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W7/U IR
Comptroller of the Currency
Administrator of National Banks







Annual Report 1978
Comptroller of the Currency

The Administrator of National Banks

John G. Heimann
Comptroller of the Currency




Letter of Transmittal
Treasury Department,
Office of the Comptroller of the Currency,
Washington, D.C., November 30, 1979

Sirs: Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1978 Annual Report of the
Comptroller of the Currency.
Respectfully,
John G. Heimann,
Comptroller of the Currency.
The President of the Senate
The Speaker of the House of Representatives

Contents
Title of Section
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.

Condition of the National Banking System
Income and Expenses of National Banks
Structural Changes in the National Banking System
Bank Examinations and Related Activities
Law Department
Fiduciary Activities of National Banks
International Banking and Finance
Administration
Customer and Community Programs
Financial Operations of the Office of the Comptroller of the Currency

Page
1
5
9
19
21
37
39
43
47
51

Appendices
A. Merger Decisions, 1978
B. Statistical Tables




57
125

Statistical Tables
Table No.

Title

Page

1 Assets, liabilities and capital accounts of national banks, 1977 and 1978
2 Income and expenses of national banks, 1977 and 1978
3 National banks and banking offices, by states, December 31,1978
4 Applications for national bank charters and charters issued, by states, calendar 1978
5 Applications for national bank charters pursuant to corporate reorganizations and charters issued, by
states, calendar 1978
6 Applications for conversion to national bank charter and charters issued, by states, calendar 1978
7 Branches of national banks, by states, calendar 1978
8 CBCT branches of national banks, by states, calendar 1978
9 De novo branch applications of national banks, by states, calendar 1978
10 De novo branches of national banks opened for business, by community size and by size of bank,
calendar 1978
11 Mergers, calendar 1978
12 Examinations of overseas branches, subsidiaries and EDP centers of national banks, 1972-1978
13 Outstanding external currency claims of U.S. banks on foreign borrowers, December 31,1978
14 Officer of the Comptroller of the Currency: balance sheets
15 Office of the Comptroller of the Currency: statements of revenue, expenses and Comptroller's equity....
16 Office of the Comptroller of the Currency: statement of changes in financial position

VI




3
7
10
11
12
13
14
15
16
17
17
41
41
52
53
54

I. Condition of the National Banking System
National bank assets continued to grow rapidly during 1978, increasing 12 percent, to more than $892
billion. Foreign office assets, including those held by
Edge Act subsidiaries, continued to grow at an even
more rapid rate, increasing 17 percent during the year
to $170 billion. That reflects continuing inflation and the
growth of the economy as a whole through most of the
year, although at a slower pace than in 1977. Assets
increased at a rate somewhat lower than 1977's 13.1
percent, the fastest growth since 1973, when assets
jumped 16.4 percent. The intervening year-end increases were 10.6 percent for 1974, 3.8 percent for
1975, and 9.3 percent, on an adjusted basis, for 1976.
National banks' foreign assets have consistently grown
more rapidly than their domestic assets and, as a result,
now account for 19 percent of total assets, compared to
14 percent 5 years ago.
Rapid growth in total assets resulted from continuing
strong loan demand, which had been slow in recovering from the severe recession which ended in early
1975. That is shown by the 14.2 percent increase in
loans net of reserves, to $490 billion, and in the continued high level of interest rates during the year.
Although that $61 billion increase in net loans
accounted for more than 60 percent of the year's
growth in total assets, the asset category showing the
greatest percentage increase .was lease financing,
which jumped 25.2 percent.
During and immediately following the last recession,
when loan demand remained weak, national banks
rapidly increasedtheirholdingsof securities, particularly
U.S. Treasury issues, in an effort to maintain their earnings and improve their liquidity. In 1977, that trend was
reversed, with total holdings of securities increasing
only 2.7 percent, compared to 8.8 percent in 1975. In
1978, holdings of securities increased only 2.8 percent.
That relatively slow growth has caused securities to
decline to 16 percent of total assets, from 20 percent in
1976. The change has been more marked in investment
holdings of U.S. Treasury issues. Such holdings actually declined 9.5 percent in 1978, following a 4.9 percent
drop in 1977. In 1976, they had increased 17.7 percent,
which followed a 62.6 percent increase, in 1975.
The continuing rapid growth in national bank assets
was made possible, largely, by a continuing increase,
9.6 percent, in total deposits, which reached $717 billion. Domestic office deposits increased at a lower rate,
7.9 percent, to $561 billion. That increase is actually




understated by nearly $8 billion because of the initiation
of interest-bearing demand notes issued to the U.S.
Treasury which now account for virtually all of what
were previously U.S. government demand deposits. In
part, because of that change, demand deposits in
domestic offices increased only 4.3 percent, compared
to a rapid increase of 12.5 percent last year. However,
1977 was the only year since 1969 that domestic demand deposits grew at a faster rate than domestic time
and savings deposits. In 1978, the proportion of time
and savings deposits to total domestic office deposits
reached a new peak of 60.7 percent. Foreign office
deposits and other purchased funds continued to grow
more rapidly than the banks' traditional domestic deposit base. That is expected during a period of high
interest rates because of the limitations on interest
which can be paid to attract other than very large deposits and because of the desire to avoid the additional
cost of holding non-interest bearing reserves.
The largest increase in what are generally considered purchased funds was the $21.7 billion increase
in deposits at foreign offices. However, a relatively
small source of those funds, borrowed money, jumped
44.9 percent to $12.9 billion, which followed a 51.3
percent increase last year. Although federal funds
purchased and securities sold under agreements to
repurchase increased 9.1 percent, it was significantly
below the rate of increase for total liabilities and below
the previous years' rates of 15.0 percent, in 1977, and
34.7 percent, in 1976.
Total equity capital of national banks increased at a
slower rate than total assets in 1978 as in 1977. Despite
a $4.2 billion increase, most of which resulted from
retained earnings, the ratio of equity capital to total
assets declined slightly, to 5.5 percent, from 1977's
level of 5.6 percent. As the average size of national
banks has increased substantially over the years, that
ratio has tended to decline. However, due to the slow
growth of assets following the last recession it did increase in 1975 and 1976 to the recent peak of 5.9
percent. Similarly, the ratio of equity capital to risk
assets, that is total assets less cash and investment
holdings of U.S. Treasury and U.S. government agency
issues, was 7.5 percent, down from 7.8 percent the
previous year. Subordinated debt, which is considered
a close substitute for equity capital for some regulatory
purposes, continued to increase moderately to $3.1
billion, an increase of 9.1 percent compared to 11.2

percent the previous year. The allowance for possible
loan losses, however, increased 17.5 percent to $4.6
billion. Those reserves, which may be used to absorb
loan losses, were equal to 1.0 percent of total loans.
At the end of 1978, the 104 national banks which
operated foreign branches and subsidiaries, including




Edge Act subsidiaries in the U.S., accounted for more
than 60 percent of all national bank assets. More detail
on their holdings of assets and liabilities is provided in
Table B-27, in the Appendix. Also, domestic office
assets and liabilities are detailed by state in Appendix
Tables B-18 and B-19.

Table 1
Assets, liabilities and capital accounts of national banks, 1977 and 1978
(Dollar amounts in millions)
Dec. 31, 1977
4,655 banks
Consolidated
foreign and
Domestic
domestic
offices

Dec. 31,1978
4,564 banks
Consolidated
foreign and
Domestic
offices
domestic

Change, 1977-1978
Fully consolidated

Amount

Percent

Assets

Cash and due from depository institutions*
U.S. Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities

$150,508
50,051
17,832
62,914
12,422

146,155

32,124

31,147

344,522
3,896

494,896
4,754

340,626

5,259
11,387
1,918
23,090

4,406
10,798
1,821
31,307

796,851
164,450
265,978
4,821
41,964
35,648
6,798

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises .
All other assets
Total assets

138,289

32,152
433,364
4,046
429,318

Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans

$170,146
45,311
21,312
66,758
12,774

143,219

Total securities

$ 92,072
49,922
17,822
62,792
7,753

13.0

$102,603
45,285
21,308
66,564
7,345
140,502

$19,638
-4,740
3,480
3,844
352
2,936

-9.5
19.5
6.1
2.8
2.1

490,142

30,996
394,671
4,566
390,105

-1,005
61,532
708
60,824

-3.1
14.2
17.5
14.2

6,582
12,652
1,573
33,874

5,561
11,930
1,456
39,132

1,323
1,265
-345
10,784

25.2
11.1
-18.0
46.7

651,444

892,272

722,285

95,421

12.0

164,473
200,071
4,821
41,964
36,201
6,714
520,244

175,356
294,707
2,078
45,689
35,909
7,229

175,356
294,707
2,078
45,689
35,909
7,229

10,706
28,708
-2,743
3,725
201
431

560,968
220,593
340,375
0
560,968

41,309
9,164
30,146
21,692
63,000

6.6
10.8
-56.9
8.9
0.7
6.3
7.9
4.3
10.4

Liabilities

Demand deposits of individuals, partnerships and corporations
Time and savings deposits of individuals, partnerships and corporations
Deposits of U.S. government t
Deposits of states and political subdivisions
All other deposits
Certified and officers' checks
Total deposits in domestic offices
Demand deposits
Time and savings deposits
Total deposits in foreign offices
Total deposits

519,659
211,429
308,229
134,398
654,057
59,560
NA
8,878
482
25,841

64,989
7,764
12,860
1,275
35,808
839,753

64,908
7,764
5,499
1,232
29,642
670,013

9.1
NA
44.9
164.5
38.6

90,936

12.1

3,035

Subordinated notes and debentures

59,336
NA
3,882
474
19,474
603,410

5,429
7,764
3,982
793
9,967

748,817

Federal funds purchased and securities sold under agreements to repurchase
Interest-bearing demand notes issued to U.S. Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases...
All other liabilities
Total liabilities

0
520,244

560,968
220,593
340,375
156,090
717,057

3,035

3,312

3,065

277

9.1

25
9,552
16,650
18,772
44,999

25
9,552
16,650
18,772
44,999

29
9,912
17,291
21,976
49,207

29
9,912
17,291
21,976
49,207

4
360
641
3,204
4,208

16.0
38
3.8
17.1
9.4

796,851

651,444

892,272

722,285

95,421

12.0

211,650
308,594

16.1
9.5

Equity Capital
Preferred stock
Common stock
. . . .
Surplus
.
Undivided profits a n d reserve for contingencies and other capital reserves

Total equity capital
Total liabilities, subordinated notes and debentures and equity capital

......

* In 1978, this category was expanded to include all depository institutions rather than just banks.
t Most demand deposits of the U.S. government were converted to "interest-bearing" demand notes issued to U.S. Treasury in late 1978.
NOTE: NA indicates information is not applicable.




II. Income and Expenses of National Banks
Total income and expenses of national banks increased greatly during 1978, reflecting both the continuing increase in bank assets and the rapid rise in
interest rates. Continuing steady economic expansion is
reflected in the rapid increase in national banks' net
income by more than $1 billion, or 20 percent. That was
the highest rate of increase of net income in the decade,
and follows last year's substantial rise of 11.9 percent. It
resulted from banks' ability to limit the reduction in their
interest rate margins despite the increasing need to rely
on purchased funds and the development of higher
priced consumer deposits such as the 26-week money
market rate certificate.
During 1978, total operating income jumped 26.1 percent to $67.8 billion. That rate was more than double the
12 percent increase in assets over the year, reflecting
the ability of banks to adjust their loan rates during a
period of rapidly rising interest rates. That is possible
because most bank loans are short term and because an
increasing proportion are being made on a floating rate
basis. The prime rate, the basic commercial lending
rate, increased from 7.75 to 11.75 percent during 1978.
Total operating expenses increased somewhat more
slowly than income, growing 25.6 percent to $59 billion.
That produced a $2 billion increase in income before
taxes and securities gains. The 29.8 percent increase in
net operating earnings was trimmed by a sharp increase
in applicable income taxes of 46.6 percent, to $2.6 billion. Also, national banks suffered a net loss, after taxes,
of $128 million on sales of securities for the year, a
reversal of last year's modest gain of $36 million. That
loss was partially offset by net extraordinary gains of $26
million, which left net income for the year at $6.2 billion.
The rate of return on assets was 0.69 percent, up significantly from 1977's 0.64 percent.
Interest income, including income from lease financing and corporate stock, increased 26.7 percent over
1977 to reach $61.9 billion; it accounted for more than 91
percent of total operating income. The largest component of that, interest and fees on loans, totalled $46
billion in 1978, an increase of nearly 30 percent over
1977. Thus, in addition to loans increasing 13 percent,
national banks were able to increase the average return
on their loan portfolio by more than 1 full percentage
point during the year. However, interest on balances with
depository institutions and income from federal funds
transactions jumped even more disproportionately, 36




and 43 percent respectively, reflecting their greater responsiveness to changes in interest rates.
Security holdings, which increased slowly during the
year, accounted for less than 13 percent of total operating income. That continued the trend of decreasing reliance on income from securities which was interrupted
briefly in 1975, as a result of the recession. Although
holdings of U.S. Treasury and government agency
securities actually declined during 1978, as they had in
1977, income on those investments rose a modest 4.2
percent as a result of the rising interest rates on government issues. Revenues from obligations of states and
political subdivisions totalled $3.25 billion, showing an
increase of 11 percent over 1977. Non-interest income,
resulting mainly from fees for services, increased just
over 20 percent to $5.9 billion.
On the expense side, the rapidly rising interest rates
during 1978 had a marked effect on deposit costs. Total
interest expense on deposits was $30 billion, an increase of 30 percent over 1977. That increase would
have been even more dramatic except for the fact that
most bank deposits are still subject to interest rate controls. The expense of deposits which are acquired at a
competitive market rate, large time certificates of deposit and deposits in foreign offices, jumped 74 percent
and 42 percent respectively, nearly three times the
actual increase in those deposits. Deposits at foreign
offices, essentially all of which pay interest at market
rates, accounted for one-third of the total interest expense for deposits, although they equal less than 22
percent of total deposits.
Other interest expenses, with the exception of those
for long term subordinated debt, increased more rapidly than those for deposits. The cost of federal funds
purchased and securities sold under agreements to
repurchase grew $1.9 billion, or 60 percent, during
1978. Also, the $1 billion paid on borrowed money was
nearly 70 percent higher than in 1977. However, that
item now includes the expense of demand notes issued
to the U.S. Treasury which were introduced late in the
year. The full effect of that change will not be shown
until 1979. Total interest expense was $36.3 billion, a 34
percent increase over 1977, which is equal to 62 percent of total operating expenses.
Salaries and employee benefits increased by 14.3
percent, slightly greater than the rate of increase for total
assets. However, the proportion of total expenses that

item represents declined to 18 percent from 20 percent
last year. The most substantial improvement in expenses
results from the continuing decline in net loan losses
which dropped to $1.4 billion in 1978, substantially below the post-recession peak of more than $2 billion in
1975. Therefore, national banks were able to substantially increase their loan loss reserves while only increasing
their expense provision by $146 million.
During 1978, national banks not only enjoyed substantial growth in net income, but continued the trend toward
retaining a larger portion of those earnings. Cash div-




idends totalling $2.2 billion were declared in 1978, only
a 10 percent increase over 1977. Those dividends
equalled less than 36 percent of earnings. The comparable pay-out ratio was 39 percent last year, and nearly 43
percent in 1975. As retained earnings are the primary
source of equity capital in banking, high levels of retained earnings and net income are necessary to prevent the decline of current capital ratios. Because of the
rapid increase in net income and the slight increase in
leveraging, net income to equity capital rose to 12.5
percent from 11.4 percent last year.




Table 2
Income and expenses of national banks, 1977 and 1978
(Dollar amounts in millions)
1977
4,655 banks
Percent
distribution

Amount
Operating income.
Interest and fees on loans
Interest on balances with depository institutions*
Income on Federal funds sold and securities purchased under agreements to

1978
4,564 banks

Change, 1977-1978

Percent
distribution

Amount

Amount

Percent

$45,997.7
4,407.3

67.8
6.5

$10,551.4
1,164.3

29.7
35.9

2.8

2,197.8

3.2

665.7

43.5

4,532.0
2,929.6
640.1
537.6
1,131.3
986.9
1,566.6
1,243.3

8.4
5.4
1.2
1.0
2.1
1.8
2.9
2.3

4,721.6
3,252.1
693.2
639.4
1,214.8
1,089.5
1,932.2
1,696.9

7.0
4.8
1.0
0.9
1.8
1.6
2.8
2.5

159.6
322.5
53.1
101.8
83.5
102.6
365.6
453.6

4.2
11.0
8.3
18.9
7.4
10.4
23.3
36.5

53,788.9

Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more (issued by domestic offices) .
Interest on deposits in foreign offices
Interest on other deposits
Expense of federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other borrowed
money f
Interest on-subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense .
Provision for possible loan loss
Other operating expenses

65.9
6.0

1,532.1

I OOv'l

Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of states and political subdivisions in the U.S..
Income from all other securities (including dividends on stock). .
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income

$35,446.3
3,243.0

100.0

67,842.4

100.0

14,053.5

26.1

9,486.9
4,031.5
7,123.0
11,956.9

20.2
8.6
15.2
25.5

10,845.2
7,021.9
10,139.7
12,873.9

18.4
11.9
17.2
21.8

1,358.3
2,990.4
3,016.7
917.0

14.3
74.2
42.4
7.7

3,116.1

6.6

4,989.6

8.5

1,873.5

60.1

604.0
202.7
2,851.1
1,985.1
5,598.3

1.3
0.4
6.1
4.2
11.9
100.0

1,023.1
234.3
3,194.3
2,131.2
6,522.5

1.7
0.4
5.4
3.6
11.1

419.1
31.6
343.2
146.1
924.2

69.4
15.6
12.0
7.4
16.5

58,975.8

100.0

12,020.2

25.6

6,833.3
1,767.1
5,066.3

8,866.6
2,591.0
6,275.6

2,033.3
323.9
1,209.3

29.8
46.6
23.9

52.5
16.0

-253.5
-125.2

-306.2
-141.2

-583.2
-832.5

46,955.6

Total operating expenses
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes

36.5

-128.3

-164.8

-451.5

5,102.7
36.0

6,147.3
26.1

1,044.6
-9.9

20.5
-27.5

Net income

5,138.7

6,173.4

1,034.7

20.1

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared

1,993.2
1.1
1,994.3

2,194.7
1.4
2,196.1

201.5
0.3
201.8

10.1
27.3
10.1

Recoveries credited to allowance for possible loan losses
Losses charged to allowance for possible loan losses
Net loan losses

503.9
2,179.8
1,670.9

685.9
2,124.6
1,438.7

177.0
-55.2
-232.2

34.8
-2.5
-13.9

Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net

.

Percent

Percent

Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses

43.0
7.3
17.6
19.4
87.3

44.3
9.2
16.0
17.5
86.9

Ratio of net income to:
Total assets (end of period)
Total equity capital (end of period)

0.64
11.4

0.69
12.5

Ratio to total operating income.

* In 1978, this category was expanded to include all depository institutions, rather than just banks.
t Most demand deposits of the U.S. government were converted to "interest-bearing" demand notes issued to the U.S. Treasury in late 1978.

. Structural Changes in the National Banking
System
At year-end 1978, there were 4,564 national banks,
2,313 of which were unit banks. The remaining 2,251
national banks operated a total of 17,439 branches. In
addition to those 22,003 traditional banking offices, national banks operated 765 CBCT branches (electronic
banking facilities).
The total number of national banks declined for the
third consecutive year. At year-end 1978, there were 91
fewer national banks than a year earlier, although the
number of national bank offices had increased by 286.
All national banks must be members of the Federal
Reserve System, and a principal reason for the reduction in number of national banks continues to be the
costs associated with that membership. During 1978,
68 national banks converted to state charters and 25
national banks merged or consolidated with state
banks. Only 39 new national banks were chartered and
only three state chartered banks converted into national
banks during the year. When state branching laws are
liberalized, as they were in Florida during 1977, there is
a tendency for banks to merge to create branch systems. That tendency has contributed to the reduction in
number of national banks; for example, in Florida alone,
in 1978, mergers where the resulting bank was a national bank accounted for a reduction of eight banks.




During 1978, the Comptroller granted preliminary
approval to organize 42 new national banks. As in recent years, the largest number of applications
approved was for locations in Texas, a state that does
not allow branching, but does permit multibank holding
companies. Thirteen new bank applications were
approved for Texas; no more than four were approved
for any other state.
National banks continued to expand by branching
during 1978. The Comptroller's Office received 792
branch applications during the year, compared to 741
in 1977. National banks opened 630 de novo branches
in 1978 and 93 branches were added to the system
through conversion or consolidation. In 1978, banks
with total resources of less than $100 million opened 48
percent of the new branches, compared to 55 percent
in 1977. Banks with total resources of more than $1
billion opened 23 percent of the new branches, compared to 18 percent in 1977. The number of CBCT
branches increased by 238 during the year.
The Comptroller's Office approved 47 merger applications involving two or more operating banks in 1978
compared to 64 applications in 1977. Forty-four mergers were consummated during the year compared to 70
in 1977.

Table 3
National banks and banking offices, by states, December 31, 1978
Number

National Banks
Total
All national banks.
50 states
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida

Unit

4,564
4.564

2,313
2,313
34
1
1
15
9

99
6
3
69
53
137
19
5
16
236

106
3
1
4

100

64
2
6
419
121
99
151
79
54
17

14
0
0
270
28
49

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

34
73
125
205
37
101
56
117
4

5
8
13

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

96
40

Georgia ..
Hawaii
Idaho
Illinois
Indiana...

Iowa
Kansas...
Kentucky .
Louisiana.
Maine

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

39

100

16
12
1

153
3
54
48

79
1
7

With
branchesf

2,251
2,251
65
5
2
54
44
31
16
4
12
136

Number

of
branchesf

of
off ices f

17,439

22,003

17,433

21,997

340
79
319
175
2,761
31
201
5

439
85
322
244

2,814
168
220
10

135
302

151
538

50
2
6
149
93
50
51
63
42
16

332
11
178
182
507

117

396
13
184
601
628
190
226
333
331
134

29
65
112
52
34
47
8
38
3
32

356
447
868
67
256
67
8
56
85
98

390
520
993
272
293
168
64
173
89
137

86
30
93
22
24

973
118
1,489
809
29
1,096
60
321
1,408
115

1,069
158
1,613
836
72
1,313
251
327
1,634
120

322
85
364
13
113
46
683
594
26
89
0

340
117
436
622
123
59
771
614
132
218
46

91
75
254
277

124
27
43
217
191
6
226
5

10
10
31
5
19
43
132
1
74
0

18
32
72

4
18
8

609

106
129
46

597
6
4
4
2
80
84
46

14
14
64
12
4
9
84
18
26
45
0

0
0

0
0

0
0

0
6

0
6

13

136

153

10
13
88
20

17

174
59
5
152
5

* Includes national and non-national banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.
tFor the purposes of this table, CBCT's are not considered branches or offices. For information on those branches, see Table 8 of this report.

10




Table 4
Applications for national bank charters* and charters issued, by states, calendar 1978

Receivedf

Approved

118
6
0
0
2
10
6
0
0
0
5

42

Georgia ..
Hawaii....
Idaho
Illinois
Indiana...
Iowa
Kansas...
Kentucky .
Louisiana.
Maine

2
0
0
1
1
1
1
2
4
0

0
0
0
0
1
0
0
1

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

0
1
6
0
0
1
0
1

0

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

0
0

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

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

3
0
0
0
3
2
0
0
0
2

0
0

Disapproved

Withdrawn

Pending
December 31,
1978

14
3
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
2
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
2
0
0
1
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0

0
0
0
31
0
0
0
0
1

0

0
0
0
0
0
0
0
0
0
0
0

0
0

0
0

0
0

61
0
0
0

1
6
4
0
0
0
3

1
0

1
1
1
2
0

Chartered

39
2
0
0
0
0
4
0
0
1
4
0
0
0
1
1
0
0
0
1
0

Virgin Islands.
Puerto Rico ..

0
0

1
3
0
0
0
0
0
0
0

0
0

1
0
0
0
0

1
0
0

0
0
6
0
0
0

0
0
0
0
0
0
2
0
0
0

0
0
0
0
0
0

0

0

1
0
46
4
0
0
2
2
4
1

1
0
13
4
0
0
1
1
3
1

0
0
0
2
0
0
0

0
0

0
0

1
1

1
0
0
0

1
0

1

1
1
0
0
3
0
0
0

0
0

0

1
4
1
1
1
0
0
0
0
0

1
0
0
0
0

1
0
0
0

0
0
0
13
0
0
0
0
1
1
0
0
0

*Excludes conversions and corporate reorganizations,
tIncludes applications pending as of December 31, 1977.




11

Table 5
Applications for national bank charters pursuant to corporate reorganizations and charters issued,
by states, calendar 1978

Received*
Total .

Approved

Disapproved

Withdrawn

Pending
December 31,
1978

Chartered

38

28

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

2
0
0
0
1
0
0
0
0
0

1
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

Georgia ..
Hawaii....
Idaho
Illinois
Indiana...

6
0
0
3
1
1
0
0
0
0

6
0
0
2
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
1
0
0
0
0
0

6
0
0
2
0
0
0
0
0
0

0

0
1
2
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
0
0
0
0
0
0
0
0

0
1
2
0
0
0
0
0
0
0

Iowa
Kansas...
Kentucky .
Louisiana.
Maine
Maryland
Massachusetts.
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

1
3
0
0
0
0
0
0
0

1

25

1
0
0
0

1
0
0
0
0
0

1

1
0
0
0
0
0
0
0
0
0

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

0
0
0
0
4
0
0
0
0

0
0
0
0
0
2
0
0
0
0

0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
0
0
0
0

0
0
0
0
0
2
0
0
0
0

0
0
0

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

0
0
0
14
0
0
1
0
0
0
0

0
0
0
12
0
0
1
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
0
0
0
0
0
0
0
0

0
0
0
9
0
0
1
0
0
0
0

0
0

0
0

0
0

0
0

0
0

0
0

Virgin Islands...
Puerto Rico

* Includes applications pending as of December 31, 1977.

12




1

1
0
2
0
0
0
0

Table 6
Applications for conversion to national bank charter and charters issued, by states, calendar 1978

Received*

Approved

Rejected

Withdrawn

Pending
December 31,

Chartered

1978
1

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

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
1
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
1

Georgia
Hawaii
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maine

0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
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

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

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
0
1
0
0
0
0
0
0

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

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
0
0
0
0
0
0
0
0

South Carolina
South Dakota
Tennessee

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
0
1
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
1
0
0

Iowa

Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
'Includes applications pending as of December 31, 1977.




13

Table 7
Branches* of national banks, by states, calendar 1978

Branches
in
operation
December 31,
1977

De novo
branches
opened for
business
Jan. 1 to
Dec. 31,1978

Branches
acquired
through
merger or
conversion
Jan. 1 to
Dec. 31, 1978

Existing
branches
discontinued
or
consolidated
Jan. 1 to
Dec. 31, 1978

Branches
in
operation
December 31,
1978

All national banks

17,066

630

93

350

17,439

50 states

17,060

630

93

350

17,433

317
77
308
169
2,741
32
205
4
130
221

24
3
12
9
74
0
1
1
5
69

0
0
0
0
15
0
0
0
0
19

1
1
1
3
69
1
5
0
0
7

340
79
319
175
2,761
31
201
5
135
302

Georgia ..
Hawaii
Idaho
Illinois
Indiana...
Iowa
Kansas...
Kentucky .
Louisiana.
Maine

322
11
170
145
496
88
72
242
267
118

10
0
8
37
18
7
3
14
10
1

0
0
0
0
1
0
0
0
0
0

0
0
0
0
8
4
0
2
0
2

332
11
178
182
507
91
75
254
277
117

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

338
451
835
37
233
75
8
53
82
93

19
2
51
31
16
5
0
3
3
4

1
0
6
0
8
0
0
0
0
2

2
6
24
1
1
13
0
0
0
1

356
447
868
67
256
67
8
56
85
98

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

1,043
116
1,505
801
26
1,058
58
317
1,392
115

14
7
10
15
3
35
2
13
29
0

0
0
2
1
0
5
0
0
7
0

84
5
28
8
0
2
0
9
20
0

973
118
1,489
809
29
1,096
60
321
1,408
115

307
80
358
8
107
45
687
586
23
88
0

15
4
9
5
3
2
10
10
3
1
0

1
1
0
0
6
0
17
0
1
0
0

1
0
3
0
3
1
31
2
1
0
0

322
85
364
13
113
46
683
594
26
89
0

0

0

136

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

South Carolina.
South Dakota..
Tennessee....
Texas
Utah
Vermont
Virginia
Washington...
West Virginia..
Wisconsin
Wyoming
Virgin Islands.
District of Columbia — a l l t . . .

131

*Does not include CBCT or foreign branches. For those branches, see tables 8 and B-28.
t Includes national and non-national banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.

14




Table 8
CBCT branches* of national banks, by states, calendar 1978

Branches
in
operation
December 31,
1977
All national banks.

De novo
branches
opened for
business
Jan. 1 to
Dec. 31, 1978

Branches
acquired
through
merger or
conversion
Jan. 1 to
Dec. 31,1978

0

Existing
branches
discontinued
or
consolidated
Jan. 1 to
Dec. 31, 1978

Branches
in
operation
December 31,
1978

527

289

51

765

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

3
2
0
2
3
0
0
0
1
30

4
0
0
2
0
12
0
0
0
6

0
0
0
0
0
0
0
0
0
0

7
2
0
4
3
12
0
0
1
36

Georgia
Hawaii
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maine

13
0
1
0
1
44
30
2
3
0

3
0
0
0
1
0
35
1
10
0

0
0
0
0
0
1
24
0
0
0

16
0
1
0
2
43
41
3
13
0

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

1
1
0
0
1
0
0
73
0
0

2
0
1
12
0
0
2
17
0
0

0
0
0
0
0
0
0
0
0
0

3
1
1
12
1
0
2
87
0
0

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

3
0
75
1
11
13
66
8
1
0

1
0
39
0
2
46
36
0
17
0

0
0
6
0
0
1
0
0
0
0

4
0
108
1
13
58
102
8
18
0

South Carolina..,
South Dakota...
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia...

5
3
43
0
0
0
15
8
0
64
0

7
3
6
0
0
0
4
1
0
22
0

0
0
2
0
0
0
0
0
0
17
0

12
6
47
0
0
0
19
9
0
69
0

1

0

Iowa

Wisconsin
Wyoming
District of Columbia — allf

0

0

* Customer-Bank Communications Terminal branches.
t Includes national and non-national banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.




15

Table 9
De novo branch applications of national banks, by states, calendar 1978
Pending
December 31, 1978

Received*

Approved

1,003

709
10
3
24
4
74
4
3
0
10
82

57

15
4
28
7
110
5
5
0
12
113

1
0
0
0
2
0
1
0
2
3

37
1
0
2
2
3
0
0
0
0
15

200
3
1
2
1
31
1
1
0
0
13

17
0
6
43
27
6
3
9
13
1

14
0
4
31
16
5
2
6
11
0

0
0
0
1
1
0
0
0
0
0

1
0
0
2
0
0
0
0
1
1

2
0
2
9
10
1
1
3
1
0

28
7
160
35
12
3
0
3
9
4

22
5
96
28
11
2
0
2
6
3

3
0
30
5
0
1
0
0
2
0

0
0
1
2
0
0
0
0
0
0

3
2
33
0
1
0
0
1
1
1

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

28
7
16
23
3
81
10
16
33
2

23
7
11
21
3
58
2
14
22
0

0
0
0
0
0
1
0
0
1
0

0
0
0
0
0
0
0
0
1
0

5
0
5
2
0
22
8
2
9
2

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

17
5
11
13
11
3
18
12
2
7
0

17
3
6
10
5
1
10
10
2
6
0

0
0
1
0
1
0
1
0
0
0
0

0
0
1
0
1
0
0
2
0
1
0

0
2
3
3
4
2
7
0
0
0
0

Total .
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia ..
Florida
Georgia ..
Hawaii
Idaho
Illinois
Indiana...

Iowa
Kansas...
Kentucky .
Louisiana.
Maine
Maryland
Massachusetts.
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

* Includes 121 applications pending as of December 31, 1977.

16




Rejected

Abandoned

Table 10
De novo branches* of national banks opened for business, by community size and by size of bank,
calendar 1978
Population of cities
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
Total

Total resources of banks
(millions of dollars)

Branches

140
220
105
. 56
. 44
. 29
. 26
. 10
630

Branches

Less than 10.0

17

10.0to24.9
25.0 to 49.9
50.0 to 99.9
100.0 to 999.9...

84

108
. 95
181
145
630

1,000.0 and over.

Total

*Does not include CBCT branches.

Table 11
Mergers*, calendar 1978
Transactions
involving
two or more
operating banks

Others pursuant
to
corporate
reorganization

Total

Applications received, 1978:
Mergers
Consolidations
Purchases and Assumptions

35
3
15

26
0
0

61
3
15

Total received

53

26

79

Approvals issued, 1978:
Mergers
Consolidations
Purchases and Assumptions

31
3
13

24
0
0

LO CO CO

Total approvals

47

24

71

2
1
2

2
0
0

4
1
2

5

2

7

29
13

23
2
0

52
4
13

44

25

69

Abandoned, 1978:
Mergers
Consolidations
Purchases and Assumptions
Total abandoned
Consummated, 1978:
Mergers
Consolidations
Purchases and Assumptions
Total consummated

i

* Includes mergers, consolidations and purchases and assumptions where the resulting bank is a national bank.




17

IV. Bank Examinations and Related Activities
The Office is responsible for examining all national
banks and their affiliates. With the ever increasing demands placed on the OCC's limited resources, the
Office has established a national policy on the frequency of on-site examinations. Thts policy combines on-site
examination priorities with an off-site examination program, utilizing National Bank Surveillance System analysis, which will make the most effective contribution to
the overall supervisory mission of this Office.
Banks requiring special supervisory attention will receive on-site examinations at least twice annually, including at least one full scope general examination.
Banks not requiring special supervisory attention,
which have assets exceeding $100 million will receive
one on-site examination at least annually. Banks with
less than $100 million in assets that do not require
special supervision will receive one on-site examination
at least every 18 months.
During the year ended December 31, 1978, the
Office examined 3,432 banks, 1,040 trust departments,
and 45 affiliates and subsidiaries and conducted 75
special supervisory examinations.
During 1978, the condition of the national banking
system continued to improve as measured by traditional standards. That improvement reflected the continued
strength of the economy over the last 4 years. It must be
stressed that the health of our banking system inevitably reflects the basic strength or weakness of the
economy. Although the performance of individual
banks may and does vary independently of overall economic conditions, the financial condition of the banking
system as a whole is inextricably linked to the domestic
and, increasingly, the international economy.
Examinations of national banks are meant to provide
an objective evaluation of a bank's soundness, to permit the Office to appraise the quality of management
and directors, and to identify areas where corrective
action might be required to strengthen the bank, improve the quality of its performance and enable it to
comply with applicable laws, rules and regulations. To
accomplish those objectives, the Office employs standardized examination 'procedures. Because banks are
not identical, examiners, drawing on professional judgment and experience, may have to modify the application of those procedures to fit the circumstances encountered in each bank. The use of such procedures
provides for the conduct of consistent and objective
examinations of varying scope.




As of December 31,1978, the Office employed 2,254
examiners; 2,093 commercial and 161 trust. Included in
these numbers are examiners specifically trained in
computer operations and consumer affairs and regulation. These specialized areas are a part of the regular
examination process.

EDP Examination
The EDP Examination Division and the Trust Examination Division are under the supervision of the Deputy
Comptroller for Specialized Examinations. The Trust Examination Division is covered in this report under Fiduciary Activities of National Banks.
The EDP Examination Division has made significant
achievements during the past year. Supervision of data
processing operations have improved through the expansion of the report review process at the regional and
national levels. A review assistant has been added to
the Washington staff. Quality control reviews have been
improved and administrative follow up actions have expanded.
For the first time, a formal career development program was initiated for the EDP examiner. A new title of
Associate National Bank Examiner - EDP was established and certification in the EDP examination program
has been achieved through the use of an associate
examination. Training was improved through the use of
formalized schools for all levels of examiners.
In the area of interagency activities, the EDP Examination Division has cooperated with the other federal
financial regulators in many ways. An Interagency Policy Statement was developed and implemented. The
policy established joint examination procedures for joint
EDP examinations and EDP report distribution guidelines. A Uniform Interagency Rating System for data
processing operations was drafted. The OCC has
joined with the Federal Reserve System and the FDIC in
a major revision of the OCC EDP Examination Handbook and work program. The final products will be
adopted by all three agencies as uniform examination
procedures for data processing operations. Sister
agency requests have also affected this division. The
OCC has provided training for selected Federal Reserve and FDIC examiners in the use of OCC EDP
examination procedures. In addition the National Credit
Union Administration (NCUA) requested individuals
within the EDP Examination Division to conduct an examination of NCUA's computer operation at the
19

Washington headquarters. That was completed during
March 1979.
The division completed a comprehensive review of

20




the OCC's internal computer operation during the fall of
1978. Many significant improvements in the operation
can be directly attributed to that review.

V. Law Department
The Law Department advises the Comptroller of the
Currency on legal matters arising in the administration
of laws, rulings and regulations governing national
banks. At the end of 1978, the Department employed
55 attorneys in the Washington Office and an additional
18 in regional offices around the country. Some of the
Department's major activities are described below.

Litigation
At the beginning of 1978, 55 lawsuits were pending.
During the year, 45 new lawsuits were filed. During this
same period, 30 cases were closed.
Extensive litigation resulting from bank failures, including U.S. National Bank in San Diego and Franklin
National Bank in New York, continued in 1978. In those
lawsuits, bank shareholders, directors, bonding companies, auditors and others sued the United States
under the Federal Tort Claims Act contending that government negligence caused the banks to fail. All of the
federal district courts which have ruled to date have
held that the examination and supervisory powers of the
federal banking agencies are not intended for the specific benefit of the bank involved and do not result in an
actionable duty to the bank or its shareholders on the
part of the agencies. In the first of these cases to reach
the appellate level, Harmsen v. Smith, 586 F.2d 156 (9th
Cir. 1978), the Ninth Circuit Court of Appeals held that
the federal scheme of bank regulation creates no duty
on the part of the Comptroller to shareholders and
directors.
However, in litigation involving the failure of Franklin
National Bank, the district court held that if the federal
banking agencies were so involved with the bank that
they managed and controlled its day-to-day operations,
then the government may have assumed a duty to the
bank to prevent fraud. In re Franklin National Bank
Securities Litigation, 445 F. Supp. 723, supplemented,
449 F. Supp. 574 (E.D. N.Y. 1978). Since government
involvement with a problem bank is always extensive,
this case poses a dilemma. On the one hand, a "normal" degree of bank supervision which may be inadequate to protect the public interest in the case of a
problem bank cannot result in government liability,
while the extensive supervision that such a bank warrants can subject the government to subsequent liability for alleged negligence contributing to its failure. The
case is still in preliminary stages, however, and resolution of this legal issue must await conclusion of the




action at the district court level and a subsequent
appeal.
The Comptroller's new regulation on credit life insurance, barring insiders of national banks from retaining
income from the sales of such insurance to loan customers, was challenged by the Independent Bankers
Association of America in the United States District
Court for the District of Columbia (IBAA v. Heimann,
Civil No. 77-2189). The IBAA contended that the Comptroller lacks the statutory power to promulgate regulations and that the regulation in question is contrary to
law. The district court dismissed the action on the
ground that review of the regulation should more properly follow an administrative proceeding under the
Financial Institutions Supervisory Act of 1966. IBAA has
appealed, and the case is now pending in the U.S.
Court of Appeals for the District of Columbia Circuit.
Although the Comptroller's Office believes its authority
to issue this regulation is plain, legislative clarification of
the Comptroller's rulemaking authority appears necessary to forestall litigation of this type.
Branching by national banks also continued to be a
source of controversy. The federal statute authorizing
national banks to establish branches (12 USC 36)
makes such authority contingent upon the authority
given to state banks by the state in question. That
statute, however, defines the term "state bank" to include trust companies, savings banks and other institutions carrying on a banking business.
In reliance upon that statute, the Comptroller
approved an application by a national bank in Oklahoma to establish a branch pursuant to the power of
Oklahoma trust companies to do so. Although trust
companies may branch in Oklahoma, state commercial
banks are forbidden to do so. The State Banking Commissioner and the Independent Bankers Association of
Oklahoma filed suit challenging that approval arguing
that national banks should be confined to the branching
powers granted to state commercial banks. The suit is
now pending.
In another "branching" lawsuit, 12 years after the
Comptroller had issued an interpretive ruling declaring
that the off-premises solicitation of loans does not
violate the National Bank Act, the Independent Bankers
Association of America filed suit to overturn the ruling.
In reliance upon the ruling, many banks over the years
have established off-premises and out-of-state offices
where loans are solicited and preliminary paperwork
21

done. However, decisions on such loans always were
made at the bank's main office or at an established
branch. In its complaint, the IBAA argues that any offpremises activities of a bank must be considered branching even if loans actually are not made off-premises.
In short, the Association seeks to confine all banks to
walk-in customers and thus to limit banking competition
solely to those banks formally located in a given geographical area. The case is now pending. IBAA v.
Heimann, Civil No. 78-0811 (D.C.)
In the only significant suit brought under the Freedom
of Information Act (FOIA), the United States Court of
Appeals for the District of Columbia Circuit held in Consumers Union v. Heimann, 589 F.2d 531 (D.C. Cir.
1978), that the disclosure policy of the Truth-in-Lending
Act does not supersede the exemption from disclosure
accorded to bank examination reports in the FOIA. The
court held that exemption 8 of the Act, which allows the
withholding of reports of examination and other similar
documents, applies to special consumer examination
reports as well as to the general reports made of a
bank's overall condition, and that they need not be
disclosed to the public.
Finally, in the area of bank supervision, the United
States Court of Appeals for the Fifth Circuit upheld the
Comptroller's powers to issue a cease and desist order
barring a bank's major shareholder from obtaining
credit from the bank directly or indirectly. Groos National Bank v. Comptroller of the Currency, 573 F.2d 889
(5th Cir. 1978). That case is only the second decision
by a U.S. Court of Appeals on a petition to review a final
order issued by a bank regulatory agency under the
Financial Institutions Supervisory Act of 1966.

Antitrust
In United States v. The Second National Bank and Trust
Co. of Lexington, et ai, Civil No. 77-87, 4 CCH Trade
Reg. Rep. 1145,007 (#2586), the expense and delays in
defending an antitrust suit caused the defendant banks
to withdraw the merger application which had been
approved by this Office on April 27, 1977. Each bank,
by resolution of its board of directors, terminated the
merger agreement and the court dismissed the complaint on March 14, 1978.
Two significant decisions interpreting the anti-tying
provisions of the Bank Holding Company Act Amendments of 1970 were handed down by federal appellate
courts in 1978.
In Swerdloffv. Miami National Bank, 584 F.2d 54 (5th
Cir. 1978), the owner of a corporation, which had been
placed in involuntary bankruptcy, alleged that the bank
engaged in an illegal tie-in when it conditioned credit on
the transfer of 51 percent of the corporation's capital
stock to another bank customer. The district court
granted the bank's motion for judgment on the grounds
that the money was lent to the corporation and only the
corporation had standing as a "customer" to bring suit.
The court of appeals reversed and remanded the case
holding that the complaint adequately alleged an illegal
tying arrangement.
In Costner v. The Blount National Bank of Maryville,
Tenn., 578 F.2d 1192 (6th Cir. 1978), the plaintiff
22




obtained a loan to purchase the stock of an automobile
dealership with the stock serving as collateral. The loan
agreement required the dealership to sell a substantial
share of its automobile installment paper to the bank.
The bank subsequently foreclosed on the dealership's
stock, which was sold at less than fair market value to a
group headed by the lending officer's brother. The
court of appeals held that the tie-in between the granting of credit and the sale to the bank of the dealership's
installment paper was illegal under the Bank Holding
Company Act Amendments of 1970 and that, unlike
allegations based on the Sherman Act, it was unnecessary for the plaintiff to prove that the bank had appreciable economic power in its market.
Another important case involving tie-ins imposed by
financial institutions was decided under the Sherman
Act. In Foster v. Maryland State Savings & Loan Ass'n.,
590 F.2d 928 (D.C. Cir. 1978), cert denied, 99 S. Ct.
842 (1979), the defendant savings and loan required
each borrower to pay an attorney's fee charge of $100
for title search and mortgage preparation if the borrower employed counsel other than the law firm retained by
the savings and loan. The charges were waived if the
borrower used the savings and loan's law firm for settlement. Plaintiff borrowers contended that these arrangements constituted an illegal tie-in of legal services to the
sale of credit and an unlawful restraint of trade on the
market for legal settlement services. The court of
appeals, in a twice amended decision, found no illegal
tie-in because the provision of legal services and the
granting of credit did not, in this instance, constitute two
separate products. Rather, the borrower's $100 payment represented an incidental and inseparable part of
his "purchase" of a loan, rather than the "purchase" of a
tied product. Further, the court held any restraint of
trade that did exist in the market for legal settlement
services was reasonable and de minimus in nature.
However, the court noted that several partners of the
savings and loan association's law firm occupied high
corporate positions in the association and stressed that
the court was not addressing the propriety of this
arrangement under any legal standard other than the
antitrust laws. A concurring opinion states that the majority might reach a different conclusion if the record
were to show that the association "steered" legal business to its counsel or otherwise made a showing that
the arrangement with the law firm was characterized by
"venality."

Securities Disclosure
Approximately 340 national banks have a class of
securities registered with the Comptroller pursuant to
the Securities Exchange Act of 1934 ("1934 Act"). The
Securities Disclosure Division has reviewed registration
statements, annual and special meeting proxy materials, periodic reports and materials required to be filed
in connection with tender offers and election contests
for those banks. Reports of beneficial ownership and
changes in beneficial ownership have been recorded,
and a public file of 1934 Act filings has been maintained.
During 1978, the division prepared proposed and

adopted amendments to 12 CFR 11, "Securities Exchange Act Rules," designed to make the Comptroller's
regulations under the 1934 Act substantially similar to
rules of the Securities and Exchange Commission
(SEC), in a response to statutory mandate.
Seven regional conferences were presented in Hershey (Pa.), Cleveland, Chicago, Atlanta, Richmond,
New York and San Francisco for the benefit of national
banks having a class of securities registered with the
Comptroller pursuant to the 1934 Act. The conferences
were designed to assist banks in complying with the
reporting requirements of the 1934 Act, and to inform
them of proposed changes in 12 CFR 11 and various
regulations of the SEC which will affect banks. The
conferences also focused on compliance with the requirements of the Comptroller's "Securities Offering
Disclosure Rules," 12 CFR 16, relating to the offering
and sale by national banks of their securities.
The division assisted the Trust Operations Division of
the Comptroller's Office in federal securities law matters.
It again participated in a seminar for trust examiners
and a fraud seminar designed to help examiners recognize possible violations of Section 10(b) of the 1934 Act
and SEC Rule 10b-5. The division assisted in the finalization of amendments to 12 CFR 9, "Fiduciary Powers
of National Banks and Collective Investment Funds,"
relating to variable amount master notes, securities
handling procedures, and the use by trust departments
of material inside information available to the bank as a
result of its commercial banking activities. The revision
of 12 CFR 9.7(d), which requires national banks with
fiduciary powers to adopt written policies and procedures to ensure that they will not use material inside
information in connection with any decision or recommendation to purchase or sell any security, was
adopted on February 16, 1978. The division assisted in
the drafting of a new proposed regulation, 12 CFR 12,
"Recordkeeping and Confirmation Requirements for
Certain Transactions Effected by National Banks," in
response to recommendations contained in the SEC
report on bank securities activities. The proposal
addresses the recordkeeping and confirmation requirements to be promulgated for national,banks engaged in
the purchase or sale of securities on the order of a
customer. At the end of the year a final regulation had
not been adopted.
The division suspended trading in the stock of two
national banks pending the public dissemination of information which might affect the market activity in, and
the price of, the banks' stocks. The division assisted the
SEC in several enforcement actions against national
banks alleging violations of the federal securities laws.
The division also had numerous meetings and discussions with the SEC on such matters as access to and
disclosure of information contained in bank examination
reports, activities of trust departments, and 1934 Act
filings of bank holding companies which are parents of
national banks.
The division took a leading role in the initiation and
negotiation of a consent decree against two national
banks and an individual in a suit filed by the Comptroller
as co-plaintiff with the Securities and Exchange Com


mission. This suit established a precedent, concurred
in by the Department of Justice, for the Comptroller's
Office appearing on its own behalf in civil actions initiated by it under the 1934 Act. Also, the division initiated
the Comptroller's first civil injunctive action under the
1934 Act as sole plaintiff, alleging violations of sections
13(d) and 14(d) of that Act. A preliminary injunction was
obtained and as of the end of the year the case was
pending before the court for determination of final relief.
The division, working closely with the Office's Investment Securities Division, instituted and pursued the first
private investigation by the Comptroller's Office of the
activities of a registered bank municipal securities dealer under the 1934 Act. At the end of 1978 the investigation was still in progress.
In the administration of 12 CFR 16, the division processed approximately 120 offering circulars filed by
national banks in connection with the public offering
and sale of their equity or debt securities. In addition,
the division responded to numerous requests filed
under the exemptive provisions of the regulation. Regional Counsel have been assisted by the division in
reviewing offering circulars of organizing banks.

Legislative Counsel
The principal responsibilities of the Legislative Counsel
Division relate to the legal aspects of legislation. The
subject matter covers virtually every area of the Office's
jurisdiction and almost every legislative measure of interest to national banks. In addition, the division deals
with matters of intergovernmental and operational interest. In connection with those general responsibilities,
the division maintains such information as status of bills,
reports on bills, press information and primary legislative documents as well as files on Public Laws passed
in the current and immediately preceding Congresses.
Division attorneys prepare testimony to be given before Congressional committees and letters of comment
on pending bills to be sent to members of Congress.
They draft legislation and write memoranda and briefing papers concerning various legislation. Division
attorneys are in frequent contact with members of Congress and their staffs; personnel in Treasury, Office of
Management and Budget and other federal and, occasionally, state agencies; Office staff in the regions and
in Washington; and public representatives who want
information on banking legislation. They also attend
relevant hearings on the Hill and participate in meetings
with Treasury and other agencies to consult on and
keep abreast of legislation of interest to this Office. In
addition, division attorneys speak to various groups,
including bar associations, foreign bankers and Office
staff, on legislative matters.
The following are the legislative activities of the
Second Session of the 95th Congress (1978) which are
of significance to the Comptroller's Office.
Securities Investor Protection Act Amendment (P.L. 95-

283; May 21, 1978) — Provides customers of securities
broker-dealers protection against losses which might
occur as a result of the financial failure of brokerdealers.
23

Federal Banking Agency Audit Act (P.L. 95-320; July 2 1 ,

1978) — Provides for an audit by the General Accounting Office of the Federal Deposit Insurance Corporation
and the Comptroller of the Currency.
International Banking Act of 1978 (P.L. 95-369; Sept. 17,

1978) — Establishes a system of federal regulation of
foreign banking activities in domestic markets. Chartering and examination of foreign-owned federal branches
and agencies are the responsibility of OCC. The law
permits interstate branches of foreign banks (1) for
branches existing on or before 7/27/78, (2) for branches whose deposit-taking powers are restricted to internationally-related transactions permissible for Edge
Act corporations, (3) for federal branches when permitted by the state in which it is to be operated and for
state branches with the approval of the state regulatory
authority. Federal branches and agencies are to be
subject to reserve requirements. FDIC insurance is required for domestic deposits but is limited to foreign
banks which accept retail deposits less than $100,000.
FDIC may waive that requirement if the branch is exclusively engaged in wholesale banking, even though it
accepts deposits under $100,000. The nonbanking
activities of foreign banks and foreign companies are
subject to the restrictions of the Bank Holding Company
Act but such activities, including securities affiliates, in
existence prior to July 26, 1978, have been permanently grandfathered. The Federal Reserve Board is authorized to terminate the grandfather status of any company after December 31, 1985, pursuant to its powers
under the Bank Holding Company Act. Securities activities of federally chartered foreign branches and agencies are subject to the same restrictions that apply to
national banks under the Glass-Steagall Act. The law
authorizes a study of the treatment of American banks
overseas and a review of the McFadden Act's prohibitions on interstate branching by commercial banks.
Ethics in Government Act of 1978 (P.L. 95-521; Oct. 26,
1978) — The Act contains requirements to file reports
disclosing personal financial information on officers or
employees of the three branches of the Federal Government at grades GS-16 or above, and certain other
employees. It is to take effect January 1,1979. It establishes a special Office of Government Ethics to direct
executive branch policies relating to the prevention of
conflicts of interest. It places limitations on postemployment activities of executive branch employees;
July 1, 1979 is the effective date for that provision.
Finally, the Act sets out new procedures for appointing
a special prosecutor whenever the Attorney General
believes that high level executive personnel have
violated federal criminal laws, and establishes an Office
of Senate Legal Counsel to defend the Senate in any
court proceedings.
The Financial Institutions Regulatory and Interest Rate

Control Act of 1978 (P.L. 95-630; Nov. 10, 1978) — The
following is a brief summary of each title as it affects
OCC.

24




Title I—Supervisory Authority Over Depository
Institutions
This Title, which is the cornerstone of the bill, increases the extent of specific powers the OCC may
exercise in supervising national banks. It provides for
civil money penalties, cease and desist orders against
individuals, expanded grounds for removal of officers
and directors and immediate suspension of insiders
indicted for crimes involving dishonesty or breach of
trust. It restricts overdrafts to executive officers and
directors, and places limitations on loans to insiders. It
also provides that the Federal Reserve may order divestiture by a bank holding company of subsidiaries
which endanger the holding company's safety and
soundness.
Title II—Interlocking Directorates
This Title prohibits management interlocks among
depository institutions in the same SMSA or in the same
or adjacent city, town or village. Depository institutions
with less than $20 million in assets are restricted only in
the same or contiguous or adjacent city, town or village.
All management interlocks between depository institutions or holding companies with $1 billion in assets and
another institution or holding company with $500 million
or more in assets are prohibited regardless of geographical location. Existing interlocks are grandfathered
for 10 years. OCC is given rulemaking authority under
the Title.
Title III—Foreign Branching (FDIC Housekeeping
Amendments)
This Title, which pertains primarily to the FDIC, also
contains provisions applicable to OCC. Antidiscrimination standards are extended to foreign banks operating
in the U.S., and representation of such compliance
must be made to OCC before applications for charters
are granted to foreign banks.
In addition, this Title brings OCC employees under
the federal criminal statute, 18 USC 1114, dealing with
assaults on employees engaged in official duties. Finally, the FDIC is given additional general rulemaking authority.
Title IV—American Arts Gold Medallions
This Title authorizes the public sale of governmentissued gold medals.
Title V—Credit Union Restructuring
This Title establishes the National Credit Union Administration with a board consisting of three members.
Its activities are to be financed by fees rather than
Congressional appropriations.
Title VI—Change in Bank Control Act
This Title authorizes OCC to disapprove changes in
control of national banks within 60 days of filing. Disapproved parties have a right to a formal hearing. The
Title sets forth what information will be required and
grounds for disapproval. The Title also provides for civil
money penalties of $10,000 a day.

Specific rulemaking authority is given to OCC, which
must report to Congress on the administration of this
Title and make recommendations for changes.
Title VII—Change in Savings and Loan Control Act
This Title parallels Title VI and is applicable to the
Federal Home Loan Bank Board's responsibilities for
savings and loan institutions.
Title VIII—Correspondent Accounts
This Title prohibits preferential treatment in loans to
customers where correspondent relationships exist.
The OCC may assess a $1,000 a day penalty for violations. National banks are required to make reports to
the Comptroller on correspondent loans to insiders.
The OCC is authorized to make rules and regulations
to carry out these provisions. Those accused of violating this Title may have a hearing on the record.
Title IX—Disclosure of Material Facts
This Title requires insured banks to report annually a
list of their major stockholders and the aggregate
amount of all their loans to officers and major stockholders, their affiliated companies, and political or campaign committees. This information will be made public.
The OCC is given rulemaking authority to carry out
this provision.
Title X—Federal Financial Institutions Examination
Council
This Title establishes an examination council to develop uniform standards for examinations and improve
coordination among the agencies. It is composed of all
five federal financial regulatory agencies. The Council
members select the first chairman and thereafter the
chairmanship will rotate. The Council employs its own
staff and consultants. Expenses will be met from the
agencies, with the OCC furnishing one-fifth of the expenses of the Council.
The Title also provides for liaison with state officials.
Title XI—Right of Financial Privacy
This Title protects the financial records of bank customers from certain government seizures. Civil money
penalties, damages to the customer and costs are provided for in this Title.
Title XII—Charters for Thrift Institutions
This Title permits mutual savings banks to convert to
a federal charter and become subject to supervision
and regulation by the Federal Home Loan Bank Board.
Title XI11—NOW Accounts
NOW accounts are permitted for New York financial
institutions, effective upon enactment.
Title XIV—IRA and Keogh Accounts
This Title increases deposit insurance on IRA and
Keogh Accounts from $40,000 to $100,000.
Title XV—Miscellaneous Provisions
The provisions of major interest to OCC in this Title



are an amendment to the Community Reinvestment Act
concerning financial institutions which predominantly
serve the needs of military personnel who are not located within a defined geographic area, and a provision which authorizes to OCC to grant national charters
to limited purpose trust companies. This Title also permanently prohibits credit card surcharges.
Title XVI—Interest Rate Controls
This Title extends Regulation Q for 2 years to December 15, 1980. Significantly, it also eliminates the differential on transaction accounts. The maximum rate of
interest payable on such accounts is the rate which
insured commercial banks can pay.
Title XVII—Federal Savings and Loan Investment
Authority
This Title is a modernization of Section 5(c) of the
Homeowners' Loan Act, which prescribes the asset
powers of federal savings and loan associations.
Title XVIII—National Credit Union Central Liquidity
Fund
This Title establishes a liquidity facility for credit unions.
Title XIX—Export-Import Amendments
This Title was a "rider" on the bill and has no direct
bearing on the OCC.
Title XX—Electronic Fund Transfers
This Title provides consumer protection in connection
with electronic fund transfers. Rulemaking authority is
vested in the Federal Reserve Board and the OCC is
delegated enforcement authority with respect to national banks.
Title XXI—Effective Date
Except as specifically provided in other Titles, the Act
becomes effective on March 10, 1979.

Legal Advisory Services Division
During the year 1978, the Legal Advisory Services Division received approximately 1,900 written inquiries and
3,800 consumer inquiries. Those figures represent only
written assignments for which a control sheet was prepared. They do not include the large number of telephone calls, interim correspondence or supporting
memoranda required for many inquiries. Members of
the division also participated in numerous meetings
with bankers, banking lawyers, consumers, federal and
staff regulatory authorities and representatives of other
branches of the federal government to discuss various
topics affecting national banks.
During the year the division participated in the writing
of regulations and rulings which were published in the
Federal Register. Some of the proposed regulations
concerned leasing of bank premises, flood insurance,
enforcement of Regulation B, separation of the commercial department of a bank from its trust department,
hearing procedures for the removal of bank officers (12
CFR 24), Community Reinvestment Act Regulations (12
25

CFR 25) and application procedures and interpretive
rulings on real estate loans, charitable contributions
and other real estate owned. The division also assisted
in the publication of the amendments to 12 CFR 11 and
12 CFR 12. Toward the end of the year, a proposed
revision of 12 CFR 1, governing investment securities,
was developed. It was published in the Federal Register on January 3, 1979. The revision, if adopted, should
result in a savings to OCC of approximately $13,000 per
year in publishing costs.
Significant letter rulings issued by the division interpreting OCC statutes, rulings and regulations are
issued each month and published by various loose-leaf
reporting services.
Division attorneys also served on various task forces
and committees which considered such areas as the
Equal Credit Opportunity Act, Comptroller's conflicts of
interest issues, civil service matters, and implementation of the Financial Institutions Regulatory and Interest
Rate Control Act of 1978. A number of special assignments were undertaken by members of the division
staff. One staff member participated in the President's
Personnel Interchange Program as the Treasury Department's representative. Another served as Special
Assistant to the Chief Counsel for a 6-month period.
The paralegal unit responded to a record number of
inquiries from consumers. The unit received 3,760 new
consumer inquiries during 1978, of which 1,627 were
referred to regional offices. During that same period,
2,061 such inquiries were resolved; 209 remained
pending as of the end of the year. Some 4,186 consumer assignments were processed and resolved during
1978 with the help of the paralegal unit. That number
includes new inquiries, inquiries pending from 1977,
and inquiries referred to regional offices or other agencies.

Enforcement and Compliance Division
For the second consecutive year, the number of formal
administrative actions under the Financial Institutions
Supervisory Act increased 50 percent over the preceding year. The administrative actions dealt with such
areas as violations of laws, rules and regulations; abusive insider transactions; poor managerial practices;
and general unsafe and unsound practices and conditions. The actions required such items as:
• Reviews of bank correspondent accounts, director and officer remuneration, management
capabilities, lending and investing policies, earnings and capital position.
• Prohibitions against preferential transactions by
insiders, payment of checks drawn against uncollected or insufficient funds, extensions of credit to
particular individuals and extensions of credit outside the bank's trade area.
• Increases in equity capital, liquidity and allowance for possible loan losses.
• Restrictions on the payment of dividends, travel
and entertainment expenses and excessive
salaries.
• Limitations on the lending and investing authority
of bank officers.
26




•

Reimbursement by officers and directors for losses resulting from violations of law or from improper, self-serving transactions.
• Reimbursement for excessive salaries and for improper expenses.
• Correction of violations of laws, rules and regulations, including the violations of consumer laws.
• Hiring of independent counsel or auditors to review questionable insider transactions.
• Prohibitions relating to GNMA standby forward
placement contracts.
As in previous years, the division participated in examinations and investigations of white collar crime
leading to criminal referrals to the U.S. Department of
Justice. In one particular instance, a national bank examiner uncovered a large volume of unexplained and
unsupported travel and entertainment expenses.
Through the use of subpoenas and depositions, it was
established that the chief executive officer had charged
lavish amounts of personal expenses to his bank. This
information led to the individual's resignation of his
position as chief executive officer and chairman of the
board, sale of his controlling interest in the bank, and
reimbursement of the bank for personal expenses
charged to the bank.
The division also coordinated, with several other
agencies, an investigation and the institution of a civil
action against two national banks and an individual
involving violations of federal securities laws. The settlement of the case required the banks and the individual
to cease the objectionable practices and to take affirmative actions to correct the conditions resulting from
those practices.
During the course of 1978, the division conducted
three seminars to give national bank examiners intensive exposure to the investigation, documentation and
reporting of fraudulent transactions in financial institutions. The seminar included presentations on conducting an examination into fraudulent transactions; criminal
statutes; testifying, interviewing and taking depositions;
writing criminal referrals; and actual and hypothetical
cases involving fraud within banks. The seminars were
open to the other federal and state banking agencies.
The division established communications with various foreign commissioners of banks to promote
cooperation with respect to frauds being perpetrated
on United States banks and citizens through the use of
offshore shell banks.
Listed below is a short summary of each administrative action initiated during 1978. (Similar detail is available for 1977 on pp. 18-23 of the Annual Report for that
year.)
1. A Notice of Charges and a Temporary Order to
Cease and Desist were served which prohibited the
bank from violating its legal lending limits; from
making loans to any borrower whose loan had been
criticized; from granting loans which were unsupported by current and adequate credit information;
from violating Federal Reserve Regulation Z or 12
CFR 23; and from allowing the chief executive officer of the bank to grant or approve any extension of

2.

3.

4.

5.

credit, to sell or purchase any loan participation, or
to make investments on behalf of the bank without
the specific, prior written approval of the Board of
Directors. While the proceedings were pending the
bank converted to a state charter.
An Agreement prohibited violations of the bank's
legal lending limits and loans to any borrower with
criticized credit. The bank was ordered to hire a
qualified and capable chief executive officer and
the Board was told to submit a written program to
augment capital. The Agreement proscribed favorable treatment in the use of bank assets and facilities by officers, directors, or 10 percent shareholders of the bank. The bank was to reduce concentrations of credit; improve its liquidity position;
obtain adequate credit information and collateral
before granting new loans; increase reserves; and
implement internal control and investment policies.
An Agreement required the correction of all violations of legal lending limits and prohibited loans to
officers and directors in violation of 12 USC 375a.
The Board of Directors was called on to raise equity
capital; to evaluate the reasonableness of all remuneration to the bank's officers and directors for
services rendered; and to review all of the bank's
correspondent accounts with other financial institutions. Bank reserves were to be raised; criticized
assets and loans were to be curtailed, if not eliminated entirely; and full credit information was to be
demanded on loans, as was prompt collection.
An Agreement prohibited violations of the bank's
legal lending limits; proscribed loans to any borrower whose loan had been criticized; and ordered that
no loan be granted unless supported by current
satisfactory credit information. Additional capital
was considered crucial to the future well-being of
the bank. The bank's latitude in declaring dividends
was circumscribed and the bank was directed to
implement its existing internal audit procedures. An
independent accountant was to assess the reasonableness and legitimacy of all remuneration and
benefits tendered to bank officers within the preceding 12 months. A new loan and investment policy was to be implemented; a new senior lending
officer was to be added to the existing staff; and
reserves were to be maintained at an adequate
level.
An Agreement prohibited violations of the bank's
lending limits. Loans in violation of 12 USC 371c
were proscribed and any loans made for the benefit
of an affiliate of the bank were to be approved by a
majority of the Board of Directors. Elimination of
assets from critical status was requested; the further extension of credit to any borrower whose loans
had been criticized was severely circumscribed;
and improved collection of, and a reduction in the
level of, delinquent loans was ordered. Complete
credit information was required on all loans, as was
a revision of the bank's written lending policy. A
program to increase the equity capital of the bank
and a program to improve the bank's earnings and
liquidity position were also required.




6. An Agreement proscribed loans in excess of the
bank's lending limit. The Board of Directors was
instructed to raise the equity capital of the bank, to
provide the bank with a qualified and capable
senior lending officer, and to evaluate the reasonableness of all remuneration and benefits tendered
to the bank's executive officers within the prior 2
years. A written forecast of the bank's financial
operations for the year was to be submitted, outlining the Board's plans to restore the bank's operations to a sound and profitable basis. Improvement
of the bank's liquidity position, augmentation of the
bank's reserves for bad debts, and a new loan
policy were requested. Current and satisfactory
credit information on all loans was required, as was
the elimination of all assets from criticized status. An
independent audit of the bank was ordered within
120 days.
7. An Agreement prohibited the bank from extending
further credit to any borrower whose loan had been
criticized and forbade the violation of the bank's
legal lending limit. An internal audit of the bank was
ordered to assess the reasonableness and legitimacy of all remuneration paid by the bank to its
officers during the prior 12-month period and to
determine if restitution was appropriate. Elimination
of internal control and audit deficiencies was required, as was the adoption of a safe and sound
written loan policy and the maintenance of an adequate loan valuation reserve. The Board of Directors was also required to secure additional equity
capital for the bank and to remove all assets from
classified status, with particular attention to substandard loans to insiders' interests. The Board was
to submit the bank's 1978 budget with pro forma
financial exhibits and liquidity projections, and was
to evaluate all fees paid by the bank to insiders. All
correspondent accounts with other financial institutions were to be reviewed.
8. Violations of the legal lending limits were proscribed and the Board of Directors was to ensure
that the bank obtain indemnification from responsible directors for any losses on loans granted in
violation of 12 USC 84. The bank was also prohibited from granting any preferential loans or overdrafts or from holding cash items in abeyance for
the benefit of officers, directors or their interests. No
transactions from which any officer or director derived personal pecuniary benefit, other than as
reasonable compensation for normal services performed in the ordinary course of employment, were
permitted without the prior written approval of the
regional administrator. A senior executive officer
with authority over lending was to be appointed.
The Board was to develop a program to improve
the bank's profitability and its liquidity position and
was to review the bank's investment and loan
policies. The bank agreed to eliminate criticized
assets, to obtain full credit information and to obtain
an independent audit.
9. The bank was prohibited from extending credit to
any borrower whose residence or principal place of
27

business was located outside the bank's trade
area, and was ordered to cease generating new
business from any of its loan production offices,
limiting the activity of those offices to the collection
of outstanding loans. Borrowers whose loans had
been criticized were to be denied further credit and
criticized assets were to be eliminated. The Board
of Directors was ordered to provide a new senior
lending officer and to prepare an analysis of the
bank's present and future capital needs. A program
to improve and sustain the earnings of the bank
was required. Remuneration to directors was to be
confined to services rendered. Legal lending limits
were to be adhered to, full credit information on
loans was to be required, and internal control and
audit deficiencies were to be rectified. A review of
the reserves for possible loan losses was ordered
and the bank was to adopt a policy on those reserves.
10. A Notice of Charges and a Temporary Order to
Cease and Desist were followed by a Permanent
Order which prohibited the bank from honoring any
instrument that would either create an overdraft or
would constitute payment in excess of $500 against
uncollected funds in the demand deposit account
of any insider. No official checks lacking previously
collected funds sufficient to cover the check were
permitted. Violations of the bank's legal lending
limits were proscribed. An independent audit of the
bank was ordered, with particular attention to transactions between the bank and insiders. The bank
was further required to institute policies to ensure
that all transactions between the bank and insiders
were conducted on nonpreferential terms which
were fair to the bank. The bank was also instructed
to comply with the provisions of an Agreement
drawn up in 1976.
11. An Agreement was entered into which prohibited
violations of the bank's legal lending limits and
ordered that excessive loans be reduced to conforming amounts. Members of the Board of Directors assenting to a loan in violation of the lending
limits were to indemnify the bank for any resulting
losses. The bank was also forbidden to grant any
credit to specific individuals or their interests. The
Board of Directors was to prepare a written program to augment the bank's capital. Elimination of
assets from criticized status was required, no loans
were to be granted to borrowers whose previous
loans had been criticized, no loans were to be
granted without prior compliance with 31 CFR 103,
and no dividends were to be declared unless in
conformance with 12 USC 56 or 60, justified by
sound banking policy and approved in writing by
the regional administrator. The bank was ordered to
submit a written loan policy addressing the deficiencies in the loan portfolio management, and
establishing guidelines for preventing undue concentrations of credit and improper overdrafts. A
comprehensive independent audit was required to
study the remuneration paid to the officers and
directors and to review the bank's reserves for possible loan losses.
28




12. An Order to Cease and Desist was issued against
the bank which ordered the Board of Directors to
appoint a compliance committee. All lending and
investing authority of the president and executive
vice-president of the bank was withdrawn and
given to the compliance committee. A capable
chief executive officer and a senior lending officer
were to be provided. An independent auditor was
to assess the merit of remuneration paid by the
bank, reimbursement was called for on all expenses not incurred solely for the benefit of the
bank, and salaries were to be adjusted to a level
commensurate with the services rendered. The
bank was also prohibited from making any loans
and from selling or buying any assets to or from
certain individuals. The bank's lending territory was
to be strictly confined to its primary service area,
dividends were to be curtailed, increased investments in bank premises were to be reduced; concentrations in credit were to be reduced, criticized
assets were to be reduced, and current and satisfactory credit information on all loans was to be
required. Equity capital was to be increased; the
bank's earnings improved; new loan and investment policies instituted; violations of 12 USC 371c,
377, 463, 375a, and 84 corrected; and all correspondent accounts reviewed.
13. An Agreement called for the reduction and/or elimination of fees paid to bank directors until bank
earnings improved or asset problems were resolved. Maintenance of an acceptable level of liquidity, the raising of equity capital, and a review of
reserves for possible loan losses were called for.
The bank's CPA firm was to determine whether any
insider had received any benefit from certain loans
or extensions of credit. The bank was prohibited
from acquiring any loan participation or asset and
from extending credit to a certain individual, any
member of his family, or his relatives. The Board
was instructed to continue complying with consumer laws and regulations.
14. A Notice of Charges and an Order to Cease and
Desist ordered the bank to cease paying any salary
or compensation to the Chairman of the Board or
his son, and to cease paying any salary to specified
insiders unless such fees were reasonable and in
return for services rendered to the bank. Directors'
fees for attendance at Board meetings were not to
exceed $100 per month. The bank was ordered to
divest itself of its airplane and to cease making any
payments on automobiles. The bank was to be
audited and to adjust its reserves for loan losses.
All expenses paid by the bank were to be in connection with bank business only. Any transactions
between the bank and the family or business of the
Chairman of the Board were to be closely scrutinized. The bank was prohibited from transacting
any insurance business with the company owned
by the Chairman. The Board was not to alter the
bank's lease if the result was to increase payments.
Violations of 12 USC 84, 371c and 375a and 12
CFR 23 were to be corrected, the bank's loan policy
was to be amended, and no dividends were to be

declared unless justified and approved by the regional administrator.
15. An Agreement required correction of violations of
law, a new chief executive officer, a capital plan,
the elimination of criticized assets and preferential
insider loans, the improvement of lending policies,
and a review of the bank's reserves for possible
loan losses.
16. An Order to Cease and Desist prohibited the bank
from violating the legal lending limits, from acquiring any loan participation or other obligation or
asset, and from extending any credit to a list of
specified individuals, business entities, or relatives
or affiliates of such. The Board of Directors was
called on to provide the bank with a capable and
qualified chief executive officer and to review the
reasonableness of all salaries paid to bank executive officers. Current and satisfactory credit information was to be required on all loans. A new
written loan policy was to be formulated and internal control and audit procedures were to be rectified. Adequate loan valuation reserves were to be
maintained and correspondent bank accounts
were to be reviewed to determine that they were in
the best interests of the bank.
17. An Agreement called for the correction of all violations of 12 USC 375a and for a reduction in the
bank's ratio of net loans to total capital. A written
liquidity program was to be submitted for the
approval of the regional administrator, concentrations of credit to insiders were to be reduced, removal of assets and loans from criticized status
was to be effected, and the declaration of dividends was circumscribed. A detailed budget for
1978 was to be submitted to the regional administrator, with particular attention paid to the acquisition of new management, new capital and new
ownership.
18. An Agreement prohibited violations of the bank's
lending limits and required full credit information on
all loans. The Board of Directors was to review and
revise the written lending policy of the bank to ensure its safety and soundness. Elimination of assets
from criticized status was required and review of
reserve for possible loan losses was called for. The
Board was asked to implement a program to
coordinate the bank's assets and liabilities, to augment bank capital, to rectify deficiencies in internal
control procedures so that checks would not be
honored against uncollected funds, and to achieve
desired levels of liquidity. A senior lending officer
was to be employed to supervise the bank's loan
portfolio.
19. An agreement required the Board of Directors to
formulate an investment policy applicable to all
securities holdings and bank activities by which the
bank was to operate its investment and trading
accounts. The Board of Directors was required to
develop a written program restricting the bank's
market-making activities in the bank's stock. Other
problems addressed included hiring a new chief
executive officer, increasing capital and liquidity,



20.

21.

22.

23.

implementing new lending policies, and increasing
the reserve for possible loan losses.
An Order to Cease and Desist required that the
bank submit a program to increase equity capital. It
further required that the bank remain within the
lending limitations and reduce excessive loans.
Credit was not to be extended nor further loans
made to borrowers whose credit had been criticized. The bank was to increase its liquidity and
decrease its dependence upon market rate funds.
A program to increase the bank's earnings and a
budget for profitable operation were to be formulated and adopted. The bank was to develop a
policy regulating the types of advances and the
circumstances under which loans would be made
to insiders or their interests.
An Agreement required that action be taken to remove all loans to insiders which had been criticized
in the report of examination from criticized status.
Guidelines were set restricting loans to directors.
Overdrafts were prohibited for insiders and their
interests. A new written lending policy was to be
submitted to the regional administrator. Criticized
assets were to be eliminated and loans were not to
be made to borrowers with criticized credit. Collections were to be improved and a new lending officer
hired. The reserve for possible loan losses was
ordered to be increased. A budget was to be made
and a program formulated to provide for contingency capital needs.
An Agreement required new loan and investment
policies. A new lending officer and an internal auditor were to be hired. The bank was required to
increase its reserve for possible loan losses. A program was to be instituted to sustain bank earnings
which was to include a budget and a plan to reduce
non-accrual loans. Provisions to supply sufficient
equity capital were to be made. Corrections of deficiencies in internal control were to be implemented. All criticized assets were to be eliminated and loans to borrowers with criticized credit
were prohibited.
A Permanent Order to Cease and Desist was stipulated to, which ordered the bank to raise not less
than $200,000 in equity capital within 30 days of the
effective date of the Order. The Board of Directors
was instructed to assess the reasonableness of all
remuneration paid to bank directors and officers for
services rendered to the bank. The bank was
prohibited from acquiring any loan participation or
any other obligation or asset and from guaranteeing extensions of credit to a list of specified
individuals or their interests. Programs were called
for to maintain an acceptable level of liquidity and a
safe and sound investment policy. Review of the
bank's loan policy and reserve for possible loan
losses was required. Elimination of all assets from
criticized status was required and deficiencies in
internal control and audit procedures were to be
eliminated. Violations of the bank's legal lending
limits were proscribed and the bank was ordered to
bring all loans to its executive officers into conformity with 12 USC 375a.
29

24. An Agreement addressed the bank's major problems, including a substantial increase in classified
assets, numerous violations of law, marginal capital, earnings and liquidity.
25. A Notice of Charges and a Temporary Order to
Cease and Desist required that in the future banking fees for appraisal and loan origination be disclosed pursuant to Federal Reserve Regulation Z
and that such fees be paid directly to the bank.
26. A stipulated Cease and Desist Order required the
bank to submit a program to increase equity capital, to refrain from paying dividends without prior
approval by the regional administrator, and to review and evaluate the reasonableness of salaries
paid to directors and executive officers based on
their services rendered to the bank.
27. An Agreement was made with the bank to formulate
and institute programs to increase equity capital,
augment reserves for possible loan losses, improve
the bank's asset and liability posture, and eliminate
deficiencies in internal and audit control. The bank
was prohibited from lending in excess of legal limitations and from lending to borrowers with criticized
loans. The bank was further ordered to reduce all
excessive loans, correct all violations of law, recover from the directors all losses from loans knowingly
made in violation of 12 USC 84, and take all necessary steps to remove loans to officers from criticized status. Loan and investment policies were to
be reviewed and supplemented. The bank was forbidden to pay employees on the basis of the bank's
gross income without first adjusting for possible
loan losses, securities or non-recurring gains or
losses, and income taxes.
28. After a Notice of Charges was served, a Temporary
Order to Cease and Desist was issued prohibiting a
specific bank officer from extending loans, authorizing expenditures, investments, selling or exchanging bank assets, borrowing in the bank's
name, participating in the bank's contracts, bookkeeping, and hiring and firing personnel. The bank
was forbidden to extend credit to borrowers with
criticized loans. The bank contested the issuance
and scope of the Temporary Order in federal district court, after a hearing. The court denied the
bank's petition for a temporary restraining order
against the Comptroller and sustained the issuance
of the Comptroller's Order.
29. An Order to Cease and Desist prohibited a specific
bank officer from extending loans and employing or
removing personnel. The bank was ordered to
appoint a new chief executive and a cashier, and to
define and limit the duties, salaries and bonuses of
executive officers. Loans were to remain within the
legal limitations, excessive loans were to be reduced, and all criticized assets were to be removed
from criticized status. Loans to borrowers with criticized credit were forbidden. Lending policies were
to be reviewed and new ones submitted to the
regional administrator. An audit by an independent
auditor was ordered and deficiencies in internal
control and audit were to be corrected. Capital
30




30.

31.

32.

33.

34.

structure was to be strengthened and augmented
with the incorporation Jof a budget. Employees were
to receive training in consumer law.
An Agreement addressed the major problems of
low liquidity, poor lending practices, inadequate
documentation of loans, loans without repayment
schedules, and a high level of classified loans.
An Agreement ordered the bank to appoint a new
chief executive officer, define the duties of senior
management and establish a reasonable compensation plan. Policies on loans and overdrafts were
ordered to be the same for all persons. Credit concentrations were to be reduced. A new loan policy
was to be established limiting the amounts of loans
to insiders, preferential interest rates, the bank's
trade area, its concentrations of credit, and certain
purchases of loan participations. The bank was
commanded to eliminate deficiencies in internal
control procedures and to prepare a policy for the
payment of expenses. Loans were to remain within
the legal limitations, and certain loans were to be
reduced and collected. Specific questionable expenses were to be examined with compliance reported to the regional administrator. Only legal political campaign contributions were authorized. A
shareholder list was to be made and out-of-territory
loans were to be reduced.
An Agreement was entered into with the bank to
augment equity capital, reduce reliance on ratesensitive funding sources and increase core deposits. A budget was to be implemented, major
assets were to be removed from criticized status,
and loans were not to be made to borrowers with
criticized credit. A new senior lending officer was to
be hired. All fees, bonuses, salaries, or remunerations paid to Board members were to be eliminated,
except those to the full-time president, until the
bank's earnings and capital warranted such payments. The validity of certain expense payments
was to be examined and the repayment of all expenses unrelated to the bank's business was to be
secured. The bank was ordered to increase and
maintain adequate reserves for possible loan losses, to eliminate deficiencies in internal control policies, to provide fidelity insurance coverage in the
appropriate amounts, and to fill vacancies on the
Board of Directors. Loans exceeding the lending
limitations were prohibited and excessive loans
were to be reduced.
An Agreement required an outlining of the authority
of the bank's chief executive officer, the removal of
all criticized assets, and the prohibition of loans to
borrowers with criticized credit. The loan valuation
reserve was to be increased, as was the liquidity
percentage, and an adequate capital structure was
to be maintained. The bank was further ordered to
correct the deficiencies in its data processing subsidiary.
An Agreement ordered the appointment of a new
senior loan officer to formulate a plan detailing the
authority and duties of each lending officer. New
loan policies and audit procedures were set forth

providing principles for placing loans on a nonaccrual status, identifying non-marketable loans,
collecting loans, obtaining complete credit information, and treating criticized loans. Loans to insiders
and their interests were to be limited, and were to
require the use of the same terms for all persons.
Removal of assets from criticized status was
ordered and loans to borrowers with criticized credit were to be discontinued. Loans to directors
were to be removed from criticized status and a
report sent to the regional administrator. A policy
was formulated to monitor loans to major stockholders and their families. The bank was instructed to
inform the directors of the status of deficiencies
disclosed by audit and to establish procedures for
treatment of property held in a fiduciary trust.
35. An Agreement required an asset/liability program to
reduce reliance upon rate-sensitive deposits and
borrowed funds, and development of a plan to improve liquidity. The bank agreed not to pay any
dividends unless in conformance with the law and
approved by the regional administrator. Programs
to raise new equity capital, to improve bank earnings and to increase reserves for possible loan losses were required. A review of the written investment
policy was required, with provisions to include income and liquidity considerations as well as a
schedule of desired maturities. All criticized assets
were to be eliminated and loans to borrowers with
criticized credit were forbidden. A real-estate broker
was engaged to review the lease for the bank
branch. The duties of the chief executive officer
were to be detailed and a review made as to the
reasonableness of salaries to executive officers and
fees and services to directors. Violations of specific
sections of law were to be corrected. Unsecured
deposits were prohibited where security was required by law or contract.
36. Because of non-compliance with an outstanding
Agreement, an Amendment to that Agreement was
executed. Several violations of law required correction, including an over-investment in fixed assets. A
new lending officer was required as was a comprehensive program to eliminate internal controls exceptions. Lending to criticized borrowers was
prohibited. Dividends were restricted, reserves for
possible loan losses were augmented and were to
be reviewed quarterly, and the bank's liquidity was
to be improved.
37. A Permanent Order prohibited acquisition by the
bank of any liability for the benefit of a specific
person or his interests. The bank was ordered to
remain within its legal lending limitations, to limit its
loans to its executive officers, andto appoint a new
chief executive officer. Equity capital and liquidity
were to be augmented and rate-sensitive deposits
were to be reduced. The reserve for possible loan
losses was to be reviewed and the compensation
paid to the Board of Directors was to be evaluated.
All criticized assets were to be eliminated from criticized status and no loans were to be made to borrowers with criticized credit. Large lines and con


38.

39.
&
40.

41.

centrations of credit were to be reduced and imperfections in the securing of collateral were to be eliminated. New sound loan and investment policies
were to be formulated and internal control procedures were to be improved.
An Agreement required the appointment of a new
chief executive officer, a compliance committee of
outsiders and an independent attorney. The independent attorney was to study the payments, loans
and bonuses given to the members of the Board of
Directors. Illegitimate payments were to be returned
to the bank. The duties of the executive officer were
to be outlined, and no loans were to be made to the
officers or directors except under the same terms as
for other persons. The expansion of the loan portfolio
was to be controlled. Criticized assets were to be
removed from critical status and no loans were to be
made to borrowers with criticized credit. A new lending policy was to be written and a program to augment the equity of the bank formulated. The loan
policy was ordered revised and the reserve for possible loan losses was to be increased. Deficiencies
in internal control and audit procedures were
ordered corrected by an audit committee.
Following service of a Notice of Charges and a Temporary Order to Cease and Desist on two affiliated
banks, a Permanent Order was issued. The Permanent Order prohibited the banks from acquiring any
obligations from, or extending credit to, specified
persons, their families and interests. Credit terms for
officers were to be the same as for all persons. All
contracts with specified persons were to be reviewed. No loans were permitted to borrowers with
criticized credit and all criticized loans were to be
removed from criticized status. A review of expenses paid to officers and other expenses incurred
by the banks were to be reviewed for reasonableness, and all demand and time accounts maintained
by the banks with other financial institutions were to
be reviewed and closed, if deemed unwarranted.
The reserve for possible loan losses was to be augmented and new equity capital was to be raised. A
sound investment policy was to be written and no
dividends were to be paid without the regional administrator's approval.
Following service of a Notice of Charges and a Temporary Order to Cease and Desist, a Permanent
Order to Cease and Desist was issued against the
bank, removing all authority from the bank's president and requiring a new chief executive officer.
Lending was not to exceed the legal limitations and
all loans in excess were to be reduced. An independent auditor was to be employed to conduct an
audit. An average liquidity level was to be achieved
and capital was to be increased. Dividends were not
to be paid except in conformance with law and the
approval of the regional administrator. Action to
eliminate criticized assets was ordered, and loans to
borrowers with criticized credit were prohibited. A
loan policy was to be written and adhered to and
collateral exceptions were to be corrected. The restructuring or altering of loans was to be limited and
31

42.

43.

44.

45.

32

the procedures defined, and collection efforts were
to be improved.
An Agreement ordered the bank to adopt a written
loan policy of a safe and sound nature. Loans to
insiders were not to contain any preferential terms.
Transactions between the bank and insiders were
allowed only if the terms and conditions were at least
as favorable to the bank as could be obtained from
an independent third party. A written policy defining
in what circumstances depositors would be permitted to draw against uncollected funds and overdraw
accounts was called for. Violations of the legal lending limits were proscribed. The bank was ordered to
assess its relationship with its affiliate concerning
the sale and leaseback of bank equipment and was
ordered to submit its request for approval of a suitable aggregate investment in fixed assets to the
regional administrator. A written investment policy
was to be devised in keeping with the bank's projected liquidity needs.
A Notice of Charges and an Order to Cease and
Desist were entered against the bank. All lending
authority was withdrawn from the bank's president
and a new chief executive officer was required. All
violations of law were to be corrected and reimbursement was required of specific executive officers for interest and charges not assessed against
them on illegal loans and overdrafts. The overdraft
policy was ordered amended and the reserve for
possible loan losses increased. An auditor who was
to report to the regional administrator was to be
retained. Regulatory reports and a capital plan were
to be submitted. No dividends were to be paid unless lawful and approved by the regional administrator. Criticized assets were to be eliminated and no
loans were to be made to borrowers with criticized
credit. Requirements were listed for the granting or
restructuring of loans and the bank's non-accrual
policy was to be altered. Collection efforts were to
be improved.
An Order to Cease and Desist was entered following a Notice of Charges against the bank. The bank
was ordered not to lend beyond the legal limitations,
to remove all loans, and to refrain from extending
further credit to a specific person or his interests. A
new chief executive officer was to be hired and a
compliance committee appointed. Criticized assets
were ordered reduced or eliminated and noninterest expenses were to be controlled. A new loan
policy was to be written and an asset-liability management policy formulated. Dividends were to be
paid only in conformity with the law or with the
approval of the regional administrator. The maintenance of adequate reserves for loan losses was
ordered and a new sound investment policy was
written.
An Agreement stipulated that the bank would not
lend to borrowers with criticized credit or to a specified person or his interests. All criticized assets were
to be eliminated and lending was to be within the
legal limitations. No charged-off assets were to be
rebooked. All recoveries in excess of $5,000 were to




46.

47.

48.

49.

50.

51.

be disclosed, with their sources, to the regional
administrator. A new loan policy was to be written
with a plan to reduce or eliminate unduly risky concentrations of credit. The reserve for possible loan
losses was to be reviewed and a plan to raise equity
capital formulated.
A Notice of Charges and a Temporary Order to
Cease and Desist prohibited the bank from extending credit to any borrower whose loan had been
criticized. Violations of the bank's legal lending
limits, of the bank's powers to hold real property,
and of 12 USC 375a were proscribed.
An Agreement commanded that all directors be informed of 12 USC 84 and be made aware of their
liability for violations of that section. Should a violation occur, the bank was not to suffer any losses. No
loans were to be made in excess of the legal limitation and loans were not to be granted to borrowers
with criticized credit. A loan committee was to be
established to review all loans of $10,000 or more
and to set loan limits. The bank agreed to increase
collection efforts, to discontinue certain practices in
treatment of interest on renewed loans, and to eliminate criticized assets. An audit was required in
order to correct deficiencies in internal control and
audit procedures and to review the reserve for possible loan losses and other areas. No cash dividends were to be paid for 2 years except in conformity with the law and with the approval of the regional administrator.
An Agreement ordered a program to raise equity
capital, improve earnings, and review reserves for
possible loan losses. The bank was forbidden to
accept unsecured deposits of public funds. No
additional loans were permitted to borrowers with
criticized credit. A plan to improve the financial
situation of the bank was ordered to be strictly followed.
An Agreement to correct all violations of law was
entered into with the bank. Deficiencies in internal
control were to be corrected, lines of authority for the
officers were to be drawn, and action was to be
taken on all criticized loans. A new, safe investment
policy was to be adopted and a plan projecting the
future of certain aspects of the bank was to be
formulated. A Committee was ordered appointed to
review the performance of the bank's senior officers.
An Agreement prohibited the acquisition of obligations or extensions of credit to an insider unless
certain conditions were met, and preferential transactions with insiders were forbidden. Independent
directors and a compliance committee to review
correspondent accounts and all extra expenses
paid recently by the bank were to be appointed.
Rules governing correspondent accounts were set
forth. A new lending policy was ordered, with additional scrutiny of extensions to insiders to be
adopted.
An Agreement required the appointment of a new
chief executive officer. Loans were not to exceed the
legal limitations, and those in excess of the limit were
to be reduced. Capital was to be augmented as was

52.

53.

54.

55.

56.
57.
58.
59.
60.
&
61.

62.

the reserve for possible loan losses. The bank was
ordered to take action to eliminate assets from the
criticized list. A loan policy was to be written, with
attention to overdraft handling procedures. Loans
made to directors, officers and major shareholders
were to be on the same terms as to other persons. A
sound investment policy and a budget were to be
formulated. Deficiences in internal control and audit
were to be eliminated.
An Agreement detailed the duties of the chief executive officer, ordered the elimination of all criticized
assets, and limited loans to borrowers with criticized
credit. A review of the loan policy and a strengthening of the capital structure was demanded. A
budget to restore earnings to the bank and an assetliabilities plan were to be written. An audit was
ordered to correct deficiencies in internal audit and
control.
A Permanent Cease and Desist Order limited the
power of a member of the Board. A determined
amount of equity capital was to be added to the
bank's funds and the legal lending limit was not to
be exceeded. Loans to borrowers with criticized
credit were not to be made. A daily liquidity average was ordered. Monthly balance sheets were to
be submitted to the regional administrator.
An Agreement prohibited violations of the bank's
lending limit, required corrective action on outstanding violations, and specified the Board of
Directors' liability for ultimate indemnification of the
bank for losses on illegal loans. A new chief executive officer and senior lending officer were to be
hired and provided with written job descriptions.
After a full audit by an independent auditor, the
bank was to adopt a written internal audit program.
A written lending policy was required and criticized
loans were addressed. Finally, certain technical
changes were required in the trust department.
An Agreement addressed the serious problems the
bank faced with high operating expenses and net
losses for the previous 2 years. A plan to replace $1
million in subordinated debt was required, as was a
program to improve the bank's earnings. Quarterly
reviews of reserves for possible loan losses were
mandated and further extensions of credit to criticized borrowers were prohibited. Collection efforts
were required, as was a review of current management adequacy. Failure to comply with the Agreement within 90 days would require the submission
of alternate proposals, including the possibility of
sale or merger.
Notices of Charges were served on six banks who
had rejected prepared Agreements because they
were unwilling to admit responsibility for violations
of 12 USC 371c. The banks suffered from inadequate capital, very high criticized assets, violations of
law, poor lending practices, and inadequate reserves for possible loan losses. After extensive settlement negotiations but before administrative hearings commenced, the banks converted to state
charters.
An Agreement required the appointment of a new




63.

64.

65.
66.

67.

68.

chief officer and the drafting of a new loan policy
addressing the restructuring of old loans, geographic limitations, and Regulation B compliance. All
criticized assets were to be eliminated and loans to
borrowers with criticized credits were prohibited.
Collection of charged-off assets was instituted. A
review of the reserve for possible loan losses was to
be conducted and a new budget and equity capital
program were to be written.
An Agreement required no further extensions of
credit in violation of the legal lending limit and increased collection efforts to reduce excessive
loans already outstanding. Criticized assets were
addressed and further lending to criticized borrowers was prohibited. A plan to improve earnings and
augment capital was mandated and a new lending
policy was required. Internal controls were addressed and liquidity was to be increased. The reserve
for possible loan losses was to be reviewed quarterly and all violations of law were to be eliminated.
An amended Agreement to correct all violations of
the law was entered into with the bank. The bank
agreed to formulate a program to increase the
earnings of the bank; to maintain asset, deposit,
and net loan ratios below certain levels; and to
improve the capital position of the bank. A review of
the trading account policies and accounting and
control procedures was required. Criticized assets
were to be eliminated and loans to borrowers with
criticized credits were prohibited. An audit was to
be conducted. The reserve for possible loan losses
was to be reviewed and a report on it submitted to
the regional administrator.
An Agreement dealt with lending policy, criticized
assets and reserves for possible loan losses.
An Agreement required restitution by specific insiders, particularly one bank official. The bank's independent auditor was to conduct an investigation
into the scope of the abuses and the Board of
Directors agreed to seek reimbursement. The President resigned and was prohibited from involvement in bank affairs without the specific approval of
this Office. Internal procedures and controls were
adopted to prevent future insider abuses and a
written policy limiting insider borrowing was
adopted.
An Agreement required an increase in the capital
accounts of the bank and a program for assetliability management. Loans and the level of ratesensitive funds were limited, and an oversight committee was appointed to supervise compliance with
this requirement. The bank was prohibited from
acquiring obligations for the benefit of insiders. Criticized assets were to be eliminated and loans to
borrowers with criticized credit were forbidden.
Dividends were not to be paid until the bank had
complied with 12 USC 60 and had received
approval of the regional administrator.
An Agreement required reimbursement of chief executive officer's salary and of any expense item
found to be unrelated to legitimate bank business,
the appointment of a new chief executive officer,
33

correction of lending deficiencies, and adequate
review of the reserve for possible loan losses.
69. An Agreement ordered the bank to immediately
stop paying salary to the Chairman of its Board (the
control owner of the bank) and to take any necessary steps to secure repayment of all salary paid
since June 30, 1977. An independent audit was to
be conducted to examine all the bank's operating
expenses with particular attention to the relationship of expense items to legitimate bank business.
Any expense found to be unrelated to legitimate
bank business was to be repaid by the Chairman or
the Board of Directors, personally. The bank was
advised to make all disclosures required by the
"Truth-in-Lending" Act and to properly distribute
the proceeds of credit life insurance income as
prescribed in 12 CFR 2. Elimination of assets from
criticized status was advocated and extensions of
credit to any borrowers with criticized loans were
proscribed. The Board was to revise the bank's
loan policy to correct all deficiencies, detailing the
conditions under which overdrafts against demand
deposit accounts were to be allowed and prohibiting payment of an overdraft on the account of an
insider of the bank. The Board was ordered to seek
recovery of a $5,000 statutory bad debt of the
bank's President and to implement a program to
maintain the reserve for possible loan losses at an
adequate level.
70. An Agreement required the appointment of a new
chief executive officer and a special committee to
act on behalf of the bank. A new management team
was also to be hired. A written program to augment
equity capital, a sound investment program, and a
budget were to be drafted. The bank was forbidden
to enter into any standby Government National
Mortgage Association forward placement contracts
and was to develop a program for sound and profitable operation. Directors were not to be paid for
attending Board meetings, and the reserve for possible loan losses was to be reviewed.
71. After issuance of a Notice of Charges and a
Temporary Order to Cease and Desist, a Permanent Order to Cease and Desist was consented to
by the bank. The Board of Directors was ordered to
withdraw all responsibilities from the Chairman of
the Board and the President and Chief Executive
Officer. A committee of 3 officers and/or directors
was to be established to act in their stead until a
new chief executive officer could be hired.The
bank was prohibited from acquiring any asset from,
and from extending credit to, the present Chairman
of the Board and the Chief Executive Officer, their
families or business interests. An independent audit of the bank was required to assess the terms
and circumstances surrounding all transactions
entered into during the prior 2 years between the
bank and any of its affiliates, insiders, or insiders'
interests, and to determine the business legitimacy
of all expense items paid by the bank during that
period. A program of audit controls was requested,
as were procedures to ensure that all bank assets,
34



funds and facilities were used solely for the bank's
benefit and not for the personal benefit of any insider. The bank was to be repaid for all expenses
incurred for the personal benefit of insiders. Conflicts of interest were to be prohibited, and insider
transactions circumscribed. Loans to executive
officers were to conform to 12 USC 375a and loans
to affiliates to conform to the lending and collateral
requirements of 12 USC 371c. Conformity with the
Bank Holding Company Act was mandated. Equity
capital was ordered raised by at least $500,000
declaration of dividends was circumscribed, and
an adequate reserve for loan losses was ordered
maintained. The bank was to reduce the level of
delinquent loans and to remove all assets from its
books which had been classified loss in the report
of examination.
72. An Agreement ordered the bank to adopt and
maintain policies and procedures designed to (1)
prevent violations of law, rules and regulations, and
(2) ensure that the preparation of financial statements and reports filed with regulatory agencies
were in conformity with applicable law. The bank
was required to maintain an adequate reserve for
possible loan losses and to account for its "Other
Real Estate Owned" in accordance with applicable
law. The chief executive officer's responsibilities
were required to be set out in detail, with particular
attention paid to strengthening and improving the
efficiency of the bank's internal controls and procedures and to assessing problem loans in the bank's
loan portfolio. Elimination of assets from criticized
status was to be effected and extensions of credit
to any borrower whose loan had been criticized
were proscribed. The bank's latitude in acting as
investment advisor for a publicly held company
was circumscribed, as was the bank's latitude in
declaring dividends. The bank's trust department
was to adhere to sound fiduciary principles. The
bank was required to limit its activities at locations
away from its legally established branches, with
particular attention to be paid to the bank's factoring operation. The bank was required to reduce its
overall dependence on rate-sensitive, volatile liability instruments.
73. An Agreement prohibited a particular Director of
the bank and his interests from having any involvement with the bank or from receiving any benefits
from the bank. All new loan activities were to be
curtailed until a program was designed to improve
the bank's liquidity position. The bank was required
to reduce its dependence on borrowed funds and
volatile deposits, and to implement written guidelines to coordinate and manage the bank's assets
and liabilities. Elimination of assets from criticized
status was required and the declaration of dividends was circumscribed.
74. An Agreement required correction and prevention
of all violations of law, rule or regulation. A new
chief executive officer was to be employed and a
new lending policy formulated. Criticized assets
were to be eliminated, and further lending to bor-

rowers with criticized loans was prohibited. A
budget was required, along with a program to improve earnings and a quarterly review of the reserve for possible loan losses. Equity capital was to
be increased, and comprehensive improvements in
internal controls were to be made. An internal auditor was to be appointed and an annual external
audit was to be required.
75. An Agreement required the employment of a new
chief executive officer and senior lending officer. A
formal plan to improve earnings was required,
along with a comprehensive budget and capital
program. Criticized assets were addressed. New
lending, investment and asset concentration policies were required. The reserve for possible loan
losses was to be reviewed quarterly, and no loans
were permitted to criticized borrowers.
76. Insider abuse by the president, his family, and two
other directors was addressed by an Agreement.
Independent legal counsel was retained to conduct
an investigation to determine the extent of insider
abuse. Upon receiving counsel's report, the Board
of Directors was to take appropriate corrective action. Specific abuses were addressed, such as misuse of expense accounts, market making in the
bank's stock, and insider leasing of bank branch
premises. Internal controls were to be reviewed, as
were internal and external audit procedures. A plan
to monitor the bank's growing dependence on ratesensitive funds and a plan to deal appropriately
with credit life insurance income were required.




77. A Notice of Charges and a Temporary Order to
Cease and Desist prohibited the bank from paying
for any personal travel, entertainment or longdistance telephone expenses incurred by the
bank's president or by any other insider. Acquisition of any loan participation or other asset or extension of credit for the benefit of the bank president
was proscribed. The bank's latitude in declaring
dividends was circumscribed.
78. An Agreement required the bank to engage an
independent auditor to conduct a comprehensive
audit to determine if any loans to insiders were of a
preferential nature and that salaries and fees paid
to insiders were reasonable and not detrimental to
minority shareholders. The bank was then required
to hire an attorney to review the information from the
audit and advise the regional administrator and
Board of Directors of instances where loans or expenses were inappropriately granted. The Board
agreed to assume responsibility for repayment of
expenses so categorized. The bank was also to
adopt a written program to eliminate criticized
assets, to cease lending money or extending credit
to borrowers with criticized credit, to improve and
maintain its liquidity position, to write a fiscal year
1977 report, including a letter explaining the differences between that report and the one originally
sent to shareholders, and to obtain a current
appraisal of real estate it holds as "Other Real
Estate Owned."

35




VI. Fiduciary Activities of National Banks
At year-end 1978, there were 1,763 national banks
engaged in fiduciary activities. Fourteen national banks
received approval to offer trust services during the year.
Nevertheless, the year saw a net decrease of 58 active
national bank trust departments, due to conversions,
mergers, and surrender of fiduciary powers.
The Trust-Examination Division performed 1,011 trust
department examinations and special supervisory examinations during the year. Some of those examinations
were performed in conjunction with examinations of
other areas of the bank. By year-end, 92 percent of all
trust departments had been examined once under the
revised procedures and 13 percent had been examined
under the new procedures for the second time. Those
examinations were performed by a field staff of 14 regional directors for trust operations, 47 national trust
examiners, 34 associate national trust examiners, and
69 assistant national trust examiners. Trust personnel
from six regions performed 54 examinations outside of
their home regions, in an attempt to help all regions
meet the goal of examining every national bank trust
department with the new procedures by December
1978.
A reorganization of the Office of the Comptroller of the
Currency transferred the responsibility for the administration of the Trust Examination Division to the Director
for Trust Examinations, under the supervision of the
Deputy Comptroller for Specialized Examinations. The
correction and clearance of examination report matters
was then decentralized to the 14 regions. That action
was taken to promote greater efficiency and to permit
regional administrators to have supervisory responsibility over all functions of the banks in their regions.
Effective March 16, 1978, 12 CFR 9.7(d) was
amended. That amendment gives regulatory recognition to the established principle of law which prohibits
the use of material inside information in connection with
a purchase or sale of any security. The regulation requires banks to establish written policies and procedures to insure that federal securities laws are complied
with in making any decision or recommendation to purchase or sell any securities. On May 31, the Comptroller
announced the recision of 12 CFR 9.101, 9.102, 9.103
and 9.104. The recision of those sections eliminated the
requirements for national bank trust departments with
holdings of equity securities with a market value of $75
million or more to file quarterly reports of equity transactions and an annual report of equity holdings. The sec-




tions were eliminated to prevent duplication of reporting
requirements between this agency and the Securities
and Exchange Commission (SEC) which adopted requirements that institutional investors file annual and
quarterly reports of equity holdings.
On November 1, 1978, the Comptroller of the Currency, republished for comment a proposed rule concerning recordkeeping and confirmation requirements for
certain transactions effected by national banks. The
proposed amendments would require national banks to
establish uniform procedures and records relating to
the handling of securities transactions for trust department accounts and for customers. The proposed
amendments were, in part, an outgrowth of the recommendations of the Securities and Exchange Commission's Final Report on Bank Securities Activities. The
republication of the proposed rule was issued under 12
CFR 12 in recognition that the proposed rule would not
affect only banks exercising fiduciary powers.
A uniform interagency trust rating system was developed in conjunction with the Board of Governors of
the Federal Reserve System and the Federal Deposit
Insurance Corporation. The rating system evaluates six
critical areas of trust departments' administration and
operations. A composite rating of the overall condition
of the trust department is determined by the sum of the
ratings in the six individual areas. Also, the three regulatory agencies jointly modified the Trust Department
Annual Report. The major modification was to limit the
assets reported to those over which the bank has investment discretion.
In January, all commissioned trust examiners
attended a 4-day school concerning federal securities
laws and regulations. Staff from the Securities and Exchange Commission addressed the group on such subjects as the Securities Act of 1933, the Exchange Act of
1934, and the regulation of registered transfer agents.
During the school, examiners were presented with modifications to the revised examination procedures which
were to be implemented by OCC personnel. The major
modifications to the existing work programs included
the introduction of judgemental sampling, observation
as a method of examination verification, and elimination
of duplicative examination procedures checklist steps.
An extensive securities activities section was added to
the existing examination work program on operations.
The securities activities examination procedures require
verification that the execution of securities transactions
37

are in compliance with federal securities laws and regulations and sound fiduciary principles. Also, an additional work program was added to the examination procedures requiring that every trust department establish
policies, procedures and controls in order to comply
with the various consumer laws and regulations.
A supplement to the Comptroller's Handbook for National Trust Examiners was issued to all trust examiners,
national banks with fiduciary powers, and other
subscribers. The supplement contained all modifications to the examination procedures as well as additional interpretative opinions and revisions to existing opinions in the precedents and opinion section of the Handbook.
In the Trust Continuing Education Program, two Introductory Trust Examiner Schools were held. These 5-day
schools are intended for examiners who have completed 2 to 6 months of on-the-job trust training. The
schools were attended by a total of 27 assistant national
trust examiners. The instructors for the schools were
commissioned trust examiners. During the week of June
12, nine trust examiners from various regions attended
an Interagency Trust Workshop. The primary topics of
that workshop were securities laws and regulations and

38




the Employee Retirement Income Security Act. During
the latter part of the year, four trust examiners were
temporarily assigned to Washington to develop courses
for the Advanced Trust Examiners School. In April, the
Trust Examination Division instituted a program of rotating a field examiner into the division for 6 weeks to
provide assistance to the division and to expose the
field examiner to the workings of the Trust Examination
Division in Washington.
At year-end, 853 banks were registered with this
Office as transfer agents. The activities of national
banks acting as either registered or non-registered
transfer agents are regulated through examination procedures and through the rules of the Securities and
Exchange Commission. The Comptroller of the Currency, in conjunction with the Securities and Exchange
Commission, the Board of Governors of the Federal
Reserve System, and the Federal Deposit Insurance
Corporation, has initiated a program of joint examinations of registered transfer agent servicers. That program should result in savings to the agencies and a
reduction of the overlapping regulation of registered
transfer agent servicers, in keeping with the spirit of the
Securities Reform Act of 1975.

VII. International Banking and Finance
World output and trade continued to increase in 1978
after the most severe recession since the 1930's, but
recovery in the domestic economies of the industrial
world remained hesitant except in the United States.
Unemployment persisted and, despite some easing in
Europe and Japan, high rates of inflation continued to
impair economic performance in many industrial and
primary producer countries. Inequalities in rates of economic growth and inflation, especially between the United States and several other major industrial countries,
led to a maldistribution of current account balances
among major industrial countries, instability in exchange markets, and depreciation of the U.S. dollar
during 1978. Inflation and depreciation of the dollar
caused the United States to implement policies of
monetary and fiscal restraint and to take action to quell
exchange market disturbances. Europe and Japan implemented economic recovery programs during 1978
which, combined with the gradual U.S. economic slowdown and the resultant cut in the American trade deficit
and inflation rate, could increase world trade and stabilize world currency values. In the prevailing inflationary
environment, however, industrial countries fear expansionary policies might fuel further inflation.
Following the late 1973 oil price increases, impetus to
increased international business by commercial banks
was provided by (1) OPEC countries' investment in the
international banking system, especially in the Eurocurrency market and (2) the increase in oil-importing countries' balance of payments financing needs. More recently, the decline in the OPEC countries' current payments surpluses and in the total payments deficits of
oil-importing countries outside the United States
changed that situation. By 1978, the oil-importing countries had switched from balance of payments financing
to borrowing for increasing their monetary reserves. The
OPEC countries have been replaced as the main
source of funds by several industrial countries where
the continuing low economic growth has meant increased commercial bank liquidity and moderate
domestic credit demands. Such countries have been
looking more to the international sector for profitable
outlets. That, along with the international liquidity created by the U.S.'s current payments deficits in 1977 and
1978, has led to a "borrower's market" for international
banking funds.
The Office of the Comptroller of the Currency has
been confronted with the resultant growth in national




banks' foreign assets/deposits/earnings/foreign exchange activities, their substantial lending to foreign
public sector borrowers and the problem of the applicability of statutory lending limits to such credits.
At year-end 1978, foreign loans of United States
banks and bank holding companies aggregated $217
billion. Sixty-three percent of that total represented
credit extensions to borrowers in industrialized developed countries and offshore banking centers. Credits to borrowers in non-oil producing, developing nations totaled $52 billion, or 24 percent of the total. By the
end of 1978, the international assets of national banks
were $182 billion, up 14 percent from $160 billion on
December 31, 1977. Total assets of the 646 foreign
branches of national banks aggregated $181 billion, a
12 percent increase over the $162 billion held at the end
of 1977.
The International Examinations Division of the Office
of the Comptroller of the Currency is delegated the
responsibility of supervising the international activities
of national banks. The Office's primary supervisory tool
is the bank examination function. Examinations of international divisions, foreign branches and foreign affiliates are especially tailored to the organizational, geographical and reporting structure of the banks under
examination. Examiners evaluate the quality of international loan and investment portfolios and analyze foreign exchange activities, reporting procedures,
accounting and bookkeeping systems, and the adequacy of internal controls and audit programs. During
1978, approximately 175 national bank examiners participated in examinations of international banking divisions in the 14 regions. Over the same period, 142
examiners traveled to 19 countries to examine 61 foreign branches. The assets of the other foreign branches,
including "shell" branches, were examined using records maintained at the banks' head offices or elsewhere. Three foreign subsidiaries and ten electronic
data processing centers were examined on-site. The
Office maintains a permanent staff of six examiners in
London who are responsible for continuously supervising the activities of the branches of 26 national banks
located there.
In late 1978, the Comptroller's Office, the Federal
Reserve Board and the Federal Deposit Insurance Corporation adopted uniform procedures for evaluating
and commenting on "country risk" factors in international lending by U.S. banks. Under the new system, to be
39

implemented in early 1979, examiners from the three
agencies will segregate country risk factors from the
evaluation of other lending risks, and deal with this
special cateory of lending risks in a separate section of
their examination reports. The commercial credit risks in
the banks' international portfolios will continue to be
assessed on an individual loan basis according to "traditional" standards of credit analysis. A key element in
the new procedures is the assessment of bank management's ability to analyze and monitor country risk in its
international lending. The procedures will be incorporated in the Comptroller's Handbook for National Bank
Examiners during 1979.
The International Banking Act, passed by the Congress in late 1978, is expected to have a profound
impact on OCC operations, including the International
Examinations Division. The effects of the Act on the
Comptroller's international activities will be in the areas
of licensing, supervision and regulation of foreign
banks' federal branches and agencies; foreign directors; registration of representative offices; and regulatory studies.
During 1978, the three bank regulatory agencies
further refined the joint, semiannual, Consolidated
Country Exposure Reports which show, by country, the
foreign claims held by U.S. banks and bank holding
companies. Information from those reports facilitates
the systematic monitoring of overseas lending by U.S.
banks. The monthly Foreign Currency Report continued
to be used by the International Examinations Division to
monitor the foreign exchange trading activities of national banks.
The training of international examiners received major
emphasis during 1978 with three training schools conducted by the International Examinations Division in
Washington, D.C. The subjects of the schools were
international banking and foreign exchange. The Division conducted a basic training school in international
banking for Federal Deposit Insurance Corporation examiners in November 1978. The first international banking training school under the Office's continuing education program was piloted in December 1978 and more
courses will be incorporated into the program during
1979.
To keep field examiners and other staff informed, the
International Examinations Division prepared and circulated the twice-monthly "International Report" contain-

40




ing news articles and other reference data. The Report
was mailed to approximately 300 national bank examiners in all 14 regions as well as to members of Congress
and selected staff of the Comptroller's Office, the Federal Reserve System, the Federal Deposit Insurance Corporation and the Treasury. Division staff participated in
outside international conferences and seminars held in
London, New York and Philadelphia. The Office was
also represented at the 1978 annual meeting of the
Bankers' Association for Foreign Trade.
The Division arranged for examiners to attend outside
seminars and schools on international banking. Those
schools included the Colgate Darden Graduate School/
Bankers' Association for Foreign Trade international
lending seminars, various Robert Morris Associates international workshops, and the American Bankers
Association's School for International Banking at the
University of Colorado.
Throughout 1978, the International Examinations Division represented the Office on international banking
matters with other U.S. government departments and
agencies, foreign bank supervisors, Congressional staff
members, private agencies and American and foreign
bankers. The International Examinations Division continued to work closely with the Congress, the Federal
Deposit Insurance Corporation, the Federal Reserve
System, the Bankers' Association for Foreign Trade,
and foreign officials and bankers to strengthen the quality and supervision of the national banking system
throughout the world by improving both supervisory
techniques and communications among the regulatory
agencies, bankers and foreign governments. A noteworthy example of that interaction occurred in early
1978, when Comptroller John Heimann became the first
Comptroller of the Currency to join the Cooke Committee, an international association of bank regulators
headquartered in Basel, Switzerland. The Committee
(formally referred to as the Bank for International Settlements Committee on Banking Regulations and Supervisory Practices) meets several times each year to discuss problems of bank solvency and liquidity and bank/
supervisory regulation and practices. Also, during
1978, under an agreement with the International Monetary Fund (IMF), the Comptroller's Office provided, on a
temporary basis, examiners for the IMF's technical
assistance programs in Bolivia and Nicaragua.

Table 12
Examinations of overseas branches, subsidiaries, and EDP centers of national banks, 1972-1978
Year

Examinations

Banks

4
3
4
15
13
2
10

Examiners

24
28
26
25
37
20
19

58
59
96
153
215
101
142

EDP centers

184
92
137
80
145
60
64

Countries

16
22
23
23
25
25
26

Branches and
subsidiaries
1972
1973
1974
1975
1976
1977
1978

Table 13
Outstanding external currency claims of U.S. banks on foreign borrowers, December 31, 1978
(Dollars in billions)
By residence of borrower

Type of country

Banks

Other
Public
Borrowers

Total

Percent of
Total

8.8

$ 27.4

$103.6

47.7

14.4
12.2
9.7
2.4
1.0

5.1
6.1
11.8
2.6
1.5

7.1
10.6
9.3
4.4
1.2

26.6
28.9
30.8
9.4
3.7

12.3
13.3
14.2
4.3
1.7

Oil exporting surplus

1.6

0.7

1.0

3.3

1.5

Centrally planned

2.9

1.9

0.4

5.2

2.4

4.9

0.4

2.6

38.9

0.3
61.7

5.6

116.5
53.7

217.1

100.0

17.9

28.4

100.0

Industrialized
Developing, by income group:
High income
Upper middle income
Middle income
Lower middle income
Low income

Other
Total
Percent of total claims




$ 67.4

$

Other
Private
Borrowers

41

VIII. Administration
The Administration Department is responsible for providing a range of administrative services which support
the on-going functions of the Office of the Comptroller of
the Currency. The Department is headed by the Deputy
Comptroller for Administration and is divided into five
primary operating divisions — Equal Employment
Opportunity, Finance and Administration, Human Resources, Operations Planning and Systems and Data
Processing.

Equal Employment Opportunity (EEO)
Two additional EEO counselors were appointed and
trained for the Washington Office. Due to the increase in
the number of formal complaints, two investigators were
also appointed.
An indepth analysis of the OCC work force was conducted in January 1978 to identify areas where underrepresentation of minorities and women exist. Regional
Administrators, department heads and division directors were provided with a copy of the analysis and, as a
result, set hiring projections and promotion goals in
underrepresented areas. A comprehensive listing consisting of various minority organizations and media
(newspapers, radio and television) throughout the United States was distributed tq all regional directors of
human resources, the National Recruitment Coordinator
and the manager of Minority and Special Emphasis
Programs.
A quarterly analysis of all regional ceiling and turnover reports was conducted. Results were used to set
hiring projections for 1979-80.
An EEO training program was developed for managers and supervisors in the Washington Office and was
sent to the regional offices to be used as a guideline for
apprising regional employees of the EEO function at
regional staff conferences.
Preliminary guidelines on the discrimination complaint processing system were developed to revise and
up-date Administrative Circular 41. Issuance of these
guidelines has been temporarily delayed because of
the change anticipated by the Treasury Department as
a result of the Civil Service Reform Act which transferred
this function to EEOC.
Four formal complaints were filed in 1978. Three
alleged race discrimination and one alleged age discrimination. Two of the race discrimination complaints
were resolved informally, one is pending, and the age




complaint was remanded to the EEO Counselor for informal processing.
Three formal complaints filed in the later part of 1977
alleged race, sex, and national origin discrimination.
Those cases were carried over in 1978 to complete
processing. The reports of investigation on those three
complaints did not substantiate the allegations of
discrimination. Two employees appealed to the Treasury Department for a decision without a hearing. The
Treasury concurred with OCC findings. One employee
refused to accept the final disposition offered by OCC
because the offer was made with a finding of no discrimination. That employee elected to resign.

Finance and Administration
The Finance and Administration Division is responsible
for promoting maximum utilization of the Office of the
Comptroller of the Currency's financial and physical
resources such as accounting, budgeting, contracting
and procurement, office space management and leasing, records and reports management, and distribution
and administrative services. The division consists of
four branches — Financial Management, Procurement
and Contracting, Distribution Services and Administrative Services.
The Financial Management Branch develops policy
for and directs Office fiscal and budgetary operations.
In 1978, that branch further refined the computer-based
financial information system (FIS) which relies on the
concept of cost center responsibility accounting. The
system provided managers with timely financial information to use in analyzing and controlling the costs of
their operations.
The computerized budget monitoring system, which
provides each organization with monthly budget performance reports comparing actual versus budgeted
expenses by individual expense account, was further
refined by financial management in 1978. The system
helped increase managers' awareness of the need to
control expenses by identifying potential cost saving
areas.
The second year's experience under the Office's new
budget process was very satisfactory. Actual expenses for 1978 were 0.5 percent under budget.
The Procurement and Contracting Branch is responsible for purchasing goods and services for the
Washington Office as well as the 14 regional offices.

43

During 1978, the branch substantially increased its
minority contracting in accordance with the federal government's policy to provide more government business
to minority firms.
In 1978, an internal requisition control system was
established to monitor the status of requisitions from the
date of receipt to issuance of purchase orders. That
management tool insures that the status of any requisition may be readily ascertained.
Procurement and contracting also installed a microfilm cassette system to provide ready access to all
government-wide General Services Administration
schedules. That system provides the Office with up-todate ordering information.
The Distribution Services Branch provides printing
and supply operations and mail and messenger services for the Office. The branch continued consolidating
mailings and improved folding procedures in 1978 to
avoid increased postal costs. A new folder-inserter
should allow automated mailings of circulars, speeches
and bulletins and, thus, reduce postal costs in 1979.
The Administrative Services Branch consists of two
sections — Facilities Management and Publications
and Records Management.
In 1978, the Facilities Management Section directed
several construction management and space design
projects to renovate and relocate several Washington
headquarters departments. The section also implemented new Washington Office security procedures
and a new parking policy which reduced parking expenses and improved parking availability.
The Publications and Records Section coordinated
the printing and distribution of Office manuals, such as
the Comptroller's handbooks for national bank examiners and trust examiners. The section also headed a task
force to analyze regional word processing requirements
and to propose equipment which will be implemented in
1979. During 1978, Publications and Records developed a monthly reporting system to provide senior
management with information to enable them to monitor
the status of certain bank supervision, financial and
administrative activities.

Human Resources Division
The Human Resources Division continued the successful implementation of the human resources programs
approved by the Department of the Treasury in January
1977. Major accomplishments were made in the areas
of personnel development, compensation, staff analysis, national recruitment, employee relations and staffing and operations.
During 1978, 77 training sessions were conducted by
the Human Resources Division. Over 2,100 Washington
and regional participants attended courses in bank examination policies and procedures, supervisory and
management development, instructor training techniques, report writing and clerical skills.
The following new programs were developed:
• Regional ANBE Examining School (Level I)
• Basic International Examining School (Level II)
• Electronic Data Processing School (Level II)
• Financial Analysis School (Level III)
44




• Advanced Trust Examiners School (Level III)
• ANBE School for Advanced Study — Revised
(Level V)
• OCC Management Seminar (Level VI)
• Put-It-In-Writing Workshop
• Supervisory Development Seminar
• Career Development Program for Secretaries
The Compensation Program is to determine, for each
professional, administrative and managerial position, a
salary level which is competitive with the financial community and is equitable relative to other positions in
OCC. During 1978, activities toward that goal included
a survey of over 600 professional, administrative and
managerial positions from which descriptions were prepared for the more than 24 distinct jobs identified. A
point factor evaluation plan for rating covered positions
was also completed. That plan was applied to all of the
jobs in the survey and preliminary evaluations were
submitted to the line management committee for review.
A salary survey of positions in national banks, other
federal regulatory agencies, Federal Reserve District
Banks, major accounting firms and state bank regulatory agencies was also completed. Preliminary analysis
of all salary data gathered was completed to be used as
a base for a new salary schedule.
Policy implementation issues were identified and are
being developed into a work plan to complete the Salary Administration Program.
The Human Resources Information System (HRIS) is
a computer-based system designed to provide OCC
management with accurate and timely personnel information, including data on employee skills, experience
and training and on applicant, project, and position
history. A system for retrieving information stored in the
Treasury Payroll/Personnel Information System (TPPIS)
was installed in 1978.
Over 400 highly qualified individuals were successfully recruited to fill bank examiner positions during
1978. Increased emphasis was placed on minority recruitment and hiring. Several steps were taken to increase the number of minority, female, handicapped
and veteran applicants for OCC positions. Those steps
included development of a comprehensive minority and
female recruitment plan, increased advertising in minority sponsored publications, and recruitment trips to key
minority organizations and educational institutions. Also
during 1978, the position of Manager, Minority and Special Emphasis Programs was established to promote
minority recruitment, career development for lower level
employees and other special programs.
The OCC Career Development Program proceeded
in 1978 with the development of policies for Career
Development Levels I and II which were then formally
issued. Regional and Washington panels met and
selected 23 participants for the 1978 Career Development Level II Program. Those individuals are being developed for future managerial positions with the OCC.
The Human Resources Division assisted management with the several reorganization plans. Among
those were the proposal and the subsequent implementation of the Washington Office reorganization, the reorganization of the OCC's regional structure and the elimi-

nation of several subregions, and the restructuring of
several Washington divisions and one regional office.
Personnel services to managers and employees
throughout OCC were increased and expanded in all
areas of Human Resources during 1978. The Staffing
and Operations Group developed new procedures designed to provide the most responsive service possible.
They include a Status of Request for Personnel Action
Form to provide regional offices with status reports on
personnel actions being processed through TPPIS.
Staffing and Operations has also established a highly
proficient clerical pool to answer temporary needs
throughout the Washington Office during peak work
periods and to provide a source for filling vacant positions. During 1978, liaison between Staffing and Operations and the Office of Personnel Management (Civil
Service Commission) improved the quality of candidate
referral requests.
Recruitment and processing activities for 1978 were
extremely heavy. Washington vacancies announced
and merit staffed totaled approximately 180. A plan for
matching applicant skills to job requirements has been
developed. The plan is based on identifying abilities
and experience necessary for successful performance
in a position and determining the degree to which each
candidate has demonstrated those capabilities.
During 1978, 54 special achievement, 127 high quality, 41 Gallatin, and 6 suggestion awards were reviewed,
evaluated and processed.
The OCC Cooperative Education Program was revised in 1978. The new program emphasizes recruitment of minorities and females, formal and on-the-job
training for developing assistant national bank examiners, and closer relationships with colleges and universities. Implementation of a Washington Cooperative Education Program is planned for 1979.

Operations Planning
In early 1978, the operations planning staff was given a
mandate to integrate planning with budgeting, to simplify the planning process and to reduce paperwork
submissions required of planning units.
Working with a newly-established planning/budget integration committee, the planning staff revised the planning process to include budgeting which, for the first
time, permitted OCC managers to address OCC operations both functionally and organizationally. A combined
planning/budget calendar was established for the entire
year and one of the first major projects was an immediate and extensive review of OCC policy objectives,
operating goals and administrative assumptions by the
operations planning refinement committee. That led to
the proposal for minimum standards of planning response for the national banking regions and subsequent approval by senior management of uniform regional performance targets. Another major project was
the early development of formats, programs and reports
for automation of the planning process to permit presentation of OCC-wide plans to senior management in
complete, manageable form.
The operations planning staff joined with task forces
of representatives of Finance and Administration, other



headquarters units and two regions to develop materials for and lead planning budget workshops, one for
planning officials from the regions, the other for
Washington personnel. The Washington task force
addressed OCC operating goals and its recommendation that the unwieldly 109 goals be reduced to 35 was
approved.
The Operations Planning Division's decision to segment plan submissions into two phases (one for 3 full
years in the future, another for a later-developed
quarterized current year plan) brought about more
realistic planning, because of improved top-down action in establishing operating goals and performance
targets for 3 years ahead.
The first integrated and automated OCC consolidated
plan was delivered to Planning and Budget Review
Committee members on July 24. It was accompanied
by an analysis of major advantages and disadvantages
facing the OCC and, among other things, an analysis of
projected workday and expense needs for every planning unit by each operating goal and performance
target and for all examination-related functions.
The division also played substantial roles in other
major office programs. One staff member devoted
approximately 50 percent of his time to liaison with the
General Accounting Office staff which is auditing OCC
operations and procedures. Another staff member
assisted in development of a manual system for tracking examinations planned and completed, by type and
priority, for each region.
The planning cycle and portions of the planning
guide were revised to reflect changes to OCC organizational structure, titles and operational channels, and
much time was spent assisting the Human Resources
Division in developing the proposed time reporting system for the pilot project to start early in 1979. Operations
planning also provided the ZBB task force with the
review and evaluation of zero-based budgeting materials, which led to the adoption of a functional rather
than organizational format, thus keeping ZBB decision
packages to a minimum.

Systems and Data Processing
During 1978, national bank call reports were successfully processed and NBSS bank performance reports
were provided on time to all OCC regions and national
banks during the four quarters of 1978. Bank performance reports were also produced for the Federal Reserve System and, during the last two quarters of 1978,
for state banks in New York and Virginia.
In the face of increasing ADP requirements, the Systems and Data Processing Division was successful in
consistently reducing costs. Specific areas of reduction
include:
• An automated fiscal system was developed and
implemented to allow the release of all tab card
equipment, thus resulting in annual savings of
$17,000.
• A new, more efficient terminal configuration was
designed and implemented which will result in
annual savings of approximately $9,000.
45

• Efforts to reduce our regulatory data base were
successful and will result in annual savings of
approximately $37,000.
• A volume discount program was negotiated with
our major ADP contractor which will result in
annual savings of approximately $24,000.
• Competitive selection of new data entry support
was accomplished and will result in annual savings of approximately $20,000.
• Efforts to reduce magnetic tape storage at our
major ADP contractor were successful and will
result in annual savings of approximately
$72,000.
A Request for Proposals concerning a study of feasibility of merging OCC and FDIC ADP support was prepared and issued to interested vendors. Continued
efforts in this area may eventually result in the merger of
OCC and FDIC ADP functions.
The division continued to assist other areas of the

46




OCC in automating systems. An automated system for
tracking corporate transactions was designed and developed for the Bank Organization and Structure Division. An automated planning system was developed
and implemented. That system will support the integration of planning and budgeting functions for the Office.
A system for controlling the flow of staff work in Human
Resources was designed and implemented, and an
automated Statistical Data Sheet system which produces past and present bank examination data for national bank examiners was designed and implemented.
The division also provided management support in
several areas. The "Revenue Study Task Force Report"
identifying various OCC revenue sources was completed and presented to the Deputy Comptroller for
Operations and a comprehensive study concerning the
proper functions and placement of management analysis was completed for the Deputy Comptroller for
Administration.

IX. Customer and Community Programs
In the 1978-79 reorganization of the Office of the
Comptroller of the Currency (OCC), consumer affairs
activities were expanded and restructured into three
divisions headed by the Deputy Comptroller for Customer and Community Programs.
The Consumer, Community and Fair Lending Examinations Division (CCFLED) is responsible for all examination-related activities in the areas of consumer protection, community lending and civil rights. The CCFLED
coordinates and supervises the OCC consumer compliance examination program, which includes the Community Reinvestment Act, the Equal Credit Opportunity
Act, the Truth in Lending Act, the Fair Housing Act, etc.
Other functions of the CCFLED include consumer complaint resolution, examination report review and analysis, corrective action, consumer examiner training and
banker education.
The Customer Programs Division was established, but
not fully operational, in 1978. That division is responsible
for developing and implementing consumer and civil
rights programs outside of the examination process. It is
oriented toward policy development on issues, conveying such OCC policy to outside groups through a
continuing liaison function. Consumer education is
another primary role of the Customer Programs Division.
The third division, the Community Development Division, parallels the Customer Programs Division and concentrates on community lending. That new division will
develop and operate programs designed to promote
community lending by national banks. Through this division, information and assistance will be available to national banks for increasing and improving their community lending activities. Coordination of the Commercial
Reinvestment Task Force and the Minority Bank Program will be within the purview of the Community Development Division.
In addition to the three formalized divisions, a position
of Special Assistant for Civil Rights has been created.
The primary functions of that position are oversight of
OCC efforts to comply with the terms of the Fair Housing
suit settlement, initiation of policies and programs to
strengthen OCC's enforcement of civil rights, and liaison
with civil rights organizations.

Legislation
Two bills concerning consumer protection in the financial area were enacted in late 1978 — The Electronic
Fund Transfer Act (EFTA) and the Right to Financial




Privacy Act. EFTA, Title IX of the Consumer Credit Protection Act, provides a basic framework establishing the
rights, liabilities and responsibilities of consumers in relation to electronic fund transfer systems. EFTA sets forth
certain requirements for disclosure, receipts, error resolution and consumer liability for unauthorized use. The
Board of Governors of the Federal Reserve System has
been given authority to write regulations to implement
the Act (Regulation E). The Right to Financial Privacy Act
is intended to protect customers of financial institutions
from unwarranted access to their financial records by
the federal government. Financial institutions may not
provide any financial records of consumers to any federal government agency unless the agency has certified
that it has followed the prescribed legal procedures and
consumer notification requirements.
Uniform regulations were issued on November 6,1978
implementing the Community Reinvestment Act of 1977
(CRA). The regulations, published by the OCC, Federal
Reserve Board (FRB), Federal Home Loan Bank Board
(FHLBB), and Federal Deposit Insurance Corporation
(FDIC), are identical in their substantive provisions, but
contain technical and procedural variations to accommodate functional differences among the types of institutions regulated. Before issuing the regulations, the
agencies held a series of CRA hearings in six cities to
obtain input from interested persons. Bankers, consumers, attorneys and public interest groups testified on how
the CRA should be implemented and enforced. Uniform
examination procedures were also developed by the
agencies which formalized a CRA performance assessment for all financial institutions.
The Fair Debt Collection Practices Act (15 USC 1692
et seq.), signed into law on September 20, 1977, became effective on March 20, 1978. An interagency task
force including representatives from the OCC, FDIC,
and FRB was established to develop a uniform approach
to enforcement of the Act. A joint release was sent to all
banks presenting the Act in a clear and informative manner. The release included a fact sheet, question and
answer summary, and copy of the statute.
The Joint Notice of Statement of Enforcement Policy of
the Truth in Lending Act and Regulation Z (Guidelines)
were signed in December 1978, by the OCC and the
other four federal financial regulatory agencies. The
Guidelines are designed to address the most common
substantive violations of the regulation and to correct the
conditions resulting from violations such as miscalcu47

lated annual percentage rates. The Guidelines call for
reimbursement to consumers for overcharges of $1 or
more, or for smaller overcharges which are part of a
pattern or which result from willful noncompliance. The
Guidelines establish a minimum standard for corrective
action and in no way preclude any of the agencies from
taking enforcement action for violations not covered by
the Guidelines. Under the final Guidelines, creditors may
use either a lump sum or lump sum/payment reduction
method of reimbursement.
In June 1978, the five financial regulatory agencies,
including the OCC, proposed uniform guidelines for the
enforcement of the Equal Credit Opportunity Act, Regulation B, and the Fair Housing Act. The proposed guidelines require creditors who are found to be in violation of
any of those laws to take certain actions to redress
consumers who have been adversely affected. For example, a creditor who illegally required a co-signer on a
prohibited basis would be required to offer to release
any unnecessary co-signer from liability. As of the end of
1978, the agencies were in the process of redrafting the
guidelines in response to suggestions received during
the comment period.

Consumer, Community and Fair Lending
Examinations Division (CCFLED)
The CCFLED administers the OCC's consumer compliance examination program. Every national bank receives a periodic consumer examination. Approximately
1,767 such examinations were conducted in 1978.
In the fall and spring of each year, OCC conducts
three 2-week consumer examiner training schools. In
1978, approximately 300 examiners were trained. Also,
representatives from trade associations, consumer
groups and other federal and state regulatory agencies
were invited to attend the schools. At any time, about
150, or 6 percent of the examining force, are actively
conducting consumer examinations. Examiners spend
6 months in the consumer program before returning to
commercial examinations. A consumer career path has
been proposed which, when finalized in 1979, will allow
examiners to remain in the consumer examination program and advance in salary and position up to Regional
Director of Customer and Community Programs. Examiner training relies extensively on lectures, case studies, problem-solving techniques and examination procedures.
Through the consumer complaint resolution process,
the OCC is able to both assist individuals with bankrelated problems and detect areas of noncompliance. In
1978, 11,319 written complaints were received. That
represents a 34 percent increase in written complaints
over the 1977 total. It is estimated that a comparable
number of walk-in and telephone complaints or inquiries
were also received.
The complaint resolution function is operated in the
Washington Office and the 14 regional offices. Upon
receipt of a written complaint, an inquiry is made by
either an attorney or a paralegal. An acknowledgment is
immediately sent to the consumer notifying him or her of
receipt of the complaint. The bank against which the
48




complaint has been made is contacted by letter and
asked for information and documentation. If necessary,
an examiner will be assigned to visit the bank to investigate the matter further. The consumer is notified in writing of the results of our investigation. Since late 1978,
most complaints received in the Washington office have
been referred to the regional offices. The only exceptions are complaints referred by Congress and complaints which appeal the decisions of the regional
offices.
All complaints are entered into an automated system,
the Consumer Complaint Information System (CCIS),
which categorizes complaint information by region and
bank, type of complaint and resolution. Monthly CCIS
reports are used by Washington and regional personnel
to identify banks with concentrations of complaints and
to monitor unresolved complaints. That information is
also forwarded to consumer examiners to use as an
examination tool indicating potential problems in banks.
In 1978, the Comptroller's consumer complaint pamphlet was introduced. The pamphlet, entitled "Do You
Have a Complaint Against a National Bank?" was designed to help consumers notify the OCC about any
problems they have with national banks. The pamphlet
begins with an explanation of how to resolve a complaint
and includes a summary of some consumer credit protection and civil rights laws. Consumers are encouraged
to first contact the bank and discuss their complaint. If
the bank fails to resolve the problem, the consumer is
then encouraged to use the attached form to notify the
nearest OCC regional office. The complaint form includes a postage-paid mailing envelope. The form asks
for pertinent information about the bank and the consumer. Comment was solicited from banks, consumer
groups and state and local government agencies before the final pamphlet was issued. The Comptroller
announced the availability of the complaint pamphlet to
national banks and urged them to display the pamphlets in their lobbies.
Special Fair Housing investigations are conducted by
OCC examiners if an allegation of discrimination involving housing credit is made against a national bank. Such
an investigation may be precipitated by a consumer
complaint or a regular consumer examination report
which has uncovered a potential discrimination problem. Special procedures have been developed for such
investigations.
Another function of this division is the education of
bankers in consumer credit protection, community and
fair lending laws. In 1978, representatives of the OCC
participated in a number of educational programs for
bankers. In June and August, OCC staff led compliance
seminars on all facets of consumer compliance at three
industry-sponsored graduate schools of banking. In
addition, the OCC and the other bank regulatory agencies, participated in Consumer Compliance Workshops
for bankers sponsored by the American Bankers Association (ABA) in May and November. The eight workshops were all well received and attended by over 1,800
bankers. Most of the educational materials distributed at
the workshops were prepared by the OCC. Throughout
the year, regional consumer specialists spoke to bank-

ing and consumer groups on various consumer topics
and regularly represent the OCC as sources of guidance
and information.
In November 1978, the ABA, in conjunction with the
OCC, published Consumer Compliance: a Sourcebook
of Materials and References for use in the November
ABA Workshops. The Sourcebook contains educational
materials, case studies and compliance aids supplied
by the Consumer, Community and Fair Lending Examinations Division. The OCC also provided substantial
assistance to the Consumer Bankers Association (CBA)
in the development of a banker's manual entitled, Most
Common Violations Found in the Consumer Compliance
Examination and How to Correct Them. CBA also published a manual, supplied by the OCC, entitled Computational Procedures, for bankers to use in computing
and verifying annual percentage rates and other Regulation Z disclosures.
The division keeps field examiners and national banks
up to date on new and changing legislation and regulations. In 1978, banking circulars were issued on the Fair
Debt Collection Practices Act, the Flood Disaster Protection Act and the Community Reinvestment Act.
The OCC regularly participates in two federal interagency consumer education groups, the Federal Interagency Council on Citizen Participation and Consumer Education and Information Liaison (CEIL). During regularly scheduled meetings, representatives from the
various agencies discuss ways to improve input into
agency decision-making and how agencies can improve their services to consumers.

Customer Programs Division
The primary function of the Customer Programs Division
is to ensure that consumer interests and concerns are
represented and considered in the OCC's policy making
decisions. During the latter part of 1978, the Customer
Programs Division was involved in the interagency
groups on Fair Lending Enforcement Guidelines, Regulation Z Enforcement Guidelines, and Regulation E
(EFTA). The division has represented the Comptroller at
many consumer and industry group conferences and
meetings.

means by encouraging banks and community groups to
work together. Since its inception it has:
• Made information available to a number of banks,
community groups and government agencies on
ways of increasing their community lending activities.
• Developed and maintained liaison with the banking community, state and local officials, federal
agencies, community groups and others interested in increasing community lending by national banks, with the goal of promoting dialogues
and working partnerships among those parties.
• Reviewed proposals of banks wishing to create
community development corporations, and
established a system for the receipt of quarterly
reports on their activities.
• Reviewed and commented on housing and community development programs of other financial
institutions and other agencies of the federal government.
• Coordinated the activities of the Commercial
Reinvestment Task Force, of which the Comptroller of the Currency is Chairman.

Special Assistant for Civil Rights
The Civil Rights function was established to coordinate
and monitor the OCC fair lending enforcement programs. One of the first projects undertaken was a data
collection and analysis system. That system, when finalized in 1979, will be a substitute monitoring program
under Regulation B, 12 CFR 2O2.l3(d).
The system is expected to generate information on
applicants and property characteristics which will assist
this office in enforcing the Fair Housing and Equal Credit
Opportunity Acts. The Special Assistant conducted a
number of preliminary studies to help establish the system. First, home loan data was collected from two banks
and analyzed on an experimental basis. Second, cost
analyses were conducted to help determine the actual
cost of the system to national banks. Third, a survey was
conducted to collect information about variations in processing home loan applications and underwriting criteria within the industry.

Community Development Division
The Community Development Division attempts to foster
urban and rural redevelopment through non-regulatory




49

X. Financial Operations of the Office of the
Comptroller of the Currency
Total revenue of the Office of the Comptroller of the
Currency for 1978 was $95.7 million, an increase of 9.0
percent over 1977, which compares to a 6.1 percent
increase the previous year. Assessment receipts, which
account for 92 percent of total revenue, amounted to
$88.0 million, an increase of $7.1 million due principally
to an increase in national bank assets. Revenue from
trust examinations totaled $3.0 million, an increase of
$222 thousand. Revenue from applications for new charters and new branches increased by $67 thousand and
$43 thousand, respectively. Fees for special supervisory
examinations, affiliate examinations and mergers and
consolidations declined $32 thousand, $32 thousand,
and $66 thousand, respectively. Interest on investments
increased $666 thousand, a rise of 24.7 percent, to total
$3.4 million. The other revenue categories remained at
substantially the same levels as in 1977.
Total expenses amounted to $92.7 million, compared
to $83.9 million in 1977. That is an increase of $8.8 million
or 10.4 percent, over 1977.
Salaries, personnel benefits and travel expenses
amounted to $78.4 million, or 84.5 percent of total ex-




penses for the year. Those three expenses amounted to
$70.1 million in 1977. Salary increases were caused by a
full year under the govemmentwide general pay increase of 7.05 percent, effective October 1977, another
general pay increase of 5.5 percent, effective October
1978, and an increase in our examining staff and support
personnel. Travel expenses totaled $11.6 million, an increase of $900 thousand over 1977.
The remaining expenses totaled $14.4 million, an increase of $631 thousand from the previous year. The
most significant changes occurred in rent, which increased $707 thousand and in consultants, which decreased $511 thousand.
The equity account is in reality a reserve for contingencies. Financial operations in 1978 increased that reserve
by the $3 million excess of revenue over expenses, to
$33.4 million at year-end. That represents a 4-month
reserve for operating expenses, based on the level of
expenses during the last 3 months of 1978. The equity
account has been administratively restricted in the
amount of $2,670,000, as explained in note 3 to the
financial statements.

51

Table 14

COMPTROLLER OF THE CURRENCY
BALANCE SHEETS
1978

December 31
1977

ASSETS
Current assets:
Cash
Obligations of U.S. government (Note 2)
Accrued interest on investments
Accounts receivable
Travel advances
Prepaid expenses and other assets

Long-term obligations of U.S. government (Note 2)
Fixed assets and leasehold improvements (Note 2):
Furniture, equipment and software
Leasehold improvements
Less accumulated depreciation and amortization

169,908
17,977,313
326,288
494,969
894,855
53,286

$ 1,436,692
13,336,032
344,474
726,793
725,636
313,809

19,916,619

Total current assets

16,883,436

18,171,757

17,990,955

5,059,843
5,144,674

4,703,509
5,005,914

10,204,517
2,726,271

$

9,709,423
2,051,371

7,478,246

7,658,052

$45,566,622

Total assets

$42,532,443

$ 1,716,150
3,281,767

$ 1,801,357
3,784,881

4,997,917

5,586,238

4,425,810
2,706,051

3,804,739
2,705,716

12,129,778

12,096,693

2,670,000
30,766,844

2,511,000
27,924,750

LIABILITIES AND COMPTROLLER'S EQUITY
Current liabilities:
Accounts payable and accrued expenses
Accrued travel and salaries
Total current liabilities
Long-term liabilities:
Accumulated annual leave
Closed Receivership Funds (Note 3)
Total liabilities
Comptroller's equity:
Administratively restricted (Note 3)
Unrestricted
Commitments and contingencies (Note 4):
Total liabilities and Comptroller's equity
See notes at end of tables.

52



33,436,844

30,435,750

$45,566,622

$42,532,443

Table 15

COMPTROLLER OF THE CURRENCY
STATEMENTS OF REVENUES, EXPENSES AND COMPTROLLER'S EQUITY
Year ended December 31

1978

1977

$87,993,876
4,045,553
3,361,575
124,066
199,832
95,724,902

$80,890,627
3,911,277
2,695,547
105,058
247,922
87,850,431

60,893,478
5,807,972
11,650,723
4,219,810
1,547,045
991,625
2,093,678
1,758,138
1,062,180
536,057
800,675
432,329
236,811
138,086
339,585
215,616

54,207,151
5,280,343
10,653,384
3,512,347
1,389,048
908,311
1,641,971
1,950,627
1,215,583
474,167
635,063
439,162
747,899
157,435
384,724
284,689

92,723,808

Revenues (Note 1):
Semiannual assessments
Examinations and investigations
Investment income
Examination reports sold
Other

83,881,904

3,001,094
30,435,750
$33,436,844

3,968,527
26,467,223

Expenses:

Salaries
Retirement and other employee benefits (Note 4 ) . . .
Travel and per diem
Rent and maintenance (Note 4)
Communications
Moving and shipping
Employee education and training
Data processing
Printing, reproduction and subscriptions
Office machine repairs and rentals
Depreciation and amortization
Supplies
Consulting services
Conferences
Remodeling
Other

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

$30,435,750

See notes at end of tables.




53

Table 16

COMPTROLLER OF THE CURRENCY
STATEMENTS OF CHANGES IN FINANCIAL POSITION
Year ended December 31
1977
1978
Financial resources were provided by:
Excess of revenues over expenses
Charges and (credits) not affecting working capital in the period:
Additions to accumulated annual leave
Depreciation and amortization
Amortization of premium and accretion of discount on long-term U.S. government obligations, net
Net (gain) loss on sale of fixed assets
Working capital provided by operations for the period
Long-term U.S. government obligations transferred to current assets
Proceeds from sale of fixed assets
Net closed receivership fund receipts

$ 3,001,094

$ 3,968,527

1,153,788
800,675

805,397
635,063

Financial resources were used for:
Purchase of long-term investments.
Purchase of fixed assets
Payment of accrued leave

24,007
(2,559)

4,986,629
8,047
335

5,430,435
2,554,204
12,006
419

4,995,011

Total

29,823
1,249

7,997,064

210,625
630,165
532,717

7,142,725
1,771,307
378,011

1,373,507

$(1,294,979)

$(1,266,784)
4,641,281
(18,186)
(231,824)
169,219
(260,523)

$ 1,268,816
(2,283,340)
(66,434)
220,485
136,595
(3,418)
(727,296)

85,207
503,114

(902,187)
334,504

588,321

Increase (decrease) in working capital.

9,292,043

$ 3,621,504

3,033,183

Total

(567,683)

$ 3,621,504

$(1,294,979)

Analysis of Changes in Working Capital

Increase (decrease) in current assets:
Cash
Obligations of U.S. government
Accrued interest on investments
Accounts receivable
Travel advances
Prepaid expenses and other assets

(Increase) decrease in current liabilities:
Accounts payable and accrued expenses...
Accrued travel and salaries

Increase (decrease) in working capital.
See notes on next page.

54



Notes to Financial Statements
December 31, 1978 and 1977
Note 1—Organization
The Comptroller of the Currency (Comptroller's Office) was created by an Act of Congress for the purpose of establishing and
regulating a national banking system. The National Currency Act of
1863, rewritten and re-enacted as The National Banking Act of 1864,
created the Comptroller's Office and provided for its supervisory
functions and the chartering of banks.
No funds derived from taxes or federal appropriations are allocated to or used by the Comptroller's Office in any of its operations.
The revenue of the Comptroller's Office is derived principally from
assessments and fees 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. The Comptroller's Office is exempt from federal income taxes.
Note 2—Significant Accounting Policies
The accounting policies of the Comptroller of the Currency conform to generally accepted accounting principles. The financial statements are prepared on the accrual basis of accounting.
Obligations of the U.S. government are valued at amortized cost.
For the current portion of obligations of the U.S. government, this
approximates market value. The market value of the long-term U.S.
government obligations owned at December 31, 1978 and 1977 was
$16,656,000 and $17,419,000, respectively. It is the intention of the
Comptroller's Office to hold these securities until their maturity, which
ranges from 1980 through 1984. Therefore, no valuation reserve has
been provided for in either 1978 or 1977. Premiums and discounts on
investments in U.S. government obligations are amortized or
accreted ratably over the terms of the obligations.
Furniture, equipment and software are valued at cost. Expenditures for maintenance and repairs or relatively minor items are
charged to earnings as incurred. Renewals of significant items are
capitalized. Depreciation is computed using the straight-line basis
over the estimated useful lives of the assets, which range from 5 to 10
years. Leasehold improvements are valued at cost and are amortized
over the terms of the related leases (including renewal options) or the
estimated useful lives, whichever is shorter.
Note 3—Closed Receivership Funds
Prior to the assumption of closed national bank receivership functions by the Federal Deposit Insurance Corporation in 1936, the
Comptroller of the Currency appointed individual receivers for all
closed national banks. After settling the affairs of the closed banks
and issuing final distributions to the creditors of the banks (principally
depositors), the receivers transferred to the custody of the Comptroller's Office all remaining funds which represented distributions
which were undeliverable or had not been presented for payment.
Closed Receivership Funds in the accompanying balance sheets
represent the potential claims for such funds by the original creditors
of the receiverships. Since inception of the receivership function,
unclaimed funds have been invested in U.S. government securities.
The income from investments has been applied as an offset to expenses incurred by the Comptroller's Office in performing this function and accordingly has been recorded as revenue in the statements
of revenues, expenses and Comptroller's equity. Through December

31, 1978, income has exceeded direct expenses by approximately
$2,670,000 (including $159,000 and $180,000 in 1978 and 1977,
respectively), which excess amount is included in the Comptroller's
equity. An analysis of allocable indirect expenses has not been made.
In its reexamination of the legal status of Closed Receivership
Funds and related excess income earned thereon, the Comptroller's
legal staff has been unable to locate any definitive statutory or case
law which specifies the ultimate disposition of such funds. In the
absence of legal precedent, the legal staff is unable to currently give
a definitive opinion as to the appropriate disposition of either the
unclaimed receivership funds or the excess income from investment
of such funds. The Comptroller is in the process of seeking legislative
resolution of these matters.
Pending a resolution of the legal uncertainties and legislative
action surrounding these funds, the Comptroller's Office has included
a liability for Closed Receivership Funds in its balance sheets and
recognized income from investment of such funds as revenue in its
statements of revenue, expenses and Comptroller's equity. In recognition of these uncertainties, the Comptroller has administratively restricted a portion of the Comptroller's equity in an amount that approximates the excess income earned from investment of Closed Receivership Funds since custody of the funds commenced.
Note 4—Commitments and Contingencies
The Comptroller's Office occupies office space in Washington,
D.C. under a lease agreement which provided for an initial 5-year
term with five consecutive 5-year renewal options. As of December
31, 1978, the first of these options, expiring in 1984, has been exercised. In addition, regional and sub-regional offices lease space
under agreements which expire at various dates through 1992. Minimum rental commitments under leases in effect at December 31,
1978 are as follows: 1979, $3,838,274; 1980, $3,675,517; 1981,
$3,484,326; 1982, $3,057,764; 1983, $3,014,052; 1984 and after,
$4,485,182 — a total of $21,555,115. Certain of the leases provide
that annual rentals may be adjusted to provide for increases in taxes
and other related expenses.
Total rental expense under operating leases was $4,219,810 and
$3,512,347 for the years ended December 31, 1978 and 1977, respectively.
The Comptroller's Office contributes to the Civil Service retirement
plan for the benefit of all its eligible employees. Contributions aggregated $4,133,000 and $3,698,000 in 1978 and 1977, respectively.
The plan is participatory, with 7 percent of salary being contributed by
each party.
The accompanying balance sheets include a liability for annual
leave, accumulated within specified limits, which if not taken by
employees prior to retirement is paid at that date.
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, having a
par or stated value of $13,593,000 are not assets of the Comptroller's
Office and accordingly are not included in the accompanying financial statements.
The Comptroller's Office is a defendant, together with other bank
supervisory agencies and other persons, in litigation generally related
to the closing of certain national banks. In the opinion of the Comptroller's legal staff, the Comptroller's Office will be able to defend
successfully against these complaints.

OPINION OF INDEPENDENT ACCOUNTANT
To the Comptroller of the Currency
In our opinion, the accompanying balance sheets, the related statements of revenues, expenses and Comptroller's
equity and of changes in financial position present fairly the financial position of the Comptroller of the Currency at
December 31, 1978 and 1977, and the results of its operations and the changes in its 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 at December 31, 1978 and 1977, by correspondence with
the custodians.
Price Waterhouse & Co.
Washington, D.C.
April 18, 1979.




55




APPENDIX A

Merger Decisions, 1978

Merger* Decisions, 1978
/. Mergers consummated, involving two or more operating banks
Jan. 1, 1978:
Page
Exchange National Bank of Pinellas County, Largo, Fla.
The Exchange Bank of Dunedin, Dunedin, Fla.
The Exchange Bank and Trust Company of Clearwater,
Clearwater, Fla.
Merger
63
Jan. 1, 1978:
Indian Head National Bank of Portsmouth, Portsmouth,
N.H.
Indian Head National Bank of Rochester, Rochester, N.H.
Merger
63
Jan. 10, 1978:
Zions First National Bank, Salt Lake City, Utah
First State Bank, Salina, Utah
Richfield Commercial and Savings Bank, Richfield, Utah
Merger
64
Jan. 28, 1978:
First Alabama Bank, N.A., Notasulga, Lee County, Ala.
First Bank of Macon County, Notasulga, Macon County,
Ala.
Purchase
65
Feb. 6, 1978:
Southeast First National Bank of Maitland, Maitland, Fla.
Southeast National Bank of Orlando, Orlando, Fla.
Southeast Bank of East Orange, Orlando, Fla.
Merger
66
Feb. 13, 1978:
Wells Fargo Bank, National Association, San Francisco,
Calif.
Eight Branches of The Bank of California, National Association, San Francisco, Calif.
Purchase
66
Feb. 20, 1978:
Florida First National Bank of Jacksonville, Jacksonville,
Fla.
Florida National Bank at Arlington, Jacksonville, Fla.
Florida National Bank at Lake Shore, Jacksonville, Fla.
Florida Dealers and Growers Bank at Jacksonville, Jacksonville, Fla.
Florida Northside Bank of Jacksonville, Jacksonville, Fla.
Merger
68
Feb. 21, 1978:
First National Bank of Catawba County, Hickory, N.C.
The First National Bank of West Jefferson, West Jefferson, N.C.
Merger
69
Mar. 8, 1978:
Town-Country National Bank, Camden, Wilcox County,
Ala.
Wilcox County Bank, Camden Wilcox County, Ala.
Purchase
70
Mar. 13, 1978:
Southwest National Bank of Pennsylvania, Greensburg,
Pa.
The First National Bank of Youngwood, Youngwood, Pa.
Fidelity Deposit Bank of Derry, Derry, Pa.
Consolidation
71
Mar. 30, 1978:
The American National Bank and Trust Company of
Michigan, Kalamazoo, Mich.
The First National Bank of Lawton, Lawton, Mich.
Purchase
73




Mar. 31, 1978:
Page
First National Bank of Grand Rapids, Grand Rapids,
Mich.
The Moline State Bank, Moline, Mich.
Merger
74
Mar. 31, 1978:
The First National Bank in Huntington, Huntington, Ind.
Roanoke State Bank, Roanoke, Ind.
Merger
75
Apr. 1, 1978:
The Detroit Bank-Sterling, N.A., Sterling Heights, Mich.
Van Dyke-Sixteen Mile Branch of The Detroit Bank and
Trust Company, Detroit, Mich.
Purchase
76
Apr. 1, 1978:
The First National Bank of Maryland, Baltimore, Md.
The First National Bank of Snow Hill, Snow Hill, Md.
Merger
77
Apr. 20, 1978:
Flagship First National Bank of Miami Beach, Miami
Beach, Fla.
Flagship First National Bank of Coral Gables, Coral
Gables, Fla.
Flagship National Bank of Miami, Miami, Fla.
Merger
78
Apr. 20, 1978:
Michigan National Bank—Port Huron, Port Huron, Mich.
Four Port Huron Branches of Michigan National Bank,
Lansing, Mich.
Purchase
79
Apr. 30, 1978:
Atlantic National Bank of West Palm Beach, West Palm
Beach, Fla.
Atlantic Westside Bank of Palm Beach County, West
Palm Beach, Fla.
Purchase
80
May 1, 1978:
The First National Bank of Convoy, Convoy, Ohio
The Middle Point Banking Company, Middle Point, Ohio
Merger
80
May 4, 1978:
The Trotwood Bank, Trotwood, Ohio
The Central Trust Company of Montgomery County, National Association, Dayton, Ohio
Merger
81
May 6, 1978:
Wells Fargo Bank, National Association, San Francisco,
Calif.
The First National Bank of Orange County, Orange, Calif.
Merger
83
May 31, 1978:
Drovers & Mechanics National Bank of York, York, Pa.
York Haven State Bank, York Haven, Pa.
Merger
85
May 31, 1978:
First National Bank of Jackson, Jackson, Miss.
Citizens Bank of Hattiesburg, Hattiesburg, Miss.
Merger
86
June 29, 1978:
Concord National Bank, Concord, N.H.
The Pittsfield National Bank, Pittsfield, N.H.
Merger
87

59

June 30, 1978:
Page
Century National Bank of Broward, Fort Lauderdale, Fla.
Century National Bank of Coral Ridge, Fort Lauderdale,
Fla.
Merger
87
June 30, 1978:
Flagship Bank of Melbourne, National Association, Melbourne, Fla.
Flagship Bank of West Melbourne, National Association,
West Melbourne, Fla.
Merger
88
July 14, 1978:
Gallatin National Bank, Uniontown, Pa.
The Rices Landing National Bank, Rices Landing, Pa.
Purchase
89
July 31, 1978:
Crocker National Bank, San Francisco, Calif.
Three Branches of The Bank of California, National Association, San Francisco, Calif.
Purchase
90
Aug. 31, 1978:
Eaton National Bank and Trust Co., Eaton, Ohio
The First National Bank of New Paris, New Paris, Ohio
Purchase
91
Aug. 31, 1978:
Virginia National Bank, Norfolk, Va.
Virginia National Bank/Richmond, Richmond, Va.
Virginia National Bank/Lynchburg, Lynchburg, Va.
Virginia National Bank/Henry County, Henry County, Va.
Merger
92
Sept. 30, 1978:
First & Merchants National Bank, Richmond, Va.
First & Merchants National Bank of the Peninsula, York
County, (P.O. Williamsburg), Va.
First & Merchants National Bank of Tidewater, Chesapeake, Va.
First & Merchants National Bank of Prince William, Unincorporated Area of Prince William County, Va.
Merger
93
Oct. 13, 1978:
The Citizens and Southern National Bank of S.C., Charleston, S.C.
Hilton Head National Bank, Hilton Head, S.C.
Purchase
94
Oct. 20, 1978:
Security Pacific National Bank, Los Angeles, Calif.
Humboldt National Bank, Eureka, Calif.
Merger
95
Nov. 3, 1978:
United National Bank, Sioux Falls, S. Dak.
Rosholt Community Bank, Rosholt, S. Dak.
Purchase
96

Dec. 1, 1978:
Zions First National Bank, Salt Lake City, Utah
Zions First National Bank of Ogden, Ogden, Utah
Merger
Dec. 8, 1978:
Gallatin National Bank, Uniontown, Pa.
First National Bank of Scottdale, Scottdale, Pa.
Purchase
Dec. 29, 1978:
Barnett Bank of Tampa, National Association, Tampa,
Fla.
Barnett Bank of Brandon, National Association, Unincorporated Area of Brandon, Fla.
Merger
Dec. 29, 1978:
National Central Bank, Lancaster, Pa.
Farmers Bank of Kutztown, Kutztown, Pa.
Merger
Dec. 29, 1978:
The Chester National Bank, Chester, N.Y.
The National Union Bank of Monticello, Monticello, N.Y.
Merger
Dec. 29, 1978:
The National Bank and Trust Company of Norwich, Norwich, N.Y.
First National Bank in Sidney, Sidney, N.Y.
Merger
Dec. 31, 1978:
Adams County National Bank, Cumberland Township
(P.O. Gettysburg), Pa.
The National Bank of Arendtsville, Arendtsville, Pa.
Merger
Dec. 31, 1978:
Century National Bank of Palm Beach County, West Palm
Beach, Fla.
Century National Bank, Boynton Beach, Fla.
Merger
Dec. 31, 1978:
Lincoln First Bank of Rochester, Rochester, N.Y.
National Bank of Westchester, White Plains, N.Y.
Lincoln First Bank-Central, National Association, Syracuse, N.Y.
First-City National Bank of Binghamton, N.Y., Binghamton, N.Y.
The First National Bank of Jamestown, Jamestown, N.Y.
Consolidation
Dec. 31, 1978:
Southeast First National Bank of Sarasota, Sarasota, Fla.
Southeast Bank of St. Armands, Sarasota, Sarasota, Fla.
Southeast Bank of Siesta Key, Sarasota, Fla.
Southeast Bank of Venice, Venice, Fla.
Southeast Bank of Village Plaza, N.A., Sarasota, Fla.
Merger

Page
97

98

99

99

101

101

103

105

106

107

//. Mergers consummated, involving a single operating bank
Jan. 3, 1978:
Page
Peoples Bank and Trust, N.A., Trenton, Mich.
PBT, National Association, Trenton, Mich.
Consolidation
108
Jan. 31, 1978:
The First National Bank of Cassopolis, Cassopolia, Mich.
Cassopolis National Bank, Cassopolis, Mich.
Consolidation
108
Feb. 6, 1978:
Blackstone Valley National Bank, Northbridge, Mass.
Old Colony National Bank of Worcester County, Northbridge, Mass.
Merger
109
Feb. 15, 1978:
The Central Security National Bank of Lorain County, Lorain, Ohio
The Central Trust Company of Lorain County, National
Association, Lorain, Ohio
Merger
110

60



Apr. 1,1978:
Capitol National Bank, Raleigh, N.C.
New Capitol Bank, National Association, Raleigh, N.C.
Merger
Apr. 7, 1978:
First National Bank of McAllen, McAllen, Tex.
McAllen Commerce Bank National Association, McAllen,
Tex.
Merger
Apr. 14, 1978:
City National Bank in Wichita Falls, Wichita Falls, Tex.
City Bank, National Association, Wichita Falls, Tex.
Merger
May 12, 1978:
Kelly Field National Bank of San Antonio, San Antonio,
Tex.
American Servicemen's National Bank, San Antonio, Tex.
Merger

Page
110

111

112

112

May 15, 1978:
Page
First National Bank of Maywood, Maywood, III.
Maywood National Bank, Maywood, III.
Merger
113
July 15, 1978:
Community National Bank, Flushing, Ohio
Second National Bank, Flushing, Ohio
Merger
114
July 31, 1978:
The Citizens National Bank of Emporia, Emporia, Va.
Greensville-Emporia National Bank, Emporia, Va.
Merger
114
July 31, 1978:
National Bank of Marshall, Marshall, Mich.
CFC National Bank, Marshall, Mich.
Merger
115
Aug. 1, 1978:
Bexar County National Bank of San Antonio, San Antonio,
Tex.
North St. Mary National Bank, San Antonio, Tex.
Merger
116
Aug. 17, 1978:
The First National Bank & Trust Company of Augusta,
Augusta, Ga.
National Interim Bank of Augusta, Augusta, Ga.
Merger. :
116
Aug. 17, 1978:
The First National Bank & Trust Company in Macon,
Macon, Ga.
National Interim Bank of Macon, Macon, Ga.
Merger
117
Aug. 17, 1978:
The First National Bank of Rome, Rome, Ga.
National Interim Bank of Rome, Rome, Ga.
Merger
117
Aug. 17, 1978:
The National Bank and Trust Company of Columbus, Ga.,
Columbus, Ga.
National Interim Bank of Columbus, Columbus, Ga.
Merger
117

Aug. 17, 1978:
Trust Company of Georgia Bank of Savannah, N.A.,
Savannah, Ga.
National Interim Bank of Savannah, Savannah, Ga.
Merger
Sept. 11, 1978:
Eastern Shore National Bank, Daphne, Ala.
FBG National Bank of Daphne, Daphne, Ala.
Merger
Sept. 14, 1978:
The First National Bank of Dalton, Dalton, Ga.
First National Interim Bank of Dalton, Dalton, Ga.
Merger
Oct. 2, 1978:
The First National Bank in Mineral Wells, Mineral Wells,
Tex.
Hubbard National Bank, Mineral Wells, Tex.
Merger
Nov. 14, 1978:
The Herget National Bank of Pekin, Pekin, III.
HNB Bank, N.A., Pekin, III.
Merger
Nov. 27, 1978:
The Brooks Field National Bank of San Antonio, San Antonio, Tex.
Brooks Field Bank of Commerce National Association,
San Antonio, Tex.
Merger
Nov. 30, 1978:
Guaranty National Bank, Houston, Tex.
Guaranty Bank of Commerce National Association, Houston, Tex.
Merger
Dec. 14, 1978:
Colonial National Bank, Unincorporated Area of Harris
County, Tex.
New Colonial National Bank, Unincorporated Area of Harris County, Tex.
Merger

Page

117

118

119

120

120

121

122

122

///. Mergers approved, but abandoned pursuant to litigation
Feb. 14, 1978:
Page
Second National Bank and Trust Company of Lexington,
Lexington, Ky.
Bank of Lexington, Lexington, Ky.
Merger
123




61

/. Mergers consummated, involving two or more operating banks.
EXCHANGE NATIONAL BANK OF PINELLAS COUNTY,
Largo, Fla., and The Exchange Bank of Dunedin, Dunedin, Fla. and The Exchange Bank and Trust Company of
Clearwater, Clearwater, Fla.
Banking offices
Total
assets

Names of banks and type of transaction

The Exchange Bank and Trust Company of Clearwater, Clearwater, Fla., with
and The Exchange Bank of Dunedin, Dunedin, Fla., with
and The Exchange National Bank of Pinellas County, Largo, Fla. (16281), which had
merged Jan. 1,1978, under charter and title of the latter bank (16281). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Controller of the
Currency seeking prior permission for the Exchange
Bank and Trust Company of Clearwater, Clearwater,
Fla. ("Clearwater Bank"), and The Exchange Bank of
Dunedin, Dunedin, Fla. ("Dunedin Bank") (collectively,
"Merging Banks"), to merge into The Exchange National Bank of Pinellas County, Largo, Fla. ("ENB"), the
charter bank, under the charter and title of The Exchange National Bank of Pinellas County, with corporate headquarters in Clearwater, Fla. The subject application rests upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
Clearwater Bank was established in 1962 as an independent state-chartered commercial banking institution. As of December 31, 1976, it had total deposits
of $57.9 million.
Dunedin Bank was established de novo in September 1973, by its parent bank holding company, Exchange Bancorporation, Inc., Tampa, Fla., the 12th
largest multi-bank holding company headquartered in
the state. As of year-end 1976, Dunedin Bank's deposits totaled approximately $11 million.

In
To be
operation operated

$63,300,000
15,827,000
11,203,000
90,330,000

ENB was also established de novo by its parent
holding company, and commenced operations in
1974. As of the aforementioned date, the charter
bank's total deposits were $8.8 million.
Inasmuch as all three of the proponent banks are
subsidiaries of the same bank holding company, no
meaningful competition exists among them, nor is
there any potential for increased competition. This application essentially represents a corporate reorganization whereby Exchange Bancorporation, Inc., is consolidating its banking interests located within Pinellas
County. Furthermore, the proposal appears to be in
accord with the recently enacted state branching statutes.
The application does not give the appearance of
being adverse to the public interest, and should be,
and hereby is, approved.
August 3, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are wholly-owned subsidiaries of
the same bank holding company. As such, their proposed merger is essentially a corporate reorganization
and would have no effect on competition.

INDIAN HEAD NATIONAL BANK OF PORTSMOUTH,
Portsmouth, N.H., and Indian Head National Bank of Rochester, Rochester, N.H.
Banking offices
Names of banks and type of transaction

Total
assets

Indian Head National Bank of Portsmouth, Portsmouth, N.H. (1052), with
and Indian Head National Bank of Rochester, Rochester, N.H. (15652), which had
merged Jan. 1,1978, under charter of the latter bank (15652) and title "Indian Head Bank, National
Association." The merged bank at date of merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency, pursuant to 12 USC 1828(c), soliciting prior
consent for the merger of Indian Head National Bank




In
To be
operation operated

$38,034,000
9,973,000
48,007,000

of Portsmouth, Portsmouth, N.H. ("Merging Bank"),
into Indian Head National Bank of Rochester, Rochester, N.H. ("Charter Bank"), under the charter of Indian
Head National Bank of Rochester, with the title of "Indi63

an Head Bank, National Association," and with corporate headquarters in Portsmouth, N.H. The subject application rests upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
Charter Bank was issued national banking association charter number 15652 on May 23, 1968. As of
June 30, 1977, Charter Bank held total commercial
bank deposits of $8.8 million.
Merging Bank was chartered as a national banking
association on April 25, 1865, and as of June 30, 1977,
its total deposits were $34.6 million.
Both of the proponent banks are subsidiaries of Indian Head Banks, Inc., Nashua, N.H., a registered multibank holding company. Accordingly, this application is
regarded as essentially a corporate reorganization
whereby Indian Head Banks, Inc. is consolidating a
portion of its banking interests in the hopes of produc-

ing a more efficient and more economically profitable
unit. Due to the common ownership and control of the
proponent banks, there will be produced no adverse
impact upon competition.
The Rochester community particularly should be
better served by the combination of Charter Bank with
Merging Bank as a result of some economies of scale
and larger legal lending limits.
This application is therefore deemed to be in the
public interest, and should be, and hereby is,
approved.
December 2, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it is essentially a corporate reorganization
and would have no effect on competition.

ZIONS FIRST NATIONAL BANK,
Salt Lake City, Utah, and First State Bank, Salina, Utah, and Richfield Commercial and Savings Bank, Richfield,
Utah
Banking offices
Names of banks and type of transaction

Total
assets

Richfield Commercial & Savings Bank, Richfield, Utah, with
and First State Bank, Salina, Utah, with
and Zions First National Bank, Salt Lake City, Utah (4341), which had
merged Jan. 10, 1978, under charter and title of the latter bank (4341). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), an application has been
filed with the Office of the Comptroller of the Currency
requesting prior consent to merge Richfield Commercial and Savings Bank, Richfield, Utah ("RCSB"), and
First State Bank, Salina, Utah ("FSB") (collectively,
"Merging Banks"), into Zions First National Bank, Salt
Lake City, Utah ("Charter Bank"), under the charter
and title of Zions First National Bank. The subject application rests upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
Charter Bank, the second largest commercial bank
in Utah, was granted national banking association
charter number 4341 by this Office on June 12, 1890.
As of June 30, 1977, Charter Bank held total deposits
of $702.3 million. Additionally, Charter Bank is a subsidiary of Zions Utah Bancorporation, Salt Lake City,
Utah, a registered multi-bank holding company.
Both of the Merging Banks are state-chartered commercial banking institutions. RCSB is a unit bank, with
no branches and June 30, 1977, total deposits of
$18.1 million. FSB operates its main office and a total
of three branches; one each in Panguitch, Kanab, and

64


$ 21,030,000
43,990,000
932,212,000
896,755,000

In
To be
operation operated
1
4

41
46

Manti. As of June 30, 1977, FSB had total deposits of
$36.5 million. Both Charter Bank and FSB have branch
offices in Kanab. The application reflects that it is not
Charter Bank's intent to combine the two offices in
Kanab, but rather to sell its present branch in Kanab to
another non-affiliated bank, and thereby preserve two
banking facilities within that community. Also, inasmuch as there are only 15 banking offices domiciled
within the entire four-county area served by Merging
Banks, approval of this application does not give the
appearance of having an adverse effect upon existing
competition.
The banking community presently served by Merging Banks should be better served through the introduction of new and expanded banking services. The
legal lending limit of the resulting bank will be able to
accommodate larger loan requests of banking customers. Considerations relating to convenience and needs
benefits are deemed to be positive in considering
approval of the application.
The financial and managerial resources of Charter
Bank are regarded as satisfactory, and are enhanced
by the same factors present in its parent bank holding
company. Likewise, the financial and managerial re-

sources of both RCSB and FSB are satisfactory, and
all of the proponent banks' future prospects appear
favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that the subject application is in the public interest, and should be, and hereby is, approved.

December 9, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

FIRST ALABAMA BANK, N.A.,
Notasulga, Lee County, Ala., and First Bank of Macon County, Notasulga, Macon County, Ala.
Banking offices
Names of banks and type of transaction

Total
assets*

First Bank of Macon County, Notasulga, Macon County, Ala., with
was purchased Jan. 28,1978, by First Alabama Bank, N.A., Notasulga, Lee County, Ala. (16699),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
On January 28, 1978, application was made to the
Comptroller of the Currency for prior written approval
for First Alabama Bank, N.A., Notasulga, Lee County,
Ala. ("Assuming Bank"), to purchase certain of the
assets and assume certain of the liabilities of First
Bank of Macon County, Notasulga, Macon County,
Ala. ("First").
On January 26, 1978, First was a state-chartered
bank operating through its main office with deposits of
approximately $3.8 million. On January 26, 1978, at
4:30 PM, Central Standard Time, First was declared
insolvent and the Federal Deposit Insurance Corporation ("FDIC") was appointed as receiver. The present
application is based upon an agreement, which is incorporated herein by reference, the same as if fully set
forth, by which the FDIC, as receiver, has agreed to
sell certain of First's assets to the Assuming Bank, and
the Assuming Bank has agreed to assume certain of
the former liabilities of First. For the reasons stated
hereafter, the Assuming Bank's application is
approved, and the purchase and assumption transaction may be consummated immediately.
Under the Bank Merger Act, 12 USC 1828(c), the
Comptroller cannot approve a purchase and assumption transaction which would have certain proscribed
anticompetitive effects unless he finds those anticompetitive effects to be clearly outweighed in the public
interest by the probable effect of the transaction in
meeting the convenience and needs of the community
to be served. Additionally, the Comptroller is directed
to consider the financial and managerial resources
and future prospects of the existing and proposed institution, and the convenience and needs of the community to be served. When necessary, however, to
prevent the evils attendant upon the failure of a bank,
the Comptroller can dispense with the uniform standards applicable to usual acquisition transactions and
need not consider reports on the competitive consequences of the transaction ordinarily solicited from the
Department of Justice and other banking agencies. He



In
To be
operation operated

$4,385,000

1

500,000
4,108,000

0
1

is authorized in such circumstances to act immediately, in his sole discretion, to approve an acquisition and
to authorize the immediate consummation of the transaction.
The proposed acquisition will prevent disruption of
banking services to the community, and potential losses to a number of uninsured depositors. The Assuming Bank, as a new banking subsidiary of First Alabama Bancshares, Inc., Birmingham, Ala., a registered
multi-bank holding company, has sufficient financial
and managerial resources to absorb First and to enhance the banking services it offers within the Notasulga market.
The Comptroller thus finds that the proposed transaction will not result in a monopoly, be in furtherance
of any combination or conspiracy to monopolize or
attempt to monopolize the business of banking in any
part of the United States, and that the anticompetitive
effects of the proposed transaction, if any, are clearly
outweighed in the public interest by the probable
effect of the proposed transaction in meeting the convenience and needs of the community to be served.
For those reasons, the Assuming Bank's application to
purchase certain assets and assume certain liabilities
of First as set forth in the agreement executed with the
FDIC, as receiver, is approved. The Comptroller further
finds that the failure of First requires him to act immediately, as contemplated by the Bank Merger Act, to
prevent disruption of banking services to the community. The Comptroller thus waives publication of notice,
dispenses with the solicitation of competitive reports
from other agencies, and authorizes the transaction to
be consummated immediately.
January 28, 1978
Due to the emergency nature of the situation, no Attorney General's report was requested.

* Asset figures are as of call dates immediately before and after
transaction.

65

SOUTHEAST FIRST NATIONAL BANK OF MAITLAND,
Maitland, Fla. and Southeast National Bank of Orlando, Orlando, Fla., and Southeast Bank of East Orange,
Orlando, Fla.
Banking offices
Names of banks and type of transaction

Total
assets*

Southeast First National Bank of Maitland, Maitland, Fla. (15237), with
and Southeast Bank of East Orange, Orlando, Fla., with
and Southeast National Bank of Orlando, Orlando, Fla. (15814), which had
merged Feb. 6, 1978, under the charter and title of the latter bank (15814). The merged bank at date
of merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act of 1966 (12 USC
1828(c)), an application has been filed with the Office
of the Comptroller of the Currency requesting prior
consent to merge Southeast First National Bank of
Maitland, Maitland, Fla. ("Maitland Bank"), and Southeast Bank of East Orange, Orlando, Fla. ("East Orange
Bank") (collectively, "Merging Banks"), into Southeast
National Bank of Orlando, Orlando, Fla. ("Charter
Bank"), under the charter and title of Southeast National Bank of Orlando. The subject application rests upon
an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth.
Maitland Bank was granted national banking association charter number 15237 by this Office on January
3, 1964, and as of June 30, 1977, held total commercial bank deposits of $53.7 million.
East Orange Bank is a state-chartered commercial
banking institution that, as of June 30, 1977, had total
deposits of $8.4 million.
Charter Bank has operated as a national bank under

In
operation

To be
operated

$ 61,313,000
9,469,000
37,767,000
112,010,000

charter number 15814 since July 20, 1970, and as of
mid-year 1977, its total deposits were $23.6 million.
Both of the Merging Banks and Charter Bank are
banking subsidiaries of Southeast Banking Corporation, Miami, Fla., the largest multi-bank holding company headquartered in the state of Florida. Accordingly, due to the common ownership and control existing
among the proponent banks, there is no meaningful
degree of existing competition between any of these
subsidiaries of Southeast Banking Corporation. The
application must, therefore, be regarded essentially as
a corporate reorganization.
Applying the statutory criteria, it is the conclusion of
this Office that this application is not adverse to the
public interest, and should be, and hereby is,
approved.
January 6, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are wholly-owned subsidiaries of
the same bank holding company. As such, their proposed merger is essentially a corporate reorganization
and would have no effect on competition.

WELLS FARGO BANK, NATIONAL ASSOCIATION,
San Francisco, Calif., and Eight Branches of The Bank of California, National Association, San Francisco, Calif.
Banking offices
Names of banks and type of transaction

Total
assets*

Eight Branches of The Bank of California, National Association, San Francisco, Calif. (9655), with,
were purchased Feb. 13,1978, by Wells Fargo Bank, National Association, San Francisco, Calif.
(15660), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency by Wells Fargo Bank, National Association,
San Francisco, Calif. ("Purchasing Bank"), requesting
prior permission to purchase the assets and assume
the liabilities of eight branches ("Branches") of The
Bank of California, National Association, San Francisco, Calif. ("Selling Bank"). The subject application
* Asset figures are as of call dates immediately before and after
transaction.
t Assets are for the entire bank.

66


$ 2,995,357,000t
14,845,509,000
15,291,670,000

In
operation

To be
operated

8
348
356

rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Selling Bank was granted national banking association charter number 9655 and, as of June 30, 1977,
held total deposits of $2.5 billion.
Purchasing Bank was granted national banking
association charter number 15660 on February 5,
1910, and as of June 30, 1977, its total deposits were
$11.4 billion.
In an attempt to consolidate its position on a more
regional banking concept, Selling Bank, on May 11,

1977, announced its intention to sell 30 of its branches
which are located in areas where Selling Bank does
not possess a significant relevant geographic market
penetration. The eight branches being considered as
the subject of this application, are located in southern
California; six of the branch offices are domiciled in
San Bernadino County, and one each is located in
Fresno and Orange counties. The Fresno Branch is
approximately 260 miles north of the Santa Ana Office,
the nearest of the other branches being purchased,
and the Santa Ana Branch is almost 35 miles southwest of the nearest of the six San Bernadino County
branches. Because Purchasing Bank did not commence its market expansion and penetration of the
southern California area until approximately 10 years
ago, well after its significantly larger competitors had
successfully established their presences outside their
San Francisco Bay Area home bases, Purchasing
Bank's presence in the three market areas relevant to
this application is negligible. Accordingly, approval of
this application would result in no adverse effect upon
existing competition.
The fortified presence of Purchasing Bank within the
relevant geographic markets should better serve the
banking public with a more viable competitor that is a
more meaningful banking alternative capable of providing new and expanded banking services. Considerations relating to convenience and needs benefits are
consistent with approval.
The financial and managerial resources of Purchasing Bank and Selling Bank are generally satisfactory,
and Purchasing Bank has the capacity to operate the
branches in an efficient and profitable manner. The
sale of the branches will increase Selling Bank's capital and should have a favorable impact on that bank's
earnings by lowering overhead operational costs related to the branches.
The future prospects of the proponent banks appear
favorable and consistent with approval of this proposal.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
January 10, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The eight branches covered by this application are
located in three different areas of the state. Consequently, we have analyzed the effect on competition in
each of these areas.
Existing Competition

(1) San Bernardino County. Six of the eight branches Applicant proposes to acquire are in San Bernardino County which is part of the Riverside-San Bernardino-Ontario SMSA. The six offices have total deposits
of $40.2 million, or 1.5 percent of total county deposits.
Bank will retain five other offices in San Bernardino
County with total deposits of just under $100 million.
Applicant currently has three offices in the county (one
of which was opened since June 30, 1976) which held
approximately $30 million in total deposits as of June



30, 1976. After the acquisition, Applicant would hold
approximately 2.5 percent of the county's bank deposits and would rank seventh among banks operating
there. Applicant has no offices in the "primary service
areas," as defined in the application, of any of the six
branches it proposes to acquire. It therefore appears
that the acquisition of these branches by Applicant
would not have an adverse effect on existing competition.
(2) Orange County. Applicant proposes to acquire
one of the two offices Bank operates in Orange County—Bank's Santa Ana office which holds total deposits
of approximately $23 million (including $3 million in
large certificates of deposit which Applicant will not
acquire), or 0.54 percent of total Orange County bank
deposits. Bank will retain its office in Newport Beach,
Orange County, which holds total deposits of approximately $6.4 million. Applicant has 12 offices in the
county with deposits of approximately $92 million, or
2.1 percent of total county bank deposits. After the
acquisition, it would hold approximately 2.6 percent of
total county bank deposits and would move to a ranking of eighth from its current position of ninth. While
Applicant has two offices in Santa Ana, neither is within the "primary service area," as defined in the application, of the branch to be sold. In addition, there are
several other banks in the area surrounding the branch
and located closer to it than Applicant's closest office.
It therefore appears that the acquisition of this branch
by Applicant would not have an adverse effect on existing competition.
(3) Fresno County. The final branch Applicant proposes to acquire is in Fresno. The branch, which is
Bank's only office in Fresno County has total deposits
of $16.6 million, or 1.3 percent of total county bank
deposits. Applicant has eight offices in the county with
total deposits of approximately $85 million, or 6.5 percent of total county bank deposits. It ranks fourth
among banks operating there. After the acquisition, it
would hold 7.8 percent of total county bank deposits
and rank about equal with Crocker National, which
holds the third largest share of the county's bank deposits. Banking is highly concentrated in Fresno
County; the top four banks (including Applicant) control over 82 percent of total county bank deposits.
Both the branch Applicant proposes to acquire and
its "Fresno Main Office" are located on the same block
in downtown Fresno, and one of Applicant's other
offices is located within a short distance of the branch.
It therefore appears that the proposed acquisition
would eliminate a substantial amount of existing competition between Applicant and Bank. Bank holds 2.6
percent and Applicant 5.9 percent of the total deposits
held by banks operating in the "primary service area"
of Bank's Fresno branch as defined in the application.
Since Bank's share includes $5.2 million in large certificates of deposit which it will retain, Applicant will
actually acquire approximately $11.4 million in deposits, increasing its share of local deposits to 7.1 percent.
Accordingly, the proposed acquisition of Bank's
Fresno branch would have an adverse effect on competition inasmuch as it would eliminate existing com67

petition and contribute to increased banking concentration. A sale to one of the smaller banks in the area
would be highly preferable and there is no evidence
that Bank's Fresno branch could not be sold independently of the other seven branches Applicant proposes
to acquire.
Potential Competition

Applicant, which is the third largest banking institution
in the state, must be considered a potential entrant
into those markets in which it is not presently represented. Historically, Applicant has been much more
heavily branched in northern California than in the
southern part of the state. According to its 1976 Form
10-K, Applicant has undertaken a program of expansion in southern California and as of December 31,
1976, had 71 branches there. The report continues (p.
1): "It is anticipated that future branch expansion will
occur primarily in southern California." The seven
branches Applicant proposes to acquire in San Bernardino and Orange counties are in southern California. There can be little doubt that Applicant has both
the resources and desire to enter new markets de
novo as well as by acquisition. Moreover, compared to
the two largest banking institutions in California, Bank

of America and Security Pacific, and to several other
banks, Applicant is poorly represented in southern
California. Thus, we conclude that Applicant is a significant potential entrant in the markets in southern California in which it is not currently represented.
The Riverside-San Bernardino-Ontario SMSA has
undergone a population increase since 1970 greater
than that for the state as a whole. The Orange County
SMSA has undergone very substantial population
growth and has an average per capita income higher
than that for the state as a whole. While both areas
have a substantial number of banking offices at the
present time, de novo entry into these areas by Applicant appears feasible. Accordingly, the acquisition by
Applicant of six branches of Bank in San Bernardino
County and one branch of Bank in Orange County
would have a slightly adverse effect on potential competition.
In sum, the acquisition of Bank's Fresno branch by
Applicant would have an adverse effect on existing
competition and would increase concentration in a
market that is already highly concentrated. In addition,
the acquisition of the other seven branches would
have a slightly adverse effect on potential competition
in the markets involved.

FLORIDA FIRST NATIONAL BANK OF JACKSONVILLE,
Jacksonville, Fla., and Florida National Bank at Arlington, Jacksonville, Fla., and Florida National Bank at Lake
Shore, Jacksonville, Fla. and Florida Dealers and Growers Bank at Jacksonville, Jacksonville, Fla. and Florida
Northside Bank of Jacksonville, Jacksonville, Fla.
Banking offices
Names of banks and type of transaction

Total
assets

Florida National Bank at Lake Shore, Jacksonville, Fla. (14974), with
and Florida National Bank at Arlington, Jacksonville, Fla. (14759), with
and Florida Northside Bank of Jacksonville, Jacksonville, Fla., with
and Florida Dealers and Growers Bank at Jacksonville, Jacksonville, Fla., with
and Florida First National Bank of Jacksonville, Jacksonville, Fla. (8321), which had
merged Feb. 20, 1978, under the charter and title of the latter bank (8321). The merged bank at date
of merger had

COMPTROLLER'S DECISION
An application has been filed pursuant to 12 USC
1828(c), with the Office of the Comptroller of the Currency requesting prior permission to merge Florida National Bank at Lake Shore, Jacksonville, Fla. ("Lake
Shore Bank"); Florida National Bank at Arlington, Jacksonville, Fla. ("Arlington Bank"); Florida Dealers and
Growers Bank at Jacksonville, Jacksonville, Fla.
("FDGB"); and, Florida Northside Bank of Jacksonville,
Jacksonville, Fla. ("Northside Bank") (collectively,
"Merging Banks"), into Florida First National Bank of
Jacksonville, Jacksonville, Fla. ("Charter Bank"), under
the charter and title of Florida First National Bank of
Jacksonville. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth.
Lake Shore Bank possesses national banking asso
68


$ 24,044,000
26,007,000
11,345,000
17,464,000
360,423,000
439,281,000

In
To be
operation operated
1
1
1
3
4
10

ciation charter number 14974, and as of February 1,
1977, had total deposits of approximately $20 million.
Arlington Bank was granted a national banking
association charter by this Office on November 21,
1955, and its total deposits were $22.8 million as of
February 1, 1977.
Both FDGB and Northside Bank are state-chartered
commercial banking institutions. FDGB is a member of
the Federal Reserve System. FDGB and Northside
Bank had total deposits on February 1, 1977, of $14.6
million and $9.5 million, respectively.
Charter Bank operates under national banking association charter number 8321, and had total deposits of
$284.5 million as of the aforementioned date for banking data.
All of the proponent banks are banking subsidiaries
of the fifth largest registered bank holding company
headquartered in Florida, Florida National Banks of

Florida, Inc., Jacksonville, Fla. Accordingly, the proposed transaction is essentially a corporate reorganization, and would have no adverse effect upon competition.
It is therefore the conclusion of the Office of the
Comptroller of the Currency that this application is not
adverse to the public interest, and should be, and
hereby is, approved.

January 13, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The banks are all wholly-owned subsidiaries of the
same bank holding company. As such, the proposed
transaction is essentially a corporate reorganization
and would have no effect on competition.

FIRST NATIONAL BANK OF CATAWBA COUNTY,
Hickory, N.C., and The First National Bank of West Jefferson, West Jefferson, N.C.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank of West Jefferson, West Jefferson, N.C. (8571), with
and First National Bank of Catawba County, Hickory, N.C. (4597), which had
merged Feb. 21,1978, under charter and title of the latter bank (4597). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), the Bank Merger Act, the
Office of the Comptroller of the Currency is in receipt
of an application that requests prior consent to effectuate a merger of The First National Bank of West Jefferson, West Jefferson, N.C. ("Merging Bank"), into First
National Bank of Catawba County, Hickory, N.C.
("Charter Bank"), under the charter and title of First
National Bank of Catawba County. The subject application rests upon an agreement between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Charter Bank was granted national banking association charter number 4597 by this Office on July 14,
1891, and as of June 30, 1977, it had total commercial
bank deposits of $183.3 million. In addition to its head
office, Charter Bank maintains 11 offices in Catawba
County and one office in adjoining Alexander County.
Merging Bank, also a national banking association,
operating under charter number 8571, had June 30,
1977, total deposits of $23.5 million. Merging Bank operates only its main office and one drive-in branch,
both of which are domiciled within Ashe County in the
central-western section of the state.
The closest offices of Charter Bank and Merging
Bank are approximately 70 road miles apart, and the
respective primary services areas of the proponent
banks are separated by three intervening counties,
wherein are located offices of significantly larger competing banks. Given the geographic distance separating Charter Bank and Merging Bank, and the fact that
approval of this proposed transaction would constitute
Charter Bank's initial entry into Ashe County, consummation of the subject transaction would not have the
effect of eliminating any meaningful degree of existing
competition between the two banks.



$ 28,758,000
220,993,000
249,751,000

In
To be
operation operated
2
13
15

Inasmuch as commercial banks in North Carolina
enjoy statewide branching privileges, both Charter
Bank and Merging Bank could legally utilize de novo
expansion into each other's market area. However, inasmuch as West Jefferson and its immediate environs
do not appear attractive for de novo entry (Merging
Bank opened its drive-in facility in 1973); and presently, only Merging Bank and Northwestern National Bank
of North Wilkesboro, the state's fourth largest commercial bank, operate offices within Ashe County, the size
disparity between Merging Bank and Northwestern
National Bank has inhibited Merging Bank's competitive abilities and efforts. The introduction of Charter
Bank into Ashe County should provide increased competition to Northwestern, and the banking public
should be better served through their enhanced competitive atmosphere.
The banking community in Ashe County should also
enjoy the benefits of Charter Bank's ability to introduce
new and expanded banking services into the area,
particularly the introduction of trust services offered by
Charter Bank to the present banking customers of
Merging Bank. Considerations relating to convenience
and needs benefits are regarded as a positive factor in
approval of this application.
The financial and managerial resources of both
Charter Bank and Merging Bank are regarded as
satisfactory. However, Merging Bank's management is
vested primarily in one individual who apparently has
not adequately provided for successor management;
Charter Bank appears to possess the managerial talent necessary to insure management succession at
Merging Bank.
The future prospects of both proponents, separately
and in combination, appear favorable, and consistent
with approval.
69

Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
January 18, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Bank's office locations are limited to Ashe County,
where Applicant at present has no offices. The closest
offices of the two institutions are over 50 miles apart
and are separated by three intervening counties. No
branch offices of either bank will be closed if the merger is consummated. Accordingly, the proposed acquisition will not eliminate any significant amount of
existing competition.
The proposed acquisition, however, will have an
adverse effect on potential competition in Ashe County. At present only two banks have office locations
there and the market is about equally divided between
them (with Bank's competitor apparently having a
growing edge). Applicant's resources and stated in-

terest in expansion even if the application is denied
make it a prime candidate for de novo entry into the
county, which would enhance competition through the
creation of a third competitor in the market. Bank's
current competitor—the Northwestern National Bank of
North Wilkesboro—has opened two branches in the
county in the past 5 years which proves that de novo
expansion is possible. However, there are numerous
other potential entrants into Ashe County under North
Carolina's statewide branching laws. Moreover, the
disparity in size between Bank and its competitor
Northwestern (the fifth largest bank in North Carolina
with 173 offices) has handicapped Bank's efforts to
remain competitive. All things considered, de novo entry by Applicant into Ashe County is clearly more consistent with the public interest than is entry by acquisition.
Conclusion

In sum, the proposed acquisition will not have an
adverse effect on actual competition and will have an
adverse effect upon potential competition.

TOWN-COUNTRY NATIONAL BANK,
Camden, Wilcox County, Ala., and Wilcox County Bank, Camden, Wilcox County, Ala.
Names of banks and type of transaction

Total
assets*

Wilcox County Bank, Camden, Ala., with
was purchased Mar. 8,1978, by Town-Country National Bank, Camden, Ala. (16708), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
On March 7, 1978, application was made to the Comptroller of the Currency for prior written approval for
Town-Country National Bank, Camden, Wilcox County,
Ala. ("Assuming Bank"), to purchase certain of the
assets and assume certain of the liabilities of Wilcox
County Bank, Camden, Wilcox County, Ala. ("Wilcox").
On March 1, 1978, Wilcox was a state-chartered
bank operating through its main office, and held commercial bank deposits of approximately $10.5 million.
The board of directors of Wilcox, by unanimous vote,
requested the Superintendent of Banks for the State of
Alabama to take charge of and liquidate the affairs of
the bank under the provisions of the Code of Alabama
of 1975, Section 5-10-25. This was accomplished at
the close of business on March 1, 1978, and the Superintendent of Banks appointed the Federal Deposit
Insurance Corporation ("FDIC") as his agent to assist
him in this statutory takeover. The FDIC is acting as
receiver of Wilcox and the present application is
based upon an agreement, which is incorporated herein by reference the same as if fully set forth, by
which the FDIC, as receiver, has agreed to sell certain
* Asset figures are as of call dates immediately before and after
transaction.

70


$12,664,000
750,000
11,608,000

Banking offices
In
To be
operation operated
1
0
1

of Wilcox's assets to the Assuming Bank, and the
Assuming Bank has agreed to assume certain of the
former liabilities of Wilcox. For the reasons stated
hereafter, the Assuming Bank's application is
approved, and the purchase and assumption transaction may be consummated immediately.
Under the Bank Merger Act, 12 USC 1828(c), the
Comptroller cannot approve a purchase and assumption transaction which would have certain proscribed
anticompetitive effects unless he finds these anticompetitive effects to be clearly outweighed in the public
interest by the probable effect of the transaction in
meeting the convenience and needs of the community
to be served. Additionally, the Comptroller is directed
to consider the financial and managerial resources
and future prospects of the existing and proposed institution, and the convenience and needs of the community to be served. When necessary, however, to
prevent the evils attendant upon the failure of a bank,
the Comptroller can dispense with the uniform standards applicable to usual acquisition transactions, and
need not consider reports on the competitive consequences of the transaction ordinarily solicited from the
Department of Justice and other banking agencies. He
is authorized in such circumstances to act immediately
in his sole discretion, to approve an acquisition, and to

authorize the immediate consummation of the transaction.
The proposed acquisition will prevent a further disruption of banking services to the Camden community
and potential losses to a number of uninsured depositors. The Assuming Bank is a new bank organized by
individuals residing in, or having interests in, Camden
and Wilcox County. The new bank has the financial
resources to absorb Wilcox County Bank and to enhance the banking services available in the Camden
banking market.
The Comptroller thus finds that the proposed transaction will not result in a monopoly, be in furtherance
of any combination or conspiracy to monopolize or
attempt to monopolize the business of banking in any
part of the United States, and that the anticompetitive
effects of the proposed transaction, if any, are clearly
outweighed in the public interest by the probable

effect of the proposed transaction in meeting the convenience and needs of the community to be served.
For these reasons, the Assuming Bank's application to
purchase certain of the assets and to assume certain
of the liabilities of Wilcox as set forth in the agreement
executed with the FDIC, as receiver, is approved. The
Comptroller further finds that the failure of Wilcox requires him to act immediately, as contemplated by the
Bank Merger Act, to prevent additional disruption of
banking services to the community. The Comptroller
thus waives publication of notice, dispenses with the
solicitation of competitive reports from other agencies,
and authorizes the transaction to be consummated immediately.
March 7, 1978.
Due to the emergency nature of the situation, no Attorney General's report was requested.

SOUTHWEST NATIONAL BANK OF PENNSYLVANIA,
Greensburg, Pa., and The First National Bank of Youngwood, Youngwood, Pa., and Fidelity Deposit Bank of Derry,
Derry, Pa.
Names of banks and type of transaction

Total
assets

Fidelity Deposit Bank of Derry, Derry, Pa., with
and The First National Bank of Youngwood, Youngwood, Pa. (6500), with
and Southwest National Bank of Pennsylvania, Greensburg, Pa. (5351), which had
consolidated Mar. 13, 1978; under charter and title of the latter bank (5351). The consolidated bank at
date of consolidation had

COMPTROLLER'S DECISION
An application has been filed with the Office of the
Comptroller of the Currency requesting prior consent
to consolidate Southwest National Bank of Pennsylvania, Greensburg, Pa. ("Charter Bank"), Fidelity Deposit
Bank of Derry, Derry, Pa. ("Fidelity Bank"), and The
First National Bank of Youngwood, Youngwood, Pa.
("FNB"), under the charter and title of Southwest National Bank of Pennsylvania. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Charter Bank has operated under national banking
association charter number 5351 since the charter was
issued by this Office on May 15, 1900. In addition to its
main office in Greensburg, the county seat of Westmoreland County, Charter Bank operates "seven other
offices within Westmoreland County, and three additional branches in contiguous Allegheny County. As of
September 30, 1977, the bank held total deposits of
$184.4 million.
Fidelity Bank is a state-chartered commercial banking institution with September 30, 1977, total deposits
of $7.3 million. It is the smallest of the three proponents. Fidelity Bank operates only a single banking
office, located approximately 15 miles to the northeast
of Greensburg in Westmoreland County.



$

8,371,000
23,973,000
205,681,000
238,003,000

Banking offices
In
To be
operation operated
1
2
11
14

FNB was chartered as a national banking association on November 22, 1902. This bank operates its
main office and one branch in the Youngwood area
and is the only commercial banking facility in the community of Youngwood. As of September 30, 1977, FNB
had total deposits of $21.5 million.
The main office of Charter Bank, in Greensburg, is
approximately 15 miles from the sole office of Fidelity
Bank and there are numerous banking offices in the
intervening area. Fidelity Bank is one of the smallest
commercial banks in Pennsylvania and, with the introduction of a branch of the seventh largest bank in the
state, Equibank, in Derry, Fidelity Bank has suffered a
dramatic loss of its market share of deposits. Although
Charter Bank does maintain one office in Unity Township, approximately 10 miles distant from Derry, there
is only a negligible degree of competition existent between Charter Bank and Fidelity Bank. Therefore,
approval of this proposal will not eliminate any existing
competition to a significant degree.
The head offices of Charter Bank and FNB are about
5 miles apart, and FNB operates a branch 2 miles
north of Youngwood Borough (approximately 3 miles
from an office of Charter Bank). It is noted, however,
that Youngwood Borough is virtually surrounded by
Hempsfield Township wherein six banks, including
Equibank and Pittsburgh National Bank (the fifth
71

largest bank in Pennsylvania), maintain offices. Additionally, although their main offices are only 5 miles
apart, Charter Bank and FNB derive few deposits and
make few loans from each other's respective locality;
the two banks appear to basically serve different market areas. Thus, the proposed consolidation of Charter
Bank and FNB would not eliminate existing competition between these two institutions to any appreciable
extent.
Youngwood Borough is located 25 miles southwest
of the community of Derry. Derry is located within the
less populous eastern section of Westmoreland County. The county is bisected into two distinct portions by
U.S. Route 119, which runs north-south through
Greensburg. The western section contains nearly 90
percent of the county's population, and the larger
proportion of the industrial and commercial establishments. The overflow of Pittsburgh population and industry has expanded into the western portion of Westmoreland County. The eastern portion lies in the foothills
of the Allegheny Mountains, a resort area that is
heavily forested, which has only one large population
center, Latrobe. Due to the geographical barriers and
the dominant influence of the Pittsburgh community
upon the western section of Westmoreland County,
Fidelity Bank and FNB are oriented toward two separate and distinct areas. Consummation of the subject
proposal would not have any adverse effect upon existing competition between these two banks.
Applicable Pennsylvania branching laws permit
commercial banks to expand de novo into contiguous
counties; thus, the applying banks have the legal
capability to branch into each other's areas. Because
of the small size of Fidelity Bank and FNB, their management succession difficulties and limited financial
resources, neither appears to be a likely candidate to
employ that mode of expansion within the foreseeable
future. Although Charter Bank may be expected to
pursue an active course in de novo branching, neither
the Youngwood nor the Derry area appears attractive
for Charter Bank to expand de novo in the face of its
significantly larger competitors. Overall, the small sizes
of all of the proponent banks, and the ability of some of
the state's largest banks to branch throughout the
area, greatly mitigates any adverse effect upon potential competition.
With the proposed consolidation, the competitive
abilities of all three banks will be greatly enhanced and
the resulting bank will be in a position to better serve
its customers and be a more viable banking alternative. Charter Bank is a full-service institution that offers
a wide variety of services to its customers, including
fiduciary services (both personal and corporate).
Neither Fidelity Bank nor FNB offers trust services to its
customers, and the introduction of this new service will
be far more convenient to banking customers in Derry
and Youngwood. The increased legal lending limit of
the resulting institution will also better serve the banking community, especially in short-term financing of
municipal and commercial accounts. In sum, the introduction of new and expanded banking services will
better serve the public, and lends weight toward
approval of this proposal.

72


The financial and managerial resources of Charter
Bank are satisfactory. The financial conditions of Fidelity Bank and FNB are generally satisfactory. The management of both Fidelity Bank and FNB are of concern
in passing upon this application. The situation in both
banks is similar in that neither bank has adequately
provided for management succession. Senior management of Fidelity Bank suffers health problems, and
the decision has been made to "get out of the banking
business." The chief executive officer of FNB has
admitted difficulty in keeping pace with current
changes in banking, especially with regard to various
regulatory requirements. The increased competitive
environment and FNB's board of directors reluctance
to acquire the services of an individual with the necessary training and expertise to assume the duties of the
managerial role, has led to the board's decision to
merge or sell FNB. Charter Bank has the necessary
managerial talent to assume the operations of both
Fidelity Bank and FNB and to adequately provide for
management succession at both banks. Factors relating to financial and managerial resources weigh favorably toward approval of this application.
The future prospects of Charter Bank appear favorable, and the future prospects of Fidelity Bank and
FNB, when combined with Charter Bank, appear more
favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
February 9, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Effect on Existing Competition
The main office of Applicant in Greensburg is 15 miles
from the sole office of Derry Bank in Derry. There are
numerous other banking offices located in this intervening 15-mile area. Applicant has an office in Unity
Township which is 10 miles from Derry, but that bank
has no accounts with residents of Derry. Applicant has
only one mortgage and nine installment loans within
the area encompassed by the Derry ZIP Code, and
Derry Bank has no mortgages and only one installment
loan involving persons in the Greensburg area. Neither
bank derives measurable deposits from areas served
by the other. In sum, the proposed acquisition will not
eliminate existing competition to any significant degree.
The head offices of the Youngwood Bank and Applicant are only 5 miles apart. Youngwood opened a
branch in December 1976, 2 miles north of Youngwood Borough. This branch is approximately 3 miles
away from Applicant. Applicant has no branch offices
in Youngwood Borough nor any offices south of
Greensburg. Youngwood Borough is almost completely surrounded by Hempsfield Township which has six
banks and sixteen offices (not including those of Applicant located there). Recently, Pittsburgh National Bank
and Equibank, ranked fifth and seventh, respectively,
in the state, obtained approval to open branch offices
between Youngwood Bank and Applicant.
The application indicates that Applicant has 20

mortgages (out of a total of 3,126) and 37 installment
loans (out of a total of 12,600) with residents of Youngwood Borough, and derives an equally negligible
amount of deposits from the area served by Youngwood Bank. Also, Greensburg residents have 2 percent of the deposit accounts, less than 4 percent of
the mortgages are less than 3.5 percent of the installment loans of Youngwood Bank. Thus, the proposed
acquisition of the Youngwood Bank would not eliminate existing competition to any appreciable extent.
Effect upon Concentration

If the relevant market area is Westmoreland County,
this merger would have little, if any, adverse effect. All
three banks are now operating offices within Westmoreland County (1970 population: 376,935), one of
the four counties composing the Pittsburgh SMSA. A
total of 22 banks have offices within Westmoreland
County. Because of Pennsylvania's banking laws,
which permit contiguous county branching, some of
the large Pittsburgh banks—including Mellon Bank,
the Union National Bank of Pittsburgh, the Pittsburgh
National Bank, and Equibank—have made significant
inroads upon the county. Of the 79 branch offices
operating in the county as of June 30, 1976, 42 (or 53
percent) were operated by these four large Pittsburgh
banks. Furthermore, in terms of deposits, the top four
banks in Westmoreland County hold 6 percent of
county deposits, so the market is not highly concentrated. Applicant is the second largest bank, with 12
percent of the county's deposits; the Youngwood Bank
ranks 12th with 2 percent; and the Derry Bank ranks
17th with 1 percent.
If the market is defined as either Pittsburgh Market
Area 46 or Greensburg-Latrobe Market Area 45, the
proposed acquisition would have a more adverse effect
in terms of enhancing concentration. Applicant and

Youngwood Bank are located in Pittsburgh Market
Area 46, an area which includes parts of Westmoreland, Beaver, Washington and Butler counties as most
of Allegheny County. Though the four largest banks
have 90.7 percent of the deposits, Applicant has 0.7
percent of the total deposits, whereas Youngwood
Bank has 0.2 percent. Moreover, 39 banks operate
391 offices. The Derry Bank is not represented in this
market at all. Within this area Applicant ranks fifth and
Youngwood Bank ranks 26th.
Though Youngwood is located in Area 46, it appears
to be right on the boundary of the Greensburg-Latrobe
Market Area 45 which has 12 banks with 24 offices. In
that area, Applicant ranks second. Nevertheless, even
if the merger is approved, Applicant will remain
second and will still be behind Mellon Bank which has
deposits of $171 million. This is also a highly concentrated market since the largest four banks hold 83.9
percent of the total deposits. Applicant has 22.7 percent of those deposits. If Youngwood Bank is included
in this market, it would rank fifth, with 4.8 percent of the
total deposits. (Applicant's share of the market would
drop to 21.5 percent.)
While these figures are somewhat higher than those
suggested by the merger guidelines, the relatively
small size of Youngwood Bank, its location very close
to the boundaries of Market Areas 45 and 46, and the
large number of other banks in the region, are mitigating factors. Therefore, a merger between Applicant
and Youngwood Bank would have some adverse
effect on competition.
Conclusion
The proposed acquisition would increase the concentration in Market Areas 45 and 46, and would eliminate
some direct competition, and overall it would have
some adverse competitive effects.

THE AMERICAN NATIONAL BANK AND TRUST COMPANY OF MICHIGAN,
Kalamazoo, Mich., and The First National Bank of Lawton, Lawton, Mich.
Banking offices
Names of banks and type of transaction

Total
assets*

The First National Bank of Lawton, Lawton, Mich. (12084), with
was purchased Mar. 30, 1978, by The American National Bank and Trust Company of Michigan,
Kalamazoo, Mich. (13820), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency by The American National Bank and Trust
Company of Michigan, Kalamazoo, Mich. ("ANBTC"),
the purchasing bank, requesting prior permission to
purchase the assets and assume the liabilities of The
First National Bank of Lawton, Lawton, Mich. ("FNB"),
the selling bank. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth.



$

In
To be
operation operated

9,762,000

2

230,705,000
235,811,000

18
20

ANBTC was chartered on November 1, 1933, and as
of March 31, 1977, the purchasing bank's total deposits were $184.3 million. The largest of seven banking subsidiaries of the 15th largest bank holding company headquartered in Michigan, American National
Holding Company, Kalamazoo, Mich., ANBTC operates its main office in the city of Kalamazoo, and 17
branch offices, all domiciled within Kalamazoo County.
FNB, organized in 1922, had deposits aggregating
$8.3 million as of March 31, 1977. The selling bank
* Asset figures are as of call dates immediately before and after
transaction.

73

maintains only one branch office (West Paw Paw
Township) in addition to its head office.
The closest offices of ANBTC and FNB are approximately 9 miles apart, and all offices of ANBTC are in
Kalamazoo County, whereas both of FNB's offices are
in adjacent Van Buren County. Additionally, three other
banking subsidiaries of American National Holding
Company operate within the relevant market. It therefore appears that approval of this proposal would have
the effect of eliminating a degree of existing competition between ANBTC and FNB. It is noted, however,
that the service area of ANBTC is comprised of two
separate, distinct and noncontiguous areas; one consisting of the cities of Kalamazoo, Portage, Richland,
Plainwell, Oshtemo and Ortego. The second area surrounds the village of Mendon, in St. Joseph County.
The relevant market is served by five commercial
banks that operate a total of 54 branches, and the
market is characterized as being one of high concentration and intense competition. Furthermore, the
largest share of the market's relevant deposits is held
by a competing registered bank holding company,
First National Financial Corporation, Kalamazoo, which
holds approximately one-third of the total commercial
bank deposits within the market, and whose two
offices of The First National Bank and Trust Company
of Michigan located in Paw Paw, are the nearest
offices of any competing bank to an office of FNB.
Inasmuch as ANBTC's share of market deposits would
increase by 0.7 percent, to 21.3 percent, it is the conclusion of this Office that the subject proposal would
have some adverse effect upon existing competition.
The introduction of ANBTC into the Lawton area will
result in improved and expanded banking services to
the banking community including, but not limited to,
higher interest rates on savings accounts, lower service charges on demand checking accounts, and the
introduction of new banking services such as trust services, mortgage loan sales and services, overdraft
banking, and an increased legal lending limit. Considerations relating to convenience and needs benefits
add some weight toward approval of the application.
A review of the application discloses that the annual

net earnings of FNB for the past 4 operating years
have declined significantly; net earnings of approximately $31,000 for 1976 are only slightly in excess of
30 percent of the bank's net earnings for 1973. That
significant decline in earnings is primarily attributable
to the purchase and installation of computer facilities,
and related personnel staffing.
Of additional note, FNB is served by absentee executive management and requires the services of a
full-time, competent chief executive officer. Affiliation
with ANBTC and its corporate parent should provide
FNB with the financial stability and managerial direction which it needs inasmuch as both the financial and
managerial resources of ANBTC are considered to be
satisfactory. The future prospects of both proponent
banks are considered to be satisfactory; however, the
future prospects of FNB in conjunction with ANBTC are
regarded as more favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
January 18, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Lawton and Paw Paw are small communities located in
a predominantly rural area approximately 12 miles
west of Kalamazoo. The closest office of a subsidiary
of ANHC to an office of Bank is American National
Bank—West's Lawrence office which is about 8 miles
west of Bank's office in Paw Paw. In addition, an office
of Applicant is located in Oshtemo, about 10 miles
east of Lawton. Only one other banking organization
operates offices within 10 miles of Lawton. The First
National Bank and Trust Co. of Michigan, total deposits of approximately $375 million, operates two
offices in Paw Paw. It therefore appears that the proposed merger would eliminate direct competition between subsidiaries of ANHC and Bank, and would reduce significantly the number of competitive alternatives in the area.
We conclude that the proposed merger would have
an adverse effect on competition.

FIRST NATIONAL BANK OF GRAND RAPIDS,
Grand Rapids, Mich., and The Moline State Bank of Lawton, Lawton, Mich.
Banking offices
Names of banks and type of transaction

Total
assets

The Moline State Bank, Moline, Mich., with
and First National Bank of Grand Rapids, Grand Rapids, Mich. (16296), which had
merged Mar. 31,1978, under charter and title of the latter bank (16296). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application filed pursuant to the Bank
Merger Act of 1966 (12 USC 1828(c)), that requests
prior written consent of a proposed merger of The
74



In
To be
operation operated

$ 6,506,000
17,573,000
24,079,000

Moline State Bank, Moline, Mich. ("Merging Bank"),
into First National Bank of Grand Rapids, Grand
Rapids, Mich. ("Charter Bank"), under the charter and
title of First National Bank of Grand Rapids. The subject application rests upon an agreement executed be-

tween the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Charter Bank was issued national banking association charter number 16296 by this Office on March 21,
1974, and as of September 30, 1977, the bank held
total deposits of $14.5 million.
Merging Bank is a state-chartered commercial banking institution that was established in 1919. As of June
30, 1977, Merging Bank's total deposits aggregated
approximately $5.7 million.
Both of the proponent banks are wholly-owned
banking subsidiaries of First National Financial Corporation, Kalamazoo, Mich. ("FNFC"), a registered multibank holding company, the seventh largest headquartered in Michigan. Due to this common ownership and
control, there is no existing competition between Charter Bank and Merging Bank, nor is there any potential
for the development of competition in the future.
The combination of the proponent banks would
serve to establish a more meaningful banking alternative and a more viable competitor that would possess
a strengthened capital base and be in a better position
to offer new and expanded banking services to the
banking public. Considerations relating to conveni-

ence and needs benefits are regarded as a positive
factor in this case.
The financial and managerial resources of Merging
Bank are considered to be satisfactory. Charter Bank
has encountered numerous asset problems in its operating history due to the inability of its former corporate
parent, Northern States Bancorporation, Detroit, to
properly supervise the bank's affairs. Charter Bank
was sold to FNFC in December 1976, and its present
holding company parent has met with some success
in its efforts to improve the overall condition of the
bank. The future prospects of Merging Bank are favorable, and Charter Bank's future prospects are greatly
enhanced by approval of this transaction.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that this application is in the
public interest, and should be, and hereby is,
approved.
February 22, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

THE FIRST NATIONAL BANK IN HUNTINGTON,
Huntington, ln<±, and Roanoke State Bank, Roanoke, Ind.
Banking offices
Names of banks and type of transaction

Total
assets

Roanoke State Bank, Roanoke, Ind., with
and The First National Bank in Huntington, Huntington, Ind. (14398), which had
merged Mar. 31, 1978, under charter and title of the latter bank (14398). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has received an application, pursuant to 12 USC 1828(c),
requesting prior consent of the proposed merger of
Roanoke State Bank, Roanoke, Ind. ("Merging Bank"),
into The First National Bank in Huntington, Huntington,
Ind. ("Charter Bank"), under the charter and title of
The First National Bank in Huntington. The subject application rests upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
Merging Bank is a state-chartered commercial banking institution that commenced operations on July 1,
1949. As of March 31, 1977, Merging Bank held total
commercial bank deposits of slightly less than $8 million, thereby ranking as the smallest bank headquartered within Huntington County.
Charter Bank has operated as a national banking
association since February 18, 1938, when this Office
granted it charter number 14398. As of March 31,
1977, this bank's total deposits were $65.7 million. In
addition to its main office domiciled in Huntington,
Charter Bank operates three other offices in Hunting


In
To be
operation operated

$ 9,235,000
76,366,000
85,921,000

ton, and one branch in Andrews, approximately 5
miles west of Huntington. Charter Bank ranks as the
largest of six commercial banks headquartered in
Huntington County, and controls slightly less than 43
percent of the county's total deposits.
The focal point of this application is the definition of
the relevant geographic market. If only Huntington
County were to be considered as the market, on a pro
forma basis Charter Bank would control approximately
48 percent of the county's deposits and the number of
banking alternatives would decrease from six to five.
The application reflects, however, that the relevant
geographic market more properly encompasses more
than Huntington County, per se, including the southeastern section of Whitley County and the southwestern portion of Allen County, including the city of Fort
Wayne. It is of significant note that four Fort Waynebased banks have branches located within 11 miles of
Roanoke. Assuming that the geographic market as defined by the proponent banks is correct, Charter Bank
would be the sixth largest bank, controlling slightly
more than 4 percent of the market's deposits, and
Merging Bank would be the smallest bank, controlling
75

only 0.5 percent of total deposits. Additionally, due to
a self-imposed lending limitation of $25,000, the Merging Bank refers loans in excess of that limit to Charter
Bank for origination and servicing. Therefore, it is not
unreasonable to conclude from that fact alone that
Merging Bank and Charter Bank are not major competitors. Although there is some overlap of the proponent banks' respective trade areas, the resources and
scope of operation of Merging Bank are limited, and its
competitor influence within its market is minimal.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that approval of this application would not have a significantly adverse effect upon
competition.
With approval of this application, the city of Roanoke
would no longer be afforded "home-office" protection,
and de novo branching by other banks in Huntington
County, into Roanoke, would be possible. The introduction of new and expanded banking services to the
present customers of Merging Bank should better
serve the banking community within the Roanoke area
and is considered to be a positive factor in approval of
this application.
The financial and managerial resources of both

Charter Bank and Merging Bank are satisfactory. The
president of Merging Bank is past the usual age of
retirement, however, due to a lack of successor management within the bank, and because the prospects
of obtaining a competent successor have not been
favorable, he has been reluctant to retire. Charter Bank
possesses sufficient managerial strength to operate
Merging Bank, and thereby resolve the management
succession problem of Merging Bank.
The future prospects of both proponent institutions
appear favorable, and the combination of Merging
Bank with Charter Bank, should help to insure the
favorable future prospects of both banks.
It is thus the conclusion of the Office of the Comptroller of the Currency that this application is not
adverse to the public interest, and should be, and
hereby is, approved.
December 2, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a significantly adverse
effect upon competition.

THE DETROIT BANK—STERLING, N.A.,
Sterling Heights, Mich., and Van Dyke—Sixteen Mile Branch of The Detroit Bank and Trust Company, Detroit, Mich.
Banking offices
Names of banks and type of transaction

Total
assets*

Van Dyke—Sixteen Mile Branch of The Detroit Bank and Trust Company, Detroit, Mich., with
was purchased Apr. 1, 1978, by The Detroit Bank—Sterling, N.A., Sterling Heights, Mich. (16712),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted an application requesting prior consent for
The Detroit Bank—Sterling, N.A. (organizing), Sterling
Heights, Mich. ("Purchasing Bank"), to purchase the
assets and assume the liabilities of Van Dyke—Sixteen
Mile Branch Office ("Van Dyke Branch"), of The Detroit
Bank and Trust Company, Detroit, Mich. ("Selling
Bank"). The subject application rests upon an agreement executed between the proponent banks, and is
incorporated herein by reference, the same as if fully
set forth.
By an action dated August 1, 1977, this Office
granted preliminary approval for the organization of
Purchasing Bank; that to date, has no operating history.
Selling Bank is a state-chartered commercial banking institution, and is a member of the Federal Reserve

* Asset figures are as of call dates immediately before and after
transaction.
t Assets are for the entire bank.

76



$3,432,512,000f
3,000,000
27,610,000

In
operation

To be
operated

1
0

System. As of June 30, 1977, Selling Bank had total
deposits of $2.8 billion.
Both of the proponent banks are subsidiaries of DETROITBANK Corporation, Detroit, Mich., ("DETROITBANK"), the third largest banking organization in
Michigan. Purchasing Bank is to assume the business
of an existing branch of one of DETROITBANK's five
banking subsidiaries; and would merely transfer
approximately $16 million in deposits into a newly created institution, thereby producing no adverse effect
upon competition.
Although Purchasing Bank would be servicing its
customers as a relatively small subsidiary of DETROITBANK, rather than as a branch of Selling Bank, Purchasing Bank will have the ability to provide additional
banking offices in Sterling Heights, as the need arises.
Additionally, the establishment of a bank in Sterling
Heights, with the ability to open new branches, would
have a favorable impact upon future competition within
the city, and will better serve the needs of the banking
community. Considerations relating to convenience
and needs benefits weigh toward approval of this application.

The financial and managerial resources and future
prospects of Selling Bank are generally satisfactory.
Inasmuch as Purchasing Bank is essentially the successor to a successfully operated branch office, its
future prospects as a subsidiary of DETROITBANK
appear favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
January 30, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Van Dyke—Sixteen Mile Branch Office of The Detroit
Bank and Trust Company would become a subsidiary
of DETROITBANK 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 DETROITBANK Corporation, it
would have no effect on competition.

THE FIRST NATIONAL BANK OF MARYLAND,
Baltimore, Md., and The First National Bank of Snow Hill, Snow Hill, Md.
Banking offices
Names of banks and type of transaction

Total
assets*

The First National Bank of Snow Hill, Snow Hill, Md. (3783), with
and The First National Bank of Maryland, Baltimore, Md. (1413), which had
merged Apr. 1, 1978, under charter and title of the latter bank (1413). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), an application has been
filed with the Office of the Comptroller of the Currency
seeking prior consent to merge The First National Bank
of Snow Hill, Snow Hill, Md. ("Merging Bank"), into The
First National Bank of Maryland, Baltimore, Md. ("Charter Bank"), under charter and title of The First National
Bank of Maryland. The subject application rests upon
an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth.
Merging Bank was granted its charter by this Office
on August 29, 1887, and as of September 30, 1977,
the bank had total commercial bank deposits of $13.9
million. The Merging Bank has not established any
branches since its organization, and the instant proposal constitutes Merging Bank's first participation in a
merger or acquisition transaction.
The Office of the Comptroller of the Currency on July
10, 1865, granted national banking association charter
number 1413 to Charter Bank. With September 30,
1977, total deposits of approximately $1.2 billion,
Charter Bank now operates 83 banking offices
throughout the state of Maryland, and ranks as the
third largest bank headquartered within the state.
Additionally, Charter Bank has received approval for
the establishment of a CBCT unit in Ocean City, Md.
Although Charter Bank's CBCT unit is to be located
in the northeastern portion of Worcester County (Merging Bank's primary service area), Charter Bank presently operates no banking offices within the county,
and its closest office to Snow Hill is approximately 17
miles distant near Salisbury, with offices of competing
banks located within the intervening area.
The community of Snow Hill in the southern portion
of Worcester County on Maryland's eastern shore, is



$

16,122,000
1,478,851,000
1,492,099,000

In
To be
operation operated
1
83
84

currently served by two commercial banking offices;
Merging Bank (the larger of the two), and an office of
Maryland National Bank, the largest commercial bank
in Maryland. The whole of Worcester County however,
is served by a total of 10 banks that operate 18 banking offices, including one additional branch of Maryland National Bank. Merging Bank ranks as the fourth
largest of the 10 banks with slightly in excess of 10
percent of the total deposits within the county.
Inasmuch as Charter Bank is not represented within
the relevant market, Merging Bank experiences direct
competition from the largest bank in Maryland, and
given the geographic distance separating the closest
offices of the proponent banks, there is no meaningful
competition existing between Merging Bank and Charter Bank, and approval of the proposed merger would
have no adverse effect upon competition.
Applicable Maryland statutes allow commercial
banks to branch statewide. However, it appears that
the Snow Hill area is not attractive for de novo entry b\
Charter Bank and approval of this proposal would not
adversely affect potential competition.
With the introduction of Charter Bank into Snow Hill,
the competitive environment should be stimulated, and
the banking public should benefit from the new and
expanded banking services that Charter Bank will provide. Considerations relating to convenience and
needs benefits are regarded as a positive factor in
considering approval of this application.
The financial and managerial resources of both
Charter Bank and Merging Bank are satisfactory, and
the future prospects of both institutions are regarded
as favorable.
* Asset figures are as of the call dates immediately before and after
transaction.

77

Accordingly, applying the statutory criteria, it is the
conclusion of this Office that this application is not
adverse to the public interest, and should be, and
hereby is, approved.
February 13, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Snow Hill (1970 population 2,200), is a rural community
located about 20 miles southwest of Ocean City in
Worcester County. The area surrounding Snow Hill is
primarily agricultural and light industry. Snow Hill is the
county seat and oldest town in the county, but has not
experienced the growth and development in the northern part of the county around Ocean City.
Applicant operates five branches in Salisbury, the
commercial center of the area, which is within 17 miles of
Snow Hill. These are the offices of Applicant and Bank
which are the closest to each other, and there are no
other banks in the area between Snow Hill and Salisbury.
It thus appears that the proposed acquisition will eliminate at least some existing competition.
Worcester County contains 10 banks with 21 offices,
most of which are in the more developed northern portion of the county in and around Ocean City. The southern half of the county, considered by Applicant to be the

primary service area of Bank, contains three banks with
five offices. In this area, Maryland National Bank, the
largest in the state, has 48.5 percent of deposits, Eastern
Shore National Bank has 27.6 percent, and Bank has
23.9 percent. Applicant is currently not represented in
the primary service area of the Bank, although it is heavily represented in the contiguous Salisbury area. The
southern Worcester County-Salisbury area—whether it
can properly be defined as a market is somewhat unclear on the facts before us—presently contains nine
banks, including branches of the state's three largest
banks. As of December 31, 1976, Applicant was the
largest banking organization in the area controlling
$63.1 million, 29.5 percent of the area's deposits, and
Bank was the fifth largest, controlling $12.2 million, 5.7
percent of the area's deposits. Thus, the proposed acquisition would increase Applicant's share from 29.5
percent to 35.2 percent of deposits in this larger area.
Maryland permits statewide branching, so Applicant
could theoretically enter Snow Hill de novo by establishing a branch. Given the population of Snow Hill,
however, it does not appear that the town is a particularly
attrective location.
Overall, the proposed acquisition would have an
adverse effect upon competition.

FLAGSHIP FIRST NATIONAL BANK OF MIAMI BEACH,
Miami Beach, Fla., and Flagship First National Bank of Coral Gables, Coral Gables, Fla., and Flagship National
Bank of Miami, Miami, Fla.
Banking offices
Names of banks and type of transaction

Total
assets

Flagship National Bank of Miami, Miami, Fla. (15411), with
andFlagship First National Bank of Coral Gables, Coral Gables, Fla. (13008), with
and Flagship First National Bank of Miami Beach, Miami Beach, Fla. (12047), which had
merged Apr. 30, 1978, under charter of the latter bank (12047) and title "Flagship National Bank of
Miami." The merged bank at date of merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission to merge Flagship National Bank of Miami, Miami, Fla. ("Miami
Bank"), and Flagship First National Bank of Coral
Gables, Coral Gables, Fla. ("Coral Gables Bank"), into
Flagship First National Bank of Miami Beach, Miami
Beach, Fla. ("Charter Bank"), under the charter of
Flagship First National Bank of Miami Beach, and with
the title of "Flagship National Bank of Miami". The subject application rests upon an agreement executed between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Charter Bank was established in 1921, operates
under national banking association charter number
12047 and, as of calendar year-end 1977, had total
deposits of $227.2 million.

78


In
To be
operation operated

$121,338,000
222,517,000
248,243,000
571,967,000

Miami Bank was established in 1964, operates
under national banking association charter number
15411, and as of calendar year-end 1977, had total
deposits of $110.1 million.
Coral Gables was established in 1926, operates
under national banking association charter number
13008 and, as of calendar year-end 1977, had total
deposits of $192.6 million.
All three of the banks involved in the subject proposal are banking subsidiaries of Flagship Banks, Inc.,
Miami Beach, Fla., a registered multi-bank holding
company. Due to their common ownership and control,
there is no meaningful competition existent among the
proponent institutions. This application must be regarded essentially as a corporate reorganization
whereby Flagship Banks, Inc., is consolidating a portion of its banking interests.

It is therefore the opinion of the Office of the Comptroller of the Currency that this proposal is not adverse
to the public interest, and should be, and hereby is,
approved.
March 24, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are all wholly-owned subsidiaries
of the same bank holding company. As such, their
proposed mergers are essentially corporate reorganizations and would have no effect on competition.

MICHIGAN NATIONAL BANK—PORT HURON,
Port Huron, Mich, and Four Port Huron Branches of Michigan National Bank, Lansing, Mich.
Banking offices
Names of banks and type of transaction

Total
assets*

Four Port Huron Branches of Michigan National Bank, Lansing, Mich. (14032), with
were purchased Apr. 20, 1978, by Michigan National Bank—Port Huron, Port Huron, Mich. (16714),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application filed pursuant to 12 USC
1828(c), that seeks prior written consent for Michigan
National Bank—Port Huron (organizing), Port Huron,
Mich. ("Purchasing Bank"), to purchase the assets
and assume the liabilities of four Port Huron branches
of Michigan National Bank, Lansing, Mich. ("Selling
Bank"). The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth. Additionally, as required by the Bank Merger
Act, notice of the proposed transaction was published
in a form approved by this Office, and reports on the
competitive effects were requested from the U.S. Attorney General, the Federal Deposit Insurance Corporation, and the Board of Governors of the Federal Reserve System; and the application and reports have
been considered in the light of the factors set forth
within the Bank Merger Act.
By action dated August 8, 1977, this Office granted
preliminary approval to organize a new national bank
in Port Huron, to be known as "Michigan National
Bank—Port Huron." The new bank application was
sponsored by principals of the second largest commercial banking organization headquartered in Michigan, Michigan National Corporation, Bloomfield Hills,
Mich. ("MNC"), a registered multi-bank holding company that controlled 16 banks with aggregate deposits
of approximately $3.4 billion, as of June 30, 1977. The
primary function of Purchasing Bank is to facilitate the
acquisition of assets and assumption of the liabilities of
four branch offices in Port Huron of MNC's largest
banking subsidiary, Michigan National Bank, Lansing,
Michigan.
MNC is the largest banking organization represented in the Port Huron area, and Selling Bank is




$1,788,909,000f
14,000,000
190,048,000

In
To be
operation operated
4
0

legally prohibited from additional branching in Port
Huron. As a separately chartered institution however,
Purchasing Bank would be allowed to enjoy full branching privileges, and inasmuch as Purchasing Bank is
a new bank and would acquire the assets and assume
the deposit liabilities (approximately $153.5 million) of
four branches of a bank currently controlled by MNC,
consummation of the subject proposal would merely
have the effect of transferring accounts from an existing bank to a new bank, both of which are controlled
by MNC.
Purchasing Bank, to date, has no operating history;
however, based upon its proposed management, initial capitalization, and projected earnings, in conjunction with the historical operating history of the four
branches of Selling Bank, Purchasing Bank's future
prospects, as a subsidiary of MNC, appear favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this proposal is not adverse to the public
interest, and should be, and hereby is, approved.
March 21, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed transaction is part of a plan through
which the four Port Huron branches of Michigan National Bank would become subsidiaries of Michigan
National Corporation, a bank holding company. The
instant transaction, 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 Michigan National Corporation, it would have
no effect on competition.
*Asset figures are as of call dates immediately before and after
transaction.
t Assets are for the entire bank.

79

ATLANTIC NATIONAL BANK OF WEST PALM BEACH,
West Palm Beach, Fla., and Atlantic Westside Bank of Palm Beach County, West Palm Beach, Fla.
Banking offices
Total
assets*

Names of banks and type of transaction

Atlantic Westside Bank of Palm Beach County, West Palm Beach, Fla., with
was purchased Apr. 30,1978, by Atlantic National Bank of West Palm Beach, West Palm Beach, Fla.
(13300), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission for Atlantic National Bank of West Palm Beach, West Palm Beach,
Fla. ("Purchasing Bank"), to purchase the assets and
assume the liabilities of Atlantic Westside Bank of Palm
Beach County, West Palm Beach, Fla. ("Selling
Bank"). The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth.
Purchasing Bank was granted charter number
13300 as a national banking association on March 20,
1929, and as of September 30, 1977, had total deposits of $69.2 million.
Selling Bank commenced commercial banking operations in 1974, and as of September 30, 1977, had
total deposits of $9.0 million.
Both Purchasing Bank and Selling Bank are banking
*Asset figures are as of call dates immediately before and after
transaction.

In
To be
operation operated

$ 12,472,000
97,447,000
111,950,000

subsidiaries of the sixth largest commercial banking
organization headquartered within the state of Florida,
Atlantic Bancorporation, Jacksonville, Fla., a registered multi-bank holding company that controls 31
banks with deposits aggregating $1.2 billion. Inasmuch as the two proponent banks are commonly
owned and controlled, approval of this application
would not produce an adverse impact upon any relevant area of consideration.
The instant proposal essentially represents a corporate reorganization whereby Atlantic Bancorporation is
realigning and consolidating its banking interests. The
application is therefore deemed to be not adverse to
the public interest, and should be, and hereby is,
approved.
March 31, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The banks are both wholly-owned subsidiaries of the
same bank holding company. As such, the proposed
transaction is essentially a corporate reorganization
and would have no effect on competition.

THE FIRST NATIONAL BANK OF CONVOY,
Convoy, Ohio, and The Middle Point Banking Company, Middle Point, Ohio
Banking offices

Names of banks and type of transaction

Total
assets

The Middle Point Banking Company, Middle Point, Ohio, with
and The First National Bank of Convoy, Convoy, Ohio (8017), which had
merged May 1,1978, under charter of the latter bank (8017) and title "United National Bank." The
merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), the Bank Merger Act, an
application has been filed with the Office of the Comptroller of the Currency that requests approval of a proposed merger of The Middle Point Banking Company,
Middle Point, Ohio ("Merging Bank"), into The First National Bank of Convoy, Convoy, Ohio ("FNB"), the
Charter Bank, under the charter of The First National
Bank of Convoy, and with the title of "United National
Bank." The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth. Reports on the competitive factors of the propos
80


In
To be
operation operated

$ 6,024,000
15,354,000
20,520,000

al were solicited from the Attorney General, the Federal Deposit Insurance Corporation and the Board of
Governors of the Federal Reserve System; none of the
three agencies concluded that the proposal would
have substantially adverse competitive effects. As an
incident to the proposed merger, the existing office of
Merging Bank would become a branch of the resulting
bank, and the resulting bank will change its corporate
title to "United National Bank." The Office of the Comptroller of the Currency has considered this application
and all reports received in the light of the factors set
forth in the Bank Merger Act.
FNB has operated under national banking associa-

tion charter number 8017 since said charter was
issued by this Office on December 23, 1905. FNB, with
total deposits of approximately $12.6 million, as of
September 30, 1977, operates only one branch office
in addition to its main office.
Merging Bank is a unit state-chartered commercial
banking institution that had deposits aggregating
approximately $4.9 million on September 30, 1977.
The closest office of FNB to Merging Bank's site is
FNB's main office in Convoy, approximately 15 miles
distant. The area intervening between these offices
contains offices of competing banks, and the intervening market area around the city of Van Wert, serves to
minimize any competitive overlap of the proponents.
Although there would be the elimination of some existing competition between FNB and Merging Bank,
this competition is regarded as negligible; and overall,
consummation of the instant proposal would have no
substantially adverse effect upon competition.
Pursuant to applicable Ohio state branching statutes, either FNB or Merging Bank could expand via de
novo branching throughout Van Wert County. The loss
of this potential competition is not viewed as significant, however, given the relatively small size of the
proponent banks, and their ranking within the relevant
market.
Van Wert County is located within a rich agricultural
area of Ohio, and the record indicates that, due to its
small lending limit (approximately $35 thousand),
Merging Bank has been unable to accommodate loan
requests from customers with larger farm operating requirements. Consummation of this proposal would increase the legal lending limit of the resulting bank to a
level that would provide a more convenient financing

source for local farm operations, and the surviving
bank would be a more meaningful banking alternative.
Additionally, new and expanded banking services
would benefit the banking public. Considerations relating to convenience and needs benefits are regarded
as being consistent with approval.
The financial and managerial resources of FNB are
considered to be satisfactory. The financial resources
of Merging Bank are generally satisfactory. The directorate of Merging Bank does not appear to have adequately provided for adequate management to maintain a viable banking organization. Since August 1977,
Merging Bank has not had its own chief operating
officer and interim management has been provided by
FNB. FNB's management appears to be competent
and capable bankers with the necessary experience
required to direct the affairs of Merging Bank. Banking
factors, in this case, weigh heavily for approval of the
application.
The future prospects of FNB appear favorable, and
the future prospects of Merging Bank are greatly enhanced by approval of this application.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved; and, incident
thereto, the establishment of a branch office at the site
of Merging Bank's main office, by FNB, is approved.
March 31, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

THE TROTWOOD BANK,
Trotwood, Ohio, and The Central Trust Company of Montgomery County, National Association, Dayton, Ohio
Banking offices

Names of banks and type of transaction

Total
assets

The Trotwood Bank, Trotwood, Ohio, with
and The Central Trust Company of Montgomery County, National Association, Dayton, Ohio (16330),
which had
merged May 4, 1978, under charter and title of the latter bank (16330). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act of 1966 (12 USC
1828(c)), the Office of the Comptroller of the Currency
is in receipt of an application that seeks prior written
consent to effectuate a proposed merger of The Trotwood Bank, Trotwood, Ohio ("Merging Bank"), into
The Central Trust Company of Montgomery County,
National Association, Dayton, Ohio ("Charter Bank"),
under the charter and title of The Central Trust Company of Montgomery County, National Association. The
subject application rests upon an agreement executed
between the proponent banks, and is incorporated herein by reference, the same as if fully set forth.



In
To be
operation operated

$39,937,000

3

32,973,000

4

72,910,000

Charter Bank was granted national banking association charter number 16330 by this Office on May 21,
1974, and as of June 30, 1977, the Charter Bank's
deposits had grown to a total of $20.9 million.
Merging Bank commenced operations as a statechartered commercial banking institution in 1908, and
is located approximately 7 miles northwest of Dayton,
Ohio, the county seat and largest city within Montgomery County, Ohio. As of June 30, 1977, Merging Bank
had total deposits of $33.5 million. In addition to its
main office, Merging Bank operates two branches, one
established in 1970 located at the Broadmore Plaza in
Trotwood, and one at the Salem Mall in Dayton, estab81

lished in 1976. The subject transaction represents
Merging Bank's initial participation in a merger or consolidation transaction during its 70-year operating history.
The proponents' closest offices are Merging Bank's
newly opened branch at the Salem Mall, less that 1
mile from the Friendship branch of Charter Bank. It
should be noted however, that the Friendship branch
is located in a center for senior citizens, and is open
only one day during the week. The next closest offices
are the Salem Mall office and the Englewood office of
Charter Bank. These offices are approximately 6 miles
apart, and there are offices of competing banking institutions within the intervening area. The banking structure of the Dayton Banking Market, particularly Montgomery County, is dominated by three large Daytonbased banks (The First National Bank, The Third National Bank and Trust Company of Dayton, and Winters
National Bank and Trust Co.) controlling slightly less
than 90 percent of the total commercial bank deposits
within Montgomery County.
It appears that Merging Bank experiences its most
intense competition from the Trotwood branch of The
Third National Bank and Trust Company of Dayton, an
institution whose total deposits are in excess of nine
times those of Merging Bank. Thus, there is no significant existing competition between the proponent
banks that would be eliminated by approval of this
proposed transaction.
Applicable Ohio state branching statutes would permit both Charter Bank and Merging Bank to establish
de novo banking offices throughout their home county.
However, given the sizes of the proponents in relation
to their major competitors, the loss of any potential
competition is not regarded as significant, and should
not bar approval of this application. In point of fact, the
combined bank resulting from this transaction will be
in a better position to compete with the significantly
larger competitors in its market.
In addition to the benefit from additional lending resources and several larger scale operational efficiencies, the resulting bank, as a banking affiliate of the
Central Bancorporation, Inc., Cincinnati, a registered
multi-bank holding company, the eighth largest in
Ohio, would benefit from specialized expertise that
would be available through affiliation with the holding
company parent and be in a position to offer new and
expanded banking services to the public. Considerations relating to convenience and needs benefits
weigh for approval of the application.
The financial and managerial resources of Charter
Bank and Merging Bank are generally satisfactory. The
president and chief executive officer of Merging Bank
is currently near the usual age of retirement and there
does not appear to be any strong successor available
within ranks of the existing officers of the bank. Charter
Bank, and its corporate parent, possess the competent and capable managerial talent necessary to provide for the orderly succession of senior management
at Merging Bank. The capital structure of the surviving
institution will be strained. Additionally, inasmuch as
the merger agreement executed between Charter
Bank and Merging Bank makes provision for stockhol
82


ders of Merging Bank to receive a deferred payment,
the resultant bank's aggregate indebtedness to these
stockholders, may result in a violation of 12 USC 82.
Therefore, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and subject to the following conditions is,
approved.
In order to ensure the favorable future prospects of
the surviving national banking association, prior to, or
at the time of, consummation of this proposal, the equity capital accounts of the resulting bank shall be increased by an amount aggregating at least $5 million.
Additionally, should there actually arise any violation of
12 USC 82, it will be rectified prior to consummation of
the subject proposal.
April 4, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Effect on Actual Competition
Applicant and Bank are direct competitors. All of their
offices are in the northwest quadrant of Montgomery
County. Excluding Applicant's Friendship Center
branch, the nearest pair of offices—Applicant's Englewood branch and Bank's Salem Mall branch—are 5
miles apart. Other banks have offices adjacent to
these two branches and in the intervening area. Bank's
other two offices are within 6.5 miles of Applicant's
offices.
Using Montgomery County as the relevant market,
this merger would not have an adverse effect on actual
competition. The application, however, suggests an
area labelled the "Primary Area-Trotwood," from which
almost three-fourths of Bank's deposits are derived, as
the relevant market. Application, Exhibit C, pp. 3-4;
Appendix 1 (Map). Six banks operate in Primary AreaTrotwood; the three large downtown Dayton banks
hold 73 percent of the area's deposits (measured by
branch office deposits). Bank is fourth largest with a
16.7 percent market share, and Applicant is the smallest with a 1.0 percent market share. Application, Exhibit C, p. 10. Without taking a position as to the relevant geographic market or markets for analyzing this
application, we note that the proposed merger would
eliminate existing competition to a substantial extent
within the Primary Area-Trotwood.
Effect on Concentration

Montgomery County has 12 commercial banks, more
than any other county in Ohio. Nevertheless, it is one
of the most concentrated banking markets in the state.
The three large downtown banks between them hold
89 percent of deposits and loans. Bank, the county's
fourth largest bank, is only one-eighth as large as the
third largest bank. The bank resulting from the proposed merger will still be a distant fourth in size with 4.1
percent of the market. It would be more than twice as
large as the fifth largest bank, which has a 1.9 percent
share.
The predictable consequences of this tightly concentrated market are reflected in the pricing of banking services in Montgomery County. The three large
downtown banks offer passbook savings accounts

which pay interest only on the low monthly balance,
and none offer "free checking" accounts.
During the past 10 years, four new banks have received charters in Montgomery County and there has
been one bank merger. Applicant, the most recent
bank chartered, merged with another of the four new
banks 7 months after Applicant commenced business.
Although 22 branches have been opened in the last 5
years, the county has significantly fewer bank offices
per capita than any of Ohio's major banking markets.
Bank (60.0 percent growth) and Applicant (57.9 percent growth) were respectively the second and third
fastest growing banks in Montgomery County, as
measured by deposit growth, between December 31,
1974 and 1976. Only BancOhio's subsidiary bank
grew at a faster rate (74.4 percent). Despite the rapid
growth of these three small banks, the market share of
the three large downtown banks declined by less than
2 percent during those two years.
Effect on Potential Competition

Ohio law currently restricts banks to branching within a
single county. However, the state legislature appears
likely to pass a more liberal branching statute in the
near future. The new statute would permit statewide
branching through acquisition immediately and, starting in 1979, de novo office branching in adjacent
counties. Holding companies currently operate statewide.
The proposed acquisition would eliminate Dayton's
most desirable toehold entry possibility. The only
realistic chance of reducing the domination of the
three large downtown banks is if outside banking organizations enter Dayton. Although they are relatively
small banks, Applicant and BancOhio's subsidiary are
viewed in Dayton as credible competitors of the three
large downtown banks because they can draw on the
resources and expertise of their parent corporations.
Although the population of Dayton has declined in
recent years, its banks nevertheless appear to have

much room for growth. In both Akron and Toledo,
which have also declined in size in recent years, the
banks have significantly more branch offices per capita, and a greater percentage of total savings. If Dayton's banks operated as many branches or held the
same percentage of savings, they would operate 16 to
34 more branches and hold an additional $297 to 444
million in deposits. These figures suggest that Dayton
is a desirable market for a banking organization not yet
present.
No one banking organization not presently in Montgomery County can be identified as the one most likely
to enter Dayton. Nevertheless it seems reasonable to
expect one or more to do so. At the present, they can
enter Dayton by chartering a new bank or by acquiring
an existing bank.
Bank's acquisition by an outside banking organization would increase the probability of ultimately deconcentrating the Dayton banking market. Bank is the
most desirable toehold acquisition possibility among
Montgomery County's seven small independent banks
because: (1) it is the largest; (2) it is the fastest growing; (3) it is profitable; (4) it is one of two with any
significant experience operating a branch network;
and (5) it is one of two with an office close to downtown Dayton. Taking everything into account, we conclude that this acquisition would have an adverse
effect on potential competition.
Conclusion

If this transaction was either a horizontal merger between two independent banks, or a market extension
merger by an outside holding company, we would be
less concerned. However, due to the nature of the
Dayton market, the unique characteristics of Bank, the
imminent change in the regulatory background, and
the fact that this would be Applicant's second merger
in just over 3 years, we believe that the proposed acquisition will have an adverse effect on competition.

WELLS FARGO BANK, NATIONAL ASSOCIATION,
San Francisco, Calif, and The First National Bank of Orange County, Orange, Calif.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank of Orange County, Orange, Calif. (8181), with
and Wells Fargo Bank, National Association, San Francisco, Calif. (15660), which had
merged May 6,1978, under charter and title of the latter bank (15660). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has received an application, filed pursuant to 12 USC
1828(c), the Bank Merger Act, requesting the prior
approval for the proposed merger of The First National
Bank of Orange County, Orange, Calif. ("FNB"), the
merging bank, into Wells Fargo Bank, National Association, San Francisco, Calif. ("Wells"), the charter



$

177,335,000
13,327,844,000
13,487,435,000

In
To be
operation operated

11
356
367

bank, under the charter and title of Wells Fargo Bank,
National Association. Incident to the proposed merger,
the existing offices of FNB will become branches of
Wells, as the resulting bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Wells, the third largest commercial bank headquar83

tered in California, was granted national banking association charter number 15660 by this Office on February 5, 1910. As of September 30, 1977, Wells had total
deposits (domestic and foreign) aggregating approximately $12.4 billion, and operated its main office and
345 branches.
FNB commenced operations in 1906, and possesses national banking association charter number 8181.
On September 30, 1977, FNB had total deposits of
$136.5 million and operated 11 banking offices, all
domiciled within the boundaries of Orange County.
Wells currently operates 12 banking offices throughout Orange County (eight branches, one of which is in
Orange County, were acquired on January 10, 1978,
when this Office approved Wells' application to acquire eight offices from The Bank of California). The
closest offices of Wells and FNB are slightly in excess
of 1 mile apart, and there exists some competition between the two banks. The elimination of this competition is deemed to be not substantially adverse however, inasmuch as there are 47 commercial banks operating over 320 offices within the county. Three of these
are statewide banking institutions operating 165 commercial bank offices and controlling almost 57 percent
of the total deposits within Orange County. (On a pro
forma basis, the resulting institution would hold only
approximately 4.9 percent of the market's deposits,
and would rank as the sixth largest competitor in
Orange County.)
California state branching statutes permit unlimited
branching throughout the state. Therefore, approval of
this proposed merger would foreclose the possible development of future competition between Wells and
FNB. In recent years, Wells has embarked upon an
expansion program throughout southern California (the
vast preponderance of Wells' operations is concentrated within the San Francisco Bay Area, and northern
California), and this proposal will serve to further Wells'
expansion in an area where its representation has
been more limited than that of its major statewide competitors. The foreclosure of any future potential competition between Wells and FNB via de novo branch
expansion is not considered to be significant, and is
not considered a bar to approval of this application.
Although the general banking needs of Orange
County residents are being adequately met, Wells'
more influential position in the county should serve to
stimulate the competitive environment, thereby better
serving the banking public. Considerations relating to
convenience and needs benefits are a positive factor
in approving the application.
The financial and managerial resources of both
Wells and FNB are generally satisfactory. The future
prospects of Wells and FNB appear favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved. Also, as an inci* On January 10, 1978, the Comptroller of the Currency granted
Applicant approval to acquire eight branches from the Bank of California, one of which was in Orange County. The following data reflect
that acquisition.
*

Q.A


dent to approval of the application, Wells is hereby
authorized to operate all offices of FNB as branches of
the charter bank.
April 6, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Orange County (the Anaheim-Santa Ana-Garden
Grove SMSA) is situated along the Pacific Ocean between the Los Angeles and San Diego metropolitan
areas. Its estimated population at the beginning of
1977 was 1,759,500, and for the past two decades it
has been the fastest growing area in the state. It is
both an important manufacturing area and a developed residential center. The manufacturing sector
of the economy is predominantly light industry, producing goods such as electronic components, instruments and Pharmaceuticals.
Applicant operates 13 offices in Orange County*,eight of which are within 5 miles of an office of
Bank. Their two nearest offices, located in Anaheim,
are about 1.5 miles apart, and there are no banking
alternatives along the main thoroughfare that runs between them. It therefore appears that there is some
existing competition between the banks which would
be eliminated by the proposed merger.
As of June 30, 1976, 45 banks operated in Orange
County. Applicant and Bank are the seventh and
eighth largest banks in the county, holding approximately 3.1 percent and 2.5 percent, respectively, of
the county's commercial bank deposits. If the proposed merger is consummated the resulting bank
would be the fifth largest bank in the county, holding
approximately 5.6 percent of the county's commercial
bank deposits.
The proposed merger would also eliminate the
potential for increased future competition between Applicant and Bank. California law permits unlimited
branching, and Applicant could be permitted to establish de novo branches throughout Orange County. It
appears that the region east of Santa Ana and
Anaheim and extending from Yorba Linda to Mission
Viejo is a particularly attractive area for de novo expansion by Applicant. It is growing faster than the
county as a whole, probably because it is the natural
area of expansion for residential development. The
area is presently served by eight of Bank's branches
and only one of Applicant's. Given Applicant's
announced intention to expand in southern California
(Applicant's 1976 Form 10-K states that: "It is anticipated that future branch expansion will occur in southern California"), its expansion in the recent past (in the
past 5 years it has acquired 19 offices, 18 of which are
in southern California), and the attractiveness of the
eastern area of Orange County, it appears reasonable
to expect Applicant to increase its presence there by
de novo branching.
The proposed merger would eliminate some direct
competition as well as the potential for increased future competition between the parties. We conclude
that the proposed transaction would have an adverse
effect on competition.

DROVERS & MECHANICS NATIONAL BANK OF YORK,
York, Pa., and York Haven State Bank, York Haven, Pa.
Banking offices
Names of banks and type of transaction

Total
assets

York Haven State Bank, York Haven, Pa., with
and The Drovers & Mechanics National Bank of York, York, Pa. (2958), which had
merged May 31,1978, under charter and title of the latter bank (2958). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act (12 USC 1828(c)),
York Haven State Bank, York Haven, Pa. ("Merging
Bank"), and The Drovers & Mechanics National Bank
of York, York, Pa. ("Charter Bank"), have applied to the
Comptroller of the Currency for prior consent to merge
Merging Bank into Charter Bank under the charter and
title of The Drovers & Mechanics National Bank of
York. Incident to the proposed merger, the existing
office of Merging Bank would become a branch office
of the resulting bank. The subject application rests
upon an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth. This Office has considered the application in the light of factors set forth within the Bank
Merger Act.
Merging Bank is a state-chartered commercial banking institution that was established in 1918. As of September 30, 1977, Merging Bank had total deposits of
approximately $15.1 million at its sole banking office in
York Haven. The subject transaction constitutes Merging Bank's first participation in a merger or acquisition
agreement.
Charter Bank has operated as a national banking
association since April 28, 1883, when it was granted
charter number 2958 by this Office. As of September
30, 1977, Charter Bank's total deposits aggregated
almost $79.3 million, and the bank operated its main
office and seven branch offices.
The community of York Haven is located approximately 10 miles to the north of the city of York, and is
situated on the western shore of the Susquehanna River. All banking offices of the proponents are domiciled
within York County, and the closest offices are Charter
Bank's branch in Emigsville, approximately 7 miles
south of Merging Bank's site. It is noted however, that
there is an office of a competing bank within the intervening area. Although there is nominal existing competition between Charter Bank and Merging Bank,
approval of this application would have no substantially adverse consequences inasmuch as there are now
15 commercial banks that compete within York County; of which Charter Bank ranks as the fifth largest with
6.7 percent of the total deposits, and Merging Bank is
12th largest with 1.2 percent of the total deposits within the market. Furthermore, the four largest banks in
the market control almost 70 percent of the total deposits, and pro forma, Charter Bank would remain as
the fifth largest bank.
Charter Bank intends to expand current banking services to the customers of Merging Bank; and addition


In
To be
operation operated

$ 17,708,000
92,904,000
110,651,000

ally, to offer new services such as trust and fiduciary
services, and credit card facilities. The introduction of
these services should aid Merging Bank in becoming
a full-service banking facility that is better able to meet
the needs of the banking community. Considerations
relating to convenience and needs benefits are regarded as a positive factor in considering approval of
this proposal.
The financial and managerial resources of both
Charter Bank and Merging Bank are satisfactory; and
the future prospects of both institutions appear favorable.
Applying the statutory criteria, it is the conclusion of
the Office of the Comptroller of the Currency that this
application is not adverse to the public interest, and
should be, and hereby is, approved. Additionally, as
an incident to approval of the merger, Charter Bank is
hereby authorized to operate the banking office of
Merging Bank as a branch office of the resulting bank.
April 14, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
At present both banks have office locations only in
York County, a southeastern Pennsylvania county bordering the state of Maryland. Bank is the only commercial bank presently operating an office in the borough
of York Haven, a small community on the Susquehanna River located approximately 8 miles north of the city
of York (1970 population 329,540), where Applicant's
offices are concentrated. The closest office of Applicant to Bank is a branch facility of Applicant located in
the town of Emigsville, 6 miles from the borough of
York Haven. Between the two offices, there is only one
intervening facility, a branch of the York Bank and
Trust Company. Thus, the merger will adversely affect
actual competition within the county, particularly for
the residents of the York Haven area who will have
their banking choices reduced from three to two.
The adverse effect of the merger should not be significant however. Fifteen banks presently compete in
the county, with Applicant ranking fifth and Bank 12th
in county deposit size. Although banking is concentrated in the county with the top four banks having 68
percent of the market, Applicant's and Bank's market
shares are only 6.7 and 1.2 percent, respectively. Upto-date service features—such as 24-hour teller
machines and extended banking hours—provide further evidence of active competition in the market.
The merger should not adversely affect potential
competition in the county. Several small competitors
would remain in the market as possible foothold ac85

quisitions. Moreover, the county's strong economic
base, deriving from a well-balanced blend of industry
and agriculture, would support de novo entry and
branching under Pennsylvania's contiguous county
branching laws.

In sum, the proposed acquisition would have some
adverse effect on competition.

FIRST NATIONAL BANK OF JACKSON,
Jackson, Miss., and Citizens Bank of Hattiesburg, Hattiesburg, Miss.
Banking offices
Names of banks and type of transaction

Total
assets

Citizens Bank of Hattiesburg, Hattiesburg, Miss., with
and First National Bank of Jackson, Jackson, Miss. (10523), which had
merged May 31,1978, under charter and title of the latter bank (10523). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Citizens Bank of Hattiesburg, Hattiesburg, Miss.
("Citizens"), the merging bank, and First National Bank
of Jackson, Miss. ("FNB"), the charter bank, have applied to the Office of the Comptroller of the Currency
for prior approval, pursuant to the Bank Merger Act (12
USC 1828(c)), to merge Citizens into FNB, under the
charter and title of First National Bank of Jackson. Incident to the proposed merger, the existing offices of
Citizens would become branch offices of the resulting
bank. The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth. This Office has considered the application in the
light of factors set forth within the Bank Merger Act.
FNB was granted national banking association charter number 10523 by this Office on April 27, 1914. As
of September 30, 1977, FNB had total deposits of
$737.1 million.
Citizens is a state-chartered commercial banking institution that commenced operations in 1902. As of
September 30, 1977, Citizens operated a main office
and six branches and had total deposits of $45.2 million. (Citizens has received approval for the establishment of one additional office, which is, to date, unopened.) The subject proposal constitutes Citizens' initial participation in a merger or acquisition transaction
since its organization.
The main office of FNB is approximately 90 miles
distant from the city of Hattiesburg, the county seat of
Forrest County, and FNB's closest office is in Columbia, more than 30 miles from Hattiesburg. Additionally, FNB is not presently established within the political boundaries of Forrest County. Due to the distance
separating FNB and Citizens, and given the competitive atmosphere in the Hattiesburg area, approval of
this proposal would have no effect upon existing competition.
The two banks involved in this proposal operate in
different banking markets, and there is little, if any,
competition existent between them. With respect to
potential competition, however, it is noted that the Hattiesburg area is one of the few attractive areas for de

86


$

57,347,000
962,140,000
1,019,487,000

In
To be
operation operated
7
35
42

novo entry in Mississippi. Two of the 10 largest commercial banks headquartered in Mississippi (First Mississippi National Bank, Hattiesburg and Deposit
Guaranty National Bank, Jackson) are now represented in Hattiesburg. These banks, because of their
presence in Jackson, are already in direct competition
with FNB. Inasmuch as Citizens currently ranks as the
second largest bank in Hattiesburg, the introduction of
FNB into Hattiesburg would maintain the competitive
balances among these three larger institutions. (Deposit Guaranty National Bank operates six branches in
Hattiesburg as a result of a merger, approved by this
Office, between Deposit Guaranty National Bank and
Southern National Bank of Hattiesburg, effective December 30, 1977.) Therefore, it is concluded that the
competitive atmosphere within the Hattiesburg area
would be enhanced, not diminished, by approval of
this application.
Although Citizens ranks as the second largest commercial bank in Hattiesburg, it is substantially smaller
than the largest bank, First Mississippi National Bank.
With the introduction of FNB into Hattiesburg, the
banking public should be better served through increased competition and the introduction of new and
expanded banking services. Considerations relating to
convenience and needs benefits are regarded as a
positive factor in this application.
The financial and managerial resources of FNB and
Citizens are satisfactory. Likewise, the future prospects of both banks appear favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved. Further, as incident to approval of the merger, FNB is hereby authorized to operate, as branches, all offices of Citizens.
April 26, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it does not appear that it would have a
significantly adverse effect upon competition.

CONCORD NATIONAL BANK,
Concord, N.H., and The Pittsfield National Bank, Pittsfield, N.H.
Banking offices
Names of banks and type of transaction

Total
assets

The Pittsfield National Bank, Pittsfield, N. H. (1020), with
and Concord National Bank, Concord, N. H. (318), which had
merged June 29,1978, under charter and title of the latter bank (318). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency seeking prior permission to effectuate a merger of The Pittsfield National Bank, Pittsfield, N. H.
("Merging Bank"), into Concord National Bank, Concord, N. H. ("Charter Bank"), under the charter and
title of Concord National Bank. Under the proposed
merger, the sole office of Merging Bank would become
a branch office of the resulting bank. The subject application rests upon an agreement executed between the
proponent banks, and is incorporated herein by reference, the same as if fully set forth.
Merging Bank has operated as a national banking
association since April 17, 1865, when it was granted
charter number 1020 by this Office. As of December
31, 1977, Merging Bank had total commercial bank
deposits of $4.0 million, and operated its sole banking
office in Pittsfield.
Charter Bank was granted national banking association charter number 318 by this Office on March 15,
1864, and had total commercial bank deposits of
$58.9 million as of December 31, 1977. A whollyowned subsidiary of First Bancorp of New Hampshire,
Inc., Manchester, N. H., a registered multi-bank holding company, Charter Bank operates a main office and
three branch offices within the city of Concord.
The town of Pittsfield is located approximately 19
miles to the northeast of the city of Concord, both localities are in Merrimac County. The closest office of
Charter Bank is approximately 16 miles distant from
Merging Bank's office. Given the geographic distance
separating the proponent banks, and the presence of

In
To be
operation operated

$ 4,520,000
70,946,000
75,430,000

competing banking alternatives, approval of the instant
merger would not have the effect of eliminating any
meaningful degree of existing competition between the
two banks. Additionally, the potential for increased
competition between Merging Bank and Charter Bank
appears to be minimal.
Charter Bank proposes to improve and expand the
banking services currently provided by Merging Bank,
and to offer new banking services such as, trust services, credit cards, automatic savings plans and overdraft checking privileges. Additionally, through an increased legal lending limit, the resulting bank would
be able to accommodate larger loan requests of the
Pittsfield banking community. Considerations relative
to convenience and needs are consistent with, and
add weight toward, approval of this application.
The financial and managerial resources of both
Charter Bank and Merging Bank are satisfactory, and
should favorably enhance the future prospects of the
resulting bank. The financial and managerial resources
of Charter Bank's parent organization are also satisfactory.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
May 4, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

CENTURY NATIONAL BANK OF BROWARD,
Fort Lauderdale, Fla., and Century National Bank of Coral Ridge, Fort Lauderdale, Fla.
Banking offices
Names of banks and type of transaction

Total
assets

Century National Bank of Coral Ridge, Fort Lauderdale, Fla. (14848), with
and Century National Bank of Broward, Fort Lauderdale, Fla. (14554), which had
merged June 30,1978, under charter and title of the latter bank (14554). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act (12 USC 1828(c)), an
application has been filed with the Office of the Comptroller of the Currency that requests prior written consent to the proposed merger of Century National Bank



$107,275,000
301,434,000

In
To be
operation operated
3
4

408,709,000

of Coral Ridge, Fort Lauderdale, Fla. ("Merging
Bank"), into Century National Bank of Broward, Fort
Lauderdale, Fla. ("Charter Bank"), under the charter
and title of Century National Bank of Broward. The
subject application rests upon an agreement executed
87

between the proponent banks, incorporated herein by
reference, the same as if fully set forth. Incident to the
proposed merger, the existing offices of Merging Bank
would become branch offices of the resulting bank.
This Office has considered the application in the light
of factors set forth within the Bank Merger Act.
Charter Bank was issued national banking association charter number 14554 by this Office on June 1,
1946, and as of October 1, 1977, Charter Bank's total
deposits aggregated slightly in excess of $245 million.
Merging Bank was chartered by this Office on December 5, 1958, and had total deposits of about $89
million, on October 1, 1977.
Both Charter Bank and Merging Bank are whollyowned banking subsidiaries of Century Banks, Inc.,
Fort Lauderdale, Fla. a registered multi-bank holding
company. Due to this element of common ownership
and control existing between the proponents, this application must be regarded essentially as a corporate
reorganization whereby Century Banks, Inc. is consoli-

dating a portion of its banking interests in the Fort
Lauderdale area. Consequently, approval of the subject proposal would produce no adverse impact upon
any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this proposal is not adverse to the public
interest, and should be, and hereby is, approved.
Additionally, Charter Bank is authorized to operate the
existing offices of Merging Bank as branches of the
resulting institution.
May 4, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging
sidiaries of the
their proposed
ganization and

banks are both wholly-owned subsame bank holding company. As such,
merger is essentially a corporate reorwould have no effect on competition.

FLAGSHIP BANK OF MELBOURNE, NATIONAL ASSOCIATION,
Melbourne, Fla., and Flagship Bank of West Melbourne, National Association, West Melbourne, Fla.
Banking offices
Names of banks and type of transaction

Total
assets

Flagship Bank of West Melbourne, National Association, West Melbourne, Fla. (15533), with
and Flagship Bank of Melbourne, National Association, Melbourne, Fla. (15311), which had
merged June 30,1978, under charter and title of the latter bank (15311). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency asking prior permission to effect a merger of
Flagship Bank of West Melbourne, National Association, West Melbourne, Fla. ("Merging Bank"), into Flagship Bank of Melbourne, National Association, Melbourne, Fla. ("Charter Bank"), under the charter and
title of Flagship Bank of Melbourne, National Association. The subject application rests upon an agreement
executed between the proponent banks, incorporated
herein by reference, the same as if fully set forth.
Charter Bank has operated under national banking
association number 15311 since April 30, 1964. As of
June 30, 1977, Charter Bank had total deposits of
$44.6 million.
Merging Bank has operated under national banking
association number 15533 since July 26, 1965. As of
June 30, 1977, Merging Bank had total deposits of
$9.0 million.
Both Charter Bank and Merging Bank are banking


88


In
To be
operation operated

$11,556,000
51,008,000
62,564,000

subsidiaries of Flagship Banks, Inc., Miami Beach, Fl.,
a registered multi-bank holding company that controls
42 banks with deposits aggregating $1.5 billion. Inasmuch as the two proponent banks are commonly
owned and controlled, approval of this proposal would
not produce an adverse impact upon any relevant
area of consideration.
The subject application essentially represents a corporate reorganization whereby Flagship Banks, Inc., is
realigning and consolidating its banking interests. The
application is therefore deemed to be not adverse to
the public interest, and should be, and hereby is,
approved.
May 31, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are all wholly-owned subsidiaries
of the same bank holding company. As such, their
proposed mergers are essentially corporate reorganizations and would have no effect on competition.

GALLATIN NATIONAL BANK,
Uniontown, Pa., and The Rices Landing National Bank, Rices Landing, Pa.
Banking offices
Names of banks and type of transaction

Total
assets*

The Rices Landing National Bank, Rices Landing, Pa. (7090), with
was purchased July 14, 1978, by Gallatin National Bank, Uniontown, Pa. (5034), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency by Gallatin National Bank, Uniontown, Pa.
("Gallatin Bank"), the purchasing bank, requesting
prior permission to purchase the assets and assume
the liabilities of The Rices Landing National Bank,
Rices Landing, Pa. ("Rices Landing Bank"), the selling
bank. The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth.
A wholly-owned subsidiary of GNB Corporation, Uniontown, Pa., a registered one-bank holding company,
Gallatin Bank was granted charter number 5034 as a
national banking association on March 5, 1896, and as
of December 31, 1977, had total commercial bank deposits of $305.9 million. Gallatin Bank's principal area
of operation is Fayette County wherein it operates 18
banking offices, including its main office. Additionally,
Gallatin Bank has three banking offices in Greene
County, two in Somerset County, and one banking
office each in Washington and Westmoreland counties.
Rices Landing Bank was granted national banking
association charter number 7090 by this Office on
January 9, 1904, and as of December 31, 1977, had
total commercial bank deposits of $13.1 million. The
main office of Rices Landing Bank, its one branch
office, and a limited-service, drive-in facility are all
domiciled within Greene County.
The market area that would be most affected by the
subject acquisition is the "Washington—Waynesburg"
banking market, consisting of Greene County and
southern Washington County. Within this market area,
Gallatin Bank operates four branch offices, and Rices
Landing Bank operates all three of its banking offices.
Inasmuch as Gallatin Bank has a branch office located
approximately 5 miles from the main office of Rices
Landing Bank, there appears to be some direct competition existent between these banking offices.
However, within the primary service area of these
closest banking offices of the proponent banks, there
are located several branch offices of competing commercial banking institutions. Additionally, the banking
public in the Washington—Waynesburg market area
have available numerous conveniently located banking
alternatives. It is therefore concluded that approval of
this acquisition would have no substantially adverse
effect upon existing competition.
Applicable Pennsylvania banking statutes restrict
branching by a bank to the county in which its principal
place of business is located, and to all counties



$ 15,381,000
384,591,000
407,513,000

In
To be
operation operated
3
25
28

immediately contiguous. Due to the unique geographic
location of Greene County, bordered by only two other
Pennsylvania counties, and the restrictive branching
laws of Pennsylvania, there are only six possible purchasers of Rices Landing Bank other than Gallatin
Bank. Four of the banks are not of significant size to
purchase Rices Landing Bank; of the two conceivable
alternative purchasers, one is a state bank intent on
remaining the largest single office bank in Pennsylvania and the other, the market leader in Greene and
Washington counties, would present anticompetitive
problems. Accordingly, Gallatin Bank is considered
the most acceptable alternative purchaser from a
practical, as well as a legal standpoint.
Rices Landing Bank is presently faced with an immediate management succession problem. Due to the
recent resignation of the president and chief executive
officer, and the lack of a successor from within the
organization, the directors of Rices Landing Bank determined that the proposed purchase by Gallatin Bank
would provide an immediate solution to this problem.
Gallatin Bank is considered a sound organization, has
a capable and experienced management group and,
thus, has the resources to staff Rices Landing Bank
with capable management.
Approval of the subject proposal would have the
effect of maintaining Rices Landing Bank as a viable
competitor and the resulting bank would offer the
banking public a substantially larger legal lending
limit, improved and expanded banking services, and
new banking services such as trust services and automatic savings plans. It is, therefore, concluded that
considerations relative to convenience and needs are
consistent with, and add weight toward, approval of
this application.
The financial and managerial resources of Gallatin
Bank are considered to be satisfactory. Approval of
this proposal would alleviate Rices Landing Bank's
management succession problem and, given the generally satisfactory financial condition of Rices Landing
Bank, the future prospects of the resulting bank are
favorably enhanced.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
May 26, 1978.

*Asset figures are as of call dates immediately before and after
transaction.

SUMMARY OF REPORT BY ATTORNEY GENERAL
Greene County is a rural county that forms the southwest corner of the state. It is bordered on the south
and west by West Virginia, on the east by Fayette
County and on the north by Washington County. The
economic base of the county is coal mining, and the
fortunes of the county have fallen and risen with that
industry. The county's economic prospects appear
favorable as a result of the energy crisis and renewed
interest in coal as an energy supply.
The parties' closest offices (Applicant's office in Jefferson and Bank's head office in Rices Landing) are 5
miles apart and there are no offices of other banks in
the intervening area. It therefore appears that the
proposed transaction will eliminate some direct competition between Applicant and Bank.
Four banks operate offices in Greene County. As of
June 30, 1977, Applicant held the third largest share
(24 percent) and Bank held the fourth largest share
(15.5 percent) of the deposits held in these offices.
The Federal Reserve Bank of Philadelphia has defined a "Washington—Waynesburg" banking market
which consists of Greene County and the southern
portion of Washington County. Nine banks operate
offices in this area, in which banking is highly concen-

trated. As of June 30, 1977, the four largest banks held
80.6 percent of the deposits held in banking offices in
that area. Applicant held the fourth largest share (8.5
percent) and Bank held the seventh largest share (3.8
percent). If the proposed transaction is consummated,
Applicant would remain the fourth largest bank in the
area with approximately 12.3 percent of local deposits,
and concentration among the four largest banks in the
two-county area would increase from 80.6 percent to
84.4 percent.
The application indicates that Bank's management
has concluded that a sale of Bank is advisable in order
to resolve Bank's management succession problems.
Under Pennsylvania law, which permits only contiguous county branching, six banks (other than Applicant) could be permitted to purchase Bank. However,
only two of these banks appear to be of a size sufficient to purchase Bank, and one (First National Bank
and Trust Company of Washington) has a larger share
than Applicant of deposits both in Greene County and
in Greene and Washington counties combined, while
the other (Fayette County Bank and Trust) is a unit
bank.
Overall, in our view, the proposed transaction would
have some adverse effect on competition.

CROCKER NATIONAL BANK,
San Francisco, Calif., and Three Branches of The Bank of California, National Association, San Francisco, Calif.
Banking offices
Names of banks and type of transaction

Total
assets*

Three Branches of The Bank of California, National Association, San Francisco, Calif. (9655), with... were purchased July 31,1978, by Crocker National Bank, San Francisco, Calif. (1741), which had . . .
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application filed by Crocker National
Bank, San Francisco, Calif. ("Purchasing Bank"), to
purchase the assets and assume the liabilities of three
branches of The Bank of California, National Association, San Francisco, Calif. ("Selling Bank"). The subject
application rests upon an agreement executed between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Purchasing Bank has operated under national banking association charter number 1741, since the charter
was granted by this Office on November 30, 1870. As
of September 30, 1977, Purchasing Bank held total
commercial bank deposits aggregating approximately
$6.7 billion, and operated its main office in San Francisco and 359 branches throughout the state of California.

*Asset figures are as of call dates immediately before and after
transaction.
t Assets are for the entire bank.



$3,001,206,000t
12,758,506,000
13,240,376,000

In
To be
operation operated
3
360
363

Selling Bank, also a national banking association
since 1910, had total deposits on September 30, 1977,
of approximately $2.2 billion, and operated its head
office and 77 branch offices.
The subject application is a portion of an overall
plan announced by Selling Bank on May 11, 1977, to
dispose of a total of 33 of its California-based branch
offices and their respective assets and liabilities. The
three branches in this application are located in
Greenbrae (Marin County), Santa Rosa (Sonoma
County), and Tahoe City (Placer County); the three
branches have total deposits aggregating approximately $27 million.
The Greenbrae office of Selling Bank is the bank's
only location within Marin County. Purchasing Bank
currently has 10 banking offices within the county, and
is the second largest banking organization represented therein. (The pro forma ranking of Purchasing
Bank will be unaltered.) Although the Greenbrae
branch of Selling Bank is about 1 mile distant from an
existing office of Purchasing Bank, there is only negligible existing competition between them, and, inasmuch as the Greenbrae office has not proven to be

a profitable operation for Selling Bank, it is not unreasonable to believe that Selling Bank would probably close the branch (should this application be denied), thereby reducing the number of banking alternatives and inconveniencing the banking public.
The Santa Rosa office of Selling Bank is its only
representation in Sonoma County, wherein Purchasing
Bank operates six offices. The number of banking
alternatives available to the public highly mitigates any
adverse consequences that might arise through the
elimination of one banking alternative. Furthermore, the
ranking of Purchasing Bank as the fourth largest banking organization within the county, would be unaltered.
Of the three commercial banks competing in Tahoe
City, Selling Bank's Tahoe City office is the smallest,
and there are eight commercial banks (in both California and Nevada) that operate 14 branches in the immediate area. The acquisition of this small branch, total deposits of approximately $5.6 million, would have
no substantially adverse effect on competition. The
same is true for the acquisition of all three branches by
Purchasing Bank.
Inasmuch as the Purchasing Bank has a considerably more fully developed statewide branch network
than Selling Bank, Purchasing Bank is in a better position to offer a broader range of banking services and
statewide convenience to its banking customers. Additionally, as aforenoted, should the subject proposal not
be consummated, there is great likelihood that Selling
Bank, in an attempt to reduce operational expenses

and fortify its capital base, would close one or more of
the branches. Should that come to pass, the banking
public would be inconvenienced and the lack of Selling Bank's presence in these areas would become
fact. Accordingly, considerations relating to convenience and needs benefits are regarded as weighing
toward approval of this application.
The financial and managerial resources of Purchasing Bank and Selling Bank are generally satisfactory,
and Purchasing Bank has the capacity to operate and
manage the branches in an efficient and profitable
manner. The sale of the branches will enhance Selling
Bank's capital resources, and should favorably impact
upon that institution's earnings by lowering overhead
operational costs related to branch operations.
The future prospects of both of the proponents
appear favorable, and are enhanced by approval of
this application.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
May 24, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

EATON NATIONAL BANK AND TRUST CO.,
Eaton, Ohio, and The First National Bank of New Paris, New Paris, Ohio
Banking offices
Names of banks and type of transaction

Total
assets*

The First National Bank of New Paris, New Paris, Ohio (9211), with
was purchased Aug. 31, 1978, by Eaton National Bank and Trust Co., Eaton, Ohio (7557), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted an application filed by Eaton National Bank
and Trust Co., Eaton, Ohio (''Purchasing Bank"), that
requires the Comptroller's prior written consent to purchase the assets and assume the liabilities of The First
National Bank of New Paris, New Paris,-Ohio ("FNB"),
the selling bank. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth.
Purchasing Bank was issued national banking association charter number 7557 by this Office on January
14, 1905, and as of December 31, 1977, had total
deposits of $24.3 million. In addition to its main office
in Eaton, Purchasing Bank maintains its only branch
office in West Alexandria, Ohio, 6 miles east of Eaton.
Operating under national banking association char


In
To be
operation operated

$ 6,571,000
29,977,000
35,434,000

ter number 9211, FNB was chartered on July 31, 1908,
and held commercial bank deposits aggregating
approximately $5.7 million, at calendar year-end 1977.
The relevant geographic market for consideration of
the subject proposal is approximated by the whole of
Preble County, Ohio, wherein there are seven commercial banks that operate 11 banking offices. Purchasing
Bank ranks as the second largest banking organization behind The Preble County National Bank of Eaton,
with total deposits of approximately $38.7 million. FNB
is the second smallest of the seven banks within the
relevant market, and controls only slightly more than 5
percent of the total market deposits. The main offices
of the proponents are the closest offices of the two
institutions, approximately 15 miles apart. It appears
that the two proponent banks are serving two different
*Asset figures are as of call dates immediately before and after
transaction.

91

primary service areas and there is little overlap of competition for loan and deposit accounts between Purchasing Bank and FNB. It is, therefore, concluded that
approval of this transaction would result in no substantially adverse effect upon competition.
Pursuant to applicable Ohio state branching statutes, both of the proponents could, with regulatory
approval, establish de novo operations within each
other's primary service areas. However, given the economic growth in recent years, and the limited population of the New Paris area, it does not appear likely
that Purchasing Bank would pursue this mode of expansion into New Paris. Furthermore, considering the
limited financial and managerial resources of FNB, in
conjunction with the fact that after seven decades of
operation the bank continues as a unit operation, it can
not be reasonably concluded that FNB will seek to
expand its operations within the foreseeable future.
FNB has followed a non-aggressive competitive philosophy and the bank has generally been meeting only
the minimum banking needs of the New Paris banking
public. Approval of this proposal would result in a local, convenient source of full-service banking to the residents of New Paris. The introduction of such new and
expanded banking services as maximum legal rates
paid upon time deposits, trust services, an expanded
legal lending limit, bank credit cards, 24-hour banking
available through the introduction of automated teller
machines, and extended banking hours and additional
drive-in facilities should prove to be of considerable
convenience to the New Paris community. Considerations relating to convenience and needs of the banking
public lend weight toward approval of this application.

The financial resources of both Purchasing Bank
and FNB appear to be satisfactory. The managerial
resources of Purchasing Bank are also satisfactory.
The managerial resources of FNB are considered to
be somewhat less than satisfactory however, inasmuch as both the chairman of the board and the
president of FNB are inactive and the bank's management is vested solely in the person of the cashier.
Although that one officer appears to have administered the bank's affairs in a generally effective and
satisfactory manner, there is no management depth or
provision for management succession at FNB. Purchasing Bank has the necessary management composed of experienced and capable bankers who are
well qualified and capable of handling FNB's affairs
and operations in an effective and efficient fashion.
This is an additional positive factor in considering
approval of the subject proposal.
The future prospects of Purchasing Bank appear
favorable and the future prospects of FNB would
appear to be greatly enhanced by consummation of
this application.
Accordingly, for the reasons herein summarized
above, this application is deemed to be in the public
interest, and should be, and hereby is, approved. Incident to approval of the application, Purchasing Bank is
authorized to operate the office of FNB as an office of
the resulting bank.
July 26, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a significantly adverse
effect upon competition.

VIRGINIA NATIONAL BANK,
Norfolk, Va., and Virginia National Bank/Richmond, Richmond, Va., and Virginia National Bank/Henry County, Henry
County, Va., and Virginia National Bank/Lynchburg, Lynchburg, Va.
Names of banks and type of transaction

Total
assets

Virginia National Bank/Henry County, Henry County, Va. (16167), with
and Virginia National Bank/Lynchburg, Lynchburg, Va. (15819), with
and Virginia National Bank/Richmond, Richmond, Va. (16610), with
and Virginia National Bank, Norfolk, Va. (9885), which had
merged Aug. 31,1978, under charter and title of latter bank (9885). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application that has been filed pursuant
to the requirements of the Bank Merger Act (12 USC
1828(c)), seeking prior written permission to merge
Virginia National Bank/Henry County, Henry County,
Va. ("Henry County Bank"); Virginia National Bank/
Lynchburg, Lynchburg, Va. ("Lynchburg Bank"); and
Virginia National Bank/Richmond, Richmond, Va.
("Richmond Bank") (collectively, "Merging Banks"), into

92


$

21,402,000
19,597,000
84,996,000
2,097,962,000
2,221,958,000

Banking offices
In
To be
operation operated
3
4
5
153
165

Virginia National Bank, Norfolk, Va. ("Charter Bank"),
under the charter and title of Virginia National Bank. The
subject application rests upon an agreement executed
between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Henry County Bank has operated as a national
banking association since August 14, 1973, when this
Office granted the bank charter number 16167. As of
December 31, 1977, Henry County Bank had total deposits of $16.3 million.

Lynchburg Bank commenced operations as a national bank on December 4, 1972, and as of year-end
1977, held total commercial bank deposits of approximately $17.2 million.
Richmond Bank, the largest of the three merging
banks, with total deposits of slightly in excess of $61.1
million, as of December 31, 1977, has operated under
national banking association charter number 16610
since October 20, 1976.
Charter Bank, with total deposits of approximately
$1.8 billion, as of year-end 1977, has been a national
bank since July 6, 1972.
All three Merging Banks and Charter Bank are
wholly-owned banking subsidiaries of Virginia National
Bankshares, Inc., Norfolk, Va., a registered multibank
holding company that was incorporated in 1971. The
subject application must therefore be regarded essen-

tially as a corporate reorganization whereby the bank
holding company is realigning and consolidating a
portion of its banking interests in an effort to produce a
more efficient and profitable operation.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that this application is not
adverse to the public interest, and should be, and
hereby is, approved.
July 12, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are all wholly-owned subsidiaries
of the same bank holding company. As such, their
proposed merger is essentially a corporate reorganization and would have no effect on competition.

FIRST & MERCHANTS NATIONAL BANK,
Richmond, Va., and First & Merchants National Bank of the Peninsula, York County, (P.O. Williamsburg), Va., and
First & Merchants National Bank of Tidewater, Chesapeake, Va., and First & Merchants National Bank of Prince
William, Unincorporated Area of Prince William County, Va.
Names of banks and type of transaction

Total
assets

First & Merchants National Bank of the Peninsula, York County (P.O. Williamsburg), Va. (15984), with
and First & Merchants National Bank of Tidewater, Chesapeake, Va. (16184), with
and First & Merchants National Bank of Prince William, Unincorporated Area of Prince William
County, Va. (16402), with
and First & Merchants National Bank, Richmond, Va. (1111), which had
merged Sept. 30,1978, under charter and title of latter bank (1111). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application, pursuant to the Bank Merger
Act (12 USC 1828(c)), requesting prior permission to
merge First & Merchants National Bank of the Peninsula, York County (P.O. Williamsburg), Va. ("York Bank");
First & Merchants National Bank of Tidewater, Chesapeake, Va. ("Chesapeake Bank"); and First & Merchants Bank of Prince William, Unincorporated Area of
Prince William County, Va. ("Prince William Bank"), into
First & Merchants National Bank, Richmond, Va.
("Charter Bank"), under the charter and title of First &
Merchants National Bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Charter Bank has operated as a national banking
association since May 3, 1865, when it was granted
charter number 1111 by this Office. As of March 31,
1978, Charter Bank had total commercial bank deposits of $1.1 billion.
York Bank was established in 1972, operates under
national banking association charter number 15984,
and had deposits of $140.9 million as of March 31,
1978.
Chesapeake Bank received its charter as a national



$

Banking offices
In
To be
operation operated

162,930,000
145,571,000

10
17

5,509,000
1,534,194,000

1
65

1,848,204,000

93

banking association on September 25, 1973, when it
was granted charter number 16184. It held deposits of
$122.6 million on March 31, 1978.
Prince William Bank has operated under national
banking association charter number 16402 since
November 19, 1974, and as of March 31, 1978, had
total commercial bank deposits of $4.4 million.
All four of the banks involved in the proposed merger are banking subsidiaries of First & Merchants Corporation, Richmond, Va., a registered multibank holding company. Inasmuch as the proponent banks are
commonly owned and controlled, approval of the subject application would not produce an adverse impact
upon any relevant area of consideration.
The instant proposal must be regarded essentially
as a corporate reorganization whereby First & Merchants Corporation is consolidating a majority of its
banking interests. This merger is therefore deemed to
be not adverse to the public interest, and should be,
and hereby is, approved.
August 31, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it is essentially a corporate reorganization
and would have no effect on competition.
93

THE CITIZENS AND SOUTHERN NATIONAL BANK OF S.C,
Charleston, S.C, and Hilton Head National Bank, Hilton Head, S.C
Banking offices
Names of banks and type of transaction

Total
assets*

Hilton Head National Bank, Hilton Head, S.C. (16449), with
was purchased Oct. 13,1978, by The Citizens and Southern National Bank of S.C, Charleston, S.C.
(14425), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted for filing an application that requests prior
written consent for The Citizens and Southern National
Bank of S.C, Charleston, S.C ("CSNB"), the purchasing bank, to purchase the assets and assume the
liabilities of Hilton Head National Bank, Hilton Head,
S.C ("HHNB"), the selling bank. The subject application is based upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
CSNB has operated as a national banking association since January 20, 1940, when this Office granted it
charter number 14425. As of March 31, 1978, CSNB
had total commercial bank deposits aggregating
approximately $606.5 million. The principal subsidiary
of The Citizens and Southern Corporation, Charleston,
S.C, a registered one-bank holding company, CSNB
operates a total of 77 branches that are located in
most of the major geographic and market centers of
the state, and ranks as the second largest commercial
banking organization headquartered in South Carolina.
HHNB, national banking association charter number
16449, commenced operations on April 7, 1975. As of
March 31, 1978, the selling bank had total deposits of
approximately $11.7 million and operated as a unit
bank.
Hilton Head Island (population of approximately
9,000 year-round residents) is a portion of Beaufort
County, situated near the extreme southern tip of
South Carolina. The primary factor in the economy of
Hilton Head Island is tourism, catering to the affluent.
Many employees of various tourist-related businesses
located on the island commute daily from the mainland. The nearest office of CSNB to HHNB's site, is the
main office of CSNB in Charleston, approximately 100
road miles distant. Given the considerable geographic
distance separating the nearest banking offices of the
proponents, the availability of numerous banking alternatives, and the fact that, although CSNB may be
properly termed a "statewide banking operation," it
does not derive any significant degree of either its deposit or loan business from Hilton Head Island, it must
be concluded that approval of this application would
have no substantially adverse competitive effects.
*Asset figures are as of call dates immediately before and after
transaction.


94


In
To be
operation operated

$ 14,768,000

1

787,421,000
842,072,000

85
86

Applicable South Carolina statutes provide for statewide branching by commercial banks, with the approval
of the appropriate supervisory authority. However, considering the financial condition of HHNB, as outlined
below, it is not reasonable to conclude that HHNB,
which lacks both the financial and managerial resources to expand via de novo branching, would do so.
Moreover, it does not appear that CSNB would choose
to commence de novo banking operations on the island, considering the present representation of banks
on the island.
Commercial banking services are currently offered
to the banking public on Hilton Head Island by branch
offices of Bankers Trust of South Carolina, Columbia;
The Bank of Beaufort, Beaufort; and HHNB. There are,
however, banking services not currently provided,
which CSNB proposes to offer. Those new banking
services include simple interest loans, simple language loan agreements, extended-term loans for new
car purchases (up to 48 months to repay), automated
teller machines, money market certificates of deposit,
bank credit cards, trust and fiduciary services, and
bond investments. Additionally, CSNB has the capacity and expertise to expand upon already existing
banking services. The introduction of CSNB onto Hilton
Head Island should stimulate the competitive atmosphere, thereby benefiting the banking public. Considerations relating to convenience and needs benefits
lend weight toward approval of the application.
The financial and managerial resources of CSNB are
regarded as highly satisfactory. The managerial resources of HHNB are regarded as somewhat weak,
and not totally satisfactory. HHNB has been the victim
of a recent check kiting operation that has resulted in a
substantial loss to the bank; consequently the capital
accounts of HHNB have been reduced to a level that
impairs its sound financial operation. Moreover, the
substantial adverse publicity concerning the incident
has served to undermine the confidence of the banking public in HHNB. CSNB will obviously be a significantly stronger competitor within the Hilton Head Island banking market than HHNB has been and the
presence of CSNB should prove to be the impetus to
the restoration of the public's confidence in HHNB.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that approval of this application is in the public
interest, and should be, and hereby is, approved. Inci-

dent to approval of the application, CSNB is also authorized to operate the former banking office of HHNB
as a branch of the surviving institution.
September 7, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a substantial competitive
impact.

SECURITY PACIFIC NATIONAL BANK,
Los Angeles, Calif., and Humboldt National Bank, Eureka, Calif.
Banking offices
Names of banks and type of transaction

Total
assets

Humboldt National Bank, Eureka, Calif. (15329), with
and Security Pacific National Bank, Los Angeles, Calif. (2491), which had
merged October 20,1978, under charter and title of latter bank (249). The merged bank at date o f . . .
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted an application filed pursuant to statutory requirements of 12 USC 1828(c), the Bank Merger Act.
The subject application seeks prior written permission
to effectuate a proposed merger of Humboldt National
Bank, Egreka, Calif. ("HNB"), the merging bank, into
Security Pacific National Bank, Los Angeles, Calif.
("SPNB"), the charter bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
SPNB has operated under national banking association charter number 2491 since the charter was
granted by this Office on August 16, 1880. As of calendar year-end 1977, SPNB had total domestic and foreign office deposits aggregating approximately $14.9
billion, thereby ranking as the second largest commercial bank headquartered within the state of California.
In addition to its head office in Los Angeles, SPNB
operated 547 branch offices, as of December 31,
1977.
HBN received national banking association charter
number 15329 from this Office on June 2, 1964. As of
December 31, 1977, the merging bank had total commercial bank deposits of $43.7 million and operated a
main office and seven branches.
The relevant geographic markets served by the proponent banks do not overlap and their nearest offices
are more than 100 miles apart. All eight of HNB's
banking offices are domiciled within Humboldt County
and approval of the subject proposal would allow
SPNB's initial entry into this Northern California banking market.
HNB currently ranks a distant third among commercial banking organizations operating within Humboldt
County, behind Bank of America National Trust and
Savings Association and Crocker National Bank, which
are first and second largest, respectively. Although
SPNB could, with prior supervisory approval, establish
de novo branches in the areas served by HNB (California permits statewide banking), such expansion into



$
47,320,000
19,588,912,000
19,671,502,000

In
To be
operation operated
8
571
579

Humboldt County does not appear likely within the
foreseeable future inasmuch as the area is not experiencing rapid economic growth. Humboldt County's
major industry is timber, with tourism a secondary
source of revenue. The timber industry is expected to
suffer when the Redwood National Park, located within
the county, expands via acquisition of present commercial timberlands. Additionally, due to the mechanization of the timber industry, unemployment is a growing problem in Humboldt County. Given the economic
picture as presented, it appears appropriate to conclude that SPNB would not choose de novo expansion
to enter the Humboldt County market.
Approval of this proposed merger would result in the
present customers of HNB experiencing new and expanded banking services. Among the various new services that SPNB proposes to offer HNB customers are
reductions on consumer loan rates, bank credit card
operations, computer account services, international
banking services, and trust and fiduciary services.
SPNB's ability to more effectively compete with HNB's
significantly larger competitors should better serve the
banking public, and the public should further benefit
through the services of a more meaningful banking
alternative that is a more aggressive competitor and a
source of full-service banking. Considerations relating
to convenience and need lend weight toward approval
of the application.
The financial and managerial resources of both
SPNB and HNB are satisfactory. The proposed merger
would however, provide HNB with management succession. HNB's president is nearing the normal age of
retirement and has experienced recent health problems, consequently he has commenced a plan for his
retirement and there does not appear to be any leading candidate within the officer ranks of the bank who
is fully capable of succeeding to the position.
The future prospects of PSNB appear favorable, and
the provision of successor management and new and
expanded banking services should help to insure the
favorable future prospects of HNB.
Accordingly, applying the statutory criteria, it is the
95

conclusion of this Office that the subject proposal is
not adverse to the public interest, and that this application should be, and hereby is, approved.
September 19, 1978.

ern California. Furthermore, Applicant has opened 63
de novo branches in the last 5 years, and plans to
open four more.
Although Applicant is the most likely potential entrant, several circumstances diminish the likelihood
that any bank would enter Humboldt County by de
novo branching. Humboldt County's major industry is
timber, with tourism a secondary source of economic
activity. Despite the possibility of some growth as
Humboldt State University continues to expand, significant economic or population growth (1977 population—106,000) is unlikely in Humboldt County. The timber industry is expected to suffer when Redwood National Park, located in the county, expands by acquisition of commercial timberlands, although tourism will
increase somewhat as a result. In addition, unemployment is a problem in the county, in part because of
mechanization of the timber industry. Furthermore, the
county appears to be more heavily banked than the
state as a whole. Thus, Humboldt County does not
appear to be an attractive area for de novo entry.
Some attributes of the banking market in Humboldt
County may mitigate the anticompetitive consequences of the proposed merger. The fact remains,
however, that the most capable entrant proposes to
absorb the largest and most successful competitor
available to it in Humboldt County. For these reasons
we conclude that the proposed transaction would have
an adverse effect upon competition.

SUMMARY OF REPORT BY ATTORNEY GENERAL
This merger would have no effect on direct competition, since Applicant's closest office is approximately
100 miles from Bank's offices.
The merger would, however, eliminate a significant
potential competitor from a highly concentrated market. Humboldt County is served by six banking organizations and 25 banking offices (with one additional
office approved but unopened). As of June 30, 1977,
the top two banks (Bank of America and Crocker National) held 71 percent of the total deposits and 69.8
percent, respectively, of the IPC demand deposits in
the county. The top four (filled out by Bank and Wells
Fargo), held 91.4 percent of the total deposits and
90.1 percent of the IPC demand deposits. Bank, as
noted above, is the third largest market entrant, with
11.5 percent of the total deposits and 13.5 percent of
the IPC demand deposits.
Applicant is the most likely de novo entrant into
banking in Humboldt County. The only larger bank in
the state (Bank of America) is already well represented, indeed dominant, in the county, and Applicant
is admittedly eager to expand its operations in north*

*

UNITED NATIONAL BANK,
Sioux Falls, S. Dak., and Rosholt Community Bank, Rosholt, S. Dak.
Banking offices
Names of banks and type of transaction

Total
assets*

Rosholt Community Bank, Rosholt, S. Dak., with
was purchased Nov. 3, 1978, by United National Bank, Sioux Falls, S. Dak. (15639), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted an application filed by United National Bank,
Sioux Falls, S. Dak. ("UNB"), the purchasing bank, requesting prior written consent to purchase the assets
and assume the liabilities of Rosholt Community Bank,
Rosholt, S. Dak. ("Selling Bank"). The subject application is based upon an agreement executed between
the proponent banks, incorporated herein by reference, the same as if fully set forth.
UNB was granted national banking association charter number 15639 by this Office on October 30, 1967.
As of March 31, 1978, UNB had total deposits of
approximately $120.7 million and operated a main
office and 18 other banking offices that are domiciled
in 14 cities and towns, primarily within the western and
* Asset figures are as of call dates immediately before and after
transaction.

96


$

8,807,000
149,808,000
158,361,000

In
To be
operation operated
1
19
20

southern sectors of the state. Furthermore, UNB is the
primary subsidiary of United National Corporation,
Sioux Falls, a registered one-bank holding company
(consolidated assets of $143.4 million on December
31, 1977), that ranks as the fifth largest banking organization in South Dakota.
Selling Bank, with total commercial bank deposits of
approximately $7.9 million as of March 31, 1978, is a
state-chartered commercial banking institution that
was established in 1927. The community of Rosholt is
situated within the northeastern corner of South Dakota, approximately 9 miles from the Minnesota border,
almost 6 miles from the North Dakota border, and 160
miles north of Sioux Falls. Agricultural activities constitute the economic base of the Rosholt area; the surrounding area is a portion of the southern tip of the
fertile Red River Valley. The nearest offices of the
proponent banks are more than 150 miles apart and
there is no meaningful existing competition between

the participating institutions. Approval of the subject
application would, therefore, have no adverse competitive effects.
Due to constantly increasing credit requirements of
the Rosholt area, it has become increasingly difficult
for Selling Bank to provide area farmers and ranchers
with sufficient funds for their expanding operations. As
a unit of UNB, Selling Bank would continue to provide
full-service banking. Moreover, the resulting legal lending limit will better serve more of the banking needs of
the Rosholt banking community. Considerations relating to convenience and needs benefits are regarded
as being consistent with approval of the proposal.
The financial and managerial resources of UNB and
Selling Bank are considered to be generally satisfactory. The future prospects of both participating banks
appear favorable and the future prospects of Selling

Bank appear to be enhanced by approval of this proposal.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the subject application is
not adverse to the public interest, and should be, and
hereby is, approved. Incident to approval of the application, UNB is also authorized to operate the former
banking office of Selling Bank as a branch of the surviving bank.
September 26, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed these proposed transactions and
conclude that they would not have a substantial competitive impact.

ZIONS FIRST NATIONAL BANK,
Salt Lake City, Utah, and Zions First National Bank of Ogden, Ogden, Utah
Banking offices
Names of banks and type of transaction

Total
assets

Zions First National Bank of Ogden, Ogden, Utah (16043), with
and Zions First National Bank, Salt Lake City, Utah (4341), which had
merged Dec. 1, 1978, under charter and title of latter bank (4341). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency, pursuant to the Bank Merger Act (12 USC
1828(c)), requesting prior written permission to effectuate a proposed merger of Zions First National Bank
of Ogden, Utah ("Merging Bank"), into Zions First National Bank, Salt Lake City, Utah ("Charter Bank"),
under the charter and title of Zions First National Bank.
The subject application rests upon an agreement executed between the proponent banks, incorporated
herein by reference, the same as if fully set forth.
Merging Bank was granted national banking association charter number 16043 by this Office on November 28, 1972, and as of March 31, 1978, the bank had
total deposits of approximately $12.1 million.
Charter Bank, also a national banking association,
was granted charter number 4341 on June 12, 1890.
As of March 31, 1978, Quarter Bank's commercial
bank deposits aggregated $895.2 million.
Both of the proponents are banking subsidiaries of




$

11,382,000
1,173,809,000
1,185,191,000

In
To be
operation operated
1
45
46

Zions Utah Bancorporation, Salt Lake City, a registered multibank holding company. Considering the
element of common ownership and control that exists
between Merging Bank and Charter Bank, the subject
application must be regarded essentially as a corporate reorganization.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this proposal is not adverse to the public
interest, and should be, and hereby is, approved. Incident to approval of this application, Charter Bank is
authorized to operate the former banking office of
Merging Bank as a branch of the surviving institution.
October 18, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging
sidiaries of the
their proposed
ganization and

banks are both wholly-owned subsame bank holding company. As such,
merger is essentially a corporate reorwould have no effect on competition.

97

GALLATIN NATIONAL BANK,
Uniontown, Pa., and First National Bank of Scottdale, Scottdale, Pa.
Banking offices
Names of banks and type of transaction

Total
assets

First National Bank of Scottdale, Scottdale, Pa. (13772), with
was purchased Dec. 8,1978, by Gallatin National Bank, Uniontown, Pa. (5034), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has
accepted for filing an application that requires prior
written consent to the proposed purchase of assets
and assumption of liabilities of First National Bank of
Scottdale, Scottdale, Pa. ("FNB"), the selling bank, by
Gallatin National Bank, Uniontown, Pa. ("GNB"), the
purchasing bank. The subject application rests upon
an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth.
A wholly-owned banking subsidiary of GNB Corporation, Uniontown, Pa., a registered one-bank holding
company, GNB was granted national banking association charter number 5034 by this Office on March 5,
1896. As of March 31, 1978, GNB had total commercial bank deposits of approximately $312.5 million.
GNB's primary area of operation is approximated by
the whole of Fayette County wherein GNB operates 18
banking offices including its main office. Additionally,
GNB maintains six banking offices in neighboring
Greene County, two branches in Somerset County,
and one branch each in Washington and Westmoreland counties.
FNB is also a national banking association since it
was granted charter number 13772 on September 12,
1933. Due to the close proximity of the community of
Scottdale to the political boundary separating Westmoreland County from Fayette County, the bank
serves portions of the banking public in both counties.
As of March 31, 1978, FNB had total deposits of
approximately $32.2 million and operated only its main
office.
Although GNB operates in all of the counties into
which it may branch (Fayette, Greene, Somerset,
Washington and Westmoreland), approximately 80
percent of its total deposits are generated by the
bank's offices in Fayette County. As aforenoted, FNB's
location affords the bank the ability to serve residents
of both Fayette and Westmoreland counties; however,
it appears that FNB's primary service area is restricted
to the area surrounding the community of Scottdale
(between Mt. Pleasant in Westmoreland County and
Connellsville in Fayette County). GNB maintains banking offices in both Mt. Pleasant and Connellsville, and
there are no other banking offices between Scottdale
and Connellsville. It should be noted, however, that
any degree of existing competition between GNB and
FNB is mitigated by the fact that Pittsburgh National
Bank (total deposits approximately $2.5 billion) operates two offices in Mt. Pleasant and one office in Connellsville. Additionally, Yough Valley National Bank (to
98


$ 37,166,000
407,513,000
450,492,000

In
To be
operation operated

1
28
29

tal deposits approximately $9.5 million) is headquartered in Connellsville. Overall, it is the opinion of this
Office that the degree of existing competition between
FNB and GNB is not so intense as to be substantially
adversely affected by approval of this application.
GNB's entry into the Scottdale area will introduce
new and expanded banking services to the public.
FNB has a history of a rather conservative operation,
with very restrictive mortgage loan requirements and
little in the way of specialized loans. Additionally, FNB
has no trust department; an area where GNB has considerable expertise that will be made available to
Scottdale area residents. The substantially increased
legal lending limit will further provide commercial and
local business customers of FNB a greater flexibility in
meeting their individual and corporate credit requirements. Considerations relating to convenience and
needs benefits are regarded as being a positive factor
and add weight toward approval of the application.
The financial and managerial resources of both FNB
and GNB are regarded as satisfactory and consistent
with approval. It is noted, however, that the management and directorate of FNB are advanced in age.
GNB is in a position to provide for adequate management succession through the continued provision of
capable, competent bankers that are well able to conduct the affairs of FNB in a sound manner. The future
prospects of GNB are considered favorable, and those
of FNB would appear to be favorably enhanced via
affiliation with GNB.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the subject application is
in the public interest, and should be, and hereby is,
approved. As an incident to approval of this application, GNB is also hereby authorized to operate the
main office of FNB as a branch of the surviving bank.
October 30, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The only county in which Applicant and Bank both
operate is Westmoreland County. The two towns of
Scottdale (1970 population 5,818) and Mount Pleasant
(1970 population 5,895), where the offices of Bank and
Applicant are located are only 8 miles apart. The only
other commercial banks in the vicinity are the Scottdale Savings and Trust Company in Scottdale (a unit
bank with total deposits of $14.2 million) and a branch
office of the Pittsburgh National Bank in Mount
Pleasant. Thus, it appears that the proposed merger
would eliminate existing competition between Applicant and Bank.
Twenty-three banks with 85 offices and one mutual

savings bank presently compete in Westmoreland
County. Banking in the county is concentrated: the top
four banks hold 66.65 percent of the demand deposits
and 61.54 percent of total bank deposits in the county.
Bank ranks 10th in size among banks in the county,
with 2.82 percent of the county's demand deposits,
and Applicant ranks 14th with 1.36 percent. Several

major Pittsburgh banks are headquartered or represented in the county. Accordingly, the proposed acquisition would not increase concentration in Westmoreland County by a significant amount.
Overall in our view, the merger will have an adverse
effect on competition.

BARNETT BANK OF TAMPA, NATIONAL ASSOCIATION,
Tampa, Fla., and Barnett Bank of Brandon, National Association, Unincorporated Area of Brandon, Fla.
Banking offices
Total
assets

Names of banks and type of transaction

$33,816,000
67,307,000

Barnett Bank of Brandon, National Association, Unincorporated Area of Brandon, Fla. (16023), with ..
and Barnett Bank of Tampa, National Association, Tampa, Fla. (16437), which had
merged Dec. 29,1978, under charter and title of the latter bank (16437). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Office of the Comptroller of the Currency requesting prior permission to
merge Barnett Bank of Brandon, National Association,
Unincorporated Area of Brandon, Fla. ("Merging
Bank"), into Barnett Bank of Tampa, National Association, Tampa, Fla. ("Charter Bank"), under the charter
and title of Barnett Bank of Tampa, National Association. The subject application rests upon an agreement
executed between the proponent banks, incorporated
herein by reference, the same as if fully set forth.
Charter Bank has operated as a national banking
association since February 26, 1975, when it was
granted charter number 16437 by this Office. As of
June 30, 1978, Charter Bank had total commercial
bank deposits of $58.7 million.
Merging Bank was granted national banking association charter number 16023 by this Office on October 13, 1972, and had total commercial bank deposits
of $29.0 million as of June 30, 1978.
Both Charter Bank and Merging Bank are banking
subsidiaries of Barnett Banks of Florida, Inc., Jacksonville, Fla., a registered multi-bank holding company.
Due to their common ownership and control, approval
of this merger would not have an adverse effect upon

In
To be
operation operated
1
1

101,123,000

2

any relevant area of consideration. This application
must be regarded essentially as a corporate reorganization whereby Barnett Banks of Florida, Inc., is consolidating a portion of its banking interests.
It is, therefore, the opinion of the Office of the Comptroller of the Currency that this proposal is not adverse
to the public interest, and should be, and hereby is,
approved.
This application was filed prior to the November 6,
1978 effective date of the Comptroller's Community
Reinvestment Act regulations, 12 CFR 25. However,
pursuant to the Community Reinvestment Act, Public
Law No. 95-128, available information relevant to the
bank's record of meeting its community credit needs
was reviewed and revealed no evidence to suggest
that the applicants are not meeting the credit needs of
their community, including low and moderate income
neighborhoods.
November 29, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging
sidiaries of the
their proposed
ganization and

banks are both wholly-owned subsame bank holding company. As such,
merger is essentially a corporate reorwould have no effect on competition.

NATIONAL CENTRAL BANK,
Lancaster, Pa., and Farmers Bank of Kutztown, Kutztown, Pa.
Banking offices
Names of banks and type of transaction

Total
assets

Farmers Bank of Kutztown, Kutztown, Pa., with
and National Central Bank, Lancaster, Pa., (694), which had
merged Dec. 29,1978, under the charter and title of the latter bank (694). The merged bank at date of
merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application, pursuant to the Bank Merger



$

33,816,000
1,530,610,000
1,564,426,000

In
To be
operation operated
2
57

59

Act (12 USC 1828(c)), requesting prior permission to
merge Farmers Bank of Kutztown, Kutztown, Pa.
("Farmers Bank"), the merging bank, into National
99

Central Bank, Lancaster, Pa. ("National Central"), the
charter bank, under the charter and title of National
Central Bank. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth.
National Central, a wholly-owned subsidiary of National Central Financial Corporation, Lancaster, Pa., a
registered one-bank holding company, was granted
national banking association charter number 694 by
this Office on January 9, 1865, and as of March 31,
1978, had total commercial bank deposits of $1.1 billion. National Central presently operates a total of 55
banking offices: 16, including its main office, in Lancaster County, 13 in Berks County, 12 in York County,
nine in Dauphin County, three in Chester County and
two in Lebanon County.
Farmers Bank was incorporated in 1909, and operates its main office in Kutztown, and one branch office
in Lyons, Pa. (both situated in northeastern Berks
County). As of March 31, 1978, Farmers Bank held
commercial bank deposits of $27.6 million.
The closest offices of the merging bank and the
charter bank are the main office of Farmers Bank in
Kutztown and National Central's branch office in Hamburg, Pa., located approximately 15 miles apart. The
intervening area is sparsely populated with the two
communities linked via a series of rural, country roads.
There are banking offices of competing commercial
banks located within the market area of the merging
bank, including offices of larger banks headquartered
in Allentown and Reading, Pa. Thus, there appears to
be no meaningful degree of existing competition between National Central and Farmers Bank. Additionally, the potential for increased competition between the
proponent banks appears to be minimal. Overall,
approval of this merger would have no substantially
adverse effect upon competition.
National Central offers a full range of commercial
banking services to its customers. National Central
proposes to offer new and expanded banking services
to the customers of Farmers Bank, including, but not
limited to, trust department services, credit cards,
overdraft checking privileges, and a substantially larger legal lending limit. Considerations relating to convenience and needs of the banking community to be
served add additional weight toward approval of the
application.
The financial and managerial resources of National
Central and Farmers Bank are regarded as satisfactory, although Farmers Bank has limited management
depth. The future prospects of National Central appear
favorable, and the future prospects of Farmers Bank,
when combined with National Central, appear more
favorable since the charter bank has the necessary
managerial resources to adequately provide for the
merging bank's succession of management.
This application was filed prior to the November 6,
1978, the effective date of the Comptroller's Commun-


100


ity Reinvestment Act regulations, 12 CFR 25. However,
pursuant to the Community Reinvestment Act, Public
Law No. 95-128, available information relevant to the
bank's record of meeting its community credit needs
was reviewed and revealed no evidence to suggest
that the applicants are not meeting the credit needs of
their community, including low and moderate income
neighborhoods.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
November 29, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
Berks County (1970 population 296,382) is located in
the southeast-central portion of Pennsylvania and
makes up the Reading SMSA. Its economy is based
on a diversified mix of farming and industries such as
primary metals, chemicals and allied products, and
electrical machinery. The county has experienced substantial growth over the past two decades: population
increased by 10.7 percent between 1960 and 1975
and median household income increased by 143.1
percent. Growth in Bank's immediate area has been
even more pronounced because of the location of
Kutztown midway between the cities of Reading and
Allentown. From 1960 to 1975, the population in Kutztown increased 32.67 percent and median household
income increased 148.8 percent. The economic outlook for both the county and the Kutztown area remains favorable.
The nearest office of Applicant to Bank is Applicant's branch facility in the town of Hamburg, located
14.6 miles northwest of Kutztown via a series of country roads. There are no offices of other banks located
in the intervening area (which is sparsely populated),
although there are offices of several of Bank's competitors that are closer to Bank than Applicant's Hamburg branch. It appears, therefore, that the proposed
transaction would eliminate some direct competition
between Applicant and Bank.
Sixteen commercial banks currently operate offices
in Berks County. As of June 30, 1977, Applicant held
the third largest share with 16.1 percent of total deposits and Bank held the eighth largest share with 1.8
percent of total deposits in Berks County commercial
banking offices. If the proposed transaction is consummated, the resulting bank will remain the third
largest bank in the county with a 17.9 percent share of
deposits held in county banking offices. Concentration
among the four largest banks in the county (in terms of
county deposits) would increase from 87.0 percent to
88.8 percent. Thus, the proposed acquisition would
increase the high level of concentration among the
banks in Berks County.
Overall, in our view, the proposed transaction would
have an adverse effect on competition.

THE CHESTER NATIONAL BANK,
Chester, N.Y., and The National Union Bank of Monticello, Monticello, N.Y.
Banking offices
Names of banks and type of transaction

Total
assets

The National Union Bank of Monticello, Monticello, New York (1503), with
and The Chester National Bank, Chester, New York (1349), which had
merged December 29,1978, under charter and title of the latter bank (1349). The merged bank at
date of merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), an application has been
filed with the Office of the Comptroller of the Currency
requesting prior permission to merge The National Union Bank of Monticello, Monticello, N.Y. ("Merging
Bank"), into The Chester National Bank, Chester, N.Y.
("Charter Bank"), under the charter and title of The
Chester National Bank. The subject application rests
upon an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth.
Charter Bank was granted national banking association charter number 1349 by this Office on June 28,
1865, and had total commercial bank deposits of
$52.0 million as of December 31, 1977. A whollyowned subsidiary of First Commercial Banks, Inc.,
Albany, N.Y., a registered multi-bank holding company, Charter Bank operates a main office and eight
branch offices in Orange County and an additional
branch office in Sullivan County.
Merging Bank has operated as a national banking
association'since August 4, 1865, when it was granted
charter number 1503 by this Office. As of December
31, 1977, Merging Bank had total commercial bank
deposits of $21.9 million and operates two banking
offices, both located within the village of Monticello,
the county seat of Sullivan County.
Charter Bank and Merging Bank serve separate and
distinct service areas, and the closest offices of the
proponent banks are approximately 12 miles apart,
with several intervening offices of competing banks.
Also, there are numerous banking alternatives in close

$26,896,000
59,087,000

In
To be
operation operated
o

11

85,983,000

13

proximity to both Charter Bank and Merging Bank,
including banking offices of New York City-based
commercial banks. Accordingly, approval of this application would result in no substantially adverse effect
upon competition. Additionally, approval would remove home office protection from the village of Monticello, allowing branch establishment by other commercial banks within Monticello and thereby better
serving the banking public.
As part of the proposed merger, Charter Bank, in
conjunction with its corporate parent, intends to offer
new and expanding banking services to the customers
of Merging Bank. Those services include a larger legal
lending limit, trust services, individual retirement
accounts and credit card services. Considerations relating to convenience and needs benefits are therefore
regarded as lending weight to approval.
The financial and managerial resources of both
Charter Bank and Merging Bank are satisfactory, and
the future prospects of the proponent banks independently, and in combination, appear favorable.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is in the public interest, and
should be, and hereby is, approved.
October 11, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
We have reviewed this proposed transaction and conclude that it would not have a significantly adverse
effect upon competition.

THE NATIONAL BANK AND TRUST COMPANY OF NORWICH,
Norwich, N.Y., and First National Bank in Sidney, Sidney, N.Y.
Banking offices
Names of banks and type of transaction

Total
assets

First National Bank in Sidney, Sidney, N.Y. (13563), with
and The National Bank and Trust Company of Norwich, Norwich, N.Y. (1354), which had
merged Dec. 29,1978, under charter and title of the latter bank (1354). The merged bank at date of
merger had

COMPTROLLER'S DECISION
An application has been accepted by the Office of the
Comptroller of the Currency that seeks and requires
the prior written consent of this Office to effectuate the
proposed merger of First National Bank in Sidney, Sid


$ 22,748,000
219,518,000
242,469,000

In
To be
operation operated

2
15
17

ney, N.Y. ("Sidney"), the merging bank, into The National Bank and Trust Company of Norwich, Norwich,
N.Y. ("Charter Bank"), under the charter and title of
The National Bank and Trust Company of Norwich. The
subject application rests upon an agreement executed
101

between the proponent banks, and is incorporated herein by reference, the same as if fully set forth.
Sidney was granted national banking association
charter number 13563 by this Office on July 11, 1931.
As of March 31, 1978, Sidney had total deposits of
approximately $19.3 million, and operated its main
office and a drive-in facility in the village of Sidney.
Charter Bank, charter number 1354, is headquartered in Norwich, Chenango County, and operates 14
other offices in four counties (eight branches in Chenango County, three branches in Delaware County,
two in Broome County, and one office in Tioga County). As of March 31, 1978, Charter Bank had total deposits of $175.9 million.
Although for purposes of The Bank Holding Company Act of 1956, Sidney is a subsidiary of Charter
Bank (inasmuch as approximately 33.5 percent of the
total outstanding voting shares of Sidney are held by
Charter Bank's trust department), it does not appear
that Charter Bank exercises active control over Sidney's normal daily operations. The closest offices of
the proponent banks are Charter Bank's Bainbridge
and Afton offices, approximately 6 and 10 miles west
of the village of Sidney, respectively, and Sidney's
main office. From a review of the record, it appears
that there is a degree of existing competition between
Charter Bank and Sidney. This competition is not
however regarded as substantial, and any actual competition is highly mitigated by Charter Bank's stock
ownership in Sidney (almost sufficient to legally preclude any merger with another banking institution).
Further mitigating factors are the composition of Sidney's loan portfolio with over 60 percent in residential
mortgages and slightly less than 30 percent in consumer loans (both credit unions and savings and loan
associations actively compete with Sidney for these
types of customer accounts), and the fact that the merger would eliminate home office protection within the
village of Sidney, thereby allowing the entrance of
other financial institutions and resulting in a more
vigorous competitive atmosphere. Overall, anticompetitive effects of this proposal are deemed to be not
substantially adverse.
The general banking services offered by Sidney are
limited due to the size and experience of the bank's
staff. Charter Bank's operations are departmentalized.
Each department is staffed with qualified personnel,
including Charter Bank's agriculture and trust departments. Charter Bank has four full time agricultural loan
officers trained to assist farmers in the Sidney area
with their financial matters and to provide professional
advice as needed. Sidney has a small trust department, but the bank does not actively seek new
accounts due to the limited staff and lack of qualified
personnel. (Sidney's president acts as the bank's trust
officer; however, he has no formal training in this area.)
Additional expanded and new banking services to be
realized by Sidney's customers as a result of this merger include a vastly increased legal lending limit, payment of maximum legal interest rates on various savings plans, bank related charge cards, pre-approved
revolving lines of credit, and estate and trust planning.

102


Considerations relating to convenience and needs
weigh heavily for approval of this application.
The financial resources of both Charter Bank and
Sidney are regarded as satisfactory. The managerial
resources of Charter Bank are satisfactory and those
of Sidney are general satisfactory. A major factor in
considering the possibility of a merger on Sidney's
part is the fact that Sidney has no apparent succession to present bank management. Charter Bank possesses qualified personnel that are regarded as competent and capable bankers who appear well able to
successfully administer Sidney's business affairs and
enhance the future prospects of both proponents.
These factors add additional weight toward approval
of the application.
This application was filed prior to the November 6,
1978 effective date of the Comptroller's Community
Reinvestment Act regulations, 12 CFR 25. However,
pursuant to the Community Reinvestment Act, Public
Law No. 95-128, available information relevant to the
bank's record of meeting its community credit needs
was reviewed and revealed no evidence to suggest
that the applicants are not meeting the credit needs of
their community, including low and moderate income
neighborhoods.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the subject application is
in the public interest and is approved. Incident to
approval of the merger application, Charter Bank is
authorized to operate all former offices of Sidney as
branches of the surviving banking institution.
November 29, 1978
SUMMARY OF REPORT BY ATTORNEY GENERAL
The Binghamton SMSA covers four counties in New
York State and one in Pennsylvania. Binghamton is
about 45 miles from both Sidney and Norwich. The
SMSA covers a much wider area than that which
appears appropriate for competitive analysis here. Applicant, utilizing New York State Department of Commerce designations, claims that even the Binghamton
Economic Area, which covers five counties in New
York state and within which all its offices are located, is
too small to be the relevant geographic market in this
instance. It argues that the relevant market consists of
an additional eight counties as well as the five counties
in the Binghamton Economic Area; this "market" has a
total of 52 commercial banks, of which 27 are in the
Binghamton Economic Area. The application also declares that Bank's market is limited to not more than 20
miles from Sidney, which would include Applicant's
main office location. This area also includes the communities of Oneonta and Walton, head office locations
of Wilber National Bank and National Bank of Delaware
County, respectively, parties to another proposed merger concerning which we are writing to you today.
In our opinion, the appropriate market is, at the
largest, the counties of Delaware, Otsego and Chenango. Sidney is at the northwestern corner of Delaware County near the eastern boundary of Chenango
County and the southwestern boundary of Otsego
County. No new banks have been established in this

area in the last 5 years and two commercial banks
have opened a total of only three offices in that period.
Several mergers have taken place in the last 10 years,
including three by Applicant.
In Delaware County, Bank's home county, Applicant
is the leading bank in deposits and number of offices.
Its three branches hold $25.2 million in deposits, or
17.7 percent of total county deposits. The second
largest bank, National Bank of Delaware County, holds
$22.6 million in deposits, of 15.9 percent of total county deposits, and, as noted, proposes to merge with
Wilber National Bank of Oneonta. Bank is the third
largest in the county, with 13 percent of total deposits.
After the proposed acquisition, the combined bank
would control 30.7 percent of total county deposits.
In Chenango County, Applicant's home county is, by
far, the dominant banking institution. It has nine of the
12 offices and 69.5 percent of total deposits in the
county. A Binghamton-based subsidiary of First Lincoln Banks, Inc., accounts for an additional 11.3 percent of total deposits at its one office in Chenango
County. Neither Applicant nor Bank has an office in
Otsego County, which adjoins both of the above counties.

In the combined three-county area, Applicant is the
largest bank with 27.4 percent of deposits. Bank has
3.7 percent, and, after the acquisition, the combined
bank would have 31.1 percent of total deposits. Wilber
National Bank and National Bank of Delaware, after
merging, would be the second largest bank with 18.6
percent of three-county deposits.
Applicant's nearest office to Bank is Bainbridge, 6
miles southwest. Although Applicant says there is little
"head to head" competition between them, it appears,
on the basis of the limited information in the application, that they are the leading competitors for real
estate mortgages in the area of Bank's offices. In
1975, between them, they accounted for 77 of 266
mortgages recorded, in 1976 for 108 of 319 mortgages recorded, and in 1977 for 106 of 364 mortgages recorded. No other lender had as high a share
as either Applicant or Bank. This direct and significant
competition would be eliminated as a result of the acquisition.
In view of the elimination of the existing competition
between Bank and Applicant, and the position of the
resulting bank in the market, the proposed acquisition
would have an adverse effect on competition.

ADAMS COUNTY NATIONAL BANK,
Cumberland Township (P.O. Gettysburg), Pa., and The National Bank of Arendtsville, Arendtsville, Pa.
Banking offices
Names of banks and type of transaction

Total
assets

The National Bank of Arendtsville, Arendtsville, Pa. (9139), with
and Adams County National Bank, Cumberland Township (P.O. Gettysburg), Pa. (311), which h a d . . .
merged Dec. 3 1 , 1 9 7 8 , under charter and title of the latter bank (311). The merged bank at date of
merger had

COMPTROLLER'S DECISION
An application has been filed with the Office of the
Comptroller of the Currency pursuant to the Bank Merger Act (12 USC 1828(c)), that requires prior written
consent to the proposed merger of The National Bank
of Arendtsville, Arendtsville, Pa. ("NBA"), the merging
bank, into Adams County National Bank, Cumberland
Township (P.O. Gettysburg), Pa. ("ACNB"), the charter
bank, under the charter and title of Adams County National Bank. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth.
ACNB was founded in 1857 as a. state-chartered
savings institution and has operated as a national
banking association since March 11, 1864, when this
Office granted charter number 311 to the bank. In
addition to its main office, ACNB operates six branch
offices, all domiciled within Adams County. As of
March 31, 1978, ACNB had total commercial bank deposits of approximately $106.5 million.
Operating under national banking association charter number 9139 since May 18, 1908, as of March 31,
1978, NBA had total deposits of $11.9 million. In addi


$ 13,795,000
124,277,000
138,065,000

In
operation

To be
operated

o

8
10

tion to its head office in Arendtsville, NBA operates
one branch office in Franklin Township.
At the present time, both of the proponents' operations are confined to Adams County wherein there are
headquartered eight commercial banks that operate
25 banking offices. ACNB ranks as the largest commercial bank in Adams County and NBA ranks as the
fourth largest bank within the county. The main offices
of the proponent banks are approximately 10 miles
apart and their nearest offices are separated by 8 road
miles. From data contained within the file, it would
appear that the proponents serve two separate and
distinct primary service areas within Adams County.
NBA primarily serves the northwest and west-central
portions of the county while ACNB primarily serves the
banking community of the immediate Gettysburg area,
the surrounding south-central and eastern portions of
Adams County, a portion of adjoining York County
(running along the eastern border of Adams County),
and part of Carroll County, Md. ACNB derives less
than 4 percent of its total deposits and slightly in excess of 2 percent of its total loans from the primary
service area of NBA. Likewise, NBA obtains approximately 6.5 percent of its total deposits and less than 9
103

percent of its total loans from the area of ACNB's focal
competitive impact. NBA realizes its most intense
competition from the Biglerville office of the Gettysburg
National Bank (total deposits of $78.9 million), located
approximately 3 miles to the east of NBA's head office,
and The Bendersville National Bank (total deposits of
$11.7 million), 5 miles to the north of Arendtsville.
Approval of this application would result in the first
largest (ACNB) and the second largest (The Gettysburg National Bank) commercial banks directly competing in all parts of Adams County. Additionally, the
National Central Bank, Lancaster (total deposits of
approximately $1.2 billion) operates two offices in
Hanover (located near the York-Adams County line),
and Dauphin Deposit Bank and Trust Company, Harrisburg (total deposits of $468 million) also maintains
two banking offices in Hanover. One other larger competitor, CCNB Bank, N.A., New Cumberland (total deposits of $240 million) has a branch in New Oxford,
Adams County, about 8 miles to the east of Gettysburg. The combined resources of NBA and ACNB
should fortify the competitive position of ACNB with
respect to these larger competitors and the banking
public should be better served through this stimulated
competitive atmosphere. The resulting bank should be
in an enhanced position to more effectively compete
with the larger banks headquartered outside of Adams
County, but which actively compete within Adams
County. Although approval of this application would
have the effect of eliminating a degree of existing competition between ACNB and NBA, it is the opinion of
this Office that the overall effect of the proposal would
not be substantially adverse and, in fact, NBA's banking customers would be offered a more viable and
meaningful banking alternative.
Applicable Pennsylvania branching statutes permit
the participating banks to establish ate novo offices
throughout the counties of Adams, Franklin, Cumberland and York. Due to the size of the community of
Arendtsville (approximately 600 residents) and the rural surrounding atmosphere, it does not appear that
ACNB would choose to enter the immediate Arendtsville area via de novo expansion. Furthermore, given
the relative size of NBA, in relation to its major competitors, the operating philosophy of the bank and the
bank's limited financial resources, it does not appear
reasonable to conclude that the merging bank would
utilize this form of expansion.
The economy of Adams County is primarily agrarian
in nature, with a heavy emphasis upon the raising and
harvesting of fruit on a commercial basis. There are
several actual and potential customers employed in
this seasonal line of commerce for whom NBA is unable to provide service and meet credit requests. The
increased legal lending limit of the resulting bank will
better serve the credit needs of the banking public
currently served by NBA. Additionally, NBA does not
fully quality as a "full-service" bank inasmuch as the
bank does not offer to its customers such important
banking services as trust and fiduciary services, bankrelated credit card programs, I.R.A. programs, bank
letters of credit, and daily compounded interest on
regular savings accounts. All of these and other ex
104


panded and improved banking services will be offered
as a result of this merger. It is further contemplated
that the physical facilities of NBA will be altered with
the interior of the bank's head office being renovated
in order to provide additional space to better accommodate both customers and employees of NBA. On
balance, considerations relating to convenience and
needs lend considerable weight toward approval of
the subject proposal.
The financial and managerial resources of ACNB are
considered to be satisfactory. The financial resources
of NBA are regarded as satisfactory. The active dayto-day operations management of NBA is primarily
vested in one officer of the bank and it is noted that the
directorate of NBA is elderly and has not made apparent provision for adequate management succession at
the bank. Furthermore, ACNB has an established management personnel training program and is able to
provide competent and capable bankers who will be in
a position to prudently manage the affairs of NBA in a
sound manner.
The future prospects of ACNB appear favorable and
the future prospects of NBA should be favorably enhanced by affiliation with the charter bank.
This application was filed prior to the November 6,
1978, effective date of the Comptroller's Community
Reinvestment Act regulations, 12 CFR 25. However,
pursuant to the Community Reinvestment Act, Public
Law No. 95-128, available information relevant to the
bank's record of meeting its community credit needs
was reviewed and revealed no evidence to suggest
that the applicants are not meeting the credit needs of
their community, including low and moderate income
neighborhoods.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office, that the application is in the
public interest, and is approved.
November 30, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
At present both Applicant and Bank operate offices
exclusively in Adams County, which had a 1970 population of 56,937. Ten banks now operate a total of 24
offices in Adams County; eight of these banks are
headquartered in the county. Banking in Adams County is highly concentrated with the top four banks holding 79.9 percent of county deposits. Applicant is the
largest bank in the county with 38.5 percent of the
county deposits; Bank ranks fourth in size with a 4.3
percent market share.
Inasmuch as the city of Hanover and its environs in
neighboring York County serve as the commercial hub
for much of Adams County, it can be argued that the
appropriate relevant geographic market must include
these York County areas. The Federal Reserve Bank of
Philadelphia has recognized a Gettysburg—Hanover
market in its study of Pennsylvania banking markets.
Even under this broader market definition Applicant
has the largest market share with 21.1 percent of deposits and Bank has the eighth largest share with 2.4
percent.
Applicant argues that, despite its dominant pres-

ence in Adams County, it is an "outsider" for all practical purposes in Upper Adams, the northwest portion
of Adams County where Bank is located. Nevertheless,
the application indicates that direct competition between the two banks will be eliminated as a result of
the merger. According to Applicant, 3.5 percent of Applicant's deposits and 2.1 percent of Applicant's loans
originated in the service area of Bank and 6.5 percent
of Bank's deposits and 8.5 percent of Bank's loans
originated in Applicant's service area. These figures
do not include deposits from loans to persons having
businesses in both areas, persons who originally lived
in one area but moved to the other, persons residing in
one area and working in the other, and joint loan
participations. It should also be noted that the offices
of Applicant and Bank are separated by distances

ranging only from 8 to 20 miles. Thus, the merger if
consummated would have a significantly adverse
effect on actual competition in the area.
The proposed merger would also have an adverse
effect on potential competition in Adams County by
permitting an existing competitor to acquire a bank
that would be a suitable entry vehicle for a bank located in a contiguous county. The resulting unavailability of Bank as an entry vehicle thus lessens the possibility of needed deconcentration in the banking industry in Adams County.
Given the small size of bank and the relatively few
residents of Arendtsville, the overall conclusion is that
the proposed acquisition would have an adverse effect
on competition.
*

*

CENTURY NATIONAL BANK OF PALM BEACH COUNTY,
West Palm Beach, Fla., and Century National Bank, Boynton Beach, Fla.
Banking offices
Names of banks and type of transaction

Total
assets*

Century National Bank, Boynton Beach, Boynton Beach, Fla. (16415), with
and Century National Bank of Palm Beach County, West Palm Beach Fla. (16586), which had
merged Dec. 31,1978, under charter and title of the latter bank (16586). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Office of the Comptroller of the Currency requesting prior permission to
effectuate a merger of Century National Bank, Boynton
Beach, Boynton Beach, Fla. ("Merging Bank"), into
Century National Bank of Palm Beach County, West
Palm Beach, Fla. ("Charter Bank"), under the charter
and title of Century National Bank of Palm Beach
County. The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth.
Charter Bank was organized as the Northwood Bank
of West Palm Beach in 1973 and converted to a national banking association with charter number 16586
on June 14, 1976. As of June 30, 1978, Charter Bank
had total commercial bank deposits of $10.3 million.
Merging Bank was granted charter number 16415
as a national banking association on December 13,
1974, and as of June 30, 1978, had total commercial
bank deposits of $7.3 million.
Both Charter Bank and Merging Bank are banking
subsidiaries of Century Banks, Inc., Fort Lauderdale,
Fla., a registered multi-bank holding company that
controls 12 banks with deposits aggregating $742.1
million. Due to the common control and ownership between the proponent banks, the proposed merger
would not have any adverse competitive impact.
This application was filed prior to the November 6,




$ 8,474,000
12,846,000
14,933,000

To be
In
operation operated
1
2
3

1978, effective date of the Comptroller's Community
Reinvestment Act regulations, 12 CFR 25. However,
pursuant to the Community Reinvestment Act, Public
Law No. 95-128, available information relevant to the
bank's record of meeting its community credit needs
was reviewed and revealed no evidence to suggest
that the applicants are not meeting the credit needs of
their community, including low and moderate income
neighborhoods.
It is the conclusion of the Office of the Comptroller of
the Currency that this application essentially represents a corporate reorganization whereby Century
Banks, Inc., is consolidating its banking interests in
Palm Beach County and the proposal would not produce an adverse impact upon any relevant area of
consideration. The application is therefore deemed to
be not adverse to the public interest, and should be,
and hereby is, approved.
November 29, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are both substantially-owned subsidiaries of the same bank holding company. As such,
their proposed merger is essentially a corporate reorganization and would have no effect on competition.

"Asset figures are as of call dates immediately before and after
transaction.

105

LINCOLN FIRST BANK OF ROCHESTER,
Rochester, N.Y., and National Bank of Westchester, White Plains, N.Y., and Lincoln First Bank-Central, National
Association, Syracuse, N.Y., and First-City National Bank of Binghamton, N.Y., Binghamton, N.Y., and The First
National Bank of Jamestown, Jamestown, N.Y.
Banking offices
Names of banks and type of transaction

Total
assets

Lincoln First Bank of Rochester, Rochester, N.Y., with
and National Bank of Westchester, White Plains, N.Y. (10525), with
and First-City National Bank of Binghamton, N.Y., Binghamton, N.Y. (15625), with
and The First National Bank of Jamestown, Jamestown, N.Y. (15626), with
and Lincoln First Bank-Central, National Association, Syracuse, N.Y. (15627), which had
consolidated Dec. 31,1978, under charter of latter bank (15627) and title "Lincoln First Bank, N.A."
The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has received an application that requests prior written consent to the proposed consolidation of Lincoln First
Bank of Rochester, Rochester, N.Y. ("LFBR"); National
Bank of Westchester, White Plains, N.Y. ("NBW"); FirstCity National Bank of Binghamton, N.Y., Binghamton,
N.Y. ("FCNB"); The First National Bank of Jamestown,
Jamestown, N.Y. ("FNBJ"); and Lincoln First BankCentral, National Association, Syracuse, N.Y. ("Charter
Bank"), under the charter of Lincoln First Bank-Central,
National Association, and with the title of "Lincoln First
Bank, N.A." The subject application rests upon an
agreement executed among the proponent banks, incorporated herein by reference, the same as if fully set
forth.
LFBR is a state-chartered commercial bank that as
of December 31, 1977, had total deposits of $1.1 billion.
NBW is a national banking association operating
under charter number 10525, as granted by this Office
on April 29, 1914. As of calendar year-end 1977, NBW
had total deposits of $597.8 million.
FCNB has operated as a national bank since May
11, 1967, and had total deposits of $262.9 million as of
December 31, 1977.
FNBJ operates under national banking association


106


$1,195,733,000
725,418,000
306,593,000
154,266,000
410,838,000
3,160,782,000

To be
In
operation operated
51
38
16
10
25
140

charter number 15626 and, at year-end 1977, had total
deposits of slightly less than $141 million.
Charter Bank had deposits aggregating approximately $332.4 million as of the calendar end of 1977
and is a national banking association.
All five of the proponent banks are wholly-owned
banking subsidiaries of Lincoln First Banks Inc.,
Rochester, N.Y. By means of the subject proposal, the
corporate parent, Lincoln First Banks Inc., would
cease to be a registered multi-bank holding company
but, rather, through the consolidation of all its banking
interests, would become a one-bank holding company. The primary benefit to the banking public would
be the creation of a financially stronger banking institution, with enhanced resources and increased competitive abilities.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that this proposal is not
adverse to the public interest, and should be, and
hereby is, approved.
September5, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The consolidating banks are all wholly-owned subsidiaries of the same bank holding company. As such,
their proposed consolidation is essentially a corporate
reorganization and would have no effect on competition.

SOUTHEAST FIRST NATIONAL BANK OF SARASOTA,
Sarasota, Fla., and Southeast Bank of St. Armands, Sarasota, Fla., and Southeast Bank of Siesta Key, Sarasota,
Fla., and Southeast Bank of Village Plaza, N.A., Sarasota, Fla., and Southeast Bank of Venice, Venice, Fla.
Banking offices
Names of banks and type of transaction

Total
assets

Southeast Bank of St. Armands, Sarasota, Fla., with
and Southeast Bank of Siesta Key, Sarasota, Fla., with
and Southeast Bank of Venice, Venice, Fla., with
and Southeast Bank of Village Plaza, N.A., Sarasota, Fla. (15901), with
and Southeast First National Bank of Sarasota, Sarasota, Fla. (16531), which had
merged Dec. 31,1978, under charter and title of the latter bank (16531). The merged bank at date of
merger had

COMPTROLLER'S DECISION
An application has been filed with the Office of the
Comptroller of the Currency, pursuant to the Bank Merger Act (12 USC 1828(c)), that requires prior written
consent to effectuate a proposed merger of Southeast
Bank of St. Armands, Sarasota, Fla. ("St. Armands
Bank"); Southeast Bank of Siesta Key, Sarasota, Fla.
("Siesta Key Bank"); Southeast Bank of Venice, Venice
Fla. ("Venice Bank"); and Southeast Bank of Village
Plaza, N.A., Sarasota, Fla. ("Village Plaza Bank") (collectively, "Merging Banks"), into Southeast First National Bank of Sarasota, Sarasota, Fla. ("Charter
Bank"). The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth.
St. Armands Bank is a state-chartered commercial
banking institution that as of March 31, 1978, held total
deposits of $50.8 million.
Siesta Key Bank is also a state-chartered bank, and
had total deposits of slightly less than $29 million, on
March 31, 1978.
Venice Bank, with total commercial bank deposits of
$23.9 million is the smallest of the three proponent
state-chartered commercial banks.
With total deposits of approximately $23.8 million on
March 31, 1978, Village Plaza Bank is a national banking association operating under charter number
15901.
Charter Bank has operated under national banking




$ 50,918,000
32,058,000
26,117,000
29,491,000
107,126,000
241,188,000

in
To be
operation operated
1
1
1
1
2
6

association charter number 16531 as granted by this
Office on January 14, 1976. As of March 31, 1978,
Charter Bank had total deposits aggregating approximately $94.6 million.
All four Merging Banks and Charter Bank are commercial banking subsidiaries of the largest banking
organization headquartered within the state of Florida,
Southeast Banking Corporation, Miami, Fla., a registered multi-bank holding company that controls 40
banking subsidiaries, with total deposits of $2.8 billion,
as of December 31, 1977.
The subject application must be regarded essentially as a corporate reorganization whereby Southeast
Banking Corporation is consolidating a portion of its
banking interests located in the Sarasota, Fla. area.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the subject application is
not adverse to the public interest, and should be, and
hereby is, approved. Additionally, incident to approval
of this application, Charter Bank is authorized to operate all existing offices of the Merging Banks as branches of the resulting bank.
August 23, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The merging banks are all wholly-owned subsidiaries
of the same bank holding company. As such, their
proposed merger is essentially a corporate reorganization and would have no effect on competition.

107

//. Mergers consummated involving a single operating bank.
PEOPLES BANK AND TRUST, N.A.,
Trenton, Mich., and PBT Bank, National Association, Trenton, Mich.
Banking offices

Names of banks and type of transaction

Total
assets*

PBT Bank, National Association, Trenton, Mich. (16571), with
and Peoples Bank and Trust, N.A., Trenton, Mich. (16571), which had
consolidated Jan. 3,1978, under charter and title of the latter bank (16571). The consolidated bank at
date of consolidation had
.

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission to consolidate
PBT Bank, National Association (organizing), Trenton,
Mich. ("PBT"), and Peoples Bank and Trust, N.A.,
Trenton, Mich. ("Charter Bank"), under the title and
charter of Peoples Bank and Trust, N.A. The subject
application rests upon an agreement executed between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
On August 18, 1977, this Office granted its preliminary approval for the organization of PBT. The new national banking association charter application was
sponsored by principals of the sixth largest banking
organization headquartered in the state of Michigan,
Old Kent Financial Corporation, Grand Rapids, Mich.
("Old Kent"). To date, PBT has no operating history.
Charter Bank commenced operations on April 5,
1976, and as of June 30, 1977, the bank's total deposits were $135.2 million.
The closest office of any of Old Kent's seven subsidiary banks to Charter Bank is in excess of 150
miles. Therefore, the Board of Governors of the Federal Reserve System concluded that, in view of the dis*Asset figures are as of call dates immediately before and after
transaction.

$

120,000
158,215,000

In
To be
operation operated
0
1

165,617,000

tance involved and Michigan's restrictive branching
statutes, no competition existed between any of Old
Kent's banking subsidiaries and Charter Bank, when
the Board approved Old Kent's application to acquire
100 percent of the outstanding voting shares of the
successor by consolidation to Charter Bank on October 25, 1977.
Approval of this application would threrfore merely
combine a non-operating institution with an existing
commercial bank, and would produce no adverse impact upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
November 29, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed consolidation is part of a plan through
which Peoples Bank and Trust, N.A. would become a
subsidiary of Old Kent Financial Corporation, a bank
holding company. The instant transaction, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Old Kent
Financial Corporation, it would have no effect on competition.

THE FIRST NATIONAL BANK OF CASSOPOLIS,
Cassopolis, Mich., and Cassopolis National Bank, Cassopolis, Mich.
Banking offices
Total
assets

Names of banks and type of transaction

Cassopolis National Bank, Cassopolis, Mich. (1812), with
and The First National Bank of Cassopolis, Cassopolis, Mich. (1812), which had
consolidated Jan. 31,1978, under charter and title of the latter bank (1812). The consolidated bank at
date of consolidation had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission to consolidate
The First National Bank of Cassopolis, Cassopolis,
Mich. ("FNB"), and Cassopolis National Bank (organizing), Cassopolis, Mich. ("Cassopolis Bank"), under the

108


In
To be
operation operated

$ 127,000
20,639,000
20,776,000

charter and title of The First National Bank of Cassopolis.
The Office of the Comptroller of the Currency, in an
action dated February 12, 1976, granted preliminary
approval for the organization of a new national banking
association to be known as "Cassopolis National

Bank." The new association was organized by principals of the 32nd largest commercial banking organization headquartered within the state of Michigan, Western Michigan Corporation, Niles, Mich, a registered
one-bank holding company, whose subsidiary First
National Bank of Southwestern Michigan, Niles, holds
total deposits representing approximately 0.4 percent
of total deposits held by all commercial banks in the
state. To date, Cassopolis Bank has no operating history.
FNB has operated under national banking association charter number 1812 since April 18, 1871. As of
June 30, 1977, FNB had total deposits of $17.8 million.
The Board of Governors of the Federal Reserve System, by action dated June 30, 1976, denied the application of Western Michigan Corporation to acquire
FNB. Upon request for reconsideration filed with the
Board by the subject bank holding company, the
Board, on April 29, 1977, approved Western Michigan
Corporation's application to acquire 100 percent (less
directors' qualifying shares) of the successor by merger to FNB. Subsequently, on August 15, 1977, the
Federal Reserve Bank of Chicago, acting pursuant to
authority delegated by the Board, posed no objection

to Western Michigan Corporation's proposal to consolidate FNB and Cassopolis Bank. The primary purpose
of Cassopolis Bank is to act as the vehicle for the
acquisition of FNB by the bank holding company; and
as such, would merely combine an existing commercial bank with a non-operating entity. Accordingly, this
proposal would produce no adverse effect upon any
relevant area of consideration.
This application is therefore regarded as being not
adverse to the public interest, and should be, and
hereby is, approved.
November 15, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed transaction is part of a plan through
which First National Bank of Cassopolis would become
a subsidiary of Western Michigan Corporation, a bank
holding company. The instant consolidation, however,
would merely combine an existing bank with a nonoperating institution; as such, and without regard to
the acquisition of the surviving bank by Western Michigan Corporation, it would have no effect on competition.

BLACKSTONE VALLEY NATIONAL BANK,
Northbridge, Mass., and Old Colony National Bank of Worcester County, Northbridge, Mass.
Banking offices
Names of banks and type of transaction

Total
assets

Blackstone Valley National Bank, Northbridge, Mass. (1022), with
and Old Colony Bank of Worcester County, National Association, Northbridge, Mass. (1022), which
had
merged Feb. 6, 1978, under charter and title of the latter bank (1022). The merged bank at date of
merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission to effectuate a
merger of Blackstone Valley National Bank, Northbridge, Mass. ("Merging Bank"), into Old Colony Bank
of Worcester County, National Association (organizing), Northbridge Mass. ("Old Colony"), the charter
bank, under the charter and title of Old Colony Bank of
Worcester County, National Association. The subject
application rests upon an agreement executed between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
On August 9, 1977, the Office of the Comptroller of
the Currency granted preliminary approval for the
organization of Old Colony. To date, the charter bank
has no operating history.
Merging Bank was organized as The Blackstone
Bank in 1825 and converted to a national banking association with charter number 1022 on April 17, 1865. As
of December 31,1976, Merging Bank had total deposits
of $25.4 million.
Old Colony was organized by principals of First National Boston Corporation, Boston, Mass., a registered



In
To be
operation operated

$28,566,000

5

1,030,000

0

29,596,000

multi-bank holding company that as of year-end 1976
controlled five banking subsidiaries with domestic
commercial bank deposits aggregating $3.0 billion.
The combination of Old Colony and Merging Bank
would have merely the effect of combining a nonoperating entity with an existing commercial banking
institution; and as such, would produce no adverse
effect upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the proposal considered
herein is not adverse to the public interest, and the
application should be, and hereby is, approved.
November 18, 1977.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Blackstone Valley National Bank would become a subsidiary of First National Boston 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 Boston Corporation, it would have no effect on competition.
109

THE CENTRAL SECURITY NATIONAL BANK OF LORAIN COUNTY,
Lorain, Ohio, and The Central Trust Company of Lorain County, National Association, Lorain, Ohio.
Banking offices

Names of banks and type of transaction

Total
assets

The Central Security National Bank of Lorain County, Lorain, Ohio (15456), with
and The Central Trust Company of Lorain County, National Association, Lorain, Ohio (15456), which
had
merged Feb. 15,1978, under charter of the latter bank (15456) and title "The Central Security
National Bank of Lorain County." The merged bank at date of merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency has received an application filed pursuant to 12 USC
1828(c), requesting prior permission to effectuate a
merger of The Central Security National Bank of Lorain
County, Lorain, Ohio ("Merging Bank"), into The Central Trust Company of Lorain County, National Association (organizing), Lorain, Ohio ("Charter Bank"), under
the charter of The Central Trust Company of Lorain
County, National Association, and with the title of The
Central Security National Bank of Lorain County. The
subject application rests upon an agreement executed
between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Merging Bank was granted national banking association charter number 15456 by this Office on December 24, 1968. As of March 31, 1977, Merging Bank's
total commercial bank deposits aggregated $93.4 million.
In an action dated June 21, 1977, this Office granted
preliminary approval for the organization of Charter
Bank. The application was sponsored by principals of
The Central Bancorporation, Inc., Cincinnati, Ohio

In
To be
operation operated

$110,424,000

11

240,000

0

108,868,000

11

("Central"); to date, Charter Bank has no operating
history.
The Board of Governors of the Federal Reserve System granted its prior approval for the acquisition of
Merging Bank by Central on July 5, 1977. Charter
Bank's primary function is to serve as the vehicle for
the acquisition of the existing national bank by the
bank holding company.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
January 13, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
The Central Security National Bank of Lorain County
would become a subsidiary of The 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 The
Central Bancorporation, Inc., it would have no effect
on competition.

CAPITOL NATIONAL BANK,
Raleigh, N.C., and New Capitol Bank, National Association, Raleigh, N.C.
Banking offices
Names of banks and type of transaction

Total
assets

Capitol National Bank, Raleigh, N.C. (16100), with
and New Capitol Bank, National Association, Raleigh, N.C. (16100), which had
merged Apr. 1,1978, under the charter of the latter bank (16100) and title "Capitol National Bank.'
The merged bank at date of merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application, pursuant to the Bank Merger
Act (12 USC 1828(c)), that requires the prior approval
of this Office of the proposed merger of Capitol National Bank, Raleigh, N.C. ("Merging Bank"), into New
Capitol Bank, National Association (organizing),
Raleigh, N.C. ("Charter Bank"), under the charter of
New Capitol Bank, National Association, and with the
title of Capitol National Bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth. As required by the Bank

110


$12,840,000
240,000

In
To be
operation operated

2
0

13,080,000

Merger Act, notice of the proposed transaction was
published in an acceptable form and reports concerning the competitive effects were requested from the
U.S. Attorney General, the Federal Deposit Insurance
Corporation, and the Board of Governors of the Federal Reserve System. This Office has considered the application and all reports received in the light of the
factors set forth in the Bank Merger Act.
Charter Bank was granted preliminary approval to
organize b'y this Office on November 14, 1977; and to
date, the new bank has no operating history. The new
bank application was sponsored by principals of United
Carolina Bancshares Corporation, Whiteville, N.C.

("UCB"), a registered multi-bank holding company,
that controls three wholly-owned banking subsidiaries
and 49 percent of the outstanding voting shares of
Merging Bank. The primary significance of Charter
Bank is to facilitate the acquisition of the remaining 51
percent of Merging Bank's shares by UCB.
Merging Bank has operated as a national banking
association since its inception in 1973. As of June 30,
1977, Merging Bank had total deposits of approximately $8.6 million, and operated two banking offices
in Raleigh.
On January 31, 1978, acting pursuant to delegated
authority for the Federal Reserve Board, the Federal
Reserve Bank of Richmond approved the application
of UCB to acquire 100 percent of the outstanding voting shares (less directors' qualifying shares) of the
successor by merger to Merging Bank. The subject
merger is a portion of an overall plan whereby Merging
Bank will become a wholly-owned subsidiary of UCB.
The merger would merely join an existing bank with a

non-operating institution; and as such, would have no
adverse consequences within any relevant area of
consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
February 27, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Capitol National Bank would become a subsidiary of
United Carolina Bancshares 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 Carolina Bancshares Corporation, it would have no effect on competition.

FIRST NATIONAL BANK OF MCALLEN,
McAllen, Tex., and McAllen Commerce Bank National Association, McAllen, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

First National Bank of McAllen, McAllen, Tex. (14635), with
and McAllen Commerce Bank National Association, McAllen, Tex. (14635), which had
merged Apr. 7,1978, under charter of the latter bank (14635) and title "First National Bank of
McAllen." The merged bank at date of merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application filed pursuant to 12 USC
1828(c), that seeks prior written permission to effect a
merger of First National Bank of McAllen, McAllen,
Tex. ("Merging Bank"), into McAllen Commerce Bank
National Association (organizing), McAllen, Tex.
("Charter Bank"), under the charter of McAllen Commerce Bank National Association, and with the title of
First National Bank of McAllen. The subject application
rests upon an agreement executed between the proponent banks which is incorporated herein by reference, the same as if fully set forth. Notice of the proposal, as required by the Bank Merger Act, was published in a form approved by this Office, and competitive factor reports were solicited from the U.S. Attorney
General, the Federal Deposit Insurance Corporation,
and the Board of Governors of the Federal Reserve
System; all three agencies submitted reports. The
Office of the Comptroller of the Currency has considered the application and all comments and reports received in the light of the factors set forth in the Bank
Merger Act.
On August 25, 1977, this Office granted preliminary
approval for the organization of Charter Bank. Sponsored by principals of Texas Commerce Bancshares,
Inc., Houston, Tex. a registered multi-bank holding
company, to date Charter Bank has no operating his


In
To be
operation operated

$122,664,000
240,000
124,593,000

tory and its primary function is to serve as the vehicle
for the acquisition of Merging Bank by Texas Commerce Bancshares, Inc.
Merging Bank has operated under national banking
association charter number 14635 since November 1,
1949. As of June 30, 1977, Merging Bank's total deposits aggregated slightly in excess of $100 million.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that the proposed merger is a portion of a plan
whereby Merging Bank will become a subsidiary of a
bank holding company and, as such, would merely
combine an existing commercial bank with a nonoperating institution, resulting in no adverse impact
upon any relevant area of consideration. The application is therefore deemed to be not adverse to the public interest, and should be, and hereby is, approved.
March 7, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
First National Bank of McAllen would become a subsidiary of Texas Commerce 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 Texas Commerce Bancshares, Inc., it would have no effect on competition.
111

CITY NATIONAL BANK IN WICHITA FALLS,
Wichita Falls, Tex., and City Bank, National Association, Wichita Falls, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

City National Bank in Wichita Falls, Wichita Falls, Tex. (13665), with
and City Bank, National Association, Wichita Falls, Tex. (13665), which had,
merged Apr. 14,1978, under charter of the latter bank (13665) and title "City National Bank in Wichita
Falls." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to provisions of the Bank Merger Act of 1966
(12 USC 1828(c)), an application has been filed with
the Office of the Comptroller of the Currency requesting prior written consent to a proposed merger of City
National Bank in Wichita Falls, Wichita Falls, Tex.,
("Merging Bank"), into City Bank, National Association
(organizing), Wichita Falls, Tex. ("Charter Bank"),
under the charter of City Bank, National Association,
and with the title of City National Bank in Wichita Falls.
The subject application rests upon an agreement executed between the proponent banks, incorporated
herein by reference, the same as if fully set forth. Additionally, as required by the Bank Merger Act, notice of
the proposed transaction was published in a form
approved by this Office, and reports concerning the
competitive effects were requested from the U.S. Attorney General, the Board of Governors of the Federal
Reserve System, and the Federal Deposit Insurance
Corporation; reports were submitted by the U.S. Attorney General and the Federal Reserve Board.
By action dated October 19, 1977, this Office
granted preliminary approval for the organization of
Charter Bank. The application to organize a new national bank was sponsored by principals of First International Bancshares, Inc., Dallas, Tex. ("FIB"), a registered multi-bank holding company, the third largest
banking organization headquartered in Texas, that controls 27 banks with total deposits of $3.98 billion. To
date, Charter Bank has no operating history, and its
primary function is to serve as the acquisition vehicle

In
To be
operation operated

$209,725,000
242,000
209,967,000

for FIB to acquire the successor by merger to Merging
Bank.
Merging Bank has operated under national banking
association charter number 13665 since March 15,
1933, and as of December 31, 1977, Merging Bank's
total commercial bank deposits aggregated $181.1
million.
On January 6, 1978, the Federal Reserve Board
granted its prior approval, as required by the Bank
Holding Company Act of 1956 (12 USC 1842(a)(3)), of
the application of FIB to acquire the successor by merger to Merging Bank. The instant proposal involving
Charter Bank and Merger Bank would have the effect
of merely combining a non-operating entity with an existing institution; and would produce no adverse effect
upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
March 15, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
City National Bank in Wichita Falls 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.

KELLY FIELD NATIONAL BANK OF SAN ANTONIO,
San Antonio, Tex., and American Servicemen's National Bank, San Antonio, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

Kelly Field National Bank of San Antonio, San Antonio, Tex. (14794), with
and American Servicemen's National Bank, San Antonio, Tex. (14794), which had
merged May 12,1978, under charter of the latter bank (14794) and title "Kelly Field National Bank of
San Antonio." The merged bank at date of merger had

COMPTROLLER'S DECISION
Kelly Field National Bank of San Antonio, San Antonio,
Tex. ("KFNB"), the merging bank, and American Servicemen's National Bank (organizing), San Antonio, Tex.
("Charter Bank"), have applied to the Office of the

112


In
To be
operation operated

$64,817,000
240,000
65,057,000

Comptroller of the Currency, pursuant to 12 USC
1828(c), the Bank Merger Act, for prior written consent
to effectuate a merger of KFNB into Charter Bank,
under the charter of American Servicemen's National
Bank, and with the title of Kelly Field National Bank of

San Antonio. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth. This Office has considered the application in
the light of factors set forth within the Bank Merger Act.
KFNB has operated under national banking association charter number 14794 since the charter was
granted by this Office on October 11, 1956. As of September 30, 1977, KFNB had total commercial bank
deposits aggregating approximately $58.7 million.
By action dated June 10, 1977, this Office granted
preliminary approval for Charter Bank to organize. To
date, the bank has no operating history. The primary
function of Charter Bank is to serve as the acquisition
vehicle for Kelly Field Bancshares Corporation, San
Antonio, Tex. to acquire 100 percent (less directors'
qualifying shares) of the successor by merger to Kelly
Field National Bank of San Antonio. (The Board of Governors of the Federal Reserve System, on September
9, 1977, granted prior approval for Kelly Field Bancshares Corporation to become a bank holding company.)

Approval of the subject proposal would merely have
the effect of combining a non-operating entity with an
existing commercial bank, and would produce no
adverse effect upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the application is not
adverse to the public interest, and should be, and
hereby is, approved.
April 7, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Kelly Field National Bank of San Antonio would become a subsidiary of Kelly Field Bancshares 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 Kelly
Field Bancshares Corporation, it would have no effect
on competition.

FIRST NATIONAL BANK OF MAYWOOD,
Maywood, III., and Maywood National Bank, Maywood,
Banking offices
Names of banks and type of transaction

Total
assets*

First National Bank of Maywood, Maywood, III. (14470), with
and Maywood National Bank, Maywood, III. (14470), which had
merged May 15,1978, under charter of the latter bank (14470) and title "First National Bank of
Maywood." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), an application has been
filed with the Office of the Comptroller of the Currency
asking prior written consent to the proposed merger of
First National Bank of Maywood, Maywood, III. ("Merging Bank"), into Maywood National Bank (organizing),
Maywood, III. ("Charter Bank"), under the charter of
Maywood National Bank, and with the title of First National Bank of Maywood. The subject application rests
upon an agreement executed between the proponent
banks, incorporated herein by reference, the same as
if fully set forth.
By action dated October 26, 1976, this Office
granted preliminary approval to organize a new national banking association to be known as "Maywood National Bank." To date, Charter Bank has no operating
history, and the primary function of Charter Bank is to
serve as the vehicle for the acquisition of Merging
Bank by First Maywood, Inc., Maywood, III., a newly
approved bank holding company.
Merging Bank has operated under national banking
association charter number 14470 since this Office
issued that charter on September 7, 1943. As of Sep-




In
To be
operation operated

$36,307,000
120,000
37,411,000

tember 30, 1977, Charter Bank held total commercial
bank deposits aggregating $32.6 million.
Inasmuch as approval of this transaction would
merely have the effect of combining a non-operating
entity with an existing commercial bank, there would
be no adverse impact upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that this proposal is not
adverse to the public interest, and should be, and
hereby is, approved.

April 14, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
First National Bank of Maywood would become a subsidiary of First Maywood, 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 Maywood, Inc., it would have
no effect on competition.
*Asset figures are as of call date immediately before and after transaction.

113

COMMUNITY NATIONAL BANK,
Flushing, Ohio, and Second National Bank, Flushing, Ohio.
Banking offices
Names of banks and type of transaction

Total
assets*

Community National Bank, Flushing, Ohio (12008), with
and Second National Bank, Flushing, Ohio (12008), which had
merged July 15,1978, under charter of the latter bank (12008) and title "Community National Bank."
The merged bank at date of merger had

COMPTROLLER'S DECISION
Community National Bank, Flushing, Ohio ("Merging
Bank"), and Second National Bank (organizing),
Flushing, Ohio ("Charter Bank"), have applied to the
Office of the Comptroller of the Currency, pursuant to
the Bank Merger Act (12 USC 1828(c)), for prior written consent to the proposed merger of Community National Bank, Flushing, Ohio, into Second National Bank
(organizing), Flushing, Ohio, under the charter of the
Second National Bank and with the title of Community
National Bank. The subject application rests upon an
agreement executed between the proponent banks,
incorporated herein by reference, the same as if fully
set forth. This Office has considered the application in
the light of factors set forth within the Bank Merger Act.
By action dated September 26, 1977, this Office
granted preliminary approval for the organization of a
new national bank (Charter Bank), sponsored by principals of First Steuben Bancorp. Inc., Steubenville
Ohio ("FSB"), a registered multi-bank holding company. To date, the Charter Bank has no operating history, and its primary function is to serve as the acquisition vehicle for Merging Bank to become a banking
subsidiary of FSB.
*Asset figures are as of call dates immediately before and after
transaction.

$14,598,000
180,000

In
To be
operation operated
2
0

14,768,000

Merging Bank has operated under national banking
association charter number 12008 since that charter
was issued by this Office on August 19, 1921. As of
December 31, 1977, Merging Bank had total deposits
of approximately $14.2 million.
The subject proposal would merely have the effect
of combining an existing commercial bank with a nonoperating entity; and as such, would have no adverse
consequences within any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
June 15, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Community National Bank would become a subsidiary
of First Steuben 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 First Steuben Bancorp, Inc., it would
have no effect on competition.

THE CITIZENS NATIONAL BANK OF EMPORIA,
Emporia, Va., and Greensville-Emporia National Bank, Emporia, Va.
Banking offices
Names of banks and type of transaction

Total
assets*

The Citizens National Bank of Emporia, Emporia, Va. (12240), with
and Greensville-Emporia National Bank, Emporia, Va. (12240), which had
merged July 31,1978, under the charter of the latter bank (12240) and title "The Citizens National
Bank of Emporia." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act (12 USC 1828(c)), an
application has been filed with the Office of the Comptroller of the Currency requesting prior written consent
to the proposed merger of Greenville-Emporia National
Bank (organizing), Emporia, Va., ("Charter Bank"), with
The Citizens National Bank of Emporia, Emporia, Va.
*Asset figures are as of call date immediately before and after transaction.

114


$32,964,000
60,000

In
To be
operation operated
4
0

33,225,000

("Merging Bank"), under the charter of GreenvilleEmporia National Bank, and with the title of The
Citizens National Bank of Emporia. The subject application rests upon an agreement executed between the
proponent banks, incorporated herein by reference,
the same as if fully set forth.
By action dated February 24, 1978, this Office
granted preliminary approval to organize a new national bank to be known as Greenville-Emporia National
Bank. The new bank applicatn was sponsored by principals of the ninth largest banking organization head-

quartered within the Commonwealth of Virginia, Central National Corporation, Richmond, Va. ("CNB"), a
registered multi-bank holding company that controls
six subsidiary banks with total deposits of approximately $428 million. To date, Charter Bank has no
operating history.
Merging Bank has operated as a national banking
association since 1922 when it was granted charter
number 12240 by this Office. As of December 31,
1977, Merging Bank held total commercial bank deposits aggregating approximately $28.9 million.
On April 28, 1978, the Board of Governors of the
Federal Reserve System granted its prior approval to
an application filed by CNB for the acquisition of the
successor by merger to The Citizens National Bank of
Emporia. The primary purpose of Charter Bank is to
serve as the acquisition vehicle for CNB to acquire
Merging Bank.
Accordingly, approval of the subject merger would

have the effect of merely combining a non-operating
institution with an existing commercial bank; and as
such, would produce no adverse effect upon any relevant area of consideration.
The application is therefore deemed to be in the
public interest, and should be, and hereby is,
approved.
June 30, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Citizens National Bank of Emporia would become a
subsidiary of Central 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 Central National Corporation, it would have no effect on competition.

NATIONAL BANK OF MARSHALL,
Marshall, Mich., and CFC National Bank, Marshall, Mich.
Banking offices
Names of banks and type of transaction

Total
assets

National Bank of Marshall, Marshall, Mich. (15877), with
and CFC National Bank, Marshall, Mich. (15877), which had
merged July 31,1978, under charter of the latter bank (15877) and title "National Bank of Marshall."
The merged bank at date of merger had

COMPTROLLER'S DECISION
Application has been made to the Comptroller of the
Currency requesting prior permission to effectuate a
merger of National Bank of Marshall, Marshall, Mich.
("Merging Bank"), into CFC National Bank (organizing), Marshall, Mich. ("Charter Bank"), under the charter of CFC National Bank, and with the title of National
Bank of Marshall. The subject application rests upon
an agreement executed between the proponent
banks, and is incorporated herein by reference, the
same as if fully set forth.
On March 20, 1978, this Office granted preliminary
approval for the organization of Charter Bank; to date,
the new bank has no operating history. Charter Bank
was organized by principals of Chemical Financial
Corporation, Midland, Mich. ("Chemical"), a registered
multi-bank holding company, and its primary purpose
is to act as the acquisition vehicle whereby Merging
Bank would become a banking subsidiary of Chemical.
Merging Bank was granted national banking association charter number 15877 by this Office on June 4,




In
To be
operation operated

$ 9,925,585
120,000
10,045,585

1971, and as of December 31, 1977, held total deposits of $8.8 million.
The proposed merger would merely have the effect
of combining an existing commercial banking institution with a non-operating entity; and as such, would
produce no adverse effect upon any relevant area of
consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
June 28, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
National Bank of Marshall would become a subsidiary
of Chemical 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 Chemical Financial Corporation,
it would have no effect on competition.

115

BEXAR COUNTY NATIONAL BANK OF SAN ANTONIO,
San Antonio, Tex., and North St. Mary National Bank, San Antonio, Tex.
Banking offices

Names of banks and type of transaction

Total
assets*

Bexar County National Bank of San Antonio, San Antonio, Tex. (14283), with
and North St. Mary National Bank, San Antonio, Tex. (14283), which had
merged Aug. 1,1978, under charter of the latter bank (14283) and title "Bexar County National Bank
of San Antonio." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to the Bank Merger Act (12 USC 1828(c)), an
application has been submitted to the Office of the
Comptroller of the Currency requesting prior written
permission to effect a merger of North St. Mary National Bank (organizing), San Antonio, Tex. ("Charter
Bank"), and Bexar County National Bank of San Antonio, San Antonio, Tex. ("Merging Bank"), under the
charter of North St. Mary National Bank, and with the
title of Bexar County National Bank of San Antonio. The
subject application rests upon an agreement executed
between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
On March 24, 1978, this Office granted preliminary
approval to organize a new national bank to be known
as North St. Mary National Bank. The new bank application was sponsored by principals of the fourth
largest banking organization in Texas, Republic of
Texas Corporation, Dallas, Tex. a registered multibank holding company that controls 14 banks with
aggregate commercial bank deposits of approximately
$3.4 billion. The primary purpose of Charter Bank is to
serve as the vehicle for the acquisition of the successor by merger to Bexar County National Bank of San
Antonio. (By action dated June 16, 1978, the Board of
*Asset figure for Bexar County National Bank of San Antonio before
merger is as of immediately preceding call date.

In
To be
operation operated

$150,627,000
240,000
$146,752,000

Governors of the Federal Reserve System granted its
prior approval for Republic of Texas Corporation to
have Merging Bank become a subsidiary of the bank
holding company.)
Merging Bank was granted national banking association charter number 14283 by this Office on October 16, 1934. As of December 31, 1977, Merging Bank
had total deposits of slightly less than $145 million.
Approval of this proposal would merely join together
an existing commercial bank with non-operating entity;
and as such, would have no adverse impact upon any
relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the subject application is
in the public interest, and should be, and hereby is,
approved.
June 30, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Bexar County National Bank of San Antonio would become a subsidiary of Republic of Texas 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 Republic of
Texas Corporation, it would have no effect on competition.

THE FIRST NATIONAL BANK & TRUST COMPANY OF AUGUSTA,
Augusta, Ga., and National Interim Bank of Augusta, Augusta, Ga.
Banking offices
Names of banks and type of transaction

The First National Bank & Trust Company of Augusta, Augusta, Ga. (1860), with
and National Interim Bank of Augusta, Augusta, Ga. (1860), which had
merged Aug. 17,1978, under charter of the latter bank (1860) and title "The First National Bank &
Trust Company of Augusta." The merged bank at date of merger had


116


Total
assets
$103,902,000
250,000
100,543,000

In
To be
operation operated
8
0

THE FIRST NATIONAL BANK & TRUST COMPANY IN MACON,
Macon, Ga., and National Interim Bank of Macon, Macon, Ga.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank & Trust Company in Macon, Macon, Ga. (10270), with
and National Interim Bank of Macon, Macon, Ga. (10270), which had
merged Aug. 17,1978, under charter of the latter bank (10270) and title "The First National Bank &
Trust Company in Macon." The merged bank at date of merger had

In
To be
operation operated

$186,073,000
250,000
171,912,000

THE FIRST NATIONAL BANK OF ROME,
Rome, Ga., and National Interim Bank of Rome, Rome, Ga.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank of Rome, Rome, Ga. (2368), with
and National Interim Bank of Rome, Rome, Ga. (2368), which had
merged Aug. 17,1978, under charter of the latter bank (2368) and title "The First National Bank of
Rome." The merged bank at date of merger had

In
To be
operation operated

$82,118,000
250,000
81,079,000

THE NATIONAL BANK AND TRUST COMPANY OF COLUMBUS, GA.,
Columbus, Ga., and National Interim Bank of Columbus, Columbus, Ga.
Banking offices
Names of banks and type of transaction

Total
assets

The National Bank and Trust Company of Columbus, Ga., Columbus, Ga. (31901), with
and National Interim Bank of Columbus, Columbus, Ga. (31901), which had
merged Aug. 17, 1978, under charter of the latter bank (31901) and title "The National Bank and
Trust Company of Columbus, Ga." The merged bank at date of merger had

$94,982,000
250,000

In
To be
operation operated
7
0
7

91,149,000

TRUST COMPANY OF GEORGIA BANK OF SAVANNAH, N.A.,
Savannah, Ga., and National Interim Bank of Savannah, Savannah, Ga.
Banking offices

Names of banks and type of transaction

Total
assets

Trust Company of Georgia Bank of Savannah, N.A., Savannah, Ga. (13472), with
and National Interim Bank of Savannah, Savannah, Ga. (13472), which had
merged Aug. 17,1978, under charter of the latter bank (13472) and title "Trust Company of Georgia
Bank of Savannah, N.A." The merged bank at date of merger had

COMPTROLLER'S DECISION
Five separate but related applications have been submitted to the Office of the Comptroller of the Currency
pursuant to applicable requirements of 12 USC
1828(c), the Bank Merger Act, requesting prior written
consent to the proposed mergers of The First National
Bank & Trust Company of Augusta, Augusta, Ga. ("Augusta Bank") into National Interim Bank of Augusta
(organizing), Augusta, Ga. ("Augusta Charter Bank")
under the charter of National Interim Bank of Augusta
and with the title of The First National Bank & Trust
Company of Augusta; The National Bank and Trust
Company of Columbus, Ga., Columbus, Ga. ("Columbus Bank") into National Interim Bank of Columbus,



$121,484,000
250,000
116,113,000

In
To be
operation operated
11
0
11

Columbus, Ga., ("Columbus Charter Bank") under the
charter of National Interim Bank of Columbus and with
the title of The National Bank and Trust Company of
Columbus, Ga.; The First National Bank & Trust Company in Macon, Macon, Ga. ("Macon Bank") into National Interim Bank of Macon (organizing), Macon, Ga.
("Macon Charter Bank") under the charter of National
Interim Bank of Macon and with the title of The First
National Bank & Trust Company in Macon; The First
National Bank of Rome, Rome, Ga. ("Rome Bank") into
National Interim Bank of Rome (organizing), Rome, Ga.
("Rome Charter Bank") under the charter of National
Interim Bank of Rome and with the title of The First
National Bank of Rome; and, Trust Company of Geor117

gia Bank of Savannah, N.A., Savannah, Ga. ("Savannah Bank") into National Interim Bank of Savannah
(organizing), Savannah, Ga. ("Savannah Charter
Bank") under the charter of National Interim Bank of
Savannah and with the title of Trust Company of Georgia Bank of Savannah, N.A. The applications rest upon
five separate and distinct agreements executed between the five pairs of the 10 proponent banks and
each agreement is incorporated herein by reference,
the same as if fully set forth.
By separate actions, all dated May 18, 1978, this
Office granted preliminary approval for the organization of Augusta Charter Bank, Columbus Charter Bank,
Macon Charter Bank, Rome Charter Bank and Savannah Charter Bank. To date, none of the five institutions
has any operating history. All five of the new bank
applications were sponsored by principals of Trust
Company of Georgia, Atlanta, Ga. ("TCG"), a registered multi-bank holding company, and the primary
purpose of each of the five charter banks is to serve as
the acquisition vehicle for TCG to acquire the minority
interests in each of the five existing national banking
associations.
Augusta Bank has operated under national banking
association charter number 1860 since the charter was
granted by this Office on August 10, 1871. As of December 31, 1977, Augusta Bank had total deposits of
$88.7 million.
Columbus Bank was chartered by this Office in 1892
and, as of calendar year-end 1977, held total commercial bank deposits aggregating $77.8 million.
Chartered by this Office on September 30, 1912,
Macon Bank's total deposits at year-end 1977, were
$143.3 million.
National banking association charter number 2368

was granted to Rome Bank on August 22, 1877, and
the bank's deposits totaled approximately $69.7 million, as of December 31, 1977.
Savannah Bank's charter (number 13472) was
granted by this Office on June 7, 1930, and the bank's
deposits had grown to slightly less than $103 million,
at year-end 1977.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that approval of each of the
five subject proposals would sanction a part of a plan
through which Augusta Bank, Columbus Bank, Macon
Bank, Rome Bank and Savannah Bank will become
wholly-owned banking subsidiaries of TCG. The applications are therefore deemed to be in the public interest, and should be, and hereby are approved subject to the following condition: that a simple majority of
the minority shares in each of the five existing banks,
not currently owned or controlled by TCG, be voted in
favor of the proposed merger(s) involving their respective bank(s).
July 18, 1978
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed mergers are part of a plan through
which First National Bank of Rome; First National Bank
& Trust Company in Macon; First National Bank & Trust
Company of Augusta; Trust Company of Georgia Bank
of Savannah, N.A.; and National Bank and Trust Company of Columbus, Ga., would become subsidiaries of
Trust Company of Georgia, a bank holding company.
The instant mergers, however, would merely combine
existing banks with non-operating institutions; as such,
and without regard to the acquisitions of the surviving
banks by Trust Company of Georgia, they would have
no effect on competition.

EASTERN SHORE NATIONAL BANK,
Daphne, Ala., and FBG National Bank of Daphne, Daphne, Ala.
Banking offices
Names of banks and type of transaction

Total
assets*

Eastern Shore National Bank, Daphne, Ala. (16285), with
and FBG National Bank of Daphne, Daphne, Ala. (16285), which had
merged Sept. 11,1978, under charter of the latter bank (16285) and title "Eastern Shore National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to the statutory requirements of 12 USC
1828(c), the Bank Merger Act, an application has been
filed with the Office of the Comptroller of the Currency
that requires prior written consent to the proposed
merger of Eastern Shore National Bank, Daphne, Ala.
("ESNB"), the merging bank, into FBG National Bank
of Daphne, (organizing), Daphne, Ala. ("FBG"), the
charter bank, under the charter of FBG National Bank
*Asset figures are as of call dates immediately before and after
transaction.

118


In
' To be
operation operated

$9,242,000
60,000
8,664,000

of Daphne and with the title of Eastern Shore National
Bank. The subject application rests upon an agreement executed between the proponent banks, incorporated herein by reference, the same as if fully set
forth.
ESNB has operated as a national banking association since February 26, 1974, when this Office granted
charter number 16285 to the bank. As of March 31,
1978, ESNB held total commercial bank deposits of
approximately $5.8 million.
FBG has no operating history, and the charter
bank's application for corporate existence was sponsored by First Bancgroup-Alabama, Inc., Mobile, Ala.,

a registered multi-bank holding company that controls
five banking subsidiaries with total deposits of approximately $602.4 million. The primary function of FBG is
to serve as the vehicle for the acquisition of the successor by merger to Eastern Shore National Bank by
First Bancgroup-Alabama.
The instant merger would have the effect of merely
combining a non-operating entity with an existing commercial bank; and, as such, would result in no adverse
impact upon any relevant area of consideration.
Accordingly, this application is deemed to be in the
public interest, and should be, and hereby is, approved.

August 9, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Eastern Shore National Bank would become a subsidiary of First Bancgroup-Alabama, 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 Bancgroup-Alabama, Inc.,
it would have no effect on competition.

THE FIRST NATIONAL BANK OF DALTON,
Dalton, Ga., and First National Interim Bank of Dalton, Dalton, Ga.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank of Dalton, Dalton, Ga. (3907), with
and First National Interim Bank of Dalton, Dalton, Ga. (3907), which had
merged Sept. 14,1978, under the charter and title of the latter bank (3907). The merged bank at date
of merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), the Bank Merger Act, an
application has been filed with the Office of the Comptroller of the Currency that requires prior written consent to the proposed merger of The First National Bank
of Dalton, Dalton, Ga. ("FNB"), the merging bank, into
First National Interim Bank of Dalton (organizing), Dalton, Ga. ("Charter Bank"), under the charter of First
National Interim Bank of Dalton and with the title of The
First National Bank of Dalton. The subject application
is based upon an agreement executed between the
proponent banks, incorporated herein by reference,
the same as if fully set forth.
On June 21, 1978, this Office granted preliminary
approval to organize a new national bank to be known
as "First National Interim Bank of Dalton." To date,
Charter Bank has no operating history, and its primary
function is to serve as the vehicle for the acquisition of
the successor by merger to The First National Bank of
Dalton by First National Holding Corp., Atlanta, Ga.
("FNHC"), a registered multi-bank holding company.
FNB has operated under national banking associa-




In
To be
operation operated

$109,013,000
250,000
110,290,000

tion charter number 3907 since this Office granted the
charter on July 10, 1888. As of March 31, 1978, merging bank had total commercial bank deposits aggregating slightly less than $85 million.
Inasmuch as approval of this proposal would merely
have the effect of combining a non-operating entity
with an existing commercial bank, it is the conclusion
of this Office that approval of the application is not
adverse to the public interest. The subject application
is therefore deemed to be in the public interest, and
should be, and hereby is, approved.
August 14, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
First National Bank of Dalton would become a subsidiary of First National Holding 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 First National Holding Corp., it
would have no effect on competition.

119

THE FIRST NATIONAL BANK IN MINERAL WELLS,
Mineral Wells, Tex., and Hubbard National Bank, Mineral Wells, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

The First National Bank in Mineral Wells, Mineral Wells, Tex. (12669), with
and Hubbard National Bank, Mineral Wells, Tex. (12669), which had
merged Oct. 2,1978, under the charter of the latter bank (12669) and title "The First National Bank in
Mineral Wells". The merged bank at date of merger had

COMPTROLLER'S DECISION
In compliance with applicable requirements of the
Bank Merger Act (12 USC 1828(c)), an application has
been filed with the Office of the Comptroller of the
Currency that requests prior written permission to
effectuate the proposed merger of The First National
Bank in Mineral Wells, Mineral Wells, Tex. ("Merging
Bank"), into Hubbard National Bank (organizing), Mineral Wells, Tex. ("Charter Bank"), under the charter of
Hubbard National Bank and with the title of The First
National Bank in Mineral Wells. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
By action dated March 10, 1978, this Office granted
preliminary approval to organize Charter Bank; to date,
the bank has no operating history.
Merging Bank has operated under national banking
association charter number 12669 since April 4, 1925.
As of December 31, 1977, Merging Bank had total
commercial bank deposits amounting to approximately
$37.5 million.
The new bank application for the establishment of
Charter Bank was sponsored by principals of Republic
of Texas Corporation, Dallas, Tex. ("RTC"), a registered multi-bank holding company that controls 14

$46,244,000
120,000

In
To be
operation operated

1
0

47,108,000

banks with total deposits of $3.4 billion. The primary
purpose of Charter Bank is to serve as the acquisition
vehicle for RTC to acquire all of the outstanding voting
shares of the successor by merger to The First National Bank in Mineral Wells.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that approval of this application would merely
have the effect of combining a non-operating institution with an existing commercial bank and, as such,
would produce no adverse effect upon any relevant
area of consideration. The application is therefore
deemed to be in the public interest, and should be,
and hereby is, approved.
August 25, 1978
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
First National Bank in Mineral Wells would become a
subsidiary of Republic of Texas 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 Republic of Texas Corporation, it would have no effect on competition.

THE HERGET NATIONAL BANK OF PEKIN,
Pekin, III., and HNB Bank, N.A., Pekin, III.
Banking offices
Names of banks and type of transaction

Total
assets

The Herget National Bank of Pekin, Pekin, III. (9788), with
and HNB Bank, N.A., Pekin, III. (9788), which had
merged Nov. 14,1978, under the charter of the latter bank (9788) and title "The Herget National Bank
of Pekin." The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to 12 USC 1828(c), an application has been
filed with the Office of the Comptroller of the Currency
requesting prior permission to merge The Herget National Bank of Pekin, Pekin, III. ("Merging Bank"), into
HNB Bank, N.A. (organizing), Pekin, III. ("Charter
Bank"), under the charter of HNB Bank, N.A., and with
the title of The Herget National Bank of Pekin. The
subject application rests upon an agreement executed
between the proponent banks, incorporated herein by
reference, the same as if fully set forth.

120


$98,515,000
240,000

In
To be
operation operated

2
0

98,515,000

Merging Bank has operated under national banking
association charter number 9788 since the charter was
granted by this Office on June 16, 1910. As of June
30, 1978, Merging Bank had total commercial bank
deposits of $88.3 million.
This Office granted preliminary approval for the
organization of Charter Bank on October 22, 1974 and,
to date, Charter Bank has had no operating history.
The primary function of Charter Bank is to act as the
acquisition vehicle for Herget Financial Corp., Pekin,
III. ("Herget Financial"), to acquire 100 percent (less

directors' qualifying shares) of the successor by merger to The Herget National Bank of Pekin. On September 22, 1978, the Board of Governors of the Federal
Reserve System, pursuant to the Bank Holding Company Act of 1956, approved the application by Herget
Financial to become a one-bank holding company
through the aforementioned acquisition.
The subject merger would merely have the effect of
combining an existing commercial bank with a nonoperating entity; as such, would produce no adverse
effect upon any relevant area of consideration.
Accordingly, applying the statutory criteria, the application is, therefore, deemed to be not adverse to the

public interest, and should be, and hereby is,
approved.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Herget National Bank of Pekin would become a subsidiary of Herget 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 Herget Financial Corporation, it
would have no effect on competition.

THE BROOKS FIELD NATIONAL BANK OF SAN ANTONIO,
San Antonio, Tex., and Brooks Field Bank of Commerce National Association, San Antonio, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

The Brooks Field National Bank of San Antonio, San Antonio, Tex. (14847), with
and Brooks Field Bank of Commerce National Association, San Antonio, Tex. (14847), which had
merged Nov. 27,1978, under the charter of the latter bank (14847) and title "Brooks Field National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency, pursuant
to the statutory requirements of 12 USC 1828(c) (the
Bank Merger Act), has accepted for filing an application that seeks and requires the prior written consent of
the Office to the proposed merger of The Brooks Field
National Bank of San Antonio, San Antonio, Tex.
("Merging Bank"), into Brooks Field Bank of Commerce National Association (organizing), San Antonio,
Tex. ("Charter Bank"), under the charter of Brooks
Field Bank of Commerce National Association, and
with the title of Brooks Field National Bank. The subject
application rests upon an agreement executed between the proponent banks, incorporated herein by
reference, the same as if fully set forth.
Merging Bank has operated as a national banking
association since November 28, 1958, when this Office
granted charter number 14847 to the bank. As of
March 31, 1978, Charter Bank's total deposits were
approximately $56.5 million.
On May 10, 1978, preliminary approval to organize
Charter Bank was granted by this Office; to date, the
new bank has no operating history. The primary purpose for the organization of Charter Bank is to provide
the vehicle for the acquisition of the succesor by merger to the Brooks Field National Bank of San Antonio by




$70,083,000
240,000
70,323,000

In
To be
operation operated
1
0
1

National Bancshares Corporation of Texas, San Antonio, a registered multi-bank holding company that as
of December 31, 1977, controlled four subsidiary
banks with total consolidated deposits of approximately $622.7 million. The effect of the instant proposal
would be to merely combine a non-operating entity
with an existing commercial bank; and as such, would
produce no adverse effect upon any relevant area of
consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of this Office that the application is not
adverse to the public interest, and should be, and
hereby is, approved.
October 20, 1978.
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Brooks Field National Bank of San Antonio 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.

121

GUARANTY NATIONAL BANK,
Houston, Tex., and Guaranty Bank of Commerce National Association, Houston, Tex.
Banking offices

Names of banks and type of transaction

Total
assets

Guaranty National Bank, Houston, Tex. (15834), with
and Guaranty Bank of Commerce National Association, Houston, Tex. (15834), which had
merged Nov. 30,1978, under the charter of latter bank (15834) and title "Guaranty National Bank.'
The merged bank at date of merger had

COMPTROLLER'S DECISION
The Office of the Comptroller of the Currency is in
receipt of an application, pursuant to the Bank Merger
Act (12 USC 1828(c)), that requests prior permission
to effectuate a merger of Guaranty National Bank,
Houston, Tex. ("Merging Bank"), into Guaranty Bank of
Commerce National Association (organizing), Houston,
Tex. ("Charter Bank"), under the charter of Guaranty
Bank of Commerce National Association, and with the
title of Guaranty National Bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
Merging Bank has operated under national banking
association charter number 15834 since the charter
was granted by this Office on October 9, 1970. As of
June 30, 1978, Merging Bank had total commercial
bank deposits of $41.2 million.
Charter Bank was granted preliminary approval to
organize by this Office on August 15, 1978; to date,
the new bank has no operating history. The primary
function of Charter Bank is to act as the acquisition
vehicle for National Bancshares Corporation of Texas,
San Antonio, Tex., a registered multi-bank holding
company, to acquire 100 percent (less directors' qualifying shares) of the successor by merger to Guaranty

$45,635,000
240,000

In
To be
operation operated
1
0
1

45,635,000

National Bank. On October 6, 1978, The Board of Governors of the Federal Reserve System, pursuant to the
Bank Holding Company Act of 1956, approved the
aforementioned acquisition by National Bancshares
Corporation of Texas.
The subject merger would merely have the effect of
combining an existing commercial bank with a nonoperating entity; and as such, would produce no
adverse effect upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is the
conclusion of the Office of the Comptroller of the Currency that this application is not adverse to the public
interest, and should be, and hereby is, approved.
October 20, 1978
SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Guaranty National Bank 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.

COLONIAL NATIONAL BANK,
Unincorporated Area of Harris County, Tex., and New Colonial National Bank, Unincorporated Area of Harris
County, Tex.
Banking offices
Names of banks and type of transaction

Total
assets

Colonial National Bank, Unincorporated Area of Harris County, Tex. (16493), with
and New Colonial National Bank, Unincorporated Area of Harris County, Tex. (16493) , which had
merged Dec. 14,1978, under the charter of the latter bank (16493) and title "Colonial National Bank."
The merged bank at date of merger had

COMPTROLLER'S DECISION
Pursuant to the statutory requirements of the Bank
Merger Act (12 USC 1828(c)), an application has been
filed with the Office of the Comptroller of the Currency
that requires prior written permission to effect the
proposed merger of Colonial National Bank, unincorporated area of Harris County, Tex. ("Merging Bank"),
into New Colonial National Bank, unincorporated area
of Harris County, Tex. ("Charter Bank"), under the

122


$23,273,000
240,000
22,654,000

In
To be
operation operated
1
0
1

charter of New Colonial National Bank and with the title
of Colonial National Bank. The subject application
rests upon an agreement executed between the proponent banks, incorporated herein by reference, the
same as if fully set forth.
By action dated June 19, 1978, this Office granted
preliminary approval for the organization of Charter
Bank; to date, the new bank has no operating history.
Merging Bank has operated under national banking

association charter number 16493 since the charter
was granted by this Office on September 12, 1975. As
of June 30, 1978, Merging Bank had total commercial
bank deposits of approximately $18.3 million.
The primary purpose of this merger is to facilitate the
acquisition of all of the voting shares (except for directors' qualifying shares) of the successor by merger to
Colonial National Bank by Republic National Baneshares, Inc., Houston, Tex., a newly approved bank
holding company. The end result of this merger would
be to combine a non-operating entity with an existing
commercial bank and, as such, would have no
adverse impact upon any relevant area of consideration.
Accordingly, applying the statutory criteria, it is

deemed that the application is not adverse to the public interest, and should be, and hereby is, approved.
October 25, 1978.

SUMMARY OF REPORT BY ATTORNEY GENERAL
The proposed merger is part of a plan through which
Colonial National Bank would become a subsidiary of
Republic 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 Republic National Bancshares,
Inc., it would have no effect on competition.

///. Mergers approved but abandoned.
THE SECOND NATIONAL BANK AND TRUST COMPANY OF LEXINGTON,
Lexington, Ky., and Bank of Lexington, Lexington, Ky.
Names of banks and type of transaction
Bank of Lexington, Lexington, Ky., and The Second National Bank and Trust Company of Lexington, Lexington, Ky. (2901), applied for
permission to merge Aug. 18, 1976, under charter of the latter bank (2901) and title "Second National/Bank of Lexington." The application was
approved Apr. 27, 1977. The pending merger was challenged by Justice Department May 26, 1977, and was abandoned February 14, 1978.
For text of Comptroller's Decision and Summary of Report by Attorney General, see 1977 Report, pp. 136-139.




123




APPENDIX B

Statistical Tables

Statistical Tables
Table
No.
Title
Page
B-1
Comptrollers of the Currency, 1863 to
the present
127
B-2
Deputy Comptrollers of the Currency . . .
128
B-3
Regional administrators of national
banks
128
B-4
Changes in the structure of the national
banking system, by states, 1978
129
B-5
Applications for national bank charters,
approved and rejected, calendar 1978..
130
B-6
Applications for national bank charters
pursuant to corporate reorganizations,
by states, calendar 1978
131
B-7
Newly organized national banks, by
states, calendar 1978
131
B-8
Mergers consummated pursuant to corporate reorganizations, by states, calendar 1978
132
B-9
State-chartered banks converted to national banks, by states, calendar 1978 ..
134
B-10 National bank charters issued pursuant
to corporate reorganizations, by states,
calendar 1978
135
B-11 National banks reported in voluntary liquidation, by states, calendar 1978
136
B-12 National banks merged or consolidated
with state banks, calendar 1978
136
B-13 National banks converted into state
banks, by states, calendar 1978
138
B-14 Purchases of state banks by national
banks, by states, calendar 1978
140
B-15 Consolidations of national banks, or national and state banks, by states, calendar1978
140
B-16 Mergers of national banks, or national
and state banks, by states, calendar
1978
140
B-17 Mergers resulting in national banks, by
assets of acquiring and acquired banks,
1960-1978
143

126



Table
Title
Page
No.
B-18 Total assets, liabilities and equity capital
of domestic offices and subsidiaries of
national banks, United States and other
areas, June 30,1978
144
B-19 Total assets, liabilities and equity capital
of domestic offices and subsidiaries of
national banks, December 31,1978
152
B-20 Domestic office loans of national banks,
by states, December 31,1978
160
B-21 Outstanding balances, credit cards and
related plans of national banks, December31,1978
161
B-22 Income and expenses of foreign and
domestic offices and subsidiaries of national banks, by states, year ended December31,1978
162
B-23 National banks engaged in lease financing, December 31, 1978
178
B-24 Assets and equity capital, net income
and dividends of national banks, 1967-

1978
B-25
B-26

Loan losses and recoveries of national
banks, 1970-1978
Assets and liabilities of national banks,
date of last report of condition, 1972-

1978
B-27
B-28
B-29
B-30

Consolidated assets and liabilities of national banks with foreign operations, December 31,1978
Foreign branches of national banks, by
region and country, December 31,1978
Total foreign branch assets of national
banks, year-end 1953-1978
Foreign branch assets and liabilities of
national banks, December 31,1978 . . . .

179
180

181
182
183
183
184

Table B - 1
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

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 0. .
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

21
22
23
24 Heimann, John G




Date of
appointment

May
Mar.
Feb.
Apr.
May
Apr.
May
Aug.
Apr.
Jan.
Oct.
Apr.
Feb.
Mar.
May
Dec.
Nov.
May
Oct.
Apr.
Nov.
Nov.
July
July

9, 1863
21, 1865
1,1867
25, 1872
12, 1884
20, 1886
1, 1889
2, 1892
26, 1893
1, 1898
1, 1901
27, 1908
2, 1914
17, 1921
1, 1923
20, 1924
21, 1928
11, 1933
24, 1938
16, 1953
16, 1961
16, 1966
5, 1973
21, 1977

Date of
resignation

Mar.
July
Apr.
Apr.
Mar.
Apr.
June
Apr.
Dec.
Sept.
Mar.
Apr.
Mar.
Apr.
Dec.
Nov.
Sept.
Apr.
Feb.
Nov.
Nov.
Mar.
July

8, 1865
24, 1866
3, 1872
30, 1884
1, 1886
30, 1889
30, 1892
25, 1893
31, 1897
30, 1901
28, 1908
27, 1913
2,
30,
17,
20,
20,
16,
15,
15,
15,
23,
31,

1921
1923
1924
1928
1932
1938
1953
1961
1966
1973
1976

State
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.
New York.

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
47
48
49
50
51
52
53
54
55
56
57
58

Dates of tenure
May
Aug.
Mar.
Aug.
Jan.
Jan.
Aug.
Apr.
Mar.
Sept.
June
July
May
July
Jan.
July
July
Dec.
Jan.
Feb.
Jan.
Jan.
Oct.
May
July
Sept.
Oct.
Jan.
Sept.
Mar.
Feb.
Sept.
May
Apr.
Aug.
Sept.
Dec.
Jan.
July
Sept.
Sept.
July
July
Feb.
July
July
Feb.
Aug.
Aug.
Aug.
Aug.
Aug.
Aug.
Mar.
Mar.
Mar.
Nov.
Nov.

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
Oppegard.G. J
Upham, 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, HollisS
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
Ream, Joseph M
Bloom, Robert
Chotard, Richard D
Hall, Charles B
Jones, David H
Murphy C. Westbrook ..
Selby, H.Joe
Homan, PaulM
Keefe, James T
Muckenfuss, Cantwell F.,
Wood, Billy C
Longbrake, William A. ..

9, 1963 Aug.
1, 1865 Jan.
12, 1867 Apr.
8, 1872 Jan.
5, 1886 Jan.
27, 1887 May
11, 1890 Mar.
7, 1893 Mar.
12, 1896 Aug.
1, 1898 June
29, 1899 Mar.
1, 1908 Feb.
21, 1923 Dec.
1, 1923 June
6, 1925 Nov.
1, 1927 Feb.
6, 1927 Oct.
1, 1928 Jan.
24, 1933 Jan.
24, 1936 Jan.
16, 1938 Sept.
16, 1938 Sept.
1, 1938 Dec.
1, 1939 Aug.
7, 1941 Mar.
1, 1941 Sept.
1, 1944 Feb.
1, 1949 Aug.
1, 1950 May
1, 1951 Apr.
18, 1952 Dec.
15, 1959 Aug.
16, 1960 Aug.
2, 1962 Nov.
4, 1962 Oct.
3, 1962 July
23, 1962
1, 1963 Mar.
13, 1964 June
1, 1964 Sept.
1,1964 June
19, 1965 Oct.
1, 1966
21, 1967 Dec.
5, 1973 Mar.
5, 1973 Sept.
2, 1975 June
31, 1975 Feb.
31, 1975 Nov.
31, 1975
31, 1975 Sept.
31, 1975 Dec.
31, 1975
27, 1978
27, 1978
27, 1978
7, 1978
8, 1978

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
18, 1975
3, 1978
30, 1966
26, 1975
1, 1967
26, 1974
31,'1974
27, 1978
8, 1978
30, 1978
28, 1978
25, 1977

New York.
Ohio.
Minnesota.
New York.
New York.
Virginia.
Indiana.
Kentucky.
South Carolina.
New York.
District of Columbia
Indiana.
Illinois.
Illinois.
Virginia.
Maryland.
Indiana.
Washington.
Georgia.
Georgia.
Texas.
California.
Iowa.
Iowa.
Iowa.
Nebraska.
Nebraska.

Texas.
New York.
Virginia.
Colorado.
Ohio.
Missouri.
Texas.
Connecticut.
Ohio.
Iowa.
Virginia.
Iowa.
Massachusetts.
Wisconsin.
Louisiana.
Ohio.
Mississippi.
Georgia.
Kansas.
Pennsylvania.
New York.
Missouri.
Pennsylvania.

20, 1976 Texas.
30, 1977 Maryland.
Texas.

Nebraska.
Massachusetts.
Alabama.
Texas.
Wisconsin.

Table B-3
Regional administrators of national banks
Region

Name

1 Ralph W. Gridley
2
3
4
5
6
7
8
9
10
11
12
13
14

JohnR. Burt
R. Coleman Egertson
Larry T. Gerzema
Robert J.Herrmann
John G. Hensel
Billy C. Wood
Clifton A. Poole
Kenneth W. Leaf
John W. Rogers
Michael Doman
Kent D. Glover
M. B. Adams
Victor E. DelTredici


128


Headquarters
Boston, Mass
New York, N.Y
Philadelphia Pa
Cleveland, Ohio
Richmond, Va
Atlanta, Ga
Chicago, III
Memphis, Tenn
Minneapolis, Minn
Kansas City, Mo
Dallas, Tex
Denver, Colo
Portland, Oreg
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.

Table B-4
Changes in the structure of the national banking system, by states, 1978
Consolidated and merged
under 12 USC 215
In
operation
Dec. 31,
1977
All national banks ...

Consolidated

4,655

40

97
6
3
72

2
0
0
0
0
4
0
0
1
5

0
0
0
0
0
0
0
0
0
0

0
0
0
1
1
0
0
0
1

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

15
263

Georgia
Hawaii
Idaho
Illinois
Indiana

64
2
6
423
121

Iowa

Organized
and opened
for business
during 1978

58
133

21
5

99

Kansas
Kentucky
Louisiana
Maine

160
82
53
17

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

36
72
123
204

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

100
40
127
28
43
218
193
7
233
5

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

19
32
73
604
12
14
103
21
106
128
46

36
113
56
117
4
41

1

Insolvencies

1
0
0
0
0
1
0
0
0

0
0
0
12
0
0
0
0
1
1
0

Liquidated

Merged

Merged or
Converted to consolidated
state banks
with state
banks
27

4,564

11

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
3
2
0
0
0
0
7

0
0
0
0
1
0
2
0
0
14

99
6
3
69
53
137
19
5
16
236

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
0
0
0
0
0
0
0

0
0
0
4
1

0
9
3
0
0

0
0
0
0
0
0
0
0
0
0

64
2
6
419
121
99
151
79
54
17

0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
0
0
0
2

0
0
0
0
0
0
0
0
0
0

0
0
1
0
0
0
0
0
0
0

0
0
1
1
0
13
0
0
0
0

1
0
0
0
0
0
0
0
0
0

34
73
125
205
37
101
56
117
4

0
0
0
0
0
0
0
0
1
0

0
0
2
1
0
0
0
0
1
0

2
0
0
0
0
0
0
0
0
0

0
0
0
0
0
1
0
0
2
0

2
1
0
0
0
0
3
0
1
0

0
0
1
0
0
0
0
1
2
0

96
40
124
27
43
217
191
6
226
5

0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
1
0
6
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
0

0
0

0
0
0
0
0
1
4
0
0
0
0

18
32
72
609
10
13
88
20
106
129
46

0
0
0
0
2
0
0
0
0

1
7
1
0
5
1
1
0
0

0
0
0
0
0
NOTE: This table reflects information for operating banks, and may not agree with other tables* because of effective dates.
Does not include one non-national bank in the District of Columbia supervised by the Comptroller of the Currency.
For summary of changes 1863-1977 see Table B-4 in Annual Report, 1977.
Puerto Rico




In
operation
Dec. 31,
1978

68

27

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

12 USC 214

39

0

129

Table B-5
Applications for national bank charters*, approved and rejected, by states, calendar 1978
ALABAMA

Town-Country National Bank, Camden
Columbiana
Central Bank of Dothan, National Association,
Dothan
Fort Payne
Mobile
First Alabama Bank, N.A., Notasulga

Approved

Rejected

Mar. 5
Sept 27
Mar . 6
Apr . 4
Feb. 20
Jan.

28

ARKANSAS

Oct 20

Booneville
CALIFORNIA

Santa Fe National Bank, Norwalk and Santa Fe
Aug. 31
Springs
May 15
Meridian National Bank, Pleasant Hill
Dec. 15
Sonoma
Fph 7
Westwood National Bank, Westwood
COLORADO

Chapel Hills National Bank, El Paso County
First Bank of Villa Italia, National Association,
Lakewood

Ont 18
Dec. 22

FLORIDA

Charlotte County National Bank, Unincorporated
Area of Charlotte County
The Gold Coast National Bank, Unincorporated
Area of Dade County

Sept 6
Foh 20
Aug 5

KENTUCKY

First National Bank of Versailles, Versailles . . .

Aug.

25

LOUISIANA

Aug. 15
Feb 7

Farmerville
Leesville

Rejected

TEXAS

Corpus Christi
Forestwood National Bank of Dallas, Dallas
Baybrook National Bank, Unincorporated Area of
Harris County
Citizens' National Bank, Unincorporated Area of
Harris County
Continental National Bank, Unincorporated Area
of Harris County
First City Bank - Westheimer, N.A., Unincorporated Area of Harris County
Westyiew Commerce Bank National Association,
Unincorporated Area of Harris County
South Belt Commerce Bank National Association,
Houston
Bayport National Bank, La Porte
League City National Bank, League City
League City
Texas National Bank of Midland, Midland
The American National Bank of Mount Pleasant,
Mount Pleasant
Salado National Bank, Unincorporated City of
Salado
First National Bank of Sulphur Springs, Sulphur
Springs

Dec R

June 21

Mar 8
Jan.

20

Sept. 18
Auq 5
Jan.

25

Feb. 27
Dec. 22
June 22
June 22
Mar 23
Dec. 22
Auq.

14

Dec. 22

Zions First National Bank of Cedar City, Cedar
City
June 30
Zions First National Bank of Orem, Orem
Dec . 6
First Security Bank of Richfield, N.A., Richfield ..
Oct. 17
First Security Bank of St. George, N.A., St.
George
Oct 17
WASHINGTON

National Bank of Bremerton, Bremerton
Friday Harbor

MASSACHUSETTS

BayBank Boston, N.A., Boston

Approved

Sept. 18

UTAH

INDIANA

National Bank of Clarksville, Clarksville . . .

SOUTH DAKOTA

Tri-State National Bank, Belle F o u r c h e ....

May 10

Dec. 22
Mar. 2

WEST VIRGINIA
MICHIGAN

Michigan National Bank - Ann Arbor, Ann Arbor.
Northern National Bank, Grayling
Marcellus
The Detroit Bank - Novi, National Association,
Novi

American National Bank of Glen Daniel, Glen
Daniel

Nov. 24
Dec. 13
Aua

s

Mar 23

NEBRASKA

South Sioux City

Feb 27

OKLAHOMA

Citizens National Bank of Ardmore, Ardmore....
Ardmore
Midwest National Bank, Midwest City

Tri City National Bank of Brown Deer, Brown Deer
Community National Bank, Mukwonago
Northern Security National Bank of Rhinelander,
Pelican
Westby

130

Jan. 31
Oct. 19
Dec. 22
Oct. 19

WYOMING

Jan.

18
Jan.

18

Wyoming National Bank of East Casper, Casper

Dec. 22

* Does not include applications for conversion or pursuant to corporate reorganization.




Fph 7

WISCONSIN

Mar. 23

Table B-6
Applications for national bank charters pursuant to corporate reorganization, by states, calendar 1978
Rejected

OHIO

ALABAMA

Approved

FBG National Bank of Daphne, Daphne . ..

Feb. 23

The F.B.G. National Bank of Lancaster, Lancaster
H.C.B. National Bank of Norwalk, Norwalk

May 15
May 15
June 20
May 15
May 15
May 15

Approved

Rejected

TEXAS

GEORGIA

National Interim Bank of Augusta, Augusta
National Interim Bank of Columbus, Columbus.
First National Interim Bank of Dalton, Dalton . . .
National Interim Bank of Macon, Macon
National Interim Bank of Rome, Rome
National Interim Bank of Savannah, Savannah .

New National Bank of Commerce of Dallas, Dallas
Oct. 20
Citizens Bank, National Association, Denison . . .
Nov. 8
New Colonial National Bank, Unincorporated
Area of Harris County
June 19
Guaranty Bank of Commerce National Association, Houston
Aug. 14
Gulf Bank, National Association, Houston
Oct. 19
5600 Lancaster National Bank, Fort Worth
Aug. 3
New Lufkin National Bank, Lufkin
Sept. 5
Hubbard National Bank, Mineral Wells
Mar. 8
1409 Avenue K National Bank, Piano
Sept. 26
Brooks Field Bank of Commerce National Association, San Antonio
May 10
North St. Mary National Bank, San Antonio
Mar. 24
First Waco Bank, National Association, Waco ...
May 15

ILLINOIS

FNEP National Bank, Evergreen Park
City Bank, National Association, Rockford

Jan. 11
Oct. 19

INDIANA

Indiana Interim National Bank, Gary . . .

Oct. 20

MASSACHUSETTS

N e w H a r b o r National Bank, Boston ....

Aug. 7

MICHIGAN

CFC National Bank, Marshall
NLB National Bank of Muskegon, Muskegon...

Aug. 5
Dec. 12

Mar. 17
June 22

VIRGINIA

Greensville - Emporia National Bank, Emporia ..

Feb. 23

Table B-7
Newly organized national banks, by states, calendar 1978
Charter
No.

Title and location of bank
Total, United States: 39 banks

Total capital
accounts
$66,500,000

ALABAMA

16708 Town-Country National Bank, Camden
16699 First Alabama Bank, N.A., Notasulga

750,000
500,000

Total: 2 banks

1,250,000

COLORADO

16747 United Bank of Arvada National Association, Arvada
16701 Citizens National Bank, Colorado Springs
16723 The Women's Bank, N.A., Denver
16704 FirstBank of South Longmont, National Association

1,000,000
1,500,000
2,000,000
1,000,000

Total: 4 banks

5,500,000

DISTRICT OF COLUMBIA

16720 The Women's National Bank, Washington

2,000,000

FLORIDA

16698
16749
16722
16759

Royal Trust Bank of South Dade, N.A., Unincorporated Area of Dade
First National Bank of West Delray, Unincorporated Area West of Delray Beach
Florida Coast Bank of South Palm Beach County, National Association, Unincorporated Area of Southwest Palm
Beach County
First National Bank of Jefferson County, Monticello

2,000,000
1,200,000
1,000,000
1,000,000
5,200,000

Total: 4 banks
ILLINOIS

16715

F i r s t N a t i o n a l B a n k o f W h e e l i n g , W h e e l i n g ...

1,000,000

INDIANA

16760

2,164

Industrial National Bank of East Chicago, East Chicago
LOUISIANA

16732

National Bank of Commerce of DeRidder, DeRidder

•.

1,000,000

MASSACHUSETTS

16757

B a y B a n k B o s t o n , N.A., B o s t o n ....




2,500,000

131

Table B-7—Continued
Newly organized national banks, by states, calendar 1978
Charter
No.

Total capital
accounts

Title and location of bank
MICHIGAN

16710 Old Kent Bank of Norton Shores, National Association, Norton Shores ..
16714 Michigan National Bank - Port Huron, Port Huron
16707 Michigan National Bank - Sterling, Sterling Heights
16712 The Detroit Bank - Sterling, N.A., Sterling Heights

$ 1,250,000
14,000,000
2,000,000
3,000,000
20,250,000

Total: 4 banks
MINNESOTA

2,000,000

16744 Granite City National Bank of St. Cloud, St. Cloud
MISSISSIPPI

16726 Citizens National Bank of Columbus, Columbus

1,250,000

MISSOURI

16750

Commerce Bank of Clay County, National Association, Kansas City .

1,000,000

NEW MEXICO

16741

Southwest National Bank, Hobbs

1,500,000

OKLAHOMA

16743 Citizens National Bank of Ardmore, Ardmore

1,500,000

TEXAS

16703
16721
16725
16733
16754
16762
16716
16724
16718
16752
16756
16740
16731

First National Bank of Dimmit County, Carrizo Springs
Carrollton First National Bank, Carrollton
American National Bank of Dallas, Dallas
Baybrook National Bank, Unincorporated Area of Harris County . . .
Citizens National Bank, Unincorporated Area of Harris County
First City Bank - West, N.A., El Paso
Overton Park National Bank, Fort Worth
National Bank of Commerce of Kerrville, Kerrville
Lake Worth National Bank, Lake Worth
Southwest Lubbock National Bank, Lubbock
Ingram Park Bank of Commerce National Association, San Antonio.
South Park National Bank, San Antonio
American National Bank, Texarkana

1,250,000
1,500,000
1,500,000
1,500,000
1,200,000
1,250,000
1,600,000
1,500,000
1,250,000
2,000,000
1,250,000
1,250,000
1,500,000

Total: 13 banks ..

18,550,000

WEST VIRGINIA

16761

Stonewall National Bank, Weston .

1,000,000

WISCONSIN

16748 Tri City National Bank of Brown Deer, Brown Deer.

1,000,000

Table B-8
Mergers* consummated pursuant to corporate reorganizations, by states, calendar 1978
(Dollar amounts in thousands)
Operating bank
New bank
Resulting bank

Effective
date of
merger

Total
capital
accounts

Total
assets

ALABAMA

Sept. 11

Eastern Shore National Bank, Daphne
FBG National Bank of Daphne, Daphne
Charter issued September 5, 1978
Eastern Shore National Bank, Daphne

....

$

781

$

8,664

GEORGIA

Aug. 17

132

The First National Bank & Trust Company of Augusta, Augusta
National Interim Bank of Augusta, Augusta
Charter issued August 11, 1978
The First National Bank & Trust Company of Augusta, Augusta
The National Bank and Trust Company of Columbus, Ga., Columbus
National Interim Bank of Columbus, Columbus
Charter issued August 11, 1978




8,697

100,543

Table B-8—Continued
Mergers* consummated pursuant to corporate reorganizations, by states, calendar 1978
(Dollar amounts in thousands)
Operating bank
New bank
Resulting bank

Effective
date of
merger
Aug. 17

Sept. 14

Aug. 17

Aug. 17

Aug. 17

The National Bank and Trust Company of Columbus, Ga., Columbus
The First National Bank of Dalton, Dalton
First National Interim Bank of Dalton, Dalton
Charter issued September 13, 1978
The First National Bank of Dalton, Dalton
The First National Bank & Trust Company in Macon, Macon
National Interim Bank of Macon, Macon
Charter issued August 11, 1978
The First National Bank & Trust Company in Macon, Macon
The First National Bank of Rome, Rome
National Interim Bank of Rome, Rome
Charter issued August 11, 1978
The First National Bank of Rome, Rome
Trust Company of Georgia Bank of Savannah, N.A., Savannah
National Interim Bank of Savannah, Savannah
Charter issued August 11, 1978
Trust Company of Georgia Bank of Savannah, N.A., Savannah

Total
capital
accounts

Total
assets

$ 9,457

$91,149

12,417

110,290

18,338

171,912

7,729

81,079

9,592

116,113

3,129

36,045

7,541

98,515

2,316

29,596

1,984

20,766

964

10,046

11,541

154,553

1,455

12,840

1,111

15,297

9,464

108,868

1,441

22,654

4,755

45,635

ILLINOIS

May 15

Nov. 14

First National Bank of Maywood, Maywood
Maywood National Bank, Maywood
Charter issued May 12, 1978
First National Bank of Maywood, Maywood
The Herget National Bank of Pekin, Pekin
HNB Bank, N.A., Pekin
Charter issued November 13, 1978
The Herget National Bank of Pekin, Pekin . . . .
MASSACHUSETTS

Feb. 6

Blackstone Valley National Bank, Northbridge
Old Colony Bank of Worcester County, National Association, Northbridge
Charter issued January 31, 1978
Old Colony BankofWorcesterCounty, National Association, Northbridge
MICHIGAN

Jan. 31t

July 31

Jan. 3f

The First National Bank of Cassopolis, Cassopolis
Cassopolis National Bank, Cassopolis
Charter issued January 31, 1978
The First National Bank of Cassopolis, Cassopolis
National Bank of Marshall, Marshall
CFC National Bank, Marshall
Charter issued July 25, 1978
National Bank of Marshall, Marshall
Peoples Bank and Trust, N.A., Trenton
PBT Bank, National Association, Trenton
Charter issued December 28, 1977
Peoples Bank and Trust, N.A., Trenton
NORTH CAROLINA

Apr. 1

Capitol National Bank, Raleigh
New Capitol Bank, National Association, Raleigh
Charter issued March 31, 1978
Capitol National Bank, Raleigh
OHIO

July 15

Feb. 15

Community National Bank, Flushing
Second National Bank, Flushing
Charter issued July 15, 1978
Community National Bank, Flushing
The Central Security National Bank of Lorain County, Lorain
The Central Trust Company of Lorain County, National Association, Lorain
Charter issued February 15, 1978
The Central Security National Bank of Lorain County, Lorain
TEXAS

Dec. 14

Nov. 30

Colonial National Bank, Harris County
New Colonial National Bank, Harris County
Charter issued December 13, 1978
Colonial National Bank, Harris County
Guaranty National Bank, Houston
Guaranty Bank of Commerce National Association, Houston
Charter issued November 28, 1978
Guaranty National Bank, Houston
First National Bank of McAllen, McAllen
McAllen Commerce Bank National Association, McAllen
Charter issued March 23, 1978




133

Table B-8—Continued
Mergers* consummated pursuant to corporate reorganizations, by states, calendar 1978
(Dollar amounts in thousands)
Operating bank
New bank
Resulting bank

Effective
date of
merger
Apr 7

Oct. 2

May 12

Nov. 27

Aug. 1

Apr. 14

Total
capital
accounts

First National Bank of McAllen McAllen.. . .
The First National Bank in Mineral Wells, Mineral Wells
Hubbard National Bank, Mineral Wells
Charter issued September 27, 1978
The First National Bank in Mineral Wells, Mineral Wells
Kelly Field National Bank of San Antonio, San Antonio
American Servicemen's National Bank, San Antonio
Charter issued May 10, 1978
Kelly Field National Bank of San Antonio, San Antonio
The Brooks Field National Bank of San Antonio, San Antonio
Brooks Field Bank of Commerce National Association, San Antonio
Charter issued November 24, 1978
Brooks Field National Bank, San Antonio
Bexar County National Bank of San Antonio, San Antonio
North St. Mary National Bank, San Antonio
Charter issued July 31, 1978
Bexar County National Bank of San Antonio, San Antonio
City National Bank in Wichita Falls, Wichita Falls
City Bank, National Association, Wichita Falls
Charter issued April 11, 1978
City National Bank in Wichita Falls, Wichita Falls . . . .

Total
assets

$ 8,158

$ 124 593

4,487

47,108

5,528

64,817

6,686

70,323

9,954

146,752

14,389

209,725

2,767

33,225

VIRGINIA

July 31

The Citizens National Bank of Emporia, Emporia
Greensville - Emporia National Bank, Emporia
Charter issued July 31, 1978
The Citizens National Bank of Emporia, Emporia

* Includes consolidation involving a simple operating bank,
t Consolidation

Table B-9
State-chartered banks converted to national banks, by states, calendar 1978
Charter
No.

Title and location of bank

Effective
date of
charter

Outstanding
Capital stock

Surplus, undivided profits
and reserves

Total assets

$1,425,000

Total: 3 banks

$7,126,976

$122,572,813

FLORIDA

16728

Ellis First National Bank of Flagler County, Bunnell, conversion of
Ellis Citizens Bank, Bunnell

Aug.

1

300,000

1,316,056

16,801,327

Feb.

24

600,000

2,316,880

34,279,134

Jan.

3

525,000

3,494,040

71,492,352

MINNESOTA

16702

St. Anthony National Bank, St. Anthony Village, conversion of
State Bank of St. Anthony, St. Anthony
WEST VIRGINIA

16696

Wheeling National Bank, Wheeling, conversion of Morris Plan
Bank & Trust Company, Wheeling




Table B-10
National bank charters issued pursuant to corporate reorganizations, by states, calendar 1978
Charter
No.

Title and location of bank

Date of
Issuance

Total: 25 banks
ALABAMA

16285

F B G National B a n k of D a p h n e , D a p h n e ....

Sept.

GEORGIA

1860
4691
3907
10270
2368
13472

National Interim Bank of Augusta, Augusta
National Interim Bank of Columbus, Columbus
First National Interim Bank of Dalton, Dalton
National Interim Bank of Macon, Macon
National Interim Bank of Rome, Rome
National Interim Bank of Savannah, Savannah
Total: 6 banks

Aug.
Aug.
Sept.
Aug.
Aug.
Aug.

11
11
13
11
11
11

May
Nov.

12
13

Jan.

31

July
Jan.

25
31

Mar.

31

July
Feb.

15
15

Dec.
Dec.
Nov.
Mar.
Sept.
May
Nov.
July
Apr.

29
13
28
23
27
10
24
31
11

July

31

ILLINOIS

14470
9788

Maywood National Bank, Maywood
HNB Bank, N. A., Pekin
Total: 2 banks
MASSACHUSETTS

1022

Old Colony Bank of Worcester County, National Association, Northbridge .
MICHIGAN

15877
1812

CFC National Bank, Marshall
Cassopolis National Bank, Village of Cassopolis
Total: 2 banks
NORTH CAROLINA

16100

N e w Capitol Bank, National Association, R a l e i g h . . . .
OHIO

12008
15456

Second National Bank, Flushing
The Central Trust Company of Lorain County, National Association, Lorain.
Total: 2 banks
TEXAS

12696
16493
15834
14635
12669
14794
14847
14283
13665

5600 Lancaster National Bank, Fort Worth
New Colonial National Bank, Unincorporated Area of Harris County
Guaranty Bank of Commerce National Association, Houston
McAllen Commerce Bank National Association, McAllen
Hubbard National Bank, Mineral Wells
American Servicemen's National Bank, San Antonio
Brooks Field Bank of Commerce National Association, San Antonio
North St. Mary National Bank, San Antonio
City Bank, National Association, Wichita Falls
Total: 9 banks
VIRGINIA

12240

Greensville - Emporia National Bank, Emporia




135

Table B-11
National banks reported in voluntary liquidation, by states, calendar 1978
(Dollar amounts in thousands)

Title and location of bank

Date of
liquidation

Total: 8 national banks

Total capital
accounts of
liquidated
bank*

$29,125

ILLINOIS

The Drovers National Bank of Chicago (6535), Chicago, absorbed by Drovers Bank of Chicago, Chicago

Jan.

20

15,337

Mar.

30

1,388

May
Jan.

19
31

1,361
3,626

Aug.

31

648

July
Dec.

14
8

1,985
3,636

Oct.

13

1,144

MICHIGAN

The First National Bank of Lawton (12084), Lawton, absorbed by The American National Bank and Trust Company of
Michigan (13820), Kalamazoo
NEW JERSEY

The Hamilton Bank, National Association (16169), Hamilton Township, absorbed by Bank of Mid-Jersey, Bordentown
Mid-Jersey National Bank (15838), Woodbridge, absorbed by Princeton Bank and Trust Company, Princeton
OHIO

The First National Bank of New Paris (9211), New Paris, absorbed by Eaton National Bank and Trust Co., Eaton
PENNSYLVANIA

The Rices Landing National Bank (7090), Rices Landing, absorbed by Gallatin National Bank (5034), Uniontown
First National Bank of Scottdale(13772), Scottdale, absorbed by Gallatin National Bank (5034), Uniontown
SOUTH CAROLINA

Hilton Head National Bank (16449), Hilton Head, absorbed by The Citizens and Southern National Bank of S.C.
(14425), Charleston
* Includes subordinated notes and debentures, if any.

Table B-12
National banks merged or consolidated with state banks, by states, calendar 1978
(Dollar amounts in thousands)

Title and location of bank

Total capital
accounts of
national
banks*

Effective
date

Total: 25 banks.

$93,015

CALIFORNIA

Commercial and Farmers National Bank (15532), Oxnard, merged into The Chartered Bank of London, San Francisco,
under title "The Chartered Bank of London"
Jan.

23

3,085

Sept.

25

1,250

Dec.

11

1,853

Oct.

9

2,617

April

1

4,965

Oct.

9

8,863

Sept.

1

1,142

Dec.

31

6,386

May

1

2,002

Jan.

3

822

CONNECTICUT

The Connecticut Bank and Trust Company, N.A. (15294), Norfolk, merged into The Connecticut Bank and Trust
Company, Hartford, under title "The Connecticut Bank and Trust Company"
Liberty National Bank (16006), Stamford, merged into The Connecticut Bank and Trust Company, Hartford, under title
"The Connecticut Bank and Trust Company"
FLORIDA

Southeast National Bank of Cocoa (15475), Cocoa, and Southeast First National Bank of Satellite Beach (15084),
Satellite, merged into Southeast Bank of Titusyjlle, Titusville, under title "Southeast Bank of Brevard"
Barnett Bank of Delray Beach, National Association (14774), Delray Beach, merged into Barnett Bank of West Delray
Beach, Palm Beach County, under title "Barnett Bank of Delray Beach"
Southeast National Bank of Dunedin (14922), Dunedin, and Southeast National Bank of St. Petersburg (15036), South
Pasadena, merged into Southeast First Bank of Largo, Largo, under title "Southeast Bank of Pinellas"
First American National Bank of Hemando County (16520), Hernando County, merged into Hernando State Bank,
Brooksville, under title "Hernando State Bank"
First American Bank of Lake Worth, National Association (14796), Lake Worth, merged into First American Bank of
North Palm Beach, North Palm Beach, under title "First American Bank of Palm Beach County"
Landmark Bank of Melbourne, National Association (14712), Melbourne, merged into Landmark Bank of Brevard,
Indialantic, under title "Landmark Bank of Brevard"
Barnett Bank of West Lake Worth, National Association (16424), Lake Worth, merged into Barnett Bank of West Palm
Beach, West Palm Beach, undertime "Barnett Bank of Palm Beach County"

136



Table B-12—Continued
National banks merged or consolidated with state banks, by states, calendar 1978
(Dollar amounts in thousands)

Title and location of bank
First Marine National Bank (15782), Palm Springs, and First Marine Bank of Boca Raton, Boca Raton, and First
Marine Bank of Palm Beach Gardens, Palm Beach Gardens, merged into First Marine Bank and Trust Company of
the Palm Beaches, Riviera Beach, under title "First Marine Bank and Trust Company of the Palm Beaches"
Barnett Bank of St. Augustine, National Association (11420), St. Augustine, merged into Barnett Bank of Anastasia
Island, St. Augustine, under title "Barnett Bank of St. Johns County"
The Gulf National Bank (16170), Tallahassee, merged into The Lewis State Bank, Tallahassee, under title "The Lewis
State Bank"
Barnett Bank of East Polk County, National Association (13383). Winter Haven, merged into Barnett Bank of
Aubumdale, Winter Haven, under title "Barnett Bank of East Polk County"
The Exchange National Bank of Winter Haven (13437), Winter Haven, merged into The Exchange Bank of Central
Florida, HainesCity, undertime "Exchange Bank of Polk County"

Total capital
accounts of
national
banks*

Effective
date

Dec. 30 77

$1,641

Apr.

1

3.447

Mar.

1

1,169

May

1

6,546

Nov.

30

9.049

Apr.

1

688

Sept.

29

2.122

Dec.

11

3,531

The First National Bank in Bedford (14284], Bedford, merged into Johnstown Bank and Trust Company, Johnstown,
under title "Johnstown Bank and Trust Company"
Apr.
The First National Bank of Hawley (6445), Hawley, merged into West Side Bank, Scranton, under title "First State Bank" Sept.

17
29

3.318
1.676

Dec. 30 77

1,362

Sept.

30

9,036

Dec.

29

3.268

Mar.

31

11,646

Nov.

30

1,531

MARYLAND

The Peoples National Bank of Hancock (13853), Hancock, merged into Blue Ridge Trust Company, Hancock, under
title "The Peoples Bank of Hancock"
NEW YORK

Chemical Bank - Eastern National Association (2517), Greenwich, merged into Chemical Bank, New York under title
"Chemical Bank"
OREGON

Crater National Bank (15583), Medford, merged into Western Bank, Coos Bay, under title "Western Bank"
PENNSYLVANIA

VERMONT

First National Bank of White River Junction (3484), White River Junction, merged into Inter-State Trust Company,
White River Junction, under title "First Inter-State Bank"
VIRGINIA

Fidelity American Bank NA, Tidewater (11381), Portsmouth, merged into Fidelity American Bank, Virginia Beach,
Virginia Beach, under title "Fidelity American Bank"
First Virginia Bank-Manassas National (5032), Prince William County, merged into First Virginia Bank, Falls Church,
under title "First Virginia Bank"
Alexandria National Bank of Northern Virginia (7093), Springfield, merged into Arlington Trust Company, Inc.,
Herndon, under title "First American Bank of Virginia"
Williamsburg National Bank (15562), Williamsburg, merged into Southern Bank and Trust Company, Richmond, under
title "Southern Bank and Trust Company"
* Includes subordinated notes and debentures, if any.




137

TableB-13
National banks converted into state banks, by states, calendar 1978

(Dollar amounts in thousands)

Charter
No.

Title and location of bank

Total capital
accounts of
national
banks*

Effective
date

i223,979,530

Total: 68 banks.
ARKANSAS

11580
6758
14941

The Farmers National Bank of Clarksville, Clarksville, converted into Farmers Bank and Trust Company,
Clarksville
The First National Bank of Newport, Newport, converted into First State Bank of Newport, Newport
First National Bank of Warren, Warren, converted into First State Bank of Warren, Warren

July
July
Dec.

6
7
14

1,640,897
2,828,370
2,260,000

July
Sept.

12
30

7,615,107
526,000

Dec.
Dec.

29
29

1,794,503
2,553,737

Dec.

29

656,000

Dec.

29

4,958,999

Dec.
Dec.

29
9

2,357,433
1,727,831

Dec.

29

2,576,929

Mar.

1

1,677,266

Dec.

19

3,968,000

May
Apr.

15
10

3,998,756
3,726,912

May

26

6,245,966

July
July
June
Oct.
Aug.
Jan.
Dec.
June
Oct.

1
1
1
1
1
3
27
1
1

1,506,000
735,682
428,458
208,000
598,307
305,722
1,328,271
471,532
535,000

June

30

1,480,194

Oct.

27

1,586,445

Apr.

4

3,242,782

CALIFORNIA

14670
6919

Community National Bank, Bakersfield, converted into Community First Bank, Bakersfield

15425

FLORIDA

Central Bank, National Association, Oakland, converted into Central Bank, Oakland

15204
16146

15465
15770
16038
15263

Second National Bank of Clearwater, Clearwater, converted into First American Bank of Pinellas,
Clearwater
The First National Bank of Davie, Davie, converted into First American Bank of Davie, Davie
Second National Bank of Homestead, Homestead, converted into First American Bank of Homestead,
Homestead
The Second National Bank of North Miami, North Miami, converted into First American Bank of Dade
County, North Miami
Second National Bank of North Miami Beach, North Miami Beach, converted into First American Bank of
North Miami Beach, North Miami Beach
Park National Bank, Pinellas Park, converted into Park Bank of Florida, Pinellas Park
First National Bank of the Upper Keys, Tavemier, converted into First American Bank of the Florida Keys,
Tavernier
ILLINOIS

14647
14405
5070
14426

National Bank of Chenoa, Chenoa, converted into Bank of Chenoa, Chenoa
The South Shore National Bank of Chicago, Chicago, converted into the South Shore Bank of Chicago,
Chicago
The Southern Illinois National Bank, Fairview Heights, converted into Southern Illinois Bank, Fairview
Heights
State National Bank of Lincoln, Lincoln, converted into State Bank of Lincoln, Lincoln
INDIANA

13729

Marion National Bank of Marion, Marion, converted into American Bank & Trust Company, Marion
KANSAS

10644
11177
11775
8596
3794
16540
2777
5359
7195

The Farmers National Bank of Atwood, Atwood, converted into Farmers Bank & Trust, Atwood
The Farmers National Bank of Beaver, Beaver, converted into Farmers State Bank, Beaver
The Exchange National Bank of Clyde, Clyde, converted into Exchange Bank of Clyde, Clyde
The First National Bank of Formoso, Formoso, converted into the Formoso Bank, Formoso
The Howard National Bank, Howard, converted into Howard State Bank, Howard
Jennings National Bank, Jennings, converted into Jennings Bank, Jennings
The First National Bank of Newton, Newton, converted into First Bank of Newton, Newton
The First National Bank of Nortonville, Nortonville, converted into Bank of Nortonville, Nortonville
The First National Bank of Overbrook, Overbrook, converted into The First Security Bank, Overbrook . . . .

6160

The Montgomery National Bank of Mt. Sterling, Mt. Sterling, converted into Montgomery Bank & Trust
Company, Mt. Sterling
The Traders National Bank of Mt. Sterling, Mt. Sterling, converted into Traders Bank and Trust Company,
Mt. Sterling
The Clark County National Bank of Winchester, Winchester, converted into Clark County Bank, Inc.,
Winchester

KENTUCKY

6129
995

MICHIGAN

16571

Peoples Bank and Trust, N.A., Trenton, converted into Peoples Bank and Trust Company, Trenton

June

11,814,798

MINNESOTA

11552

The First National Bank of Good Thunder, Good Thunder, converted into First State Bank of Good
Thunder, Good Thunder

June

12

312,000

MISSOURI

16306
7351
4441
4111
16351

138

United Missouri Bank of Blue Springs, National Association, Blue Springs, converted into United Missouri
Bank of Blue Springs, Blue Springs
The First National Bank of Braymer, Braymer, converted into The Braymer Bank, Braymer
United Missouri Bank of Carthage, National Association, Carthage, converted into United Missouri Bank of
Carthage, Carthage
The Citizens National Bank of Chillicothe, Chillicothe, converted into Citizens Bank and Trust Company,
Chillicothe
United Missouri Bank of Jefferson City, National Association, Jefferson City, converted into United
Missouri Bank of Jefferson City, Jefferson City




July
Sept.

19
7

903,215
447,455

June

9

3,111,000

July

20

5,359,000

July

26

852,636

Table B-13—Continued
National banks converted into state banks, by states, calendar 1978

(Dollar amounts in thousands)

Charter
No.
15299
9236
3110
9382
4215
15176
4160
5160

Title and location of bank
United Missouri Bank of Joplin, National Association, Joplin, converted into United Missouri Bank of
Joplin, Joplin
Traders National Bank of Kansas City, Kansas City, converted into Traders Bank of Kansas
City, Kansas City
United Missouri Bank of Milan, National Association, Milan, converted into United Missouri Bank of Milan,
Milan
The Thornton National Bank of Nevada, Nevada, converted into Thornton Bank, Nevada
The First National Bank of Plattsburg, Plattsburg, converted into American Bank of Plattsburg, Plattsburg
Belt National Bank of St. Joseph, St. Joseph, converted into Belt American Bank of St. Joseph, St. Joseph
The First National Bank of Stewartsville, Stewartsville, converted into American Bank of Stewartsville,
Stewartsville
United Missouri Bank of Warrensburg, National Association, Warrensburg, converted into United Missouri
Bank of Warrensburg, Warrensburg

Total capital
accounts of
national
banks*

Effective
date

12

$2,052,756

July

6

10,040,535

June
Jan.
Sept.
Sept.

21
19
29
20

1,255,619
1,594,225
1,513,000
1,561,803

Aug.

11

566,564

June

9

2,264,000

Mar.
Sept.

21
1

35,492,895
33,640,611

July

NEW JERSEY

399
1113

First Peoples National Bank of New Jersey, Haddon Township, converted into First Peoples Bank of New
Jersey, Haddon Township
Heritage Bank-North, N.A., Monroe Township, converted into Heritage Bank-North, Monroe Township . . .
NEW MEXICO

13438

Hot Springs National Bank, Truth or Consequences, converted into Western Bank, Truth or Consequences

June

2,158,340

OKLAHOMA

12148
16457
12334

The First National Bank of Coyle, Coyle, converted into Eighty Niner Bank of Coyle, Coyle
Citizens National Bank of Lawton, Lawton, converted into Citizens Bank, Lawton
The State National Bank of Wynnewood, Wynnewood, converted into the State Bank of Wynnewood,
Wynnewood

Dec.
Apr.

1
3

196,000
869,000

June

1

512,000

Sept.

21

5,223,490

Apr.

1

4,365,000

Oct.

2

802,539

June
Dec.
Apr.
Jan.
Jan.
Nov.
Oct.

1
1
17
27
20
17
23

7,630,115
786,000
378,000
991,419
1,195,126
2,792,000
193,756

Sept.

29

1,826,000

PENNSYLVANIA

5147

The Juniata Valley National Bank, Mifflintown, converted into The Juniata Valley Bank, Mifflintown
PUERTO RICO

16020

Banco de Santander-Puerto Rico, N.A., Hato Rey, converted into Banco de Santander of Puerto Rico,
Hato Rey
TENNESSEE

7314

The First National Bank of Tracy City, Tracy City, converted into First Bank and Trust, Tracy City
TEXAS

14427
5533
10694
15956
16304
164
10956

Citizens National Bank & Trust Company of Baytown, Baytown, converted into Citizens Bank and Trust
Company of Baytown, Baytown
The Delta National Bank of Cooper, Cooper, converted into The Delta Bank, Cooper
The First National Bank of Dawson, Dawson, converted into First Bank & Trust Company, Dawson
First National Bank of Deer Park, Deer Park, converted into First Bank of Deer Park, Deer Park
Western National Bank, Duncanville, converted into Western Bank, Duncanville
National Standard Bank, Houston, converted into The Standard Bank, Houston
The First National Bank of Schwertner, Schwertner, converted into Schwertner State Bank, Schwertner.
UTAH

1549

Citizens N a t i o n a l B a n k , O g d e n , c o n v e r t e d into T h e Citizens Bank, O g d e n . . . .
VIRGINIA

15139
13878
6018
8984
15566

The First National Bank, Narrows, converted into First Virginia Bank - West, Narrows
The First National Bank in Onancock, Onancock, converted into First Virginia Bank - Eastern Shore,
Onancock
First Virginia Bank - First National, Purcellville, converted into First Virginia Bank - Loudoun, Purcellville ..
The Peoples National Bank, Rocky Mount, converted into First Virginia Bank - Franklin County, Rocky
Mount
First Virginia Bank, N.A., Strasburg, converted into First Virginia Bank - Shenandoah Valley, Strasburg ...

Oct.

2,906,000

Nov.
Dec.

1,679,000
2,348,000

Oct.
Oct.

3,590,000
4,383,000

May

1,946,983

WASHINGTON

11935

T h e First N a t i o n a l B a n k of S t a n w o o d , S t a n w o o d , c o n v e r t e d into B a n k of S t a n w o o d , S t a n w o o d ...
WEST VIRGINIA

15597

The Valley National Bank of Huntington, Huntington, converted into The Valley Bank, Huntington

Apr.

28

886,551

Includes subordinated notes and debentures, if any.




139

Table B-14
Purchases of state banks by national banks, by states, calendar 1978
(Dollar amounts in thousands)
Total capital
accounts of
state banks

Effective
date

Title and location of bank
Total: 4 banks

$ 2,362

ALABAMA

Town-Country National Bank (16708), Camden, purchased Wilcox County Bank, Camden
First Alabama Bank, N.A. (16699), Notasulga, purchased First Bank of Macon County, Notasulga

Mar.
Jan.

8
28

451
364

May

1

803

Nov.

3

744

FLORIDA

Atlantic National Bank of West Palm Beach (13300), West Palm Beach, purchased Atlantic Westside Bank of Palm
Beach County, West Palm Beach
SOUTH DAKOTA

United National Bank (15639), Sioux Falls, purchased Rosholt Community Bank, Rosholt

TableB-15
Consolidations of national banks, or national and state banks, by states, calendar 1978
(Dollar amounts in thousands)
Outstanding
capital
stock

Consolidating banks
Resulting bank

Effective
date

Surplus

Undivided
profits and
reserves

Total assets

Total: 2 consolidations
NEW YORK

Dec. 31

Lincoln First Bank-Central, National Association (15627), Syracuse
Lincoln First Bank of Rochester, Rochester
National Bank of Westchester (10525), White Plains
First-City National Bank of Binghamton, N.Y. (15625), Binghamton..
The First National Bank of Jamestown (15626), Jamestown
Lincoln First Bank, N.A. (15627), Rochester

$ 8,620
37,500
11,264
4,250
2,000
63,634

$ 9,200
25,000
11,290
10,750
2,000
63,634

$ 6,918
19,115
19,643
10,172
5,882
78,327

$ 410,838
1,195,733
725,418
306,593
154,266
3,160,782

3,930
100
100
5,180

5,000
1,000
500
7,000

9,139
1,405
473
9,467

205,681
23,973
8,371
238,003

PENNSYLVANIA

Mar. 13

Southwest National Bank of Pennsylvania (5351), Greensburg
The First National Bank of Youngwood (6500), Youngwood
Fidelity Deposit Bank of Derry, Derry
Southwest National Bank of Pennsylvania (5351), Greensburg

TableB-16
Mergers of national banks, or national and state banks, by states, calendar 1978
(Dollar amounts in thousands*)

Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Total: 29 merger actions
CALIFORNIA

Oct.

May

Humboldt National Bank, Eureka (8321)
Security Pacific National Bank, Los Angeles (2491)
20 Security Pacific National Bank, Los Angeles (2491)
The First National Bank of Orange County, Orange (8181) . . .
Wells Fargo Bank, National Association, San Francisco
(15660)
6 Wells Fargo Bank, National Association, San Francisco
(15660)

See footnotes at end of table.

140




$

695
309,521
309,521
1,378

$

1,305
310,479
310,479
2,350

$

1,019
264,774
303,145
4,686

$

47,320
19,588,912
19,671,502
177,335

94,461

310,101

229,717

13,327,844

94,461

310,101

220,387

13,487,435

Table B-16—Continued
Mergers of national banks, or national and state banks, by states, calendar 1978
(Dollar amounts in thousands*)

Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total
assets

FLORIDA

June

Feb.

Jan.

June

30

20

1

30

Apr.

30

Feb.

6

Dec.

31

Dec.

Dec.

29

31

Century National Bank of Coral Ridge, Fort Lauderdale
(14848)
Century National Bank of Broward, Fort Lauderdale (14554)
Century National Bank of Broward, Fort Lauderdale (14554)
Florida National Bank at Lake Shore, Jacksonville (14974)...
Florida National Bank at Arlington, Jacksonville (14759)
Florida Dealers and Growers Bank at Jacksonville, Jacksonville
Florida Northside Bank of Jacksonville, Jacksonville
Florida First National Bank of Jacksonville, Jacksonville (8321) ..
Florida First National Bank of Jacksonville, Jacksonville (8321) ..
The Exchange Bank and Trust Company of Clearwater,
Clearwater
The Exchange Bank of Dunedin, Dunedin
The Exchange National Bank of Pinellas County, Largo
(16281)
. .
The Exchange National Bank of Pinellas County, Largo
(16281)
Flagship Bank of West Melbourne, National Association,
West Melbourne (15533)
Flagship Bank of Melbourne, National Association, Melbourne (15311)
Flagship Bank of Melbourne, National Association, Melbourne (15311)
Flagship National Bank of Miami, Miami (15411)
Flagship First National Bank of Coral Gables, Coral Gables
(13008)
Flagship First National Bank of Miami Beach, Miami Beach
(12047)
Flagship National Bank of Miami, Miami (12047)
Southeast First National Bank of Maitland, Maitland (15237) .
Southeast Bank of East Orange, Orlando
Southeast National Bank of Orlando, Orlando (15814)
Southeast National Bank of Orlando, Orlando (15814)
Southeast Bank of St. Armands, Sarasota
Southeast Bank of Siesta Key, Sarasota
Southeast Bank of Venice, Venice
Southeast Bank of Village Plaza, N.A., Sarasota (15901)
Southeast First National Bank of Sarasota, Sarasota (16531)
Southeast First National Bank of Sarasota, Sarasota (16531)
Barnett Bank of Brando, National Association, unincorporated area of Brando (16023)
,
Barnett Bank of Tampa, National Association, Tampa (16437)
Barnett Bank of Tampa, National Association, Tampa (16437)
Century National Bank, Boynton Beach, Boynton Beach
(16415)
Century National Bank of Palm Beach County, West Palm
Beach (16586)
Century National Bank of Palm Beach County, West Palm
Beach (16586)

$1,221
3,483
3,483
450
250

$4,479
11,017
16,717
1,500
975

$ 2,605
7,887
10,492
593
811

$107,275
301,434
408,709
24,044
26,007

300
300
12,500
12,500

1,850
550
20,000
20,000

260
216
12,567
12,567

17,464
11,345
360,423
439,281

1,500
500

2,500
500

1,272
69

63,300
15,827

500

400

95

11,203

360

5,540

1,436

90,330

180

279

336

11,556

720

1,880

2,137

51,008

845
2,068

2,214
3,642

2 473
3,046

62,564
121,338

1,650

5,600

8,222

222,517

3,800
8,887
1,250
960
1,000
3,576
611
560
540
800
5,000
7,000

4,800
12,672
2,756
740
831
4,498
2,389
708
660
200
2,002
7,000

9,540
20,809
1,344
781
585
599
2,081
1,116
673
701
1,111
5,153

248,243
571,967
61,313
9,469
37,767
112,010
50,918
32,058
26,117
29,491
107,126
241,188

500
720
1,083

300
2,480
2,917

1,217
657
1,874

33,816
67,307
101,123

800

300

1

10,618

630

630

328

14,933

1,071

1,289

330

28,208

25
1,500
1,500

475
1,500
1,500

772
2,975
2,756

9,235
76,366
85,921

120
15,945
16,065

450
34,948
35,835

982
32,409
32,845

16,122
1,478,851
1,492,831

200
750
950

320
750
1,070

98
870
218

6,506
17,573
24,079

625
8,973
9,518

3,443
51,599
54,886

3,504
3,519
3,832

57,347
962,140
1,019,487

INDIANA

Mar.

Roanoke State Bank, Roanoke
The First National Bank in Huntington, Huntington (14398)...
31 The First National Bank in Huntington, Huntington (14398)...
MARYLAND

Apr.

The First National Bank of Snow Hill, Snow Hill (3783)
The First National Bank of Maryland, Baltimore (1413)
1 The First National Bank of Maryland, Baltimore (1413)
MICHIGAN

Mar.

The Moline State Bank, Moline
First National Bank of Grand Rapids, Grand Rapids (16296)
31 First National Bank of Grand Rapids, Grand Rapids (16296)
MISSISSIPPI

May

31

Citizens Bank of Hattiesburg, Hattiesburg
First National Bank of Jackson, Jackson (10523)
First National Bank of Jackson, Jackson (10523)

See footnotes at end of table.




141

Table B-16—Continued
Mergers of national banks, or national and state banks, by states, calendar 1978
(Dollar amounts in thousands*)

Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total
assets

NEW HAMPSHIRE

June

29

Jan.

1

The Pittsfield National Bank, Pittsfield, (1020)
Concord National Bank, Concord (318)
Concord National Bank, Concord (318)
Indian Head National Bank of Portsmouth, Portsmouth (1052)
Indian Head National Bank of Rochester, Rochester (15652)..
Indian Head Bank, National Association, Rochester (15652). .

$ 25
760
760
275
350
690

$ 125
2,240
2,240
925
200
1,060

$ 316
2,842
2,842
551
(239)
312

$ 4,520
70,946
75,430
38,034
9,973
48,007

200
815
1,015
125

1,000
1,530
2,530
1,000

1,378
1,127
2,505
1,432

26,896
59,087
85,983
22,748

4,863

4,863

11,219

219,518

5,959

5,959

11,814

242,469

50
1,982
2,588

450
7,000
6,894

2,709
6,558
9,267

28,758
220,993
249,751

140
213
353
1,000

210
511
721
1,000

104
371
442
2,000

6,024
15,354
20,520
39,937

1,250

785

586

32,973

2,250

1,785

1,086

72,910

200
1,625
1,950
100
17,500
17,600
100
2,464
1,864

500
3,690
4,190
1 500
46,155
47,655
800
3,036
2,236

428
3,097
3,406
882
39,412
40,294
966
3,499
3,268

13,795
124,277
138,065
33,816
1,530,610
1,564,426
17,708
92,904
110,651

300
10,000
10,000
200
325
10,000
10,000

200
10,000
10,500
200
375
10,000
10,000

253
23,629
23,882
1,796
3,031
25,128
19,957

11,382
1,173,809
1,185,191
21,030
43,990
932,212
986,755

500
1,013
1,200
20,552
20,552

950
598
2,800
33 337
40,397

725
398
3,378
67,265
71,776

21,402
19,597
84,996
2 097 962
2,221,958

3,400

3,400

5,890

162,930

2,600

2,600

2,828

145,571

400
21,982
28,382

400
38,023
44,423

12
35,443
44,173

5,509
1,534,194
1,848,204

NEW YORK

Dec.

29

Dec.

29

The National Union Bank of Monticello, Monticello ( 1 5 0 3 ) . . . .
The Chester National Bank, Chester (1349)
The Chester National Bank, Chester (1349)
First National Bank in Sidney, Sidney (13563)
The National Bank and Trust Company of Norwich, Norwich
(1354)
The National Bank and Trust Company of Norwich, Norwich
(1354)
NORTH CAROLINA

Feb.

The First National Bank of West Jefferson, West Jefferson
(8571)
First National Bank of Catawba County, Hickory (4597)
21 First National Bank of Catawba County, Hickory (4597)
OHIO

May

May

The Middle Point Banking Company, Middle Point
The First National Bank of Convoy, Convoy (8017)
1 United National Bank, Convoy (8017)
The Trotwood Bank, Trotwood
The Central Trust Company of Montgomery County, National
Association, Dayton (16330)
4 The Central Trust Company of Montgomery County, National
Association Dayton (16330)
PENNSYLVANIA

Dec.
Dec.
May

The National Bank of Arendtsville, Arendtsville (9139)
Adams County National Bank, Cumberland Township (311) .
31 Adams County National Bank, Cumberland Township (311) .
Farmers Bank of Kutztown Kutztown
National Central Bank, Lancaster (694)
29 National Central Bank, Lancaster (694)
York Haven State Bank, York Haven
The Drovers & Mechanics National Bank of York, York (2958)
31 The Drovers & Mechanics National Bank of York, York (2958)
UTAH

Dec.

Jan.

Zions First National Bank of Ogden, Ogden (16043)
Zions First National Bank, Salt Lake City (4341) ..
1 Zions First National Bank, Salt Lake City (4341)
Richfield Commercial & Savings Bank, Richfield
First State Bank, Salina, Salina
Zions First National Bank, Salt Lake City (4341)
10 Zions First National Bank, Salt Lake City (4341)
VIRGINIA

Aug.

Sept.

Virginia National Bank/Henry County, Henry County (16167)
Virginia National Bank/Lynchburg, Lynchburg (15819)
Virginia National Bank/Richmond, Richmond (16610)
Virginia National Bank Norfolk (9885)
31 Virginia National Bank Norfolk (9885)
First & Merchants National Bank of the Peninsula, York County (15984)
.
First & Merchants National Bank of Tidewater, Chesapeake
(16184)
First & Merchants National Bank of Prince William, Prince
William (16402)
.
First & Merchants National Bank, Richmond (1111)
30 First & Merchants National Bank, Richmond (1111)

* Some asset figures are from the nearest Report of Condition.

142




TableB-17
Mergers resulting in national banks, by assets of acquiring and acquired banks, 1960—1978*
/Assess of acquired banks
Assets of acquiring banksf
Under $10 million
$10 to 24.9 million
$25 to 49.9 million
$50 to 99.9 million
$100 million and over
Total

Acquired
banks
1960-1977

Under $10
million

$10 to 24.9
million

$25 to 49.9
million

$50 to 99.9
million

$100 million
and over

101
159
188
228
749

101
141
121
123
262

0
18
51
62
256

0
0
16
38
124

0
0
0
5
48

0
0
0
0
59

1,425^:

248

387

178

53

59

* Includes all forms of acquisitions involving two or more banks from May 13, 1960 through December 31, 1978.
t In each transaction, the bank with the larger total assets was considered to be the acquiring bank.
^ Comprises 1,316 transactions, 37 involving three banks, 13 involving four banks, 10 involving five banks, one involving six banks, one involving
seven banks and one involving nine banks.




143

TableB-18
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
Total,
Total, U.S. and
United States
other areas
Number of banks

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises.
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets
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
Deposits of commercial banks
Certified and officers' checks
Total deposits
Total demand deposits
Total time and savings deposits .
Federal funds purchased and securities sold under agreements to repurchase.
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures
Equity Capital
Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital.



4,616

Alabama

Alaska

4,616

$ 993,755

1,011,666

1,011,666

4,913,625
27,791,430
367,083,442
4,244,194
362,839,248
4,701,197
11,324,838
1,750,663
2,338,166
9,878,834

4,913,625
27,791,430
367,083,442
4,244,194
362,839,248
4,701,197
11,324,838
1,750,663

671,166,240

2,338,166
9,878,834
21,406,883
671,166,240

159,117,068
280,054,749
5,230,668
43,128,060
4,996,487
27,493,932
6,911,383
526,932,347
202,925,268
324,007,079
63,112,716
5,835,560
1,005,362
9,949,905

159,117,068
280,054,749
5,230,668
43,128,060
4,996,487
27,493,932
6,911,383
526,932,347
202,925,268
324,007,079
63,112,716
5,835,560
1,005,362
9,949,905

21,406,883

Arkansas

56

$ 593,538
291,599
177,441
606,194
8,278
5,479

13,792,569
5,179,432
1,989,410
5,880,644

195,707

$ 177,524
71,245
35,045
158,171
470
2,828
0
37,400

5,180,620
60,475

815,045
7,243

$ 838,605
520,595
139,649
469,999
6,761
6,615
2,716
453,450
3,882,513
33,775

5,120,145
25,806
172,289
7,171
58
29,298
119,587
8,825,172

807,802

3,848,738

2,707,528

10,482
62,417
2,453
0
0
21,618

13,759
159,277
6,483
0
6,539
83,886

8,649
105,302
4,854

1,387,455

6,557,072

475,229
389,102
16,696
244,460
0
5,805
20,111
1,151,403
568,314
583,089
62,387
24,323
12,477
0
22,123

1,939,817
3,309,057
41,223

483,447

297,696
1,269,213
21,706
10,752
78,542

California

72

99

$ 90,728,922 $ 90,728,922
47,530,326
47,530,326
19,599,400
19,599,400
62,841,067
62,841,067
2,509,975
2,509,975

Arizona

20,147

303,187
2,732,166
24,638

166

2,295
67,113
4,901,770

142,446

126,396
436,867
5,495,323
56,637,298
639,849
55,997,449
1,738,500
1,699,644
57,294
650,025
2,414,896
4,783,945
100,384,840

14,214,441

14,214,441

621,050,331

621,050,331

2,281,936
4,008,862
77,663
744,701
0
272,706
54,230
7,440,098
2,773,796
4,666,302
486,972
43,617
4,301
29,300
143,205
8,147,493

3,095,982

3,095,982

45,746

750

85,908

28,176

405,790

26,193
9,740,275

0
117,203
242,607
266,003

6,120
631,933

0
31,874
41,046
39,188
1,884
113,992

0
40,977

19,364,820
1,009,958
47,019,927

26,193
9,740,275
16,878,681
19,364,820
1,009,958
47,019,927

174,081
6,198
321,793

0
73,960
96,769
157,897
13,369
341,995

0
989,248
2,275,913
2,408,519
37,560
5,711,240

671,166,240

671,166,240

8,825,172

1,387,455

6,557,072

4,901,770

100,384,840

16,878,681

22,264,608
45,574,426
765,700
4,040,419
1,336,234
3,266,256
1,361,062

1,272,713

55,932
112,062
5,694,625
2,235,629
3,458,996
372,484
4,564
12,600
6,539
58,559
6,149,371

1,274,945
2,153,116
30,404
398,318
0
210,257
25,114
4,092,154
1,659,619
2,432,535
351,274
20,712
11,939
2,295
53,225
4,531,599

26,683,883
51,924,822
8,852,934
1,642,883
153,925
2,414,998
2,594,365
94,267,810

233,481
3,053

100,537

78,608,705

Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
Colorado
Number of banks

Connecticut

District of
Columbia

Delaware

Florida

Georgia

Hawaii

135

21

5

16

249

64

2

$ 1,396,810
477,059
146,551
822,977
1,386
10,320
8,117
251,798

$ 588,658
223,382
104,124
293,365
59,225
5,579
12,372
118,503

$ 7,172
9,777
1,701
2,282
302
99
0
4,350

$ 768,075
453,086
142,006
670,559
17,090
9,021
5,000
433,255

$ 2,674,276
2,716,347
1,286,978
2,081,913
141,784
32,407
27,216
982,234

$ 1,691,132
481,065
151,333
642,450
14,115
39,769
9,891
576,578

$ 19,485
24,596
9,751
577
0
200
0
2,000

4,854,985
49,426
4,805,559

1,909,920
21,090
1,888,830

48,514
208
48,306

3,052,094
36,235

9,269,941
107,180

4,722,003
72,754

3,015,859

9,162,761

4,649,249

90,893
1,485
89,408

52,683
162,782
26,519
2,753
25,608
111,338

9,117
70,710
9,733
3,458
9,331
192,225

22,816
68,122
4,161
1,397
19,559
67,343

46,129
429,275
86,337
2,986
16,244
502,944

46,474
247,149
132,556
93,955
56,391
218,788

6,336
2,409
1,128
0
10
1,370

8,302,260

3,588,612

0
1,146
108
0
0
514
75,757

5,697,349

20,189,831

9,050,895

157,270

2,363,245
3,201,304
89,973
749,339
19,900
450,437
95,687

1,116,570
1,489,832
52,302
166,776
0
173,855
32,692

18,544
46,165
1,371
2,250
0
0
532

1,938,299
2,101,847
126,434
42,019
169,138
135,198
79,542

6,125,093
8,765,817
135,245
1,303,596
2,157
641,942
221,624

2,764,259
2,667,197
68,924
751,483
13,305
471,208
50,840

47,937
64,335
1,098
29,448
0
1,107
3,035

6,969,885

3,032,027

68,862

4,592,477

17,195,474

6,787,216

146,960

3,102,517
3,867,368
549,296
57,146
26,242
25,608
96,653
7,724,830

1,444,224
1,587,803
261,257
20,116
88
9,331
33,010

2,348,717
2,243,760
539,298
29,684
12,931
19,559
55,800
5,249,749

7,436,595
9,758,879
1,126,306
102,391
11,604
16,341
204,664

3,602,248
3,184,968

53,793
93,167

1,174,276
97,061
42,657
58,117
226,496

0
0
0
10
1,476

3,355,829

20,613
48,249
0
94
0
0
488
69,444

18,656,780

8,385,823

148,446

36,752

15,435

200

12,484

35,774

57,532

1,500

0
107,364
173,538
255,698
4,078

0
49,948
107,406
57,517
2,477

0
1,580
1,726
2,744
63

1,001
357,972
591,206
533,915
13,183

0
158,312
224,760
163,037
61,431

0
3,799
2,508
1,017
0

540,678

217,348

6,113

323
65,519
136,270
230,625
2,379
435,116

1,497,277

607,540

7,324

8,302,260

3,588,612

75,757

5,697,349

20,189,831

9,050,895

157,270

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises...
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets
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
Deposits of commercial banks
Certified and officers' checks
Total deposits
Total demand deposits
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital




Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
Illinois

Idaho

Iowa

Indiana

Kansas

Kentucky

Louisiana

6

420

120

99

157

80

53

358,865
269,727
54,350
282,710
2,943
4,981
0
64,300

$ 5,924,192
3,500,108
2,740,215
5,704,876
385,696
98,477
552,580
1,707,516

$ 1,659,633
1,442,913
653,901
1,547,316
199,940
17,449
34,136
621,944

$ 674,123
399,515
201,585
604,192
16,022
5,039
6,117
244,141

$ 1,127,520
1,281,647
251,565
986,330
7,978
10,611
1,030
583,132

33,153,837
392,695
32,761,142

7,854,882
83,946
7,770,936

3,060,214
24,744

3,538,091
31,594

4,552,136
50,153

3,035,470

$ 730,002
577,960
267,926
675,554
15,883
7,906
13,334
321,140
3,023,742
28,923
2,994,819

$ 708,473
484,163
121,668
666,512
6,679
6,434
8,655
180,082

1,952,451
16,399
1,936,052

3,506,497

4,501,983

4,568
63,156
1,767
0
0
39,021

45,539
695,312
283,962
178,340
967,244
1,211,022

140,176
249,056
40,267
8,702
38,367
487,146

2,963
78,267
6,399
1,304
10,584
83,341

4,352
123,483
4,006
1,724
0
68,432

26,432
173,288
27,215
897
14,740
154,014

3,082,440

56,756,221

14,911,882

5,369,062

5,806,521

84,704
116,847
6,153
67
4,593
84,157
5,985,684

9,148,382

767,172
1,605,559
21,069
188,284
0
17,875
28,157

10,896,892
23,810,064
386,357
2,713,140
1,222,981
2,707,523
478,829

3,070,743
6,749,973
109,427
1,632,057
2
381,086
140,881

1,185,776
2,719,848
36,960
305,707
0
271,199
34,977

1,420,772
2,326,687
45,525
754,800
0
247,670
35,547

1,622,549
2,782,589
59,803
355,069
0
265,249
41,777

2,501,205
3,383,579
65,856
1,238,251
2,966
336,550
75,446

2,628,116

42,215,786

12,084,169

4,554,467

4,831,001

5,127,036

7,603,853

897,932
1,730,184

14,038,245
28,177,541

4,283,006
7,801,163

1,550,600
3,003,867

1,906,887
2,924,114

198,426
1,725
4,232
0
39,528
2,872,027

8,285,452
155,436
35,664
971,458
1,019,750

1,467,261
25,697
19,249
38,367
212,898

338,601
13,481
1,143
10,711
64,919

401,145
35,351
1,456
0
49,125

52,683,546

13,847,641

4,983,322

5,318,078

2,058,216
3,068,820
294,157
16,383
19,659
4,593
77,519
5,539,347

3,207,050
4,396,803
688,894
9,860
29,046
14,862
102,695
8,449,210

22,305

Number of banks

109,308

31,548

28,723

24,157

13,608

26,569

0
37,651
128,479
19,726
. 2,252

7,715
788,574
1,683,843
1,392,884
90,351

400
197,305
376,590
439,125
19,273

0
95,216
154,524
208,166
6,380

0
77,653
129,938
213,725
11,413

1,500
113,616
230,818
305,741
20,928

188,108

3,963,367

1,032,693

0
63,665
91,586
190,465
11,301
357,017

464,286

432,729

672,603

3,082,440

56,756,221

14,911,882

5,369,062

5,806,521

5,985,684

9,148,382

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises...
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets
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
Deposits of commercial banks .
Certified and officers' checks
Total deposits
Total demand deposits
.
. .
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money .. . .
.
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital



. .

Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

17

34

72

125

204

36

109

121,118
59,442
56,063
174,433
530
1,329
0
19,500

$ 761,006
299,282
87,384
490,598
6,076
8,092
26,998
208,338

$ 1,911,772
1,496,477
187,860
748,526
50,084
30,280
75,160
508,652

$ 3,136,413
1,834,040
439,814
2,526,945
99,693
31,737
20,667
1,475,008

$ 1,850,911
851,332
579,004
1,663,385
46,323
17,753
308,216
434,155

$ 632,476
402,057
128,250
599,973
9,083
7,770
19,999
123,019

$ 1,921,934
630,496
354,339
1,210,590
13,780
17,198
55,480
1,315,746

731,560
6,162

Number of banks

3,629,909
33,482
3,596,427

6,459,275
93,715
6,365,560

13,522,410
128,161
13,394,249

8,400,440
77,362
8,323,078

2,201,476
23,189
2,178,287

5,684,027
66,551
5,617,476

39,800
97,892
7,895
762
88,258
67,249
5,786,057

65,845
249,600
29,092
83,970
296,081
989,514

49,657
355,228
47,358
48,852
159,586
538,424

152,762
172,952
52,195
17,494
142,001
196,357

153
97,001
5,367
78
2,035
62,674

58,054
169,855
16,551
14,334
60,457
135,345

13,088,473

24,157,671

14,807,918

4,268,222

11,591,635

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve

$

...

725,398

Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises.. .
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets

0
28,198
1,209
408
0
15,077
1,202,705

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
Deposits of commercial banks
Certified and officers' checks
Total deposits
Total demand deposits
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures

281,717
635,516
13,954
91,261
0
5,047
8,583
1,036,078

1,544,260
2,678,386
51,417
216,137
868
91,831
53,832

3,452,424
4,511,673
139,482
687,378
100,831
703,871
137,056

5,145,135
11,653,622
219,295
2,067,670
865
530,862
578,688

3,033,392
6,285,898
107,540
890,862
111
629,831
108,271

983,437
1,759,912
19,064
651,185
6,536
180,155
11,920

2,749,354
3,785,504
132,820
582,743
148
912,295
70,414

4,636,731

9,732,715

20,196,137

11,055,905

3,612,209

8,233,278

331,572
704,506
61,887
6,395
4,848
0
9,600
1,118,808

1,800,590
2,836,141
570,617
14,351
13,197
88,258
71,867
5,395,021

4,726,050
5,006,665
1,722,895
73,961
25,746
296,680
200,693

6,819,220
13,376,917
1,650,818
29,293
19,129
159,586
335,154

3,998,691
7,057,214
2,012,561
187,093
5,063
142,199
311,183

1,379,156
2,233,053
304,425
8,246
18,148
2,035
36,849

12,052,690

22,390,117

13,714,004

3,981,912

3,847,391
4,385,887
2,034,972
196,406
41,044
60,457
214,640
10,780,797

2,050

2,995

36,357

104,702

131,434

9,820

29,965

0
20,480
23,791
36,735
841
81,847

0
63,928
118,204
193,715
12,194
388,041

0
166,719
408,906
403,531
20,270
999,426

0
324,529
624,260
682,935
31,128
1,662,852

0
270,156
301,168
361,835
29,321

0
46,061
211,839
15,363
3,227

962,480

276,490

2,128
149,132
235 618
380,515
13,480
780,873

1,202,705

5,786,057

13,088,473

24,157,671

14,807,918

4,268,222

11,591,635

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital




Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
Nebraska

Montana

New
Hampshire

Nevada

New Jersey

New Mexico

39

97

39

127

2,123,893
1,721,622
1,115,242
2,561,760
293,373
23,548
6,049
366,332
10,387,265
112,315

301,901
250,479
119,050
327,601
2,317
4,426
0
134,582
1,516,485
17,273

14,512,648
4,162,004
717,279
3,531,124
270,189
170,565
1,587,174
1,672,412
38,647,908
679,503

New York

56

117

236,619
155,745
60,190
311,054
4,165
3,894
4,878
30,245

721,257
284,804
192,279
556,685
9,863
6,608
40,379
371,562

240,129
199,419
82,745
191,543
313
1,990
0
32,800

1,480,511
13,444

2,969,520
33,044

1,069,170
9,687

190,233
128,928
13,332
190,697
1,549
1,941
0
12,920
902,997
8,608

1,467,067

2,936,476

1,059,483

894,389

10,274,950

1,499,212

37,968,405

5,038
42,281
1,404
0
278
30,821

41,058
86,096
4,009
673
2,989
70,103

61,191
43,680
0
0
0
23,639

14
31,237
836
0
927
11,605

91,162
349,510
71,318
165
38,960
301,570

2,089
78,168
3,859
31
0
36,035

2,353,679

5,324,841

1,936,932

1,478,608

19,339,454

2,759,750

565,493
937,331
348,709
1,035,775
3,499,488
5,406,979
76,385,575

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
Deposits of commercial banks
Certified and officers' checks
Total deposits

537,898
1,238,470
17,824
197,860
0
35,165
20,786
2,048,003

1,256,692
2,395,862
34,638
371,488
0
353,568
25,408

685,300
805,661
13,442
135,010
0
5,261
33,852

387,542
721,206
22,852
124,899
0
19,710
14,859

4,933,382
9,893,435
182,137
1,312,947
409
209,297
238,020

4,437,656

1,678,526

1,291,068

16,769,627

784,509
1,081,828
26,224
466,337
0
34,179
32,250
2,425,327

15,965,708
23,325,151
451,533
2,014,908
1,941,050
6,991,833
1,003,960
51,694,143

Total demand deposits
Total time and savings deposits .,
Federal funds purchased and securities sold under agreements to repurchase.
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities

656,339
1,391,664
88,012
5,527
2,455
278
33,965

1,741,034
2,696,622

782,445
896,081
72,468
15,117
6,477
0
20,088

6,058,579
10,711,048
875,498
73,104
6,679
39,879
225,890

942,804
1,482,523

398,979
10,353
10,545
2,989
59,253
4,919,775

1,792,676

17,990,677

86,436
4,806
15,802
0
30,235
2,562,606

24,067,015
27,627,128
9,068,521
1,094,051
37,237
3,559,010
3,416,636

2,178,240

496,829
794,239
40,221
13,123
2,882
927
14,631
1,362,852

17,784

24,850

0

2,075

70,997

16,194

352,006

0
63,129
63,314
28,153
3,059

101
75,593
101,393
195,534
7,595

0
27,918
36,647
77,645
2,046

300
15,143
46,486
49,650
2,102

2,244
292,511
458,020
500,519
24,486

1,500
55,704
73,692
47,087
2,967

Number of banks
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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell.
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises.
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets
Liabilities

Subordinated notes and debentures

68,869,598

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves.
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital.



157,655

380,216

144,256

113,681

1,277,780

180,950

1,421
1,759,212
2,292,843
2,968,521
141,974
7,163,971

2,353,679

5,324,841

1,936,932

1,478,608

19,339,454

2,759,750

76,385,575

Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
North
Carolina
Number of banks

North Dakota

Oklahoma

Ohio

Pennsylvania

Oregon

Rhode Island

43

218

191

7

231

5

181,660
122,047
57,092
260,223
4,009
2,188
0
17,759

$ 3,619,640
2,289,565
735,804
3,901,633
88,710
42,459
48,549
850,136

$ 1,336,574
1,018,623
89,499
1,479,379
26,445
14,002
55,323
436,157

$ 4,952,109
3,464,722
2,088,405
3,824,324
294,217
62,480
916,702
1,778,146

$ 284,840
379,630
55,238
376,825
10,263
4,304
47,454
50,472

6,369,347
67,345
6,302,002

1,162,343
9,824

13,814,761
161,097

5,470,464
57,256

24,168,578
270,062

1,152,519

13,653,664

5,413,208

$ 843,819
323,218
47,862
910,986
5,545
10,083
21,158
315,866
4,405,407
35,993
4,369,414

23,898,516

1,973,351
17,825
1,955,526

79,417
220,799
19.896
12,224
174,566
306,505

418
34,496
1,240
10
393
26,796

148,894
471,030
15,089
14,710
54,919
961,644

31,893
167,240
10,572
471
529
129,612

32,190
158,318
9,290
7,204
145,288
450,790

258,716
548,226
113,728
83,132
651,327
1,581,818

92,275
66,055
10,545
507
49,944
108,581

11,560,629

1,860,850

26,896,446

10,209,527

7,651,031

44,516,568

3,492,459

3,312,059
4.449,635
83,951
613,857
6,000
324,504
71,529

434,341
1,053,953
12,762
113,738
0
14,281
15,398

6,440,710
12,740,197
236,469
1,743,777
13
363,377
269,431

2,700,503
4,186,762
118,449
1,225,133
0
424,646
86,357

1,963,416
3,296,719
32,946
429,459
0
83,228
62,223

9,205,343
19,950,209
259,815
2,231,959
132,178
1,541,031
286,280

618,707
1,755,600
20,575
196,181
0
24,617
31,656

8,861,535

1,644,473

21,793,974

8,741,850

5,867,991

33,606,815

2,647,336

3,930,937
4,930,598
1,152,410
241,245
57,039
174,566
170,235

499,604
1,144,869
39,730
11,480
911
393
19,896

7,840,534
.13,953,440
2,207,767
22,759
44,419
54,919
623,795

3,399,053
5,342,797
493,858
29,409
4,583
529
110,770

2,283,969
3,584,022
807,042
113,262
13,534
145,288
103,772

11,222,434
22,384,381
4,607,791
876,153
51,345
654,593
1,444,571

744,046
1,903,290
446,498
3,209
26,932
49,944
80,837

10,657,030

1,716,883

24,747,633

9,380,999

7,050,889

41,241,268

3,254,756

134,829

14,300

43,214

61,985

165,750

264,275

20,490

0
168,400
256,359
336,045
7,966
768,770

0
34,319
40,273
48,443
6,632
129.667

0
399,990
883,587
793,428
28,594

0
92,835
150,144
183,721
7,692
434,392

927
505 013
1,197,340
1,241,993
65,752

0
30 390
88,087
91,922
6,814

2,105,599

500
148,030
193,885
413,918
10,210
766,543

3,011,025

217,213

11,560,629

1,860,850

26,896,446

10,209,527

7,651,031

44,516,568

3,492,459

27

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises. . .
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets

$ 1,647,826
483,720
4B3.555
1,172,423
6,497
13.064
182,395
455.740

$

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
Deposits of commercial banks
Certified and officers' checks
Total deposits
Total demand deposits
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital




Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)
South
Carolina
Number of banks

South Dakota

Tennessee

Texas

Utah

Vermont

19

32

73

604

12

13

$ 477,098
223,307
77,806
374,246
208
3,795
26.158
164,507

$ 222.735
120,899
50,895
309,930
5,504
2,735
0
24,087

$ 1,238,072
975,425
306,549
832,831
15,546
13,886
14,387
330.092

$ 7,056,556
4,071,305
1,444,005
6,514,564
103,274
61,090
84,036
2,327,683

1,798,449
19,421

1,556,917
14,495
1,542,422

5,073,396
61,621

27,037,142
289,748
26,747,394

$ 314,049
169,218
59,988
209,200
1,073
2,952
1,399
160,935
1,780,015
15,061
1,764,954

$ 35,957
32,052
4,548
62,146
3,361
820
0
8,165
339,720
2,811
336,909

44,514
205,986
42,724
47
3,574
235,620

3.270,174

2,322
43,171
2.033
0
399
33,000
2,360,132

1,340,455
1,077.183
32,613
211,778
0
41,931
25,343

501,862
1,344,656
14.786
196,783
0
26,546
13,717

2,729,303

2,098,350

1,573,618
1,155,685

Virginia
102

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises...
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Totalassets

1,779,028
13,983
79,047
5,403
0
867
44,721

5,011,775

9,271,028

$ 1,460,944
764,118
323,544
1,310,133
8,282
17,90713.032
543.409
6,695,769
65,349
6,630,420

160,590
923,338
72,283
44,778
647,267
700,465
50,958,628

20,933
38,421
1,131
0
87
36,826

116
10,240
441
0
0
4,324

8,522
287,334
26,276
12
4,191
163,281

2,781,166

499,079

11,561,381

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
Deposits of commercial banks
Certified and officers' checks
Total deposits
Total demand deposits
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures

2,262,977
4,168,924
67,041
874,902
0
479,962
43,026
7,896,832

13,777,330
17,552,175
401,782
5,908,544
14,080
2,696,240
380,004

645,233
1,298,967
17,778
305,135
0
48,226
26,773

90,671
331,207
4,194
21,999
0
1,674
6,775

2,971,046
5,616,354
95,244
963,737
483
140,162
83,863

40,730,155

2,342,112

456,520

9,870,889

2,964,105
4,932,727

17,434,626
23,295,529

3,503,207
6,367,682

557,568
18,523
7,560
3,574
128,727

4,553,440
267,156
107,132
647,402
828,421

775,674
1,566,438
212,367
3,901
128
87
35,818

109,086
347,434

224,998
25,362
813
867
34,992

583,465
1,514,885
44,332
1,345
2,266
399
27,469

2,908
1,203
14
0
2,615

587,905
63,459
47,723
4,191
151,223

3,016,335

2,174,161

8,612,784

47,133,706

2,594,413

463,260

10,725,390

7,600

22,331

32,075

270,010

46,759

3,416

46,332

0
41,861
81,076
120,815
2,487

0
40,659
45,482
73,595
3,904

133
803,237
956,270
1,615,018
180,254

0
35,453
58,887
45,514
140

0
7,392
9,399
14,645
967

246,239

163,640

0
143,919
214,777
252,514
14,959
626,169

3,554,912

139,994

32,403

0
164,875
269,252
342,129
13,403
789,659

3,270,174

2,360,132

9,271,028

50,958,628

2,781,166

499,079

11,561,381

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital.



Table B-18—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
United States and other areas, June 30, 1978
(Dollar amounts in thousands)

20

106

128

46

District of
Columbia
non-national*
1

$ 1,953,658
438,506
168,550
993,451
14,973
12,479
101,100
603,072
8,624,738
84,646
8,540,092

$ 435,828
419,271
348,917
749,735
11,600
6,482
294
176,493
2,441,178
24,614
2,416,564

$ 1,089,462
733,331
282,642
872,393
51,815
11,661
39,918
235,495
5,435,720
52,632
5,383,088

$ 191,378
137,579
68,775
235,897
2,611
1,786
0
31,905
1,001,849
9,086
992,763

$ 3,467
18,729
6,354
3,369
2,213
1
0
6,100
21,026
278
20,748

331 529
294,087
11,546
25,786
199,503
226,948
13,915,280

11 915
117,803
2,075
0
0
41,565
4,738,542

38 863
205,879
106,905
879
39,221
145,182
9,236,734

2 306
34,408
1,118
56
0
26,009
1,726,591

0
587
0
0
0
713
62,281

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
Deposits of commercial banks
Certified and officers' checks
Total deposits

3,659,946
5,608,709
84,144
1,211,237
15,436
289,586
141,335
11,010,393

1,021,665
2,614,431
39,973
220,685
0
70,924
43,621
4,011,299

1,916,888
4,317,287
95,545
751,409
7,738
278,819
78,924
7,446,610

437,575
770,298
48,349
203,464
5
29,418
15,084
1,504,193

20,755
30,337
1,899
4,952
0
54
518
58,515

Total demand deposits
Total time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Mortgage indebtedness
Acceptances executed by or for account of this bank and outstanding
Other liabilities
Total liabilities

4 273 244
6,737,149
1,527,008
51 943
17,969
199,503
201,967
13,008,783

1 254 663
2,756,636
246,237
18 521
7,250
0
43,533
4,326,840

2 459 289
4,987,321
915,651
35 749
3,665
39,263
151,537
8,592,475

554 115
950,078
46,476
18 531
3,614
0
17,081
1,589,895

28 158
30,357
0
0
0
0
323
58,838

108,447

7,404

54,807

8,464

90

6,000
199,121
238 809
328,332
25,788
798,050

0
70,214
144,683
178,667
10,734
404,298

0
142,558
222 616
209,774
14,504
589,452

0
10,358
41 510
72,536
3,828
128,232

0
278
1 000
2,075
0
3,353

13,915,280

4,738,542

9,236,734

1,726,591

62,281

Washington
Number of banks

West Virginia

Wisconsin

Wyoming

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 bonds, notes and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell
Loans, total (excluding unearned income)
Reserve for possible loan losses
Loans, net of reserve
Direct lease financing
Bank premises, furniture and fixtures and other assets representing bank premises. . .
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers'liabilities to this bank on acceptances outstanding
Other assets
Total assets
Liabilities

Subordinated notes and debentures

L

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital

Non-national banks in the District of Columbia are supervised by the Comptroller of the Currency.



TableB-19

en

Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)
Total,
United States
Number of banks

Alabama

Arkansas

Arizona

Alaska

California

Colorado

69

53

137

$ 967
495
189
528
18

$ 627
272
177
606
25

$ 14,555
4,688
2,763
5,541
618

1,653
476
155
866
15

287

1,230

1,080

13,611

1,512

44
809
7

169
4,542
41

268
2,780
25

3,879
62,387
698

801

4,501

2,755

61,690

367
5,149
55
5,094

10
63
3
22

20
167
4
115

9
109
4
79

1,947
1,834
75
8,738

57
178
20
175

1,409

7,172

4,931

106,330

9,057
2,783
3,384
32
688
568
104

4,564

99

6

102,603
45,285
21,308
66,564
7,345

$ 1,125
435
336
1,286
63

178
66
58
160
3

140,502

2,120

30,996
394,671
4,566

236
5,445
63
5,382
29
182
9
153
9,236

Assets

Cash and due from depository institutions
U.S. Treasury securities
Obligations of other U.S. government agencies and corporations..
Obligations of states and political subdivisions
All other securities
Total securities
Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans
Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets..

390,105
5,561
11,930
1,456
39,132
722,285

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
All other deposits
Certified and officers' checks
Total deposits in domestic offices

175,356
294,707
2,078
45,689
35,909
7,229
560,968

2,446
4,195
31
769
315
69

474
416
6
222
5
19

2,120
3,586
28
316
71
108

1,357
2,160
7
385
218
27

24,073
49,252
316
4,452
3,747
1,294

7,825

1,142

6,230

4,154

83,134

7,559

Demand deposits
Time and savings deposits..
Federal funds purchased and securities sold under agreements to repurchase.
Interest-bearing demand notes issued to U.S. Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities

220,593
340,375
64,908
7,764
5,499
1,232
29,642

2,987
4,838

535
607

1,712
2,441

383
78
89
5
147

83
16
10
12
24

2,411
3,820
338
58
1
12
86

271
26
19
12
66

28,143
54,990
8,583
823
1,483
237
5,718

3,520
4,039
566
87
45
34
144

670,013

8,527

1,237

6,725

4,547

99,978

8,434

3,065

47

82

28

322

38

0
1,024
2,314
2,692

Subordinated notes and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits and reserve for contingencies and other capital reserves .
Total equity capital

29
9,912
17,291
21,976

0
118
249
296

0
32
42
47

0
43
121
200

0
76
98
182

49,207

663

121

364

356

6,030

0
111
187
288
586

Total liabilities, subordinated notes and debentures and equity capital.

722,285

4,931

106,330

9,057

* See note at end of table.




9,236

1,409

7,172

Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)

Connecticut
Number of banks

District of
Columbia

Delaware

Georgia

Florida

Idaho

Hawaii

19

5

16

236

64

2

6

$ 856
201
109
313
39

$ 8
9
2
3

$ 897
461
165
714
40

$ 3,115
2,363
1,179
2,229
183

$ 2,060
480
202
660
68

$ 21
15
17
1

662

14

1,380

5,954

1,410

33

$ 398
288
67
323
8
686

Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans

220
2,113
23
2,090

6
49

346
3,406
39
3,367

1,090
9,784
112
9,672

898
4,930
68
4,862

8
89
1
88

180
1,976
18
1,958

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

9
70
8
338
4,252

0
1

28
72
3
115

52
442
61
511

8
2
1
2

34
68
2
49

79

6,209

20,896

54
248
128
303
9,964

162

3,376

1,428
1,578
12
260
230
29

18
48

6,475
8,706
52
1,303
698
247

3,095
2,824
35
765
534
119

52
66

1

2,044
2,300
134
76
303
83

3,536

71

4,941

17,480

7,372

150

814
1,715
5
209
8
30
2,782

1,755
1,781
290
140
6
10
34

20
51
0

1

2,468
2,473
564
88
30
13
109

7,817
9,663
1,368
121
88
16
281

4,042
3,330
1,407
60
111
42
288

58
92
0
1
0
0
1

4,015

72

5,744

19,353

9,281

153

936
1,846
251
37
1
4
78
3,154

12

33

57

2

22

66
137
251
453

1
354
587
568
1,510

0
159
226
241

0
4
3
1

222

0
2
2
3
6

626

8

0
38
144
18
200

4,252

79

6,209

20,896

9,964

162

3,376

Assets

Cash and due from depository institutions
U S Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities

49

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
All other deposits
Certified and officers' checks
Total deposits in domestic offices
Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Interest-bearing demand notes issued to U.S. Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities
Subordinated notes and debentures

4

15

27
2
4

Equity Capital

Preferred stock
Common stock
Surolus
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital
' See note at end of table.




0
49
109
64

Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)
Kansas

Iowa

Indiana

Illinois

Louisiana

Maine

419

121

99

151

79

54

17

$ 7,097
3,484
2,692
6,165
691
13,032

$ 1,937
1,366
660
1,607
222

$ 809
357
225
645
27

$ 822
469
140
675
24

3,855

1,254

$ 875
557
283
687
37
1,564

1,308

$ 1,326
1,198
295
1,003
18
2,514

$ 150
58
67
163
2
290

1,852

Number of banks

821
8,342
87

266
3,190
27

4,836
52
4,784

42
744
7

3,163

410
3,796
35
3,761

664

8,255

365
3,172
30
3,141

146
260
36
634

4
127
4
79

29
181
18
165

0
28
1
15

6,161

98
127
4
80
6,609

9,681

1,263

Assets

Cash and due from depository institutions
U S Treasury securities
Obligations of other U S government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities

Kentucky

. .

Federal funds sold and securities purchased under agreements to resell

35,811
420
35,391

Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans

737

155
742
245
2,753
61,267

15,944

5
90
6
115
5,708

Demand deposits of individuals partnerships and corporations
Time and savings deposits of individuals, partnerships and corporations
Deposits of U S government
Denosits of states and oolitical subdivisions
All other deoosits
Certified and officers' checks

12,516
24,226
132
2,861
4,401
390

3,437
7,017
35
1,821
380
128

1,350
2,783
13
319
289
34

1,551
2,420
14
759
338
39

1,801
2,986
15
390
324
42

2,777
3,491
49
1,216
360
84

303
648
3
111
6
10

Total deposits in domestic offices

44,526

12,818

4,788

5,121

5,558

7,976

1,080

Demand deoosits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
intprpqt.hparjnri dpmand notes issued to U S Treasurv
Othpr liabilities for borrowed monev
.
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities

15,666
28,859

4,600
8,218

2,075
3,045

8,256
1,157
499
37
2,520

1,470
177
42
22
302

1,730
3,058
373
37
17
9
79

398
64
18
1
57

2,218
3,340
367
84
15
20
95

3,419
4,557
711
39
35
32
143

358
722
67
14
1
5
11

56,995

14,831

5,303

5,659

6,139

8,935

1,177

113

34

31

25

13

32

2

7
792
1,695
1,665

200
387
492

0
64
96
214

0
96
157
224

4,159

1,079

374

477

0
77
135
244
457

2
118
238
356
714

0
20
24
39
84

61,267

15,944

5,708

6,161

6,609

9,681

1,263

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets
Liabilities

Suhorriinatpd notps and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital
* See note at end of table.




. .

Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)
Maryland
Number of banks

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

34

73

125

205

37

101

56

$ 738
337
82
629
15

$ 2,133
1,638
205
807
176

$ 3,541
1,774
462
2,667
194

$ 2,233
755
591
1,828
345

$ 638
350
139
588
24

$ 2,610
549
384
1,180
87

$ 263
150
56
333
11

1,063

2,826

5,097

3,519

1,101

2,200

550

293
3,713
35
3,678

556
6,877
99
6,778

1,774

528
8,666
82
8,584

106
2,440
26
2,414

1,820
5,878
67

73
1,533
14

5,811

1,519

125
394
33
954
26,071

171
188
34
478
15,734

1
99
4
64

69
172
14
247

4,427

12,944

5
45
1
31
2,487

Assets

Cash and due from depository institutions
U S Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities
Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans
. . . .
Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

47
113
8
278
6,217

153
253
22
1,556
14,276

14,292
138
14,154

Liabilities

3,778
4,773
43
707
779
175
10,254

5,650
12,008
82
2,425
586
629

3,569
6,589
34
1,022
792
104

1,082
1,879
7
616
217
14

3,110
3,855
52
640
1,342
69

609
1,298
5
201
52
23

21,379

12,109

3,816

9,068

2,188

7,221
14,158
1,700
412
54
42
653
24,240

4,590
7,519
1,343
326
256
8
526
14,567

1,421
2,395
213
30
2
19
44

4,549
4,519
2,275
242
77
40
422

737
1,451
59
11
1
5
39

5,811

4,999
5,255
1,884
285
56
25
693
13,197

4,123

12,125

2,302

4

36

113

143

16

31

18

Preferred stock
Common stock
Surplus...
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital

0
64
119
220

0
168
422
452

0
339
640
738

0
47
233
8

2
144
230
413

403

1,042

1,717

0
296
326
402
1,024

288

789

0
66
66
35
167

Total liabilities, subordinated notes and debentures and equity capital

6,217

14,276

26,071

15,734

4,427

12,944

2,487

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
All other deposits
Certified and officers' checks
Total deposits in domestic offices
Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Interest-bearing demand notes issued to U.S. Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities
Subordinated notes and debentures

1,610
2,736
17
301
108
41
4,813
1,885
2,928
584
129
41
25
220

Equity Capital

CJi

* See note at end of table.




Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)

Nebraska
Number of banks
Assets

Cash and due from depository institutions
U.S. Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities
Federal funds sold and securities purchased under agreements to resell

New
Hampshire

595

49
1,146

North
Carolina

New Mexico

39

96

40

124

27

$ 256
198
100
202
3

$ 207
145
16
172
4

$ 372
246
121
362
7

337

14,988
3,970
839
3,861
1,644
10,314

1,955
600
404

503

$ 2,321
1,600
1,084
2,766
332
5,781

32

485

10,671
111
10,560
116
346
60
334

152
1,618
17
1,600

42,707
748

574
6,638
74

41,960

6,565

2
82
4
39

582
974
277

90
242

11,585

117
$ 923
285
217

New York

New Jersey

Nevada

423

736

2,119

1,371
140
2,515

Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans

3,092
33
3,059

1,141
12
1,129

946
9
937

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

43
88
3
83
5,767

76
47
0
22
2,057

33
1
15
1,562

20,004

2,986

82,797

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
All other deposits
Certified and officers' checks

1,442
2,527
9
352
426
32

11
505
48
29
2,584

55,570

Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Interest-bearing demand notes issued to U.S. Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities

1,977
2,810
409
45
16
11
70

993
1,591
106
22
8
17
37

26,380
29,190
9,618
344
910
39
8,443

4,483
5,462

5,338

5,226
9,785
56
1,560
266
215
17,108
6,272
10,836
992
190
66
7
280
18,643

16,749
24,754
201
1,953
10,878
1,035

4,787

421
762
6
139
19
15
1,361
530
831
38
21
2
4
16
1,441

847
1,144

Total deposits in domestic offices

705
873
5
157
4
27
1,771
783
988
43
22
33
8
21
1,898

28

0

Liabilities

Subordinated notes and debentures
Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital
* See note at end of table.




77
104
220
401
5,767

3,872
4,782
40
824
361
66
9,945

1,117
158
24
73
442

2,773

74,925

11,760

61

20

353

134
0
169
258
385
811
12,706

2
287
455
556

2
58
79
55

160

0
16
47
56
118

1,300

193

1
1,815
2,360
3,343
7,519

2,057

1,562

20,004

2,986

82,797

0
28
44
88

18
747
12,706

Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)

North Dakota

Oklahoma

Ohio

Pennsylvania Rhode Island

Oregon

South
Carolina

43

217

191

6

226

5

18

$ 200
114
53
264
7

$ 3,848
2,353
847
4,110
169

$ 1,094
295
75
937
56

$ 524
192
102
400
31

7,479

1,363

$ 5,785
3,254
2,253
4,258
1,268
11,033

$ 327
353
107
402
49

438

$ 1,742
1,025
95
1,611
108
2,839

911

725

1,162

747

219

1.785

105

254

14,908
167
14,741

5,894
62
5,832

4,805
40
4,765

26,260
296
25,964

2,146
19
2,127

1,839
21

Net loans

31
1,217
10
1,206

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

1
38
2
27
1,943

170
490
15
1,355
29,260

30
175
9
163
11,535

35
165
9
642
8,292

278
565
84
2,703
48,198

94
68
8
182
3,820

15
86
4
34
3,461

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
All other deposits
Certified and officers' checks
Total deposits in domestic offices

497
1,097
4
96
20
16

7,400
13,393
92
1,828
494
273

3,118
4,575
43
1,247
567
145

2,083
3,653
13
662
105
73

10,145
20,812
86
2,476
1,536
348

646
2,011
5
210
22
25

1,427
1,132
7
197
47
28

1,730

23,480

9,694

6,589

35,403

2,919

2,837

Demand deoosits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase
Interest-bearing demand notes issued to U.S Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities

557
1,173
23
6
3
4
25
1,791

8,815
14,665
2,453
466
53
45
528

3,969
5,725
560
176
67
5
154

1,631
1,206
207
81
15
5
44

10,655

11,952
23,451
4,898
422
714
52
3,347
44,834

749
2,170
353
57
59
27
161

27,026

2,404
4,185
561
117
69
14
352
7,702

3,575

3,190

16

41

73

141

252

20

13

Preferred stock
Common stock
Surplus
.
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital

0
35
41
61
137

0
403
894
895
2,193

1
150
199
458
807

0
92
149
207
449

1
505
1,202
1,403
3,111

0
30
88
106
225

0
41
81
136
258

Total liabilities, subordinated notes and debentures and equity capital

1,943

29,260

11,564

8,292

48,198

3,820

3,461

Number of banks
Assets

Cash and due from depository institutions
U S Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities
Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses

1,818

Liabilities

Subordinated notes and debentures
Equity Capital

<*

* See note at end of table.




Table B-19—Continued

en
oo

Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)
Virginia

Washington

South Dakota

Tennessee

32

72

609

10

13

88

20

Cash and due from depository institutions
U S. Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities

$ 258
104
61
314
8
487

$ 1,417
875
357
912
39

$ 485
173
62
224
4

$ 46
29
7
64
6

2,183

$ 8,837
3,899
1,478
7.Q97
229
12,703

463

106

$ 1,458
649
383
1,403
43
2,478

$ 2,084
382
196
1,077
52
1,707

Federal funds sold and securities purchased under agreements to resell
Total loans Excluding unearned income)
Allowance for possible loan losses
Net loans
,

38
1,634
15
1,619

444
5,280
67
5,214

2,849
29,454
322
29,132

138
1,808
16
1,791

10
361
3
358

438
6,811
68
6,742

1,023
9,284
96

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

2
48
2
33
2,487

50
212
37
253

174
979
63
1,751

40
38
2
41

56,489

2,999

5
537

416
315
12
626

9,809

31
295
20
191
11,653

15,372

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
All other deposits
Certified and officers' checks

561
1,437
9
170
28
18

2,543
4,271
37
884
492
50

15,681
19,394
161
5,880
3,108
524

698
1,414
4
333
28
29

98
345
1
34
1
7

3,101
5,505
28
908
97
76

3,986
6,090
38
1,293
272
150

Total deposits in domestic offices

2,223

8,277

44,749

2,506

487

9,715

11,829

Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase.
Interest-bearing demand notes issued to U S Treasury
Other liabilities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities

640
1,583
27
8

3,247
5,031
578
54
19
13
178
9,121

19,822
24,927

805
1,701

115
372

3,468
6,247

5,122
461
224
111
1,732

208
32
2

2
4
4

52

3

647
107
83
61
193

4,534
7,295
1,771
217
66
27
507

52,399

2,802

500

10,806

14,417
108

Number of banks

Utah

Texas

Vermont

Assets

10

9,189

Liabilities

2,296

Total liabilities
Subordinated notes and debentures

5
32

....

22

31

311

46

3

50

0
43
48
78

4
825
1,025
1,926

0
35
64
52

3,780

151

0
8
10
17
34

0
159
270
369
797

6
199
240
401
846

56,489

2,999

537

11,653

15,372

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits and reserve for contingencies and other capital reserves
Total equity capital

170

0
144
224
289
657

Total liabilities, subordinated notes and debentures and equity capital

2,487

9,809

* See note at end of table.




Table B-19—Continued
Total assets, liabilities and equity capital of domestic offices and subsidiaries of national banks,
December 31, 1978
(Dollar amounts in millions)
West Virginia
Number of banks

Wisconsin

Wyoming

District of
Columbia
non-national*

106

129

46

1

Cash and due from depository institutions
U.S. Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions
All other securities
Total securities

$ 514
381
358
743
18
1,500

$ 1,111
735
315
967
124

$ 220
137
78
246
5

2,141

466

B3
18
6
3
2
29

Federal funds sold and securities purchased under agreements to resell
Total loans (excluding unearned income)
Allowance for possible loan losses
Net loans

180
2,587
26

398
5,794
56

1,028
10

25

2,561

5,738

1,018

25

Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
All other assets
Total assets

11
122
1
45
4,936

41
217
74
178

2
36
2
28

9,899

1,855

62

1,077
2,691
16
255
91
34

2,205
4,499
22
617
300
84

17
31

4,164

7,728

505
826
27
244
26
14
1,643

49

1,288
2,876
246
18
23
8
47

2,689
5,039

615
1,027

18
31

1,095

27
7
9
4
20
1,709

58

83

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
All other deposits
Certified and officers' checks
Total deposits in domestic offices
Demand deposits
Time and savings deposits
Federal funds purchased and securities sold under agreements to repurchase....
Interest-bearing demand notes issued to U.S. Treasury
Other liabijities for borrowed money
Mortgage indebtedness and liability for capitalized leases
All other liabilities
Total liabilities .

4,506

Subordinated notes and debentures

190
32
7
178
9,230
55

Equity Capital

Preferred stock
Common stock
Surplus
Undivided profits and reserve for contingencies and other capital reserves .
Total equity capital
Total liabilities, subordinated notes and debentures and equity capital.
CD




0
70
151
201

0
145
229
241

423

614

137

9,899

1,855

4,936

*Non-national banks in the District of Columbia are supervised by the Comptroller of the Currency.
NOTE: Dashes indicate amounts of less than $500,000. Data may not add to totals because of rounding.

0
10
44
83
62

Table B-20
Domestic office loans of national banks, by states, December 31, 1978

(Dollar amounts in millions)
Total
loans,
gross
All national banks

Loans
secured
by real
estate

Loans to
financial
institutions

Loans to
purchase
or carry
securities

Loans to
farmers

$404,384
5,692
838
4,787
2,857
63,882
5,246
2,154
51
3,457
10,138

$117,198
1,593
333
1,387
964
23,601
1,295
804
29
1,172
3,723

$27,057
112
1
269
27
5,395
194
128
0
487
340

$7,984
27

$13,430
102

150
71
844
87
2
0
22
58

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

5,164
91
2,018
36,253
8,611
3,223
3,233
3,933
5,005
753

1,289
47
599
7,290
3,511
968
642
1,266
1,483
306

243
0
30
4,039
302
38
73
90
171
2

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

3,812
6,990
14,598
8,790
2,536
5,976
1,612
3,150
1,197
984

1,407
1,388
5,749
2,542
831
1,398
447
422
569
365

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

11,027
1,685

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

South Carolina
South Dakota
Tennessee

Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Commercial Personal
and indusloans to
trial loans
individuals

Other
loans

Total loans
less unearned
income

$394,671
5,445
809
4,542
2,780
62,387
5,149
2,113
49
3,406
9,784

337
144
2,028
499
13
1
1
70

$134,648
1,740
286
1,069
808
17,903
1,654
655
6
954
2,418

$93,273
1,959
212
1,458
773
12,912
1,392
514
16
717
3,315

$10,794
159
6
118
71
1,200
125
39

33
0
6
1,592
64
55
93
21
66

44
1
221
984
254
664
680
148
62
9

1,707
17
573
15,726
2,015
779
844
1,084
1,798
217

1,726
26
579
5,447
2,328
662
832
1,258
1,296
213

123
10
1,175
137
56
68
65
129
7

4,930
89
1,976
35,811
8,342
3,190
3,172
3,796
4,836
744

155
749
855
374
60
485
3
70
4
4

42
44
89
342
35
179
1
102
4

26
50
130
550
66
267
233
1,039
18
2

893
3,312
3,729
3,106
631
2,060
414
711
257
286

1,192
1,287
3,477
1,566
854
1,401
495
754
340
317

98
159
568
310
60
185
18
51
5
9

3,713
6,877
14,292
8,666
2,440
5,878
1,533
3,092
1,141
946

15,537
6,014
4,863
26,985
2,183

4,856
430
7,125
1,226
338
5,184
1,453
1,612
8,354
855

322
25
4,764
392
2
485
191
492
2,794
100

24
3
1,946
79
3
101
188
39
440
9

123
276
103
227
227
608
193
199

2,843
522
20,340
2,553
376
4,053
2,020
1,501
8,499
831

2,829
564
6,900
2,375
284
5,265
1,406
978
5,952
331

145
18
2,007
158
11
222
147
49
746
58

10,671
1,618
42,707
6,638
1,217
14,908
5,894
4,805
26,260
2,146

1,916
1,676
5,484
30,071
1,842
370
7,110
9,341
2,791
5,906
1,065

390
434
1,545
5,901
795
191
2,751
2,456
1,226
2,348
308

21
2
172
1,663
31
1
97
486
11
305
2

26
455
92
1,372
47
7
97
442
12
145
130

579
408
1,723
12,667
561
85
1,620
3,296
482
1,693
343

860
360
1,725
6,372
371
80
2,356
2,422
1,016
1,244
265

33
13
134
1,286
23
6
159
169
34
93
13

1,839
1,634
5,280
29,454
1,808
361
6,811
9,284
2,587
5,794
1,028

3,482

1,187

489

960

719

104

3,431

43,360
6,885
1,241

4
92
811
15
29
70
9
79
4

104
213

District of Columbia—

air

22

* Includes national and non-national banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.
NOTE: Dashes indicate amounts of less than $500,000. Data may not add to totals because of rounding.

160




Table B-21
Outstanding balances, credit cards and related plans of national banks, December 31, 1978
(Dollar amounts in thousands)
Credit cards and
other related credit plans

Total
number
of
national
banks
All national banks . . .
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia

Outstanding
volume

Number of
national
banks

4,564
99
6
3
69
53
137
19
5
16
236
64

1,850
19
4
2
10
43
103
11
0
12
95
28

$17,542,357

Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada

2
6
419
121
99
151
79
54
17
34
73
125
205
37
101
56
117
4

2
4
160
72
35
19
38
13
15
15
57
72
122
3
40
24
28
3

2,903
64,980
1,447,174
218,627
71,107
92,857
129,382
127,855
26,596
327,021
298,003
646,927
121,817
54,633
361,892
10,686
194,962
42,569

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

39
96
40
124
27
43
217
191
6
226
5

27
65
8
60
25
15
145
29
3
59
4

29,751
244,970
34,819
3,313,988
339,128
8,000
659,831
170,613
210,313
789,692
66,045

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

18
32
72
609
10
13
88
20
106
129
46

10
8
14
135
4
2
37
12
19
100
20

118,865
4,389
219,817
656,793
66,309
4,053
348,025
454,334
42,857
251,967
7,381

17

13

148,893

District of Columbia — all*

153,455
31,368
251,459
50,085
3,417,638
319,791
125,588
0
148,769
423,861
338,412

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




161

Table B-22
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)
Total,
United States
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in.the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses

Alabama

Arizona

Alaska

Arkansas

California

Colorado

4,564

99

6

3

69

53

137

$45,997.7
4,407.3

$530.2
1.6

$92.8
1.1

$403.5
6.4

$252.3
0.8

$8,212.7
1.058.1

$524.3
0.5

2,197.8

20.7

3.5

26.4

23.7

298.6

22.9

4,721.6
3,252.1
693.2
639.4
1,214.8
1,089.5
1,932.2
1,696.9

56.9
65.7
2.8
0.9
15.8
20.2
25.9
14.9

47.0
23.9
0.8
1.8
11.3
27.9
11.6
6.9

44.8
43.4
0.7
5.1
21.0
21.2
18.4
21.5

755.7

567.5

32.4
30.8
0.9
1.1
4.3
12.6
9.4
8.1
376.6

474.5
258.4
153.0
166.8
134.8
181.3
334.0
289.8

67,842.4

8.2
9.1
0.3
1.0
1.4
6.0
7.2
1.3
132.0

11,562.0

723.8

10,845.2
7,021.9
10,139.7
12,873.9

139.1
106.9
0
189.5

37.9
17.8
0
17.1

126.4
42.1
0.3
158.9

70.8
37.5
0
108.5

1,866.1
1,158.0
2,603.7
1,927.1

143.0
85.0
1.0
150.4

4,989.6

39.9

5.1

25.3

24.6

594.2

42.5

1,023.1
234.3
3,194.3
2,131.2
6,522.5

1.4
0.1
13.3
2.8
16.0

0.4
5.7
36.4
25.2
58.4

1.7
2.1
25.9
10.0
43.9

136.6
23.1
508.8
336.0
901.7

4.5
2.9
43.4
23.8
104.5

111.4

479.2

325.0

10,055.3

600.8
123.0
35.9
87.1

58,975.8

5.9
3.6
41.2
32.2
95.1
653.4

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net

8,866.6
2,591.0
6,275.6

102.3
15.7
86.6

20.6
5.7
14.9

88.3
32.1
56.2

51.6
8.4
43.3

1,506.7
619.2
887.5

-253.5
-125.2

-0.4
-0.2
-0.2

0.6
0.2
0.4

-2.3
-1.2
-1.1

0.3
0.2
0.1

-55.0
-28.9
-26.1

-0.5
-0.3
-0.2

Income before extraordinary items
Extraordinary items, net
Net income

6,147.3
26.1
6,173.4

86.4
0.1

15.3
0.8
16.1

43.3
0.4
43.7

861.4
2.0
863.4

86.9
0.4

86.5

55.1
0
55.1




-128.3

87.3

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared
Recoveries credited to allowance for possible loan losses .
Losses charged to allowance for possible loan losses
Net loan losses
Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period)
See note at end of table.

CO




2.8
4.1
1.3

17.1
0
17.1
3.7
14.9
11.2

9.6
0
9.6
2.8
9.9
7.1

295.1
0
295.1
83.3
290.9

26.4
5.0
28.7
24.3
84.4

35.5
5.5
22.3
21.1
84.4

49.2
6.5
16.1
15.1
87.0

13.3

15.1

38.8
7.5
18.8
21.2
86.3
12.3

2,194.7
1.4
2,196.1
685.9
2,124.6
1,438.7

30.0
0
30.0

2.0
0

11.2
34.5

44.3
9.2
16.0
17.5
86.9
12.5

39.2
6.5
18.4
22.3
86.5
13.0

23.3

2.0

207.6

14.3

28.1
0
28.1
6.5
21.5
15.0
32.7
6.9
19.8
23.7
83.0
14.9

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)

Connecticut
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses
Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income




District of
Columbia

Delaware

Florida

Georgia

16

19

236

Hawaii

Idaho

64

$200.7
24.4

$4.6
0.1

$318.8
26.6

$900.7
23.5

$527.7
22.4

$9.1
0

$198.1
1.2

5.7

0.4

22.8

91.0

64.8

0.5

5.9

22.9
13.9
2.7
0.9
15.3
3.7
9.6
56
306.4

0.8
0.2
0
0
0
0.1
0.1
0.1
6.3

44.5
31.0
1.6
1.2
17.0
12.7
7.4
3.2

271.0
104.0
12.1
6.0
45.7
45.4
62.9
26.6

44.3
33.5
3.4
5.1
21.5
34.2
22.6
45.8

2.2

24.2
14.7
0.6
1.1
2.2
8.3
7.5
2.2

486.8

1,589.0

69.0
21.0
8.7
69.5

1.2
0.2
0
2.5

93.9
60.7
48.9
74.9

30.4

0

2.0
1.0
22.9
13.7
35.3
273.5
32.8
10.0
22.9
-0.3
-0.2

0.7

825.3

0.4
0.9
0.1
13.8

265.9

295.7
127.2
2.3
419.9

177.2
72.4
17.1
129.5

3.8
2.6
0
2.8

53.8
26.3
0
80.4

37.1

95.4

110.4

0.4
0.2
0.8
5.4

2.2
0.7
27.8
13.6
40.7

5.7
2.3
88.6
59.0
277.7

8.1
5.0
54.5
57.9
130.4

0.1
1.3
0.1
2.4

0.4
1.9
12.5
6.0
30.6

400.4

1,374.0

762.6

13.1

223.0

1.0
0.3
0.6

86.4
30.7
55.7

215.0
52.9
162.1

62.7
8.4
54.3

0.7
0.3
0.4

-1.2
-0.6
-0.6

-7.6
-3.6
-4.0

0.5
0.5

43.0
13:3
29.6
-1.6
-0.8

158.1
4.5
162.6

54.4
0.1

0.4
0.3

28.9
0

54.5

0.7

28.9

-0.1
22.7
0.4

0.7
0

55.1

23.1

0.7

55.1

11.2

-0.8

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared

10.2
0
10.2

Recoveries credited to allowance for possible loan losses
Losses charged to allowance for possible loan losses
Net loan losses ..

. . .

Ratio to total operating income:
Interest on deposits :
Other interest expense
Salaries and employee benefits .
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period)
See note at end of table.

Ol




0.2
0
0.2

20.8
0.1
20.9

82.0
0.1
82.1

14.7
0
14.7

—

9.1
0

—

9.1

5.2
14.9
9.7

0.1
0.3
0.2

4.7
12.5
7.8

17.1
62.7
45.6

11.4
71.3
59.9

0.3
0.4
0.1

2.7
6.3
3.6

32.4
10.9
22.5
23.5
89.3
10.4

42.8
1.0
18.5
22.2
84.5
10.4

37.9
8.2
19.3
16.9
82.3
12.2

34.6
6.5
18.6
22.8
86.5
10.8

26.5
15.0
21.5
29.4
92.4

39.1
0.7
27.5
27.5
94.8

40.1
5.1
20.2
18.5
83.9
14.5

8.7

L

8.9

s

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)

Illinois
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the US
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income




Indiana

Kansas

Iowa

Kentucky

Louisiana

Maine

419

121

99

151

79

54

17

$3,923.4
536.3

$783.4
24.8

$282.8
1.2

$290.3
0.6

$350.7
3.1

$456.7
6.3

$72.9
0.1

154.9

40.9

22.5

23.5

18.3

41.5

2.2

440.7
313.0
66.4
20.7

42.1
30.8
1.6
0.4
8.2
7.3
18.1
4.0

58.4
33.4
1.9
0.5
7.8
10.1
13.0
4.8

8.2
7.9

8.1

1,201.1

418.9

444.2

17.9
23.5
5.8
718.1

2.8
2.2
3.3
1.3

5,910.0

44.9
35.9
0.9
8.0
4.3
9.3
17.2
5.2
497.9

105.0
48.5
1.6
3.0

147.1
149.0

150.8
82.0
15.6
11.0
25.9
22.8
27.6
16.4

101.0

199.0

75.9
45.5
0
134.2

88.3
49.8
5.8
140.6

121.0
122.7
4.3
148.6

22.6
6.9
0
33.3

112.2
46.1

0.1
0

709.3
833.9
1,110.7
989.6

7.9
363.8

66.0
26.7
0
154.4

690.6

106.0

27.9

30.9

24.1

498

4.2

61.6
8.8
209.5
207.1
416.5

6.0
3.0
69.2
31.5
124.4

0.9
2.4
19.3
8.8
50.9

2.3
2.0
24.9

2.3
1.1
30.2

11.3
47.8

15.2
57:6

2.0
2.4
47.4
23.4
78.0

5,237.7

1,024.8

357.3

374.9

415.1

672.2
161.1
511.1

176.3
38.0
138.3

61.6
13.9
47.7

69.3
15.7
53.6

82.8
19.2
63.6

599.5
118.6
28.9
89.7

0.2
0.2
7.3
4.9
13.0
92.5

-15.5
-7.1

-1.6
-0.8

-1.6
-0.6

-2.5
-1.2

-4.6
-2.2

-0.5
-0.2

-8.4

-0.3
-0.1
-0.2

-0.8

-0.3

138.1
0.2

46.9

-1.3
62.3
-0.1

-2.4

502.7
1.3

-0.9
52.7
0.9

8.1
0

504.0

138.3

46.9

53.6

62.2

87.3
0.8
88.2

114.0

8.5
0.1
8.4

8.1

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared
Recoveries credited to allowance for possible loan losses .
Losses charged to allowance for possible loan losses
Net loan losses
Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period)
See note at end of table.




139.4
0.1
139.5
41.3
207.6
166.3

51.8

49.6
12.9
12.0
14.1
88.6
12.1

40.4
9.6
16.6
18.7
85.3
12.8

51.8
9.4
30.7
21.6

2.2
7.4

16.8
0
16.8
5.1
12.7

5.2

7.6

13.2
3.7
13.8
10.1

43.2
7.4
15.8
18.9
85.3
12.5

40.5
7.9
17.1
18.9
84.4
11.2

39.4
5.5
17.7
20.7
83.4
13.6

14.5
0
14.5

13.2
0

25.5
0.1

4.5
0

25.6

4.5

8.1
25.9

1.1
4.8

17.8

5.9

38.4
7.5
16.9
20.7
83.5
12.4

39.8
4.6
22.4
25.0
91.6
9.7

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)

Maryland
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses .
Income before income taxes and securities gains or losses...
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income




Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

34

73

125

205

37

101

56

$370.1
13.5

$1,010.1
215.7

$1,392.5
83.0

$816.1
30.4

$222.3
4.3

$562.4
16.0

$146.5
0.2

25.3

66.4

97.3

32.5

13.2

99.6

3.6

28.4
27.3
0.8
6.1
6.9
12.7
9.4
7.7
508.1

121.9
35.8
36.5
36.3
59.1
17.3
50.8
38.8
1,688.7

158.6
128.8
10.8
5.6
43.7
34.5
30.4
34.9
2,020.1

103.5
89.0
4.1
12.0
29.3
15.4
48.2
39.6

35.0
20.1
1.0
0.2
3.2
9.3
13.3
4.6

15.2
15.8
0.5
0.5
0.4
4.0
6.2
2.7

1,220.0

335.3

68.4
56.4
1.8
5.1
27.3
11.6
31.9
22.8
903.2

195.7

103.3
30.5
19.1
129.6

291.9
143.4
394.1
163.2

357.2
190.6
95.1
619.6

177.0
152.6
42.0
297.7

57.9
48.6
0
89.2

143.9
110.2
19.3
161.0

31.8
14.2
0
71.5

45.3

206.2

88.3

139.2

23.6

169.8

5.4

2.9
0.3
33.0

0.6
0.8
19.8

5.0
1.5

31.3

13.4

136.4
1,048.2
171.8
36.7
135.2

-2.0
-0.9

-4.3
-2.4

40.4
8.4
107.6
45.3
192.3
1,743.7
276.4
59.0
217.4
-10.1
-4.8

20.2
9.5
42.3

57.1
439.9
68.2
18.7
49.5

36.1
2.6
87.8
53.2
153.8
1,532.4
156.3
61.9
94.4

-4.7
-2.2

39.3
293.2
42.1
4.6
37.5
-0.9
-0.4

-1.0

-1.9
92.5
1.6
94.1

-5.2

-2.5

-0.5

212.1
0.9

132.7
1.4
134.1

37.0
0

18.8

48.5
48.5

213.1

37.0

101.2

0.5
1.4
8.2
2.4
23.7

782.2

159.1

121.0
27.1
93.9
-3.3
-1.5
-1.8
92.2
0.1
92.3

"36.5
9.6

46.9
23.4

26.9
-1.0
-0.5
-0.5
26.4
0.2
26.6

92.8
0
92.8

43.7
0_
43.7

12.7
0_
12.7

37.5
0.1
37.6

8.8
0_
8.8

4.8
21.2
16.4

4.0
13.6

9.7
25.0

37.7

18.0
45.0
27.0

9.6

15.3

2.9
3.8
0.9

35.3
9.5
20.3
21.4
86.6

41.5
14.5
17.3
17.5
90.7

44.8
6.8
17.7
17.1
86.3

40.4
13.8
14.5
17.2
85.9

41.1
7.5
17.3
21.6
87.4

32.2
19.5
15.9
19.0
86.6

43.8
3.7
16.2
17.5
81.3

12.0

9.0

12.4

13.1

12.9

11.7

15.9

18.6
0
18.6

41.6

24.2
61.9

Net loan losses

3.5
18.7
15.2

Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period) . . . .

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared
Recoveries credited to allowance for possible loan losses .
Losses charged to allowance for possible loan losses

See note at end of table.

CD




41.6

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)
Nebraska
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income

New
Hampshire

Nevada

New Jersey

New Mexico

New York

North
Carolina

117

4

39

96

40

124

27

$298.2
0.8

$109.2
0

$93.2
0.3

$939.2
14.1

$154.7
1.7

$9,198.4
1,503.9

$656.7
70.1

27.1

3.6

3.0

40.0

11.1

136.0

40.9

33.2
29.8
1.2
3.7
8.3
7.6
19.5
8.3
437.5

20.5
9.6
0.2
6.4
2.9
7.2
2.8
2.2
164.6

10.3
8.9
0.2
2.8
2.6
2.5
1.0
124.8

199.5
127.7
24.0
10.0
22.5
30.3
28.7
23.6
1,459.5

25.7
16.3
0.4
0.3
3.0
6.8
9.5
1.7
231.2

331.6
245.8
261.7
192.0
151.6
55.3
475.7
518.9
13,070.9

70.8
60.7
2.4
10.4
27.8
28.8
24.8
29.5
1,023.0

73.3
33.7
0
132.9

35.9
18.3
0
35.2

26.4
7.6
0
37.7

292.2
106.8
11.7
480.8

43.0
38.6
0
55.6

1,753.2
899.8
4,798.3
896.9

198.7
87.6
74.5
210.5

Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses

29.1

4.5

3.3

72.0

7.5

711.5

89.8

3.4
2.0
26.9
8.9
52.3
362.5

0.3
0
9.3
3.6
19.4
126.4

0.7
0.2
9.3
4.4
21.0
110.6

4.8
4.5
99.0
38.2
170.0
1,279.9

0.7
1.4
16.3
6.6
25.8
195.3

536.2
32.8
484.6
472.0
1,034.3
11,619.8

5.6
10.3
58.2
28.7
107.2
871.1

Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net

75.0
18.5
56.5
-0.3
-0.1
-0.2

38.2
12.0
26.1
-0.4
-0.2
-0.2

14.2
1.9
12.3
-0.2
-0.1
-0.1

179.6
19.7
159.9
-3.2
-1.6
-1.7

35.9
8.9
27.0
—
0

1,451.1
602.2
848.9
-35.1
-17.9
-17.2

1-51.9
40.9
111.0
-10.9
-5.6
-5.3

Income before extraordinary items
Extraordinary items, net
Net income

56.3
0.5
56.8

25.9
0.1
26.0

12.2
0.3
12.5

158.3
0.2
158.5

27.0
0.2
27.2

831.7
0.5
831.3

105.7
1.6
107.3




Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared
Recoveries credited to allowance for possible loan losses
Losses charged to allowance for possible loan losses

17.8
17.8

8.9
0
8.9

4.3
0

71.7
0.1

4.3

71.8

6.9
0
6.9

342.5
342.5

30.5
0
30.5

199.9
522.3
322.4

8.3
27.6
19.3

50.5
9.8
13.4
15.2
88.9
11.1

36.4
10.3
19.4
19.2
85.2

1.2
2.3
1.1

1.0
4.1

11.8
42.1

Net loan losses

4.5
11.3
6.8

3.1

30.3

2.6
7.9
5.3

Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period)

38.1
7.9
16.8
20.1
82.9
14.2

32.5
2.9
21.8
19.6
76.8
16.3

36.3
3.4
21.2
27.8
88.6
10.6

41.1
5.6
20.0
21.0
87.7

40.7
4.2
18.6
21.1
84.5

12.2

14.1

See note at end of table.




13.2

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)

North Dakota
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income




Ohio

Oklahoma

Oregon

Pennsylvania Rhode Island

South
Carolina

43

217

191

6

226

5

18

$110.6
0.4

$1,414.4
78.6

$564.9
3.9

$451.2
30.5

$2,510.1
204.1

$208.5
3.3

$185.1
0.8

3.0

82.9

38.5

14.9

149.0

3.2

14.2

12.9
12.9
0.5
1.0
2.3
4.5
1.1
149.2

221.1
196.7
9.0
1.54
52.6
56.4
55.3
24.3
2,206.6

78.5
73.8
2.9
2.0
12.9
19.7
16.9
18.2
832.1

27.5
45.4
1.0
3.9
12.7
28.2
12.4
9.9
637.6

407.3
211.0
34.7
19.6
97.2
32.7
70.6
120.4
3,856.6

29.7
18.6
1.3
8.0
12.4
3.6
3.7
14.3
306.7

21.3
19.2
0.2
1.2
6.2
14.9
8.8
6.3
278.1

23.4
7.3
0
63.7

387.6
189.6
21.8
627.6

136.2
164.3
2.4
188.6

127.0
60.6
12.9
163.4

601.4
475.3
305.3
883.5

50.1
54.3
12.9
68.3

75.7
10.0
0.3
55.7

2.3

170.9

43.2

45.6

409.4

31.8

19.0

0.8
1.1
6.6
2.7
15.8
123.5

5.3
2.8
120.1
57.8
257.6
1,841.1

3.3
4.8
36.7
32.3
90.4
702.3

5.2
11.2
30.1
12.7
62.3
531.1

57.3
19.2
186.1
120.0
319.9
3,377.4

0.5
1.6
14.0
8.6
32.8
275.0

1.8
0.8
21.7
8.1
39.1
232.1

25.7
6.4
19.3
-0.7
-0.3

365.5
72.3
293.2
-21.1
-10.1
-11.0

129.8
22.3
107.6

106.5
32.1
74.4
-5.7
-2.9
-2.7

479.2
86.9
392.3
-24.9
-11.7

31.7
5.3
26.4

46.0
12.0
34.0

-1.2
-0.6

-0.6
-0.3

-13.1

-0.6

-0.3

282.2
0.5
282.7

106.2
0.7

71.7
0
71.7

379.2
—
379.1

25.9
0
25.9

33.7
0.1
33.8

-0.3
19.0
—
19.0

-2.3
-0.9
-1.4

106.9

156.2

28.9

28.2
0
28.2

20.5
62.3
41.8

10.5
30.9
20.4

3.3
8.0
4.7

47.6
2.8
15.7
16.8
82.8

38.0
8.1
17.6
19.7
83.4

42.7
6.2
16.4
19.2
84.4

37.2
9.7
19.9
16.5
83.3

13.9

12.9

13.2

16.0

117.5

28.9

Total cash dividends declared .

5.7
0
5.7

117.5

Recoveries credited to allowance for possible loan losses
Losses charged to allowance for possible loan losses
Net loan losses
....

0.5
2.3
1.8

Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period)

Cash dividends declared on common stock
Cash dividends declared on preferred stock

See note at end of table.




11.0
0
11.0

1.07
0
1.07

34.1
115.1
81.0

3.1
8.4
5.3

3.4
8.9
5.5

43.1
12.6
15.6
16.2
87.6
12.2

44.2
11.1
16.3
18.1
89.7

23.7
7.8
27.2
24.8
83.5

156.2

11.5

L

13.1

Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)
South Dakota
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses
Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income




Tennessee

32

72

$148.9
0.4

Texas

Utah

Vermont

Virginia

Washington

609

10

13

88

20

$507.0
7.5

$2,883.8
304.9

$187.1
1.5

$32.7
0.1

$676.6
16.8

$945.8
27.7

2.7

35.0

214.5

7.9

1.0

31.4

63.5

12.3
15.9
0.7
0.3
1.1
3.9
6.2
1.6
193.9

89.5
43.3
2.0
5.3

393.4
324.3

2.8
3.0
0.3

74.8
71.5

13.2

95.6
60.5

17.2
10.4
0.3
2.6
3.3
6.8
8.4
1.5

0.3
0.8
0.8
0.5

13.7
27.8
15.2

42.9
51.7
2.3
37.7
23.4
43.7
31.2
28.1

774.3

4,478.5

247.0

42.4

951.6

1,298.1

30.2
11.7
0

146.8

82.9

206.1

612.4
740.1
425.7
810.7

38.7
50.0
0
51.9

8.9
1.5
0
18.3

171.7
77.9
0.6
286.0

280.6
136.1
55.3
274.1

2.9

51.5

397.7

12.5

0.1

44.3

113.8

0.4
1.8
8.4
5.2
19.3

1.9
2.0
53.3
34.0
93.2

20.1

0.7
4.0
12.7
6.1
31.0

0.1
0.3
2.7
0.9
4.9

5.2
3.9
55.7
28.8
156.5

162.8

684.4

207.7

37.7

830.7

31.1

4.7
0.6
4.1
-0.1

170.4

100.2

118.7

-10.1
-4.9

39.3
13.0
26.3
-2.1
-1.1

120.9
20.7

-0.7
-0.4

90.0
22.4
67.5
-0.9
-0.4

-6.6
-3.2

-1.6
-0.8

-0.3

-0.5

-5.2

-1.0

-0.1

-3.4

-0.8

23.1

67.0
2.7

532.1
3.1

25.3
0

4.1

23.1

69.8

535.2

25.3

4.1

96.8
-0.3
96.5

117.9
0.1
117.9

7.7
23.4

15.6
24.7
31.2

92.7
2.8

17.0
9.6
87.3
87.5

21.1

169.0
127.5
450.0
3,774.3
704.2
166.8
537.4

1.5
3.0
19.3

9.9
10.1
75.9
30.7
141.1
1,127.6

51.8

Recoveries credited to allowance for possible loan losses
Losses charged to allowance for possible loan losses
Net loan losses
Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses

.

Ratio of net income to total equity capital (end of period)
See note at end of table.




160.9

9.6
0
9.6

1.5
0
1.5

35.8
0
35.8

30.9
0.4
31.3

16.6
40.3
23.7

42.6
106.2

1.2
4.4

3.9

Cash dividends declared on common stock
Cash dividends declared on preferred stock
Total cash dividends declared

8.0
0
8.0

23.1
0
23.1

160.7
0.2

1.5
5.4

63.6

3.2

0.2
1.1
0.9

8.5
30.0
21.5

11.9
24.6
12.7

48.8
2.6
15.6
17.0
84.0

39.0
7.2
19.0
23.3
88.4

41.3
7.0
15.7
20.2
84.1

46.7
1.2
21.0
20.0
88.9

38.3
5.6
18.0
25.3
87.3

35.9
10.3
21.6
19.1
86.9

13.6

10.6

44.1
9.8
13.7
16.7
84.3
14.2

16.8

12.1

12.1

13.9




Table B-22—Continued
Income and expenses of foreign and domestic offices and subsidiaries of national
banks, by states, year ended December 31, 1978
(Dollar amounts in millions)

West
Virginia
Number of banks
Operating income:
Interest and fees on loans
Interest on balances with depository institutions
Income on Federal funds sold and securities purchased under agreements to
resell
Interest on U.S. Treasury securities and on obligations of other U.S. government
agencies and corporations
Interest on obligations of States and political subdivisions in the U.S
Income from all other securities (including dividends on stock)
Income from lease financing
Income from fiduciary activities
Service charges on deposit accounts
Other service charges, commissions, and fees
Other operating income
Total operating income
Operating expenses:
Salaries and employee benefits
Interest on time certificates of $100,000 or more, issued by domestic offices
Interest on deposits in foreign offices
Interest on other deposits
Expense of Federal funds purchased and securities sold under agreements to
repurchase
Interest on demand notes issued to the U.S. Treasury and on other
borrowed money
Interest on subordinated notes and debentures
Occupancy expense of bank premises, net, and furniture and equipment expense
Provision for possible loan losses
Other operating expenses
Total operating expenses
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Securities gains (losses), gross
Applicable income taxes
Securities gains (losses), net
Income before extraordinary items
Extraordinary items, net
Net income

Wisconsin

Wyoming

District of
Columbia
non-national

106

129

46

1

$228.6
1.6

$533.0
31.0

$104.3
0.2

$1.9
0

17.5

24.7

3.6

0.2

56.4
36.6
1.2
1.2
5.4
3.6
6.3
2.8

72.6
45.3
5.0
5.5
14.2
9.8
29.1
28.8

361.1

799.0

14.9
11.7
0.4
0.3
1.3
4.0
2.3
1.5
144.6

1.7
0.2
0.2
0
0
0.2
0.1
—
4.5

57.6
22.9
0
138.2

126.4
74.2
34.9
233.0

24.8
13.8
0
46.0

1.0
0.5
0
1.1

19.3

76.7

3.4

0.2

2.1
0.7
18.1
6.6
39.2
304.7

5.3
4.4
42.4
11.5
94.2

1.3
0.7
6.9
4.7
15.5
117.1

0
0.2
0.3
0.6

27.5
7.0
20.5

0.6
0.2
0.4

-1.8

-0.1
—
-0.1

—
—

69.1
—
69.1

20.4
—
20.4

56.4
7.0
49.4
-1.3
-0.5
-0.8
48.6
0.2
48.8

703.0
96.0
25.1
70.8
-3.6
-1.8

3.9

0.4
0.2
0.6




Cash dividends declared on common stock
Cash dividends declared on preferred stock....
Total cash dividends declared
Recoveries credited to allowance for possible loan losses .
Losses charged to allowance for possible loan losses
Net loan losses
Ratio to total operating income:
Interest on deposits
Other interest expense
Salaries and employee benefits
Other non-interest expense
Total operating expenses
Ratio of net income to total equity capital (end of period) ..

12.4
0
12.4
2.9
6.6

25.3
0

6.3
0

25.3

6.3

0.1
0
0.1

5.7
12.1

1.3
4.6

0.3

3.7

6.4

3.3

0.3

44.6
6.1
16.0
17.7
84.4
11.6

42.8
10.8
15.8
18.5
88.0
11.3

41.4
3.7
17.2
18.7
81.0
14.9

35.6
4.4
22.2
24.4
86.7

NOTE: Dashes indicate amounts of less than $50,000. Data may not add to totals because of rounding.

16.0

Table B-23
National banks engaged in lease financing, December 31, 1978

(Dollar amounts in thousands)
Total number
of national
banks

Number of banks
engaged in lease
financing

Amount of lease
financing at
domestic offices

All national banks.

4,564

864

$5,560,946

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

99
6
3
69
53
137
19
5
16
236

9
2
1
9
19
39
1
0
4
45

28,845
10,293
19,752
8,918
1,946,546
57,044
8,969
0
27,891
51,508

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky . . .
Lousiana . . .
Maine

64
2
6
419
121
99
151
79
54
17

15
1
3
79
26
21
26
15
11
0

53,778
7,984
33,988
155,148
145,657
5,014
4,411
97,689
29,254
0

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

34
73
125
205
37
101
56
117
4
39

3
11
23
29
6
25
17
26
3
2

46,754
152,802
124,636
170,623
653
69,438
4,882
42,744
76,218
7

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

96
40
124
27
43
217
191
6
226

9
11
15
6
9
66
92
2
13

115,866
1,958
581,596
89,532
1,402
169,753
29,842
34,536
277,844

Rhode Island..
South Carolina.
South Dakota..
Tennessee....
Texas

5
18
32
72
609
10
13
88
20
106
129
46

3
2
5
12
71
3
2
4
9
19
25
15

93,945
15,190
2,172
49,663
174,028
40,311
103
31,236
416,025
11,049
41,217
2,232

Utah
Vermont
Virginia
Washington...
West Virginia..
Wisconsin . . . .
Wyoming

District of Columbia — all*

17

'Includes the non-national bank in the District of Columbia, which is also supervised by the Comptroller of the Currency.

178



27,891

Table B-24
Assets and equity capital, net income, and dividends of national banks, 1967-1978
(Dollars in millions)
Capital stock (pa r value)

Year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978

Number
of
banks
4,758
4,716
4,669
4,621
4,600
4,614
4,661
4,708
4,744
4,737
4,655
4,564

Total
assets*
(foreign
and
domestic)
NA
NA
NA
NA
NA
$489,403
569,451
629,568
658,751
704,329
796,851
892,272

Preferred

Common

$55
58
62
63
43
42
37
13
14
19
25
29

$5,312
5,694
6,166
6,457
6,785
7,458
7,904
8,336
8,809
9,106
9,552
9,912

Ratios (percent)

Total

Total
equity
capital*

$5,367
5,752
6,228
6,520
6,828
7,500
7,941
8,349
8,823
9,125
9,577
9,941

$18,495
20,268
22,134
23,714
25,624
28,223
30,935
33,572
36,688
41,325
44,999
49,207-

Net income
before
dividends
$1,757
1,932
2,534
2,829
3,041
3,308
3,768
4,044
4,259
4,591
5,139
6,173

Cash
dividends
on
capital
stock
$ 796
897
1,068
1,278
1,390
1,310
1,449
1,671
1,821
1,821
1,994
2,196

Net income Net income
before
before
dividends to dividends to
total
total
assets
equity capital
NA
9.50
NA
9.53
NA
11.45
NA
11.93
NA
11.87
.68
11.72
12.18
.66
.64
12.05
.65
11.61
11.11
.65
.64
11.42
.69
12.54

* Data are not exactly comparable because assets through 1975 are net of reserves on loans and securities and since then are net of valuation reserves
and unearned discount of loans. Also, equity capital beginning for 1976 is reported including certain portions of the reserves on loans and securities
which were not reported separately for the years 1969-1975.

CD




Cash
dividends to
net income
before
dividends
45.30
46.43
42.15
45.17
45.71
39.60
38.46
41.32
42.76
39.66
38.80
35.57

Cash
dividends
to total
equity
capital
4.30
4.43
4.83
5.39
5.42
4.64
4.68
4.98
5.00
4.41
4.43
4.46

Table B-25
Loans losses and recoveries of national banks, 1970-1978
Year
1970
1971
1972
1973
1974
1975
1976
1977
1978

Total loans at
domestic offices,
end of year, net
$173 456,091
190,308,412
226,354,896
266,937,532
292,732,965
287,362,220
299,833,480
340,605,630
390,104,999

Net loan losses at
domestic offices
$601,734
666,190
545,473
731,633
1,193,730
2,047,643
1,819,748
1,380,261
1,277,398

Ratio of net losses
Total loans,
foreign and domestic,
to loans, net
end of year, net*
(Percent)
0.35
0.35
0.24
0.27
0.41
0.71
0.61
0.41
0.33

$372,458,078
429,317,723
490,142,134

Total net loan
lossesf

Ratio of net losses
to loans, net
(Percent)

$2,105,582
1,670,903
1,438,705

* Loans used in all years are net of reserves; after 1975 loans are also net of unearned discount.
t Beginning in 1976 national banks report consolidated loan losses and recoveries including those on loans at foreign offices.
NOTE: For earlier data, see Annual Reports of the Comptroller of the Currency, 1947, p. 100; 1968, p. 233 and 1975, p. 161.

180




0.57
0.39
0.29

Table B-26
Assets and liabilities of national banks, date of last report of
condition, 1972-1978
(Dollar amounts in millions)
Consolidated foreign and domestic assets
Number

Year

of

Total
assets*

banks

1972
1973
1974
1975
1976
1977
1978

4,614
4,661
4,708
4,744
4,737
4,655
4,564

$485,181
564,714
624,300
648,350
704,329
796,851
892,272

Cash
and due
from banks

$ 91,345
108,128
112,790
117,715
126,437
150,508
170,146

Total
securities*

$105,195
106,833
109,376
128,163
139,472
143,219
146,155

Loans,
net*

$253,538
303,931
345,527
347,686
372,458
429,318
490,142

Liabilities
Other
assets

$35,103
45,822
56,607
54,786
65,962
73,806
85,829

Total
deposits

$412,316
470,143
519,536
540,492
582,246
654,057
717,057

* For years 1972-1975, data are net of securities and loan reserves. Since 1975 data are net of valuation reserves and unearned discount on loans.
t Includes subordinated capital notes and debentures.
NOTE: For earlier data on domestic office assets and liabilities, see Annual Report of the Comptroller of the Currency, 1977, p. 200.

oo




Other
liabilitiesf

$44,499
63,675
71,191
71,204
80,758
97,795
126,008

Total
equity
capital

$28,366
30,896
33,573
36,654
41,325
44,999
49,207

Table B-27
Consolidated assets and liabilities of national banks with foreign operations, December 31, 1978
(Dollar amounts in millions)
Foreign* and
domestic offices
Cash and due from depository institutions
U.S. Treasury securities
Obligations of other U.S. government agencies and corporations
Obligations of states and political subdivisions in the United States
Other bonds, notes, and debentures
Federal Reserve stock and corporate stock
Trading account securities
Federal funds sold and securities purchased under agreements to resell

Domestic
offices

$131,885
20,148
8,604
28,774
5,754
774
4,220
19,005

$64,343
20,122
8,600
28,580
1,049
644
3,626
18,854

324,705
3,060

224,479
2,872

321,645

221,607

5,505
6,694
1,219
787
14,685
14,160

4,483
5,972
1,102
1,660
11,698
21,532

583,859

413,872

94,844
147,082
1,143
19,940
4,473
24,834
4,412

94,844
147,082
1,143
19,940
4,473
24,834
4,412

Total deposits in domestic offices

296,728

296,728

Total demand deposits
Total time and savings deposits

124,124
172,604

124,124
172,604

156,090

NA

452,818

296,728

52,018
5,227
11,845
814
14,826
17,152
554,700

51,937
5,227
4,484
772
11,801
14,011
384,960

2,143

1,896

5,226
9,798
11,594
398

5,226
9,798
11,594
398

Loans, total (excluding unearned income)
Less: Allowance for possible loan losses
Loans, net
Lease financing receivables
Bank premises, furniture and fixtures, and other assets representing bank premises
Real estate owned other than bank premises
Investments in unconsolidated subsidiaries and associated companies
Customers' liability on acceptances outstanding
Other assets
Total assets
Demand deposits of individuals, partnerships, and corporations
Time and savings deposits of individuals, partnerships and corporations
Deposits of United States government
Deposits of States and political subdivisions in the United States
Deposits of foreign governments and official institutions
Deposits of commercial banks
Certified and officers1 checks

Total deposits in foreign offices*
Total deposits
Federal funds purchased and securities sold under agreements to repurchase.
Interest bearing demand notes issued to the U.S. Treasury
Other liabilities for borrowed rnoney
Mortgage indebtedness and liabilities for capitalized leases
Banks' liability on acceptances executed and outstanding
Other liabilities
Total liabilities
Subordinated notes and debentures
Preferred stock
Common stock
Surplus
Undivided profits
Reserve for contingencies and other capital reserves
Total equity capital
Total liabilities and equity capital
Number of banks

27,016

27,016

583,859

413,872
104

* For reporting purposes foreign offices include Edge and Agreement subsidiaries located in the U.S. and branches in Puerto Rico, Virgin Islands
and Trust Territories.
NOTE: Dashes indicate amounts less than $500,000.

182




Table B-28
Foreign branches of national banks, by region and country, December 31, 1978
Region and country

Number

Central America
El Salvador.
Guatemala.
Honduras..
Mexico . . . .
Nicaragua .
Panama . . .

46
2
3
3
5
4
29

South America..

94

Argentina..
Bolivia
Brazil
Chile
Ecuador...
Guyana....
Paraguay..
Peru
Uruguay...
Venezuela .

32
6
19
3
13
1
5
3

West Indies — Caribbean
Antigua
Bahamas
Barbados
British Virgin Islands
Cayman Islands
Dominican Republic
French West Indies
Haiti
Jamaica
Netherlands Antilles
St. Lucia
Trinidad Tobago
West Indies Federation of States .
Europe .
Austria
Belgium
Denmark
England
France
Germany
Greece
Ireland
Italy
Luxembourg
Monaco
Netherlands
Northern Ireland..
Scotland

Region and country

Number

Europe — Continued
Switzerland
Africa

18

Egypt
Gabon
Ivory Coast.
Kenya
Liberia
Mauritius . . ,
Senegal
Seychelles..
Sudan
Tunisia
Middle East

160
1
60
5
2
50
19
2
4
5
4
1
6
1
130

3
34
13
19
17
4
9
5
1
6
1
3

26

Bahrain
Jordan
Lebanon
Oman
Qatar
Saudi Arabia
United Arab Emirates..
Yemen Arab Republic .
Asia and Pacific
Brunei
Fiji Islands
Hong Kong
India
Indonesia
Japan
Korea
Malaysia
Pakistan
Philippines
Republic of China.
Singapore
Thailand
U.S. overseas areas and trust territories
Canal Zone (Panama)
Caroline Islands
Guam
Marianas Islands
Marshall Islands
Puerto Rico
Virgin Islands
Total

118
3
4
29
10
5
22
7
5
4
9
4
14
2
54
2
1
3
1
1
24
22
646

Table B-29
Total foreign branch* assets of national banks, year-end 1953-1978
(Dollar amounts in thousands)
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965

$1,682,919
1,556,326
1,116,003
1,301,883
1,342,616
1,405,020
1,543,985
1,628,510
1,780,926
2,008,478
2,678,717
3,319,879
7,241,068

1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978

$ 9,364,278
11,856,316
16,021,617
28,217,139
38,877,627
50,550,727
54,720,405
83,304,441
99,810,999
111,514,147
134,790,497
161,768,609
180,712,782

* Includes military facilities operated abroad by national banks from 1966 through 1971.
r Revised.



183

Table B-30
national banks, December 31, 1978
Foreign branch assets and liabilities of
(Dollar amounts in thousands)
ASSETS
Cash and cash items in process of collection
Balances with all banks in the U.S. and non-U.S.
branches of U.S. banks
Balances with non-U.S. banks outside the U.S
Securities
Loans, discounts and overdrafts
Customers' liability on acceptances outstanding
Premises, furniture and fixtures
Accruals — interest earned, foreign exchange profits,
etc
Due from other non-U.S. branches of this bank
Due from head office and U.S. branches of this bank..
Due from consolidated subsidiaries of this bank
Other assets
Total assets

184




$ 705,640
13,204,982
42,845,811
3,025,930
82,443,202
2,593,936
378,386
3,384,170
20,212,487
4,576,620
6,251,011
1,090,607
$180,712,782

LIABILITIES
Deposits of all banks in the U.S. and non-U.S.
branches of U.S. banks
Deposits of non-U.S. banks outside the U.S
Other deposits
Liabilities for borrowed money
Acceptances executed and outstanding
Accrued taxes and other expenses
Due to other non-U.S. branches of this bank
Due to head office and its U.S. branches of this bank .
Due to consolidated subsidiaries of this bank
Other liabilities

$ 20,381,613
50,185,028
64,301,769
5,006,333
2,607,656
3,164,050
21,062,695
11,513,680
1,892,144
597,814

Total liabilities
MEMORANDA
Standby letters of credit
Commercial letters of credit issued and outstanding ..
Guarantees and letters of indemnity
Contracts to buy foreign exchange and bullion
Contracts to sell foreign exchange and bullion

$180,712,782
= = = = =
$ 5,148,810
3,172,930
1,478,589
79,755,566
78,225,796

o
Comptroller of the Currency
Administrator of National Banks
Washington, D.C. 20219
Official Business, Penalty for Private Use, $300




Postage and Fees Paid
Department of the Treasury
Treasury—556


Federal Reserve Bank of St. Louis, One Federal Reserve Bank Plaza, St. Louis, MO 63102