Jersey Bancorp.,
it would have no effect on competition.

T H E CITY NATIONAL BANK OF MILLVILLE, MILLVILLE, N.J.,

AND T H E SECOND NATIONAL BANK OF MILLVILLE,

MILLVILLE, N J .
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The City National Bank of Millville, Millville, NJ. (14673), with
and The Second City National Bank of Millville, Millville, NJ. (14673), which
had
merged Apr. 28, 1972, under charter of the latter bank (14673) and title "The
City National Bank of Millville." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 20, 1971, The City National Bank of
Millville, Millville, N. J., and The Second City National
Bank of Millville (organizing), Millville, N.J., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
of the former.
The City National Bank of Millville, the merging
bank, is located in Cumberland County, which is in
the Third Banking District of New Jersey. The bank,
with total deposits of $12.9 million, is the 45 th in size
of the 63 commercial banks in the Third Banking District. The merging bank has one branch, also located
in Millville, and serves an estimated population of
22,000 people.
Competitors of The City National Bank of Millville
include the Bank of New Jersey, Camden, with deposits
of $348 million; the South Jersey National Bank, Camden, with deposits of $337 million, which is the proposed lead bank of the $507 million Heritage Bancorporation; and the Peoples National Bank of New Jersey, Haddon Township, with deposits of $192 million.
The Second City National Bank of Millville, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank to
United Jersey Banks, a registered bank holding company. The charter bank will not be operating as a commercial bank prior to this merger.
United Jersey Banks, Hackensack, N.J., the bank
holding company which will acquire the resulting
bank, is the second largest banking organization in New
Jersey. United Jersey Banks had deposits of $775 million as of December 1970. The holding company has a
banking network of six subsidiary banks which operate in all three of the banking districts in New Jersey.
Those subsidiaries include Peoples Trust of New Jersey,




$16,475,140

2

123, 600

To be
operated

0

16,475, 140

2

Hackensack, with deposits of $726 million; First National Bank of Princeton, Princeton, with deposits of
$81 million; Third National Bank of New Jersey, Camden, with deposits of $27 million; and Cumberland
National Bank of Bridgeton, Bridgeton, with deposits
of $29 million. Applications have also been approved
for the acquisition of three additional banks, one each
in Carlstadt, Montvale, and Ridgewood.
At present, although two subsidiaries of the applicant are located in the Third Banking District, there
is no direct competition between them and the merging
bank. The main office of the bank in Bridgeton, located
11 miles from Millville, is the nearest office of a subsidiary of United Jersey Banks to any office of the merging bank. The City National Bank of Millville has, in
the past, restricted itself to a relatively small trade area.
That local orientation precludes any competition
between the merging bank and any subsidiary of
United Jersey Banks. The resulting bank will conduct
the same banking business at the same locations and
with the same name as presently used by the merging
bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Second City National Bank of Millville would
become a subsidiary of United Jersey Banks, a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by United Jersey Banks, it
would have no effect on competition.

CLERMONT NATIONAL BANK, MILFORD, OHIO, AND T H E

F.B.G. NATIONAL BANK OF MILFORD, MILFORD, OHIO
Banking offices

Name of bank and type of transaction

Total assets
In
operation

Clermont National Bank, Milford, Ohio (3234), with
and The F.B.G. National Bank of Milford, Milford, Ohio (3234), which had
merged May 1, 1972, under charter of the latter bank (3234) and title "Clermont
National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 1, 1972, the Clermont National Bank,
Milford, Ohio, and The F.B.G. National Bank of Milford (organizing), Milford, Ohio, applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of the
former.
The Clermont National Bank, the merging bank, is
headquartered in Milford and has nine branch offices
located throughout Clermont County. The bank, originally chartered in 1884, has total assets of $52.5 million and IPC deposits of $42.9 million.
The F.B.G. National Bank of Milford, the charter
bank, is being organized to provide a vehicle to transfer ownership of the merging bank to First Bane Group
of Ohio, Inc., a registered bank holding company.
The charter bank will not be operating as a commercial
bank prior to the merger.
First Bane Group, the bank holding company which
will acquire the resulting bank as a subsidiary upon
consummation of the proposed merger, is the fifth
largest of Ohio's nine multi-bank holding companies.
First Bane Group controls nine subsidiary banks with
aggregate deposits of $709 million. The largest subsidiary of First Bane Group is the City National Bank and
Trust Company of Columbus, with deposits of $404
million. Each of the nine subsidiary banks of First Bane

$50,321,683
120, 000

To be
operated

9
0

50, 441, 683

9

Group operates in a different county from that of the
other subsidiaries. None of those trade areas overlap the
service area of the Clermont National Bank. One or
more counties separate the trade area of the Clermont
National Bank from the trade area and respective
county in which each subsidiary of First Bane Group
operates all of its banking offices. While the Barnitz
Bank, Middletown, Ohio, is the closest subsidiary of
First Bane Group to the merging bank, its nearest office
is located 19 miles from the merging bank. The next
closest subsidiary is the Security Central National Bank
of Portsmouth which is situated 74 miles from the nearest office of the Clermont National Bank.
Consummation of the proposed merger will result in
no adverse competitive effects. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by
the merging bank. The great distances which separate
the existing subsidiaries of First Bane Group from the
existing offices of the merging bank insures that no competition exists now; therefore, none will be eliminated
by the proposed merger.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 29,

1972.

NOTE.—No Attorney General's report received.

MADISON NATIONAL BANK, MADISON, N.J., AND N E W MADISON NATIONAL BANK (MADISON, N.J.), MADISON,

N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Madison National Bank, Madison, N.J. (15360), with
and New Madison National Bank (Madison, N.J.), Madison, N.J. (15360), which
had
merged May 1, 1972, under charter of the latter bank (15360) and title "Madison
National Bank." The merged bank at date of merger had




To be
operated

$10, 682, 293

3

125, 599

0

10, 829, 784

3

COMPTROLLER'S DECISION

On January 19, 1972, the Madison National Bank,
Madison, N.J., and the New Madison National Bank
(Madison, N.J.) (organizing), Madison, N.J., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
of the former.
Madison National Bank, the merging bank, is headquartered in Madison, N.J., a city with a population of
17,000. This bank, with IPC deposits of $8.7 million,
was chartered in 1964.
New Madison National Bank, the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to Midlantic Banks, Inc. The
charter bank will not be operating as a commercial
bank prior to the merger. Midlantic currently owns
four other banks. The lead bank, National Newark and
Essex Bank, Newark, N.J., with total assets of $764
million, is the third largest commercial bank in the
State. Midlantic's other subsidiary banks are: The
Sussex and Merchants National Bank, Newton, N.J.;
Raritan Valley National Bank, Edison, N.J.; and Elmer
Bank and Trust Company, Elmer, N.J. The bank subsidiaries of Midlantic have total assts of $908 million.
Madison National offers a limited range of banking
services based primarily upon savings and time deposits
and a loan portfolio heavily concentrated in mortgage
loans and in bankers' acceptances. Madison National
has exhibited a relatively slow rate of growth which is
attributable to its limited scope of services and to the
aggressive and larger financial institutions with which
it competes. Madison National's limited resources have
prevented it from being a major bidder for obligations
of local municipalities and political subdivisions. Madison National has not been a significant source of commercial and industrial loans because its lending limit is
relatively low and the types of loans which it can offer
are limited. The bank does not offer accounts receivable loans, inventory loans, or revolving credit loans.
It only infrequently makes small commercial construction loans. Those types of loans are available from
larger banks in Madison National's market area. During the period from 1968 through 1970, the consumer
loan portion of the bank's loan portfolio dropped from
18 percent to 6 percent of its total portfolio. Madison




National does not own or lease data processing equipment and, consequently, does not offer payroll accounting, record keeping, billing, account reconciliation, or
other services based on the use of such equipment.
Affiliation with Midlantic will provide financial, technological, and managerial resources necessary to improve Madison National's services in the above lines of
service.
There will be no adverse effects on competition resulting from consummation of the proposed merger.
Acquisition by Midlantic of the merging bank, which
is the only operating bank involved in the proposed
transaction, would, when added to Midlantic's other
bank subsidiaries, increase Midlantic's share of banking
business in New Jersey only minimally. Affiliation of
Madison National with Midlantic would increase the
latter's share of total deposits in the State from 4.9
percent to 5.0 percent. The State's three other registered bank holding companies hold 6.7 percent, 5.1
percent, and 5.1 percent of the State's deposits. Acquisition of Madison National would increase Midlantic's
percentage of deposits held by all its commercial banks
in the First Banking District, in which Madison is
located, from 8.7 percent to 8.8 percent. The State's
other registered bank holding companies hold 11.4 percent, 8.2 percent, and 8.0 percent of First District
deposits. Moreover, consummation of the proposed
merger would not eliminate significant competition
between Midlantic subsidiaries and the merging bank
as there is little present competition between them.
None of Midlantic's subsidiary banks has offices in
Morris County, where Madison National is located.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 30,1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
New Madison National Bank (org.) would become a
subsidiary of Midlantic Banks, Inc., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by Midlantic Banks, Inc., it would
have no effect on competition.

THE BANK OF CALIFORNIA, NATIONAL ASSOCIATION, SAN FRANCISCO, CALIF., AND B.C.

NATIONAL BANK, SAN

FRANCISCO, CALIF.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Bank of California, National Association, San Francisco, Calif. (9655), with.. $2, 183, 850, 834
253, 054
and B. C. National Bank, San Francisco, Calif. (9655), which had
merged May 1, 1972, under charter of the latter bank (9655) and title "The
Bank of California, National Association." The merged bank at date of merger
2, 183, 859, 712
had

COMPTROLLER S DECISION

On January 20, 1972, The Bank of California, National Association, San Francisco, Calif., and the B. C.
National Bank (organizing), San Francisco, Calif.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and with
the title of the former.
The Bank of California, National Association, the
merging bank, is headquartered in San Francisco,
Calif., a city of 750,000 people. The bank, with IPC
deposits of $1.3 billion, was chartered originally in 1864.
B. C. National Bank, the charter bank, is being organized to provide a vehicle to transfer ownership of the
merging bank to the BanCal Tri-State Corporation.
The charter bank will not be operating as a commercial bank prior to the merger.
Since the merging bank is the only operating bank
involved in the proposed transaction, there can be no

To be
operated

78
0

78

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MARCH 16,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which B. C. National Bank (org.) would become a
subsidiary of BanCal Tri-State Corp., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition
of the surviving bank by BanCal Tri-State Corp., it
would have no effect on competition.

LONG POINT NATIONAL BANK OF HOUSTON, HOUSTON, TEX., AND LONG BANK, NATIONAL ASSOCIATION, HOUSTON,
TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Long Point National Bank of Houston, Houston, Tex. (14777), with
and Long Bank, National Association, Houston, Tex. (14777), which had
merged May 18, 1972, under charter of the latter bank (14777) and title "Long
Point National Bank of Houston." The merged bank at date of merger had

COMPTROLLER S DECISION

On September 22, 1971, the Long Point National
Bank of Houston, Houston, Tex., and Long Bank,
National Association (organizing), Houston, Tex., applied to the Comptroller of the Currency for permis-

136



$34,716,283
255, 756
34, 972,039

To be
operated

1
0

1

sion to merge under the charter of the latter and with
the title of the former.
Long Point National Bank of Houston, the merging
Bank, is headquartered in Houston, Tex., and operates one banking office in that city. The bank, with

total resources of $32.9 million and IPC deposits of
$27.6 million, was originally chartered in 1956.
Long Bank, National Association, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to Southwest Baneshares, Inc. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there can
be no adverse effect on competition resulting from the
consummation of the proposed merger. The resulting
bank will conduct the same banking business at the
same location and with the same name as presently
used by the merging bank.

STATE BANK OF HONEOYE FALLS, HONEOYE FALLS, N.Y.,

Applying the statutory criteria, it is concluded that
proposed merger is in the public interest and the application is, therefore, approved.
APRIL 17,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Long Bank, N.A, (org.) would become a subsidiary of Southwest Bancshares, Inc., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Southwest Bancshares,
Inc., it would have no effect on competition.

AND CITIBANK (MED-WESTERN), NATIONAL ASSOCIA-

TION, HONEOYE FALLS,

N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

State Bank of Honeoye Falls, Honeoye Falls, N.Y., with
and Citibank (Mid -Western), National Association, Honeoye Falls, N.Y. (15976)
which had.
merged June 8, 1972, under charter and title of the latter bank (15976). The
merered bank at date of mercer had

COMPTROLLER'S DECISION

On December 27, 1971, the State Bank of Honeoye
Falls, Honeoye Falls, N.Y., and the Citibank (MidWestern) , National Association (organizing), Honeoye
Falls, N.Y., applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter.
The State Bank of Honeoye Falls, the merging bank,
is headquartered in Honeoye Falls, N.Y. This bank has
total resources of $9.3 million and IPC deposits of
$6.3 million.
Citibank (Mid-Western), National Association, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to the First National City Corporation, a registered
bank holding company. As the charter bank, it will
not be operating as a commercial bank prior to the
merger. The resulting bank will conduct the same banking business at the same locations as presently used




$10, 561, 390

2

60,000

To be
operated

0

10,621,390

2

by the merging bank, with the new name of Citibank
(Mid-Western), National Association.
First National City Corporation, New York, N.Y.,
the bank holding company which will acquire the resulting bank, is the second largest of the 13 registered
multi-bank holding companies in New York State. The
holding company has domestic resources of $16.5 billion. First National City Corporation presently controls two banks: First National City Bank, New York,
N.Y., the lead bank in its banking structure; and
Citibank (Suffolk), National Association, Bay Shore,
N.Y., which was formed de novo and opened in November 1971.
The closest branch of any subsidiary of First National City Corporation is 330 miles away from the
State Bank of Honeoye Falls. Therefore, competition
with the merging banks and the First National City
Corporation is insignificant.
Consummation of the proposed merger will serve
to increase competition in the Eighth Banking District.

137

Affiliation of the proposed subsidiary with the First
National City Bank will allow the resulting unit in
Honeoye Falls to provide expanded and improved
services. This will place the resulting subsidiary in a
better position with which to compete with the large
banks in the Eighth Banking District.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The application, therefore, is approved.
MAY 4, 1972.
*

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Citibank (Mid-Western), National Association
(org.), would become a subsidiary of First National
City Corporation, a bank holding company. The instant merger, however, would merely combine an existing bank with a non-operating institution; as such, and
without regard to the acquisition of the surviving bank
by First National City Corporation, it would have no
effect on competition.
*

*

CONTINENTAL NATIONAL BANK OF FORT WORTH, FORT WORTH, TEX., AND CONTINENTAL BANK, NATIONAL
ASSOCIATION, FORT WORTH, TEX.
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

Continental National Bank of Fort Worth, Fort Worth, Tex. (11997), with
and Continental Bank, National Association, Fort Worth, Tex. (11997), which
had
merged June 26, 1972, under charter of the latter bank (11997) and title "Continental National Bank of Fort Worth." The merged bank at date of merger had. ..

COMPTROLLER S DECISION

On September 23, 1971, the Continental National
Bank of Fort Worth, Fort Worth, Tex., and the Continental Bank, National Association (organizing), Fort
Worth, Tex., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
Continental National Bank of Fort Worth, the
merging bank, is headquartered in Fort Worth. The
bank, with total resources of $213.8 million and I PC
deposits of $108.8 million, was chartered in 1903.
Continental Bank, National Association, the charter
bank, is being organized to provide a vehicle to transfer ownership of the merging bank to the Southwest
Bancshares, Inc. The charter bank will not be operating
as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

138



$237, 703, 268

1

256, 591

0

237, 986, 858

1

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct its banking business at the same location,
and with the same name as presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MAY 26, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Continental Bank, N.A. (org.) would become a subsidiary of Southwest Bancshares, Inc., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition
of the surviving bank by Southwest Bancshares, Inc., it
would have no effect on competition.

CITIZENS NATIONAL BANK, ENGLEWOOD, N.J.,

AND N E W CITIZENS NATIONAL BANK, ENGLEWOOD,
ENGLEWOOD, N.J.

N.J.,

Banking offices
Total assets

Name of bank and type of transaction

In
operation

$272, 372, 182

COMPTROLLER'S DECISION

On April 2,1969, the Citizens National Bank, Englewood, N.J., and the New Citizens National Bank,
Englewood, N.J. (organizing), Englewood, N.J.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and with
the title of the former with the main office of the
resulting bank to be located in Tenafly, N.J,
Citizens National Bank, the merging bank, is headquartered in Englewood, and has offices located
throughout Bergen County. The bank, with total resources of $236.0 million and IPC deposits of $195.5
million, was chartered originally in 1890.
New Citizens National Bank, the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to the Midlantic Banks, Inc.
The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank

13

125, 000

Citizens National Bank, Englewood, N.J. (4365), with
and New Citizens National Bank, Englewood, N.J., Englewood, N.J. (4365),
which had
merged June 30, 1972, under charter of the latter bank (4365) and title "Citizens
National Bank." The merged bank at date of merger had

To be
operated

0

272, 497, 182

involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used
by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MAY 16, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which New Citizens National Bank (org.) would become a subsidiary of Midlantic Banks, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Midlantic Banks, Inc., it
would have no effect on competition.

SECURITY PACIFIC NATIONAL BANK, LOS ANGELES, CALIF., AND

SECPAC

NATIONAL BANK, LOS ANGELES, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Security Pacific National Bank, Los Angeles, Calif. (2491), with
and SEGPAC National Bank, Los Angeles, Calif. (2491), which had
merged June 30, 1972, under charter of the latter bank (2491) and title "Security
Pacific National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On January 17, 1972, the Security Pacific National
Bank, Los Angeles, Calif., and the SECPAC National
Bank (organizing), Los Angeles, Calif., applied to the
501-017 0—73

10




$9,161,771,661
236, 304
9, 162, 007, 965

To be
operated

455
0

455

Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
Security Pacific National Bank, the merging bank, is
headquartered in Los Angeles, Calif., a city of 2.5 mil-

139

lion people. The bank, with IPC deposits of $5.7 billion,
was chartered originally in 1871.
SECPAG National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the Security Pacific Corporation. The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations and with the same name as presently used
by the merging bank.
*

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the application is, therefore, approved.
MARCH 20,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
SECPAC National Bank (org.) would become a subsidiary of Security Pacific Corporation, a bank holding
company. The instant merger, however would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition
of the surviving bank by Security Pacific Corporation,
it would have no effect on competition.
#

*

T H E SOUTH CAROLINA NATIONAL BANK OF CHARLESTON, CHARLESTON, S.C.,
CHARLESTON,

AND SECURITY NATIONAL BANK,

S.C.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

The South Carolina National Bank of Charleston, Charleston, S.C. (2044), with..
and Security National Bank, Charleston, S.C. (2044), which had
merged June 30, 1972, under charter of the latter bank (2044) and title "The
South Carolina National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On February 9, 1972, The South Carolina National
Bank of Charleston, Charleston, S.C, and the Security
National Bank (organizing), Charleston, S.C, applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title, "The South Carolina National Bank."
The South Carolina National Bank of Charleston,
the charter bank, is headquartered in Charleston, and
has 89 branches located throughout the State. The
bank, with total assets of $746.5 million and IPC deposits of $529.8 million, was originally chartered in
1834.
The Security National Bank, the merging bank, is
being organized to provide a vehicle to transfer ownership of the charter bank to the South Carolina National Corporation, which is being organized as a onebank holding company. The merging bank will not operate as a commercial bank prior to this merger.

140



$755, 104, 675
250, 000

To be
operated

94
0

755, 354, 675

94

Because the charter bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
locations as presently used by the charter bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MAY 11, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Security National Bank (org.) would become a subsidiary of SC National Corporation, a bank holding company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by SC National Corporation, it
would have no effect on competition.

ROCKINGHAM NATIONAL BANK, HARRISONBURG, VA., AND ROCKINGHAM BANK, N.A.,

HARRISONBURG, VA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Rockingham National Bank, Harrisonburg, Va. (5261), with
and Rockingham Bank, N.A., Harrisonburg, Va. (5261), which had
merged July 1, 1972, under charter of the latter bank (5261) and title "Rockingham National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On February 2, 1972, the Rockingham National
Bank, Harrisonburg, Va., and the Rockingham Bank,
N.A. (organizing), Harrisonburg, Va., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of the
former.
The Rockingham National Bank, the merging bank,
is headquartered in Harrisonburg, and has four
branches in Rockingham County and three offices in
Augusta County. The bank has total assets of $71.7
million and IPC deposits of $55.1 million. The merging
bank was originally chartered in 1900.
The Rockingham Bank, National Association is
being organized to provide a vehicle to transfer ownership of the merging bank to Valley of Virginia Bankshares, Inc. The charter bank will not be operating as
a commercial bank prior to the merger.
Because the merging bank is the only operating bank

$75,602,417
120, 000

To be
operated

8
0

75,722,417

8

involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
APRIL 24,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Rockingham Bank, N.A. (org.) would become a subsidiary of Valley of Virginia Bankshares, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Valley of Virginia Bankshares, Inc., it would have no effect on competition.

UNION PLANTERS NATIONAL BANK OF MEMPHIS, MEMPHIS, TENN., AND UNION PLANTERS BANK, NATIONAL
ASSOCIATION, MEMPHIS, TENN.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Union Planters National Bank of Memphis, Memphis, Tenn. (13349), with
and Union Planters Bank, National Association, Memphis, Tenn. (13349), which
had
merged July 1, 1972, under charter of the latter bank (13349) and title "Union
Planters National Bank of Memphis." The merged bank at date of merger had .

COMPTROLLER'S DECISION

On March 8, 1972, Union Planters Bank, National
Association (organizing) Memphis, Tenn., and Union
Planters National Bank of Memphis, Memphis, Tenn.,
applied to the Comptroller of the Currency for permis-




To be
operated

$1, 038, 300, 351

33

250, 000

0

1,038,312,376

sion to merge under the charter of
the title of the latter.
The Union Planters National
the merging bank, was organized
headquartered in Memphis, has

33

the former and with
Bank of Memphis^
in 1869. The bank,
total assets of $1.1

billion and IPC deposits of $620 million. It operates 26
branches in Tennessee.
The Union Planters Bank, National Association, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging
bank to the Union Planters Corporation. The Union
Planters Corporation is a recently organized Tennessee
corporation which will become a one-bank holding
company upon approval of its acquisition of the resulting bank. The charter bank will not be operating as a
commercial bank prior to this merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca-

FIRST

tions and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
MAY 4, 1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Union Planters National Bank of Memphis
would become a subsidiary of Union Planters Corporation, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Union
Planters Corporation, it would have no effect on
competition.

& MERCHANTS NATIONAL BANK OF THE PENINSULA, YORK COUNTY (P.O.

WILLIAMSBURG), VA., AND

SIX BRANCHES OF FIRST & MERCHANTS NATIONAL BANK, RICHMOND, V A .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Six Newport News Branches of First & Merchants National Bank, Richmond, Va.
(1111), with
were purchased July 3, 1972, by First & Merchants National Bank of the Peninsula,
York County (P.O. Williamsburg), Va. (15984), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On February 29, 1972, First & Merchants National
Bank of the Peninsula (organizing), Williamsburg,
Va., applied to the Comptroller of the Currency for
permission to purchase the assets and assume the liabilities of the six Newport News branches of First &
Merchants National Bank, Richmond, Va.
First & Merchants National Bank of the Peninsula,
the purchasing bank, is a new National banking association in the process of organization. The proposed
location of the main office of the purchasing bank is
in York County, Va., adjacent to the community of
Williamsburg. An application has been submitted by
First & Merchants Corporation to the Board of Governors of the Federal Reserve System for permission
to acquire all of the voting shares, except for directors'
qualifying shares, of the purchasing bank. First & Merchants National Bank of the Peninsula will not open

142



$99, 414, 363

6

8, 500, 000
107,914,363

To be
operated

0

6

for business unless it becomes a subsidiary by First
& Merchants Corporation.
The First & Merchants National Bank, the selling
bank, with total deposits of $832.2 million, desires to
sell six of its existing branches, all of which are located in the city of Newport News, Va., to the purchasing bank. All of the voting shares of First & Merchants National Bank, except for directors' qualifying
shares, are owned by First & Merchants Corporation, a
registered bank holding company with its principal
place of business in Richmond, Va.
Since both the purchasing and selling banks involve
the same bank holding company, the entire transaction is a corporate reorganization. The buying bank
will be able to branch de novo in the area, whereas the
selling bank is not able. This transaction will be very
pro-competitive. Approval of the present application
will not alter the location or quality of services pres-

ently rendered, as the resulting bank will continue to
provide all services presently furnished by First & Merchants National Bank, except that trust services in the
Newport News area will continue as part of First &
Merchants National Bank.
Applying the statutory criteria it is the view of this
Office that the proposed transaction is in the public
interest and is, therefore, approved.
MAY 16, 1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First & Merchants National Bank would become a subsidiary of First & Merchants Corporation, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating institution; as such, and without regard to the
acquisition of the surviving bank by First & Merchants
Corporation, it would have no effect on competition.

VIRGINIA NATIONAL BANK, NORFOLK, VA., AND VIRGINIA BANK, N.A.,

NORFOLK, VA.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

Virginia National Bank, Norfolk, Va. (9885), with
and Virginia Bank, N.A., Norfolk, Va. (9885), which had
merged July 10, 1972, under charter of the latter bank (9885) and title "Virginia
National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On July 15, 1971, Virginia National Bank, Norfolk,
Va., and Virginia Bank, N.A. (organizing), Norfolk,
Va., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter and
with the title of the former.
Virginia National Bank, the merging bank, is headquartered in Norfolk, Va., and holds IPC deposits of
$838.3 million.
Virginia Bank, N.A., the charter bank, is being organized to provide a vehicle to transfer ownership of
the merging bank to Virginia National Bankshares,
Inc. The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will




$1,444,599,440
240, 000

To be
operated

110
0

1, 444, 606, 640

110

conduct the same banking business at the same locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the application is, therefore, approved.
JUNE 8,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Virginia Bank, N.A. (org.) would become a
subsidiary of Virginia National Bankshares, Inc., a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Virginia National Bankshares, Inc., it would have no effect on
competition.

143

THE SECURITY NATIONAL BANK OF TRENTON, TRENTON, N.J.,

AND FIRST NATIONAL STATE BANK OF CENTRAL

JERSEY, TRENTON,

N.J.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Security National Bank of Trenton, Trenton, N.J. (13039), with
and First National State Bank of Central Jersey, Trenton, NJ. (13039), which had.
merged July 14, 1972, under charter and title of the latter bank (13039). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On January 11, 1972, The Security National Bank of
Trenton, Trenton, N.J., and the First National State
Bank of Central Jersey (organizing), Trenton, N.J.,
applied to the Comptroller of the Currency for permission to merge under the charter and with the title
of the latter.
The Security National Bank of Trenton, the merging bank, presently operates two offices in the city of
Trenton and has received approval to establish an
office in the village of Lawrenceville. The bank, with
assets of $56.8 million and IPC deposits of $45.9 million, is the seventh largest of the 11 commercial banks
headquartered in Trenton.
The First National State Bank of Central Jersey,
the charter bank, is being organized to provide a
vehicle to transfer ownership of the merging bank to
the First National State Bancorporation. The charter
bank will not be operating as a commercial bank
prior to the merger.
First National State Bancorporation, Newark, N.J.,
the bank holding company which will own the resulting bank, controls deposits of $925 million. That holding company currently operates three banks, with 42
offices, in the First Banking District; and two banks,
with 11 offices, in the Second Banking District of New
Jersey. The principal subsidiary of the holding company is the First National State Bank of New Jersey,
Newark, which has deposits of $764 million.

144



$60, 206, 744
250, 000

To be
operated
2
0

60,213,959

2

There is no competition between the merging bank
and any subsidiary of the First National State Bancorporation because large distances separate them and an
adequate number of competitors operate in the intervening distances. The closest subsidiary of the holding
company to The Security National Bank of Trenton is a
branch of the Edison Bank, National Association, Edison, which is located 26 miles away. The only other
subsidiary bank of First National State Bancshares in
the Second Banking District is the First National State
Bank of Spring Lake, whose main office is 45 miles
from that of the merging bank. The resulting bank
will conduct the Same banking business at the same
locations as presently used by the merging bank.
Applying the statutory criteria to this application,
it is concluded that the proposed merger is in the
public interest. The application is, therefore, approved.
JUNE 7,

1972.

SUMMARY OF REPORT BY ATTORNEY

GENERAL

The proposed merger is part of a plan through which
First National State Bank of Central Jersey (org.)
would become a subsidiary of First National State
Bancorporation, a bank holding company. The instant
merger, however, would merely combine an existing
bank with a non-operating institution; as such, and
without regard to the acquisition of the surviving
bank by First National State Bancorporation, it would
have no effect on competition.

THE KINGSPORT NATIONAL BANK, KINGSPORT, TENN., AND T H E NATIONAL BANK OF KINGSPORT, KINGSPORT,
TENN.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Kingsport National Bank, Kingsport, Tenn. (14657), with
and The National Bank of Kingsport, Kingsport, Tenn. (14657), which had
merged July 24, 1972, under charter of the latter bank (14657) and title "The
Kingsport National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On April 19, 1972, The Kingsport National Bank,
Kingsport, Tenn., and The National Bank of Kingsport (organizing), Kingsport, Tenn., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
The Kingsport National Bank, the merging bank, is
headquartered in Kingsport, and has four branch offices located throughout Sullivan County. The bank,
with total resources of $26.8 million and IPC deposits
of $18.7 million, was chartered in 1945.
Sullivan County is a rapidly growing county located
in the industrial corridor of northeast Tennessee. Its
two major population centers are Bristol, with a 1970
population of 20,064, and Kingsport, with a 1970 population of 31,938. In 1970, the county was the fifth
largest in the State, with a population of 127,329.
Including the merging bank, Sullivan County has three
banks with 17 banking offices operating in the county.
The other two banks are The First National Bank of
Sullivan County, with deposits of $94 million; and the
Tri-City Bank and Trust Company, Blountville, with
deposits of $24.6 million. In addition to those, the
merging bank competes with the First Valley Bank,
Weber City, with deposits of $4.4 million, as well as
the Weber City Branch of the Virginia National Bank,
the Church Hill branch of the Citizens and Union
Bank of Rogersville, and the Mt. Carmel branch of the
First National Bank of Rogersville.
The National Bank of Kingsport, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the First Tennessee
National Corporation. The charter bank will not be
operating as a commercial bank prior to the merger.
First Tennessee National Corporation is a registered
bank holding company and the largest multi-bank holding company in Tennessee. The largest subsidiary in
the applicant's banking structure is the First National




$29,219,045
131,600
29, 344, 045

To be
operated
5
0

5

Bank of Memphis, Memphis, Tenn., which holds total
deposits of $792.7 million. The First Tennessee National Corporation also owns two other banking subsidiaries: The Banking and Trust Company, Jonesboro, Tenn., with deposits of $27.6 million; and the
White's Creek Bank and Trust Company, White's
Creek, Tenn., with deposits of $6.6 million.
The major competitors of the First National Bank
of Memphis include the Union Planters National Bank
of Memphis, Memphis, with deposits of $730 million;
the National Bank of Commerce, Memphis, with deposits of $260 million; and the Memphis Bank and
Trust, Memphis, with deposits of $61 million.
The effect of this merger will be to enable the First
National Corporation to acquire The Kingsport National Bank, the merging bank. As a result the merging
bank will be able to offer an expanded range of banking services to the residents of its trade area. The
acquisition will also add increased management depth
to the subsidiary bank and will give that bank direct
access to expanded loan reserves that will enable the
Kingsport National Bank to grow with its expanding
trade area.
Competition will not be adversely affected by consummation of this transaction. The nearest office of a
subsidiary of the acquiring corporation to an office of
the merging bank is 7 miles away, and there is very
little competition between the two banks. In the present service area of the merging bank, its competitive
position will be improved and competition will be
enhanced by the entrance of a stronger banking entity.
The First Tennessee National Corporation will continue to rank as the largest multi-bank holding company in the State, but its increase in resources will not
substantially affect the banking structure in Tennessee.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JUNE 23, 1972.

145

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Kingsport National Bank would become a subsidiary
of First Tennessee National Corporation, a bank hold-

ing company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by First Tennessee National
Corporation, it would have no effect on competition.

T H E FIRST NATIONAL BANK OF FORT WORTH, FORT WORTH, TEX., AND BURNETT PLAZA NATIONAL BANK OF
FORT WORTH, FORT WORTH, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Fort Worth, Fort Worth, Tex. (2349), with
and Burnett Plaza National Bank of Fort Worth, Fort Worth, Tex. (2349), which
had
merged Aug. 7, 1972, under charter of the latter bank (2349) and title "The First
National Bank of Fort Worth." The merged bank at date of merger had

COMPTROLLER S DECISION

On December 20, 1971, The First National Bank of
Fort Worth, Fort Worth, Tex., and the Burnett Plaza
National Bank of Fort Worth (organizing), Fort
Worth, Tex., applied to the Comptroller of the Currency for permission to merge under the charter of the
latter and with the title of the former.
The First National Bank of Fort Worth, the merging
bank, is headquartered in Fort Worth, and was originally organized in 1877. The bank has total assets of
$579.9 million and IPC deposits of $315.6 million.
The Burnett Plaza National Bank of Fort Worth, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank to
First United Bancorporation, Inc., a bank holding company. The charter bank will not be operating as a
commercial bank prior to this merger.
First United Bancorporation, Fort Worth, Tex., the
holding company which will gain control of The First
National Bank of Fort Worth as a result of this merger,
was originally organized in 1929. At present, First
United Bancorporation has four banking subsidiaries
headquartered in Fort Worth, and one additional subsidiary in Arlington, Tex. Those banks are the University State Bank, with deposits of $32.3 million; the
Security State Bank, with deposits of $14 million; the
Seminary State Bank, with deposits of $13 million; the
Gateway National Bank, with deposits of $12.5 million;




To be
operated

$651, 899, 078

1

240, 000

0

651, 910, 278

1

and the Great Southwestern National Bank, Arlington,
with deposits of $4 million.
Since the original formation of the holding company
in 1929, all of the stock of the First United Bancorporation has been held in trust for the benefit of the
shareholders of the First National Bank of Fort Worth
by several of its directors. That means that the First
National Bank of Fort Worth, First United Bancorporation, and the banking subsidiaries which it controls are all commonly owned at present. Accordingly,
the proposed merger will not eliminate any competition between any of those banks. The resulting bank
will conduct the same banking business at the same
location and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 6,1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank of Fort Worth would become a
subsidiary of First United Bancorporation, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by First United Bancorporation, it would have no effect on competition.

T H E LIVESTOCK NATIONAL BANK OF KANSAS CITY, KANSAS CITY, M O . , AND LIVESTOCK BANK OF KANSAS CITY,
NATIONAL ASSOCIATION, KANSAS CITY, M O .

Banking offices
Total assets

Name of bank and type of transaction

In
operation

$27, 200, 724

On May 8, 1972, The Livestock National Bank of
Kansas City, Kansas City, Mo., and the Livestock
Bank of Kansas City, National Association (organizing), Kansas City, Mo., filed an application with the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
The Livestock National Bank of Kansas City, the
merging bank, was chartered in 1955, and now holds
deposits of $21 million.
The Livestock Bank of Kansas City, National Association, the charter bank, is being organized to provide a vehicle to transfer ownership of the merging
bank to First National Charter Corporation. The
charter bank will not be operating as a commercial
bank prior to the merger.
First National Charter Corporation, Kansas City,
Mo., the bank holding company which will acquire
the resulting bank, was organized in 1969, and presently owns seven banks. Its principal subsidiary is The
First National Bank of Kansas City, the third largest
bank in that city, with deposits of $365 million. First
National Charter Corporation has two additional
metropolitan area subsidiaries, the Leawood National
Bank, with deposits of $18.7 million, and the Citizens
Bank of Belton, with deposits of $7.4 million. Its remaining subsidiaries include the Webster Groves Trust
Company, the North Side Bank, the Bank of Overland,
and the National Bank of Boonville, which have aggregate deposits of $118.5 million.
There is no competition between The Livestock Na-




1

240, 000

The Livestock National Bank of Kansas City, Kansas City, Mo. (14735) with
and Livestock Bank of Kansas City, National Association, Kansas City, Mo.
(14735), which had
merged Aug. 8, 1972, under charter of the latter bank (14735) and title "The
Livestock National Bank of Kansas City." The merged bank at date of merger had.

COMPTROLLER S DECISION

To be
operated

0

27,440, 724

1

tional Bank of Kansas City and any subsidiary of First
National Charter Corporation. The merging bank was
organized as an outgrowth of the merger between The
First National Bank of Kansas City and the Inter-State
National Bank of Kansas City. Since its inception the
merging bank has been closely affiliated with the holding company through the ownership of 80 percent of
its stock by the majority shareholders of The First National Bank of Kansas City. As a result of that affiliation, the merging bank has maintained strong correspondent ties with the principal subsidiary of the
holding company.
This merger will facilitate the corporate reorganization of the merging bank and will have no effect on
competition within the Kansas City banking community. The resulting bank will conduct the same business
at the same location and with the same name as presently used by the merging bank.
Applying the statutory criteria, we find that this proposal is in the public interest and the application is,
therefore, approved.
JULY 7,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Livestock National Bank of Kansas City would become a subsidiary of First National Charter Corporation, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard
to the acquisition of the surviving bank by First National Charter Corporation, it would have no effect
on competition.

147

FIRST NATIONAL BANK OF BAY SHORE, BAY SHORE, N.Y., AND FIRST BANK OF BAY SHORE, NATIONAL ASSOCIATION, BAY SHORE, N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

First National Bank of Bay Shore, Bay Shore, N.Y. (10029), with
and First Bank of Bay Shore, National Association, Bay Shore, N.Y. (10029),
which had
merged Aug. 31, 1972, under charter of the latter bank (10029) and title "First
National Bank of Bay Shore." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 9, 1972, the First National Bank of
Bay Shore, Bay Shore, N.Y., and the First Bank of
Bay Shore, National Association (organizing), Bay
Shore, N.Y., applied to the Comptroller of the Currency for permission to merge under the charter of the
latter and with the title of the former.
The First National Bank of Bay Shore, the merging
bank, is seventh in size of the 15 commercial banks
headquartered in Suffolk County. The bank has assets
of $67 million and IPC deposits of $53.4 million. The
merging bank has seven operating offices and two approved, but as yet unopened, branches, all of which
are located in Suffolk County.
Competitors of the First National Bank of Bay
Shore include Security National Bank, Huntington,
with total deposits of $1.1 billion; the Marine Midland Tinker National Bank, East Setauket, with total
deposits of $122 million; Bankers Trust of Suffolk,
National Association, with deposits of $82 million; and
the Eastern National Bank of Long Island, Smithtown,
with deposits of $67 million. Several of those large
competitors, as well as many of the smaller Suffolk
County banks, are subsidiaries of the large New York
City holding companies.
First Bank of Bay Shore, National Association, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank to
Manufacturers Hanover Corporation, a registered bank
holding company. The charter bank will not be operating as a commercial bank prior to this merger.
Manufacturers Hanover Corporation, New York,
N.Y., the bank holding company which will acquire
the resulting bank, is one of the large holding com-




To be
operated

$74, 718, 703

7

120, 000

0

74, 722, 339

7

panies based in New York City. The principal asset
of that holding company is the Manufacturers Hanover Trust Company, New York, N.Y. That bank
has total deposits of $12.5 billion, and operates
branches throughout the five boroughs of New York
City as well as in Nassau and Westchester counties.
At present there is no competition between any
branch of Manufacturers Hanover Trust Company
and the merging bank. The closest branch of Manufacturers Hanover Trust is in Woodbury, approximately 20 miles away from North Babylon, the location
of the merging bank's closest branch. Woodbury is located in contiguous Nassau County, and numerous
banking alternatives separate it from North Babylon.
Consummation of the proposed merger will allow
the resulting bank to retain its present competitive
position in Suffolk County. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 27,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First Bank of Bay Shore, N.A. (org.) would become
a subsidiary of Manufacturers Hanover Corp., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank of Manufacturers Hanover
Corp., it would have no effect on competition.

NORTHEAST NATIONAL BANK OF FORT WORTH, NORTH RICHLAND HILLS (P.O. FORT WORTH), TEX., AND FIRST
NATIONAL BANK OF NORTH RICHLAND HILLS, NORTH RICHLAND HILLS, TEX.

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In
operation
Northeast National Bank of Fort Worth, North Richland Hills (P.O. Fort Worth),
Tex. (14982), with
and First National Bank of North Richland Hills, North Richland Hills, Tex.
(14982), which had
merged Aug. 31, 1972, under charter of the latter bank (14982) and title "Northeast National Bank of Fort Worth." The merged bank at date of merger had

COMPTROLLER'S DECISION

On April 28, 1972, the Northeast National Bank of
Fort Worth, North Richland Hills, Tex., and the First
National Bank of North Richland Hills (organizing),
North Richland Hills, Tex., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
The Northeast National Bank of Fort Worth, the
merging bank, was organized in 1962, and is headquartered in Fort Worth. The bank has assets of $31 million and IPC deposits of $23.2 million.
The First National Bank of North Richland Hills,
the charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to Northeast Bancorp, Inc., which will become a one-bank
holding company upon the acquisition of the resulting
bank. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating bank

$34, 333, 438
240, 000
34, 573, 438

involved in the proposed transaction, there can be
no adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same
location and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 31,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Northeast National Bank of Fort Worth would become
a subsidiary of Northeast Bancorp, Inc., a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Northeast Bancorp, Inc.,
it would have no effect on competition.

INTER NATIONAL BANK OF MIAMI, MIAMI, FLA., AND INB NATIONAL BANK OF MIAMI, MIAMI, FLA.

Banking offices
Name of bank and type of transaction

Total assets

In
operation
Inter National Bank of Miami, Miami, Fla. (15156), with
and INB National Bank of Miami, Miami, Fla. (15156), which had
merged Sept. 2, 1972, under charter of the latter bank (15156) and title "Inter
National Bank of Miami." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 8, 1972, the Inter National Bank of Miami,
Miami, Fla., and the INB National Bank of Miami (or-




$52, 585, 336
240, 000
52, 592, 536

To be
operated
1
0
1

ganizing) , Miami, Fla., applied to the Comptroller of
the Currency for permission to merge under the charter
of the latter and with the title of the former.
Inter National Bank of Miami, the merging bank,

149

is headquartered in Miami, and operates only one
office. The bank, with total resources of $51.6 million
and IPC deposits of $43.3 million, was chartered in
1963.
INB National Bank of Miami, the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to The Royal Trust Company, Montreal, Quebec, Canada. The charter bank
will not be operating as a commercial bank prior to
the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be
no adverse effect on competition resulting from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same

locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 25,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Inter National Bank of Miami would become a subsidiary of The Royal Trust Company, a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by The Royal Trust Company, it
would have no effect on competition.

THE NATIONAL EXCHANGE BANK OF CASTLETON-ON-HUDSON, CASTLETON-ON-HUDSON, N.Y.,
(EASTERN), NATIONAL ASSOCIATION, CASTLETON-ON-HUDSON,

AND CITIBANK

N.Y.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

The National Exchange Bank of Castleton-on-Hudson, Castleton-on-Hudson,
N.Y. (5816), with
and Citibank (Eastern), National Association, Castleton-on-Hudson, N.Y. (5816),
which had
merged Sept. 6, 1972, under charter and title of the latter bank (5816). The
merged bank at date of merger had
COMPTROLLER'S DECISION

On February 24,1972, The National Exchange Bank
of Castleton-on-Hudson, Castleton-on-Hudson, N.Y.,
and Citibank (Eastern), National Association (organizing), Castleton-on-Hudson, N.Y., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The National Exchange Bank of Castleton-on-Hudson, the merging bank, was established in 1901, and
since its inception has maintained its head office within
the village of Castleton-on-Hudson. The bank has established three branches in Rensselaer County, one
each in the villages of Nassau and Averill Park and
one in the city of Rensselaer. The merging bank has
assets of $13.3 million and IPC deposits of $10.5
million.
Competitors of the merging bank include the National Commercial Bank and Trust Company, Albany,
with deposits of $917 million; the State Bank of Albany,
with deposits of $747 million; the Union National Bank




To be
operated

$14, 353, 641
61,900
14,415,541

of Troy, with deposits of $77 million; and the Community State Bank, Albany, with deposits of $41
million.
Citibank (Eastern), National Association, the charter bank, is being organized to provide a vehicle by
which to transfer ownership of the merging bank to
First National City Corporation, a registered bank
holding company. The charter bank will not be operating as a commercial bank prior to the merger.
First National City Corporation, New York, N.Y.,
the bank holding company which will acquire the resulting bank, is the second largest of the 13 multi-bank
holding companies in New York State. The holding
company has domestic resources of $16.5 billion. First
National City Corporation presently controls two
banks: First National City Bank, New York City, the
lead bank in its banking structure; and Citibank (Suffolk), National Association, Bay Shore, N.Y., which
was chartered and opened in November 1971. Applications are currently pending to acquire the Silver

Creek National Bank, Silver Creek, and the State Bank
of Honeoye Falls, Honeoye Falls, N.Y.
At present, there is no competition between any subsidiary of First National City Corporation and the
merging bank. The National Exchange Bank of Castleton-on-Hudson is approximately 80 miles from the
Westchester County line, the area in which First National City Corporation has its closest subsidiary. The
large distances which separate the merging bank from
subsidiaries of First National City Corporation and the
large number of banks located in the intervening area
precludes any competition between those banks. The
resulting bank will conduct the same banking business
at the same locations as presently used by the merging
bank.

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 18,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Citibank (Eastern), N.A. would become a subsidiary of First National City Corporation, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by First National City Corporation, it would have no effect on competition.

DOUGLAS NATIONAL BANK, ROSEBURG, OREG., AND DB NATIONAL BANK, ROSEBURG, OREG.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Douglas National Bank, Roseburg, Oreg. (14860), with
and DB National Bank, Roseburg, Oreg. (14860), which had
merged Sept. 14, 1972, under charter of the latter bank (14860) and title "Douglas
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 12, 1972, DB National Bank (organizing),
Roseburg, Oreg., and Douglas National Bank, Roseburg, Oreg., applied to the Comptroller of the Currency for permission to merge under the charter of
the former and with the title of the latter.
The Douglas National Bank, the merging bank, was
chartered on May 25, 1959, and currently has deposits
of $23.2 million. The bank's primary service area is
the central part of Douglas County, Oreg., omitting
the far southern and western portions of the county.
That area has experienced a steady but not spectacular
growth. While Douglas National Bank has adequate
financial and managerial resources to meet the present
needs of the community, it believes that affiliation with
a bank holding company will allow it to compete
more successfully in the future with Oregon's two
large banking chains.
Douglas National Bank has three offices in the area
and total deposits of approximately $23.2 million. It
competes with three offices of U.S. National Bank of
Oregon, with four officer of First National Bank of
Oregon, and with three offices of South Umpqua State




$31,658, 129
120,000
31,563,129

To be
operated

4
0
4

Bank. Douglas National Bank also faces extensive competition from other facilities in the area, such as
savings and loan associations, personal loan companies,
and credit unions.
DB National Bank, the charter bank, is being organized to provide a vehicle to transfer ownership of the
merging bank to United Bancorp., an Oregon corporation. The charter bank will not be operating as a commercial bank prior to the consummation of this transaction.
United Bancorp., Roseburg, Oreg., intends to become a registered bank holding company and plans to
gain control of the resulting bank. At present United
Bancorp, has only taken assets and controls no other
banks; thus, no competition will be eliminated by the
holding company's acquisition of the resulting bank.
The resulting bank will conduct the same banking
business at the same location with the same name as
presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 14,

1972.

151

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Douglas National Bank would become a subsidiary of
United Bancorp., a bank holding company. The instant

merger, however, would merely combine an existing
bank with a non-operating institution; as such, and
without regard to the acquisition of the surviving bank
by United Bancorp., it would have no effect on
competition.

T H E CENTRAL NATIONAL BANK AT CAMBRIDGE, CAMBRIDGE, OHIO, AND CAMBRIDGE NATIONAL BANK, CAMBRIDGE,
OHIO
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The Central National Bank at Cambridge, Cambridge, Ohio (13905), with
and Cambridge National Bank, Cambridge, Ohio (13905), which had
merged Sept. 25, 1972, under charter of the latter bank (13905) and title "The
Central National Bank at Cambridge." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On June 2, 1972, The Central National Bank at
Cambridge, Cambridge, Ohio, applied to the Comptroller of the Currency for permission to merge with
Cambridge National Bank (organizing), Cambridge,
Ohio, under the charter of the latter and with the title
of the former.
Cambridge National, Bank is being organized to provide a vehicle to transfer ownership of the existing
bank to BancOhio Corporation, a registered bank
holding company. The organizing bank will not be
operating as a commercial bank prior to the merger.
The Central National Bank at Cambridge, the existing bank, with total deposits of $26.7 million, was
organized in 1933, and presently operates four branch
offices. The existing bank is headquartered in Guernsey
County in the city of Cambridge, the county seat,
which is located approximately 80 miles east of Columbus and 130 miles south of Cleveland at the intersection of two major interstate highways.
The immediate service area of the existing bank
encompasses most of the densely populated areas of
Guernsey County; the population is estimated at
34,000. The economy of Guernsey County is primarily
agricultural, with Cambridge serving as its industrial
center. National Cash Register is the largest employer
in the service area with approximately 2,600 employees.
Banks competing with The Central National Bank
in its service area include First National Bank of Cambridge, with total deposits of $28.3 million, which is a
subsidiary of Columbus-based First Bane Group of

152



$32,272,212
120,000
32,392,212

To be
operated

5
0

5

Ohio, Inc., Ohio's fifth largest multi-bank holding
company, and The Quaker City National Bank, Quaker
City, with total deposits of approximately $9 million,
which is seeking a branch office in Cambridge. Further
competition is provided by two savings and loan associations and several finance companies and credit
unions.
BancOhio Corporation, headquartered in Columbus, Ohio, is the largest bank holding company and the
second largest banking organization in the State. It
controls 31 subsidiary banks with deposits in excess of
$1.6 billion, representing approximately 7.4 percent of
the total commercial deposits in Ohio. In addition,
BancOhio Corporation owns two non-banking subsidiaries, i.e., a realty corporation and a supply company
which service the needs of banks within the holding
company's system.
Competition will not be adversely affected by consummation of the proposed merger. The Central National Bank is the only operating bank involved in the
proposed merger. Further, the proposed affiliation will
have a negligible effect on the competitive position of
BancOhio Corporation with respect to other banking
institutions in Ohio. Total State deposits held by the
parent corporation would increase only slightly to 7.5
percent and the corporation would remain the second
largest banking institution in the State. There is no
present competition between The Central National
Bank and any existing or proposed subsidiary of the
holding company, the nearest being 20 miles away.
In addition, because of the distance involved and

Ohio's restrictive branching laws, it is considered unlikely that meaningful future competition would develop between that bank and BancOhio Corporation's
other subsidiaries.
Consummation of the proposed merger will enable
the resulting bank to offer additional and expanded
services to area residents and businessmen such as FHA
mortgage loans, computer loans, and international
banking services. In addition, the resulting bank will
acquire greater managerial resources and expertise
necessary to maintain and enhance meaningful competition in its service area.
Applying the statutory criteria to this application, it

is concluded that the proposed merger is in the public
interest. The application, therefore, is approved.
AUGUST 23,1972.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Central National Bank at Cambridge would become a
subsidiary of BancOhio Corporation, a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by BancOhio Corporation, it would
have no effect on competition.

T H E FIRST NATIONAL BANK AND TRUST COMPANY OF RAVENNA, RAVENNA, OHIO, AND THE
BANK OF RAVENNA, RAVENNA, OHIO

F.B.G.

NATIONAL

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank and Trust Company of Ravenna, Ravenna, Ohio (5370),
with
and The F.B.G. National Bank of Ravenna, Ravenna, Ohio (5370), which had. .
merged Sept. 29, 1972, under charter of the latter bank (5370) and title "The
First National Bank & Trust Company of Ravenna." The merged bank at date
of merger had

COMPTROLLER S DECISION

On June 12, 1972, application was made with the
Comptroller of the Currency for permission to merge
The F.B.G. National Bank of Ravenna (organizing),
Ravenna, Ohio, with The First National Bank and
Trust Company of Ravenna, Ravenna, Ohio, under
the charter of the former and with the title of "The
First National Bank & Trust Company of Ravenna."
The F.B.G. National Bank of Ravenna, the organizing bank, is being organized to provide a vehicle to
transfer ownership of the existing bank to First Bane
Group of Ohio, a registered bank holding company
headquartered in Columbus, Ohio. The organizing
bank will not be operating as a commercial bank prior
to the merger.
The First National Bank and Trust Company of
Ravenna, the existing bank, with total deposits of $57
million, is headquartered in Ravenna, and maintains
four branch offices in Portage County. It operates
under a charter granted in 1900 to the First National
Bank of Mantua, Mantua, Ohio, which merged into




To be
operated

$71,939,416
120,000
72,059,416

the First Savings Bank and Trust Company of Ravenna
to form the subject bank in 1959.
The existing bank is second largest of six commercial
banks in Portage County. The first and third largest
competing banks are subsidiaries of billion-dollar multibank holding companies; the first, Portage National
Bank, near Kent, Ohio, with total deposits of $64 million, is a subsidiary of Huntington Bancshares, Inc.,
Columbus, Ohio; and the third, The Second National
Bank of Ravenna, with total deposits of $34 million,
is a subsidiary of The Society Corporation, Cleveland,
Ohio. The three remaining competing banks have aggregate deposits of approximately $37 million. In addition to aggressive competition from the commercial
banks in its service area, the existing bank also receives
very substantial competition from many banking organizations located in the nearby Akron and Cleveland
communities. Also, strong competition is provided by
savings and loan associations, finance companies, as well
as credit unions, farm lenders, insurance companies,
and other financial institutions in Portage County and
in the Akron market generally.

153

The existing bank's primary service area is Portage
County. It consists of approximately 506 square miles
and supports a rapidly expanding suburban community.
Its economy is interdependent with those of nearby
Summit and Cuyahoga counties; it is based on farming,
government, and several local manufacturing
industries.
First Bane Group of Ohio is the fifth largest of nine
multi-bank holding companies in Ohio. It controls 11
banks and is seeking to acquire the $26.9 million Liberty National Bank, Fremont, Ohio. As of December 31, 1971, the holding company controlled 3.6 percent of $21.6 billion of total commercial bank deposits
and 4 percent of total commercial bank loans in the
State.
The proposed merger will have no adverse effect
on competition. The existing bank is the only operating bank involved in the proposed transaction. Furthermore, there is no present competition between the existing bank and any present or proposed subsidiary of
the bank holding company, the nearest being 50 miles
from Ravenna. In addition, because of the distance involved and Ohio's restrictive branching laws, it is
considered unlikely that meaningful future competition
will develop between existing bank and First Bane
Group of Ohio's subsidiaries. The proposed affiliation
will not affect the bank holding company's position
among the holding companies and banking institutions

in Ohio. Its percentage of deposits and loans will increase only .2 percent and .3 percent respectively.
Consummation of the proposed merger will increase
rather than lessen banking competition within Portage
County. The proposed affiliation will enable resulting
bank to offer additional and expanded services to area
residents and businessmen, such as improved farm and
education lendings, international banking and trust
services and mortgage financing. In addition, the resulting bank will acquire greater managerial resources
and expertise necessary to maintain and enhance meaningful competition in its service area.
Accordingly, applying the statutory criteria to this
application, it is concluded that the proposed merger
is in the public interest. Therefore, the application is
approved.
AUGUST 24,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank and Trust Company of Ravenna
would become a subsidiary of First Bane Group of
Ohio, Inc., a bank holding company. The instant
merger, however, would merely combine an existing
bank with a non-operating institution; as such, and
without regard to the acquisition of the surviving bank
by First Bane Group of Ohio, Inc., it would have no
effect on competition.

T H E LIBERTY NATIONAL BANK OF FREMONT, FREMONT, OHIO, AND T H E
FREMONT, OHIO

F.B.G.

NATIONAL BANK OF FREMONT,

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Liberty National Bank of Fremont, Fremont, Ohio (13997), with
and The F.B.G. National Bank of Fremont, Fremont, Ohio (13997), which had. .
merged Sept. 29, 1972, under charter of the latter bank (13997) and title "The
Liberty National Bank of Fremont." The merged bank at date of merger h a d . . . .

COMPTROLLER S DECISION

On June 13, 1972, The Liberty National Bank of
Fremont, Fremont, Ohio, and The F. B. G. National
Bank of Fremont (organizing), Fremont, Ohio, applied to the Comptroller of the Currency for permission to merge under the charter of the latter and with
the title of the former.
The Liberty National Bank of Fremont, the merg-

154



$29,916,745
120, 000
29, 916, 745

To be
operated
3
0
3

ing bank, is headquartered in Fremont, and has three
offices located throughout Sandusky County. The bank,
with total resources of $26.9 million and IPC deposits
of $21.8 million, was chartered originally in 1934.
The F. B. G. National Bank of Fremont, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to the First Bane Group
of Ohio, Inc. The charter bank will not be operating
as a commercial bank prior to the merger.

First Bane Group of Ohio, Inc., the applicant, is
headquartered in Columbus, and is the fifth largest
of nine multi-bank holding companies operating the
State. It controls 11 banks and, in addition to this
acquisition, has an application pending to acquire the
$65 million First National Bank and Trust Company
of Ravenna, Ravenna, Ohio. Applicant controls $777.2
million of the $21.6 billion of bank deposits in Ohio
and is the seventh largest banking organization in the
State. The applicant is employing the procedure of
establishing a new interim National bank into which
the existing institution will be merged in order to effect
this transaction.
The Liberty National Bank, Fremont, the subject
bank, with deposits of $23.6 million, was organized in
1934. It operates two branch offices in Sandusky
County.
Fremont, Ohio, home of the subject bank, has a
population of 16,573 and is the county seat of Sandusky County. It is located in the northwest quadrant
of the State, approximately 100 miles west of Cleveland, and 100 miles northwest of Columbus, the State
capital and headquarters of the applicant. The economy of the market area is mainly industrial in Fremont
and agricultural in surrounding Sandusky County.
The selling bank is the third largest of six commercial banks in the county. Keen competition is afforded
by the Croghan Colonial Bank and its four branches,
with $43.6 million in deposits, and the Fremont Savings Bank Co., with three branches and deposits of
$29.4 million, which is affiliated with Society Corporation, the State's third largest multi-bank holding company. The remaining three competing banks in
Sandusky County are the Home Banking Co., Gibsonburg, with deposits of $18.4 million; the Woodville
State Bank, Woodville, with deposits of $16 million, an
affiliate of Huntington Bancshares, Incorporated, the
sixth largest banking organization in the State; and
The Clyde Savings Bank Co., Clyde, Ohio, with de-

posits of $11 million. In addition, certain non-bank
financial institutions located in the county offer strong
competition for available consumer business.
The acquisition should benefit the Fremont community by making available to it the substantial lending resources and trust facilities of the parent banking
system. In addition, it should serve to make the subject
bank more effective in serving the general banking
needs of the community and enable it to better service
the commercial business which it does not presently do
effectively.
Competition will not be adversely affected by consummation of this transaction. The acquisition of the
subject bank will increase the applicant's share of statewide deposits and loans only by insignificant percentages, and the applicant would continue to rank as
seventh largest banking organization and fifth largest
of nine multi-bank holding companies in Ohio. Because the service areas of the subject bank and present
subsidiary banks of the applicant overlap only marginally, there is little present competition between them
to be eliminated. In the service area of the subject
bank, competition will be improved since the subject
bank will become a more viable competitive force while
smaller institutions will not be seriously disadvantaged.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
AUGUST 24,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Liberty National Bank of Fremont would become a
subsidiary of First Bane Group of Ohio, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by First Bane Group of Ohio,
Inc., it would have no effect on competition.

FIRST NATIONAL BANK OF DECATUR, DECATUR, ALA., AND DECATUR NATIONAL BANK, DECATUR, ALA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Decatur, Decatur, Ala. (6380), with
and Decatur National Bank, Decatur, Ala. (6380), which had
merged Sept. 30, 1972, under charter of the latter bank (6380) and title "First
National Bank of Decatur." The merged bank at date of merger had

501-017 0—73-

-11




$43, 630, 424
120, 000
43,750,424

To be
operated
3
0
3

155

COMPTROLLER'S DECISION

On April 21, 1972, the First National Bank of Decatur, Decatur, Ala., and Decatur National Bank (organizing), Decatur, Ala., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
First National Bank of Decatur, the merging bank,
is located in Decatur, Ala., and serves the northwest
part of Morgan County, which includes the towns of
Danville and Hartselle. This bank was organized in
1895, and has current deposits of $34.9 million. Because of local statutes, it is prohibited from branching
in Morgan County outside the city limits of Decatur.
Decatur National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership of
the merging bank to Alabama Bancorporation, Birmingham, Ala. The charter bank will not be operating
as a commercial bank prior to the merger.
Alabama Bancorporation located in Birmingham,
Ala., was organized in 1970 as a bank holding company and owns as its only wholly-owned subsidiary the
First National Bank of Birmingham, Birmingham, Ala.
That bank is the largest commercial bank in the State,
and has current deposits of $733.6 million. An application has also been filed by Alabama Bancorporation to

T H E AMERICAN NATIONAL BANK

acquire the American National Bank and Trust Company of Mobile, Mobile, Ala.
There is no competition between the present subsidiary of Alabama Bancorporation and the First National Bank of Decatur, as the nearest offices of each
are separated by 72 miles, two counties, and eight competing banks.
Consummation of the subject merger will result in
no adverse competitive effects. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank. Applying the statutory criteria, it is concluded that the proposed merger is in the public interest
and the application is, therefore, approved.
AUGUST 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank of Decatur would become a subsidiary of Alabama Bancorporation, a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by Alabama Bancorporation, it
would have no effect on competition.

& TRUST COMPANY OF MOBILE, MOBILE,
NATIONAL BANK, MOBILE, ALA.

ALA.,

AND MOBILE

COUNTY

Banking offices

Total assets

Name of bank and type of transaction

In
operation

The American National Bank & Trust Company of Mobile, Mobile, Ala. (13414),
with
.
and Mobile County National Bank, Mobile, Ala. (13414), which had
merged Sept. 30, 1972, under charter of the latter bank (13414) and title "The
American National Bank & Trust Company of Mobile." The merged bank at date
of merger had

COMPTROLLER S DECISION

On April 10, 1972, The American National Bank
& Trust Company, Mobile, Ala., and the Mobile
County National Bank (organizing), Mobile, Ala.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of the former.
The American National Bank & Trust Company,
the merging bank, is headquartered in Mobile, Ala.,
and has five offices located in Mobile and Baldwin

156



$91, 457, 068
240, 000
91,697,068

To be
operated

9
0

9

County. The bank, with deposits of $68.7 million,
was chartered in 1929.
Mobile County National Bank, the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to the Alabama Bancorporation. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating
bank in the proposed transaction, there is no competition between the applicant institutions. The resulting

bank will continue to conduct the same banking business at the locations now used by the merging bank.
Alabama Bancorporation controls two institutions:
the $647.6 million First National Bank, Birmingham,
and the $31.4 million First National Bank, Decatur.
The nearest office of those banks to the merging bank
is over 200 miles away, which effectively prevents any
competition between the merging bank and any subsidiary of the Alabama Bancorporation.
It is believed that consummation of the subject
proposal will not result in adverse competitive effects
either in Mobile or throughout the State of Alabama.
Mobile supports two other institutions: the $205.6
million Merchants National Bank of Mobile, and the
$203.4 million First National Bank of Mobile, both
of which are significantly larger than the merging institution. While the Alabama Bancorporation, which controls deposits of $679.5 million, is the largest bank holding company in the State, its immediate competitors
are the First Alabama Bancshares, Inc., which operates
three subsidiary banks with aggregate deposits of $489.4
million, and the Central and State National Corporation, which controls the State's third and eighth largest
commercial banks, with aggregate deposits of $388.1

million. Intense competition among the respective holding companies will continue.
Approval of the proposed merger will improve the
bank's ability to meet the demands both for credit
and for more sophisticated bank services. The bank
will have access to investment advice and expertise in
real estate financing which will aid the area's economy.
In addition, affiliation with the holding company will
provide better management and larger resources for
loans.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is approved.
AUGUST 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
American National Bank & Trust Company of. Mobile
would become a subsidiary of Alabama Bancorporation, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Alabama Bancorporation, it would have no effect on
competition.

T H E FIRST NATIONAL BANK OF PORT ARTHUR, PORT ARTHUR, TEX., AND FIRST BANK, NATIONAL ASSOCIATION
PORT ARTHUR, TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Port Arthur, Port Arthur, Tex. (5485), with
and First Bank, National Association, Port Arthur, Tex. (5485), which had
merged Oct. 10, 1972, under charter of the latter bank (5485) and title " T h e
First National Bank of Port Arthur." The merged bank at date of merger h a d . . . .

COMPTROLLER S DECISION

On March 17, 1972, The First National Bank of Port
Arthur, Port Arthur, Tex., and First Bank, National
Association (organizing), Port Arthur, Tex., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
of the former.
The First National Bank of Port Arthur, the merging bank, was established in 1900, and is the largest
of the three commercial banks in that city, with assets
of $84.9 million and IPC deposits of $58.7 million.




$91,824, 150
254, 638
92, 078, 788

To be
operated
1
0
1

First Bank, National Association, the charter bank,
is being organized to provide a vehicle to transfer ownership of the merging bank to Southwest Bancshares,
Inc. The charter bank will not be operating as a commercial bank prior to the merger.
Southwest Bancshares, Inc., Houston, Tex., the bank
holding company which will acquire the resulting bank,
was organized in 1970, and currently owns Bank of
the Southwest, National Association, Houston; Village
National Bank, Houston; and the First National Bank
in Longview. The Bank of the Southwest, National Association, with total assets of $837 million and deposits

of $666.7 million, is the lead bank in the holding company's group of subsidiaries. In addition to the aforementioned, Southwest Bancshares has investments in
five other Houston-area banks as well as a bank in Kilgore, Tex. Those affiliated banks have aggregate deposits of $126.7 million; the largest of them is the Western National Bank, with total deposits of $42 million.
There is no competition between the merging bank
and any subsidiary or affiliate of Southwest Bancshares.
The merging bank is situated approximately 70 miles
from the Houston subsidiaries of Southwest Bancshares,
and approximately 200 miles from the Longview and
Kilgore affiliates of the holding company. Those large
distances preclude any competition between the banks
involved in this application. The resulting bank will

conduct the same business at the same location and with
the same name as presently used by the merging bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and is,
therefore, approved.
SEPTEMBER 6,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank of Port Arthur would become a
subsidiary of Southwest Bancshares, Inc., a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Southwest Bancshares,
Inc., it would have no effect on comoetition

T H E AMERICAN NATIONAL BANK OF BEAUMONT, BEAUMONT, TEX., AND PARK STREET BANK NATIONAL ASSOCIATION, BEAUMONT, TEX.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The American National Bank of Beaumont, Beaumont, Tex. (5825), with
and Park Street Bank National Association, Beaumont, Tex. (5825), which had...
merged Oct. 12, 1972, under charter of the latter bank (5825) and title "The
American National Bank of Beaumont." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On August 12, 1971, Park Street Bank National Association (organizing), Beaumont, Tex., and The
American National Bank of Beaumont, Beaumont,
Tex., applied to the Comptroller of the Currency for
permission to merge under the charter of the former
and with the title of the latter.
The American National Bank of Beaumont, Beaumont, Tex., the merging bank, is headquartered in
Beaumont, Tex. The bank, with total resources of
$112 million and IPC deposits of $66.7 million, was
chartered in 1901.
Park Street Bank National Association, Beaumont,
Tex., the charter bank, is being organized to provide
a vehicle to transfer ownership of the merging bank
to Texas Commerce Bancshares, Inc., a Delawarebased bank holding company.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

158



$126,362,426
240, 000

1
0

126,602,426

1

adverse competitive effect resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same location
and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The
application is, therefore, approved.
SEPTEMBER 11,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Park Street National Association (org.) would
become a subsidiary of Texas Commerce Bankshares,
a bank holding company. The instant merger, however, would merely combine an existing bank with a
non-operating institution; as such, and without regard
to the acquisition of the surviving bank by Texas
Commerce Bankshares, it would have no effect on
competition.

THIRD NATIONAL BANK OF HAMPDEN COUNTY, SPRINGFIELD, MASS., AND THIRD BANK OF HAMPDEN COUNTY
(NATIONAL ASSOCIATION), SPRINGFIELD, MASS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Third National Bank of Hampden County, Springfield, Mass. (308), with
and Third Bank of Hampden County, (National Association), Springfield, Mass.
(308), which had
merged Oct. 17, 1972, under charter of the latter bank (308) and title "Third
National Bank of Hampden County." The merged bank at date of merger had.. .

COMPTROLLER'S DECISION

On July 3, 1972, the Third National Bank of Hampden County, Springfield, Mass., and the Third Bank
of Hampden County, (National Association) (organizing) , Springfield, Mass., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
Third National Bank of Hampden County, the merging bank, is headquartered in Springfield, and has
18 offices located throughout Springfield and the surrounding area. The bank, with total resources of $248.9
million and IPC deposits of $180.2 million, was chartered originally in 1864.
Third Bank of Hampden County, (National Association) , the charter bank, is being organized to provide
a vehicle to transfer ownership of the merging bank
to the T.N.B. Financial Corp. The charter bank will
not be operating as a commercial bank prior to the
merger.
Because the merging bank is the only operating

$265, 344, 541

To be
operated

19

240, 000

0

265, 584, 541

19

bank involved in the proposed transaction, there can
be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting
bank will conduct the same banking business at the
same locations and with the same name as presently
used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
SEPTEMBER 6,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Third National Bank of Hampden County would
become a subsidiary of T.N.B. Financial Corp., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by T.N.B. Financial Corp.,
it would have no effect on competition.

CITY NATIONAL BANK OF DETROIT, DETROIT, MICH., AND CNB NATIONAL BANK, DETROIT, MICH.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

City National Bank of Detroit, Detroit, Mich. (14925), with
and CNB National Bank, Detroit, Mich. (14925), which had
merged Oct. 31, 1972, under charter of the latter bank (14925) and title "City
National Bank of Detroit." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 9, 1972, the City National Bank of Detroit,
Detroit, Mich., and the CNB National Bank (organizing) , Detroit, Mich., applied to the Comptroller of the




$692, 091, 523
250, 000
692, 091, 523

To be
operated

31
0
31

Currency for permission to merge under the charter
of the latter and with the title of the former.
The City National Bank of Detroit, the merging
bank is headquartered in Detroit, Mich., and has 29
offices located throughout the Detroit Metropolitan

159

Area. The bank, with total resources of $759 million
and I PC deposits of $437 million, was chartered originally in 1949.
CNB National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the Northern States Financial
Corporation, Detroit, Mich. The charter bank will not
be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
SEPTEMBER 27,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
City National Bank of Detroit would become a subsidiary of Northern States Financial Corporation, a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Northern States
Financial Corporation, it would have no effect on competition.

FIRST NATIONAL BANK OF CANTON, CANTON, OHIO, AND T H E STARK COUNTY NATIONAL BANK, CANTON, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation

First National Bank of Canton, Canton, Ohio (76), with
and The Stark County National Bank, Canton, Ohio (76), which had
merged Oct. 31, 1972, under charter of the latter bank (76) and title "First
National Bank of Canton." The merged bank at date of merger had

COMPTROLLER'S DECISION

On January 21, 1972, the First National Bank of
Canton, Canton, Ohio, and The Stark County National Bank (organizing), Canton, Ohio, applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
of the former.
The First National Bank, the merging bank, is headquartered in Canton, Ohio, and has 10 offices located
throughout Stark County and one in Carroll County.
The bank, with total resources of $180.6 million and
IPC deposits of $141.9 million, was chartered in 1863.
The Stark County National Bank, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to The Central Bancorporation, Inc. The charter bank will not be operating
as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
in the proposed transaction, there is no competition
between the applicant institutions. The resulting bank
will continue to conduct the same banking business at
the locations now used by the merging bank.

160



$184,020,092
240, 000
184,031,459

To be
operated

11
0

11

The Central Bancorporation, Inc., was incorporated
under the laws of Delaware in 1968 for the purpose of
becoming a bank holding company. Presently the holding company controls the $518.9 million Central Trust
Company, Cincinnati, Ohio; the $26.2 million Citizens
National Bank of Marietta, Marietta, Ohio; the $24.5
million First Trust and Savings Company, Zanesville,
Ohio; and the $12.1 million Canal Winchester Bank,
Canal Winchester, Ohio. In addition, Bancorporation
is in the process of acquiring the $23 million Home
Banking Company, Saint Marys, Ohio. Through its
currently affiliated banks, the holding company has 34
banking offices operating throughout Ohio: the Central Trust Company operates 26 in Hamilton County;
the Citizens National Bank of Marietta operates two in
Washington County; the First Trust and Savings Bank
operates four in Muskingum County; and the Canal
Winchester Bank operates two offices in Franklin
County. As the nearest office of one of the aforementioned banks to the merging bank is at least 100 miles
away, there is no meaningful competition between the
merging bank and a present subsidiary of the Central
Bancorporation.

It is believed that consummation of the subject proposal will not have any adverse competitive effects on
the banking structure in the service area of the merging
bank. Canton supports four other institutions: the
$55.2 million Canton National Bank; the $27.6 million
Dime Bank; the $208.4 million Harter Bank and Trust
Company; and, the $109 million Peoples-Merchants
Trust Company, all of which effectively compete with
the merging bank. Within the remaining service area of
the merging bank, 14 other banks operate 50 branch
offices and provide competition.
Approval of the proposed merger will improve the
merging bank's ability to meet the community's demands for increased credit services and more sophisticated banking services. It is contemplated that the
merger and subsequent affiliation with Central Bancorporation will provide the Canton service area with
comprehensive trust services, mortgage lending serv-

ices, accounts receivable and inventory financing, international financial guidance, and small business installment lending services.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest, and the
application is, therefore, approved.
SEPTEMBER 11,

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Stark County National Bank (org.) would become a
subsidiary of Central Bancorporation, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Central Bancorporation,
Inc., it would have no effect on competition.

THE SECOND NATIONAL BANK OF ORANGE, ORANGE, N.J.,
ORANGE,

1972.

AND THE THIRD NATIONAL BANK OF ORANGE,

N.J.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The Second National Bank of Orange, Orange, N.J. (4724), with
and The Third National Bank of Orange, Orange, N.J. (4724), which had
merged Nov. 1, 1972, under charter of the latter bank (4724) and title "The
Second National Bank of Orange." The merged bank at date of merger had

COMPTROLLER S DECISION

On May 9, 1972, The Second National Bank of
Orange, Orange, N.J., and The Third National Bank
of Orange (organizing), Orange, N.J., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of the
former.
The Second National Bank of Orange, the merging
bank, is headquartered in Orange, N.J., and has two
other offices in that city. The bank, with total resources
of $43.3 million and IPC deposits of $35.4 million, was
chartered in 1892.
The Third National Bank of Orange, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to United Jersey Banks,
a New Jersey general business corporation organized as
a registered bank holding company. That new bank will
survive the proposed merger and will function as a sub-




$45, 982, 262
120, 000
45, 985, 862

To be
operated

b
3

sidiary of United Jersey Banks. The charter bank will
not be operating as a commercial bank prior to the
merger.
United Jersey Banks, Hackensack, N.J., the prospective owner of the resulting bank, is a registered bank
holding company organized in 1969. At the end of
1971, the applicant had total assets of $1.2 billion and
controlled total deposits of $1.1 billion through its subsidiaries. It presently owns 10 commercial banks in the
State of New Jersey and ranks second in size in New
Jersey with respect to volume of total deposits.
United Jersey Banks faces strong competition from
several other large bank holding companies in New
Jersey as well as the large independent banks in the
State and in New York City. Competition in the
Orange area is provided by offices of First National
State Bank of New Jersey, Newark, with total deposits
of $930 million; and National Newark and Essex Bank,
Newark, with total deposits of $730 million, which is a

161

member of Midlantic Banks, Inc., a multi-bank holding
company with total deposits of $841 million. Mutual
savings banks, permitted by New Jersey law to offer
personal checking accounts, also furnish competition.
The United States Savings Bank, Newark, with total
deposits of $315 million, and Orange Savings Bank,
Orange, with deposits of $137 million are two of the
large mutual savings banks in the Orange area.
There is no competition between the present subsidiaries of United Jersey Banks and The Second National Bank of Orange because of the distance
separating the closest offices of the two and because
of the number and size of competitors in the intervening distances. The nearest office of a United Jersey
Banks subsidiary is 7.7 miles from Orange. Consummation of the proposed acquisition would provide increased banking facilities to the businesses and residents

of the area and thereby stimulate competition rather
than restrict it.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
SEPTEMBER 6,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Second National Bank of Orange would become
a subsidiary of United Jersey Banks, a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition
of the surviving bank by United Jersey Banks, it
would have no effect on competition.

CITIZENS NATIONAL BANK OF SOUTH JERSEY, BRIDGETON, N.J., AND SECOND CITIZENS NATIONAL BANK OF SOUTH
JERSEY, BRIDGETON, N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Citizens National Bank of South Jersey, Bridgeton, N.J. (2999), with
and Second Citizens National Bank of South Jersey, Bridgeton, N.J. (2999),
which had
merged Nov. 2, 1972, under charter of the latter bank (2999) and title "Citizens
National Bank of South Jersey." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 17, 1972, the Citizens National Bank of
South Jersey, Bridgeton, N.J., and the Second Citizens
National Bank of South Jersey (organizing), Bridgeton,
N.J., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter
and with the title of the former.
The Citizens National Bank of South Jersey, the
merging bank, is headquartered in Bridgeton, and
operates four offices, two in Bridgeton and one each
in West Cape May and in Woodbine. The bank, with
total resources of $20.3 million and IPC deposits of
$15.7 million, was organized as the result of a merger
between Citizens National Bank of South Jersey, Woodbine, and Bridgeton National Bank, Bridgeton, on
January 14, 1972.
Second Citizens National Bank of South Jersey,
Bridgeton, the charter bank, is being organized to provide a vehicle to transfer ownership of the merging

162



To be
operated

$23,017,511

4

120, 006

0

23,017,511

4

bank to Citizens Bancorp, Vineland, N.J., a multibank holding company. The charter bank will not be
operating as a commercial bank prior to the merger.
Citizens Bancorp, the prospective owner of the resulting bank, was organized in 1969, and is the smallest
multi-bank holding company in New Jersey. The applicant controls two banks; Citizens State Bank, Vineland, and Continental Bank of New Jersey, Maple
Shade. Through those two subsidiaries, the applicant
operates five banking offices in New Jersey's Third
Banking District which have aggregate deposits of
$22 million. Citizens Bancorp faces strong competition
from four multi-bank holding companies which operate
subsidiaries in the Third Banking District. Two of
those competing holding companies control deposits
of over $1 billion. Locally-based independent banks in
Cumberland and Cape May counties provide additional competition. The principal competitors of Citizens National Bank of South Jersey include Farmers

and Merchants National Bank, Bridgeton, with deposits
of $33 million, and Cumberland National, Bank of
Bridgeton, with deposits of $28 million.
Competition between Citizens National Bank of
South Jersey and any subsidiary of Citizens Bancorp is
negligible. The nearest office of a Citizens Bancorp
subsidiary to an office of Citizens National Bank of
South Jersey is 15 miles distant. That distance, as well
as the large number of banking alternatives, prevents
the holding company from competing with its prospective subsidiary. Acquisition of Citizens National
Bank of South Jersey by Citizens Bancorp should result in an increase rather than a diminution in competition. The new subsidiary will offer such expanded
services as overdraft checking, data processing services,
consumer oriented loans, and an expanded trust department. Those improved services will allow the resulting subsidiary to compete more effectively with
the large commercial banks in its trade area and will,
therefore, stimulate competition.
In regard to the merger of Citizens National Bank
of South Jersey with Second Citizens National Bank of

THE

South Jersey, there will be no adverse competitive
effect. Because the merging bank is the only operating bank involved in the proposed transactions, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The resulting bank will conduct the same banking business
at the same locations and with the same name as
presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 2,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Citizens National Bank of South Jersey would
become a subsidiary of Citizens Bancorp, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating instituton; as such, and without regard to the
acquisition of the surviving bank by Citizens Bancorp,
it would have no effect on competition.

FIRST NATIONAL BANK OF MARLTON, MARLTON, N.J.,
MARLTON, N J .

AND SECOND NATIONAL BANK OF MARLTON,

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Marlton, Marlton, N J . (13125), with
and Second National Bank of Marlton, Marlton, N J . (13125), which had
merged Nov. 2, 1972, under charter of the latter bank (13125) and title "First
National Bank of Marlton." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 18, 1972, The First National Bank of Marlton, Marlton, N.J., and the Second National Bank of
Marlton (organizing), Marlton, N.J., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title "First
National Bank of Marlton".
The First National Bank of Marlton, the merging
bank, is headquartered in Marlton, in the Third Banking District of New Jersey. The bank, with total resources of $22 million and I PC deposits of $18.3 million, operates three offices in Burlington County, and
now ranks seventh in size of the 12 commercial banks
headquartered in Burlington County.




$24, 620, 853
120, 000
24,517,849

To be
operated

3
0
3

Second National Bank of Marlton, the charter bank,
is being organized to provide a vehicle to transfer the
ownership of the merging bank to the Citizens Bancorp., Vineland, N.J., a bank holding company. On
July 12, 1972, the Federal Reserve Board, approved
Citizens Bancorp's application to acquire ownership of
the bank. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating bank
here involved, there can be no adverse effect on competition resulting from consummation of the proposed
merger. Neither is there any significant competition
between the merging bank and the two existing banking subsidiaries of Citizens Bancorp. The resulting bank
will conduct the same banking business at the same

163

locations as presently used by the merging bank. Furthermore, considerations relating to the convenience
and needs of the communities to be served are consistent with approval of the application.
In weighing the factors of this case in light of the
statutory criteria, it is concluded that the proposed
merger is in the public interest. The application is,
therefore, approved.
OCTOBER 2,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank of Marlton would become a subsidiary of Citizens Bancorp, a bank holding company.
The instant merger, however, would merely combine
an existing bank with a non-operating institution; as
such, and without regard to the acquisition of the surviving bank by Citizens Bancorp, it would have no
effect on competition.

TRUST COMPANY OF OCEAN COUNTY, LAKEWOOD, N.J., AND FIRST NATIONAL STATE BANK OF OCEAN COUNTY,
LAKEWOOD, N.J.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Trust Company of Ocean County, Lakewood, N.J., with
and First National State Bank of Ocean County, Lakewood, NJ. (16035), which
had
merged Nov. 10, 1972, under charter and title of the latter bank (16035). The
merered bank at date of mercer had

COMPTROLLER S DECISION

On July 7, 1972, the Trust Company of Ocean
County, Lakewood, N.J., and the First National State
Bank of Ocean County (organizing), Lakewood, N.J.,
applied to the Comptroller of the Currency for permission to merge under the charter and title of the latter.
The Trust Company of Ocean County, the merging
bank, was originally chartered in 1934, and presently
has deposits of $31.2 million. The bank serves a population of approximately 75,000 persons who live in the
northeastern portion of Ocean County, the bank's primary service area. The county's most significant business factor is the resort industry; during the summer
the population doubles. The county has experienced
rapid population growth; it increased 92 percent over
the past 10 years, making it the fastest growing county
in the United States.
Trust Company of Ocean County ranked fourth in
size among six commercial banks serving the Ocean
County area and held $31.2 million in deposits, or 8
percent of the $387.6 million in deposits held by those
six banks. Competition is chiefly furnished by First
National Bank of Toms River, N J., with $198.2 million
in deposits; First State Bank of Ocean County, Toms
River, with $86.2 million in deposits; and the Pineland
State Bank, Bricktown, N.J., with $38.4 million in de-

164



To be
operated

$39, 786, 202

5

125,000

0

39, 786, 202

5

posits. In addition, an approved but unopened branch
of Peoples National Bank of New Jersey, Westmont,
with deposits of $220.3 million, and United Jersey National Bank of Ocean County, a newly chartered bank,
will provide aggressive competition. While none of the
present competing banks is affiliated with a holding
company, the newly chartered United Jersey National
Bank of Ocean County is a subsidiary of United Jersey
Banks, a multi-bank holding company with deposits
of $1.2 billion.
First National State Bank of Ocean County, Lakewood, N.J., the charter bank, is being organized to
provide a vehicle to transfer ownership of the merging
bank to First National State Bancorporation, Newark,
N.J. First National State Bancorporation is the largest
of eight registered multi-bank holding companies in
New Jersey. The holding company held $1.2 billion in
deposits, or 7.1 percent of the $17.1 billion total deposits of the commercial banks in New Jersey. Subsidiary banks of the holding company include First
National State Bank of New Jersey, Newark; First
National State Bank of North Jersey, Hackensack;
First National State Bank of Northwest Jersey, Succasunna; The Edison Bank, National Association,
South Plainfield; and First National State Bank of
Spring Lake, Spring Lake, N.J. The holding company
has also recently acquired Ridgefield Park Trust Com-

pany, Ridgefield Park, and the Security National Bank
of Trenton, Trenton, N. J.
The proposed merger will not significantly increase
the resources and deposits of First National State
Bancorporation which will remain about equal in size
to the United Jersey Banks, Hackensack, and Midlantic Banks, Inc., Newark, each having total resources
of over $1 billion.
The closest branch of any subsidiary of First National State Bancorporation to an office of the Trust
Company of Ocean County is the Sea Girt office of
The First National State Bank of Spring Lake, 12
miles from the county line office of the Trust Company of Ocean County in Lakewood. There are five
other banking offices in the intervening distance. The
Spring Lake bank cannot branch into Ocean County
because it lies within a different banking district.
Affiliation with First National State Bancorporation
will allow the Trust Company of Ocean County to fill
its increasing needs for financial resources and successor management. Further, it will enable the bank to
improve the quality and range of services it offers
within its service area, notably in its trust department

which has been referring business to competitors due
to a lack of expertise in this field. The affiliation with
the holding company should result in an enhancement
of competition.
It is apparent that there are no adverse competitive
effects since the number of banking alternatives will
remain unchanged and the concentration of banking
resources will increase only minimally.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 5,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Trust Company of Ocean County would become
a subsidiary of First National State Bancorporation, a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by First National
State Bancorporation, it would have no effect on
competition.

MELLON NATIONAL BANK AND TRUST COMPANY, PITTSBURGH, PA., AND MELLON BANK, N.A.,

PITTSBURGH, PA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Mellon National Bank and Trust Company, Pittsburgh, Pa. (6301), with
and Mellon Bank, N.A., Pittsburgh, Pa. (6301), which had
merged Nov. 28, 1972, under charter and title of the latter bank (6301). The
merged bank at date of merger had

COMPTROLLER S DECISION

On September 19, 1972, the Mellon National Bank
and Trust Company, Pittsburgh, Pa., and the Mellon
Bank, N.A. (organizing), Pittsburgh, Pa., applied to
the Comptroller of the Currency for permission to
merge under the charter and title of the latter. Mellon
National Bank and Trust Company, the merging bank,
is headquartered in Pittsburgh and has 95 offices located throughout the Pittsburgh area. The bank, with
total resources of $6.3 billion and IPC deposits of $2.9
billion, was chartered originally in 1902.
Mellon Bank, N.A., the charter bank, is being organized to provide a vehicle to transfer ownership of the




$4, 999, 445, 730
240, 000
4,999,455,613

To be
operated

98
0
98

merging bank to the Mellon National Corporation. The
charter bank will not be operating as a commercial
bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations as presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 26,

1972.

165

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Mellon National Bank and Trust Company would become a subsidiary of Mellon National Corporation, a
bank holding company. The instant merger, however,

HIGHLAND

NATIONAL

BANK

would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Mellon National Corporation, it would have no effect on competition.

OF NEWBURGH, NEWBURGH, N.Y.,
NEWBURGH, N.Y.

AND 385

BROADWAY

NATIONAL

BANK,

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Highland National Bank of Newburgh, Newburgh, N.Y. (1106), with
and 385 Broadway National Bank, Newburgh, N.Y. (1106), which had
merged Nov. 30, 1972, under charter of the latter bank (1106) and title "Highland
National Bank of Newburgh." The merged bank at date of merger had

COMPTROLLER S DECISION

On August 11, 1972, 385 Broadway National Bank
(organizing), Newburgh, N.Y., and Highland National Bank of Newburgh, Newburgh, N.Y., applied to
the Comptroller of the Currency for permission to
merge under the charter of the former and with the
title of the latter.
Highland National Bank of Newburgh, the merging
bank, with deposits of $55 million, operates one branch
in Vails Gate and one branch in Newburgh. All three
offices are located in Orange County and are within 4
miles of each other.
In its immediate service area the merging bank
competes with 10 other commercial banks. Of those
11 banks, which held deposits of $1.9 billion as of yearend 1971, Highland is the seventh largest. Of the 43
commercial banks headquartered in the Third Banking
District, which hold aggregate deposits of $3 billion,
Highland National Bank ranked 12th in size.
385 Broadway National Bank, the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to United Bank Corporation
of New York, the 10th largest registered bank holding
company headquartered in New York State. It presently controls two commercial banks, one in Albany
and the other in Buffalo which, at year-end 1971, held
total deposits of $1.1 billion. Its subsidiaries operate in
the Fourth and Ninth Banking Districts of New York.
The proposed acquisition will enable Highland National Bank to increase its capital structure, when
needed, through its parent corporation. In addition,

166



$67, 009, 252
120,000
67, 129, 252

To be
operated

3
0
3

the holding company anticipates providing a broader
scope of lending services to include leasing, commercial
mortgages, farm loans, term loans, and overdraft credit
through the bank which will also provide customers of
Highland National Bank expanded individual and corporate trust services, enable Highland to coordinate
the investment activities of its governmental customers,
and expand its present limited day-to-day computer
capabilities.
Competition will not be adversely affected by consummation of this transaction. Because the nearest
office of a subsidiary of United Bank Corporation of
New York to an office of the subject bank is over 54
miles away, there is little competition between them.
In the Newburgh area, the transaction will make the
merging bank, which is presently a small, relatively
ineffective competitor in its market area, a more significant competitive force, and thereby improve area
competition. In Albany and Buffalo, the addition of
the much smaller bank to the holding company system
will have a negligible effect. Statewide, the transaction
will have little effect since the applicant will continue
to rank as 10th largest holding company and its share
of statewide deposits will increase by only an insignificant amount. The resulting bank will conduct the same
banking business at the same locations as presently used
by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER5, 1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Highland National Bank of Newburgh would become a
subsidiary of United Bank Corporation of New York,
a bank holding company. The instant merger, how-

ever, would merely combine an existing bank with a
non-operating institution; as such, and without regard
to the acquisition of the surviving bank by United Bank
Corporation of New York, it would have no effect on
competition.

JEFFERSON NATIONAL BANK, LYNCHBURG, VA., AND JEFFERSON BANK, N.A.,

LYNCHBURG, VA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Jefferson National Bank, Lynchburg, Va. (15819), with
and Jefferson Bank, N.A., Lynchburg, Va. (15819), which had
merged Dec. 4, 1972, under charter of the latter bank (15819) and title "Jefferson
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 24, 1972, the Jefferson Bank, N.A. (organizing) , Lynchburg, Va., and the Jefferson National B ink,
Lynchburg, Va., applied to the Comptroller of the Currency for permission to merge under the charter of the
former and with the title of the latter.
The Jefferson National Bank, the merging bank, was
organized in August 1970, and operates as a unit bank.
It now has assets of $9.7 million and IPC deposits of
$6.2 million.
The Jefferson Bank, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership of
the merging bank to Virginia National Bankshares, Inc.
The charter bank will not be operating as a commercial
bank prior to this merger.
Competition between the Jefferson National Bank
and Virginia National Bankshares or its subsidiaries is
minimal. At present, that holding company operates
only one subsidiary, the Virginia National Bank. Although the Virginia National Bank operates 11 offices
in 53 communities in Virginia, that subsidiary has no
offices in the Lynchburg area. The nearest offices of the
Virginia National Bank to Lynchburg are located in




$10, 708,855
240, 000

To be
operated

1
0

10,948,855

1

Buena Vista, 38 miles to the northeast; at Farmville,
50 miles to the east; and at Dillwyn, 63 miles to the
northeast. Those relatively large distances and the
adequate number of intervening competitors effectively preclude the merging bank from competing with
the Virginia National Bank. The resulting bank will
conduct the same banking business at the same location
and with the same name as presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 27,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Jefferson National Bank would become a subsidiary of
Virginia National Bankshares, Inc., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition of
the surviving bank by Virginia National Bankshares,
Inc., it would have no effect on competition.

167

PEOPLES NATIONAL BANK OF HUNTSVILLE, HUNTSVILLE, ALA., AND ALABAMA NATIONAL BANK OF HUNTSVILLE,
HUNTSVILLE, ALA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Peoples National Bank of Huntsville, Huntsville, Ala. (15267), with
and Alabama National Bank of Huntsville, Huntsville, Ala. (15267), which had. .
merged Dec. 7, 1972, under charter of the latter bank (15267) and title "Peoples
National Bank of Huntsville." The merged bank at date of merger had

COMPTROLLER'S DECISION

On May 11, 1972, the Alabama National Bank of
Huntsville (organizing), Huntsville, Ala., and the
Peoples National Bank of Huntsville, Huntsville, Ala.,
applied to the Comptroller of the Currency for permission to merge under the charter of the former and
with the title of the latter.
The Peoples National Bank of Huntsville, the merging bank, was organized in 1964, and currently has
deposits of $22.8 million. Although the bank is in good
condition and has experienced substantial growth in
the past, future expansion appears to be limited to some
degree by its competitive market position and its inability to serve the increasingly sophisticated needs of
its trade area.
The merging bank competes with six commercial
banks including the First National Bank, Huntsville,
with deposits of $83.7 million and 12 operating
branches, which is affiliated with First Alabama Baneshares, Inc.; the State National Bank of Alabama,
Decatur, with deposits of $252.8 million and seven
operating branches, which is a member of Central
State National Corporation; the Henderson National
Bank, Huntsville, with deposits of $37 million and five
operating branches; and the Bank of Huntsville, with
deposits of $13.5 million and two operating branches.
The Alabama National Bank of Huntsville, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to The
Alabama Financial Group, Inc., a bank holding company. The charter bank will not be operating as a
commercial bank prior to this transaction.
The Alabama Financial Group, Inc., Birmingham,
Ala., is the registered bank holding company which

168



$28, 910, 627
250, 000

To be
operated

3
0

28, 692,794

3

will gain control of the resulting bank. The Alabama
Financial Group, Inc., wholly owns the Birmingham
Trust National Bank, Birmingham, Ala. That bank,
with deposits of $383.7 million, is the second largest
commercial bank in the State of Alabama, and is
the only subsidiary bank of this holding company. At
present, The Alabama Financial Group, Inc., has also
submitted an application to acquire the First National
Bank of Dothan, Dothan, Ala.
There is no competition between the present subsidiary of The Alabama Financial Group, Inc., and
the merging bank, as the only bank owned by the
holding company is in Birmingham, 110 miles southwest of the site of the Peoples National Bank of
Huntsville. Furthermore, the First National Bank of
Dothan is located 280 miles from the merging bank,
thereby foreclosing the possibility of any competition
between those two banks. The resulting bank will conduct the same banking business at the same location
and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 6,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Peoples National Bank of Huntsville would become a
subsidiary of Alabama Financial Group, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by Alabama Financial
Group, Inc., it would have no effect on competition.

THE FIRST NATIONAL BANK OF DOTHAN, DOTHAN, ALA., AND ALABAMA NATIONAL BANK OF DOTHAN, DOTHAN,
ALA.
Banking offices

Total assets

Name of bank and type of transaction

The First National Bank of Dothan, Dothan, Ala. (5249), with
and Alabama National Bank of Dothan, Dothan, Ala. (5249), which had
merged Dec. 22, 1972, under charter of the latter bank (5249) and title "The
First National Bank of Dothan." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 9, 1972, the Alabama National Bank of
Dothan (organizing), Dothan, Ala., and The First
National Bank of Dothan, Dothan, Ala., applied to
the Comptroller of the Currency for permission to
merge under the charter of the former and with the
title of the latter.
The First National Bank of Dothan, the merging
bank, was chartered in 1900, and currently has deposits
of $63.1 million. The bank is situated in the southeast
corner of Alabama in an area which has recently
experienced rapid economic growth as a result of
extensive highway development and an expansion of
existing air and water transportation facilities which
have fostered increased industrial growth. Although
The First National Bank of Dothan competes effectively in its market area, it is experiencing limitations
on its trade area. Credit requirements are increasing
and the bank finds correspondent participation too
limiting and inefficient.
The First National Bank of Dothan is presently
the largest bank in its trade area and competes with
the Dothan Bank and Trust Company, with deposits
of $34 million, and the City National Bank, Dothan,
with deposits of $13 million. Those two competing
banks operate seven branches with one additional
branch under construction. Three other smaller banks
compete but are located as much as 19 miles away.
The Alabama National Bank of Dothan, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to the Alabama Financial Group, Inc., a bank holding company formerly
known as the Birmingham Trust National Bank (or
B.T.N.B.) Corporation. The charter bank will not be
operating as a commercial bank prior to this
transaction.




$82,425,410
130,000

In
operation

To be
operated
7
0

83, 845, 126

1

The Alabama Financial Group, Inc., Wilmington,
Del, is the registered bank holding company which
will gain control of the resulting bank. The Alabama
Financial Group, Inc. wholly owns the Birmingham
Trust National Bank, Birmingham, Ala. That bank,
with deposits of $383.7 million, is the second largest
commercial bank in the State of Alabama, and is the
only subsidiary bank of the holding company. At
present, the Alabama Financial Group, under the
name B.T.N.B., has also submitted an application to
acquire the Peoples National Bank of Huntsville,
Huntsville, Ala.
There is no competition between the present subsidiary of the Alabama Financial Group, Inc. and the
merging bank, as the only bank owned by the holding
company is in Birmingham, approximately 200 miles
from Dothan. Furthermore, the Peoples National
Bank of Huntsville is located 280 miles from the
merging bank, thereby foreclosing the possibility of
any competition between those two banks. The resulting bank will conduct the same banking business
at the same location and with the same name as
presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 22,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
First National Bank of Dothan would become a subsidiary of Alabama Financial Group, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a non-operating institution; as such, and without regard to the
acquisition of the surviving bank by Alabama Financial
Group, Inc., it would have no effect on competition.

169

FIRST NATIONAL BANK IN ORANGE, ORANGE, TEX., AND NEW NATIONAL BANK IN ORANGE, ORANGE, TEX.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

First National Bank in Orange, Orange, Tex. (13661), with
and New National Bank in Orange, Orange, Tex. (13661), which had
merged Dec. 28, 1972, under charter of the latter bank (13661) and title "First
National Bank in Orange." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 8, 1972, the First National Bank in
Orange, Orange, Tex., and the New National Bank
in Orange (organizing), Orange, Tex., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
The First National Bank in Orange, the merging
bank, was organized in 1889, and operates as a unit
institution in compliance with State law. The bank
has assets of $32.9 million and IPC deposits of $22.4
million.
The New National Bank in Orange, the charter
bank, is being organized to provide a vehicle by which
to transfer ownership of the merging bank to the First
City Bancorporation of Texas, Inc. The charter bank
will not be operating as a commercial bank prior to
this merger.
The First City Bancorporation of Texas, Inc., the
holding company which will acquire the resulting bank,
is headquartered in Houston. The principal subsidiary
of that holding company is the First City National
Bank of Houston, which is the largest commercial bank
in Harris County and the third largest bank in the
State. That bank has deposits of $1.3 billion.
There is no competition between the applicant or

BANK OF CALEDONIA, CALEDONIA, N.Y.,

$34, 265, 412
120, 000

To be
operated
1
0

34, 269, 012

1

its subsidiaries and the First National Bank in Orange
because of the large distances which separate the closest
banks and the adequate number of banking alternatives in the intervening distances. The First National
Bank in Orange is located approximately 112 miles
east of Houston, which effectively prevents it from
competing with any of the subsidiaries of the First
City Bancorporation of Texas. The resulting bank will
conduct the same banking business at the same location
and with the same name as presently used by the
merging bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 28,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which First National Bank in Orange would become
a subsidiary of First City Bancorporation of Texas,
Inc., a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by First
City Bancorporation of Texas, Inc., it would have no
effect on competition.

AND CHASE MANHATTAN BANK OF GREATER ROCHESTER (NATIONAL

ASSOCIATION), CALEDONIA,

N.Y.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

Bank of Caledonia, Caledonia, N.Y., with
and Chase Manhattan Bank of Greater Rochester (National Association), Caledonia N.Y. (16050) which had
merged Dec. 29, 1972, under charter and title of the latter bank (16050) . The
merged bank at date of merger had

170



To be
operated

$11,095,453

2

56, 296

0

11, 144,622

2

COMPTROLLER'S DECISION

On July 31, 1972, Chase Manhattan Bank of
Greater Rochester (National Association) (organizing), Caledonia, N.Y., and the Bank of Caledonia,
Caledonia, N.Y., applied to the Comptroller of the
Currency for permission to merge under the charter
and title of the former.
The Bank of Caledonia, the merging bank, was
chartered in 1900, and presently has deposits of $8.8
million. The bank, located in New York's Eighth Banking District, has its head office in the village of
Caledonia, which had a population of 2,327 in 1970.
It has a single branch in the village of Scottsville,
which had a population of 1,967 in 1970. The bank's
service area consists of the four contiguous towns of
Caledonia and York, in northwest Livingston County,
and Wheatland and Rush, in southern Monroe County.
That service area had a population of 14,550 in 1970.
There are no competing commercial banks within
a 6.5-mile radius of either office of the Bank of
Caledonia. Eight banks are less than 16 miles from
an office of the Bank of Caledonia and provide some
degree of competition. A number of those banks are
affiliated with bank holding companies or are in the
process of such affiliation. As various specialized banking services not usually undertaken by small banks are
implemented by virtue of those affiliations, the Bank
of Caledonia will find it increasingly difficult to maintain its presently limited share of the market which is
0.4 percent of total bank assets in the Eighth District.
Chase Manhattan Bank of Greater Rochester (National Association), Caledonia, N.Y., is being organized to provide a vehicle to transfer ownership of the
merging bank to Chase Manhattan Corporation. Chase
Manhattan Corporation presently controls the Chase
Manhattan Bank (National Association), New York,
N.Y., and the Chase Manhattan Bank of Long Island
(National Association), Melville, N.Y. Chase Manhattan Corporation has no banking operations in New




York's Eighth Banking District and views the proposed
acquisition as a means of entry into this area. The
Eighth Banking District is highly concentrated, with
the four largest banks holding 85.1 percent of the total
assets and 70.7 percent of all operating offices as of December 1971. As the nearest office of a subsidiary of the
Chase Manhattan Corporation is 327 miles from
Caledonia, no adverse effects on competition should
result from the proposed merger and acquisition. The
Chase Manhattan Corporation's entry into the Eighth
Banking District will provide strong competition for
the area's four major banks.
Affiliation with Chase Manhattan Corporation will
give the resulting bank access to the financial and
managerial resources of the holding company's principal subsidiary, the Chase Manhattan Bank (National
Association). Thus, the proposed merger will help
the resulting bank better meet the needs of the community it serves. As a result of this merger, the consumer or businessman will, for the first time in this
area, be able to take care of all his banking needs at
one bank.
The proposed acquisition will not significally increase the resources and deposits of the Chase Manhattan Corporation.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 29,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
Bank of Caledonia would become a subsidiary to The
Chase Manhattan Corporation, a bank holding company. The instant merger, however, would merely
combine an existing bank with a non-operating institution; as such, and without regard to the acquisition
of the surviving bank by The Chase Manhattan Corporation, it would have no effect on competition.

EXCHANGE NATIONAL BANK OF CHICAGO, CHICAGO, I I I . , AND EXCHANGE CHICAGO BANK, NATIONAL ASSOCIATION,
CHICAGO, I I I .
Banking offices

Total assets

Name of bank and type of transaction

In
operation

Exchange National Bank of Chicago, Chicago, 111. (12945), with
and Exchange Chicago Bank, National Association, Chicago, 111. (12945), which
had
merged Dec. 31, 1972, under charter of the latter bank (12945) and title "Exchange National Bank of Chicago." The merged bank at date of merger had

COMPTROLLER S DECISION

On April 17, 1972, the Exchange Chicago Bank,
National Association (organizing), Chicago, 111., and
the Exchange National Bank of Chicago, Chicago,
111., applied to the Comptroller of the Currency for
permission to merge under the charter of the former
and with the title of the latter.
The Exchange National Bank of Chicago, the
merging bank, was organized in 1926, and is currently the sixth largest bank headquartered in Chicago.
The bank has assets of $367 million and IPC deposits of $299.7 million.
The Exchange Chicago Bank, National Association,
the charter bank, is being organized to provide a vehicle to transfer ownership of the merging bank to
the Exchange International Corporation, which wishes
to become a one-bank holding company. The charter
bank will not be operating as a commercial bank prior
to this merger.
Since the merging bank is the only operating bank

To be
operated

$416, 140, 383

1

250, 000

0

416, 150, 142

1

involved in the proposed transaction, there can be
no adverse effect on competition resulting from consummation of the proposed merger. The resulting
bank will conduct the same banking business at the
same location and with the same name as presently
used by the merging bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 28,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Exchange National Bank of Chicago would become a subsidiary of Exchange International Corporation, a bank holding company. The instant merger,
however, would merely combine an existing bank with
a non-operating institution; as such, and without regard to the acquisition of the surviving bank by Exchange International Corporation, it would have no
effect on competition.

FIRST NATIONAL BANK IN DALLAS, DALLAS, TEX., AND FIRST BANK, NATIONAL ASSOCIATION, DALLAS, TEX.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

First National Bank in Dallas, Dallas, Tex. (3623), with
and First Bank, National Association, Dallas, Tex. (3623), which had
merged Dec. 31, iQ79, under charter of the latter bank (3623) and title "First
National Bank in Dallas." The merged bank at date of merger had

COMPTROLLER S DECISION

On June 6, 1972, the First National Bank in Dallas,
Dallas, Tex., and the First Bank, National Association
(organizing), Dallas, Tex., applied to the Comptroller

172



$2, 525, 832, 730
250, 000
2, 526, 082, 730

To be
operated

1
0

1

of the Currency for permission to merge under the
charter of the latter and with the title of the former.
The First National Bank in Dallas, the merging
bank, was originally organized in 1875, and operates

as a unit institution in conformity with State law. The
bank has assets of $2.5 billion and IPG deposits of
$958 million.
The First Bank, National Association, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to First International
Bancshares, Inc. The charter bank will not be operating
as a commercial bank prior to the merger.
Although First International Bancshares, the resulting holding company, is newly organized and has no
prior financial history, it has filed an application to
acquire the Houston-Citizens Bank and Trust Company as well as the resulting bank. There is no competition between the two proposed subsidiaries because
large distances separate the two banks and an adequate
number of competitors operate in the intervening distance. Dallas and Houston are separated by approximately 230 miles which effectively precludes any direct
competition between the First National Bank in Dallas

and the Houston-Citizens Bank and Trust Company.
The resulting bank will conduct the same banking
business at the same location and with the same name
as presently used by the merging bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
DECEMBER 1,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which First National Bank in Dallas would become
a subsidiary of First International Bancshares, Inc., a
bank holding company. The instant merger, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by First International Bancshares, Inc., it would have no effect
on competition.

NATIONAL CENTRAL BANK, LANCASTER, PA., AND THE KING STREET BANK, N.A.,

LANCASTER, PA.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

National Central Bank, Lancaster, Pa. (694), with
and The King Street Bank, N.A., Lancaster, Pa. (694), which had
merged Dec. 31, 1972, under charter of the latter bank (694) and title "National
Central Bank." The merged bank at date of merger had
COMPTROLLERS DECISION

On July 31, 1972, the National Central Bank, Lancater, Pa., and The King Street Bank, N.A. (organizing) , Lancaster, Pa., applied to the Comptroller of
the Currency for permission to merge under the charter
of the latter and with the title of the former.
National Central Bank, the merging bank, is headquartered in Lancaster, Pa., and has offices located
throughout Berks, Dauphin, Lancaster, and York
counties. The bank has total resources of $711.5 million and IPC deposits of $545 million.
The King Street Bank, N.A., the charter bank, is
being organized to provide a vehicle to transfer ownership of the merging bank to the National Central Financial Corporation, Lancaster, Pa. The charter bank
will not be operating as a commercial bank prior to
the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no




$736, 826, 803
240, 000

To be
operated

40
0

736, 834, 003

40

adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will
conduct the same banking business at the same locations and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 27,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through which
National Central Bank would become a subsidiary of
National Central Financial Corporation, a bank holding company. The instant merger, however, would
merely combine an existing bank with a non-operating
institution; as such, and without regard to the acquisition of the surviving bank by National Central Financial Corporation, it would have no effect on competition.

173

/ / / . Additional approvals
A. Approved, but in litigation
THE

PEOPLES

NATIONAL

BANK,

GREENVILLE, S.C,
AND BANKERS TRUST
COLUMBIA, S.C.

CO.

OF

SOUTH

CAROLINA,

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Bankers Trust Go. of South Carolina, Columbia, S.C, with
and The Peoples National Bank, Greenville, S.G. (10635), which had
applied for permission to consolidate Feb. 10, 1972, under charter of the latter
bank (10635) and title "Bankers Trust of South Carolina, N.A." The application
was approved June 12, 1972. The pending consolidation was challenged by Justice
Department July 11, 1972, and is presently in litigation

COMPTROLLER S DECISION

On February 10, 1972, The Peoples National Bank,
Greenville, S.C, and the Bankers Trust Company of
South Carolina, Columbia, S.C, applied to the Comptroller of the Currency for permission to consolidate
under the charter of the former and with the title,
"Bankers Trust of South Carolina, N.A." with its main
office in Columbia, S.C
The Peoples National Bank, the applicant, was organized in 1887 and is currently the seventh largest bank
in South Carolina. The bank is headquartered in
Greenville, the third largest metropolitan area in South
Carolina, situated in the northern tip of the State. The
Peoples National Bank now operates 18 offices throughout greater Greenville, Simpsonville, Seneca, Greer,
and Woodruff, and has assets of $117 million and I PC
deposits of $93.5 million.
The service area of the applicant extends through
Greenville County and parts of Oconee and Spartanburg counties. The economy of that area, while the
second strongest in South Carolina, is almost wholly
dependent on the manufacture of textiles and related
industries which produce seasonal unemployment and
volatile market conditions. That type of economy places
a great stress on the asset structure of a bank by forcing
it to contend with the variable seasonal adjustments
to both credit and deposit needs.
The Peoples National Bank is situated in an area
of intense banking competition, relative to the State of
South Carolina. The area is served by offices of the
South Carolina National Bank of South Carolina, with
deposits of $338.9 million; the Southern Bank and
Trust Company, with deposits of $94 million; and a

174



$266, 614, 000
116,899,000

To be
operated

52
20

local unit bank, First Piedmont Bank and Trust Company, with deposits of $16.5 million.
Bankers Trust Company of South Carolina, the consolidating bank, was established in 1886. It currently
has assets of $266.6 million and IPC deposits of $195
million. Since 1959, the bank has been involved in an
aggressive program of expansion from which it has
emerged the fourth largest bank in the State, with 51
operating offices in 28 communities throughout central
and western South Carolina.
The service area of Bankers Trust Company extends
west of an imaginary line from Charleston through
Columbia and Whitemire to Pickens, S.C, representing in excess of half the land mass of the State. Such a
large area must inevitably serve a diversified economy
including areas of rural agriculture as well as centers of
commercial and industrial activity. In serving the wide
variety of business needs presented by that diversified
economic base, Bankers Trust Company of South
Carolina has been forced to develop many areas of
financial specialty. The consolidating bank is, therefore, truly a "full-service" commercial bank.
Bankers Trust Company of South Carolina competes directly with the main offices of Citizens and
Southern National Bank of South Carolina, the South
Carolina National Bank, and the First National Bank
of Columbia, each with deposits in excess of $240 million. The consolidating bank also competes, through its
many branches, with all of the locally-based banks scattered throughout its service area.
Consummation of the proposed consolidation will
not eliminate any competition between the two proponents of the application since the Bankers Trust
Company of South Carolina and Peoples National

Bank do not now compete with each other. Neither of
the two banks have any offices in any town or county
served by the other. The nearest offices of the two banks
are in Seneca and in the town of Six Mile, situated 23
miles apart. Pickens, where Bankers Trust Company
also has a branch, is located 25 miles from Greenville.
A survey conducted by the two banks indicates that
Peoples National Bank derives in excess of 97 percent of
its deposits from the three counties in which it maintains offices. Those counties are Greenville, Oconee,
and Spartanburg. The same survey also indicated that
Bankers Trust Company derives only 0.6 percent of its
deposits from those same three counties. From that information it is evident that neither of the two banks
offers a substantial degree of competition to the other.
Thus, consumer choice would not be reduced by the
successful completion of the consolidation.
A second standpoint from which to look at competition is through an examination of the economy of the
area in which The Peoples National Bank is located, as
well as the number and size of the banks already established there. From that it is readily apparent that
the area is presently saturated in terms of banking competition. The unstable character of the textile industry
and the seasonal variations involving employment and
credit needs has caused The Peoples National Bank to
show no increase in profit in the past 3 years. That indicates that the area in question could not easily support the entrance of an additional bank. For Bankers
Trust Company to enter this region through de novo
branching would require it to spend an inordinate
amount of time and money to become a sizable competitor in the area; the projected profit from such entry
would not justify the size of the expenditure required.
Consolidation with The Peoples Naipnal Bank is, therefore, the most practical way for Bankers Trust Company to expand into this area.
The converse of the previous issue is to determine
whether The Peoples National Bank could become a
statewide competitor that might compete with the
present offices of Bankers Trust Company of South
Carolina. As, in its 90 years of existence, The Peoples
National Bank has not shown a desire nor made any
effort to expand from its regional position, there is no
reason to infer that The Peoples National Bank will
initiate such an expansion in the near future.
The relative poverty of the State of South Carolina
inhibits the growth of banks and encourages the larger
industrial firms in the State to seek out-of-state financing. Most of the profitable large loan business in South
Carolina is being lost to out-of-state financial institu-




tions. The largest bank in the State has assets of only
$600 million, indicating the significant disadvantage
encountered by in-state banks in trying to service large
loan demands. Through the consolidation, the resulting bank will become the third largest bank in the State
and will be in a position to offer stronger and more
effective competition to the largest banks in the State.
In addition, since South Carolina is already a financial
market dominated by Georgia and North Carolina
banks, the transaction will tend to dilute that outside influence.
The proposed consolidation will act to unify and
strengthen the banking system of South Carolina by
aiding the internal economic development of the State.
The Peoples National Bank will, as a result of the
consolidation, gain access to the specialized service
departments which Bankers Trust Company has developed in the past. Any suggestion of adverse competitive effects arising from the size of the resulting
bank will in reality be overshadowed by the benefits
which that resulting unit will have, both on the economy of the State and in the benefits to the communities which the resulting bank will serve. In addition,
the bank will only be the third largest bank in the
State, and will face strong competition with the larger,
statewide financial systems, as well as out-of-state
organizations that canvass the State for is prime banking business.
Applying the statutory criteria, it is concluded that
the proposed consolidation is in the public interest.
The application is, therefore, approved.
JUNE 12,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the two banks are about 110
miles apart. At the present time neither bank operates
offices in a county served by the other. Two offices of
Bankers Trust, however, are located in Pickens County,
between 20 and 30 miles from Greenville. Pickens
County is part of the Greenville Standard Metropolitan
Statistical Area ("SMSA"). Thus, there may be some
competition between these two offices of Bankers Trust
and Peoples which would be eliminated by the consolidation.
South Carolina law permits statewide branching by
commercial banks. Thus, both banks could enter the
markets served by the other either by de novo branching or through merger with a smaller competitor.
Bankers Trust and Peoples are the fourth and sixth
largest commercial banks, respectively. Only seven of
the 95 banks in the State hold total deposits in excess

175

of $100 million. Of these seven leading banks only two,
including Peoples, do not operate offices throughout
most of the State.
Peoples is the largest bank headquartered in Greenville. It holds 28.6 percent of county deposits, the
second largest share of deposits held by any bank in
Greenville County. Seven banks operate in the county,
with the two largest holding 62.9 percent and the four
largest, 88.2 percent. Thus, commercial banking in
Greenville County is highly concentrated. Three of the
seven large banks in the State do not presently operate
in Greenville County. Bankers Trust is the second largest of these three (and only about $30 million in deposits smaller than the largest). This consolidation,
therefore, would eliminate potential competition in
Greenville County between the second largest bank operating there and one of only a few significant potential entrants into that market.
Commercial banking in South Carolina has polarized

into two groups, one consisting of a few large banks,
operating regionally or statewide, and many small
banks, serving local communities. The position of the
leaders has been growing progressively stronger in the
State. If the consolidation of Bankers Trust and Peoples is approved, it will eliminate one of the few remaining banks capable of expanding into a full statewide competitor. It could also trigger other mergers
having a similar effect, thus eliminating further potential competition throughout the State.
Approval of this application would result in the
acquisition of the State's sixth largest banking organization by the State's fourth largest banking organization. This consolidation would eliminate each of the
two banks as potential entrants into banking markets
served by the other
and particularly Bankers Trust
as an entrant into Greenville. We therefore conclude
that the proposed consolidation would have a significantly adverse effect on competition.

B. Approved, but abandoned after litigation
WELLS FARGO BANK, NATIONAL ASSOCIATION, SAN FRANCISCO, CALIF., AND FIRST WESTERN BANK AND TRUST
COMPANY, LOS ANGELES, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First Western Bank and Trust Company, Los Angeles, Calif., with
and Wells Fargo Bank, National Association, San Francisco, Calif. (15660),
which had
applied for permission to merge Oct. 13, 1971, under charter and title of the
latter bank (15660). The application was approved Dec. 20, 1971, but was
abandoned by the banks Nov. 7, 1972, after filing of antitrust suit by the Justice
Department

COMPTROLLER S DECISION

On October 13, 1971, Wells Fargo Bank, National
Association, San Francisco, Calif., and First Western
Bank and Trust Company, Los Angeles, Calif., applied
to the Office of the Comptroller of the Currency for
permission to merge under the charter and with the
title of the former.
Wells Fargo, the charter bank, has total resources of
over $7 billion, and operates 292 branches, all but 38
of which are located in northern California. It is headquartered in San Francisco. The bank confined its
operations to northern California until 1967, when it
began a program of de novo branching in the southern
portion of the State. Because of declining economic

176



$1, 110,046,249

95

6, 209, 423, 244

To be
operated

295

conditions and reduction in the population growth rate
in that area, together with the multitude of banking
alternatives in southern California, the bank curtailed
its plans for further branch expansion in the south.
In addition, continued increases in start-up costs and
decreased profitability have forced the bank to limit its
competitive challenge there.
First Western, the merging bank, is headquartered
in Los Angeles, and has assets slightly in excess of
$1 billion. It operates 95 branches throughout the
State. First Western came into existence in 1961, as the
result of a settlement of antitrust litigation. That settlement required its predecessor, old First Western, to
sell 49 of its branches, many of which were located
in northern California, to a competitor, the United

California Bank. The remaining 65 branches, scattered
thinly throughout the State and representing, largely,
the smaller, newer, and less profitable branches of the
former bank, became the nucleus of the present and
structurally deficient First Western Bank. First Western
was required to open new headquarters in Los Angeles
and to give up its former San Francisco main office
together with its trust department and many of its
corporate and international customers. Since 1966,
attempts to expand through branching and to increase
its rate of growth have failed. From its inception, and
as of today, the average deposits of First Western
branches have ranged far below the average branch
deposits of all other California banks. Only one of
the 21 branches opened by First Western since 1966
has shown a profit and that profit has resulted largely
because some of the business at the main office in
Los Angeles was transferred to the branch. In early
1970, First Western determined to abandon its de
novo branch expansion program.
The most telling indication of First Western's inherent structural deficiency and inability to recover from
the spinoff in 1961, is that its market share has dropped
from 2 percent in 1961 to 1.8 percent as of December 31, 1970. The efforts of First Western to compete
successfully on a statewide basis have been further
hampered by the large dividends it has been required
to pay to its succession of owners in order to service
their purchase indebtedness. The average dividend
paid by First Western Bank between 1966 and 1970 was
86 percent of net income compared to a rate of 55 percent for the other large California banks. Because of
those dividend requirements, First Western has been
unable to retain sufficient earnings to permit it to embark on programs designed to make it an effective competitive factor in California.
The decision of its present owner, World America Investors Corp., a wholly-owned subsidiary of World Airways, Inc., to sell First Western was prompted by the
passage of the Bank Holding Company Act Amendments of 1970. World Airways, Inc. is the world's largest international supplemental air carrier and owns,
through its subsidiary, in excess of 99 percent of the
stock of First Western. By virtue of the amendments,
Wrorld Airways, Inc. became a bank holding company
subject to severe restrictions on the non-banking activities in which it could engage or into which it could expand in the future. Further, the Federal Reserve Board
must, within 2 years of the date of enactment, review
the interrelation of bank and non-bank activities of
holding companies. If it is determined that the activi-




ties of any subsidiary, which is engaged in business not
closely related to banking, would tend to affect the
bank adversely, the holding company must choose
either to sell the bank or to retain the bank and any
related subsidiaries and sell its holdings not related to
banking. The decision was made by World Airways,
Inc. to sell First Western in order to relieve itself of the
non-banking operating limitations imposed by the
amendments and to avoid the possibility of an adverse
hearing decision by the Federal Reserve Board. That
decision is consonant with the Congressional policy
against bank ownership by companies engaged in activities unrelated to banking.
That decision to sell required a purchaser or purchasers with sufficient resources to buy a bank of that
size. Though sought by First Western, no private investors with sufficient financial and operational qualifications were discovered. The several foreign banks that
expressed an interest in acquiring First Western and
analyzed its structure failed to make an offer. Depressed
market conditions preclude the prospect of making a
public offering. The Bank Holding Company Act
Amendments of 1970 prohibit non-bank holding corporations from purchasing First Western, thereby
eliminating a great number of potential purchasers
who would otherwise be interested in acquiring First
Western. A spinoff of the First Western shares to stockholders of World Airways, Inc. is not possible since
those shares have been pledged to secure a very substantial loan incurred by World America Investors
Corp. when it purchased such shares. The only remaining feasible approach was an acquisition by a California bank or bank holding company not widely represented in the southern part of the State. Wells Fargo,
which has adequate resources, operates relatively few
southern branches, so an agreement was reached between the two banks. Wells Fargo agreed that it will
sell the 41 branches of First Western which are located
in northern California to banks not heavily represented
in that area or to other purchasers.1
The proposal, contemplating the divestiture of those
41 branches, will not have any significant anticompetitive effects. Wells Fargo holds only 10.1 percent of the
total deposits held by all commercial banks in the State,
as of June 30, 1971. First Western holds only 1.8 percent of such deposits. With the divestment of the 41
branches operated by First Western in northern California, the resulting bank will hold approximately 11
percent of the total deposits in the State and its share
1

These branches are indentified on pp. 1-3 of appendix C
of the application.

177

in northern California would remain static at 19.5 percent. In the southern part of California, the resulting
bank will hold only 3 percent of the deposits. Only 38
of Wells Fargo's branches are located in southern
California, and of those, only eight appear to be in
competition with branches of First Western, which has
54 branches in southern California. Of the eight locations in which the two banks appear to compete, six
are in Los Angeles County where 58 banks having 939
banking offices are represented. In Orange County,
where two offices of Wells Fargo compete with two
offices of First Western, 25 banks operate 321 branches.
The receiving bank will be subject to intense competition from both larger and smaller banks in every area
in which it maintains an office.
The merger will benefit the customers of First Western and the general public. First Western, because of
its inherent shortcomings, has been unable, unlike all
other large California banks, to afford membership in
the Federal Reserve System, to pay daily interest on
passbook savings accounts, or to offer credit card services. Additionally, it offers very limited international
services and has trust departments at only seven locations. Its lending limit of $6.5 million causes major
California and National firms to look to the larger
banks for financing. Recently, for example, one of the
First Western's largest and oldest customers decided
to patronize only those banks having a lending limit
in excess of $10 million.
Wells Fargo has a full range of banking activities
to offer to the customers of First Western. It emphasizes
the full range of retail banking services which the
merging bank has been unable to provide. The customers of First Western will be able to rely on Wells
Fargo for student loans, mortgage loans, convenient
facilities, and up-to-date computerized information, as
well as those services presently unavailable through
First Western. Since the latter has been unable to
provide for research and development, its customers,
commercial and individual, will receive the benefit of
Wells Fargo's extensive experience with technical innovations and improved services such as investment
counselling, market analysis, and management science.
It is the conclusion of this Office that the proposal,
prompted as it is by an unusual legislative development, in the context of a unique fact situation, will
be in the public interest and will carry out the Congressional policy. It will produce no significant anticompetitive results. On the contrary, in northern California where Wells Fargo maintains the majority of
its branches, the purchaser or purchasers of the merg-

178



ing bank's northern branches will introduce additional
competition and, in southern California, the resulting
bank will hold only 3 percent of bank deposits. The
banking structure throughout the State will be affected only minimally and the thousands of customers
served by First Western will receive the benefit of the
widest range of services a modern bank can provide.
In the light of the foregoing facts it appears that
the subject application will have a minimal negative
effect upon competition in selective areas in southern
California, but will have a procompetitive effect on
banking throughout the State. It will clearly redound
to the public interest. The application, therefore, is
approved. However, the merger may not be consummated before the later of the following two dates:
(a) the 30th calendar day after the date of this approval, or (b) the date upon which Wells Fargo delivers
to this Office a certified copy of a definitive agreement
or agreements between Wells Fargo and one or more
purchasers satisfactory to this Office providing for
the sale of the 41 northern California branch offices
of First Western to be transferred within 90 days of
the consummation of the merger of Wells Fargo
and First Western, or as soon thereafter as all of the
requisite regulatory approvals to such sale have been
obtained.
DECEMBER 20,

1971.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger would eliminate direct competition between the parties in the whole cluster of
commercial banking services throughout much of the
State of California. It would also eliminate competition in at least two specialized submarkets
(i) correspondent banking and (ii) commercial and industrial
loans to intermediate-sized businesses.
Wells Fargo presently has offices in 43 of California's
55 counties; and First Western has offices in 21. Wells
Fargo operates offices in 18 of the counties in which
First Western operates; those 18 counties include most
of the metropolitan areas in the State (with the exception of San Diego), and so contain the great bulk of
the population of California.
Since some of these counties (for example, Los Angeles County and Orange County) are very large geographic areas with substantial population, smaller geographic areas within these counties may be appropriate
markets for testing the competitive effects in commercial banking.
Looked at another way, 51 of First Western's 95
offices are located less than 2 miles, often less than

1 mile, from a Wells Fargo office. These First Western
offices hold over 71 percent of its deposits. Hence,
whether viewed in terms of the State as a whole, the
counties in which both compete, or the immediate area
around the offices of each, the loss of direct competition is substantial.
The proposed merger will significantly increase the
concentration of banking resources in the State of
California
a State where the top five banks already
have almost 80 percent of deposits. Because of the widespread branching network and extensive competition
between the two banks throughout the State, it is not
unreasonable to use statewide concentration figures to
measure the aggregate effect of this merger on local
banking markets. According to the application, as of
June 30, 1970, Wells Fargo held approximately 10
percent of all deposits held by commercial banks in the
State of California and First Western held about 1.8
percent of such deposits. During the same period,
Wells Fargo controlled about 10.7 percent of all loans
by commercial banks and First Western controlled
about 1.8 percent of such loans.
Correspondent services are essential to smaller banks,
so that they can be effective competitors of the large
branch systems. Wells Fargo and First Western both
provide correspondent services to banks located
throughout California.
Inter-bank deposits held by banks are a measure of
the amount of correspondent business done by a bank.
The figures published in The American Banker indicate that Wells Fargo is the sixth largest and First
Western the eighth largest of the 18 commercial banks
based in California that offer correspondent services.
If this merger is consummated, Wells Fargo will be the

third largest bank in terms of domestic inter-bank
deposits.
Commercial and industrial lending is a recognized
primary aspect of a commercial bank's activity, but it
is also a specialized activity. Commercial and industrial
loans involve specialized credit evaluation and supervision.
Wells Fargo and First Western are two of only eight
major banking systems in California which have the
expertise and lending limits to make loans to intermediate-sized borrowers along with a substantial distribution of offices through which such loans can be
made and administered. As a result of the merger of
Wells Fargo and First Western, there will be a substantial elimination of existing competition in this kind of
lending. Concentration in the State will probably be
increased by at least the statewide deposit concentration of the two banks; it is probable that the combined
share of the merging banks will exceed 12 percent of
such loans in California.
California law permits commercial banks to operate
branch offices throughout the State. Each major bank
is, therefore, a significant potential entrant into those
areas of California which it does not serve and which
the other does serve. In addition, each is a significant
potential entrant into those areas of California served
by neither. Illustrative of the competitive potential
of these banks is Wells Fargo's vigorous8 expansion program into Southern California.
In view of the substantial reduction in both actual
and potential competition both in general commercial
banking services as well as in certain specified services,
we conclude that the proposed merger would have a
significantly adverse effect on competition.

THE NATIONAL BANK OF GEORGIA, ATLANTA, GA., AND BANK OF FULTON COUNTY, EAST POINT, GA.
Banking offices

Total assets

Name of bank and type of transaction

To be
operated

In
operation

Bank of Fulton County, East Point, Ga., with
and The National Bank of Georgia, Atlanta, Ga. (15541), which had
applied for permission to merge Sept. 29, 1971, under charter and title of the
latter bank (15541). The application was approved Jan. 11, 1972. The pending
merger was challenged by Justice Department Feb. 8, 1972, and is presently in
litigation

COMPTROLLER S DECISION

On September 29, 1971, the Bank of Fulton County,
East Point, Ga., and The National Bank of Georgia,



$32,617,000
174,481,000

2
20

Atlanta, Ga., applied to the Office of the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.

179

The National Bank of Georgia, with I PC deposits
of $110.4 million, was organized in 1911, and currently
operates 17 offices throughout Fulton and DeKalb
counties.
Atlanta, home of the charter bank, is the capital
of the State of Georgia and the county seat of Fulton
County. It has a well-diversified economic base and is
a major regional center in manufacturing, trade, finance, transportation, communications, government,
and education. Atlanta and the surrounding metropolitan areas constitute one of the fastest growing regions in the southeast. U.S. census data indicates that
the population of the Atlanta Standard Metropolitan
Statistical Area was 1.4 million on April 1, 1970, as
compared with 1.0 million on April 1, 1960.
The Bank of Fulton County, the merging bank, with
deposits of $24 million, was organized in 1934 and operates only one branch office within East Point.
East Point, Ga., home of the merging bank, with a
population estimated at 46,825 persons, is the State's
seventh largest city; in terms of area and the Greater
Atlanta Metropolitan Area it is relatively small. East
Point is situated directly between downtown Atlanta
and the Atlanta Municipal Airport and abuts the city
limits of Atlanta. The economy of the area is dependent on industry and manufacturing. The greatest single
factor in the economy is the presence of the Atlanta
Municipal Airport. Wholesale trade is also of importance.
The charter bank is the smallest of the five large
banks operating in Atlanta. The largest is Citizens and
Southern National Bank, Atlanta, with total deposits
of $1.4 billion, and the others are, First National
Bank, Atlanta, with total deposits of $789.2 million;
Trust Company of Georgia, with total deposits of
$825.7 million; and Fulton National Bank, with total
deposits of $408.2 million. Other banks in the combined service area include Citizens and Southern
Bank, East Point, Ga., with total deposits of $23.3
million; Bank of the South, College Park, Ga., with
total deposits of $13.7 million; and the Citizens Bank,
Hapeville, Ga., with total deposits of $17.4 million.
The charter bank, following the merger, would make
available, to present customers of the merging bank and
to other persons and corporations located within its
primary service area, banking services that are not
presently conveniently available. Among those would
be better, faster clearances in accounts with internally
operated data processing services; a fully-staffed and
experienced trust department; a fully-staffed and experienced mortgage lending department; higher credit
limits; the capital structure to develop new branches

180



as needed; a stronger and fully-staffed commercial department; resources and staff for more effective installment lending activity; a more effective advertising
and public relations department; and, freedom from
the need to raise new capital necessary to compete
effectively in all the above activities.
Competition will not be adversely affected by consummation of the transaction. Although some competition exists between the two merging institutions
because of the slight overlap of their service areas,
it is thought to be insignificant. In Atlanta, competition
should be improved since the charter bank will be in
a better position to compete with the four larger
banks operating there, and any smaller institutions
should not be seriously disadvantaged. In the East
Point area, the merging bank is presently the smallest
bank and consummation of the transaction would improve competition by making the East Point offices of
the resulting bank more effective competitors. Potential competition will not be affected; although Georgia
branching law has been changed to permit the large
Atlanta-based banks to branch de novo into Fulton
County, doing so wrould be economically unfeasible
for the charter bank and it is doubtful it would follow
this route.
Applying the statutory criteria it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
JANUARY 11,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

There are 17 banking offices, operated by seven
banking organizations, located within County Bank's
service area, including County Bank's two offices and
two offices of National Bank of Georgia. National
Bank of Georgia's office nearest to an office of County
Bank is located approximately 3 miles away. That
office is approximately 4 miles from County Bank's
other office. Together these three offices form a triangle in the central portion of County Bank's service
area, National Bank of Georgia's office being located
at the northern tip. There are no other banking offices
located within the triangle, although there are several
banking offices near the tips. National Bank of
Georgia's other office located within County Bank's
service area is approximately 5 and 6 miles northeast
of County Bank's two offices. Moreover, National Bank
of Georgia has recently received approval to establish
a branch office approximately 4.7 and 4.9 miles south
of County Bank's two offices.
Approximately 3.2 percent, or $4.9 million, of National Bank of Georgia's total deposits originate within

the service area of County Bank. This figure represents 17.3 percent of County Bank's total deposits.
Approximately 5.0 percent, or $2.5 million, of National
Bank of Georgia's total I PC demand deposits originate within the service area of County Bank. This
figure represents 17.0 percent of County Bank's total
IPC demand deposits. Virtually 100 percent of County
Bank's IPC demand and total deposits originate within
the service area of National Bank of Georgia.
There are a number of other banking offices, in addition to the two of National Bank of Georgia, that
compete directly with County Bank. Because of the
proximity of their offices and the degree of competitive overlap, however, it seems clear that significant
existing competition between County Bank and National Bank of Georgia will be permanently eliminated by this merger.
The suburban areas of Fulton County are not yet
dominated by the five large Atlanta banks to the same
extent that those banks dominate the city of Atlanta.
Since the change in the branch banking law on January 1, 1971, however, the large Atlanta banks have
attempted to acquire a large number of previously
"affiliated" suburban banks in both Fulton and adjoining DeKalb counties, thereby eliminating both existing
competition and the potential for future competition

WACHOVIA BANK AND TRUST COMPANY, N.A.,

which these banks represent. Three such acquisitions
of very small banks have already been made, two by
First National Bank of Atlanta and one by Trust Company of Georgia. Another proposed acquisition by
Trust Company was abandoned after suit was filed.
Seven additional proposed acquisitions, two by First
National and five by subsidiaries of Citizens and
Southern National Bank, are blocked by pending antitrust litigation.
The proposed merger involving one of Atlanta's
largest banks, would eliminate the largest completely
independent suburban bank in the Atlanta area and
one of only three independent banks (other than the
five large Atlanta banks) in the area with deposits of
over $20 million. Thus, one of the few
and hence
significant
sources of future competition to the
large Atlanta banks now moving into South Fulton
County and the suburbs generally would no longer
exist.
This merger would eliminate significant existing and
potential future competition. In addition, by eliminating the largest independent suburban bank in the
Atlanta area, the transfer of the concentrated market
structure of Atlanta to the suburban areas around the
city will be greatly facilitated. Therefore, we conclude
that the proposed merger would have a significantly
adverse effect on competition.

WINSTON-SALEM, N.C.,

AND BANK OF GRANITE, GRANITE FALLS,

N.C.
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Bank of Granite Granite Falls N.G. with
and Wachovia Bank and Trust Company, N.A., Winston-Salem, N.G. (15673),
which had
applied for permission to merge Aug. 1, 1972, under charter and title of the latter
bank (15673). The application was approved Nov. 3, 1972, but was abandoned
by the banks Dec 18 1972 after filing of antitrust suit by the Justice Department

COMPTROLLER S DECISION

On August 1, 1972, the Wachovia Bank and Trust
Company, N.A., Winston-Salem, N.C, and the Bank
of Granite, Granite Falls, N.C, applied to the Comptroller of the Currency for permission to merge under
the charter and with the title of the former.
The Wachovia Bank and Trust Company, N.A., the
charter bank, was organized in 1879. The bank, cur-




To be
operated

$22, 379, 572

5

2, 052, 003, 034

176

rently the largest commercial bank in North Carolina
with assets of $2 billion and IPC deposits of $1.3
billion, operates 175 branches in 64 communities
throughout the State. Wachovia Bank and Trust Company, with a large staff of capable management personnel which is more than sufficient to meet its present
needs and future plans for expansion has established
itself as a leader in offering innovative financial services to both corporations and individual customers.

181

As the largest commercial bank in North Carolina,
the charter bank competes with most of the statewide
and regional banks in the State. These competitors
include the North Carolina National Bank, the second
largest bank in the State, with total deposits of $1.5
billion; the First Union National Bank, the third
largest bank, with deposits of $1.1 billion; the First
Citizens Bank and Trust Company, the fourth largest,
with deposits of $715 million; and the Northwestern
Bank, the fifth largest bank in North Carolina, with
deposits of $631 million. The charter bank also competes with the smaller, local banks situated in the cities
and towns across the State in which it maintains active
branches.
The Bank of Granite, the merging bank, was organized in 1906, and currently has assets of $22.4 million
and IPC deposits of $16.3 million. The bank operates
four branches, two in Lenoir and one each in Hudson
and Hickory. It is the smallest financial institution in
its service area and does not have the financial resources to offer many of the specialized services which
its larger competitors offer. As a result, the Bank of
Granite has lost many customers and has been unable
to provide adequate depth in its management resources. In addition, because of its insufficient capitalization to open additional offices, it has been unable to
expand its financial resources. Because it is unable to
maintain a formalized recruiting program to assure
adequate experienced successor management, it is now
having difficulty in finding a replacement for its cashier
and sole operations officer who will retire at the end
of the current year.
The Bank of Granite competes in the towns of
Granite Falls, Hudson, and Lenoir, in Caldwell
County, and in the town of Hickory, in Catawba
County. The Hickory banking market is dominated by
the First National Bank of Catawba County which
operates six banking offices in Hickory and has deposits
of $114.5 million. That bank controls a majority of
the banking deposits and loans of the city which is
the economic focal point of the four surrounding
counties of Caldwell, Catawba, Alexander, and Burke.
Hickory is also served by several of the largest banks
in the State, including two offices of the North Carolina National Bank, the second largest bank in the
State, and five offices of the Northwestern Bank, the
fifth largest bank in North Carolina. In Caldwell
County, the merging bank has no direct competition
in Hudson, but competes with a branch of the Northwestern Bank in Granite Falls, and one branch each
of the Northwestern Bank and the First Union National Bank of North Carolina in Lenoir.

182



The service area of the Wachovia Bank and Trust
Company is multifaceted since the charter bank competes on several levels with a wide variety of banks.
In the 64 cities and towns in which it maintains
offices, the charter bank competes for local individual
and commercial business. Those markets are local in
nature and exist because a banking institution has
office facilities in a certain city or town. Those small,
local customers generally restrict their banking business to the city or town in which they live or in which
their business is domiciled because their banking needs
are limited and can usually be fulfilled by one or more
of the existing small banks in that particular locality.
In the area of general corporate and commercial
services the Wachovia Bank and Trust Company competes not only throughout the State of North Carolina
but also in international, national, and regional
markets. Those corporate and commercial customers
do not restrict banking relationships to the banks located in their own city but seek out sizeable banks that
are able to provide specialized services such as cash
management, large lines of credit, bond and corporate
trust services, and specialized financing arrangements
including large-scale leasing, which are unavailable
from smaller banks.
In contrast to the large markets serviced by the
charter bank, the Bank of Granite is a locally-oriented
institution which competes for individual and commercial business solely in the four towns in which it
maintains offices. A survey of all checking and savings
accounts of the merging bank indicates that over 95
percent of those accounts are maintained in Granite
Falls, Hudson, Lenoir, and Hickory, which are the
towns where the bank operates its offices.
Thus, the relevant market area for the Bank of
Granite is that part of Caldwell and Catawba counties served by its offices. Wachovia Bank and Trust
Company maintains no offices in the towns served by
the Bank of Granite.
Catawba County, located in the northwestern portion of the State, had, in 1970, an estimated population
of 90,000 persons, making it the 12th most populous
county in the State. The economy of the county is
dependent primarily on commercial and industrial
activities which include one of North Carolina's largest
concentrations of manufacturing concerns with principal products of textiles, furniture, electrical equipment, and machinery. Although there are several nationally-known firms represented in the county, the
majority of the industry is locally-owned and -operated.
As a result of that relatively well-diversified industrialization, Catawba County, with Hickory as its focal point,

has evolved as the trade and commercial center of
that portion of the State.
Caldwell County is situated to the northwest of and
adjacent to Catawba County and derives its economic
importance from its close proximity to that highly
industralized area. Granite Falls, the head office city of
the Bank of Granite, located in Caldwell County, is
4 miles from the northern boundary of the city of
Hickory. The residents of Granite Falls use Hickory
as a major trade and employment center. Similarly,
Hudson is a residential community located 3 miles
south of Lenoir, and is oriented to the needs of Lenoir,
which is the largest urban center in Caldwell County.
Lenoir is located 15 miles northwest of Hickory.
Caldwell County has a considerably slower growing
and less diversified economy than does Catawba
County. The location of Hickory as a convenient trading center for the residents and businesses of Caldwell
County has retarded the overall development of Caldwell County in several vital areas and will most
likely continue to do so. The lack of diversification in
the economy of Caldwell County is caused by a heavy
dependence on furniture and textile-apparel manufacturing, both of which have recently suffered from
drastic reductions in the demand for their products.
The recent closing of four textile plants has made
Caldwell County more dependent on the production
of furniture than ever before. Efforts to further diversify the industrial base of the county have successfully
attracted only three new companies in the past 10
years. There is an obvious need in Caldwell County
for new industry to aid in diversifying the economic
base which now relies almost exclusively on the economic fortunes of two basically unstable industries.
There is no competition between the Bank of Granite
and any office of the Wachovia Bank and Trust Company because relatively large distances separate the
closest offices of the two banks and an adequate number of competitors operate in the intervening distances.
The closest office of the charter bank to the Bank
of Granite is its Hildebran office which is a small branch
situated several miles west of Hickory in Burke County.
A survey of the business conducted by that small
office indicates that in excess of 85 percent of its
accounts are derived directly from Hildebran, and
virtually none of them originates in Hickory. Seven
neighborhood banking offices operated by four Hickory
banks are situated between the Bank of Granite's
Hickory office and the charter bank's branch in Hildebran. The home office of the Bank of Granite is in
Granite Falls, 11 miles from Hildebran; approximately




20 miles separate the merging bank's offices in Lenoir
and the Morgantown office of the Wachovia Bank and
Trust Company.
Convenience is a primary factor in obtaining all but
specialized banking services. The distance in road mileage between the offices of the Wachovia Bank and
Trust Company and the merging bank, and the many
intervening alternative banking facilities, make an overlap in the market areas for retail and minor commercial business virtually non-existent, with the exception
of customers who need and seek specialized corporate
or commercial and trust services from larger banks located outside the area. The alternative banking facilities available to those customers are the larger banks
located in Lenoir, Hickory, and elsewhere. Virtually
none of the business held by the Wachovia Bank and
Trust Company in the market area of the Bank of
Granite was gained through competition with the merging bank, but rather that business is regional or National in nature and requires services not offered by the
Bank of Granite as a result of its small size. That overlapping business, to the extent that it does exist, was
obtained in competition with other statewide banks
and larger banks operating from outside the State of
North Carolina. That means that the charter bank
currently competes more with the large competitors of
the Bank of Granite than it does with the merging
bank itself.
It does not appear likely that the Wachovia Bank
and Trust Company would be able to establish a de
novo branch in the service area of the merging bank
in the foreseeable future. Of the four local markets
served by the Bank of Granite, only the town of Hickory is attractive to the charter bank from a de novo
point of view. The charter bank has twice attempted
to enter Hickory by that method but has been effectively forestalled by the First National Bank of Catawba
County, the dominant bank in Hickory. In 1962, the
Wachovia Bank and Trust Company, then a State
bank, applied to the North Carolina Banking Commission for a de novo office in Hickory. That application
was vigorously protested by the First National Bank
of Catawba County and the application was subsequently denied by the State Banking Commission. On
March 9, 1970, in a second attempt to gain entry, the
charter bank applied to the Comptroller of the Currency for permission to open an office in Hickory. That
application was again protested by the First National
Bank of Catawba County and, after an administrative
hearing, the application was approved by the Comptroller. The protestant then filed suit against both the

charter bank and the Comptroller of the Currency,
seeking an injunction. In an opinion dated April 15,
1971, the United States District Court permanently
enjoined the Comptroller from issuing a certificate
to the Wachovia Bank and Trust Company authorizing
the establishment of a branch in Hickory. Thus, the
charter bank has been effectively prevented from opening a de novo office in Hickory, and is thereby barred
from entering the most economically feasible portion of
the service area of the merging bank through the establishment of a de novo branch. The only viable alternative by which the Wachovia Bank and Trust Company can enter Hickory and the dynamic Catawba
County market is through the proposed application.
Although the First National Bank of Catawba
County has protested the present application and an
administrative hearing was held in Raleigh on September 27, 1972, during which evidence was presented
by both the charter bank and the protestant in support
of their respective positions, it is the view of this Office
that the objections raised by the First National Bank of
Catawba County are not substantiated in fact but
merely represent the groundless fears which the dominant bank in Hickory is experiencing when faced with
the prospect of effective competition. A careful examination of the evidence accompanying this application
indicates that consummation of the proposed merger
will result in no adverse competitive effects. The proposed merger will result in no increased concentration
in any banking market and there would be a de minimis
increase in the share of deposits held by the Wachovia
Bank and Trust Company in North Carolina.
In view of the market structure now existing in
Hickory, it is obvious that the pro-competitive entry of
the Wachovia Bank and Trust Company into Catawba
County will stimulate competition, not only for the
dominant First National Bank of Catawba County, but
also by creating a realistic banking alternative to the
other large banks operating in both Catawba and Caldwell counties. The Bank of Granite is currently operating in both Catawba and Caldwell counties at a
distinct competitive disadvantage, and has lost accounts in all of the communities it serves because it is
unable to offer trust services, mortgage loans, and other
services which its much larger competitors offer. Each
bank with which it competes offers a full range of personal and corporate trust services which the merging
bank is precluded from offering because of its limited
size. The large banks now operating in Hickory and
other parts of Catawba County have, despite their size,
been ineffective against the First National Bank of

184



Catawba County because of the powerful financial
position that bank maintains in the county.
The Wachovia Bank and Trust Company has both
the aggressive competitive drive and the necessary resources to open the county to more competitive banking. In the Lenoir-Hudson area, the bank will compete
with the third and fifth largest banks in the State. In
the Hickory-Granite Falls area, where the Bank of
Granite competes with the North Carolina National
Bank, the second largest bank in the State; the First
Citizens Bank and Trust Company, the fourth largest
in the State; the Northwestern Bank, the fifth largest
commercial bank in North Carolina; and First National Bank of Catawba County, the dominant bank in
Hickory, the entry of the Wachovia Bank and Trust
Company will result in an atmosphere of more effective
competition.
The resulting bank will bring both expanded and
unique banking services to the several market areas of
the Bank of Granite. Of particular importance to Caldwell and Catawba counties will be, among others, the
lending limit of the resulting bank, which will be substantially larger than some of the existing banks in
those markets, a complete line of both personal and
corporate trust services, an industrial development department, which will be especially useful in stimulating
the sluggish economy of Caldwell County, a complete
line of international banking services, and a small business loan program. The Wachovia Bank and Trust
Company will be able to shift needed funds into the
service areas of the Bank of Granite to meet credit
needs, on a year-round basis, in amounts well above
the capabilities of the merging bank, by transferring
needed funds from areas with a low loan demand. The
legal lending limit of the Bank of Granite is now
$181,300 to any one borrower and the general policy
of the bank has been to limit loans to $100,000. That
low lending limit has effectively handicapped this bank
which competes in an area dominated by larger banks,
and has also served to stifle the economic potential of
certain areas in Caldwell County by failing to meet
local loan demands. The resulting bank, by contrast,
will make available increased funds in this area. The
proposed merger will also resolve the management
problem which now exists at the merging bank by assuring adequate experienced successor management at
offices of the resulting bank.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
NOVEMBER 3,

1972.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Wachovia does not presently operate any banking
offices in Caldwell or Catawba County. It does, however, operate a total of seven banking offices in adjacent Burke and Alexander counties, at distances of
about 6 to 22 miles from Granite's closest office. The
application indicates that Wachovia draws about $8
million in loans and about $1.2 million in deposits (excluding deposits of correspondent banks) from the four
towns where Granite operates offices. Much of this loan
business is in the form of automobile financing, including paper purchased from automobile dealers. Granite
is also a significant lender in automobile and other
consumer-oriented lines.
As North Carolina's largest bank, Wachovia can be
expected to increase its competitive efforts in these four
adjacent counties, and thus compete more and more
extensively with Granite. Wachovia has no office in
Hickory or Lenoir, the largest cities in the area, and
thus can be expected to concentrate its increased efforts
in these towns, both of which are served by Granite.
Granite is one of only three banks in Caldwell County,
where Lenoir is located, holding about 38 percent of
county deposits. At present, Wachovia and Granite
hold the third and fifth largest shares of commercial
bank deposits m the four-county area, about 9 percent
and 5.6 percent, respectively. The four leading banks
in the area hold about 85 percent of such deposits.
Additional competitive effects of the proposed
merger are occasioned by the fact that Wachovia's parent, The Wachovia Corporation, also owns American
Credit Corporation, a diversified non-bank financial
service corporation. American Credit operates two
automobile finance offices in Hickory and another such
office in Lenoir. These offices make both direct and indirect automobile loans to residents of Catawba and




Caldwell counties. American Credit also operates consumer loan offices in Lenoir, Hickory, and Newton from
which it makes other personal loans to area residents.
Finally, through its commercial finance and leasing
subsidiaries, American Credit provides various loans,
leasing, and factoring services to small- and middlesized businesses in both Caldwell and Catawba counties. In view of the nature of Granite's loan portfolio,
the proposed merger would also appear to eliminate
competition between Granite and American Credit.
Many recent bank mergers in North Carolina have
typically resulted in the succession by the largest banks
in the State to the leading local market positions of
those acquired banks. The proposed merger would
clearly contribute to and continue this trend, since
Wachovia would succeed to the particularly strong
position Granite enjoys in Caldwell County.
In addition, the instant merger presents more immediate anticompetitive effects. This is so because
WTachovia is not acquiring a bank in a distant market,
but rather a significant competitor in a region
Wachovia already serves, as does its affiliate, American
Credit. Highway connections between Lenoir, Hickory,
and Morgan ton (where Wachovia has a branch), the
three largest communities in the four-county area, are
excellent; there are also good roads providing access to
these communities from other parts of the area. Probable employment patterns and commercial traffic indicate that WTachovia offices are at least reasonable alternatives for customers served by Granite. By acquiring
Granite, Wachovia v/ould eliminate an existing competitor, and a possible vehicle for entry into the fourcounty area by a smaller, more distant bank less able
than Wachovia to expand in a de novo fashion.
The proposed merger would have a variety of anticompetitive effects. Overall, its effect on competition
would be significantly adverse.

185




APPENDIX B

Statistical Tables

501-017 O - 73 - 13

Statistical Tables
Table
No.
Tide
Page
B-l
Comptrollers of the Currency, 1863 to the
present
189
B-2
Deputy Comptrollers of the Currency
190
B-3
Regional Administrators of National banks....
191
B-4
Changes in the structure of the National Banking
System, by States, 1863-1972
192
B-5
Charters, liquidations, and changes in issued
capital stock of National banks, calendar 1972.
193
B-6
Applications for National bank charters, approved and rejected, by States, calendar 1972..
194
B-7
Applications for National bank charters, by
States, pursuant to corporate reorganizations,
calendar 1972
196
B-8
Newly organized National banks, by States,
calendar 1972
198
B-9
National bank charters issued and mergers consummated pursuant to corporate reorganizations, by States, calendar 1972
200
B-10 State-chartered banks converted to National
banks, by States, calendar 1972
205
B - l l National bank charters issued pursuant to corporate reorganizations, by States, calendar
1972
..
206
B - l 2 National banks reported in voluntary liquidation,
by States, calendar 1972
208
B - l 3 National banks merged or consolidated with
State banks, by States, calendar 1972
209
B - l 4 National banks converted into State banks, by
States, calendar 1972
210
B - l 5 Purchases of State banks by National banks, by
States, calendar 1972
211
B - l 6 Consolidations of National banks, or National
and State banks, by States, calendar 1972. . .
212
B-l 7 Mergers of National banks, or National and State*
banks, by States, calendar 1972
212
B—18 Mergers resulting in National banks, by assets of
acquiring and acquired banks, 1960-72
216
B - l 9 Domestic branches entering the National Banking System, by de novo opening, merger, or
conversion, by States, calendar 1972
216
B-20 Domestic branches of National banks closed, by
States, calendar 1972
226

188




Table
No.
Title
Page
B-21 Principal assets, liabilities, and capital accounts
of National banks, by deposit size, year-end
1971 and 1972
228
B-22 Dates of reports of condition of National banks,
1914-72
229
B-23 Total and principal assets of National banks, by
States, Tune 30, 1972
231
B-24 Total and principal liabilities of National banks,
by States, June 30, 1972
232
B-25 Capital accounts of National banks, by States,
June 30, 1972
233
B-26 Total and principal assets of National banks, by
States, Dec. 31, 1972
234
B-2 7 Total and principal liabilities of National banks,
by States, Dec. 31, 1972
235
B-28 Capital accounts of National banks, by States,
Dec. 31, 1972
236
B-29 Loans of National banks, by States, Dec. 31,
1972
337
B-30 Outstanding balances, credit cards and related
plans of National banks, Dec. 31, 1972
238
B-31 National banks engaged in direct lease financing,
Dec. 31, 1972
239
B-32 Income and expenses of National banks, by
States, year ended Dec. 31, 1972
240
B-33 Income and expenses of National banks, by
deposit size, year ended Dec. 31, 1972
254
B-34 Capital accounts, net income, and dividends of
National banks, 1944-72
256
B-35 Loan losses and recoveries of National banks,
1945-72
257
B-36 Securities losses and recoveries of National
banks, 1945-72
257
B-3 7 Assets and liabilities of National banks, date of
last report of condition, 195O-72
258
B-38 Foreign branches of National banks, by region
and country, Dec. 31, 1972
259
B-39 Total assets of foreign branches of National
banks, year-end 1953-72
260
B-40 Foreign branches of National banks, 1960-72.. .
260
B-41 Assets and liabilities of foreign branches of
National banks, Dec. 31, 19/2: consolidated
statement
260
B-42 Trust assets and income of National banks, by
States, calendar 1972
261

TABLE

B-l

Comptrollers of the Currency, 1863 to the present
No.

1
2
3
4
5
6
7
8
9
10
11
12

13
14
15
16
17
18
19
20
21
22
23

Name

McCulloch, Hugh.
Clarke, Freeman
Hulburd, Hiland R
Knox, John Jay
Cannon, 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
Smith, James E




Date of
appointment

May 9, 1863
Mar. 21, 1865
Feb. 1, 1867
Apr. 25, 1872
May 12, 1884
Apr. 20, 1886
May 1, 1889
Aug. 2, 1892
Apr. 26, 1893
Jan. 1, 1898
Oct. 1, 1901
Apr. 27, 1908
Feb. 2, 1914
Mar. 17, 1921
May 1, 1923
Dec. 20, 1924
Nov. 21, 1928
May 11,1933
Oct. 24, 1938
Apr. 16, 1953
Nov. 16, 1961
Nov. 16, 1966
July 5, 1973

Date of

State

resignation

Mar. 8, 1865
July 24, 1866
Apr. 3, 1872
Apr. 30, 1884
Mar. 1, 1886
Apr. 30, 1889
June 30, 1892
Apr. 25, 1893
Dec. 31, 1897
Sept. 30, 1901
Mar. 28, 1908
Apr. 27, 1913
Mar. 2, 1921
Apr. 30, 1923
Dec. 17, 1924
Nov. 20, 1928
Sept. 20, 1932
Apr. 16, 1938
Feb. 15, 1953
Nov. 15, 1961
Nov. 15, 1966
Mar. 23, 1973

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.
South Dakota.

189

TABLE

B-2

Deputy Comptrollers of the Currency
Name

No.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46

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
Prentiss, Jr., William..
Diggs, Marshall R. . .
Upnam, C. B
Mulroney, A. J
McCandless, R. B... .
Sedlacek, L. H
Robertson, J. L
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 C
Gwin, John D
Howland,Jr., W . A..
Mullin, Robert A

190



Dates of tenure
M a y 9, 1863
Aug. 1, 1865
Mar. 12, 1867
Aug. 8, 1872
Jan. 5, 1886
Jan. 27, 1887
Aug. 11, 1890
Apr. 7, 1893
Mar. 12, 1896
Sept. 1, 1898
June 29, 1899
July 1, 1908
M a y 21, 1923
July 1, 1923
an. 6, 1925
uly 1, 1927
July 6, 1927
Dec. 1, 1928
Jan. 24, 1933
[an.
Feb. 24, 1936
^eb.
Jan. 16, 1938
Jan. 16, 1938
1938
Oct.
1939
May
July 7; 1941
1941
Sept.
1944
Oct.
1949
Jan.
|
Sept. i 1950
,
Mar. 1 1951
Feb. 18, 1952
Sept. 15, 1959
M a y 16, 1960
Apr. 2, 1962
Aug. 4, 1962
Sept. 3, 1962
Dec. 23, 1962
Jan. 1, 1963
July 13, 1964
Sept. 1, 1964
Sept. 1, 1964
July 19, 1965
July 1, 1966
Feb. 21, 1967
July 5, 1973
July 5,1973

Aug.
Jan.
Apr.
Jan.
Jan.
May
Mar.
Mar.
Aug.
June
Mar.
Feb.
Dec.
June
Nov.
Feb.
Oct.
Jan.
Jan.
Jan.
Sept.
Sept.
Dec.
Aug.
Mar.
Sept.
Feb.
Aug.
May
Apr.
Dec.
Aug.
Aug.
Nov.
Oct.

State

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

June 30, 1966
June

1, i 967

New York.
Ohio.
Minnesota.
New York.
New York.
Virginia.
Indiana.
Kentucky.
South Carolina.
New York.
Dist. of Columbia.
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.
Iowa.
Massachusetts.
Wisconsin.
Louisiana.
Ohio.
Georgia.
Kansas.

TABLE

B-3

Regional Administrators of National banks
Region

Name

Headquarters

Charles H. Paterson.
2
3
4
5

Boston, Mass

Charles M. Van Horn.
R. Coleman Egertson.
Charles B. Hall
John G. Hensel

New York, N.Y
Philadelphia, Pa
Cleveland, Ohio.. . .
Richmond, Va

oseph M. R e a m . . . .
6
7 'oseph G. Lutz
8 John W. Schaffer, Jr.
9 Donald B. Smith
10 bhn R. Burt
11 *Michael Doman
12
13
14

John R. T h o m a s . . . .
H.JoeSelby
Arnold E. Larsen....




Atlanta, Ga
Chicago, 111
Memphis, Tenn
Minneapolis, Minn.
Kansas City, M o . . .
Dallas, Tex
Denver, Colo
Portland, Ore
San Francisco, Calif.

States

Connecticut, Maine, Massachusetts, New Hampshire,
Rhode Island, Vermont.
New Jersey, New York, Puerto Rico, Virgin Islands.
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.
Oklahoma, Texas.
Arizona, Colorado, New Mexico, Utah, Wyoming.
Alaska, Idaho, Montana, Oregon, Washington.
California, Guam, Hawaii, Nevada.

191

TABLE

B-4

Changes in the structure of the National Banking System, by States,

Organized
ana opened
for business 18631972

Consolidated and merged
under 12 U.S.C. 215

12 U.S.C. 214
Insolvencies

Consolidated

1863-1972

Liquidated

Merged

Converted Merged or
to State
consolidated
banks
with State
banks

United States,

16,062

722

616

2,821

6,753

203

333

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

210
8
33
167
611
275
138
32
39
333

4
0
1
1
21
5
11
0
8
2

9
0
0
2
51
0
8
0
0
2

45
0
6
39
66
57
7
1
7
43

63
2
21
55
395
86
69
18
13
42

0
0
1
0
4
3
2
0
0
0

0
1
1
0
19
0
15
8
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

210
7
112
988
452
566
461
250
124
129

8
1
0
20
14
4
6
11
4
8

4
0
2
10
6
2
3
2
1
9

42
0
35
227
98
205
77
37
16
13

87
4
65
299
205
243
198
110
53
79

8
1
1
15
3
11
6
8
0
0

0
0
2
2
4
1
0
2
0
1

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

157
392
362
520
100
337
211
414
18
86

3
44
11
8
5
13
4
2
1
3

17
18
6
0
4
11
1
2
0
7

17
28
77
116
16
58
76
83
4
5

69
208
157
193
35
148
76
199
8
23

1
1
0
4
2
4
0
5
0
0

11
11
5
0
0
1
0
0
1
0

483
97
1,043
164
264
736
782
154
1,297
70

56
1
127
8
3
32
12
2
110
3

65
1
91
22
0
30
6
4
105
2

60
25
130
44
100
112
85
31
211
2

153
37
441
58
118
336
454
103
494
58

1
0
13
0
0
2
33
0
8
0

27
0
78
9
0
6
0
6
93
0

138
224
225
1,376
49
85
293
246
205
306
80
1
2

8
14
9
45
4
3
23
19
11
9
0
0
0

14
2
5
24
1
4
54
9
0
0
0
0
0

43
93
36
142
6
17
28
51
38
54
12
0
0

49
81
94
574
23
29
74
143
68
116
26
0
1

1
2
6
49
3
2
3
0
0
0
0
0
0

4
0
2
4
2
6
10
1
0
0
0
0
0

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
Virgin Islands
Puerto Rico

192



In operation
Dec. 31,
1972

TABLE

B-5

Charters, liquidations, and changes in issued capital stock of National banks, calendar 1972
Capital stock
Number of
banks
Common
Increases:
Banks newly chartered:
Primary organization
Conversion of State banks

116*
16

Capital stock:
Preferred: 3 cases bv new issue
Common:
699 cases by statutory sale
623 cases by statutory stock dividends
12 cases by statutory consolidation
28 cases by statutory merger
10 cases by conversion of preferred stock
65 cases by conversion of capital notes
Capital notes and debentures: 250 cases by new i s s u e . . . .
Total increases
Decreases:
Banks ceasing operations:
Voluntary liquidations:
Succeeded by National banks
Succeeded by State banks
Statutory consolidations
Statutory mergers
Converted into State banks
Merged or consolidated with State banks
Insolvent. . .
Capital stock:
Preferred: 18 Retired
Common:
4 cases by statutory reduction
2 cases by statutory consolidation
5 cases by statutory merger
Capital notes and debentures:
43 retirements
34 converted to common stock
Total decreases

Preferred

Capital notes and
debentures

42,931,805
22,321,650
3, 648, 000
214,428,289
384, 907, 440
4, 582, 591
20, 070, 575
1,020,324
1, 265, 330
734,058,061

132

691,528,004

3
2
8

600, 000
839, 700

74f
24
11
0

3, 648, 000

734,058,061

18,025,615
6, 463, 689
6, 970, 063
928, 750
472, 860
3,318,530
28, 041, 665
2, 410, 205

122

30, 649, 144

6, 970,063

30,451,870

Net chancre
.
.
.
Charters in force Dec. 31, 1971, and issued capital

4,608

+ 10

660, 878, 860
6,768, 126, 378 r

-3,322,063
43,851,961

703, 606, 191
1,517, 164,215

Charters in force Dec. 31, 1972, and issued capital

4,618

7, 429, 005, 238

40, 529, 898

2, 220, 770, 406

•Includes 62 reorganized banks with capital stock of $9,506,005.
f Includes 62 reorganized banks.
'Revised.
NOTE: Premium on sale of common stock
$251, 748, 509
Premium on sale of convertible notes
21,211, 064
Total




$272, 959, 573

(667 cases)
( 9 1 cases)
(758

193

TABLE B-6

Applications for National bank charters, approved and rejected, by States, calendar 1972*
Approved

Rejected

Approved

Rejected

FLORIDA—continued
First City National Bank of Oxford,
Oxford
The Peoples Bank at Selma Mall, National
Association, Selma

Aug. 10
May 19

ARIZONA

South Tucson

Aug. 11
ARKANSAS

Grand National Bank, Hot Springs

May

1

CALIFORNIA

Foothill National Bank, Glendora
Los Angeles National Bank, Los Angeles. .
First National Bank of Riverbank, Riverbank
Mexican American National Bank of San
Diego, San Diego
San Fernando
San Francisco
Plaza National Bank, San Jose

Sept. 5
July 6
Nov. 15
Nov. 21

Continental National Bank of Miami,
Miami
Palm Beach Gardens
Panama City
Pinellas Park
The Exchange National Bank of Pinellas
Park, Pinellas Park
St. Petersburg
Sun Bank of Semoran, National Association, Unincorporated area of Seminole
County
Sunrise Golf Village
The Gulf National Bank, Tallahassee
First Financial National Bank of Tampa,
Unincorporated area of Hillsborough
County
Tampa
Weeki Wachee
West Palm Beach
West Palm Beach

May 16
Nov. 13
Dec. 15

Nov. 29
Sept. 26
Dec. 12
May 25
May 25
June 22
Mar. 17
Aug. 11

Oct. 16

July 17
Dec.
Nov.
June
Dec.

15
14
23
12

GEORGIA

Carrollton.
Decatur. . .

Nov. 27
July 27

COLORADO

Colorado Springs
Feb. 11
Colorado Springs
Feb. 11
Colorado Springs
Feb. 11
Colorado Springs
Aug. 30
Coronado National Bank, Denver
Sept. 6
Denver
Sept. 22
First National Bank-North in Grand
Junction, Grand Junction
May 16
Longmont
May 19

HAWAII

Bank of Honolulu, National Association,
Honolulu

May 2

ILLINOIS

Old Republic National Bank, Chicago
Mar. 30
American National Bank, Downers Grove. . Aug. 22
INDIANA

Citizens National Bank, Boca Raton
Broward National Bank of Plantation,
Plantation
The National Bank of Cape Coral, Cape
Coral
Cape Coral
Ellis National Bank of Clearwater, Clearwater
Clewiston National Bank, Clewiston
Coconut Grove
Crystal River
Unincorporated Area of Dade County
Englewood
First National Bank of Englewood, Englewood
Citizens National Bank of Fort Lauderdale,
Fort Lauderdale
Southport American National Bank of
Fort Lauderdale, Fort Lauderdale
Fort Lauderdale
The Exchange National Bank of Holiday,
Holiday
First National Bank of Hudson, Hudson. .
Jacksonville
Marine National Bank of West Jacksonville, Jacksonville
Jupiter National Bank, Jupiter
Sun Bank of Leesburg, National Association, Leesburg
Miami
Miami
See footnote at end of table.




The First National Bank of Scottsburg,
Scottsburg

Aug. 11

Dec. 1

Sept. 13
Dec. 20
Dec. 20

First National Bank of Shawnee Mission,
Fairway
June 12
MICHIGAN

Oct. 2
Nov. 15
Nov.
Nov.
Nov.
Feb.

16
27
28
2

Feb. 2
May 4

Kentwood National Bank, Kentwood

Feb. 4

MINNESOTA

National Bank of Minnetorika, Minnetonka
Aug. 22
Ridgedale National Bank, Minnetonka
Aug. 22
Shelard National Bank, St. Louis Park
June 20
MISSISSIPPI

July

7
Aug. 3

May 8
June 21
Sept. 14
Dec. 11
May 23
May 10
Mar. 15
Sept. 12

Sept. 27
Magee
First National Bank of Wiggins, Wiggins. . May 15
Mar. 6
Portageville
Boatmen's National Bank of North St.
Louis County, Unincorporated area of
St. Louis County
May 3
Commerce Bank of St. Louis, National
Association, St. Louis
May 11
United Missouri Bank of St. Louis, National Association, St. Louis
Nov. 16

TABLE B-6—Continued
Applications for National bank charters, approved and rejected, by States, calendar 1972*
Approved

Rejected

United Jersey National Bank of Cherry
Hill, Cherry Hill
United Jersey National Bank of Ocean
County, Lakewood
Newark
City National Bank of New Jersey, Newark.
Progressive National Bank, Newark
New Jersey National Bank of Princeton,
Princeton
Roseland National Bank, Roseland
Ship Bottom
Glendale National Bank of New Jersey,
Township of Voorhees
Independent National Bank, Township of
Willingboro

Feb. 28
July

7
Mar. 13

Mar. 13
July 5
May 12
Aug. 7
May 26
Sept. 11
May 18

NEW MEXICO

United Southwest National Bank of Santa
Fe, Santa Fe

May

5

NEW YORK

Monroe
The Chase Manhattan Bank of Central
New York (National Association), Syracuse

Jan. 20
Mar. 8

NORTH CAROLINA

United National Bank, Fayetteville
Franklin
Capitol National Bank, Raleigh
Rural Hall
Smithfield
Columbus National Bank, Whiteville

Dec. 14
Aug. 22
June 28
Mar. 7
Aug. 22
June 14

May 17
Mar. 6
Dec. 1

Nov. 17
June
June 29
Sept. 5
Dec. 1
Mar. 16
May 1
Nov. 28
Dec. 12
Sept. 19

5

an. 4

u y 11
l
an. 11
fan. 23
Jan. 11

Feb. 29
Feb. 29
Feb. 29
Mar. 6
Mar. 21
June 23
June 23
Aug.

4

Nov. 21
Nov. 21
Dec. 14
Nov. 30
May 22

Oct. 5
Aug. 30
Jan. 19
July 10
Aug. 11
Nov. 30
May 31

Sept. 12
Oct. 18

Nov. 29
Mar. 14
Oct. 12
Aug. 29
Mar. 3
Oct. 19

Northwestern National Bank, Port Angeles. Mar. 6
WEST VIRGINIA

TEXAS

Austin
Chemical National Bank, Clute
Town North National Bank, Dallas
Love Field National Bank, Dallas
Duncanville National Bank, Duncanville..
El Paso
The National Bank of Texas at Fort
Worth, Fort Worth

June

WASHINGTON

TENNESSEE

Lebanon
Citizens National Bank, Sevierville

Rejected

UTAH

PENNSYLVANIA

New World National Bank, Pittsburgh

American National Bank of Garland,
Garland
Harlingen
Huston
Houston
Houston
Great Northern Bank, National Association, Houston
Houston
Houston
Executive National Bank, Houston
Metropolitan National Bank, H o u s t o n . . . .
Bank of Woodlake, National Association,
Houston
Bank Plaza del Oro, N.A., Houston
San Felipe National Bank, Houston
Houston
Antoine National Bank, Houston
Inwood National Bank, Houston
Heritage National Bank, Houston
Kingwood Commerce Bank, N.A., Humble
City National Bank of Laredo, Laredo
Lubbock
Marble Falls
Montgomery
Nederland
Pearland
Pearl and.
National Bank of Round Rock,'
First
Round Rock
Sattler
Woodville

First Security Bank of Logan, National
Association, Logan
Zions National Bank of Ogden, Ogden
Orem
First Security Bank of Price, National
Association, Price
Richfield
St. George

OKLAHOMA

Exchange National Bank of Del City, Del
City
Riverside National Bank, Jenks
Union National Bank, Tulsa

Approved

TEXAS—continued

NEW JERSEY

Beckley. . .
Charleston
Guyan National Bank, Unincorporated
area of Cabell County
Dec. 11
Union Central National Bank, Vienna,
Unincorporated area of Wood County. . May 24

May 12
May 17

WISCONSIN

Metropolitan National Bank, Monona. . . . Aug. 10

•Excludes conversions, and charters to be issued pursuant to corporate reorganizations.




196

TABLE B-7

Applications for National bank charters, by States, pursuant to corporate reorganizations, calendar 1972
ALABAMA

NEW JERSEY—continued

Approved
Commercial Bank National Association,
Anniston
Decatur National Bank, Decatur
Alabama National Bank of Dothan,
Dothan
Alabama National Bank of Huntsville,
Huntsville.
Madison National Bank, Huntsville
Mobile County National Bank, Mobile. . .
Montgomery County National Bank,
Montgomery

Dec. 15
Jan. 11
Jan. 24
Jan. 24
t)ec. 26
Jan. 11
Dec. 13

CONNECTICUT

Rejected

Approved
Second Citizens National Bank of South
Jersey, Bridgeton
First National State Bank of Ocean County,
Lakewood Township
Second National Bank of Marlton, Marlton
The Third National Bank of Orange,
Orange

Albuquerque

A « - on
Apr. 20

nxiNOIS

Exchange Chicago Bank, National Association, Chicago
Feb. 16
U A National Bank, Chicago
Nov. 28
SNB National Bank, Evanston
June 2 9
KANSAS
Poyntz National Bank of Manhattan,
Kansas, Manhattan

Dec. 21

LOUISIANA
Tower National Bank, New Orleans

Nov. 3

MAINE
Waterstreet National Bank, Augusta
July 12
w*-«^«,,c» w «
MASSACHUSETTS
Second Bay State National Bank, Lawrence
May 8
tlna?T^l&fe^M
uonal Association), Springfield

YJ (

MICHIGAN
CNB National Bank, Detroit
Detroit National Bank, Detroit
Manufacturers Bank Detroit, N.A., Detroit.
Second National Bank and Trust Co. of
Escanaba, Escanaba
The Union National Bank, Grand Rapids.
C. Bank National Association, Grand
Rapids
Holland National Bank, Holland
Miner's Second National Bank and Trust
Co. of Ishpeming, Ishpeming
Second National Bank and Trust Co. of
Marquette, Marquette
Hackley Bank National Association, Muskegon
The Second Bank of Saginaw, N.A.,
Saeinaw
8

Mar 1 S
Mar. 13

May 23
June 12
July 7
Dec. 29
July 17
Pec. 29
Aug. 4
Dec. 29

196



Mar. 10
Feb. 22

Apr. 11

NEW YORK
Chase Manhattan Bank of Western New
York (National Association), Buffalo
Dec. 12
Chase Manhattan Bank of Greater Roch)
g
^ (( N?? t i o n a l Association), ,Village of
Caledonia
June 12
di
Citibank (Eastern), National Association,
Castleton-on-Hudson
Feb. 14
Hayes National Bank, Clinton
. . . July 6
Th
« Second National Bank of Highland,
Highland
June 16
Farmers Bank of Malone, National Association, Malone
Aug. 21
Moravia National Bank, Moravia Village. May 24
385 Broadway National Bank, Newburgh.. Mar. 17
Republic Bank, National Association, New
York
June 1
First Bank of Olean, National Association,
Olean
Nov. 20
Citibank (Central), National Association,
Oriskany Falls
June 27
Chase Manhattan Bank of the Mid£udson (National Association), SauCitibank (Mid-Hudson), National Association, Woodbury. . . .
Aug. 9
OHI
N B G N a t i o n a l Bank
T h c F BG

°

> Cleveland
B a n k o f Fremont,

Oct. 24

National

Fremont
Mar. 1
Greenfield National Bank, Greenfield
Nov. 30
^ " ^ f***°D* ^
° f H o p e d a l e ' Allcy o
T h e T f i G National Bank' of Ravenna
R ™ ™ £ ' N a t l o n a l B a n k °* K a v e n n a » M
,
Ravenna
Mar. 1
OKLAHOMA
OKLAHOMA
Three Rivers National Bank of Muskogee,
Muskogee
Nov. 1
PENNSYLVANIA
First Washington Bank, N.A., Washington. Nov. 29

Dec. 29
Nov. 15
Tulv 13
y

J

NEW JERSEY

New Somerset Hills & County National
Bank, Basking Ridge

Apr. 5

NEW MEXICO
_,f _. ^T % , . ^ .
The First New Mexico National Bank,

The Connecticut Bank and Trust Company, N.A., Norwalk.
May 25
FLORIDA
TMH Mo*™oi u««u ~t \xi~~yi \/fJo™;
INB National Bank of Miami, Miami
„ . TM^TO

Mar. 9

TENNESSEE
.
« , *, . ,
.•
American Bank National Association,
Chattanooga
The Second National Bank of Cookeville,
Cookeville

Aug. 25

May 25
Aug. 15

Hamilton Bank, N.A., Knoxville
Nov. 7
The National Bank of Lawrenceburg,
Lawrenceburg
Aug. 31

Rejected

TABLE

B-7—Continued

Applications for National bank charters, by States, pursuant to corporate reorganizations, calendar
TEXAS—continued

TEXAS
Approved

Second National Bank of Abilene, Abilene.
Bank of Amarillo, N.A., Amarillo
Austin Bank, National Association, Austin.
State National Bank of Corpus Christi,
Corpus Christi
First Bank, National Association, Dallas...
Ervay Bank, National Association, Dallas.
Maverick County National Bank, Eagle
Pass
Bancorp National Bank of Ennis, Texas,
Ennis
Kennedy Boulevard Bank, National Association, Houston
Gulf Bank, National Association, Houston.
Westheimer National Bank, Houston
New National Bank in Orange, Orange...




1972—Continued

Mar. 14
Feb. 22
Aug. 29
June 19
May 19
Nov. 20
Oct. 27
June

9

Aug. 11
Aug. 11
Nov. 14
Apr. 26

Rejected

Approved

First Bank, National Association, Port
Arthur
New National Bank of Raymondville,
Raymondville
Capital National Bank, San Angelo
Citizens Bank, N.A., San Antonio
Frost Bank, N.A., San Antonio

Rejected

Mar. 8
May 8
Feb. 1
June 1
June 2

VIRGINIA

Rockingham Bank, N.A., Harrisonburg... Jan. 24
Jefferson Bank, N.A., Lynchburg
June 21
WISCONSIN

Second Neenah West National Bank,
Neenah

June 13

197

TABLE B-8
Newly organized National banks, by States, calendar 1972*
Title and location of bank

Charter
No.
Total, United States: 54 banks

Total capital
accounts
$72, 322,030

ALABAMA

15995

The Peoples Bank at Selma Mall, National Association, Selma.

500,000

CALIFORNIA

15958

Gavilan National Bank, Gilroy.

2,000,000
COLORADO

16054
16010
15987

First National Bank-North in Grand Junction, Grand Junction
Fort Collins National Bank, unincorporated area of Larimer County.
Westland National Bank, Longmont

500,000
700,000
500,000
1,700,000

Total: 3 banks.
CONNECTICUT

16006

Liberty National Bank, Stamford.

2,000,000
FLORIDA

16023
15974
16034
15944
16025
16008
15967
15948
16036
16038
15949

Barnett Bank of Brandon, National Association, unincorporated area of Brandon.
Jefferson National Bank at Kendall, unincorporated area of Dade County
Citizens National Bank of Fort Lauderdale, Fort Lauderdale
United National Bank of Westland, Hialeah
The Exchange National Bank of Holiday, Holiday
Second National Bank of West Hollywood, Hollywood
Peoples National Bank, Naples
The Orlando National Bank—West, Orlando
First National Bank of Seminole, unincorporated area of Pinellas County
The Exchange National Bank of Pinellas Park, Pinellas Park
Fidelity National Bank, Pompano Beach

1,000,000
1,000,000
1,000,005
1,000,200
1,000,000
1,000,000
3,000,000
800,000
1,500,000
1,000,000
1,275,000
13,575,205

Total: 11 banks.
ILLINOIS

15978

500,000

Gurnee National Bank, village of Gurnee
INDIANA

16018

2, 000, 000

Midwest National Bank, Indianapolis
IOWA

15933

300,000

The Lakes National Bank, Arnolds Park
KANSAS

16053

First National Bank of Shawnee Mission, Fairway

1,000,000

LOUISIANA

15952

Century National Bank in New Orleans, New Orleans. .

2,000,000

MAINE

15954

1,000,000

Central National Bank, Waterville
MICHIGAN

15938

The American National Bank in Portage, Portage.

See footnote at end of table.




405,000

TABLE B-8—Continued
Newly organized National banks, by States, calendar 1972*
Title and location of bank

Charter
No.

Total capital
accounts

MISSOURI

15996
16048

The National Bank of Affton, unincorporated area of Affton
Commerce Bank of St. Louis, National Association, St. Louis

$1,000,000
5, 000, 000
6, 000,000

Total: 2 banks
NEW JERSEY

16028
15971
16011
16026
15975
15934

Bridgewater National Bank, Bridgewater Township
United Jersey National Bank of Cherry Hill, Cherry Hill
The Hillsborough National Bank, Hillsborough Township
United Jersey National Bank of Ocean County, Lakewood Township
Midlantic National Bank, Parsippany-Troy Hills Township
Bank of Wayne, National Association, Wayne Township
Total: 6 banks

1,500,000
1,000,000
1,750,000
1,000,000
1,000,000
1,500,000
7, 750, 000

NEW YORK

15966
16047
15968

Vanguard National Bank, Hempstead
Chase Manhattan Bank of Central New York, National Association, Syracuse
Hudson Valley National Bank, Yonkers
Total: 3 banks

2,112,825
2, 000, 000
2, 500, 000
6,612,825

OHIO

15945

Community National Bank, Loveland

16057

Riverside National Bank, Jenks

16024
15999
16063
15951
15956
15980
16039
16005
16040
15970
16019
15979

Chevy Chase National Bank, Austin
First National Bank of Colleyville, Colleyville
Nueces National Bank, Corpus Christi
Fidelity Bank, National Association, Dallas
First National Bank of Deer Park, Deer Park
Town North National Bank, Farmers Branch
Bank of Woodlake, National Association, Houston
Metropolitan National Bank, Houston
Metropolitan National Bank, McAllen
Montgomery County National Bank, Montgomery County
Frost National Bank of Round Rock, Round Rock
Heritage National Bank, Tyler

500, 000
OKLAHOMA

504,000
TEXAS

Total: 12 banks

600,000
750,000
600, 000
500,000
750, 000
1,000,000
1,000,000
3, 000, 000
1,000,000
1,000,000
500,000
875, 000
11,575,000

UTAH

15942
16043

First Security Bank of Bountiful, National Association, Bountiful

500,000
600,000

Zions National Bank of Ogden, Ogden
1,100,000
Total: 2 banks

,
VIRGINIA

15984

8, 500,000
First and Merchants National Bank of the Peninsula, York County
WASHINGTON

16041

800,000
Northwestern National Bank, Port Angeles
PUERTO RICO

16020

2,000,000
First National Bank of Puerto Rico, Hato Rey

•Excludes charters issued pursuant to corporate reorganizations.




199

TABLE B-9
National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1972
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

ALABAMA

Feb. 3,1972

Sept. 30,1972

Sept. 30,1972

Dec. 7, 1972

Dec. 22, 1972

First National Bank of Birmingham, Birmingham
Jefferson County National Bank, Birmingham
Charter issued February 2, 1972
First National Bank of Birmingham, Birmingham
First National Bank of Decatur, Decatur
Decatur National Bank, Decatur
Charter issued September 26, 1972
First National Bank of Decatur, Decatur
American National Bank & Trust Company, Mobile
Mobile County National Bank, Mobile
Charter issued September 26, 1972
American National Bank & Trust Company, Mobile.
Peoples National Bank of Huntsville, Huntsville
Alabama National Bank of Huntsville, Huntsville
Charter issued December 5, 1972
Peoples National Bank of Huntsville, Huntsville
First National Bank of Dothan, Dothan
Alabama National Bank of Dothan, Dothan
Charter issued December 18, 1972
First National Bank of Dothan, Dothan

$69, 975, 506

$833, 355, 240

3, 741, 448

43, 750, 424

6,088,196

91,697,068

2, 399, 041

28, 692, 794

6, 523, 767

83,845, 126

CALIFORNIA

June 30, 1972

The Bank of California, National Association, San Francisco
B.C. National Bank, San Francisco
Charter issued April 25, 1972
The Bank of California, National Association, San Francisco.
Security Pacific National Bank, Los Angeles
SECPAC National Bank, Los Angeles
Charter issued June 30, 1972
Security Pacific National Bank, Los Angeles

Sept. 2,1972

Inter National Bank of Miami, Miami
INB National Bank of Miami, Miami
Charter issued September 1, 1972
Inter National Bank of Miami, Miami.

Dec. 31, 1972

Exchange National Bank of Chicago, Chicago
Exchange Chicago Bank, National Association, Chicago
Charter issued December 15, 1972
Exchange National Bank of Chicago, Chicago

May

1,1972

115,752,193

2,183,859,712

527,991,733

9, 162,007,965

3,821,089

52, 592, 536

16, 268, 326

416, 150, 142

48, 227, 832

648, 979, 886

6, 207, 724

88,788,617

INDIANA

Jan. 3, 1972

Merchants National Bank & Trust Company of Indianapolis, Indianapolis
Meridian National Bank, Indianapolis
Charter issued December 30, 1971
Merchants National Bank & Trust Company of Indianapolis, Indianapolis

Hutchinson National Bank & Trust Company, Hutchinson
Polaris National Bank, Hutchinson
Charter issued February 14, 1972
Hutchinson National Bank & Trust Company, Hutchinson.

Feb. 15,1972
See footnotes at end of table.

200



TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1972
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

MASSACHUSETTS

Oct. 17,1972

Third National Bank of Hampden County, Springfield
Third Bank of Hampden County, National Association, Springfield
Charter issued October 16, 1972
Third National Bank of Hampden County, Springfield

$20, 773, 375

$265, 584, 541

10, 554, 560

195,213,034

31,119,100

692, 091, 523

2,616,460

27, 440, 724

3, 684, 072

56, 253, 094

31,816, 132

416,213,784

45, 592, 014

661,593,362

MICHIGAN

Jan. 31, 1972

Oct. 31, 1972

American National Bank & Trust Company of Michigan, Kalamazoo
American Bank of Michigan, National Association, Kalamazoo
Charter issued January 28, 1972
American National Bank & Trust Company of Michigan, Kalamazoo.
City National Bank of Detroit, Detroit
CNB National Bank, Detroit
Charter issued October 27, 1972
City National Bank of Detroit, Detroit
MISSOURI

Aug. 8, 1972

The Livestock National Bank of Kansas City, Kansas City
Livestock Bank of Kansas City, National Association, Kansas City
Charter issued August 3, 1972
The Livestock National Bank of Kansas City, Kansas City
NEBRASKA

Mar. 31, 1972

First National Bank of Grand Island, Grand Island
First National Bank in Grand Island, Grand Island
Charter issued March 27, 1972
First National Bank of Grand Island, Grand Island
NEW JERSEY

American National Bank & Trust, Montclair
Second American National Bank, Montclair
Charter issued December 23, 1971
Jan. 1, 1972 American National Bank & Trust of New Jersey, Montclair
New Jersey Bank (National Association), Clifton
Second New Jersey Bank (National Association), Clifton
Charter issued April 7, 1972
Apr. 13, 1972 New Jersey Bank (National Association), Clifton
City National Bank of Millville, Millville
Second City National Bank of Millville, Millville
Charter issued April 26, 1972
Apr. 28, 1972 City National Bank of Millville, Millville
Madison National Bank, Madison
New Madison National Bank (Madison, New Jersey), Madison
Charter issued April 26, 1972
May 1,1972 Madison National Bank, Madison
Citizens National Bank, Englewood
New Citizens National Bank, Englewood, N.J., Englewood
Charter issued June 26, 1972
June 30, 1972 Citizens National Bank, Englewood
The Security National Bank of Trenton, Trenton
First National State Bank of Central Jersey, Trenton
Charter issued July 11, 1972
July 14,1972 First National State Bank of Central Jersey, Trenton
The Second National Bank of Orange, Orange
The Third National Bank of Orange, Orange
Charter issued October 30, 1972
Nov. 1,1972 Second National Bank of Orange, Orange
See footnote at end of table.




1, 440, 538

951, 324

18,189,012

4, 035, 781

2, 571, 577

16,475,140

10, 829, 784

272,497,182

60,213,959

45, 985, 862

201

TABLE B-9—Continued
National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1972
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

NEW JERSEY—continued

Nov. 2, 1972

Nov

2 1972

Nov. 10, 1972

Citizens National Bank of South Jersey, Bridgeton
Second Citizens National Bank of South Jersey, Bridgeton
Charter issued November 1, 1972
Citizens National Bank of South Jersey, Bridgeton
First National Bank of Marlton, Marlton
Second National Bank of Marlton, Marlton
Charter issued November 1, 1972
First National Bank of Marlton, Marlton
Trust Company of Ocean County, Lakewood
First National State Bank of Ocean County, Lakewood
Charter issued November 8, 1972
First National State Bank of Ocean County, Lakewood

$1, 260, 378

$23,017,511

1, 750, 716

24,517,849

2, 949, 792

39, 786, 202

5, 609, 007

80, 537, 695

3, 794,056

58, 084, 979

4,401,783

78, 987, 962

1,238,670

13,518,243

1,010,317

10,621,390

6, 349, 853

74, 722, 339

NEW YORK

Jan.

Jan.

Mar.

Apr.

June

Aug.

Sept.

Nov.

Dec.

The Union National of Troy, Troy
Union National Bank, Albany
Charter issued January 4, 1972
18, 1972 Union National Bank, Troy
.
....
.
.
Tappan Zee National Bank, Nyack
The Bank of Tappan Zee, N. A., Nyack
Charter issued January 27, 1972
31,1972 Tappan Zee National Bank Nyack
Eastern National Bank of Long Island, Smithtown
East Bank, N.A., Smithtown
Charter issued March 1, 1972
3,1972 Eastern National Bank of Long Island, Smithtown
The Silver Creek National Bank, Silver Creek
Citibank (Western), National Association, Silver Creek
Charter issued April 5, 1972
10, 1972 Citibank (Western), National Association, Silver Creek
State Bank of Honeoye Falls, Honeoye Falls
Citibank (Mid-Western), National Association, Honeoye Falls
Charter issued June 8, 1972
8, 1972 Citibank (Mid-Western), National Association, Honeoye Falls
First National Bank of Bay Shore, Bay Shore
First Bank of Bay Shore, National Association, Bay Shore
Charter issued August 28, 1972
31, 1972 First National Bank of Bay Shore, Bay Shore
The National Exchange Bank of Castleton-on-Hudson, Castleton-on-Hudson
Citibank (Eastern), National Association, Castleton-on-Hudson
Charter issued September 5, 1972
6, 1972 Citibank (Eastern), National Association, Castleton-on-Hudson
Highland National Bank of Newburgh, Newburgh
385 Broadway National Bank, Newburgh
Charter issued November 29, 1972
30, 1972 Highland National Bank of Newburgh, Newburgh
Bank of Caledonia, Caledonia
Chase Manhattan Bank of Greater Rochester (National Association),
Caledonia
Charter issued December 27, 1972
29, 1972 Chase Manhattan Bank of Greater Rochester (National Association),
Caledonia

695, 804

14,415,541

5, 032, 852

67,129,252

1,300,517

11,144,622

3, 843, 697

50, 441, 683

OHIO

Clermont National Bank, Milford
F.B.G. National Bank of Milford, Milford
Charter issued April 26, 1972
May 1,1972 Clermont National Bank, Milford
See footnote at end of table.

202



TABLE B-9—Continued
National bank charters issued* and mergers consummated pursuant to corporate reorganizations\ by States^ calendar 1972
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

OHIO—continued

Sept. 25, 1972

Sept. 29, 1972

Sept. 29, 1972

Oct. 31, 1972

lentral National Bank at Cambridge
lambridge National Bank, Cambridge
Charter issued September 25, 1972
lentral National Bank at Cambridge, Cambridge
The Liberty National Bank of Fremont, Fremont
F.B.G. National Bank of Fremont, Fremont
Charter issued September 25, 1972
The Liberty National Bank of Fremont, Fremont
The First National Bank & Trust Company of Ravenna, Ravenna
F.B.G. National Bank of Ravenna, Ravenna
Charter issued September 25, 1972
First National Bank & Trust Company of Ravenna, R a v e n n a . . . .
First National Bank of Canton, Canton
The Stark County National Bank, Canton
Charter issued October 30, 1972
First National Bank of Canton, Canton

$2,334,112

$32,392,212

2,057,134

29, 916, 745

6, 352, 880

72,059,416

15,427,918

184,031,458

1,912,664

31,563,130

501,303,180

4,999,455,613

OREGON

Sept. 14, 1972

Douglas National Bank, Roseburg
DB National Bank, Roseburg
Charter issued September 13, 1972
Douglas National Bank, Roseburg
PENNSYLVANIA

Nov. 28, 1972

Dec. 31, 1972

Mellon National Bank & Trust Company, Pittsburgh
Mellon Bank, N.A., Pittsburgh
Charter issued November 22, 1972
Mellon Bank, N.A., Pittsburgh
National Central Bank, Lancaster
The King Street Bank, N.A., Lancaster
Charter issued December 27, 1972
National Central Bank, Lancaster

56,717,077

736, 834, 003

51,125,658

755, 354, 675

68, 261, 202

677, 796, 495

SOUTH CAROLINA

June 30, 1972

The South Carolina National Bank of Charleston, Charleston
Security National Bank, Charleston
Charter issued June 27, 1972
The South Carolina National Bank, Charleston
TENNESSEE

Jan.

1, 1972

July

1,1972

July 24, 1972

Third National Bank in Nashville, Nashville
Fourth and Church Street National Bank, Nashville
Charter issued December 30, 1971
Third National Bank in Nashville, Nashville
Union Planters National Bank of Memphis, Memphis
Union Planters Bank, National Association, Memphis
Charter issued June 26, 1972
Union Planters National Bank of Memphis, Memphis.
The Kingsport National Bank, Kingsport
The National Bank of Kingsport, Kingsport
Charter issued July 21, 1972
The Kingsport National Bank, Kingsport

75, 038, 829

1,038,312,376

2,393,513

29, 344. 045

14, 928,039

224, 190, 129

TEXAS

The Alamo National Bank of San Antonio, San Antonio
Alamo Bank, National Association, San Antonio
Charter issued December 21, 1971
Jan. 5, 1972 The Alamo National Bank, San Antonio
See footnote at end of table.




TABLE B-9—Continued
National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1972
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

TEXAS—continued

Apr.

3, 1972

Aug. 30, 1972

Oct. 10, 1972

Oct. 12, 1972

Dec. 28, 1972

Dec. 31, 1972

Apr.

3, 1972

May 18, 1972

June 26, 1972

Aug. 7, 1972

The State National Bank of El Paso, El Paso
State Bank, National Association, El Paso
Charter issued April 3, 1972
The State National Bank of El Paso, El Paso
Northeast National Bank of Fort Worth, North Richland Hills
First National Bank of North Richland Hills, North Richland Hills
Charter issued August 28, 1972
Northeast National Bank of Fort Worth, North Richland Hills
The First National Bank of Port Arthur, Port Arthur
First Bank, National Association, Port Arthur
Charter issued October 6, 1972
The First National Bank of Port Arthur, Port Arthur
The American National Bank of Beaumont, Beaumont
Park Street Bank, National Association, Beaumont
Charter issued October 10, 1972
The American National Bank of Beaumont, Beaumont
First National Bank in Orange, Orange
New National Bank in Orange, Orange
Charter issued December 20, 1972
First National Bank in Orange, Orange
First National Bank in Dallas, Dallas
First Bank, National Association, Dallas,
Charter issued December 27, 1972
First National Bank in Dallas, Dallas
National Bank of Commerce of San Antonio, San Antonio
Bank of Commerce, National Association, San Antonio
Charter issued March 23, 1972
National Bank of Commerce of San Antonio, San Antonio
Long Point National Bank of Houston, Houston
Long Bank, National Association, Houston
Charter issued May 15, 1972
Long Point National Bank of Houston, Houston
Continental National Bank of Fort Worth, Fort Worth
Continental Bank, National Association, Fort Worth
Charter issued June 22, 1972
Continental National Bank of Fort Worth, Fort Worth
The First National Bank of Fort Worth, Fort Worth
Burnett Plaza National Bank of Fort Worth, Fort Worth
Charter issued August 4, 1972
The First National Bank of Fort Worth, Fort Worth

$23, 532, 890

$259,012,081

2, 418, 594

34, 573, 438

6, 682, 965

92, 078, 788

10, 282, 353

126,602,426

3, 859, 865

34, 269, 012

154,463,036

2, 526, 082, 730

23, 729, 083

355,426, 244

3, 145, 576

34, 972, 039

13,927, 164

237, 986, 859

40, 065, 349

651, 910, 278

21,652,649

366, 839, 367

4, 302, 301

75,722,417

99, 152, 742

1,444,606,640

1,719,879

10, 948,855

UTAH

Zions National Bank, Salt Lake City
Zions Bank, N.A., Salt Lake City
Charter issued April 4, 1972
Apr. 7, 1972 Zions First National Bank, Salt Lake City.
VIRGINIA

Rockingham National Bank, Harrisonburg
Rockingham Bank, N.A., Harrisonburg
Charter issued June 27, 1972
July 1,1972 Rockingham National Bank, Harrisonburg.
Virginia National Bank, Norfolk
Virginia Bank, N.A., Norfolk
Charter issued July 6, 1972
July 10, 1972 Virginia National Bank, Norfolk
Jefferson National Bank, Lynchburg
Jefferson Bank, N.A., Lynchburg
Charter issued November 29, 1972
Dec. 4, 1972 Jefferson National Bank, Lynchburg

•Includes only charter issuances related to mergers consummated in 1972. For a full listing of all charters issued during 1972,
pursuant to corporate reorganizations, see Table B-11.

204



TABLE

B-10

State-chartered banks converted to National banks, by States, calendar 1972*
Effective
date of
charter

Outstanding
capital stock

Surplus, undivided profits
and reserves

$32,121,650

$70, 386,672

$1,561,964,217

Sept. 20

5,000,000

8, 770, 834

320,981,330

June 12

1,200,000

526, 378

17,398,792

Sept. 25

250,000

438, 005

12,257,017

July

7

577, 500

980, 798

34,750,871

Mar. 20

50,000

267, 793

2, 378, 916

Nov. 10

1,000,000

2,011,511

47, 562, 436

3

200,000

700, 055

13,012,740

June 30

18,000,000

36, 556, 355

686,592,813

May 15

90, 750

363, 729

5, 587, 553

Feb. 1

150,000

251,259

6, 747, 977

Feb. 1

300,000

366,615

10,377,614

June 1

50,000

94, 887

1,917,361

Sept. 1

500,000

4, 046, 662

54,827,118

Jan.

3

653,400

2, 105, 273

36, 860, 241

Manitowoc Savings Bank National Association, Manitowoc May 22
Conversion of Manitowoc Savings Bank.
American City Bank and Trust Company, National Association, Milwaukee
Dec. 29
Conversion of American City Bank and Trust Company.

1,000,000

4, 154, 925

70, 902, 776

3, 100, 000

8,751,593

239, 808, 662

Charter
No.

Title and location of bank

Total: 16 banks

Total assets

ARKANSAS

16009

Worthen Bank and Trust Company, National Association, Little Rock
Conversion of Worthen Bank and Trust Company.

15977

City National Bank of Hallandale, Hallandale
Conversion of City Bank of Hallandale.
First National Bank of Tav. Tav
Conversion of Bank of Jay.
Bank of Stuart, National Association, Stuart
Conversion of Bank of Stuart.

FLORIDA

16012
15991

GEORGIA

15947

National Bank of Grady County, Whigham
Conversion of Bank of Grady County.
MICHIGAN

16037

Central Bank, National Association, Grand Rapids
Conversion of Central Bank.

15986

First Hennepin National Bank, Minneapolis
Conversion of First Hennepin State Bank.

MINNESOTA

July

MISSOURI

15985
15962

Commerce Bank of Kansas City, National Association,
Kansas City. .
Conversion of Commerce Bank of Kansas City.
First National Bank of St. Peters, St. Peters
Conversion of Bank of St. Peters.
MONTANA

15936
15940

Montana National Bank of Red Lodge, Red Lodge
Conversion of The First Security Bank of Red Lodge.
Montana National Bank of Roundup, Roundup
Conversion of Miners and Merchants Bank.
NORTH DAKOTA

15973

Columbus National Bank, Columbus
Conversion of Cloumbus State Bank.

16002

Raleigh County National Bank, Beckley
Conversion of The Raleigh County Bank.
Union Trust National Bank, Parkersburg
Conversion of Union Trust and Deposit Company.

WEST VIRGINIA

15932

WISCONSIN

15972
16056

•Excludes State-chartered banks which became National banks pursuant to corporate reorganizations (see Table B-9): Trust
Company of Ocean County, Lakewood, N.J., became First National State Bank of Ocean County; Bank of Caledonia, Caledonia,
N.Y., became Chase Manhattan Bank of Greater Rochester (National Association).




205

TABLE

B-ll

National bank charters issued pursuant to corporate reorganizations, by States, calendar 1972
Title and location of bank

Charter
No.

Date of
issuance

Total: 62 banks
ALABAMA

3185 Jefferson County National Bank, Birmingham
6380 Decatur National Bank, Decatur
5249 Alabama National Bank of Dothan, Dothan
15267 Alabama National Bank of Huntsville, Huntsville
13414 Mobile County National Bank, Mobile
Total: 5 banks

Feb. 2
Sept. 26
Dec. 18
Dec. 5
Sept. 26

CALIFORNIA

2491
9655

SECPAC National Bank, Los Angeles
B.C. National Bank, San Francisco
Total: 2 banks

June 30
Apr. 25
FLORIDA

15156

INB National Bank of Miami, Miami

Sept. 1
ILLINOIS

12945

Exchange Chicago Bank, National Association, Chicago

Dec. 15

KANSAS

10765

Polaris National Bank, Hutchinson

Feb. 14
MASSACHUSETTS

1014
308

Second Bay State National Bank, Lawrence
Third Bank of Hampden County, (National Association), Springfield
Total: 2 banks

Dec. 27
Oct. 16

MICHIGAN

13671
14925
13820

Detroit National Bank, Detroit
CNB National Bank, Detroit
The American Bank of Michigan, National Association, Kalamazoo
Total: 3 banks

Dec. 27
Oct. 27
Jan. 28

MISSOURI

14735

Livestock Bank of Kansas City, National Association, Kansas City

Aug. 3

NEBRASKA

2779

First National Bank in Grand Island, Grand Island

Mar. 27

NEW JERSEY

2999
15709
4365
16035
15360
13125
14673
4724
13039

Second Citizens National Bank of South Jersey, Bridgeton
Second New Jersey Bank (National Association), Clifton
New Citizens National Bank, Englewood, N.J., Englewood
First National State Bank of Ocean County, Lakewood Township
New Madison National Bank (Madison, New Jersey), Madison
Second National Bank of Marlton, Marlton
The Second City National Bank of Millville, Millville
The Third National Bank of Orange, Orange
First National State Bank of Central Jersey, Trenton
Total: 9 banks

963
16050
5816
10029
15976
16044
14734
10258
14763

Union National Bank, Albany
Chase Manhattan Bank of Greater Rochester (National Association), Village of Caledonia
Citibank (Eastern), National Association, Village of Castleton-on-Hudson
First Bank of Bay Shore, National Association, Village of Bay Shore
Citibank (Mid-Western), National Association, Honeoye Falls
385 Broadway National Bank, Newburgh
The Bank of Tappan Zee, N.A., Nyack Village
Citibank (Western), National Association, Village of Silver Creek
East Bank, N.A., Smithtown Village
Total: 9 banks

Nov.
Apr.
June
Nov.
Apr.
Nov.
Apr.
Oct.
July

1

7
26
8
26
1
26
30
11

NEW YORK

206



Jan. 14
Dec. 27
Sept. 5
Aug. 28
June 7
Nov. 29
Jan. 27
Apr. 5
Mar. 1

TABLE B-ll—Continued
National bank charters issued pursuant to corporate reorganizations, by States, calendar 1972
Title and location of bank

Charter
No.

Date of
issuance

OHIO

13905
76
13997
3234
5370

Cambridge National Bank, Cambridge
The Stark County National Bank, Canton
The F.B.G. National Bank of Fremont, Fremont
The F.B.G. National Bank of Milford, Milford
The F.B.G. National Bank of Ravenna, Ravenna
Total: 5 banks

Sept. 25
Oct. 30
Sept. 25
Apr. 26
Sept. 25
OREGON

14860

DB National Bank, Roseburg

Sept. 13
PENNSYLVANIA

694
6301

The King Street Bank, N.A., Lancaster
Mellon Bank, N.A., Pittsburgh
Total: 2 banks

Dec. 27
Nov. 22
SOUTH CAROLINA

2044

June 27
Security National Bank, Charleston
TENNESSEE

14611
14657
13349

5825
3623
2521
2349
11997
14777
14982
13661
5485
13587
6956

American Bank National Association, Chattanooga
The National Bank of Kingsport, Kingsport
Union Planters Bank, National Association, Memphis
Total: 3 banks
TEXAS

Dec. 27
21
26

July
June

Oct.
Dec.
Apr.
Aug.
June
May
Aug.
Dec.
Oct.
Dec.
Mar.

10
27
3
4
22
15
28
20
6
14
23

Apr.

Park Street Bank National Association, Beaumont
First Bank, National Association, Dallas
State Bank, National Association, El Paso
Burnett Plaza National Bank of Fort Worth, Fort Worth
Continental Bank, National Association, Fort Worth
Long Bank, National Association, Houston
First National Bank of North Richland Hills, North Richland Hills
New National Bank in Orange, Orange
First Bank, National Association, Port Arthur
Capital National Bank, San Angelo
Bank of Commerce, National Association, San Antonio
Total: 11 banks

4

UTAH

4341

Zions Bank, N.A., Salt Lake City
VIRGINIA

5261
15819
9885

Rockingham Bank, N.A., Harrisonburg
Jefferson Bank, N.A., Lynchburg
Virginia Bank, N.A., Norfolk

June 27
Nov. 29
July 6

Total: 3 banks




207

TABLE

B-12

National banks reported in voluntary liquidation, by States, calendar 1972

Title and location of bank

Date of
liquidation

Total: 5 National banks.

Total capital
accounts of
liquidated
banks

$5, 124, 967
CALIFORNIA

The First National Bank of Upland, Upland, Calif. (8266), absorbed by Crocker National Bank, San
Francisco (1741)

May 19

1,175,392

June 30

1, 258, 773

Sept. 29

852, 368

Mar. 17

1, 186,868

Nov. 18

651, 566

UTAH

American National Bank of Salt Lake City, Salt Lake City, Utah (15243), absorbed by Tracy-Collins
Bank and Trust Company, Salt Lake City
WASHINGTON

The First National Bank of Ferndale, Fernjdale, Wash. (11667), absorbed by Old National Bank of Washington, Spokane (4668),
Olympic National Bank, Port Angeles, Wash. (15906), absorbed by Peoples'National Bank of Washington,
SeattI (14394).
attle
WISCONSIN

Southridge National Bank of Greendale, Greendale, Wis. (15823), absorbed by the Southridge Bank of
Greendale

208



TABLE

R-13

National hanks merged or consolidated with State hanks, by States, calendar 1972

Title and location of bank

Effective
date

Total: 10 banks.

Total
capital
accounts of
National
banks

$22, 867, 040
MASSACHUSETTS

First National Bank of Natick, Natick, Mass. (14834), merged into Guaranty Trust Company, Waltham,
Mass., under the title "Guaranty-First Trust Company"

Dec. 31

1,250,583

June 30

3, 109, 135

Apr. 3

4,355,912

NEW JERSEY

The United National Bank of Bergen County, Cliffside Park, NJ. (14162), merged into Hudson Trust
Company, Union City, N.J., under the title of "Hudson Trust Company"
Keansburg-Middletown National Bank, Middletown, NJ. (10376), merged into Union City Trust Company, Elizabeth, N.J., under the title of "United Counties Trust Company"
Total: 2 banks.

7, 465, 047
NEW YORK

The Tanners National Bank of Catskill, Catskill, N.Y. (1198), merged into Mechanics and Farmers Bank
of Albany, Albany, N.Y., under the title "The Bank of New York, Albany"
The First National Bank of Painted Post, Painted Post, N.Y. (13664), merged into Central Trust Company,
N.Y., Rochester, N.Y., under the title "Central Trust Company, Rochester, N.Y."

Mar. 1

1, 175,979

June 28

913,625

Total: 2 banks.

2, 089, 604
PENNSYLVANIA

The Athens National Bank, Athens, Pa. (5202), merged into Northern Central Bank and Trust Company,
Williamsport, Pa., under the title "Northern Central Bank and Trust Company"
Community National Bank of Pennsylvania, Benscreek, Pa. (14156), merged into Johnstown Bank and
Trust Company, Johnstown, Pa., under the title "Johnstown Bank and Trust Company"
The Bradford National Bank, Bradford, Pa. (2428), merged into Elk County Bank and Trust Company, St.
Marys, Pa., under the title "First Laurel Bank"
The First National Bank of Lebanon, Lebanon, Pa. (240), merged into Dauphin Deposit Trust Company,
Harrisburc, Pa., under the title "Dauphin Deposit Trust Company"
The First National Bank of Meshoppen, Meshoppen, Pa. (5429), merged into United Penn Bank, WilkesBarre, Pa., under the title "United Penn Bank"
Total: 5 banks.




July 17

1,081,672

Oct.

2

721,175

July

1

5,947,515

June 30

3,799,517

Dec. 30

511,927
12,061,806

209

TABLE

B-14

National banks converted into State banks, by States, calendar 1972

Title and location of bank

Charter
No.

Effective
date

Total: 24 banks

Total
capital
accounts of
National
banks

$64, 045, 622
COLORADO

Union National Bank in Denver, Denver, converted into Union Bank and Trust

8

2, 853, 650

Sept. 1

18, 609, 486

The First National Bank in Wyoming, Wyoming, converted into Wyoming Bank and Trust
Company

Apr. 3

449, 827

9562 The First National Bank of Oakland City, Oakland City, converted into First Bank and Trust
Company of Oakland City

Oct. 16

913,569

Oct. 19

994, 540

July

1

606, 784

Oct. 20

363, 740

Apr. 6

16,390, 174

14248

Jan.

CONNECTICUT

227

The Second National Bank of New Haven, New Haven, converted into Second New Haven
Bank
ILLINOIS

14332

KANSAS

14959

Seneca National Bank of Wichita, Wichita, converted into Seneca State Bank
NEBRASKA

13426
9762

First National Bank in Cozad, Cozad, converted into First Bank and Trust Company
The First National Bank of Imperial, Imperial, converted into Chase County Bank and Trust
Company
NEW YORK

11881

Valley National Bank of Long Island, Valley Stream, converted into Valley Bank of New York. .
OKLAHOMA

15232
12812
10875
5345
15308

First National Bank, Broken Bow, Broken Bow, converted into First Broken Bow Bank and
Trust
First National Bank in Duncan, Duncan, converted into First Bank and Trust Company
First National Bank of Erick, Erick, converted into First American Bank
The First National Bank of Marietta, Marietta, converted into Firstbank of Marietta
Oklahoma National Bank of Norman, Norman, converted into Norman Bank of C o m m e r c e . . . .

5
3
11
1
15

688, 134
1, 106, 329
261, 307
659, 362
778, 797

First National Bank in Harriman, Harriman, converted into Hamilton Bank of Roane County.. . Oct. 20
The First National Bank, Jellico, converted into City and County Bank of Campbell County
Hamilton National Bank of Morristown, Morristown, converted into Hamilton Bank of Morris- Oct. 2
town
The First National Bank of South Pittsburg, South Pittsburg, converted into Hamilton Bank of Oct. 31
Marion County
Oct. 31

2, 085, 757
447, 052

July
Jan.
Apr.
Feb.
Dec.

TENNESSEE

12031
7665
8025
3660

2, 623, 859
1, 133,852

TEXAS

14101
14104
14157
15094

The First National Bank of Baytown, Bay town, converted into First American Bank and Trust
of Baytown
First National Bank in Groveton, Groveton, converted into First Bank in Groveton
The Robstown National Bank, Robstown, converted into The Bank of Robstown
The First National Bank of Sundown, Sundown, converted into Sundown State Bank

Aug.
Oct.
Mar.
Jan.

7
16
27
3

1, 138, 329
874, 213
717,089
195, 507

Jan.

3

8,147,451

VERMONT

1698

The Howard National Bank and Trust Company, Burlington, converted into The Howard
Bank

210



TABLE B-14—Continued
National banks converted into State banks, by States, calendar 1972

Title and location of bank

Charter
No.

Effective
date

Total
capital
accounts of
National
banks

May

1

$1, 117,584

Dec. 29

889, 230

VIRGINIA

11387
15334

The Peoples National Bank, Pulaski, converted into Bank of Virginia—Pulaski
Bank of Virginia-Fredericksburg, N.A., Fredericksburg, converted into Bank of VirginiaFredericksburg
,

TABLE

B-15

Purchases of State banks by National banks, by States, calendar 1972

Title and location of bank

Effective
date

Total: 8 banks.

Total capital
accounts of
State banks

$9, 405, 373
CALIFORNIA

United States National Bank, San Diego, Calif. (10391), purchased the Beverly Hills Fidelity Bank, Beverly
Hills

July 14

5, 108, 661

KENTUCKY

The First-Hardin National Bank of Elizabeth town, Elizabethtown, Ky. (6028), purchased the Bank of
Sonora, Sonora

Mar. 17

153,907

Bellefontaine National Bank, Bellefontaine, Ohio (13749), purchased the Belle Center Bank Company,
Belle Center

May

1

500, 642

May

6

1,735,644

Sept. 11

641,826

June

9

548,174

Mar. 20

376, 428

Sept. 20

340,091

PENNSYLVANIA

Western Pennsylvania National Bank, Pittsburgh, Pa. (2222), purchased the Economy Bank of Ambridge,
Ambridge
National Bank of the Commonwealth, Indiana, Pa. (14098), purchased the Farmers and Merchants Bank
of Cherry Tree, Cherry Tree
First National Bank and Trust Company, Washington, Pennsylvania, Washington, Pa. (5920), purchased
the Community Bank of Pittsburgh, Pittsburgh
WASHINGTON

The National Bank of Commerce of Seattle, Seattle, Wash. (4375), purchased the Oroville State Bank,
Oroville
WISCONSIN

National Bank of Commerce in Superior, Superior, Wis. (14109), purchased the Poplar State Bank,
Poplar




211

TABLE

B-16

Consolidations* of National banks, or National and State banks, by States, calendar 1972
Consolidating banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

$200,000
200,000
928,810

$200, 000
550,000
221, 190

$204, 308
1,379,839
1, 584, 148

$11,332,641
30, 100, 757
41, 433, 398

150,000
3, 980, 049
4,245,831
3,981,400
275, 000
4, 256, 400
3, 693, 750
500, 000
4, 818, 750

450, 000
4, 908, 272
5,197,491
7, 343, 600
400, 000
7, 743, 600
3, 906, 250
890, 426
4, 796, 676

222, 489
4, 263, 858
4, 486, 347
1, 984, 442
459, 948
2, 444, 390
4, 060, 544
780, 370
4,224,914

10,248, 139
247,114,722
257, 294, 688
194,554,577
17,249,371
211,803,949
169,038,930
33,741,235
202, 780, 165

Total: 7 consolidations
LOUISIANA

Dec.

1

First National Bank, Slidell (14989)
Commercial Bank and Trust Company, Covington
Commercial National Bank, Covington (14989)
NEW JERSEY

Mar. 17
Aug. 31
Sept. 29

First National Bank of Woodstown, Woodstown (399)
Peoples National Bank of New Jersey, Westmont (12022).
Peoples National Bank of New Jersey, Westmont (399).. .
Colonial National Bank, Haddonfield (14457)
Elmer Bank and Trust Company, Elmer
Colonial National Bank, Haddonfield (14457)
First National Bank of Central Jersey, Somerville (3866) .
First Clinton National Bank, Clinton (1114)
First National Bank of Central Jersey, Somerville (3866).
NEW YORK

Oct.

16

National Bank of North America, Jamaica (7703)
The National Bank of Far Rockaway, Far Rockaway
(9271)
National Bank of North America, Jamaica (7703)

30, 918, 330 69,081,670
500,000
31,095,470

76, 593, 445 2,581,004,178

500, 000
4, 656, 099
48, 615
69, 904, 530 76, 642,060 2,585,660,277

PENNSYLVANIA

May

1

May 31

Citizens and Northern National Bank and Trust Company,
Towanda (328)
The First National Bank of Ralston, Ralston (9508)
Citizens and Northern National Bank and Trust Company,
Towanda (328)
The Farmers National Bank of Lititz, Lititz (5773)
The First National Bank of Intercourse, Intercourse (9216).
Farmers First National Bank, Lititz (5773)

1,400,000
50, 000

1,400,000
100, 000

625, 302
110,630

56, 674, 730
2, 160, 046

1,520,000
1,584,000
50, 000
1,959,000

1,500,000
2, 332, 000
600, 000
2, 932, 000

786, 670
377, 925
188,801
291, 183

58,906,816
62, 553, 642
11,301,451
74,000, 162

* Excludes consolidations involving only one operating bank, effected pursuant to corporate reorganization.
TABLE

B-17

Mergers* of National banks, or National and State banks, by States, calendar 1972
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

$100,000
5,000,000
5, 150,000

$100,000
5,000,000
5,000,000

$272, 519
6, 184, 550
6, 507, 070

$7, 496, 743
238, 887, 138
246, 245, 666

615, 740
1, 204, 800
1, 758, 960
1,000,000
4, 747, 060
5,547,060

365, 734
663, 735
1, 091, 050

156,491
345, 926
511,973
567, 994
3, 683, 755
4, 251, 749

20, 768, 741
56, 264, 565
79, 095, 779
15, 808, 944
237,417,758
253, 226, 702

Total: 39 merger actions
ALASKA

Jan.

1

Bank of Petersburg, Petersburg
National Bank of Alaska, Anchorage (14651).
National Bank of Alaska, Anchorage (14651).
CALIFORNIA

San Joaquin Valley National Bank, Tulare (15357).
American National Bank, Bakersfield (15437)
Mar. 10 American National Bank, Bakersfield (15437)
Commercial National Bank, San Leandro (15451)..
First National Bank of San Jose (2158)
May 1 First National Bank of San Jose (2158)
See footnote at end of table.

212



768, 168
5,000,000

5, 968, 168

TABLE B-l 7—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1972
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

INDIANA

Sept. 30

Dillsboro State Bank, Dillsboro
First National Bank of Aurora, Aurora (0699).
First National Bank of Aurora, Aurora (0699).

$35,000
200,000
326,000

$200, 000
200,000
400,000

$297, 919
636, 800
843, 718

65, 000
5, 420, 330
5, 420, 330

335,000
5, 079, 670
5, 079, 670

208, 562
5, 059, 643
5, 059, 643

4,918,293
236,704,821
241,623, 114

700,000
210,000
200,000
850,000

2, 000, 000
172,200
40,000
2, 650, 000

1,165,946
242, 916
0
1,231,061

71,853,399
5,259,610
240, 000
77, 120, 209

160,000
1,898,440
2, 042, 440

363, 016
5, 030, 000
5, 409, 016

115,712
790, 584
1,013, 136

8, 723, 642
119, 164,988
128,087,692

Citizens National Bank of South Jersey, Woodbine (12977)
150,000
160,000
Bridgeton National Bank, Bridgeton (2999)
200,000
400,000
Citizens National Bank of South Jersey, Bridgeton (2999). .
360, 000
550,000
Trenton Trust Company, Trenton
1,347,825
3,184,000
National State Bank, Elizabeth (1436)
12,000.000 12,000,000
The National State Bank, Elizabeth (1436)
12,000,000 10,000,000
Ridgefield Park Trust Company, Ridgefield Park
132,500
1,617,500
First National State Bank of North Jersey, Hackensack
(12014)
500, 000
750,000
First National State Bank of North Jersey, Hackensack
(12014)
2, 000, 000 2, 000, 000
First National Bank of Hightstown, Hightstown (1737)...
700, 000
1,000,000
Monmouth County National Bank of Red Bank, Red
Bank (2257)
3, 825, 000 8, 675, 000
Colonial First National Bank, Red Bank (2257)
4, 770, 000 10,230,000
2,081,985
Suburban Trust Company, Westfield
2,128,981
The National Bank of New Jersey, New Brunswick (0587). 1,627,775
3, 629, 523
The National Bank of New Jersey, New Brunswick (0587) 4, 000, 000 4, 000, 000

40, 749
226, 093
266, 827
3, 292, 588
1,891,200
1,219,038
233,213

8, 274, 284
10, 662, 876
18,937, 122
170,830,079
449,219,093
613,327,744
19,379,193

1,977,632

57,719,663

1,210,845
720,818

77,098, 856
31, 105, 142

5, 557, 359
5,478,177
6, 070, 573
3,217,330
3, 100, 276

271, 134,779
302,176,433
115,531,849
106, 633, 978
216,080,833

$6, 291, 368
13, 573, 402
19, 864, 770

MAINE

Sept. 29

Kezar Falls National Bank, Parsonsfield (9826).
Maine National Bank, Portland (4128)
Maine National Bank, Portland (4128)
MASSACHUSETTS

Dec. 29

Bay State National Bank, Lawrence (1014)
First Bank and Trust Company, Haverhill *
Second Bay State National Bank, Lawrence (1014).
Bay State National Bank, Lawrence (1014)
MISSISSIPPI

Aug. 31

Lumberton State Bank, Lumberton
First Mississippi National Bank, Hattiesburg (5176).
First Mississippi National Bank, Hattiesburg (5176). .
NEW JERSEY

Jan. 14
Feb. 25

June 23

Aug. 18
Dec. 22

NEW YORK

Mar. 17

Mar. 31

May

5

June 30

Bank of Gouverneur, Gouverneur
300,000
700,000
12,633,834
290, 279
Saint Lawrence County National Bank, Canton (8531)..
555,519
1,687,636
48,545,161
1, 185, 100
Saint Lawrence National Bank, Canton (8531)
743,019
2,500,136
61,246,870
1, 153,435
The Chenango County National Bank and Trust Company, Norwich (3011)
200,000
300,000
12,767,713
774, 090
First-City National Bank of Binghamton, Binghamton
(15625)
4, 050, 000 8, 000, 000 5, 447, 355
198,857,489
First-City National Bank of Binghamton, Binghamton
(15625)
4, 250, 000 8, 300, 000 6,221,446
211,625,203
Royal National Bank of New York, New York (15029).., 9, 637, 360 19,020,644
283, 329, 958
5, 752, 494
Security National Bank, Huntington (6587)
15,329,825 35,516,814 28, 886, 386 1,401,513,359
Security National Bank, Hempstead (6587)
22,213,655 54, 537, 458 36,802,281 1,684,379,988
First National Bank of Edmeston, Edmeston (3681)
150,000
357,426
6, 390, 209
250,000
1, 153,420
Central National Bank, Canajoharie (1122)
61,707,611
1, 850, 000 1, 529, 139
1,466,760
Central National Bank, Canajoharie (1122)
2, 100, 000 1, 743, 935
68, 138,012

See footnote at end of table.




213

TABLE

R-17—Continued

Mergers* of National hanks, or National and State hanks, hy States, calendar 1972
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW YORK—continued

June 30

Oct.

20

Bank of Philadelphia, Philadelphia
The Waddington Bank, Waddington
Jefferson National Bank, LaFargeville (13365)
Jefferson National Bank, LaFargeville (13365)
First National Bank of Central Square, Central Square
(10109)
The Oneida National Bank and Trust Company of Central New York, Utica (1392)
The Oneida National Bank and Trust Company of Central New York, Utica (1392)

$25,000
25,000
25,000
225, 000

$55,000
25,000
175,000
255, 000

$81, 538
123, 657
216, 965
272, 159

$2,056,210
2, 163, 152
3, 154, 290
7, 373, 652

160, 000

500, 000

590,713

17,866,296

5, 846, 220 10, 000, 000

9, 676, 143

358, 761, 262

6, 342, 220 10, 500, 000 10, 266, 855

376, 627, 558

NORTH CAROLINA

First State Bank, Reidsville
Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)
Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)
Banner Elk Bank, Banner Elk
North Carolina National Bank, Charlotte (13761)
21 North Carolina National Bank, Charlotte (13761)
Carolina Bank of Commerce, Eden
North Carolina National Bank, Charlotte (13761)
North Carolina National Bank, Charlotte (13761)
Bank of Winston-Salem, Winston-Salem
Bank of North Carolina, National Association, Jacksonville (14676)
Bank of North Carolina, National Association, Jacksonville (14676)
The Farmers Bank, Woodland
North Carolina National Bank, Charlotte (13761)
28 North Carolina National Bank, Charlotte (13761)
Bank of Hobbsville, Hobbsville
Bank of North Carolina, National Association, Jacksonville (14676)
8 Bank of North Carolina, National Association, Jacksonville (14676)
North Mecklenburg Bank, Cornelius
First Union National Bank of North Carolina, Charlotte
(15650)
18 First Union National Bank of North Carolina, Charlotte
(15650)
The Farmers Bank of Seaboard
Bank of North Carolina, National Association, Jacksonville (14676)
20 Bank of North Carolina, National Association, Jacksonville (14676)
The Bank of New Bern, New Bern
North Carolina National Bank, Charlotte (13761)
15 North Carolina National Bank, Charlotte (13761)
North State Bank, Burlington
Bank of North Carolina, National Association, Jacksonville (14676)
28 Bank of North Carolina, National Association, Jacksonville (14676)
See footnote at end of table.

214



300,000

1, 100,000

534, 076

25, 928, 414

50, 640, 070 51,000,000

38, 865, 842 2,013,049,917

51,360,070
50,000
17, 158,605
17,241, 105
499, 125
17,241, 105
18, 072, 980
300,000

52, 100, 000
215,000
54, 091, 394
54, 273, 895
1, 000, 000
54, 273, 895
54, 941, 145
300, 000

38, 998, 846 2, 037, 667, 546
68, 960
4, 375, 735
25, 629, 925 1, 746, 667, 642
25, 713, 835 1,751,048,916
581, 238
30,314,680
28, 108, 755 1, 883, 287, 655
28, 744, 065 1, 913, 684, 553

3, 430, 375

7,021,625

45, 537

4,217,332

1, 748, 846
287, 718, 384
3,613,375
7, 438, 625
1, 794, 383
291, 935, 716
600,000
400,000
156, 576
16,886, 190
18, 072, 980 54, 941, 145 30, 636, 433 1,955,172,481
18, 447, 980 55, 566, 145 30, 964, 220 1, 972, 125, 047
216, 547
150,000
100,000
5, 151,000
3,613,275
7, 438, 625
105, 163
315,919,749
3, 738, 375 7, 563, 625
321, 709
321,071,599
150,000
150,000
362, 351
19, 088, 825 39, 000, 000 18, 724, 416

8, 177, 358

19, 086, 767 1, 444, 982, 363
129,511 1, 452, 020, 945
3, 482, 290
3, 738, 375 7, 563, 625
428, 362
324,860,673
3,931,935
7, 610, 390
557, 873
328,310,716
120,000
400,000
217,095
13, 274, 782
55, 566, 145 23,061,765 2, 146, 544, 229
29, 516, 768
55, 566, 145 23, 179,633 2, 159,619,294
30, 111,968
408,000
1, 025, 000
221, 763
25, 555, 565
19.238,825
40,325

39, 150,000
200,000

3,835, 155

12,707,170

1,209,016

348, 815, 525

8,690,310

9,285,015

1, 428, 974

369, 659, 404

TABLE B-17—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1972
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

OHIO

June 27

Aug. 15
Sept. 30

Sept. 30

Nov. 29

The North Bloomfield Banking Company, North Bloomfield
The Union National Bank of Youngstown, Youngstown
(13586)
The Union National Bank of Youngstown, Youngstown
(13586)
The Johnstown Bank, Johnstown
The First National Bank of Newark, Newark (858)
The First National Bank of Newark, Newark (858)
The Mount Union Bank, Alliance
The Canton National Bank, Canton (14501)
The United National Bank and Trust Company, Canton
(14501)
The Rockford National Bank, Rockford (11804)
First National Bank of Mercer County, Celina (5523)...
First National Bank of Mercer County, Celina (5523)
The Bank of North Lewisburg Company, North Lewisburg
The Citizens National Bank of Urbana, Urbana (863). .
The Citizens National Bank of Urbana, Urbana (863). .

$330, 000

$420, 000

$327, 395

$15,760,951

6, 000, 000

9, 500, 000

3, 547, 450

158,026, 680

6, 528, 000
100,000

1, 440, 000

10,472,000
225, 000
2, 000, 000
2, 325, 000
1, 000, 000
1, 560, 000

3, 124,823
202,215
426, 873
629, 089
852, 237
1,774, 110

175,472,146
6, 560, 340
54, 690, 902
61,251,243
26, 392, 208
62, 738, 793

2, 200, 000
125,000
750, 000
1,000,000

2, 560, 000
125, 000
750, 000
1, 000, 000

2, 491, 346
372, 727
889, 253
999,981

89,131,000
9, 293, 053
33, 386, 519
42, 747, 466

150, 000
300,000
450, 000

150,000
700,000
1, 050, 000

86, 176
1,042,331
928, 507

3,315,595
19, 774, 260
23, 064, 855

125,000
450, 000
575, 000
250, 000
1,959,000
2, 959, 000

375, 000
2, 562, 000
2, 937, 000
1, 500, 000
2, 932, 000
4, 200, 000

438, 095
1, 607, 054
2, 045, 149
885, 583
238, 349
758, 125

11,526,647
64, 502, 935
76, 029, 581
32,971,030
74, 955, 286
108,092, 670

300,000
531,250
887, 500

700, 000
2, 200, 000
2, 900, 000

1,011,358
1, 099, 962
2, 167, 887

25, 668, 570
51, 887, 864
77, 825, 040

210,615

5,858,331

22, 000, 000 20, 000, 000

9, 473, 329

725, 887, 290

22, 000, 000 20, 000, 000

9, 076, 674

731,770,109

270, 775
2, 173, 367
2, 380, 489

9,490,771
91,406,456
100, 905, 977

1, 069, 976
12, 083, 157
10, 353, 134

18, 654, 553
561, 390, 669
574,786,617

1,500,000
1,500,000
625, 000

PENNSYLVANIA

June 30
July

Oct.

17

2

The First National Bank of Oley, Oley (8858)
The National Bank of Boyertown, Boyertown (2137)
National Bank of Boyertown, Boyertown (2137)
The Farmers National Bank of Ephrata (4923)
Farmers First National Bank, Lititz (5773)
Farmers First National Bank, Ephrata (5773)
The First National Bank of Mount Carmel, Mount Carmel
(3980)
The First National Bank of Sunbury, Sunbury (1237)
First National Trust Bank, Sunbury (1237)
UTAH

Sept.

5

North Davis Bank, Layton
First Security Bank of Utah, National Association, Ogden
(2597)
First Security Bank of Utah, National Association, Ogden
(2597)

200,000

135,000

VERMONT

Nov. 24

Ethan Allen National Bank, Fairhaven (2422)
Vermont National Bank, Brattleboro (1430)
Vermont National Bank, Brattleboro (1430)

220, 000
1,524, 110
1,799,110

220,000
2, 261, 912
2,481,912

WASHINGTON

July

15

Bothell State Bank, Bothell
Peoples National Bank of Washington, Seattle (14394)
Peoples National Bank of Washington, Seattle (14394)

200,000
11,722,500
11,722,500

700,000
11,777,500
12,477,500

•Excludes mergers involving only one operating bank, effected pursuant to corporate reorganization.




215

TABLE

R-18

Mergers resulting in National banks, by assets of acquiring and acquired banks,

1960-72*

Assets of acquired bank
Assets of acquiring bank]

Acquired
banks
1960-72

Under $10
million

$10 million
to $24.9
million

$25 million
to $49.9
million

$50 million
to $99.9
million

$100 million
and over

84
132
151
164
488

84
118
98
104
211

0
14
42
38
169

0
0
11
19
57

0
0
0
3
24

0
0
0
0
27

l,019J

615

263

87

27

27

Under $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

•Includes all forms of acquisitions involving two or more banks from May 13, 1960 through December 31, 1972.
f i n each transaction, the bank with larger total assets was considered to be the acquiring bank.
{Comprises 981 transactions, 23 involving three banks, six involving four banks, and one involving five banks.

TABLE

B-19

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Local

251

Total.
ALABAMA

15073
14569
15473
3185
14414
15427
15658
15316
7746
13414
1814
15053
15604
7568

First National Bank of Athens, Athens
Birmingham Trust National Bank, Birmingham
City National Bank of Birmingham, Birmingham
The First National Bank of Birmingham, Birmingham
State National Bank of Alabama, Decatur
Shoals National Bank of Florence, Florence
Fort Rucker National Bank, Fort Rucker
The American National Bank of Huntsville, Huntsville
The First National Bank of Jasper, Jasper
The American National Bank & Trust Company of Mobile, Mobile.
The First National Bank of Montgomery, Montgomery
Phenix National Bank, Phenix City
'
The Deposit National Bank of Mobile County, Prichard
The First National Bank of Wetumpka, Wetumpka
ALASKA

12070
14651
14747

The First National Bank of Anchorage, Anchorage
National Bank of Alaska, Anchorage
Alaska National Bank, Fairbanks
ARIZONA

3728
14324

First National Bank of Arizona, Phoenix
The Valley National Bank of Arizona, Phoenix
ARKANSAS

16009
13693
6758
15482
15631

Worthen Bank & Trust Company, National Association, Little Rock
The First National Bank in Mena, Mena
The First National Bank of Newport, Newport
Pine Bluff National Bank, Pine Bluff
First National Bank, Searcy

216



Outside
branches
611

Total

862

TABLE
Domestic branches entering the National

B-19—Continued

Banking System, by de novo opening, merger, or conversion, by States, calendar

1972

Branches openedfor business
Charter
No.

Title and location of bank
Outside
branches
CALIFORNIA

15347
15437
14695
12904
15007
15958
2491
15532
15349
10391
13044
9655
1741
15660
2158
14891

Alameda First National Bank, Alameda
American National Bank, Bakersfield
City National Bank, Beverly Hills
The Capital National Bank, Downey
First National Bank of Fresno, Fresno
Gavilan National Bank, Gilroy
Security Pacific National Bank, Los Angeles
Commercial and Farmers National Bank, Oxnard
Valley National Bank, Salinas.
United States National Bank, San Diego
Bank of America National Trust and Savings Association, San Francisco
The Bank of California, National Association, San Francisco
Crocker National Bank, San Francisco
Wells Fargo Bank, National Association, San Francisco
The First National Bank of San Jose, San Jose
Santa Barbara National Bank, Santa Barbara

0
3
1
1
1
1
22
2
1
3
14
3
7
10
2
1

COLORADO

2179
14862

The First National Bank of Colorado Springs, Colorado Springs
Lakeside National Bank, Wheat Ridge
CONNECTICUT

780
4
1338
720
227
15439
15354
14972
15363

The City National Bank of Connecticut, Bridgeport
The State National Bank of Connecticut, Bridgeport
Hartford National Bank and Trust Company, Hartford
The Home National Bank and Trust Company, Meriden
The Second National Bank of New Haven, New Haven
The North Haven National Bank, North Haven
Orange National Bank, Orange
Vernon National Bank, Vernon
Westport National Bank, Westport
DISTRICT OF COLUMBIA

2038
3423
15605

The First National Bank of Washington, District of Columbia
The National Bank of Washington, District of Columbia
National Savings and Trust Company, District of Columbia.
Union Trust Company of the District of Columbia, District of Columbia.
GEORGIA

1559
9617
15541
4944
4691
14061
11936
3830
7969
15373
13068
4429
7899

The First National Bank of Atlanta, Atlanta
The Fulton National Bank of Atlanta, Atlanta
The National Bank of Georgia, Atlanta
The First National Bank of Brunswick, Brunswick
The Fourth National Bank of Columbus, Columbus
First National Bank in Elberton, Elberton
First National Bank of Lawrenceville, Lawrenceville
The First National Bank of Cobb County, Marietta
First National Bank of McDonough, McDonough
First National Bank of Houston County, Savannah
The Citizens and Southern National Bank, Savannah
The First National Bank of Valdosta, Valdosta
The First National Bank of Waynesboro, Waynesboro

.

HAWAII

14911

Hawaii National Bank, Honolulu, Honolulu
IDAHO

1668
11076

The Idaho First National Bank, Boise
The Farmers National Bank of Buhl, Buhl




217

TABLE B-19—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location oj bank
Outside
branches
ILLINOIS

11923
14419
1926
14748
14372
15594
10079
14524
4400
13605
1715
4994
14605

First National Bank and Trust Company, Centralia
Mercantile National Bank of Chicago, Chicago
The De Witt County National Bank of Clinton, Clinton.
Downers Grove National Bank, Downers Grove
First National Bank in Harvey, Harvey
Libertyville National Bank, Libertyville
The Litchfield National Bank, Litchfield
Union National Bank of Marseilles, Marseilles
The National Bank of Monmouth, Monmouth
The Second National Bank of Robinson, Robinson
The Salem National Bank, Salem
The First National Bank of Vandalia, Vandalia
Wauconda National Bank, Wauconda
INDIANA

699
1066
2183
12132
7725
14113
13759
984
869
6765
13729
14921
9756
7180
5067
14288
13987

The First National Bank of Aurora, Aurora
The First National Bank of Columbus, Columbus
The First National Bank of Crown Point, Crown Point
The National City Bank of Evansville, Evansville
Lincoln National Bank and Trust Company of Fort Wayne, Fort Wayne
The First National Bank of Goshen, Goshen
American Fletcher National Bank and Trust Company, Indianapolis
The Indiana National Bank, Indianapolis
Merchants National Bank & Trust Company of Indianapolis, Indianapolis.
The Lowell National Bank, Lowell
Marion National Bank of Marion, Marion
American National Bank and Trust Company of Muncie, Muncie
The American National Bank of Noblesville, Noblesville
The First National Bank of Portland, Portland
The Rockville National Bank, Rockville
Farmers & Merchants National Bank of Rensselaer, Rensselaer
The National Bank and Trust Company of South Bend, South Bend
IOWA

14832
5022
5891

South Des Moines National Bank, Des Moines
Northwestern National Bank of Sioux City, Sioux City
First National Bank of West Des Moines, West Des Moines.
KENTUCKY

12293
5900
1900
6028
13651
13479
109
906
6622
11544

The Third National Bank of Ashland, Ashland
The Citizens National Bank of Bowling Green, Bowling Green
The National Bank of Cynthiana, Gynthiana
The First-Hardin National Bank, Elizabeth town
The New Farmers National Bank of Glasgow, Glasgow
The Lincoln National Bank of Hodgenville, Hodgenville
First National Bank of Louisville, Louisville
First Security National Bank and Trust Company of Lexington, Lexington.
The First National Bank of Pikeville, Pikeville
The Citizens National Bank of Somerset, Somerset
LOUISIANA

14484
9834
15642
14989
14086
14753
4154
11669
13668

Security National Bank, Alexandria, Alexandria
Louisiana National Bank of Baton Rouge, Baton Rouge
Parish National Bank of Bogalusa, Bogalusa
Commercial National Bank, Covington
The Citizens National Bank in Hammond, Hammond
The National Bank of Commerce in Jefferson Parish, Jefferson Parish.
The First National Bank of Lake Charles, Lake Charles
First National Bank in Mansfield, Mansfield
The Hibernia National Bank, New Orleans

218



Total

TABLE B-19—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Outside
branches

LOUISIANA—continued

15952
13689
14977

Century National Bank in New Orleans, New Orleans.
First National Bank of Commerce, New Orleans
Whitney National Bank of New Orleans, New Orleans.

1437
4459
13750
941
4128

Merchants National Bank of Bangor, Bangor
The First National Bank of Farmington, Farmington.
Norway National Bank, Norway
Canal National Bank, Portland
Maine National Bank, Portland
MARYLAND

15314
1413
13745
5561
14937
15154
15249

Aberdeen National Bank, Aberdeen
,.. .
The First National Bank of Maryland, Baltimore
Maryland National Bank, Baltimore
Sandy Springs National Bank and Savings Institution, Sandy Springs.
American National Bank of Maryland, Silver Spring
Peoples National Bank of Maryland, Suitland
Chesapeake National Bank, Towson
MASSACHUSETTS

779
614
590
1320
528
474
484
1129
2618
866
799
736
1082
308
1440
1022
14033
79

Plymouth-Home National Bank, Brockton
Middlesex Bank, N.A., Burlington
The Fall River National Bank, Fall River
Falmouth National Bank, Falmouth
Community National Bank, Framingham
First National Bank of Franklin County, Greenfield
The Haverhill National Bank, Haverhill
Merrimack Valley National Bank, Haverhill
The Hudson National Bank, Hudson
Milford National Bank and Trust Company, Milford
The Merchants National Bank of New Bedford, New Bedford. .
First National Bank of Cape Cod, Orleans
First Agricultural National Bank of Berkshire County, Pittsfield.
Third National Bank of Hampden County, Springfield
The National Bank of Wareham, Wareham
Blackstone Valley National Bank, Whitinsville
Tanners National Bank in Woburn, Woburn
Worcester County National Bank, Worcester
MICHIGAN

14933
14185
13833
14925
13738
14948
13671
16037
11954
14144
3806
15367
191
14032
15444
14016
1587
9000
15899

National Bank and Trust Company of Ann Arbor, Ann Arbor
Security National Bank of Battle Creek, Battle Creek
Farmers and Merchants National Bank in Benton Harbor, Benton Harbor.
City National Bank of Detroit, Detroit
Manufacturers National Bank of Detroit, Detroit
Michigan Bank, National Association, Detroit
National Bank of Detroit, Detroit
Central Bank, N.A., Grand Rapids
The First National Bank of Hermansville, Hermansville
First National Bank in Howell, Howell
The First National Bank of Iron Mountain, Iron Mountain
City Bank and Trust Company, National Association, Jackson
The First National Bank and Trust Company of Michigan, Kalamazoo... .
Michigan National Bank, Lansing
Livonia National Bank, Livonia
The National Bank of Ludington, Ludington
The First National Bank of Monroe, Monroe
The First National Bank of Alger County at Munising, Munising
West Oakland Bank, National Association, Novi

501-017 O—73




219

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Outside
branches
MICHIGAN—continued

15938
15274
15403
15167
15527
13874
14934
14918
15611
15286
13807

The American National Bank in Portage, Portage
National Bank of Rochester, Rochester
*
Valley National Bank of Saginaw, Saginaw
National Bank of Southfield, Southfield
Oakland National Bank, Southfield
National Bank Wyandotte-Taylor, Taylor
The Empire National Bank of Traverse City, Traverie City.
National Bank and Trust Company of Traverse City, Traverse City.
First National Bank of Warren, Warren
First National Bank of Wyoming, Wyoming
The National Bank of Ypsilanti, Ypsilanti
MISSISSIPPI

15663
15559
5176
15539
15516
15548
10523
13551

Coahoma National Bank, Clarksdale
First National Bank of Greenwood, Greenwood
First Mississippi National Bank, Hattiesburg
Southern National Bank of Hattiesburg, Hattiesburg.
Citizens National Bank, Jackson
Deposit Guaranty National Bank, Jackson
First National Bank of Jackson, Jackson
First National Bank in Meridian, Meridian
MISSOURI

7351
4441
14984
4157
13162
15299
15985
6382
9382
15183
5156

The First National Bank of Braymer, Braymer
United Missouri Bank of Carthage, National Association, Carthage.
Columbia National Bank, Columbia
The First National Bank of Independence, Independence
First National Bank and Trust Company of Jopjin, Joplin
United Missouri Bank of Joplin, National Association, Joplin
Commerce Bank of Kansas City, National Association, Kansas City.
The First National Bank of Neosho, Neosho
The Thornton National Bank of Nevada, Nevada
American National Bank in Springfield, Springfield
The Peoples National Bank of Warrensburg, Warrensburg
NEBRASKA

9694

The Gering National Bank, Gering.
NEVADA

7038
15645

First National Bank of Nevada, Reno.
Nevada National Bank, Reno
NEW HAMPSHIRE

877
574
1059
1070
1310
19
1052
13861

The Keene National Bank, Keene
The Amoskeag National Bank, Manchester
Bank of New Hampshire, National Association, Manchester.
The Souhegan National Bank of Milford, Milford
Indian Head National Bank of Nashua, Nashua
The First National Bank of Portsmouth, Portsmouth
Indian Head National Bank of Portsmouth, Portsmouth....
First National Bank of Rochester, Rochester
NEW JERSEY

10823
15781
5621
2999
9498
13203
1209

The First National Bank of Absecon, Absecon
Atlantic National Bank, Atlantic City
The First National Bank of Blairstown, Blairstown
Citizens National Bank of South Jersey, Bridgeton
The Farmers and Merchants National Bank of Bridgeton, Bridgeton.
Third National Bank of New Jersey, Camden
South Jersey National Bank, Cherry Hill

220



Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches openedfor business
Chart*
No.

Title and location of bank
Total

Outside
branches
NEW JERSEY—continued
The United National Bank of Bergen County, Cliffside Park.
New Jersey Bank (National Association), Clifton
National Union Bank of New Jersey, Dover.
First National Bank of South Jersey, Egg Harbor Township
The National State Bank, Elizabeth, N.J., Elizabeth
First National State Bank of North Jersey, Hackensack
Colonial National Bank, Haddonfield
Peoples National Bank of Monmouth County, Hazlet
The First Jersey National Bank, Jersey City
First National State Bank of Ocean County, Lakewood
The City National Bank of Millville, Millville
The First National Bank of Minotola, Minotola
Pint Chami National Bank, Monroe Township
American National Bank & Trutt of New Jersey, Montclair
The First National Iton Bank of New Jersey, Morristown.
1113
13363 First Merchants National Bank, Neptune Township
Broad National Bank, Newark, Newark
12771
First National State Bank of New Jersey, Newark
1452
The National Bank of New Jersey, New Brunswick
587
15790 Bank of Passaic and Clifton, National Association, Passaic
15839 The First National Bank, Piscataway, Piscataway Township
4872 The First National Bank of Princeton, Princeton
2257 Colonial First National Bank, Red Bank
Citizens First National Bank of Ridgewood, Ridgewood
11759
3866 First National Bank of Central Jersey, Somerville
First National State Bank of Northwest Jersey, Succasunna
860
4365 Citizens National Bank, Tenafly
2509 The First National Bank of Toms River, N.J., Toms River
First National Bank of New Jersey, Totowa
329
New Jersey National Bank, Trenton
,
1327
Peoples National Bank of New Jersey, Westmont
399
15838 Mid-Jersey National Bank, Woodbridge
National Bank and Trust Company of Gloucester County, Woodbury.
1199

14162
15709
2076
1326
1436
12014
14457
4147
374
16035
14673
10440

$6

2
0
0
1
0
0
0
1
0
1
1
0

0
1
1
2
10
1
2
0
2
3
0
1

0

1
1

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

1
2
0
0
12
1
0

J

NEW MEXICO

14786
12485
13814
14836
14628
1750
13438

First National Bank in Alamogordo, Alamogordo
Albuquerque National Bank, Albuquerque
First National Bank in Albuquerque, Albuquerque
First National Bank of Grants, Grants
First National Bank of Lea County, Hobbs
The First National Bank of Santa Fe, Santa Fe
Hot Springs National Bank, Truth or Consequences

1
1
1
1
0
1
0

0
0
0
0
1
0
1

0
0
0
1
3
0
0
1
0
0
0
0
1
0
0
0
0
0

2
1
1
1

NEW YORK

15758
1301
963
15625
12997
15080
1122
853
976
15464
9322
1151
1245C
658'
770!
1336.
1592!
1331

Bankers Trust Company of Albany, National Association, Albany
National Commercial Bank and Trust Company, Albany
Union National Bank, Albany
First-City National Bank of Binghamton, Binghamton
Franklin National Bank, Brooklyn
Liberty National Bank and Trust Company, Buffalo
Central National Bank, Canajoharie, Canajoharie
The St. Lawrence National Bank, Canton
The Putnam County National Bank of Carmel, Carmel
First National Bank of East Hampton, East Hampton
The First National Bank of East Islip, East Islip
Marine Midland Tinker National Bank, East Setauket
The National Bank of Geneva, Geneva
Security National Bank, Hempstead
National Bank of North America, Jamaica
Jefferson National Bank, La Fargeville
Chase Manhattan Bank of Long Island (National Association), Melville.
Nanuet National Bank, Nanuet




2

4
3
1
1
1
1
4
0
12
c

2
2
1

221

TABLE

R-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Outside
branches

NEW YORK—continued
The Chase Manhattan Bank (National Association), New York
Community National Bank & Trust Company of New York, New York
1416 First National City Bank, New York
13493 Finger Lakes National Bank, Odessa
2151 Wilber National Bank of Oneonta, Oneonta
12788 Bankers Trust of Suffolk, National Association, Patchogue
465 Marine Midland Bank of Southeastern New York, N.A., Poughkeepsie
15641 Bankers Trust Hudson Valley, National Association, Poughkeepsie
4230 The Suffolk County National Bank of Riverhead, Riverhead
15556 First National Bank of Rochester, Rochester
11708 Scarsdale National Bank and Trust Company, Scarsdale
..
14763 Chemical Bank of Suffolk, National Association, Smithtown
15627 Lincoln National Bank and Trust Company of Central New York, Syracuse..
1342 The Merchants National Bank & Trust Company of Syracuse, Syracuse
.
721 Marine Midland Bank-Eastern, National Association, Troy
1392 The Oneida National Bank and Trust Company of Central New York, Utica.
2659 The National Bank of Northern New York, Watertown
10525 National Bank of Wcstchester, White Plains

2370
15558

NORTH CAROLINA

11091
15636
15650
13761
14481
13779
14676
10610
11229
10608
15673

The First National Bank of Albermarle, Albermarle
City National Bank, Charlotte
First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
Citizens National Bank of Concord, Concord
The Citizens National Bank in Gastonia, Gastonia
Bank of North Carolina, National Association, Jacksonville
Southern National Bank of North Carolina, Lumberton
First National Bank of Reidsville, Reidsville
The Planters National Bank and Trust Company, Rocky Mount.
Wachovia Bank and Trust Company, N.A., Winston-Salem
NORTH DAKOTA

15973
3096

Columbus National Bank, Columbus.
The Grafton National Bank, Grafton.

13749 Bellefontaine National Bank, Bellefontaine
3654 The Farmers National Bank of Canfield, Canfield
76 First National Bank of Canton, Canton
,
14501 The United National Bank & Trust Company, Canton
,
5523 First National Bank of Mercer County, Celina
15423 The Capital National Bank, Cleveland
4318 Central National Bank of Cleveland, Cleveland
786 The National City Bank of Cleveland, Cleveland
14761 Society National Bank of Cleveland, Cleveland
7621 The City National Bank & Trust Company of Columbus, Columbus....
7745 The Huntington National Bank of Columbus, Columbus
5065 The Ohio National Bank of Columbus, Columbus
5530 Western Ohio National Bank, Covington
10 The Third National Bank and Trust Company of Dayton, Ohio, Dayton.
15577 Elyria Savings & Trust National Bank, Elyria
15861 Citizensbank National Bank, Felicity
15591 Tri-County National Bank, Fostoria
8228 The First National Bank of Harrison, Harrison
98 The First National Bank of Ironton, Ironton
652 The Portage National Bank, Kent
14360 The First National Bank of Marysville, Marysville
484!
The Old Phoenix National Bank of Medina, Medina
8709 The First National Bank of Warren County, Morrow
858 The First National Bank of Newark, Newark




2
0
9
26
0
1
16
2
0
2
16

Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Local

Outside
branches

Total

OHIO—continued
13742
14686
7035
7781
7862
2160
14586
2350
13586
863
164

First National Bank, Orrville
The Lake County National Bank of Painesville, Painesville
The Peoples National Bank of Plymouth, Plymouth
The Security Central National Bank of Portsmouth, Portsmouth
The Citizens Baughman National Bank, Sidney
The First National Bank and Trust Company in Steubenville, Steubenville.
First National Bank of Toledo, Toledo
The Mahoning National Bank of Youngstown, Youngstown
The Union National Bank of Youngstown, Youngstown
The Citizens National Bank of Urbana, Urbana
The First National Bank of Zanesville, Zanesville

0
0
1
0
0
1
2
1
0
0
1

1
1
0
1
1
0
0
2
2
1
0

1
1
1
1
1
1

0
0
0
0
0
0

0
2
0
1
0

1
3
1
2
1

1
0
0
0
0
0
0
0
0
0
0
0
1
0
1
0
0
0
1
0
1
0
1
0
0
0
0
2
0
0
0
1
0

0
1
1
1
2
3
2
1
1
1
1
3
0
2
1
2
3
2
0
1
0
1
0
1
1
1
3
1
1
1
1
0
1

OKLAHOMA

14005
4862
13891
15429
5478
4704

The First National Bank in Durant, Durant
The First National Bank and Trust Company of Oklahoma City, Oklahoma City.
First National Bank and Trust Company, Ponca City
First National Bank, Sallisaw, Sallisaw
The First National Bank of Tahlequah, Tahlequah
The First National Bank and Trust Company of Vinita, Vinita
OREGON

15583
1553
15491
4514
14860

Crater National Bank, Medford
First National Bank of Oregon, Portland
Great Western National Bank, Portland
United States National Bank of Oregon, Portland.
Douglas National Bank, Roseburg
PENNSYLVANIA

373
4915
723
5823
2137
15422
355
5019
8854
311
249
580
3893
14098
2634
694
5773
12
870
357
1516
5686
562
14542
13754
7710
252
2222
5702
328
8764
6483
1237

The First National Bank of Allen town, Allentown
The Farmers National Bank of Athens, Athens
Central-Penn National Bank, Bala-Cynwyd
First National Bank of Somerset County, Berlin
National Bank of Boyertown, Boyertown
Provident National Bank, Bryn Mawr
Southeast National Bank of Pennsylvania, Chester
DuBois Deposit National Bank, DuBois
,
The Citizens National Bank of Evans City, Evans City
,
Adams County National Bank, Gettysburg
Fiist National Bank of Mercer County, Greenville
The Commonwealth National Bank, Harrisburg
Peoples First National Bank and Trust Company, Hazleton
National Bank of the Commonwealth, Indiana
The Fulton National Bank of Lancaster, Lancaster
National Central Bank, Lancaster
Farmers First National Bank, Lititz
The First National Bank of Pennsylvania, Meadville
Marine National Bank, Meadville
Tri-County National Bank, Middleburg
The Union National Mount Joy Bank, Mount Joy
The Second National Bank of Nazareth, Nazareth
First National Bank of Lawrence County at New Castle, New Castle
,
Cumberland County National Bank and Trust Company, New Cumberland.
The First National Bank of Peckville, Peckville
The Pen Areyl National Bank, Pen Argyl
Pittsburgh National Bank, Pittsburgh
Western Pennsylvania National Bank, Pittsburgh
Keystone National Bank, Punxsutawney
Citizens & Northern National Bank and Trust Company, Ralston
The McDowell National Bank of Sharon, Sharon
The First National Bank of Slippery Rock, Slippery Rock
First National Trust Bank, Sunbury
f




223

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Outside
branches
PENNSYLVANIA—continued

39
5034
5920
5184

The First National Bank of Bradford County, Towanda
Gallatin National Bank, Uniontown
First National Bank & Trust Co., Washington, Pa., Washington.
Southern Pennsylvania National Bank, York
RHODE ISLAND

13981
1302
15723

Columbus National Bank of Rhode Island, Providence. .
Industrial National Bank of Rhode Island, Providence. .
Rhode Island Hospital Trust National Bank, Providence.
SOUTH CAROLINA

14425
2044
13720
10536
10660

The Citizens and Southern National Bank of South Carolina, Charleston.
The South Carolina National Bank, Charleston
First National Bank of South Carolina, Columbia
The Conway National Bank, Conway
The National Bank of South Carolina of Sumter, Sumter
TENNESSEE

14611
7848
9667
9397
14653
4177
15056
2168
3576
13635
14657
13539
2049
10028
336
13349
3032
13103
14619
15590
3660
12639

American National Bank and Trust Company of Chattanooga, Chattanooga.
The Hamilton National Bank of Chattanooga, Chattanooga
The First National Bank of Cookeville, Cookeville
The First National Bank of Franklin County at Decherd, Decherd
The First National Bank of Gatlinburg, Gatlinburg
The First National Bank of Greeneville, Greeneville
The First National Bank of Gibson County, Humboldt
The First National Bank of Jackson, Jackson
The Second National Bank of Jackson, Jackson
The Hamilton National Bank of Johnson City, Johnson City
The Kingsport National Bank, Kingsport
The Hamilton National Bank of Knoxville, Knoxville
Park National Bank of Knoxville, Knoxville
The First National Bank of Anderson County, Lake City
The First National Bank of Memphis, Memphis
Union Planters National Bank of Memphis, Memphis
First American National Bank of Nashville, Nashville
Third National Bank in Nashville, Nashville
First National Bank of Pulaski, Pulaski
First National Bank of Selmer, Selmer
The First National Bank of South Pittsburg, South Pittsburg
The First National Bank of Springfield, Springfield
UTAH

14964
2597
4341

First Western National Bank, Moab
First Security Bank of Utah, National Association, Ogden.
Zions First National Bank, Salt Lake City
VERMONT

1430
194
2274

Vermont National Bank, Brattleboro
Catamount National Bank, North Bennington.
The Randolph National Bank, Randolph
VIRGINIA

7093
651
15353
9295
14904

Alexandria National Bank, Alexandria
United Virginia Bank/First & Citizens National, Alexandria.
Woodlawn National Bank, Alexandria
The First National Bank of Altavista, Altavista
Dominion National Bank, Baileys Cross Roads

224



Total

TABLE R~ 19—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1972
Branches opened for business
Charter
No.

Title and location of bank
Local

Outside
branches

Total

VIRGINIA—continued

15390
8875
9343
6389
5683
10834
1522
7206
15461
10194
9885
14190
11387
10857
1111
2737
15117
1824
10973
11901
155G2
15984

First Virginia Bank-Monticello National, Gharlottesville
The National Bank of Ghilhowie, Chilhowie
American National Bank & Trust Company of Danville, Danville
The National Bank of Fairfax, Fairfax
The First National Bank of Farmville, Farmville
The Grayson National Bank, Independence
The Fidelity National Bank, Lynchburg, Lynchburg
The First National Bank of Martinsville and Henry County, Martinsville.
First National Bank of Norfolk, Norfolk
United Virginia Bank/Seaboard National, Norfolk
Virginia National Bank, Norfolk
Farmers & Merchants National Bank in Onley, Onley
The Peoples National Bank, Pulaski
The Richlands National Bank, Richlands
First & Merchants National Bank, Richmond
The First National Exchange Bank of Virginia, Roanoke
United Virginia Bank Security National, Roanoke
The Farmers National Bank of Salem, Salem
The Farmers & Merchants National Bank of Stanley, Stanley
The First National Bank of Stuart, Stuart
Williamsburg National Bank, Williamsburg
First & Merchants National Bank of the Peninsula, County of York

2
1
1
2
1
1
1
1
3
1
2
1
1
1
2
2
2
2
1
1
1
6

WASHINGTON

4375 The National Bank of Commerce of Seattle, Seattle.
3417 Pacific National Bank of Washington, Seattle
14394 Peoples National Bank of Washington, Seattle
11280 Seattle-First National Bank, Seattle
4668 Old National Bank of Washington, Spokane
12292 Puget Sound National Bank, Tacoma
WEST VIRGINIA

15385

The First National Bank of Belle, Belle.
WISCONSIN

144
15972
14460
14109

First Wisconsin National Bank of Madison, Madison
Manitowoc Savings Bank, National Association, Manitowoc.
The First National Bank in Menomonie, Menomonie
National Bank of Commerce in Superior, Superior




225

TABLE

B-20

Domestic branches of National banks closed, by States, calendar 1972
Branches closed
Charter
No.

Title and location of bank
Local

Outside
branches

Total

42

Total

127

0
0
2
1
0
0
0
0

1
1
0
2
1
9
1
1

ARIZONA
14324

T h e Valley National Bank of Arizona, Phoenix

14670
14695
2491
3050
10391
13044
9655
1741

Community National Bank, Bakersfield
City National Bank, Beverly Hills
Security Pacific National Bank, Los Angeles
Southern California First National Bank, San Diego
United States National Bank, San Diego
Bank of America National Trust and Savings Association, San Francisco.
The Bank of California, National Association, San Francisco
Crocker National Bank, San Francisco

14248

Union National Bank in Denver, Denver

CALIFORNIA

COLORADO

CONNECTICUT

227

The Second National Bank of New Haven, New Haven.
DISTRICT OF COLUMBIA

15127

Public National Bank, District of Columbia
GEORGIA

9617

The Fulton National Bank of Atlanta, Atlanta
IDAHO

11076

The Farmers National Bank of Buhl, Buhl
INDIANA

2234

The Merchants National Bank of Muncie, Muncie
IOWA

14868
3320

Northwest D e s M o i n e s National Bank, D e s M o i n e s . . . .
T h e First N a t i o n a l Bank of Sibley, Sibley

14959

Seneca National Bank of Wichita, Wichita

KANSAS

KENTUCKY

5900

The Citizens National Bank of Bowling Green, Bowling Green

2260
94

First-Manufacturers National Bank of Lewiston and Auburn, Lewiston.
Canal National Bank, Portland

MAINE

MASSACHUSETTS

474
1082
1481
2232
7!

First National Bank of Franklin County, Greenfield
First Agricultural National Bank of Berkshire County, Pittsfield.
Security National Bank of Springfield, Springfield
First Bristol County National Bank, Taunton
Worcester County National Bank, Worcester
MICHIGAN

1382C
1540;

American National Bank and Trust Company of Michigan, Kalamazoo.
Valley National Bank of Saginaw, Saginaw

226



12

TABLE B-20—Continued

Domestic branches of National banks closed, by States, calendar 1972
Branches closed
Charter
No.

Title and location of bank
Local

Outside
branches

Total

NEW JERSEY

1209
14162
1436
4365
10376
1452
12425

South Jersey National Bank, Gamden
The United National Bank of Bergen County, Cliffside Park.
The National State Bank, Elizabeth, N.J., Elizabeth
Citizens National Bank, Englewood
Keansburg-Middletown National Bank, Middletown
,
First National State Bank of New Jersey, Newark
The Union Center National Bank, Union

1198
6587
7703
2370
1461
13664
11881

The Tanners National Bank of Catskill, Catskill
Security National Bank, Huntington
National Bank of North America, New York
The Chase Manhattan Bank (National Association), New York.
First National City Bank, New York
The First National Bank of Painted Post, Painted Post
Valley National Bank of Long Island, Valley Stream

15650
13761
10610
10608
15673

First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
Southern National Bank of North Carolina, Lumberton. .
The Planters National Bank and Trust Company, Rocky Mount.
The Wachovia Bank and Trust Company, N.A., Winston-Salem.

NEW YORK

20

NORTH CAROLINA

OHIO

7744
786
2604
8228

The
The
The
The

Athens National Bank, Athens
National City Bank of Cleveland, Cleveland
Winters National Bank and Trust Company of Dayton, Dayton.
First Bank of Harrison, Harrison
PENNSYLVANIA

2428
14156
240
705

The Bradford National Bank, Bradford
Community National Bank of Pennsylvania, Johnstown.
The First National Bank of Lebanon, Lebanon
The Union National Bank of Pittsburgh, Pittsburgh

15664

Industrial National Bank of Rhode Island, Providence

15639

United National Bank, Rapid City

13681
8025
3660

National Bank of Commerce, Memphis
The Hamilton National Bank of Morristown, Morristown
The First National Bank of South Pittsburg, South Pittsburg. .

15243

American National Bank, Salt Lake City

RHODE ISLAND

SOUTH DAKOTA

TENNESSEE

UTAH

VERMONT

1430
1698

Vermont National Bank, Brattleboro
The Howard National Bank and Trust Company, Burlington.
VIRGINIA

15334
15461
11387
1111

Bank of Virginia-Fredericksburg, National Association, Fredericksburg.
First National Bank of Norfolk, Norfolk
The Peoples National Bank, Pulaski
First & Merchants National Bank, Richmond

14394

The Peoples National Bank of Washington, Seattle.

WASHINGTON

Adjustment made from prior years




227

TABLE

B-21

Principal assets, liabilities, and capital accounts of National banks, by deposit size, year-end 1971 and 1972
[Dollar amounts in millions]
Securities*
Number
of banks

Total
assets

Cash and
cash items

Loans*
Total

Deposits

U.S.
Treasury
securities]

Fixed
assets
Total

Demand

Time
and
savings

Capital
stock

Capital
Surplus,
notes and undivided
deben- profits, and
tures
reserves

1972
Deposit size

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..
$500.0 and over...

12
65
420
904
1,603

Total

$16

$3
17
233
926
3,404
3,707

$4
39
576
2,483
9,416
9,608
9,619
20, 626
51, 367

6,680
16, 555

315
110

1,731
7,549
28, 795
31,065
31,922
77,682
256, 057

43,311

$5
57
772
3,552
13,898
15, 709
16,290
39, 685
140, 489

4,614

434, 947

67,401

230, 456 103, 736

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..
$500.0 and over...

15
75
549
992
1,556
690
338
289
96

17
140
2,260
8,270
27,566
27,546
26,447

4
47
775
2,786
9, 263
8,752

212, 935

3
22
313
1,068
3,366
3,462
3,421
11,646
35,900

Total

4,600

376, 456

59, 201

781
404

132

4,048

11,752

$3
27
326

$1
3
25
117
478
542
604

$9
101

$6
59
734
3,049
10, 999
11,665
12, 226
32, 345

$2
41

1,355
4,344

$0
0
1
5
34
66
91
320
1,612

2,129

$3
11
41

$4
18
124
470

4,186

27, 614
28, 278
66,808
202,493

101,482

797
3,699
14, 847
15,949
16,051
34,463
101,011

35, 299

7,333

359, 427

172,565

186, 862

7,500

3
33
445
1,350
3,930

2
34
138

10
116
1,990
7, 367
24,631
24, 377
23, 293
61, 278
171, 151

7
71
946
3,322
10, 565
10, 521
10, 139
30, 416
85, 997

3
46
1,044
4,044
14, 066
13,856
13, 153
30, 861
85, 153

3
6
54
159
493
506
484
1,346
3,777

1,107

1,409
1,321
3,477
10, 368

314, 212

151, 985

162, 227

6, 828

1,449

18, 795

1, 155
3,788

3,449
3,316

1,378

1,531
6,748
25,846

142

486
555
564

1,556
1,577
1,563
3,652
11,757

20, 723

1971
Deposit size

71, 275

6
59
1,007
3,875

13, 145

m\

113,522

19, 395
46, 853

15, 959

509
507
1,311
3,628

194, 145

96, 029

36, 396

6,611

13,600

13,231
35,699

8, 155

3, 328
3, 027
8, 320

* Loans and securities figures are shown gross; reserves are not deducted from the respective assets.
fInvestment securities only; excludes securities held in trading accounts.
NOTE: Data may not add to totab because of rounding. Dashes indicate amounts of less than $500,000.



4
15

3
25
49
62
203

167
516
1,517

TABLE

B-22

Dales of reports of condition of National banks,

1914-72

[For dates of previous calls see Annual Report for 1920, vol. 2, table No. 42, p. 150]
Tear
1914
1915
1916
1917
1918
1919
1920
1921
1922
1923
1924
1925
1926
1927
1928
1929
1930....
1931
1932
1933
1934
1935
1936
1937
1938
1939
1940
1941
1942
1943
1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
I960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972

See notes on next page.




Jan.

Feb.

13

Mar.

Apr.

4
4
7
5
4
4
28 ....'
21
10

May

1
1
1
10
12
4
28
5
3

31
6
12
23
28
27
27
25
5
4
4
31
7
29
26
4
4
13
20
12
11
24
9
31
20
15
11
10
14
4
12
15
12
26
18
15
26
5
25
18
30
30
20
18

June
30
23
30
20
29
30
30
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
29
30
30
30
30

July

Aug.

Sept.

Oct.

12
2
12
11

Nov.

31
W
17
20
1
17
15

31
12
8
6
15
14
10
28
10
3
4
24
29
30
25
17

1
28
2
24
18
30
6
1
4
10
5
30
7
5
26
11
24
6
3
27
28
30
1
13
20
4
30
21
28
30
10

Dec.
31
31
27
31
31
31
29
31
29
31
31
31
31
31
31
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
31
31
31
31
31
31
30
28
20
31
31
31
30
31
31
31
31
31

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
conditions 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 trans-

230



action 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 condition 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 to publish periodic reports of conditions. (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 conditions, 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

R-23

Total and principal assets of National banks, by States, June 30, 1972
[Dollar amounts in millions]
Securities, grossf
Number
of banks

Total
assets

Cash
assets*

U.S. Gov
eminent
obligations%

State and
local

Loans,
gross

Federal
funds

Direct
lease
financing

Other

United States

4,607

$392, 163

$60, 197

$42, 892

$51,033

$2, 885

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

88
5
3
69
55
122
26
5
11
236

4,564
628
3,754
2, 164
54, 860
4,446
3,658
44
2,380
12, 161

696
93
472
344
7,996
734
659
4
436
2,005

516
73
286
292
5,846
389
206
11
265
1, 782

773
141
537
283
5,715
528
527
2
301
2, 050

25
2
9
7
207
26
39

Georgia. . . . . . . . . . . .
Hawaii,
Idaho.

61

969
12
137
3,826
1,380
537
493
415
788
117

321
1?
119
4,216
1, 143
407
580
414
842
55

579
6
198
4,129
1, 086
344
451
409
713
135

M

$207, 414 $12, 756
2,260
284
2,277
1,074
29, 741
2,509
2,057
25
1,275
5,460

93
2,706
92
49
1
31
346

19
388
76
10
11
9
23
2

3; 309
54
725
17,157
4,274
1,423
1,560
1,428
2,273
511

161
0
4
734
517
89
221
104
270
24

15
119

160

J

5
20

Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

415
122
100
171
80
50
20

5,715
93
1,239
31, 700
8,742
2, 876
3,404
2,854
5,056
873

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

39
82
105
198
38
100
54
125
4
48

3,381
9,878
15,176
8,036
2, 086
6,982
1, 164
3,034
1,066
873

540
1,740
2, 441
1,197
340
1,287
142
463
129
130

340
760
1,709
1, 050
294
731
178
351
149
112

603
,313
836
869
238
926
150
349
141
95

22
85
147
65
10
30
4
10
6
2

1,701
5,215
8,092
4, 437
1, 102
3,456
639
1,721
558
493

77
301
503
165
35
368
18
55
41
17

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

119
33
163
23
43
219
194
8
284
5
19
32
77
534
9
25

13,235
1,493
55, 053
6,980
958
16, 158
5,674
4,367
23, 909
2, 103

1,695
216
9,857
1, 158
110
2,102
935
684
3,343
237

1,706
171

2,378
231
5,997
998
130
2,513
967
579
3,476
346

193
6
406
22
2
151
41
9
297
19

6,686
768
31, 104
3,814

185

1,949
1, 185
6,909
25, 390

333
134
1,220
4,526
187

3
2
71
139
6
5
25
18
11
33
2

1,035
660
3,444
12,426
696
272
3,824
3, 576
1,030
3,074
405
83

75
21
218
1,163
15
10
148
677
74
506
11
3

26

1,818

40

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

1
7

100
23
87

1, 173
442
6,616

1

6,763
2,203
5,794
775
145

14

3,541

127
42

4,235
623
163

2,357
752
379
2, 745
119
179

105
20

123

10

267
164
902
3,671
126
65
913
750
369
642
100
25

693

451

435

39
783
894
255
820

170
822
2,574
101
43

711
507
399
549

516

7,990
2,519
2,466
12,664
1,280

61
674
114

13
594
301
46
602
37

*Cash, balances with other banks, and cash items in process of collection,
f Includes investment securities and securities held in trading accounts.
^Includes U.S. Treasury securities and obligations of other U.S. Government agencies.
§Also includes securities purchased under agreements to resell.
|| 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.



231

TABLE

B-24

Total and principal liabilities of National banks, by States, June 30, 1972
[Dollar amounts in millions]
Deposits
Tdtal
liabilities

United States.

$354,479

Total
deposits

Demand
deposits,
total

Time and
savings
deposits,
total

Demand
deposits,
IPC*

Time
deposits
IPC

$322, 385

$149, 877

$172,509

$111,974

$147, 298

Reserves
on loans
and
securities

$21, 541

Federal
funds purchascd\

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia.
Florida*. > . . . , . * . ,

4,175
582
3,495
1,978
51, 142
4,111
3,374
40
2, 163
11,198

3,958
554
3,090
1, 875
45,484
3,742
3,084
39
2,073
10,487

1,922
241
1,231
963
17,400
1,884
1,657
15
1,271
5,334

2,035
314
1,859
912
28,084
1,858
1,427
24
802
5,155

1,454
196
1,039
739
14, 358
1,457
1,301
14
1,085
4,201

1,793
144
1,735
835
22,415
1,597
1,237
24
776
4,412

68
10
274
61
3,701
222
168
0
42

Georgia...
Hawaii...
Idaho....
Illinois
Indiana...
Iowa
Kansas. . .
Kentucky.
Louisiana.
Maine.. . .

5,203
87
1,146
28, 866
8,082
2,653
3,086
2,606
4,623
800

4, 328
85
1,088
25,497
7,285
2,486
2,841
2,491
4,301
739

2,554
37
457
10,877
3,380
1,210
1,442
1,263
2, 130
353

1,774
49
631
14,620
3,905
1,276
1,399
1,228
2,171
386

1,943
32
367
8,481
2,348
806
983
1,010
1,576
282

1,470
34
583
12,651
3,654
1,191
1,199
1,146
1,655
356

611
0
7
2, 133
531
HI
159
57
201
27

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

3,105
8,987
13.985
l\ 361
1,918
6,342
1,080
2,766
985
785

2,882
7,475
13, 152
6,290
1,816
5,532
1,012
2,553
956
722

1,548
4,532
5,076
2,836
960
3,292
374
1,237
417
412

1,334
2,942
8, 076
3,454
856
2,240
638
1,317
539
310

1,206
3,354
3,622
1,895
655
2, 261
305
894
333
340

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

12,176
1,378
49, 795
6,418
881
14, 739
5, 171
4,005
21,664
1,937

11,591
1,303
42, 730
5,792
843
13,479
4,799
3,687
19,684
1,761

4,996
603
23, 119
2,851
297
5,577
2,358
1,581
8,216
617

6,595
699
19,611
2,941
547
7,902
2,440
2, 106
11,468
1, 144

3,939
456
14,652
2,152
243
4,314
1,696
1,327
6,519
484

1,250
2,573
6,943
3, 139
706
2,067
579
1,230
433
284
6,164
528
15, 780
2,457
512
7, 119
2,016
1,837
10, 242
1,091

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

1,789
1,087
6,349
23, 312
1,083
405
6,086
6,273
2,007
5,356
709
136

1,630
1,044
5,779
20, 729
970
391
5,680
5,234
1,886
4,657
680
121

1,090
380
2,681
11, 104
414
126
2, 322
2, 263
809
1,859
285
25

540
664
3,099
9,624
556
265
3,358
2,971
1,077
2, 798
394
97

890
306
1,853
8, 071
318
108
1,922
1,896
604
1,425
216
15

509
600
2,536
7,390
472
261
3,024
2,721
1,047
2,474
351
56

65
8
363
1,900
61

3,217

3,095

1,911

1,183

1, 593

1, 154

56

District of Columbia—all %.

S

137
855
461
765
49
699
24
143
1
17
141
32
3, 141
273
8
738
254
181
878
109

170
850
49
363
8
0

*IPC deposits are those of individuals, partnerships, and corporations.
fAlso includes securities sold under agreements to repurchase.
^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.

232




TABLE

B-25

Capital accounts of National banks, by States, June 30, 1972
[Dollar amounts in millions]
Total
capital
accounts

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

Debentures

Preferred
stock

Common
stock

$12,171

$6,989

144
14
90
60
1,298
122
133
1
97
348

96
11
60
53
668

41

93
13
37
39
740
79
59
1
40
260
115
2
20
673
131
43
74
40
82

131
1
44
1,190
251
73
115
113
182
22

18
481
192
71
95
60
115
21

102
394
400
175
97
208
27
77
22
43

78
161
218
188
8
200
13
83
28
22
231
22
902
110
21
312
163
63
501
45

$1,902

347
40
230
169

4
1
43
12
425
15
12
0

195
860

$43

1

Georgia
Hawaii
Idaho
Illinois. .
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

459
6
82
2,435
588
197
294
219
387
65

65
2
0
46
4
5
7
1
1

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

247
780
1,039
605
150
577
74
239
73
80

3
36
190
83
7
27
5
19
0
1

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

935
103
4,484
499
68

46
12
305
90
5

1,273
461
320

31
38
75
84

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

142
84
505

District of Columbia—all

2,006
146

21

429
179
384
60
8

0
6
21
66
0
2
27
5
3
27
2
0

294

14

1,848
80
34
470

profits

$7,153

28, 720

3,193
298
250
4

Undivided
Surplus

53
161
217
153
38
137
27
55
23

14
0
20
0
0
0
0
0
7
0

243
26
1,254
109
18
314
110
80
394
29

397
38
1,993
186
21

0
0
0
1
0

32
21
128
541

59
27
196

0
0
0
0
0
0

121
121
34

614

148
102

970
73

80

46
1
55
211
105

102
7

156
26
4

45
29
150
506
16
13
131
110
54
94
24
3

52

129

95

21
7

685
40

10
188
178
83

•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.




233

TABLE

B-26

Total and principal assets of National banks, by States, Dec. 31, 1972
[Dollar amounts in millions]
Securities, gross]
Number

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

4,614

89
5
3
70
55
124
26
5

11
244
61
1
7

415
122
100

171
80
50
19

Total
assets

$434, 947

5,053
649
4,304
2,754
58, 797
4,913
3,694
47
2,504
14, 070
6,268
106
1,427
35, 953
9,483
3,193
3, 742
3,213

5,693
882

Cash
assets*

Other

$67, 401

$47, 866

$52,717

$3,154

$230,456

16,672

717

81
460
483
9,105
784
662
4
381
2,403

606
88
329
356
6,443
425
208
11
279
1,933

866
134
550
325
5, 550
540
505
2
291
2,140

53
4
13

2,470
308

196
7
154
143
2,041
185
118
1
111
654

1,116
12
195
4,568
1,438
546
585
480
962
116

313
20
158
4,649
1,196
505
622
471
957
59

588
5
198
4,247
1,075
350
454

534
1,888
2,408
1,278
389
1,492
144
524
127
129

360
904
1,833
1,296
274
840
216
393
144
128

620
1,125
1,987
1,000
273
933
169
370

1,930
188
4, 698
726
187
2,655
818
478
3,036
147

2,430
228
6,459
1,052
154
2, 466
1,020

200
187
952
2,920
111
45
733
552
429
706

250
196
968
4, 019

39
82
106
199
38
102
54
123
4
48

16,372
8,992
2, 322
8,006
1,295
3,452
1,135
933

New Jersey
New M exico
New Y o r k . . . . . .
North Carolina..
North D a k o t a . . .
Ohio. .
..
Oklahoma
Oregon
Pennsylvania.....
Rhode Island. . .

121
33
163
23
43
218
192
8
276
5

14, 398
1, 633
62, 614
7,901
1,048
17,711
6,218
4,940
26, 291
2, 288

1,654
237
11,832

19
32
73

2,116

538
10
24
101
23
88

29, 107

353
150
1, 284
5, 234
238
42

South Carolina
%mth D a k o t a . . . . . . . . . . . .
Tennessee. . .
Texas..
.
....,
Utah......
Vermont. • * . . , , , . . . , . . . . . . . .
Virginia.,. .";•.,.,....»
Washington..............
West Virginia
Wisconsin. V
Wybming. . . . . . . . . . . . . . .
Virgin Islands,..
Puerto Rico.
District of Columbia—all ||.

127
42
1
I
14

1, 307
7,748
1, 370

476
7, 229
7,064
2,468
6, 375

Federal
funds
soldi

State and
local

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

3,632
10, 755

Loans,
gross

U.S.
Government
obligations X

1,403
116
2,292
1,015
679
3,547
218

823

981

413

706
HI

143
83

610
3,637

289

125
56
975
842

873
131

121
9
3

138

13
2

391
666
112
20
0

3,720

593

468

420

283
873

8

257
23
26
16
126

2,615
1,354
32,605
2,774
2,051
27
1,359
6, 385
3,666
59
798
19, 768
4,812
1,542
1, 721
2,582
550

209
5
19
1,056
572
175
254
207
314
13

17
79
152
63
10
28
3
12
6
2

1,923
5,616
8, 837
4,906
1,236
3,743
679
1,841
611
525

77
602
661
198
66
780
50
219
50
39

254
6
469
22
2
163
39
9
283
5

7,236
849
34, 788
4,311
541
8,926
2, 848
2,703
13,877
1,486

441
80
785
124
22
704
305
243
1, 101
76

4
2
74
168
3
4
27
19
10
34
6

1, 142
708
3, 918
13,810
789
297
4,270
3, 868
1,159
3,496
435
84
2

102
29
262
1, 982
60
22
165
435
123
402
33
0
0

26

1,965

159

75

19
411
102
9
11
10
18
2

•Cash, balances with other banks, and cash items in process of collection,
f Includes investment securities and securities held in trading accounts,
jIncludes U.S. Treasury securities and obligations of other U.S. Government agencies.
§Also includes securities purchased under agreement to resell.
| [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.




TABLE

R-27

Total and principal liabilities of National banks, by States, Dec. 31, 1972
[Dollar amounts in millions]
Deposits
Total
liabilities
Total
deposits

United States.

$400,413

Demand
deposits,
total

Time and
savings
deposits,
total

Demand
deposits,
IPC*

Time
deposits,
IPC

Federal
funds
purchased]

$359, 427

$172,565

$186,862

$130, 376

$157,663

Reserves
on loans
and
securities

$24, 349

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

4,644
599
4,004
2,530
54, 805
4,551
3,421
43
2,280
13,001

4,350
578
3,585
2,360
49,046
4,231
3,204
42
2,164
12,265

2,167
251
1,381
1,249
19,598
2,231
1,845
17
1,322
6,381

2,183
327
2,204
1,111
29, 448
2,000
1,359
25
842
5,884

1,681
212
1,184
941
16,305
1,749
1,479
16
1,150
4,915

1,884
154
1,981
1,014
23, 157
1,776
1,151
25
819
4,850

136
2
266
116
3,600
166
130
0
70
420

Georgia...
Hawaii. . .
Idaho.. . .
Illinois
Indiana...
Iowa
Kansas. . .
Kentucky.
Louisiana.
Maine.. . .

5,727
100
1,325
33, 020
8,796
2,961
3,413
2,954
5,217
807

4,933
98
1,269
29, 133
7,843
2,672
3,149
2,804
4,780
778

2,950
42
572
12,555
3,690
1,318
1,688
1,477
2,485
364

1,983
56
692
16, 578
4, 153
1,355
1,461
1,327
2,295
413

2,213
37
458
9,585
2,726
933
1,148
1,175
1,815
305

1,641
36
636
14, 189
3,890
1,270
1,276
1,213
1,794
382

480
0
12
2,277
686
238
171
87
287
9

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

3,340
9,833
15,077
8,290
2, 144
7,348
1,204
3,176
1,049
842

3, 114
8,306
14, 193
7,334
2,003
6,320
1,137
2,937
1,008
805

1,617
5,281
5,811
3,495
1,065
3,995
449
1,526
429
482

1,497
3,026
8,382
3,839
938
2,325
688
1,411
579
322

1,326
3,898
4, 184
2,369
766
2, 707
362
1,117
359
371

1,349
2,536
7,273
3,455
771
2,143
618
1,282
468
302

135
1,010
485
660
88
900
25
163
0
11

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

13, 276
1,512
57,049
7,296
967
16, 235
5,697
4,538
23, 980
2, 116

12,848
1,427
48, 146
6,586
938
14, 958
5,278
4,201
21,391
1,949

5,812
628
26, 263
3,320
364
6,596
2,674
1,807
9, 154
674

7,036
799
21,884
3,265
573
8,363
2,604
2,394
12, 237
1,275

4,536
504
17,426
2,589
305
5, 126
1,976
1,524
7,455
533

6,458
578
17,232
2,718
544
7,470
2, 137
1,908

101
39
4,227
360
6
810
323
175
1,462
114

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

1,948
1,206
7, 164
26,917
1,262
437
6,669
6,560
2,257
5,899
803
121
5

1,804
1, 165
6,469
23, 893
1, 165
427
6, 190
5,881
2, 100
5,293
775
103
5

1,230
448
3,099
13,281
556
144
2,602
2,651
889
2,280
338
20
2

574
716
3,370
10,612
610
283
3,588
3,230
1,212
3,013
437
83
3

1,035
374
2, 144
9,625
418
120
2,207
2,231
679
1,809
257
16
2

536
651
2,746

3,384

3,205

1,970

1,235

1,671

1,207

District of Columbia—allj.

10,812
1, 187

8, 138

494
269
3,205
2,946
1, 156
2,702
384
54
3

75
10
382
2,401
52
226
482
86
370
5
13
0
115

*IPC deposits are those of individuals, partnerships, and corporations,
f Also includes securities sold under agreements to repurchase.
% 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.




TABLE

B-28

Capital accounts of National banks, by States, Dec. 31, 1972
[Dollar amounts in millions]
Total
capital
accounts

Debentures

Common
stock

Preferred
stock

$30, 352

$2, 129

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

364
43
267
202
3,428
322
239
4
201
973

3
1
75

Georgia. .
Hawaii...
Idaho....
Illinois...
Indiana. .
Iowa
Kansas...
Kentucky.
Louisiana.
Maine

484
6
91
2,516
613
204
302
229
426
66

69
2
5
61
3
5
7
2

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

260
805
1,137
623
157
594
80
244
77
83

3
36
194
84
8
28
5
19
0

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

992
109
4,787
536
70
1,325
475
357
2,064
154

55
12
305
89
5
36
41
100
119
5

0
20
0
0
0
0
0
6
0

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

147
88
527

0
7
21
92

0
0
0
1
0

District of Columbia—all*.

304

$42

21
431
23
12
0
1
40

14

$12,717
148
18
90
69

Capital
reserves

$7, 524
108
11
65
59
760
91
42
1
61
238

1,392

126
130
1
97
395
138
1
40

114

1,312

251
71
118
101
194
22

419
207
74
99
61
128
21

53
162
245
154
38
140
28
56
23
14

1

39
3
0
0

$7, 458

117
2
26
677
143
48
76
61
84
21

12

13
2
27
5
3

Undivided
profits

94
13
37
48
745
81
55
1
40
281

United States.

1,936
97
34
493
436
191
418
63
8
2

Surplus

104
295
432
180
109
216
28
78
22
43

89
211
248
199
2
205
18
87
33
24

255
27
359
127
19
318
112
80
395
30

414
38

252
27
,067
93
22
323
171
75
505
46

33
24
129
550
30
8
125
127
35
105

7
—

1

53

2,028

223
23
646
150
102
488
73

1
20

65
28
199
700
37
10
194
181
88
175
26
4
1

47
29
167
536
18
14
143
111
58
93
26
3

131

102

•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.

236



TABLE

B-29

Loans of National banks, by States, Dec. 31, 1972
[Dollar amounts in millions]

Loans

Loans
secured
by real
estate

Loans to
financial
institutions

Loans to
purchase
or carry
securities

Loans to
farmers

Commercial Personal
and
loans to
industrial individuals
loans

United States

$230, 456

$56, 121

$19,041

$8, 427

$7, 264

$82, 459

$50, 468

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

2,470
308
2,615
1,354
32, 605
2,774
2,051
27

126
1
154
37
2,938
183
94
1
203
307

22

43

31
38

239
71
1,084
279
2

755
96
693
383

1,359
6,385

492
133
786
344
9,609
627
737
15
436
1,659

946
76
673
464
5,757
806
544
8
325
2,038

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

3,665
59
798
19, 768
4,812
1,542
1,721
1,548
2,582
550

721
25
218
3,074
1,521
376
235
434
551
206

266
0
10
2,795
360
26

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

1,923
5,616
8,837
4,906
1,236
3,743
679

640
948
3,648
1,258
271
634
189
218
247
150

114
607

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

7,236
849
34, 788
4,311
541
8,926
2,848
2,703
13,877

3,025
152
5,744
543
165
2,602
577
676
4,008
619

294
26
4,272
318
2
455
173
216
1,271
101

77
10
3,097
44
1
204
96
29
206

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

1, 142
708
3,918
13,810
789
297
4,270
3,868
1, 159
3,496
435
84
2

209
169
641
2,075
248

25
3
265
1, 122
42

18
4
65
750

1,841

611
525

1,486

,

District of Columbia—all*

1,965

51
70

196
3

631
302
71
278
3
37

11
7

792
31
7
0
20
110

45
0
4
1,467
119
40
45
36
59
1

53
80
129
160
17

189
2
71
3
3

1

99
64
0

129
236
28
179
4
0
0

31
2
40
100
4
64
3
0
0

615

294

40

160
1,203
1, 100
373
1,272

1

69
23
127
483
112
307
429
79
30
6
19
7
65
231
39
170
126
609
10
5

13
88
125
38
97
106

291
102
179
2
15
234
49
790
30
8
77
177
9
83
84

11,401
788
566
3
344
2,078

1,269
26
191
8,543
1,212
396
501
375
962

1,259
6
244
2,715

1,409
373
445
513

713

173

156

529
2,842

536
977
1,960
1,067
441
898
197
432
180
190

2,145
1,816
366
1,485

159
451
153
162
1,887
283

15,860
1,712
149
2,591
954
1, 138
4,491
454
381
146

1,562
5,569
234
51

1,279
1,391
253
1,072
127

11
2
470

1,800
261
4,519
1,436
122
2,720
651
515

3,251
278
439
146
1,271
2,935
168
70

1,417
793
474
717
116
8
467

•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.




237

TABLE

&-30

Outstanding balances, credit cards and related plans of National banks, Dec. 31, 1972
Credit cards

Other related credit plans

Outstanding
volume

Number
of banks

Average
balance
per card*

(dollars in
thousands)

Outstanding
volume

Number
of banks

(dollars in
thousands)

United States.

801

3, 930,643

$262

789

958,077

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

16
1
2
4
28
40
6
0
1
59

56, 561
5,618
73, 077
13,959
783, 650
96,849
43,596

236
352
285
212
320
213
289
0
208
215

8
0
2
6

2,313

Georgia
Hawaii
Idaho.
Illinois
Indiana
Iowa..
Kansas.
Kentucky
Louisiana
Maine

24

139, 129

0
3
25
41
6
4
34
6
14

0

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

2
43
31
3

2

10
4
5
3
24

0

54,513
109, 422

16,111
153,222
56,841
18, 164
31, 275
37, 084
40,540
8,988

207

46,411
64, 745
160,844
8,830
17,828
112,317
1,324
56,484
13,236
9,852

226
256
203
145
215
238
212
219

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

18
5
33
8
6
106
7
2
21
4

41, 830
13,907
463,405
86,049

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

5
0
13
49
4
5
18
6
8
33
9
0
0

33, 109

476

214, 666
56,760
59, 912
140,201
24, 583
0

86, 992
183,690
19, 558
1,640
97, 287
104,244
11,391
59, 577
896
0
0

•Average balance for cards with outstanding balances on Dec. 31, 1972.

238



258
0
349
248
194
257
225
292
217

0

15,810
472

21

169, 074
11,936
13,469

2

7,182
37, 653

7
0
1
76
15
12
9
6
5
7

11,396

40
8
0
39

8
39
26
74
3
15

7

0

0

6,058
33, 599
9,523
2,020
953

2,991
4,215
1,576
9,277
71,082
39, 353
30,308
1,210
10, 029
488

16
1
6

2, 831
3,529
1, 923

238
257
284
255
450
285
236
267
252
273

28
2
32
11
11
48
13
0

45,050

32
2

92,448

259
0
238
235

3
4
8
39
0

758
261

263
214

127
102
243
278
265
278
279
0
0

2
20
5

5

55
10
0
0

607

197,323
30, 128
1,165
24,638
2, 191
0

11,555
5,600
10,390
0
614

8,779
9,520

531
14, 775
1,474
0
0

TABLE B-31

National banks engaged in direct lease financing, Dec. 31, 1972
Total number
of banks

Number of banks
engaged in direct
lease financing

Amount of direct
lease financing

(dollars in thousands)

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

89
5
3
70
55
124
26
5
14
244

7
20
25
5
0
3
23

1,422
17
3,775
2,916
373, 786
7,373
4,273
0
3,210
12, 241

Georgia.
Hawaii
Idaho
Illinois.
Indiana
Iowa
Kansas
,
Kentucky.
Louisiana
Maine

61
1
7
415
122
100
171
80
50
19

12
0
2
39
13
9
16
4
6
0

8,662
0
3,251
71, 099
41, 356
1,344
1,756
6,862
12, 097
0

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

39
82
106
199
38
102
54
123
4
48

4
6
25
14
3
20
3
7
2
1

3,402
29, 454
12, 439
38, 191
487
24, 736
423
414
9,376
3

New Jersey
New Mexico
New Y o r k . . . . .
North Carolina
North Dakota
Ohio
Oklahoma.
Oegon
Pennsylvania
Rhode Island.

121
33
163
23
43
218
192
8
276
5

7
2
12
3
28
67
3
13
2

20, 287
65
166,190
6,636
51
33,711
16, 380
9,670
44,808
6,758

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

19
32
73
538
10
24
101
23
88
127
42
1

2
5
30
2
2
9
5
9
18
11
0
0

68
165
29, 753
15, 133
8,407
339
6,308
16, 930
1,512
13,222
2,112
0
0

4,617

510

1,072,870

Total United States and possessions*

6
1

2

•Includes 3 non-National banks in the District of Columbia.




239

TABLE

B-32

Income and expenses of National banks,* by States, year ended Dec. 31, 1972
[Dollar amounts in thousands]
United States

Number of banks.
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased
under agreements to resell
,
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and
corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges,
commissions, and fees
Other operating income
Total operating income.

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold
under agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing, etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense.

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income.



Alabama

Alaska

Arizona

Arkansas

California

Colorado Connecticut

70

55

124

26

$179,847

$93, 915

$2,181,228

$202, 514

$141,461

621

1,432

5,164

97, 176

6,418

2,416

24, 575

1,869

14, 631

11,679

237, 374

17,043

7,261

567, 168
2, 039, 707
175,601
770, 938
718,310

5,596
31, 127
1,701
6,559
12,539

3,083
5,404
172
502
2,810

3,027
22, 883
271
6,120
9,022

6,064
13,325
519
1,914
5,988

70, 997
208, 658
17,541
91,490
131,975

4,881
21, 507
1,292
14, 050
13,848

3,555
18, 974
2,243
14,008
7,239

695, 876
1,003,844

8,577
6,224

2,456
1,241

4,745
3,870

3,160
3,345

134,981
192,457

12,969
6,291

5,510
4,814

23, 542, 737

286,431

44,204

245, 848

145, 073

3, 363, 877

300,813

207,481

4, 461, 024
778, 680
8, 084, 736

58, 051
9,060
96, 270

11,224
1,397
15, 238

56, 036
8,563
94,492

28, 737
4,262
48, 714

698,617
116,479
1, 279, 790

60,540
9,338
88, 702

53, 158
9,860

976, 133
77, 932
111,299
903, 572

4,389
1, 174
220
8,907

147
9
40
1,776

10, 267
0
2,854
10, 385

3,197
353
1,222
6, 167

128, 102
2,208
25, 107
150,250

7,442
1,838
1,333
10,313

6,934
208
587
12,558

651,214
584, 310
2, 685, 804

10, 704
6,431
33, 932

1,556
966
4,595

7,875
4,232
24, 652

5,341
2,429
18, 750

73, 225
82, 677
322, 158

9,439
8,841
49, 649

7,496
5,360
26, 231

19, 314, 704

229, 138

36,948

219, 356

119, 172

2,878,613

247, 435
,
.
53, 378
14, 987
38, 391
979
39, 370
+ 19
0

178,213

39, 389

23, 782

4,614

89

$15,084,947

$180,044

$26, 046

641,771

9,489

1, 844, 474

4, 228, 033
982, 206
3, 245, 827
54,137
3, 299, 964
+ 8 , 312
-370

57, 293
12,401
44,892
1,064
45, 956
+ 77

7,256
988
6,268
927
7,195
0
0

26, 492
1,414
25,078
-598
24,480
+651
0

25,901
5,394
20, 507
1,270
21, 777

3, 307, 906

46, 034

7, 195

25, 131

21, 797

+20
0

485, 264
142, 141
343, 123
5,709
348, 832
+2, 992
0

351,824

55, 821

i

29, 268
5,702
23, 566
-60
23,506

+276

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including premium received
Addition to surplus, undivided profits and reserves
incident to mergers and consolidations
Transfers from reserves on loans and securities
All other increases
Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including
premium paid
Reduction in surplus, undivided profits and reserves
incident to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases

Net change in capital accounts
Capital accounts f

46,034

1, 303, 523

3,546

1,537

109,427
41,433
459,425
1, 913, 808

979
177
3,782
8,484

331
0
0
0
133
314
2, 182 50,447

1, 307, 628
2,703

16,396
0

807
0

135, 537

101

20

27, 330
150,430
269, 708

0
1, 139
3,722

50,314

9,789
0

21, 797

351,824

39, 389

23, 782

6,536

174,735

16, 975

473

68
288
1,237
8, 129

2,248
102
216,997
394,082

300
321
1,652
19, 248

0
216
224

5,017
0

176,438
0

13,641
19

12, 249
0

363

7, 195 25, 131

3, 307, 906

12, 241

62

32

0
-197
15

0
2,306
253

33
1,906
447

504
21, 259
87, 675

0
2, 123
1,456

913

0
1,222
267

1, 893, 336

21, 358

645

12, 348

7,766

298, 117

17,301

13, 770

3, 328, 378

33, 160

8,732

63, 230

22, 160

447, 789

41, 336

10, 925

3, 202, 126

300, 929

244, 649

177,392

28,716,089

347, 057

Ratios:
Net income before dividends to capital accounts
(percent)

11.52

13.26

18.24

10.78

10.99

13.09

9.72

Total operating expense to total operating revenue
(percent)

82.04

80.00

83.59

89.22

85.57

82.26

85.89

See footnotes at end of table.




39, 448 233, 145

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1972
[Dollar amounts in thousands]
Delaware

Number of banks

5

Total operating income
Operating expense:
Salaries and wages of officers and employees
,
Pensions and other employee benefits
,
Interest on deposits
,
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
.
Total operating expense

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
....
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income



61

1

7

415

122

$90, 561

$435,417

$290, 974

$5,072

$59, 290

$1,119,400

$320, 685

3,244

23, 107

8,786

67

1,038

47,088

20,982

478

12, 997

60, 742

14, 602

644

7,067

170, 128

48,507

175
67
6
0
95

2,057
10, 337
890
6,732
6, 156

40, 671
86, 731
7,083
23, 922
27, 753

3,667
24,044
2,295
13, 129
18, 659

277
272
5
0
13

1,062
8,215
799
735
3,818

68,200
180,509
24,890
76, 320
30,254

15,293
44,024
6,321
14,804
15, 707

38
42
,

244

63

Operating income:
Interest and fees on loans
,
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and
corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
,
Other operating income
,

11

$1,909

,

District of
Columbia

1,997
3,099

31,392
13, 237

8,924
22, 613

293
84

1,794
657

36,871
90,374

14, 676
12, 674

2,873

138, 070

750, 055

407, 693

6,727

84,475

1, 844, 034

513, 673

604
97
1,011

33,219
5, 182
34,490

138, 928
22,068
246,813

94,070
17,481
86,007

1,917
227
2,303

17,403
2,666
30, 622

292,684
52,208
696,966

92,885
14,417
185, 155

0
0
0
HI

2,514
27
1,091
6,157

19, 245
787
2,205
20, 787

25, 057
9,688
3,121
17,569

8
0
75
508

287
948
151
2,048

110,097
11,979
3,298
66,501

27,094
244
172
21, 505

141
8
377

4,808
2,669
17,212

23,340
15, 537
111,923

14,860
13, 166
53, 439

246
210
1,027

2,329
1,395
8,380

40,912
47,437
167, 670

15,863
12, 939
60, 322

2,349

107, 369

601, 633

334, 458

6,521

66,229

1,489, 752

430, 596

524
194
330
13
343
0
0

30, 701

9,720
20,981
647
21,628
+213
0

148, 422
31,931

116,491
2,084
118,575
+723
0

73, 235
22, 275
50,960
1, 103
52,063
-1,234
0

206
26
180
76
256

0

18,246
5, 295
12, 951
319
13,270
37
0

354, 282
73, 920
280, 362
2,066
282,428
-231
-30

83,077
16, 753
66, 324
2, 933
69, 257
+ 150
0

343

21,841

119,298

50, 829

257

13, 263

282, 167

69,407

Florida

Georgia

Hawaii

+1

Illinois

Idaho

Indiana

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers from reserves on loans and securities
All other increases
Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves inci*
dent to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases
Net change in capital accounts
Capital accountsf

343

21,841

119,298

50, 829

257

13,263

282, 167

69,407

285

1,072

80, 770

36, 428

0

11,000

128, 792

2,909

0
0
93
378

0
0
30

494
92
8,867
45,881

0
0
0

0
12
0
11,012

620
10,313
8,143
147, 868

676
1,095
6,824

1, 102

6,987
899
5,885
94,541

11,504

8,649
632

40,624
8

17, 932
0

132
0

4,346
0

131,247
95

19, 242
0

82

3,588

7,371

0
21
42

0
387
674

1,644
5,619
4,322

0
2,468
5,325

0
0
150

0
582
6,019

447
21,077
9,483

476
790
13, 295

147

10, 424

55, 805

33,096

282

10,947

163, 523

34, 235

574

12, 519

158, 034

63,614

-25

13, 328

266, 512

46,676

3,660

195,036

887,031

453, 935

5,605

83, 709

2,400, 910

588, 877

84
0

1, 174

432

Ratios:
Net income before dividends to capital accounts (percent)..

9.37

11.20

13.45

11.20

4.59

15.84

11.75

11.79

Total operating expense to total operating revenue
(percent)

81.76

77.76

80.21

82.04

96.94

78.40

80.79

83.83

See footnotes at end of table.




TABLE

R-32—Continued

Income and expenses of National banks,* by States,year ended Dec. 31, 1972
[Dollar amounts in thousands]
Iowa

Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
Other operating income
Total operating income

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
,
Total operating expense

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




100

Kansas

Kentucky

Louisiana

Maine

171

80

50

$105, 249 $117,271

$107,673

$168,617

6,863

8,869

6,044

9,574

871

17,681

26,545

20,979

42, 486

6, 524
13,750
739
4, 174
4,981

7,649
18,086
551
3,586
7, 154

3,260
16,698
570
2,780
5,251

6,979
1,538

6,453
2,326

168, 478

19

Maryland

Massachusetts

Michigan

39

82

106

$41, 092 $133,431

$376, 365

$593, 475

4,960

13,097

28, 535

2,860

15, 260

39,007

81, 835

6,516
29, 714
1,605
3,768
11,093

449
4,250
106
2, 106
1,863

5,011
21,979
1,019
3,949
9,255

8,296
41, 860
3,898
44,069
17,736

17,501
76, 578
9,315
25, 470
23, 103

3,302
6,202

10, 125
5, 142

980
1,731

5,369
4, 170

18, 868
35, 478

19,486
17, 753

198, 490

172, 759

288, 640

56, 308

204,403

598, 674

893, 558

29, 961
4,400
62, 558

35, 893
5,541
67, 365

32, 537
4,943
58, 767

50, 876
8, 105
101, 744

12,946
2,345
17, 123

43, 702
6,341
57, 809

140, 939
25, 555
132, 158

157,430
28, 597
377, 936

6,369
124
348
5,095

5,990
462
470
6,016

3, 192
90
90
6, 186

7,225
1,567
99
10, 258

620
177
12
2,470

7,240
749
165
10, 606

39, 439
1,310
2, 150
29, 847

25, 234
502
9,769
34, 322

7,880
2, 192
18, 366

6,455
3,963
22, 366

5,409
3, 174
23, 839

1,985
1, 114
8,786

6,986
3,764
23,844

19, 051
18, 186
67, 523

24, 102
11,245
83, 262

137, 293

154,521

138, 227

9,957
6,991
36,507
233, 329

47, 578

16L206

476, 158

31, 185
8,032
23, 153
551
23,704
-61
-6

43, 969
12, 842
31, 127
665
31,792
-259
0

34, 532
8,007
26, 525
1,035
27,560
0

55,311
11,800
43,511
2,252
45, 763
-92
0

8,730
1,638
7,092
165
7,257
-113
0

43, 197
10, 639
32, 558
433
32, 991
4-149
0

122,516
42, 915
79, 601
937
80, 538
+ 66
0

23, 637

31,533

27, 638

45, 671

144

33, 140

80,604

752, 399
'
141, 159
32, 153
109, 006
1,545
110,551
+ 169
-13
110,707

+ 78

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident to
mergers and consolidations
Transfers from reserves on loans and securities
All other increases
Total increases.

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases

Net change in capital accounts
Capital accountsf
Ratios:
Net income before dividends to capital accounts (percent). .
Total operating expense to total operating revenue
(percent)
See footnotes at end of table.




23, 637

31, 533

27, 638

45,671

7, 144

33, 140

80, 604

110,707

1,369

1,625

3,084

13,709

0

2,827

1,593

121,270

0
112
965

30
122
2,767

0
722
1,247

339
3,067
11,623

0
7
1,647

5,392
475

2,446

4,544

5,053

28, 738

1,654

0
30
1,594
4,451

9,236

5,320
839
6,508
133,937

11,761
0

10, 491
58

8, 165
0

14, 249
125

3,632
0

10,902
0

43, 351
0

36, 164
206

1

189

0

150

0

133

40

2,834

0
1,649
741

0
1,004
1,700

0
1,511
1,644

0
2,943
1, 170

50
687
993

0
1,096
673

322
3,221
2,507

100
4,543
1, 160

14, 152

13,442

11,320

18, 637

5,362

12,804

49,441

45,007

11,931

22, 635

21,371

55, 772

3,436

24, 787

40,399

199, 637

198,052

292, 402

218,512

393, 572

64, 781

247, 261

783, 498

1, 036, 239

11.93

10.78

12.65

11.60

11.03

13.40

10.29

10.68

81.49

77.85

80.01

80.84

84.50

78.87

79.54

84.20

1,776

TABLE

B-32—Continued

Income and expenses of National banks* by States, year ended Dec. 31, 1972
[Dollar amounts in thousands]
Montana

Nebraska

54

123

$238, 110

$52, 003

$132, 888

$45, 956

$39, 398

3,089

16, 529

1,512

4,856

1,752

1,543

13,718

40,229

12, 955

30, 728

9,056

15,817

7,030

5,919

71,626

13, 151
36, 992
1,142
18,475
12, 039

2,470
10, 293
393
1,745
6,067

8,913
34, 423
2,007
19,010
7,366

1,830
6,283
248
458
2,835

5,586
14, 741
569
5,596
4,962

2,143
5,985
363
1,961
3,513

815
3,673
135
1,078
3,271

30, 567
97, 593
14,550
19, 939
28, 117

23, 548
17,692

4,953
3,053

11,569
18, 256

2,554
576

7,383
4,482

1,555
763

576
1,253

12, 659
11,982

Minnesota

199

Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
Other operating income

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing, etc.
Provisions for loan losses (or actual net loan losses)
Other operating expenses

$316, 796

$88, 887

8,448

102

Nevada

New
Hampshire
48

New
Jersey
121
$479, 040

133, 355

386,911

79, 355

196, 880

71,021

57, 661

779, 291

77,990
13, 758
171,771

23, 882
3,895
39, 522

71,044
11,994
106, 153

12, 522
2,258
32, 107

35, 020
5,644
65, 171

14, 351
2,061
23, 862

12, 771
2,222
14, 350

156, 959
28, 867
288, 347

28, 503
3,087
4,727
11,273
12, 476
6,754
55, 326

3,069
38
299
4, 183
4,767
6, 106
18, 255

30, 338
347
1,280
11,857
13, 309
9,317
46, 878

784
27
316
2,092
2,349
1,141
9,300

5,512
108
1,075
7,940
7,498
4,037
24, 187

24
0
0
2,961
1,782
2,555
7,779

382
29
55
3,191
2,072
1,126
10, 150

5,273
1,769
2,811
35, 626
23, 010
18, 564
91, 525

385, 665

Total operating expense

Net income



38

Missouri

488, 512

Total operating income

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries

Mississippi

.'

104,016

302,517

62, 896

156, 092

55, 375

46, 348

652, 751

102, 847
36, 165
66, 682
1,062
67,744
+576
0

29, 339
8,612
20, 727
124
20, 851

84,394
23, 020
61, 374
1,531
62,905

14, 459
3,723
10, 736
84
10, 820

15,646
4,735
10,911
55
10,966

11,313
3,056
8,257
552
8,809

+21

0

0

+ 126
0

40,788
11,848
28,940
135
29, 075
—249
0

+295
0

—4
0

126, 540
12, 276
114,264
2,670
116,934
+ 1,131
0

68, 320

20, 859

62, 926

10,946

28, 826

11,261

8,805

118,065

+8

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers from reserves on loans and securities
All other increases

28, 826

11,261

8,805

118,065

2, 145

15,090

0

65

47,401

40
213
6,582

8
392
1,567

0
493
1,002

0
490
8

0
373
127

5,306
1,083
11,570

4,433

10, 770

4, 112

16, 585

498

565

65, 360

26, 251
0

9,000
0

35, 084
204

4,268
0

11,494
6

3, 160
0

3, 124
0

63, 747
3

310

120

0

0

0

0

0

7,365

0
4,890
1,673

34
230
659

0
2,373
1,624

0
1,536
1,543

0
978
0

0
314
595

8,997
2,676
3,298

33, 124

10,043

39, 285

5,704

14, 579

4, 138

4,033

86,086

95, 022

15, 249

34,411

9,354

30, 832

9,621

5,337

97, 339

584, 890

149, 575

558, 549

74, 495

232, 752

73, 353

80, 248

941, 369

Net income before dividends to capital accounts (percent).

11.68

13.95

11.27

14.69

12.38

15.35

10.97

12.54

Total operating expense to total operating revenue
(percent)

78.95

78.00

78. 19

81.31

79.28

77.97

80.38

83.76

Toted increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including
premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases

Net change in capital accounts
Capital accountsf

68, 320

20, 859

62, 926

56,907

2,778

3,935

198
236
2,485

590
548
517

59, 826

10,946

0
1, 155
281

Ratios:

See footnotes at end of table.




•«s

TABLE

B-32—Continued

Income and expenses of National banks* by States', year ended Dec. 3J, 1972
[Dollar amounts in thousands]
New
Mexico

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




,
*

23

43

218

192

8

276

$62, 814

$2,042, 115

$282, 246

$39, 670

$604, 052

$199,849

$183,082

$867, 769

2,812

27, 144

7,760

963

27, 224

12,907

6, 103

55, 508

7,655

186, 027

21, 122

7,815

112,855

37, 856

15, 607

123,843

2,397
9,766
626
1,465
4, 146

30,093
236, 414
20, 934
120, 175
66, 860

18,704
41, 202
1,061
15, 705
14,744

2,234
5,799
87
957
2,200

22, 555
103, 457
11,492
26, 795
31, 297

4,887
38, 765
2,237
6,973
11,353

5,223
25, 674
397
6,700
14,908

34,711
134,475
15,206
59, 574
21,915

3,502
1,395

80, 703
323, 143

12, 432
15,422

2,016
488

25, 795
15, 379

8,045
6,724

6,559
5,214

40, 878
45, 462

3, 133, 608

430, 398

62, 229

980, 901

329, 596

269, 467

1, 399, 341

18,190
2,630
35,216

566, 446
124,400
935, 083

99, 275
17, 268
137,072

9,348
1,681
28, 346

173,808
24, 718
361, 760

56, 701
8,380
116,982

61, 306
10, 229
96, 998

246,510
45, 018
516, 975

1,249
151
983
2,609

161, 960
8, 799
15, 393
143,213

12, 385
957
5,535
18, 142

126
5
307
1,530

30,417
1,179
1,681
32, 373

13, 354
124
2,343
8,600

5,878
60
5,679
12,315

64, 065
8,733
5,513
52, 334

2,760
2,777
11,763

69, 139
113,299
357, 965

12, 825
6,544
54,668

1,774
681
6,088

28, 114
20,694
127,310

8,239
9,581
42, 630

7,404
4,901
25,948

37, 027
23, 069
155, 180

78, 328

Total operating income

163

96,578

Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of-other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
Other operating income

North
Carolina

33

Number of banks

New York

2,495, 697

364,671

49, 886

802, 054

266, 934

230, 718

1, 154, 424

18, 250
4,612
13,638
413
14,051

637,911
146, 287
491, 624
1,593
493,217

65, 727
12, 970
52, 757
830
53, 587

+ 223
0

12, 343
3,269
9,074
125
9, 199
-27
0

178,847
33, 462
145, 385
3,330
148, 715

62, 662
10,240
52, 422
2, 157
54, 579

+533
-3

38, 749
7,248
31,501
234
31, 735
-642
0

244,917
37, 255
207, 662
2,561
210,223
- 1 , 369
-251

14, 076

496, 662

53,810

9, 172

148, 771

55, 109

31,093

208, 603

+ 25
0

+ 3,445
0

North
Dakota

Ohio

+67
-11

Oklahoma

Oregon

Pennsylvania

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers from reserves on loans and securities
All other increases

14, 076

496, 662

53, 810

9, 172

148, 771

55, 109

31,093

208, 603

2, 173

169, 680

27, 375

1,766

12,828

5,128

75, 139

54,210

0
26
4,912
7,111

35, 232
1,934
81,425
288,271

10, 368
1,321
15,069
54, 133

250
69
282

3,909
4,472
3,523
24, 732

20
0
13
75, 172

6,309
3,631
4,090

2,367

999
501
3,481
10, 109

68,240

4,257
0

136,988
925

20, 995
0

3, 144
0

58, 837
0

24, 220
5

8,951
0

95, 386
344

65

89, 270

75

0

336

346

0

1,382

0
701
3,364

486
5,746
18, 662

0
2,715
2,411

450
257
479

133
5,920
3,202

225
1,679
2,814

0
1,179
9,914

2,517
8,159
29, 258

8,387

252, 077

26, 196

4,330

68, 428

20,044

137,046

12,800

532, 856

105,075

86,221

139,797

102,571

4, 527, 443

1,273,064

460,050

316, 458

2,004, 223

Ratios:
Net income before dividends to capital accounts (percent)

13.72

10.97

10.84

13.69

11.69

11.98

9.83

10.41

Total operating expense to total operating revenue
(percent)

81. 10

79.64

84.73

80. 17

81.77

80.99

85.62

82.50

Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves
incident to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases

Net change in capital accounts
Capital accounts!

See footnotes at end of table.


CO


TABLE

R-32—Continued

Income and expenses of National banks* by States, year ended Dec. 31, 1972
[Dollar amounts in thousands]
Rhode
Island
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing, etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
,
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income



South
Carolina

South
Dakota

Tennessee

Texas

Utah

Vermont

Virginia

5

19

32

73

538

10

24

101

$94, 974

$86, 147

$52, 325

$266, 550

$925, 613

$56, 878

$21, 075

$312,480

2,156

2,658

1,648

13,594

66, 223

678

592

6,235

5,464

7,686

8,502

32, 798

100, 032

5, 154

2,259

29, 082

1,242
11,988
282
9,000
2,578

2,902
10,811
208
3,296
7,419

1, 780
7, 181
138
993
3, 145

12,431
37, 563
3,999
10,008
12, 625

42, 221
140, 918
8,733
44,296
43, 430

1,378
6,059
183
1,424
3,709

426
2,352
306
279
1, 106

12, 752
38, 675
1,483
11, 187
8,017

2,593
2,790

3,349
3,654

3,052
600

14, 763
13,001

36, 720
43, 395

2,471
943

236
270

15, 577
6,958

133, 067

128, 130

79,364

417,332 1,451,581

78, 877

28,901

442,446

21,846
5,493
50, 138

34, 470
5,803
23,645

12, 345
2,330
34, 528

78,063
12,600
145, 758

239, 526
36, 360
475, 108

13, 666
1,629
25, 734

5,361
867
12, 107

86, 028
16,094
158,356

3,225
353
16
4,248
2,295
3,826
16, 919

2,343
13
0
4,644
5,760
2,562
19, 171

139
24
424
2,106
2,438
1,465
7,060

14,712
1,731
981
13,463
14,902
13, 934
50, 320

91,394
10, 562
2,072
32, 166
42, 778
41, 478
183, 258

2,508
1,967
287
1,768
1,973
919
9,402

56
37
122
933
834
477
3,345

6,836
649
2,072
15, 789
15,003
9,885
57, 887

108, 359

98,411

62, 859

346,464 1, 154, 702

59, 853

24, 139

368, 599

24, 708
6,899
17,809
-69
17,740
0
0

29, 719
9, 132
20, 587
246
20, 833

16, 505
4,856
11,649
127
11,776

73, 847
15, 921
57, 926

+8

+ 76

4,762
1,013
3,749
32
3,781
-28
0

17,740

20, 841

3,753

0

296,879
69, 438
227, 441
4,965
232,406

0

70, 868
15,065
55, 803
1,663
57,466
303
-55

0

19, 024
6,327
12,697
133
12, 830
0
0

11,852

57, 714

232, 868

12, 830

+462

422

58, 348

+225
0

58, 573

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers from reserves on loans and securities
All other increases
Total increases

Decreases :
Cash dividends declared:
On common stock
On preferred stock.
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases

17,740

20, 841

11,852

57,714

232, 868

12, 830

3,753

58, 573

6,200

625

1,864

10,271

94,706

13,700

507

12,473

0
15

0
341
699

18, 788

3,040
0
644

464
17
220

5,653
747
2,735

2,904

4,043
463
2,290
17,067

6,923
3,866

6,434

250
12
8, 182
9,069

124, 283

17, 384

1,208

21, 608

10, 125
0

7,905
0

4,332
0

22,200
0

84, 013
17

4,830
0

1,380
24

26, 516
0

338

0

15

65

6,730

0

55

75

0
867
2,871

0
1,114
8, 197

0
156
298

0
1,728
3,349

250
14,444
24, 333

397
337

55
225
323

8,573
3,878
1,957

27, 342

129, 787

2,062

47, 439

227, 364

2,899

219

Total decreases

Net change in capital accounts
Capital accounts!
Ratios:
Net income before dividends to capital accounts (percent)..
Total operating expense to total operating revenue (percent).
See footnotes at end of table.




147, 930

141, 362

83, 461

17

505, 721 1, 842, 441

83, 729

36, 131

11.41

12.64

15.32

10.39

83.02

79.55

75.88

83.52

472, 139

to
TABLE

R-32—Continued

Income and expenses of National banks* by States, year ended Dec. 3J, 1972
[Dollar amounts in thousands]
Washington

Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under agreements to
resell
Interest and dividends on investments:
U.S. Treasury securities.
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions, and fees
Other operating income
Total operating income

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds pruchased and securities sold under agreements to
repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing, etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




West
Virginia

Wisconsin

Wyoming

42

Virgin
Islands

Puerto
Rico

District of
Columbia—

23

88

127

$271, 908

$78, 644

$231, 261

$33, 572

$18

$6, 841

$127,421

25, 527

4,224

19,628

823

0

13

4,665

21, 474
6,055

32, 157
2,059
12, 791
23, 069
16,449
12, 852

17,924
6,810
15,478
574
2,442
2,082
1,954
1,965

25, 698
7,829
26, 767
2,052
8,441
7,169
12,665
9,622

5,929
1,240
4,401
286
488
1,962
1,204
908

25
4
0
6
0
3
0
0

557
1
830
8
0
91
171
347

23,715
2,971
15,555
1,484
11,439
8,906
3,014
4,636

424, 341

132,097

351, 132

50,813

56

8,859

203, 803

98, 872
16, 675
133, 197

20, 658
2,969
52,064

60, 792
12, 291
142, 165

8,902
1, 182
20, 038

42
3
10

1,973
229
4,319

45, 550
7,369

32, 154
743
250
19, 581
14, 362
15, 167
48, 573

2,486
81
219
3,495
3,506
1,925
16, 427

16,615
1,220
2, 135
12, 788
11,462
4,847
37, 086

257
273
145
1,718
1,242
1, 166
6, 124

0
0
0
12
3
0
75

0
422
0
380
151
587
395

2,700
875
1,685

9,806
6,260
4,000
23, 675

379, 574

103, 830

301, 401

41,047

145

8,456

152, 536

44,767
4,527
40,240
811
41, 051
-276
-2

28, 267
5,602
22, 665
1,051
23, 716

49, 731
11,319
38,412
970
39, 382
-301
0

9,766
2,385
7,381
215
7,596
+ 36
0

-89
0
-89
0
-89
0
0

403
-223
626
0
626
0
0

51, 267
17,432
33, 835
973
34, 808

40,773

23, 777

39,081

7,632

-89

626

35,271

+61
0

1

14

50, 616

+463

0

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including premium
received
r
Addition to surplus, undivided profits and reserves incident to mergers
and consolidations
Transfers from reserves on loans and securities.
....
All other increases
Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid. . . .
Reduction in surplus, undivided profits and reserves incident to mergers
and consolidations
.
..
....
Transfers to reserves on loans and securities
.
All other decreases
Total decreases

Net change in capital accounts
Capital accounts f
Ratios:
Net income before dividends to capital accounts (percent)
Total operating expense to total operating revenue (percent)

40, 773

23, 777

39, 081

7,632

-89

626

35,271

5,473

1,093

17,604

738

800

0

1,522

1,584
22
1,634

2
43
722

29
1,230
1,597

426
6
1,533

0
0
1,201

0
0
0

0
0
35

8,713

1,860

20, 460

2, 703

2,001

0

1,557

15,315
32
0

5, 771
0
30

18,489
0
147

2,538
0
0

0
0
0

0
0
0

13, 734
632
82

1,637
6,516
625

0
1,016
1, 100

0
1,685
2,707

0
351
380

0
0
28

0
249
0

0
1,318
680

24, 125

7,917

23, 028

3,269

28

249

16,446

25, 361

17, 720

36,513

7,066

1,884

377

20, 382

426, 101

178,969

389, 545

59, 997

1,884

7,880

293,513

9.57

13.29

10.03

12.72

7.94

12.02

89.45

78.60

85.84

80.78

95.45

74.84

258. 93

•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.
f Includes the aggregate book value of debentures, preferred stock, common stock, surplus, undivided profits, and reserves. Excepting Puerto Rico, these are averages
from the June and December call dates in the year indicated and the previous December call date.
JIncludes 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.




to

TABLE R-33
Income and expenses oj National banks,* by deposit size, year ended Dec. 31, 1972
[Dollar amounts in thousands]
Banks operating full year with deposits in December 1972, of—
Total

Number of banks

4,614

Operating income:
$15,084,947
Interest and fees on loans
Income on Federal funds sold and securities
641, 771
purchased under agreements to resell
Interest and dividends on investments:
1, 844, 474
U.S. Treasury securities
Obligations of other U.S. Government
567, 168
agencies and corporations
Obligations of States and political
2, 039, 707
subdivisions
175,602
Other securities
770, 938
Trust department income
718,310
Service charges on deposit accounts
Other service charges, collection and ex695, 876
change charges, commissions, and fees
1,003, 944
Other operating income
Total operating income




23, 542, 737

$2,000.0
$2,000.1
$5,000.1
$10,000.1
$25,000.1
$50,000.1
$100,000.1
Over
and under to $5,000.0 to $10,000.0 to $25,000.0 to $50,000.0 to $100,000.0 to $500,000.0 $500,000.0
77

420

$3, 453

$56, 171

494

4,074

904

1,603

781

404

315

110

$258, 783 $1,011,913 $1, 128, 362 $1, 154,886

$2,719,030

$8, 752, 349

17,034

56, 695

48, 037

42,194

103, 620

369, 623

188,047

179,695

343, 163

847, 382

1,246

17, 176

62, 201

205, 564

274

6,467

23, 688

83, 333

84, 870

76, 184

134,464

157,888

154
63
0
195

4,836
798
124
3,640

33,094
3, 167
506
18, 484

154, 803
11,315
5,273
73, 556

182, 856
14, 932
17,505
73, 165

185, 722
18,208
36, 056
68, 588

408, 608
40,106
146, 784
135,942

1,069,634
87,013
564, 690
344, 740

109
91

1,728
1,202

7,729
4,484

30,906
18, 920

38, 202
18,942

38, 897
25, 314

142, 037
118,582

436, 268
816, 409

6,079

96,216

429, 170

1, 652, 278 1, 794, 918 1, 825, 744

4, 292, 336

13,445,996

Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and
securities sold under agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures.. . .
Occupancy expense of bank premises, net...
Furniture and equipment, depreciation,
rental costs, servicing, etc
Provision for loan losses (or actual net loan
losses)
Other operating expenses
Total operating expense

4, 461, 024
778, 680
8, 084, 736

2,061
191
1,426

22, 878
2,422
34, 181

87, 923
11,090
161,221

304, 623
44, 487
653,613

320, 401
50, 127
708, 003

339,214
54, 919
708, 032

831, 147
139,397
1, 504, 555

2, 552, 777
476, 047
4,313,705

976, 133
77, 932
111,299
903, 572

13
5
1
292

118
104
24
3,292

637
196
183
13,382

2,738
1, 169
1,862
54, 656

7, 110
1,722
3,533
62, 834

13, 725
1,888
4,892
71,749

113,471
7,667
17,067
166, 571

838,321
65, 181
83, 737
530, 796

651,214

220

2,567

11,540

44,815

51, 532

55,519

148, 527

336, 494

584, 310
2, 685, 804

141
1,404

2,559
13,227

10,094
56,694

35, 176
209, 227

38, 721
226, 945

33, 847
225, 750

93, 526
524, 726

370, 246
1,427,831

19,314,704

5,754

81, 372

352, 960

1, 352, 366

1, 470, 928

1, 509, 535

3, 546, 654

10,995, 135

323, 990
67, 881
256, 109
9,712
265, 821

316, 209
63, 762
252, 447
8,702
261, 149

—42
265, 796

261, 950

745, 682
158, 137
587, 545
14, 103
601, 648
—4
—53
601, 591

2, 450, 861
602, 381
1,848,480
8,947
1, 857, 427
+6, 159
—269
1,863,317

Income before income taxes and securities gains
or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries....
Net income

4, 228, 033
982, 206
3, 245, 827
54, 137
3, 299, 964
+8, 312
—370
3, 307, 906

325
102
223
7
230
—33
0
197

14,844
3,875
10, 969
330
11,299
+ 104
0
11,403

76, 210
18, 078
58, 132
2,098
60, 230
—1
60,517

299, 912
67,990
231,922
10, 238
242, 160
+981
—6
243, 135

Cash dividends declared:
On common stock
On preferred stock

1, 307, 628
2,703

267
0

3,718
0

16, 170
8

63,290
45

80, 991
179

84, 507
24

241, 261
667

817,424
1,780

1,310,331

267

3,718

16, 178

63, 335

81, 170

84, 531

241, 928

819, 204

Total cash dividends declared

+288

+ 17

+800
+1

•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.


On


TABLE

B-34

Capital accounts, net income, and dividends of National banks, 1944—72
[Dollars amounts in thousands]
Capital stock (par

Tear (last call)

5,031
5,023
4,013
5,011
4,997
4,981
4,965
4,946
4,916
4,864
4,796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,503
4,615
4,773
4,815
4,799
4,758
4,716
4,669
4,621
4,600
4,614

Common

$110,597
80, 672
53, 202
32, 529
25, 128
20, 979
16, 079
12,032
6,862
5,512
4,797
4,167
3,944
3,786
3,332
3,225
2,050
2,040
9,852
24,304
27, 281
28, 697
29, 120
38, 081
57,704
62, 453
62, 572
56, 761
42, 627

$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
5, 503, 820
6, 165, 757
6, 326, 508
6, 640, 849
7,132,092

Ratios (percent)

Cash dividends

Number
of banks
Preferred

1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972

value)*

Total

Total
capital
accounts*

$1,551,116 $4, 114,972
1,616,884
4,467,618
1,699,833
4, 893, 038
1,769,205
5, 293, 267
1,804,490
5, 545, 993
1,884,352
5,811,044
1,965,977
6, 152, 799
2, 058, 050
6, 506, 378
2,177,888
6,875,134
2, 263, 746
7, 235, 820
2, 386, 226
7, 739, 553
2,460,621
7,924,719
2, 562,055
8, 220, 620
2, 716, 931
8, 769, 839
2,875,117
9,412,557
3, 066, 632 10,003,852
3, 259, 258 10,695,539
3, 466,166 11,470,899
3, 672,455 12,289,305
3, 886, 042 13, 102,085
4,163,070 14, 297, 834
4, 629,087 16,111,704
5, 064,805 17,971,372
5, 262, 295 19,095,324
5,561,524 20, 585, 402
6, 228, 210 22,158,066
6, 389, 080 24,080,719
6,697,610 25, 986, 802
7,174,719 28, 714, 775

Net income
before
dividends

$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
1,931,556
2, 534, 029
2, 829, 334
3,041,122
3, 307, 906

On

On
preferred
stock

common
stock

$5, 926
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
4,344
4,428
4,677
4,011
2,703

$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
892, 934
1,063,647
1, 273, 039
1, 386,166
1,307,628

Net income
before
dividends
to capital
accounts

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
9.38
11.44
11.75
11.70
11.52

Cash dividends to
net income
before
dividends

Cash dividends on
preferred
stock to
preferred
capital

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
49.25
46.63
45.30
46.45
42.15
45. 16
45.71
39.61

4.79
5.12
4.56
4.22
5.19
5.24
4.43
5.11
5.83
6.02
5.50
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
7.53
7.09
7.46
7.07
6.34

•These 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, sec Annual Reports of the Comptroller of the Currency, 1938, p. 115, and 1963, p. 306.




Total cash
dividends
to capital
accounts

3.53
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
4.36
4.82
5.31
5.35
4.56

TABLE

B-35

Loan losses and recoveries of National banks,

1945-72

[Dollar amounts in thousands]

Year

Total loans, end Net losses or
recoveries (~f-)
of year, net

$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

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959.

+ $7,740

Ratio of net
losses or net
recoveries ( + )
to loans

Tear

Ratio of net
Total loans, end Net losses or
losses or net
of year, net
recoveries ( + ) recoveries ( + )
to loans

Percent

+0.06
.02
. 14
.08
. 14
.05
.07
.05
.08
.06
.07
.08
.07
.07
.04

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

Percent

1960.
$63, 693, 668
1961
67, 308, 734
1962
75, 548, 316
1963
83, 388, 446
1964
95, 577, 392
1965
116,833,479
1966
126, 881, 261
1967
136,752,887
1968
154,862,018
1969
168, 004, 686
1970
173,456,091
1971
190,308,412
1972
226, 354, 896
Average for
1945-72.. . 78, 932, 738

$130, 177
112,412
97,617
121, 724
125, 684
189,826
240, 880
279,257
257, 280
303, 357
601, 734
666, 190
545, 473

0.20
. 17
. 13
.15
.13
.16
.19
.20
.17
.18
.35
.35
.24

144, 594

. 18

NOTE : For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Reports of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 233.

TABLE

B-36

Securities losses and recoveries of National banks,

1945-72

[Dollar amounts in thousands]

Year

Total securities,
end of year,
net

Losses and
chargeoffs*

Ratio of net
losses to
securities

Year

Total securities,
end of year,
net

Losses and
chargeoffs*

$43, 852, 194
49,093, 539
51, 705, 503
52,601,949
54, 366, 781
57, 309, 892
57, 667,429
69,656,371
76,871,528
70,216,983
84, 157, 505
95, 948, 647
103, 658, 543

$154, 372
51, 236
47, 949
45, 923
86,500
67, 898
302, 656
149, 545
344, 068
286,215
137, 704
+ 189,347
+ 94,506

54,824,710

111,132

Percent

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959

$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

$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

0.04
.09
.10
.07
.04
.04
. 12
.15
.25
.08
.32
.56
.35
.12
1.09

Ratio of net
losses to
securities

Percent

1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
Average for
1945-72...

0.30
.08
.08
.07
.15
. 11
.52
.21
.44
.41
. 16

+ .20
+ .09
.20

•Excludes transfers to and from valuation reserves beginning in 1948.
NOTE : For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Reports of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 234.




257

TABLE

R-37

Assets and liabilities of National banks, date of last report of condition, 1950-72
[Dollar amounts in thousands]

Tear

Number
of banks

Total assets

Cash and due
from banks

Total securities,
net

Loans, net

Other assets

Total deposits

Liabilities
for borrowed
money

Other
liabilities

Capital

Surplus,
undivided
profits and
reserves

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
4,716
4,669
4,621
4,600
4,614

$97, 240, 093
102, 738, 560
108,132,743
110,116,699
116, 150,569
113,750,287
117,701,982
120, 522, 640
128, 796, 966
132,636, 113
139,260,867
150,809,052
160,657,006
170,233,363
190, 112,705
219, 102,608
235, 996, 034
263, 374, 709
296,593,618
310,263,170
337, 070, 049
372, 538, 487
430, 768, 064

$23,813,435
26,012,158
26, 399, 403
26,545,518
25, 721, 897
25, 763, 440
27, 082, 497
26,865,134
26, 864, 820
27, 464, 245
28, 674, 506
31,078,445
29, 683, 580
28, 634, 500
34, 065, 854
36, 880, 248
41, 689, 580
46, 633, 658
50, 952, 691
54, 727, 953
56, 040, 460
59, 200, 995
67,401,118

$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
76, 871, 528
70, 030, 342
84,157,465
95, 948, 647
103, 658, 543

$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
127, 453, 846
136,752,887
154,862,018
168,004,686
173,455,791
190,308,412
226, 354, 896

$1, 126, 555
I, 259, 008
I, 321, 382
1,416, 802
1,668, 736
I, 569, 791
I, 867, 761
2, 173,520
2, 347, 698
2, 557, 024
3, 040, 499
3, 328, 334
3,719,607
5, 608, 468
6, 102, 678
8, 078, 989
9, 185, 179
10, 331, 793
13,907,381
17,500, 189
23,416,333
27, 080, 433
33, 353, 507

$89, 529, 632
94,431,561
99, 257, 776
100, 947, 233
106,145,813
104,217,989
107,494,823
109,436,311
117,086, 128
119,637,677
124,910,851
135,510,617
142,824,891
150,823,412
169,616, 780
193,859,973
206, 456, 287
231, 374, 420
257, 883, 926
256, 426, 791
283, 784, 496
314,211,616
359,427,154

$76, 644
15,484
75, 921
14, 851
11,098
107, 796
18,654
38, 324
43, 035
340, 362
110,590
224,615
1, 635, 593
395, 201
299, 308
172,087
1,015,147
296, 821
689, 087
2,283,717
1, 280, 365
866, 103
2, 370, 204

$1, 304, 828
I, 621, 397
I, 739, 825
1,754,099
1,889,416
1,488,573
1, 716, 373
I, 954, 788
I, 999, 002
2, 355, 957
3,141,088
3,198,514
3, 446, 772
5, 466, 572
5, 148,422
7, 636, 524
9, 975, 692
11,973,852
16,496,707
28, 284, 638
27, 130, 131
30, 387, 265
38,616,017

$2,001,650
2, 105, 345
2, 224, 852
2, 301, 757
2, 485, 844
2, 472, 624
2, 638, 108
2,806,213
2, 951, 279
3, 169, 742
3, 342, 850
3, 577, 244
3, 757, 646
4, 029, 243
4, 789, 943
6, 089, 792
6,299,133
6,602,519
7, 008, 482
7, 347, 948
7, 680, 597
8, 277, 752
9, 629, 168

$4, 327, 339
4, 564, 773
4, 884, 369
5, 107, 759
5,618,398
5, 463, 305
5, 834, 024
6, 278, 004
6,717,522
7, 132,375
7, 755, 488
8, 298, 062
8, 992, 104
9, 518, 935
10, 258, 252
11,334,232
12, 159, 775
13, 127,097
14,515,416
15,906,249
17,194,460
18,794,699
20, 722, 810

1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972

•After deduction of securities and loan reserves.
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
Annual Report of the Comptroller of the Currency, 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-38

Foreign branches of National banks, by region and country, Dec. 31, 1972
Region and country

Number

Region and country

Central America

47

El Salvador
Guatemala
Honduras
Mexico
Nicaragua
Panama

1
3
3
5
3
32

Number

Italy
Luxembourg
Monaco
Netherlands
Northern Ireland
Scotland
Switzerland

Africa

South America

128

Argentina
Bolivia
Brazil
Chile
Colombia
Ecuador
Guyana
Paraguay
Peru
Uruguay
Venezuela

38
3
21
0
28
15
1
6
8
4
4
=
126

Liberia

West Indies Caribbean
Antigua
Bahamas
Barbados
British Virgin Islands
Cayman Islands
Dominican Republic
French West Indies
Grenada
Haiti West Indies
Jamaica
Montserrat
Netherlands Antilles
St. Lucia
Trinidad and Tobago
West Indies Federation of States
Europe
Austria
Belgium
England
France
Germany
Greece
Ireland

501-017 O—73



2
75
4
3
1
15
2
2
1
7
1
3
1
6
3
107
1
4
29
11
21
14
4

Middle East
Bahrain
Israel
Lebanon
Qatar
Saudi Arabia
Trucial States
Asia and Pacific
Brunei
Fiji Islands
Hong Kong
India
Indonesia
Pan
rea
Malaysia
Pakistan
Philippines
Republic of China
Singapore
Thailand
Vietnam
U.S. overseas areas and trust territories
Panama (Canal Zone)
Caroline Islands
Guam
Marianas Islands
Marshall Islands
Puerto Rico
Virgin Islands
Total

15
2
2
3
1
2
5
93
2
3
19
11
6
17
3
5
4
4
3
11
2
3
48

2
1
6
1
1
19
18
566

259

TABLE

B~39

Total assets offoreign branches* of National banks, year-end

1953-72

[Dollar amounts in thousands]
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962

1963
$1,682,919
1964
1, 556, 326
1965
1,116,003
1966
1, 301, 883
1967.. /
1, 342, 616
1968
1,405,020
1969
1, 543, 985
1970
1, 628, 510
1971
1, 780, 926
1972
2,008, 478
•Includes military facilities operated abroad by National banks in 1966 through 1971.

TABLE

R-40

Foreign branches of National banks,

End of year

National bank
branches as a
Number of branches
percentage of total
operated by
foreign branches
National banks
of U.S. banks

1960
1961
1962
1963
1964
1965
1966

93
102
111
124
138
196
230

75.0
75.6
76.6
77.5
76.7
93.5
94.3

TABLE

$2, 678, 717
3, 319, 879
7, 241, 068
9, 364, 278
11, 856, 316
16, 021, 617
28, 217, 139
38, 877, 627
50, 550, 727
54, 720, 405

1960-72

End of year

National bank
Number of branches
branches as a
operated by
percentage of total
National banks
foreign branches
of US. banks

1967
1968
1969
1970
1971
1972

95.5
95.0
93.0
92.7
91.5
90.2

278
355
428
497
528
566

R-41

Assets and liabilities offoreign branches of National banks, Dec. 31, 1972: consolidated statement
[Dollar amounts in thousands]
Liabilities

Assets

Gash and cash items in process of collection
Demand balances with other banks
Time balances with other banks
Securities
Loans, discounts and overdrafts, etc
Customers' liability on acceptances outstanding. .
Customers' liability on deferred payment letters
of credit
Premises, furniture and
fixtures
Accruals—interest earned, foreign exchange
profits, etc
Due from other foreign branches of this bank
Due from head office and its domestic branches. .
Other assets
Total assets

260



$332, 251
927, 290
19, 312, 958
642, 449
24, 946, 767
1, 056, 107
66, 916
166, 212
607, 634
4, 570, 802
1, 896, 943
194,075
54, 720, 405

Demand deposits
$4, 209, 576
Time deposits
42, 519, 675
Liabilities for borrowed money
772, 990
Acceptances executed
1, 106, 680
Deferred payment letters of credit outstanding...
21, 876
Reserve for interest, taxes and other accrued
expenses
678, 193
Other liabilities
204, 721
Due to other foreign branches of this bank
4, 325, 794
Due to head office and its domestic b r a n c h e s . . . .
880, 899
Total liabilities

-.. 54, 720, 405
Memoranda

Letters of credit outstanding
$30, 683, 737
Future contracts to buy foreign exchange and
bullion
23,058, 104
Future contracts to sell foreign exchange and
bullion
22, 008, 956

TABLE

B-42

Trust assets* and income of National banks, by States, calendar 1972
[Dollar amounts in millions]
Number
of banks

Employee
benefit
accounts^

Other
trust
accounts X

Total
trust
accounts

Agency
accounts^

Total,
trust and
agency
accounts

Trust depart'
ment income

(Dollars in
thousands)

1,739

$69, 066

$101,095

$170,161

$41, 887

$212,048

775, 645

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

32
4

358
46
222
66

1,148

1,506

6,559

68
937
374

163
35
116
30

1,669

22
715
309

7,277

9,690
1,536
2,195

16, 966
2,279
2,709

2,127

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

31
0

1,524
4,635
1,517

Total United States

2
34
16
30
11
1
6
92

2

168
97
48
51
53
21
16

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

12
53
38
21
20
42
14
22
3
21

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

68
18
73
15
12
62
44
2
122
3

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

8
10
30
146
2
10
49
10
37
41
16

743
513
0
500
489
763
0
52

8,592
597
128
116
74
255
49

103

502

1,053

1,061

19,093
2,746
3,770

6,120
1,914
91,490
14,050
14,008

2,025
5,124
2,280

1,495
1,309
1,612

3,519
6,433
3,892

11,439
23, 922
13, 129

0
98

0
150

0
8

0
158

0
735

7,991
2,996

16, 583
3,593

4,903
1,006

21,486
4,599
1,032

76, 320
14, 804
4,174
3,586
2,780
3,768
2,106
3,949
44,069
25, 470
18,475
1,745
19,010

0

575
581
407
342
301

0

703
696
481
597
350

467
0

329
252
117
120
122

404

0

948
598
717
473

0

172

804

976

245

4,562
6,265
1,506

4,964
3,575
2,616

9,526
9,840
4,122

1,697
2,080
1,088

1,220
11,222
11,921
5,210

1,150
7
216
19
11
562
27
18, 134
1,601
25
2,320
299

3,489

4,639

1,573

6,213

75
668
384
201

82
884
403
212

17
265
30
82

99

458

1,150

2,249

2,811

1,106

3,917

286

313

41

354

10, 596
2,346

28,731
3,953

35,904
4,771

5,272

7,174
817
37
1,425
425

5,596
1,961
1,078
19,439
1,465
120, 175
15, 705

68

257

126

325

150

12

338

433
294

188

9,017
1,700
1,279
19, 224
2,154

320

821

6,127

9,802
1,430

7,592
1,275
1, 142
15,929
1,753

519
105

705
141

1,818
5,328

2,152
7,941

1,707

2,942
9,648

209
40

323
42

21
4

344
46

1,565
1,930

1,907
2,427

1,053

2,959
2,716

1,532
75

1,874

324
186
35
335

2,614
114
2
342
497
33
342
6

976

456

489
81

138

3,294
400
149
49
790

290
69
518
19

854
190

957

26, 795
6,973
6,700
59, 574
9,000
3,296
993

10,008
44,296
1,424
279

2,391

11,187
12,791
2,442
8,441

100

488

559

*As of December 31, 1972.
f Employee benefit accounts include all accounts for which 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, for 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 for which the bank acts as registrar of stock and bonds, assignee, receiver, safekeeping agent, custodian, escrow agent, or similar capacities.
§ Includes both managing agency and advisory agency accounts.
|] 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.



261

APPENDIX C

Addresses and Selected
Congressional Testimony




Addresses and Selected Congressional Testimony
Date and Topic
Feb. 7, 1972, Remarks of Dean E. Miller, Deputy Comptroller of the Currency for Trusts, before the Midwinter Trust
Conference of the American Bankers Association, New York, N.Y
Aug. 2, 1972, Statement of Robert Bloom, Chief Counsel, Office of the Comptroller of the Currency, before the Senate
Committee on Banking, Housing, and Urban Affairs, on S. 3562
Sept. 7, 1972, Remarks of Dean E. Miller, Deputy Comptroller of the Currency for Trusts, before the Western Trust Conference of the American Bankers Association, Monterey, Calif
Sept. 8, 1972, Statement of Robert Bloom, Chief Counsel, Office of the Comptroller of the Currency, before the Subcommittee
on Commerce and Finance, of the House Interstate and Foreign Commerce Committee, on H.R. 14567 and 14826,
and S. 3876
Nov. 15, 1972, Remarks of David C. Motter, Deputy Comptroller of the Currency (Economics), before the Third Annual
CPA—Bankers Seminar, Houston, Tex
Nov. 16, 1972, Remarks of Dean E. Miller, Deputy Comptroller of the Currency for Trusts, before the Midcontinent Trust
Conference of the American Bankers Association, Chicago, 111

264




Page
265
270
271
275
277
281

REMARKS OF DEAN E. MILLER, DEPUTY COMPTROLLER OF THE CURRENCY FOR TRUSTS, BEFORE THE MIDWINTER
TRUST CONFERENCE OF THE AMERICAN BANKERS ASSOCIATION, NEW YORK, N.Y.,

It was 9 years ago this month when I attended my
first Midwinter Trust Conference. For me, anyway,
it was a very dramatic and significant conference, one
at which Mr. Saxon announced the proposed wideranging changes in Regulation 9. When I went to
New York that Sunday, I, of course, had no idea how
those proposed rules would be received. Many persons
had told us, during the period that we were working on
the revisions, that we should not fool with a system that
was, by and large, working well. Hardly any of our
proposed changes went unchallenged, although, in
nearly every case, the proposals had been advocated by
other trustmen. I was generally apprehensive of the
cumulative reaction to our sweeping revision of so
many pillars of trust regulation.
As I, for thefirsttime, went through the now familiar
lengthy wait in the lobby while getting checked in, I
looked at the trustmen around me, none of whom, of
course, I knew at that time, and wondered "What
are we doing to your world?" The next morning, when
Mr. Saxon received a standing ovation after his speech,
I decided that we, indeed, had effected a revolution in
that world. The passing of time, having served, with
some assistance from the Supreme Court in placing
Regulation 9 in its proper perspective, has since shown
that that was not quite the case. But, I never come to
New York without remembering that first trust conference, already almost a decade ago. Although today
I also plan to speak to you in part about changes we are
making in Regulation 9, it is quite a different occasion.
As most of you are aware, in September of this year,
our Office published in the Federal Register some proposed revisions of Regulation 9. We received many
comments on those proposals, and, after analysis of that
material, we are considering a number of changes. We
have also had the benefit of the views of the President's
Commission on Financial Structure and Regulation,
the so-called Hunt Commission, as expressed in its report. While many of the Hunt Commission's recommendations involve very complex questions of policy
to be resolved by the appropriate bodies, including, not
leastly, the Administration, those relating to trust departments include several suggestions to the bank




FEB. 7,

1972

supervisory agencies that do not require such preliminary decisions. Some reflect actions we have already
taken, we are trying to strengthen those and to adopt
others that seem equally meritorious, into our supervisory framework. Let me discuss those recommendations with you.
Recommendation 2(a) of the Commission is that
the appropriate regulatory agencies examine and monitor bank and other trust departments to assure that
brokerage commissions shall not be used to attract or
hold deposit balances and loans of brokerage houses
with the banking department of the corporate fiduciary. This is related to number 2(b), where we assure
that each corporate fiduciary establish procedures to
review whether every effort has been made to achieve
the best execution of buy and sell orders for securities
and to evaluate the services rendered by the trust department which have been paid for by an allocation of
brokerage commissions.
As you who are National bankers are aware, we have
had an interest in that area for some time. Currently,
our examiners request a statement of the policy of the
bank as to allocation of brokerage commissions. That
does not satisfy the professional critics, who assume that
bankers wilfully give false statements in writing to the
examiners. That has not been our experience, and until
it is, we believe that the procedure is a meaningful
check. When it appears, from the reply, that a bank's
policy may have violated the securities or antitrust laws,
the bank is so advised. In addition, the examiner ascertains, by means of a test check, whether the account
has suffered a detriment through receipt of less than
the best execution. We plan to strengthen our procedures in that latter regard in order to render more
comprehensive protection. We are currently considering amending Section 9.11 of Regulation 9 to provide:
In addition, the bank's allocation of brokerage
business in trust accounts shall be examined to
determine if the best execution is achieved, and
if possible violations of law have occurred.
We have not progressed to the point of publishing
that as a proposed rule, but would welcome your comments nevertheless. I think that it is clear that our

265

policies are in accord with the spirit, and in some cases
the letter, of the Hunt Commission recommendations
in that area.
Recommendation 2(c) apparently is that we impose
a rule applying to trust departments in banks with total
assets over $200 million, which would deny trust department investment personnel access to commercial
banking department credit information. The Commission felt that prohibition should not be applied to banks
smaller than that because, in such institutions, there is
little poential for anti-competitive effects, and also because such banks would have great difficulty in complying with such a rule inasmuch as trust department personnel often serve in the bank's commercial operations
as well. Of course, the question here is not so much one
of antitrust, but violation of the securities laws resulting
from use of insider information. The rationale for the
suggested dividing line is the same, in a smaller bank
there is less possibility of there being material inside information available in the credit files, and less potential
impact of investment actions based upon such information, thus the adverse effect of recognizing and permitting the continuance of that organizational structure
would probably be minimal. The proposal is an interesting one, and we have it under consideration. Once
again, any comments you might wish to offer will be
welcome. Inasmuch as this would constitute one additional limitation on the freedom of operation of a business, we are loath to impose it unless it is shown to be
absolutely necessary.
We now have under consideration an amendment
of the language of Section 9.7 (d) which gives recognition to the problem of insider information and should
at least preclude the possibility that a bank would misinterpret the Regulation as excusing the use of such
information. As amended, the paragraph would read:
The trust department may utilize personnel and
facilities of other departments of the bank, and
other departments of the bank may utilize the
personnel and facilities of the trust department,
only to the extent not prohibited by law.
The next recommendation of the Commission is
based upon a similar fear, that insider information
would be used by a bankfiduciarybefore such information became known to the public. While the issue has
not been decided by a court, it appears to us that the assertions of the SEC—that securities laws would apply
to a bank fiduciary's acting on the basis of knowledge
acquired on its commercial side, and thatfiduciarylaw
would not require a bank to act upon such information
if, in doing so, it would violate securities laws—will
be accepted by the courts. Thus, the question before

266



us is whether we should anticipate that determination and impose the rule as a matter of trust department regulation. To me, there appear to be good
reasons for doing so, accordingly, we are currently
considering a further amendment to Section 9.7 which
would add the following sentence at the end:
No director, officer, or employee of a National
bank shall recommend or initiate any purchase
or sale of securities for a trust department account
on the basis of insider information.
Once again, that has not yet been published, but comments are welcome.
Recommendation 2(e) of the Commission is that we
ensure that:
Each corporate fiduciary shall establish procedures to review at frequent intervals the amount of
uninvested cash in each trust account and shall
require the officer responsible to justify the retention of balances.
The matter of the amount of uninvested cash has long
been a prime subject of inquiry by our examiners.
Regulation 9 has, for years, required at Section 9.10:
Funds held in afiduciarycapacity by a National
bank awaiting investment or distribution shall not
be held uninvested or undistributed any longer
than is reasonable for the proper management of
the account.
The representatives of our Office have, as a part of
each examination, scrutinized cash balances for compli*
ance with that requirement. That practice has continued justification, particularly in these days when we
hear it said of so many banks that their trust operation
is profitable only if the amount of trust funds on deposit
on the commercial side is taken into consideration.
That state of affairs provides a built-in incentive to keep
trust funds on deposit, and also provides a powerful
argument for the adoption of more realistic fee schedules and of a policy of ceasing to give away trust services. To reflect our intensified interest in that area, we
are considering amending Section 9.7(a) (2) of Regulation 9 to add, at the end:
Such reviews shall include the amount of uninvested cash in each account, and a justification of
the retention of any balances.
That completes the list of recommendations made
to the banking regulatory authorities. Now I would
like to devote some time to a discussion of other proposals made by the Hunt Commission. I emphasize that
the opinions I express are solely my own, and in some
cases, are even subject to further reflection and inquiry
on my part.
The first recommendation was that a Federal prudent-man investment rule be enacted. That has a certain appeal to me. As I have said before, there is a fuzzi-

ness as to what the prudent-man rule is. Actually, it
appears that there are two prudent-man rules. It is an
investment rule and it is also incorporated into the
trustee's duty to exercise reasonable care and skill. That
latter duty, to exercise such care and skill as a prudent
man would, is but one of the duties of a trustee (Scott
lists at least 16) yet it is believed by many who have
too casually examined the law of trusts to be the only
duty. As a result, we have had some poorly reasoned
judicial decisions and opinions of counsel which said,
in effect, that a trustee can do almost anything so long
as he is prudent, speculate prudently, self-deal prudently, etc. If that is, in fact, what the prudent-man rule
is, then it simply won't do in this age. The conflict of
interests which exists between the bank's business and
that of its fiduciary accounts in every bank with
a trust department, cannot be effectively moderated
by a rule that permits anything, "if prudent." As I have
said before, every banker believes that the transactions
into which he has entered for the bank are prudent.
The determinant must be clearly recognized, the public
interest requires that the business of the bank and that
of its fiduciary accounts must be kept separate, and no
prudent-man rule should be understood as permitting
otherwise. A Federal law making that clear would be
in the public interest.
But implementation of that recommendation presents problems. Frankly, I don't see how such a Federal
statute could be imposed on individual trustees, except
possibly as a part of the Internal Revenue Code. That,
in my opinion, would not accomplish the desired purpose. The Internal Revenue Code and the law of trusts
are not co-extensive, I wish more lawyers and pension
fund consultants understood that, for the philosophy
held by some of them that a company may freely make
use of its employee benefit trusts as sources of capital,
to the full extent permitted by the tax laws, is a continuing source of difficulty for all of us. Putting a
prudent-man rule in the Code probably would not be
effective. On the other hand, it would be, by comparison, no problem at all to put it in the banking laws
and apply it to all insured banks, and into the Welfare
and Pension Plans Disclosure Act and apply it to all
pension funds.
Presently, the prudent-man rule is a matter of local
law, variously interpreted or enacted in the several
states. Commonly, governing instruments contain provisions which provide for investment without regard
to the rules of law otherwise applicable to trustees. To
the extent that that may take a trustee out from under
the prudent-man rule, it makes for further lack of uniformity and lessens the effectiveness of the rule. Thus,




in my opinion, it would appear desirable for a Federal
prudent-man statute to provide that such language is
ineffective.
If those measures were taken, banks would be at a
disadvantage to individuals. Would that be a crippling
disadvantage? I think that a compelling, perhaps persuasive, argument could be made that the application
of a Federal, non-waivable, prudent-man investment
rule to banks would be a proper price to be paid, by
the customer, to obtain the advantages of a professional
corporate fiduciary—immortality, experience, and expertise—and, by the bank, because of the conflicts it
has that other fiduciaries do not.
One might also make a compelling case that our
Office has moved in that direction through its application of Regulation 9 to National banks. We have interpreted State law in a fairly uniform manner in
applying the self-dealing and conflict of interest provisions of the Regulation, and in so doing, made a
Federal law of sorts. There are times when I think that
we should incorporate a prudent-man rule into Regulation 9. Although it might put National banks at a
disadvantage to State banks in states where a more
liberal rule is in effect, we should not give that consideration too much weight. Speaking very personally, if a
bank were in some manner to bring discredit upon
itself and the banking industry through ill-advised
trust department actions, I would much prefer that
bank to be a State bank, as I told the officers of a
National bank that once threatened to convert. At
this time it would appear preferable, in view of the
relative non-urgency of the proposal and the desirability of having a uniform rule applying to all banks,
that a prudent-man rule be adopted by Federal legislation. The recent experience in attempting to enact a
fiduciary standard for pension funds suggests, however,
that that might not be easy.
The Hunt Commission also recommended that a
requirement be imposed to make corporate fiduciaries
file annual reports on trust holdings with the appropriate regulatory agency. I have previously stated my
disagreement with such proposals and will not repeat
myself here. However, I would admit that, as a loyal
government employee, I would support such a proposal
if the administration were to adopt it, and would prepare to implement it. For example, if the recommendations of the Commission on that point were to be
adopted, it would appear most sensible to alter our
modus operandi somewhat. The reports would be filed
with us, and we should use them. Thus I would think
that we would have to transfer several of the functions
which scrutiny of these reports would permit from our

267

field examining staff to our Washington Office. Examiners would cover other aspects of the trust department's operations, and, of course, verify the accuracy
of the reports. Obviously that would require an increase
in the staff of the Washington Office.
Recommendations 4 and 5 of the Commission are
interrelated. They are:
4. That bank holding companies be permitted to
operate a single trust affiliate to carry on trust activities for all banks in the holding company.
5. That bank holding companies be permitted
under state laws to operate system-wide common
trust funds among all affiliate banks with trust
powers.
As those matters concern holding companies, they are
to a degree subjects for the Federal Reserve, but there
is an overlapping here, particularly for chains where
the lead bank is a National bank. We have gone a long
way in permitting the effectuation of Recommendation
4 by permitting co-fiduciary and agency arrangements
between banks, subject to certain safeguards. We feel
that we have gone as far as we can in that area and
that a bank, named as a fiduciary, cannot delegate its
responsibilities to another. It can share them with a
co-fiduciary, and it can obtain advice and assistance
from another, more experienced bank, but it cannot,
and should not, we believe, accept an undertaking to
act as fiduciary for someone, and then, in effect, substitute a third party in its stead, even if that third party
is an affiliated trust company. That arrangement would
all too easily permit deception of the public. On the
other extreme, I can see no difficulty whatever in permitting a holding company to have a trust company to
which the banks in the chain would refer their trust
business, as long as the trust company were the sole
fiduciary. That is close to what is being done now in
some holding company groups between the smaller
banks and the lead bank.
Recommendation 5 requires, in addition to amendment of State laws, such as enacted by New York and
Virginia, an amendment of Section 584 of the Internal Revenue Code. Suffice it to say that such legislation is before Congress, that we favor it, and that we
have an amendment of Regulation 9 already drafted
to carry it into effect should the proposal be enacted
into law.
The remaining four recommendations of the Hunt
Commission dealing with corporate fiduciaries relate
to pension funds. The first is that the Federal prudentman rule, discussed earlier, be applied to all pension
funds. Of course, under the present laws of prudent-

268



man jurisdictions, pension trusts are subject to the rule
as it exists in those states, and to the extent that the report suggests, otherwise it is in error. But the recommendation, that there be a Federal prudent-man rule
imposed as to all pension funds, is one that I heartily
favor. Speaking personally, I would hope that there
be enacted absolute prohibitions on the investment of
funds of employee benefit trusts in any employer-related
media—its stock, property leased to it, loans to it—
whatever. Our experience with direction trusts and the
continued efforts of some of you to get absolution for
closing your eyes to them, have contributed to that
conviction. Some day a large number of employees are
going to have their retirement expectations dashed
because our tax laws do not sufficiently prevent the use
of employee benefit funds by employers as an additional source of capital. I hope that banks don't get
tarnished in the process, but I'm afraid that it will
happen as long as you keep accepting such trusts and
whining that your only course of action is exculpation.
It is very singular to me in this day of general agreement as to the duties and social responsibilities of business toward the public, that all that some of you can
think of with reference to that essentially deceptive
practice of permitting yourselves to be named as
trustees and then proceeding to deny it, is how to devise ways to accomplish that end and emerge without
liability.
The remaining three recommendations have been
covered to some extent by existing legislative proposals
of the Administration and, of course, I stand on those
proposals. Accordingly, I will not comment upon those
recommendations.
So much for the Hunt Commission, and back to
Regulation 9. We have some other proposed changes
that we published last September, and which I would
like to discuss with you. The two most difficult features
of the new provisions have proved to be the ones pertaining to promotion and disclosure of common trust
funds, and the 10 percent limitations. As to the former,
our current thinking is to change the Regulation so as
to make certain distinctions between traditional common trust funds and pooled pension and profit-sharing
trusts. While the prohibition on predictions or representations as to future results would be continued for
both types of funds, hereafter the prohibition on making reference to funds other than those of the bank
would apply only to traditional common trust funds.
National banks would still be required to furnish a
copy of their annual reports to any person, upon request, for both types of funds. However, a reasonable
charge could be imposed for that service. The limita-

tion concerning publicizing the availability of the report would thereafter apply only to traditional common
trust funds.
We would hope, through this, to strike a balance
between the need for the public to find out what is
going on in bank collective investment funds, the legitimate need of banks to inform in order to better compete, and the limitations upon promotion of those funds
which result from the SEC's interpretation of the common trust fund exemption in the Investment Company Act. If that appears to be an unworkable or
unwise provision, tell us and we will try again.
As to the 10 percent limitations which, as you know,
apply only to traditional common trust funds, we are
now considering the incorporation of modified provisions dealing with the situation when a limitation is
exceeded by means other than outright excessive investment on the part of the bank, either on the part of
a particular account, in the one case, or in a particular
security, in the other. Thus, in cases where an account
or a particular security come to exceed 10 percent of
the market value of a common trust fund for any other
reason, we have considered providing for a corrective
mechanism. As to the investment of a fund, it would
work on a delayed-action basis. Under the Regulation,
if the excess reached the point of 15 percent of the
fund, and if the excessive investment in a particular
holding continued in excess of 15 percent on each consecutive valuation date for 6 months, the bank would
be required to reduce the participation, or the investment, as the case might be, back to 10 percent within a
reasonable time, not to exceed 12 months. As to an
excessive investment by a fund, the 12-month period
would date from the expiration of the 6-month period.
Of course, any excess resulting from an improper investment made either deliberately or through inadvertence, must be corrected as soon as possible. In the
case of an excessive participation, that would mean at
the next valuation date. As to an excessive investment,
it would mean immediately. It is our thought that the
foregoing would help attain the regulatory purposes of
maintaining a reasonable diversification in common
trust funds regardless of what factors may tend to cause
a concentration, and yet would not cause precipitate
action to be taken to correct temporary imbalances.
The other amendments to the Regulation being
considered are not very different from those which we
proposed in September. One would require that a bank
accept requests for withdrawals from a traditional
common trust fund received at any time prior to the
valuation date. It is recognized that that conflicts with
some State banking laws and regulations. However, I




personally feel so strongly that this is the equitable
solution, that we should not defer. Because compliance
with Regulation 9 is required as a condition for tax
exemption for all common trust funds, it is anticipated
that some fund plans would have to be amended to
conform to that requirement, if made effective.
The Regulation would call for plans for collective
investment funds to include, in their provisions, acceptable valuation criteria. It is expected that plans that
incorporate, by reference, acceptable State regulations
on the subject, such as is the case in New York, would
be in conformity with the requirement.
Some of the other pending changes include (1) an
amendment to Section 9.13 which would permit a bank
to participate in a central certificate depository, where
permitted under local law; (2) an amendment of the
definition of trust department so as to continue that
term in the Regulation, and to include all persons
within a bank who perform fiduciary responsibilities,
whether they are so-named, or not; and (3) an amendment of Section 9.12 to make clear that the bank may
engage in a self-dealing transaction with a trust account where required to do so, by the Comptroller of
the Currency, to correct a criticism.
Finally, the authority to operate a common trust
fund for managing agency accounts would be deleted.
That is another chapter of the story of the struggle to
make available the investment expertise of bank trust
departments to the person of modest means. One of the
foremost revelations of that struggle has been the extent to which the protection of the public could be
given as the basis for so many diverse points of view on
that proposal. While we do not believe that the Investment Company Institute case requires that authorization to be removed from the Regulation, it appears
that no useful purpose would be served in retaining it.
Of much more promise in this area is the proposal of
Provident National Bank of Philadelphia to establish
and manage a closed-end investment company. Once
again, my view of the public interest is that it would
be best served by making such a service available to
the public, and that proposal appears to be the way
to accomplish it. I note that the Hunt Commission
recommended that banks be permitted to manage and
sell mutual funds, including commingled agency accounts. It should come as no surprise to you that we
agree with that proposal in all respects.
In conclusion, I would state that the commentary
which we have received on our proposed rules has been
of great assistance to us, and I hope that it will not
end here. As Mr. Camp has said, we are always ready
to receive your questions, your comments, and your

269

mild criticisms. Seriously, both you and the staff of
the Trust Division of your association have been very
helpful, although I am sure that many will say that
what finally emerges certainly is not what they would
have written if they were doing it alone. Probably, that
will include me. We have also received the comments of
persons outside the industry, including the Nader organization. I expect that they might make the same
comment, perhaps even stronger, about the final
language. We won't please everybody, but then that is
not the proper function of a government regulation, to
please either the regulatees or the professional fault
finders. Rather, it is in my opinion, to provide a means
of supervision which is effective, and yet imposes the
least possible restraint. That requires, on the one hand,
that the proper control be imposed even if it conflicts
with a long-standing practice, and on the other, that
the regulation attempt to meet only those dangers
that are real, rather than also including the hypothetical. That is what I hope we will accomplish.
STATEMENT OF
ROBERT BLOOM, CHIEF COUNSEL,
OFFICE OF THE COMPTROLLER OF THE CURRENCY,
BEFORE THE SENATE COMMITTEE ON BANKING,
HOUSING, AND URBAN AFFAIRS, ON S. 3562,
AUG.

2, 1972

The Comptroller of the Currency and the Treasury
Department favor continuation of the policy adopted
by the Congress in 1969 of complete equality of treatment between State and National banks with regard to
State taxes. Both S. 3562 and Title II of H.R. 15656
provide complete equality of treatment, but impose
restrictions on the States with regard to collecting two
types of taxes from any bank. The language of either
bill is acceptable. However, we believe that the wording of H.R. 15656 is somewhat clearer and less susceptible to the creation of questions of interpretation.
Unless one or the other of the bills is enacted prior
to the end of this year, the "permanent amendment"
of section 5219 of the revised statutes (12 U.S.C. 548)
will become effective on January 1, 1973. If that provision is permitted to go into effect without revision, there
will thereafter, be no federal statutory restrictions of
any kind on the power of States and their subdivisions
to impose taxes on insured banks. The Congress, in
enacting Public Law 91-156 in 1969, was concerned
over possible unforeseen consequences of that substantial change in preexisting law and requested, in section
4(a), that the Board of Governors of the Federal Reserve System make a study to determine the probable
impact on the banking systems and other economic

270



effects of the change and, in section 4(b), requested
that the Federal Reserve study include recommendations as to any additional Federal legislation that may
be needed on the subject. The Board, in response to
that request, made an exhaustive study of the subject.
The Board's conclusions and recommendations
dated May 1971 were that the permanent amendment
of Public Law 91-156 should not be permitted to go
into effect without revision. The Board concluded that
if this were allowed, the changed tax status of banks
could open the way for State and local tax measures
which "could impair the ability of the banking system
and possibly the entire structure of financial intermediaries to contribute to the efficient allocation of the Nation's credit resources." The Board recommended that
restrictions be continued on the powers of states and
local governments to collect two types of taxes: (1)
a tax on intangible personal property, and (2) "doing
business" taxes imposed by States other than the State
of the home office.
The reasons for the Board's recommendations are
clearly and persuasively set forth in their Report. I shall
only briefly summarize them here. The case for prohibition of ad valorem taxes on intangible personal property of banks is set forth on pages 2, 3 and 4 of the
Report. The Board points out that a general tax on
intangibles would bear with much greater weight on
banks and other depositary institutions than on nonfinancial businesses. Virtually all the assets of such institutions are in the form of intangibles whereas that type
of property is much less important for nonfinancial
firms. Banks are closely regulated and supervised with
published balance sheets; the tax assessors are unlikely
to undervalue fixed claims, such as bank assets, to
the degree that they can, and generally do, undervalue
other types of assets. However equal the treatment provided in the tax law, in practice depositary institutions would be at a marked disadvantage compared
with businesses and individuals, particularly where intangibles are blanketed into a general property tax that
purports to apply the same evaluation standards and
rates to all types of tangible and intangible personal
property.
An intangibles tax applied to banks would have a
number of adverse economic consequences depending
in magnitude on the level and geographic extent of the
tax. The principal effect would be an impairment of
the ability of such financial intermediaries to gather in
savings and allocate funds for productive investment.
The process of financial intermediation performed by
banks is particularly vulnerable to an intangibles tax
because the duplication of financial assets that is inher-

ent in the flow of savings, first into deposits and then
into customer loans, would expose savings flowing
through intermediaries to an additional layer of taxation not encountered when funds flow directly from
savers to ultimate borrowers.
A tax on intangible assets would tend to induce banks
to divert funds from taxable to tax-exempt forms of
assets—that is, from financing for consumers and businesses to acquisition of Federal, State, and local obligations.
The Board also recommended, and these bills embody, a limitation on taxation by States other than the
state of the principal office. The bills permit such other
states to collect the following forms of taxes from outof-state banks which may be doing some business
within the collecting state's borders: (1) sales and use
taxes upon purchase, sales, or use of tangible personal
property within such jurisdiction; (2) taxes on real
estate or on the occupancy of real estate located within
such jurisdiction; (3) taxes on the execution, delivery,
or recordings of documents within such jurisdiction;
(4) ad valorem taxes on tangible personal property located within the jurisdiction; (5) license registration
transfer, excise or other fees, except those based on
gross receipts or net incomes, imposed on the ownership, use or transfer of tangible personal property located within the jurisdiction; and (6) payroll taxes
based on persons employed in the jurisdiction.
The bills would prohibit non-domiciliary States from
collecting taxes measured by income or receipts or
other so-called "doing business" taxes. Section 207 (a)
of H.R. 15656 would direct the Board of Governors
to study further the question of the application of
State "doing business" taxes on out-of-State insured
commercial banks and to make recommendations for
legislation which will provide equitable State taxation
of out-of-State insured commercial banks. We understand that the Board does not believe that it is the
appropriate agency to make such recommendations.
The reasons for the limitation on "doing business"
taxes by non-domiciliary States are stated on pages 4,
5 and 6 of the Board's report. In the absence of some
Federal standard under which States are required to
divide the tax base, there is no assurance that the sum
of the taxes which two or more States may levy will not
exceed 100 percent of the actual base. Even where this
limit is not exceeded, serious burdens result when two
or more states claim jurisdiction to tax, for example,
the same net income, using different rules for interstate division of the tax base and requiring different
kinds of records and reports.




The added cost of acquiring technical competence
regarding the differing tax laws and procedures over
all states where business is done, maintaining the records needed to determine which taxes are applicable
and the amount of liability, and preparing and filing
the returns in all affected states may be even greater
than the taxes.
In addition to the importance of avoiding overtaxation of any given tax base, it is equally important to
avoid excessive compliance costs and the erection of
barriers to interstate credit flows. Such barriers would
be raised not only by the taxes themselves, but also if
there ensued uncertainty, controversy, and litigation of
the sort that for decades has characterized taxation of
interstate mercantile and manufacturing businesses.
Uncertainties about potential tax liabilities and concern about compliance burdens could become material factors in decisions to make particular loans or
investments.
The imposition of income or other "doing business"
taxes would tend to induce out-of-State lenders to divert credit flows away from states imposing such taxes
and into states with a favorable tax climate or into
marketable securities.
The Board's conclusion, with which we agree, is that
the non-domiciliary State's power to impose income or
other "doing business" levies, should be suspended
until such time as a formula can be devised for the fair
allocation of such taxes among states.
The Comptroller of the Currency fully supports the
recommendations of the Board of Governors of the Federal Reserve as embodied in Title II of H.R. 15656 and
S. 3562.
REMARKS OF
DEAN E. MILLER, DEPUTY COMPTROLLER
OF THE CURRENCY FOR TRUSTS,
BEFORE THE WESTERN TRUST CONFERENCE
OF THE AMERICAN BANKERS ASSOCIATION,
MONTEREY, CALIF., SEPT. 7, 1972

"Without Precedent"
It is always a pleasure, as well as an honor, to be
asked to come to a place such as this and address a
group such as yourselves. One feels very pleasant on
being invited, and can spend a considerable period
after accepting basking in the glow of being so honored,
while doing nothing to pay for it. The glow is not without vexing little interruptions, however, and probably
the first is when you are asked to give a title for your
remarks. As this usually takes place quite some time in
advance of actual preparation of your text, it presents

271

something of a challenge. You know of matters on
which you would like to speak if it were today, or tomorrow, or next week. But beyond that a number of
variables begin to take effect, or could, so that there is
always a risk, at least in my area, that the matters of
today will not be appropriate when the time arrives to
speak. Thus it is a challenge to provide a title far in
advance which covers that possibility. There are two
ways I have coped with that problem. One has been to
pick a good safe general title, such as "Trust Department Supervision" (which is not my title today). That
is certainly a safe course to follow, as because of my
position, there is always something I can say relevant
to the title, although that something is not always
the same. That way of choosing a title has the disadvantage of being colorless, the kind of thing that makes
your spot on the program look like a good time to be
elsewhere. My alternative has been to try to find a
catchy title; one which might suggest various things
to different people, and perhaps in the process, provide
motivation for them to come and listen to see if, in fact,
the message concerns one, or several, of the possible
subjects within the broad coverage of the title about
which they would like to hear. It also provides the
speaker with flexibility, and can look great on a program. That was my course for this conference, when I
titled my remarks "Without Precedent." One could see
that on the program and assume that I was going to
say that the number of criticisms in examination reports
of banks in this area is without precedent, which isn't
so. Or one could assume that I would dwell upon the
unprecedented growth in assets held in bank trust departments, or the unexampled development of new
services being offered by them. One could assume that
I was going to be sarcastic and observe that the existing
desire of so many uninformed people to modify or restrict bank trust department operations in so many
novel ways is worthy of note. Those were all considerations that went into my choice of a title, while, of
course, I maintained the hope that the real subject on
which I wished to speak would not become outdated.
I shall proceed upon the assumption that it hasn't.
Over the last two decades, and more particularly the
last one, there has emerged a marked change in attitude
on the part of a great many members of our judicial
system in the direction of activism. "Activism" itself
isn't precisely the correct word, unless viewed in the
context of the way the judicial system works, with the
initiative taken by litigants and the judge responding.
Perhaps the development, therefore, could better be
described as a responsiveness to activism. Thus we have
seen judges agreeing with plaintiffs that causes of ac-

272



tion, which in previous periods were not thought to
exist, in fact, did, either under common law or under
statutes which have been on the books for some time.
As a corollary, we have seen them finding judicial
remedies for those causes, some of which had been
thought, in times past, to be the role of other branches
of government.
It would be difficult to pinpoint precisely when that
change to responsiveness began. Some would say that
it started with the ascendancy of Chief Justice Warren
to the Supreme Court, but I do not think that would
be accurate. A case might be made that the prevailing
theories of proper jurisprudential activity follow a cyclical pattern, and what we are presently experiencing is
the movement of the cycle away from the mean, or central position of the spectrum, and that the process has
parallels in previous eras. I put that statement in those
terms because I have not made the investigation necessary to develop the facts to support or refute the proposition. It is not material to my point here whether what
we are seeing is part of a cycle which will one day abate
and reverse itself, or whether it represents a permanent
restructuring of our governmental system, insofar as it
may imply a greater judicial role in the lawmaking
process. Even if the cyclical analysis is correct; it is apparent that we are nowhere near the turning point, and
the trend is apt to continue. I do not believe that the
new members of the Supreme Court, the "strict constructionists", even if they become a majority, have been
shown to be conceptually opposed to the general principle of growth of judge-made law and judicial remedies. Until a number of cases, on a variety of subjects,
are decided by the Supreme Court on the ground that
they are legislative rather than judicial questions, I
think that my assumptions here are safe. Neither does
it appear to me that a countermove will soon be generated by the lower judiciary or by the bar. Current
trends in decisions and suits filed are, I believe, in the
direction of more new courses of action, more new
judge-made remedies. A visit to the campus of any law
school can supply evidence that such trends are likely
to continue and intensify.
Thus, I hope I have established the bases for my
preliminary conclusion—that we are now in an era
where judges are discovering new causes of actions in
areas where grounds for resort to the courts were heretofore thought to be lacking, and are fashioning new judicial remedies to redress those causes of action, with the
result that whole new volumes of decisional law are
being created. In the process they are becoming increasingly result-oriented, and less and less apt to be swayed

by forms and rules that permit results which run counter to very basic and simple rules of fairness.
The process is not entirely being conducted at the
judicial level, for the legislatures and Congress have
occasionally assisted through enactment of statutes
creating new rules and giving rights of action to enforce
those rules. However, it is primarily occurring in the
courts, in part, some have said, due to the failure of
our existing legislative machinery to function properly.
It has been claimed that courts have become more
rapid sources of redress than legislatures, as the undemocratic features of those latter bodies have increasingly made them unresponsive to needed change. The
committee system, the absence of party leadership and
discipline, and the high degree of effectiveness of lobbying efforts of vested interests have been pointed to as
the reasons why that state of affairs has come to pass.
Personally, I believe a strong argument can be made
that until there is legislative reform we are increasingly
going to have laws made, and new rights and wrongs
and their remedies delineated, by the judiciary.
Rather than devoting more of my time to the development of that conclusion, let me now relate what
I think this means to our area of endeavor—the trust
business of banks. Put summarily, and in terms of my
title, I think that it means that legal precedent is going
to become less and less of a reliable guide for you in
determining how you will run your business. Indeed,
isn't that already so? Who could have foreseen, on the
basis of precedent, the implications of the McDonnell
Douglas and Texas Gulf applications of the securities
laws as to trust department operations? Or the application of the antitrust laws to the question of allocation
of brokerage in return for deposits? Or to the holding
of competing closely-held companies in trust accounts?
Who could have foreseen that some kinds of trust accounts created by settlors in accordance with the time
honored motives and procedures would become securities, issued by some entity other than the bank which
accepted them? Who could have anticipated the emergence of suits by beneficiaries for engaging in investment and administrative procedures which have gone
unchallenged for years?
Yet those things, and many similar ones, have come
to pass, and those of you who failed to anticipate them,
and most of you are included in that number, are now
viewed as being slightly less than perspicacious as a
result. Yet, in most cases you were acting pursuant to
the advice of your competent legal counsel, as old Regulation F used to require. Were they incompetent?
That certainly would be too harsh a judgment. A case
can be made, however, for the proposition that they,




and you, failed to anticipate the prevailing jurisprudential trends. But, I don't think that fault can be
found for that either. This industry, particularly, has
had to be guided by the past, in its many legal requirements of care and prudence. It has been a fact of your
existence that the propriety of your actions will be
judged after the fact, with the full benefit of hindsight.
Thus, in making your decisions, it has been useful to
prepare for that judgment, should it come, to rely upon
what has stood the test of time
what has been tried
before and found acceptable. But, as I think I have
shown, precedent, or the absence thereof, if you will,
may no longer be of complete comfort to you in making
judgments, and you may be faulted if you don't anticipate future developments. The next question is obvious, if I think that this revolution has occurred in
our traditional framework for determining the rightness of your actions, what would I have you do?
To begin with, I would point out that what I think
we are seeing is no revolution. It is not a cataclysmic
development that has completely overturned the preexisting order, The continuing jurisprudential evolution has not primarily been contrary to reason or logic;
it has only been contrary to precedent. Some decisions
have greatly unsettled the preexisting order of things,
to be sure, but on the whole, they have not been unjust. In nearly every area you can name, the ultimate
result has been one which can be grounded on very
elementary notions of justice. The principal effect, I
think, of the emergence of the judiciary as a prime
means of effecting reform, has been to remove impediments to justice, impediments which in some cases also
provided very meaningful protections for business and
financial operations. In other cases, we have seen practices attacked which might not be considered to be protections, but which were an integral part of a complex
system of rules which the establishment knew well and
had come to plan upon. Those have come under attack where they have, in addition, been used by some
to cause injustice to others. There are several areas in
the corporate fiduciary business which may be vulnerable to that type of attack. Let me touch upon what
I think are a few of them.
Possibly the biggest area is the employee benefit
trusts. Here there have evolved a number of practices which have the sanction of widespread acceptance by the banks, apparent authority in appropriate
governing instruments, and conformity with laws having concerns other than the protection of beneficial interest holders—the tax laws, usually. Here too, the
National legislature has struggled for years to come up
with legislation to provide protection for the employee,

273

with the prospects, at best, still only of achieving partial redress. The field is ripe for an extension of the
trend I have described. In some situations where investments have been made, consistent with investments
in similar accounts at other banks, where the bank's
acquiescence therein is pursuant to specific governing
instrument authority, and where there is no question
of failure to conform to the tax laws, it is apparent
that under any common sense rule, the investment is
obviously motivated by something other than the employee's exclusive benefit.
Another situation might be in the case of a personal
trust which was very conservatively invested over the
years, say in government bonds, so much so, that the
trustee's fees have exceeded the income and growth
and have gradually eaten away the rest. The investments were legal under the law of the State, the trustee
strictly conformed to the governing instrument provisions and has filed regular accountings, but the widow
is poverty-stricken.
There may be other possibilities, I shall not anticipate them. My two examples are cases in which, I now
think, the beneficiary may have a gripe, and some of
you don't agree. The point is that I do not believe that
you can rely upon precedent, or its absence, in situations where the beneficiary is getting less than he might
have had the trustee been truly zealous in serving only
him. The fact that it has always been done this way,
or that everyone in New York is doing it, or that there
are miles of language of authorization and exculpation,
or that it conforms to the tax laws, or the disclosure
laws, or even to those rules of the law of trusts which
no longer have justification, will not be of help. Further, I do not think that you can rely upon legal advice
that, in the foregoing situations, you will be protected.
It is unfortunate that some attorneys apparently believe
that the steps necessary to qualify for a tax benefit, or
to comply with the Welfare and Pension Plans Disclosure Act, are the same as those necessary to protect
a bank trustee from liability for a wrong done its beneficiary. Another curious example, which I have occasionally run across, concerns the banks' employee
benefit trusts for their own employees. It is difficult to
be charitable toward attorneys' opinions concluding
that because a bank's plan is trusteed by individuals,
rather than the bank itself, our Office has no authority
to review it. Invariably, those individuals are either
identified with, or subject to, the bank's management
and, of course, they are reviewed just as if the bank itself was trustee. I think it should be a breach of trust for
you to pay an attorney for advice like that.

274



Much of the "new law" which has already come on
the scene in the professional fiduciary area concerns
the application of "other laws." The securities laws are
a good example. In some cases, as I have noted, it has
been extremely unfortunate that a long-standing practice is given a securities law label, and then subjected to
the rules of a very different ballgame. Often the application of securities laws has not necessarily provided the
optimum regulation. On the other hand, because
certain practices were engaged in by many banks pursuant to proper authority, in conformity with the tax
laws but to the possible detriment of a segment of the
public, the idea that resort to the securities laws is
possible has arisen. The same could be the case for
antitrust laws. How different it might be if you and
your lawyers, instead of merely looking to see if a suit
for breach of trust had succeeded in the past, in a
transaction similar to what was before you, also inquired if there were any other public interest which
such an action would offend? It is a question that you
will have to be constantly asking in the future. The
precedents are yet to be made, and if you are the one
who makes them, it will be painful. If an activity of a
bank trustee, that offends a public concern not previously considered in decision making, is attacked as a
violation of some indivisible, non-exculpable duty of
the trustee, or of the Securities Exchange Act of 1934,
or of the Clayton Act, or of some act waiting in the
wings yet to be applied, I think you can count on the
courts finding against you. And, if it happens very
often, you're going to be forced to make a decision
on whether to be bankers or trustmen, for you may be
deprived of the opportunity to be both.
So, the next time your good customer, or your
management, comes in your door with such a proposal
and you know the kind I mean, see if you can do a
little more than smile weakly and whimper something
about the jerk in Washington with the silly-sounding
title who doesn't have express written authority to
object to the specific transaction, but who will do so.
Use a little imagination about the possible duties of
the trustees, or the Federal or State laws that the
action might violate. I can assure you, there is an army
of plaintiffs' attorneys, and perhaps less than an army,
but a sizeable number of government attorneys, who
have the most fertile of imaginations, and they will be
doing just that.
In a talk I gave at the Midwinter Trust Conference
earlier this year, I indicated that we were considering
the amendment of Regulation 9 to impose a requirement that our examiners inquire as to whether a bank

has achieved the best execution on security purchases
and sales. Several persons have commented upon that
proposal, in the main, pointing out that "best execution" is a very difficult thing to isolate and define. Following that conference, the SEC published a policy
statement. One portion of that statement reads as
follows:
Where there is no self-dealing, and an advisor is
not affiliated with the brokerage firm executing
the transaction, it is reasonable to presume that
the commission rate paid to such a non-affiliated
broker reflects the full range of and quality of the
broker's service and is in the beneficiary's best interest; however, as indicated in the policy statement, where commission rates reflect services furnished to the managed account in addition to the
cost of execution, managers must stand ready to
demonstrate that such expenditures were bona
fide. The determinative factor is whether the
transaction represents the best qualitative execution for the beneficiary.
As we interpret that excerpt, it can be translated
fairly easily to a bank trust department context. Accordingly, we have instructed our examiners to follow
it, substituting "bank" for "advisor", of course. It would
appear that the bank could buy services, such as research, from brokers consistently with those principles,
as long as the service was not illusory, and was for the
benefit of the accounts for whom the transactions were
executed, and were not for the bank. We shall presume
that a commission rate paid, if consistent with quotations for that day, is proper and in the account's best
interest, but other circumstances might destroy that
presumption.
An example of where such a presumption would be
destroyed might be in a fully discretionary account
where a bank followed directions from the settlor as to
choice of brokers. If, on the same day, a purchase for
one account of a particular security were made through
a broker so designated, and a combined purchase for
several other accounts of the same security were made
through another broker at a negotiated fee which was
more favorable, it would appear that we should be
concerned. You may think of other examples.
In February I also mentioned that an amendment of
Regulation 9, to provide that "no director, officer, or
employee of a National bank shall recommend or initiate any purchase or sale of securities for a trust department on the basis of inside information," was under
consideration. That was recommended by the Hunt
Commission. We have not adopted such an amendment, although, of course, that does not mean that
banks are free to make such purchases or sales. No one
would question that securities laws apply to banks in

that case. However, to put a specific legal requirement
on Regulation 9 would be contrary to our regulatory
modus operandi. The Regulation generally requires
that bank trust departments be operated in accordance
with law, Regulation 9, and soundfiduciaryprinciples.
That is broad enough to encompass all applicable law,
and putting specific provisions in the Regulation would
only complicate the process. The question would always come up, once we started putting in specific prohibitions, what about the practices omitted? Instead
of a regulation, we would soon have a vast catalogue
that would be unnecessarily complex and still not necessarily comprehensive. Accordingly, we have issued no
regulations on that point.
Speaking of the Hunt Commission, I am occasionally
reminded that it did recommend that banks file annual
reports on their trust holdings. Most recently I came
across another bill, H.R. 16246, which would require
quarterly disclosures of certain trust department holdings with the FDIC. It was introduced by Chairman
Patman. We think that such reports would be unnecessary, and only productive of increased bureaucratic
impediments to business. As I said in New York, we
would, if such a requirement were enacted, do what
we could to modify our procedures so as to make the
reports as useful and non-duplicative as possible.
To sum up, I think that we are in an era when, increasingly, we are going to have to deal with substantive justice and cease to rely upon formalistic distinctions in all areas of our thinking. For just as you cannot
cure a conflict of interest by spinning-off a trust department to an affiliated entity, neither can you remove a
wrong to a beneficiary by saying that because of some
technicality you owe him no duty. I just don't think it
will work out that way. Do not say to me "read me the
statute" or "cite me the decision" which forbids it. The
day that I have that statute or decision may be one day
too late for the banking industry.
STATEMENT OF
ROBERT BLOOM, CHIEF COUNSEL,
OFFICE OF THE COMPTROLLER OF THE CURRENCY,
BEFORE THE SUBCOMMITTEE ON
COMMERCE AND FINANCE OF THE HOUSE
INTERSTATE AND FOREIGN COMMERCE COMMITTEE,

O N H.R. 14567 AND 14826 AND S. 3876,
SEPT. 8,

1972

The Office of the Comptroller of the Currency welcomes this opportunity to present its views on these
three bills which are designed to provide Federal authority to achieve standardization and automation of

275


i_ni7 n - 73 _

the securities transfer process in order to prevent future
back-office crises.
We believe that this object is one with which the
Congress should deal promptly.
The means to be established by these bills to accomplish their common end, while similar in many
respects, contain certain differences. These differences
are of importance to the banking agencies. H.R. 14567
is sponsored by the SEC and supported by the Administration. H.R. 14567 would give the Securities and Exchange Commission authority to establish rules and
regulations concerning minimum standards for the performance of transfer functions, measures, and personnel standards for safe handling and custody of securities and funds, and operational compatibility of the
transfer agent with other persons involved in the securities handling process.
The enforcement of these rules, with reference to
transfer agents which are banks, would be placed in
the bank regulatory agencies. Substantive rules would
be proposed by the Commission only after prior consultation with the bank regulatory agencies. All transfer agents would be required to register. However,
bank transfer agents would register with the bank regulatory agencies and a notice supplied to the SEC, all
other transfer agents would register with the Commission.
H.R. 14567, by utilizing the existing banking agencies to participate in and administer the provisions of
this Act as they are applied to banks, is an excellent
means of approaching the problem, in our opiniqn.
The bank supervisory agencies are fully capable of administering the provisions of this Act and are willing
to do so.
Accordingly, if the responsibility for applying the
provisions of this bill to banks were given to another
agency, such as the SEC, the result would be an additional and unnecessary expense and overlapping and
bureaucratic duplication.
Indeed, it is our belief that H.R. 14567 does not go
as far as it might in this direction. The bank supervisory agencies presently oversee the operation of all
aspects of banking activities, including their performance as transfer agents. That is done primarily through
the regular examination of those banks by on-the-spot
examinations.
In this, the methods of the banking agencies differ
from that of the SEC, which relies primarily upon reports which are filed with the Commission in Washington and subject to scrutiny there. Both systems are effective. However, it would appear that no case is
made for requiring banks to be subjected to both sys-

276



tems of supervision, as this bill would accomplish
through requiring banks to file registration statements.
The statements would serve no supervisory purpose
and can only be justified on the basis of providing evenhandedness of treatment between bank and nonbank
transfer agents—an evenhandedness which cannot
exist in reality, because of the dissimilar supervisory
frameworks of these institutions.
In addition, because the great majority of transfer
agents in this country are banks, it would appear that
a better solution would be for the standards of performance for transfer agents to be established by the
SEC and the banking agencies jointly.
We do not believe that such a system would be unworkable, as some witnesses have asserted. All of the
agencies involved are responsible governmental entities and realize their primary responsibility is to serve
the public. We do not believe that there would be any
difficulty in achieving agreement on the measures
necessary for the protection of the public.
By contrast, H.R. 14826 makes no reference to the
bank regulatory agencies. For the reasons outlined
above, therefore, we do not believe that it offers the
best solution, and recommend that it not be enacted.
The principal difference between H.R. 14567 and
S. 3876, in our opinion, is with respect to the extension
of Federal supervision to clearing agencies and depositories. H.R. 14567 provides for both substantive rule
making and enforcement over all clearing agencies in
the SEC. S. 3876 divides the responsibilities between
SEC and banking agencies with respect to trust companies that are clearing agencies. The latter approach
definitely appears to us to be the proper division of
responsibility.
In connection with clearing agencies and depositories, we should like to point out a technical omission in
all three bills. Under existing law, a National bank is
not permitted to purchase or own a minority stock interest in any corporation with certain statutory exceptions. Also under present law, National banks and State
member banks are not permitted to own minority stock
interest in any corporation, with certain statutory
exceptions.
Since it is, we believe, contemplated by all parties
that in the future, corporations will be set up to serve
as clearing houses for depositories, which might be
owned jointly by the participating brokers and banks,
there is an intention to permit banks to own the necessary stock in such corporations for the purpose of having a voice in the management of the corporation, if in
nothing else, in the election of directors. We believe
that State laws are in the process of being amended to

permit State banks to have ownership in clearing agencies and depositories. But, in order for National banks
to participate in that manner, whatever bill is enacted,
we believe, should have a provision specifically empowering National banks and then through a certain
carry-through provisions which will also apply to State
member banks automatically, to own the stock,
whether all of it or a minority interest, if the clearing
agency is to be owned jointly with others.
We have suggested a form of amendment to the National Bank Act which would accomplish that purpose. We recommend that whichever bill isfinallyenacted have that provision in it.
REMARKS OF
DAVID C. MOTTER, DEPUTY COMPTROLLER
OF THE CURRENCY (ECONOMICS),
AT THE THIRD ANNUAL CPA—BANKERS SEMINAR,
HOUSTON, TEX., NOV. 15, 1972

"The Business of Banking in the 1970's"
I would like to give attention to three general topics;
the dimensions of the business of banking, new proposals relating to the regulation of banks and other
financial institutions, notably the Hunt report, and
the area often referred to as social responsibility of
business.
In my view, determining the dimensions of the business of banking was the most crucial issue facing the
industry in the 1960's, and will continue to be the
dominant issue throughout the 1970's. Bankers have
every reason to be proud of the dynamic response their
industry has made, and continues to make, to the
burgeoning and evermore sophisticated demands by
the public for financial services. Reflecting that dynamic responsiveness, the product and service mix of
the banking industry today differs significantly from
that in 1960. Although it would, indeed, be rash to try
to project the 1980 mix, it is quite safe to predict that
the changes from the current offering will be as great as
those which have occurred in the earlier decade.
Bank entry into non-traditional areas has not been
accomplished without overcoming obstacles and opposition. The principal obstacles have been, and are,
statutory and regulatory barriers, some of which
stemmed from Depression and post-Depression anxieties. Most of the opposition has come from nonbanking firms that saw the expansion of banks into
their areas of operation as a competitive threat.
We are proud of the role the Comptroller of the
Currency has played in encouraging banks to meet the




new financial needs of the public as they arise, and to
•expand activities in non-traditional areas when it
appears that greater bank participation would be in
the public interest. The Office has engaged in a comprehensive review of its entire body of regulation, with
the express purpose of weeding out those regulatory
restrictions that were not required by statute and were
not needed to maintain the liquidity, solvency, and
continuity of the National Banking System. That review continues.
In ascertaining whether a proposed new activity
can properly be carried out by banks, the Office applies
a three-fold test. Is bank participation legal under the
relevant statutes? Will bank participation have no
adverse effect on bank soundness? Will bank participation be in the public interest, in the sense of greater
consumer choice in the relevant product market?
When the answers to all three questions are affirmative,
our Office lifts existing regulatory barriers to bank
participation.
The list of activities into which banks first entered
in recent years, or in which their role has greatly expanded, is long and growing; direct lease financing,
travel services, specified insurance activities, data processing, factoring, revenue bond underwriting, and commingled trust funds, among others. You will recognize
that bank participation in a number of those sparked
litigation brought by non-bank firms already engaged
in the activity.
In those cases, even the plantiffs seldom had the
effrontery to claim that bank entry and participation
had an adverse effect on the customers in the relevant
market. After all, bank participation led to additional
sources of supply and added competition, often creating
downward pressure on existing prices. In general, the
thrust of the suits was anti-competitive; most simply
stated, the briefs of the plaintiffs held that bank competition was inappropriate, improper, illegal, and
unfair.
To a considerable degree, the one-bank holding company movement of 1968-70 represented an attempt by
banks and bankers to strengthen banking's hand in
suits of that type, by shifting the form of corporate
organization. You all recall the prolonged Congressional hearings of 1969 and 1970, finally culminating
in the December 1970 amendments to the Bank Holding Company Act.
With hindsight, it seems fair to say that the position
of the banking industry on the question of the dimensions of the banking business was never properly dramatized during the Congressional hearings and debate.
At least, large elements of the Congress and the public

277

never grasped or understood it. Rhetoric about holding
company expansion was allowed to obscure the basic
issue: would bank participation in activities A, B, C,
et al. be in the public interest? It should have been
possible to contrast more sharply the pro-competitive
stance of the banking industry with the anti-competitive stance of the opponents of bank expansion.
After all, when firms embark on a new activity, they
represent additional competitors in the relevant market.
Other things being equal, the effect of the additional
competition is to put downward pressure on existing
prices. That effect, within limits, will thus redound to
the benefit of the users of the services in question. Banks
now participate in mortgage servicing, direct lease
financing, broadened trust services, sales finance operations, and other financially-related activities.
Because the true stance of the banking industry was
masked, muffled, and misunderstood, the outcome in
1970, and to the present, was almost serendipitous. To
the good fortune of both the public and the banking
industry, Congress in its December 1970 amendments
to the Bank Holding Company Act refused to pinpoint
a specific negative "laundry list" of activities. The
wisdom of that decision is evident when we note that,
in the absence of restrictive statutes or regulations,
changes in the product mix of financial institutions
often occur with breathtaking speed. The 1970 Bank
Holding Company Act amendments provided a flexible
statutory base for further expansion by banking organizations into financially-related activities.
The Federal Reserve Board's Regulation Y has, in
effect, placed a regulatory umbrella over most of the
newer activities upon which banks had embarked during the preceeding decade. The Board has not yet
demonstrated a strong bent for opening the way to
additional activities; however, the momentum and the
logic of the situation are such that one may realistically
hope that it will happen over time. Up to now, the
absence of geographic restrictions on the expansion of
holding companies into non-traditional activities has
been the most significant aspect of the 1970 legislation
and its implementation.
In our Office, we view the 1970 legislation and Regulation Y as one element in the vindication of the Comptroller's earlier pioneering positions—often lonely positions. Another vindication may be found in portions of
the Hunt Commission report, to which I would now
like to turn.
If one can give an overall characterization to that
report, it favors elimination of many archaic restrictions on all types of financial institutions and the crea-

278



tion of a climate in which those institutions are freer
to compete with each other and with other firms. With
regard to specific activities, for example, the report
recommended that commercial banks be allowed to
create commingled agency accounts, to underwrite revenue bonds, and to engage in whatever activities are
"approved for bank holding companies by the Board
of Governors under the Bank Holding Company Act."
The Commission report also supports certain bank
operating powers that have been in contention in recent
years, including the right to issue subordinated debt
instruments of all maturities and an expanded use of
the so-called "working capital" acceptances.
An Administration task force is developing a set of
recommendations based on the Hunt report. No Administration position has yet been announced; therefore, nothing about that eventual position should be
inferred from my remarks. Recently a Treasury official indicated that a list of recommendations based on
the Hunt report may be released in early April, followed by submission of draft legislation in June.
Regardless of its eventual disposition, I think the
Hunt report has considerable inherent interest for students of banking. The report's recommendations are
built on the assumption that elimination of most competitive restrictions in the financial sector will be in the
public interest. As noted before, the financial sector
of our economy, and the banking industry in particular, are still burdened with a heavy overlay of statutes
and regulations stemming from the economic debacle
of the 1930's. The effect of many of those statutory and
regulatory restrictions is to hamper severely the ability
of entrepreneurs to meet developing financial needs of
the public responsively and rapidly. Much of the body
of law and regulation rests on a holdover of fear of the
collapse of financial organizations and, indeed, of the
whole financial system.
Quite rightly and understandably, the legacy from
a period when about half of our commercial banks
permanently closed their doors has remained strong. I
do not at all mean to downgrade the necessity of safeguarding the liquidity and solvency of our banking
system. We should keep in mind, however, that, qualitatively, we have a different type of system in the 197O's
than we had in the 1930's.
The touchstone of competition has been rather consistently applied in the Hunt report. In most of its
recommendations, one or more of the following are involved : freeing existing participants in a market from
certain restrictions on their activities; allowing the
entry of new participants into a market; or the creation

of rules of the game which place all participants on a
more nearly equal footing.
In connection with time and saving deposits of commerical banks and thrift institutions, the Commission
recommends the immediate abolition of ceiling rate
controls for deposit and share accounts of $100,000 or
more. For time and savings deposits of less than
$100,000, the Commission recommends that the power
of the Federal Reserve Board to impose ceilings be
considered a standby power "to be exercised only when
serious disintermediation is threatened" and that even
the standby power be abolished 10 years after the implementation of the Commission's recommendations.
Thus, the clear thrust of the Commission here is to free
depository-type institutions to compete for funds in the
marketplace.
On the topics of required reserves and the taxation
of financial institutions, the Hunt Commission offers
guidelines aimed at placing all competitors on a more
nearly equal footing.
The Commission recommended uniform reserve
requirements for all commercial banks and for all those
savings and loan associations and mutual savings banks
which offer third party payment services, "with no
differences based on classification of city or size of
institution."
In connection with taxes, the Commission recommended that the Congress enact "a single tax formula
applicable to all depository institutions offering third
party payments services." A transition period of 5 years
was recommended for adjustments to that formula.
I think it is apparent that in the area of taxation and
reserve requirements, it is much easier to set forth an
overall goal of equality than it is to develop workable
and equitable procedures to reach the goal over time.
Some observers have stated that they see the so-called
transitional problems as perhaps the principal barrier
to the implementation of the Commission's tax and
reserve recommendations.
The Commission's recommendations in the housing
and mortgage area again reflect an attempt to give
more importance to the functioning of free markets. It
is recommended that "interest rates on FHA and VA
mortgages be determined in the market place, without
regard to administrative or statutory ceilings. . . ."
The Commission urges a number of steps which would
make the variable-rate mortgage a more readily available option to be offered by financial institutions to
home buyers. The Commission also recommends that
"states remove statutory ceilings on allowable interest
rates on residential mortgages. . . ."




On the topic of branch banking, although the Commission would leave the branching determination to
the individual states, it does recommend that "by State
laws, the power of commercial banks to branch, both
de novo and by merger, be extended to a statewide
basis. . . ."
In our Office, frankly, we do believe that a regulatory authority can come closest to achieving the optimum banking structure in its jurisdiction when all
structural options are open
chartering a new bank,
adding branches for existing banks, merging of two
or more existing banks, and forming of holding companies which can then acquire existing banks. However, we alsofirmlybelieve that the decision concerning
branching should rest entirely with the individual
states.
For my concluding topic, I would like to present a
few ideas concerning the social responsibility of business, in general, and of banking, in particular. In doing
so, I am going to draw heavily on a statement made by
the Comptroller of the Currency, for two reasons: I
agree fully with it, and I believe it to be one of the best
statements on this subject that anyone has made.
Much of the current criticism directed at the business sector reflects a lack of knowledge and understanding of the functioning of our free enterprise system, and
of the crucial contribution of that system in making our
economy the richest and the most productive in the
world today. In a word, I believe that the banking industry, and to some extent the business sector in general,
is receiving a "bum rap" from a number of its "social
activist" critics. However, I am not suggesting that
anyone should rest on his laurels. There is much to be
done, in both the public and private sectors, if our
Nation is to fulfill the hopes and dreams of its citizens.
Certain key relationships underlie the functioning of
financial institutions in our enterprise economy. Over
80 percent of bank funds stem from depositors who
have every reason to believe that their funds will be
carefully safeguarded. The banking industry can properly perform its principal functions only if individual
institutions are operated in a way that maintains their
solvency, and thus, the safety of deposits. That point
appears to escape some banking critics. The banking
industry is faced with the sort of massive misconception
about its role that recently led to a description of a
branch system's operation as "being like a regressive
tax, taking money from those who can least afford to
lose it and giving it to those who need it least."
Commercial banks primarily serve as an intermediary
between savers and borrowers. The savers seek safety

279

of their principal and, in the case of time deposits, a
return on that principal. The credit made available to
borrowers, both individuals and businesses, provides a
vital lubricant in the functioning of our enterprise
economy. In general, those borrowers who are able to
provide reasonable assurance of their ability to repay
loans will become the preferred risks. Where insufficient funds are available to meet the needs of all prospective borrowers, the interest rate mechanism serves
as one allocative device.
It is clear that profits play a crucial role as a guiding
force in that operation. Borrowers' anticipations of
profitable operations lead them to the banker's window
in the first place. The ability of the banker to make
accurate assessments of the likelihood of profitable
operations by prospective borrowers will, in turn,
largely determine the eventual profits of the bank itself.
Those for whom the term "profit" is a dirty word have
failed, in my view, to study and to comprehend the
dynamics of our economic history. The economic
growth in this Nation over two centuries is firmly and
unquestionably related to the incessant drive for profits
on the part of both business enterprises and individuals.
One hears the term "social responsibility of business" very often today. In my view, it is a useful and
meaningful phrase if defined within appropriate limits.
However, if defined by those who fail to understand
the functioning of an enterprise economy, it may be
used, perhaps unwittingly, as a wedge to undermine
the heart of our economic system.
I believe there are several key elements in the social
responsibility of all who are engaged in the banking
business. First, the banking business, indeed all businesses, must adhere strictly to the letter and the spirit
of our laws. Of course, in a viable democratic society
the same adherence on the part of individuals is a
necessity. Second, an important element of social responsibility is the involvement by bank officers and
employees in the legislative, administrative, and electoral processes. The aim of this involvement should be
to improve the body of law, or to aid in its proper interpretation. Finally, to carry out its own peculiar
social responsibility, the banking business must be operated in a manner consistent with the achievement of
an efficient allocation of resources for the economy as
a whole. Within the context of a competitive market
economy, the appropriate guideline for the bank to
achieve an approximation of that result, is to pursue its
long-run profit goals.
That last requirement, in my view, is the key to a
proper and consistent interpretation of true "social responsibility." Several points need to be made in con-

280



nection with that requirement. Those who would remove the profit test as the basic operating guideline for
businessess leave a dangerous vacuum. Banking, and all
businesses, are simply called upon by those self-appointed guardians of the consumer and the public to
follow those policies which those same paragons, in
their wisdom, have decided are correct. Yet we know
that differences of opinion, and quite divergent orderings of priorities exist within any democratic society.
The safeguard of the objective test of the marketplace
is lost when enterprises succumb to the pressures of
those critics of business. The full consequences of such
a surrender can easily be overlooked.
We can now turn to the positive aspects involved in
our operating rule. Many critics of the profit motive
as an operating principle fail to perceive that narrowly
construed, short-term profit goals are often utterly inconsistent with broadly-based long-term profit goals.
When the "long view" is taken, as it should be, I believe, we find that the interests of business enterprises
and of society are much closer to convergence.
A leading banker made this statement:
At a dinner of a group who know the financial
community well, the question was raised: Can
a commercial bank afford to respond to the
escalating demands for more socially responsible
behavior within our present, profit-oriented market system?
My answer was that, given the current business environment, neither banks nor any other
business enterprises can afford not to respond.
No greater inducement needs to be offered for
directing our attention and our resources as businessmen to the root problems of our society than
that they exist, that they are impediments to
human fulfillment, and that they obviously require correction. I hasten to point out . . . that
there is both self-concern and social concern in
that conclusion, for businessmen must live in, as
well as work in, the community environment—
with all its ills.
It is clear, as we enumerate the principal social concerns of our day, that commercial banks operating in
cities and towns across the country, must be, and are,
involved in the manifold efforts to alleviate these concerns. Billion-dollar banks cannot leave the polluted
atmosphere of large urban centers to resettle in our
wildernesses. The labor force for our banks is, and
must be, drawn principally from urban areas. Bank
customers and bank employees live in housing of all
qualities found within our urban environment. The
financing of the construction of adequate housing, and
the holding of mortgages for individual homeowners,
must be an important segment of the business of commercial banks. The maintenance of our competitive

industrial structure by making funds available to new
business entrepreneurs is also in the best interest of the
banking system, individual banks, and the enterprise
economy. In a phrase, the long-run profit motive allows
commercial banks to identify the interests of their institutions with the broad interests of the community
where the bank is located.
In conclusion, while our society has substantial problems, I believe that there are grounds for optimism.
Strong efforts by men of good will can accomplish
much. I am confident that the banking industry will
continue to meet its crucial responsibilities conscientiously and creatively.
REMARKS OF
DEAN E. MILLER,
DEPUTY COMPTROLLER
OF THE CURRENCY FOR TRUSTS,
BEFORE THE MIDCONTINFNT TRUST CONFERENCE
OF THE AMERICAN BANKERS ASSOCIATION,
CHICAGO, I I I . , NOV. 16,

1972

"More of the Same"
Some of you may be familiar with the text or at
least the tenor of my recent remarks before the Western
Trust Conference. It was reported in the American
Banker and elsewhere. I have received quite a number
of comments on that speech, none unfavorable, but
some which have raised questions indicating that what
I said was not fully understood. And when the head of
one of the country's largest trust departments told me
"It was a good speech—I think I understand what you
were getting at," the need to try again became apparent. Accordingly, I am going to try to restate and
elaborate upon those remarks.
I suppose you might draw as a moral that if you're
going to compliment Miller on his speech, do so in a
way that will guarantee that you won't have to endure
it again.
The initial point upon which I premised my later
conclusions was the increasing responsiveness, in the
last few years, on the part of the judiciary, to what I
termed "activism." I did no more than point it out as
a fact of our existence, purposely avoiding being specific about cases or even areas where it has occurred,
for fear that any such reference might be misconstrued
as implying approval or disapproval. The point I was
making was that, whether you liked it or not as a practice, or whether you liked it or not in individual cases,
it is a recurring phenomenon. People are going to court
in increasing numbers, petitioning for judicial redress




for all kinds of wrongs and purported wrongs, and, occasionally, are winning. Indeed, that is occurring more
and more often; it is happening to banks, among others.
It does not appear to be likely to stop in the near future.
I don't think that changing a few more Supreme Court
justices will alter the situation. Rather, I believe that it
is a movement widely accepted among all shades of
political opinion at the bar. Although attorneys and
judges may think that individual cases have taken
courts into areas they should not have entered, I think
that, at the same time, few of them would reject the
idea of resort to the court for a remedy in a similar case
involving a fact situation which they felt needed justice.
Nearly every member of the bar, even if he won't concede it, has his own special areas of concern in which
he would not be alarmed to see a judicial remedy applied. For example, the attorney who thinks it's wrong
for a judge to redraw a school district boundary may
well think it appropriate for the judiciary to second
guess a bank charter decision. We have occasionally
seen things previously not thought to constitute actionable wrongs or to be matters subject to judicial review,
come to a judicial remedy. We have seen judges issuing
orders that, in previous times, might have been thought
of as executive or legislative in nature. Jails have been
condemned, bridge construction has been held up, and
the suspensions of football players have been rescinded,
to name a few such occasions. Those actions are coming
simultaneously with an increasing recognition of a
truism—that it is extremely difficult, if not sometimes
impossible, to utilize the legislative or administrative
process to make needed changes in the order of things.
Before you shout "radical" or "fascist" at me, let me
point out that the same statement can be made from
either point of view. Last session, a minority in Congress
was able to frustrate several of the President's proposals
which had apparently had the support of the majority
of the people. I'm sure you can think of some "vice
versas" in proposals pushed by the Democratic leadership in Congress.
One example of a judicial remedy becoming popular for the very reason of lack of administrative or
legislative solution, is the class action. Its popularity
is undoubtedly related to the increased judicial responsiveness to activism. In theory at least, it presents
a useful device to effect the correction of a wrong in a
manner benefitting all who have been wronged, thus
giving the judicial decision an effect approximating
that of a statute or an administrative rule. Further, it
accomplishes that end in a forum most bound to rules
of fairness in procedure, and "openness" of the record.

281

Once again, I am making these observations without
attempted implication as to the lightness of that
remedy in any given context, or even as a general
proposition. Rather, I am pointing out the features of
the class action which render it desirable to a broad
spectrum of persons and thus make it unlikely that,
given our present legislative and administrative structure, its use will abate. Indeed, there are even legislative proposals for creating express rights to bring class
actions in some areas.
I could continue to "flesh in" my premise about judicial responsiveness, but only at the ever-increasing
risk of diverting your attention to areas I wish to avoid,
and of being misunderstood as implying approval or
disapproval. I think I have made the point that the
condition is present and likely to continue. Now let me
proceed to a consideration of what that means to you
as trustmen, and to me.
First, it would seem likely that banks will be sued
more often—indeed, won't everyone?—and further,
that they will be sued more often because of activities
in their trust department. That is not to say that I
think such suits are warranted. Most of those I have
seen have not been, and I don't think that conditions
in, or activities of, National bank trust departments
are such as to lead to the conclusion that lawsuits are
likely. Rather, my conviction stems primarily, as I have
said, from the observation that everyone these days,
including banks, are more likely to become the target
of litigation—some of which is based on novel theories.
The possibility of such litigation is very real and should
be anticipated.
This, I suppose, takes me to the real heart of my
message—how I think you should anticipate that possibility. Evidence indicates that, in the more recent
past, you, your management, and your counsel have
not always been too good at anticipating. Viewed with
the omniscience of hindsight, the advantage which
every litigant will have over you, it seems almost incredible now that some common practices, would grow
up and become accepted apparently simply because
everyone did them, without any anticipation that, one
day, some fairly clear principles of securities or antitrust laws might be applied to them. If that is speaking too generally, two examples are the allocation of
brokerage in return for deposits, and the potential
problems resulting from a bank's possession of credit
files regarding companies whose securities were held
by it in trust accounts. In those and similar cases, I
think your counsels were, in part, deceived as to the
weight given the fact that bankers were not in fact

282



acting like predators. No one foresaw the day when
numbers of critics would say, in effect:
You have the potential here to commit great
abuses; therefore, you must be committing them
and hiding the fact behind your traditional veil
of confidentiality, with the assistance of the bank
regulatory authorities.
It was not foreseen that the fact that you are honorable and trustworthy persons, and that is a fact, would
not be apparent to critics, or that a time would arrive
when critics would readily assume, for whatever purpose, that you were scoundrels who could not be trusted
to continue such practices in a responsible manner.
That time has come. With it has come a climate
where practices which can and will be reasoned to
violate sets of rules formulated with other persons, industries and their ethical standards and ways of doing
business in mind, if we are to assume that bankers will
do everything, in a manner contrary to the public interest, not specifically prohibited. The best example
of such rules are many of the securities laws and
regulations.
Of course, the emergence of that attitude has had a
much broader effect than simply the increased applicability of the securities or antitrust laws. It runs
to all possible means for finding banks at fault. I am
reminded of an exchange I had with a man critical of
banks, and particularly, of bank trust departments. I
made a passing reference to a conflict of interest situation in a bank's trust department. The response was
immediate, and delivered in a manner similar, I suppose, to Bobby Fischer saying "checkmate." "So you
admit there is a conflict of interest." I patiently, but
with some irritation, proceeded to explain that, indeed,
there were conflicts between a bank and its trust department, and that that was what trust deparment
supervision has been all about, lo these many years. But,
the point is that that state of mind is prevalent among
bank critics, and must be considered, along with the
fact that, of all bodies of law, that which most concerns you, the law of trusts, which is largely judge-made
law, is most susceptible to change. In the event that a
person brings an action before a modern-day judge,
complaining that a particular bank trust department
has committed a breach of trust, there is little expectation that the judge will say: "But there is no Federal
or State statute forbidding it." The judge can find the
law in the sky above him, or wherever it is that the
legal romanticists say the common law originates from.
If he can relate that discovery to some accepted principles of fiduciary law, in a logical manner, his decision
will probably be upheld.

What kind of a decision should a bank expect in
such a novel case? It will most likely be one reflecting
the realities of the situation, particularly those necessary to effect a just result. One must not forget, as
some counsel apparently have, that in a question of
breach of fiduciary duty, a judge, particularly in today's climate, is not going to be swayed by formalities,
as well he might in a tax case. Rather, he will be looking to the duty owed the beneficiary by the fiduciary.
In determining what that duty is, he will not, I believe,
stop at what the governing instrument creating the
relationship might say about the duties of the trustee
or other fiduciary. Neither will he stop at some of the
State statutes with similar purposes. He will find another consideration to be possibly just as relevant—
what do the fiduciaries call themselves, and how do
they hold themselves out to the beneficiaries? Of paramount importance, however, will be the question,
"What is the purpose of the trust?" All the other considerations devolve from the answer to that question.
All powers given, indeed, every word in the governing
instrument will be read with that in mind.
The problem for you is compounded by the fact
that some have difficulty in ascertaining or remembering the purpose of a given trust. That is an occasional
failing of settlors. Some appear to not be able to master
the legal results that ensue when they take some of their
assets and establish a trust. They continue to view the
assets as being essentially theirs, and subject to their
control. If the trust is an amendable or revocable personal trust, that may not be so important, certainly it
will not be if the settlor revokes and remakes the trust
when he changes his mind. In a personal trust, which
is irrevocable, or in an employee benefit trust, which in
practical effect may be irrevocable, we have a different
situation, however. Here we now have a group of beneficiaries who may have vested rights, in any event, they
have expectations which the settlor has created. In the
case of employee benefit trusts, those expectations may
be more important than whether rights are vested or
not. Such a situation assumes a nature of contract, almost, in that reliance upon them tends to keep employees from leaving.
When a settlor thus creates certain expectations in a
group of beneficiaries, his power to disappoint those
expectations becomes somewhat limited. He may, thereafter, utilize whatever powers he has retained only in
a manner consistent with the purposes for which the
trust is established. If he has named another person to
act as trustee of the trust, that restriction applies to
both him and the trustee, for both are fiduciaries.




In such circumstances, I have quite often seen attorneys confuse the fiduciaries' powers with the purposes
for which the account was established. They have not
comprehended the principle that all powers given in
a governing instrument and all excuses which are given
the fiduciaries are limited by the purpose of the trust.
They may be relied upon only when they serve the purposes of the trust—they are being given improper
weight if they are relied upon to support or exculpate
acts contrary to the legitimate expectations of the
beneficiaries. Unless, and until, that is understood and
made the basis of decisions by fiduciaries, there will
exist a very logical and foreseeable base for a judge's
application of the most basic rules of the law of trusts
to resolve a beneficiary's complaint against a bank.
How, then, should a bank trustee protect itself? It
must recognize that some fundamental changes must
be made in approach and outlook. The business of the
settlor and that of his trusts must be kept completely
separated. I have heard the argument that a fiduciary
should be permitted to invest in small related businesses in its locality, or in its real estate, or in its own
stock, or its directors' concerns—always assuming that
specific authorization exists for such investments—
because, as a businessman^ he is most familiar with
those investments, and forcing him to invest elsewhere
requires that he go into areas with which he is less
familiar. The person who makes that argument is really
saying that the trustee isn't properly qualified. This
is an age in which afiduciary,only competent to invest
trust funds in investments involving a conflict of interest, must be viewed as unqualified for his trust. That
is not just limited to banks, except perhaps, for revocable personal trusts, it is true of all settlors whose trusts
have others as beneficiaries: the rich man who has
created a trust for his children; the doctor whose H.R.
10 plan includes his nurses; the company, be it a
manufacturing concern or a bank, whose management
in one form or other runs its employee benefit plans.
In one way or another, that truth is going to become
recognized law. Some of the ways it could come to pass,
would not be very pleasant for you.
When a bank is involved, the principle is especially
relevant, and its ramifications are extremely widespread. The position of a bank vis-a-vis its employee
benefit trusts for its own employees should be obvious.
There can be no double standard of investment
one
for trusts where the beneficiaries are bank employees,
and one for other accounts. Employees of the bank are
not that dissimilar, legally, to other beneficiaries. The
b,ar to mixing the bank's business with that of its trusts

283

must be just as high. With a bank it doesn't stop there;
a bank is a professional fiduciary, holding itself out to
the public as having special skills in investments, and
having long experience with sound fiduciary principles. Thus, when it shares fiduciary responsibility with
a settlor, as it always does when the bank is named as
trustee and the settlor has some fiduciary responsibilities, it can't stand by and watch its fellow fiduciary
violate that principle. In every case I have seen where
a bank has done so, that fellow fiduciary was a customer on the commercial side of the bank. Make no
mistake about it, a bank's decision not to interfere with
a departure from the principle of not mixing one's
business with that of one's trust, because the other fiduciary involved is a customer of the bank, is, for the
bank, in turn, to mix its banking business with its
fiduciary business. And make no mistake either as to
the seriousness of such a decision.
At this point, you might summarize what I have
said in this way. You should anticipate future developments in the law, both statutory and common, with
regard to trust department practices. In so doing, you
should not give too much weight to precedents that
are more technical than inherently sound, or to the fact
that the practice hasn't been challenged to date
in
other words, to the absence of precedents. You should
be particularly alert to avoid investment practices or
management decisions that do not reflect a complete
divorce of considerations of the commercial side of the
bank from those of the trust side. An area of particular
concern is in trusts where the settlor, be it your own
management or a good customer, does not realize that
the trust it has created is no longer its property. "O.K.,
Miller", you say, "we'll do that. So what else is new?"
I very humbly would suggest that you do a little more.
Not only must you continue to educate your management to the realities of the 70's, and to strengthen your
procedures accordingly, I think that it would not be
inappropriate to do a little more to speed up the laggards among you. That is not, as some of you might
reply, a matter which is solely my job as a trust department supervisor. You have an interest in that area I
would think more vital than mine. A particularly bad
apple that comes to light can lead to repressive countermeasures which could make your continuing in the
trust business very difficult
perhaps impossible. I
realize that it would be difficult, if not impossible, for
you either individually or collectively to set up some
sort of self-policing procedure, but I don't think that
it would be difficult for you to support, or even sponsor
legislation putting limits on the permissible investments

284



of a trust in settlor-oriented media. Don't tell me it's
impossible, I've seen too many direction trust exculpatory statutes enacted by State legislatures at the urging
of bankers, to swallow that. Instead of directing your
lobbying efforts toward accomplishing means of gaining exculpation for participating in a basically undesirable practice, why not push for a uniform prohibition?
And in the case of Federal pension legislation, instead
of attempting to limit or qualify the prohibitions upon
employer-oriented media and delegation of fiduciary
duty, why not attempt to strengthen them? Perhaps
you should weigh more closely whether you lose more
by fighting prohibitions and limitations that affect all
fiduciaries, risking that one of those fiduciaries will go
off the deep end, taking all of you with him, than you
would through promoting the limitations on a meaningful scale, to be applied universally without discrimination as to the type of fiduciary. I personally think that
decision should be made after deeper reflection than
has been the case to date. Please note that that is purely
a personal observation and suggestion. We won't know
what it is really worth for several years. But, if at that
future date, I am in the I-told-you-so position, it won't
be a very happy occasion for you, or me, or the public,
I am afraid.
Now let me turn my attention to one or two little
housekeeping items, so to speak. As you are aware, I
am sure, last year we published for comment some proposed changes in Regulation 9. Those proposals have
been pending for some time while we analyzed the
many comments. Now we have concluded our study of
a part of the proposals and have put them into effect.
Let me describe the changes very briefly.
Most of the changes, indeed reflecting the proposals,
involve incorporation into regulatory language of interpretations of the existing language. The first changes
I will deal with are in that category.
The definitions of 'fiduciary powers" and "trust
department" have been amended to correspond to rulings we have given as to permissible activities of National banks. Under the new language, it is clearer that
no matter where, or by whom, a bank's fiduciary
powers are being exercised, that location or person is
considered to be the trust department of the bank for
the purposes of Regulation 9.
Section 9.7 has been amended to make clear that
it does not provide an authority for a bank to utilize
personnel of other departments to perform fiduciary
functions, and vice versa, where law prohibits such
usage.
Section 9.12 has been amended to recognize that a
bank may buy an asset from a trust account where re-

quested to do so by the Comptroller. Among other
things, this should end the response we have received
from some legal purists when we have criticized a transaction and requested that the bank purchase an asset
at no loss to the account: "But that would violate
Regulation 9."
Section 9.13 has been amended to permit the use of
a central certificate service.
Changes have been made in the requirements of the
contents of a collective investment fund plan to require
a general statement of the investment policy of the
bank with respect to the fund, and to require that
valuations, in usual circumstances, should be made
within 10 business days.
9.18(b) (2) has been rewritten to reflect more clearly
the requirements of the alternative means of obtaining
tax exemption for collective investment funds for taxexempt trusts.
9.18(c)(2) has been amended to incorporate the
joint investment rule, presently found in the "Opinions" section of the Manual, into the Regulation. Note
that that amendment deals with permanent investment
and does not concern our variable amount note ruling,
which is a temporary investment device.
9.18(c) (3) and 9.18(c) (4) have been rewritten to
make more clear the qualifications to use of those paragraphs by banks.




In addition, a requirement has been incorporated
that annual reports be filed with the Comptroller
within 90 days of the end of the fund's fiscal year.
Some of the changes made to 9.2 (a) and (c) and
9.11 (d), reflect changes in form numbers or titles.
Section 9.18(a) (3) has been deleted and the definition of "managing agent" revised to reflect that authority no longer exists for that type of fund. I repeat
that in so doing we are not conceding that it is required
by the holding in Investment Company Institute v.
Camp.
Now, for a substantive change, the provisions of
Section 9.18 (b) (5) relating to promoting and advertising a collective investment fund have been
amended to provide a distinction between traditional
common trust funds and pooled employee benefit
trusts. Stricter standards are imposed upon the former.
Not adopted, but still under consideration, are the
remainder of the proposals, including those concerning best execution of security purchases and sales, the
application of the common trust fund 10 percent limitations where exceeded because of withdrawals or
market appreciation, and requiring that requests for
admissions and withdrawals be accepted up to the
valuation date.
We appreciate your assistance in our endeavors and
hope that between us we can continue to improve the
quality of trust services available to the public.

2S5

INDEX
Administration of the Comptroller's Office, 25-27
Administrative enforcement authority, 15
Administrative Services Division, 26-27
Appraisal of National bank shares, 19
Assets of the Comptroller's Office, 30
Assets of National banks:
of acquiring and acquired banks, 1960-1972, 216
by deposit size, 1971 and 1972, 228
of foreign branches, 1953-1972, 260
of foreign branches, Dec. 31, 1972, 260
at last report of condition, 1950-1972, 258
in 1971 and 1972,2
by States, June 30, 1972,231
by States, Dec. 31, 1972, 234
of trust accounts, 261
Balances per credit plan, 238
Bank chartering. (See Charters and chartering)
Bank examination:
of international activities, 23
legal requirement for, 13
purpose of, 13
summary of 1972 activities in, 13
training programs for, 13, 23, 26
of trust departments, 21, 26, 266
Bank holding companies, 268
Bank mergers. (See Mergers)
Bank Organization Division, 26
Bank regulation, 279
Banking:
r
and competition, 278-89
and direct lease financing, 239
dimensions of, 277—78
litigation on, 15-19
taxation of, 270-71, 279
Banking offices, by States, Dec. 31, 1972, 6
Bloom, Robert, remarks of, 270-71, 275-77
Branches of National banks:
in calendar 1972, 10
closed in 1972,226-27
denovo,5, 10-12
foreign, 23, 259, 260
litigation on, 17-18
opened in 1972, 12,216
by States, Dec. 31, 1972,6
Brokerage, allocation of, 265-66, 282
Capital accounts of National banks:
by deposit size, 1971 and 1972, 228
from 1944 to 1972, 256
in 1971 and 1972,2
by States, June 30, 1972, 233
by States, Dec. 31, 1972,236




Capital stock of National banks, 193
Cases in litigation, 15-19, 174-76
Central certificate service, 21, 269, 285
Changes in structure of the National Banking System:
in 1972, 5-12
by States, 1863-1972, 192
Charters and chartering:
applications pursuant to corporate reorganizations, 8, 196
applications by States, 7, 194—95
and conversion by State banks, 9, 205
issued in 1972, by States, 7, 198-99
issued pursuant to corporate reorganization, 8, 200—04,
206
litigation on, 16-17
Class action, 281-82
Clearing agencies and depositories, 276—77
Closing of branches in 1972, 226-27
Collective investment funds, 21-22, 285
Common trust funds:
promotion and disclosure on, 268-69
10 percent limitation on, 22, 269, 285
Comptroller of the Currency:
administration of, 25-27
changes in financial position of, 32
Comptrollers, listed, 189
Deputy Comptrollers, listed, 190
Deputy Comptrollers' addresses, 265-70, 271-75, 277-85
financial operations of, 29-33
litigation by, 15-19
Comptroller's equity, 30-31
Condition of the National Banking System, 1-2
Condition report dates, 1914-1972, 229-30
Congressional testimony of Chief Counsel, 270—71, 275—77
Consolidations:
of National banks, 212
of National with State banks., 209
(See also Mergers)
T
Conversions:
of National into State, 210-11
of State into National, 205
Corporate reorganization:
charter applications pursuant to, 8, 196
charters issued pursuant to, 8, 206
mergers pursuant to, 38-40, 121-73, 200-04
Credit balances, 238
Data processing services of banks, 15
Dates of reports of condition, 1914-1972, 229-30
Decisional law, increase in, 272-73
De novo branches, 5, 10-12, 216-25
Deputy Comptrollers of the Currency:
addresses of, 265-70, 271-75, 277-85
listed, 190

287

Direct lease financing of National banks, 239
Dividends of National banks, 4, 256
Edge corporations, 23
Equity, Comptroller's, 30-31
Examination of banks. (See Bank examination)
Expenses of Comptroller's Office, 31
Expenses of National banks:
by deposit size, 254-55
in 1971 and 1972,3-4
by States, 240-53
Fiduciary activities. (See Trust departments)
Financial operations of the Comptroller's Office, 29-33
Fiscal Management Division, 25
Foreign branches:
assets of, 1953-1972,260
assets and liabilities of, Dec. 31, 1972, 260
and international finance, 23
number of, 260
by region and country, 259
Growth of judge-made law, 272-73, 274, 282
Growth of bank activities, 277-78
Holding Company Act Amendments, 277-78
Hunt Commission recommendations, 265—68, 275, 278—89
Incidental powers, 15-16
Income of National banks:
by deposit size, 254-55
from 1944 to 1972,256
in 1971 and 1972, 3-4
by States, 240-53
of trust accounts, 261
Insider information, 266, 275
Interest permissible to National banks, 16
Internal Audit Division, 27
International banking, 23
International Division, 23
Investment securities, 1-2
Judicial responsiveness to activism, 272—73, 281—82
"Laundry list" of banking activities, 278
Liabilities of the Comptroller's Office, 30
Liabilities of National banks:
bys deposit size, 1971 and 1972, 228
of foreign branches, 260
at last report of condition, 1950-1972, 258
in 1971 and 1972,2
by States, June 30, 1972,232
by States, Dec. 31, 1972, 235
Liquidations of National banks, 208
Listing of National banks, by States, 6
Litigation on:
administrative enforcement authority, 15
authority to appraise National bank shares, 19
branches, 17-18
data processing services, 15
incidental powers, 15—16
interest permissible to National banks, 16
main office relocations, 17
mergers, 19,40, 174-85
new banks, 16—17
travel services, 15-16
Loans of National banks:
from 1945 to 1972, 257
by States, 237

288



Losses of National banks, 1945 to 1972, 257
Main office relocations, 17
Management Services Division, 27
Managing agent, defined, 285
Mergers:
approval opinions, 41—185
approvals, listed, 36-40
involving two or more operating banks, 36-38, 41-121
litigation on, 19, 40, 174-85
of National with State banks, 209
in 1972, 12,36-40,41-173
pursuant to corporate reorganizations, 38-40, 121-73,
200-04
resulting in National banks, by assets, 1960-1972, 216
by States, 212-15
Miller, Dean E., remarks of, 265-70, 271-75, 281-85
Motter, David C , remarks of, 277-81
National banks involved in direct lease financing, 239
New activities for banks, 277-78
Newly organized National banks:
chartered, 5
litigation on, 15-19
by States, 198-99
1970 amendments to Bank Holding Company Act, 277—73
Number of National banks in each State, 6
Office of the Comptroller of the Currency. (See Comptroller
of the Currency)
Opinion of independent accountant, 33
Permissible interest for National banks, 16
Personnel management, 25-26
President's Commission on Financial Structure and Regulation, 265-68, 278-79
Product-service mix of banks, 278
Prudent-man investment rule, 266-67, 268
Purchases of State banks by National banks, 211
Records Management Branch, 26-27
Recoveries of National banks, 1945-1972, 257
Regional Administrators of National banks, listed, 191
Regulation 9:
amendments to, 21-22, 274-75, 284-85
proposed revisions of, 22, 265-66, 268-69
provisions of, 267, 284-85
and prudent-man rule, 266-67
terms redefined, 21, 269, 284, 285
Regulation Y, 278
Rejected applicants, litigation by, 16
Relocation of main offices, 17
Reports of condition, 229-30
Reserves of National banks, 2
Responsiveness of the judiciary, 272-73
Revenue of Comptroller's Office, 31
Securities of National banks:
losses and recoveries on, 1945-1972, 257
in 1971 and 1972, 2
Securities transfers, 275-77
Social responsibility of business, 279-81
State banks:
consolidations of National banks with, 209, 212
conversion of National banks into, 210—11
conversion to National banks, 9, 205
mergers with National banks, 212-15
purchased by National banks, 211

State taxation of National banks, 270-71
Structural changes in the National Banking System, 5-12
Summary suspension authority, 15
Supply, Printing, and Services Branch, 27
Supreme Court rulings, 16-17
Ten percent limitation on common trust funds, 269
Travel services, 15-16
Trust departments:
activities summarized, 21-22
assets and income of, by State, 261
and change, 273-74




Trust departments—Continued
definition of, 21, 269, 284
and Regulation 9, 21—22, 265—66
responsibilities of, 273-74, 283
and securities law, 266, 274-75
separation from commercial side of bank, 266-67, 282,
283-85, 285
and uninvested cash, 266
Trust law, 283
Uniform reserve requirements, 279
Working capital of the Comptroller's Office, 32

289


Federal Reserve Bank of St. Louis, One Federal Reserve Bank Plaza, St. Louis, MO 63102