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Annual Report 1970
Comptroller of the Currency




The Administrator of National Banks

William B. Camp
Comptroller of the Currency




For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C. 20402 - Price $2.50
Stock Number 4801-0006

Letter of Transmittal
TREASURY DEPARTMENT,
OFFICE OF THE COMPTROLLER OF THE CURRENCY,
WASHINGTON, D.C., SEPTEMBER 30,

1970

SIRS: Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1970 Annual Report of
the Comptroller of the Currency.
Respectfully,
WILLIAM B. CAMP,

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




HI

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

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

Page
1
3
5
13
14
19
20
21
25

Appendices
A. Merger Decisions, 1970
B. Statistical Tables
C. Addresses and Selected Congressional Testimony of the Comptroller of the Currency

29
181
253

Index

271




Statistical Tables
Table No.

Title

1 Assets, liabilities, and capital accounts of National
banks, 1969 and 1970
2 Income and expenses of National banks, 1969 and
1970
3 National banks and banking offices, by States,
Dec. 31, 1970
4 Applications for National bank charters, and
charters issued, by States, calendar 1970
5 Applications for National bank charters to be
issued pursuant to corporate reorganizations,
and charters issued, calendar 1970
6 Applications for conversion to National bank
charters, and charters issued, by States, calendar 1970

VI




Page

Table No.

2

7
8

4

9

6
7

10
11
12

8
13
9

Title

Branches of National banks, calendar 1970
De novo branch applications of National banks,
by States, calendar 1970
De novo branches of National banks opened for
business, by community size and by size of bank,
calendar 1970
Mergers, calendar 1970
Office of the Comptroller of the Currency: balance
sheet, 1969 and 1970
Office of the Comptroller of the Currency: statement of revenue, expenses and Comptroller's
equity, 1969 and 1970
Office of the Comptroller of the Currency: statement of source and application of funds, 1969
and 1970

Page
10
11

12
12
26

27

28

I. Condition of the National Banking System
The year 1970 saw a transition from drum-tight
funds markets early in the year to relative ease in
markets later. Balance-sheet changes for National
banks reflected that shift; their ability to compete
for funds was greatly strengthened by the June suspension of Regulation Q ceilings on single-maturity, large-denomination time deposits with maturities under 90 days.
Total deposits of National banks increased 10.7
percent during 1970; that figure, however, masks
the great disparity between growth of time and demand deposits. While demand deposits showed an
increase over the year of 2.9 percent, time and savings deposits spurted by 20.2 percent.
The changes in asset composition during 1970




show that the period of relative ease was utilized by
National banks to rebuild their liquidity. While
total assets grew by 8.6 percent, to $340.9 billion,
total securities held jumped by 20.2 percent. That
figure contrasted with the relatively small increase
in outstanding loans of 3.2 percent, to a total of
$177.2 billion.
Total capital of National banks increased 7.0
percent during the year, reaching $24.9 billion at
year-end. The states whose National banks led in
total assets were New York, with $1.6 billion at
the end of the year; California, with $45.9 billion;
Illinois, with $27.8 billion; and Texas, with $22.1
billion.

TABLE 1

Assets, liabilities, and capital accounts of National banks, 1969 and 1970
[Dollar amounts in millions]
Dec. 31, 1970,
4,621 banks

Dec. 31, 1969,
4,669 banks
Amount

Cash and due from banks.
U.S. Treasury securities
Securities of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Total securities.

Federal funds sold and securities purchased under agreements to resell
Direct lease financing
Loans
Fixed assets
Customers' liability on acceptances outstanding.
Other assets
Total assets.

Percent
distribution

Amount

Percent
distribution

Change, 1969-1970

Amount

Percent

$54,727

17.43

$56,040

16.44

$1,313

2.40

29,589

9.42

34,223

10.04

4,634

15.66

4,640
34,526
1,362

1.48
10.99
.43

6,681
41,542
1,800

1.96
12.19
.53

2,041
7,016
438

43.99
20.32
32.16

70,117

22.32

84,246

24.71

14,129

20.15

5,809
696
171,702
5,280
1,838
3,879

1.85
.22
54.67
1.68
.59
1.24

10,436
790
177,202
5,911
2,054
4,227

3.06
.23
51.98
1.73
.60
1.24

4,627
94
5,500
631
216
348

79.65
13.52
3.20
11.95
11.75
8.97

314,048

100.00

340,906

100.00

26,858

8.55

$105,961

33.74

$107,768

31.61

$1,807

1.70

103,238
3,175
19,569

32.87
1.01
6.23

119,843
5,061
25,053

35.15
1.48
7.35

16,605
1,886
5,484

16.08
59.40
28.02

2,138
16,649
5,696

.69
5.30
1.81

3,386
18,494
4,179

.99
5.43
1.23

1,248
1,845
-1,517

58.37
11.08
-26.63

256,426

81.65

283,784

83.24

27,358

10.67

141,092
115,334

44.93
36.72

145,122
138,662

42.57
40.67

4,030
23,328

2.86
20.23

9,947
2,284

3.17
.73

11,830
1,280

3.47
.38

1,883
-1,004

18.93
-43.96

1,880
16,472

.60
5.24

2,096
13,204

.61
3.87

216
-3,268

11.49
-19.84

287,009

91.39

312,194

91.57

25,185

8.77

LIABILITIES

Demand deposits of individuals, partnerships, and corporations
Time and savings deposits of individuals, partnerships
and corporations
Deposits of U.S. Government
Deposits of States and political subdivisions
Deposits of foreign governments and official institutions,
central banks, and international institutions
Deposits of commercial banks
Certified and officers' checks, etc
Total deposits.
Demand deposits
Time and savings deposits

Federal funds purchased and securities sold under agreements to repurchase
Liabilities for borrowed money
Acceptances executed by or for account of reporting
banks and outstanding
Other liabilities
Total liabilities

Minority interest in consolidated subsidiaries. .

1

1

RESERVES ON LOANS AND SECURITIES

3,698
87

1.17
.03

3,747
89

1.10
.03

49
2

1.33
2.30

1,120
62
6,166
10,488
4,707
711

.36
.02
1.96
3.34
1.50
.23

1,161
63
6,457
10,659
5,864
671

.34
.02
1.89
3.13
1.72
.20

41
1
291
171
1,157
-40

3.66
1.61
4.72
1.63
24.58
-5.63

23,254

7.40

24,875

7.30

1,621

6.97

314,048

100.00

340,906

100.00

26,858

8.55

Reserves on l o a n s . . . .
Reserves on securities.
CAPITAL ACCOUNTS

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

NOTES: The 1969 and 1970 data reflect consolidation of all majority-owned bank premises subsidiaries and all significant domestic
majority-owned subsidiaries, with the exception of Edge Act subsidiaries.



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II. Income and Expenses of National Banks
The relative shift from loans to securities during 1970 was reflected in the aggregate income and
expense data for National banks. Interest on securities increased 13.7 percent over the 1969 figure,
reaching $3.6 billion for 1970. In contrast, loan
income increased only 9.7 percent. The latter accounted for 67.0 percent of all operating income
of National banks in 1970, compared to 68.6 percent the preceding year.
Total operating income of National banks was
$20.4 billion in 1970, representing a 12.1 percent
year-to-year increase. Total operating expenses rose
at an even greater rate, 14.0 percent, to reach
$16.3 billion. As a result, income before taxes and




securities transactions increased only 5.5 percent
over the previous year's figure.
Interest paid on deposits increased only 3.0
percent during 1970, but the $6.2 billion total still
accounted for 38.1 percent of total operating expenses. Salaries and wages spurted 12.8 percent in
1970, with the $3.8 billion total representing 23.6
percent of operating expenses.
With securities losses lower in 1970 than in 1969,
and applicable income taxes virtually unchanged,
net income of National banks rose 11.6 percent,
from $2.5 billion to $2.8 billion. Cash dividends
declared during 1970 totalled $1.3 billion.

TABLE 2
Income and expenses of National banks*, 1969 and 1970
[Dollar amounts in millions]
Dec. 31, 1969
Amount

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

Percent
distribution

4,669

Number of banks

Total

Dec. 31, 1970

income

....

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

Amount

Change, 1969-1970

Percent
distribution

Amount

Percent

4,621

$12,492.6

68.55

$13,698.4

67.04

$1,205.8

9.65

473.2

2.60

602.9

2.95

129.7

27.41

1,524.7

8.37

1,654.1

8.09

129.4

8.49

264.2

1.45

327.0

1.60

62.8

23.77

1,302.2
81.6
562.4
659.1

7.15
.45
3.09
3.62

1,535.3
90.7
626.2
686.4

7.51
.44
3.07
3.36

233.1
9.1
63.8
27.3

17.90
11.15
11.34
4.14

426.8
434.5

2.34
2.38

534.8
677.9

2.62
3.32

108.0
243.3

25.30
56.02

18,221.2

100.00

20,433.7

100.00

2,212.5

12.14

3,402.6
530.0
6,036.2

23.78
3.71
42.19

3,838.6
625.2
6,215.2

23.55
3.84
38.12

436.0
95.2
179.0

12.81
17.96
2.97

777.1
255.8
56.3
618.8

5.43
1.79
.39
4.33

937.5
169.8
55.2
723.8

5.75
1.04
.34
4.44

160.4
-86.0
-1.1
105.0

20.64
-33.62
-1.95
16.97

467.4

3.27

546.6

3.35

79.2

16.94

296.2
1,865.6

2.07
13.04

405.6
2,784.7

2.49
17.08

109.5
919.1

36.93
49.27

14,306.0

100.00

16,302.0

100.00

1,996.0

13.95

Income before income taxes and securities gains or
losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries

3,915.2
1,259.1
2,656.1
-125.7
2,530.3
4.0

4,131.7
1,239.9
2,891.8
-64.5
2,827 3
2.1

216.5
-19.2
235.7
61.2
297.0
-1.9
0

5.53
-1.52
8.87
48.69
11.74
-47.50

Net income

2,534.3

2,829 3

295.0

11.64

1,063 7
4.4

1,273.0

....

209.3
.3

19.68
6.82

..

1,068 1

209.6

19.62

Cash dividends declared:
On common stock
On preferred stock
Total cash dividends declared

Ratio to income before income taxes and securities:
Applicable income taxes
.
Net securities losses
Extraordinary charges or credits

32.16
3.21
.10

30 01
1.56
.05

Ratio to total operating income:
Salaries and waires
Interest on deposits
All other ODeratincr exDenses

18.67
33.13
26.71

18.79
30.42
13.63

78.51

79.78

13.91

13.85

Total operating expenses

Net income

"Includes all banks operating as National banks at year-end, and full year data for those State banks converting to National
banks during the vear.



III. Structural Changes in the National
Banking System
The National banking system comprised 4,621
banks, operating 12,366 branches and a total of
16,987 banking offices as of year-end 1970. The
branch figure represented an increase of 819, or
7.1 percent, during calendar 1970. That increase
compares with figures of 752 branches, or 7.0
percent, during 1969. As a result of mergers and
consolidations, the number of National banks has
declined slightly, from 4,669, at the beginning of
1970.
Of the 819 new branches, 737 were de novo
branches, new branches offering banking services
to the public for the first time at their respective
sites. Over 58 percent of the de novo branches were
located in communities with populations under
25,000; only 9 percent were located within cities
with populations of over 500,000. Forty-seven percent of the de novo branches opened during 1970
are operated by banks with total assets of less than
$100 million. California, with 87, New York, with
77, and Pennsylvania, with 64, led the Nation in
de novo branch openings. The difference between
net branch additions to the system and de novo
branches was accounted for by the entry of 186




branches through merger and conversion and the
discontinuation of 104 branches.
Thirty-nine charters were issued for newly-organized National banks in 1970, in comparison
with 16 in 1969. The unit banking states of Texas,
with nine, and Florida, with six, led in this category. Also, during calendar 1970, preliminary approval was given to 42 charter applications for
newly-organized banks, compared with 33 in 1969.
In addition to the charter activity relating to newlyorganized banks, 26 charters were issued pursuant
to corporate reorganizations, principally for the
purpose of forming bank holding companies.
Eleven charters were issued by the Comptroller
for the conversion of State banks to National banks.
During 1970, there were 80 merger, consolidation, or purchase transactions, involving two or
more operating banks, in which the resulting bank
was a National bank. That figure was identical
with that for 1969. In addition, 25 mergers pursuant to corporate reorganization and involving
only one operating bank were consummated during
1970.

TABLE 3

National banks and banking offices, by States, Dec. 31, 1970
National banks
Number of
branches
Total

Unit

With
branches

1,639

12,366

43
0
1
36
7
113
6
3
1
215

46
5
2
33
53
9
20
2
10
0

189
50
215
82

62
1
7
414
122
99
171
80
49
19

31
0
2
360
48
59
139
36
11
4

31
1
5
54
74
40
32
44
38
15

165
9
108
54
339
54
32
141
181
101

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

42
86
101
199
38
98
49
125
4
48

12
22
30
197
5
75
48
101
1
25

30
64

253
428
560
6
142
23
1
25
60
51

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

129
33
169
22
42
217
203
10
299
5

23
8
66
3
32
69
168

106
25
103
19
10
148
35

3
138
0

161
5

1,050

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

19
33
77
530
10
26
101
25
85
125
41
1

4
24
17
530
5
11
26
8
85
90
41
0

15
9
60
0
5
15
75
17
0
35
0
1

240
58
276
0
74
49
475
440
0
65
0

14

1

13

101

United S t a t e s . . . .

4,621

2,982

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

89
5
3
69
60
122
26
5
11
215

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

District of Columbia—all

Number of

71
2
33
23
1
24
3

23

7

2,370

9
221
4
66
0

682
73
1,261

549
10

742
35
249
92

7

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




TABLE 4

Applications for National bank charters, * and charters issued\ * by States, calendar 1970
Received^

Approved

Rejected

Abandoned

46

Pending
Dec. 31, 1970

United States

159

42

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

2
0
0
1
4
13
2
0
0
33

0
0
0
1
0
0
0
0
10

1
0
0
0
1
5
2
0
0
14

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

3
0
0
8
1
1
1
0
1
1

0
0
0
3
1
0
0
0
0
0

0
0
0
2
0
1
1
0
0
1

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

1
1
5
4
0
3
0
0
0
0

0
1
4
1
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0

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

14
0
6
1
0
0
1

5
0
2
1
0
0
0
0
0
0

4
0
1
0
0
0
1
0
0
0

South C a r o l i n a . . . .
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Virgin Islands

0
0
1
38
0
0
2
4
1
4
2
0

0
0
0
7
0
0

0
0
0
22
0
0
1
1
0
1
2
0

0
0
0

*Excludes conversions and corporate reorganizations,
tincludes 45 applications pending as of Dec. 31, 1969.




2

1

0
1

2
0
0

62

1

Charters
issued

TABLE 5

Applications for National hank charters to he issued pursuant to corporate reorganizations, and charters issued, by States,
calendar 1970
Received*

Approved

Rejected

United States

33

31

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

1
0
0
0
1
0
0
0
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

0
0
0
0
0
0
0

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

1

1

0

0

0

0

1
1

1
1

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

1

New Mexico
New York
North C a r o l i n a . . . .
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

0
0
4
0
0
0
0
12
0
1
0
0
5
0
0
0
0

0
0
4
0
0
0
0
12
0
1
0
0
5
0
0
0
0

South C a r o l i n a . . . .
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Virgin Islands

0
0
0
4
0
0
1
0
0
0
0
0

0
0
0
3
0
0

New Jersey

•Includes 1 application pending as of Dec. 31, 1969.




1

0
0
0
0
0

Abandoned

Pending
Dec. 31, 1970

Charters
issued

TABLE 6

Applications for conversion to National bank charters, and charters issued, by States, calendar 1970
Received*

United States

16

Approved

Rejected

Abandoned

10

Pending
Dec. 31', 1970

1

3

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
1

0
0
0
0
0
0
0
0
0
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

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

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

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
2
0
0
0

New Jersey
New Mexico
New York
North C a r o l i n a . . . .
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

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

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

"Includes 4 applications pending as of Dec. 31, 1969.




Charters
issued

TABLE 7

Branches of National banks, calendar 1970

Branches in
operation
Dec. 31, 1969

Branches
De novo
Existing
acquired
branches
branches
opened for
discontinued
through
business
or consolidated
merger or
conversion
Jan. 1-Dec. 31,
Jan. 1-Dec. 31,
1970
Jan. 1-Dec. 31,
1970
1970

Branches
in operation
Dec. 31, 1970

United States....

Ml,547

737

186

104

12,366

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

173
47
199
78
2,293
2
205
3
64
0

14
2
16
4
87
7
14
1
3
0

2
1
0
0
12
0
5
0
0
0

0
0
0
0
22
0
3
0
1
0

189
50
215
82
2,370
9
221
4
66
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

155
7
106
44
318
51
27
135
167
91

11
2
0
10
17
4
5
6
13
9

0
0
2
0
5
0
0
0
1
2

1
0
0
0
1
1
0
0
0
1

165
9
108
54
339
54
32
141
181
101

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

239
406
533
6
127
20
1
22
56
45

16
22
30
0
11
3
0
3
4
5

6
6
1
0
4
0
0
0
0
1

8
6
4
0
0
0
0
0
0
0

253
428
560
6
142
23
1
25
60
51

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

602
67
1,163
495
9
*691
37
240
979
88

57
6
77
40
1
45
3
10
64
4

34
0
23
19
0
7
0
0
31
0

11
0
2
5
0
1
5
1
24
0

682
73
1,261
549
10
742
35
249
1,050
92

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

222
55
'259
0
61
45
'437
414
0
57
0
6

22
1
18
0
6
3
35
17
0
8
0
1

0
2
0
0
7
1
5
9
0
0
0
0

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

240
58
276
0
74
49
475
440
0
65
0
7

District of Columbia—all

97

101

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

10




TABLE 8

De novo branch applications of National banks, by States, calendar 1970
Received*

Approved

Rejected

Abandoned

Pending
Dec. 31, 1970

United States

1,255

782

152

53

268

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

17
10
23
5
184
12
25
0
12
0

12
4
16
5
115
12
22
0
5
0

1
3
3
0
41
0
0
0
0
0

0
1
0
0
7
0
0
0
0
0

4
2
4
0
21
0
3
0
7
0

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

62
0
7
13
31
7
2
7
11
10

7
0
6
9
21
6
2
6
7
7

0
0
0
0
2
0
0
1
3
1

11
0
0
1
0
0
0
0
0
1

44
0
1
3
8
1
0
0
1
1

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

53
32
71
0
12
5
2
4
3
4

35
25
30
0
7
2
2
4
2
3

5
3
21
0
2
0
0
0
1
0

5
0
6
0
1
0
0
0
0
1

8
4
14
0
2
3
0
0
0
0

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

78
11
168
74
0
48
8
11
75
5

53
8
113
38
0
39
8
6
52
3

11
0
19
2
0
3
0
3
10
0

2
0
7
3
0
1
0
0
0
0

12
3
29
31
0
5
0
2
13
2

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

23
1
17
0
10
2
74
18
0
8
0
0

14
0
13
0
7
1
39
11
0
5
0
0

4
0
2
0
0
0
8
3
0
0
0
0

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

5
1
1
0
2
0
25
3
0
3
0
0

District of Columbia—all t

15

*Includes 266 applications pending as of Dec. 31, 1969.
tincludes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.




11

TABLE 9

De novo branches of National banks opened for business, by community size and by size of bank, calendar 1970
Population of cities

Branches

Total resources of banks

Branches

[millions of dollars]
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

179
252
90
64
45
40
24
43

Less than 10.0
10.0 to 24.9
25.0 to 49.9
50.0 to 99.9
100.0 to 1,000.0
Over 1,000.0

70
124
86
69
220
168

Total

737

737

TABLE

10

Mergers, * calendar 1970

Applications carried over from 1969
Applications received 1970
Disposition of applications 1970:
Approved
Abandoned
Applications pending December 1970
Transactions completed 1970:
Mergers
Consolidations
Purchase of assets
Total completed
The aggregate total capital stock and capital accounts for the certificates issued are as follows:

Capital stock
Capital accounts

Transactions
involving
two or more
operating banks

Other, pursuant
to corporate
reorganizations

15
79

3
26

80
2
12

24
0
5

60
10
10

25
0
0

80

25

f

Charter or
purchasing bank

Merging,
consolidating,
or selling bank

Combined

$817,785,022
2,949,470,801

$63,961,298
207,439,895

$881,012,920
3,168,016,022

*Includes mergers, consolidations and purchase and sale transactions where the resulting bank is a National bank.
"(•Includes only those transactions involving 2 or more operating banks.




IV. Bank Examinations and Related Activities
The National Bank Act requires that all National banks be examined twice in each calendar
year, but the Comptroller, in the exercise of his
discretion, may waive one such examination in a
2-year period, or may cause such examinations to
be made more frequently, if considered necessary.
In addition, the District Code authorizes the Comptroller to examine each non-National bank and
trust company in the District of Columbia.
This year was, once again, the most active in the
history of the Comptroller's Office. During the
year ending December 31, 1970, the Office examined
7,084 banks, 14,777 branches and facilities, 1,590
trust departments and branches, 232 affiliates and
subsidiaries, and conducted 402 special examinations and visitations. Investigations were conducted
in connection with applications for 1,996 de novo
branches, four State banks were examined in connection with conversions to National banks, and
the Office received 145 applications to establish new
National banks. That latter figure includes seven
corporate reorganizations.
National bank examinations are designed to determine the condition and performance of banks,
the quality of their operations, the capacity of
management, and whether the banks are complying
with Federal laws. All facets of an examination
have, as their end result, the determination of
liquidity and solvency, present and prospective,
and the determination of whether the bank is
operating within the framework of applicable
banking laws and regulations. The appraisal of a
bank's loans and lending policies, investments and
investment policies, and the ability and capacity of
its management constitute the most exacting phases
of the examination process.
As of December 31, 1970, the Office employed
1,635 examining personnel, 1,537 commercial examiners and 98 trust examiners. During 1970, efforts were conducted to improve the quality and




efficiency of examinations. New assistant examiners
were provided with monitored on-the-job training,
nine sectional schools, and a self-instructional program which was implemented during 1970. The
National Bank Examiner's School continues to be
of prime importance in the career development
program of examining personnel. Those schools
are attended by all recently-commissioned National
Bank Examiners, and the curriculum covers all
aspects of commercial examinations. Loan and investment analysis, determination of asset quality,
and evaluation of bank management receive the
greatest emphasis. Considerable time is also devoted
to diversification of risk, liquidity, capital adequacy,
earnings, bank operations, investment in fixed
assets, borrowings, future prospects, and review of
the various laws and regulations affecting National
banks.
The more senior National Bank Examiners began attending 5-day EDP seminars during 1970.
Those training sessions are intended to update
the examiners' knowledge of EDP equipment and
examination procedures and techniques. It is anticipated that 750 examiners will have completed
such training by the end of 1971. Training and
instruction is supplemented by correspondence
courses offered by the American Institute of Banking and Dun and Bradstreet. Also, every year, a
number of our examining personnel graduate from
the various graduate schools of banking.
The comprehensive Comptroller's Handbook of
Examination Procedure, an internal manual covering all areas of banking examination, published in
1969, was supplemented during 1970 by a new instructional booklet, EDP Examination Procedures.
The booklet standardizes EDP examination procedures and establishes minimum standards of output.
The Office will continue its efforts to review and update training programs and examining techniques
in the months and years ahead.

V. Litigation
The rise in the number of cases filed challenging
administrative actions or rulings of the Comptroller that began during calendar 1969, continued
virtually unabated through 1970. Twenty new
cases were filed during 1970. There were 31 cases
pending on January 1, 1970; 23 cases were terminated during the year; and 28 cases were pending
at the end of calendar year 1970.
The Comptroller's ruling was overturned by the
courts in only two of the 22 cases terminated. The
more significant cases involved the following subjects:

A. Incidental Powers Cases
Three cases involving the standing of competitors of National banks who allege that the activities of particular National banks exceed the authority contained in the incidental powers clause of
the National Bank Act, 12 U.S.C. §24 (Seventh),
were reviewed by the Supreme Court during 1970.
The Supreme Court review was prompted when
two circuit courts of appeals reached diametrically
opposed conclusions in two substantially identical
cases, brought by data processing service bureaus,
challenging the right of a National bank to offer
data processing services to other banks and bank
customers, as is permitted by the Comptroller.
ADAPSO v. Camp, 406 F.2d 837 (8th Cir.); The
Wingate Corp. v. Industrial National Bank of
Rhode Island, 408 F.2d 1147 (1st Cir.). In a farreaching opinion, reinterpreting the law of standing as it applied to suits against all federal
agencies, the Supreme Court held in ADAPSO v.
Camp, 397 U.S. 150, that data processing service
bureaus do have standing to bring suit in federal
court to challenge the authority of a National
bank to sell data processing services. On the authority of its ruling in ADAPSO, the Supreme
Court also held that Section 4 of the Bank Service
Corporation Act also confers standing upon travel
agents to contend, contrary to the Comptroller's
14




ruling, that National banks lack incidental power
to operate a travel agency. Arnold Tours, Inc. v.
Camp, 39 L.W. 3226.
Since the Supreme Court decisions did not reach
the ultimate issues on the merits, i.e., whether
National banks are authorized by the National
Bank Act to provide travel agency and data processing services, the cases were returned to the
district courts for further proceedings. No further
proceedings in the district courts had taken place
at year end 1970.

B. Other Banking Powers
1. Collective Investment Funds.
A case challenging the authority of National banks possessing
trust powers to operate a commingled managing
agency account awaited decision by the Supreme
Court at the end of 1970. Camp v. Investment
Company Institute, O.T. 1970, No. 61. The Supreme Court review had been requested by ICI
after the Court of Appeals for the District of
Columbia, in a unanimous opinion, upheld the
authority of the bank to operate the account. The
case involves a commingled agency fund established by First National City Bank of New York
with the specific approval of the Comptroller, the
SEC, and the Board of Governors of the Federal
Reserve Board. Writing prior to the Supreme
Court's reinterpretation of the law of standing in
ADAPSO, two judges of the court expressed "reservations amounting to virtual disbelief" in the
standing of the plaintiff mutual fund industry to
bring the suit. Chief Judge Bazelon noted that the
commingled managing agency account was "a descendent of the individual managing agency account and the common trust fund, fitting within
the traditional authority of banks to manage other
people's money in a fiduciary capacity." All three
judges concurred in finding that the approval
given by each of the involved federal agencies
was within its respective statutory authority.

2. Receiving Interest on Credit Card Transactions.
Two cases, brought during 1969, by the
State of Idaho, against the Comptroller and two
National banks headquartered in Boise, Idaho,
were scheduled at the end of 1970 for trial in 1971.
The district court ruled, in response to several
motions, that the State Commissioner of Finance
had standing to maintain the actions. State of
Idaho v. First Security Bank, N.A. and Camp,
Civil No. 1-69-83; State of Idaho v. Idaho First
National Bank & Camp, Civil No. 1-69-101. The
The State Commissioner contends that each of
the National banks involved charges, on certain
credit card transactions, an interest rate higher
than that which State banks could charge on similar transactions. The Comptroller is made a defendant because he has interpreted Section 30 of
the National Bank Act, 12 U.S.C. §85, to permit
National banks to charge the same interest rate
that any competing State institution, e.g., a small
loan company, could charge on similar loans.

law. At year-end, no proceedings had taken place
in the Somerset Trust case, other than the filing
of an amended complaint by plaintiffs.
2. Cases Brought by Applicants.
At the end
of 1970, two actions were pending by organizers
of proposed National banks, challenging the refusal of the Comptroller to charter -the applied
for bank. Klanke v. Camp, S.D. Texas, Civil No.
69-H-1033 and Pitts v. Camp, D. S.C., Civil No.
69-979. The Klanke and Pitts cases awaited further
proceedings after the district courts had ruled, in
response to preliminary motions by the Comptroller, that the courts had jurisdiction to review
the Comptroller's exercise of discretion in rejecting a National bank charter application. An additional case, challenging the refusal of the Comptroller to charter a National bank, was voluntarily
dismissed by plaintiffs during the year. Olsen v.
Camp, E.D. Mich., Civil No. 31804.

C. New Banks

1. Cases Brought by Competitors.
Four cases,
involving challenges, by competitors, of the Comptroller's approval of the relocation of a National
bank's main office, resulted in opinions during the
year upholding the Comptroller's decision. In The
Ramapo Bank v. Camp, 425 F.2d 333, the Third
Circuit Court of Appeals upheld the Comptroller's
approval of a New Jersey National bank's simultaneous applications to relocate its main office
to a different town 2.3 miles away, and to retain
its former main office as a branch. The Supreme
Court declined to review that decision, and thus
left it standing as final. While the Ramapo case
was pending, federal district courts granted judgment for the Comptroller in three additional similar cases in New Jersey. Peoples Trust Co. v. Camp
and Hackensack Trust Co., N.A., D. N.J., Civil
No. 1191-69, Midland Bank & Trust Co. v. Camp
and Hackensack Trust Co., D. N.J., Civil No.
1174-69; and Peoples Trust of New Jersey v. Camp
and Edgewater National Bank, D. N.J., Civil No.
1121-69. In addition to the cases arising in New
Jersey, the decision of the Seventh Circuit in
Marion National Bank v. Camp, 418 F.2d 121
(Jan. 1970), which was partially contrary to the
later holding of the Ramapo court, became final
during 1970, when neither party appealed. The
Marion court held that the Comptroller could
not, as part of "a single indissoluable process",

1. Cases Brought by Competitors.
Three suits
against the Comptroller's Office, in which existing
banks alleged that the Comptroller's chartering
of a new competing National bank was unlawful,
were pending at the end of 1970. Sterling National
Bank v. Camp, 431 F.2d 514 (5th Cir. 1970);
Humble State Bank v. Camp, S.D. Texas, Civil
No. 69-H-1209; and Somerset Trust Co. v. Camp,
D. N.J., Civil No. 659-70. In Sterling, the Fifth
Circuit Court of Appeals held that the record
developed by the Comptroller's Office in processing
the application showed the Comptroller's decision
to be rational and lawful, and that the Comptroller's approval was not invalidated either (1) by his
receipt of information from the applicant ex parte
or (2) by the lack of an opinion accompanying
the Comptroller's determination. Plaintiff in
Sterling has requested review of the Fifth Circuit
decision by the Supreme Court, but, at year-end
1970, the court had not acted upon plaintiff's
petition. The Humble case was pending at the end
of the year on motions by the Comptroller to
dismiss for lack of standing, or, in the alternative,
to grant summary judgment for the Comptroller,
because the record developed by the Comptroller's
Office in processing the application showed the
Comptroller's decision to be in accordance with




D. Main Office Relocations

15

approve simultaneous applications by a State-chartered bank in Indiana to convert to a National
Association, to relocate its main office to the county
seat 12 miles away, and to retain a branch at the
site of its former main office. Subsequent to the
Seventh Circuit's decision, the Indiana bank, as
permitted by the Court of Appeals' opinion, withdrew the branch portion of its application, converted to a National Association, and moved its
main office. The bank then filed a new application
for a branch at its former main office site, which
application was approved by the Comptroller. The
net effect of the Marion decision was to leave an
Indiana town without a local banking office for a
period of approximately 2 weeks.
2. Cases Brought by Applicants.
In the first
case of its kind, a rejected applicant has filed an
action seeking to compel the Comptroller to approve its simultaneous application to relocate its
main office to another municipality, and to retain
its former main office structure as a branch. First
National Bank of Southaven v. Camp, D. Miss.,
Civil No. DC 7074-K. At year-end 1970, no proceedings had taken place in this case, other than
the filing of a complaint.

E. Branches
The decision of the Supreme Court in Camp v.
Dickinson, 396 U.S. 122, discussed in the 1969
Annual Report, became final in 1970, when the
Supreme Court denied a petition for rehearing.
The ruling of the Supreme Court, in Dickinson
to the effect that an armored car, used by a National bank in Florida to pick up and deliver
funds from customers of the bank, and an offpremises night depository each constituted a
"branch", as that term is defined in the National
Bank Act, 12 U.S.C. §36 (£), appears to have raised
more questions that it has settled. The Court rejected the argument advanced by the National
Association of Supervisors of State Banks, in an
amicus curiae brief, that State law defined what
was a branch of a National bank, but held that
the armored car and receptacle were branches,
because "deposits" were received within the meaning of 12 U.S.C. §36 (f). Thus there remains some
confusion as to whether similar armored car operations would be branches in States where armored
cars may be operated by State banks. Additional
problems of interpretation and application may
16




arise under peculiar circumstances in connection
with the performance of armored car services by
subsidiaries of bank holding companies. In Jackson
v. First National Bank of Gainesville, 430 F.2d
1200, for example, the Fifth Circuit Court of
Appeals held, subsequent to the Dickinson ruling,
that, where a messenger service subsidiary of the
holding company controlling the First National
Bank of Cornelia, Ga., continued to operate the
messenger car service, previously operated by the
bank, exactly as it had been operated before, solely
on behalf of the bank, and for the benefit of the
bank's customers, and where the armored car
service charged the bank's customers nothing, and
had no visible means of financial support, the
performance of the messenger car service by the
holding company subsidiary amounted to prohibited branch banking. At year-end 1970, the bank
was seeking Supreme Court review of the Fifth
Circuit ruling.
In First Citizens Bank & Trust Co. v. Camp,
C.A. No. 13859, the Court of Appeals for the
Fourth Circuit reversed a district court which had
issued a preliminary injunction temporarily overturning the Comptroller's approval of a branch
bank in North Carolina. The appellate court
found the district court's order, which had issued
even though the district judge had the Comptroller's entire administrative record before him
and could have granted final judgment for the
Comptroller, to be an abuse of discretion. The
court thus returned the case to the district court
with instructions to hold a hearing on the damages
sustained by the bank by reason of the "improper
issuance of the injunction order", and directed
that the district court proceed to a final determination of the case on the merits. Subsequent to
the issuance of this opinion, the plaintiff voluntarily dismissed the suit. The Comptroller's Office
is hopeful that the Fourth Circuit opinion will
discourage frivolous litigation commenced by competitors merely for the purpose of delaying the
opening of competing branch banks.
Three additional cases, brought by competing
banks during 1970, resulted in orders upholding
the Comptroller's approval of challenged branch
applications. Two of these cases involved challenges
to the Comptroller's approval of branch applications for National banks in New Jersey. Montclair
National Bank & Trust Co. v. Camp, D. N.J.,
Civil No. 1004-69; Springfield State Bank v. National State Bank of Elizabeth, D. N.J., No. 846-69.

In the third case, a United States District Court
in Michigan held that the Comptroller reasonably
concluded, upon the basis of information presented to him, administratively, that the contested
branch was not within the same unincorporated
village as an already existing branch of the plaintiff
bank, located approximately 34 of a mile away,
and that under such circumstances, the branch
was permitted by statute and the Comptroller's
decision must be upheld. National Lumberman's
Bank & Trust Co. v. Camp, W.D. Mich., Civil
No. 6179.

F. Merger Cases
In 1970, the Comptroller was a party to six
merger cases. In two that were litigated to judgment, the Court upheld the Comptroller and the
defendant banks and found the mergers to be
lawful. Both of these cases have been terminated
with no appeal to the Supreme Court. In one case,
the Supreme Court reversed and remanded it to
the district court. In another, a holding company
acquisition, the district court, before trial, is considering the Comptroller's motion to lift the statutory stay. In a fifth case, the Comptroller has filed
a motion to dismiss the complaint on the ground
that the "section of the country" selected by the
Antitrust Division is, as a matter of law, too small
to be a "section of the country'* under §7 of the
Clayton Act. In the sixth case, a three-bank consolidation, a consent decree was entered on December
7, 1970, terminating the cause.
In United States v. The First National Bank of
Maryland, 310 F. Supp. 157 (D. Md. 1970), an
appeal from the judgment for the Comptroller and
the defendant banks was noticed to the Supreme
Court by the plaintiff on March 20, 1970, but was
dismissed by stipulation on March 30, 1970.
On April 21, 1970, after a lengthy trial, the district court rendered an opinion in favor of the
Comptroller and the defendant banks in the market
extension, or potential competition, merger case
of United States v. The Idaho First National Bank
and Fidelity National Bank, 315 F. Supp. 261 (D.
Idaho 1970). The Antitrust Division elected not to
appeal. The court found that Twin Falls, Idaho,
with four banks already there, would not support a
fifth bank entry, and that it was not reasonably
probable that Idaho First would enter Twin Falls
by branching in the foreseeable future. The court




also found that the anticompetitive effects of the
merger, if any, would be clearly outweighed in the
public interest by improving the quality of bank
services to meet the convenience and needs of the
Twin Falls community. The court considered it
important that the merger would increase the lending limit of Fidelity National and either provide
services not now available through Fidelity, or increase services, in the trust area; real estate and
construction lending, including FHA and VA
loans; consumer and installment loans; purchase
of dealers' paper; automobile and mobile home
financing; and industrial and municipal loans. The
merger would also bring to the area, for the first
time, regional computer services, investment advice,
commercial counseling, and accounts receivable
financing.
United States v. Phillipsburg National Bank &
Trust Co., et al, 306 F. Supp. 645 (D. N.J. 1969),
was appealed, and reversed, and remanded by the
Supreme Court on June 29, 1970, with Mr. Justice
Harlan and Chief Justice Berger dissenting in part,
399 U.S. 350 (1970). The majority opinion found
that the district court erred in its determination as
to the relevant product market and the relevant
geographic market, and that these errors invalidated the district court's determination that the
merger would have no significant anticompetitive
effect. The product market was found to be commercial banking, and the section of the country
to be Phillipsburg-Easton and environs which had
a 1960 population of almost 90,000. The Court did
not examine the convenience and needs advanced
by the Comptroller and defendant banks because
the district court had examined them in the wrong
"section of the country," so that the convenience
and needs defense still has not been thoroughly
examined by the Supreme Court. The Court did
state that the banks contention that they lack
personnel and resources to serve their community
effectively and to compete vigorously were procompetitive factors, and certainly relevant in determining the convenience and needs of the community under the Bank Merger Act. The Court also
held that "the community to be served" is virtually
always as large, or larger, than the geographic
market or section of the country, and that the
convenience and needs cannot be measured in a
smaller area.
On February 27, 1970, the Antitrust Division
filed suit alleging that the acquisition by United
Virginia Bankshares, a registered bank holding
17

company, of controlling interest in Peoples National Bank, Manassas, Va., was violative of §7 of
the Clayton Act in that it would eliminate potential competition between them, would eliminate
United Virginia Bankshares as a potential entrant
into commercial banking in the Manassas and
Prince William County area, and would entrench
the three dominant banking organizations in these
market areas. United States v. United Virginia
Bankshares Incorporated, the Peoples National
Bank of Manassas, and Manassas Bank, N.A., Civil
No. 85-70-A, E.D. Va. 1970. The Comptroller,
after intervening, filed a motion to lift the statutory
stay provided for in the Bank Merger Act (12
U.S.C. §1828 (c) (7) (A)) and in the Bank Holding
Company Act (12 U.S.C. §1849). The Comptroller
contended that there would be irreparable injury
to Peoples National Bank, that the purpose of the
stay was to prevent the difficulties of unscrambling
of banking assets, and that this problem is not
present in the acquisition of majority control of a
bank by a holding company. The Court was considering this motion and a plan agreed upon by the
defendants, and approved by the Comptroller, to
facilitate divestiture, should it become necessary,
but no decision had been made as of December 31.
On December 11, 1970, the Antitrust Division




filed a §7 Clayton Act case against the merger of
County National Bank of Bennington and Catamount National Bank United States v. County
National Bank of Bennington and Catamount National Bank, Civil No. 6088, D. Vt. 1970. The suit
alleges the merger may substantially lessen competition in the "Bennington area/' The Comptroller,
following intervention, and the defendant banks
have both filed motions to dismiss the complaint
on the grounds that the "Bennington area/' which
has a population of 23,733, is too small and economically insignificant to be a "section of the country" under §7 of the Clayton Act, and that Bennington appears to be the type of small town that
Congress intended would not be covered by the
Act when the word "community1' was deleted in the
1950 amendment. The motions are pending.
On December 7, 1970, a consent decree was entered in the three bank consolidation case of
United States v. National Bank & Trust Co. of
Central Pa., et al., Civil No. 69-2902, E.D. Pa.,
which in effect allowed the consolidation but required the banks to sell nine branches. It also prohibits the consolidated bank from further bank
mergers in Dauphin, Lancaster, and York counties
for 10 years.

VI. Fiduciary Activities of National Banks
The number of fiduciary accounts and the market
value of assets held by trust departments of National banks continued to grow in 1970. During
the year, 45 application for permits to exercise
fiduciary powers were received from National banks
and 26 were approved. In addition, five State banks
with trust departments converted to National
charters. Taking into account losses through mergers and consolidations, the number of National
banks authorized to exercise fiduciary powers had,
by year-end, risen to 1,943.
Against this background, the Comptroller's Office
carried out its responsibilities as effectively as possible. Training of personnel continued to have a
high priority. In April, a two-week school for Assistants in Trust was held in Washington, D.C.; 32
Assistants, from the various regions, attended. Three
members of the F.D.I.C. trust examining force and
one representative from each of the bank supervisory staffs of the states of Connecticut, Wisconsin,
New Hampshire, New York, North Carolina,
Michigan, Illinois, and Maryland also took part.
The course was divided into two parts, one giving
a greater understanding of the functions and operations of a trust department, and the other dealing
with the supervisory policies and procedures
through which the responsibilities of this Office are
carried out. A number of recognized banking and
legal authorities helped conduct the first portion of
the course, and the Trust Division staff, assisted by
representatives from the field, conducted the second.
A joint seminar with the F.D.I.C. held in November for the Associates in Trusts of the Office. That
course was aimed at intermediate level trust examiners who are expected to reach the highest level
of qualification, Representative in Trusts, in the




near future. Fourteen Associates and eight examiners from the Federal Deposit Insurance Corporation attended. The first part of that course dealt
with principles of management supervision, and the
second with emerging examination problems.
During the year, the federal banking agencies instructed their trust department examiners to enquire into bank policies relating to the allocation
of brokerage business. Later, an opinion was received from the Justice Department holding that
the allocation of brokerage business in return for
brokers' deposits may violate the antitrust laws.
The examiners were instructed to so advise the
banks. Based upon initial results it appears that the
practice, while perhaps used in years past, is no
longer a factor in placing brokerage business.
The banking agencies continued their close
scrutiny of securities fails. Banks were counseled to
adopt a procedure of payment on delivery when
possible. By year-end, it appeared that the instances
of failure to deliver securities paid for by trust
departments were relatively few. Special attention
was given to holdings of restricted stock in trust
accounts because of problems of liquidity and valuation.
In December, the case of Investment Company
Institute v. Camp was argued before the Supreme
Court. (See "Litigation.") The decision, expected
early in 1971, may have broad implications for
determining the extent to which the Banking Act
of 1933 limits trust department activities. Resolution of those questions should end the uncertainty
which has prevailed since the suit was brought, and
should enable this Office to draw more definitive
boundaries for such activities.

19

VII. International Banking and Finance
During this past decade, National banks displayed a phenomenal rate of international expansion that continued to accelerate during 1970. At
the beginning of the 10-year period, on December
31, 1960, only three National banks had foreign
branches, and their 85 branches reported total assets of $1,628 million. In the year 1970, 31 National banks opened 72 new foreign branches, and
at the close of this decade, 59 National banks were
operating 497 foreign branches with total assets of
$38.9 billion. The international activities of National banks also continued to expand directly,
through ownership of foreign banks, and indirectly,
through ownership of Edge and agreement corporations, with financing and investing spreading on a
global basis.
There were no major currency devaluations during the year and, in addition to this favorable factor, the increase in international activities of National banks was encouraged by more than average
incentives of growth and profits.
Anti-inflationary monetary policies and the related tight money situation in the United States
led to a further increase in the supply of Eurodollars in 1970. That supply, tapped most easily by
foreign branches in London and Nassau, was used
by National banks to serve their customers' need
for funds. During the year, 26 new branches of
National banks opened in Nassau, and 2 opened in
London. By the end of 1970, 56 National Banks
had 72 branches in operation in London and Nassau, and 14 applications for branches in those locations were awaiting approval of U.S. or foreign
authorities.
The International Division of the Office of the
Comptroller of the Currency was formed during
the decade to keep pace with these expanding activities. In 1970, examination reports and procedures were revised to improve the examination
of foreign assets of National banks through their
domestic head offices, and supplemental, direct visitations of foreign branches were more frequent.
20




By 1970, all of the 14 National bank regions contained banks with international activities, so a related representation was developed for the international examining staff. During the year, 43 examiners conducted branch examination in Europe,
South American, and the Far East. In November,
the first of a series of Sectional Training Schools
on international examination was held in Chicago.
Examiners from regions four, seven, and nine attended this school; similar schools will be held for
examiners located in other regions.
Continued close cooperation with the Federal
Reserve Board and the Department of State proved
most beneficial in the supervision and examination
of international offices. That cooperation was extended to the authorities in those foreign countries
where National banks are represented. During the
year, numerous bankers and regulatory officials
from various foreign countries visited the International Division for group discussions and training
sessions of various lengths. The visitors were primarily interested in the function of banking in the
United States. A number described some of the
benefits derived by their countries from the international activities of National banks.
The circulation of some instruments drawn on
certain foreign banks prompted the issuance of a
series of warning bulletins during 1970. This
action, in cooperation with foreign central banks
and the Department of Justice, served to avert the
hazards posed by those activities.
The need for close supervision of foreign banking activities by the directorates of U.S.-based banks
was repeatedly dramatized during the year. The
closures of banks in secrecy countries, and in countries with changing political situations, emphasized
the direct and contingent risks involved in exchange contracts, investments, and other accounts
located in foreign correspondents, subsidiaries, and
branches.

V I I I . Administrative and Management
Developments
In 1970, the Office of the Comptroller of the
Currency achieved further modernization of its administrative practices. The five divisions under
the direction of the Administrative Assistant to the
Comptroller coordinated activities with rewarding
results.
For the Fiscal Management Division, 1970 proved
to be an exceptionally challenging year in terms of
the demands placed upon the financial management information system. The demands for information arose primarily because of the greater
increase in expenditures than in revenue. Also,
there was an increase in the number and types of
reports on budgetary and financial matters required for submission to the Treasury Department.
As a result of the program, initiated in 1967, to
produce a financial information system responsive
to management needs, information was provided in
a timely manner, permitting management decisions
to deal effectively with the rising costs of operations.
The increased reporting requirements of the Treasury Department were met smoothly because comprehensive financial data was available.
The on-going program of improving and
strengthening the financial system of the Comptroller's Office has thus been justified. Additional
major improvements during 1970 included further
elimination of manual accounting procedures
through machine applications and the refinement
of existing machine applications. The purpose was
to obtain more accurate and useful information
under the responsibility-centered cost accounting
aspects of the financial system. The most significant achievement there was the preparation of all
monthly financial statements on an automated
basis. As 1970 came to a close, studies and analyses
were underway concerning the feasibility and need
for assigning general overhead costs to specific costcenters.




The review and analysis of cash forecasting and
cash flow continued to contribute to record investment income.
The Fiscal Management Division was again able
to reduce its staff by one employee through refinement of work procedures. Over a period of Wi
years, the staff has been reduced by 10 employees,
resulting in substantial savings in salary costs to
the Comptroller's Office.
The Personnel Division gave additional emphasis
to programs initiated in 1969, and developed new
personnel policies in 1970 to achieve a more progressive and comprehensive personnel management
program. The Cooperative Work-Study Program,
designed to train and develop college students for
future bank examiner positions, was expanded. At
the end of 1970, the Office had 72 financial interns
in the program including approximately 20 percent
from minority groups. That is considered a realistic
approach in the continuing effort to achieve a more
effective equal employment opportunity program.
The merit promotion plan for non-examiner personnel served to make employees more aware of
promotion opportunities and permitted selections
from among the best qualified. It also resulted in a
substantial increase in the number of vacancies
filled by grade promotions from within the Office.
The Personnel Division played a key role in the
Office-wide training effort for bank examiners. All
facets of examination and all levels and categories
of National bank examiners were involved in this
effort. (See sections on "Bank Examinations," "Fiduciary Activities," and "International Banking.")
A new pay policy was issued in May 1970 which
established a more systematic and equitable basis
for assigning grade levels and determining pay for
all employees. It provides that there shall be equal
pay for substantially equal work, and that pay distinctions will be in proportion to difference in re21

sponsibility and performance. It also provides that
pay rates will be comparable with private enterprise rates for the same levels of work.
As a result of a comprehensive study of the field
examination function, a Guide for Determining
Grade Levels of National Bank Examiner Positions
was issued in December 1970. This included descriptions of the typical responsibilities of National
bank examiners. The basic objectives of the guide
were to better identify a career ladder for examiners, to provide a common understanding of grade
levels, to achieve pay equity, and, to encourage
more effective manpower utilization practices.
An Evaluation of Personnel Management report
was received by the Comptroller in July 1970, from
the Civil Service Commission. This was the result
of an inspection made by Commission representatives of the personnel operations of the Office of
the Comptroller of the Currency. In Chairman
Hampton's letter to Secretary Kennedy, he stated
that the "summary accomplishments in bringing
modern concepts of personnel management to the
operation of his office is indeed impressive."
Several revised personnel procedures were issued
to streamline the paperwork requirements and to
minimize the efforts of managers in requesting personnel actions. They included certain delegations
to regional administrators and the establishment of
a more systematic means for expediting personnel
actions.
As a part of our continuing efforts to emphasize
youth in meeting our organizational objectives, a
youth advisory panel was established in Washington
on September 16, 1970. Initial goals were established, including an effort to achieve better communications between management and employees.
A survey of total staffing revealed approximately
65 percent of all employees are under 35 years of
age including a substantial percentage of those in
executive positions.
In June 1970, all employees were notified of
their rights under Executive Order 11491, Labor
Management Relations in the Federal Service. The
initiation of that program included the establishment of a labor-management relations policy within the Office of the Comptroller. Other provisions
involved the recognition of the supervisory status
of commissioned bank examiners, the forms of
recognition which will be accorded to labor organizations, and implementing instructions essential to
the new program.
During the calendar year 1970, a total of $76,251
22




was awarded to employees for their participation in
the incentive awards program, and $1,850, in the
suggestion program. In addition, a total of $2,136
was granted to five individual employees representing special achievement awards. High quality increase awards were approved for 215 employees in
recognition of their superior performance.
At the request of management, the Personnel
Division developed appropriate materials to permit
division chiefs and other key managers in Washington to analyze their workload in terms of their current and future manpower needs. Organization and
staffing charts, questionnaires, and related materials
were coordinated and summarized in order to facilitate minimum staffing for each organizational segment. Proposals were also submitted to top management for consideration in setting personnel ceilings for the Washington Office departments and divisions, and such ceilings were established.
As in past years, many employees enrolled in a
variety of courses to increase their knowledge and
skill. For example, several of our management
level personnel participated in the Federal Executive Institute Management seminars and Harvard
Graduate School of Business management programs.
A number of studies were conducted and proposals presented for management consideration at
the end of the year. Those included a comprehensive personnel management evaluation program to
be initiated in 1971. It also included proposed
statements of significant personnel management and
training goals to be achieved during 1971. Those
goals contained specific plans for accomplishment
and interim target dates.
In 1970, the Administrative Services Division
underwent a limited reorganization. Based on
operational experience and the results of an internal audit, publication control functions were
assumed at the division level, and the Publications
and Issuance Branch was eliminated as a branch.
Both functions and their personnel were transferred
to the Office of the Director. The division began
publication of an employee newsletter and continued its program of improving the appearance of
Office publications.
Space management activity consisted of completing the relocation of two regional offices, Philadelphia and Portland, to more adequate quarters; the
closing or consolidating of two sub-regional offices;
and the establishing of five new sub-regional offices.
Several offices were relocated in the Washington

headquarters, resulting in greater control, increased
efficiency, and better space utilization. Records disposition schedules were approved for regional
offices. Classification and disposal of remaining
records, stored locally, were completed. The initial
phase of microfilming vital records was largely completed and the up-dating phase was initiated.
In the area of supply and procurement, the issuance of policy and procedural directives for both
Washington and the field resulted in a noticeable
improvement in requisitioning practices and internal operations.
The Internal Audit Division extended its review
of internal operations to include management
audits relating to the activities of operational divisions; previously, the scope of activity had centered
primarily on financial audits. During this period
the division also initiated a program whereby management, both in Washington and in the field
offices, were solicited for ideas on audit areas to be
included in the annual audit plan. The response
was stimulating and the annual audit plan was
adjusted to increase the extent of audit coverage of
field activities.




In 1970, the Management Services Division provided staff support in several areas. A more effective management improvement program was established and expanded to include views and contributions of the field offices. Initial results enhanced
better communications within the office and produced a refinement of procedures at the field level.
This past year saw a continued effort to improve
and stimulate interest in the emergency preparedness program. The Comptroller's Office took part in
a Treasury-wide alerting test which was extended
beyond the regional offices to include, for the first
time, sub-regional offices. Highlighting the program for 1970 was a visit, by Washington staff
members who have emergency preparedness assignments, to the Treasury alternate relocation site.
That visit provided a more realistic understanding
of emergency duties and more insight into the total
program.
Data processing services continued to provide divisions with timely, accurate information and, further, aided economists in various research projects,
among them the recently published monograph,
"Bank Trusts: Investments and Performance."

OFFICE OF THE COMPTROLLER OF THE CURRENCY
Chart of Organization

Comptroller
of the
Currency

National Advisory
Committee on
Banking Policies
and Practices

Chief
Counsel

Comptroller
(Economics)

Administrative
Assistant to the
Comptroller

First Deputy
Comptroller

Deputy
Comptroller

Chief
National Bank
Examiner

Comptroller

L

__i
Deputy
Chief Counsel

Deputy
Comptroller
(FDIC Affairs)

Special
Assistant
(Congressional
Affairs)

Special
Assistant
(Public Affairs)

Deputy
Comptroller
for Trusts

Director,
International
Division

14 Regional
Administrators of
National Banks

Deputy Regional
Administrators

1

Assistant
Chief National
Bank Examiners

Dept. of
Banking &
Economic
Research

Statistical
Division

I ADVISORS I




National Bank
Examiners —
International

Deputy
Administrative Asst..
(Fiscal Management)

Director
Administrative
Services
Division

Director
Management
Services
Division

Comptroller
for Mergers
and Branches

Chief
Representative
in Trusts

Director,
Bank Organization
Division

Regional Advisory
Committees

Deputy Director

Special
Assistant

Regional Counsel

1
Law
Department

Deputy
Administrative Asst.
(Personnel)

National Bank
Examiners

I EXAMINING I

Mergers and
Consolidations
Branch

New Bank
Branch

1
Capital
Increase
Branch

ICORPORATE I

1
Branch
Applications
Branch

Director
Internal Audit
Division

^•ADMINISTRATIVEBT

I X . Financial Operations of the Office of the
Comptroller of the Currency
During 1970, the Office of the Comptroller of the
Currency, as well as many other government agencies and private businesses, experienced rapidly rising costs while at the same time sustaining a slower
rate of income growth. Consequently, various cost
control measures were instituted to offset this condition and, I am pleased to report another successful year in our financial operations.
Total income for the year was $36.8 million, an
increase of 12.9 percent over 1969. This increase is
principally due to the $3.4 million rise in assessment income, resulting from a full year under the
higher assessment rates effected in July 1969, and a
$17.4 billion rise in National bank assets. Disregarding the assessment rate increase, the growth
rate for assessment income is substantially lower
than in previous years because of the decline in the
rate of growth in National bank assets. National
bank assets affecting 1970 assessment income increased only 5.88 percent, compared to an increase
of 12.61 percent the prior year.
Interest on investments continues to be a significant factor in the overall income picture. This income category shows a 33.6 percent rise, to $1.8
million, representing almost 70 percent of the excess of revenue over expenses for the year. Calendar year 1970 represents the third consecutive year
that the annual percentage increase has exceeded
25 percent. This increase reflects the record high
interest rates experienced during the year and the
continuing effort to keep funds fully invested.
Revenue from trust examinations for the year increased $305,000, to $2.0 million, primarily due to a
full year under the revised rates effective in mid1969. Branch investigation income was up by
$71,000 reflecting a continued high rate of activity
in this area.
Income from new charter applications increased




$34,000, while merger and consolidation fees decreased by $59,000. All other income categories remained fairly constant with 1969 levels.
Total expenses amounted to $34.2 million compared to $28.8 million in the previous year, an increase of $5.4 million. This amounts to an 18.8
percent increase, 5.9 percent greater than the increase in revenue. This significant increase in expenses occurred mainly during the last six months
of the calendar year, and generally reflects the
necessary increase in total employment. In order
to combat these rapidly rising costs, which were also
being experienced by other government agencies
and private businesses, it was necessary to institute
reduced personnel ceilings and certain other cost
control measures to maintain a proper balance between income and expense.
Salaries, personnel benefits, and travel expenses
amounted to $32.2 million, representing 94.2 percent of the total expenses for the year, and a rise of
19.2 percent over the previous year. Significant factors causing this rise were: (1) the 6 percent congressional pay raise effective January 1, 1970, (2) an
8 percent increase in the total number of employees, and (3) a full year under higher per diem and
other travel costs.
The remaining expenses totaled $2.0 million, an
increase of $227,000 which represented higher costs
for education, rent, and communications. These expenses also include a contribution of $50,000 to
provide financial assistance to the Presidential Commission on Financial Structure and Regulation.
The equity account is in reality a reserve for contingencies. Transfers of $2.6 million increased the
equity to $19.9 million at year-end. This represents
a 6 % months' reserve for operating expenses,
based on the level of expenses over the last six
months of 1970.

25

TABLE 11

OFFICE OF THE COMPTROLLER OF THE CURRENCY
BALANCE SHEET
December 31
Assets

1970

Current assets:
Cash
Obligations of U.S. Government, at cost (approximates market value)
Accounts receivable
Accrued interest
Travel advances
Prepaid expenses and other assets

1969

$67,875
7,243,415
280,439
455,070
408,152
70,036

$196,540
8,419,153
77,015
321,764
375,598
53,494

8,524,987

9,443,564

17,284,418

13,115,282

872,788
398,784
1,271,572
581,368

779,966
389,679
1,169,645
481,757

$26,499,609

$23,246,734

Current liabilities:
Accounts payable and other accruals
Salary deductions and withholdings
Accrued travel and salary

$211,623
71,615
1,724,656

$201,387
78,139
1,393,328

Total current liabilities
Accumulated annual leave
Closed receivership funds

2,007,894
1,840,243
2,706,683

1,672,854
1,577,011
2,708,387

6,554,820
19,944,789

5,958,252
17,288,482

$26,499,609

$23,246,734

Total current assets
Obligations of U.S. Government, at cost (approximates market value)
Fixed assets, at cost:
Furniture and
Office machinery and equipment

fixtures

Less accumulated depreciation
Total assets
Liabilities and Comptroller's Equity

Total liabilities
Comptroller's equity
Total liabilities and Comptroller's equity

26




TABLE

12

OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENT OF REVENUE, EXPENSES AND COMPTROLLER'S EQUITY
Year ended December 31
Revenue:
Semi-annual assessments
Examinations and investigations
Examination reports sold
Revenue from investments
Other

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

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




1970

1969

$31,336,670
2,927,733
500,520
1,836,908
238,041

$27,939,249
2,525,087
497,560
1,374,760
288,224

36,839,872

32,624,880

24,781,477
1,949,486
3,604,529
1,868,782
509,129
89,347
194,533
125,280
68,963
96,939
369,040
98,136
243,631
184,293

21,133,705
1,568,850
2,838,279
1,470,600
366,699
69,551
333,246
115,328
94,375
90,246
306,600
123,334
135,007
117,824

34,183,565

28,763,644

2,656,307

3,861,236

17,288,482

13,427,246

$19,944,789

$17,288,482

27

TABLE 13
OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENT OF SOURCE AND APPLICATION OF FUNDS
Year ended December 31
1970
Funds were provided by:
Excess revenue over expenses
Add charges not requiring current outlay of funds:
Depreciation
Net increase in accumulated annual leave
Net loss on sales of fixed assets
Total funds provided
Funds were applied to:
Net increase in investment in long term U.S. Government obligations
Purchases of furniture and fixtures
Purchases of machinery and equipment
Changes in closed receivership funds
Total funds applied
Increase (decrease) in working capital
Current assets

1969

$2,656,307

$3,861,236

125,280
263,232
10,148

115,328
218,583
12,679

3,054,967

4,207,826

4,169,136
100,039
37,705
1,704

727,159
92,483
25,639
(121)

4,308,584

845,160

(1,253,617)

3,362,666

8,524,987

9,443,564

2,007,894

1,672,854

Working capital at end of year

6,517,093

7,770,710

Working capital at beginning of year

7,770,710

- 4,408,044

$(1,253,617)

$3,362,666

Current liabilities

Working capital increase (decrease)

-

OPINION OF INDEPENDENT ACCOUNTANT
To the Comptroller of the Currency
Office of the Comptroller of the Currency
In our opinion, the accompanying balance sheets, the related statements
of revenue, expenses and Comptroller's equity and the statements of source and
application of funds present fairly the financial position of the Office of the
Comptroller of the Currency at December 31, 1970 and 1969, the results of its
operations and the supplementary information on funds 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.
PRICE WATERHOUSE & CO.
WASHINGTON, D.C.

January 29, 1971

28







APPENDIX A

Merger Decisions, 1970

Merger* Decisions, 1970
/. Mergers consumated, involving two or more operating banks'
Page

Page
Jan. 1, 1970:
The Delaware County National Bank, Chester, Pa.
National Bank of Chester County and Trust
Company, West Chester, Pa.
Consolidation
Jan. 2, 1970:
National Community Bank of Rutherford, Rutherford, N.J.
The Bank of Sussex County, Franklin, N.J.
Merger
Jan. 9, 1970:
New Jersey Bank (N.A.), Clifton, N.J.
Peoples National Bank of Sussex County, Sparta,

34

36

N.J.

Merger
Jan. 9, 1970:
Northwestern National Bank of Sioux Falls, Sioux
Falls, S. Dak.
Community State Bank of Lake Preston, Lake
Preston, S. Dak.
Merger
Jan. 19, 1970:
The Citizens National Bank of Bryan, Bryan, Ohio
The West Unity Banking Company, West Unity,
Ohio
Merger
Jan. 23, 1970:
Wachovia Bank and Trust Company, N.A., Winston-Salem, N.C.
Citizens Bank & Trust Company of Andrews,
Andrews, N.C.
Merger
Jan. 30, 1970:
United States National Bank, San Diego, Calif.
Southland National Bank, Yucaipa, Calif.
Purchase
Feb. 20, 1970:
North Carolina National Bank, Charlotte, N.C.
Marion Bank and Trust Company, Marion, N.C.
Merger
Feb. 27, 1970:
County National Bank, Middletown, N.Y.
Rockland National Bank, Suffern, N.Y.
Merger
Feb. 27, 1970:
New Jersey Bank ( N J \ . ) , Clifton, N.J.
Jersey State Bank, River Edge, N.J.
Merger
Feb. 28, 1970:
First National Bank, Bowling Green, Ohio
Hardy Banking Company, North Baltimore, Ohio
Merger
Mar. 13, 1970:
Central Penn National Bank, Bala-Cynwyd, Pa.
Community Bank & Trust Company, Paoli, Pa.
Merger

37

40

41

42

45

45

47

51

53

54

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




Mar. 13, 1970:
Virginia National Bank, Norfolk, Va.
The First National Bank of Harrisonburg, Harrisonburg, Va.
Merger
Mar. 18, 1970:
First National Bank in Mount Clemens, Mount
Clemens, Mich.
The Armada State Bank, Armada, Mich.
Merger
Mar. 31, 1970:
First National Bank in Mansfield, Mansfield, Pa.
The Citizens National Bank, Blossburg, Pa.
Merger
Apr. 10, 1970:
Wells Fargo Bank, N.A., San Francisco, Calif.
Los Padres National Bank, Santa Maria, Calif.
Merger
Apr. 11, 1970:
First National Bank in Mansfield, Mansfield, La.
Bank of Grand Cane, Grand Cane, La.
Purchase
Apr. 17, 1970:
The Connecticut National Bank, Bridgeport, Conn.
Atlantic National Bank, Stamford, Conn.
Merger
Apr. 30, 1970:
First National Bank of Lincolnton, Lincolnton,
N.C.
The First National Bank of Mooresville, Mooresville, N.C.
Merger
Apr. 30, 1970:
Old National Bank of Washington, Spokane, Wash.
Commercial Bank of Washington, Twisp, Wash.
Merger
Apr. 30, 1970:
South Jersey National Bank, Camden, N.J.
Union National Bank and Trust Company, Mount
Holly, N.J.
Merger
May 1, 1970:
The First National Bank of Maryland, Baltimore,
Md.
First National Bank of Harford County, Bel Air,
Merger
Md.
May 11, 1970:
First Trenton National Bank, Trenton, N.J.
New Jersey National Bank and Trust Company,
Neptune, N.J.
Merger
May 18, 1970:
The Cassia National Bank of Burley, Burley, Idaho
Lava Hot Springs State Bank, Lava Hot Springs,
Idaho
Merger
May 22, 1970:
Peoples National Bank of New Jersey, Westmont,
Haddon Township, N.J.

56

58

59

60

62

63

65

66

68

70

70

73

Page
The Vineland National Bank and Trust Company,
Vineland, N.J.
Merger
May 29, 1970:
Zions First National Bank, Salt Lake City, Utah
Bank of Commerce, Magna, Utah
Purchase
June 1, 1970:
Virginia National Bank, Norfolk, Va.
The Merchants and Farmers Bank, Smithfield, Va.
Merger
June 2, 1970:
The First National Bank of Houlton, Houlton,
Maine
The First National Bank of Fort Fairfield, Fort
Fairfield, Maine
Merger
June 11, 1970:
Southern California First National Bank, San
Diego, Calif.
Gateway National Bank, El Segundo, Calif.
Merger
June 30, 1970:
Bristol County Trust Company, Taunton, Mass.
The First National Bank of Attleboro, Attleboro,
Mass.
Merger
June 30, 1970:
First National Bank of South Jersey, Egg Harbor
Township, N.J.
The First National Bank of Williamstown, Williamstown, N.J.
Merger
June 30, 1970:
First National Bank of Westmoreland, Greensburg, Pa.
The Peoples National Bank of Tarentum, Tarentum, Pa.
Consolidation
June 30, 1970:
State Bank of Whiting, Whiting, Ind.
The First National Bank of Cedar Lake, Cedar
Lake, Ind.
Consolidation
June 30, 1970:
The Merchants National Bank of Allentown, Allen town, Pa.
The Fogelsville National Bank, Fogelsville, Pa.
Merger
June 30, 1970:
Zions First National Bank, Salt Lake City, Utah
Bank of St. George, St. George, Utah
Purchase
July 1, 1970:
The First National Bank of Ebensburg, Ebensburg, Pa.
The Peoples Bank of Clymer, Clymer, Pa.
Merger
July 1, 1970:
The Idaho First National Bank, Boise, Idaho
Fidelity National Bank of Twin Falls, Twin Falls,
Idaho
Merger
July 6, 1970:
National Bank of North America, New York, N.Y.
Trade Bank and Trust Company, New York, N.Y.
Consolidation
July 6, 1970:
Peoples National Bank of Washington, Seattle,
Wash.
Langley State Bank, Langley, Wash.
Purchase
July 6, 1970:
University National Bank, Rockville, Md.
Montgomery Banking and Trust Company, Rockville, Md.
Merger




74

76

77

80

82

83

85

86

88

89

91

91

93

93

95

97

Page
July 9, 1970:
The Merchants National Bank of Burlington, Burlington, Vt.
Barre Trust Company, Barre, Vt.
Merger
July 10, 1970:
Trust Company National Bank, Morristown, N.J.
Montclair National Bank and Trust Company,
Montclair, N.J.
Consolidation
July 17, 1970:
First County National Bank and Trust Company,
Woodbury, Woodbury, N.J.
The First National Bank and Trust Company of
Paulsboro, Paulsboro, N.J.
Pitman National Bank and Trust Company, Pitman, N.J.
Merger
July 17, 1970:
The Farmers National Bank of Salem, Salem, Ohio
Citizens Savings Bank, Columbiana, Ohio
Merger
July 27, 1970:
First National Bank of Eastern North Carolina,
Jacksonville, N.C.
The State Bank of Wingate, Wingate, N.C.
Merger
July 31, 1970:
First & Merchants National Bank, Richmond, Va.
Suburban National Bank of Virginia, (McLean
P.O.), Fairfax County, Va.
Merger
July 31, 1970:
Lincoln National Bank and Trust Company of
Central New York, Syracuse, N.Y.
The National Exchange Bank of Boonville, Boonville, N.Y.
Merger
July 31, 1970:
Security Pacific National Bank, Los Angeles, Calif.
Bank of Sacramento, Sacramento, Calif.
Merger
July 31, 1970:
The Commercial National Bank of Kansas City,
Kansas City, Kans.
Exchange State Bank of Kansas City, Kansas City,
Kans.
Merger
Aug. 1, 1970:
Southern National Bank of North Carolina, Lumberton, N.C.
Bank of Charlotte, Charlotte, N.C.
Merger
Aug. 7, 1970:
National Bank of Agriculture, Delano, Calif.
The First National Bank of Caruthers, Caruthers,
Calif.
Consolidation
Aug. 14, 1970:
Maine National Bank, Portland, Maine
The First National Bank of Pittsfield, Pittsfield,
Maine
Merger
Aug. 14, 1970:
The Indian Head National Bank of Nashua,
Nashua, N.H.
The Wilton National Bank, Wilton, N.H.
Merger
Aug. 17, 1970:
National Bank of Washington, Tacoma, Wash.
The Pacific National Bank of Seattle, Seattle,
Wash.
Consolidation
Aug. 28, 1970:
North Carolina National Bank, Charlotte, N.C.

98

100

102

104

106

107

109

Ill

113

115

116

117

118

120

31

Page
The State Commercial Bank, Thomasville, N.C.
Merger
Aug. 28, 1970:
The First National Bank of Allentown, Allentown,
Pa.
Saucon Valley Trust Company, Hellerton, Pa.
Merger
Aug. 31, 1970:
Easton National Bank and Trust Company, Easton,
Pa.
The Citizens Bank of Wind Gap, Wind Gap, Pa.
Merger
Aug. 31, 1970:
National Bank and Trust Company, Charlottesville, Va.
The National Bank of Orange, Orange, Va.
Merger
Sept. 1, 1970:
Midland National Bank, Milwaukee, Wis.
The Home Bank, Milwaukee, Wis.
Merger
Sept. 9, 1970:
Carlton National Bank, Carlton, Minn.
The First National Bank of Carlton, Carlton,
Minn.
Purchase
t
Sept. 10, 1970:
National Bank of South Dakota, Sioux Falls, S.
Dak.
Security Bank, Madison, S. Dak.
Merger
Sept. 25, 1970:
Old National Bank of Washington, Spokane, Wash.
North West Bank, Seattle, Wash.
Merger
Sept. 28, 1970:
The Park National Bank of Newark, Newark, Ohio
The Peoples State Bank, Granville, Ohio
Purchase
Sept. 30, 1970:
Marine National Bank, Erie, Pa.
The First National Bank of Edinboro, Edinboro,
Pa.
Merger
Sept. 30, 1970:
Old National Bank of Washington, Spokane, Wash.
First National Bank in Tonasket, Tonasket, Wash.
Purchase
Sept. 30, 1970:
Zions First National Bank, Salt Lake City, Utah
Bountiful State Bank, Bountiful, Utah
Purchase
Oct. 13, 1970:
National Bank of North America, New York, N.Y.
First National Bank in Yonkers, Yonkers, N.Y.
Consolidation
Oct. 30, 1970:
First National Bank of South Jersey, Egg Harbor
Township, N.J.
The First National Bank of Pedricktown, Pedricktown, N.J.
Merger

124

126

127

129

131

132

132

133

Oct. 30, 1970:
Hartford National Bank and Trust Company,
Hartford, Conn.
General Bank and Trust Company, New Haven,
Conn.
Merger
Oct. 30, 1970:
The Warren National Bank, Warren, Pa.
The Gold Standard National Bank of Marienville, Marienville, Pa.
Purchase
Nov. 6, 1970:
The Citizens National Bank, Bryan, Ohio
The Pioneer Banking Company, Pioneer, Ohio
Merger
Nov. 6, 1970:
Wells Fargo Bank, N.A., San Francisco, Calif.
The First National Bank of Holtville, Holtville,
Calif.
Merger
Nov. 14, 1970:
First Union National Bank of North Carolina,
Charlotte, N.C.
The Bank of French Broad, Marshall, N.C.
Merger
Nov. 23, 1970:
Virginia National Bank, Norfolk, Va.
Carroll County Bank, Hillsville, Va.
Merger
Dec. 1, 1970:
The Riddell National Bank of Brazil, Brazil, Ind.
The First National Bank of Center Point, Center
Point, Ind.
Merger
Dec. 4, 1970:
First National State Bank of New Jersey, Newark,

Page

142

144

145

147

148

149

151

N.J.

135

136

137

138

139

141

Orange Valley Bank, Orange, N.J.
Merger
Dec. 7, 1970:
National Bank & Trust Company of Central Pennsylvania, York, Pa.
The Reading Trust Company, Reading, Pa.
Lancaster County Farmers National Bank, Lancaster, Pa.
Consolidation
Dec. 31, 1970:
First Citizens National Bank, Mansfield, Pa.
Grange National Bank of Potter County, Ulysses,
Pa.
Merger
Dec. 31, 1970:
First National Bank of Central Jersey, Somerville,

152

154

154

N.J.
The First National Bank of Roselle, Roselle, N.J.
Consolidation
Dec. 31, 1970:
The Littleton National Bank, Littleton, N.H.
Lisbon National Bank, Lisbon, N.H.
Merger

156

157

//. Mergers consummated pursuant to corporate reorganization,
involving a single operating bank*
Page
Jan. 3, 1970:
Coshocton National Bank, Coshocton, Ohio
National Bank of Coshocton, Coshocton, Ohio
Merger
Jan. 3, 1970:
First National Bank of Cambridge, Cambridge,
Ohio

159

•Includes mergers and consolidations where the emerging bank is a National bank.




Page
The Guernsey County National Bank, Cambridge,
Ohio
Merger
Jan. 14, 1970:
First National Bank of New Jersey, Newark, N.J.
National State Bank of New Jersey, Newark, N.J.
Merger
Feb. 24, 1970:
Gallatin National Bank, Uniontown, Pa.

159

160

Page

Blythe National Bank, Uniontown, Pa.
Merger
Feb. 27, 1970:
Columbus National Bank of Rhode Island, Providence, R.I.
Rhodes National Bank, Providence, R.I.
Merger
Mar. 25, 1970:
Cumberland County National Bank and Trust
Company, New Cumberland, Pa.
CCNB National Bank, New Cumberland, Pa.
Merger
Apr. 30, 1970:
The Citizens National Bank of Chillicothe, Chillicothe, Mo.
Chillicothe National Bank, Chillicothe, Mo.
Merger
Apr. 30, 1970:
The Fort Worth National Bank, Fort Worth, Tex.
Bank of Fort Worth, N.A., Fort Worth, Tex.
Merger
May 1, 1970:
The First National Bank of St. Joseph, St. Joseph,
Mo.
First National Bank of Buchanan County, St.
Joseph, Mo.
Merger
June 12, 1970:
National Newark & Essex Bank, Newark, N.J.
Essex Bank, N.A., Newark, N.J.
Merger
June 12, 1970:
Raritan Valley National Bank, Edison Township,
N.J.
Second Raritan Valley National Bank, Edison
Township, N.J.
Merger
June 12, 1970:
The Sussex and Merchants National Bank of Newton, Newton, N.J.
The Second Sussex and Merchants National Bank
of Newton, Newton, N.J.
Merger
June 18, 1970:
New England Merchants National Bank of Boston,
Boston, Mass.
New England Merchants Bank (N.A.), Boston,
Mass.
Merger
July 1, 1970:
First National Bank of Warren, Warren, Mich.
Warren National Bank, Warren, Mich.
Merger
July 28, 1970:
The National Bank of Auburn, Auburn, N.Y.

161

161

162

163

163

164

165

165

166

167

168

Page

Bank of Auburn, N.A., Auburn, N.Y.
Merger
August. 31, 1970:
The Peoples National Bank and Trust Company,
Dover, Ohio
The F.B.G. National Bank of Dover, Dover, Ohio
Merger
Sept. 30, 1970:
Peoples National Bank of Monmouth County,
Hazlet Township, N.J.
Second Peoples National Bank of Monmouth
County, Hazlet Township, N.J.
Merger
Sept. 30, 1970:
The Cumberland National Bank of Bridgeton,
Bridgeton, N.J.
Cumberland County National Bank, Bridgeton,
N.J.
Merger
Sept. 30, 1970:
The Third National Bank & Trust Company of
Camden, Camden, N.J.
The Fourth National Bank & Trust Company of
Camden, Camden, N.J.
Merger
Dec. 10, 1970:
Bank of the Southwest National Association, Houston, Tex.
Southwest Bank, N.A., Houston, Tex.
Merger
Dec. 16, 1970:
The First National Bank at East Palestine, East
Palestine, Ohio
East Palestine National Bank, East Palestine, Ohio
Merger
Dec. 21, 1970:
City National Bank, Hackensack, N.J.
First National State Bank of North Jersey, Hackensack, N.J.
Merger
Dec. 21, 1970:
First National Bank of Spring Lake, Spring Lake,
N.J.
First National State Bank of Spring Lake, Spring
Lake, N.J.
Merger
Dec. 21, 1970:
The Edison Bank, South Plainfield, N.J.
The Edison Bank, N.A., South Plainfield, N.J.
Merger
Dec. 21, 1970:
The Warren County National Bank, Washington,
N.J.
The Second Warren County National Bank, Washington, N.J.
Merger

168

169

170

171

171

172

173

174

174

175

176

///. Additional Approvals
Page

A. Approved, but in litigation
Oct. 9, 1970:
Catamount National Bank, North Bennington,
Vt.
The County National Bank of Bennington, Bennington, Vt.
Consolidation

177

Page

B. Approved, but consummation deferred due to related litigation
Feb. 2, 1970:
The Peoples National Bank of Manassas, Manassas, Va.
Manassas Bank, N.A., Manassas, Va.
Merger

179

NOTE: The 1967 Annual Report carried the Comptroller's decision approving the proposed merger of the Phillipsburg National Bank and Trust Company and the Second National Bank of Phillipsburg, both of Phillipsburg, N.J., under the heading "Approved, but in litigation." Plans for the merger were abandoned after the Supreme Court remanded the case to the
District Court for further findings in 1970.
The 1969 Annual Report carried the Comptroller's decision approving the proposed merger of The First National Bank
of Sunbury, Sunbury, Pa., and Snyder County Trust Company, Selinsgrove, Pa., under the "Approved, but in litigation" heading. After the filing of an action against the merger by the Antitrust Division in 1969, the banks abandoned their merger
plans on April 22, 1970.




7. Mergers consummated, involving two or more operating banks
THE DELAWARE COUNTY NATIONAL BANK, CHESTER, PA., AND NATIONAL BANK OF CHESTER COUNTY AND TRUST COMPANY,
WEST CHESTER, PA.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

National Bank of Chester County and Trust Company, West Chester, Pa. (552),
with. . .
and The Delaware County National Bank, Chester, Pa. (355), which had
consolidated Jan. 1, 1970, under charter of the latter bank (355) and title
"Southeast National Bank of Pennsylvania." The consolidated bank at date of
consolidation had

COMPTROLLER S DECISION

On August 12, 1969, The Delaware County National Bank, Chester, Pa., and National Bank of
Chester County and Trust Company, West Chester, Pa., applied to the Comptroller of the Currency for permission to consolidate under the
charter of the former and with the title "Southeast
National Bank of Pennsylvania."
The Delaware County National Bank, the
charter bank, was organized in 1814 as the Bank of
Delaware County. In 1864 it became a National
bank and adopted its present name. This bank operates 11 offices and has total resources of $161 million.
The charter bank is headquartered in the city
of Chester and serves the southern portion of Delaware County. This county, which has an estimated
population of 553,000, is one of the three counties
bordering on Philadelphia County. Delaware
County is considerably smaller in area than the
other two, Bucks and Montgomery. Its farthest
reach extends only 20 miles from the city of Philadelphia, and it is the most urbanized of the three
counties. Its principal city, Chester, is located between Wilmington, 12 miles to the south, and
Philadelphia, 6 miles to the north.
Delaware County is mostly urban and industrial.
In 1960, 96 percent of the county's population was
characterized by the Census Bureau as urban, with
the rest rural. Of the total countywide payroll in
1967, $800 million, or 57 percent, was derived from
employment in manufacturing, 17 percent from
wholesale and retail trading, and 11 percent from
other types of services. Agricultural employment
contributed not more than 0.2 percent.
The charter bank operates all of its 11 branches
in Delaware County. Two of these branches are actually extensions of the main office as they are lo34




$103,691,564
161,059,614
264,751,178

8
12

20

cated across the street from it. Three branches
have been established within the last four years in
an effort to keep pace with branching inroads
being made by out-of-county banks. Additional
branching at that pace can only be undertaken by
significantly increasing the pressure on the bank's
earnings and capital position.
The National Bank of Chester County, the consolidating bank, was first organized as the Bank of
Chester County in 1814. In 1864 it became a National bank and adopted its present name.
The consolidating bank, with resources of $92
million, is headquartered in West Chester, Pa., the
county seat of Chester County. This bank serves a
major portion of the county through a network of
nine branch offices. Chester County and the surrounding area were, until a dozen years ago, primarily dependent upon an agricultural economy.
However, the population movement from Philadelphia, approximately 27 miles east, has resulted in a
heavy demand for housing and the conversion of
farmland into residential communities.
Eight of the nine offices operated by the consolidating bank are located in Chester County. The
branch located outside of the county is just across
the line in Delaware County. It is estimated that
95 percent of the consolidating bank's total deposits are derived from Chester County.
The charter bank faces strong competition in its
service area. Under Pennsylvania law, a bank may
branch within the county of its head office, and
counties contiguous thereto. As Delaware County,
the service area of the charter bank, is contiguous
to Philadelphia, the large metropolitan banks are
permitted to branch into Delaware County. There
are presently six Philadelphia banks conducting
branch operations in Delaware County. All of
these competing banks are larger in overall terms

than the charter bank. Two of the six have more
offices in Delaware County than does the charter
bank.
Three Montgomery County banks also conduct
branch operations in Delaware County. Two of
these are former Philadelphia banks which have
moved their main offices, and both are substantially larger than the charter bank. At present, the
charter bank, which was once the county's leading
bank, is the third largest bank in terms of total
offices, and ninth largest in total resources.
The consolidating bank also faces strong competition in its market area and anticipates increasing
competitive pressure in the near future. While
Chester County is not contiguous to Philadelphia,
and banks headquartered in Philadelphia are not
permitted to branch into Chester County, three
Philadelphia banks have moved their head offices
to Montgomery County, and two of these have followed with branches into Chester County. It is anticipated that other Philadelphia banks will take
this route into Chester County. As these city banks
expand into Chester County by merger, or otherwise, the consolidating bank will be under increasing pressure to change its circumstances or lose customers.
At present there is little evidence of competition
between the charter bank and consolidating bank.
Their head offices are approximately 17 miles
apart, and all but one of the offices of each of the
banks is at least 10 miles from the office of the
other. The one exception is the office of the consolidating bank which is in Delaware County, 1 mile
from the Brandywine office of the charter bank.
This office of the applicant accounts for only 0.6
percent of its total deposits, and the office of the
consolidating bank in Delaware County, which has
been in existence for 10 years, accounts for 4.5 percent of its deposits.
Consummation of the proposed consolidation
will make available to all customers at Chester
County, the services presently available at Delaware County National Bank. Consummation of the
consolidation of these two banks will insure a responsiveness to the needs of individual customers
in the resulting service area that is not always
provided by the larger Philadelphia-based banks. It




will ensure continued local control of a larger
bank designed to serve local needs.
Applying the statutory criteria, it is concluded
that the proposed consolidation is in the public interest and the application is, therefore, approved.
OCTOBER 24,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are approximately 1 mile apart, near Painters Crossroads,
in Delaware County. While one of the largest
banks in the Philadelphia area has approval to locate a branch in this immediate area, it seems clear
that the proposed merger would eliminate some
existing competition between the merging banks in
this localized market. Substantial distances and numerous offices of other commercial banks, including offices of large Philadelphia-based banks, separate the remainder of the merging banks' offices.
Both of the merging banks face substantial
competition from very large banks which operate
offices throughout the Greater Philadelphia Area.
Under Pennsylvania law, both merging banks
could be permitted to branch de novo into the
service areas of one another. Both appear to possess the resources necessary to open new offices in
attractive areas.
DCNB is the ninth largest of 11 commercial
banks operating offices in Delaware County. As the
only locally headquartered bank, however, it holds
approximately 21 percent of the IPC demand deposits located therein. Delaware County is adjacent
to Philadelphia and Montgomery counties, a fact
which permits the operation of branch offices in
Delaware County by all of the very large banks
headquartered in and around Philadelphia. Most
of these large banks already enjoy substantial and
growing shares of the Delaware County market.
While NBC's entry into Delaware County through
merger with DCNB would result in its affiliation
with a bank with a leading share of the Delaware
County market, the presence of existing and increased competition from a substantial number of
large Philadelphia banks indicates that the proposed merger would be unlikely to have a substantially adverse effect on potential competition in
Delaware County.

35

NATIONAL COMMUNITY BANK OF RUTHERFORD, RUTHERFORD, N J . ,

AND T H E BANK OF SUSSEX COUNTY, FRANKLIN,

NJ.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Bank of Sussex County, Franklin, N.J., with
and National Community Bank of Rutherford, Rutherford, NJ. (5005), which
had
merged Jan. 2, 1970, under charter and title of the latter bank (5005). The
merged bank at date of merger had. .

COMPTROLLER'S DECISION

On August 11, 1969, the National Community
Bank of Rutherford, Rutherford, N. J., and The
Bank of Sussex County, Franklin, N.J., applied to
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
former.
National Community Bank of Rutherford, the
charter bank, was organized as a National bank in
1895. This bank has total assets of $357 million,
and currently operates 21 offices throughout Bergen County.
Bergen County is located in the northeastern
corner of New Jersey and is bordered on the north
by New York State, on the east by the Hudson
River, and on the south and west by Passaic, Essex,
and Hudson counties. The population of the
county was 913,520 in 1968, a growth of 17.1 percent over the 1960 figure. Because of its proximity
to New York City, 45 percent of its wage earners
commute there daily. The county's economy is well
diversified with numerous sizeable industrial,
wholesale, and retail centers providing a varied
base. The continuing influx of commerce and industry assures a favorable economic outlook.
The Bank of Sussex County, the merging bank,
has total assets of $51 million, and currently operates six banking offices scattered throughout Sussex
County. The merging bank was organized in 1919
as the Sussex County Trust Company, and operated
as such until June 1963 when it merged with The
Farmers National Bank, Sussex, N. J., and assumed
its present title. Although the last examination of
the merging bank indicates satisfactory condition,
growth of capital funds has not kept pace with the
steady increases in deposits resulting from the
rapid economic growth of the county. Also, provisions for the succession of senior management personnel, some of whom have attained retirement
age, have not been adequate.
Sussex County, located in the northwestern corner of the State, has an estimated population of
36




To be
operated

S55, 387,215

6

374, 309,033

23

430, 173,045

29

68,120, with an influx of summer residents of between 130,000 and 200,000, most of whom are attracted by the numerous lakes and resorts in the
area. There are presently no major industries in
the county. Approximately one-third of the area is
farm land. An estimated 40 percent of the working
population travels outside the county for employment. Future industrial development can be expected as a result of two Federal conservation projects, currently under construction along the
Delaware River, which will provide an economical
source of electrical energy and extensive recreational facilities.
There is virtually no competition between the
merging banks. The participants' head offices are
located approximately 40 miles apart. The charter
bank's Oakland office is 28 miles from the closest
office of the merging bank. Between those two
offices are many offices of major competing banks.
The proposed merger would not tend to reduce
competition.
Consummation of the proposed merger will
serve the convenience and needs of Sussex County.
The economic growth of this county has resulted
in increased demands upon local banks to provide
adequate credit and specialized services. The Bank
of Sussex County has not been able to keep pace
with those demands. Through this merger, the
charter bank will able to extend its broad range
of specialized services into the Sussex County area.
Consummation of this merger will not only solve a
management succession problem of the merging
bank, but it will also enable the resulting bank to
compete more effectively with the large banks in
the area.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest and the application is, therefore, approved.
NOVEMBER 21,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are ap-

proximately 28 miles apart. Many offices of competing banks, including some of the largest banks
in northern New Jersey, are located in the intervening area. Therefore it would appear that the proposed merger would not eliminate any substantial
amount of existing competition between the merging banks.
Recent legislation in New Jersey has greatly
broadened the sphere of permissible branch office
operation for commercial banks, which may now
operate offices anywhere in the newly created banking district in which they are located. However,
this legislation retains community-wide home office
protection against de novo branching and provides
branch office protection in communities of less
than 7,500 population. The merging banks are
both located in the First Banking District; therefore the proposed merger would permanently eliminate any possibility of future competition between
them in areas presently served by either, or in
other areas of the district.
National Community clearly has the capability
to open de novo offices wherever legally permissible and financially attractive. However, while Sussex County has a bright economic future, present
opportunities for the establishment of de novo
branches within the county are somewhat limited
by New Jersey's home and branch office protection
laws.

The above-mentioned legislation has induced
substantial market extension activity by many of
the State's larger banks, both through de novo
branching and through merger. Major merger activity by the largest banks in a district could result
in undue domination of commercial banking in
the district by a few very large banking institutions. We therefore consider it important from a
competitive standpoint that the larger banks in a
given banking district enter new market areas
through de novo branching, or in the alternative
through merger with a small bank in the local
area.
In this manner, leading local banks may be preserved to offer effective competition to new large
entrants in the local markets. Such banks are also
sources of potential competition, on a district-wide
basis, to the large district banks, through affiliation
with one another in new banking institutions, including bank holding companies.
Through acquisition of Sussex Bank, National
Community, one of the larger banks in the First
District will immediately acquire about 34 percent
of total Sussex County commercial bank deposits,
eliminating the leading local bank, and the one
most capable of offering competition to it should it
enter Sussex County through merger with a
smaller bank. We conclude that the proposed
merger would have an adverse effect on competition.

NEW JERSEY BANK (N.A.), CLIFTON, N.J., AND PEOPLES NATIONAL BANK OF SUSSEX COUNTY, SPARTA, N J .
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Peoples National Bank of Sussex County, Sparta, N.J. (15375), with
New Jersey Bank (National Association), Clifton, N J . (15709), which had
merged Jan. 9, 1970, under charter and title of the latter bank (15709). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On September 4, 1969, Peoples National Bank of
Sussex County, Sparta, N. J., and New Jersey Bank
(N. A.), Clifton, N. J., applied to the Office of the
Comptroller of the Currency for permission to
merge, under the charter and with the title of the
latter.
New Jersey Bank (N. A.), with IPC deposits of




$8,599,317
506,883,752
515,199,963

To be
operated

2
21
23

$370.5 million, was originally chartered in 1869,
and currently operates 19 branch offices, all in the
southern portion of Passaic County. The charter
bank is a well-managed and progressive institution
offering a full range of banking services to its
widely diversified customers.
Passaic County, located in the northeastern section of New Jersey, contains 16 municipalities
37

with an estimated population of 464,000. The
three most populated municipalities in the county
are Paterson, Clifton, and Passaic, which together
comprise the southern end of the county and contain an aggregate population of 294,000. As a result of Passaic County's proximity to New York
City, it has been able to attract numerous manufacturing, wholesaling, and retailing facilities. The
favorable commuting situation existing between
Passaic County and the major commercial centers
of New York and northern New Jersey, coupled
with a generally favorable tax situation, has caused
housing in the county to become extremely desirable with new home construction continuing at a
steady pace and the number of new households increasing by 4,000 during 1968 alone. Population in
the county has increased more than 14 percent since
1960, and the population of every municipality has
also grown.
New Jersey Bank (N. A.) is one of eight commercial banks which together operate a total of 52
offices, and hold resources of $1.3 billion in Passaic
County. While New Jersey Bank is the largest commercial bank in the county, First National Bank of
Passaic County ranks second, with total assets of
$419 million and 19 offices. Because of the proximity of Passaic County to New York, and the fact
that many county residents commute to New York
for employment, the large banks operating in New
York City also compete on a substantial basis in
Passaic County.
The Peoples National Bank of Sussex County,
with IPC deposits of $6.2 million, commenced operations in 1964 and currently operates one branch
in Sussex County, located 11.8 miles north of the
main office. The merging bank is essentially a
country bank, generally not considered sufficiently
equipped to deal with the anticipated growth of
the area in which it operates. It has a capital deficiency problem, an imminent management succession problem, and a lending limit that is inadequate for existing and future needs.
Sussex County N.J., has an estimated population
of 70,000 and is located in the northwestern corner
of the State. The county encompasses an area of
526.3 square miles and is divided into 24 municipalities, the largest of which are Sparta Township,
with a population of about 10,000, and Newton
Town, with a population of about 8,200. All other
municipalities in the county have estimated population of less than 5,000. The area is generally rural
and agricultural, containing approximately 500
38




farms which utilize about one-third of the available land area. The topography, generally hilly
woodland dotted with numerous lakes and miles of
streams and rivers, makes the area ideal for recreational and resort purposes. Sussex County is almost
completely devoid of major industrial facilities at
the present time, and approximately 40 percent of
the working population travel outside of the
county, mainly to Morris and Passaic counties, for
employment. Economic growth has been proceeding
rapidly during the past decade, and it is expected
that industry will move into the area in the not too
distant future.
Banking competition within Sussex County is
currently provided by six commercial banks, three
savings and loan associations, and one building
and loan association. The Bank of Sussex County,
Franklin, is the largest commercial bank in the
county, with total resources of $52 million and six
offices. Peoples National Bank of Sussex County is
the smallest commercial bank in the county, with
only half the resources of the next largest bank.
Additional competition within the county is provided by branch offices of several Morris County,
Passaic County, Orange County (N. Y.), and Pike
County (Pa.) banks, many of which are much
larger than any of the banks headquartered in Sussex County. The competitive effect of these banks
becomes even more significant in view of the large
percentage of the working population which leaves
the county for employment.
Consummation of this proposal will greatly benefit the Sussex County area where Peoples National
Bank of Sussex County now operates. By substituting two offices of the much larger, more sophisticated and aggressive New Jersey Bank (N.A.) for
much smaller, less aggressive, rurally-oriented Peoples Bank, the merger will introduce, to that area,
a breadth of banking services that it has not hitherto experienced. It will also benefit the area by
introducing a bank more able to meet the county's
present needs and contribute to its future economic growth and expansion. Among the advantages to be derived are a lending limit larger than
that of any bank in the county and a commercial
finance department specializing in making accounts
receivable, inventory, direct and indirect equipment, Small Business Administration, and other
loans, thus offering new financing alternatives to
local businesses. Because of the tremendous increase
in resources, there will be a greater availability of
construction money, Small Business Administration

loans, F.H.A. mortgages, mortgage warehousing
loans, and higher education loans. Other services
to be made available to Peoples National Bank's
customers include a full range of corporate and
trust services, computer services to aid local businessmen with payroll and recordkeeping problems,
and international services which, to date, have
been handled by the merging bank through correspondent banks. The usual economies of scale
which can be passed on to customers in better service at lower cost will be supplemented by savings
due to the fact that the resulting bank itself will
be able to provide most of the services needed by
its customers without relying on correspondent
banks. Finally, the Peoples Bank, which has a
management succession problem, will have available to it the sufficient depth of experienced,
knowledgeable, and capable management which the
charter bank now possesses, ensuring sound operations in the present and for the future.
Competition will not be adversely affected by
this merger. Because the nearest offices of the merging banks are 29 miles apart and their main offices
38.5 miles apart, there is virtually no competition
between them to be eliminated. In Passaic County,
the addition of the smaller merging bank to the
charter bank would have little effect on the competitive position of the charter bank, which is already the largest in that area. Because of the urbanized, industrialized, and highly developed
nature of that area's economy, all banks, large and
small, should continue to prosper and show good
results. In addition, the merger should heighten
competition with the large New York banks that
compete in Passaic County. In Sussex County, replacing the smallest bank operating there with a
large, aggressive, and competitive out-of-county institution would stimulate competition among all
banks, without unbalancing the competitive structure in the resulting bank's favor. In addition, potential competition will not be adversely affected
since most of the municipalities in Sussex County
are closed to de novo branching due to State statutory home office protection or population requirements. In fact, the subject merger will open
Sparta, the largest municipality in the county, to
de novo branching.




Considered in the light of the statutory criteria,
this merger is judged to be in the public interest
and is, therefore, approved.
DECEMBER 5,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are approximately 30 miles apart, with several offices of
other commercial banks in the intervening area.
Neither bank draws appreciable deposits or loans
from the service area of the other. Therefore, it
would appear that the proposed merger would not
eliminate any significant amount of existing competition between the merging banks.
Under New Jersey law, either bank could be
permitted to open de novo branches in the service
area of the other, although not in communities subject to home or branch office protection. As one of
the largest banks in New Jersey, New Jersey Bank
has the resources to open de novo branches where
legally permitted. Its opportunities for de novo
entry into Sussex County are, however, somewhat
limited by home and branch office protection laws.
For example, the town of Sparta, largest communnity in Sussex County, is protected by the home
office of Peoples itself.
The recent changes in New Jersey law have induced substantial merger activity by the larger
banks in the State as part of their market extension programs. We believe that the largest of these
banks, such as New Jersey Bank, should expand
into new areas either through de novo branching
or through acquisition of a smaller bank in the
area that they wish to enter. Such methods of expansion are desirable from a competitive standpoint as they preserve leading local banks most capable of providing competition to the largest
banks, and most likely, through affiliation with one
another or in bank holding companies, to be able
to provide new competition to the large banks on
a broad scale.
While New Jersey Bank is one of the largest
banks in the State, Peoples is one of the smaller
banks in Sussex County, and in those areas of the
county which it primarily serves. Accordingly, we
conclude that the proposed merger is unlikely to
have a significantly adverse effect on potential competition.

39

NORTHWESTERN NATIONAL BANK OF SIOUX FALLS, SIOUX FALLS, S. DAK., AND COMMUNITY STATE BANK OF LAKE PRESTON,
LAKE PRESTON, S. DAK.

Banking offices
Total assets

Name of bank and type of transaction

Community State Bank of Lake Preston, Lake Preston, S. Dak., with
and Northwestern National Bank of Sioux Falls, Sioux Falls, S. Dak. (10592),
which had
merged Jan. 9, 1970, under charter and title of the latter bank (10592). The
merged bank at date of merger had
COMPTROLLER'S DECISION

On October 10, 1969, the Northwestern National
Bank of Sioux Falls, Sioux Falls, S. Dak., and the
Community State Bank of Lake Preston, Lake
Preston, S. Dak., applied to the Office of the Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
The Northwestern National Bank of Sioux Falls,
the charter bank, is located in Sioux Falls, and has
IPC deposits of $95 million. The bank is a subsidiary of Northwest Bank Corporation which is
headquartered in Minneapolis, Minn. The merging
bank, the Community State Bank of Lake Preston,
is located in Lake Preston, Kingsbury County, and
has IPC deposits of $5.2 million.
The primary effects of the merger will be felt in
Kingsbury County which has a population of 9,227
and contains five banks. The merger will merely
replace a small, locally-owned bank with a branch
of a much larger banking system. The Kingsbury
County area is almost exclusively an agricultural
one, and the recent trend toward consolidation of
farms has left its banking facilities inadequate to
meet heavier loan demands. The merger will bring
a bank with a lending limit of $900,000, rather
than $70,000 as is available from the merging
bank, to the residents of Kingsbury County. In addition, modern services such as computer services,
a staff of agricultural credit experts, and a diversified trust department will be made available in the
county.
The merger will have no adverse effects on competition. The banks presently compete with each
other only to a very minimal degree. The closest
branches of the charter bank to Lake Preston are
33, 32, and 37 miles from Lake Preston. Six other
banks are located closer to Lake Preston than any
branch of the charter bank. Since the area is rural
and towns are widely separated, all banks and
bank branches draw business primarily from the
40




In
operation

To be
operated

$6,502,795

1

129,971,893

12

136,325,911

13

areas immediately surrounding the banking offices.
The merging bank draws over 89 percent of its deposits and 95 percent of its loans from Kingsbury
County. The three closest Northwestern National
Bank branches, located in three different counties,
draw comparable percentages of business from the
counties in which they are situated. There is an insignificant amount of overlap in the number of
customers common to both banks.
The merger will have little effect of the banking
structure in the State. The resulting bank will gain
less than one-half of 1 percent of total statewide
deposits and loans. However, it will greatly benefit
the banking customers of Kingsbury County whose
requirements far exceed the present capabilities of
any of the five local banks.
Applying the statutory criteria to the proposal,
it is concluded that the merger is in the public interest. It is, therefore, approved.
DECEMBER 8,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest branch of Sioux Falls Bank to Lake
Preston is located in Brookings (Brookings
County), 33 miles to the east. Other Sioux Falls
Bank branches are located 37 miles southeast of
Lake Preston in Madison (Lake County) and 42
miles west in Huron (Beadle County). In each case,
there are banks intervening between Lake Preston
Bank and the existing Sioux Falls Bank branch
offices. Nevertheless some of Lake Preston Bank's
customers also maintain accounts at one of the
three closest Sioux Falls Bank branches. It appears
therefore that a little existing competition will be
lost as a result of this merger.
South Dakota law prohibits the establishment of
a de novo branch in a community in which any
State or National bank previously has been authorized to operate. The only method of obtaining a
branch in Lake Preston is through the acquisition

of, or the consolidation with Lake Preston Bank.
However, Sioux Falls Bank could enter other communities in Kingsbury County, or Sioux Falls
Bank's parent, Northwest Bancorporation, could
have sought a charter for a new bank in Lake
Preston.

In the light of the size and economic outlook of
Lake Preston and Kingsbury County, they are not
very attractive for the establishment of an additional bank. Thus, it cannot be said that any substantial meaningful potential competition will be
lost as a result of the proposed merger.

THE CITIZENS NATIONAL BANK OF BRYAN, BRYAN, OHIO, AND THE WEST UNITY BANKING COMPANY, WEST UNITY, OHIO
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
The West Unity Banking Company, West Unity, Ohio, with
and T h e Citizens National Bank of Bryan, Bryan, Ohio (13740), which had . . . .
merged J a n . 19, 1970, under charter of the latter bank (13740) and title " T h e
Citizens National Bank." T h e merged bank at date of merger had

$7,476,663
18,416,311
25,976,478

1
2
3

pany, employing over 300 persons; and, Vistron
Corporation, employing 355 persons.
On July 16, 1969, the Citizen's National Bank of
The Citizens National Bank of Bryan, with IPC
Bryan, Bryan, Ohio, and The West Unity Banking
deposits
of $14.7 million, was established in 1933,
Company, West Unity, Ohio, applied to the Compand presently operates through its main office and
troller of the Currency for permission to merge
one in-town branch.
under the charter of the former and with the title
West Unity, home of the merging bank, is a
"The Citizens National Bank/' A public hearing
on the application was held on October 15, 1969, small rural community with a population of 1,600
persons. Within the immediate vicinity of the town
in Cleveland, Ohio.
are seven industrial firms employing 530 persons.
Both the applicant bank and the merging bank
The largest employer is the Fifty-plus-Five Corpoare located in Williams County in the northwestration
which employs 385 persons. Farming is the
ernmost portion of Ohio, bordering on Michigan
major
contributor
to the economy of West Unity,
on the north and Indiana on the west. Although
and
has
been
since
the
town came into existence.
the county as a whole is rural in nature, manufacThe West Unity Banking Company, with IPC
turing workers comprise 40 percent of the labor
deposits of $6.3 million, was established in 1913,
force. In 1964, the approximately 215,000 acres of
and presently operates as a unit bank. Although
farm land were divided into 1,600 farms whose
the bank showed substantial deposit growth beaverage value exceeded $40,000. Farm size in the
tween 1964 and 1968, deposits during that period
county has steadily increased since that time, and
presently the average farm size is estimated at 150 increasing by some 85 percent, there was a marked
slowdown in the bank's growth during the first 6
acres, with a value of about $600 per acre. There
months of 1969, with deposits down more than
been a concomitant increase in mechanized farm$300,000, or 4 percent.
ing.
Although substantial evidence relating to the relBryan, the home of the applicant bank and the
evant market was submitted by both parties at the
county seat, is the largest community in Williams
public hearing, it is concluded that it would not
County, and has a population of 8,000. There are
26 manufacturing plants in or around Bryan and
be unreasonable to include within that area porthese companies employ approximately 3,800 pertions of Defiance and Fulton counties. Within that
sons. Major firms include Aro Corporation which
market area there are 13 banks and one savings
produces tools, power motors, and self-feed drills,
and loan association. Those 14 institutions have
employing over 1,100 persons; Ohio Art Company,
total deposits of $116.7 million. Although the releemploying over 600 persons; Spangler Candy Comvant market area includes more than Williams
COMPTROLLER'S DECISION




41

County, when that county itself is compared to
other similar Ohio counties, it ranks 17th among
the 24 counties in terms of absolute deposit size of
its leading bank. The county ranks 23rd in terms
of market share of the lead bank and people per
banking office. It ranks last in concentration of its
largest bank, both in terms of loans and of deposits. The county, with nine banks, ranks first of
those 24 counties in terms of number of banks.
Although some direct competition between the
constituent banks will be eliminated as a result of
this merger, the public should be better served.
The resulting bank will be large enough to meet
the expanding needs of its customers, particularly
those of the farmer with his ever increasing scale
of operations and his need for improved farm
credit expertise. With the average size of a farm in
Williams County now being 150 acres, and the average capital requirement for land alone at
$90,000, it is apparent that a need exists for available working capital loans. The resulting institution will be better able to compete for certain
commercial loans and deposits that are now being
placed with out-of-territory banks. A number of
corporate borrowers who now seek financing from
out-of-territory banks, particularly in Toledo, Fort
Wayne, Detroit, Cleveland, and Chicago, would
benefit from this merger since a greater portion of
their credit needs could be met locally. Finally,
lack of competent successor management at The
West Unity Banking Company will be resolved by
the merger. Although the resulting bank will be
the largest bank in its service area, its size should
stimulate more extensive competition from the remaining banks.

It is concluded that this proposal is in the public interest and meets the relevant statutory criteria. The merger is, therefore, approved.
DECEMBER 18, 1969.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposal would merge the largest and fifth
largest commercial banks operating in Williams
County, Ohio.
Head offices of the participating banks are about
10 miles apart, and there are no banking offices in
the intervening area. Both banks have accounts
from most areas of the county. Hence, competition
exists between the two banks. This competition
will be permanently eliminated by the proposed
merger.
Commercial banking in Williams County is concentrated. As of June 29, 1968, there were a total
of nine banks, including the applicants, with total
deposits of $65.3 million. Of that total, Citizens
Bank, the largest, held about 22.2 percent, West
Unity Bank, the fifth largest, held about 9.2 percent, and the four largest banks held 68.3 percent.
If the proposed merger were consummated, the resulting bank would hold about 31.4 percent, and
the four largest banks about 77.5 percent, of these
deposits. Hence, the merger would substantially increase concentration in an already concentrated
banking market.
Consummation of the proposed merger will
eliminate existing competition between the participants and will increase banking concentration.
Consequently, it is our view that the proposed
transaction will have an adverse effect upon competition.

WACHOVIA BANK AND TRUST COMPANY, N.A., WINSTON-SALEM, N.G., AND CITIZENS BANK & TRUST COMPANY OF ANDREWS,
ANDREWS, N.C.

Banking offices
Name of bank and type of transaction

Citizens Bank & Trust Company of Andrews, Andrews, N.C, with
and Wachovia Bank and Trust Company, N.A., Winston-Salem, N.C. (15673),
which had
merged Jan. 23, 1970, under charter and title of the latter bank (15673). The
merged bank at date of merger had

42




Total assets

In
operation

To be
operated

$33, 025 ,897

8

1 ,596, 594 ,516

133

1 ,629, 620 ,413

141

COMPTROLLER'S DECISION

On September 5, 1969, Wachovia Bank and
Trust Company, N.A., Winston-Salem, N.C., and
Citizens Bank 8c Trust Company of Andrews, Andrews, N.C., applied to the Comptroller of the
Currency for permission to merge under the
charter and with the title of the former.
Wachovia Bank and Trust Company, N.A., is a
statewide banking system operating 119 offices in
43 communities of North Carolina. North Carolina
ranks among the states showing the greatest economic development. On the eastern seaboard, the
port facilities are being expanded, recreational and
beach resort development has increased, truck
farming and poultry plants have grown, and there
has been an influx of light industry. In the mideastern and central sections, light industry has
been replacing tobacco production. In the Piedmont area, industrialization and distribution facilities have been expanding. Although North Carolina leads the country in furniture and tobacco
manufacture, its leading industry is textiles, particularly yarn and hosiery manufacturing. The western, or mountain, region provides strong economic
support for the furniture, wood products, and textile industries of the Piedmont area. Four
statewide branch bank systems and five sizable regional branch systems have played a significant
role in the economic development of the State.
Communities with offices of Wachovia extend
from Elizabeth City in the east to Asheville in the
west. Although it is a statewide bank, it operates
no branches west of Asheville. It generates the majority of its business from the Piedmont Crescent,
the area beginning with Charlotte on the west,
going through the Piedmont Corridor to WinstonSalem, and east to the Raleigh-Durham area. The
charter bank, which presently has IPC deposits of
$1.1 billion, was organized in 1879, and has been a
leading bank in the southeastern United States for
many years.
The charter bank, with assets of $1.6 billion,
competes with every major bank in the southeastern part of the country. Its primary competitors in
North Carolina are the $1.3 billion North Carolina National Bank, the $1 billion First Union National Bank, the $660 million First Citizens Bank
and Trust Company, and the $450 million Northwestern Bank of North Wilkesboro. While Wachovia is still the largest bank in North Carolina, its
competitors' growth rates have been much greater




in the past 8 years. Wachovia's share of the North
Carolina banking market declined from 24.1 percent, in 1960, to 22.3 percent, in 1968.
Citizens Bank & Trust Company of Andrews
serves a 5-county area in the westernmost part of
the State, the heart of economically-depressed Appalachia. Those five counties are Cherokee, Clay,
Graham, Jackson and Macori. While the average
annual employment in the entire State rose 15 percent between 1960 and 1967, the economy in all of
those counties except Cherokee has been relatively static. Cherokee County had sizable industrialization in recent years. The economy of the
five counties is supported only by marginal agriculture and a small amount of textile, apparel, and
furniture manufacturing. At present, the five counties combined do not equal the average North Carolina county in bank deposits, retail sales, personal
income, value added by manufacturing, or new
capital expenditures. The towns where the bank
has branches are generally small and are experiencing a population decrease. In 1960, those towns
had populations ranging from 342 to 2,235. As the
area is highly isolated and inaccessible because of
mountainous terrain, businesses and residences are
clustered around towns and communities in the
valleys. The area, however, presents a challenge for
expanding enterprise for the labor supply is abundant, water resources are plentiful, electric power
is economical through TVA facilities, and a variety
of mineral and forest products are available.
The Citizens Bank & Trust Company of Andrews, which has IPC deposits of $23 million, was
established in 1924. It opened its first branch in
Murphy, in Cherokee County, in 1933. In 1943, a
second branch was opened in Robbinsville, in Graham County. A third branch was established in
Hayesville, in Clay County, in 1945. The three
other branches are in Jackson County; one in
Sylva opened in 1962, one in Cullowhee opened in
1963, and one in Cashiers opened in 1966.
The merging bank, primarily through its Andrews, Murphy, and Robbinsville offices, has grown
substantially, from deposits of $12.6 million in
1963, to $26.4 million in 1968. The bank has been
generally conservative in its policies however; its
ownership and management has been the same
since 1926. The senior officers are in their seventies
and no provision has been made for succession in
its lending officers. Although the bank has met the
limited credit needs of the counties' residents, the
larger credit needs of the area's industries have
43

had to be met by large regional or statewide
banks. The merging institution does not provide
trust services, automation, or sophisticated credit
services. Most of the bank's business is of personal
nature, such as loans to individuals, real estate
mortgages, and direct installment lending.
In three of its five counties, Cherokee, Clay, and
Graham, the merging bank was the only bank with
established facilities until, in April 1969, a branch
of the Bank of Franklin was established in Murphy, Cherokee County. The Bank of Franklin
merged into First Union National Bank of North
Carolina on September 15, 1969. Head office competition for the merging bank is offered by a local
branch of the $1 billion First Union National
Bank, and a Bryson City office of the $450 million
Northwestern Bank. In the town of Cashiers, competition comes from a nearby office of First Union
National Bank in Highland, from an office of First
Citizens Bank & Trust Company in Brevard, and
from an office of First Union National Bank in
Sylva. In Franklin, competition comes from an
office of First Union National Bank; in Hayesville,
from the Bank of Hiawassee; and, in Murphy,
from a First Union National Bank office. In Sylva
and Cullowhee, there are competing offices of First
Union National Bank. Some competition for the
Sylva and Cullowhee offices derives from the Bryson City and Hazelwood offices of Northwestern
Bank.
There is not significant competition between the
applicant banks. The head office of Wachovia Bank
is 237 miles northeast of the head office of Citizens
Bank. The nearest office of the charter bank is the
Asheville branch, 50 miles northeast of the Citizens
office in Sylva. There are several offices of competitors in communities lying between. Although
Wachovia Bank services several large corporate accounts in the merging bank's service area, it has
never bid for the type of business handled by the
merging bank. The merger will not eliminate a
potential competitor as there is little economic
incentive for Wachovia Bank to enter Citizens
Bank's market area through de novo branching.
There is considerable competition from various
non-bank financial institutions. Savings and loan
associations offer Wachovia Bank increasing competition in 75 percent of the cities in which it operates. There are five savings and loan associations in
the merging bank's market area. A substantial
number of insurance companies do business in
Wachovia's service area. There are 30 insurance
44




companies operating in the five counties served by
the merging bank. Between 1955 and 1967, the
number of credit unions in the State increased 23.1
percent, an indication of their increasing competition for savings deposits and loan business. There
are three credit unions in Citizens Bank's service
area, and eight more in the three counties between
it and Asheville. The growth in the number of consumer finance agencies in the State was 347.3 percent between 1950 and 1968. There are four such
institutions in the five counties served by the merging bank. In the less developed regions of the
State, particularly the extreme western section,
U.S. Government agencies lend substantial
amounts of money.
This merger will benefit the communities in the
far western part of the State through the specialized services and trained management which will
be offered by the resulting bank but are not available. As the resources and policies of the larger
bank will aid in the economic development of the
area, the merger is in the public interest.
It is concluded that the proposal is in the public
interest and meets the relevant statutory criteria.
The merger is, therefore, approved.
DECEMBER 24,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of Wachovia to any of those
of Citizens Bank are in Asheville, about 47 miles
from Citizens Bank's Sylva office and approximately 86 miles from the head office of Citizens
Bank in Andrews and there are intervening offices
in Waynesville operated by the State's third and
fourth largest banks. The proposed merger, therefore, would not appear to eliminate any significant
amount of direct competition between the two
banks.
Since North Carolina law permits statewide de
novo branching, the proposed merger would eliminate the potential for increased competition that
would result if Wachovia were to establish de novo
offices in any of the five counties in which Citizens
Bank presently operates offices. Wachovia has the resources to establish de novo offices in new markets
and is clearly the largest potential entrant into the
5-county area. Four of the State's five largest banks,
including Wachovia, presently have offices in Asheville; of these four, however, only Wachovia does
not now operate offices in any of the eight counties
west of Asheville.
As of June 29, 1968, Citizens Bank had offices in

four counties (its Franklin office was opened in
March, 1969); it was the only bank at that time in
three counties and in the fourth, Jackson County,
it held 28 percent of total county deposits while

First Union held 72 percent. In the 5-county area,
on the basis of June 29, 1968 data, Citizens Bank
would account for approximately 54 percent of
total area deposits and First Union the remainder.

UNITED STATES NATIONAL BANK, SAN DIEGO, CALIF., AND SOUTHLAND NATIONAL BANK, YUGAIPA, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Southland National Bank, Yucaipa, Calif. (15488), with
was purchased Jan. 30, 1970, by United States National Bank, San Diego, Calif.
(10391), which had
After the purchase was effected, the receiving bank had
COMPTROLLER'S DECISION

On January 29, 1970, application was made to
the Comptroller of the Currency for permission for
the United States National Bank, San Diego, Calif,
to purchase assets and assume the deposit liabilities
of the Southland National Bank, Yucaipa, Calif.
In accordance with the provisions of 12 U.S.C.
181 and 12 U.S.C. 1828 (c), it is found that an
NOTE: Due to the emergency nature of the situation, a report on the competitive factors was not requested.

N O R T H CAROLINA NATIONAL BANK, CHARLOTTE, N.G.,

$17,378,384

3

535,762,328
553,140,712

56

To be
operated

59

emergency exists and that this Office must act immediately to prevent the probable failure of the
Southland National Bank and to protect its depositors, creditors, and shareholders.
Accordingly, approval by the shareholders of the
Southland National Bank of the purchase and sale
agreement is waived and the United States National Bank is authorized to proceed with the purchase and assumption transaction.
JANUARY 30,

1970.

AND MARION BANK AND TRUST COMPANY, MARION, N.C.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Marion Bank and Trust Company, Marion, N.C, with
and North Carolina National Bank, Charlotte, N.C. (13761), which had
merged Feb. 20, 1970, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 15, 1969, North Carolina National
Bank, Charlotte, N.C, and the Marion Bank and
Trust Company, Marion, N.C, applied to the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
former.
North Carolina National Bank, Charlotte, N.C,
with IPC deposits of nearly $800 million, operates
90 branches scattered widely across the State. The




$4,638,685
1,223,694,661
1,228,333,346

To be
operated

2
93
95

bank's main service area coincides with the principal economic growth area in the State, extending
in a crescent from Raleigh, in the north-central section, to Charlotte, in the southwestern portion.
Marion Bank and Trust Company, Marion, N.C,
with IPC deposits of $3.6 million, was organized
in 1929 as an industrial bank. It became a commercial bank in 1961. The bank's main office
and its one branch are located in Marion, which,
with a population estimated at 3,300, is the county
seat of McDowell County, and lies about 90 miles
45

northwest of Charlotte on the slopes of the Blue
Ridge Mountains in west-central North Carolina.
Manufacturing is the most important source of employment in the county; the textile and furniture
industries, both of which are characterized by low
wage scales, are of primary importance. McDowell
County lags behind the rest of the State in income and population growth, and little improvement is predicted.
There is no significant competition between the
merging banks. The nearest office of the charter
bank to the merging bank is in Morganton, approximately 20 miles east of Marion in Burke
County. Neither bank draws a significant amount
of business from the service area of the other. Furthermore, an analysis of the merging bank's loan
portfolio, with its heavy concentration of installment credit, indicates that this bank is not primarity in competition for the other types of credits and
services offered by commercial banks. Nor does it
appear that the charter bank is a likely potential
entrant into the service area of the merging bank
because that area is presently served by branches of
two of North Carolina's largest banks which have
statewide branching systems, and because of the
slow economic growth predicted for McDowell
County. Due to its limited size and resources, and
the distances involved, it does not appear probable
that the merging bank would establish branch operations in any area now served by the charter bank.
Consummation of this proposal will not significantly increase banking concentration in North
Carolina as the charter bank's percentage of total
bank deposits in the State will increase by less than
0.1 percent of its present share. Approval of this
proposal will result in increased competition between the resulting bank and both the First Union
National Bank of North Carolina, Charlotte, N.C.,
which has system deposits of nearly $850 million
and operates two branches in Marion, and the
Northwestern Bank, North Wilkesboro, N.C., which
has system deposits in excess of $400 million and
operates a branch in Old Fort, about 9 miles east
of Marion.
When the merger is completed, the banking
public in the service area of the merging bank will
benefit from the availability of the banking services and resources of another bank with the financial expertise and resources to aid in the development of McDowell County. In addition, it is
anticipated that the increased competition resulting from approval of this merger will result in
46




benefits to the public in the form of improved
banking services by the existing banks in this area.
Applying the statutory criteria, we conclude that
the proposal is in the public interest, and the application is, therefore, approved.
JANUARY 3, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

NCNB has no offices in McDowell County; its
closest offices to those of Marion Bank are located
in Morganton, in adjoining Burke County, about
19 miles east of Marion, and in Try on and Columbus, in adjoining Rutherford County, about 30 to
35 miles south of Marion. According to the application, neither of the merging banks draws significant amounts of deposits or loans from the areas
served by the other. The proposed merger therefore would not appear to eliminate any substantial
amount of direct competition.
Since North Carolina law permits statewide de
novo branching, the proposed merger would eliminate the potential for increased competition that
would result if NCNB were to establish de novo
offices in McDowell County. NCNB has the resources to establish de novo offices in new markets
and could be considered a potential entrant into
McDowell County. NCNB is the second largest
commercial bank eligible to enter McDowell
County. Wachovia Bank and Trust Company,
N.A., the State's largest bank, and First Citizens
Bank & Trust Company, the State's fourth largest
bank, also maintain offices in counties contiguous
to McDowell County; Wachovia's closest office to
McDowell County is in Morganton.
In addition to Marion Bank, two other banks
operate offices in McDowell County: First Union
National Bank of North Carolina, the State's third
largest bank, operates two offices in Marion; and,
The Northwestern Bank, the State's fifth largest
bank, operates an office in Old Fort. As of June 29,
1968, Marion Bank held approximately 21.4 percent of total deposits in the county, First Union
held 64.4 percent, and Northwestern Bank held
14.2 percent.
It should be noted, however, that the proposed
merger is part of a continuing trend of mergers
and acquisitions by North Carolina's largest commercial banks, which has the effect of retarding the
development of a more competitive banking structure in North Carolina and results in the same
limited group of competitors facing each other in
an increasing number of the State's banking mar-

kets. If the proposed merger is approved, commercial banking in McDowell County will be entirely

distributed among three of the State's five largest
banks.

COUNTY NATIONAL BANK, MIDDLETOWN, N.Y., AND ROCKLAND NATIONAL BANK, SUFFERN, N.Y.
Banking offices

Total assets

Name of bank and type of transaction

Rockland National Bank, Suffern, N.Y. (5846), with
and County National Bank, Middletown, N.Y. (13956), which had
merged Feb. 27, 1970, under charter of the latter bank (13956) and title "Empire
National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 9, 1969, the Rockland National
Bank, Suffern, N.Y., with deposits of $136 million,
and the County National Bank, Middletown, N.Y.,
with deposits of $147 million, applied to the Office
of the Comptroller of the Currency for permission
to merge under the charter of the latter and with
the title of "Empire National Bank."
County National Bank, organized in 1934, and
headquartered in Middletown, N.Y., is a full-service institution with IPC deposits of $115.9 million.
Since 1959, the charter bank has established eight
de novo branch offices in Orange and Sullivan
counties. The bank presently operates 28 offices, 15
of which are in Orange County, 10 in Dutchess
County, and three in Sullivan County. As of June
30, 1969, the bank had assets of $172.7 million and
deposits totaling $146.5 million.
Rockland National Bank, formed in 1901 under
the name "The Suffern National Bank and Trust
Company," assumed its present name in 1967. The
bank is headquartered in Rockland County and
operates 13 offices therein. Seven de novo branches
have been opened in the county since 1960 and a
branch location in the Blue Hill Complex, Pearl
River, Rockland County, is approved but unopened. As of June 30, 1969, total assets of Rockland National Bank were $151.3 million, and total
deposits were $135.7 million.
The service area of both participating banks lies
in the Third Banking District of New York. The
charter bank operates in an area which includes
the whole of Orange County, the southern portion
of Dutchess County between the Hudson River
and the Taconic Parkway, and the eastern tip of
Sullivan County contiguous to Orange County.




$149,118,970
171,844,047
320,963,017

In
operation

To be
operated

14
28
42

The merging bank serves Rockland County and a
small portion of Orange County on Route 17 in
Tuxedo Park.
Sullivan County, with a population of 48,000,
lies in the northwest section of the proposed service
area. Much of the 663,040 acres of the county is
very hilly and dotted with lakes. A large resort industry has developed for the 2 million tourists
and vacationers who visit the lakes and luxury hotels in the area every year. Much of the county remains rural in character and devoted to poultry
and dairy farming.
Commercial banking in Sullivan County is represented by the main offices of four commercial
banks and their six branch offices. The largest of
these banks is the $37 million Sullivan County National Bank of Liberty, Liberty N.Y. The other
banks include the $31 million National Union
Bank, Monticello, N.Y., the $14.5 million United
National Bank, Callicoon, N.Y.; and the $11.4
million single-unit First National Bank of Jeffersonville, N.Y. In addition to the aforementioned
banks, 10 branch offices of banks headquartered in
other counties operate in Sullivan County. One
savings and loan association branch operates in
Sullivan County at Monticello, N.Y.
Orange County, with a present population estimated at 213,000, has shown a steady growth over
the years due to its proximity to New York City.
Principle cities in the county include Middletown,
home of the charter bank, with 22,000 people;
Newburgh, with 32,000 people; and Port Lewis,
with approximately 10,000 people. The economy of
the area is based primarily on dairy and truck
farming which has a volume in excess of $30 million each year. There is evidence of a growing
47

manufacturing and industrial base utilizing the
skilled, and semiskilled, manpower and the excellent transportation facilities that the area affords.
The leading industries in the county, as measured
by the number of persons employed, include the
following: apparel, 3,600; textiles, 2,200; chemicals,
1,400; and, food, 1,200. Nationally known concerns
include the Arrow Corporation, International
Nickel Co., Rubberoid Corporation, and DuPont
Company. Manufacturing activities are largely confined to Middletown and Newburgh.
In addition to the charter bank, 11 commercial
banks, with 37 branch offices, are headquartered in
Orange County. These include the $49 million
Highland National Bank of Newburgh, the $46
million First National Bank of Highland, the $33
million Chester National Bank, the $29 million
Columbus Trust Company, the $27 million Orange
County Trust Company, and the $23 million National Bank of Orange and Ulster Counties. Six
branch offices of banks headquartered outside the
county also serve the county. Fourteen savings institutions with 18 branch offices operate throughout
the area and are active competitors for the savings
dollar and residential loans.
Dutchess County, with a present population of
approximately 220,000, is in the northwest section
of the proposed service area. The economy of the
county is mixed industry and agriculture, with industry largely centered around Poughkeepsie, the
county's largest city. The remainder of the county
reflects its agricultural heritage. The largest employers are International Business Machines, employing over 5,000, and Shatz Manufacturing Co.,
Federal Bearing Co., and Texas Research Center,
each having at least 1,000 employees.
The banking needs of Dutchess County are
served by 11 commercial banking institutions with
21 branch offices. These include the $161 million
Marine National Bank of Southeastern New York,
the $39 million Dutchess Bank and Trust Company, and the $23 million First State National
Bank. In addition, the county is served by six savings banks and four savings and loan associations.
Rockland County, headquarters for the merging
bank, is situated immediately west of Westchester
County, southeast of Orange County, and contiguous to metropolitan New York City, which is immediately south. It is one of the fastest growing
regions in the State, recording a population growth
from 136,000, in 1960, to 220,000, today, a 60 percent increase. Rockland has 110,355 acres of land, of
48




which 38,017 acres, or 34 percent, is used by institutions, parks, and public facilities. Almost threefourths of the county parkland is in the Palisades
Interstate Park, which forms a natural barrier between Rockland County and Orange, and stretches
from the Hudson River to the New Jersey border.
Geographically, the center of Rockland County is
33 miles from the center of Manhattan. Since
transportation facilities are well developed between
the city and the communities located in the
county, many people find it attractive and convenient to live in the suburban atmosphere of the
county and commute to jobs in the city. It is estimated that in 1960, 27 percent of the county work
force commuted to jobs outside the county. The
county is undergoing rapid urbanization which is
reflected in large numbers of new single family
subdivisions, modern apartment houses, shopping
centers, and industrial plants. Rockland County
has the third highest household income, $13,363, in
New York State. As of 1963, there were 196 manufacturing firms in the county, employing 12,127
persons on a payroll of $74.2 million. In 1963,
Rockland County has 1,256 retail establishments
with sales of $198.3 million, and total payrolls of
$20.2 million; by 1968, retail trade had increased
to $292.4 million. Rockland County also had 145
wholesale trade establishments with sales of $79.3
million in 1963. Those firms employed 1,204 people, and had a total annual payroll of $7.5 million. The largest employers in the county include
Avon Products, Inc.; Lederle Laboratories; Continental Can Co., Inc.; Geigy Chemical Corporation;
Kay-Fries Chemical, Inc.; and Flintkote Co.
Rockland County is presently serviced by five
commercial banks and 48 branch offices. They include, in addition to the merging institution, the
$84 million Marine Midland Trust Company of
Rockland County, the $48 million Tappan Zee
National Bank, and the $43 million Nanuet National Bank. Moreover, six savings banks and savings and loan associations service the area.
There is no significant competition between the
applicant banks. Their head offices are 40 miles
apart, and County National Bank has no branches
in Rockland County. Although Rockland National
Bank has a single branch in Orange County, at
Tuxedo Park, which is but 1 mile away from
County National Bank's Sterling Forest office,
there is negligible competition between them because of the terrain of the area, expressways and a
railroad line separate the countryside, and the

present population distribution, which polarizes
Sterling Forest and Tuxedo Park into two separate
residential areas. Further competition between the
two banks is prevented by Palisades Interstate Park
which effectively divides the remaining portions of
the respective service areas from the New Jersey
border to the Hudson River. No convenient road
to link Rockland County with the County National Bank's service area to the north has been established through this park.
The geographic distribution of deposits of the
two banks reveals that 89 percent of Rockland National Bank's IPC demand deposits are derived
from Rockland County, and 93.4 percent of
County National Bank's IPC deposits come from
Orange, Dutchess, and Sullivan counties. By contrast, only 3.5 percent of Rockland National
Bank's IPC deposits and only 0.7 percent of
County National's IPC deposits are derived from
the other's service area. The respective ratio of
commercial loans for those same areas indicates that
only 8.9 percent of Rockland National's loans originate in County National Bank's service area, and
1 percent of County National Bank loans are derived from Rockland National Bank's trade area.
There is little potential for future development
of competition between the merging banks. Although de novo branching by one applicant into
the other's service area is possible, two factors mitigate against this possibility. First, the New York
home office protection law closes the most economically attractive cities to branching. Secondly, both
service areas appear to be adequately serviced by
commercial banking institutions; the population to
office ratio is markedly lower than the State average. New York State on the whole has an office for
every 7,339 people, while Rockland County has an
office for every 4,639 persons; Orange County has
an office for every 4,536 persons; and Sullivan
County, has one office for every 2,415 people. Although Dutchess County has only one office for
every 6,000 people, its geographical isolation from
Rockland County makes unfeasible de novo entry
by the Rockland National Bank.
The proposed merger will not adversely affect
the banking structure in the resulting bank's service area which resembles the Third Banking District with the exception of Westchester, Putnam,
and Ulster counties. However, a sound analysis of
the applicant's competiton must include most
large banks in the Third District because of two
important factors: first, the potential for branching




in the Third District by any bank headquartered
in that district; and, second, the existence, in the
district, of the five largest New York State registered bank holding company systems, which have
seven affiliated banks and operate 52 offices directly
competitive with the applicants in the four counties where the applicants' offices are located. The
district's two largest banks, the $827 million
County Trust Company, White Plains, N. Y., with
59 offices, and the $402 million National Bank of
Westchester, with 34 offices, are affiliated with the
$2.5 billion Bank of New York Company, Inc., and
the $1.5 billion Lincoln First Banks, Inc., respectively. In addition, the Dutchess Bank and Trust
Company, with 5 offices, is affiliated with the $5
billion Charter New York Corporation; the Marine
Midland Bank of Southeastern New York, with 12
offices, and the Marine Midland Trust Company of
Rockland County, with 11 offices, are affiliated
with the $5.5 billion Marine Midland Banks, Inc.;
and the First State Bank of Rockland County, with
12 offices, and the State of New York National
Bank, with 9 offices, are affiliated with the $7.4 billion Bankers Trust New York Corporation. The
combined resources of the resulting bank, $324
million, represent only 1.4 percent of the resources of these registered bank holding companies
which, through their affiliated subsidaries, furnish
extremely keen competition to the applicant banks
through steadily accessible lines of credit, a wide
range of services, and aggressive management.
Among the commercial banks headquartered in
the Third District, County National Bank and
Rockland National Bank ranked third and sixth,
respectively. After the merger the resulting bank
will continue to rank third behind County Trust
Company and National Bank of Westchester, holding approximately 10 percent of the district's $2.8
billion in total commercial deposits.
The mutual savings banks and savings and loan
associations also offer strong competition for deposit and loan business. The 31 savings banks and
30 savings and loan associations headquartered in
the Third Banking District have total deposits of
$2.4 billion, and loan accounts of $2.1 billion.
Since both types of savings institutions are permitted by law to pay a higher rate of interest for savings deposits, the competitive position of these
thrift institutions will be largely unaffected by the
proposed merger, and they will continue to be a
strong financial influence on the commercial banks.
Another significant deterrent to any adverse im49

pact by the resulting bank on the banking structure in the service area is the proximity of New
York City to Rockland, Orange, Sullivan, and
Dutchess counties. Since Rockland and Orange
counties are prime residential regions, dotted with
"bedroom" communities for residents who work in
New York City, many of these people who commute to work fulfill their banking needs with the
large New York City banks. This permits the city
banks, to compete in the Third District without actually entering physically.
The resulting bank will provide its customers
with a broader range of services than either of the
two banks can now provide alone. The lending
limit will be increased to $1.9 million, thereby
doubling the present lending limit of both applicant institutions. This will permit the large industrial and manufacturing firms which, in the last
few years, have had to seek assistance from New
York City banks, to reestablish credit relationships
with the applicant. Not only will the larger lending
limit better the resulting bank's competitive position, but it will also ensure the retention of deposits that might otherwise have been withdrawn
and then deposited in the New York City banks,
in order to acquire lines of credit. The merger will
provide the area with a trust department with an
adequate staff, having sufficient capability to compete directly with other area banks and with the
large New York City banks for the corporate and
personal trust business that presently exists and
that is predicted for the future. The resulting bank
intends to develop an international services department. With many manufacturing companies
in the service area who export a large portion of
their output, it is believed that an international
department would benefit the firms and individuals
requiring such services. Additional benefits to the
customers and communities served by the resulting
bank are apparent from the bank's intent to enter
the field of municipal financing. Expanded and improved computer services will be made available,
and management depth, especially in County National Bank, will be increased by a recruitment and
training program that neither applicant bank can
presently afford.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest.
The application is, therefore, approved.
JANUARY 23,

1970.




SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the merging banks are about
40 miles apart, but RNB's Orange County branch
in Tuxedo is only about 2 miles from CNB's
Sterling Forest branch. There would appear to be
significant competition between these two
branches.
While CNB does not draw substantial deposits
from Rockland County, RNB's competitive influence in Orange County is not insubstantial. RNB
draws about 3.4 percent of its total IPC demand
deposits, or about $1.3 million, and about 4.2 percent of its total savings deposits, or about $2.5 million, from Orange County. We conclude, therefore,
that the proposed merger would eliminate some
amount of direct competition between the merging
banks.
New York State law limits de novo branching by
a commercial bank to the banking district within
which it is headquartered. In addition, New York
has a home office protection law prohibiting de
novo branching into cities or villages where the
head office of another bank is located. Both CNB
and RNB are located in the Third Banking District, which consists of the counties of Westchester,
Putnam and Ulster, as well as, Orange, Rockland,
Dutchess and Sullivan. Thus, each bank may legally open de novo branches in the areas where
the other bank derives most of its business.
CNB is one of the largest and most capable potential entrants into Rockland County, where
RNB maintains its leading market position. Although several of the county's major population
centers are closed at present to de novo branching
by State home office protection laws, Rockland
County has been one of New York's fastest growing areas with an estimated 60 percent increase in
population in 1960's. This growth is expected to
continue at a rate of 6 percent annually to 1975,
and 3 percent annually from 1975 to 1990. It
would appear that desirable possible alternatives
for de novo entry by new banking institutions will
attend such growth.
Although there are other banks with comparable
legal and financial ability to enter Rockland
County, and although New York's developing pattern of holding company formation and entry may
bring new competitive influences into Rockland
County, CNB's status as one of the district's largest
and most widely distributed banks renders it one

of the more likely potential entrants; accordingly,
its merger with the county's largest bank, in
terms of local deposits, would have an adverse effect on potential competition.
In like manner, RNB is one of the largest banks
legally permitted to open new branches in Orange,
Dutchess and Sullivan counties, where CNB presently competes. The most serious effect on potential competition presented by the proposed merger
along this line would appear to be in Orange
County, where CNB maintains by far the leading
competitive position. While some of Orange County's major population centers are closed by home
office protection, prospects for future growth and
development of new attractive banking sites are
bright.

Although there are other large and capable potential entrants into Orange County, RNB's leading position in adjacent Rockland County indicates that the proposed merger would have an
adverse effect on potential competition in Orange
County.
In addition to the possibility of de novo entry
into the service areas of one another, both banks
could expand throughout the district, and come
into competition with one another, through
merger with smaller banks in areas in which they
do not now effectively compete.
We conclude that the overall effect of the proposed merger on potential competition in various
sections of the Third Bank District of New York
would be adverse.

NEW JERSEY BANK (N.A.), CLIFTON, N.J., AND JERSEY STATE BANK, RIVER EDGE, N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Jersey State Bank, River Edge, N.J., with
and New Jersey Bank (National Association), Clifton, N J . (15709), which had. .
merged Feb. 27, 1970, under charter and title of the latter bank (15709). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 5, 1969, Jersey State Bank, River
Edge, N.J., and New Jersey Bank (N.A.), Clifton,
N.J. applied to the Comptroller of the Currency for
permission to merge under the charter and with the
title of the latter.
New Jersey Bank (N.A.), with IPC deposits of
$376.7 million, was organized in 1869. It operates
all its 21 offices in the southern section of Passaic
County. The bank also has one approved but unopened branch, and one branch application pending. In addition, it has a pending application to
merge with The Peoples National Bank of Sussex
County, Sparta, N.J. The bank is in generally
good condition, having adequate capital, a favorable earnings record, and highly regarded management.
Passaic County is located in the northeastern section of the State, near New York City. It contains
16 municipalities with an estimated population of
464,000, making it the sixth most populated of the




$20,516,992
506,259,053
526,776,046

To be
operated

3
23
26

21 counties in the State. It ranks as the fourth
smallest county in the State in terms of land area,
with only 192 square miles. The three most populated municipalities in the county are Paterson,
Clifton, and Passaic, which together comprise the
entire southern end of the county, and contain an
aggregate population of 294,000. The economy of
the area is based upon manufacturing, wholesaling,
and retailing, much of the area is residential because of the favorable commuting to New York
and northern New Jersey commercial centers.
Jersey State Bank, with IPC deposits of $16.8
million, was chartered in 1957, and presently operates a branch office in Emerson, N.J., and another
in River Edge, N.J. The bank, besides having operational problems in recent years, has a small
lending limit that has inhibited its ability to service local businesses' need for larger loans.
The merging Jersey State Bank is located in Bergen County, directly across the Hudson River
from New York City. Bergen County has a total
51

land area of 235 square miles, contains 70 municipalities, and has an estimated population of
914,000. The construction of the George Washington Bridge in the 1930's opened up the county as a
place of residence for many New York City workers. Bergen County is part of the New York-New
Jersey metropolitan area which domiciles many of
the largest industrial corporations in the United
States. Within Bergen County there are a number
of industrial parks containing many manufacturing
and other industrial-type plants.
The overall trade area contains 38 commercial
banks, operating 172 offices, with resources of approximately $3.4 billion, deposits of approximately
$3 billion, and loans of approximately $1.8 billion.
The numerous commercial banks and other financial institutions located in New York City also
compete actively for deposits and loans in the Bergen County trade area. The overall trade area contains 93 savings and loan offices with deposits of
about $1.3 billion and loans of $1.2 billion. There
are also numerous mortgage companies, finance
companies, credit unions, and insurance companies
which compete for deposits and loans within the
area.
This merger would be of particular benefit to
the customers of and the communities in which
the merging bank operates. It will be the solution
to the successor management problem, and the
many operational difficulties which that bank experiences. In addition, the merged institution will be
better able to serve the needs of the customers of
the Jersey State Bank; the lending limit will increase from the present $128,000 for the Jersey
State Bank to a $3.9 million limit for the resulting
institution. New and expanded services will be
made available in the Jersey State Bank service
area, and will include complete trust services, computer services, 5 percent 5- and 8-year savings
bonds, payroll services, a complete international
department, participation with the Small Business
Administration in loans, and highly sophisticated
commercial finance and installment loan departments.
Competition will not be adversely affected by
consummation of this transaction. Because the
service areas of the merging banks are about 7
miles apart, and the intervening area is presently
densely banked, there is little competition between
them. Although in the overall service area one
banking alternative will be eliminated, adequate
alternative sources remain. The resulting bank will
52




be better able to compete with the largest Bergen
County and New York City banks than can the
merging bank. In Passaic County, the resulting
bank will remain as the largest, but will increase
its lead only by a slight amount. In the newly
formed First Banking District of New Jersey, the
resulting bank will rank fifth in size, and will be
smaller than 12 of the 37 commercial banks located in New York City.
It is concluded in the light of the statutory criteria, that the merger is in the public interest and
it is, therefore, approved.
JANUARY 21,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are
about 10 miles apart, and there are numerous intervening banking alternatives. Each bank, however, draws a small amount of deposits from areas
served by the other. It would appear that the proposed merger would eliminate only a limited
amount of direct competition.
Under New Jersey law, either bank could open
de novo branch offices in the service area of the
other, although not in communities subject to
home or branch office protection. As one of the
largest banks in the newly created First Banking
District, Clifton Bank has the resources to open
de novo offices where legally permissible. While
Paramus and River Edge would appear to be
closed, Clifton Bank could be permitted to open
de novo branch offices in other municipalities
served by Jersey State. There are a number of other
likely potential entrants into this area including
the larger banks headquartered in Bergen County
itself.
The recent changes in New Jersey law have induced substantial merger activity by the larger
banks in the State as part of their market extension programs. We believe that the largest of these
banks, such as Clifton Bank, should expand into
new areas either through de novo branching or, in
the alternative, through merger with a smaller
bank in the area they wish to serve. Such methods
of expansion are desirable from a competitive
standpoint as they preserve leading local banks
most capable of providing competition and most
likely, through affiliation with one another or in
bank holding companies, to be able to provide
new competition to the large banks on a broad
scale.
While Clifton Bank is one of the largest banks

in the State, Jersey State is among the smallest
banks operating offices in central Bergen County,
and one of the smallest banks in northeastern New

Jersey. Accordingly, we conclude that the proposed
merger is unlikely to have a significantly adverse
effect on potential competition.

FIRST NATIONAL BANK, BOWLING GREEN, OHIO, AND HARDY BANKING COMPANY, NORTH BALTIMORE, OHIO

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

Hardy Banking Company, North Baltimore, Ohio, with
and First National Bank, Bowling Green, Ohio (15416), which had
merged Feb. 28, 1970, under charter and title of the latter bank (15416). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 4, 1969, the First National Bank,
Bowling Green, Ohio, and the Hardy Banking
Company, North Baltimore, Ohio, applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the
title of the former.
The First National Bank, the charter bank, was
organized in 1952 as a State institution and converted to a National charter in 1964. This bank,
which now has IPC deposits of $22 million, operates its main office in Bowling Green and a branch
in each of the towns of Rossford and Northwood,
both of which are in the northern part of Wood
County, near Toledo.
Bowling Green, with a population of 19,000, lies
23 miles south of Toledo, and is the county seat of
Wood County. This county, together with adjacent
portions of Lucas County, constitutes the charter
bank's primary service area. This area not only
encompasses some of the most productive farm
land in the State of Ohio, but also includes substantial industrial activity centered around the production of stone, clay, and glass products, transportation, electrical equipment, and metal and rubber
products. Bowling Green State University, with an
enrollment of 13,000, makes a substantial contribution to the local economy.
The Hardy Banking Company was organized in
1896 and continues to operate from a single office.
This bank, with IPC deposits of only $3.4 million,
has not been an aggressive competitor in the area's
banking structure. Its size has limited the services
it has been able to render to its customers.




$4,281,052
30,728,502
34,864,742

1
5

6

North Baltimore, a town of 3,000, is also located
in Wood County, 15 miles south of Bowling
Green. Although this is principally an agriculturally oriented community, many of its residents
commute to industrial jobs in Finlay, 9 miles
south.
There is little existing competition between the
participating banks whose offices are 15 miles
apart. Not only does the distance factor minimize
the development of competition between them,
but the conservative policies of the merging bank
also militate against it. The size of North Baltimore precludes the receiving bank from seeking a
de ?iovo branch in the town; the competitive impact of such an entry on the merging bank would
be severe.
The operation of the North Baltimore bank as a
branch of the receiving bank following the merger
will offer more effective competition with other
banks now serving the area. These other banks include The Bank of Wood County Company, Bowling Green, with deposits of $41 million and a
branch in North Baltimore; The Cygnet Savings
Company, Cygnet, Ohio, with deposits of $11 million; and, the Custar State Bank Co., Custar, Ohio.
Several other banks located in Hancock County,
just south of North Baltimore, also compete for
business in this general area.
When the merger is approved, the banking public in the service area of the merging bank will
benefit from the expanded range of banking services made available by the charter bank. Trust
services, a bank credit card, and a greatly expanded lending limit will be made available
through the charter bank. The increased competi53

tion with banks now operating in this area will result in further benefits to the public. In addition,
approval of this application will provide management continuity for the merging bank.
Applying the statutory criteria, we find that the
proposal is in the public interest and the application is, therefore, approved.
JANUARY 22,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest branch of FNB is 14 miles from
Hardy Bank, the distance from Bowling Green to
North Baltimore. There are presently two banks
operating in North Baltimore (population 3,500) :
Hardy Bank, and a branch of Wood County Bank.
There is one intervening bank between Bowling
Green and North Baltimore located in Cygnet,
about 4 miles north of North Baltimore, and 10
miles south of Bowling Green. The application
states that about 5 percent of FNB's business originates in the North Baltimore service area. The
proposed merger would eliminate some direct competition between FNB and Hardy Bank.

Furthermore, since State law permits de novo
branching within the county in which the bank is
located, FNB can increase its activity in the southern part of the county. It has the resources to do
this, and the fact that it has no branches in the
southern half of the county means that de novo
entry could increase competition in the area. The
merger, therefore, will foreclose the potential for
the development of greater competition between
the two banks.
Eleven commercial banks operate in Wood
County. The four largest banks hold 65 percent of
the total deposits. As of June 30, 1968, FNB was
the second largest bank in the county, with about
14 percent of total deposits. Hardy Bank, the 10th
largest bank, has about 2.2 percent of total deposits, and the effect of this merger would be to increase countywide concentration by this amount.
Since the proposed acquisition would eliminate
some direct competition, and the potential for increased competition, the proposed merger is likely
to have an adverse effect on banking competition
in Wood County.

CENTRAL PENN NATIONAL BANK, BALA-CYNWYD, PA., AND COMMUNITY BANK & TRUST COMPANY, PAOLI, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Community Bank & Trust Company, Paoli, Pa., with
and Central Penn National Bank, Bala-Cynwyd, Pa. (723), which had
merged Mar. 13, 1970, under charter and title of the latter bank (723). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 20, 1969, Community Bank & Trust
Company, Paoli, Pa., and Central Penn National
Bank, Bala-Cynwyd, Pa., applied to the Comptroller of the Currency for permission to merge under
the charter and with the title of the latter.
Central Penn National Bank, with IPC deposits
of $336.7 million, was chartered originally in 1828.
In 1968, the bank relocated its office to Bala-Cynwyd, just across the western county line from Philadelphia. Relocation of its head office enables the
bank to branch into three additional counties,
Berks, Chester, and Lehigh. Presently, through a
branch system of 24 operating offices, the charter
bank serves the city of Philadelphia, lower Bucks
54




$48,912,682
444,909,782
488,940,101

To be
operated

7
25
32

County, and portions of eastern Montgomery
County. Three additional branches are in the process of construction, and one branch application is
pending. While the condition of this bank is generally good, its growth has not kept pace with that
of its seven major competitors in the Philadelphia
area.
The primary service area of the charter bank includes, Philadelphia, Bucks County, and Montgomery County. Philadelphia has a population of 2 million, and the 7-county area in which the charter
bank can legally branch has a population of 4.4
million people. The economy of this area is
mixed, with Philadelphia as the nucleus of a
major industrial complex. The metropolitan area

has, in recent years, been spreading; overcrowded
conditions in the city have caused many businesses
to move into the outlying suburbs. Much of the
7-county area outside the bank's present service area
is agriculturally oriented.
Since Central Penn is a Philadelphia-oriented
bank, it competes with seven major banks, four of
which each have resources of well over $1 billion.
Philadelphia and its adjacent counties are serviced
by 430 banking offices. In Philadelphia, and the
7-county area, there are 645 banking facilities, operated by 59 commercial banks. In 1969, Philadelphia area deposits increased by an average of 10
percent while those of Central Penn increased only
1 percent. Numerous other financial institutions
operate in the area.
Community Bank & Trust Company, with IPC
deposits of $38.6 million, was originally organized
as the Paoli Bank and Trust Company in 1927. It
operates its six branches, including a drive-in facility, and its main office in Chester County. The
lending limit and services of this bank are not sufficient to attract the business of large industries located in Chester County. Its senior management
lacks successors, and its capital is inadequate to
permit the establishment of additional branches.
The service area of the merging bank is primarily Chester County which has a population
255,000, and an area of 486,400 acres, mostly farms
or undeveloped land. While agriculture is of declining importance, industrial growth has been
strong over the last decade. Some 350 manufacturing firms now employ over 30,000 persons. The entire work force in the county is in excess of 63,000
persons. Mushroom production is most important
to the county's economy, with 80 million pounds
produced annually.
Substantial competition is derived from large
out-of-county based banks, including Continental
Bank and Trust Company, with IPC deposits of
$460 million, and four branches in the county; Industrial Valley Bank Sc Trust Company, with IPC
deposits of $323 million, and six in-county
branches; and American Bank and Trust Company, with IPC deposits of $405 million, and one
in-county branch. The first two of those banks are
headquartered in Montgomery County, while the
third is headquartered in Reading, in Berks
County. The largest bank headquartered in Chester County is the National Bank of Chester
County and Trust Company, West Chester, Pa.,
with IPC deposits of $78 million. This bank was




recently granted approval to merge with The Delaware County National Bank, Chester, Pa., which
has IPC deposits of $19 million.
This merger will create a larger institution capable of better serving the combined service area's
needs for expanded banking services, particularly
trust services and a larger lending limit. In addition, management succession problems in the merging bank will be resolved. The lack of capital that
inhibits the merging bank's growth will be solved.
Actual competition will not be adversely affected. Since both banks serve separate and distinct
areas, there is no competition between them to be
eliminated. The service area of the charter bank
will not be affected since the merger will make a
i/2 billion dollar bank only slightly larger. In the
service area of the merging bank, the merger will
enable the resulting institution to compete more
effectively with the several large banks operating
in the area.
Potential competition will not be affected. Because of the relatively high cost of establishing de
novo branches in an area about 15 miles from
where it does business, it is very unlikely that the
applicant would branch into Chester County in
competition with the merging bank. The merging
bank cannot branch de novo without increasing its
capital and, in any event, would be unlikely to
branch into the highly banked areas where the applicant operates.
Applying the statutory criteria, it is concluded
that this merger is in the public interest. The application is therefore approved.
FEBRUARY 9,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

All but two of Central Penn's 24 offices are more
than 15 miles from a Community office. There is
probably limited competition between one Central
Penn office, in Montgomery County, and the nearest office of Community, about 3 miles away.
Community, now the second largest commercial
bank headquartered in Chester County, holds
about 13 percent of the total deposits held by all
commercial banking offices in the county. The largest bank headquartered in the county, holding
about 25 percent of total county deposits has recently merged with Delaware County National
Bank, headquartered in Delaware County. A total
of 13 banks now operate 41 offices in the county.
Three of these are large banks headquartered outside Chester County.
55

Central Penn is the largest bank not now operating in Chester County which could branch de
novo into that county. Only seven other Philadelphia area banks not now operating in Chester
County can branch into the county, and the largest
of these holds total deposits of about $62 million.
Central Penn recently moved its head office from
downtown Philadelphia to Montgomery County
for the express purpose of expanding throughout a
wider area. Since 1958, Central Penn has established eight de novo offices and has received approval to open five more. These facts indicate that
Central Penn is a likely de novo entrant into Chester County.

There are two banks in neighboring Reading,
and two in Lancaster, each with total deposits in
excess of $100 million, that could be considered
potential de novo entrants into Chester County.
Given the strong economic ties between Chester
County and the Philadelphia area, however, these
Reading and Lancaster banks cannot be considered
as likely to enter Chester County de novo as Central Penn.
Thus, the merger would combine the most likely
de novo entrant into Chester County with the largest independent bank in the county. The effect on
potential competition would be adverse.

VIRGINIA NATIONAL BANK, NORFOLK, V A . , AND T H E FIRST NATIONAL BANK OF HARRISONBURG, HARRISONBURG, V A .

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Harrisonburg, Harrisonburg, Va. (1572), with
and Virginia National Bank, Norfolk, Va. (9885), which had
merged Mar. 13, 1970, under charter and title of the latter bank (9885). The
merged bank at date of merger had

COMPTROLLER S DECISION

On November 20, 1969, The First National
Bank of Harrisonburg, Harrisonburg, Va., and the
Virginia National Bank, Norfolk, Va., applied to
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
Virginia National Bank, with IPC deposits of
$656.5 million, presently operates 95 branches and
two military facilities in communities widely scattered throughout the State, and has, in addition,
two approved but unopened branches and one
branch application pending. This bank is in sound
condition, well-managed, and profitable.
Although the charter bank competes with other
large banking organizations in the State on a statewide basis, its operations are considerably concentrated in the central and southeastern sections of
Virginia and the tidewater area surrounding
Hampton Roads. It has recently entered the Washington suburban area in northern Virginia
through merger with two smaller banks, one in Arlington County, and the other in Prince William
56




$39,328,751
915,449,691
954,254,957

To be
operated

4
97
101

County. Areas served by the charter bank are
widely diversified economically, and include shipping, manufacturing, agriculture, and trade.
The charter bank competes at various places
with every other banking organization of statewide market significance, as well as with a number
of other banking, and non-bank financial institutions in the areas it serves. Its nearest office to the
merging bank is in Elkton, some 18 miles east of
Harrisonburg, its only Rockingham County office.
The First National Bank of Harrisonburg, with
IPC deposits of $30.4 million, was established in
1864. In addition to its head office, it operates two
branches within the city of Harrisonburg. Financial General Corporation of Washington, D.C.,
controls 25.7 percent of the outstanding stock of
the merging bank. This bank has experienced a
decreasing share of total local banking deposits in
recent years, from a 47.2 percent share, in 1960,
to a 30 percent share as of December 1968. It now
ranks as the second largest Harrisonburg bank,
whereas it had previously ranked number one.
Harrisonburg, with a population of 13,800, is
the economic hub of the county, and is the largest

retail trading center in the Shenandoah Valley between Staunton and Front Royal. Harrisonburg
and Rockingham County derive diversified economic support from agriculture, manufacturing,
and wholesale and retail trade. Major farm products include apples and poultry, and the largest
single employer in the county is the poultry processing industry.
The merging bank competes in Harrisonburg
with the $23.9 million deposit United Virginia
Bank/Spotswood, the $17.4 million deposit Valley
National Bank, and the $40.9 million deposit
Rockingham National Bank, the town's largest.
Other banks located in Rockingham County include the $9.4 million deposit The Planters Bank
of Bridgewater, the $8.3 million deposit Farmers
and Merchants Bank of Timberville, and the $6.8
million deposit The First National Bank of Broadway. In addition to Financial General Corporation, which also owns a controlling interest in Valley National Bank, Harrisonburg, two other bank
holding companies are represented in the county.
These are United Virginia Bankshares, Inc., which
controls United Virginia Bank/Spotswood, and
First Virginia Bankshares Corporation which controls Planters Bank of Bridgewater.
This merger will benefit the community of Harrisonburg by introducing an office of a statewide
institution capable of providing more varied and
sophisticated financial services. It will replace the
conservative, less aggressive merging bank with a
forward-looking institution which should stimulate
the local economy and enable the local office of the
resulting institution to retain its proportionate
share of the local banking market.
This merger will have little adverse competitive
effect. Because the nearest offices of the two institutions are 18 miles apart, there is little significant
competition between them. In Harrisonburg, the
actual or potential adverse effect on competition
that the common ownership of the merging bank
and Valley National Bank by Financial General
Corporation might have will be eliminated. The
entry of the charter bank into Harrisonburg
should stimulate competition, particularly with respect to the large banking organizations now repre-




sented there, and will bring a choice of a broad
range of banking services to the Harrisonburg area
on a more substantially equal competitive basis
than is possible for the merging bank. Potential
competition will not be eliminated since the
charter bank is prohibited by State law from
branching de novo into Harrisonburg.
Applying the statutory criteria, it is concluded
that the merger is in the public interest. The application is, therefore, approved.
FEBRUARY 5,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

All of Harrisonburg Bank's offices are in Harrisonburg. VNB's closest offices is in Elkton, also
Rockingham County, about 18 miles east of Harrisonburg. VNB also operates a branch in Shenandoah, some 5 miles north of Elkton. Three other
commercial banks operate offices in Harrisonburg,
but there are no banking alternatives between
Harrisonburg and Elkton. However, there appears
to be only limited competition existing between
VNB's Elkton branch and Harrisonburg Bank.
The Massanutten Mountains lie between the two
cities, and the merging banks derive little business
from one another's service area.
VNB's Elkton office holds about 4 percent of the
deposits in commercial banks in Rockingham
County, while Harrisonburg Bank holds about 25
percent of such deposits. After the merger, VNB
would hold the largest share of deposits in Rockingham County.
Under Virginia law VNB cannot open de novo
branch offices in Rockingham County. Of the four
banks that operate offices in Harrisonburg, the two
smallest are presently controlled by registered bank
holding companies. The two independent banks,
Harrisonburg Bank and Rockingham National
Bank, are comparable in size and market position.
Thus, there is no present merger path by which
VNB could enter Harrisonburg without acquiring
such a substantial market position.
The proposed merger would, however, eliminate
the possibility of VNB's entry through establishment of a holding company, and acquisition of a
newly chartered bank in the area.

57

FIRST NATIONAL BANK IN MOUNT CLEMENS, MOUNT CLEMENS, MICH., AND T H E ARMADA STATE BANK, ARMADA, MICH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Armada State Bank, Armada, Mich., with
and First National Bank in Mount Clemens, Mount Clemens, Mich. (12971),
which had
merged Mar. 18, 1970, under charter and title of the latter bank (12971). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On December 2, 1969, the First National Bank
in Mount Clemens, Mount Clemens, Mich., applied to the Comptroller of the Currency for permission to merge with The Armada State Bank,
Armada, Mich., under the charter and with the
title of the former.
First National Bank in Mount Clements, the
charter bank, was organized in 1926, and has total
assets of $65 million. This bank operates its main
office and two branches in the city of Mount Clemens, and an additional banking facility at nearby
Selfridge Field Air Force Base.
The Armada State Bank, the merging bank, was
organized in 1933, and has total assets of $5.4 million. The merging bank is a unit bank with its
only office located in the village of Armada, in Macomb County.
Macomb County, which is the site of all offices
of the participating banks, has been designated by
the United States Bureau of Census as being a part
of the Detroit Standard Metropolitan Statistical
Area. Macomb County, located in the southeastern
part of the State, in the lower half of the triangle
formed by the cities of Detroit, Flint, and Port
Huron, has an area of 481 square miles, and a
population of approximately 600,000.
Mount Clemens, the location of the charter
bank, is 20 miles north of Detroit and has a population of about 20,000. The city, which was once
considered primarily residential, is currently experiencing a trend towards industrialization. Coexistent with this trend has been the development of
service-oriented businesses such as shopping centers, restaurants, and motels.
The village of Armada, the site of the merging
bank, is located in the north-central section of Macomb County, 37 miles north of Detroit, and 17
miles north of Mount Clemens. The economy of
this community, which has a population of ap58




To be
operated

$5,983,449

1

75,588,838

3

81,827,802

4

proximately 1,000, is primarily dependent upon agriculture. The merging bank, which upon consummation of the proposed merger will operate as a
branch of the charter bank, is currently the only
financial institution in Armada.
Consummation of the proposed merger will not
have an adverse effect on competition. In Mount
Clemens, the charter bank competes with the aggressive Mount Clemens Savings Bank which has
total assets of approximately $47 million. Competition is also furnished by Macomb County branches
of the larger Detroit-based banks located close to
Mount Clemens. Existing competition between the
participating banks is minimal, both in view of the
distance separating their offices and their relative
size. Potential future competition is effectively precluded by virtue of Michigan's home office protection law.
Consummation of the proposed merger will
serve the convenience and needs of the community
of Armada. This merger will increase the local
lending limit available to residents of Armada by
nearly tenfold. A potential management succession
problem developing at the merging bank will be
averted by this proposal.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest and the application is, therefore, approved.
FEBRUARY 9, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The merger would eliminate some direct competition as no banks are located on the road linking
Mount Clemens and Armada; there are, however,
alternative banks located closer to Armada than is
First National. Also four large Detroit banks have
offices in the southern part of Macomb County
near Mount Clemens.
Michigan law allows banks to branch anywhere
within the county in which the home office is lo-

cated, and also into all counties adjacent to the
one in which the home office is located, but only
within a 25-mile radius of the home office. However, there is branch and home office protection
but it is possible for banks to branch into areas ad-

jacent to the protected area and become actual
competitors. This would eliminate the potential
that First National would be such an entrant into
the Armada area.

FIRST NATIONAL BANK IN MANSFIELD, MANSFIELD, P A . , AND T H E CITIZENS NATIONAL BANK, BLOSSBURG, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Citizens National Bank, Blossburg, Pa. (13381), with
and First National Bank in Mansfield, Mansfield, Pa. (13618), which had
merged Mar. 31, 1970, under charter of the latter bank (13618) and title "First
Citizens National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 22, 1969, The Citizens National
Bank, Blossburg, Pa., and the First National Bank
in Mansfield, Mansfield, Pa., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title
of "First Citizens National Bank."
The Citizens National Bank, Blossburg, Pa., the
merging bank, is a unit bank with IPC deposits of
$4.5 million. It was chartered in 1929, and has
never been involved in a merger or similar transaction. The bank's primary service area includes the
borough of Blossburg, and an area 5 miles north
of Blossburg.
Blossburg, situs of the merging bank, is a town
of 1,956 persons, located 10 miles south of Mansfield, Pa., in southwestern Tioga County. The town
lies in a small valley completely surrounded by
hills and dense forests. The primary industries are
the Blossburg State Hospital, two casting foundaries, and a wooden pallet manufacturer. Area businesses employ about 700 persons, with the foundries alone employing 450 persons and having an
annual payroll of $2.75 million. A significant number of people commute to Elmira, Painted Post,
and Corning, N.Y. for work. Mining and coal
transportation are also important to the Blossburg
economy, contributing $4 million annually to the
payrolls.
The First National Bank in Mansfield, organized
in 1932, has IPC deposits of $8.4 million. It oper-




$5,409,069
11,901,611
17,320,680

To be
operated

1
1

2

ates a single office and has never been involved in
a merger or similar transaction. The service area of
the applicant includes the borough of Mansfield
and an area 5 miles south of Mansfield, as far as
the township of Covington.
Mansfield is located in the eastern portion of
Tioga County at the intersections of U.S. Routes 6
and 15. The terrain is mountainous and densely
forested. As industry is nonexistant, the economy
of the area is dominated by dairy farming. Mansfield is the site of Mansfield State College, which
has a faculty numbering 230, and an administrative
and service staff of 244. Its budget for 1969 was in
excess of $7 million.
The merger will eliminate an insignificant
amount of competition between the applicant
banks. Their service areas overlap only around
Covington Township. Approximately 300 depositors of the participating banks come from the Covington Township area, but only 60 of these have
accounts in both banks. While the banks are only
10 miles apart, and have a potential for increased
competition, this is not expected due to the small
population to be served and the existence of other
area bank offices between and around the two subject institutions.
There are two other banks operating in Tioga
County: The Commonwealth Bank and Trust
Company, Muncy, Pa., with deposits of $26.8 million; and the Northern National Bank and Trust
Company, Wellsboro, Pa., with deposits of $22.9
59

million. The Commonwealth Bank and Trust is a
very aggressive institution with three branches in
Tioga County, and the Northern National Bank
and Trust has four branches in addition to its
head office at Wellsboro. These two banks, respectively, hold 42 and 36 percent of Tioga County's
total deposits of $63 million. Presently, the charter
bank is the third largest of the four county banks,
holding 14.3 percent of the deposits, while the
merging bank is the smallest of the four county
banks, holding 7.6 percent of the deposits. When
this merger is consummated, the resulting bank
will still be third in size, with 21.9 percent of the
deposits. Although this places the resulting bank
short of the deposits of the other two banks, it
should create a stronger, more viable institution,
capable of effectively competing with the two
larger banks.
Additional competition is experienced from
banks in neighboring cities around Tioga County:
The First National Bank of Troy, Troy, Pa.; The
First National Bank of Ralston, Ralston, Pa.; and
the First National Bank of Canton, Canton, Pa.
Although Elmira, N.Y. lies 30 miles northeast of
Mansfield several commercial and savings banks
from that city advertise in the local newspaper
delivered in Mansfield and Blossburg. There are
no savings and loan associations or mutual banks in
the resulting bank's trade area.
The union of these two institutions will provide
several beneficial results to the merging bank and
its customers. The statutory lending limit of the
resulting bank will be $100,000, which will allow it

WELLS FARGO BANK, N.A.,

to meet the expanding credit needs of local businessmen. Off-premise computer services will be initiated, and a full-time trust department will be instituted. The merger is expected to solve the
personnel problems that beleaguer all small banks,
because increased salary scales, medical services,
and pension programs can be offered to attract
prospective and present personnel.
Applying the statutory criteria to the proposed
merger, we find it is in the public interest and the
application is therefore approved.
JANUARY 14,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The merging banks are located in small communities approximately 10 miles apart. There are
no other banks in either community nor in the intervening area. It would appear that the proposed
merger would eliminate some direct competition
between the merging banks.
Seven commercial banks operate a total of 10
banking offices in the service area of the resulting
bank, which encompasses the eastern half of Tioga
County, a western portion of Bradford County,
and part of northern Lycoming County. First National and Citizens hold about 12 percent and 6
percent, respectively, of the total deposits in these
banking offices. These figures may understate the
competitive effects of the proposed merger as First
National and Citizens both lie near the center of
the area in question.
We conclude that the proposed merger may have
an adverse effect on competition.

SAN FRANCISCO, CALIF., AND LOS PADRES NATIONAL BANK, SANTA MARIA, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Los Padres National Bank, Santa Maria, Calif. (15271), with
and Wells Fargo Bank, National Association, San Francisco, Calif. (15660),
which had
merged Apr. 10, 1970, under charter and title of the latter bank (15660). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On December 29, 1969, the Los Padres National
Bank, Santa Maria, Calif., and the Wells Fargo
Bank, N.A., San Francisco, Calif., applied to the
60




To be
operated

$12,438,566

2

5,436,787,409

268

5,449,225,975

270

Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
Wells Fargo Bank, N.A., with resources of $5.5

billion, is headquartered in San Francisco. This
bank, which operates most of its 267 branches in
Northern California, has recently started to expand into Southern California through de novo
offices, and by mergers.
The merging Los Padres National Bank opened
its main office in Santa Maria in 1964. It now operates one branch 6 miles south of the main office.
Through both offices, this bank has generated deposits of $9.8 million.
The economy of the area served by Wells Fargo
Bank is fully diversified in agriculture, industry,
finance, lumbering, fishing, tourism, mining, oil
production, military establishments, and many
commercial and service activities. The merging
bank serves the city of Santa Maria, Calif., which
has a population of approximately 34,000, and the
surrounding area, encompassing the northern section of Santa Barbara County. The economy of
this area is based on agriculture, with emphasis on
the growing of vegetables, berries, and flowers, as
well as dairy farming, and poultry and livestock
raising. Oil production also comprises an important segment of the economy.
Although Wells Fargo Bank, as the third largest
bank in the State, competes with numerous offices
of statewide, regional, and local banks, it does not
compete with the merging bank. The offices of the
charter bank nearest to the merging bank are located in Ventura, 104 miles southeast; in Bakersfield, 127 miles east; and in King City, 109 miles
north.
The merging bank presently competes with four
of the five largest banks in the State of California.
Within its service area, the Bank of America, with
deposits of $21.9 billion, operates two offices; Security Pacific National Bank, with deposits of $5.7
billion, operates two offices; and United California
Bank, with deposits of $4.3 billion, and Crocker
Citizens National Bank, with deposits of $4.3 billion, operate one office each. Consummation of this
merger will not put undue competitive pressure
upon any of these competing banks serving the
area. It will, in fact, introduce the third largest
bank in the State into an area already being served
by four of the five largest banks in the State. Competition is also offered in the service area by several savings and loan associations, credit unions,
sales finance companies, personal loan companies,
and mortgage companies.
The merger will provide the customers of the




merging bank with another alternate source of extended customer service in Santa Maria and northern Santa Barbara County. The increased competition of these large banks will redound to the
benefit of area residents.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
MARCH 4,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Wells Fargo has no offices in the Santa Maria
area; its nearest branches are over 100 miles from
Los Padres' offices. The applicants derive a few deposit accounts from each other's areas. The
amounts, however, are minor and the areas are
also served by a number of other large California
banking institutions. The direct competition that
will be eliminated by the proposed merger is insignificant.
Wells Fargo is the only one of the five large
banks that dominate California banking that does
not serve the Santa Maria area. Given the significant growth record of this area, Wells Fargo's interest in expanding into growing markets in southern California, and its capacity to expand by de
novo branching through opening multiple
branches at one time, it follows that Wells Fargo is
the most likely de novo entrant into the Santa
Maria area.
Santa Maria is a highly concentrated banking
area. It is served by only five banks; four of these
are major statewide banking organizations while
the fifth is Los Padres, the only independent bank
in the market. In spite of being a new independent bank in a market dominated by the largest
banks in the State, Los Padres had, as of June 29,
1968, 15 percent of commercial bank deposits, and
10 percent of IPC demand deposits held in banking offices in the Santa Maria area. It ranked as
the third largest in terms of both total deposits
and IPC demand deposits in bank offices in Santa
Maria.
This merger will eliminate the only independent
bank in this market, give the third largest bank in
the State the third largest market position in the
Santa Maria area, and eliminate permanently its
ability to enter this area de novo and increase competition. The result will be elimination of potential competition, entrenchment of a concentrated
banking structure, and the elimination of the di61

versity that comes from having banks of varied size
serving a particular market.

The effect of this merger on competition will be
adverse.

FIRST NATIONAL BANK IN MANSFIELD, MANSFIELD, L A . , AND BANK OF GRAND CANE, GRAND CANE, L A .

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Bank of Grand Cane, Grand Cane, La., with
was purchased Apr. 11, 1970, by First National Bank in Mansfield, Mansfield,
La. (11669), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On November 19, 1969, the First National Bank
in Mansfield, Mansfield, La., applied to the Comptroller of the Currency for permission to purchase
the assets and assume the liabilities of the Bank of
Grand Cane, Grand Cane, La., under the charter
and with the title of the former.
The First National Bank in Mansfield is headquartered in Mansfield, La., and operates as a unit
bank. This bank, with total resources of $14.8 million, and IPC deposits of $11.5 million, was established in 1920. The Bank of Grand Cane, the
selling bank, headquartered in Grand Cane, La.,
has total resources of $511,000, and IPC deposits of
$444,000, only $1,000 of which are in savings and
time deposits.
Both banks are located in DeSoto Parish, which
has an economy dependent on agriculture with oil
production and timber processing offering some diversification. Since Mansfield is near the geographic center of the parish and serves it as a trade
center, the applicant has customers from throughout the parish. The population of Mansfield, 6,000
persons, constitutes approximately one-quarter of
the total population of the parish. Grand Cane, 8
miles north of Mansfield, has a population of approximately 400 persons. The selling bank draws
most of its customers from the town and the surrounding farm area.
Primary competition for the applicant comes
from the Mansfield Bank and Trust Company,
Mansfield La., with total assets of $8.2 million, and
the DeSoto Federal Savings and Loan Association,
Mansfield, La., with total assets of $10 million.
There are two other banks located in the parish,
62




To be
operated

$423,758

1

15,574,130
15,997,888

1

2

the Bank of Logansport, Logansport, La., with
total assets of $4.6 million, and the Pelican State
Bank, some 16 miles southeast of Mansfield in an
unincorporated community, with total assets of approximately $1.5 million. The latter bank has applied for permission to move its main office to
Mansfield. The offices of three finance companies
are also located in Mansfield, each with outstanding loans of approximately $100,000. There should
be no significant change in the relative competitive
positions of these institutions and the applicant
upon consummation of the proposed transaction.
The selling bank and the buying bank do not
compete to any significant extent since the management of the selling bank has followed a conservative policy concerning loans, savings deposits, and
bank services in general, thereby offering little if
any competition to other financial institutions. It
is obvious from the fact that there are only $1,000
in time and savings deposits in the selling bank
that this bank offers no competition for such
funds. Also, a lending limit of only $6,000 limits
any competition in the lending area. The purchase
of this small and unaggressive bank by the larger,
more aggressive, and growing bank would be of
material benefit to the banking public of Grand
Cane. All significant banking services would be
available at a local branch, including a much
larger lending limit to satisfy the needs of the
larger farming operations in the area.
Applying the statutory criteria it is concluded
that the proposed purchase and assumption is in
the public interest and the application is, therefore, approved.
JANUARY 30,

1970.

SUMMARY OF REPORT BY ATTORNEY

GENERAL

Grand Cane Bank and First National each operates a single office, one in the town of Grand Cane
(population 400) and the other in the town of
Mansfield (population 6,000), 6 miles apart, in
mid-DeSoto Parish, in the northeastern part of
Louisiana.
Since First National regards the entire parish as
its service area, it is clear that this merger will
eliminate direct competition between the merging
banks; however the limited activity of the Grand

Cane Bank at present suggests that the loss of competition may not be as substantial as might otherwise appear. First National, on the other hand, is
the largest of the five banks presently serving the
parish, and has nearly 50 percent of all commercial
bank deposits. While this acquisition will not substantially increase that share, it will eliminate the
possibility that Grand Cane Bank would combine
with one of the smaller banks in the county to create a more substantial competitor better able to
compete with First National.

T H E CONNECTICUT NATIONAL BANK, BRIDGEPORT, CONN., AND ATLANTIC NATIONAL BANK, STAMFORD, CONN.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Atlantic National Bank, Stamford, Conn. (15584), with
and The Connecticut National Bank, Bridgeport, Conn. (335), which had
merged Apr. 17, 1970, under charter and title of the latter bank (335). The
merged bank at date of merger had

COMPTROLLER S DECISION

On December 8, 1969, The Connecticut National Bank, Bridgeport, Conn., applied to the
Comptroller of the Currency for permission to
merge with Atlantic National Bank, Stamford,
Conn., under the charter and with the title of the
former.
Connecticut National Bank, the charter bank,
was organized in 1806 as the Bridgeport Bank, a
State-chartered bank and trust company. In 1865,
it converted into a National bank, and, in 1955, assumed its present name. As of January 30, 1969, it
was the fourth largest commercial bank in the
State, with total assets of $356.8 million.
The charter bank operates 42 branches located
in the southern and western parts of Connecticut
including several branches in Bridgeport, the Waterbury area, and northern Fairfield County. Of the
branches located outside of Bridgeport, 12 are
within 10 miles of the city, and 13 are over 20
miles away, the farthest located in Wolcott, 36
miles distant.
The economies of the towns served by the
charter bank vary. Bridgeport is Connecticut's
leading manufacturing center, with transportation
equipment, electrical equipment, and fabricated
metals as the principal industries. It is also an im-




$19,569,744
360,808,344
380,378,088

To be
operated

4
44
48

portant retail and wholesale trade center. Although Bridgeport's present population of 154,000
has decreased slightly since 1960, population in the
outlying suburbs has increased during the same period.
The charter bank has offices in Danbury and
Waterbury, north of Bridgeport. These towns, like
Bridgeport, have economies dependent on manufacturing industries. To the south of Bridgeport,
the charter bank has offices in the towns of Darien
and New Canaan. These towns, which border on
Stamford, are affluent commuter towns for New
York City.
Atlantic National Bank, the merging bank, was
organized on December 30, 1919, as the Italian
Loan and Brokerage Association. In 1926, it became a State-chartered industrial bank known as
the Italian Loan Association. That name was
changed in 1940 to the Atlantic Industrial Bank of
Stamford. On April 29, 1966, it converted to a
National charter and assumed its present name. As
of June 30, 1969, the charter bank, which is the
smallest commercial bank in Stamford, had total
assets of $18 million and operated three branches
all within the city of Stamford.
Stamford is located 36 miles east of New York
City and 22 miles west of Bridgeport. With a popu63

lation of approximately 112,000, it is the second
largest city in Fairfield County, and the fourth
largest in Connecticut. Of the four largest cities,
Stamford alone experienced a population increase
in the period 1950-1967, increasing 46 percent.
Growth in recent years is attributable to the influx
of major corporate research laboratories and the
reorganization of several major corporate headquarters in the Stamford area. The economy of the
area is diversified. Presently 36 percent of the
workers in the Stamford labor market are employed in manufacturing industries, as compared
to 51 percent in the Bridgeport market. The largest
industry groups are heavy machinery, electrical
equipment, chemicals, and printing. The average
weekly manufacturing wage in early 1969 was
$142. The Stamford area also serves as a major regional shopping center. Three large branches of
major New York department stores are located
there: Bloomingdale's, Gimbels, and Lord & Taylor.
Competition between the charter and the merging banks is minimal. The closest branches of the
charter bank are the Darien and New Canaan
branches which are located 5 and 6 miles respectively from the head office of the merging bank.
Notwithstanding their proximity to Stamford, only
5.4 percent of their total demand and savings balances are attributable to customers with Stamford
addresses.
Consummation of the proposed merger should
enhance future banking competition in the Stamford area. Under Connecticut's home office protection statute the charter bank could not establish a
de novo bank in Stamford. The effect of the proposed merger will be to substitute branches of a
large aggressive bank for a bank with limited competitive capacity.
Consummation of the proposed merger will
serve the convenience and needs of the Stamford
community. Present customers of the merging bank
will be benefited by having their checking accounts

64



computerized. Additionally, the charter bank will
provide a qualified and experienced trust department, the services of a well-developed commercial
credit department, a vastly increased lending limit,
and other services not now available to customers
of the merging bank.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest
and the application is, therefore, approved.
MARCH 3,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposal would merge Atlantic Bank (total
deposits $16.1 million) into CNB, Connecticut's
fourth largest bank.
A distance of about 22 miles separates the head
offices of the merging banks. However, CNB has
branch offices in New Canaan and Darien 6 and 5
miles, respectively, from Atlantic Bank's head
office. It appears that substantial numbers of New
Canaan and Darien residents work in Stamford; although several banks operate offices in the intervening areas, Atlantic Bank and the New Canaan
and Darien offices of CNB derive some amount of
business from the areas immediately served by each
other. At least some direct competition exists; this
competition will, of course, be permanently eliminated by consummation of the proposed merger.
Connecticut law does not permit commercial
banks to branch de novo into townships in which
there are already located the home offices of other
banks. Under this law, Stamford is closed to de
novo branching by CNB. However, Atlantic Bank
might be permitted to establish de novo branches
in New Canaan and Darien.
Commercial banking in the Stamford-New Canaan-Darien market is highly concentrated. As of
June 30, 1968, six banks operated offices in this
area with total deposits of about $335 million. The
top three banks held about 87 percent of these deposits. Atlantic Bank had about 3.4 percent, and
CNB had less than 1 percent of these deposits.

FIRST NATIONAL BANK OF LINCOLNTON, LINCOLNTON, N.G., AND T H E FIRST NATIONAL BANK OF MOORESVILLE,

MOORESVILLE, N.G.
Banking

Total assets

Name of bank and type of transaction

In
operation

T h e First N a t i o n a l Bank of Mooresville, Mooresville, N . G . ( 9 5 3 1 ) , with
a n d First N a t i o n a l Bank of Lincolnton, Lincolnton, N . G . ( 6 7 4 4 ) , w h i c h h a d . . . .
m e r g e d Apr. 30, 1970, under charter of the latter bank ( 6 7 4 4 ) a n d title "Carolina
First N a t i o n a l Bank." T h e m e r g e d bank at date of merger h a d

COMPTROLLER S DECISION

On January 13, 1970, The First National Bank
of Mooresville, Mooresville, N.C., and First National Bank of Lincolnton, Lincolnton, N.C., applied to the Comptroller of the Currency for permission to merge under the charter of the latter
bank and with the title "Carolina First National
Bank."
The First National Bank of Lincolnton, with
IPC deposits, of $14.8 million, was chartered in
1903, and presently operates through its head office
in Lincolnton, and branch offices in Lincolnton,
Denver, and Cherryville. Competition in Lincolnton derives primarily from a branch of the
$600 million First Citizens Bank and Trust Company, the fourth largest bank in the State. In Cherryville, the bank competes with the $7 million
Cherryville National Bank. Lincolnton is located
only 35 miles northwest of Charlotte, bringing
the charter bank under the competitive influence of
the five largest banks in the State, each of which
has offices there.
Lincolnton, with a population of approximately
5,900, is the largest community in, and the county
seat of, Lincoln County. Textile manufacturing is
the most significant contributor to the local economy with practically 50 percent of all manufacturing jobs available in that one industry. Other
major employers include paper manufacturing,
apple processing, wood products production, and
furniture manufacturing.
The First National Bank of Mooresville, with
IPC deposits of $7.9 million, was organized in
1900. In addition to its main office, it operates two
branches within the city limits of Mooresville. This
bank is not a full-service institution as it has no
trust department. In addition, it has a serious
management succession problem. Competition for
the bank is derived from a local office of the $15
million Piedmont Bank and Trust Company, head-




offices

$11,138,427
21,496,891
32,635,318

To be
operated

3
4

7

quartered in nearby Davidson. It is also in direct
competition with the $14 million Mooresville Federal Savings and Loan Association and the $6 million Citizens Savings and Loan Association. The
Mooresville Bank, like the Lincolnton Bank, is
also under the competitive influence of larger
Charlotte-based banks. In addition to their offices
in Charlotte, the North Carolina National Bank,
First Union National Bank, and the Northwestern
Bank all have offices in Statesville, about 15 miles
north of Mooresville.
Mooresville, home of the merging bank, with a
population of approximately 9,200, is located in
Iredell County which adjoins Lincoln County
along its eastern boundary. The county population
has shown a steady increase and future expansion
is predicted. Mooresville is in the southern portion
of the county, approximately 25 miles from Charlotte. Lake Norman, the largest lake in North Carolina, borders the town on the west and acts as a
natural barrier between Iredell and Lincoln counties. The economy of Mooresville is primarily
based on the textile industry.
This merger will make available in the Mooresville area a broader range of banking services than
the merging institution presently possesses. In addition, the merger will be the solution to the merging
bank's management succession problem. A larger
limit should be of benefit to the customers of both
banks, particularly customers in the Mooresville
area where future economic and population growth
are forecast.
Competition will not be adversely affected as a
result of this merger. The service areas of the two
banks do not overlap, the head offices being 25
miles apart, and their closest offices some 15 miles
apart, with Lake Norman lying between them.
There is, therefore, little if any competition to be
eliminated. In the Lincolnton area, the merger
will have little if any affect other than to enable
65

the resulting bank to be a slightly more effective
competitor to the much larger First Citizens Bank
and Trust Company. In Mooresville, the merger,
rather than adversely affecting competition, will
enhance competition for available trust business.
In the overall service area of the resulting bank,
the merger will create an institution more capable
of resisting the incursions of the large Charlottebased statewide banks. Although both participating banks can legally branch de novo into the service area of the other, this method of growth does
not appear to be feasible for them.
Applying the statutory criteria to this application, it is concluded that the merger is in the public interest. The application is, therefore, approved.
MARCH 12,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Lincolnton Bank's Denver office, the office
nearest to Mooresville, is about 12 miles west of
Mooresville across Lake Norman, the State's largest
lake. There is one competing banking office in
Mooresville, but none in Denver. Neither merging
bank derives significant business from the area
served by the other. Therefore, the proposed merger
would not appear to have an adverse effect upon
any actual competition.
Either merging bank could legally branch de
novo into the area served by the other. However,
several of the largest banks in North Carolina have
offices nearby and appear more likely potential entrants. Therefore, the proposed merger would not
appear to eliminate a significant potential competitor.

OLD NATIONAL BANK OF WASHINGTON, SPOKANE, WASH., AND COMMERCIAL BANK OF WASHINGTON, TWISP, WASH.

Banking offices
Name of bank and type of transaction

Total assets

Commercial Bank of Washington, Twisp, Wash., with
and Old National Bank of Washington, Spokane, Spokane, Wash., (4668),
which had
merged Apr. 30, 1970, under charter of the latter bank (4668) and title "Old
National Bank of Washington." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 5, 1969, the Old National Bank of
Washington, Spokane, Wash., with deposits ol
$262.7 million, and the Commercial Bank of Washington, Twisp, Wash., with deposits of $5.2 million
applied to the Office of the Comptroller of the
Currency for permission to merge under the
charter and with the title of the former.
Old National Bank of Washington, organized in
1891, and headquartered in Spokane, Wash., has
IPC deposits of $242.8 million, and offers its
customers full commercial banking services including a trust department. The charter bank has 38
offices operating in nine counties in eastern Washington; it has received permission to open three
additional offices. It is a subsidiary of Washington
Bancshares, Inc., a registered bank holding company which controls the $35 million First National
Bank in Spokane and owns 5 percent or less of the
stocks of Security Bank of Washington, Ephrata,
66




In
operation

To be
operated

$5, 495 ,805

2

291, 760 ,801

38

298, 144 ,823

40

Wash.; Valley Commercial Bank, Clarkston, Wash.;
Bank of Yakima, Yakima, Wash.; and the Northeast Bank, Seattle, Wash.
Spokane, with a population approximating
188,500, is the second largest city in Washington,
and is situated 285 miles east of Seattle and 17
miles west of the Idaho State line. For reasons of
size and location, it is considered the capital of the
"Inland Empire", a region that includes a large
part of eastern Washington, northern Idaho, and
western Montana. The economy of the region is
largely dependent on agriculture, lumbering, and
mining, with manufacturing, transportation, and
military businesses registering a significant secondary impact on the income of the area. Manufacturing has increased in the last decade; at the time of
application the Spokane area had approximately
350 manufacturing plants which employed approximately 13,000 people.
The Commercial Bank of Washington, organized

1909, is the only commercial financial institution
headquartered in Twisp, Wash. The bank records
IPC deposits of $3.7 million in its main office and
single branch at Pateros, Wash.
Twisp is a rural town of 766 people in Okanogan County. Lumbering is the primary industry of
the county, with apples, farming, and tourism having considerable impact on the economy. While
tourism and recreation are seasonal industries,
their importance has been increasing with the completion of the North Cross Highway and the extension of North Cascades National Park southward
to within a few miles of the merging bank's service
area. Tourism is expected to increase to the benefit
of the area's economy.
No competition exists between the applicant institutions. The Pateros branch of the merging bank
and the Davenport branch of the charter bank are
the closest facilities of the applicants and they are
approximately 100 miles apart. In addition, five
offices of competitor banks intervene between the
two service areas. The potential for competition between the applicants is remote, State statutes restrict de novo branching of a bank across county
lines to those incorporated communities that have
no banking offices. There are only four incorporated, non-banked, communities in Okanogan
County, and each has a population of less than 400.
Consequently, none are sufficiently large to be considered as potential branch locations at this time.
While there are a number of larger towns, they are
already adequately serviced by branch banks or
main offices of competitive institutions.
The banking structure of the merging bank's
trade area is adequate and it will not be adversely
affected by consummation of the merger. In addition to the merging bank, Twisp and Pateros are
served by four banks including the $1.9 billion
Seattle-First National Bank and the $1.2 billion
National Bank of Commerce, two of the State's
largest. Seattle-First National Bank has branches at
Chelan, Okanogan, and Omak, which together have
deposits of $25 million. The National Bank of
Commerce of Seattle retains $6.5 million in deposits
at its Brewster branch. The other two banks, Central Washington Bank in Chelan, and Farmers State
Bank in Winthrop, aggregately have deposits of
less than $2 million. In relation to these institutions, the resulting bank will have combined deposits of $5.2 million at the Twisp and Pateros
branches. The merger will introduce the full serv-




ices of the Old National Bank of Washington which
can be expected to intensify competition for the
deposit business which now gravitates to the market
area's two largest banks, viz. Seattle-First National
and the National Bank of Commerce of Seattle.
The convenience of the proposed merger to the
public will be substantial. The management succession dilemma that is imminent in the merging institution will be solved through the present staff of
the charter bank and the management training
program which the charter bank presently maintains to meet its needs. The charter bank will provide trust and agricultural services, neither of which
are available to the merging bank's customers, but
which are offered by branches of the two large
Seattle banks. The merger will greatly increase the
lending limit of the merging institution which at
the time of application was $67,000. The larger
lending limit, plus the ability to transfer funds
from the charter bank to the Twisp-Pateros service area without seeking participations, will benefit
the merging bank's trade area.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest. The
application is, therefore, approved.
MARCH 23,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Old National, the largest bank in eastern Washington, is the fifth largest bank in the State. Its
nearest branches to Twisp and Pateros are located
more than 80 miles away in other counties.
The merger will not eliminate any significant
competition between the two banks. The merger
will bring about direct competition between Old
National and two big Seattle-based banks that now
have branches in Okanogan County.
Under Washington law, the entry of another bank
into either Twisp or Pateros by de novo branching
is prohibited. Remington Rev. Wash. Stat. 30.40.
020. Hence, a bank not presently serving this area
can enter only by acquiring an existing bank or
opening an office in a community which presently
has no bank office. Old National has the size and
interest to use the latter method. The merger will,
therefore, make entry by other smaller banks not
presently serving the Twisp and Pateros areas more
difficult.
Of the six banks which serve Okanogan County,
Commercial Bank is the fifth largest in terms of
deposits in banking offices in Okanogan County. It
67

is also the third largest of four independent, local
banks in that county. This merger will, therefore,

not foreclose the possibility of entry by other banks
into the county, as a whole, through acquisition.

SOUTH JERSEY NATIONAL BANK, GAMDEN, N J., AND UNION NATIONAL BANK AND TRUST COMPANY, MOUNT HOLLY, N J .

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Union National Bank and Trust Company, Mount Holly, N J . (2343), w i t h . . . .
and South Jersey National Bank, Camden, N J . (1209), which had
merged Apr. 30, 1970, under charter and title of the latter bank (1209). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 27, 1969, the South Jersey National
Bank, Camden, N.J., applied to the Office of the
Comptroller of the Currency for permission to
merge with the Union National Bank and Trust
Company, Mount Holly, N.J., under the charter
and with the title of the former.
The South Jersey National Bank was chartered
as a State institution in 1812, and converted to
National bank status in 1865. An aggressive competitor in the Philadelphia-Camden area, the bank
reports IPC deposits of $211.5 million, and operates
21 branch offices. It has seven approved but unopened branches, and one application pending. It
is one of the two banks in the United States which
is permitted to maintain a branch facility in a State
other than the one in which it is headquartered;
it has had an office in Philadelphia, Pa., since 1813.
The applicant has become a recognized specialist
in construction loan services, which it offers in
addition to the other normal activities of a fullservice commercial bank.
The Union National Bank and Trust Company,
with IPC deposits of $25.3 million, is headquartered in Mount Holly, N J . Chartered in 1871 as a
State bank, it converted to National bank status in
1876, and has retained its National charter since
that time. This bank operates three branch offices;
in addition, it has an application pending for a
branch in Hainesport Township, several miles west
of Mount Holly. While the bank is now managed
by knowledgeable and competent personnel, it has
a management succession problem which is expected to become acute in the next 5 years. The
president is of retirement age, and the executive
68




$34,499,979
305,339,193
339,637,141

To be
operated

4
27
31

vice president-cashier has announced plans to retire
within the next 2 or 3 years.
Camden, headquarters for the applicant bank, is
the county seat and hub city for Camden County,
a populous county in southern New Jersey. The
city has a population of 116,000, supported by retail, manufacturing, and commercial facilities both
in the city and in nearby Philadelphia. The banking structure in Camden and western Camden
County is well developed, with several large banks
and numerous branch facilities.
Mount Holly, situs of the merging bank, is located in Burlington County, approximately 20 miles
northeast of Camden. The city, which now has approximately 15,000 residents, is expected to increase
greatly with the continuing development of Burlington County. In the last 5 years, Union National
Bank and Trust's service area population has increased from 35,000 to about 68,000 people, and,
in the same period, Burlington County's population has increased from 250,000 to 355,000. Much
of the county is yet undeveloped owing to its agricultural heritage. It is that abundance of open land
that is attracting new industry and stimulating the
growth of the county, particularly in the merging
bank's trade area. Further economic stimulation in
western Burlington County is derived from the
proximity of Fort Dix and McGuire Air Force Base,
and the large numbers of military and civilian personnel associated with these facilities. The Mount
Holly area is served by two commercial banks other
than the merging bank: The Burlington County
Trust Company of Moorestown, the largest bank
in Burlington County, which has assets in excess
of $73 million, has a branch in Mount Holly and
two branches within 4 miles; and the $57 million

Mechanics National Bank of Burlington County
which has three branches within 6 miles of the
merging bank's offices.
The entire western portion of southern New
Jersey, which includes Camden, Gloucester, and
Burlington counties, is now undergoing a vast
transformation from a predominantly agricultural
environment to a highly developed industrial and
residential area situated in the megalopolis that
stretches from Boston, Mass., to Washington, D.C.
Transportation facilities are excellent as all major
mediums—highway, air, rail, and water—now serve
the area. Business interests are attracted because of
the availability of land and labor, and the strategic
location of the area in the center of the eastern
markets. The area also affords relatively easy access
to the midwest and south-central States. Among the
largest employers are R.C.A., Owens Corning Fiberglass, New Jersey Telephone Company, C.F.&.I.
Steel Corporation, Colorado Fuel and Iron Company, plus numerous electronic, chemical, and machinery producing plants.
Competition between the applicant institutions
is insignificant. Prior to July 17, 1969, New Jersey
banking law forbade a bank from branching in any
county other than the one in which it maintained
its head office. Since each applicant bank resided in
a different county, each was effectively isolated
from the other's market area. Distance also works
to reduce competition; the main offices of the banks
are 20 miles apart, and South Jersey's nearest
branch is 12 miles from Mount Holly. Competitor
banks located between the two banks effectively
separate them. No less than 11 of Burlington County's 14 banks have 30 offices closer to, and between,
Mount Holly and South Jersey National Bank's
nearest offices. In addition, competitor institutions
in Camden County operate some six branches between the applicants. As a result, the amount of
overlapping deposit and loan business between
these banks is minute.
The revision of the New Jersey branch laws on
July 17, 1969, now permits all banks in a designated
district to branch de novo under limited circumstances, throughout the district. Both applicants are
in the Third Banking District; however, de novo
branching into the other's trade area by either institution is unlikely. Suitable sites are hard to find
because of the "home office" protection rule and
the pending applications of competitor institutions
for branches into presently unbanked or underserviced areas. For Union National Bank, the expense




of de novo branching into South Jersey's market
area is prohibitive because its capital resources are
already thin in relation to its deposit size, and it
does not have the depth in management to staff
new offices.
Approval of the proposed merger will not adversely affect area competition nor significantly concentrate assets in the resulting bank. The Third
Banking District has 74 commercial institutions
with total deposits of $2.2 billion. A realistic assessment of area competition must include consideration of the large, competitive Philadelphia banks
among which are the $2.5 billion First Pennsylvania
Bank; the $2 billion Philadelphia National Bank;
the $1.7 billion Girard Trust Bank; the $1.3 billion
Fidelity Bank; and the $971 million Provident National Bank. Although these banks can not physically locate in New Jersey, it has been comparatively
easy for them to become substantial competitors.
A number of residents of Camden and Burlington
counties work in Philadelphia and satisfy their
banking needs through Philadelphia banks. Also,
since the Burlington County banks are not able to
meet large money needs, many individual and corporate loan requests must be handled by Camden
or Philadelphia institutions. In return, the individual or business usually will maintain a deposit
account with the bank. If a small bank manages
to serve its customers' needs, it usually is on a
participation basis with larger area banks, often
contingent on the availability of funds at the correspondent level.
Approval of the merger will introduce into Burlington County an institution that can accommodate its rapidly expanding individual and commercial needs. South Jersey National Bank will
bring a wide variety of services found in all the
large Philadelphia banks. The lending limit of
South Jersey National Bank is slightly in excess of
$2 million to any one borrower on an unsecured
basis, while Union National Bank's is only $300,000.
However, the resulting bank, with a limit of $2.5
million, will ensure the merging bank's customers
of a greatly increased credit source without having
to go to the Philadelphia banks. For construction
loans, the major type of business for the South
Jersey National Bank, the lending limit of South
Jersey National Bank will increase from $22 million to $25 million, a very desirable increase in view
of growing Camden-Burlington construction demands. The resulting bank will introduce a number of banking services that are not presently
69

available to customers of the merging bank such
as an investment advisory service, an estate planning
department, full trust services, EDP services, an
armored car service, payroll preparation, lock box
services, check guarantee cards, and overdraft lines
of credit. The present services operated by the
merging bank will be updated and expanded.
Applying the statutory criteria to the proposed
merger, we find it is in the public interest and the
application is, therefore, approved.
JANUARY 21,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest office of Camden Bank is about 12
miles from Mount Holly, with several other banks
in the intervening area. The proposed merger,
therefore, would not appear to eliminate any significant amount of direct competition between the
two banks.
Recent legislation in New Jersey broadens geographic areas for bank expansion beyond the former
limits of county lines by dividing the State into
three banking districts. Under this law, banks may
operate branch offices within an entire district.
However, the law retains community-wide home
office protection against de novo branching and

provides branch office protection in communities
of less than 7,500 persons. Thus, while Camden
Bank is presently precluded from branching de
novo into communities now served by offices of
Union Bank, it could establish branches elsewhere
in Burlington County, possibly coming into competition with Union Bank. The proposed merger
would eliminate this possibility.
Camden Bank is the second largest bank in the
Third District, and has evidenced an intent to become a regional competitor through entry into new
areas of the district. Union National is one of the
more substantial banks headquartered in Burlington County, holding about 9 percent of the total
commercial bank deposits therein. However, the
two largest banks in Burlington County, each substantially larger than Union National, operate offices in the vicinity of Mount Holly.
Although the proposed merger would open
Mount Holly, the county seat of Burlington
County, to de novo branching by other commercial
banks in the district, it would eliminate a substantial bank in a growing area, and may have some
adverse effect upon the development of a more
competitive commercial banking structure in the
Third District.

T H E FIRST NATIONAL BANK OF MARYLAND, BALTIMORE, M D . , AND FIRST NATIONAL BANK OF HARFORD COUNTY, BEL AIR, M D .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Harford County, Bel Air, Md. (13680), with
and The First National Bank of Maryland, Baltimore, Md. (1413), which had. . .
merged May 1, 1970, under charter and title of the latter bank (1413). The
merged bank at date of merger had

The "Comptroller's Decision" and the "Summary of Report by Attorney General" for this case

$38,156,284
727,720,018

To be
operated

5
48
53

761,510,201

appeared in the 1968 Annual Report under the
heading "Approved, but in litigation."

# # #
FIRST TRENTON NATIONAL BANK, TRENTON, N.J., AND N E W JERSEY NATIONAL BANK AND TRUST COMPANY, NEPTUNE, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

New Jersey National Bank and Trust Company, Neptune, N J . (15297), with. . .
and First Trenton National Bank, Trenton, N J . (1327), which had
merged May 11, 1970, under charter of the latter bank (1327) and title "New
Jersey National Bank." The merged bank at date of merger had

70




$134,280,383
508,284,242
642,564,625

To be
operated

11
14
25

COMPTROLLER'S DECISION

On January 14, 1970, the First Trenton National
Bank, Trenton, N.J., and the New Jersey National
Bank and Trust Company, Neptune, N.J., applied
to the Comptroller of the Currency for permission
to merge under the charter of the former and with
the title "New Jersey National Bank."
The charter bank, with IPC deposits of $265 million, operates 12 offices in Mercer County, 1 in
Hunterdon County, and has permission to open 3
more branches which are not yet in operation. The
New Jersey National Bank and Trust Company,
the merging bank, has IPC deposits of $110 million,
operates 10 offices in Monmouth County, and has
permission to open 3 more branches.
Both banks are located in the newly formed
Second Banking District of New Jersey. However,
the areas they serve are completely separate. The
charter bank serves Mercer County, parts of the
Second Banking District adjoining Mercer County,
that part of the Third Banking District south of
Trenton, and a significant portion of Bucks County,
Pa., which lies directly across the Delaware River
to the west. The service area of charter bank contains 32 commercial banks with 101 operating or
approved branches, holding $8.5 billion in deposits
as of December 31, 1968. The charter bank holds
3.8 percent of these deposits and ranks sixth in
size. Its competition includes the large Philadelphia
banks, several of which maintain offices within 1
mile of the main office of the charter bank.
The New Jersey National Bank and Trust Company is the fifth largest bank in Monmouth County.
The county is coextensive with the bank's service
area and contains 11 commercial banks with 89 offices and deposits of $784 million as of December
1968. The merging bank held 14.8 percent of those
deposits. Its main competitors are the Central Jersey
Bank and Trust Company, the Monmouth County
National Bank, and First Merchants National Bank.
A new bank charter has been approved for the
county, and another is pending before the State
banking officials.
The Second Banking District of New Jersey is
comprised of six central New Jersey counties lying
in a corridor between New York City and Philadelphia. The district contains a population of approximately 2.2 million. The southwestern portion of the
district, which includes charter bank's service area,
is oriented economically and commercially toward
Philadelphia, while the northern and eastern por-




tions, including merging bank, are oriented toward
New York City. There are 67 banks in the district
holding total deposits of $3.7 billion. The charter
bank has 9.9 percent of those deposits, and the resulting bank will hold 13.1 percent.
The banks in New Jersey are grossly undersized
in view of the State's highly urban and industrial
economy and its dense population. Although the
per capita income in New Jersey is very high, it has
a very low ratio of bank deposits per capita. New
Jersey has no "city banks" as the term is used in
Federal Reserve Board Regulations. Banking is
strictly retail and local.
The reasons for New Jersey's lack of banking
dynamism are both legal and geographical. Its extremely limited branching and merging law has
limited internal growth and expansion, and this
problem has been compounded by the plethora of
major banking services available in nearby New
York City and Philadelphia. New Jersey's large
and diverse industries require specialized skills and
sums of capital available in adequate amounts
only in these two metropolitan areas. As the quest
for services extends beyond State lines, the deposits
generated in New Jersey also flow toward the larger
banks. Consequently, New Jersey banks grow very
slowly even though the local economy has been
most dynamic.
The recent changes in New Jersey's branching
and merger law divide the State into three districts,
and permit branching anywhere within the district,
although this permission is restricted by a home
office protection clause. It also permits bank mergers within each district. The major effect of the
new law is the expanded merger privilege inasmuch
as there are very few sites open to de novo branching. The instant proposal is the first attempt in the
Second Banking District to carry out the intent of
the new banking laws. It will provide a large, district-wide institution, capable of competing to some
extent with the large, metropolitan, out-of-state
banks. Monmouth County, especially, needs a large
bank since its economy is growing rapidly and its
future prospects are very encouraging. Mercer
County, although it houses the State capital, has
a declining industrial base, urban renewal problems, and much slower growth.
The resulting bank will attempt to provide correspondent services in order to keep district deposits
within the State. In addition, the resulting bank
will bring to Monmouth County the following
services presently unavailable in the county: elec71

tronic data processing services, international banking services, credit card services, and a municipal
bond department. In addition, the merger will
eliminate home office protection in Neptune,
thereby opening it for further expansion by other
banks.
The proposal will have no adverse competitive
effects. Since most banks in New Jersey are small
and localized, they will be largely unaffected by
the proposal. The applicant banks do not compete
with each other. Their home offices are 39 miles
apart, and their closest branches are 23 miles apart.
A proposed branch of New Jersey National Bank
is 15 miles from charter bank's closest branch. The
service areas of the two banks are independent of
each other, separated by years of legal barriers and
by rural areas having little banking potential. Only
0.4 percent of the charter bank's deposits are derived from Monmouth County, and an even smaller
percentage of New Jersey National Bank's deposits
are generated from charter bank's service area.
The proposal appears to be in the public interest
in light of statutory criteria, and is designed to
carry out the intent of the citizens of New Jersey
as reflected in the 1969 banking amendments. It
further appears to be without adverse competitive
effects. The application, therefore, is approved.
APRIL 9,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First Trenton serves a large area surrounding the
city of Trenton in the southeastern section of New
Jersey's Second Banking District, including all of
Mercer County and adjacent sections of surrounding New Jersey counties, as well as portions of
Bucks County, Pa. Its recently approved office in
Middlesex County will broaden its service area to
some extent.
Neptune Bank's existing offices lie in eastern
Monmouth County, east of the Garden State Parkway. Its two approved, but as yet unopened, offices
in Howell Township and Freehold Borough will
afford entry into the central part of the county.
The nearest offices of the merging banks, open
or approved, are about 15 miles apart, with several
intervening banking alternatives. It would appear
the proposed merger will not eliminate substantial
existing competition.

72



Recent banking legislation in New Jersey divides
the State into three banking districts; cross-county
branching is now permitted, either de novo or by
merger, within an entire district. However, de novo
branches may not be opened in communities where
a bank has its head office, or where a branch office
exists if the population is less than 7,500.
These recent amendments to New Jersey law
have induced substantial market expansion efforts
by the State's larger banks, both through application for de novo offices and through mergers. A
number of the larger banks in the State have also
announced plans to expand through formation of
registered bank holding companies, which may control banking subsidiaries throughout the State. We
believe that large banks should expand either de
novo, or through acquisition of smaller banks in
new markets they wish to serve. In this manner,
leading banks in the new areas will be preserved to
offer effective competition to entering banks, and
may themselves be the nuclei of developing institutions capable of competing with the largest banks
on a broad geographic scale.
In view of its position as the largest commercial
bank in the Second Banking District, and its admitted interest in broadening its service area, First
Trenton is clearly one of the most likely entrants
into banking competition in Monmouth County.
Other sources of potential competition include
newly forming registered bank holding companies,
primarily led by major banks in the First Banking
District.
Neptune Bank is one of the four large banks in
Monmouth County which together hold about 78
percent of the county's total deposits. Merger with
one of the smaller banks in Monmouth County
could afford First Trenton the entry it seeks, and
introduce another strong competitor into this
highly concentrated market. Monmouth County is
an attractive market for entry because of its rapid
economic expansion.
In view of the alternative means of entry by
First Trenton into Monmouth County, it would
appear that the proposed merger, which would
eliminate one of the county's larger banks and
most capable competitors, would have an adverse
effect on competition.

T H E CASSIA NATIONAL BANK OF BURLEY, BURLEY, IDAHO, AND LAVA H O T SPRINGS STATE BANK, LAVA H O T SPRINGS, IDAHO

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Lava Hot Springs State Bank, Lava Hot Springs, Idaho, with
and The Cassia National Bank of Burley, Burley, Idaho (12256), which had
merged May 18, 1970, under charter of the latter bank (12256) and title "Cassia
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On December 10, 1969, the Lava Hot Springs
State Bank, Lava Hot Springs, Idaho, and The
Cassia National Bank of Burley, Burley, Idaho, applied to the Comptroller of the Currency for permission to merge under the charter and with the
title of "Cassia National Bank."
The Cassia National Bank of Burley, with IPC
deposits of $10.6 million, was organized in 1922. It
operates through its main office and one branch
office.
Burley, located in the south-central section of the
State, has a population of 8,700, and serves a trade
area population of 30,000. The economy of the area
is heavily dependent on agriculture, particularly
potato growing, and, to a lesser extent, upon livestock raising. Several large processing plants which
furnish year-round employment also contribute to
the economy.
Banking competition in Burley is very keen. In
addition to the charter bank, which ranks 10th in
size of the 26 banks operating in the State, branches
of the much larger First Security Bank, and Bank
of Idaho serve the Burley area. The Production
Credit Association, Farm Home Administration, 10
credit unions, and several savings and loan associations also serve the area.
Lava Hot Springs State Bank was organized in
1917, and today, with total deposits of $335 thousand, ranks as the smallest bank in the State. Prior
to the acquisition of the stock of this bank by eight
persons who own 85 percent of the Cassia National
Bank, it paid only 1 percent on savings accounts.
As a result, 90 percent of its deposits are in the demand category. The loan to deposit ratio is only
14 percent, with over 70 percent of the total assets
invested in United States Government obligations.
Lava Hot Springs, situated in Bannock County,
33 miles southeast of Pocatello and 111 miles east
of Burley, has a population of 600. Although Lava




$739,857
13,081,949

To be
operated

1
2

13,821,806

3

Hot Springs lies in an agricultural area, its principal activity, as its name would indicate, is as a
health resort and recreational center. During the
summer months the population of the town
doubles.
This merger will have no competitive impact in
either the Lava Hot Springs or Burley areas. Since
the closest bank to Lava Hot Springs is 28 miles
distant, it will not be affected. In the Burley area,
this merger will not alter the banking structure.
Clearly, this merger will not eliminate any competition between the participants.
This merger will be of benefit to the customers
in the Lava Hot Springs area by increasing the interest rate on savings accounts, thus making them
more attractive to the Lava Hot Springs customers.
Not only will it increase the lending limit at the
Lava Hot Springs office of the resulting bank, but
it will make credit available to develop service type
businesses to match the new recreational developments. Real estate financing will also become
available.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application is, therefore, approved.
MARCH 25,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Cassia National, with total deposits of $11.6 million, operates its main office and its only branch in
Burley. Lava State, with total deposits of $361,000,
is the only bank in Lava Hot Springs (approximate
population 600).
Since the applicant banks are located about 113
miles apart, the proposed merger will not eliminate
any direct competition. Considering the size of the
merging banks, it is not likely that either of the
banks can be considered likely potential competitors in the other's market. Therefore, this merger
will have no anticompetitive effect.

73

PEOPLES NATIONAL BANK OF N E W JERSEY, WESTMONT, HADDON TOWNSHIP, N J., AND
T H E VINELAND NATIONAL BANK AND TRUST COMPANY, VINELAND, N J .
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Vineland National Bank and Trust Company, Vineland, NJ. (2918), with. .
and Peoples National Bank of New Jersey, Westmont, Haddon Township, NJ.
(12022), which had
merged May 22, 1970, under charter and title of the latter bank (12022). The
merged bank at date of merger had

COMPTROLLER S DECISION

On October 16, 1969, The Vineland National
Bank and Trust Company, Vineland, N.J., and
Peoples National Bank of New Jersey, Westmont,
Haddon Township, N.J., applied to the Comptroller of the Currency for permission to merge under the charter and with the title of the latter.
Peoples National Bank of New Jersey, with IPC
deposits of $98 million, was chartered as a National
bank in 1918. It presently operates seven offices
throughout Camden County and, in addition, has
received approval for seven new offices, five in Camden County and one each in Atlantic and Gloucester counties. Three offices will be added when
the merger with Farmers and Mechanics National
Bank, Woodbury, N.J., which was approved October 10, 1969, is consummated. Peoples National
Bank is affiliated through common ownership and
voting control with the $12 million The First
National Bank of Riverside, Riverside, NJ., in Burlington County.
Camden County, home of the charter bank, is in
the southwestern part of New Jersey, and is bordered by the Delaware River on the west and by
Burlington, Atlantic, and Gloucester counties on
the remaining three sides. The county's population,
471,310 in 1968, has grown more than 20 percent
since 1960. Due to its location adjacent to Philadelphia and within the Delaware Port complex, its
economy is well diversified with numerous sizeable
industries and retail centers providing a varied
economic base. The continued influx of commerce
and industry into the area available for development assures a favorable economic outlook.
Peoples National Bank is the fourth largest of the
eight commercial banks in Camden County, and
sixth largest of the 74 commercial banks in the
Third Banking District. It faces intense competition within its trade area from the three larger




To be
operated

$29,709,165

5

131,715,508

10

166,461,909

15

Camden County banks, namely: the $282 million
Camden Trust Company; the $270 million South
Jersey National Bank, Camden; and the $125 million Colonial National Bank, Haddonfield. Additional competition is generated by 15 commerical
banks located in Philadelphia, Pa., 9 of which are
larger than the resulting bank. The competing
Philadelphia banks include the $2.5 billion First
Pennsylvania Bank; the $2.1 billion Philadelphia
National Bank; the $1.7 billion Girard Trust Bank;
the $1.4 billion Fidelity Bank; and the $971 million
Provident National Bank. Competition is also furnished by 64 savings and loan associations operating
throughout the county, and the numerous other
non-bank financial institutions operating in the
area.
Vineland National Bank and Trust Company, the
merging bank, with IPC deposits of $22.9 million,
was organized in 1883 and presently operates three
offices, all within the city of Vineland.
Cumberland County, home of the merging bank,
had an estimated population of 127,770 in 1968,
representing a 20 percent population increase over
the last 8 years. It is well situated geographically,
with the most populated areas of the county only
40 miles from Philadelphia and 35 miles from the
Jersey shore. Agriculture is an important economic
factor in the county, and industrial activity is agriculturally oriented through food processing and
packaging, and glass container manufacturing. Industrial and residential growth is expected to continue as planned expressways are completed and
access to this area from Philadelphia and Camden
is facilitated.
Competition within the county is furnished by
eight commercial banks, five savings and loan associations, and one building and loan association.
Vineland National Bank and Trust Company, the
merging bank, holds 15 percent of the county's commercial bank deposits. The largest bank in the

county is the $41 million Millville National Bank,
Millville, holding 22 percent of the country's deposits, while the second largest bank, the $36 million The Tradesmen's Bank and Trust Company,
Vineland, holds 19 percent. The latter bank is the
subject of a pending merger with the $282 million
Camden Trust Company, Camden, the largest bank
in the Third Banking District.
The proposed merger, if approved, will make a
broader range of banking services available to the
residents in the south-central part of New Jersey.
An increased lending limit will be available to provide for the borrowing needs of the larger companies in the Vineland area. Through this merger
Peoples National Bank would substitute its progressive and aggressive management for that of the
conservative Vineland National Bank.
This merger will not adversely affect competition. As the closest existing offices of the two banks
are 20 miles apart, there is no present competition
between them and no elimination of any alternative banking source will result from this merger.
The resulting bank will be the fourth largest commercial bank of the 74 existing banks in the newly
formed Third Banking District of New Jersey, but
will hold only 6 percent of the total banking deposits in the district. The merger will enable the
resulting bank to compete more effectively with
the large Philadelphia-based banks operating in the
Camden area. Competition should be stimulated
in both Camden County and the Third Banking
District as a whole, because the resulting bank will
be a more effective competitor without disadvantaging the smaller banks in the district. In Cumberland County, all banks should continue their present competitive position while competition among
the larger banks will be stimulated without reducing the number of available alternatives.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application is, therefore, approved.
DECEMBER 30,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are about
25 miles apart; numerous competitive alternatives
lie in the intervening area. According to the application, there is no overlap in the geographic sources
of deposit and loan accounts of the merging banks.
Thus, the merger would not appear to eliminate




any significant amount of existing competition between the two banks.
Under recent changes in New Jersey law, commercial banks may now operate branches anywhere
throughout the newly created banking district in
which they are located. De novo branching, however, is limited by complete home office protection
and branch office protection in communities of less
than 7,500 population. Peoples and Vineland National are both located in the Third Banking District, comprised of eight counties in southern New
Jersey.
Peoples is one of the largest banks in the Third
District, and has sufficient resources to open de novo
branch offices where attractive. Peoples has demonstrated the intent to expand its service area, and
markets in Cumberland County, including Vineland, present attractive areas for bank expansion.
However, the three major population centers of
Cumberland County, Vineland, Millville, and
Bridge ton, each have home offices of commercial
banks and are thus insulated from de novo branching by outsiders. In like manner, many of the other
communities in Cumberland County are protected
by branch offices of other commercial banks. Peoples' opportunities for de novo entry into Cumberland County are accordingly limited.
We note, however, that Peoples has chosen to
enter Cumberland County through merger with
one of the more substantial county banks. We believe it important, from a competitive standpoint,
that the largest banks in the district enter new areas
through de novo branching, or in the alternative,
through merger with small banks. In this manner,
the larger local banks, most capable of competing
with large new entrants will be preserved. These
larger local banks, through affiliation with one another or in bank holding companies, are also
sources of possible competition to the largest district banks on a broader scale.
We believe that systematic acquisition of the
larger local banks in many areas by the largest
banks in the district may result in undue concentration of commercial banking services in a limited
number of giant banking institutions. Therefore,
it would appear that Peoples' entry into Cumberland County through merger with one of the
smaller banks located in the county would have a
more positive effect on competition than its entry
through merger with Vineland National.

75

ZIONS FIRST NATIONAL BANK, SALT LAKE CITY, UTAH, AND BANK OF COMMERCE, MAGNA, U T A H
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

Bank of Commerce, Magna, Utah, with
was purchased May 29, 1970, by Zions First National Bank, Salt Lake City,
Utah (4341), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On January 26, 1970, Zions First National Bank,
Salt Lake City, Utah, applied to the Office of the
Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of the
Bank of St. George, St. George, Utah, and the Bank
of Commerce, Magna, Utah.
Zions First National Bank, the purchasing bank,
with IPC deposits of $175.4 million, is the result
of a merger in 1957 of three Salt Lake City banks:
the Zions Savings and Trust Company, opened in
1873; the Utah Savings and Trust Company, organized in 1899; and the First National Bank of
Salt Lake City, organized in 1890. The purchasing
bank, owned by the Zions Utah Bancorporation,
presently operates 16 banking offices and has approval for an additional branch. Primary competition for the bank derives from the State's two largest banks, viz., the $594.5 million First Security
Bank of Utah, N.A., and the $308.1 million Walker
Bank and Trust Company.
Salt Lake City, with a population of almost
500,000 persons, is the county seat of Salt Lake
County and the State's capital. Operations of Zions
First National Bank were confined to Salt Lake
County until 1968 when an office was established
in Spanish Fork, some 65 miles south. Subsequently
an office was established in Heber City, Utah, 50
miles southeast, and two offices were established in
Provo, Utah, some 45 miles south. The city and
its environs constitute Utah's major population,
commercial, and industrial area, the economy of
which is widely diversified with mining, manufacturing, transportation, agriculture, commerce, and
military activities prevailing. The largest employer
is Kennecott Copper Corporation which has 7,000
employees. Other significant contributors to the
area's economy include numerous defense projects;
Hill Air Force Base, located 25 miles north, the
State's largest employer with about 18,000 civilian
76




$2,147,844

1

257,221,284
259,369,128

17

18

employees; and the University of Utah with an
enrollment of about 14,000 persons.
The Bank of Commerce, Magna, Utah, one of
the two selling banks, with total IPC deposits of
$1.5 million was organized in 1963. This bank, a
unit institution, is suffering from various operating
problems which are reflected in the bank's earnings
record; it did not show a profit until 1967.
The community of Magna is located in Salt Lake
County, near the western boundary, approximately
19 miles southwest of the central business district of
Salt Lake City. Magna has a population estimated
at 7,000 and was originally organized in 1906 as a
company town for the Kennecott Copper Corporation, which remains the town's principal employer.
Local banking competition is confined primarily
to the Magna branch of the $536 million First
Security Bank of Utah, N.A. The nearest office of
the purchasing bank is 10 miles distant. Two credit
unions are also located in Magna; the membership
of each consists of employees of Kennecott Copper
Company who live throughout the Salt Lake City
area.
The Bank of St. George, St. George, Utah, the
other selling bank, with IPC deposits of $11.4 million, was organized in 1906 and has operated continuously since that time. It has two branches, one
at Hurricane, acquired in 1956 through merger
with the State Bank of Hurricane, and the other a
de novo branch opened in 1965 at Enterprise, Utah.
All three offices of The Bank of St. George are
located in Washington County which has a population of 7,000. Washington County is in the extreme
southwestern corner of Utah, bordered by Arizona
on the south and Nevada on the west. The economy
is agriculturally oriented with livestock production
a major source of income. Crops consist of grain,
alfalfa, and sugar beets, as well as fruits common to
a warm southern climate. Tourism also plays a
major role. St. George is the principal trading
center in the area and is 313 miles from Salt Lake

City. The town has a typical rural business district
except for a large number of motels and restaurants
located along highway 91, the major route connecting Los Angeles, Las Vegas, Salt Lake City, Denver,
and other points east and west. Dixie College, a
State 2-year institution is also located here. The
Bank of St. George is the only bank in the county.
The Cedar City branch of First Security Bank of
Utah, N.A., located some 50 miles to the northeast
handles Bank Americard for the area. A new State
bank has been approved for St. George.
Banking competition in Utah is divided among
51 banks. Of these the purchasing bank ranks third
in size controlling about 13.5 percent of the State's
bank deposits. The largest bank in the State, the
First Security Bank of Utah, N.A., holds 29 percent
of bank deposits, while the second largest bank,
Walker Bank and Trust Company, controls 16 percent of these deposits.
Consummation of the subject purchases will have
significant beneficial effects. In the Magna area the
single office Bank of Commerce will be replaced
by a much larger institution more capable of serving the community's banking needs. Services which
the Bank of Commerce does not offer, but which
will be offered by the resulting institution, include
trust services, complete electronic data processing
services, credit card services, and larger lending
limits. In addition the operating problems of the
smaller Bank of Commerce will be solved by its
absorption into the much larger Zions First National Bank. In St. George and Washington County,
entry of the Zions First National Bank will mean
the offering of complete trust and EDP services as
well as a larger lending limit which will be particularly beneficial to the large ranchers and farmers
in the northern part of the county whose credit
needs cannot be presently met by the smaller Bank
of St. George.
Competition will not be adversely affected by
consummation of the proposed purchases. There is

little present competition between the subject banks
to be eliminated. Statewide, the resulting bank's
position as third largest of the State's 51 banks will
be unchanged by its purchase of the State's 14th
and 51st largest banks while its share of total State
deposits will increase only from about 13 percent
to 14 percent. Potential competition will not be affected since in Magna, Hurricane, and Enterprise
it would be economically unfeasible to establish
de novo branches, while in St. George, State de novo
branching restrictions prohibit the establishment
of de novo branches. In fact consummation of the
purchase of the Bank of St. George will open up
that town to de novo branching, thereby enhancing
competition.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application is, therefore, approved.
APRIL 16,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest office of Zions to St. George's office
is about 250 miles distant. The proposed acquisition would not, therefore, eliminate any existing
competition between these two institutions.
Commerce is, however, 10 miles from the nearest
office of Zions. The proposed acquisition would,
therefore, be likely to eliminate some existing competition between these two institutions. However,
the largest bank in the State maintains an office in
Magna which has deposits twice those of Commerce.
Under Utah law, no bank can open a banking
office in St. George while St. George remains an independent bank. There is, further, no other community in the county large enough to support a
new branch. This merger will, therefore, not result
in a substantial elimination of competition.
We, therefore, conclude that the proposed acquisitions will not have a significantly adverse effect
on either actual or potential competition.

VIRGINIA NATIONAL BANK, NORFOLK, V A . , AND T H E MERCHANTS AND FARMERS BANK, SMITHFIELD, V A .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Merchants and Farmers Bank, Smithfield, Va., with
and Virginia National Bank, Norfolk, Va. (9885), which had
merged June 1, 1970, under charter and title of the latter bank (9885). The
merged bank at date of merger had




$9,760,533
958,154,895
967,583,357

To be
operated

1
101
102

77

COMPTROLLER'S DECISION

On February 16, 1970, The Merchants and Farmers Bank, Smithfield, Va., and the Virginia National
Bank, Norfolk, Va., applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
The Merchants and Farmers Bank, the merging
institution, was established in 1905, and presently
records IPC deposits of $8.4 million. It is a single
unit bank located in Smithfield, and is the smallest
of the three banks serving Isle of Wight County,
Va. The principal officer of the bank is 70 years old
and, with his retirement imminent within a few
years, there is no provision for his replacement by
anyone within the merging bank's personnel.
Smithfield, with a population of 3,300, is the
county seat of Isle of Wight County. It is located in
southeast Virginia, between Norfolk and Petersburg. The economy of Smithfield and Isle of Wight
is principally agriculture and food processing, with
about 60 percent of the county's land utilized by
farmers. The remaining lands are swamps and light
forests which support the local paper mill and pulp
industry. Isle of Wight County and Smithfield are
known principally for the Smithfield ham, which
became famous as a result of the hogs raised on
peanuts introduced into the county from Africa in
the early 17th century. The principal manufacturing firms in the county include the Union Camp
Corporation, a paper products plant employing
1,800 people, and Gwaltney, Inc., and Smithfield
Packing Company, both of Smithfield, employing
about 950 people, respectively.
Virginia National Bank, the charter bank, is the
outgrowth of a 1963 merger of Peoples National
Bank of Central Virginia, Charlottesville, and The
National Bank of Commerce, Norfolk. Through a
subsequent series of mergers with twenty small
banks scattered throughout the State and averaging
less than $10 million in size, the charter bank penetrated markets in central, southern, and southwestern Virginia and, recently, the northern Virginia
suburbs of Washington, D.C. It is notable that Virginia National Bank has offices in only two of the
six major metropolitan areas of the State. As of
December 31, 1969, the bank operated 97 branches
and two military facilities which aggregately recorded $692.8 million in IPC deposits. It also has
received approval to open three more branches in
the area of Norfolk, and a merger with the $39.7
78




million First National Bank of Harrisonburg has
been approved but not yet consummated.
The charter bank is the largest independent bank
within the Commonwealth of Virginia, and with
its wide branch network, its total service area encompasses the majority of the State, with the exception of the northwest area. Notwithstanding its
statewide organization, the primary operations of
the charter bank are carried on in the tidewater
area, in and around Norfolk, a city of approximately 330,000 people, and in those communities in
central Virginia around Charlottesville, a city of
approximately 30,000 people.
Since Merchants and Farmers Bank is a unit institution serving the Smithfield portion of Isle of
Wight County, the number of people served in the
market area numbers no more than 10,000 at the
maximum, and probably a more realistic figure
based on Smithfield and surrounding environs
would be approximately 5,000 persons. Geographically, the area is nondescript. It lies in the Coastal
Plain region with elevations from sea level to 100
feet; the northern portion of the county's area is
swampy. Approximately one-half of the county is
forested, with most of the remaining land devoted
to agriculture. Although Isle of Wight is famous
for its cured hams, this business in itself is not sufficient to make the area an economically significant
section of the country.
During the years between 1940 and 1960, the
population of Smithfield decreased by 200 persons;
however, since 1960, the population has again
grown to the 1940 level. The three aforementioned
paper and food processing firms employ about 95
percent of the work force in the area and, due to
the nature of their business, employment tends to
be seasonal. It is notable that no new manufacturing firms have settled in Isle of Wight in the last
20 years. Smithfield Packing Company has announced that due to its large credit needs it cannot
depend upon the three Isle of Wight banks but
must do its business with the charter bank which is
presently some distance away. The firm has indicated that it will switch its account to the first large
bank that can enter the area and handle its credit
needs. Accordingly, the economic future of the
county, while not bleak or presently depressed, depends upon large, aggressive banks to assist the
present businesses and induce new business to enter
the area.
This merger will not eliminate any significant or

potential competition. Presently, the charter bank
has no branches within Isle of Wight. Its nearest
offices are at least 20 miles away at Franklin, Hampton, and Suffolk. Aside from two large loans to
businesses in Smithfield that the merging bank cannot service, the Virginia National Bank derives only
50 deposit accounts from the merging bank's market area. Likewise, the merging bank does an insignificant amount of business outside of the Isle of
Wight, deriving $6.5 million of its $8.8 million in
deposits from the town of Smithfield itself.
The potential for competition by the charter
bank into Isle of Wight is limited only to merger
with one of the three county banks. State law forbids de novo branching and, in any event, the Isle
of Wight market is not attractive for entry by a
fourth institution due to expense and lack of business.
The Isle of Wight market supports two other institutions in addition to the merging bank: the
$11.7 million deposit Bank of Smithfield, and the
$9.9 million deposit Farmers Bank, Windsor, Va.,
some 15 miles southwest of Smithfield. Other local
competition from nearby counties includes the $4.2
million Bank of Surrey County, Surrey, Va., 18
miles northwest, and the $2.7 million Bank of Nansemond, 15 miles southeast of Smithfield. While one
bank will be eliminated at Smithfield, its office will
remain open as a branch of a bank which offers
the fullest line of services for the merging bank's
customers and the community. The charter bank is
many times larger than the two other banks in
Smithfield, but it is not expected that the merger
will adversely affect the community's present banking structure since the smaller banks will continue
to attract customers to the particular services which
they presently offer. The distinctive feature of this
merger is that the charter bank will be extending
services that the merging bank and its two competitors haven't the capacity to afford the public.
Essentially, the charter bank will be initiating services which presently are not offered, rather than
concentrating all its resources and personnel on
that sector of the market which is already well
served.
Among other services the Virginia National Bank
can bring to the Smithfield area is a comprehensive
mortgage loan program for construction and long
term business loans. The bank is also acquainted




with and participates in Small Business Administration loans. For local municipal authorities, Virginia National operates a specialized municipal
bond department which participates in the underwriting, trading, and distribution of municipal securities. Moreover, Virginia National has excellent
computer services, agricultural services, and trust
facilities. Locating the charter bank in Smithfield
will permit it to quickly and easily service the
credit needs of the town's largest employers to the
advantage of all the parties concerned. Although
this merger may appear to be slightly anticompetitive to the other two banks in Smithfield, the benefits to the community will far outweigh any anticompetitive aspects of the merger.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest. The
application is, therefore, approved.
APRIL 29,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Merchants is the smallest of three banks based in
Isle of Wight County. VNB has no offices in this
county. Its closest offices to Smithfield are at Hampton, 20 miles distant across the James River; at Suffolk, 20 miles southeast; and at Franklin, 32 miles
southwest. An analysis of all VNB demand deposit
accounts originating within a 15-mile radius of
Smithfield disclosed 50 accounts with deposits of
$85,285, or 0.004 percent of VNB's Tidewater demand deposits. A similar analysis at Merchants revealed that deposits totaling $292,809, or 3.3 percent
of its total deposits, originated in areas served with
VNB. Thus, it would appear that only a limited
amount of direct competition between the banks
would be eliminated by the proposed merger.
Under Virginia law VNB cannot open de novo
branch offices in Isle of Wight County. The two
other banks based in that county, Bank of Smithfield and Farmers Bank, are comparable in size and
market position to Merchants, although somewhat
larger. Thus, there is no present merger path
whereby VNB could enter Smithfield without acquiring a larger market position.
The proposed merger would, however, eliminate
the possibility of VNB's entry through establishment of a holding company, and acquisition of a
newly chartered bank in the area.

79

T H E FIRST NATIONAL BANK OF HOULTON, HOULTON, MAINE, AND T H E FIRST NATIONAL BANK OF FORT FAIRFIELD,
FORT FAIRFIELD, MAINE
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Houlton, Houlton, Maine (2749), with
and The First National Bank of Fort Fairfield, Fort Fairfield, Maine (13843),
which had
merged June 2, 1970, under charter of the latter bank (13843), and title "The
First National Bank of Aroostook." The merged bank at date of merger had

COMPTROLLER S DECISION

On December 5, 1969, The First National Bank
of Houlton, Houlton, Maine and The First National Bank of Fort Fairfield, Fort Fairfield, Maine,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of "The First National Bank of
Aroostook."
The First National Bank of Houlton, the merging bank, was organized in 1882, and presently records IPC deposits of $16.5 million. This familycontrolled bank has its main office in the business
section of Houlton, and one branch office, opened
in 1969, in the Houlton shopping center, approximately 1 mile from the head office. Its primary
service area extends in a rectangular pattern 10
miles north of the city and 40 miles south along
U.S. Route 1.
Houlton, Maine, with a population of 8,400 persons, is the county seat of Aroostook County which
is located in the far northeast corner of the State.
The city is situated in the southeastern portion of
the county approximately 7 miles west of the province of New Brunswick, Canada. Well removed
from any sizeable metropolitan area, Houlton lies
116 miles northeast of Bangor and 192 miles northeast of Augusta, the capital of Maine. The city
contains Ricker College, which has a current enrollment of 625, two hospitals, three nursing homes,
and 115 retail establishments including 19 food
stores and 14 auto dealerships. Transportation facilities serving Houlton and the surrounding area
include railroad, air, bus, and truck services. Passenger service is confined to bus and air service.
Interstate 95 begins in Houlton, and U.S. Route 1
runs north and south through the city. The economy of Houlton, as in the whole of Aroostook
County, is based upon agricultural crops, particularly potatoes, and lumber and associated paper
80




To be
operated

$20,433,149

2

8,986,563

2

29,541,440

4

products. In recent years, with the advent of better
roads, there has been marked growth in the recreation and tourist industries.
The First National Bank of Fort Fairfield, the
charter bank, was organized in 1933, and presently
records IPC deposits of $4.3 million. The bank is
a subsidiary of Depositors Corporation, a registered
bank holding company that controls the $145 million Depositors Trust Company, Augusta, Maine.
The First National Bank of Fort Fairfield was a
unit bank until late 1969, when it opened a branch
facility at Presque Isle, 12 miles southwest of Fort
Fairfield. The effective service area of the charter
bank is rectangular in shape and extends about 12
miles beyond Fort Fairfield and Presque Isle, the
two cities which lie at either end of its service area.
Fort Fairfield is a town of 5,800 persons, 50 miles
north of Houlton, 168 miles northeast of Bangor,
and 244 miles northeast of Augusta. The commercial heart of Aroostook County lies within a 14mile radius of Fort Fairfield and includes such
communities as Presque Isle, a city of 12,638; Caribou, with a population of 13,294; Limestone, with
a population of 17,441; and Easton, a town of 1,400.
The economy of the Fort Fairfield area is founded
on agricultural and forestry products. Large firms
in the area that employ 200 or more people
include American Kitchen Industries, Vahlsing Inc.,
A8cP National Produce Division, Converse Rubber
Company, Indianhead Plywood, and Potato Service
Inc. Vahlsing Inc., a food processing concern in
Easton, is presently undergoing a $9 million expansion program, and recent construction in Presque
Isle, both public and private, totals $8.5 million,
with projected construction in the future to approach $6.5 million. Three of the aforementioned
communities have their own hospitals, complemented by two nursing homes. The presence of
Presque Isle Air Force Base, a Strategic Air Com-

mand installation at Limestone, is a significant
economic factor in the Presque Isle area.
Because of its peculiar geographic and demographic characteristics, Aroostook County cannot
properly be considered an economically significant
section of the country within which to evaluate the
competitive consequences of this cash merger. This
county, whose entire eastern border abuts the province of New Brunswick for a distance of 100 miles,
is the largest in the State of Maine. Because of its
rough terrain, thick forests, and lack of roads, the
county and its people are somewhat isolated from
the more populous centers in the southern section
of the State. Although this county, with 109,500
residences, is the third most populous in the State,
the majority of those people live in the towns along
the eastern border. Most of the county has a population density of less than 10 persons per square
mile.
During the last 20 years the economy of the
county has been undergoing a drastic change. The
potato has lost its preeminence. The fact that small
and medium farmers cannot profitably raise a potato crop is demonstrated by the extensive credit
advanced to farmers in the county by the Farm
Home Administration. The Federal Land Bank
Association and the Production Credit Corporation
also have large credits outstanding in the county.
The economic future for this area depends on large
aggressive banks inducing new business to locate
in the county.
This merger will not eliminate any significant
competition or potential for competition that might
exist between the two applicant banks. The perimeters of the applicants' service areas are approximately 20 miles apart and the actual banking
premises are some 50 miles apart. Furthermore, a
wide belt of forested terrain separates the two service areas; U.S. Route 1 is the only principal highway linking the two areas. Although the merger will
eliminate one bank, its offices will remain open as
branches of the resulting bank to provide a more
complete line of services for the needs of the customers and the community. While branching is
allowed throughout Aroostook County, future
branching by either of the applicant banks appears
to be very limited due to the inherent expense of
starting a new facility, the sparse scattering of people in the county, and the present distribution of
competing banking offices in the most populated
areas of Aroostook County. The proposed merger




will not affect the Aroostock County banking structure in an adverse manner.
Other banks now operating in the service area
are the $53 million Northern National Bank, the
$11 million Aroostook Trust Company, and the
Houlton Trust Company and Washburn Trust
Company, both with approximately $7 million in
deposits. Subsequent to the merger, the Northern
National Bank will still hold 21/% times the deposits
of the resulting bank. On the other hand, the resulting bank will be able to generate more competition with Northern National Bank through the
increased lending limit and the increased economies and services afforded by the Depositors Corporation affiliation with the charter bank. Although
the remaining three banks are smaller than the resulting bank, this merger should not adversely affect
them. The Washburn Trust Company, in spite of
recording only $7 million in deposits, has an affiliation with the $90.3 million Merrill Trust Company,
Bangor, Maine, a registered bank holding company.
The Houlton Trust Company, another $7 million
deposit institution located in Houlton, Maine, is
already directly competitive with the merging institution. The Aroostook Trust Company, a nonaffiliated commercial bank with $11 million in
deposits, is the largest of the three small banks.
Because of its size and the location of its branch
offices, it should be able to retain its share of the
banking market.
While noncommercial banking competition is not
considered particularly strong in the area, the Aroostook County Federal Savings and Loan Association
has offices in Caribou and Presque Isle and four
loan companies, a credit union, and two production credit associations for farm needs provide
services within the service area. The Federal Government operates offices of the Farmers Home Administration in Houlton, Fort Fairfield, Presque
Isle, and Caribou.
The public will benefit from this merger due to
the increased capabilities of the resulting bank
over the individual applicants to serve new customers that previously have not been attracted to the
existing separate institutions. This is especially true
of The First National Bank of Fort Fairfield which
is in direct competition with five branches of the
Northern National Bank in the Fort Fairfield area.
The customers of The First National Bank of Houlton will receive the benefits of the resulting bank's
affiliation with Depositors Corporation. The lend81

ing limit of the resulting bank will attract many
customers who, in face of rising credit needs and
the limited lending capabilities of applicant banks,
have had to turn to the Portland, Augusta, and
Bangor banks, and, in some cases, to banks in Boston and New York to negotiate loans. The public
will also be the beneficiary of a wide array of specialized services including loans participations, investment and portfolio management, and a trust
operation presently run by The First National Bank
of Houlton. Although this merger may appear to
be slightly anticompetitive to the three smallest
banks in the trade area, the benefits that the community will derive from the merger plus the added
competition that the resulting bank will provide
the Northern National Bank outweighs any anticompetitive aspects.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest.
The application is, therefore, approved.
MARCH 20, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Ft. Fairfield Bank is a subsidiary of Depositors
Corporation ("Depositors"), the largest banking

organization and the largest of four bank holding
companies in Maine. On August 13, 1969, Depositors' application to acquire Houlton Bank was
denied by the Board of Governors of the Federal
Reserve System after comprehensive evaluation of
the competitive factors involved. The instant
merger application would appear to be an effort to
circumvent that decision, and presents essentially
the same competitive effects discussed by the Federal Reserve Board in denying the Depositors' application to acquire Houlton Bank.
When its original application to acquire Houlton
Bank was denied, Depositors also had pending
application to acquire Katahdin Trust Co., the
smallest of seven commercial banks operating in
Aroostook County. Since that time, Depositors'
agreement with Katahdin Trust Co., has been terminated. Since the then pending application to
acquire Katahdin Trust Co., played little, if any,
part in the Federal Reserve Board's decision, we
believe that the Board's opinion of August 13, 1969,
accurately evaluates the competitive factors involved in the proposed merger and adopt its conclusions with respect thereto.

SOUTHERN CALIFORNIA FIRST NATIONAL BANK, SAN DIEGO, CALIF., AND GATEWAY NATIONAL BANK, EL SEGUNDO, CALIF.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Gateway National Bank, El Segundo, Calif. (15239), with
and Southern California First National Bank, San Diego, Calif. (3050), which had.
merged June 11, 1970, under charter and title of the latter bank (3050). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On March 2, 1970, Gateway National Bank, El
Segundo, Calif., and Southern California First National Bank, applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
Southern California First National Bank, with
IPC deposits of $484 million, was established in
1883 as the First National Bank of San Diego. The
market area served by this bank encompasses the
whole of San Diego County, where it maintains
33 of its 48 branches and has approval for five
additional offices, and also extends into Orange
82




$31,745,184
601,086,646
632,831,830

To be
operated

6
49
55

County, where it maintains 9 offices, and into Los
Angeles County, where 6 branches are located.
Gateway National Bank, with IPC deposits of
$20 million, was established in 1964. In addition
to its head office in El Segundo, this bank maintains
four branches in Los Angeles County in the communities of Hawthorne, Manhattan Beach, Lawndale, and Lomita. Its primary market area, in which
it holds 3 percent of the area deposits, is the highly
industrialized South Bay region of Los Angeles,
extending from the Los Angeles International Airport south to the Pacific Ocean and from Harbor
Freeway west to the Pacific. The area is fully de-

veloped residentially and industrially. Employment
is offered to local residents through numerous industrial and manufacturing plants near the airport
and throughout the southwestern portion of Los
Angeles County.
The proposed merger will not result in a reduction of an alternate source of banking services as
the charter bank is not presently represented within
the market area of the merging bank. The nearest
branch of the charter bank to the merging bank
is in the West Los Angeles area, approximately
14 miles north of the merging bank's head office.
Common depositor or borrower relationships, if
any, are negligible. In addition, the charter bank's
share of the aggregate deposits in Los Angeles
County will increase by only 0.13 percent to 0.29
percent upon consummation of the merger. The
competitive position of the charter bank in San
Diego and Orange counties will remain unchanged.
Substantial competition now exists in the merging bank's service area. The Bank of America maintains 22 branches in the region and holds deposits
of $283 million, and Security Pacific National Bank,
which operates 13 branches, holds deposits of $127
million. Other banks which stimulate competition
include United California Bank, with nine
branches, and Imperial Bank, with a head office
and one branch. The $2.5 billion Home Savings
and Loan and the $1.9 billion American Savings
and Loan are among 20 savings and loan institu-

tions with $9 billion in deposits in the South Bay
area. In view of the presence of a large number of
sizeable banking institutions and the fully developed nature of the merging bank's service area,
it is unlikely that the charter bank would establish
branches de novo in this section of Los Angeles
were the proposed merger disapproved.
It is concluded that the merger will have no adverse competitive effect and is in the public interest. The application, therefore, is approved.
APRIL 24,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National operates six offices in Los Angeles
County and nine offices in adjacent Orange County.
Gateway Bank operates six offices in Los Angeles
County. The main office of First National in San
Diego is approximately 110 miles southeast of Gateway Bank's main office in El Segundo. However, the
closest Los Angeles County offices of the merging
banks are 7 miles apart. The merger would, therefore, appear to eliminate some direct competition.
First National and Gateway Bank were the 26th
and 31st largest banks, respectively, of 64 banks
operating in Los Angeles County as of June 30,
1968. Their shares of total county deposits were
0.15 percent and 0.13 percent, respectively; the
merged bank would hold 0.29 per cent. The merger
would, therefore, not have an adverse effect upon
competition.

BRISTOL COUNTY TRUST COMPANY, TAUNTON, MASS., AND T H E FIRST NATIONAL BANK OF ATTLEBORO, ATTLEBORO, MASS.
Banking offices

Total assets

Name of bank and type of transaction

In
operation
Bristol County Trust Company, Taunton, Mass., with
and The First National Bank of Attleboro, Attleboro, Mass. (2232), which h a d . .
merged June 30, 1970, under charter of the latter bank (2232) and title "First
Bristol County National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On January 22, 1970, The First National Bank
of Attleboro, Attleboro, Mass., and the Bristol
County Trust Company, Taunton, Mass., applied
to the Comptroller of the Currency for permission
to merge with the charter of the former and with
the title "First Bristol County National Bank."
The applicant banks are both located in south-




$38 ,417 ,295
32 ,267 ,252
70 ,584 ,400

To be
operated

6
5
11

eastern Massachusetts in Bristol County, which is
divided geographically, economically, and politically into three separate areas. The trading area of
the merging bank, the Bristol County Trust Company, with IPC deposits of $26.4 million, is located
in the central area where it operates six offices. The
charter bank, The First National Bank of Attleboro, with IPC deposits of $23.5 million, operates

its five offices in the northern section of Bristol
County.
Bristol County is heavily industrialized. The
manufacture of jewelry dominates the economy of
the northern sector while machine tool and silver
manufacturing are the mainstays of the economy
in the central area. The areas served by the applicant banks contain a population of approximately
152,000, and moderate growth is expected.
Both banks share the problems of small banks
located near large metropolitan areas. They have
experienced difficulty in attracting managerial talent because of their inability to offer salaries comparable to those offered by the larger banks in
Boston and Providence. Intense competition for
trust services comes from the metropolitan banks,
and has curtailed the growth and variety of fiduciary services offered by the applicant banks. The
merger would permit the resulting bank to employ
full-time trust personnel, a service available at
neither of the two banks at the present time. The
increased lending limit, as well as a greater variety
of specialized lending services, would be available
to meet the diversified needs of the corporate customers of both banks. Data processing services,
likewise, would be improved and updated for the
benefit of the customers of both banks.
The merger will have no adverse effect on the
financial structure in Bristol County. The county
now has 12 commercial banks. The First National
Bank of Attleboro holds 7.2 percent of the deposits
in the county and 7.9 percent of the commercial
bank loans. The Bristol County Trust Company
has 8.3 percent of the commercial bank deposits
and 8.9 percent of the loans. These figures do not
include competition from savings banks, cooperative banks, and Federal Savings and Loan Associations. When the deposits and loans of these institutions are considered in conjunction with commercial
bank figures, the market percentage for deposits
held by the Bristol County Trust Company is 2.6
percent, and by The First National Bank of Attleboro is 2.27 percent. In addition, credit unions and
personal loan companies also vie for lendable funds
and loan business, and commercial banks located
outside the county provide extensive competition.
The two banks compete with each other to an
insignificant degree. Although both banks operate
branches in the Seekonk area, there are few common customers and very little overlap. Those
branches, 5i/£ miles apart, are divided by geographic
and economic boundaries. Both are located in sep-




arate shopping centers. Both banks have rejected
the idea of branching into the service areas of the
other bank in view of their lack of established customers, and in view of the entrenched competition
in the other areas. The charter bank has a history
of competing with banks to the north and toward
Rhode Island whereas the the Bristol County Trust
Company has attempted to compete to the east,
west, and south of its headquarters.
It appears that the merger will have definite
benefits to the banking public and that no adverse
competitive effects are foreseen. Therefore, the merger is approved.
MAY 8, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

First National and Bristol Trust operate two of
three banking offices in Seekonk (1960 population
8,400), although in view of this town's location on
a major highway about 4 miles from Providence,
R.I., it is likely that banks in the latter city provide
alternatives to some customers. The other offices of
the merging banks are located in their home communities some 14 miles apart; First National's
South Attleboro offices are somewhat farther from
Taunton. Although each of the home communities
of the merging banks are served by other banks,
there are no alternatives in the intervening area.
It would appear that a limited amount of direct
competition between the merging banks would be
eliminated by the proposed merger.
As Massachusetts law permits commercial banks
to branch anywhere in their home counties, the
merger may foreclose the possibility of increasing
competition between the two banks.
Although the areas primarily served by the merging banks are not substantially coextensive, their
competitive overlap justifies examination of the
increased concentration in northern Bristol County,
the broader area which will comprise the service
area of the resulting bank. As of June, 1968, five
banks operated in the northern part of the county.
Bristol Trust and First National are the largest and
second largest of these banks, controlling about
25 percent and 23 percent of total deposits in this
area. One of the three other banks in northern
Bristol County, Manufacturers National Bank of
Bristol County, North Attleboro, is an affiliate of
the $1.2 billion Baystate Corp., one of two registered bank holding companies operating in Massachusetts.
In view of the elimination of some direct com-

petition and the noted increase in concentration in
commercial banking in northern Bristol County,

we conclude that the proposed merger would have
an adverse effect on competition.

FIRST NATIONAL BANK OF SOUTH JERSEY, EGG HARBOR TOWNSHIP, N.J., AND
THE FIRST NATIONAL BANK OF WILLIAMSTOWN, WILLIAMSTOWN, N J .

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The First National Bank of Williamstown, Williamstown, NJ. (7265), with
and First National Bank of South Jersey, Egg Harbor Township, NJ. (1326),
which had
merged June 30, 1970, under charter and title of the latter bank (1326). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On February 24, 1970, the First National Bank
of South Jersey, Egg Harbor Township, N.J., applied to the Comptroller of the Currency for permission to merge with The First National Bank of
Williamstown, Williamstown, N.J., under the
charter and with the title of the former.
The First National Bank of South Jersey, the
charter bank, was organized in 1822, and converted
to a National charter in 1865. The charter bank,
which operated as the Boardwalk National Bank
of Atlantic City and assumed its present name December 1, 1969, has total resources of $255 million
and operates 21 offices in Atlantic County and 1
office in Salem County.
Atlantic County, the principal market area of the
charter bank, is located in the southern portion of
the State. The county covers an area of 566 square
miles and has a population of approximately 188,
000, 30 percent of which is located in Atlantic City.
The eastern portion of the county fronts on the
Atlantic Ocean and has long been a popular resort
and recreation area. The central and western portions of the county are comprised of woodland and
farm areas that produce fruits and garden vegetables. Continued growth is anticipated as the woodlands nearer to the cities are rapidly being developed into building lots and industrial parks.
The First National Bank of Williamstown, the
merging bank, has total assets of $14 million, and
operates two offices in Williamstown and one office
in Turnersville. All offices of the merging bank
are located in Gloucester County, northwest of
Atlantic County.




$15,976,524

3

256,385,345

21

272,361,869

24

Gloucester County covers an area of 328 square
miles which borders on the Delaware River. The
population of the county is estimated at 167,200.
Industrial activity is concentrated in the western
portion of the county. Petroleum refining and
chemical manufacturing are the leading industries.
The economy of the eastern part of the county is
mainly dependent on cash crop farming. Continued
industrial and residential growth is anticipated as
improved highways are completed, making the area
more accessible to the Camden-Philadelphia area.
Competition between the charter and merging
banks is minimal. The main offices of the subject
banks are 35 miles apart and the closest branch
offices are 10 miles apart. There are approximately
70 banks operating in the Third Banking District.
Many of these banks have offices intervening between the subject banks. The charter bank's position as third largest bank in the district will be unchanged by this merger. Although potential competition through de novo branching exists, it is
limited by the scarcity of suitable or legal locations.
Consummation of the proposed merger will provide new and improved services to present and potential customers in the Williamstown area, including a larger lending limit, sophisticated computer
services, and a trust department. The merger will
also provide the bank with the management resources and depth needed to better serve the community.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest
and the application is, therefore, approved.
MAY 15, 1970.
at;

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are approximately 11 miles apart. There are a number
of banking offices located between these two
branches. It would appear that only a limited
amount of existing competition would be eliminated by the proposed merger.
Under New Jersey law, commercial banks may
open de novo branches or operate branch offices
acquired through merger anywhere in the banking
district in which they are located. Subsequent to
the recent changes in New Jersey law, larger commercial banks in the State have embarked on extensive market expansion programs, both through
de novo branching and through merger. We consider it important that the larger banks in a given
district enter new areas either de novo or through
merger with smaller banks, thereby preserving
leading local banks, most capable of remaining
substantial competitive alternatives.
The merging banks are located in the Third
Banking District, which is comprised of New Jersey's eight southernmost counties. Accordingly,
they could be permitted to open de novo offices in
areas served by each other, where not restricted by
New Jersey's home and branch office protection
laws. In view of its resources, extensive de novo
branching by First of Williamstown is unlikely.
First of South Jersey, however, is the third largest
bank in the district and has the resources to open
new offices where possible. Because of the presence
of the home office of First of Williamstown, First of
South Jersey could not be permitted to open a
de novo office in that community. Other parts of

northern Gloucester County, where First of Williamstown's other branch is located, may become
closed to de novo branching if new banks are
chartered, but it is noted that other large banks
in the district have applied for persmission to open
de novo offices in townships in this part of the
county.
Gloucester County has seen substantial reorganization of its banking community in the past few
months. Two of its larger banks have been merged
into banks based in Camden County. Three localized banks, including the county leader, are merging with one another. One of the smaller banks in
the county is merging with another small bank in
neighboring Salem County. First of Williamstown
will be the seventh to become party to a merger
agreement, and the third to be merged into one of
the largest of some 70 banks operating in the Third
Banking District. First of Williamstown presently
holds the fifth largest share of commercial bank
deposits in Gloucester County, about 6.5 percent,
and is the third largest bank headquartered in the
county.
While First of South Jersey is one of the district's
largest commercial banks, controlling about 9 percent of total commercial bank deposits therein, and
clearly one of the more likely new entrants into the
banking markets of Gloucester County, it will not
acquire a dominant position in the county through
the proposed merger. Although some de novo
branching is possible, in view of the size and relative market position of the acquired bank, the proposed merger is unlikely to have a significantly
adverse effect on potential competition.

FIRST NATIONAL BANK OF WESTMORELAND, GREENSBURG, PA., AND T H E PEOPLES NATIONAL BANK OF TARENTUM, TARENTUM, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Westmoreland, Greensburg, Pa. (14055), with
and The Peoples National Bank of Tarentum, Tarentum, Pa. (5351), which had.
consolidated June 30, 1970, under charter of the latter bank (5351) and title
"Southwest National Bank of Pennsylvania." The consolidated bank at date of
consolidation had

COMPTROLLER S DECISION

On February 19, 1970, the First National Bank
of Westmoreland, Greensburg, Pa., and The Peoples National Bank of Tarentum, Tarentum, Pa.,
86



$78,418,692
26,640,833
105,059,524

To be
operated
6
3

9

applied to the Comptroller of the Currency for
permission to consolidate under the charter of the
latter and with the title of "Southwest National
Bank of Pennsylvania."

The Peoples National Bank of Tarentum, with
IPC deposits of $21.3 million, was chartered in
1900. It operates two branches and has two approved but unopened branches. This bank is in
good condition but faces a management succession
problem owing to the anticipated retirement of a
number of its senior officers in the near future and
lack of personnel within the bank capable of replacing them.
The market area of the charter bank lies approximately 18 miles northeast of the city of Pittsburgh,
along the Allegheny River. This area consists
mainly of Allegheny County, the upper portion of
which is known as the Allegheny Valley area, and
parts of Butler, Armstrong and Westmoreland
counties. The 1960 population of the area, which
consists of approximately 19 boroughs and townships, was 118,833. The area economy consists of
highly diversified manufacturing, with the steel and
glass industries as the largest industrial employers.
The Allegheny Valley is one of the few areas in the
county that has not been urbanized and is available
for future residential developments. Completion of
a new super-highway should rapidly increase area
residential development.
The First National Bank of Westmoreland, the
consolidating bank, with IPC deposits of $62.1
million, was chartered in 1881. It operates five
branches and has two approved but unopened
branches. The condition of this bank is very good.
Its management is excellent and it has an adequate
number of middle management personnel capable
of replacing the top management of the charter
bank when they retire.
The primary service area of the bank consists of
greater Greensburg and central Westmoreland
County. Westmoreland County has a population
of 387,000, while the Greater Greensburg Area contains a population of 53,409 inhabitants. Economically, the area is highly diversified, with over 107
industries operating there. Greater Greensburg is
the commercial center for a substantial residential
region, and harbors a majority of the professional
trade. Originally, the area was a prosperous coal
mining center but exploitation has resulted in its
ultimate depletion. The area served by the consolidating bank's most outlying branches is characterized by new and rapid development.
Banking competition in the areas of both banks
is extremely keen. The two banks claim to be finding it increasingly difficult to compete for deposits
against Mellon National Bank and Trust Company,




with resources of $4.9 billion, and Pittsburgh National Bank, with resources of $1.7 billion. Among
banks presently operating in the combined service
area, the charter bank ranks ninth, and the consolidating bank ranks fifth. The fourth largest
bank, The Union National Bank of Pittsburgh,
with total deposits of $698 million, is considerably
larger than the fifth ranked bank.
Consummation of this proposal will benefit the
customers of both banks through the greater availability of lendable funds, a larger lending limit,
trust services for customers of the charter bank,
and the better, less expensive services that normally
arise out of economies of scale. In addition, the
imminent management succession problem of the
charter bank will be solved through the availability
of well-trained and -developed middle management
to replace the top management of the charter bank
when they retire.
Competition will not be adversely affected. As
the service areas of the two banks are separate and
distinct and do not overlap, little, if any, competition between the banks will be eliminated. Although one alternative banking source in the combined service area will be eliminated, adequate
alternatives remain. The consolidated bank will
rank as fifth largest in the combined service area,
the same position as now occupied by the consolidating bank. Competition will be enhanced because
the slightly larger and stronger consolidated bank
will be better able to compete with the large Pittsburgh-based banks operating in the area than can
either consolidating bank operating alone.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application is, therefore, approved.
MAY 15, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The home offices of the two banks are 25 miles
apart. The Delmont office of First National and the
home office of Peoples National are 18.8 road miles
apart. Distance, topography, and intervening banking facilities apparently negate the existence of
substantial competition between them.
Considerable penetration into Allegheny and
Westmoreland counties by the branching of large
Pittsburgh banks has taken place. Peoples National
in Tarentum competes with offices of Union National of Pittsburgh (assets $657 million) and Western Pennsylvania National (assets $747 million).
First National competes with Mellon National
87

(assets $3.8 billion), Pittsburgh National (assets $1.3
billion), Union National and Western Pennsylvania
National.
As of December 31, 1968, Peoples National accounted for $6.4 million, or 0.3 percent, of IPC
demand deposits and $21.3 million, or 0.4 percent,
of total deposits in Allegheny County. At the same
time, First National held $20.8 million, or 13.4 percent, of IPC demand deposits and $61.8 million, or
11.3 percent, of total deposits in Westmoreland
County.
The bank resulting from the proposed consolidation would be the fifth largest in the general Pitts-

burgh area, but would be substantially smaller than
the four larger banks.
Pennsylvania law permits unrestricted branching
within a bank's home county and into contiguous
counties. Cross-county branching trends indicate
increasing competitive pressure on smaller banks
by the large Pittsburgh-based banks, which, for example, operate 35 branches in Westmoreland
County.
In view of the sizes of the towns and of the competing banks already in the area, it is not believed
that this consolidation would have a significantly
adverse effect on potential competition.

STATE BANK OF WHITING, WHITING, IND., AND T H E FIRST NATIONAL BANK OF CEDAR LAKE, CEDAR LAKE, IND.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

State Bank of Whiting, Whiting, Ind., with
and The First National Bank of Cedar Lake, Cedar Lake, Ind. (14813), which
had
consolidated June 30, 1970, under charter of the latter bank (14813) and title
"Northwest Bank of Indiana, National Association." The consolidated bank at
date of consolidation had

COMPTROLLER S DECISION

On March 11, 1970, The First National Bank of
Cedar Lake, Cedar Lake, Ind., with IPC deposits
of $7.8 million, and the State Bank of Whiting,
Whiting, Ind., with IPC deposits of $22 million,
applied to the Office of the Comptroller of the
Currency for permission to consolidate under the
charter of the former and with the title of "Northwest Bank of Indiana, National Association." Permission was also requested to locate the consolidated bank's main office in Whiting, Ind.
The First National Bank of Cedar Lake, Cedar
Lake, Ind., was chartered in 1957, and opened its
only branch office on February 15, 1967, several
miles north of Cedar Lake in St. John, Ind. Cedar
Lake is a rural town about 32 miles southeast of
Chicago, 111., and 23 miles south of Whiting, Ind.
The area immediately surrounding Cedar Lake is
primarily agricultural, with some residential development. The economy of the town is highly dependent upon the large industrial complexes
located in the Gary-Hammond-East Chicago area.
The population of the town is presently estimated
at 6,900 and growth is expected as inhabitants of
88




To be
operated

$23,399,108

2

7,984,358

2

31,383,466

4

the industrial areas contiguous to Chicago seek
the more rural residential atmosphere that Cedar
Lake affords. In addition, nearby Cedar Lake is a
summer resort haven. St. John reflects the same
rural residential characteristics as Cedar Lake.
The State Bank of Whiting, Whiting, Ind., is
in the extreme northwest corner of Lake County,
adjacent to metropolitan Chicago and bordering on
Lake Michigan. The bank was chartered in 1931,
and presently operates one branch in Highland,
Ind., about 9 miles south of Whiting. Whiting,
with a population of about 8,000, is a highly industrialized town, whose economy is supported by employers such as Standard Oil Company of Indiana,
Sinclair Refining Company, Youngstown Sheet and
Tube Company, Inland Steel Company, and American Steel Foundry.
Lake County is serviced by 13 commercial banks,
with aggregate deposits in excess of $765 million.
In addition, there are numerous savings and loan
associations, credit unions, and finance companies
operating in the participating banks' trade areas.
Competition is also felt from the much larger
Chicago-based banks that solicit business in the

Lake County service area. Within its primary service area contiguous to Whiting, the State Bank of
Whiting competes with six commercial banks that
together operate 21 branch offices. There are no
commercial banks or branches within the primary
market area of First National Bank of Cedar Lake.
Approval of the proposed consolidation will cause
no undue concentration of banking assets in the
resulting bank, and will leave a substantial choice
of alternative sources of commercial banking
services.
Competition between the consolidating banks is
virtually nonexistent due to the distance separating
their offices and the presence of intervening banks.
Furthermore, neither bank appears to be a likely
potential entrant to the service area of the other
due to the factors of distance, expense, and the
home-office protection provisions of the Indiana
branch banking law.
The proposed consolidation will provide the
charter bank's customers with an increased range
of banking services, including trust services, and a
higher lending limit. In addition, management continuity will be assured for the charter bank.
Applying the statutory criteria to the proposed
consolidation, we find, that it is in the public
interest, and the application, therefore, is approved.
MAY, 15, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Fourteen commercial banks with 57 banking
offices are located in Lake County (an area which
probably overstates the relevant market). The nearest branches of the merging banks are about 6 miles
apart, and branches of three of the county's largest
banks are located in the intervening area. The head
offices of the merging banks are 23 miles apart and
there are 26 other banking offices in this area.

Neither of the merging banks derives significant
business from the areas served by the other. Hence,
this proposed merger would appear to eliminate
only a limited amount of direct competition between the merging banks.
In response to rapid population migration south,
State Bank recently established a branch in Highland, approximately 12 miles south of Whiting.
Under Indiana law, which permits countywide
branching, State Bank could establish additional
branches in the growing southern half of the
county. The proposed merger, of course, eliminates
State Bank as a potential competitor in those areas
presently served only by First National. However,
because of the size and number of other potential
competitors, this proposed merger would not appear to entail the loss of substantial potential competition.
State Bank and First National are, respectively,
the 8th and 13th ranked of 14 banks located in
Lake County. They hold approximately 4 percent
and 1.1 percent of county total deposits of $748.1
million. The proposed resulting bank will be the
seventh largest bank in the county, with about 5
percent of county total deposits.
Commercial banking is concentrated in Lake
County. The largest bank holds about 31 percent,
and the four largest banks hold about 66 percent
of county total deposits.
The proposed merger will have little effect on
this existing high level of concentration.
The proposed merger would eliminate only a
limited amount of direct competition and only
slightly affect concentration in commercial banking
in Lake County. Thus, we conclude that it is unlikely that this proposed merger would have a substantially anticompetitive effect.

T H E M E R C H A N T S N A T I O N A L B A N K OF A L L E N T O W N , A L L E N T O W N , P A . , A N D T H E FOGELSVILLE N A T I O N A L B A N K , FOGELSVILLE, P A .

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The Fogelsville National Bank, Fogelsville, Pa. (12975), with
and The Merchants National Bank of Allentown, Allentown, Pa. (6645), which
had
merged June 30, 1970, under charter and title of the latter bank (6645). The
merged bank at date of merger had




$20,875 ,731

2

185,639 ,802

13

206,538 ,179

15

89

COMPTROLLER S DECISION

On December 15, 1969, The Fogelsville National
Bank, Fogelsville, Pa., and The Merchants National
Bank of Allentown, Allentown, Pa., applied to the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
The Merchants National Bank of Allentown,
with IPC deposits of $136.8 million, was chartered
in 1903. It operates 12 branches and its head office
in Lehigh County.
Allentown, home office city of the charter bank,
is situated in the southeast portion of Lehigh
County in eastern Pennsylvania, some 62 miles
north of Philadelphia, and 36 miles northeast of
Reading. Allentown, with a 1960 population of
108,000, is the fourth largest city in Pennsylvania,
and is the center of the third largest trading area
in the State; the trading area has a population of
250,000. The economy of that area is mixed with
industry, commerce, agriculture, construction, and
government all contributing.
Included among the charter bank's competitors
in Allentown and its broader trading area in Lehigh County and the Lehigh Valley are the Industrial Valley Bank of Jenkintown, with total resources of about $441.7 million; the $220 million
Bank of Pennsylvania in Reading, which recently
opened a new branch in Allentown; and the $239
million First National Bank of Allentown. Of the
four banks presently operating in Allentown, the
charter bank is the smallest. Other competitors in
the Lehigh Valley area include the $623 million
Continental Bank and Trust Company, Norristown; the $497 million American Bank and Trust
Company of Pa., Reading; and the billion dollar
Philadelphia banks, as well as various other locallybased banks. Substantial competition is also generated by savings and loan associations, insurance
companies, factors, direct lending agencies of the
government, and the 26 personal loan and sales
finance companies vying with commercial banks
for loans and deposits in the area.
The Fogelsville National Bank, with IPC deposits of $16.3 million, was chartered in 1926. In
addition to its home office, it operates one branch
at Wescosville. While management of this bank is
good, its two senior officers are nearing retirement
age and the younger men being groomed as their
successors will not be ready to replace them by the
time they retire.
90




Fogelsville, home of the merging bank, is a small
community with 766 residents located 12 miles west
of Allentown in Lehigh County. Wescosville, where
the bank's only branch operates, is 7 miles southeast of Fogelsville. Although the economy of the
area is basically agricultural and residential, substantial economic growth is anticipated in the merging bank's service area. Three major firms—F&M
Shaeffer Brewing Company, Olin-Mathieson, and
Kraft Foods—plan to locate in the area. Construction has already begun on the Olin-Mathieson
plant, and construction by the other two companies
will begin this year.
Primary competition for the merging bank comes
from the First National Bank of Allentown, which
has two branch offices in its area, one at Macungie,
7 miles south, and the other at Trexlertown 3 miles
south. There is an overlap of the trade areas of
the merging bank and the New Tripoli National
Bank, New Tripoli, Pa.
Consummation of this merger will solve the
merging bank's management succession problem
and will make available to its customers a number
of services not presently offered, including a trust
and estate planning department, automated customer services, and a greater borrowing capacity.
The resulting institution will be more capable of
contributing to the imminent expansion of the
Fogelsville economy than can the merging institution.
The effect of this merger on competition will not
be significantly adverse. Because the nearest offices
of the two banks are 5 miles apart, and their main
offices are 12 miles apart, there is some competition
between them which will be eliminated. However,
because of the large number of institutions in the
general area, and the fact that the merging bank's
activity is confined primarily to the immediate
Fogelsville and Wescosville area, it is not believed
that such competition is significant. This merger,
by introducing offices of the charter bank to the
present trade area of the merging bank, will enhance competition with local branches of the First
National Bank of Allentown. While the resulting
bank will remain the fourth largest bank in Allentown in terms of its share of deposits and loans, it
will be better able to compete with the larger banks
operating in the valley area.
It is concluded, in the light of the statutory criteria, that the merger is in the public interest. It is,
accordingly, approved.
APRIL 30,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The home offices of the two banks are 12 miles
apart. Fogelsville Bank's branch office at Wescosville, however, is 5 miles from Merchant's closest
office. Fogelsville and Wescosville are two small
villages west of Allentown, each with a population
of approximately 750.
According to the application, Merchants draws
significant deposits from the immediate areas served
by Fogelsville Bank in the small communities of
Fogelsville and Wescosville; therefore, it would
appear that the proposed merger would eliminate
significant direct competition in these two local

areas. Fogelsville Bank also appears to draw a
significant proportion of its total deposits from
Allentown, but it would not appear to be a major
competitive factor in this much larger market.
Merchants is the second largest bank in the
Lehigh County-Bethlehem County area; according
to data for June 30, 1968, it accounts for about 20.5
percent of this market. It is acquiring a small local
bank located in Lehigh County, and in so doing is
eliminating direct competition in the immediate
communities served by the latter. For these reasons,
we conclude that the proposed merger would have
an adverse effect on competition.

ZIONS FIRST NATIONAL BANK, SALT LAKE CITY, UTAH, AND BANK OF ST. GEORGE, ST. GEORGE, UTAH

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Bank of St. George, St. George, Utah, with
was purchased June 30, 1970, by Zions First National Bank, Salt Lake City,
Utah (4341), which had
After the purchase was effected, the receiving bank had

For "Comptroller's Decision" and "Summary of
Report by Attorney General" see Zions First Na-

To be
operated

$15,754,231

3

272,307,425
288,061,656

18

21

tional Bank, Salt Lake City, Utah, and Bank of
Commerce, Magna, Utah, May 29, 1970, pp. 76-77.

T H E FIRST NATIONAL BANK OF EBENSBURG, EBENSBURG, PA., AND T H E PEOPLES BANK OF CLYMER, CLYMER, PA.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
The Peoples Bank of Clymer, Clymer, Pa., with
and The First National Bank of Ebensburg, Ebensburg, Pa. (5084), which had. . .
merged July 1, 1970, under charter and title of the latter bank (5084). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On March 31, 1970, The Peoples Bank of Clymer,
Clymer, Pa., and The First National Bank of
Ebensburg, Ebensburg, Pa., applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Peoples Bank of Clymer, Clymer, Pa., a unit
bank, was chartered in 1920. The bank presently
holds IPC deposits of $2.8 million, and is the only




$4,419,247
40,939,058
45,358,305

1
5
6

commercial bank serving Clymer. With its current
leadership at, or near, retirement age, the bank
must provide for management succession. The
bank's growth record in recent years has reflected
the unstable economy of its service area and the
unaggressive character of its management. Clymer,
with a population of 7,251, is located in Indiana
County, in the heart of the coal region of western
Pennsylvania. The community's economy is totally
91

dependent on coal, and presently, with a resurgence in the demand for coal, the town is enjoying
a wave of prosperity.
The First National Bank of Ebensburg, Ebensburg, Pa., was organized in 1897, and presently
operates five banking offices and holds IPC deposits
of $29.2 million. Under youthful and aggressive
management, the charter bank has experienced
rapid growth in the past decade.
Ebensburg, with a population of about 5,000
people, serves as the county seat of Cambria
County. The service area of the bank encompasses
the central portion of the county where approximately 25,000 people reside. The city is situated on
east-west U.S. Route 22, a factor which strengthens
its position as the political and geographical center
of Cambria County. Ebensburg and the surrounding towns have, for many years, been dependent
upon the coal industry, but the cyclical nature of
this industry has prompted the area to broaden its
economic base. Businesses such as the Kimbal
Engineering Company, which employs 220, and the
Stevens Manufacturing Company, which employs
375, have entered this area. The State of Pennsylvania also maintains a school for the mentally retarded in the Ebensburg area, thus employing approximately 1,000 people. The outlook for coal
mining has improved since the Barnes and Tucker
Coal Company, one of the area's major employers,
contracted with Pennsylvania Power and Light
Company to supply their fuel needs until the year
2010. Tourism is also gaining some importance
as a seasonal industry. Some Ebensburg residents
commute to Johnstown, an industrial-commercial
city of 54,000, located about 15 miles southwest of
Ebensburg.
There is no competition between the participating banks whose offices are located in different
counties and serve different markets. While the
charter bank's Barnesboro office is only about 12
miles from the merging bank, the difficulty of travel
and the unaggressive management of the merging
bank have effectively precluded the development of
competition between them. The effect of this
merger will be to stimulate banking competition in
the service area of the merging bank by substituting for it, an office of an aggressive, competitive
commercial bank responsive to the banking needs
of the community.
When the merger is consummated, the charter
bank will retain its rank as third largest commercial banking institution in the Johnstown-Ebens-

92



burg area, operating 5 of the 47 existing banking
offices. The trade area's two largest commercial
banks are headquartered in Johnstown, the $134
million U.S. National Bank and the $57 million
Johnstown Bank and Trust Company. Additional
competitors within the charter bank's service area
include the $49 million Johnstown Savings Bank;
the Cambria Savings and Loan, Barnesboro, Pa.;
the Ritter Finance Company; and the Cambria
Thrift Company of Ebensburg.
The banking public in the merging bank's service area will benefit from the availability of an increased range of banking services following this
merger. The lending limit of the merging bank at
the present time is $30,000; however, the resulting
institution will have a lending capacity of $300,000,
permitting it to service most individual and corporate credit needs in its market. A full range of
deposit services, at maximum legal interest rates,
will be made available in the merging bank's service area. Trust services, not now offered by the
merging bank, will be introduced through the
resulting bank. Electronic data processing will be
utilized, and plans to modernize and upgrade the
Clymer office are being formulated.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest.
The application is, therefore, approved.
JUNE 1,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The home offices of the two banks are 25 miles
apart. Two of First National's branches, however,
are 12 and 16 miles east of Clymer, and it may be
presumed that some competition exists between
them and Peoples Bank. Distance and intervening
banking facilities probably minimize the amount
of competition between Peoples Bank and First
National's main office at Ebensburg.
First National competes with U.S. National Bank
of Johnstown (assets $132 million) and Johnstown
Bank and Trust Company (assets $53 million) both
of which maintain branches in the vicinity of
Ebensburg.
As of December 31, 1968, First National accounted for 11 percent of total commercial bank
deposits in Cambria County, and Peoples National
held 3 percent of total deposits in Indiana County.
Although Pennsylvania law permitting unrestricted branching within a bank's home county
and into contiguous counties would allow First
National to branch into Clymer, the size of the

town together with its present economic situation
would be obvious deterrents.
We conclude that the proposed merger would

not have a significantly adverse effect on competition.

T H E IDAHO FIRST NATIONAL BANK, BOISE, IDAHO, AND FIDELITY NATIONAL BANK OF TWIN FALLS, TWIN FALLS, IDAHO

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Fidelity National Bank of Twin Falls, Twin Falls, Idaho (11100), with
and The Idaho First National Bank, Boise, Idaho (1668), which had
merged July 1, 1970, under charter and title of the latter bank (1668). The
merged bank at date of merger had

The "Comptroller's Decision" and the "Summary
of Report by Attorney General" for this case ap-

NATIONAL BANK OF NORTH AMERICA, N E W YORK, N.Y.,

$27,413,294
500,740,908

To be
operated

4
50
54

526,045,759

peared in the 1969 Annual Report under the heading "Approved, but in litigation/'

AND TRADE BANK AND TRUST COMPANY, N E W YORK,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Trade Bank and Trust Company, New York, N.Y., with
and National Bank of North America, New York, N.Y. (7703), which had
consolidated July 6, 1970, under charter and title of the latter bank (7703). The
consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On March 31, 1970, Trade Bank and Trust
Company, New York, N.Y., and National Bank of
North America, New York, N.Y., applied to the
Office of the Comptroller of the Currency for permission to consolidate under the charter and with
the title of the latter.
National Bank of North America, New York,
N.Y., with IPC deposits of $1.2 billion, was organized in 1905, and currently operates 91 offices in
New York City and Long Island, and one office in
Nassau, in the Bahama Islands. Presently the bank's
operations are centered in Nassau County, where it
maintains 47 offices. In addition, the bank now has
nine branches in Manhattan and three offices in
Great Neck, one of which is a drive-in facility that
has been condemned by the town for use as municipal parking.
Trade Bank and Trust Company, New York,




$230,671,731
1,711,720,943
1,942,392,675

To be
operated

7
95
102

N.Y., with IPC deposits of $206.1 million, was organized in 1922, and presently operates six offices,
five of which are located in central and lower Manhattan, while one is located in Great Neck, Long
Island. It also has one approved but unopened
branch on the east side of mid-Manhattan.
Although quite large by most standards, the consolidating bank is small compared to other New
York City banks, and lacks a lending limit adequate to service all of its customers' needs. While
the Trade Bank and Trust Company offers most
of the services offered by New York banks, some are
offered only on a limited scale.
The borough of Manhattan is the center of
activity for both banks. An island of apartment
buildings, offices, stores, and small factories, Manhattan is surrounded by the most important docking facilities for ocean going ships in the world, and
is truly the world center of financial and commer-

cial activity. At present an estimated 1.5 million
people reside in Manhattan, and more than 2.6
million are employed there. All of the consolidating bank's Manhattan offices are located in the
area below 60th Street, the center of most of Manhattan's commercial activity. In this area are found
most of New York City's world-renowed drama, art,
and musical centers, as well as the garment and
jewelry centers. Chinatown, the site of Trade
Bank's southernmost branch, is in the lower end
of Manhattan, and is comprised of just a few
blocks.
Nassau County, in which most of National Bank
of North America's branches are located, has an
estimated population of 7.6 million persons, and
is essentially a residential and commercial area
containing very little industrial activity. Great
Neck, N.Y., where three of the charter bank's offices
and one of the consolidating bank's are located, is
situated in the northwest corner of the county and
is principally a residential community with a population of about 44,000. Housing in the area consists of single family dwellings in the $40,000 range,
from which most residents commute to other areas
of Long Island and New York City for employment.
There are currently 54 commercial banks operating in Manhattan, 10 of which, with a total of 313
offices, are larger than the National Bank of North
America. In Great Neck, six commercial banks,
excluding the charter bank, operate within a few
blocks of the consolidating bank's offices; five of
those banks have total resources in excess of those
held by the National Bank of North America.
Trade Bank and Trust Company's branch is the
smallest and least impressive office in the area. As
of June 30, 1969, National Bank of North America
held 1.57 percent of the total resources of commercial banks located in New York City and Long
Island, and 2.04 percent of the total deposits of
those banks; Trade Bank and Trust Company's
resources were 0.25 percent and its deposits 0.31
percent of the same totals. When deposits and loans
of mutual savings banks and savings and loan institutions in the New York City-Long Island area are
included, National Bank of North America's share
amounts to 1.34 percent of total deposits and 1.1
percent of total loans. Additional competition is
felt from insurance companies, credit unions, factors, and personal loan companies.
Approval of this consolidation will improve service offered to present customers of Trade Bank and
94




Trust Company by making available to them a
larger lending limit, more loanable funds, an established international banking department, and more
complete trust services, as well as the other banking
services offered by the charter bank which are not
available through the consolidating bank. The
executive recruitment and training program will
provide management succession to the consolidating bank. The charter bank, which is losing one of
its Great Neck offices as a result of condemnation
proceedings, will have it replaced by the Great
Neck office of the consolidating bank located
nearby, and will not thereby lose any customers.
Competition will not be adversely affected by this
consolidation. Although both banks are in the same
general market area, because of the patterns of
competition in this densely populated area, and
because the consolidating bank is oriented principally towards commercial business, there is thought
to be little competition between them. Although
one banking alternative will be eliminated by the
consolidation, adequate alternatives will remain.
The consolidation should have a tendency to enhance competition between the resulting institution
and the mammoth New York banks. However, the
charter bank's rank among commercial banks
located in Manhattan will not change as a result
of this transaction. Banking competition in Great
Neck should be stimulated by replacing the consolidating bank, which is the smallest banking
operation in the area, with a branch of the much
larger institution. Potential competition will not be
affected since expansion by branching in the Manhattan area is prohibitive due to the enormous
rentals, staffing problems, and start-up costs which
would be involved in such a move.
Applying the statutory criteria, we find the consolidation to be in the public interest, and the application, therefore, is approved.
JUNE 3,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The main offices of the consolidating banks are
in different boroughs of New York City, but several
of their branch offices are in close proximity. Although there are a large number of other competing banks with offices nearby, it is clear that the
proposed merger would eliminate direct competition between the consolidating banks.
NBNA presently is the 11th largest commercial
bank operating in New York City, and its position
would be unchanged following the proposed con-

solidation. As of June 30, 1968, NBNA held about
0.6 percent of the total deposits held by commercial
banks in New York County (Manhattan) and
Trade Bank held about 0.4 percent of such
deposits. As of the same date, NBNA held approximately 19.7 percent of the total deposits held by

commercial banks in Nassau County, and Trade
Bank held about 0.2 percent of such deposits.
We conclude that this consolidation would eliminate direct competition between the participants
but that it would not have a significantly adverse
effect on competition.

PEOPLES NATIONAL BANK OF WASHINGTON, SEATTLE, WASH., AND LANGLEY STATE BANK, LANGLEY, WASH.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation
Langley State Bank, Langley, Wash., with
was purchased July 6, 1970, by Peoples National Bank of Washington, Seattle,
Wash. (14394), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On March 16, 1970, Peoples National Bank of
Washington, Seattle, Wash., applied to the Office
of the Comptroller of the Currency for permission
to purchase the assets and assume the liabilities of
Langley State Bank, Langley, Wash.
Peoples National Bank of Washington, Seattle,
Wash., was organized in 1889, and now holds IPC
deposits of $350.5 million, and operates 49 branches
scattered throughout the State. The bank also has
five approved but unopened branches in King
County.
Seattle, the home office of the charter bank, has
a population estimated at 591,000 people. Situated
on Puget Sound, this city has one of the West
Coast's finest natural deep-water harbors, and is
fully capable of handling the world's largest ships.
The economy of the area has experienced tremendous growth over the last 10 years, due primarily
to the growth of the aerospace industry. New
surges in industrial, commercial, and residential
growth have taken place as a result in the general
area. Large capital outlays have been made for
educational institutions, highways, bridges, airports,
harbors, and other public facilities to meet the
area's expanding requirements. However, the aerospace industry has recently experienced substantial
cutbacks which have caused the area's economy to
slow its growth.
The purchasing bank is third largest in terms of
deposits among the 94 commercial banks competing
in Washington. Seattle-First National Bank in




$3,941,855

2

432,596,659
436,538,514

49
51

Seattle, is the State's largest bank, with deposits of
$1.7 billion, and 134 banking offices. The National
Bank of Commerce of Seattle, with deposits of
slightly over $1 billion, and 96 banking offices, is
the second largest. Other banks with statewide
operations include the National Bank of Washington in Tacoma, with $381 million in deposits and
44 offices, and Old National Bank of Washington
in Spokane, with $269 million in deposits and 38
offices.
Langley State Bank was established on June 30,
1913, and now holds IPC deposits of $3.3 million.
It opened its only branch on July 10, 1965, at Freeland, and is presently ranked as 66th among Washington's 94 commercial banks. The selling bank
has been able to capture only 20 percent of the
loans generated in its trade area, despite the fact
that it is relatively free of competition. The bank's
customers are not afforded a wide range of banking
services and the bank lacks management succession.
Langley and Freeland are both located at the
southerly portion of Whidbey Island, the third
largest island in the continental United States. The
population of the island is estimated at 23,000 people, with the bulk of the residents concentrated at
the northern end. There are three incorporated
towns on the island, the largest of which is Oak
Harbor, in the north, with 9,000 residents. Coupeville, located in the island's middle portion, has
800 people, while Langley, in the south, has about
539 residents. The largest employer on the island
is the U.S. Navy, which has a base at Oak Harbor
95

with a total complement of about 6,000 persons.
The service area of the selling bank, located at the
southern end of the island, is sparsely populated
and has an economy devoted mainly to lumbering,
with some diversification provided by agriculture
and tourism. Because of the rural nature of the
island and its relative isolation and separation
from the mainland by Puget Sound, the area has
attracted people of retirement age. The town of
Langley has 20 small businesses, each employing
three to six people. The local school district employs 30 to 40 employees, while the local sawmill
has 15 employees.
The northern end of the island is served by two
branches of Everett Trust and Savings Bank, Everett, Wash., and a branch of Whidbey Island Bank,
Coupeville, Wash., all located at Oak Harbor. In
addition, there are two savings and loan association
offices and three small loan companies at Oak Harbor. The central part of the island is served by the
head office at the Whidbey Island Bank in Coupeville, which opened in 1961, and now holds assets
totalling about $4 million. This bank has an approved but unopened branch location at Clinton,
6 miles to the south of Langley. The only other
financial institution in the Langley State Bank's
service area is a small branch of a local savings and
loan association, located 6 miles south of Clinton,
which competes for real estate loans and time
deposits.
Consummation of this transaction will be of
substantial benefit to the Langley-Freeland area.
The lending limit of the resulting bank's offices in
this area will be much greater than that of the
selling bank. The resulting institution will offer
expanded banking services including trust services,
international banking services, investment counseling services, and electronic data processing services.
As many of the local residents are near retirement
age, the availability of trust services will meet their
needs. Consummation of this transaction will provide management succession for the selling bank,

96




and it is anticipated that the more aggressive lending policies of the resulting bank will redound to
the benefit of the community.
Competition will not be adversely affected by
consummation of this proposal. Since the participating banks operate in distinct areas, no competition will be eliminated. The introduction of the
charter bank's resources to the service area of the
selling bank should stimulate banking competition
in this area, while consummation of this transaction
should have no competitive effect in other parts of
the State. The charter, or purchasing, bank's rank
among Seattle and Washington State banks will
remain unchanged, since the addition of the selling
bank's assets will increase its size only minimally.
Applying the statutory criteria we find the sale
to be in the public interest, and the application,
therefore, is approved.
JUNE 4,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Although the head offices of the merging banks
are 37 miles apart, Peoples National has branches
on the mainland at Mountlake Terrace and Everett, which are 18 miles and 15 miles distant, respectively, from Langley. However, Peoples National does not operate a branch on Whidbey
Island. It would appear, therefore, that little direct
competition between the banks would be eliminated by the proposed merger.
Washington law prevents banks from establishing a de novo branch in any additional city or
town where another bank regularly transacts business (although it does permit statewide expansion
by acquisition or merger). Peoples National could
enter Langley directly only by acquisition of Langley State, the community's sole bank. But Peoples
National, the third largest bank in the State, could
open an office in any community adjacent to Langley which did not presently have a bank, and thus
become a direct competitor of Langley State. The
merger will eliminate such potential competition.

UNIVERSITY NATIONAL BANK, ROCKVILLE, M D . , AND MONTGOMERY BANKING AND TRUST COMPANY, ROCKVILLE, M D .

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

Montgomery Banking and Trust Company, Rockville, Md., with
and University National Bank, Rockville, Md. (15365), which had
merged July 6, 1970, under charter and title of the latter bank (15365). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 2, 1970, Montgomery Banking and
Trust Company, Rockville, Md., and University
National Bank, Rockville, Md., applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the
title of the latter.
University National Bank, the charter bank,
opened for business August 1, 1964, and now holds
IPC deposits of $26.6 million. The charter bank
presently operates its head office at Rockville, an
office in College Park, and one in Riverdale. It has
four offices in Montgomery County; one in Gaithersburg, one in Rockville, one in Silver Spring, and
one in Bethesda. In addition, applicant has three
approved but unopened branch locations in Silver
Spring, and one application pending for Chevy
Chase, all in Montgomery County.
The Montgomery Banking and Trust Company,
the merging bank, with IPC deposits of $8.6 million, opened for business February 1965. In addition to its head office in Rockville, it presently
operates one branch in Quince Orchard, approximately 5 miles northwest of Rockville, and has an
approved but unopened location in Olney, approximately 5 miles northeast of Rockville. While the
bank is in good condition, it must provide for
management succession.
The service area of both banks is the suburban
Maryland section of the Washington, D.C., Metropolitan Area, which encompasses Montgomery and
Prince Georges counties. The population, growth
rate, per capita income, and family income in this
area is reported to be among the highest in the Nation. The economy is stable, and depends primarily
upon the Federal Government. The population
growth rate is related to the growth of the Federal
Government. Significant government installations
in the area include the Atomic Energy Commission
and Bureau of Standards complexes, in Montgomery County; and the NASA facility and Andrews




$11 ,181 ,628
39 ,207 ,224
48 ,536 ,914

3

7
10

Air Force Base, in Prince Georges County. Apart
from service industries and the Federal Government, the largest single industry in both counties
is the construction industry. However, light industrial and research and development activities have
increased substantially over the last decade. In the
more rural areas, farming retains some economic
importance.
Banking competition in this area is intense, with
29 different banks operating through 176 offices.
Area deposits held by those 29 institutions are reported to be $1.25 billion. While many of those
banks are relatively small, the Maryland National
Bank, Baltimore, Md., with total resources of over
$1 billion, operates 12 offices, and has five approved
but unopened branch locations in this area. The
other two Baltimore-based banks operating in the
area are the First National Bank of Maryland, with
total resources of over $700 million, and seven
existing and two approved but unopened offices in
the area; and The Equitable Trust Company, with
resources of almost $600 million, and five offices in
the area. The two largest area-based banks are the
Suburban Trust Company, Hyattsville, Md., with
deposits of $459 million and 38 offices; and the $200
million Citizens Bank and Trust Company, Riverdale, Md., with 31 offices. University National Bank
ranks 12th in size among the 29 institutions. The
11 Washington, D.C.-based banks, some of which
have established offices close to the Maryland-D.C.
line, are also an important competitive factor.
This merger will create an institution more capable of meeting the area's banking needs with
greater depth in management than is currently
available to either institution individually. The resulting bank will be better able to handle the banking needs of the larger business organizations than
either participating bank currently is. Consolidation of internal operations is expected to reduce
overhead and operating expenditures.
Banking competition will not be significantly
97

affected by this merger. Neither participating bank
is a major competitive force in the relevant banking market; their combinations will give the resulting bank control of less than 4 percent of the deposits in both counties. The resulting bank will be
eighth in size among banks operating in the two
counties, five of which are large statewide or regional organizations. While the proposed merger
may result in the elimination of one alternative
banking outlet, adequate banking alternatives will
remain. Through the creation of a larger institution, competition with and among the larger competitors in the area will be enhanced.
Applying the statutory criteria, we find the
merger to be in the public interest, and the application, therefore, is approved.
JUNE 3,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head office of Montgomery in Rockville is
11.5 miles from the head office of University in
College Park, but only 2 miles from its Rockville
office which is soon to become its new head office.

The application states that, despite this proximity,
these two Rockville offices are not competitors because they are on opposite sides of a wide, heavily
traveled highway, with difficult cross access.
Although there are a number of other banking
alternatives in suburban Montgomery County, the
merging banks are clearly alternatives for a number
of its residents. Accordingly, we conclude that some
direct competition will be eliminated by the proposed merger.
As of June 30, 1968, Montgomery held about 1.4
percent of total commercial bank deposits in Montgomery County. On that date, University operated
no office in the county, but has since merged with
the Old Line National Bank, which on the above
date held about 3 percent of such deposits. Most
of Maryland's largest commercial banks operate
offices in the county, including Baltimore-based
banks which are rapidly improving their competitive positions.
Although the proposed merger would eliminate
some direct competition, we do not believe that its
overall effect would be significantly adverse.

THE MERCHANTS NATIONAL BANK OF BURLINGTON, BURLINGTON, VT., AND BARRE TRUST COMPANY, BARRE, V T .
Banking offices
Total assets

Name of bank and type of transaction

In
operation

Barre Trust Company, Barre, Vt., with
and The Merchants National Bank of Burlington, Burlington, Vt. (1197), which
had
merged July 9, 1970, under charter and title of the latter bank (1197). The
merged bank at date of merger had

COMPTROLLER S DECISION

On March 23, 1970, the Barre Trust Company,
Barre, Vt., and The Merchants National Bank of
Burlington, Burlington, Vt., applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Merchants National Bank of Burlington,
with IPC deposits of $25.8 million, was organized
in 1849. This bank operates four branch offices in
addition to its head office.
Burlington, home of the charter bank, has a
population estimated at 49,000, while Chittenden
County, the most important part of the charter
bank's service area, has a population estimated at
98




To be
operated

$10,734,254
33,728,785
44,021,777

100,000. The service area of the Bristol branch,
located in Addison County, has a population of
about 5,000. Contributing to the economy of the
Burlington area are three hospitals, three colleges,
and The University of Vermont, which has a total
student population of 10,000. The two largest employers in the area are General Electric and I.B.M.,
employing 3,000 and 4,000 persons, respectively.
The normal quota of shopping centers and owneroperated service type industries are also present.
The economy of Bristol is mainly based on resort
activity, with three major ski areas established in
the last several years, and with vacation home construction continuing.

The charter bank competes in the Burlington
area with the two largest banks in the State: the
Chittenden Trust Company and The Howard
National Bank and Trust Company. In addition,
the Burlington Savings Bank, with deposits in excess of $100 million, operates in the area. The
largest federal savings and loan association in the
State, and seven branches of finance companies also
compete in the Burlington area.
Barre Trust Company, the merging institution,
with IPC deposits of $9.6 million, was organized
in 1921. It is a unit bank beset by serious managerial, capital, and growth problems. Its inadequate
lending limit has seriously hampered its growth
and its efforts to compete with the other larger institutions in its area.
Barre, Vt., home of the merging bank, has a
population of 16,500 and is the third largest city
in the State. The population of Washington
County, the service area of the merging bank, is
estimated at 50,000. The granite industry is a major
contributor to the economy. Rock of Ages Granite,
the most well known of the local granite companies, employs 5,700 persons. Five other quarries
and numerous finishing plants are also located in
the area. Sprague Electric, an electronics firm employing 800, is located in Barre, as are two colleges
which have a total student and faculty population
of 2,300. National Life Insurance of Vermont and
the administrative offices of Vermont's State Government are located in Montpelier, 8 miles northwest of Barre, and many of their employees commute from Barre. Agriculture and retail, wholesale,
and service industries also provide some support
for the area economy.
Competing with the merging bank is The Peoples National Bank of Barre, with total deposits of
about $20 million; Montpelier National Bank, with
total deposits of $21.3 million; the Montpelier
branches of the Howard National Bank and Trust
Company, and The Chittenden Trust Company,
Vermont's largest banks; and the Granite Savings
Bank and Trust Company of Barre, with total
deposits of $28.6 million. A mutual fire insurance
company, branch offices of two small loan companies, and two small credit unions also offer competition in Barre.
Consummation of the merger will enable the
Barre office of the resulting bank to offer better
service at lower cost through its larger lending




limit, improved managerial resources, trust service
capabilities, newly available computer resources,
and its generally expanded marketing capability.
This merger will have no adverse competitive
effect. Since the service areas of the two banks are
separate and do not overlap, no competition will
be eliminated. Because each bank is the smallest
bank operating in its service area, the merger
should enhance competition by creating a larger institution more capable of competing with its larger
competitors. Potential competition will not be
affected since it is very unlikely that either merging
bank would branch into the service area of the
other owing to the adequate number of banking
outlets presently available to service each area.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The apnlication, therefore, is approved.
MAY 19, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Barre Trust is located about 45 miles southeast
of Merchants National's main office and about 43
miles away from its nearest branch office. Neither
bank derives a significant amount of business from
the service area of the other bank. Moreover,
Montpelier, the State capital, is located 8 miles
northwest of Barre, along the main highway between Burlington and Barre, where three commercial banks, including the two largest in Vermont,
operate offices. In view of these circumstances, there
would seem to be little direct competition between
the merging banks.
Under Vermont law, Merchants National could
enter the Barre-Montpelier area de novo. It accounts for about 11 percent of total deposits held
by the three commercial banks in Burlington. Its
chief competitors, Howard National Bank &r Trust
(total deposits of $116.5 million) and Chittenden
Trust Company (total deposits of $109.1 million),
have entered the Barre-Montpelier area through
previous mergers with banks in Montpelier. While
Merchants National could be considered a likely
de novo entrant into the Barre-Montpelier area,
its acquisition of Barre Trust, the smallest of three
commercial banks in Barre and the smallest of six
commercial banks in the Barre-Montpelier area,
would not have a significantly adverse effect on
potential competition.

99

TRUST COMPANY NATIONAL BANK, MORRISTOWN, N.J.,

AND MONTCLAIR NATIONAL BANK AND TRUST COMPANY, MONTCLAIR,

NJ.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Montclair National Bank and Trust Company, Montclair, NJ. (9339), with. . . .
and Trust Company National Bank, Morristown, NJ. (4274), which had
consolidated July 10, 1970, under charter of the latter bank (4274) and title
"American National Bank & Trust." The consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On February 20, 1970, Trust Company National
Bank, Morristown, N.J., and Montclair National
Bank and Trust Company, Montclair, N.J., applied
to the Comptroller of the Currency for permission
to consolidate under the charter of the former and
with the title "American National Bank and
Trust."
Trust Company National Bank, the charter bank,
has total assets of $196 million. It operates two
ofl&ces in Morristown and 15 offices in 11 other
Morris County municipalities. In addition to those
ofl&ces, Trust Company National Bank operates
one branch in adjacent Sussex County and has received approval to open two more offices in Sussex
County and one in Warren County.
Morristown, the headquarters of the charter bank
and the location of one of its branches, is an interesting residential community with a population of
approximately 22,000. It is the seat of Morris
County and is located about 35 miles west of New
York City and 17 miles west of Montclair, the headquarters of the consolidating bank.
Morristown and its environs in Morris County
comprise the market area of the charter bank. The
population of the county is approximately 405,000.
The economy of Morris County is in a dynamic
phase. Until 1950, the area was predominantly agricultural. Now the area is heavily developed residentially, and is experiencing the beginnings of
some industrialization.
The Montclair National Bank, the consolidating
bank, has total resources of approximately $158
million, and operates 10 offices in Essex County.
In addition to the headquarters in Montclair, the
bank has four branches in Montclair, three
branches in Millburn, and one branch each in
Verona and West Caldwell.
The market area of the consolidating bank is
100




$153,852,352
187,631,441
340,612,870

To be
operated

11
16

27

Essex County, particularly that part of the county
known as "West Essex County." The area is primarily residential. With the exception of the Caldwells and parts of Cedar Grove, penetration by industry has been minimal.
Montclair, the headquarters of the consolidating
bank and the hub of its system of branches, is
located 14 miles west of New York City. It has an
estimated population of 44,700. At one time, Montclair was considered one of the most affluent sections of the State and Nation. Presently, while it
does not enjoy a reputation as the redoubtable
bastion of the privileged class, as it did in the
1930's, it remains an affluent commuter community
for executives and professionals working in New
York and Newark.
Both the merging and the consolidating banks
face aggressive competition in their respective
market areas. In terms of deposits, the Trust Company National Bank ranks 11th, and Montclair
17 th, of the 88 commercial banks in the First
Banking District. The resulting bank will rank
ninth. Both banks are considerably smaller than
their larger competitors. Additional competition
is provided by six savings banks with 31 offices in
Essex and Morris counties and 55 savings and loan
associations with offices in the two counties. Competition for savings deposits and mortgage business
is extremely strong with those institutions.
The consolidating bank has experienced particularly strong competition from the State's three
largest commercial banks, and from the largest savings bank, all of which have head offices in Newark.
At present, the four municipalities in which Montclair has offices are also served by at least one of the
largest banks, each of which is over four times
Montclair's size. Last year's amendments to New
Jersey's branch banking law have intensified this
competition through new branch approvals, merg-

ers, and holding company formations. The increased competition has contributed to the $4 million shrinkage in Montclair's deposits in the last
calendar year.
Competition between Trust Company National
Bank and the Montclair National Bank is insignificant as, historically, each of the two banks have
served only their respective counties. Under the revised branch banking and merger laws that were
recently enacted, the opportunities for de novo
branching by the Trust Company National Bank
and the Montclair National Bank in either Essex
County or Morris County are slim. There is at least
one banking office in each of the 39 municipalities
in Morris County, and the Trust Company National Bank has offices in 11. Nine of these municipalities have head office protection, 20 have populations of under 7,500, thereby providing branch
office protection, and the remaining 10 are presently the sites of 30 banking offices. In the 22
towns in Essex County, there is at least one banking
office in each town, and Montclair National Bank
has offices in 4. Eleven of the towns have head office
protection and four towns have populations of
under 7,500, including one town which does not
permit any property to be zoned for business. In
the seven remaining towns, there are presently 25
banking offices. Neither the Trust Company National Bank nor Montclair National Bank has expressed any interest in applying for branches in
any of those communities in Essex County as they
already appear to be heavily banked by offices of
some of the largest banks in the State. The cost
of starting a new office and competing effectively
under these circumstances would be prohibitive.
Consolidation of the subject banks will inure to
the benefit of the residents of Essex County. Essex
County, which is presently served by Montclair
National Bank, will have the facilities and services
of a larger, more aggressive institution. Services
presently offered by one or the other of the consolidating banks, together with certain services not
now offered, will become available to all of the




customers and prospective customers of the resulting bank.
The consolidation, with resulting increased lending limit, will enable the resulting bank to compete
more effectively with the larger banks in northern
New Jersey and with the New York City banks
that actively solicit new business throughout the
service areas of the consolidating banks. As population and industrial growth in the First Banking
District continues, it will be necessary for the subject banks to accommodate to this development.
The resulting bank, through a larger lending limit,
will be able to retain the subject banks' business,
and compete effectively for new business as it develops.
Applying the statutory criteria to the proposed
consolidation we conclude that it is in the public
interest and the application is, therefore, approved.
JUNE 8,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Montclair Bank could be considered a likely
potential entrant into Morris County. By entering
the county through consolidation with Trust Company, it will add its resources to the county leader,
controlling about 33 percent of county commercial
bank deposits. However, while Montclair Bank is
a substantial bank, apparently able to effect entry
into Morris County de novo or through merger
with a smaller bank in the county, it is not among
the larger potential entrants. Each of the three
large Newark banks, as well as those described
above headquartered in Passaic, Bergen, and Hudson counties, could enter Morris County. Several
have received permission to open de novo branch
offices therein.
Each of the consolidating banks is not among
the very largest potential entrants into the primary
service area of the other. However, Trust Company's dominant position in Morris County and
the close proximity of the service areas of the banks
indicate that the proposed consolidation may have
some adverse effect on potential competition.

101

FIRST COUNTY NATIONAL BANK AND TRUST COMPANY, WOODBURY, WOODBURY, N.J., AND
THE FIRST NATIONAL BANK AND TRUST COMPANY OF PAULSBORO, PAULSBORO, N J., AND
PITMAN NATIONAL BANK AND TRUST COMPANY, PITMAN, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Pitman National Bank and Trust Company, Pitman, N J . (8500), with
The First National Bank and Trust Company of Paulsboro, Paulsboro, N J .
(5981), with
and First County National Bank and Trust Company, Woodbury, Woodbury,
N J . (1199), which had
merged July 17, 1970, under charter of the latter bank (1199) and title "National
Bank and Trust Company of Gloucester County." The merged bank at date of
merger had

COMPTROLLER S DECISION

On December 29, 1969, Pitman National Bank
and Trust Company, Pitman, N.J., and The First
National Bank and Trust Company of Paulsboro,
Paulsboro, N J . applied to the Office of the Comptroller of the Currency to merge into First County
National Bank and Trust Company, Woodbury,
Woodbury, N.J., under the charter of the latter and
with the title "National Bank and Trust Company
of Gloucester County."
Gloucester County, home of the subject banks,
has a population of 167,200, reflecting a 25 percent
increase during the past 9 years. It is situated along
the eastern shore of the Delaware River, immediately south of Camden County, and convenient to
the cities of Philadelphia and Camden. This area,
which is included in the Third Banking District of
New Jersey, has experienced tremendous growth in
the past decade, and there is every indication that
similar growth will occur in the present decade.
Although 40 percent of the county's land area is
devoted to agriculture, manufacturing and petroleum refining are both important contributors to
the economy. There is light and heavy manufacturing as well as food processing and packaging in this
highly productive agricultural area. Numerous retail shopping centers dot the area. Most of the
population and nonagricultural economic activity
is concentrated in the western sector of the county.
Woodbury, with an estimated population of
13,700, is the seat of Gloucester County. It is
situated in the northern part of the county, 7 miles
southwest of Camden. Because of its proximity to
Camden and Philadelphia, Woodbury is a "bedroom" community for many people employed in
those two cities.
102




To be
operated

$15,748,018
24,218,387
40,681,659
80,777,366

11

The First County National Bank and Trust Company, Woodbury, which has IPC deposits of $29
million, was organized as the Gloucester County
Bank in 1855. Its present corporate title was
adopted in 1960. The bank operates two in-town
offices and three out-of-town branches, all within
4 miles of Woodbury. The out-of-town offices are
located in the communities of National Park,
Woodbury Heights, and Deptford.
Paulsboro, with an estimated population of 8,900,
is located on the Delaware River about 12 miles
southwest of Camden, and 5 miles west of Woodbury.
The First National Bank and Trust Company of
Paulsboro, with IPC deposits of $17.3 million, was
organized in 1901. Besides two offices in Paulsboro,
this bank operates three out-of-town branches
within 3 miles of Paulsboro, in the communities
of Gibbstown, West Deptford, and Mulleton.
Pitman, which has an estimated population of
9,700, is primarily a residential community. It is
situated 8 miles south of Woodbury and 9 miles
southeast of Paulsboro. The Pitman National Bank
and Trust Company, with IPC deposits of $14 million, was organized in 1907, and operates as a unit
bank.
The Woodbury bank branch closest to any office
of the Paulsboro bank is its Woodbury Heights
branch, which is about 3 miles east of the latter
bank's West Deptford Township branch. Those
branches are also the closest to an office of the
Pitman bank, as they are 7 miles north and 8 miles
northwest respectively. There is no substantial
competition between these offices. Moreover, there
are several offices of other banks located between
Woodbury and Pitman.

The potential for increased competition among
the three banks in the foreseeable future appears
remote since New Jersey statutes prohibit de novo
branching in communities where the head office
of a bank is already situated, and in towns with
a population of 7,500 or less where a branch already
exists. Consummation of the merger will increase
competition as it will eliminate head office protection for Paulsboro and open it up for de novo
branches.
The First County National Bank and Trust
Company, Woodbury, competes with the Woodbury offices of Peoples National Bank of New Jersey, which has deposits of $81 million, and the
Deptford Township branch of Colonial National
Bank, Haddonfield, which has deposits of $113
million. The First National Bank and Trust Company of Paulsboro's West Deptford Township
branch competes with a branch of South Jersey
National Bank, Camden, which has deposits of
$227 million. The Pitman National Bank and
Trust Company is in direct competition with
Broadway National Bank and Trust Company of
Pitman, which plans to merge with Peoples National Bank of New Jersey, Westmont.
Upon consummation of the merger there will be
13 banks with deposits ranging from $4 million to
$254 million serving the northern half of Gloucester County and a small segment of Camden County.
The four banks in Camden County with which the
$60 million resulting bank will be better able to
compete have deposits of $81 million, $113 million,
$227 million, and $254 million.
Although the Woodbury bank is presently the
largest of 13 banks with head offices in Gloucester
County, it is only the 15th largest of 75 commercial
banks in the Third Banking District of New Jersey.
The Paulsboro bank is the third largest in Gloucester County and 29th largest in the Third Banking
District. The Pitman Bank is sixth and 43rd largest,
respectively. The resulting bank will hold 3 percent
of the deposits, and rank ninth in the Third Banking Region.
Philadelphia banks, through advertisements and
because many residents are employed in the city,
offer banking alternatives to customers in the area
of the subject banks. In addition, a number of
savings and loan associations, insurance companies,
credit unions, and sales finance and personal loan
companies are active in the relevant market area.
The resulting bank will provide imposed services
for its customers including a larger lending limit,




automated deposit bookkeeping, and improved
trust department facilities. The merger will also
alleviate management succession problems by providing an earnings potential which will enable it
to attract and train young and competent management. This merger, in keeping with current economic thinking, will develop a locally-oriented
bank in Gloucester County capable of serving
county residents, and with sufficient clout to compete effectively with out-of-county competitors.
Applying the statutory criteria to this application, it is found to be in the public interest. The
application, therefore, is approved.
MAY 22, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Pitman Bank's service area is centered about the
town of Pitman, and its sole office is about 7 miles
from the nearest offices of the other two merging
banks. A number of offices, present and proposed,
of competing banks lie in the intervening area. It
would appear that only a limited amount of direct
competition exists between Pitman Bank and the
other two merging banks; this competition will, of
course, be eliminated if the proposed merger is
approved.
A more substantial amount of direct competition
exists between Woodbury Bank and Paulsboro
Bank. While the areas in which the offices of these
two banks are located may be more accurately
described as adjacent rather than coextensive, it is
clear that a good deal of overlap in service area
exists, particularly in West Deptford Township,
between Woodbury and Paulsboro. Woodbury
Bank's Woodbury Heights branch is located only
2.1 miles from the West Deptford branch of Paulsboro Bank.
The elimination of competition between Woodbury Bank and Paulsboro Bank is aggravated by the
lack of competitive alternatives in the vicinity of
Paulsboro. Paulsboro Bank is the only bank located
in Paulsboro and the immediately surrounding
areas. The closest alternatives are in the WoodburyWoodbury Heights area, and include Woodbury
Bank. Other alternatives in this immediate area
include the $125 million Colonial National Bank
(through its merger with The First National Bank
of Westville), the $125 million Peoples National
Bank of New Jersey (through its merger with
Farmers and Mechanics National Bank), and a
branch of The National Bank of Mantua.
According to the application, additional com103

petition will be afforded by new branches of the
$300 million Bank of New Jersey and the $270
million South Jersey National Bank, as well as by
two newly chartered banks.
The proposed merger will eliminate home office
protection in Paulsboro.
As of June 30, 1968, Woodbury Bank, Paulsboro
Bank, and Pitman Bank held the first, third and
fifth largest shares of total deposits held by banks
with offices in Gloucester County (16.2 percent,
11.5 percent and 8.6 percent, respectively). Their
combined market share would have been over 36
percent. Gloucester County may understate the
relevant market, however, as large banks headquartered in adjacent sections of Camden County,
including the city of Camden, draw some amount
of deposits and loans from the areas served by
the merging banks. Banks located in Philadelphia

may also compete to some extent, particularly for
the business of commuters.
In a greater Camden market, encompassing the
northern sections of Camden and Gloucester counties (which, in view of the proximity of Woodbury
Bank and Paulsboro Bank, may overstate the relevant market) the shares of Woodbury Bank and
Paulsboro Bank total approximately 6 percent.
Although larger banks based in Camden County
are increasing their competitive presence in the
areas served by the merging banks, Woodbury
Bank and Paulsboro Bank in particular hold large
shares of deposits therein and, absent this proposed
merger, would probably continue as capable independent retail banking alternatives. We conclude
that the overall competitive effect of their merger
with one another and with Pitman Bank would
be adverse.

T H E FARMERS NATIONAL BANK OF SALEM, SALEM, OHIO, AND CITIZENS SAVINGS BANK, GOLUMBIANA, OHIO
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The Citizens Savings Bank, Columbiana, Ohio, with
and The Farmers National Bank of Salem, Salem, Ohio (973), which had
merged July 17, 1970, under charter and title of the latter bank (973). The
merged bank at date of merger had

COMPTROLLER S DECISION

On March 24, 1970, The Farmers National Bank
of Salem, Salem, Ohio, with deposits of $35.3 million, and the Citizens Savings Bank, Columbiana,
Ohio, with deposits of $10.7 million, applied to
the Office of the Comptroller of the Currency to
merge under the charter and with the title of the
former.
The Farmers National Bank of Salem, headquartered in Salem, Ohio, has IPC deposits of $33
million. The bank was organized as a State institution in 1846, and obtained a National charter in
1865. The bank presently operates two branches in
Salem and one branch in each of the nearby towns
of Lisbon and Hanoverton. While the primary
service area of the charter bank is Columbiana
County, the total market area also includes portions
of Mahoning, Stark, and Carroll counties.
Salem, with a population of approximately
104




$11,094,201
37,561,201
48,655,402

2
5

7

14,300, is the largest urban area in Columbiana
County. The county is situated in northeastern
Ohio, and Salem is located in the northern part
of the county 20 miles east of Canton, Ohio, 21
miles southwest of Youngstown, Ohio, and 62 miles
northwest of Pittsburgh, Pa. A strong manufacturing base has developed around Salem with such
industrial concerns as Crane Company (Demming
Division), L. W. Bliss Company, Electric Furnace
Company, Mullins Manufacturing Corp., Warren
Molded Plastics, Inc., Quaker Manufacturing Corp.,
Quaker Tool and Die, Inc., United Tool and Die,
Inc., Wallace-Murray Corp., (Eljer Division),
Salem Tool Co., and Sekely Industrial Tool and
Manufacturing Inc., as important employers. The
agricultural areas of the county are found in the
northern and western parts, with dairy farming,
livestock, and fruit production making substantial
contributions to the economy.

The Citizens Savings Bank was organized in 1923,
and is headquartered in Columbiana, Ohio, 10
miles east of Salem. The bank operates a branch
at Leetonia. Its total IPC deposits for both offices
is near $10.1 million.
Columbiana is a small, agricultural town of
4,600 in the northern portion of Columbiana
County. Economic activity centers on fruit production and dairy farming. There are a number of
established industries which employ about 1,500
people and lend economic stability to the community. The prospects for growth in this area appear favorable.
The proposed merger will not adversely affect the
banking structure in the resulting bank's service
area. Eighteen banks, excluding the participants,
serve the market area in question. Eleven of the
20 banks now serving Columbiana County are
headquartered in the county, and nine banks headquartered in other counties also service the market
area through 16 branch offices. Deposits of all the
commercial banks, including the participating
banks, total over $644 million. The charter bank
holds $35.3 million of this total, and upon consummation of the merger, the resulting bank's
deposits will measure only $46.1 million. In addition to the 18 other commercial banks operating
in the broad market area, the resulting bank will
compete with 11 savings and loan associations, 2
insurance companies, 20 credit unions, 4 sales
finance companies, and 14 personal loan organizations. Consequently, the resulting institution will
not dominate the area's financial structure.
Approval of the proposed merger will not eliminate a significant degree of competition between
the participating banks. While the participating
banks' main offices are approximately 10 miles
apart, the head offices of three other banks are
located in Salem, Columbiana, and Lisbon, and
they all compete directly with the applicant banks.
Several other banks, including The Union National
Bank of Youngstown, with total assets of $142 million; the First National Bank of Canton, with a
branch at Minerva, and total assets of $160 million; and The Mahoning National Bank of Youngstown, with total assets of about $140 million, all
have branch offices within 15 miles of the applicants.
The benefits accruing to the public will outweigh any anticompetitive aspects resulting from
this merger. The market area's future banking




needs will be better served by one large bank with
multiple services than by two smaller banks with
fewer services. The resulting institution will be
sufficiently large to install or lease computer facilities for its own use and the use of its customers.
The larger lending limit will enable the resulting
bank to fulfill the credit needs of the local manufacturing concerns, and to better meet the competition of the larger banks in the area. Specialized
banking services, such as agricultural loans, student
loans, bank credit card services, and increased instalment lending services will become available to
the customers in the immediate trade area of The
Citizens Savings Bank. In addition, approval of this
merger will assure management continuity, which
is presently unavailable to the merging bank.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest,
and the application, therefore, is approved.
JUNE 11,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The Leetonia branch of Citizens Savings is
located only 7 miles from Farmers National's East
Side branch, in Salem. Although there are three
other banking offices in the intervening area, merging banks are in direct competition. For example,
Farmers National derives industrial accounts and
loans from Leetonia and Columbiana. The proposed merger, of course, would eliminate this direct
competition and would eliminate the potential for
greater competition which would occur if the
banks were to open new branches closer to each
other.
Eleven banks with 23 offices were located in
Columbiana County, as of December 31, 1969. With
about 20 percent, Farmers National held the
largest share of county total deposits of $174.6 million, and the second largest share—about 20 percent—of county total demand deposits of $64 million. Citizens Savings held the sixth largest share, or
about 6 percent, of total deposits, and the seventh
largest share, or about 5 percent, of total demand
deposits. As a result of the proposed merger, that
share of total deposits held by the county's four
largest banks would increase about 6 percent, to
approximately 71 percent, and figures for total
demand deposits show a comparable increase of
about 5 percent, to nearly 70 percent.
The proposed merger is likely to result in the
elimination of direct competition between the
105

merging institutions, increase concentration in commercial banking and eliminate Citizens Savings as
an independent competitor in an area where con-

tinued economic growth is expected. We conclude
that the proposed merger would clearly have an
adverse effect upon competition.

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

AND T H E STATE BANK OF WINGATE, WINGATE,

N.C.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The State Bank of Wingate, Wingate, N.C, with
and First National Bank of Eastern North Carolina, Jacksonville, N.C. (14676),
which had
. .
merged July 27, 1970, under charter and title of the latter bank (14676). The
merged bank at date of merger had. .

COMPTROLLER S DECISION

On February 9, 1970, The State Bank of Wingate, Wingate, N.C, and First National Bank of
Eastern North Carolina, Jacksonville, N.C, applied
to the Comptroller of the Currency for permission
to merge under the charter and with the title of
the latter.
The First National Bank of Eastern North Carolina, with I.P.C deposits of $69.7 million, was established in 1952, and presently operates through
its main office, 27 branch offices, and one facility.
The bank operates in 15 counties, 13 in the eastern
portion of the State, surrounding its home county
of Onslow, and in the two western counties of
Watunga and Henderson. Until 1959, the bank
confined its activities to the city of Jacksonville,
and operated as a unit bank. Since that time, the
bank has been involved in four acquisitions, the
largest of these being the merger of the Bank of
Lillington, in 1967, with slightly more than $3
million in deposits. Primary expansion, however,
has been through de novo branching. In its home
city of Jacksonville, the charter bank competes
vigorously with six branches of the $590 million
deposit Citizens Bank and Trust Company.
Through its other branches, the bank also competes with a branch of the $402 million Northwestern Bank, in Boone; with branches of the $1.1
billion North Carolina National Bank and the $1.1
billion Wachovia Bank and Trust Company N.A.,
in Wilmington; and with a branch of the $827
million deposit First Union National Bank, in
Hendersonville.
The economy of the merging bank's home office




To be
operated

$3,046,720

2

105,073,518

32

108,120,239

34

territory, Jacksonville, is largely dependent upon
agriculture, tobacco is the leading money crop, and
upon large military installations located nearby.
Camp Lejeune, for example, covers 111,000 acres
in the county, and carries an annual payroll in
excess of $200 million. Some industry has moved
into the area in recent years and aggressive efforts
are being made to attract new industry, particularly
in light of the decline in tobacco production in
recent years.
The State Bank of Wingate, which was organized
in October 1909, presently holds IPC deposits of
approximately $2 million, and operates through
its main office and one branch, both of which are
located in the rural community of Wingate. The
bank has experienced only nominal growth
throughout its long history, as is evidenced by its
present size. Because of this, it has not been in a
position to adequately respond to the financial
needs within its service area. It has lost its most
capable young officer, leaving only the president
to manage the bank's affairs, and now the merging
bank faces a serious management succession problem. Primary competition for the bank derives
from the $50 million deposit American Bank and
Trust Company, headquartered in Monroe, N.C,
3 miles from Wingate, and the $42 million deposit
Security Bank and Trust Company in Union
County, with two branches in Monroe. In addition,
the $1.1 billion deposit North Carolina National
Bank has an approved but unopened branch in
Monroe. Competition, particularly for the larger
lines of credit in the merging bank's service area,
also derives from large banks either headquartered
or located in Charlotte.

Wingate, which is in Union County, had a 1960
population of approximately 1,300. The town is
located 35 miles southeast of Charlotte, the largest
city in the Carolinas, and 3 miles east of Monroe,
which has a population of 12,000. Economic activity
in the immediate area of Wingate is primarily dependent upon an industrial park situated approximately halfway between Wingate and Monroe,
which employs over 5,000 persons. Wingate College, with a present enrollment of 1,600 students,
is also an important contributor to the local economy. Union County, which is considered to be
within the bank's primary service area, has shown
a steady growth in population to an estimated
51,000, today. The proportion of the county's
labor force employed in agriculture has dropped
from 71.5 percent in 1930, to 11.7 percent, in 1960.
In recent years, because of its easy accessibility to
Charlotte, the county has become a "bedroom"
community for that city. Indeed, one-third of the
labor force worked outside of the city in 1960,
and it is estimated that the figure is even higher
today. In 1967, there were 412 employers in Union
County, employing some 10,000 people, and total
county employment increased over 30 percent from
1962 to 1967. Future growth trends for this area
are expected to be good.
Consummation of this merger will eliminate no
existing competition between the two banks. There
is presently no competition between the two banks
in each other's service area for either customers or
business. The closest offices of the two banks are
140 miles apart. Entrance of charter bank into the
merging bank's service area will provide a more
aggressive competitor to banks already located in,

or entering, the county, and will replace a relatively
ineffectual bank. The Wingate Bank, because of its
location within Union County, its proximity to a
large industrial park, and the accessibility to Charlotte, can become, as a result of this merger, a much
more effective competitor throughout the county.
In addition, entrance of charter bank into this
market area will provide the customers of The
State Bank of Wingate with additional banking
services such as an increased lending limit, trust
services, overdraft banking, specialized loan services,
FHA and VA loans, and credit card services. In addition, the capable and qualified management team
of charter bank will be available to the customers
of merging bank.
It is concluded that this merger will have no adverse competitive effect and is in the public interest.
The application, therefore, is approved.
JUNE 26, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

First National operates throughout eastern North
Carolina and in two counties in the western part
of the State. Wingate Bank's two offices are in
south central North Carolina, more than 100 miles
from the nearest existing office of First National.
Thus, the merger would not eliminate any significant direct competition.
First National has applied for approval to open
a de novo office in Monroe, about 3 miles from
Wingate Bank. Thus, the merger would eliminate
potential competition between the two banks. In
view of Wingate Bank's small size and the number
of banking alternatives in the area, however, this
loss of potential competition is not significant.

FIRST & MERCHANTS NATIONAL BANK, RICHMOND, V A . , AND SUBURBAN NATIONAL BANK OF VIRGINIA, ( M C L E A N P.O.),
FAIRFAX COUNTY, V A .
Banking offices
Name of bank and type of transaction

Total assets
In

operation
Suburban National Bank of Virginia, Fairfax County (P.O. McLean), Va.
(14965) with
and First & Merchants National Bank, Richmond, Va. (1111), which had
merged July 31, 1970, under charter and title of the latter bank (1111). The
merged bank at date of merger had




$49,353 ,508
769,096 ,943
816,282 ,176

To be
operated

9
54
63

107

COMPTROLLER'S DECISION

On March 31, 1970, the Suburban National Bank
of Virginia, (McLean P.O.), Fairfax County, Va.,
and the First & Merchants National Bank, Richmond, Va., applied to the Office of the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
The charter bank, with IPC deposits of $519 million, was originally organized in 1865, and presently
operates 56 branch offices. Its principal area of
operation is the Richmond Metropolitan Area
where it has 22 offices. It also operates offices in
the communities of Newport News, Staunton,
Lynchburg, Waynesboro, Norfolk, Portsmouth,
Virginia Beach, and Chesapeake. It has a facility
in the Pentagon where the merging bank operates
a branch office, and an office at Dulles International
Airport. The bank ranks second in size among all
commercial banks in Virginia, and third among all
the financial institutions. In its area, the bank
faces competition from virtually every major bank
and bank holding company in the State and derives some competition from the larger banks in
nearby Maryland and the District of Columbia.
The bank is wholly-owned by the First and Merchants Corporation, a one-bank holding company.
The merging bank, headquartered in Fairfax
County, with McLean as its post office address,
has IPC deposits of $37 million, and presently
operates two branch offices in Fairfax County and
three in Arlington County. It has received approval
for three additional branches. The bank has not
kept pace with the rapid growth of its area, and has
a poor earnings record. The bank is not a strong
competitor in its area, and lacks the management
depth necessary for future growth.
The service area of the merging bank encompasses the counties of Arlington and Fairfax and
the independent cities of Alexandria, Falls Church,
and Fairfax. This northern Virginia area, with an
estimated population of 800,000, is part of the
Washington, D.C., Standard Metropolitan Statistical Area, the fastest growing metropolitan area in
the country. The area is characterized by high educational and income levels and a mobile cosmopolitan population. It is a burgeoning center of research and development and other technically
oriented light industries. Largely responsible for
the population gravitation to this area and its development has been the rapid economic growth and
the increasing influence of Washington, D.C., since
World War II.
108




Arlington County, which was just a "bedroom"
community for Washington, presently enjoys an
estimated population of 200,000, and has experienced a significant economic development. Fairfax
County's population has grown from 262,000, in
1960, to a present population of 455,000, and the
county has become a focal point for development.
Practically all of the Arlington-based banks have
changed their headquarters to Fairfax County so
that, under the Virginia branching laws, they could
take full advantage of this new growth area. The
cities of Alexandria and Falls Church are fully developed land extensions of Arlington and Fairfax
counties. As indicated, the merging bank has not
been able to keep pace with the rapid economic
growth of its area and, as a result, is not able to
adequately serve the area's rapidly expanding
needs.
Banking competition in the area of the merging
banks is provided by 23 banks, operating 171 offices,
with aggregate deposits of approximately $1 billion.
Six of the eight statewide banking organizations
now compete vigorously in the area. The largest
bank in the State, Virginia National Bank, with
deposits of $700 million, presently operates 11 offices in the area. Banking competition is also provided by the large banks in nearby Washington,
D.C., and Maryland.
The only competition existing between the participating banks is between their offices in the
Pentagon. If this merger is approved, the office of
the charter bank will be consolidated with the
branch of the merging bank. The next closest office
of the charter bank to the merging bank is at Dulles
International Airport, about 10 miles to the west
of Suburban National Bank's westernmost office.
That office is relatively isolated and exerts no competitive influence on the northern Virginia area.
This merger will not eliminate potential competition between the participating banks because,
under the branching laws of Virginia, the banks
are not permitted to branch into the areas of the
other.
Consummation of the proposed merger will have
no significant effect on concentration of banking
resources in Virginia. First and Merchants National
Bank's share of 9.5 percent of the total commercial
bank deposits in the State will be increased by
only 0.6 percent, Suburban National Bank's share
of total State deposits. The effect of this merger
will be in the northern Virginia area served by
the merging bank, where it will introduce a more

competitive institution better able to meet the increasing needs of this rapidly growing area. This
merger will also solve the management problem
at the merging bank.
Considered in the light of the statutory criteria,
this merger is deemed to be in the public interest.
The application is, therefore, approved.
JUNE 23, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest branches of First & Merchants are
located in the Leesburg and Dulles Airport areas
of Loudoun County, approximately 15 miles from
Suburban National's Vienna branches. However,
First & Merchants does operate a restricted-service
banking facility in the Pentagon, in direct competition with Surbuban National's Pentagon
branch, as deposit and loan account overlaps indicate. The proposed merger, of course, would eliminate this competition.
Five of the six largest banking organizations in
Virginia have branches or affiliates in all the principal jurisdictions in Northern Virginia: Fairfax and
Arlington counties, and the city of Alexandria.
First & Merchants, the State's third largest bank-

ing organization, has no branch in any of these
jurisdictions, with the exceptions of their Pentagon
facility. Hence First & Merchants is a potential
entrant into this area.
However, under Virginia law, First & Merchants,
as presently organized as one-bank holding company, is precluded from establishing de novo
branches in any of these Northern Virginia jurisdictions, and can enter only via merger.
Suburban National is the sixth largest of 23 commercial banks in Northern Virginia, and has six
of the area's 178 approved banking offices. Three
banking organizations, including the largest and
sixth largest in the State, operate banking offices
in all Northern Virginia jurisdictions, and hold
about 63 percent of area total deposits of $1.4 billion. Those organizations control about one-third
of the total number of area banking offices. Suburban National has about 4 percent of area total deposits. However, in view of the fact that Suburban's
offices are located only in north-central Fairfax and
Arlington counties, this percentage may understate
its relative market position. Suburban had 3.8 percent of total Arlington County deposits as of June
29, 1968, and 7.8 percent of total Fairfax County
deposits as of that date.

LINCOLN NATIONAL BANK AND TRUST COMPANY OF CENTRAL N E W YORK, SYRACUSE, N.Y., AND
THE NATIONAL EXCHANGE BANK OF BOONVILLE, BOONVILLE, N.Y.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The National Exchange Bank of Boonville, Boonville, N.Y. (8022), with
and Lincoln National Bank and Trust Company of Central New York, Syracuse,
N.Y. (15627), which had
merged July 31, 1970, under charter and title of the latter bank (15627). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 15, 1970, The National Exchange Bank
of Boonville, Boonville, N.Y., and the Lincoln National Bank and Trust Company of Central New
York, Syracuse, N.W., applied to the Office of the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
The charter bank, with IPC deposits of $175 million, was originally organized in 1929, and presently




$6,069,082

1

243,069,535

18

249,138,617

19

operates 16 branch offices in the Sixth Banking
District. Nine of its offices are located in Onondaga
County, two in Cayuga County, three in Oswego
County, one in Seneca County, and one in Madison
County. The bank ranks fourth in size among the
25 commercial banks in the district, and holds
about 13 percent of all the commercial bank deposits. It is a wholly-owned subsidiary of the Lincoln First Banks, Inc., Rochester, N.Y., a registered
bank holding company.
109

The primary service area of the charter bank is
Onondaga County, which is virtually coterminous
with the Syracuse Metropolitan Area. That area,
with an estimated 1960 population of 423,028,
presently enjoys a well diversified and thriving
economy. There are about 41 manufacturing concerns and over 500 industrial firms in the area that
together employ an estimated 160,000 civilian residents. The city of Syracuse is the hub of financial
and business activities for the whole area, and is
the home of Syracuse University, with a student
enrollment of 17,000, and three other colleges.
The merging bank, with IPC deposits of $5 million, was organized in 1905. It is the smallest bank
in its service area and, with about 0.3 percent of
all the commercial bank deposits, ranks fourth
smallest of the 25 banks in the Sixth Banking
District. The bank provides limited banking services to its customers, and is presently faced with
a management succession problem. It faces strong
banking competition from the seven banks operating in Oneida County and two banks located in
Lewis County, including a branch office of the
largest bank in the district, the Oneida National
Bank and Trust Company of Central New York,
which is located almost directly across the street
from the merging bank. Competition for the savings dollar is also provided by three savings banks,
three savings and loan associations, and five credit
unions operating in Oneida County.
The service area of the merging bank extends
from the town of Boonville, where the bank is
located, approximately 7 miles to the north and
west, and approximately 15 miles to the south and
east. The economy of this area consists of farming,
furniture manufacturing, lumber products, recreational facilities, and milk processing. Oneida
County, where Boonville is located, was third
among the 128 counties in New York and New
Jersey in the production of milk during 1968. In
the past decade, the Boonville area has become a
major recreation center, with significant effects on
real estate investments in the area.
There is no competition presently existing between the participating banks to be eliminated by

110




consummation of this merger. The closest office of
the charter bank to the merging bank is the Oneida
office, Madison County, about 40 miles away, which
is further separated by hilly terrain and indirect
highway connections. This merger will not eliminate potential competition between the two institutions because of the size of the merging bank
and the home office protection under the New York
State law.
The addition of $5 million in deposits to the
charter bank will have no significant effect on concentration of banking resources in the Sixth Banking District. On the other hand, this merger will
benefit the Boonville area by introducing a bank
offering full banking services and better able to
meet the needs of the area. This merger will also
solve the management succession problem at the
merging bank.
Considered in the light of the statutory criteria,
this merger is deemed in the public interest. The
application is, therefore, approved.
JUNE 22,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are
almost 40 miles apart. This distance, the presence
of other banks in the intervening area, and the
limited scope of National Exchange's operations,
indicate that there is little existing competition
between the merging banks. It may be noted that
the only other commercial bank in Boonville is
Oneida National Bank and Trust Co. of Central
New York (total deposits $267 million).
Under New York State law, with certain exceptions for the New York City area not applicable
here, a bank may branch de novo, subject to home
office protection, anywhere within the banking
district in which it is headquartered. Because of
home office protection, Lincoln National may not
establish a de novo branch in Boonville. While
Lincoln First Banks could be permitted to charter
a new bank in that town, the size of the community
and of National Exchange make it unlikely that
the proposed merger will have a significantly adverse effect on potential competition.

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

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of Sacramento, Sacramento, Calif., with
and Security Pacific National Bank, Los Angeles, Calif. (2491), which had
merged July 31, 1970, under charter and title of the latter bank (2491). The
merged bank at date of merger had

COMPTROLLER S DECISION

On February 20, 1970, the Bank of Sacramento,
Sacramento, Calif., and the Security Pacific National Bank, Los Angeles, Calif., applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the
title of the latter.
The Security Pacific National Bank, with IPC
deposits of $5 billion, is the second largest bank
in California, but is far smaller than the Bank of
America, which has deposits of $18 billion. This
bank serves predominately the southern portion of
the State; of its 395 branch offices, all except 12
are located in Southern California. The bank desires to expand its services in the north and into the
Sacramento Valley through this merger.
The Bank of Sacramento, with IPC deposits of
$28 million, was organized in 1962, and presently
operates four branch offices, two in Sacramento,
one in Davis, which is about 16 miles to the west
of the head office, and one in the suburban community of Rancho Cordova, which is about 14
miles to the east of Sacramento. Although the
bank is located in a vast agricultural area, it has
not significantly served the agricultural community.
Its lending capabilities preclude the bank from
making large agricultural and commercial loans
which are increasingly demanded by the agricultural and business communities. The bank is not
able to offer to its business customers computer
services, and it does not have a revolving credit
or credit card plan for individual depositors. It
presently lacks management depth, and fears it
will not be able to compete in the highly competitive market for management talent. While the bank
has shown satisfactory growth, it feels that its
future possibilities are limited because of the intense banking competition in its area.
The general market area of the merging bank
is the Sacramento Standard Metropolitan Statistical
Area, which includes the counties of Sacramento,




$42,497,359
6,722,389,757
6,758,034,271

To be
operated

5
408
413

Yale, and Placer. The city of Sacramento, with a
population of about 272,000, is the capital of the
State, and the focal point of the entire Sacramento
Valley, one of California's important agricultural
regions, which encompasses the nine counties of
Sacramento, Yale, Placer, Colusa, Sutter, Yuba,
Glenn, Butte, and Tehama. In 1968, the Valley
accounted for approximately one-eighth of the agricultural production of the State. Sacramento is
about 87 miles east of San Francisco, and about
390 miles north of Los Angeles. Although primarily
residential, it provides a large base of civil servant
employment, and is a retail trade center for the
entire valley. There are over 400 manufacturing
establishments in Sacramento County alone, of
which the Aerojet General Corporation is the
largest, with 7,500 employees. Public payrolls in
the county provide jobs for approximately 90,000
individuals, and several large military bases provide
25,000 civilian jobs.
There are, in the Sacramento Standard Metropolitan Statistical Area, 18 banks operating 126
banking offices with total aggregate deposits of $1.4
billion. Those banks include Bank of America, with
50 offices; Crocker-Citizens, with 22 offices; Wells
Fargo Bank, with 21 offices; Bank of California,
with 5 offices; and United California Bank, with 4
offices; all of which together represent 88.7 percent
of the total bank deposits in the area. Bank of
Sacramento's share of the total bank deposits is 2.4
percent, and if the savings accounts, totalling $450
million, of the 12 savings and loan associations in
the area are included, the bank's share of the
market is only 1.9 percent. In addition, there are
88 offices of consumer finance companies, 70 credit
unions, several insurance companies, and various
other lending institutions.
There is presently no significant competition
existing between the participating banks. The
closest office of the charter bank to the merging
bank is located in Stockton, about 45 miles south
111

of Sacramento. Security Pacific National Bank estimates that less than 0.01 percent of its deposits derive from the Sacramento area, and the Bank of
Sacramento estimates that less than 0.5 percent of
its deposits derive from the service area of the
charter bank. However, Security Pacific National
Bank has received approval for a branch in Sacramento which is expected to reach $14.3 million in
deposits in its fifth year. Since this will represent
only about 1.7 percent of total bank deposits in the
metropolitan area, it is clear that the bank can not
hope to become a significant competitive force for
several years. Expansion into this area, far removed
from the head office, through de novo branching
would be difficult and expensive. This merger will
provide the needed deposit base and some of the
trained personnel needed to enable the charter
bank to become a significant competitor, in the
area, from the time of its entry. As the area is predominately agricultural, it will benefit from
the Security Pacific National Bank's experience and
expertise in the field of agricultural loans. The
bank is now engaged in the development of a highly
sophisticated data processing service for its farm
customers that will provide the bank and its customers with current and accurate financial information, a tool for planning and making future agricultural decisions and for increasing efficiency.
The effect of consummation of the proposed
transaction on the overall competitive structure in
the Sacramento SMSA will be to enhance competition by replacing a small and not vigorous competitor with a full-service institution, able to compete
effectively with the large banks operating in the
area. There will be definite competitive advantages
especially in the field of agricultural loans. The
public interest will be served further because the
offices of the Bank of Sacramento will be developed
to provide full banking services.
Considered in the light of the statutory criteria,
this merger is deemed to be in the public interest.
The application is, therefore, approved.
JUNE 8,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Security has no offices at present in the Sacramento area; its main office and branches in the
San Francisco Bay area are some 87 miles away.
Its office nearest to Sacramento is in the city of
Stockton, 48 miles to the south, in the San Joaquin
Valley. The amounts of business derived by the
112




applicants from each other's areas are negligible;
the respective areas are also served by a number of
other large California banking institutions. Thus,
from an immediate standpoint, the amount of
direct competition that will be eliminated by the
proposed merger appears insignificant.
Security, however, has previously applied for, and
received approval to open a de novo branch in the
new Capital Mall section of Sacramento, a major
redevelopment project in the downtown area, six
blocks from Sacramento Bank's head office. This
new branch will be placed into operation regardless of whether or not the proposed merger is approved. Thus, while not yet measurable in statistical terms, Security is an imminent direct competitor in the Sacramento banking market; the proposed merger will necessarily eliminate that competition.
Banking in Sacramento is highly concentrated;
the five largest banks in the area, all of which are
major California branch networks, currently hold
88.7 percent of total commercial bank deposits in
the Sacremento Standard Metropolitan Statistical
Area ("SMSA").
Security, as noted, is already an imminent entrant into this market. It is also the second largest
banking institution in California; presently it holds
11.3 percent of the deposits in the entire State. It
has had long experience and success in de novo
branching. The fact that it made application and
received approval for a de novo branch in downtown Sacramento is indicative that there is opportunity and need for additional banking facilities in
Sacramento.
Most importantly, several other statewide, or
regional, banking organizations which are not
presently serving the Sacramento area also have
tried to enter that market by acquiring Sacramento
Bank. Given the relatively smaller size of those
organizations, they have substantially greater need
for a foothold acquisition in order to make effective
entry into a concentrated market such as Sacramento. Sacramento Bank which has 2.4 percent of
bank deposits in the Sacramento SMSA is a very
suitable vehicle for such entry. Its acquisition by
Security, which is entering the market in any event,
has the effect of eliminating an additional new
entrant which in turn means that an additional
force for deconcentration is excluded from the
market.
This acquisition will eliminate Sacramento Bank

as a vehicle for entry by other banking organizations into an area dominated by a few major statewide branching networks. It will also eliminate

Security as a potential competitor. Therefore, the
proposed merger, in our view, will have an adverse
effect on competition.

T H E COMMERCIAL NATIONAL BANK OF KANSAS CITY, KANSAS CITY, KANS., AND
EXCHANGE STATE BANK OF KANSAS CITY, KANSAS CITY, KANS.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

Exchange State Bank of Kansas City, Kansas, Kansas City, Kans., with
and The Commercial National Bank of Kansas City, Kansas City, Kans. (6311),
which had
merged July 31, 1970, under charter of the latter bank (6311) and title "Commercial National Bank of Kansas City." The merged bank at date of merger had. .

COMPTROLLER'S DECISION

On April 1, 1970, Exchange State Bank of Kansas
City, Kansas, Kansas City, Kans., and The Commercial National Bank of Kansas City, Kansas City,
Kans., applied to the Comptroller of the Currency
for permision to merge under the charter of the
latter and with the title "Commercial National
Bank of Kansas City."
The Commercial National Bank of Kansas City,
with IPC deposits of $50.5 million, was originally
organized as a State bank in 1897. It acquired a
National charter in 1902, and has since operated
under its present name.
Exchange State Bank of Kansas City, chartered
in 1905, holds IPC deposits of $13 million. In
recent years, the merging bank'^ deposits have
shown no growth.
Both banks are located in Wyandotte County,
one of the seven counties which make up the
Kansas City, Kansas-Missouri Metropolitan Area.
The relevant market area, which is considered to be
the entire urban area, has an estimated population
of 1.4 million, supports a diversity of industries,
and is considered to be a major wholesaling, retailing, and transportation center. In contrast to the
present and projected growth of the urban complex, Wyandotte County's growth in recent years
has been slow, and its projected growth is the
lowest of the seven counties. This county, which
includes the main business district of Kansas City,
Kans., is an unattractive and declining area suffering from the effects of urban decay.
Seven banks, including the two applicants, are
located within a radius of three blocks in down-




$15,619,327

1

108,190,718

1

117,021,889

1

town Kansas City. In addition to those seven banks,
12 other banks operate in Wyandotte County. The
charter bank and Security National Bank, which
is the sixth largest bank in the Kansas City Metropolitan Area, are the two largest banks in that
county. Those two banks compete on an areawide
basis, while the other smaller banks, including the
merging bank, compete on a more localized basis.
In recent years, the center city banks have declined
in relative importance as their share of the total
bank deposits in Wyandotte and Johnson counties
has decreased from 58 percent in 1953, to 38 percent in 1969.
Competition among the 125 banks in the Kansas
City Metropolitan Area is intense. Commerce Trust
Company, Kansas City, Mo., with $554 million, or
15 percent of the total deposits, is the largest institution. First National Bank of Kansas City, Kansas
City, Mo., ranks second with $391 million, or 10.9
percent of the deposits. The third largest bank,
City National Bank and Trust Company of Kansas
City, Kansas City, Mo., with deposits of $369 million, holds approximately 10 percent of the area's
deposits. The charter bank, with 3 percent of the
deposits in the area, is the fifth largest bank, while
the Exchange State Bank of Kansas City is the 47th
largest bank in the market area, with only 0.42
percent of total area deposits. The resulting bank
will rank as the fourth largest bank in the area.
Additional competition is felt from many nonbank financial institutions, including 30 savings
and loan associations, with deposits of $1.6 billion,
and numerous sales finance and personal loan
companies. Competition is provided by 197 State113

chartered and 32 federally-charted credit unions,
as well as by insurance companies and direct lending agencies of the Federal Government.
Competition between the two banks is not considered significant due to the general character of
their respective operations and the presence of
other banks in the area. While the charter bank is
primarily a wholesale bank operating on a metropolitan and regional basis, the merging bank's
operations are principally retail in character with
its trade limited to Wyandotte County. The limited
degree of competition between the applicant banks
is further evidenced by their lack of common customers and the existence of common ownership.
This merger will not result in dislocation or imbalance in the present area banking structure.
Furthermore, because of the numerous banking
offices in close proximity, consummation of this
merger will leave the banking public a wide choice
of alternate banking facilities.
Approval of this application will benefit the
banking public in the service area of the resulting
bank. The increase in the charter bank's lending
limit will allow the bank to compete more aggressively for large commercial and industrial loans in
the area. The merging bank's asset problems will be
improved by merger with the well capitalized
charter bank. Consummation of this merger will
solve the management succession problem in the
merging bank, and will enable the resulting bank
to provide the merging bank's customers with a
broad range of additional banking services not
presently available from the merging bank, including an experienced trust department and data
processing facilities. Merger is the only means,
other than internal growth, by which the charter
bank can expand its operations to better meet
competitive forces and serve the community.
This proposal will promote the public interest
without lessening competition. The application is,
therefore, approved.
JUNE 24,

1970.

114




SUMMARY OF REPORT BY ATTORNEY GENERAL

Since the banks involved in this proposed merger
are located within two blocks of each other in the
principal business district of downtown Kansas
City, Kans., the merger will result in the elimination of direct competition. However, commercial
banking in the Kansas City, Missouri-Kansas area,
consisting of both Kansas City, Mo., and Kansas
City, Kans., as well as the suburban area adjacent
to the latter in Johnson County, Kans., is dominated by three Kansas City, Mo., banks, much
larger in size than either of the merging banks. The
resulting bank, with deposits of $121.6 million, as
of June 29, 1968, would rank fourth in this area.
Nevertheless, the effect of the merger would be to
reduce competition.
As of June 29, 1968, the three largest banks held
48.6 percent of all IPC demand deposits in the
area; the merging banks rank 5th and 40th among
approximately 50 banks in the area and, as of the
same date, held 1.5 percent and 0.4 percent, respectively, of such deposits, and 3.1 percent and
0.6 percent, respectively, of total deposits in the
area. After the merger, the resulting bank will rank
fourth in the area, increasing concentration by
less than 1 percent. It is to be noted that the foregoing market share and concentration figures do
not reflect the existing affiliations among many of
the area banks, nor the existence of substantial
amounts of stock ownership in a number of area
banks, including each of the merging banks, held
by certain family groups which number among
their members officers and directors of a number of
Kansas City, Kans., banks, including the second
largest bank in that city. However, the information
presently available to this Division indicates that
the respective market shares of the merging banks
would be increased by less than 1 percent if affiliations were considered.
To summarize, the proposed merger will eliminate direct competition and will slightly increase
banking concentration in the Kansas City, MissouriKansas area.

SOUTHERN NATIONAL BANK OF NORTH CAROLINA, LUMBERTON, N.G., AND BANK OF CHARLOTTE, CHARLOTTE, N.C.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

Bank of Charlotte, Charlotte, N.C, with
and Southern National Bank of North Carolina, Lumberton, N.C. (10610),
which had
merged Aug. 1, 1970, under charter and title of the latter bank (10610). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 25, 1970, the Bank of Charlotte, Charlotte, N.C, and the Southern National Bank of
North Carolina, Lumberton, N.C, applied to the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
The Southern National Bank of North Carolina,
Lumberton, N.C, with IPC deposits of $131.5 million, was organized as a State bank in 1897, and
acquired a National charter in 1914. The bank's
service area was limited to the Lumberton, N.C,
area until 1959, when it commenced a de novo
branch expansion program within a 50-mile radius.
As a result of this progam, as well as of acquisitions, the bank now operates 42 branches in 25
communities throughout the State.
The Bank of Charlotte, Charlotte, N.C, with
IPC deposits of $16.1 million, was organized in
1917, and now operates as a unit bank from an
office in the central business district of Charlotte.
It has primarily concentrated in retail banking
transactions, and has a relatively large volume of
installment loan business. The merging bank has
been owned by a single family over the years, and
its growth is attributed to the economic vitality of
the Charlotte area rather than the aggressiveness
of its management.
Charlotte, the largest city in North Carolina,
with an estimated population of 275,000, is located
within 10 miles of the South Carolina State line,
and serves as the principal distribution and financial center for both states. Its rate of population
growth is 3 percent per annum, which is among
the highest in the Nation for cities of comparable
size, and is indicative of the area's overall expansion. Though Charlotte has been primarily a distribution center serving an important industrial
region, new industrial investments have been impressive in recent years. Banks in the Charlotte




$23,910,939

1

167,058,069

46

202,508,937

47

area are keenly competitive, with de novo entry
into the area being expensive; in addition, considerable time would be required for a bank to
become established and develop an adequate business base to be competitive.
The charter bank has no branches in the relevant
market area; its nearest facility is located some 60
miles from the merging bank in Mount Gilead,
N.C. Thus, there is no competition between the
merging banks. The resulting bank, with 2 percent
of total area deposits, will rank sixth, after the five
largest statewide banks which already maintain
offices in the Charlotte-Mecklenburg area: Wachovia Bank and Trust Company, N.A., WinstonSalem, N.C, with total deposits of $1,328 million;
North Carolina National Bank, Charlotte, N.C,
with total deposits of $1,088 million; First Union
National Bank, Charlotte, N.C, with total deposits
of $866 million; First Citizens Bank and Trust
Company, Smithfield, N.C, with total deposits of
$610 million; and Northwestern Bank, North
Wilkesboro, N.C, with total deposits of $423 million, all of which are substantially larger than the
resulting bank. Additional competition is felt
throughout the area from savings and loan associations, finance companies, credit agencies, and
mortgage production offices. Since the charter bank
will merely replace the merging bank, consummation of the merger will not reduce the number of
alternate banking facilities.
The merger will benefit the charter bank by bringing it into a rapidly growing economic area. The
charter bank's deposit base originates in agriculturally-oriented communities, and is therefore subject to marked fluctuations. The addition of Charlotte to the bank's service area will diversify and
balance its operating base.
The aggressive management, the size, and the
capital structure of the charter bank, which utilizes
sophisticated electronic equipment and modern
115

banking practices, will enhance the competitive
position of the resulting bank in the Charlotte
area. The proposed merger will bring to the customers of the merging bank the resources of a
larger bank offering broader services, including
automated bookkeeping, trust services, a credit card
program, and dealer financing.
Applying the statutory criteria, we find that the
merger is in the public interest, and the application, therefore, is approved.
JUNE 29,

1970.

SUMMARY OF REPORT BY ATTORNEY

GENERAL

Southern's nearest office to the Bank of Charlotte
is in Rockingham (population 5,512), county seat
of Richmond County, 64 miles southeast of Charlotte. Numerous banking alternatives are available
to residents of Charlotte and Mecklenburg County.
The proposed merger, if approved, will not elimi-

nate any substantial existing competition between
the banks.
Southern has no Mecklenburg County office, and
should be considered a potential entrant into this
attractive and growing market.
However, it is unlikely that Southern's de novo
entry into Charlotte, permitted under State law,
would be significantly different in competitive
effect than the present acquisition. The Bank of
Charlotte has only one office and about 2 percent
of the total deposits of Mecklenburg County, where
the State's four largest banks now hold about 90
percent of county total deposits of $848.2 million,
and have 75 percent of the county's 77 banking
offices.
To summarize, in view of the small relative size
of the Bank of Charlotte and its modest position in
the highly concentrated banking market in Charlotte and in Mecklenburg County, we conclude that
the proposed merger is not likely to have a significantly adverse effect on potential competition.

NATIONAL BANK OF AGRICULTURE, DELANO, CALIF., AND T H E FIRST NATIONAL BANK OF CARUTHERS, CARUTHERS, CALIF.
Banking offices

Total assets

Name of bank and type of transaction

To be
operated

In
operation

National Bank of Agriculture, Delano, Calif. (15450), with
and The First National Bank of Caruthers, Caruthers, Calif. (11330), which had. .
consolidated Aug. 7, 1970, under charter of the latter bank (11330) and title
"National Bank of Agriculture." The consolidated bank at date of consolidation
had

COMPTROLLER'S DECISION

On May 8, 1970, The First National Bank of
Caruthers, Caruthers, Calif., and the National Bank
of Agriculture, Delano, Calif., applied to the
Comptroller of the Currency for permission to consolidate under the charter of the former and the
title of the latter.
The First National Bank of Caruthers, Caruthers,
Calif., was organized in 1919, and remains a unit
institution with IPC deposits of $2.4 million. Continuing asset problems and unaggressive competitive practices have resulted in a poor earnings
record at the charter bank, which does not offer
extended banking hours, night depository, safe
deposit, escrow, or trust services.
The economy of the market area of The First
116




$12,832,543
4,087,442
17,971,623

3
1

4

National Bank of Caruthers is relatively static, and
depends primarily upon grapes and cotton farming.
A large majority of the approximately 5,000 individuals who populate the bank's service area are
tenant farmers and small land owners with limited
resources.
The National Bank of Agriculture, Delano, Calif.,
with IPC deposits of $3.8 million, was organized in
1964, and now operates branches at Fresno, in
Fresno County, and at Bakersfield, in Kern
County. The National Bank of Agriculture's market area includes the most populous and most
prosperous portions of Fresno and Kern counties.
These counties lie in the San Joaquin Valley, an
extremely productive farming region. In Fresno
County, which has ranked first in the Nation for

agricultural production since 1950, crop values increased from $389 million, in 1960, to $463 million,
in 1968. The cities of Fresno and Bakersfield are
the financial, industrial, and shopping centers of
the San Joaquin Valley. The new and expanding
industry developing in and around Fresno and
Bakersfield offsets losses of jobs resulting from the
increased mechanization of farming. Both cities are
growing in employment and population.
There is very little competition between the consolidating banks; their nearest offices are 15 miles
apart. The charter bank has not, in any event,
proven to be an aggressive competitor. The consolidated bank will continue to compete with the
offices of major regional and statewide banks.
Consummation of the proposed consolidation
will provide the Caruthers area with a locallyoriented bank offering a broader range of services
to the agricultural businesses in the Fresno-Bakersfield-Delano market area. However, the consolidation will enable the National Bank of Agriculture
to relocate its main office from the small agricultural town of Delano to the city of Fresno.

Applying the statutory criteria to the proposed
consolidation, it is concluded that it will serve the
public interest. The application is, therefore, approved.
JULY 7,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

In Fresno County, which has a population of
almost 400,000, there are offices of most of the big
statewide banks, nearly all of which are in or near
Fresno itself. The Caruthers Bank is the only bank
located in Caruthers, although the branch of a
major statewide bank is located about 10 miles
south of the town.
The consolidation will eliminate whatever competition now exists between the two banks; however, the consolidated bank will have less than 2
percent of the commercial bank deposits in Fresno
County. Since the two banks engage in only limited
competition and are not of substantial size, this
consolidation is not likely to have any significantly
adverse effect on competition.

MAINE NATIONAL BANK, PORTLAND, MAINE, AND THE FIRST NATIONAL BANK OF PITTSFIELD, PITTSFIELD, MAINE
Banking offices
Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Pittsfield, Pittsfield, Maine (13777), with
and Maine National Bank, Portland, Maine (4128), which had
merged Aug. 14, 1970, under charter and title of the latter bank (4128). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On May 13, 1970, the Maine National Bank,
Portland, Maine, and The First National Bank of
Pittsfield, Pittsfield, Maine, applied to the Comptroller of the Currency for permission to merge
under the charter and title of the former.
The Maine National Bank was founded in 1889,
under the title of the Portland National Bank, and
acquired its present title in 1968. The bank operates 18 branches, and holds IPC deposits of $135
million. This bank has enjoyed large increases in
earnings in recent years and has excellent future
prospects. As a full-service bank, it offers a wide
variety of banking services, including trust, com-




$12,129,152
190,482,404
202,611,556

To be
operated

2
24
26

puter and data processing, credit card, travel
agency, and business development services.
The market area of the Maine National Bank
encompasses the five coastal counties of Cumberland, York, Sagadahoc, Lincoln, and Knox, as well
as the two interior counties of Oxford and Franklin. The coastal counties comprise a 130 mile
stretch along Maine's southeastern coast. Their
population, estimated at 365,000, is 37 percent of
Maine's total population. This region's economy
rests primarily upon manufacturing, agriculture,
tourism, marine products, and mining. Portland,
Maine's largest city and commercial center, is
located in Cumberland County, in the middle of
this region. Oxford and Franklin counties, located
117

on Maine's western border, became a part of the
bank's market area after a merger in 1968. Their
combined population is 65,000, and their economy
is based on lumbering, farming activity, tourism,
and manufacturing of wood products.
The First National Bank of Pittsfield was founded in 1933, and operates one branch at Hartland,
Maine. This is a small bank offering limited services, with IPC deposits of $9.4 million. It needs to
provide for management succession, since its president and vice-president are nearing retirement age
and proper replacements are unavailable within
the present management group.
The market area of The First National Bank of
Pittsfield includes Somerset County's two manufacturing towns of Pittsfield and Hartland, with populations of 5,000 and 1,500, respectively. Somerset
County's population is 40,000. The county's
economy rests primarily on Pittsfield's and Hartland's manufacturing enterprises.
There is no competition between offices of the
merging banks which, at the closest point, are 70
miles apart. This merger will not unduly concentrate banking assets in the Somerset County market
area because other major banks operate offices in
Pittsfield.
Consummation of the merger will introduce
another large, full-service bank to the Somerset
County market area. Banking competition there
will be enhanced. The resulting bank's Pittsfield
and Hartland branches will experience significantly
increased lending capacities, and will make available the broader range of banking services offered
by the charter bank. The merging bank's management succession needs will be filled from the charter
bank's management trainee pool.
Applying the statutory criteria to the proposed
merger, we conclude that it serves the public interest. The application is, therefore, approved.
JULY 9,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the participating banks are
99 miles apart, and their closest offices are some 70
miles apart. The merger would not, therefore, appear to eliminate any significant existing competition between the merging banks.
The service area of Pittsfield Bank is confined
to the southeastern portion of Somerset County. At
present, no other commercial banks operate offices
in this limited area, although competition is
afforded by offices of Depositors Trust Company,
the Newport Trust Company (a subsidiary of
Depositors Corporation), and the Merrill Trust
Company in adjacent areas. Depositors Trust Company also has filed an application to open a de novo
office in Pittsfield. According to the application,
Pittsfield Bank receives indirect competition from
the Federal Trust Company, headquartered in
Waterville. Merrill Bankshares, parent company
of the Merrill Trust Company, has recently received approval to acquire this bank.
Thus, the service area of Pittsfield Bank appears
almost entirely surrounded by offices of two of
Maine's largest banking institutions, Depositors
Corporation and Merrill Bankshares. The entry of
Maine National into this area would add a third
major bank to this general area of central Maine
and could enhance competition.
Under applicable State law, Maine National cannot open a de novo office in Somerset County, except
in communities where no banks regularly transact
banking business. Another possible alternative,
formation of a holding company and the chartering
of a new bank in the area, is presently the subject
of litigation involving another banking institution,
although Maine National is clearly one of the most
able banks to follow this course. There are no other
merger alternatives for Maine National in the service area of Pittsfield Bank.

THE INDIAN HEAD NATIONAL BANK OF NASHUA, NASHUA, N.H., AND THE WILTON NATIONAL BANK, WILTON, N.H.

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The Wilton National Bank, Wilton, N.H. (13247), with
and The Indian Head National Bank of Nashua, Nashua, N.H. (1310), which
had
merged Aug. 14, 1970, under charter and title of the latter bank (1310). The
merged bank at date of merger had

118




$10,266,204

1

61,808,730

4

72,071,608

5

COMPTROLLER'S DECISION

On April 29, 1970, The Wilton National Bank,
Wilton, N.H., and The Indian Head National
Bank of Nashua, Nashua, N.H., applied to the
Office of the Comptroller of the Currency for permission to merge under the charter and with the
title of the latter.
The Indian Head National Bank, with IPC deposits of $47.9 million, was chartered as a National
bank in 1865. In 1934, it became a subsidiary and
the lead bank of New Hampshire Bankshares, Inc.,
a bank holding company subsequently registered
as such in 1956. State banking law changes in 1963,
making branch banking permissible within certain
limitations, brought about the establishment of two
de novo branches. In 1969, this bank merged with
The Salem Trust Company, Salem, N.H., whose
sole office became its third branch.
Nashua, N.H., the home of the charter bank, is a
city with a population of about 50,000, and is
located 39 miles northwest of Boston, Mass., and 18
miles south of Manchester, N.H., within easy commuter distance of the economic cores of both
states. Across the Massachusetts border, three major
industrial centers, viz. Lowell, Lawrence, and Haverhill, provide additional sources of employment
for area residents. Within the city limits of Nashua,
in 1968, there was a recorded employment of 36,802
of which 17,069 were in manufacturing fields.
Sanders Associates, Inc., employing 6,900 in electronics work, was a leader in the local economy.
In addition to the charter bank, the banking
needs of the Nashua area are provided for by the
Nashua Trust Company, with deposits of $42 million, and the Nashua branch of the Bank of New
Hampshire, N.A., Manchester, N.H., with total
deposits of about $86 million. Two federal savings
and loan associations with combined deposits of
$59 million provide additional sources of financial
services. The presence and growth of Indian Head
National Bank of Nashua is required to preserve
the balance of local banking competition.
The Wilton National Bank, Wilton, N.H., with
IPC deposits of $8.4 million, is a unit banking institution, organized in 1928 and affiliated with New
Hampshire Bankshares, Inc., since 1934. Continuity
of management is not provided for except through
holding company channels. Wilton is a town with a
population of about 2,280, and is located 16 miles
west of Nashua. Wilton has been a static community for a number of years, and local employ-




ment is still dominated by two family enterprises
employing 500 workers. One of these companies is
reported to be closing, thus eliminating 124 jobs.
Additional industrial and commercial activity is
very limited. The surrounding towns and countryside are engaged primarily in agricultural and
service pursuits.
The Souhegan National Bank, Milford, N.H.,
with deposits of $10.7 million, is the only commercial bank within the service area of the merging
bank. The main office of this bank is located 5
miles east of Wilton, and its only branch is 3 miles
further east. A small savings bank, located to the
south, in Greenville, N.H., is the only other bank
within 10 miles of the merging bank.
When this transaction is consummated, the Wilton office of the resulting institution will offer expanded business loan capabilities, trust services,
and, within a short time, computer services. The
resulting bank's capital position will permit the
erection of a more convenient banking facility with
modern customer service features. In the Nashua
area, the beneficial effects of the merger will include an increased lending limit, a broadened
market area, and an improved base for the implementation of electronic data processing services.
Competition will not be adversely affected. Since
the banks are presently affiliated, and their service
areas do not overlap, there is little competition between them. In Nashua, the charter bank's operations will be strengthened, with the result that it
should become a more effective competitor without
causing an imbalance of existing competitive relationships. Since there are no other banks in Wilton,
competition will not be affected in that community.
The Souhegan National Bank and the savings bank
located in Greenville, N.H., should continue to
operate effectively without adverse competitive
effects from this merger.
Applying the statutory criteria, we find that the
merger is in the public interest. The application,
therefore, is approved.
JULY 10,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The two banks involved in the proposed merger
are both long standing subsidiaries of New Hampshire Bankshares, Inc., a registered bank holding
company. It is, therefore, unlikely that the proposed merger will eliminate any effective competition.
119

NATIONAL BANK OF WASHINGTON, TACOMA, WASH., AND T H E PACIFIC NATIONAL BANK OF SEATTLE, SEATTLE, WASH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Pacific National Bank of Seattle, Seattle, Wash. (13230), with
and National Bank of Washington, Tacoma, Washington, Tacoma, Wash. (3417),
which had
consolidated Aug. 17, 1970, under charter of the latter bank (3417) and title
"Pacific National Bank of Washington." The consolidated bank at date of consolidation had . . .
. .

COMPTROLLER S DECISION

On December 31, 1969, the National Bank of
Washington, Tacoma, Wash., and The Pacific National Bank of Seattle, Seattle, Wash., applied to
the Comptroller of the Currency for permission to
consolidate under the charter of the former and
with the title "Pacific National Bank of Washington," with headquarters in Seattle.
The National Bank of Washington, Tacoma,
Wash., was organized in 1885, and now holds IPC
deposits of $343 million. The bank operates 43
branches, of which 16 are located in Tacoma and
its suburbs, 5 are located elsewhere in Pierce
County, 2 are located in the southern portion of
King County, and the remaining 20 offices are
scattered throughout the State. The charter bank,
which is a subsidiary of Western Bankcorporation,
Los Angeles, Calif., emphasizes retail banking service. A major reason for this application is the
charter bank's desire to make a meaningful entry
into Seattle to enable it to compete with the State's
largest banks, and to service the banking business
of its customers who have relocated to that city.
Tacoma, the site of the headquarters of the
charter bank, lies at the northern end of Pierce
County. It is the third largest city in the State of
Washington, with the 1969 population estimated at
about 161,000. The population of Pierce County is
approximately 393,000. The economy of the Tacoma
area depends primarily on natural resource industries including the extraction and smelting of minerals and the production of lumber and wood products. Two major military installations, Fort Lewis
and McChord Air Force Base, are located approximately 12 miles south of Tacoma. The metallurgical and food processing industries are gaining in
importance, while the presence of an excellent
natural harbor has provided the stimulus for an
120




$254,292,665

16

454,265,462

44

708,296,502

To be
operated

60

important shipbuilding industry. While the Tacoma area is expected to experience further gains
in employment and population, it is subject to
cyclical swings due to its dependence on the housing industry and military activity. There are 10
commercial banks with offices in Pierce County,
including four with headquarters in Tacoma.
The Pacific National Bank of Seattle, Seattle,
Wash., was organized in 1928, and now holds IPC
deposits of $183 million. The bank operates 15
branches, all of which are in the immediate Seattle
area except for the Military Road branch, which
is located 14 miles south of Seattle in an unincorporated area in King County. Several of these
branches are more in the nature of service facilities
to corporate customers rather than sources of new
banking business.
Seattle, where the consolidating bank operates,
is located in the eastern portion of King County
and is the largest city in the State of Washington,
with a population estimated at 591,000. About onethird of the State's inhabitants reside in King
County in the general vicinity of Seattle. Seattle is
a major industrial center with the aerospace and
related industries of primary importance. The
Boeing Company, in late 1969, provided employment for 81,200 persons, or approximately 13 percent of the Seattle employment market. Shipbuilding and other heavy industries are also of great
importance. Because of its excellent port facilities,
Seattle is a major center for world trade. It is also
an important wholesale trade and distribution
center. The University of Washington, with a
student enrollment of 30,000, is located in Seattle.
Seattle is also the financial center of the State,
and the headquarters city for Washington's largest
banks. Eleven of the 13 banks operating in the
Seattle area maintain their headquarters in this

city; the consolidating bank is the fourth largest
of those. The largest bank, the Seattle-First National Bank, Seattle, Wash., holds 34.3 percent of
Seattle deposits, while the National Bank of Commerce, Seattle, Wash., holds 24.5 percent of the
same. The consolidating bank is heavily oriented
towards commercial banking business, with 73 percent of its IPC demand deposits and 77 percent of
its loans representing commercial banking activity.
Due to its limited size, it has had difficulty in servicing the major borrowing needs of its customers;
because it has had to participate large amounts of
its corporate loans, it has lost important customers
to banks with higher lending limits. Its dependence
on commercial business has also caused it to lag
behind its competitors in King County in overall
growth, and has made it unusually subject to the
cyclical swings of the business enterprises it services.
There is virtually no competition between the
participating banks whose head offices are separated
by 32 miles. The nearest branch of the consolidating bank to an office of the charter bank is the
Military Road branch, located south of Seattle,
which is 5.6 miles and 6.7 miles from the Kent and
Auburn branches, respectively, of the charter bank.
The development of competition between those
offices has been, and will be, minimal in that they
are separated, not only by a railroad and a major
interstate highway, but also by a bluff that makes
direct travel between them difficult. In addition,
offices of the State's three largest banks are located
in the intervening area.
The possibility of future competition between
the consolidating banks appears very remote. The
State of Washington's restrictive branching laws
permit statewide branching only through merger,
and permit de novo branching only within the
county in which the bank's headquarters are located, or in cities and towns which do not have a
commercial banking office. Those laws would prevent the banks from coming into direct competition
in their principal market areas through de novo
branching. Thus, each participating bank may
enter the principal market area of the other only
through merger. However, legal and banking considerations severely limit the possibility of any such
prospective merger other than the subject application. The provisions of federal banking law would
not permit Western Bancorporation or either of
the consolidating banks qua bank to charter a new
bank to be used later as a vehicle to effect market
entry through merger. A merger of the National




Bank of Washington with one of the existing small
independent banks located in Seattle would leave
the resulting bank without the branch system necessary to make a meaningful competitive entry into
that city; it could not, once there, establish further
branches under the State's branching laws. Such a
small merger, coupled with the relocation of the
National Bank of Washington's headquarters to
Seattle, would subject the bank to the costly requirement of maintaining a higher reserve on its
system deposits, without any assurance of acquiring regulatory approval for the establishment of a
satisfactory branch system in a city with an already
high population per banking office. Furthermore,
while the Pacific National Bank of Seattle could
merge with one of the small independent banks in
Pierce County, or in another county in a community where charter bank presently has a branch,
such a development would hypothesize a revolutionary reorientation from this bank's present development pattern which has kept it in the Seattle
area with a primarily wholesale outlook. It would
therefore appear that the consolidating banks cannot realistically be viewed as potential competitors.
Consummation of this proposal will consolidate
Washington's fourth and sixth largest commercial
banks to create the State's third largest banking
institution, which will hold 11.2 percent of the
State's commercial bank deposits. Since the consolidating banks operate in geographically distinct
areas, approval of this application will not increase
banking concentration in any market area in the
State. The effect of this transaction will be to create
an institution with headquarters in Seattle, the
State's commercial and financial center, which will
be capable of competing effectively with the State's
two largest banks, both of which have statewide
branching systems, viz. Seattle-First National Bank,
Seattle, Wash., which, with deposits of $1.7 billion,
holds 31.8 percent of the State's commercial bank
deposits; and the National Bank of Commerce of
Seattle, Seattle, Wash., which, with deposits of over
$1 billion, holds 19 percent of the State's commercial bank deposits. Approval of this application will
create a bank, with virtually a statewide branch
system, which will be in a position to challenge the
dominance those institutions have in Washington's
financial life, and which will increase the quality
of competitively offered banking services. Additional banking competition will be encountered
from the Seattle and Tacoma branches of The
Bank of California, N.A., San Francisco, Calif., with
121

total deposits of about $1.6 billion; the Peoples
National Bank of Washington, Seattle, Wash., with
deposits of $385 million; and the Old National
Bank of Washington, Spokane, Washington,
Spokane, Wash., with deposits of about $295 million. Mutual savings banks with recently expanded
lending powers, certain trust powers, statewide
branching privileges, and the right to convert to
commercial banks are also important competitive
factors in Washington. The two largest of these are
the Washington Mutual Savings Bank, Seattle,
Wash., which, with deposits of $719 million, has
branches in Tacoma and other locations; and the
Fidelity Mutual Savings Bank, Spokane, Wash.,
which, with deposits of $205 million, maintains
branches in Seattle as well as other locations.
Approval of this application will benefit the
banking public in the major geographical areas
affected by this proposal. The charter bank's specialization in consumer banking services, and the
consolidating bank's commercial banking orientation will enable the consolidated bank to improve
the quality of services to both classes of customers.
With the significant base that this transaction will
provide in Seattle, the consolidated bank will be
able to participate fully in the State's economic
and financial life, and to provide fuller service to
commercial customers located in Tacoma, as well
as to those whose corporate headquarters have
gravitated to Seattle. The larger lending limit of
the consolidated bank will reduce the need of the
consolidating bank to participate large credit lines,
and will assist the consolidated bank in retaining
those customers whose heavy borrowing requirements have increasingly caused them to seek the
services of the State's largest banks or of out-of-State
banks. The charter bank's comprehensive branch
network will permit the transfer of funds from
rural, capital-surplus areas, to the urban, capitaldeficit areas to be served by the consolidated bank.
With headquarters in the northwest's most important trade center, the consolidated bank will be
in a position to increase the scope of international
banking services offered to customers, in Tacoma
and Seattle, who have commercial interests overseas, possibly through the establishment of foreign
branches, or of an Edge Act Corporation. The
charter bank's retail banking experience will enable
the resulting bank to improve the quality and increase the range of consumer services to customers
in the area now served by the consolidating bank.
122




It is anticipated that the consolidated bank will
provide, throughout its service area, certain consumer services such as bank credit card and checkguaranty programs, that are not presently provided
by either bank. In addition, the larger capital base
of the consolidated bank will provide it with an
increased capability with respect to loans to new
industry, and small business participation in urban
social programs, and will expand its bond underwriting capacity.
Applying the statutory criteria, we find that the
consolidation is in the public interest, and the
application, therefore, is approved.
JULY 17,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank's headquarters is located 32 miles
from Pacific's headquarters in Seattle. Pacific has no
branch offices in Pierce County, but National Bank
operates two branches at Kent (population 17,065)
and Auburn (population 21,300) in the southern
part of King County. The closest office of Pacific to
these branches is located in an unincorporated area
on Military Road, some 5.6 road miles from National Bank's Kent office, and some 6.7 miles from
its Auburn office. Branches of the State's three
largest banks are located in the areas between National Bank's branches and Pacific's Military Road
branch. Consequently, it would not appear that
the proposed consolidation would eliminate substantial direct competition.
Banking in Seattle and King County is highly
concentrated. As of June 29, 1968, the four dominant banks in that county, including Pacific, held
nearly 88 percent of all commercial bank deposits
and nearly 90 percent of IPC demand deposits.
Pacific alone held over 13 percent of IPC demand
deposits, and was the third largest bank in the
county in that category, although it ranked fourth
in overall deposits, with 10 percent. Of the nine
banks in the State with deposits of over $100
million, six presently have offices in Seattle.
Another has recently announced plans to merge
with a small Seattle bank. Thus, only two Washington banks with deposits of over $100 million
do not presently serve Seattle. National Bank is by
far the largest of these two potential entrants, it
already has two offices in King County, and it has
indicated its desire to continue to enter Seattle and
expand throughout King County. In view of these
facts, National Bank must be considered the most

likely potential entrant into the highly concentrated Seattle and King County commercial banking markets.
In Tacoma and Pierce County, as of June 29,
1968, National Bank controlled over 42 percent of
commercial bank deposits. Moreover, the two
largest commercial banks controlled over 80 percent of such deposits. Pacific is one of four banks
in the State with deposits of over $100 million that
do not serve Tacoma and Pierce County. Of those
four banks, one is based in Spokane, in eastern
Washington, and has only recently begun to enter
the western portions of the State, and a second is
substantially smaller than Pacific. Therefore,
Pacific would appear to be one of the most likely
entrants into Tacoma and Pierce County.
Under Washington's restrictive branch banking
laws, a bank may establish de novo branches in the
city in which it has its principal place of business,
in unincorporated areas in the county in which it
has its headquarters, and in incorporated cities and
towns which do not have a banking office of any
commercial bank. Consequently, the participants
to this proposed merger may not establish de novo
branches in each other's markets in Tacoma or
Seattle. However, they can enter each other's service
areas by acquisition of smaller banks or by opening
offices in communities which do not have any banking offices.
Specifically, National Bank could enter Seattle
proper by acquiring any of the three small independent banks which exist in that city. It could
either move its headquarters to Seattle at that point,
and thereafter open further branches, or, as a condition of the merger, have the acquired bank obtain
a number of new branch authorizations. In the
alternative, National Bank could acquire a small
stock interest in a Seattle bank or assist in chartering a new one which could serve its interests in
the city. Such a bank could subsequently merge
with National Bank, if the parties so chose. Finally,
there are some nine other banks located outside of
Seattle, but within King County. National Bank
might acquire one of those banks in order to establish more effectively its presence in the Seattle area.
Pacific could enter Pierce County through the
methods described above. There are five small banks
presently serving Pierce County, of which one is
located in Tacoma. In addition, Pacific could assist




in chartering a new bank to serve Tacoma or other
parts of Pierce County and subsequently merge
with such a bank.
The proposed merger's effect upon potential
competition is not limited to the Seattle and Tacoma markets. Banking in the State of Washington,
as a whole, is highly concentrated. The five largest
banking organizations, including National Bank,
control over 70 percent of commercial bank deposits
in the State, and this merger would increase that
concentration ratio to 74 percent. The nine banking
organizations with deposits of over $100 million,
including both merging banks, control over 84 percent of such deposits. This high statewide concentration is reflected in local markets throughout the
State.
Outside of Pierce and King counties, there are 15
counties with populations, as of 1960, of 40,000 or
more. National Bank has offices in eight of those
counties, including the seven with a population of
over 75,000. In those eight counties, the aggregate
market share of the five largest banks in the State
ranges from 62 percent to 96 percent of commercial
bank deposits. Pacific, on the other hand, has not
expanded outside of King County, and is one of
only a very few of the State's largest banks which
has not expanded outside of its headquarters area.
There are seven counties outside of Pierce and
King counties with populations of over 40,000 in
which neither National Bank nor Pacific has offices.
In those seven counties, the aggregate market share
of the five largest banks in the State ranges from
50 to 94 percent of county commercial bank deposits. National Bank and Pacific are among the
largest of a relatively small number of banks who
are large enough to inject a significant competitive
force into these counties via new entry.
Overall, this merger will result in eliminating
substantial potential competition in Seattle and
King County, Tacoma and Pierce County, and in
the other 15 most populous counties in the State.
This merger will also combine banking organizations which are leading factors in two adjacent
banking markets. As a result, this merger may deter
new entrants, chill existing competition, and limit
the likelihood of eventual deconcentration in a
number of highly concentrated markets. We conclude that this merger will have a significantly
adverse effect on competition.

123

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

AND T H E STATE COMMERCIAL BANK, THOMASVILLE,

N.C.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The State Commercial Bank, Thomasville, N.C, with
and North Carolina National Bank, Charlotte, N.C. (13761), which had
merged Aug. 28, 1970, under charter and title of the latter bank (13761). The
merged bank at date of merger had

COMPTROLLER S DECISION

On May 11, 1970, The State Commercial Bank,
Thomasville, N.C, and North Carolina National
Bank, Charlotte, N.C, applied to the Office of the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
North Carolina National Bank, Charlotte, N.C,
with IPC deposits of $850.4 million, was organized
in 1933, and now operates 91 offices in 27 communities of North Carolina. This bank is the principal
component of NCNB Corporation, a one-bank holding company, which, through several other subsidiaries, engages in various bank-related activities such
as mortgage financing and servicing, insurance
agency services, factoring, and sales financing. The
charter bank's position as the leading bank in
Charlotte, the State's largest city, which has a population of over 200,000 and is the financial distribution center for both North and South Carolina,
and its strength in the Piedmont region of North
Carolina, where the bulk of the State's industry is
located, give this bank a statewide influence, and
make its service area essentially the whole State.
The State Commercial Bank, Thomasville, N.C,
with IPC deposits of $13.4 million, was established
in 1945. In addition to its main office, located in
the central business district of the city, it operates a
branch in a shopping center just to the south of
the city, and a small facility in the northeast section of the city. This bank has generally operated
in a conservative manner over the years, and is now
facing a management succession problem owing to
the imminent retirement of the bank's chief executive officer.
Thomasville, the home of the merging bank, had
a population of about 15,000 in 1960, and is located
about 8 miles northeast of Charlotte. The economy
of the area is industrial and is supported by furniture manufacturing and textiles. A few large industrial employers dominate the employment market,
124




$17,827,185
1,284,569,745
1,302,645,825

To be
operated

3
95
98

including Thomasville Furniture Industries, Inc.,
which is reported to employ between 3,000 and
3,500; Carolina Seating Company, with several hundred employees; and Amazon Cotton Mills, Inc.,
and Carolina Underwear Company, with about 500
employees each.
Since the closest offices of the two banks are
about 5 miles apart, some competition between
them will be eliminated. However, competition
between the banks is limited due to the presence
of offices of three of the State's four largest banks.
Future competition between the banks will not be
eliminated, as it is doubtful whether the charter
bank would attempt to branch de novo into the
immediate Thomasville area as it appears that
present and impending banking offices in that city
are adequate in numbers for that community.
When the merger is approved, the charter bank
will be the second largest bank in the State, and
its share of total statewide deposits will increase by
an insubstantial amount. Banking competition
should be improved in the Thomasville area by
approval of this application, because the charter
bank is more capable of competing with the local
branch of the Wachovia Bank and Trust Company N.A.
Approval of the merger will benefit the Thomasville community by introducing the broad range of
sophisticated banking services offered by the charter
bank, including trust services, automated data
processing services, a business development department, sophisticated commercial lending and mortgage financing services, consumer credit services,
and a larger lending limit. In addition, approval of
this application will provide management succession to the merging bank.
Applying the statutory criteria, we find the
merger to be in the public interest, and the application, therefore, is approved.
JULY 15,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

NCNB has no offices in Davidson County or in
counties to the east, west, and south of it, although
its four branches in High Point (Guilford County)
are within a 12 mile radius of Thomasville, where
all of SCB's offices are located. An analysis of
NCNB's 21 offices in the Greensboro-WinstonSalem-High Point SMSA showed total deposits of
$230 million, of which $1.7 million, or 0.8 percent,
derived from Davidson County. This, in turn,
amounted to about 1.5 percent of the total deposits
of about $112.5 million held by Davidson County
banks, or about 12 percent of SCB's total deposits.
Since NCNB's High Point branches are its offices
closest to Thomasville, it is likely that a significant
portion of NCNB's Davidson County deposits are
held by its High Point branches, and are likely
derived from the Thomasville area, that portion
of Davidson County closest to High Point.
However, SCB derives about 95 percent of its
total deposits from Davidson County, and only
about 0.1 percent of its total deposits from the
Greensboro-Winston-Salem-High Point SMSA. Too,
there are several banking alternatives in the area
between Thomasville and the High Point branches
of NCNB.
Hence, the primary impact of the proposed
merger is not likely to be the elimination of the
relatively little direct competition between SCB
and NCNB.
As of June 29, 1968, six banks operated 12 offices
in Davidson County. Their deposits and shares of
countrywide totals are indicated by the following
chart:
Deposits
Bank
First Union (Lexington)
Lexington State Bank
Wachovia (Thomasville)
SCB
Carolina Bank (Denton)
Industrial Bank (Lexington)

(millions)
$31.2
24.4
16.9
11.9
4.0
3.6

Percent
33.8
26.5
18.3
13.0
4.4
4.0

Since 1968, Carolina Bank has been acquired by
the State's eighth largest bank, and Industrial Bank
merged into Security Bank of Salisbury. Additionally, the State's fourth and sixth largest banks have
had de novo branches approved for Davidson




County, one in Thomasville and two in Lexington,
respectively.
In Thomasville, SCB controls over half the approved city banking offices, and has experienced
sustained growth although it competes directly
with the largest bank in the State.
Since North Carolina law permits statewide
branch banking, NCNB could branch de novo into
Davidson County, an area which probably overstates the relevant market, or into Thomasville, an
area which understates the market. Moreover, in
view of NCNB's strong position in closely adjacent
areas to the north of Davidson County, and its
absolute size, it should be regarded as a likely
potential entrant into those areas. Certainly the
acquisition of SCB by a likely potential entrant
would entail the loss of some potential competition.
However, there are several other commercial
banks which should also be regarded as potential
entrants into Davidson County and into Thomasville, thus somewhat diminishing the adverse effect
of the proposed acquisition on potential competition.
Commercial banking in North Carolina is dominated by a few institutions. Four banks control over
60 percent of deposits: Wachovia (20.5 percent),
NCNB (16.8 percent), First Union (13.4 percent)
and First-Citizens (9.4 percent). The five largest
banks control over 66 percent. These increases in
statewide concentration are part of a continuing
history. From 1957 to June, 1968, the share of total
deposits of the five largest banks increased from 42
percent to 66 percent, a 24 percent increase—the
highest of any State during this period. This change
has been the result primarily of mergers, as shown
by the fact that the number of bank competitors
has decreased steadily from 178 in June, 1961 to
only 116 in June, 1969.
Although the proposed acquisition is unlikely to
eliminate substantial direct competition between
the applicants, it will foreclose the potential for
greater competition between them and continue the
trend of acquisitions by the statewide leaders.
Hence, we conclude that the proposed acquisition
will have an adverse effect upon potential competition.

125

THE FIRST NATIONAL BANK OF ALLENTOWN, ALLENTOWN, PA., AND SAUGON VALLEY TRUST COMPANY, HELLERTOWN, PA.
Banking offices
Name of bank and type of transaction

Total assets

In
operation

Saucon Valley Trust Co., Hellertown, Pa., with
and The First National Bank of Allentown, Allentown, Pa. (373), which had. .. .
merged Aug. 28, 1970, under charter and title of the latter bank (373). The
merged bank at date of merger had

COMPTROLLER S DECISION

On February 12, 1970, Saucon Valley Trust Company, Hellertown, Pa., and The First National Bank
of Allentown, Allentown, Pa., applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The First National Bank of Allentown, with
IPC deposits of $197.8 million, operates eight
branches and primarily serves Lehigh County and
the southeastern section of Northampton County.
The bank has been involved in two acquisitions in
the past 5 years, the last having taken place in June,
1964, when it merged with the Macungie Bank.
Saucon Valley Trust Company, chartered under
the laws of the Commonwealth of Pennsylvania,
holds IPC deposits of $12.2 million, and operates
as a unit bank. It has not been involved in any
amalgamations or acquisitions since commencing
operations in 1920. Located 10 miles southeast of
the charter bank, in Hellertown, it serves the extreme southern tip of Northampton County, the
extreme eastern tip of Lehigh County, and a small
portion of northwest Bucks County.
Both banks are situated in Pennsylvania's Lehigh
Valley, one of the most progressive and economically stable areas of the eastern seaboard. As a result
of its favorable location, climate, and topography,
the region has attracted an abundance of industry
and has developed coincidentally a need for larger
local financial institutions to meet the growing
local financial needs. Recognizing the need for
additional services, the large Philadelphia banks
have actively sought both commercial and trust
business in the area in recent years. In addition,
Girard Trust Bank of Philadelphia, a $1.9 billion
institution, operates a branch at Riegelsville, 12
miles east of merging bank.
Competition in the Allentown-Bethlehem-Lehigh
Valley area is intense. The Merchants National
Bank of Allentown, with deposits of $149 million,
126




$16,691,247
260,658,654
277,349,902

To be
operated

1
9

10

is in direct competition with charter bank and operates 12 branches within the limits of Lehigh
County. The Industrial Valley Bank and Trust
Company, the eighth largest bank in the Philadelphia region, with deposits of $391 million, is the
largest bank in the relevant market area of the
proposed merger, having gained entry into Allentown in December 1968, when it merged with the
$74 million Lehigh Valley Trust Company of Allentown. It now operates six branches in this area.
The Bank of Pennsylvania in Reading, with deposits of $192 million, merged with the National
Bank of Topton, and thereby acquired three offices
near Allentown. It has since opened a regional
office in the city of Allentown and has obtained
approval for another in-city branch. Two banks
based in Bethlehem, The First Valley Bank of
Bethlehem, with deposits of $118 million, and the
$87 million Union Bank and Trust Company of
Eastern Pennsylvania, operate, respectively, nine
and four branches in the area, and both have offices
in central Allentown.
Additional competition affecting the area also
emanates from New Jersey and New York City.
Under New Jersey's new banking laws, the 93
banks in the northern district are now empowered
to establish branch offices or merge with banks in
an area from Jersey City, in the most eastern part
of the State, to Phillipsburg on the western boundary. This region borders Pennsylvania and the
eastern end of the Lehigh Valley area, only 18
miles from the head office of charter bank. Intense
competition can be expected as these New Jersey
banks locate offices adjacent to the eastern border
of this market. Moreover, only 68 miles east of the
Northampton County, Pa., line, is New York City
and its large metropolitan banks, with which a
number of business and industrial concerns in the
Lehigh Valley area bank because of the lack of size
and financial resources of local institutions.

The proposed merger will enhance Hellertown's
competitive climate. Although there are at present
no competing banks in Hellertown, the First Valley
Bank of Bethlehem is constructing a branch there,
and upon its completion, the resulting bank will
be in direct competition with a very aggressive institution with deposits of $118 million. Presented
with that competition and that from larger banks
in the neighboring areas and the big cities, the
merging bank will find its prospects for future
growth limited, particularly in light of its management succession problem. The proposed merger
will bring to customers of Saucon Valley Trust the
resources of a larger bank offering broader services,
and, the inevitable result will be more intense
competition in the Hellertown area. With larger
banking resources available, local companies will
feel more inclined to maintain local banking connections rather than allow the large city banks to
preempt much of that business.
This proposal will promote the public interest
without lessening competition. The application is,
therefore, approved.
JUNE 16,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Saucon Bank is located about 6 miles from the
nearest offices of First National. The city of Bethlehem, with numerous banking offices, lies between
Hellertown and Allentown. Although the application states that First National does not draw substantial business from Saucon Bank's immediate
area, its position as the Allentown area's leading
bank indicates that some amount of existing competition will be eliminated by the proposed merger.
An appropriate market in which to judge the

competitive effects of the proposed merger includes
Lehigh County, the city of Bethlehem (parts of
which are in Lehigh and Northampton counties),
and the township of Lower Saucon, which includes
Hellertown. First National, the larger of the two
banks headquartered in Allentown, has about 30
percent of the total deposits in this area. The acquisition of Saucon Bank would increase this share by
approximately 2 percent. Its major competitor, the
Merchants National Bank of Allentown has recently submitted an application to acquire the
Fogelsville National Bank, which would increase
its deposit share from about 20 percent to 22 percent.
The two large Bethlehem-based banks, which
each have an office in Allentown, have deposit
shares of about 16 percent and 12 percent, bringing
the present four-bank concentration ratio to 78
percent. Another 10 percent of the total deposits
are held by the Industrial Valley Bank, Jenkintown, Pa., which acquired the Lehigh Valley Trust
Company in 1968.
Further competition in the Allentown area is
now provided by new Allentown branches of the
Bank of Pennsylvania, Reading. Some future competition may be anticipated from the large Philadelphia banks which have moved their headquarters to Montgomery County from whence branching into Lehigh County (but not Northampton
County) is permitted.
The proposed merger will increase concentration
and eliminate Saucon Bank as an independent competitor in an area where extensive economic growth
is anticipated. Accordingly, we conclude that the
proposed merger will have an adverse effect on
competition.

EASTON NATIONAL BANK AND TRUST COMPANY, EASTON, PA., AND T H E CITIZENS BANK OF WIND GAP, WIND GAP, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Citizens Bank of Wind Gap, Wind Gap, Pa., with
and Easton National Bank and Trust Company, Easton, Pa. (1233), which had. .
merged Aug. 31, 1970, under charter and title of the latter bank (1233). The
merged bank at date of merger had




$7,835,984
91,385,965
99,221,949

To be
operated
1
5
6

127

COMPTROLLER'S DECISION

On March 31, 1970, The Citizens Bank of Wind
Gap, Wind Gap, Pa., and Easton National Bank
and Trust Company, Easton, Pa., applied to the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
Easton National Bank and Trust Company, with
IPC deposits of $74 million, was organized as The
Easton Bank in 1814, and assumed its present title
in 1959, after a merger with Easton Trust Company.
Through its branch system of five offices, including
one approved but unopened branch, the bank
serves Northampton County and portions of Bucks,
Carbon, Lehigh, and Monroe counties, in Pennsylvania, and Hunterdon and Warren counties, in
New Jersey.
The Citizens Bank of Wind Gap, with IPC deposits of $6 million, is a unit bank serving northcentral Northampton County and south-central
Monroe County. Since its organization in 1915, it
has not been involved in any mergers, consolidations, or acquisitions of assets.
Both banks are located in or near Pennsylvania's
Lehigh Valley, one of the most progressive and
stable areas in Pennsylvania, which has an economy
that draws support from industrial, agricultural,
and recreational activity. Large metropolitan area
banks, most notably the Philadelphia banks, have
entered this area either through merger or de novo
branching; thus the $1.6 billion Girard Trust
Bank, Philadelphia, Pa., operates a branch 8 miles
south of Easton, at Riegelsville, while Industrial
Valley Bank and Trust Company, Jenkintown, Pa.,
the State's 13th largest bank, with $377 million in
deposits, entered the market area in December 1968,
through its merger with Lehigh Valley Trust Company of Allentown. More recently, the Bank of
Pennsylvania, Reading, Pa., established itself in
Allentown through de novo branches. The intense
competition that has developed among those banks,
and others native to Allentown and Bethlehem,
has had a significant effect upon the competitive
picture in Easton, where potential customers have
been exposed to extensive advertising campaigns
and personal solicitations from outside banks. Excellent transportation facilities in the Lehigh Valley
have accelerated the economic integration of the
three cities and have contributed to the intense
banking competition in the area.
Additional competition also emanates from New
128




Jersey and New York City. Under New Jerseys'
new banking laws, the 93 banks in the northern
district are now empowered to establish branch
offices, or to merge with banks, in an area from
Jersey City, in the most eastern part of the State,
to Phillipsburg, on the western boundary. This
region borders Pennsylvania and the eastern end
of the Lehigh Valley area, only 18 miles from the
head office of the charter bank. Intense competition
may be expected as those New Jersey banks locate
offices adjacent to the eastern border of the area.
Moreover, only 68 miles east of the Northampton
County, Pa., line lies New York City and its large
metropolitan banks, with which a number of business and industrial concerns in the Lehigh Valley
area maintain banking connections because of the
lack of size and financial resources of local institutions.
While the participating banks' service areas overlap to some extent, there does not appear to be 3
significant degree of competition between them,
due to the presence of alternative sources of banking
services, and the generally unaggressive quality of
competition offered by the merging bank. The nearest alternate sources of banking services to the
merging bank are located 3 miles to the east in
Pen Argyl where The Pen Argyl National Bank,
with deposits of $11 million, and The First National
Bank of Pen Argyl, with deposits of $5 million
maintain their headquarters. One mile further to
the east are offices of the $20 million First National
Bank of Bangor and the $17 million Merchants
National Bank of Bangor. About 10 miles to the
north, in Stroudsburg, are the Monroe Security
Bank and Trust Company, with deposits of $31
million, and The First Stroudsburg National Bank,
with $29 million in deposits. Altogether, there are
offices of eight banks, with deposits ranging from
$5 million to $35 million, within 10 miles of the
merging bank.
The merger of the two banks will benefit the
customers of the merging bank. Upon consummation of the merger, the resulting bank will offer new
banking services such as trust and estate planning,
investment counseling, credit card programs, and
a more sophisticated lending department offering
instamatic check-credit programs. Automation will
provide customers with faster reporting and more
frequent account statements. In addition, the merger will provide management succession to the
merging bank.

Applying the statutory criteria, we find that the
proposed merger is in the public interest. The application, therefore, is approved.
JUNE 24,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the two banks are about 10
miles apart; one banking office intervenes directly.
It would appear that the merger will eliminate a
limited amount of direct competition between the
two banks.
Easton Bank has received approval to open an

office in Forks Township, about 7 miles south of
Wind Gap. No banking offices would intervene
directly between this office and Wind Gap Bank.
Thus, the merger would eliminate the potential for
increasing competition between the banks in northeastern Northampton County. Because of the relatively small size of Wind Gap Bank, however, as
well as the existence of other Northampton County
banks of substantial size which could branch into
this part of the county, the effect of the merger
upon potential competition would not be substantially adverse.

NATIONAL BANK AND TRUST COMPANY, CHARLOTTESVILLE, V A . , AND T H E NATIONAL BANK OF ORANGE, ORANGE, V A .

Banking offices
Total assets

Name of bank and type of transaction

The National Bank of Orange, Orange, Va. (5438), with
and National Bank and Trust Company, Charlottesville, Va. (10618), which had. .
merged Aug. 31, 1970, under charter and title of the latter bank (10618). The
merged bank at date of merger had

COMPTROLLER S DECISION

On April 17, 1970, The National Bank of
Orange, Orange, Va., and National Bank and Trust
Company, Charlottesville, Va., applied to the Office
of the Comptroller of the Currency for permission
to merge under the charter and with the title of the
latter.
National Bank and Trust Company, Charlottesville, Va., with IPC deposits of $78.8 million, was
organized in 1914. It now operates six offices in
Charlottesville, and offices in 10 widely scattered
communities in five counties in central Virginia.
The charter bank, although a regional institution,
derives the preponderance of its deposits from the
Charlottesville and Albemarle County areas.
Charlottesville, home office city of the charter
bank and the site of six of its branches, is located
near the geographic center of Albemarle County
in central Virginia. The bank's CharlottesvilleAlbemarle County service area had an estimated
July 1966 population of 74,900. The chief economic
support for this area derives from the presence of
the University of Virginia, which had a 1969-70
enrollment of over 9,000, and various related enterprises. Tourism also provides significant support to
the local economy, with Monticello, the home of




$16,090,627
102,033,911
124,566,561

In
operation

To be
operated

4
16
20

Thomas Jefferson, a major attraction. Manufacturing activities and farming, especially livestock raising, are also important sources of employment in
the area in which the bank operates.
Within its service area, the charter bank faces
active competition from 14 other banks, including
the State's three largest. In the Charlottesville area,
where the charter bank derives most of its business,
three competing banks operate 12 offices, of which
the Virginia National Bank, Norfolk, Va., the
State's largest bank, operates six. Additional competition derives from other financial institutions,
including two savings and loan associations, insurance companies, credit unions, sales finance companies, personal loan companies, and direct lending
agencies of the Federal Government.
The National Bank of Orange, Orange, Va., with
IPC deposits of $13.7 million, was organized in
1892. Besides its main office in Orange, it operates
a branch in the local shopping center and has
applied for approval to establish branches in Gordonsville and in the vicinity of Locust Grove, both
in Orange County. The merging bank's limited
training program makes it difficult to provide for
management succession, and to maintain the level
of specialization necessary for some services.
19Q

The merging bank serves the town of Orange
and surrounding portions of Orange County.
Orange County lies adjacent to Albemarle County
and has an estimated population of 13,453, up from
12,900 in 1960. The town of Orange is the largest
incorporated community in Orange County, and
has a population of approximately 3,000. Agriculture has historically been the underlying economic
support of the county, with the raising of beef
cattle, horses, and dairy products the chief sources
of income. In recent years, some light industry has
moved in to add economic diversification to the
county. More recently, farming has been giving way
to substantial recreational and residential real
estate development, particularly in the eastern portion of the county. Germanna Community College,
also in the eastern portion of the county, is scheduled to open in September 1970, with an initial
student enrollment of 600, and a faculty and staff
of 200.
The business of the merging bank has been confined primarily to Orange County. Expansion has
been inhibited by its rather limited lending base
and the keen competition from the Orange and
Gordonsville branches of the Virginia National
Bank, coupled with strong competitive pressures
exerted by the larger banks at Fredericksburg and
Culpepper. The merging bank is fifth largest of the
eight banks operating in its service area.
This merger will benefit the Orange County area
by introducing a stronger bank more capable of
offering a wider range of sophisticated services, with
depth in management, in substitution for the
smaller, less capable merging bank. The larger
lending limit and broad experience of the resulting
bank's management will be a distinct advantage to
the Orange and Orange County area.
Competition will not be adversely effected. Since
the nearest offices of the two banks are 16 miles
apart, and their service areas do not overlap, there
is no significant competition between them.
Although the proposed merger would eliminate
The National Bank of Orange, there would be no
diminution in banking choices available to the
public and no undue concentration of banking
assets would result. The charter bank's share of
deposits in the State will increase only slightly from
0.8 percent to 1.0 percent, while in its present
service area its competitive ability will not be appreciably affected. Future competition will not be

130




affected as Virginia State branching restrictions
prohibit the charter bank from branching into
Orange County, and prohibit the merging bank
from branching beyond the borders of Orange
County.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application, therefore, is approved.
JULY 6,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest branch of NBT is 16 miles from a
branch (or proposed branch) of Orange Bank. The
only other bank in Orange County is Virginia National Bank, with deposits in its Orange County
branches of about $16 million. There would appear
to be a limited amount of direct competition between Orange Bank and NBT's office in Madison,
located about 16 miles northwest of Orange. The
proposed merger would eliminate this existing
competition as well as potential competition which
could develop between Orange Bank's proposed
Gordonsville branch and NBT's Charlottesville
offices—the distance between them being about 18
miles.
State law does not permit branching beyond the
county in which the bank is located. A bank can
establish branches elsewhere by merger with banks
located in other counties. While NBT has branches
located throughout the region, it could enter
Orange County only by merger, or by becoming a
holding company and chartering a bank in Orange
County. Orange County has only moderate growth,
however, and there are several other potential
entrants in this manner.
Although two of the State's largest banks operate
offices in this general section of Virginia, NBT has
a very strong position in the counties surrounding
Charlottesville. If the proposed merger is approved,
NBT and Virginia National Bank will be the only
commercial bank alternatives in Greene, Madison,
Orange, Louisa and Fluvanna counties, which
together separate the Charlottesville area from Culpepper and Fredericksburg to the northeast.
The proposed acquisition would eliminate a
limited amount of existing competition as well as
some potential for increased direct competition.
For these reasons, the proposed merger may have
and adverse effect on competition.

MIDLAND NATIONAL BANK, MILWAUKEE, WIS., AND THE HOME BANK, MILWAUKEE, WIS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Home Bank, Milwaukee, Wis., with
and Midland National Bank, Milwaukee, Wis. (15510), which had
merged Sept. 1, 1970, under charter and title of the latter bank (15510). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On June 10, 1970, The Home Bank, Milwaukee,
Wis., and Midland National Bank, Milwaukee,
Wis., filed an application with the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
The Home Bank, Milwaukee, Wis., was chartered
by the State of Wisconsin in 1910. As of December
31, 1969, The Home Bank had total deposits of $24
million, which equals about 0.8 percent of the total
deposits in the Milwaukee market area. Located in
the inner core area of Milwaukee, this bank is
suffering from a continuing decline in deposits as
an increasing number of its customers relocate to
other sections of the city.
Midland National Bank, Milwaukee, Wis., was
organized in May 1965. As of December 31, 1969,
it had $66 million in total deposits, and ranked
sixth, with 2.3 percent of the total deposits in the
Milwaukee market area. Midland National Bank is
located in the downtown business district of Milwaukee, 15 blocks south of The Home Bank.
Although somewhat undercapitalized, it has deferred a capital increase program pending the outcome of this merger application.
Milwaukee is a large industrial center located
near the geographic and population center of the
country. The population of the metropolitan area
is approximately 1.4 million. Manufacturing is the
most important activity, with machinery and electrical machinery ranking first and second in employment, while the food and beer industry ranks third.
Milwaukee, located on the Great Lakes-St. Lawrence Seaway, serves 200 cities in 20 midwestern
states and two provinces of Canada.
There is no competition between the merging
banks since they have been associated for several
years by virtue of their common ownership.
Consummation of the merger will insubstantially




To be
operated

$24,740,760
78,826,911
100,572,816

increase Midland National Bank's share of the
total deposits in the Milwaukee market area, and
will move it from sixth to fifth position. The merger
will strengthen Midland National Bank's capital
structure and increase its lending limit, thereby
putting it in a better position to serve the needs of
its customers and to compete with the larger banks
in Milwaukee.
State law does not permit the present office of
The Home Bank to be maintained as a branch of
the merged bank. However, the approval of a State
charter for the North Milwaukee State Bank, to be
located within the inner city, would appear to fill
the void created by the closing of the office of the
merging bank, and provide banking services especially attuned to the needs of the neighborhood
residents.
Applying the statutory criteria, we find the proposal is in the public interest. The application is,
therefore, approved.
JULY 22,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The two banks are located 15 blocks apart. The
merger will eliminate some direct competition between the banks. An offsetting consideration is that
it is proposed to sell the premises of Home Bank
to a new bank which is presently seeking a charter.
This new bank will have predominantly black
ownership and management, in keeping with the
character of the area in which Home's office is
located. The merger will not, therefore, necessarily
reduce the number of banks in Milwaukee.
Milwaukee banking is dominated by the "Big
Three"—First Wisconsin, Marshall and Ilsley, and
the Marine Corporation—which hold 74 percent of
Milwaukee deposits. This merger would increase
Midland's deposits share from 2.3 percent to 3.1
percent of Milwaukee deposits.
131

The proposed merger will eliminate some competition and increase concentration slightly, but it
will also facilitate the creation of a new bank which

may be better able to serve the area. Accordingly,
we conclude that the proposed merger is not likely
to have substantial adverse effects on competition.

GARLTON NATIONAL BANK, CARLTON, MINN., AND THE FIRST NATIONAL BANK OF GARLTON, CARLTON, MINN.
Banking offices

Total assets

Name of bank and type of transaction

To be
operated

In
operation

The First National Bank of Garlton, Garlton, Minn. (6973), with
was purchased Sept. 9, 1970, by Garlton National Bank, Garlton, Minn. (15825),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

An application was made to the Comptroller of
the Currency for permission for the Carlton National Bank, Carlton, Minn., to purchase assets and
assume the deposit liabilities of The First National
Bank of Carlton, Minn.
In accordance with the provisions of 12 U.S.C.
181 and 12 U.S.C. 1828 (c), it is found that an

$6,803,122

1

350,000
6,614,372

1

1

emergency exists and that this Office must act immediately to prevent the probable failure of The
First National Bank of Carlton and to protect its
depositors, creditors, and shareholders.
Accordingly, the application is, hereby, approved.
SEPTEMBER 8, 1970.
NOTE: Due to the emergency nature of the situation, a
report on the competitive factors was not requested.

NATIONAL BANK OF SOUTH DAKOTA, SIOUX FALLS, S. DAK., AND SECURITY BANK, MADISON, S. DAK.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

Security Bank, Madison, S. Dak., with
and National Bank of South Dakota, Sioux Falls, S. Dak. (12881), which had. . .
merged Sept. 10, 1970, under charter and title of the latter bank (12881). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On June 17, 1970, the Security Bank, Madison,
S. Dak., and the National Bank of South Dakota,
Sioux Falls, S. Dak., applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
The National Bank of South Dakota, Sioux Falls,
S. Dak., was organized in 1926, and in 1931 became
an affiliate of First Bank System, Inc., a registered
bank holding company with headquarters in Minneapolis, Minn. This bank, with IPC deposits of
$141.1 million and 14 branches at locations
throughout the State, is the largest in South Dakota.
132




$10 ,47? ,960

191 ,741 ,613
202 ,214 ,573

1
14

15

The Security Bank, Madison, S.Dak., was organized in 1896, and operates from one office in Madison. It holds IPC deposits of $8.3 million. The relatively low lending limit of the merging bank has
required it to meet the borrowing needs of its
larger customers by selling participations. In general, the bank's customer services are relatively
limited. With the exception of the president, all
officers of the bank are beyond normal retirement
age, and the bank must provide for successor management.
The market area of the Security Bank is the town
of Madison and surrounding Lake County, which

is almost completely agricultural. Madison, which
is the only town in Lake County with a population
in excess of 300, has a population estimated at 6,300,
of whom 1,300 are students at a local State college.
The National Bank of South Dakota's nearest
office to Madison is in Sioux Falls, 48 miles southeast of the merging bank. In addition, the charter
bank's existing affiliates do not operate in the Madison area. There is, therefore, no competition between the participating banks or between the merging bank and the holding company affiliates of the
charter bank. Approval of this application will not
eliminate potential competition since the charter
bank is unable, under State law, to establish de novo
branches in Madison, while the provisions of federal banking law would not allow First Bank Systems, Inc., to charter a new bank in this town.
Consummation of the merger will provide the
Lake County market area with another full-service
bank offering a broader range of services, including
computer services and expanded trust services, as
well as a larger lending capacity. In addition, the
merging bank's management succession needs will
be supplied from the charter bank's management
trainee pool. As a branch of the charter bank, the
resulting bank will compete more effectively with
the Madison branch of the Northwestern National
Bank of Sioux Falls, a subsidiary of Northwestern
Bancorporation, the Nation's fifth largest registered
bank holding company.

Applying the statutory criteria to the proposed
merger, we conclude that it will serve the public
interest. The application is, therefore, approved.
AUGUST 11,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Madison is located 49 miles from the nearest
office of the National Bank, which is also the nearest office of any subsidiary of First Bank Systems,
Inc. The distance between the merging banks and
the presence of other banks in the intervening area
indicates that no substantial existing competition
will be eliminated by the proposed merger.
National Bank is the largest bank in the State.
It has the size and resources necessary to make de
novo entry into any area of the State which it
wishes to serve.
South Dakota State law would, however, prohibit National Bank from branching de novo into
Madison; but it could enter the area by branching
into any of several towns in Lake County which
have no banking offices. Given the size and potential of the county, establishment of such offices is
doubtful.
In addition, this merger is a not insubstantial
addition to the dominant banking organization in
the State which will have the effect of making it
more difficult to create new banking organizations
able to compete throughout the State.

OLD NATIONAL BANK OF WASHINGTON, SPOKANE, WASH., AND NORTH WEST BANK, SEATTLE, WASH.
Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

North West Bank, Seattle, Wash., with
and Old National Bank of Washington, Spokane, Spokane, Wash. (4668), which
had
merged Sept. 25, 1970, under charter and title of the latter bank (4668). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On March 31, 1970, the Old National Bank of
Washington, Spokane, Wash., applied to the Office
of the Comptroller of the Currency for permission
to merge with North West Bank, Seattle, Wash.,
under the charter and with the title of the former.
The Old National Bank of Washington was




$15,998,718

2

316,064,001

40

332,062,719

42

organized in 1891. It now holds IPC deposits of
$242.4 million, and operates 39 branches. Since the
late 1950's, the charter bank has been expanding
throughout eastern Washington, especially in the
Tri-Cities and Columbia Basin regions. In the
State of Washington, such expansion can occur only
by merger, as a bank may not open a de novo
133

branch outside its headquarters city or town into
a community where another bank already exists.
Old National Bank has been operating exclusively
in the eastern part of the State, but due to its expansion it has been actively competing for a number
of years with statewide branch banking systems
headquartered in Seattle.
The charter bank has its headquarters in Spokane, Wash., the second largest city in the State,
which has a population of about 300,000. Spokane
is 288 miles east of Seattle, across the Cascade Mountain range in the generally arid part of the State.
The economy of the eastern part of the State is
based principally on agriculture, although there
is some lumbering activity in the northeast sector.
The Columbia Basin Irrigation Project has opened
many acres for farming in this half of the State,
and continued progress in the extension of farmland
through irrigation is expected. Spokane is also considered to be the heart of the Inland Empire, which
includes eastern Washington, northern Idaho, and
western Montana. Agriculture, lumbering activity,
light manufacturing, mining, military installations,
and retail and wholesale trade activity provide
diversification and stability to an economy which
has good prospects.
North West Bank was organized in April 1963.
During its first five years of operation, the bank
experienced substantial asset problems; however,
operations have improved since 1968, under new
management. Because the bank's trade area is highly
competitive, its growth has been slow. Deposits have
remained steady at $12 million since 1964. Its lending limit of $273,000 is too small to service the needs
of many local businesses, most of which operate on
a national scale; consequently, it is primarily a retail bank. North West Bank opened its first branch
in March 1970, also in the downtown area.
North West Bank, Seattle, Wash., is located in
the central retail and financial district of downtown Seattle, in the western part of the State. The
economy west of the Cascades is based on lumbering activity, forest products, the aerospace industry,
manufacturing, retail, and international commerce.
The population and economy of western Washington has expanded rapidly during recent years, but
present data indicate that the expansion has
peaked, and a moderate decline is expected in 1970.
Sharp cutbacks at Boeing Company, and a depressed
lumber market are primary causes for the decline.
As there is presently no competition between the
applicant banks, the proposed merger will not
134




diminish competition. A larger lending limit will
enable the resulting bank to serve larger retailers
in the Seattle area, and allow it to provide additional banking services, including trust services,
credit card services, international trade services, and
automobile dealer financing. The projected decline
of the economy in western Washington will not
affect it when offset by the anticipated growth of
the economy in the area of the charter bank.
Approval of the application will enable the
charter bank to compete more aggressively with the
four large statewide branch banking systems operating out of Seattle and Tacoma, including the
Seattle-First National Bank, Seattle, Wash., National Bank of Commerce of Seattle, Seattle, Wash.,
Washington Mutual Savings Bank, Seattle, Wash.,
Peoples National Bank of Washington, Seattle,
Wash., and National Bank of Washington, Tacoma,
Wash. The resulting bank will hold only 5.7 percent of the deposits and 5.3 percent of the loans
in the State. Strong competition is felt throughout
the State from savings and loan associations, finance
companies, personal loan companies, credit unions,
government lending agencies, insurance companies,
and factors.
Charter bank will be the first bank headquartered in eastern Washington to enter the banking
market of western Washington.
The expansion of the charter bank into a statewide system will greatly enhance banking competition. It is concluded that the proposal is in the
public interest and meets the relevant statutory
criteria. The merger is, therefore, approved.
AUGUST 12,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are 120
miles apart. Consequently, it would not appear that
the proposed merger would eliminate any significant direct competition between the participants.
It would, however, bring about competition between Old National, the State's fifth largest commercial bank, and the big Seattle-based banks
which include Washington's three largest commercial banks (two of which have deposits in excess
of a billion dollars).
Under Washington law, entry of another bank
into Seattle by de novo branching is prohibited. A
bank not presently located in Seattle could enter
only by acquiring an existing bank in the area, or
by affiliating with a holding company which could
then charter a new bank there. Old National is

an affiliate of Washington Bancshares, which has
the resources and capability to charter a new bank
in the Seattle area.
However, entry by such a de novo chartering
would be only slightly more procompetitive than
this proposed acquisition, in view of North West

Bank's very small share of the Seattle commercial
banking market.
We conclude, therefore, that the proposed merger
is not likely to have an adverse effect on competition.

T H E PARK NATIONAL BANK OF NEWARK, NEWARK, OHIO, AND T H E PEOPLES STATE BANK,
GRANVILLE, OHIO

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The Peoples State Bank, Granville, Ohio, with
was purchased Sept. 28, 1970, by The Park National Bank of Newark, Newark,
Ohio (9179), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On January 14, 1970, The Park National Bank
of Newark, Newark, Ohio, applied to this Office for
permission to purchase the assets and assume the
liabilities of The Peoples State Bank, Granville,
Ohio. Both banks are located in Licking County
which has a population of approximately 109,000
and is situated near the geographical center of
Ohio.
Newark, the home office city of charter bank, is
located in the south central portion of the county
and has a population estimated at 47,000. The buying bank operates two branches in Newark and
one each in Heath, Hebron, and Kirkersville.
Charter bank has IPC deposits of $56 million.
The selling bank, The Peoples State Bank, is a
unit bank located in Granville, 7 miles west of
Newark. Granville has a population of approximately 3,500. The bank has IPC deposits of approximately $8.8 million, a lending limit of $55,000,
and is the only bank in Granville.
In addition to the purchasing bank, Newark is
served by the $51 million First National Bank of
Newark, an affiliate of BancOhio Corporation, a
registered bank holding company located in Columbus, and by the $47 million Newark Trust Company, which is owned by Citizens Financial Corporation, a conglomerate operating primarily in the
financial field. There are five other unit banks in
Licking County, one each in Alexandria, Croton,
Johnstown, Pataskala, and Utica. Two small out-




$11,856,469

1

75,858,814
87,715,283

6

7

of-county institutions, near Licking County's southern border in the small towns of Millersport and
Thornville, also serve the county.
Although commercial banking competition is
measured largely on a county-wide basis in Ohio,
the small banks mentioned in the previous paragraph compete in Licking County, and increasing
competition from the large Columbus banks has
been noted. The acquisition will not affect the
banking structure in Newark to any significant extent. It will, however, replace the relatively unaggressive, locally-owned bank in Granville with a
branch of the Newark-based aggressive and progressive charter bank. The two banks do not compete
to any great extent; a study of the business drawn
by buying bank in the Granville area indicates that
most of this business is not sought out on a competitive basis. Since the population of Granville is
only 3,500, and it is served by the selling bank and
will be served by a branch of The First National
Bank of Newark, which has recently received permission to establish a branch in Granville, the number of banking offices in relation to the population
indicates that Granville is more than adequately
banked. This factor would prevent the buying bank
from establishing a de novo branch in Granville.
Therefore, potential competition between the applicant banks is not a factor in this proposal. Furthermore, the lending services offered by both banks are
complementary rather than competitive. The buying bank lends heavily to commercial enterprises
135

and to consumers, while the selling bank has a
majority of its lending portfolio in residential real
estate loans and farm loans.
In evaluating the competitive effects of the
proposal, competition from savings and loan associations must be considered. As of June 30, 1969,
deposits in savings and loans in Newark were 43
percent as large as commercial bank deposits. Approximately 40 percent of real estate mortgage
loans made in Licking County during 1968 were
made by savings and loan associations. Savings and
loan associations are even more active in Columbus,
which captures a degree of the Licking County
market. Another factor worthy of note is that, although the buying bank is the largest commercial
bank in Licking County, it is the smallest independent commercial bank in the town of Newark.
The acquisition will benefit the citizens of Granville in that modern, specialized services will be
available. Computer services will be offered to the
customers of the Granville bank, a bank credit card
will be introduced, and trust services will become
available. Furthermore, internal banking problems
will be modified. Bookkeeping will be automated
and the management successor deficiencies will be
obviated.
In taking all of these factors into consideration,
it appears that the proposal is in the public interest
and it is, therefore, approved.
JULY 17,

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the two banks are 7 miles
apart, and Park National derives a not insubstantial amount of business from Granville, where the
sole office of Peoples Bank is located.
Ohio law permits only county-wide branching,
and commercial banking is highly concentrated in
Licking County, where all the offices of the merging banks are located. The three largest banks hold
84 percent of county-wide total deposits. Peoples
Bank holds the fourth largest share of county total
deposits, with about 7 percent, and the fifth largest
share of IPC demand deposits, with about 5 percent of the county-wide totals. As a result of the
proposed merger, Park National, the county's largest bank would increase its share of county-wide
IPC demand deposits from 44 percent to 48 percent,
and its total deposit share would increase from 39
percent to 45 percent. Such increases in concentration are particularly harmful in light of restrictive
State law in regard to branching.
The proposed merger will eliminate direct competition, increase concentration, and eliminate Peoples Bank as an independent competitor in an area
where continued economic growth is expected. Accordingly, we conclude that the proposed merger
would have a significantly adverse effect on competition.

1970.

MARINE NATIONAL BANK, ERIE, PA., AND T H E FIRST NATIONAL BANK OF EDINBORO,
EDINBORO, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Edinboro, Edinboro, Pa. (7312), with
and Marine National Bank, Erie, Pa. (870), which had
merged Sept. 30, 1970, under charter and title of the latter bank (870). The
merged bank at date of merger had

COMPTROLLER S DECISION

On June 17, 1970, The First National Bank of
Edinboro, Edinboro, Pa., and the Marine National
Bank, Erie, Pa., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
The Marine National Bank, with IPC deposits of
136




$10,464,946
118,134,273
128,599,219

To be
operated

2
10
12

$92 million, is headquartered in Erie, Pa., and presently operates 11 branches in north-central and
western Erie County and western Crawford County.
In addition, the bank has three approved but unopened branches, one of which will be situated in
Meadville, Pa., where the charter bank recently
was granted approval to relocate its head office.

The charter bank is an aggressive, well-managed,
growing institution. Under new management since
1964, the bank has more than doubled its total resources to the present level of $113 million.
The First National Bank of Edinboro, with IPC
deposits of $8 million, was organized in 1904, and
operates its head office in Edinboro, Pa., and a
branch office in neighboring McKean, Pa. The
merging bank has one approved but unopened
branch and is presently the only commercial bank
located in the immediate vicinity of Edinboro. The
National Bank of North East, North East, Pa., recently was granted approval to establish a branch
in Edinboro. Although the merging bank has
grown during recent years, that growth has not
been as spectacular as that of charter bank. The
market area of the merging bank encompasses the
borough of Edinboro and Washington Township.
Edinboro is located 18 miles south of Erie, Pa., and
25 miles north of Meadville, Pa.
Competition between the participating banks is
nominal. Few customers of the charter bank reside
or do business in the merging bank's service area.
None of the customers of the merging bank transact business with the charter bank, except in cases
where the merging bank has requested the charter
bank to participate in overline loans. Approval
of this merger will not have the effect of foreclosing
potential competition as the merging bank lacks
the resources to penetrate the charter bank's market
area, and because it appears doubtful that the area
served by the merging bank could support de novo
branch entry by the charter bank. After the merger
is consummated, the resulting bank will increase
its rank from fifth to fourth largest bank in the

OLD

combined Erie-Crawford County market area, and
will be a more effective competitor to the larger
banks.
The proposed merger will replace a small, unaggressive, country bank with a larger institution
which will provide the customers of the merging
bank with a broader range of banking services.
They will include a larger lending limit, lower
service charges, trust services, bank credit card services, greater availability of funds for consumer
lending, automation, and data processing services.
Applying the statutory criteria, we find the
merger is in the public interest, and the application, therefore, is approved.
AUGUST 13,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are
located about 6 miles apart. According to the application, Marine National draws only a limited number of accounts from the Edinboro market area.
However, the proximity of Edinboro Bank's
McKean office to Erie indicates that increasing competition between the banks is likely.
As of June 30, 1968, nine commercial banks operated 41 banking offices in Erie County. Marine
National, with 17.9 percent, held the third largest
share of total deposits held by such banks, while
Edinboro Bank held the eighth largest share, with
about 1.8 percent.
In view of the proximity of the merging banks
and the increase in concentration of banking in
Erie County, we believe that the proposed merger
may have an adverse effect on competition.

NATIONAL BANK OF WASHINGTON, SPOKANE, WASH., AND FIRST NATIONAL BANK IN TONASKET, TONASKET, WASH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank in Tonasket, Tonasket, Wash. (14166), with
was purchased Sept. 30, 1970, by Old National Bank of Washington, Spokane,
Spokane, Wash. (4668), which had
After the purchase was effected, the receiving bank had




To be
operated

$9,455,004

1

295,570,266
305,025,270

42
43

137

COMPTROLLER S DECISION

On September 25, 1970, application was made
to the Comptroller of the Currency for permission
for the Old National Bank of Washington, Spokane, Spokane, Wash., to purchase assets and assume the deposit liabilities of the First National
Bank in Tonasket, Tonasket, Wash.
In accordance with the provisions of 12 U.S.C.
181 and 12 U.S.C. 1828 (c), it is found that an

emergency exists and that this Office must act
immediately to prevent the probable failure of the
First National Bank in Tonasket and to protect
its depositors, creditors, and shareholders.
Accordingly, the Old National Bank of Washington, Spokane, Wash., is authorized to proceed
with the purchase and assumption transaction.
SEPTEMBER 25,

1970.

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

ZIONS FIRST NATIONAL BANK, SALT LAKE CITY, UTAH, AND BOUNTIFUL STATE BANK,
BOUNTIFUL, U T A H

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Bountiful State Bank, Bountiful, Utah, with
was purchased Sept. 30, 1970, by Zions First National Bank, Salt Lake City, Utah
(4341), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On May 28, 1970, Zions First National Bank,
Salt Lake City, Utah, applied to the Office of the
Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of
Bountiful State Bank, Bountiful, Utah.
Zions First National Bank, Salt Lake City, Utah,
with IPC deposits of $184 million, was organized in
1873. This bank, a subsidiary of Zions Utah Bancorporation, concentrates its activities in the Salt
Lake City area. It also has offices in Spanish Fork,
some 65 miles south of Salt Lake City; in Heber
City, 50 miles southeast; in Provo, approximately
45 miles south; and in St. George, some 300 miles
south.
Salt Lake City, Utah, is the county seat of Salt
Lake County, and is the State's capital. With a
population of almost 200,000, it ranks as Utah's
largest city. The Salt Lake City Metropolitan Area,
including the southern part of Davis County, where
the selling bank is located, is Utah's major population, commercial, and industrial area, and has a
population of about 500,000. The economy of the
area is widely diversified, and includes mining,
manufacturing, transportation, agriculture, commerce, and military activity. Salt Lake City is the
home of the Mormon Church and the University
138




To be
operated

$12,860,037

3

272,307,425
285,167,462

22
25

of Utah, which has an enrollment of 21,000. Numerous defense projects are located in Salt Lake
County, and Hill Air Force Base, the largest employer in the State, with 18,000 civilian employees,
lies 25 miles to the south. In the immediate Salt
Lake City area, the largest employer is Kennecott
Copper Corporation, which employs about 7,000.
Primary banking competition for the purchasing
bank emanates from the $594.5 million First Security Bank of Utah, N.A., Salt Lake City, Utah, and
the $308.1 million Walker Bank and Trust Company, Salt Lake City, Utah, the State's first and
second largest banks.
Bountiful State Bank, Bountiful, Utah, with IPC
deposits of $10.6 million, was organized in 1906.
It operates two branches, one at North Salt Lake
and one at Centerville.
The primary service area of the Bountiful State
Bank is the southern part of Davis County, including the communities of Bountiful, West Bountiful, North Salt Lake, Centerville, Woods Cross,
and, to some extent, Farmington, the county seat.
The center of this area is approximately 10 miles
north of the central business district of Salt Lake
City. In 1960, Bountiful had a population of 17,000,
which has increased to 27,800, according to 1970
preliminary census data. Davis County has grown

by 34,000 people since 1960, when its population
was 64,780. The Bountiful area is a "bedroom"
community for persons employed in Salt Lake City
and the manufacturing concerns in or near the
area. Hill Air Force Base, which, as previously
mentioned, is the State's largest employer, dominates the county's economy. Manufacturing activity
has superseded agriculture and trade to become
the county's second most important industry. Oil
refineries in the area employ 1,300 persons. The
principal competitors of the Bountiful State Bank
are the Farmers State Bank, Woods Cross, Utah,
with deposits of $12.7 million, and the South Davis
Security Bank, Bountiful, Utah, with deposits of
$6.6 million. In addition to the other banks operating in Davis County, competition derives from
offices of savings and loan associations, industrial
loan corporations, small loan companies, and credit
unions.
This purchase and assumption transaction will
benefit the Bountiful area by introducing services
hitherto unavailable, including trust services and
complete electronic data processing services. The
purchasing bank will be better able to serve the
credit needs of the Bountiful community with its
larger lending limit and broader experience in all
types of lending activity, as well as through the
wider variety of banking services it offers.
Competition will not be adversely affected by
consummation of this transaction. Although the
Bountiful State Bank is located in the broader Salt
Lake City Metropolitan Area, the participating
banks' nearest offices are 10 miles apart, and there
is little present competition between them. The
purchasing bank will remain the third largest bank
in the State and its proportionate share of deposits
will increase only slightly. It will be in a slightly
stronger competitive position with respect to the

State's two largest banks, which are considerably
larger than it. Potential competition will not be
affected since the purchasing bank is unable, under
State law, to branch de novo into Davis County,
where the selling bank's service area is located.
It is concluded in the light of the statutory
criteria, that the proposal is in the public interest.
The application is, therefore, approved.
AUGUST 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

This merger involves one of the three largest
banking organizations in Utah, and one of the
largest banks in southern Davis County. According
to the application, the home offices of the banks are
12 miles apart. However, North Salt Lake, site of a
BSB branch, is less than 5 miles northwest of Salt
Lake City, where Zions home office is located. The
only banking alternative between Bountiful and
Salt Lake City is a branch of the Bank of American
Fork.
BSB derives a limited amount of deposits from
Salt Like City. Zions derives "deposits on the order
of 2 percent of those held by banks situated in the
Bountiful area." Given that most residents of
Bountiful work in Salt Lake City, the two banks
provide clear alternatives to each other.
Hence, if the proposed merger is approved, some
existing competition will be eliminated. In addition, the merger would eliminate the possibility
of increased competition with BSB which Zions
would cause by entering any of the communities in
southern Davis County which are open to branching (i.e., any town without a bank headquartered
in it).
For these reasons, we conclude that the proposed
merger would have an adverse effect on banking
competition.

NATIONAL BANK OF NORTH AMERICA, N E W YORK, N.Y., AND FIRST NATIONAL BANK
IN YONKERS, YONKERS, N . Y .

Banking offices
Name of bank and type of transaction

First National Bank in Yonkers, Yonkers, N.Y. (13882), with
and National Bank of North America, New York, N.Y. (7703), which had
consolidated Oct. 13, 1970, under charter and title of the latter bank (7703). The
consolidated bank at date of consolidation had




Total assets
In
operation
$140,426,794
1,998,427,915
2,138,854,709

To be
operated

11
102
113

139

COMPTROLLER S DECISION

On June 21, 1970, First National Bank in Yonkers, Yonkers, N.Y., and National Bank of North
America, New York, N.Y., filed an application with
the Comptroller of the Currency for permission to
consolidate under the charter and title of the latter.
National Bank of North America, New York,
N.Y., was organized in 1905 as the First National
Bank of Freeport, and became the Meadow Brook
National Bank in 1949. In 1967, the Meadow Brook
National Bank was consolidated with the Bank of
North America under the charter of the former
and with its present title. The National Bank of
North America operates 99 offices in the city of
New York and the counties of Nassau and Suffolk.
Although it has IPC deposits of $1,166 million, and
ranks 10th among the 96 commercial banks in the
area, it is a medium size bank in its market area.
First National Bank in Yonkers, Yonkers, N.Y.,
was organized in 1933. As of December 31, 1969, it
had IPC deposits of $120 million, and ranked 52nd
among the 96 commercial banks in the area. The
bank operates 10 branches, all within the city of
Yonkers. This bank is undercapitalized, and has a
management succession problem. The three top
officers are in their seventies. All attempts to find
younger men who are qualified to succeed the present management have failed. In 1964, it attempted
to affiliate with the Chemical Bank New York
Trust Company, New York, N.Y. In 1969, it attempted to affiliate with a statewide holding company. Both attempts were rejected by the supervisory authorities on grounds not present in the
proposed consolidation.
The New York City Metropolitan Area, consisting of the five boroughs of New York City and
the counties of Nassau, Suffolk, and Westchester, is
the leading financial center in the United States.
Six of the 10 largest banks in the country are
located in the area, as are the principal offices of all
major insurance companies and investment banking and brokerage houses. In addition, many of the
Nation's major manufacturing companies are headquartered in the area. The population of the area
is approximately 11.5 million people.
Yonkers, with a population of 227,000 people, is
located in the southwest corner of Westchester
County, just north of the New York City line. It
contains many manufacturing concerns, and is an
important retail center for the Bronx and for Westchester County.
140




Consummation of the consolidation will increase
competition in the New York City area in general,
and in Yonkers in particular. It will increase National Bank of North America's share of the total
deposits of the New York City area only slightly,
from 1.80 percent to 1.94 percent.
New York State's "home office protection" law
prevents any bank except First National Bank in
Yonkers from opening an office in Yonkers until
First National Bank in Yonkers becomes affiliated
with a bank outside the city of Yonkers. The proposed consolidation would remove this barrier and
allow other banks to open branches in Yonkers. A
number of New York banks have made branch applications in anticipation of the approval of this
consolidation application.
The possibility of potential competition between
the subject banks appears to be slight. First National Bank in Yonkers could legally establish
branches in New York City, but its capital and
management limitations make this impractical.
Because the city of Yonkers is presently closed to
de novo branches, and because those possible
branch locations close enough to the city of Yonkers to provide competition to First National Bank
in Yonkers have been preempted by other banks,
there appears little likelihood of potential competition being created through branching by National
Bank of North America.
There is only a minimal amount of competition
between the two banks. Their nearest offices are 7
miles apart, with numerous banking facilities located between them. C.I.T. Financial Corporation,
of which National Bank of North America is a subsidiary, operates one small office in Westchester
County, approximately 7 miles from the nearest
branch of the First National Bank in Yonkers.
The combined bank will better serve the needs
of the public in Yonkers. More commercial, industrial, and home improvement loans, all of which
are especially important in an urban area, will be
available. The increased lending limit will allow
the combined bank to better serve the loan needs
of the area. The established international department of National Bank of North America will be
able to offer a full line of services to the businesses
in Yonkers. National Bank of North America has
a history of working to solve the problems in the
urban areas it serves. It has helped to develop and
attract new businesses, made loans to minority
group businessmen, and financed low and middle

income housing, all services which the Yonkers area
needs. The consolidation will also resolve the capital problem of the Yonkers Bank, as well as its
management succession problems.
Applying the statutory criteria, we find the proposal is in the public interest. The application is,
therefore, approved.
SEPTEMBER 9,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

National Bank of North America has no offices
in either the city of Yonkers or in Westchester
County; its closest office to an office of First Yonkers
is in the southern Bronx, 7 miles distant. Several
competing commercial banks operate offices in the
intervening area. National Bank of North America
may be considered a banking alternative for
Yonkers-Westchester residents who commute to
New York City. However, according to the application, the New York City offices of National Bank
of North America do limited banking business with
Yonkers-Westchester banking customers. In like
manner, Trade Bank and Trust Company, whose
closest offices to Yonkers are in midtown Manhattan, holds relatively few Yonkers-Westchester accounts. According to supplemental information
provided by the applicants, other subsidiaries of

C.I.T. Financial Corp. do not do substantial business in the service area of First Yonkers.
It would appear that the proposed consolidation
would eliminate no more than a limited amount of
direct competition.
Under New York law, National Bank of North
America could be permitted to open de novo
branch offices in Westchester County, but not in
any community wherein is located the head office of
any commercial bank not affiliated with a registered
bank holding company. Accordingly, the home
office of First Yonkers itself prevents National Bank
of North America (or any other commercial bank)
from branching in Yonkers. However, National
Bank of North America has the resources to enter
other sections of Westchester County de novo, as
have other major New York City banks, and indeed
is one of the largest eligible banks not yet operating
in the county.
The consolidation of First Yonkers and National
Bank of North America will open Yonkers to de
novo branching by banks headquartered in New
York City as well as any banks in New York's
Third Banking District. According to the application, a number of eligible banks are formulating
plans to enter Yonkers in this manner if the proposed consolidation is approved.

FIRST NATIONAL BANK OF SOUTH JERSEY, EGG HARBOR TOWNSHIP, N.J.,
BANK OF PEDRICKTOWN, PEDRICKTOWN, N J .

AND T H E FIRST NATIONAL

Banking offices
Total assets

Name of bank and type of transaction

The First National Bank of Pedricktown, Pedricktown, NJ. (8007), with
and First National Bank of South Jersey, Egg Harbor Township, N J . (1326),
which had
merged Oct. 30, 1970, under charter and title of the latter bank (1326). The
merged bank at date of merger had

COMPTROLLER S DECISION

On July 20, 1970, The First National Bank of
Pedricktown, Pedricktown, N.J., and the First
National Bank of South Jersey, Egg Harbor Township, N.J., applied to the Comptroller of the Currency for permission to merge under the charter
and with the title of the latter.
The First National Bank of South Jersey, Egg
Harbor Township, N.J., was organized in 1822,
and now holds IPC deposits of $207.8 million. The




In
operation

$6,273,493

2

285,013,575

25

291,287,068

To be
operated

27

bank operates 17 offices in Atlantic County, four
in Gloucester County, one in Salem County, and
another is approved but as yet unopened in Salem
County.
The First National Bank of Pedricktown, Pedricktown, N.J., was organized in 1905, and now
holds IPC deposits of $4.5 million. The bank's
home office is in Salem County and it operates one
branch in Gloucester County. In general, the merging bank's customer services are relatively limited,
141

The merging bank's $4.8 million in total deposits
represents 5.4 percent of Salem County's aggregate
deposits, and ranks the bank eighth in size among
the 10 commercial banks in Salem County.
Pedricktown, N.J., is a rural, unincorporated
town, with a population of 2,280, near the Delaware River, east of Wilmington, Del., and south of
Philadelphia, Pa. The market area of the merging
bank is gradually shifting from being predominantly agricultural into a manufacturing and residential economy. However, the bank's small lending limit of $55,000, and its lack of depth in management inhibit the bank from doing any substantial promotion of sizeable commercial banking business.
Banking competition in the Third Banking District, which is made up of five south-central New
Jersey counties, will not be adversely affected by
the proposed merger. The First National Bank of
South Jersey, with total assets of $258.9 million, is
the third largest bank in the Third Banking District. The two banks larger than the charter bank
each possess assets exceeding the charter bank's by
approximately $100 million. Competition between
the proponents is slight, as their home offices are
60 miles apart, and their nearest offices are 12 miles
apart. No potential competition between the participants will be eliminated as the merging bank's
limited resources would be likely to preclude its
expansion into the charter bank's market area, and
the charter bank cannot branch de novo into the
merging bank's market area as there is a "home
office" protection provision in New Jersey law.
Consummation of the proposed merger will not re-

duce the number of banking alternatives available
to the public, but will substitute for the merging
bank a full-service bank with a broad range of
services, as well as the management depth and
financial resources to serve commercial customers.
Applying the statutory criteria to the proposed
merger, we conclude that it will serve the public
interest. The application is, therefore, approved.
SEPTEMBER 28,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National's closest office to an office of Pedricktown Bank is located about 10 miles away, with
several other banks in the intervening area. It
would appear that the proposed merger would not
eliminate significant existing competition between
the two banks.
Pedricktown Bank serves primarily northwestern
Salem County and western Gloucester County in
the Third Banking District; accordingly, First National could be permitted to open de novo offices
in these counties except in communities that are
served by a head office of a bank or, where the
population is under 7,500, by a branch office of
a bank. Pedricktown and Logan Township are
both closed to de novo branching, but other communities in these counties are open to First National.
Pedricktown Bank holds about 5.9 percent of
total deposits held by commercial banks in Salem
County. In view of the size and relative market
position of Pedricktown Bank, we do not believe
that the proposed merger would have a significantly
adverse effect on potential competition.

HARTFORD NATIONAL BANK AND TRUST COMPANY, HARTFORD, CON IN., AND GENERAL BANK AND
TRUST COMPANY, N E W HAVEN, CONN.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
General Bank and Trust Company, New Haven, Conn., with
and Hartford National Bank and Trust Company, Hartford, Conn. (1338),
which had . . .
merged Oct. 30, 1970, under charter and title of the latter bank (1338). The
merged bank at date of merger had

COMPTROLLER'S DECISION

On June 25, 1970, General Bank and Trust Company, New Haven, Conn., and Hartford National
Bank and Trust Company, Hartford, Conn., ap142




$8,076,269

4

1 ,041,105,191

54

1 ,048,981,460

To be
operated

58

plied to the Comptroller of the Currency for permission to merge under the charter and with the
title of the latter.
The charter bank, with deposits of $821 million,

is the second largest bank in Connecticut. It was
orginally organized in 1792, and presently operates
50 branch offices that serve seven of the State's eight
counties.
The merging bank, with IPC deposits of $7 million, is the smallest bank in New Haven. It was
originally organized in 1928, and presently operates
one branch office in Hamden. The bank is faced
with a management succession problem. Direct
banking competition is provided by four of the
largest banks in the State: the Connecticut Bank
and Trust Company of Hartford, with deposits of
$830 million; the Union Trust Company of New
Haven, with deposits of $445 million; The First
New Haven National Bank, with deposits of $234
million; and the Second National Bank of New
Haven, with deposits of $160 million.
New Haven, with a population of about 141,000,
is situated on Long Island Sound, approximately
45 miles south of Hartford. Not only is it the leading retail center in south-central Connecticut, but
it is also an important seaport, and the home of
Yale University. While the city of New Haven has
suffered a decline in population, the outlying areas
continue to expand. The city's mixture of employment opportunities, which includes manufacturing,
retail, and service industries, more than justifies
healthy economic projections. Hamden, with a
population of about 48,000, is situated 5 miles
north of New Haven. That area has experienced
rapid growth in recent years due to accelerated interest in suburban living.
There is no significant competition presently existing between the two banks which will be eliminated by consummation of the proposed merger.
Their closest offices are about 20 road miles distant
from each other; the charter bank has no offices in
New Haven County. Since Connecticut law does
not permit de novo branching into townships
where there is already located the home office of
another bank, both New Haven and Hamden are
closed to de novo entry by the charter bank. The
addition of $7 million in deposits to the charter
bank will not have any significant effect on the
overall banking structure. On the other hand, consummation of this merger will solve the management problem at the merging bank, and will provide a bank which will be more able to compete




with the large New Haven-Hamden banks, and
will be better able to meet the needs of those communities.
Applying the statutory criteria, we find that this
proposal is in the public interest and the application is, therefore, approved.
SEPTEMBER 21,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

All the offices of General Bank are located in
southern New Haven County. Hartford Bank has
no New Haven County offices, and its closest office
to an office of General Bank is at Westfield, some
20 miles distant. Several banks operate offices in
this intervening area, and it appears from the application that neither of the merging banks obtains
appreciable business from the areas immediately
served by the other. Under these circumstances,
significant direct competition probably does not
exist between them.
Connecticut law does not permit a commercial
bank to establish de novo branch offices in a township where there is already located the home office
of another commercial bank. Under this law, both
New Haven and Hamden are closed to de novo
entry by Hartford Bank. Most of the townships
surrounding New Haven and Hamden are similarly
closed, but Hartford Bank could establish de novo
offices in East and West Haven (adjoining New
Haven to the south) and in Cheshire and Bethany
(adjoining Hamden to the north). As Connecticut's
largest commercial bank, Hartford National has the
resources and capabilities for such de novo expansion. Indeed, it has shown a disposition in the past
to enlarge its operations via de novo expansion.
Since 1964, it has opened 12 such branches, and
has approval for opening four more.
The proposed merger is essentially a market
extension merger through which Hartford Bank
proposes to enter the New Haven banking market
by acquisition of the smallest by far of the" five
banks operating in New Haven. This type of entry
will inject a strong new competitive force in New
Haven, capable of challenging the local leaders in
this concentrated market. Under these circumstances, we do not believe that this merger will
have any significantly adverse effect upon potential competition.

143

THE WARREN NATIONAL BANK, WARREN, PA., AND THE GOLD STANDARD NATIONAL BANK OF
MARIENVILLE, MARIENVILLE, PA.
Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The Gold Standard National Bank of Marienville, Marienville, Pa. (5727), with..
was purchased Oct. 30, 1970, by The Warren National Bank, Warren, Pa. (4879),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On July 7, 1970, The Warren National Bank,
Warren, Pa., applied to the Office of the Comptroller of the Currency for permission to purchase
the assets and assume the liabilities of The Gold
Standard National Bank of Marienville, Marienville, Pa.
The Warren National Bank, the purchasing
bank, with IPC deposits of $51 million, was organized in 1893. In addition to its head office, situated in Warren, it operates nine branches. It has
an approved but unopened office in North Warren.
The service area of the buying bank encompasses all of Warren County, western Forest
County, southwestern McKean County, and northwestern Elk County, and has a population of
70,000. The borough of Warren, with a population of 14,505, is the county seat of Warren County,
and dominates the area. A large portion of this
section of northwestern Pennsylvania forms the
Allegheny National Forest. The remaining land
area is devoted primarily to agriculture. Industry
is important to this section, but is confined to the
widely separated larger communities and their environs.
Other commercial banks with offices in the buying bank's service area include Pennsylvania Bank
& Trust Co., the only other bank in Warren, with
13 offices and total deposits of $106.2 million; the
Hamlin Bank & Trust Co., with four offices and
total deposits of $15.5 million; the Elk County
Bank & Trust Co., with four offices and total
deposits of $33.8 million; the Ridgway National
Bank, a unit bank, with total deposits of $8 million; the Farmers & Merchants Bank, St. Marys,
with total deposits of $8.2 million; the Bradford
National Bank, with three offices and total deposits
of $35.2 million; the Producers Bank & Trust Co.,
Bradford, with three offices and total deposits of
144




$3,077,259

1

103,434,682
106,511,941

9

10

$17.4 million; the First National Bank of Fryburg,
with total deposits of $6.3 million; the First Seneca
Bank 8c Trust Co., with 14 offices, one of which lies
in the charter bank's service area, and total deposits
of $109.2 million; and the Northwest Pennsylvania
Bank & Trust Co., with 17 offices, one of which lies
in the charter bank's service area, and total deposits
of $129.3 million.
The Gold Standard National Bank of Marienville,
the selling bank, with IPC deposits of $2.6 million,
is a single office institution which began operating
in 1901. This is a small, static, and unaggressive
bank. This bank has not been able to reach out
into other areas via de novo branching because of
limited capital funds available for fixed asset investment and because of lack of qualified management.
For years it has been experiencing difficulty in
generating sufficient deposits to meet the demand
for loans.
Marienville, home of the single office selling
bank, is 33 miles south of Warren, in Forest
County. The service area of the selling bank is
considered to be southern Forest County, southeastern Elk County, and northeastern Clarion
County. Forest County is the most sparsely populated county in Pennsylvania, with only 4,500 inhabitants. Of this number, 1,300 reside in Marienville. The Allegheny National Forest practically
surrounds Marienville, and abounds with the resources for hunting and fishing. Of 266,340 acres in
Forest County, 153,000 are owned by the State and
Federal governments, and are used to produce lumber and wood products. Manufacturing accounts
for 85 percent of those employed in Forest County,
of which 18.9 percent are employed in the forest
industries. A glass container plant is the principal
industry in Marienville.
No banking competition exists in Marienville as
the selling bank is the only bank located in its

service area. The 20-mile distance over the rugged
forest terrain of Allegheny National Forest which
separates the nearest offices of the purchasing bank
and the selling bank precludes any competition
between them. Some competition comes from the
Clarion offices of the First Seneca Bank and Trust
Co. of Oil City, 27 miles southwest, and the Northwest Pennsylvania Bank and Trust Co.
The purchase will have an insignificant effect in
the market area of the charter bank. This transaction will, however, benefit the Marienville community substantially, by replacing a small, static,
and unaggressive bank with an office of a large,
growing institution which will be able to provide
the banking public in and around Marienville with
modern, efficient banking services, funds for loans
at more competitive rates, and higher rates on
deposit money. Among the new services to be
offered are trust services, which are presently unavailable to the citizens of the Marienville area.
The purchasing bank will be in a better position
to adequately handle reasonable loan requests, and
thereby encourage growth and added prosperity to
the economy of the selling bank's service area.
Applying the statutory criteria, it is concluded

that the proposal is in the public interest. The
application is, therefore, approved.
SEPTEMBER 22,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest office of Warren Bank to Gold
Standard Bank is its branch at Tionesta, in western
Forest County. Tionesta is 23 miles from Marienville, and the intervening area is sparsely populated. According to the application, distance and
poor roadways result in neither bank drawing
substantial deposits or loans from the area served
by the other. Thus, the proposed transaction would
not seem to eliminate significant existing competition between the two banks.
Pennsylvania law allows unlimited branching
into contiguous counties. Although Warren Bank
could, therefore, open de novo offices anywhere in
Forest County, the limited economic base, combined with the lack of growth by Gold Standard
Bank, indicates that Warren Bank is not a likely
potential competitor by de novo branching.
Accordingly, we conclude that this transaction
will not have a significantly adverse effect on
competition.

T H E CITIZENS NATIONAL BANK, BRYAN, OHIO, AND THE PIONEER BANKING COMPANY, PIONEER, OHIO

Banking offices
Name of bank and type of transaction

Total assets
To be
operated

In
operation

The Pioneer Banking Company, Pioneer, Ohio, with
and The Citizens National Bank, Bryan, Ohio (13740), which had
merged Nov. 6, 1970, under charter and title of the latter bank (13740). The
merged bank at date of merger had

COMPTROLLER S DECISION

On July 31, 1970, The Pioneer Banking Company, Pioneer, Ohio, and The Citizens National
Bank, Bryan, Ohio, applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
The Citizens National Bank, the charter bank,
with IPC deposits of $7.2 million, was organized
in 1933. It presently operates two branches, one in
Bryan and one in West Unity. This bank is generally in good condition, but management, though
competent, is without depth. It does not offer trust
services but anticipates applying for trust powers.




$5,459,261
28,962,951
34,383,265

1
3

4

The Pioneer Banking Company, the merging
bank, with IPC deposits of $1.1 million, was
chartered in 1913, and operates no branches. It
is in satisfactory condition but offers no trust services. This bank has poor physical quarters and proposes to construct a new banking house. Management is also competent but lacking in depth or
breadth. Its small loan limit has kept it from
rendering adequate service to the community.
Bryan, Ohio, population 8,000, is the county
seat of Williams County and is located in its southcentral portion. Pioneer, Ohio, has a population
of 900, and is located 16 miles due north of Bryan
145

in the extreme north-central portion of the county.
West Unity is 11 miles northeast of Bryan and 12
miles southeast of Pioneer. The combined service
area of both banks includes all of William County,
the northern parts of Defiance County, the western
area of Fulton County, and the southern sections of
Hillsdale County, Mich.
The economy of Williams County, which has
a population of 33,000, is representative of the entire service area, and is largely dependent upon
industrial and agricultural pursuits. In Bryan, the
county's only city, and in several of the bigger
towns and villages throughout the area, there are
a significant number of industries, some of which
have substantial payrolls and employ sizeable numbers of persons.
There are eight commercial banks operating a
total of 11 banking offices in Williams County. A
number of other commercial banks are located near
the Williams County line in contiguous Defiance and Fulton counties, in Ohio, and Hillsdale
County, in Michigan. In the combined service area
there are 18 banking offices, 14 of which are operated by competing banks. Because all of the credit
needs of the larger business, commercial, or industrial firms of the area are not met by local banks,
the substantially larger banks in Toledo, Columbus,
Cleveland, Fort Wayne, and Chicago that serve
those needs can also be said to be operating in the
area.
Consummation of this merger will create an institution more capable of adequately serving the
credit needs of some of the area's larger firms than
any existing institution in the area. The resulting
bank will have managerial capability in greater
depth than either merging bank. The resulting
bank will be in a better position than the merging
institution to provide the capital to build the
needed new banking house in Pioneer. The services of the agricultural consultant employed by the
charter bank will be made available in the Pioneer
area. A data processing department is being placed
in operation at the charter bank, and its facilities
will be available to the merging bank's customers.
Competition will not be adversely affected. Because of the distance separating the merging banks'
offices, there is little competition between them.
The resulting bank will continue the charter bank's
ranking as largest county bank, but its size will not
be increased significantly. The merger should stim-

146




ulate competition by recapturing part of the local
business now lost to the large out-of-area, big-city
banks. All other banks will continue to share in the
area's economic growth and retain their proportionate shares of local banking business.
Applying the statutory criteria, it is concluded
the proposed merger is in the public interest. The
application is, therefore, approved.
OCTOBER 5,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposal would merge the largest and
seventh largest of the eight commercial banks in
Williams County, Ohio. The fifth largest has just
been acquired by the applicant. Thus, approval
of the proposed merger would mean that, within
the period of around a year, the number of independent banks would be reduced from nine to
seven.
The main offices of the participating banks are
about 16 miles apart, and applicant's newly acquired West Unity branch is about 12 miles from
Pioneer.
The resulting banks would hold about 37.5 percent of Williams County deposits, and the largest
four commercial banks would hold about 82.5 percent of these deposits. There was, and perhaps is,
strong potential competition, as evidenced by an
out-of-county bank holding company offering to
purchase controlling interest in Pioneer.
The application notes that the merger would
constitute a de jure recognition of the presently
existing de facto "combination of the financial and
managerial resources" of the two banks. We do not
view prior direct or indirect stock acquisitions with
a view toward merger, or the subsequent relationships which may thereby develop, as facts which
demonstrate that a proposed merger will have no
anticompetitive effects. Such a merger will permanently eliminate the potential for increased
competition should the various stock control arrangements be terminated at some time in the
future.
Because the merger would increase concentration
and result in the elimination of Pioneer as a conduit for the introduction of potential competition
into the market, it is our view that the proposed
transaction will have an adverse effect upon competition.

WELLS FARGO BANK, N.A.,

SAN FRANCISCO, CALIF., AND T H E FIRST NATIONAL BANK OF HOLTVILLE,
HOLTVILLE, CALIF.
Banking offices

Name of bank and type of transaction

Total assets
To be
operated

In
operation

The First National Bank of Holtville, Holtville, Calif. (9770), with
and Wells Fargo Bank, National Association, San Francisco, Calif. (15660),
which had
merged Nov. 6, 1970, under charter and title of the latter bank (15660). The
merged bank at date of merger had

COMPTROLLER S DECISION

On June 25, 1970, The First National Bank of
Holtville, Holtville, Calif., and Wells Fargo Bank,
N.A., San Francisco, Calif., applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The charter bank, with IPC deposits of $3.8
billion, was orginally organized in 1852, and is
presently the third largest bank in the State. Most
of the bank's 272 branch offices are located in
northern California. Only recently, the bank expanded its activities to the southern part of the
State and presently operates 26 branch offices in
southern California.
The merging bank, with IPC deposits of $11.5
million, was organized in 1907, and is a single-office
institution. Due to the limited services it is able
to offer, the bank does not adequately serve the
needs of its community. Although it cannot be said
that the bank has a management problem, still it
has never had a management development program, and must rely entirely on its president and
directors. Commercial banking competition to the
merging bank is provided by the four other banks
in Imperial County, which operate a total of 15
offices. They include Bank of America, N.T. & S.A.,
with six offices in the county; Security Pacific National Bank and United California Bank, with
three offices each; and Imperial Valley National
Bank, with two offices. Competition is also provided by one savings and loan association, four
finance companies, local offices of two insurance
companies, a local federal land bank association,
and a local production credit association.
Holtville, with an estimated population of 4,000,
is located about 12 miles to the east of El Centro,
the county seat and commercial center of Imperial
County. The economy of this area, like the rest of
the county, is predominately dependent on agricul-




$13,927,142

1

5,514,746,846

281

5,527,924,917

282

ture. The Holtville area contributed approximately
95 percent of the carrot production of Imperial
County in 1969. Annual crop yields, coupled with
livestock feeding, have made Imperial County the
fourth highest agricultural producer in the Nation.
The major crops include lettuce, cotton, alfalfa,
sugar beets, and cantaloupes. Heavy industry is
practically nonexistent in Imperial County. Several
light manufacturing firms have operations in the
area, including the Holly Sugar Corporation, the
Valley Nitrogen Producers, Inc., and G. T. Schjeldahl Company, which is located in Holtville.
Because of the distance separating the participating banks, there is no competition presently existing between them. The closest office of the charter
bank to the merging bank is located in San Diego,
about 137 miles to the west of Holtville. Because
of the difference in size between the participating
banks, consummation of the proposed transaction
will not eliminate potential competition between
them. Moreover, a de novo branch of the charter
bank in the Holtville area would serve to aggravate the problems at the merging bank. The addition of $11.5 million in deposits to the charter bank
will have no significant effect on concentration of
banking resources in the State. On the other hand,
consummation of this merger will introduce into
the Holtville area a bank more able to compete
with the large banks operating in that area and
better able to meet the needs and convenience of
the banking public in that area.
Applying the statutory criteria, we find that the
merger is in the public interest, and the application, therefore, is approved.
SEPTEMBER 29,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Wells Fargo has no offices in the Holtville area;
its nearest branch is in San Diego, 137 miles west
of Holtville and numerous banking facilities sepa147

rate the two. Consequently, the proposed merger
would not eliminate any direct competition between the banks.
Wells Fargo is the largest bank in California
not serving the Imperial Valley. It could make
de novo entry into that area as it is doing into

other areas of southern California. However, there
would appear to be a number of other large banks
capable of entering this area; therefore, the elimination of Wells Fargo as a potential de novo
entrant should not have a significantly adverse
competitive effect.

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

N.C. , AND THE BANK OF FRENCH BROAD,

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation

The Bank of French Broad, Marshall, N.C, with
and First Union National Bank of North Carolina, Charlotte, N.C. (15650), which
had
merged Nov. 14, 1970, under charter and title of the latter bank (15650). The
merged bank at date of merger had

COMPTROLLER S DECISION

On July 29, 1970, The Bank of French Broad,
Marshall, N.C, and First Union National Bank of
North Carolina, Charlotte, N.C, filed an application with the Comptroller of the Currency for
permission to merge under the charter and with
the title of the latter.
The First Union National Bank is headquartered
in Charlotte, the financial and distribution center
of the State, Located in the south-central Piedmont
section of North Carolina, Charlotte is one of the
State leaders in manufacturing, and boasts the
highest retail sales totals in the two Carolinas. It is
one of the fastest growing cities in the southeastern
United States.
First Union National Bank, with IPC deposits of
$684 million, is the third largest bank in the State,
and presently operates 137 banking offices in 66
communities in North Carolina. Principal banking
competition for this bank is provided by the $1.6
billion Wachovia Bank and Trust Company, operating 130 offices in 51 communities; the $1.3 billion
North Carolina National Bank, operating 91 offices
in 27 communities; and the $665 million FirstCitizens Bank and Trust Company, operating 130
offices in 57 communities. Competition to the
charter bank is also provided by such strong regional banking systems as the $486 million The
Northwestern Bank and the $247 million Branch
Banking and Trust Company. Numerous other




$8 ,906,330

2

1 ,04? 875,218

141

1 ,051 781,548

143

financial institutions also operate in the same areas
and compete with the charter bank.
The merging bank, The Bank of French Broad,
is headquartered in Marshall, Madison County, and
presently operates a branch office in Weaverville, in
bordering Buncombe County. The economy of
Madison County is primarily supported by agriculture, with tobacco the main cash crop. The population is scattered and rapidly declining due to
widespread unemployment; approximately 60 percent of the residents live on small farms. The personal income levels, housing conditions, median
value of homes, and average value of farmland are
considerably below the State norm. The creation of
an environment conducive to growth and attractive to new business is of primary importance to
the economic future of the area.
The Bank of French Broad, with IPC deposits of
$7 million, was originally organized in 1903. The
bank is faced with a management succession problem. Because of its limited experience and resources, it is doubtful that this bank can do much
in the future to stimulate growth in its service area.
The only other bank directly competing in the
area of the merging bank is the Citizens Bank in
Marshall, with deposits of $8.5 million.
There is no significant competition presently
existing between the participating banks. The
closest office of the charter bank to the merging
bank is in Ashville, Buncombe County, and is

approximately 12 miles from Weaverville. The
elimination of whatever competition now exists
between these banks can readily be outweighed by
the benefits to follow. Although First Union National Bank could, under State law, branch de novo
into the area of the merging bank, the small population and limited economic potential of the area
do not warrant de novo entry.
Consummation of the proposed merger between
First Union National Bank and The Bank of French
Broad, in addition to solving the problems at the
merging bank, will introduce a more viable institution in the service area of the merging bank. The
resulting bank will not only provide a full range
of banking services and a larger lending limit, but
will also offer access to the capital resources that
will be needed to assist future economic growth in
the area.
Applying the statutory criteria, we find the proposal is in the public interest. The application,
therefore, is approved.
OCTOBER 9, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

First Union operates six offices in Buncombe
County, five of which are in or very near Asheville.
The Weaverville office of French Broad Bank is
located about 12 miles north of Asheville, and
about 8 miles north of the nearest First Union
office. No other banking offices intervene, and the
two areas are connected by good roads. Thus, there
appears to be some existing competition between
the two banks. The application indicates that
French Broad Bank derives most of its Buncombe
County business from the Weaverville area and
points north, while First Union derives most of its
business from the Asheville area and points south.

The amount of business which First Union derives
from the Weaverville area is not insubstantial,
however, especially when compared to the total
business held by the Weaverville office of French
Broad Bank.
French Broad Bank operates its head office in
Madison County. Citizens Bank (total deposits of
$8.5 million) is the only other bank operating in
the county, with offices in Mars Hill, Marshall, and
Hot Springs. French Broad Bank holds around
34 percent of total county deposits. Although First
Union is one of many potential entrants into
Madison County, including all of the largest banks
in North Carolina, the depressed state of the economy in Madison County, the decline in population,
and the poor prospects for growth make de novo
entry by any of the potential entrants, including
First Union, unlikely.
There are presently six commercial banks operating in Buncombe County. As of June 30, 1968, First
Union held approximately 24.1 percent of the total
deposits held by all Buncombe County banking
offices, while French Broad Bank held approximately 1.3 percent. The bank holding the largest
share of Buncombe County deposits was Wachovia
Bank & Trust Co., N.A., Charlotte (also the largest
bank in the State, holding total deposits of $1,330.6
million on December 31, 1969), which held approximately 47.7 percent of toial Buncombe County
deposits. Thus, the merger would increase First
Union's share of these deposits from 24.1 percent to
25.4 percent, and would increase the share held by
the two largest banks in the county from 71.8 percent to 73.1 percent. Thus, the merger would cause
a slight increase in the already high concentration
in commercial banking in Buncombe County.
We conclude that the proposed merger would
have an adverse effect on competition.

VIRGINIA NATIONAL BANK, NORFOLK, V A . , AND CARROLL COUNTY BANK, HILLSVILLE, V A .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Carroll County Bank, Hillsville, Va., with
and Virginia National Bank, Norfolk, Va. (9885), which had
merged Nov. 23, 1970, under charter and title of the latter bank (9885). The
merged bank at date of merger had




$14,747,939
1,036,189,871
1,050,427,829

To be
operated

1
104
105

149

COMPTROLLER S DECISION

On August 18, 1970, Carroll County Bank, Hillsville, Va., and Virginia National Bank, Norfolk,
Va., applied to the Comptroller of the Currency
for permission to merger under the charter and
with the title of the latter.
Virginia National Bank, with IPC deposits of
$733 million, maintains 103 branches and two
facilities scattered throughout Virginia. Although
the charter bank is essentially a statewide banking
institution, it draws approximately two-thirds of its
deposits from the Tidewater-Charlottesville area.
The applicant presently has no office within the
service area of the merging bank.
Carroll County Bank, with IPC deposits of $11
million, was founded in 1890, and operates a single
office in Hillsville, the county seat of Carroll
County. The estimated population of the merging
bank's service area, composed of Hillsville and the
surrounding area, is 5,000 persons. Geographical
and economic conditions in the region have
hindered the bank in attracting qualified managerial personnel, and the bank's operations are
almost wholly dependent upon the president, for
whom no successor is immediately apparent.
Virginia National Bank is, to some degree, in
competition with every major bank in the southeastern portion of the United States, for certain
services. Principal competitors in Virginia are the
$1.2 billion United Virginia Bankshares, Incorporated, a registered bank holding company, that controls 10 affiliated banks with 98 offices in 32 communities in Virginia; the $785 million First &
Merchants National Bank, with 57 offices in 18
communities in Virginia; the 12 banks affiliated
with Virginia Commonwealth Bankshares, the total
resources of which amount to $679 million; the
$555 million Dominion Bankshares Corporation,
with six affiliated banks operating 53 offices in Virginia; the 11 banks affiliated with the First Virginia
Bankshares Corporation, with 102 offices and resources of $507 million; and nine banks affiliated
with Financial General Corporation, operating 40
offices in Virginia with total resources of $390 million. Further competition is provided by the smaller
Fidelity-American Bankshares, Incorporated, which,
at present, controls only two banks with 34 offices
and combined resources of $283 million.
The principal competitors of the Carroll County
Bank are the First National Bank in Galax, with

150




two offices and total resources of $20 million, and
the Merchants and Farmers Bank in Galax, with
three offices and total resources of $16 million. The
charter bank's closest offices to the merging bank
are located in Pulaski, Va., approximately 26 miles
north, and in Wytheville, approximately 30 miles
northwest of Hillsville. Because each of the participating banks is prohibited by State statute from
branching de novo into the trade area of the other,
and because no direct competition exists at the
present, this proposal will have no adverse effect
upon any existing or potential competition.
Upon consummation of the merger, the resulting
bank will be able to offer a wide variety of specialized banking services not heretofore available to
residents and businesses of Carroll County. Such
services include computer services, mortgage financing, a bond department, farm service department,
educational loans, and trust services.
It is concluded that the merger will have no adverse competitive effect and is in the public interest.
The application is, therefore, approved.
OCTOBER 22,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

County Bank is the only bank located in Carroll
County, although there are two commercial banks
in Galax, an independent city 12 miles southwest
of Hillsville. Virginia National Bank, which is
headquartered in Norfolk, 250 miles east of Carroll
County, has its nearest offices at Pulaski, in Pulaski
County, 23 miles north of Hillsville, and at Wytheville, in Wythe County, 31 miles northwest of Hillsville. According to the application, these offices
draw small fractions of 1 percent of their business
from Carroll County, and County Bank draws even
smaller proportions of its business from Pulaski or
Wythe counties. Thus, it would appear that only
an insignificant amount of direct competition
would be eliminated by the proposed merger.
Under Virginia law no bank in the State, including Virginia National Bank, is permitted to branch
de novo into Hillsville. Virginia National Bank,
however, could enter through establishment of a
holding company and the acquisition of a newly
chartered bank in the area. A community of 1,100
persons in a community with a declining population would not, however, appear to be a likely
prospect for the introduction of a second commercial bank. The proposed merger would not appear
to have an adverse effect on competition.

T H E RIDDELL NATIONAL BANK OF BRAZIL, BRAZIL, IND., AND T H E FIRST NATIONAL BANK OF CENTER
POINT, CENTER POINT, IND.
Banking offices

Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Center Point, Center Point, Ind. (9250), with
and The Riddell National Bank of Brazil, Brazil, Ind. (5267), which had
merged Dec. 1, 1970, under charter of the latter bank (5267) and title "The Riddell National Bank of Brazil, Indiana." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On May 28, 1970, The First National Bank of
Center Point, Center Point, Ind., and The Riddell
National Bank of Brazil, Brazil, Ind., applied to the
Office of the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title "The Riddell National Bank of
Brazil, Indiana."
The Riddell National Bank of Brazil, Brazil,
Ind., with IPC deposits of $17.2 million, was organized in 1885, and remains a unit bank. It serves
Brazil, Ind., which has a population of 9,000 and
is the county seat of Clay County. Brazil is about
55 miles southwest of Indianapolis and 20 miles
east of Terre Haute, in the northern part of Clay
County. Eight industrial plants located in Brazil
employ about 1,100, and many other residents
commute to nearby Terre Haute, Ind., and other
cities, for employment.
The First National Bank of Center Point, Center
Point, Ind., with IPC deposits of $2.4 million, was
organized on October 6, 1908. This unit bank is
a small, unaggressive institution with an inadequate
lending limit. It has been unable to provide for
management succession.
Center Point, Ind., is located near the center
of Clay County, about 12 miles southeast of Brazil.
It has an estimated population of 300. The economy of this area is agricultural. The merging bank
is the only bank in the town.
Both banks are located in Clay County, which
has an estimated population of 24,000, and is located in the west-central part of Indiana. Although
agriculture is the principal source of economic
support in the county, there are also, within the
county, coal producing strip mines, and 12 commercial and manufacturing firms. Five of those
companies manufacture clay products, and three
are directly associated with farming. However,
about 70 percent of the county's labor force is




$3,055,397
22,782,237

To be
operated

1
1

25,428,913

2

employed in Terre Haute, Indianapolis, Greencastle, Bloomington, and other neighboring cities.
Two other banks are located in Clay County.
They are the First Bank and Trust Company of
Clay County, Brazil, Ind., which operates its main
office and a drive-in branch in Brazil, and another
branch at Clay City, in the southern part of the
county, and which has total deposits of $22.2 million; and The Poland State Bank, Poland, Ind.,
which is in the extreme eastern part of the county,
and which has deposits of $1.5 million.
In the applicant's trade area there are 16 banks
operating 36 offices. Of those, the charter bank
ranks eighth in size. Among its principal competitors are the Terre Haute First National Bank, the
largest bank in the area, which has total deposits of
almost $97 million; The Merchants National Bank
of Terre Haute, with total deposits of $58.3 million; and the Indiana State Bank of Terre Haute,
with total deposits of almost $39 million. There are
also eight savings and loan associations in the service area which together have total resources of
$89 million as well as numerous sales finance and
personal loan companies. In addition, it is estimated that the Federal Land Bank has $2 million
in loans outstanding to farmers in Clay County.
Consummation of this merger will solve a serious
management problem in the merging bank. The
customers of the merging bank will benefit from
higher lending limits, increased interest on time
deposits, trust facilities, improved services, and the
assurance of a continuing banking outlet in their
community which the merger will provide.
Applying the statutory criteria, we find the
merger to be in the public interest, and the application, therefore, is approved.
SEPTEMBER 18,

1970

SUMMARY OF REPORT BY ATTORNEY GENERAL

The participating banks are located 12 miles
apart. There are no banks in the intervening area.
151

Thus, it would appear that some direct competition
between the banks would be eliminated by the proposed merger. Furthermore, under Indiana law,
which permits county-wide branching, Riddell Bank
could establish a branch in Center Point and, thus,
compete more directly with First National.
Riddell Bank and First National are, respectively, the second and third largest banks in Clay
County. First National's share of the total deposits
in this county, 41 percent, will increase some 6 percent, as a result of the merger. The resulting bank

will still be the second largest in the county. Even
though banks located outside the county offer some
competition in various areas, State law does not
allow them to branch into the county.
The proposed merger would eliminate some direct competition between the participants and it
would reduce the number of banks able to compete
within the county to three. Thus, we conclude
that this merger is likely to have an adverse effect
on competition.

FIRST NATIONAL STATE BANK OF N E W JERSEY, NEWARK, N.J.,

AND ORANGE VALLEY BANK, ORANGE,

N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Orange Valley Bank, Orange, N.J., with
.
and First National State Bank of New Jersey, Newark, N.J. (1452), which h a d . . .
merged Dec. 4, 1970, under charter and title of the latter bank (1452). The merged
bank at date of merger h a d . . .
.

COMPTROLLER S DECISION

On April 17, 1970, Orange Valley Bank, Orange,
N.J., and First National State Bank of New Jersey,
Newark, N.J., applied to the Office of the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
First National State Bank of New Jersey, Newark,
N.J., with IPC deposits of $662.3 million, was
founded in 1812 as the State Bank of Newark, and
assumed its present name in 1965. The charter bank
operates 29 offices, all of which are located in
Essex County. This bank has experienced good
growth over the last 20 years, its assets have increased from $172 million, in 1950, to $883 million
as of year-end 1969.
The primary service area of the charter bank is
the greater Newark area, which consists of Essex
County, most of Union County, and parts of Morris
and Hudson counties. The city of Newark has
400,000 of Essex County's total population of
972,000. Essex County ranks as one of the world's
greatest commercial and industrial centers, and is
surrounded by the counties of Hudson, Bergen,
Passaic, Morris, and Union, each of which is also
highly industrialized and commercialized. Newark
Airport is one of the Nation's most active and, in
the near future, will be undergoing a major rede152




$7, 051,864
861, 185,593
866, 967,712

To be
operated

2
29
31

velopment program designed to make it one of the
world's most modern. The port of Newark handled
about 5.5 million long tons of cargo in 1969. Essex
County is a major educational center of the State
with eight colleges, a major medical center, and 16
modern hospitals located within its boundaries.
The charter bank competes in its service area
with Fidelity Union Trust Company, Newark, N.J.,
with $731 million in total assets; National Newark
and Essex Bank, Newark, N.J., with $688 million
in total assets; and the Howard Savings Institution,
Newark, N.J., with $907 million in total assets. It
also faces aggressive competition from the large,
billion-dollar New York City banks, as well as
offices of smaller institutions. The First National
State Bank of New Jersey holds only 7.7 percent
and 7.2 percent, respectively, of the $10.4 billion in
total assets and $9.1 billion in total deposits in the
First Banking District of New Jersey.
Orange Valley Bank, with IPC deposits of $6.2
million, was founded in 1917, and presently operates, in addition to its main office, one drive-in
facility located directly across the street. Bank management has been very conservative, and as a result,
the bank has experienced slow growth, and its
earnings are below those of other banks of comparable size operating in the general area. The

merging bank does not have a pension plan or
the other fringe benefits essential to attract officer
candidates, with the result that it faces a management succession problem owing to the imminent retirement of its four top officers.
The primary service area of the merging bank
consists of the four Oranges, including Orange,
West Orange, East Orange, and South Orange.
Those four municipalities are situated in the central part of Essex County, about 4 miles west-northwest of downtown Newark, and cover an area of 21
square miles and a total population of 15,000 people. West Orange and East Orange are devoted
mainly to manufacturing, although retail merchandising activity is also important. South Orange is
mainly residential, and East Orange houses the
main, or branch, offices of a number of insurance
companies, a considerable number of office buildings, and a number of luxury apartment buildings.
At the present time, there are 20 offices of five
competing banks in the Oranges, including one
savings bank with two offices, and one branch of
the charter bank, in addition to the merging
Orange Valley Bank. National Newark and Essex
Bank has an office in Orange, and Fidelity Union
Trust Company has three offices in East Orange.
The Second National Bank of Orange, Orange,
N.J., with $37 million in total assets, has three
offices in Orange, and the Essex County State Bank,
West Orange, N.J., with assets of $8 million, maintains two offices in West Orange.
The banking needs of the Orange communities
will be better served by a branch of First National
State Bank of New Jersey. Many additional banking services will be provided which are now unavailable through the merging bank, including
trust services, automated accounting, specialized
lending services, a much higher lending limit, and
higher interest paid on time deposits. The management succession problem of Orange Valley Bank
will be solved, and the pension plan and other
fringe benefits of the charter bank will be made
available to present employees of the Orange Valley
Bank.
Competition will not be adversely affected by this
merger. Although the First National Bank of New
Jersey is the largest bank in the State, it is not in a
position to dominate banking in New Jersey or in
its service area. If the merger is approved, the
charter bank will hold 12.1 percent of deposits in
its service area, as compared with 12 percent presently. Although one competing institution will be




eliminated, adequate banking alternatives will remain. Competition in the charter bank's service
area outside of the Oranges will be little affected by
this merger. In the Oranges, however, competition
will be increased by the addition of a branch of the
strong and aggressive First National State Bank,
replacing a small, nonaggressive, noncompetitive
independent bank not now responsive to the banking needs of its community. Potential competition
will not be affected since State branch restrictions
prohibit the de novo branching of the charter bank
into Orange, the home office city of the merging
Orange Valley Bank.
Applying the statutory criteria, we find the
merger to be in the public interest, and the application, therefore, is approved.
NOVEMBER 2,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest office of First National to Orange
Valley is the Orange office located 1.1 miles away.
First National presently has no other offices in the
geographic market area of Orange Valley (Orange,
West Orange, East Orange, and South Orange).
Under New Jersey law, First National is prohibited
from opening de novo branches in Orange, West
Orange, and South Orange because of home office
protection provisions. According to the application,
it is seeking a location for a branch in East Orange.
First National derives $4.7 million in total deposits
from Orange, $4.4 million from West Orange, $10
million from East Orange and $4.2 million from
South Orange, or $23.3 million in total deposits
from the service area of Orange Valley. Loans
drawn from the same area total $16 million. In
view of the fact that First National draws substantial amounts of banking business from Orange
Valley's geographic market area, we conclude that
the proposed merger would eliminate substantial
direct competition between First National and
Orange Valley.
Twenty-one commercial banks operate a total of
141 branches in Essex County. Five savings institutions operate a total of 23 banking offices. Under
New Jersey law, savings banks are empowered to
accept demand deposits. In fact, however, savings
banks hold a minimal percentage of county IPC
demand deposits; as of June 30, 1968, savings banks
in Essex County held only about $22 million in
IPC demand deposits, and commercial banks held
over $1 billion.
As of December 31, 1968, the three largest com153

mercial banks in Essex County held approximately
83 percent of county IPC demand deposits and
approximately 51 percent of county total deposits.
These same banks operated about 65 percent of all
commercial bank offices and about 55 percent of all
offices of both commercial and savings banks. First
National held the largest shares, approximately 29
percent of county IPC demand deposits, and ap-

proximately 19 percent of county total deposits.
Merger with Orange Valley would increase these
shares by only a small amount.
The proposed merger would eliminate direct
competition and increase concentration in Essex
County. Although Orange Valley is a relatively
small bank, its absorption by a leader in the area
may have an adverse effect on competition.

NATIONAL BANK & TRUST COMPANY OF CENTRAL PENNSYLVANIA, YORK, PA., AND T H E READING TRUST COMPANY,
READING, PA., AND LANCASTER COUNTY FARMERS NATIONAL BANK, LANCASTER, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Lancaster County Farmers National Bank, Lancaster, Pa. (683), with
The Reading Trust Company, Reading, Pa., with
and National Bank & Trust Company of Central Pennsylvania, York, Pa. (694),
which had
consolidated Dec. 7, 1970, under charter of the latter bank (694) and title "National Central Bank." The consolidated bank at date of consolidation had

The "Comptroller's Decision" and the "Summary of Report by Attorney General" for this case

To be
operated

$157,188,189
158,827,533

13
11

281,850,571

22

597,866,293

46

appeared in the 1969 Annual Report under the
heading "Approved, but in litigation."

FIRST CITIZENS NATIONAL BANK, MANSFIELD, PA., AND GRANGE NATIONAL BANK OF POTTER COUNTY, ULYSSES, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

COMPTROLLER S DECISION

On October 8, 1970, Grange National Bank of
Potter County, Ulysses, Pa., and First Citizens National Bank, Mansfield, Pa., applied to the Office of
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
First Citizens National Bank, the charter bank,
with IPC deposits of $13.6 million, was organized
in 1932, and presently operates one branch, located
in Blossburg, 10 miles south of Mansfield.
154




$5,872,245
19,052,692
24,924,937

CM CM

Grange National Bank of Potter County, Ulysses, Pa. (8739), with
and First Citizens National Bank, Mansfield, Pa. (13618), which had
merged Dec. 31, 1970, under charter and title of the latter bank (13618). The
merged bank at date of merger had

To be
operated

4

Mansfield, the home of the charter bank, has a
population of 2,650 and is located 50 miles north of
Williamsport and serves as a trading center for all
of eastern Tioga County and the extreme western
portion of Bradford County. It is the home of
Mansfield State College, a State teachers college,
which has an enrollment of 3,200, a faculty of 240,
and an administration staff of 256. The service area
is characterized by dairy farms and timberland.
Several small manufacturing and coal mining firms
scattered throughout the area provide employment

for a limited segment of the population. A number
of persons residing in the northern portions of the
service area find steady and substantial employment in the nearby New York State industrial communities of Corning and Elmira.
The charter bank is third in size among banks
operating in its service area. The two banks greater
in size are Commonwealth Bank and Trust Company, Muncy, Pa., with deposits of $44.5 million,
and Northern National Bank and Trust Company,
Wellsboro, with deposits of $25.5 million. Those
three are the only banks with offices in Tioga
County. Commercial banks and other financial institutions in the Corning-Elmira area provide intense competition for the deposit dollar in the
charter bank's service area.
Grange National Bank of Potter County, the
merging bank, with total IPC deposits of $4.5
million, was organized in 1907, and presently
operates one branch in Genesee, Pa. This bank is
beset with many problems. Its management has
been unable to prevent the erosion of its capita]
structure and to maintain the confidence of the
community in the bank. Many depositors have
placed money elsewhere, and thus funds available
for lending are restricted. The merging bank is
simply unable to meet the legitimate and growing
credit needs or to offer expanded and specialized
services to its banking public. Ulysses, Pa., home
of the merging bank, is a small rural community,
50 miles west of the charter bank. The merging
bank's service area consists of an area of northeastern Potter County and a narrow strip of New
York State, immediately north of Potter County.
The economy of the service area is keyed to dairy
and potato farming. Industry and commerce are
virtually nonexistent. Much of Potter County is
characterized by vast tracts of timberland.
The merging bank is fifth in size in its service
area. It is preceded in size by the two abovementioned competing banks operating in the
charter bank's service area which also operate
branches in the merging bank's service area, as well
as The First National Bank of Coundersport,
Coundersport, Pa., with deposits of $6.5 million,
and the Citizens Bank, Coundersport, with deposits
of $5.9 million.
The merger would replace the faltering merging
institution with offices of the financially sound,




well-managed, and thriving charter bank. The result should be improved service to the Ulysses community in general. The resulting bank will be in
a position to meet the legitimate credit needs and
to offer needed expanded and specialized services to
the banking public which the merging bank cannot
offer.
Competition will not be adversely affected. Because the two banks are over 50 miles apart there is
no present competition between them. The resulting bank in the combined service area will continue
to be the third largest bank in charter bank's own
service area, and competing banks will not be disadvantaged. As the merging bank is presently an
ineffectual competitor, replacing it should improve
competition rather than reduce it.
Applying the statutory criteria, it is concluded
that the proposal is in the public interest. The
application is, therefore, approved.
NOVEMBER 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the merging banks are over
50 miles apart. The application indicates that
Grange draws some business from western sections
of Tioga County, but not from areas of the county
served by First Citizens. The proposed merger
would not appear to eliminate substantial direct
competition.
Pennsylvania law permits commercial banks to
open de novo branches in their home counties and
in counties contiguous thereto. Thus, Grange and
First Citizens could be permitted to open new
offices in each other's service area. In view of its
size and recent financial difficulties, however,
Grange could not be considered a likely potential
entrant into eastern Tioga County.
There are also a number of other banks eligible
to open new branches in the Ulysses-Genesee area,
which does not appear to be an attractive site for
such activity at present.
First Citizens, itself a relatively small bank, is
not among the larger banks legally eligible to enter
the service area of Grange. In view of this fact,
and of the size of Grange and the rural characteristics of its service area, we conclude that the proposed merger would be unlikely to have a significantly adverse effect on potential competition.

155

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

AND T H E FIRST NATIONAL BANK OF ROSELLE,

Banking offices

Total assets

Name of bank and type of transaction

In
operation

The First National Bank of Roselle, Roselle, NJ. (8483), with
and First National Bank of Central Jersey, Somerville, NJ. (3866), which had. . . .
consolidated Dec. 31, 1970, under charter and title of the latter bank (3866). The
consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On July 9, 1970, the First National Bank of
Central Jersey, Somerville, N.J., and The First
National Bank of Roselle, Roselle, N.J., applied to
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
former.
The charter bank, with IPC deposits of $81.7
million, was originally organized in 1888, and
presently operates eight banking offices in Somerset
County. The bank ranks first in size among the
seven commercial banks operating in that county,
and 11th among the 64 commercial banks in the
Second Banking District. Those 64 banks have total
aggregate deposits of $3.9 billion.
The area served by the charter bank has a population of about 434,000, and includes all of Somerset County and several communities located in
bordering counties. This area has experienced rapid
industrial, commercial, and residential expansion in
recent years. Due to Somerset County's strategic
location between New York and Philadelphia, it is
expected that the area will continue to enjoy
excellent economic growth.
The trade area presently served by The First
National Bank of Roselle is located in the heart
of Union County. Union County, with a population of about 577,000, is one of the smaller counties
in the State, and is located in the extreme eastern
portion of New Jersey, adjacent to the harbors
serving the port of New York and the immediate
New York Metropolitan Area. In contrast to Somerset County, Union County is substantially developed, and there is little vacant land remaining for
additional development. Although Union County
has substantial industries of its own, its proximity
to New York places it within the orbit of that
metropolitan area.
The First National Bank of Roselle, with IPC
deposits of $14.5 million, was originally organized
156




$17,830,469
119,994,993
137,775,462

To be
operated

2
8

10

in 1906, and presently operates two banking offices
in Roselle. The bank ranks 10th in size among
Union County's 11 commercial banks which together have total deposits of $1.1 billion. It ranks 52nd
among the 64 banks located in the banking district,
holding about 0.4 percent of the total bank deposits in the district. During the period from 1964
to 1969, the bank has experienced a decline in
deposits. It is presently faced with a serious management succession problem. Due to the proximity
of its trade area to Newark, the financial center of
New Jersey, the bank is also faced with competition
from the large banks based in that city. Competition in Union County is also provided by several
savings and loan associations, savings banks, personal finance companies, sales finance companies,
and credit unions.
There is no significant competition presently
existing between the participating banks. The
charter bank has no offices in Union County, and
its closest office to The First National Bank of
Roselle is 8 miles distant. The elimination of whatever competition may now exist between these
banks can readily be outweighed by the benefits
to follow. Consummation of the proposed transaction will not eliminate potential competition
between the two banks. Because New Jersey law
provides home office protection, de novo entry by
the charter bank into Roselle and seven other communities in Union County is precluded. Moreover,
the size and problems faced by The First National
Bank of Roselle prevent it from being an effective
competitor. The addition of $14.5 million in deposits to the charter bank will not have a significant
effect on concentration of banking resources in the
area.
Consummation of the proposed consolidation,
besides solving the management problem at The
First National Bank of Roselle, will introduce into
the Roselle area a more viable, competing institution, with greater resources and able to provide a

full line of banking services. The resulting bank,
with its greater resources, will be in a better position to aid the growing industries in the area of the
charter bank, by making available to them the
needed local capital funds.
Applying the statutory criteria to the proposed
consolidation, we conclude that it serves the public
interest and the application is, therefore, approved.
OCTOBER 7, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The closest offices of the consolidating banks are
about 12 miles apart, and are separated by numerous offices of other commercial banks. The application indicates that each draws no more than minimal banking business from the service area of the
other. It is unlikely that any substantial direct competition will be eliminated by the proposed merger.
Under New Jersey law, each of the consolidating
banks could be permitted to open de novo branches

THE

anywhere in the Second Banking District in which
they are both located, except in communities subject to home or branch office protection. However,
Roselle Bank, as one of the smallest banks in
Union County and in the entire district, could not
be considered among the most significant potential
entrants into areas served by Central Jersey Bank.
Central Jersey Bank is the largest commercial
bank headquartered in Somerset County, and, as of
June 30, 1968, was the 12th largest bank in the
Second Banking District. Its pattern of growth in
recent years has included substantial de novo
branching, and it would appear to be capable of
further expansion in this manner. It could not,
however, open a de novo office in Roselle. In view
of the size of Roselle Bank, and its small share
(about 1.5 percent) of commercial bank deposits in
Union County, we conclude that the proposed consolidation would be unlikely to have any significantly adverse effect on potential competition.

LITTLETON NATIONAL BANK, LITTLETON, N.H.,

AND LISBON NATIONAL BANK, LISBON,

N.H.

Banking offices
Total assets

Name of bank and type of transaction

In
operation

Lisbon National Bank, Lisbon, N.H. (15737), with
and The Littleton National Bank, Littleton, N.H. (1885), which had
merged Dec. 31, 1970, under charter and title of the latter bank (1885). The
merged bank at date of merger had

COMPTROLLER S DECISION

On July 13, 1970, Lisbon National Bank, Lisbon,
N.H., and The Littleton National Bank, Littleton,
N.H., applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter.
Littleton, N.H., home of the charter bank, is
located in Grafton County, in the northwest section of the State, approximately equidistant from
Burlington, Vt.; Portland, Maine; Boston, Mass.;
and Montreal, Canada. It has a population of
almost 5,100, and is one of a number of towns in
the upper Connectitcut River Valley with an area
population of better than 23,000. The general area
is one of scenic river valleys and wooded areas
dotted by small urban centers surrounded by rural
communities. Historically, agriculture and the lum-




$3,156,818
8,807,562
12,037,090

To be
operated

2
1

3

ber industry dominated the economy. Although
agriculture has declined, the wood products industry continues to be important. Smaller and more
diversified industry has grown up in the area,
and Littleton provides the largest concentration
of manufacturing and commercial concerns. It also
serves as retail hub for a 15- to 20-mile radius.
Tourism and recreationally-oriented industries and
construction also contribute to the area's economy.
The Littleton National Bank, the charter bank,
with IPC deposits of $5.5 million, was organized in
1871, and is a unit bank.
Other banking institutions in Littleton include
The Peoples National Bank of Littleton, organized
in 1966, with deposits of about $4 million; The
Littleton Savings Bank, with deposits of $29.1
million; and The Littleton Cooperative Bank.
157

Beneficial Finance Co. of Littleton and M.A.C.
Finance Plan of Littleton, Inc., also operate in this
town.
Lisbon also lies near the foothills of the White
Mountains, about 10 miles southwest of Littleton,
and has a population of about 1,500. Sugar Hill,
where the merging bank's branch is located, lies 5
miles from Lisbon and 12 miles from Littleton.
Adjacent to Sugar Hill, and included in the merging bank's service area, is Franconia, which is situated in the heart of the White Mountains and is a
four-season recreational area with a number of
lodges, motels, and inns catering to skiers, hunters,
tourists, and vacationers.
Lisbon National Bank, the merging bank, with
IPC deposits of $2.5 million, was organized in 1889,
under a State charter. It became a National bank in
1969. In addition to its head office, which is the
only bank in Lisbon, it operates one branch in
Sugar Hill.
Competitors for the Lisbon bank are the abovementioned banks in Littleton. Also competing with
both banks are nine other banks located between
11 and 40 miles from Lisbon and between 11 and
30 miles from Littleton. Because of easy accessibility to the area by means of superhighways, a number of the larger banks in Concord and Manchester,
N.H., are constantly soliciting local deposits and
loans, in some cases offering more attractive financial arrangements.
This merger would benefit the communities
where both banks presently exist by creating a
larger institution more capable of meeting the
area's banking needs. Trust facilities will be expanded in Littleton, and introduced actively in
Lisbon as a result of this merger. The marshalling
of the resources of the two banks will permit a
modest data processing system to be installed. The
larger lending limit will mean that fewer loan participations will be necessary. Development of management in depth will help to improve existing
services, as well as provide new ways of satisfying

158




customer needs. The merged institution should be
in a position to pay higher salaries and thus attract
more capable people. The normal operating economies resulting from such a merger would generally
make available better service at lower cost.
Competition will not be adversely affected. Although one banking alternative will be eliminated,
the combination of these two small banks should
not significantly disadvantage competing institutions as many alternatives will remain. A larger
bank will be in a better position to meet the competitive challenges within and outside the area.
Applying the statutory criteria, it is concluded
the proposed merger is in the public interest. The
application is, therefore, approved.
NOVEMBER 30,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The towns of Littleton (population 5,000) and
Lisbon (population 1,500) are located in the
northern part of Grafton County, and are approximately 10 miles apart. Sugar Hill (population 400),
where Lisbon National operates a branch office, is
10 miles from Lisbon and 12 miles from Littleton.
Littleton is the trading center for the smaller towns
within a radius of 15 to 20 miles; and there are a
considerable number of other small banks in this
broad area. Economic growth in the LittletonLisbon area is slow. There are a few industrial
firms in Littleton, primarily lumber and apparel
manufacturers.
This proposed merger involves two small banks
located in small communities approximately 10
miles apart. Lisbon National is the only bank in
Lisbon. There are two banks in Littleton: The
Peoples National Bank of Littleton (total deposits
$3.3 million) and Littleton National. There are
no other banks in the intervening area. Thus, the
proposed merger would eliminate direct competition between the merging banks; and, for this
reason, would have an adverse effect on competition
in the Littleton-Lisbon area.

//. Mergers consummated pursuant to corporate reorganization, involving a singl
operating bank
GOSHOGTON NATIONAL BANK, COSHOCTON, OHIO, AND NATIONAL BANK OF GOSHOGTON, COSHOCTON, OHIO
Banking offices

Total assets

Name of bank and type of transaction

To be
operated

In
operation

$45,738,949
120,000

Goshocton National Bank, Goshocton, Ohio (13923), with
and National Bank of Coshocton, Goshocton, Ohio (13923), which had
merged Jan. 3, 1970, under charter of the latter bank (13923) and title "Goshocton National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 10, 1969, the Coshocton National
Bank, Coshocton, Ohio, and the National Bank of
Coshocton (organizing), Coshocton, Ohio, applied
to the Comptroller of the Currency for permission
to merge under the charter of the latter and with
the title of the former.
Coshocton National Bank, the merging bank, is
headquartered in Coshocton, and has two branches,
both in Coshocton. This bank, with total resources
of $43.6 million and IPC deposits of $36.4 million,
was originally chartered in 1892.
National Bank of Coshocton, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the First Bane
Group of Ohio, Inc. The charter bank will not be
operating as a commercial bank prior to the
merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking busi-

3
0

3

45,858,949

ness at the same locations and with the same name
as presently conducted by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
NOVEMBER 25,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First Bane Group of Ohio, Inc., a registered
bank holding company, proposes to acquire all of
the voting shares of National Bank of Coshocton
(organizing), a non-operating institution, and as a
contemporaneous transaction, to effect the merger
of Coshocton National Bank into National Bank of
Coshocton (organizing). The effect of these transactions will be to transfer control of an existing
bank to a registered bank holding company. In and
of itself, however, the proposed merger would
merely combine an existing bank with a non-operating institution; as such, and without regard to acquisition of the surviving bank by First Bane Group
of Ohio, Inc., the proposed merger would have no
effect on competition.

FIRST NATIONAL BANK OF CAMBRIDGE, CAMBRIDGE, OHIO, AND T H E GUERNSEY COUNTY NATIONAL BANK,
CAMBRIDGE, OHIO
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Cambridge, Cambridge, Ohio (6566), with
and The Guernsey County National Bank, Cambridge, Ohio (6566), which had. .
merged Jan. 3, 1970, under charter of the latter bank (6566) and title "First
National Bank of Cambridge." The merged bank at date of merger had




$28,898,008
120,000
29,018,008

To be
operated

2
0

2

159

locations and with the same name as is presently
used by the merging bank.
Applying the statutory criteria, we find that the
proposed merger is in the public interest and the
application is, therefore, approved.

COMPTROLLER'S DECISION

On September 9, 1969, the First National Bank
of Cambridge, Cambridge, Ohio, and The Guernsey County National Bank (organizing), Cambridge,
Ohio, applied to the Comptroller of the Currency
for permission to merge under the charter of the
latter and with the title of the former.
First National Bank of Cambridge is headquartered in Cambridge, and operates one drive-in
branch, located in Cambridge. The bank, which
was chartered in 1863, now has total resources of
$25.9 million, and IPC deposits of $20.9 million.
The Guernsey County National Bank, the charter
bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the First
Bane Group of Ohio, Inc., a registered bank holding company. The charter bank will not be operating prior to the merger.
Since the merging bank is the only operating
bank involved in the proposed transaction, no adverse effect on competition can result from consummation of the proposed merger. The resulting bank
will conduct the same banking business at the same

FIRST NATIONAL BANK OF N E W J ERSEY, NEWARK, N.J.,

NOVEMBER 25,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First Bane Group of Ohio, Inc., a registered
bank holding company, proposes to acquire all of
the voting shares of Guernsey County National
Bank (organizing), a non-operating institution, and
as a contemporaneous transaction, to effect the
merger of First National Bank of Cambridge into
Guernsey County National Bank (organizing). The
effect of these transactions will be to transfer control of an existing bank to a registered bank holding company. In and of itself, however, the proposed merger would merely combine an existing
bank with a non-operating institution; as such, and
without regard to acquisition of the surviving bank
by First Bane Group of Ohio, Inc., the proposed
merger would have no effect on competition.

AND NATIONAL STATE BANK OF N E W JERSEY, NEWARK,

NJ.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National State Bank of New Jersey, Newark, N J . (1452), with
and National State Bank of New Jersey, Newark, N J . (1452), which had
merged Jan. 14, 1970, under charter of the latter bank (1452) and title "First
National State Bank of New Jersey." The merged bank at date of merger h a d . . . .

COMPTROLLER S DECISION

On August 18, 1969, the National State Bank of
New Jersey (organizing), Newark, N.J., applied to
the Office of the Comptroller of the Currency for
permission to merge with the First National State
Bank of New Jersey, Newark, N.J., under the
charter of the former and with the title of the
latter.
The First National State Bank of New Jersey,
the merging bank, is located in Newark, N.J., a city
of 400,000. The bank was chartered in 1812, and
presently has IPC deposits of $586.9 million. At the
160




$837,613,392
256,000
837,620,610

To be
operated

29
0
29

time of the application it had 27 active branches in
addition to the main office.
The National State Bank of New Jersey, the
charter bank, which is owned by First National
State Bancorporation, a holding company, is being
organized as a means to transfer ownership of the
First National State Bank of New Jersey to the
holding company. Prior to the merger, the organizing bank will not be operational. With the exception of the directors' qualifying shares, all of the
shares of the resulting bank will be owned by First
National State Bancorporation.
Because the merging bank is the only operating

bank in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting
bank will continue to conduct the merging bank's
business at the present locations, under title of the
First National State Bank of New Jersey.
The application is, therefore, approved.
DECEMBER 9,

1969

SUMMARY OF REPORT BY ATTORNEY

GENERAL

The proposed merger is part of a plan by which
an existing bank will become a wholly-owned subsidiary of First National State Bancorporation. It
would combine an existing bank with a nonoperating institution, As such, it is merely a step
in what is essentially a corporate reorganization
and will have no effects on competition.

GALLATIN NATIONAL BANK, UNIONTOWN, PA., AND BLYTHE NATIONAL BANK, UNIONTOWN, PA.
Banking
Name of bank and type of transaction

offices

Total assets
To be
operated

In
operation

Gallatin National Bank, Uniontown, Pa. (5034), with
and Blythe National Bank, Uniontown, Pa. (5034), which had
merged Feb. 24, 1970, under charter of the latter bank (5034) and title "Gallatin
National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On October 21, 1969, the Blythe National Bank
(organizing), Uniontown, Pa., applied to the Office
of the Comptroller of the Currency for permission
to merge with the Gallatin National Bank, Uniontown, Pa., under the charter of the former and with
the title of the latter.
The Gallatin National Bank, the merging bank,
is located in Uniontown, Pa., a city of 17,900. The
bank was chartered in 1896, and presently has IPC
deposits of $126.4 million. At the time of the application it had 19 active branches and one approved,
but unopened, facility.
The Blythe National Bank, Uniontown, Pa.,
owned by the GNB Corporation, is being organized
as a means to transfer ownership of the Gallatin
National Bank to the holding corporation. Prior to
the merger, the organizing bank will not be operational. With the exception of the directors' qualify-

$148,702,947
120,000

20
0

20

148,708,580

ing shares, all of the shares of the resulting bank
will be owned by the GNB Corporation.
Because the Gallatin National Bank is the only
operating bank in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will continue to conduct the merging bank's business at the present locations, under
title of the Gallatin National Bank.
The application is, therefore, approved.
DECEMBER 19,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger] * * * is part of a transaction which
will result in a presently existing bank becoming a
wholly-owned subsidiary of a one-bank holding
company. Thus, * * * [it] is merely part of a corporate reorganization, and as such will have no
effect on competition.

COLUMBUS NATIONAL BANK OF RHODE ISLAND, PROVIDENCE, R.I.,

AND RHODES NATIONAL BANK, PROVIDENCE,
Banking

Name of bank and type of transaction

•

47 395 ,936

To be
operated

coo

$47 231 ,200
258 ,700
•




offices

Total assets
In
operation

Columbus National Bank of Rhode Island, Providence, R.I. (13981), with
and Rhodes National Bank, Providence, R.I. (13981), which had
merged Feb. 27, 1970, under charter of the latter bank (13981) and title "Columbus National Bank of Rhode Island." The merged bank at date of merger had. .

R.I.

8

161

COMPTROLLER S DECISION

On August 29, 1969, the Rhodes National Bank
(organizing), Providence, R.I., applied to the Office of the Comptroller of the Currency for permission to merge with the Columbus National Bank
of Rhode Island, Providence, R.I., under the
charter of the former and with the title of the latter.
The Columbus National Bank of Rhode Island,
the merging bank, is located in Providence, R.I.,
a city of 200,000. The bank was chartered in 1934
and presently has IPC deposits of $34.8 million. At
the time of the application it had seven active
branches, one approved but under construction,
and an application pending for another facility.
The Rhodes National Bank, Providence, R.I.,
owned by National Columbus Bancorporation, is
being organized as a means to transfer ownership
of the Columbus National Bank of Rhode Island
to the National Columbus Bancorporation. Prior
to the merger, the organizing bank will not be
operational. With the exception of the directors'

qualifying shares, all of the shares of the resulting
bank will be owned by the National Columbus
Bancorporation.
Because the Columbus National Bank of Rhode
Island is the only operating bank in the proposed
transaction, there can be no adverse effect on competition resulting from consummation of the proposed merger. The resulting bank will conduct the
merging bank's business at the present locations,
under title of the Columbus National Bank of
Rhode Island.
The application is, therefore, approved.
JANUARY 5,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger] # # # is part of a transaction
which will result in a presently existing bank becoming a wholly-owned subsidiary of a one-bank
holding company. Thus, * * * [it] is merely part
of a corporate reorganization, and as such will
have no effect on competition.

CUMBERLAND COUNTY NATIONAL BANK AND TRUST COMPANY, N E W CUMBERLAND, PA., AND CCNB
NATIONAL BANK, N E W CUMBERLAND, P A .

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Cumberland County National Bank and Trust Company, New Cumberland, Pa.
(14542), with
and CCNB National Bank, New Cumberland, Pa. (14542), which had
merged Mar. 25, 1970, under charter of the latter bank (14542) and title "Cumberland County National Bank and Trust Company." The merged bank at date
of merger had

COMPTROLLER S DECISION

On October 2, 1969, the CCNB National Bank
(organizing), New Cumberland, Pa., applied to the
Office of the Comptroller of the Currency for permission to merge with Cumberland County National Bank and Trust Company, New Cumberland,
Pa., under the charter of the former and with the
title of the latter.
The Cumberland County National Bank and
Trust Company, the merging bank, is located in
New Cumberland, Pa., a town of 9,250. The bank
received its National charter in April 1946, and
presently has IPC deposits of $86.6 million. At the
162




$100,992,134
123,500
101,115,634

To be
operated

11
0
11

time of the application it had nine active branches
and two facilities.
The CCNB National Bank, owned by CCNB
Corporation, is being organized as a means to
transfer ownership of the Cumberland County
National Bank and Trust Company to the CCNB
Corporation. Prior to the merger, the organizing
bank will not be operational. With the exception
of the directors' qualifying shares, all of the shares
of the resulting bank will be owned by the CCNB
Corporation.
Because the Cumberland County National Bank
and Trust Company is the only operating bank in
the proposed transaction, there can be no adverse

effect on competition resulting from consummation
of the proposed merger. The resulting bank will
continue to conduct the merging bank's business at
the present locations under title of Cumberland
County National Bank and Trust Company. The
application is, therefore, approved.
DECEMBER 16,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger] * * * is part of a transaction which
will result in a presently existing bank becoming
a wholly-owned subsidiary of a one-bank holding
company. Thus, * * * [it] is merely part of a corporate reorganization, and as such will have no
effect on competition.

T H E CITIZENS NATIONAL BANK OF GHILLICOTHE, CHILLICOTHE, M O . , AND CHILLICOTHE NATIONAL BANK,
GHILLIGOTHE, M O .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Citizens National Bank of Chillicothe, Chillicothe, Mo. (4111), with
and Chillicothe National Bank, Chillicothe, Mo. (4111), which had
merged Apr. 30, 1970, under charter of the latter bank (4111) and title "The
Citizens National Bank of Chillicothe." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On May 13, 1969, The Citizens National Bank
of Chillicothe, Chillicothe, Mo., and the Chillicothe
National Bank (organizing), Chillicothe, Mo., filed
an application with the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
The Citizens National Bank was chartered in
1889, and now holds IPC deposits of $28 million.
The Chillicothe National Bank is an non-operating institution organized as a step in the corporate
reorganization of the merging bank. With the exception of the directors' qualifying shares, all of the
stock of the charter bank is owned by Citizens
Bancshares Corporation, a Missouri corporation.
Since the charter bank is a non-operating institution, approval of this application will have no

To be
operated

1
0

$39,078,164
129,638

1

39,230,582

effect on competition. Service to the public will not
be affected by this transaction as the resulting bank
will operate through the personnel and physical
facilities of the merging bank. Approval of the
merger will, however, facilitate the corporate reorganization of the merging bank.
Applying the statutory criteria, we find that this
proposal is in the public interest and the application is, therefore, approved.
JULY 10,

1969.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger] * * * is part of a transaction which
will result in a presently existing bank becoming a
wholly-owned subsidiary of a one-bank holding
company. Thus, * * * [it] is merely part of a corporate reorganization and as such will have no
effect on competition.

THE FORT WORTH NATIONAL BANK, FORT WORTH, T E X . , AND BANK OF FORT WORTH, N.A.,

FORT WORTH, T E X .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Fort Worth National Bank, Fort Worth, Tex. (3131), with
and Bank of Fort Worth, N.A., Fort Worth, Tex. (3131), which had
merged Apr. 30, 1970, under charter of the latter bank (3131), and title "The
Fort Worth National Bank." The merged bank at date of merger had




$553,845,040
250,000
554,095,040

To be
operated

1
0
1

163

COMPTROLLER'S DECISION

On February 2, 1970, the Bank of Fort Worth,
N.A. (organizing), Fort Worth, Tex., applied to the
Office of the Comptroller of the Currency for permission to merge with The Fort Worth National
Bank, Fort Worth, Tex., under the charter of the
former and with the title of the latter.
The Fort Worth National Bank, the merging
bank, is located in Fort Worth, Tex., a city of
360,000. The bank was chartered in 1873, and
presently has IPC deposits of $292.7 million.
The Bank of Fort Worth, N.A., owned by Fort
Worth National Corporation, is being organized as
a means to transfer ownership of The Fort Worth
National Bank to the holding company. Prior to
the merger, the organizing bank will not be operational. With the exception of the directors' qualifying shares, all of the shares of the resulting bank

will be owned by the Fort Worth National Corporation.
Because the merging bank is the only operating
bank in the proposed transaction, there can be no
adverse effect on competition resulting from consummation of the proposed merger. The resulting
bank will continue to conduct the merging bank's
business at the present locations, under the title of
The Fort Worth National Bank. The application
is, therefore, approved.
MARCH 17,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a transaction
which will result in Fort Worth National Bank
becoming a wholly-owned subsidiary of a one-bank
holding company. Thus, this merger is merely part
of a corporate reorganization and as such will have
no effect on competition.

T H E FIRST NATIO NAL BANK OF ST. JOSEPH, S T . JOSEPH, M O . , AND FIRST NATIONAL BANK OF
BUCHANAN COUNTY, S T . JOSEPH, M O .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of St. Joseph, St. Joseph, Mo. (4939), with
and First National Bank of Buchanan County, St. Joseph, Mo. (4939), which had.
merged May 1, 1970, under charter of the latter bank (4939) and title "The First
National Bank of St. Joseph." The merged bank at date of merger had

COMPTROLLER'S DECISION

On January 13, 1970, the First National Bank
of St. Joseph, St. Joseph, Mo., and the First National Bank of Buchanan County (organizing), St.
Joseph, Mo., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
The First National Bank of St. Joseph, the
merging bank, has total resources of $62 million,
and IPC deposits of $43 million. The First National
Bank of Buchanan County, the charter bank, is
being organized to provide a vehicle to transfer
ownership of the merging bank to the First Midwest Bancorp., Inc. The charter bank will not be
operating as a commercial bank prior to merging.
Because the merging bank is the only operating
bank involved in the proposed transaction, there

164




$60,902,363
236,800

To be
operated
2
0

61,573,596

2

can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking business at the same location and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
MARCH 25,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan of a corporate reorganization of First National Bank of
St. Joseph and will combine an existing bank with
a non-operating institution. As such, it will have no
effect on competition.

NATIONAL NEWARK & ESSEX BANK, NEWARK, N.J.,

AND ESSEX BANK, N.A.,

NEWARK,

NJ.
Banking offices

Name of bank and type of transaction

Total assets
To be
operated

In
operation

National Newark & Essex Bank, Newark, NJ. (1316), with
and Essex Bank, N.A., Newark, NJ. (1316), which had
merged June 12, 1970, under charter of the latter bank (1316) and title "National
Newark & Essex Bank." The merged bank at date of the merger had

COMPTROLLER S DECISION

On March 13, 1970, the National Newark &
Essex Bank, Newark, N.J., and the Essex Bank,
N.A. (organizing), Newark, N.J., applied to the
Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
National Newark and Essex Bank, the merging
bank, is headquartered in Newark, N.J., and has
offices located throughout Essex County. This
bank, with total resources of $710 million, and
IPC deposits of $543 million, was chartered originally in 1865.
Essex Bank, N.A., the charter bank, is being organized to provide a vehicle to transfer ownership
of the merging bank to the Midlantic Banks, Inc.
The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking

$694 ,373 ,972
250 ,000

37
0

694 ,623 ,972

37

business at the same locations and with the same
name as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
MAY 11, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which Midlantic Banks, Inc., a registered bank
holding company, proposes to acquire all of the
voting shares of Essex Bank, N.A. (org.), a nonoperating institution, and, as a contemporaneous
transaction, to effect the merger of National Newark & Essex Bank into Essex Bank, N.A. (org.).
The effect of these transactions will be to transfer
control of an existing bank to a registered bank
holding company. In and of itself, however, the
proposed merger would merely combine an existing bank with a non-operating institution; as such,
and without regard to acquisition of the surviving
bank by Midlantic Banks, Inc., the proposed
merger would have no effect on competition.

RARITAN VALLEY NATIONAL BANK, EDISON TOWNSHIP, N J . , AND SECOND RARITAN VALLEY
NATIONAL BANK, EDISON TOWNSHIP, N.J.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Raritan Valley National Bank, Edison Township, NJ. (15430), with
and Second Raritan Valley National Bank, Edison Township, NJ. (15430),
which had
merged June 12, 1970, under charter of the latter bank (15430) and title "Raritan
Valley National Bank." The merged bank at date of merger had
COMPTROLLER'S DECISION

On March 13, 1970, the Second Raritan Valley
National Bank (organizing), Edison Township,
N.J., applied to the Office of the Comptroller of the




To be
operated

$24 562,416

4

250,000

0

24 812,416

4

Currency for permission to merge with the Raritan
Valley National Bank. Edison Township, N.J.,
under the charter of the former and with the title
of the latter.
165

The Raritan Valley National Bank, the merging
bank, is located in Edison Township, N.J., a city
of 68,750. The bank was chartered in 1964, and
presently has IPC deposits of $16.5 million. At
the time of the application, it had three active
branches and one approved but unopened facility.
The Second Raritan Valley National Bank,
owned by Midlantic Banks, Inc., is being organized
as a means to transfer ownership of Raritan Valley
National Bank to the holding company. With the
exception of the directors' qualifying shares, all of
the shares of the resulting bank will be owned by
the Midlantic Banks, Inc. Prior to the merger, the
organizing bank will not be operational.
Because the Raritan Valley National Bank is the
only operating bank in the proposed transaction,
there can be no adverse effect on competition resulting from consummation of the proposed merger.
The resulting bank will continue to conduct the
merging bank's business at the present locations
under title of Raritan Valley National Bank.

The application is, therefore, approved.
11, 1970

MAY

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which Midlantic Banks, Inc., a registered bank
holding company, proposes to acquire all of the
voting shares of Second Raritan Valley National
Bank (organizing), a non-operating institution, and,
as a contemporaneous transaction, to effect the
merger of Raritan Valley National Bank into Second Raritan Valley National Bank (organizing).
The effect of these transactions will be to transfer
control of an existing bank to a registered bank
holding company. In and of itself, however, the
proposed merger would merely combine an existing bank with a non-operating institution; as such,
and without regard to acquisition of the surviving
bank by Midlantic Banks, Inc., the proposed
merger would have no effect on competition.

T H E SUSSEX AND MERCHANTS NATIONAL BANK OF NEWTON, NEWTON, N.J., AND T H E SECOND SUSSEX
AND MERCHANTS NATIONAL BANK OF NEWTON, NEWTON, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Sussex and Merchants National Bank of Newton, Newton, NJ. (925), with. .
and The Second Sussex and Merchants National Bank of Newton, Newton, NJ.
(925), which had
merged June 12, 1970, under charter of the latter bank (925) and title "The Sussex and Merchants National Bank of Newton." The merged bank at date of
merger had

COMPTROLLER'S DECISION

On March 17, 1970, The Sussex and Merchants
National Bank of Newton, Newton, N.J., and The
Second Sussex and Merchants National Bank of
Newton (organizing), Newton, N.J., applied to the
Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
The Sussex and Merchants National Bank of
Newton, the merging bank, is headquartered in
Newton, NJ., and has five offices and one approved
but unopened office located in Sussex County. This
bank, with total resources of $50 million, and IPC
deposits of $41 million, was established in 1818.
166




To be
operated

$51,962,403
125,000
52,087,403

The Second Sussex and Merchants National
Bank of Newton, Newton, N.J., the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the Midlantic
Banks, Incorporated, Newark, N.J. The charter
bank will not be operating as a commercial bank
prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking business at the same locations and with the same name
as presently used by the merging bank.

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
MAY 11, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which Midlantic Banks, Inc., a registered bank
holding company, proposes to acquire all of the
voting shares of Second Sussex and Merchants National Bank of Newton (organizing), a non-operating institution and, as a contemporaneous trans-

action, to effect the merger of Sussex and
Merchants National Bank of Newton into Second
Sussex and Merchants National Bank of Newton
(organizing). The effect of these transactions will be
to transfer control of an existing bank to a registered bank holding company. In and of itself, however, the proposed merger would merely combine
an existing bank with a non-operating institution;
as such, and without regard to acquisition of the
surviving bank by Midlantic Banks, Inc., the proposed merger would have no effect on competiton.

N E W ENGLAND MERCHANTS NATIONAL BANK OF BOSTON, BOSTON, MASS., AND N E W ENGLAND
MERCHANTS BANK (N.A.), BOSTON, MASS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

New England Merchants National Bank of Boston, Boston, Mass. (475), with.. . .
and New England Merchants Bank (National Association), Boston, Mass. (475),
which had
merged June 18, 1970, under charter of the latter bank (475) and title "New
England Merchants National Bank." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On March 3, 1969, the New England Merchants
National Bank of Boston, Boston, Mass., and the
New England Merchants Bank (N.A.) (organizing),
Boston, Mass., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title "New England Merchants National Bank."
New England Merchants National Bank of Boston, the merging bank, is headquartered in Boston,
and has three branches in Boston and one in
Revere. The bank, with total resources of $921.2
million, and IPC deposits of $495.2 million, was
originally chartered in 1831.
New England Merchants Bank (N.A), the charter
bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the New
England Merchants Company, Inc. The charter
bank will not be operating as a commercial bank
prior to the merger.




$936,819,917

15

250,000

0

To be
operated

937,069,917

15

Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking business at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
APRIL 21,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a transaction
which will result in New England Merchants National Bank of Boston becoming a wholly-owned
subsidiary of a one-bank holding company. Thus,
this merger is merely part of a corporate reorganization and, as such, will have no effect on competition.

167

FIRST NATIONAL BANK OF WARREN, WARREN, MICH., AND WARREN NATIONAL BANK, WARREN, MICH.

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In
operation
First National Bank of Warren, Warren, Mich. (15611), with
and Warren National Bank, Warren, Mich. (15611), which had
merged July 1, 1970, under charter of the latter bank (15611) and title "First
National Bank of Warren." The merged bank at date of merger had

COMPTROLLER'S DECISION

On April 22, 1970, First National Bank of Warren, Warren, Mich., and Warren National Bank
(organizing), Warren, Mich., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title
of the former.
First National Bank of Warren, the merging
bank, is headquartered in Warren, Mich., and
maintains two branches there. This bank, with
total resources of $20 million, and IPC deposits
of about $10 million, was chartered in 1966.
Warren National Bank, the charter bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to the First National Bancorporation, an Ohio corporation. The
charter bank will not be operating as a commercial
bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking busi-

THE NATIONAL BANK OF AUBURN, AUBURN, N.Y.,

3
0

$25,354,056
250,000

3

25,604,056

ness at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
MAY 28, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First National Bancorp., a registered bank
holding company, proposes to acquire all of the
voting shares of Warren National Bank (org.), a
non-operating institution, and, as a contemporaneous transaction, to effect the merger of First National Bank of Warren into Warren National Bank
(org.). The effect of these transactions will be to
transfer control of an existing bank to a registered
bank holding company. In and of itself, however,
the proposed merger would merely combine an existing bank with a non-operating institution; as
such, and without regard to acquisition of the surviving bank by First National Bancorp., the proposed merger would have no effect on competition.

AND BANK OF AUBURN, N.A.,

AUBURN,

N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The National Bank of Auburn, Auburn, N.Y. (1345), with
and Bank of Auburn, National Association, Auburn, N.Y. (1345), which h a d . . . .
merged July 28, 1970, under charter of the latter bank (1345) and title "The
National Bank of Auburn." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 1, 1969, The Bank of Auburn, N.A.,
(organizing), Auburn, N.Y., applied to this Office
168




$34,911,915
240,000
34,656,987

To be
operated
4
0
4

for permission to merge with The National Bank
of Auburn, Auburn, N.Y., under the charter of the
former and with the title of the latter.

The National Bank of Auburn, the merging
bank, is located in Auburn, N.Y., a city of 32,953.
The bank was chartered in 1817, and presently has
IPC deposits of $26.8 million. At the time of the
application, it had two drive-in branches in Auburn, and a branch in Locke, N.Y.
The Bank of Auburn, N.A., Auburn, N.Y., is
being organized as a means to transfer ownership of the National Bank of Auburn to the
Security New York State Corporation. Prior to
the merger, the organizing bank will not be operational. With the exception of the directors'
qualifying shares, all of the shares of the resulting
bank will be owned by the holding company.
Because the merging bank is the only operating
bank in the proposed transaction, there can be
no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will continue to conduct the merging bank's business at the present locations under

the title of The Bank of Auburn, N.A. The application is, therefore, approved.
JUNE 11, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which Security New York State Corporation, a registered bank holding company, proposes to acquire
all of the voting shares of Bank of Auburn (organizing), a non-operating institution and, as a
contemporaneous transaction, to effect the merger
of National Bank of Auburn into Bank of Auburn
(organizing). The effect of these transactions will
be to transfer control of an existing bank to a
registered bank holding company. In and of itself,
however, the proposed merger would merely combine an existing bank with a non-operating institution; as such, and without regard to acquisition of
the surviving bank by Security New York State
Corporation, the proposed merger would have no
effect on competition.

THE PEOPLES NATIONAL BANK AND TRUST COMPANY, DOVER, OHIO, AND T H E F.B.G. NATIONAL BANK
OF DOVER, DOVER, OHIO

Banking offices
Name of bank and type of transaction

Total assets

The Peoples National Bank and Trust Company, Dover, Ohio (4293), with
and The F.B.G. National Bank of Dover, Dover, Ohio (4293), which had
merged Aug. 31, 1970, under charter of the latter bank (4293) and title "The
Peoples National Bank and Trust Company." The merged bank at date of merger had

COMPTROLLER'S DECISION

On April 25, 1970, The Peoples National Bank
and Trust Company, Dover, Ohio, and The F.B.G.
National Bank of Dover (organizing), Dover,
Ohio, applied to the Comptroller of the Currency
for permission to merge under the charter of the
latter and with the title of the former.
The Peoples National Bank and Trust Company, the merging bank, is headquartered in
Columbus, Ohio, and has offices located in New
Philadelphia and Newcomerstown. This bank,
with total resources of $41 million, was chartered
originally in 1890.
The F.B.G. National Bank of Dover, the charter
bank, is being organized to facilitate the acquisition of the merging bank by First Bane Group.




$43,190,998
120,000

In
operation

To be
operated

4
0

43,191,034

4

The charter bank will not be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking business at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest,
and the application is, therefore, approved.
JULY 9, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
169

which First Bane Group of Ohio, Inc., a registered
bank holding company, proposes to acquire all
of the voting shares of F.B.G. National Bank of
Dover (org.), a non-operating institution and, as
a contemporaneous transaction, to effect the merger
of Peoples National Bank & Trust Company into
F.B.G. National Bank of Dover (org.). The effect
of these transactions will be to transfer control

of an existing bank to a registered bank holding
company. In and of itself, however, the proposed
merger would merely combine an existing bank
with a non-operating institution; as such, and
without regard to acquisition of the surviving
bank by First Bane Group of Ohio, Inc., the proposed merger would have no effect on competition.

PEOPLES NATIONAL BANK OF MONMOUTH COUNTY, HAZLET TOWNSHIP, N.J., AND SECOND PEOPLES NATIONAL
BANK OF MONMOUTH COUNTY, HAZLET TOWNSHIP, N.J.

Banking offices
of bank and type of transaction

Total assets
In
operation

Peoples National Bank of Monmouth County, Hazlet Township, N.J. (4147),
with
and Second Peoples National Bank of Monmouth County, Hazlet Township,
NJ. (4147), which had
merged Sept. 30, 1970, under charter of the latter bank (4147) and title "Peoples
National Bank of Monmouth County." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On July 8, 1970, the Peoples National Bank of
Monmouth County, Hazlet Township, N.J., and
the Second Peoples National Bank of Monmouth
County (organizing), Hazlet Township, N.J., applied to the Comptroller of the Currency for permission to merge under the charter of the latter
and with the title of the former.
Peoples National Bank of Monmouth County,
the merging bank, is headquartered in Hazlet
Township, N.J., and has offices located throughout the Atlantic shore area of Monmouth County,
N.J. This bank, with IPC deposits of 24.3 million,
was chartered originally in 1889.
Second Peoples National Bank of Monmouth
County, the charter bank, is being organized to
provide a vehicle to transfer ownership of the merging bank to the United Jersey Banks, a New
Jersey corporation organized as a proposed registered bank holding company. The charter bank
will not operate as a commercial bank prior to the
merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The

170




To be
operated

$33,985,363
116,467
33,977,506

resulting bank will conduct the same banking
business at the same locations and with the same
name as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
AUGUST 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which United Jersey Banks, a registered bank
holding company, proposes to acquire all of the
voting shares of Second Peoples National Bank
of Monmouth County (organizing), a non-operating institution and, as a contemporaneous transaction, to effect the merger of Peoples National
Bank of Monmouth County and Second Peoples
National Bank of Monmouth County (organizing) . The effect of these transactions will be to
transfer control of an existing bank to a registered
bank holding company. In and of itself, however,
the proposed merger would merely combine an
existing bank with a non-operating institution; as
such, and without regard to acquisition of the surviving bank by United Jersey Banks, the proposed
merger would have no effect on competition.

THE

CUMBERLAND NATIONAL BANK OF BRIDGETON, BRIDGETON, N.J.,
NATIONAL BANK, BRIDGETON, N J .

AND CUMBERLAND COUNTY

Banking offices
Total assets

Name of bank and type of transaction

In
operation

The Cumberland National Bank of Bridgeton, Bridgeton, N J . (1346) ,with
and Cumberland County National Bank, Bridgeton, N J . (1346), which had
merged Sept. 30, 1970, under charter of the latter bank (1346) and title "The
Cumberland National Bank of Bridgeton." The merged bank at date of merger
had

COMPTROLLER'S DECISION

On July 8, 1970, The Cumberland National Bank
of Bridgeton, Bridgeton, N.J., and the Cumberland
County National Bank (organizing), Bridgeton,
N.J., applied to the Comptroller of the Currency
for permission to merge under the charter of the
latter and with the title of the former.
The Cumberland National Bank of Bridgeton,
the merging bank, is headquartered in Bridgeton,
and operates three offices in Cumberland County.
This bank, with IPC deposits of $23 million, was
organized in 1816.
Cumberland County National Bank, the charter
bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to United
Jersey Banks, a New Jersey corporation organized
as a proposed registered bank holding company.
The charter bank will not operate as a commercial
bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking business at the same locations and with the same name

THE

$31,083,446
120,000

To be
operated

3
0

31,153,207

3

and personnel as are presently used by the merging
bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
AUGUST 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which United Jersey Banks, a registered bank holding company, proposes to acquire all of the voting
shares of Cumberland County National Bank (organizing), a non-operating institution and, as a
contemporaneous transaction, to effect the merger
of Cumberland National Bank of Bridgeton and
Cumberland County National Bank (organizing).
The effect of these transactions will be to transfer
control of an existing bank to a registered bank
holding company. In and of itself, however, the
proposed merger would merely combine an existing bank with a non-operating institution; as such,
and without regard to acquisition of the surviving
bank by United Jersey Banks, the proposed merger
would have no effect on competition.

THIRD NATIONAL BANK & TRUST COMPANY OF GAMDEN, GAMDEN, N J . , AND T H E FOURTH NATIONAL
BANK & TRUST COMPANY OF CAMDEN, CAMDEN, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Third National Bank & Trust Company of Camden, Camden, N J . (13203),
with
and The Fourth National Bank & Trust Company of Camden, Camden, N J .
(13203), which had
merged Sept. 30, 1970, under charter of the latter bank (13203) and title "The
Third National Bank and Trust Company of Camden, New Jersey." The merged
bank at date of merger had




To be
operated

$26,720,278
240,000

26,960,278

171

COMPTROLLER S DECISION

On July 8, 1970, The Third National Bank &
Trust Company of Camden, Camden, N.J., and
The Fourth National Bank and Trust Company
of Camden, Camden, N.J., (organizing), applied
to the Comptroller of the Currency for permission
to merge under the charter of the latter and with
the title of the former.
The Third National Bank & Trust Company of
Camden, the merging bank, is headquartered in
Camden, N.J., and has offices located throughout
the Camden Metropolitan Area. This bank, with
IPC deposits of $19.6 million, was chartered
originally in 1928.
The Fourth National Bank and Trust Company
of Camden, the charter bank, is being organized
to provide a vehicle to transfer ownership of the
merging bank to the United Jersey Banks, a New
Jersey corporation organized as a proposed registered bank holding company. The charter bank
will not be operating as a commercial bank prior
to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking

business at the same locations and with the same
name and personnel as are presently used by the
merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
AUGUST 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which United Jersey Banks, a registered bank
holding company, proposes to acquire all of the
voting shares of Fourth National Bank & Trust Co.
of Camden (organizing), a non-operating institution and, as a contemporaneous transaction, to
effect the merger of Third National Bank & Trust
Co. of Camden and Fourth National Bank & Trust
Co. of Camden (organizing). The effect of these
transactions will be transfer control of an existing
bank to a registered bank holding company. In
and of itself, however, the proposed merger would
merely combine an existing bank with a non-operating institution; as such, and without regard to
acquisition of the surviving bank by United Jersey
Banks, the proposed merger would have no effect
on competition.

BANK OF THE SOUTHWEST NATIONAL ASSOCIATION, HOUSTON, TEX., AND SOUTHWEST BANK, N.A.,

HOUSTON, T E X .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Bank of the Southwest National Association, Houston, Houston, Tex. (8645),
with
and Southwest Bank, National Association, Houston, Tex. (8645), which had. . .
merged Dec. 10, 1970, under charter of the latter bank (8645) and title "Bank of
the Southwest National Association, Houston." The merged bank at date of merger had

COMPTROLLER S DECISION

On January 21, 1970, the Southwest Bank, National Association (organizing), Houston, Tex.,
applied to the Office of the Comptroller of the
Currency for permission to merge with the Bank of
the Southwest National Association, Houston, Tex.,
under the charter of the former and with the title
of the latter.
172




To be
operated

$763,638,469
261,392
763,638,469

The Bank of the Southwest, the merging bank,
is located in Houston, Tex., a city of 1.1 million.
The bank was chartered in 1907, and presently has
IPC deposits of $441 million.
The Southwest Bank, National Association,
owned by Southwest Bancshares, Inc., is being
organized as a means to transfer ownership of the
merging bank to the holding company. Prior to

the merger, the organizing bank will not be operational. With the exception of the directors'
qualifying shares, all of the shares of the resulting
bank will be owned by Southwest Bancshares, Inc.
Because the merging bank is the only operating
bank in the proposed transaction, there can be
no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will continue to conduct the merging
bank's business at the present location under title

of the Bank of the Southwest National Association.
The application is, therefore, approved.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a transaction
which will result in Bank of the Southwest National
Association, Houston, becoming a wholly-owned
subsidiary of a one-bank holding company. Thus,
this merger is merely part of a corporate reorganization and as such will have no effect on competition.

T H E FIRST NATIONAL BANK AT EAST PALESTINE, EAST PALESTINE, O H I O , AND EAST PALESTINE NATIONAL BANK,
EAST PALESTINE, O H I O

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank at East Palestine, East Palestine, Ohio (13850), with. . .
and East Palestine National Bank, East Palestine, Ohio (13850), which had
merged Dec. 16, 1970, under charter of the latter bank (13850) and title "The
First National Bank at East Palestine." The merged bank at date of merger had. .

COMPTROLLER S DECISION

On September 17, 1970, The First National Bank
at East Palestine, East Palestine, Ohio, and East
Palestine National Bank (organizing), East
Palestine, Ohio, applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
The First National Bank at East Palestine, with
IPC deposits of $9.2 million, was organized in 1933.
It currently operates two branch offices, one in East
Palestine and one in Negley, both in Columbiana
County.
East Palestine National Bank is being organized
to provide a vehicle to transfer ownership of The
First National Bank at East Palestine to BancOhio
Corporation. East Palestine National Bank will
not be operating as a commercial bank prior to the
merger.
Because The First National Bank at East Palestine is the only operating bank involved in the
proposed transaction, there can be no adverse effect
on competition resulting from consummation of
the proposed merger.




$10,101,092
120,000

To be
operated

3
0

10,331,092

3

Applying the statutory criteria, it is concluded
that the proposed merger is the public interest. The
application is, therefore, approved.
NOVEMBER 16,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which BancOhio Corporation, a registered bank
holding company, proposes to acquire all of the
voting shares of East Palestine National Bank (organizing), a non-operating institution and, as a
contemporaneous transaction, to effect the merger
of First National Bank at East Palestine and East
Palestine National Bank (organizing). The effect of
these transactions will be to transfer control of an
existing bank to a registered bank holding company. In and of itself, however, the proposed merger
would merely combine an existing bank with a nonoperating institution; as such, and without regard
to acquisition of the surviving bank by BancOhio
Corporation, the proposed merger would have no
effect on competition.

173

CITY NATIONAL BANK, HACKENSACK, N.J.,

AND FIRST NATIONAL STATE BANK OF NORTH JERSEY, HACKENSACK,

NJ.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
City National Bank, Hackensack, N J . (12014), with
and First National State Bank of North Jersey, Hackensack, N J . (12014), which
had
merged Dec. 21, 1970, under charter and title of the latter bank (12014). The
merged bank at date of merger h a d . . . .

COMPTROLLER S DECISION

On September 25, 1970, City National Bank,
Hackensack, N.J., and First National State Bank of
North Jersey (organizing), Hackensack, N.J., applied to the Comptroller of the Currency for permission to merge under the charter and with the
title of the latter.
City National Bank, the merging bank, is headquartered in Hackensack, N.J., and has two operating branches, one located in Hackensack and one
in Little Ferry; and one approved but unopened
branch located in Wallington. All offices are located
in Bergen County. This bank, with total resources
of $45.4 million, and total IPC deposits of $37.7
million, was chartered originally in 1921.
First National State Bank of North Jersey, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to First
National Bancorporation. The charter bank will
not be operating as a commercial bank prior to the
merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The

To be
operated

$54,804,637

3

124,000

0

54,808,637

3

resulting bank will conduct the same banking business at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
NOVEMBER 2,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First National State Bancorporation, a registered bank holding company, proposes to acquire
all of the voting shares of First National State Bank
of North Jersey (organizing), a non-operating institution and, as a contemporaneous transaction, to
effect the merger of City National Bank and First
National State Bank of North Jersey (organizing).
The effect of these transactions will be to transfer
control of an existing bank to a registered bank
holding company. In and of itself, however, the
proposed merger would merely combine an existing
bank with a non-operating institution; as such, and
without regard to acquisition of the surviving bank
by First National State Bancorporation, the proposed merger would have no effect on competition.

FIRST NATIONAL BANK OF SPRING LAKE, SPRING LAKE, N.J., AND FIRST NATIONAL STATE BANK OF SPRING LAKE,
SPRING LAKE, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Spring Lake, Spring Lake, NJ. (13898), with
and First National State Bank of Spring Lake, Spring Lake, NJ. (13898), which
had
merged Dec. 21, 1970, under charter and title of the latter bank (13898). The
merged bank at date of merger had

174




To be
operated

$21,992,135

2

125,000

0

21,992,135

2

COMPTROLLER'S DECISION

On September 25, 1970, First National Bank of
Spring Lake, Spring Lake, N.J., and First National
State Bank of Spring Lake (organizing), Spring
Lake, N.J., applied to the Comptroller of the Currency for permission to merge under the charter and
with the title of the latter.
First National Bank of Spring Lake, the merging
bank, is headquartered in Spring Lake, and has
one branch which is located in Sea Girt. This bank,
with total resources of $19.6 million and IPC deposits of $17.1 million, was chartered originally in
1933.
First National State Bank of Spring Lake, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to the
First National State Bancorporation. The charter
bank will not be operating as a commercial bank
prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking busi-

ness at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
NOVEMBER 2,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First National State Bancorporation, a registered bank holding company, proposes to acquire
all of the voting shares of First National State Bank
of Spring Lake (organizing), a non-operating institution and, as a contemporaneous transaction, to
effect the merger of First National Bank of Spring
Lake, and First National State Bank of Spring Lake
(organizing). The effect of these transactions will be
to transfer control of an existing bank to a registered bank holding company. In and of itself, however, the proposed merger would merely combine
an existing bank with a non-operating institution;
as such, and without regard to acquisition of the
surviving bank by First National State Bancorporation, the proposed merger would have no effect
on competition.

THE EDISON BANK, SOUTH PLAINFIELD, N.J., AND THE EDISON BANK, N.A., SOUTH PLAINFIELD, N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Edison Bank South Plainfield, NJ. (15845), with
and The Edison Bank, National Association, South Plainfield, N J . (15845),
which had
merged Dec. 21, 1970, under charter and title of the latter bank (15845). The
merged bank at c ate of merger had. .

COMPTROLLER'S DECISION

On September 25, 1970, The Edison Bank, South
Plainfield, N.J., and The Edison Bank, N.A. (organizing), South Plainfield, N.J., applied to the
Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
The Edison Bank, the merging bank, is headquartered in South Plainfield, and has eight
branches located in Middlesex County. This bank,
with total resources of $68.3 million, and IPC deposits of $53.3 million, was chartered originally in
1956.




$74,017 ,262

9

140 000

0

74,021 ,762

To be
operated

9

The Edison Bank, N.A., the charter bank, is
being organized to provide a vehicle to transfer
ownership of the merging bank to the First National State Bancorporation. The charter bank will
not be operating as a commercial bank prior to the
merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking
business at the same locations and with the same
name as presently used by the merging bank.
175

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
NOVEMBER 2,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First National State Bancorporation, a registered bank holding company, proposes to acquire
all of the voting shares of Edison Bank, N.A. (organizing), a non-operating institution and, as a

contemporaneous transaction, to effect the merger
of Edison Bank and Edison Bank, N.A. (org.).
The effect of these transactions will be to transfer
control of an existing bank to a registered bank
holding company. In and of itself, however, the
proposed merger would merely combine an existing bank with a non-operating institution; as such,
and without regard to acquisition of the surviving
bank by First National State Bancorporation, the
proposed merger would have no effect on competition.

T H E WARREN COUNTY NATIONAL BANK, WASHINGTON, N.J., AND T H E SECOND WARREN COUNTY NATIONAL BANK,
WASHINGTON, N J .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In
operation
The Warren County National Bank, Washington, NJ. (860), with
and The Second Warren County National Bank, Washington, NJ. (860), which
had
merged Dec. 21, 1970, under charter of the latter bank (860) and title "The
Warren County National Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On January 8, 1970, The Warren County National Bank, Washington, N.J., and The Second
Warren County National Bank (organizing), Washington, N J., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
The Warren County National Bank, the merging
bank, is headquarterd in Washington, and presently has two branch offices located in Hackettstown, NJ. This bank, with total resources of $34.8
million, and IPC deposits of $29.2 million, was
chartered originally in 1865.
The Second Warren County National Bank, the
charter bank, is being organized to provide a vehicle to transfer ownership of the merging bank to
the First National State Bancorporation. The charter bank will not be operating as a commercial bank
prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there
can be no adverse effect on competition resulting
from consummation of the proposed merger. The
resulting bank will conduct the same banking busi-

176



$40,272,832

3

126,501

0

40,399,333

3

ness at the same locations and with the same name
as presently used by the merging bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
OCTOBER 27,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which First National State Bancorporation, a
proposed registered bank holding company, proposes to acquire all of the voting shares of Second
Warren County National Bank, a non-operating
institution, and to effect the merger of Warren
County National Bank and Second Warren County
National Bank. The effect of these transactions will
be to transfer control of an existing bank to a registered bank holding company. In and of itself, however, the proposed merger would merely combine
an existing bank with a non-operating institution;
as such, and without regard to acquisition of the
surviving bank by First National State Bancorporation, the proposed merger would have no effect on
competition.

///. Additional Approvals
A. Approved, but in litigation.
CATAMOUNT NATIONAL BANK, NORTH BENNINGTON, V T . , AND T H E COUNTY NATIONAL BANK OF
BENNINGTON, BENNINGTON, V T .

Banking offices
Total assets

Name of bank and type of transaction

Catamount National Bank, North Bennington, Vt. (194), with
and The County National Bank of Bennington, Bennington, Vt. (2395), which
had
applied for permission to consolidate July 15, 1970, under charter of the latter
bank (2395) and title "Catamount National Bank." The application was approved
Oct. 9, 1970. The pending consolidation was challenged by Justice Department
November 5, 1970, and is presently in litigation.

COMPTROLLER'S DECISION

On July 15, 1970, Catamount National Bank,
North Bennington, Vt., and The County National
Bank of Bennington, Bennington, Vt., applied to
the Office of the Comptroller of the Currency for
permission to consolidate under the charter of the
latter and with the title of the former.
The County National Bank of Bennington, the
charter bank, with IPC deposits of $14.5 million,
was organized in 1878. In addition to its head office,
this bank has a branch office in Arlington which is
located in the central portion of Bennington
County, approximately 15 miles north of the town
of Bennington.
Catamount National Bank, the consolidating
bank, with IPC deposits of $17.5 million, was organized in 1864. In addition to its head office
located in North Bennington, it operates an installment loan branch in a shopping center a short
distance from its North Bennington headquarters; a
branch in Manchester, in the northern portion of
Bennington County approximately 11 miles above
Arlington; and a branch in Brattleboro, approximately 40 miles east of Bennington, in Windham
County.
The service areas of the two banks, although
appearing to overlap, are not coextensive. The
natural market area of the combined bank would be
Bennington and Windham, the two southernmost
counties in Vermont, and abutting fringe areas of
adjacent States and counties. Catamount National
Bank had substantial deposits and loans from Manchester, Brattleboro, and other areas in Vermont.




In
operation

$20,893,674

4

17,548,669

2

To be
operated

Any new business it seeks must come in large measure from beyond the southwest corner of Vermont;
Catamount National Bank vigorously solicits business in the border areas of the State of New York
and in the northwest area of Massachusetts.
The population of the area served by these banks
is estimated at 79,000, of which 32,500 reside in
Windham County. Bennington has a population of
14,000, Brattleboro, 15,000, and Manchester, 2,500.
The economy of the western, or Greater Bennington portion of the service area is well diversified,
with 40 industries producing a wide assortment of
products. It also has the usual service and support
establishments. In the eastern, or Brattleboro area,
situated along the New Hampshire border, manufacturing, retail trade, and agriculture all contribute
significantly. In both areas, recreation and induced
economic activity are important income producing
factors. Restaurants, gift shops, and motels are
found in profusion throughout the market area,
and the vacation homes industry has been thriving
in recent years.
Chief banking competition for the consolidating
banks stems from two Brattleboro-based banks, both
of which operate branches in Bennington. Those
banks, two of the largest banks in the State, are
the Vermont Bank & Trust Company, with deposits
of $70.2 million, and the Vermont National Bank,
with deposits of $65.4 million. In the combined
service areas of the consolidating banks there are
24 different commercial banks, ranging in size from
the National Commercial Bank and Trust Company and the State Bank of Albany, each with over
177

$800 million in assets, to the Cambridge Valley
National Bank, with only $5.4 million in assets. The
consolidating banks rank 12th and 14th in size,
and after their consolidation would rank 10th. In
addition, a number of mutual savings banks, savings and loan associations, industrial banks, insurance companies, credit unions, finance companies,
personal loan companies, and several lending agencies of the Federal Government also do business in
the area.
The consolidation of these two banks will not
have an adverse effect on competition. Since the
services which the two offer are more complementary than competitive, their combination will not
have a significant impact on the market structure.
While their service areas overlap, they are not
coextensive. The Catamount National Bank, for
example, operates a branch in Brattleboro, and
County National does not. In downtown Bennington, the Catamount National Bank has very little
business and does not compete to any great extent
with the County National Bank because three banking offices, including offices of the two largest banks
in southern Vermont, Vermont Bank and Trust
Company, and Vermont National Bank, are strategically and conveniently located. A third large
bank in the area, such as will result from this consolidation, will doubtlessly enhance competition in
the area, providing a greater challenge to the Vermont National Bank and the Vermont Bank and
Trust Company, and will bring better services and
so benefit the entire community. Because of the
many banking outlets presently operating in the
area, the elimination of one independent banking
source will have a negligible effect.
This consolidation is necessary to enable both
banks to deal with such problems as the need for
larger lending limits, the recruitment of personnel
with specialized skills, and, particularly, the problem of holding management personnel with special skills. Even more important, the consolidation
is necessary to allow these banks to obtain enough
muscle to withstand the inroads of the larger banks
canvassing the area for business and seeking new
banking outlets. The consolidation of these two
banks is a better competitive solution than an increase in concentration among the larger banks.
Applying the statutory criteria, we conclude that

178




the proposal is in the public interest. The application is, therefore, approved.
OCTOBER 9,

1970.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the applicant banks are
located about 5 miles apart, with only one bank
in the intervening area. It appears that the proposed merger will eliminate substantial direct competition between County National and Catamount
National in Bennington County.
Bennington County is presently served by five
banks operating 10 banking offices. As of June 30,
1968, the three leading banks in the county held
about 75 percent of the total deposits in the county.
Catamount National and County National held
the second and third leading positions in the
county, with 24.4 percent and 24.1 percent of total
county deposits, respectively. The resulting bank
would hold by far the dominant position in the
county, with 48.5 percent of the total county deposits, and 50 percent of the county's banking
offices. Its share of county deposits would be twice
that of its closest competitor.
Even these substantial concentration statistics
may understate the competitive effects of this
merger, for its major impact would be in the
service area of County National, which, according
to the application, is limited to the southern section of Bennington County. As of June 30, 1968,
Catamount National and County National held
30.7 percent and 30.3 percent, respectively, of the
total deposits in this area. If the proposed merger
is approved, the resulting bank will operate four of
the seven banking offices there, and will hold about
61 percent of area deposits, again twice that of its
closest competitor.
According to the application, competing commercial banks in nearby states provide some
amount of banking competition in southern Bennington County. It is unlikely, however, that these
banks draw sufficient business from the area to
substantially reduce the marked increase in concentration in commercial banking that would result from the proposed merger.
For these reasons, we conclude that the proposed
merger would have a significantly adverse effect on
competition.

B. Approved, but consummation deferred due to related litigation.
T H E PEOPLES NATIONAL BANK OF MANASSAS, MANASSAS, V A . , AND MANASSAS BANK, N.A.,

MANASSAS, V A .

Banking offices
Name of bank and type of transaction

Total assets

The Peoples National Bank of Manassas, Manassas, Va. (6748), with
and Manassas Bank, N.A., Manassas, Va. (6748), which had
applied for permission to merge August 1, 1969, under charter of the latter bank
(6748) and title "United Virginia Bank /Peoples National." The application was
approved Feb. 2, 1970, but consummation was deferred due to related litigation.

COMPTROLLER S DECISION

On August 1, 1969, the Peoples National Bank
of Manassas, Manassas, Va., and Manassas Bank,
N.A., (organizing), Manassas, Va., applied to the
Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title "United Virginia Bank/Peoples National."
The Peoples National Bank of Manassas, the
merging bank, is headquartered in Manassas, Va.,
and operates five offices. This bank, with deposits
of $18 million, was organized in 1903.
Manassas Bank, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership of the merging bank to United Virginia
Bankshares holding company. The charter bank
will not be operating as a commercial bank prior
to the merger. Because the merging bank is the
only operating bank involved in the proposed transaction, there can be no adverse effect on competition resulting from confirmation of the proposed merger. The resulting bank will conduct
the same banking business at the same locations.




$22,086,934
125,000

In
operation

To be
operated

4
0

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
FEBRUARY 2, 1970.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan under
which United Virginia Bankshares, Inc., a registered bank holding company, proposes to acquire
all of the voting shares of Manassas Bank, N.A.,
a non-operating institution, and as a contemporaneous transaction, to effect the merger of The Peoples National Bank of Manassas into Manassas
Bank, N.A. The effect of these transactions will be
to transfer control of an existing bank to a registered bank holding company. In and of itself,
however, the proposed merger would merely combine an existing bank with a non-operating institution; as such, and without regard to acquisition
of the surviving bank by United Virginia Bankshares, Inc., the proposed merger would have no
effect on competition.

179




APPENDIX B

Statistical Tables

Statistical Tables
Table No.

Title

Comptrollers of the Currency, 1863 to the present
B—2 Administrative Assistants to the Comptroller of
the Currency and Deputy Comptrollers of the
Currency
B-3
Regional Administrators of National b a n k s . . . .
B-4
Changes in the structure of the National Banking
System, by States, 1863-1970
B—5
Charters, liquidations, and changes in issued
capital stock of National banks, calendar 1970.
B—6 Applications for National bank charters, approved and rejected, by States, calendar 1970.
B-7
Applications for National bank charters, by
States, pursuant to corporate reorganization,
calendar 1970
B—8 Newly organized National banks, by States,
calendar 1970
B-9
National bank charters issued and mergers consummated pursuant to corporate reorganizations, by States, calendar 1970
B-10 State-chartered banks converted to National
banks, calendar 1970
B-l 1 National bank charters issued pursuant to corporate reorganizations, by States, calendar 1970.
B-l 2 National banks reported in voluntary liquidation, calendar 1970
B-l 3 National banks merged or consolidated with
State banks, calendar 1970
B - l 4 National banks converted into State banks,
calendar 1970.
B-l5 Purchases of State banks by National banks,
calendar 1970
B - l 6 Consolidations of National banks, or National
and State banks, calendar 1970
B-l 7 Mergers of National banks, or National and
State banks, by States, calendar 1970
B - l 8 Mergers resulting in National banks, by assets of
acquiring and acquired banks, 1960-1970
B - l 9 Domestic branches entering the National Banking System, by de novo opening, merger, or
conversion, by States, calendar 1970
B-20 Domestic branches of National banks closed, by
States, calendar 1970

Page

B-l

182




Table No.

Title

183
184
185
186
187
188
189
190
192
195
196
197
197
198
199
199
201
208
209
219

Outstanding balances, credit cards and related
plans of National banks, Dec. 31, 1970
B-22 Principal assets, liabilities, and capital accounts
of National banks, by deposit size, year-end
1969 and 1970
B-23 Dates of reports of condition of National banks,
1914-70
B-24 Total and principal assets of National banks, by
States, June 30, 1970
B-25 Total and principal liabilities of National banks,
by States, June 30, 1970
B-26 Capital accounts of National banks, by States,
June 30, 1970
Br-27 Total and principal assets of National banks, by
States, Dec. 31, 1970
Br-28 Total and principal liabilities of National banks,
by States, Dec. 31, 1970
B-29 Capital accounts of National banks, by States,
Dec. 31, 1970
B-30 Loans of National banks, by States, Dec. 31,
1970
B-31 Income and expenses of National banks, by
States, year ended Dec. 31, 1970
B-32 Income and expenses of National banks, by
deposit size, year ended Dec. 31, 1970
B-33 Capital accounts, net income, and dividends of
National banks, 1944-70
B-34 Loan losses and recoveries of National banks,
1945-70
B-35 Securities losses and recoveries of National
banks, 1945-70
B—36 Assets and liabilities of National banks, date of
last report of condition, 1950-70
B—37 Foreign branches of National banks, by region
and country, Dec. 31, 1970
B-38 Total assets of foreign branches of National
banks, year-end, 1953-70
B-39 Foreign branches of National banks, 1960-70.. .
B-40 Assets and liabilities of National banks, Dec. 31,
1970: consolidated statement
B-41 Trust assets and income of National banks, by
States, calendar 1970. .

Page

B-21

221
222
223
225
226
227
228
229
230
231
232
244
246
247
247
248
249
250
250
250
251

TABLE B-l

Comptrollers of the Currency, 1863 to the present
Name

No.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

McCulloch, Hugh
Clarke, Freeman
Hulburd, Hiland R

Knox, John Jay

Cannon, Henry W. . . .
Trenholm, William L. .
Lacey, Edward S
Hepburn, A. Barton
Eckels, James H
Dawes, Charles G
Ridgely, William Barret
Murray, Lawrence O. .
Williams, John Skelton.
Crissinger, D. R
Dawes, Henry M
Mclntosh, Joseph W. . .
Pole, John W
O'Connor, J. F. T
Delano, Preston
Gidney, Ray M
Saxon, James J
Camp, William B




Date of
appointment

Date of
resignation

May 9, 1863
Mar. 21, 1865
Feb. 1, 1867
Apr. 25, 1872
May 12, 1884
Apr. 20, 1886
May 1, 1889
Aug. 2, 1892
Apr. 26, 1893
Jan. 1, 1898
Oct. 1, 1901
Apr. 27, 1908
Feb. 2, 1914
Mar. 17, 1921
May 1, 1923
Dec. 20, 1924
Nov. 21, 1928
May 11, 1933
Oct. 24, 1938
Apr. 16, 1953
Nov. 16, 1961
Nov. 16, 1966

Mar. 8, 1865
July 24, 1866
Apr. 3, 1872
Apr. 30, 1884
Mar. 1, 1886
Apr. 30, 1889
June 30, 1892
Apr. 25, 1893
Dec. 31, 1897
Sept. 30, 1901
Mar. 28, 1908
Apr. 27, 1913
Mar. 2, 1921
Apr. 30, 1923
Dec. 17, 1924
Nov. 20, 1928
Sept. 20, 1932
Apr. 16, 1938
Feb. 15, 1953
Nov. 15, 1961
Nov. 15, 1966

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

183

TABLE

B-2

Administrative Assistants to the Comptroller of the Currency and Deputy Comptrollers of the Currency
Name

Dates of tenure

State

ADMINISTRATIVE ASSISTANTS TO THE COMPTROLLER

Larsen, Arnold E
Faulstich, Albert J
Chase, Anthony G
Wickman, Wayne G
Nicoll, John
Howland, Jr., W. A

Dec.
July
July
Feb.
Aug.
Dec.

24,
2,
21,
27,
19,
1,

1961
1962
1965
1967
1968
1969

July
July
Feb.
Aug.
Nov.

1,
18,
25,
17,
28,

1962
1965
1967
1968
1969

Nebraska.
Louisiana.
Washington.
Texas.
New York.
Georgia.

DEPUTY COMPTROLLERS OF THE CURRENCY

Howard, Samuel T
Hulburd, Hiland R
Knox, John Jay
Langworthy, John S
Snyder, V. P
Abrahams, J. D
Nixon, R. M
Tucker, Oliver P
Coffin, George M
Murray, Lawrence O
Kane, Thomas P
Fowler, Willis J
Mclntosh, Joseph W
Collins, Charles W
Stearns, E. W
Await, F. G
Gough, E. H
Proctor, John L
Lyons, Gibbs
Prentiss, William, Jr
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, Hollis S
Camp, William B
Redman, Clarence B
Watson, Justin T
Miller, Dean E
DeShazo, Thomas G
Egertson, R. Coleman
Blanchard, Richard J
Park, Radcliffe
Faulstich, Albert J
Motter, David C
Gwin, John D

184




M a y 9, 1863
Aug. 1, 1865
Mar. 12, 1867
Aug. 8, 1872
Jan. 5, 1886
Jan. 27, 1887
Aug. 11, 1890
Apr. 7, 1893
Mar. 12, 1896
Sept. 1, 1898
June 29, 1899
July 1, 1908
M a y 21, 1923
July 1, 1923
Jan. 6, 1925
July 1, 1927
July 6, 1927
Dec. 1,1928
Jan. 24, 1933
Feb. 24, 1936
Jan. 16,1938
Jan. 16,1938
1938
Oct.
1939
May
1941
July
1941
Sept.
1944
Oct.
1949
Jan.
1950
Sept.
Mar. 1, 1951
Feb. 18,1952
Sept. 15,1959
M a y 16, 1960
Apr. 2, 1962
Aug. 4, 1962
Sept. 3, 1962
Dec. 23, 1962
Jan. 1, 1963
July 13, 1964
Sept. 1, 1964
Sept. 1, 1964
July 19, 1965
July 1, 1966
Feb. 21, 1967

Aug. 1, 1865
Jan. 31, 1867
Apr. 24, 1872
Jan. 3, 1886
Jan. 3, 1887
M a y 25, 1890
Mar. 16,1893
Mar. 11, 1896
Aug. 31, 1898
June 27, 1899
Mar. 2,1923
Feb. 14, 1927
Dec. 19, 1924
June 30, 1927
Nov. 30, 1928
Feb. 15, 1936
Oct. 16,1941
Jan. 23, 1933
Jan. 15, 1938
Jan. 15, 1938
Sept. 30, 1938
Sept. 30, 1938
Dec. 31, 1948
Aug. 31, 1941
Mar. 1, 1951
Sept. 30, 1944
Feb. 17, 1952
Aug. 31, 1950
M a y 16, 1960
Apr. 1, 1962
Dec. 31, 1962
Aug. 31, 1962
Aug. 3, 1962
Nov. 15, 1966
Oct. 26, 1963

June 30, 1966
June 1, 1967

New York.
Ohio.
Minnestoa.
New York.
New York.
Virginia.
Indiana.
Kentucky.
South Carolina.
New York.
Dist. of Columbia.
Indiana.
Illinois.
Illinois.
Virginia.
Maryland.
Indiana.
Washington.
Georgia.
California.
Texas.
California.
Iowa.
Iowa.
Iowa.
Nebraska.
Nebraska.
Texas.
New York.
Virginia.
Colorado.
Ohio.
Missouri.
Texas.
Connecticut.
Ohio.
Iowa
Virginia.
Iowa.
Massachusetts.
Wisconsin.
Louisiana.
Ohio.
Mississippi.

TABLE B-3
Regional Administrators of National banks
Region

Name

Headquarters

1

John L. Donovan

Boston, Mass

2

Charles M. Van Horn
R. Goleman Egertson
John W. Shaffer, Jr
Page Granford

New York, N.Y
Philadelphia, Pa
Cleveland, Ohio
Richmond, Va

3
4
5
6

Joseph M. Ream
7 Joseph G. Lutz
8 Kenneth W. Leaf
9 Donald B. Smith
10 John R. Burt
11 Michael Doman
12 John R. Thomas
13 H.JoeSelby
14 Arnold E. Larsen




Atlanta, Ga
Chicago, 111
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.
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, Hawaii, Nevada.

185

TABLE B-4
Changes in the structure of the National Banking System, by States, 1863-1970
12 U.S.C. 214

Consolidated and merged
under 12 U.S.C. 215
Insolvencies

2,820

6,741

159

313

4,621

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

204
8
33
166
608
270
137
32
39
303

4
0
1
1
21
5
11
0
8

4
0
0
2
45
0
8
0
0
1

45
0
6
39
66
56
7
1
7
43

62
2
21
55
394
86
69
18
13
42

0
0
1
0
4
1
1
0
0
0

0
1
1
0
18
0
15
8
0
0

89
5
3
69
60
122
26
5
11
215

209
7
112
981
450
565
459
250
122
128

CO —

0
20
14
4
6
11
4
8

2
0
2
8
5
2

87
4
65
299
205
243
198
110
53
79

8
1
1
12
2
11
5
8
0
0

0
0
2
1
4
1

8

42
0
35
227
98
205
77
37
16
13

1

62
1
7
414
122
99
171
80
49
19

157
388
355
519
98
328
206
413
18

3
41
11
8
5
13
4
2
1

15
14
4
0
4
6
1
1
0

17
28
77
116
16
58
76
83
4

69
207
157
193
35
148
76
199
8

0
1

0
3
0

11
11
5
0
0
1
0
0
1

42
86
101
199
38
98
49
125
4

86
459
97
1,026
163
263
725
781
153
1,295
70

3
52
1
126
8
3
32
12
2
107
3

7
41
1
73
22
0
20
5
3
97
2

5
60
25
130
44
100
112
85
31
211
2

23
152
37
441
58
118
336
454
103
492
58

0
1
0
11
0
0
2
22
0
6
0

0
24
0
76
9
0
6
0
4
83
0

48
129
33
169
22
42
217
203
10
299
5

136
224
221
1,344
46
85
284
244
202
303
79
1
1

8
13
9
45
4
3
23
19
11
9

13
2
1
8
0
3
47

43
93
36
142
6
17
28
51
38
54
12
0
0

49
81
94
574
21
29
74
140
68
115
26
0
1

1
2
2
41
3
1
1
0
0
0

3
0
2
4
2
6
10
1
0
0
ooo

19
33
77
530
10
26
101
25
85
125
41
1
0

....
....

. .
. .

.

. . .
....

New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia .
Wisconsin
Wyoming
Virgin Islands
Puerto Rico

. ...

. .
. ...

.

186




....
. ...
....
. ..
....

^

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
.
Montana
Nebraska
Nevada

o ooo

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana.
Maine

. .

O ND O

489

O CO O

710

CM CM C

15,853

CM

United States

ooo

Merged

In
operation
Converted Merged or Dec. 31,
1970
to State consolidated
with State
banks
banks

ooo

Consolidated

Liquidated

ooo

Organized
and opened
for business
1863-1970

TABLE B-5
Charters, liquidations, and changes in issued capital stock of National banks, calendar 1970
Capital stock
Capital notes and
debentures

Number of
banks
Increases:
Banks newly chartered:
Primary organization
Conversions of State banks
Capital stock:
Preferred: 2 cases by new issue
Common:
443 cases by statutory sale
669 cases by statutory stock dividends
7 cases by statutory consolidation
44 cases by statutory merger
5 cases by conversion of preferred stock
46 cases by conversion of capital notes
Capital notes and debentures: 67 cases by new issue. . .

Total decreases

Preferred

$20,551,020
11,579,514

•64
12

$300,000
30,324,840
214,309,815
10,291,240
18,645,995
14,098
1,297,405
$69,480,500
76

307,013,927

4
3
8

1,272,000
4,450,000

41
8
1

16,188,487
3,801,250
625,000

Total increases
Decreases:
Banks ceasing operations:
Voluntary liquidations:
Succeeded by National banks
Succeeded by State banks
Statutory consolidations
Statutory mergers. .
Converted into State banks
Merged or consolidated with State banks
Insolvent
Capital stock:
Preferred: 6 Retired
Common:
4 cases by statutory reduction
3 cases by statutory consolidation
7 cases by statutory merger
Capital notes and debentures:
46 Retirements
46 Converted to common stock

Common

69,480,500

300,000

f53

543,700

79,366
1,952,949
2,897,800
3,464,188
9,576,932
6,729,241
34,651,674

118

Net change
Charters in force Dec. 31, 1969, and issued capital

-42
4,671

Charters in force Dec. 31, 1970, and issued capital

4,629

r

272,362,253
6,165,757,000
6,438,119,253

16,849,873

79,366
r

220,634
62,453,000
62,673,634

r

52,630,627
1,119,738,000
1,172,368,627

* Includes 25 reorganized banks with capital stock of $4,453,520.
"("Includes 24 reorganized banks.
Revised.

r

NOTE: Premium on sale of common stock
Premium on convertible notes




$107,494,392 (440 cases)
5,431,839 ( 46 cases)

$112,926,231 (486 cases)

187

TABLE B-6
Applications for National bank charters, approved and rejected, by States, calendar 1970*
Approved

Rejected

Hamilton

June

4

ARKANSAS

Metropolitan National Bank, Little Rock. . Apr. 1

Eden Prairie
Carlton National Bank, Carlton
Dawson
Burnsville

CALIFORNIA

Mar. 24
May 14

Lauderdale Lakes National Bank, Lauderdale Lakes
Midway National Bank, Unincorporated
Area of Dade County
Charlotte County National Bank, Port
Charlotte
Port Charlotte
Orlando
Unincorporated Area of Dade County
East First National Bank, Fort M y e r s . . . .
Barnett Mall Bank, N.A., Winter Park. . .
Sarasota
Fort Lauderdale

Feb. 10
Dec. 16
NEW JERSEY

Jan. 12
Nov. 16
.

Jan. 16
Jan.
21
Jan. 22
Jan. 27

Voorhees Township
Apr. 8
Jefferson National Bank, Passaic
Oct. 15
jenerson ixauonai i>anK rassaic
Tow^shf N a t l ° n a l B a n k ) B n d S e w a t e r
P
Nov. 25
National" Bank,' Woodbridge
M i d j ^
n-o i
fi
Township
u e c . 10
Woodbridge Township
Fairfield National Bank, Fairfield
Burlington Township
P a n American National Bank, Union City.
Montville Township
Montville Township

Mar \7
May 13
June 17 . . . . . . . . .
July 20
July 21
Sept. 11
Sept. 24
Oct. 6

f

22

**"
Apr. 24
Apr. 24
June

9

June i8

July 15

Aug.'i8
Aug. 18

July 16
New York
July 17
Oyster Bay
Universal National Bank, Hempstead.
Aug. 3
Vanguard National Bank, Hempstead
Aug. 3
Village.
Nov. 25
Westhampton Beach.
Greensboro National Bank, Greensboro. . . May 12
TENNESSEE

Oct. 6
Nov. 25

ILLINOIS

Rolling Meadows
May 11
Suburban National Bank of Elk Grove
Village, Elk Grove Village
May 11
Tollway-Arlington National Bank of Ar-

People's National Bank of Spring Branch,
Houston
First National Bank of Tomball, Tomball.
San Benito
Promenade National Bank, Richardson. . .
Guaranty National Bank, Houston
Bergstrom Air Force Base
Bergstrom Air Force Base
Farmers Branch

Nov. 12

INDIANA

Midwest National Bank, Indianapolis.... Feb. 13

Feb. 16
Feb. 19

May 12

May 13
June 3

Village Bank (National Association),
Dallas
Sept. 17

U S * : \ \ \ ! J^Z 17 ! ! ! ! ! ! \ \

Village of Schaumburg

Mar. 27

Mountain City
TEXAS

July 23
Nov. 25

Brookhollow National Bank, Dallas

Dallas
Montgomery County
The Village National Bank, Houston
Houston
Houston

Oct.
20
Oct. 20
Oct. 20

Dec. 17

Dec. 17
Dec. 17

VIRGINIA

LOUISIANA

Kentwood

Jan. 30

Atlantic National Bank, Norfolk

Mar. 26

WASHINGTON

MARYLAND

Gaithersburg

Dec. 16
MASSACHUSETTS

The
Colonial National Bank of Danvers, Jan. 26
Danvers
Jan. 16
Mar. 31
June 18
Aug. 7

Mar. 23

Lynn wood
Olympia
Olympia

June 26
June 26
WEST VIRGINIA

Middletown National Bank, Middletown
Mall, Route 250 South, Marion County. June

8

WISCONSIN

Hartland National Bank, Hartland
July 24
West Allis
University National Bank, Milwaukee. . . . Nov. 10

•Excludes conversions, and charters to be issued pursuant to corporate reorganizations.




A

NORTH CAROLINA

July 20

Warner Robins
McDonough

188

Mar. 25
Mar. 30

NEW YORK

GEORGIA

National Bank of Marshall, Marshall
First National Bank of Bad Axe, Bad Axe.
The Niles National Bank and Trust Company, Niles
Meridian National Bank, Meridian Township

Sept.'ii
Sept. 16

St. Louis. .
Frontenac.

COLORADO

Fort Collins National Bank, Fort Collins. .
Lakewood
Unincorporated Area of Adams County
Skyline National Bank, Denver
..
Colorado Springs
A
Aurora..
FLORIDA
Worth Avenue National Bank, Palm
Beach
Southeast National Bank of Orlando,
Orlando
- - Security National Bank, Fort Myers Villas.
Security First National Bank, Plantation. .
First National Bank of Hallandale, Hallan-

Aug. 18
Sept. 3

MISSOURI

Ventura
Arcadia

NS2?B2R?IJ*S

Rejected

Approved
MINNESOTA

ALABAMA

Sept. 16

TABLE

B-7

Applications for National bank charters, by States, pursuant to corporate reorganizations, calendar 1970
Approved

Approved

Rejected

Rejected

NEW JERSEY—continued
Jefferson County National Bank, Birmingham
Dec.

8

CALIFORNIA

The Concord National Bank, Concord. . . Mar. 23
LOUISIANA

NBC National Bank, New Orleans

Sept.

9

MASSACHUSETTS

The National Bank of New Jersey, New
Brunswick, New Brunswick
The Edison Bank, National Association,
Borough of South Plainfield
First National State Bank of Spring Lake,
Spring Lake
Second Citizens National Bank of South
Jersey, Borough of Woodbine
First National State Bank of North Jersey,
Hackensack
Second New Jersey National Bank,
Trenton

The Massachusetts Bank, National Association, Boston
Aug. 19

Warren National Bank, Warren

Locust National Bank, St. Louis
American
National
A « — : ™ . Bank
n—i, of
~f St.
c* Joseph,
T ™ ~ U T\T«*™O1
Association, St. Joseph
Belt Bank of St. Joseph, National Association, St. Joseph
First Bank of Joplin National Association,
Joplin

Ithaca,

July 23
July 23
Oct. 19

NEW JERSEY

F.B.G.

~

• •

Aug.

5

Aug.

7

Aug. 17
Nov. 13

Association,

National

Bank

of Dover,
'

Jan

8

*

Aug

3

Nov.

4

Nov. 10
Nov. 12

TEXAS
Feb

13

j? , ' ,„
The Second Sussex and Merchants National * e b - l6
xanaiviercnams^auonai
B
W N
Cumberland
County
National
Bank, Feb. 17
Bank of Newton,
Newton
Bridgeton
Apr 30
The Fourth National Bank & Trust Company of Camden, New Jersey, Camden. Apr. 30
Second Peoples National Bank of Monmouth County, Hazlet Township
Apr. 30




National

„ D o £ e V ' ". • ' VT* V ' •; « ' Y "v " V i "
East Palestine National Bank, East Palestine
The F.B.G. National Bank of Wapakoneta,
Wapakoneta
The F.B.G. National Bank of Portsmouth,
Portsmouth
The F.B.G. National Bank of Wooster,
Wooster

Second Raritan Valley National Bank,
— "

5

OHIO

The
June 16

Aug.

Aug. 26

Feb, 24

MISSOURI

4

NEW YORK

Bank of
Ithaca

MICHIGAN

May

^

^

*T

•

,

A

.

.

Southwest Bank, National Association,
Houston
Jan. 9
Commerce Bank National Association,
Houston
Nov. 24
Second Southwest National Bank of El
Paso, El Paso
Dec. 16
VIRGINIA

Bank of Williamsburg, N.A., Williamsburg. Nov.

4

189

TABLE B-8

Newly organized National banks, by States, calendar 1970*
Charter
No.

Title and location of bank

Total, United States: 39 banks.

Total capital
accounts

$34,946,000
ARKANSAS

15836

Metropolitan National Bank, Little Rock.

1,250,000
COLORADO

15815

300,000

First National Bank in Aspen, Aspen.
FLORIDA

15787
15826
15778
15803
15814
15782

Second National Bank of Delray Beach, Delray Beach. . .
Eglin National Bank, Fort Walton Beach
Citizens First National Bank of Citrus County, Inverness.
Central Park First National Bank, Orlando
Southeast National Bank of Orlando, Orlando
Congress National Bank, Palm Springs
Total: 6 banks.

750,000
750,000
625,000
500,000
2,000,000
750,000
5,375,000

15794

First National Bank of Doraville, Doraville.

600,000

15824
15843

Peoples National Bank of Springfield, Springfield.
National Bank of Urbana, Urbana

500,000
500,000

Total: 2 banks.

1,000,000

MICHIGAN

15840
15801
15822

First National Bank of Bad Axe, Bad Axe
First Independence National Bank of Detroit, Detroit.
The Niles National Bank and Trust Company, Niles. .
Total: 3 banks.

500,000
1,500,000
1,001,000
3,001,000

MINNESOTA

15825
15779
15800

Carlton National Bank, Carlton
Park-Grove National Bank, Cottage Grove
Suburban National Bank of Roseville, Roseville.
Total: 3 banks.

350,000
500,000
1,500,000
2,350,000

MISSISSIPPI

15850

First National Bank of Lucedale, Lucedale.

250,000

15793

Springfield National Bank, Springfield.

750,000
NEW JERSEY

15781
15835
15839
15838

Atlantic National Bank, Atlantic City. .
Jefferson National Bank, Passaic. .
The First National Bank, Piscataway, Piscataway Township.
Mid-Jersey National Bank, Woodbridge Township

3,000,000
1,500,000
1,500,000
2,000,000

Total: 4 banks.

8,000,000

•»

—-»

«

v

1WT

_i_

*

1

Ti

See footnote at end of table.

190




1

TAT

11

* J

f • i

|

•

TABLE

B-8—Continued

Newly organized National banks, by States, calendar 1970*
Title and location of bank

Charter
No.

Total capital
accounts

TEXAS

15832
15820
15834
15802
15812
15818
15833
15809
15827

Bank of Harris County, N.A., Aldine
American National Bank, Corpus Christi
Guaranty National Bank, Houston
Houston Intercontinental National Bank, Houston
Madison-Southern National Bank, Houston
Pan American National Bank, Houston
Peoples National Bank of Spring Branch, Houston
American National Bank, Humble
First National Bank of Tomball, Tomball
Total: 9 banks

$ 1,000,000
800,000
1,000,000
600,000
720,000
1,000,000
1,000,000
500,000
500,000

7,120,000

VIRGINIA

15819

Jefferson National Bank, Lynchburg

1,500,000
WEST VIRGINIA

15842
15810

Middletown National Bank, Middletown Mall
The Suncrest National Bank, Morgantown
Total: 2 banks

500,000
750,000
1,250,000

WISCONSIN

15823
15785
15837
15831

Southridge National Bank of Greendale, Greendale
Tri-City National Bank of Hales Corners, Hales Corners. . .
Hartland National Bank, Hartland Village
First Wisconsin National Bank of West Towne, Madison. . .
Total: 4 banks

600,000
500,000
500,000
600,000
2,200,000

*Excludes charters issued pursuant to corporate reorganizations.




191

TABLE B-9
National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1970
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

MASSACHUSETTS

New England Merchants National Bank of Boston, Boston
New England Merchants Bank (National Association), Boston
Charter issued June 15, 1970
June 18, 1970

New England Merchants National Bank, Boston

$69,257,415

$937,069,917

2,134,556

25,604,056

2,801,472

39,230,582

5,603,826

61,573,596

75,602,053

837,629,610

1,685,283

24,812,416

57,339,828

694,623,972

3,342,532

52,087,403

3,490,963

31,153,207

MICHIGAN

First National Bank of Warren, Warren
Warren National Bank, Warren
Charter issued June 29, 1970
Tuly 1, 1970

First National Bank of Warren, Warren
MISSOURI

The Citizens National Bank of Chillicothe, Chillicothe
Chillicothe National Bank, Chillicothe
Charter issued April 21, 1970
Apr. 30, 1970

The Citizens National Bank of Chillicothe, Chillicothe
The First National Bank of St. Joseph, St. Joseph
First National Bank of Buchanan County, St. Joseph
Charter issued April 28, 1970

May 1, 1970

The First National Bank of St. Joseph, St. Joseph
NEW JERSEY

First National State Bank of New Jersey, Newark
National State Bank of New Jersey, Newark
Charter issued January 12, 1970
Jan. 14, 1970

First National State Bank of New Jersey, Newark
Raritan Valley National Bank, Edison Township
Second Raritan Valley National Bank, Edison Township
Charter issued June 10, 1970

June 12, 1970

Raritan Valley National Bank, Edison Township
National Newark & Essex Bank, Newark
Essex Bank, National Association, Newark
Charter issued June 10, 1970

June 12, 1970

National Newark & Essex Bank, Newark
The Sussex and Merchants National Bank of Newton, Newton
The Second Sussex and Merchants National Bank of Newton, Newton
Charter issued June 10, 1970

June 12, 1970

The Sussex and Merchants National Bank of Newton, Newton
The Cumberland National Bank of Bridgeton, Bridgeton
Cumberland County National Bank, Bridgeton
Charter issued September 28, 1970

Sept. 30, 1970

The Cumberland National Bank of Bridgeton, Bridgeton

See footnote at end of table.

192




TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizationsy by States, calendar 1970
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

NEW JERSEY—continued
The Third National Bank & Trust Company of Camden, Camden
The Fourth National Bank & Trust Company of Camden, Camden
Charter issued September 28, 1970
Sept. 30, 1970

The Third National Bank and Trust Company of Camden, C a m d e n . . .

$ 1,939,271

$ 26,960,278

2,226,998

33,977,506

3,581,752

54,808,637

6,242,148

74,021,762

1,583,352

21,992,135

3,045,118

40,399,333

2,857,715

34,656,987

2,261,848

29,018,008

3,366,770

45,858,949

Peoples National Bank of Monmouth County, Hazlet Township
Second Peoples National Bank of Monmouth County, Hazlet Township
Charter issued September 28, 1970
Sept. 30, 1970

Peoples National Bank of Monmouth County, Hazlet Township
City National Bank, Hackensack
First National State Bank of North Jersey, Hackensack
Charter issued December 17, 1970

Dec. 21, 1970

First National State Bank of North Jersey, Hackensack
The Edison Bank, South Plainfield
The Edison Bank, National Association, South Plainfield
Charter issued December 17, 1970

Dec. 21, 1970

The Edison Bank, National Association, South Plainfield
First National Bank of Spring Lake, Spring Lake
First National State Bank of Spring Lake, Spring Lake
Charter issued December 17, 1970

Dec. 21, 1970

First National State Bank of Spring Lake, Spring Lake
The Warren County National Bank, Washington
The Second Warren County National Bank, Washington
Charter issued December 17, 1970

Dec. 21, 1970

The Warren County National Bank, Washington
NEW YORK

The National Bank of Auburn, Auburn
Bank of Auburn, National Association, Auburn
Charter issued July 27, 1970
July 28, 1970

The National Bank of Auburn, Auburn
OHIO

First National Bank of Cambridge, Cambridge
The Guernsey County National Bank, Cambridge
Charter issued December 29, 1969
Jan. 3, 1970

First National Bank of Cambridge, Cambridge
Coshocton National Bank, Coshocton
National Bank of Coshocton, Coshocton
Charter issued December 29, 1969

Jan. 3, 1970

Coshocton National Bank, Coshocton

See footnote at end of table.




193

TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States, calendar 1970
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

OHIO—continued
The Peoples National Bank and Trust Company, Dover
The F. B. G. National Bank of Dover, Dover
Charter issued August 26, 1970
Aug. 31, 1970

The Peoples National Bank and Trust Company, Dover

$ 2,614 ,948

S 43,191,034

1,048 ,169

10,331,092

10,908 ,069

148,708,580

6,990 ,839

101,115,634

3,535 ,730

47,395,936

45,074 ,804

•*•

554,095,040

80,787 ,107

763,638,469

The First National Bank at East Palestine, East Palestine
East Palestine National Bank, East Palestine
Charter issued December 15, 1970
Dec. 16, 1970

The First National Bank at East Palestine, East Palestine
PENNSYLVANIA

Gallatin National Bank, Uniontown
Blythe National Bank, Uniontown
Charter issued February 20, 1970
Feb. 24, 1970

Gallatin National Bank, Uniontown

Cumberland County National Bank and Trust Company, New CumberldHU

CCNB National Bank, New Cumberland
Charter issued March 23, 1970
Mar. 25, 1970

Cumberland County National Bank and Trust Company, New Cumberland
RHODE ISLAND

Columbus National Bank of Rhode Island, Providence
Rhodes National Bank, Providence
Charter issued February 27, 1970
Feb. 27, 1970

Columbus National Bank of Rhode Island, Providence
TEXAS

The Fort Worth National Bank, Fort Worth
Bank of Fort Worth, National Association, Fort Worth
Charter issued April 27, 1970
Apr. 30, 1970

The Fort Worth National Bank, Fort Worth

>

"

"

Bank of the Southwest, National Association, Houston, Houston
Southwest Bank, National Association, Houston
Charter issued December 8, 1970
Dec. 10, 1970

Bank of the Southwest, National Association, Houston, Houston

"Includes only charter issuances related to mergers consummated during 1970. For a full listing of all charters issued during
1970, pursuant to corporate reorganizations, see Table B - l l .

194




TABLE

B-10

State-chartered hanks converted to National hanks, calendar 1970*

Charter

Title and location of bank

No.

State

Effective
date of
charter
1970

Total: 12 banks
15789
15784
15786
15790
15791
15797
15799
15804
15813
15817
15847
15851

Mercantile National Bank, Atlanta
Conversion of Mercantile City Bank.
Citizens National Bank of Grant County,
Marion
Conversion of The Van Buren Bank.
First National Bank, Evergreen
Conversion of Evergreen State Bank.
Bank of Passaic and Clifton, N.A., Passaic
Conversion of Bank of Passaic and Clifton.
University National Bank, Denver
Conversion of University Hills Bank.
First National Bank, Brewton
Conversion of Citizens-Farmers & Merchants
Bank, Inc.
First National Bank, Fontanelle
Conversion of State Savings Bank.
Montana National Bank of Butte, Butte
Conversion of Security Bank.
First National Bank of Chugwater, Chugwater. .
Conversion of Chugwater Valley Bank.
Thumb National Bank and Trust Company,
Pigeon
Conversion of Pigeon State Bank.
Old Colony Trust N.A., Boston
Conversion of Old Colony Trust Company.
First National Bank, Rosedale
Conversion of Bank of Beulah.

Outstanding
capital stock

Surplus, undivided
profits and
reserves

Total assets

$11,579,514

$18,801,857

$249,945,160

Ga

Feb. 28

415,625

688,109

Ind

Mar. 2

200,000

394,862

5,320,176

Colo

Mar. 2

250,000

426,718

7,927,462

NJ

Mar. 13

3,891,885

7,300,528

145,953,479

Colo

Mar. 26

800,000

1,139,985

27,421,984

Ala

Apr. 30

330,000

1,002,034

15,945,719

Iowa....

May 1

80,000

270,000

4,391,359

Mont....

May 20

180,000

300,289

6,795,697

Wyo

July 17

50,000

74,566

1,374,622

Mich

Aug. 12

275,000

449,042

11,327,476

Mass....

Dec. 31

5,000,000

6,668,721

14,765,009

Miss

Dec. 29

107,004

87,003

1,653,705

7,068,472

T h e Edison Bank, South Plainfield, N.J., became a National bank, The Edison Bank, National Association, during a corporate reorganization pursuant to the establishment of a one-bank holding company (see Table B-9).




195

TABLE B-l 1

National bank charters issued pursuant to corporate reorganizations, by States, calendar 1970
Title and location of bank

Charter
No.

Date of
issuance

Total: 26 banks.
LOUISIANA

13689

NBC National Bank, New Orleans.

Dec. 29
MASSACHUSETTS

200
475

15611

4111
4939

Dec. 30

Massachusetts Bank, National Association, Boston
New England Merchants Bank (National Association), Boston.

June 15

Warren National Bank, Warren.

June 29

Chillicothe National Bank, Ghillicothe
First National Bank of Buchanan County, St. Joseph.

Apr. 21
Apr. 28

NEW JERSEY

1346
13203
15430
12014
4147
1452
1316
587
925
15845
13898
860

Cumberland County National Bank, Bridgeton
The Fourth National Bank & Trust Company of Camden, Camden....
Second Raritan Valley National Bank, Edison Township
First National State Bank of North Jersey, Hackensack
Second Peoples National Bank of Monmouth County, Hazlet Township.
National State Bank of New Jersey, Newark
Essex Bank, National Association, Newark
The National Bank of New Jersey, New Brunswick
The Second Sussex and Merchants National Bank of Newton, Newton. .
The Edison Bank, National Association, South Plainfield
,
First National State Bank of Spring Lake, Spring Lake
The Second Warren County National Bank, Washington

Sept.
Sept.
June
Dec.
Sept.
Jan.
June
Dec.
June
Dec.
Dec.
Dec.

28
28
10
17
28
12
10
30
10
17
17
17

NEW YORK

1345

4293
13850

Bank of Auburn, National Association, Auburn.

July 27

The F.B.G. National Bank of Dover, Dover. .
East Palestine National Bank, East Palestine.

Aug. 26
Dec. 15
PENNSYLVANIA

14542
5034

CCNB National Bank, New Cumberland.
Blythe National Bank, Uniontown

Mar. 23
Feb. 20
RHODE ISLAND

13981

Rhodes National Bank, Providence.

Feb. 27
TEXAS

3131
8645

Bank of Fort Worth, National Association, Fort Worth.
Southwest Bank, National Association, Houston

196




Apr. 27
Dec. 8

TABLE

B-12

National banks reported in voluntary liquidation, calendar 1970
Date of
liquidation

Title and location of bank

Total: 7 National banks.

Total capital
accounts of
liquidated
banks

$12,463,170

Southland National Bank, Yucaipa, Calif. (15488) absorbed by United States National Bank, San
Diego, Calif. (10391)
Commonwealth National Bank, San Francisco, Calif. (15330) absorbed by Union Bank, Los Angeles,
Calif.
Umpqua National Bank, Reedsport, Oreg. (10676) absorbed by The Oregon Bank, Portland, Oreg. . . .
The First National Bank of Carlton, Carlton, Minn. (6973) absorbed by Carlton National Bank,
Carlton, Minn. (15825)
First National Bank in Tonasket, Tonasket, Wash. (14166) absorbed by Old National Bank of Washington, Spokane, Wash. (4668)
Gold Standard National Bank of Marienville, Marienville, Pa. (5727) absorbed by The Warren
National Bank, Warren, Pa. (4879)
Republic National Bank and Trust Company, Beverly Hills, Calif. (15331) absorbed by The Hongkong
& Shanghai Banking Corporation of California, San Francisco, Calif

TABLE

Jan. 30

1,552,640

Apr. 24
May 1

6,265,338
1,196,061

Sept. 9

141,496

Sept. 30

748,788

Oct. 30

328,579

Dec. 15

2,230,268

B-13

National banks merged or consolidated with State banks, calendar 1970

Title and location of bank

Effective
date

Total: 8 banks.
The Peoples National Bank of Hackettstown, Hackettstown, NJ. (8267) merged into Peoples Trust of
New Jersey, Hackensack, N.J., under the title "Peoples Trust of New Jersey"
The First National Bank of Salamanca, Salamanca, N.Y. (2472) merged into First Trust Union Bank,
Wellsville, N.Y., under the title of "First Trust Union Bank"
National City Bank of Baltimore, Baltimore, Md. (15102) merged into Suburban Trust Company,
Hyattsville, Md., under the title of "Suburban Trust Company"
Metropolitan National Bank of Maryland, Wheaton, Md. (14985) merged into Union Trust Company
of Maryland, Baltimore, Md., under the title "Union Trust Company of Maryland"
The First National Bank in Frackville, Frackville, Pa. (13992) merged into American Bank and Trust
Company of Reading, Reading, Pa., under the title "American Bank and Trust Company"
First National Bank in New Egypt, New Egypt, NJ. (13910) merged into Bordentown Banking
Company, Bordentown Township, NJ., under the title "The Bank of Mid-Jersey"
Citrus National Bank of West Covina, West Covina, Calif. (15216) merged into Golden State Bank of
Bell Gardens, Los Angeles, Calif., under the title "Golden State Bank"
The National Bank of Eaton Rapids, Eaton Rapids, Mich. (13995) consolidated into the American
Bank and Trust Company, Lansing, Mich., under the title "American Bank and Trust Company". . .




Total capital
accounts of
National
banks

$11,085,491
May 25

1,757,526

Aug. 31

788,664

Sept. 11

3,192,033

Oct. 19

1,277,961

Oct. 19

906,255

Oct. 23

710,457

Oct. 30

1,536,368

Dec. 31

916,227

197

TABLE B-14

National banks converted into State banks, calendar 1970
Title and location of bank

Effective
date

$53,200,254

Total: 41 banks.
City National Bank, Tulsa, Okla. (14908) converted into City Bank and Trust Company
The Farmers National Bank of Fayetteville, Fayetteville, Tex. (10954) converted into Fayetteville Bank. .
First National Bank of Owasso, Owasso, Okla. (15006) converted into First Bank of Owasso
The First National Bank of Milford, Milford, Tex. (12685) converted into First State Bank, Milford. . .
First National Bank in Atoka, Atoka, Okla. (15093) converted into First Bank in Atoka
First National Bank in Sulphur, Sulphur, Okla. (11016) converted into First Oklahoma Bank and
Trust Company in Sulphur
Founders National Bank of Oklahoma City, Oklahoma City, Okla. (15333) converted into Founders
Bank and Trust Company
First Strawn National Bank, Strawn, Tex. (12775) converted into Strawn Security Bank
The Edgar County National Bank and Trust Company, Paris, 111. (2100) converted into The Edgar
County Bank and Trust Company
The Security National Bank of Cairo, Cairo, 111. (13804) converted into Security Bank and Trust
Company.
The National Bank of Verden, Verden, Okla. (8859) converted into The Bank of Verden
The Batavia National Bank, Batavia, 111. (9500) converted into Batavia Bank
First National Bank of Haskell, Haskell, Okla. (7822) converted into First Bank of Haskell
Guaranty National Bank of Oklahoma City, Oklahoma City, Okla. (15207) converted into Guaranty
Bank and Trust Company
Commercial National Bank of Victoria, Victoria, Tex. (15130) converted into Commercial Bank of
Victoria
First National Bank of Holly, Holly, Colo. (7704) converted into First Bank and Trust
The Kingston National Bank, Kingston, Pa. (14023) converted into State Bank of Eastern Pennsylvania.
The Solomon National Bank, Solomon, Kans. (9794) converted into The Solomon State Bank
Commonwealth National Bank, Boston, Mass. (15399) converted into Commonwealth Bank and
Trust Company
Doylestown National Bank and Trust Company, Doylestown, Pa. (573) converted into Continental
Bank
First National Bank in Spirit Lake, Spirit Lake, Iowa (13020) converted into First Bank and Trust. . . .
The East Stroudsburg National Bank, East Stroudsburg, Pa. (4011) converted into Pocono Bank
The National Bank of Commerce of Tulsa, Tulsa, Okla. (9942) converted into Bank of Commerce of
Tulsa
The First National Bank in Hawarden, Hawarden, Iowa (13939) converted into First State Bank
The First National Bank of Wagoner, Wagoner, Okla. (5016) converted into First Wagoner Bank and
Trust Company
The First National Bank and Trust Company of Mount Vernon, Mount Vernon, 111. (13864) converted into First Bank and Trust Company
The Farmers National Bank of Carnegie, Carnegie, Okla. (12059) converted into The Farmers Bank. . .
The First National Bank of Sentinel, Sentinel, Okla. (9995) converted into Southwest State Bank
First National Bank of Oak Brook, Oak Brook, 111. (15596) converted into Oak Brook Bank
Continental National Bank, Phoenix, Ariz. (15364) converted into Continental Bank
The First National Bank of Minco, Minco, Okla. (8644) converted into The First American Bank
Hillside National Bank of Dallas, Dallas, Tex. (15101) converted into Hillside Bank and Trust Company. .
Commercial National Bank and Trust Company, Muskogee, Okla. (12890) converted into Commercial
Bank and Trust Company
National Bank of Commerce of Spartanburg, Spartanburg, S.C. (15619) converted into First-Citizens
Bank and Trust Company of South Carolina
First National Bank of Cleveland, Cleveland, Tex. (10276) converted into Cleveland Bank and Trust. . .
American National Bank in Pryor, Pry or, Okla. (14615) converted into American Bank of Oklahoma. .
The Havelock National Bank of Lincoln, Lincoln, Nebr. (9772) converted into Havelock Bank
The Lawndale National Bank of Chicago, Chicago, 111. (10247) converted into The Lawndale Trust and
Savings Bank
The First National Bank in Seagraves, Seagraves, Tex. (14646) converted into The First State Bank in
Se;
The Citizens National Bank of Tunkhannock, Tunkhannock, Pa. (6438) converted into United Penn
Bank
Orange National Bank, Orange, Tex. (5890) converted into Orange Bank

198




Total capital
accounts of
National
banks

an. 2
an. 2
an. 2
an. 9
Ian. 15

1,811,456
233,131
486,214
163,914
246,975

Jan. 15

868,203

Feb. 4
Feb. 16

1,121,936
172,837

Feb. 24

1,692,377

24
2
2
2

450,848
78,194
665,348
243,310

Mar. 9

1,267,275

Feb.
Mar.
Mar.
Mar.

961,775
207,340
2,107,018
345,392
Apr. 16

3,882,762
3,990,093
824,332
2,557,705
2,315,803
396,611

June 8

757,038

2,530,564
281,523
337,558
1,120,290
3,985,722
230,977
1,237,866
Aug. 31

3,391,499
2,023,008
1,013,334
1,018,979
782,063

Nov. 25
Dec. 1
Dec. 4
Dec. 30

3,177,346
324,143
893,662
3,003,833

TABLEB-15
Purchases of State banks by National banks, calendar 1970
Total capital
accounts of
State banks

Title and location of banks

Total: 6 banks

$3,741,259

First National Bank in Mansfield, Mansfield, La. (11669) purchased the Bank of Grand Cane, Grand
Cane, Louisiana
Zions First National Bank, Salt Lake City, Utah (4341) purchased the Bank of Commerce, Magna, Utah..
Zions First National Bank, Salt Lake City, Utah (4341) purchased the Bank of St. George, St. George,
Utah
Peoples National Bank of Washington, Seattle, Wash. (14394) purchased the Langley State Bank,
Langley, Washington
Park National Bank of Newark, Newark, Ohio (9179) purchased the Peoples State Bank, Granville, Ohio.
Zions First National Bank, Salt Lake City, Utah (4341) purchased the Bountiful State Bank, Bountiful,
Utah

54,945
216,431
1,137,638
403,265
935,860
993,120

TABLE B-16

Consolidations* of National banks, or National and State banks, calendar 1970
Effective
date

Consolidating banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Total: 10 consolidations
CALIFORNIA

Aug. 7

National Bank of Agriculture, Delano (15450)
The First National Bank of Caruthers, Caruthers (11330). .

$503,750
100,000

$304,688
200,000

$103,811
153,119

$12,832,543
4,087,442

603,750

504,687

257,270

17,971,623

The First National Bank of Cedar Lake, Cedar Lake
(14813)
State Bank of Whiting, Whiting
. ..

173,250
300,000

326,750
700,000

198,795
430,370

7,984,358
23,399,108

Northwest Bank of Indiana, N.A., Whiting (14813)

750,000

750,000

629,165

31,383,466

Trust Company National Bank, Morristown (4274)
Montclair National Bank and Trust Company, Montclair
(9339)

4,012,848

4,013,437

4,185,362

187,631,441

4,488,430

5,500,000

5,182,545

153,852,352

American National Bank & Trust, Montclair (4274)

8,321,740

9,701,165

9,512,596

340,612,870

The First National Bank of Roselle, Roselle (8483)
First National Bank of Central Jersey, Somerville (3866). .

300,000
3,093,750

300,000
3,906,250

1,115,391
1,736,788

17,830,469
119,944,993

First National Bank of Central Jersey, Somerville (3866). .

3,693,750

3,906,250

2,852,179

137,775,462

National Bank of Agriculture, Fresno (11330)
INDIANA

June 30

NEW JERSEY

July 10

Dec. 31

See footnote at end of table.




199

TABLE

B-l 6—Continued

Consolidations* of National banks, or National and State banks, calendar 1970
Consolidating banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW YORK

July

6

Oct. 13

National Bank of North America, New York (7703)
Trade Bank and Trust Company, New York

$24,995,835 $45,004,165 $40,563,634 $1 ,711,720,943
5,787,240
5,330,073
7,462,760
230,671,731

National Bank of North America, New York (7703)

29,029,750

60,970,250

39,143,707

1 ,942,392,675

National Bank of North America, New York (7703)
First National Bank in Yonkers, Yonkers (13882)

29,029,750
1,397,550

60,970,250
2,396,228

46,126,458
-0-

1 ,988,427,915

National Bank of North America, New York (7703)

30,918,330

69,081,670

39,920,236

2 ,138,854,709

140,426,794

PENNSYLVANIA

Jan.

1

June 30

Dec.

7

The Delaware County National Bank, Chester (355). . . .
National Bank of Chester County and Trust Company,
West Chester (552)

1,753,290

2,548,000

4,843,731

161,059,614

1,018,500

4,281,500

2,160,516

103,691,564

Southeast National Bank of Pennsylvania, Chester (355). .

3,026,415

6,829,500

6,749,622

264,751,178

The First National Bank of Westmoreland, Greensburg
(14055)
The Peoples National Bank of Tarentum, Tarentum
(5351)

1,496,000

2,640,000

2,022,690

78,418,692

500,000

1 050 000

546,119

26,640 833

Southwest National Bank of Pennsylvania, Greensburg
(5351)

3,144,000

2,500,000

2,675,809

105,059,524

Lancaster County Farmers National Bank, Lancaster
(683)
The Reading Trust Company, Reading
National Bank and Trust Company of Central Pennsylvania, York (694)

2,682,570
1,676,290

6,392,430
6,323,170

4,182,409
2,552,175

157,188,189
158,827,533

7,367,020

9,310,382

9,843,973

281,850,571

15,211,900

22,026,522

13,091,639

597,866,293

9,000,000
7,368,262

9,531,737
11,000,000

7,695,564
7,299,000

454,265,462
254,292,665

Pacific National Bank of Washington, Seattle (3417). . . . 13,750,000

23,250,000

14,894,564

708,296,502

National Central Bank, York (694)
WASHINGTON

Aug. 17

The Pacific National Bank of Seattle, Seattle (13230)
National Bank of Washington, Tacoma (3417)

*Excludes consolidations involving only 1 operating bank, effected pursuant to corporate reorganizations.

200




TABLEB-17
Mergers* of National banks, or National and State banks, by States, calendar 1970

Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Total: 60 merger actions
CALIFORNIA

Apr. 10

June 11

July 31

Nov. 6

Los Padres National Bank, Santa Maria (15271)
Wells Fargo Bank, National Association, San Francisco (15660)

$500,000

$375,000

$356,628

$12,438,566

91,757,810

185,242,820

56,400,610

5,436,787,409

Wells Fargo Bank, National Association, San Francisco (15660)

92,257,810

185,542,420

56,757,238

5,449,225,975

Gateway National Bank, El Segundo (15239)
Southern California First National Bank, San Diego
(3050)

1,595,226

1,126,314

265,311

31,745,184

7,062,495

13,285,305

12,044,200

601,086,646

Southern California First National Bank, San Diego
(3050)

7,062,495

13,285,305

15,031,052

632,831,830

Bank of Sacramento, Sacramento
2,262,750
Security Pacific National Bank, Los Angeles (2491). . . 168,000,000

2,447,250
182,000,000

127,667
122,362,960

42,497,359
6,722,389,757

Security Pacific National Bank, Los Angeles (2491). . . 170,262,750

189,737,250

116,522,457

6,758,034,271

The First National Bank of Holtville, Holtville (9770).
Wells Fargo Bank, National Association, San Francisco (15660)

400,000

400,000

179,980

13,927,142

92,419,970

185,455,260

65,490,961

5,514,746,846

Wells Fargo Bank, National Association, San Francisco (15660)

92,859,970

185,815,260

65,670,942

5,527,924,917

The Atlantic National Bank, Stamford (15584)
The Connecticut National Bank, Bridgeport (335). . .

350,000
6,451,225

650,000
12,000,000

176,318
4,159,177

19,569,744
360,808,344

The Connecticut National Bank, Bridgeport (335). . .

7,151,225

12,900,000

4,164,714

380,378,088

General Bank and Trust Company, New Haven
Hartford National Bank and Trust Company, Hartford (1338)

400,000

400,000

150,000

8,076,269

17,693,525

44,306,475

15,593,199

1,041,105,191

Hartford National Bank and Trust Company, Haftford (1338)

17,993,525

44,806,475

17,743,299

1,048,981,460

Lava Hot Springs State Bank, Lava Hot Springs. . . .
The Cassia National Bank of Burley, Burley (12256).

25,000
250,000

80,000
350,000

11,252
290,343

739,857
13,081,949

The Cassia National Bank of Burley, Burley (12256).

360,000

350,000

290,343

13,821,806

Fidelity National Bank of Twin Falls, Twin Falls
(11100)
The Idaho First National Bank, Boise (1668)

1,000,000
8,002,315

1,000,000
17,000,000

848,701
6,958,357

27,413,294
500,740,908

The Idaho First National Bank, Boise (1668).

8,714,815

18,000,000

8,094,559

524,045,759

CONNECTICUT

Apr. 17

Oct. 30

May 18

July 1

See footnote at end of table.




201

TABLE

B-17—Continued

Mergers* of National banks, or National and State banks, by States, calendar 1970
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

INDIANA

Dec. 1

The First National Bank of Center Point, Center Point
(9250)
The Riddell National Bank of Brazil, Brazil (5267)

$25,000
400,000

$125,000
400,000

$229,948
1,218,484

$3,055,397
22,782,237

The Riddell National Bank of Brazil, Brazil (5267). . .

475,000

525,000

1,389,554

25,428,913

KANSAS

July 31

Exchange State Bank of Kansas City, Kansas C i t y . . . .
The Commercial National Bank of Kansas City,
Kansas City (6311)

500,000

500,000

343,067

15,619,327

3,000,000

3,000,000

3,896,406

108,190,718

The Commercial National Bank of Kansas City,
Kansas City (6311) .

3,475,000

4,000,000

3,764,473

117,021,889

400,000

600,000

788,414

20,433,149

157,500

210,000

230,155

8,986,563

610,000

1,493,078

269,922

29,541,440

The First National Bank of Pittsfield, Pittsfield (13777).
Maine National Bank, Portland (4128)

250,000
5,020,330

250,000
6,479,670

576,648
3,894,441

12,129,152
190,482,404

Maine National Bank, Portland (4128)

5,420,330

6,729,960

4,471,090

202,611,556

MAINE

June 2

The First National Bank of Houlton, Houlton (2749). .
The First National Bank of Fort Fairfield, Fort Fairfield (13843)
The First National Bank of Aroostook, Fort Fairfield
(13843)

Aug. 14

MARYLAND

May 1

July 6

The First National Bank of Harford County, Bel Air
(13680)
The First National Bank of Maryland, Baltimore
(1413)
.

700,000

1,100,000

790,561

38,156,284

12,123,760

25,376,240

14,385,656

727,720,018

The First National Bank of Maryland, Baltimore
(1413)

12,526,260

27,473,740

12,699,081

761,510,201

Montgomery Banking Trust Company, Rockville
University National Bank, Rockville (15365)

1,000,000
1,434,000

500,000
1,999,630

93,102
212,551

11,181,628
39,207,224

University National Bank, Rockville (15365)

2,394,000

2,632,732

212,551

48,536,914

Bristol County Trust Company, Taunton
The First National Bank of Attleboro, Attleboro (2232).

750,000
1,000,000

1,371,800
1,000,000

691,069
1,233,829

38,417,295
32,267,252

First Bristol County National Bank, Taunton (2232). .

2,400,000

2,400,000

1,411,457

70,584,400

MASSACHUSETTS

June 30

MICHIGAN

Mar. 18

The Armada State Bank, Armada
First National Bank in Mt. Clemens, Mt. Clemens
(12971)

150,000

150,000

254,485

5,983,449

1,320,000

1,320,000

1,299,784

75,588,838

First National Bank in Mt. Clemens, Mt. Clemens
(12971)

1,488,750

1,961,250

1,299,784

81,827,802

See footnote at end of table.

202




TABLE B-17—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1970
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW HAMPSHIRE

Aug. 14

The Wilton National Bank, Wilton (13247)
The Indian Head National Bank of Nashua, Nashua
(1310)

$100,000

$370,000

$344,684

$10,266,204

997,775

4,502,225

540,136

61,808,730

1,104,900

5,000,000

612,516

72,071,608

Lisbon National Bank, Lisbon (15737). . .
Littleton National Bank, Littleton (1885).

75,000
150,000

75,000
200,000

77,275
225,792

3,156,868
8,807,562

The Littleton National Bank, Littleton (1885).

225,000

275,000

260,420

12,037,090

777,600

1,410,400

110,375

55,387,215

12,000,000

4,830,125

374,309,033

10,361,750

15,000,000

2,337,297

430,173,045

The Indian Head National Bank of Nashua, Nashua
(1310)
Dec. 31

NEW JERSEY

Jan. 2

The Bank of Sussex County, Franklin
National Community Bank of Rutherford, Rutherford
(5005)
National Community Bank of Rutherford, Rutherford
(5005)

Jan. 9

Feb. 27

Apr. 30

May 11

May 22

8,093,750,

Peoples National Bank of Sussex County, Sparta
(15375)
New Jersey Bank (National Association), Clifton
(15709)

245,400

222,700

124,960

8,599,317

7,923,366

12,138,938

9,760,327

506,883,752

New Jersey Bank (National Association), Clifton
(15709)

8,125,821

12,404,583

9,885,288

515,199,963

Jersey State Bank, River Edge
New Jersey Bank (National Association), Clifton
(15709)

444,672

555,325

349,992

20,516,992

8,164,728

12,574,359

10,621,472

506,259,053

New Jersey Bank (National Association), Clifton
(15709)

8,714,728

13,024,359

10,971,465

526,776,046

Union National Bank and Trust Company, Mount
Holly (2343)
South Jersey National Bank, Camden (1209)

1,224,000
5,076,563

988,000
11,923,437

921,244
7,339,194

34,499,979
305,339,193

South Jersey National Bank, Camden (1209)

5,765,063

13,446,938

8,260,438

339,637,141

New Jersey National Bank and Trust Company,
Neptune (15297)
First Trenton National Bank, Trenton (1327)

3,687,592
5,925,160

3,562,408
8,376,720

3,239,609
11,273,656

134,280,383
508,284,242

New Jersey National Bank, Trenton (1327).

8,998,155

12,553,725

14,513,266

642,564,625

The Vineland National Bank and Trust Company,
Vineland (2918)
Peoples National Bank of New Jersey, Westmont
(12022)

600,000

1,400,000

1,210,202

29,709,165

2,186,379

3,736,103

1,975,335

131,715,508

Peoples National Bank of New Jersey, Westmont
(12022)

3,502,629

3,736,103

1,691,704

166,461,909

See footnote at end of table.




203

TABLE B-l 7—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1970
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

NEW JERSEY—continued

June 30 First National Bank of Williamstown, Williamstown

July 17

Oct. 30

Dec. 4

(7265)
First National Bank of South Jersey, Egg Harbor
Township (1326)

$150,000

$550,000

$113,279

$15,976,524

6,770,000

6,770,000

3,818,921

256,385,345

First National Bank of South Jersey, Egg Harbor
Township (1326)

7,340,000

7,340,000

3,482,201

272,361,869

125,000

1,000,000

469,547

15,748,018

Pitman National Bank and Trust Company, Pitman
(8500)
The First National Bank and Trust Company of
Paulsboro, Paulsboro (5981)
First County National Bank and Trust Company,
Woodbury (1199)

330,000

330,000

1,571,907

24,218,387

491,420

1,508,580

874,279

40,681,659

National Bank and Trust Company of Gloucester
County, Woodbury (1199)

1,137,420

2,838,580

2,822,277

80,777,365

The First National Bank of Pedricktown, Pedricktown
(8007)
First National Bank of South Jersey, Egg Harbor
Township (1326)

200,000

250,000

98,875

6,273,493

7,340,000

7,340,000

3,979,357

285,013,575

The First National Bank of South Jersey, Egg Harbor
Township (1326)

7,640,000

7,640,000

3,928,232

291,287,068

Orange Valley Bank, Orange
First National State Bank of New Jersey, Newark
(1452)

125,000

175,000

299,375

7,051,864

12,423,750

40,040,000

10,357,619

861,185,593

First National State Bank of New Jersey, Newark
(H52)

12,423,750

40,340,000

10,656,994

866,967,712

Rockland National Bank, Suffern (5846)
County National Bank, Middletown (13956).

2,901,855
3,355,005

3,000,000
4,600,000

2,399,825
2,060,628

149,118,970
171,844,047

Empire National Bank, Middletown (5846). ,

6,256,860

7,600,000

4,460,452

320,963,017

NEW YORK

Feb. 27

July 31

The National Exchange Bank of Boonville, Boonville
(8022)
Lincoln National Bank and Trust Company of Central
New York, Syracuse (15627)

100,000

200,000

288,469

6,069,082

5,000,000

6,500,000

4,984,707

243,069,535

Lincoln National Bank and Trust Company of Central
New York, Syracuse (15627)

5,100,000

6,700,000

5,273,177

249,138,617

NORTH CAROLINA

Jan. 23 Citizens Bank and Trust Company of Andrews,

Andrews
Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)

600,000

1,000,000

692,386

33,025,897

24,720,035

62,318,000

30,086,560

1,596,594,516

Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)

25,320,035

63,318,000

30,778,946

1,629,620,413

See footnote at end of table.

204




TABLE B-17—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1970
Effective
date

Merging banks
Resulting bank

Undivided
profits and
reserves

Outstanding
capital
stock

Surplus

Marion Bank and Trust Company, Marion
North Carolina National Bank, Charlotte (13761).

$100,000
15,274,340

$300,000
44,875,660

$121,544
17,155,939

$4,638,685
1,223,694,661

North Carolina National Bank, Charlotte (13761).

15,524,340

44,875,660

17,277,482

1,228,333,346

The First National Bank of Mooresville, Mooresville
(9531)
The First National Bank of Lincolnton, Lincolnton
(6744)

250,000

600,000

263,868

11,138,427

300,000

400,000

907,440

21,496,891

Carolina First National Bank, Lincolnton (6744).

700,000

1,300,000

721,308

32,635,318

Total assets

NORTH CAROLINA—continued

Feb. 20

Apr. 30

July 27

Aug. 1

Aug. 28

Nov. 14

Jan. 19

Feb. 28

July 17

The State Bank of Wingate, Wingate
First National Bank of Eastern North Carolina,
Jacksonville (14676)

50,000

250,000

66,106

3,046,720

3,065,375

5,075,625

848,528

105,073,518

First National Bank of Eastern North Carolina,
Jacksonville (14676)

3,180,375

5,271,625

903,634

108,120,239

Bank of Charlotte, Charlotte
Southern National Bank of North Carolina, Lumberton (10610)

200,000

1,600,000

286,440

23,910,939

3,814,105

4,547,205

2,754,013

167,058,069

Southern National Bank of North Carolina, Lumberton (10610)

3,814,105

4,546,205

930,761

202,508,937

The State Commercial Bank, Thomasville
North Carolina National Bank, Charolotte (13761). . .

372,180
15,524,340

745,715
44,875,660

413,842
21,249,003

17,827,185
1,284,569,745

North Carolina National Bank, Charlotte (13761)

16,082,610

45,435,285

21,736,547

1,302,645,825

The Bank of French Broad, Marshall
First Union National Bank of North Carolina,
Charlotte (15650)

100,000

451,745

228,244

8,906,330

17,868,825

25,500,000

11,907,261

1,042,875,218

First Union National Bank of North Carolina,
Charlotte (15650)

18,068,825

26,000,000

11,987,250

1,051,781,548

The West Unity Banking Company, West Unity. . . .
The Citizens National Bank of Bryan, Bryan (13740).

160,000
325,620

240,000
325,730

205,546
513,964

7,476,663
18,416,311

The Citizens National Bank of Bryan, Bryan (13740).

518,180

565,730

686,950

25,976,478

Hardy Banking Company, North Baltimore.
First National Bank, Bowling Green (15416).

50,000
1,113,750

250,000
1,186,250

193,815
399,192

4,281,052
30,728,502

First National Bank, Bowling Green (15416).

1,323,750

1,426,250

457,839

34,864,742

The Citizens Savings Bank, Columbiana.
The Farmers National Bank of Salem, Salem (973).

125,000
750,000

525,000
1,000,000

226,909
736,133

11,094,201
37,561,201

The Farmers National Bank of Salem, Salem (973).

1,062,500

1,525,000

775,543

48,655,402

See footnote at end of table.




205

TABLE

B-17—Continued

Mergers* of National banks, or National and State banks, by States, calendar 1970
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

OHIO—continued
Nov.

6

$200,000
575,000

$123,426
705,991

$5,459,261
28,962,951

637,640

775,000

752,970

34,383,265

Community Bank and Trust Company, Paoli
Central Penn National Bank, Bala-Cynwyd (723)

930,250
6,323,620

2 ,098,625
16 ,244,085

941,276
10,858,188

48,912,682
444,909,782

Central Penn National Bank, Bala-Cynwyd (723)

7,253,870

18 ,342,710

11,799,463

488,940,101

The Citizens National Bank, Blossburg (13381)
First National Bank in Mansfield, Mansfield (13618). .

50,000
125,000

200,000
250,000

222,624
589,119

5,419,069
11,901,611

First Citizens National Bank, Mansfield (13618)

500,000

500,000

436,744

17,320,680

The Fogelsville National Bank, Fogelsville (12975). . .
The Merchants National Bank of Allentown, Allentown (6645)
.

281,250

625,000

815,033

20,875,731

2,697,990

6 000,000

2,370,373

185,639,802

The Merchants National Bank of Allentown, Allentown (6645)

3,541,740

,625,000

2,645,553

206,538,179

The Pioneer Banking Company, Pioneer
The Citizens National Bank, Bryan (13740)

$75,000
525,140

The Citizens National Bank, Bryan (13740)

:

PENNSYLVANIA

Mar. 13

Mar. 31

June

July

30

1

Aug. 28

Aug. 31

Sept. 30

Dec. 31

The Peoples Bank of Clymer, Clymer
The First National Bank of Ebensburg, Ebensburg
(5084)

50,000

250,000

330,059

4,419,247

273,000

1 ,100,000

825,908

40,939,057

The First National Bank of Ebensburg, Ebensburg
(5084)
. . . .

328,000

1 ,345,000

1,155,967

45,358,305

Saucon Valley Trust Company, Hellertown
The First National Bank of Allentown, Allentown
(373)

300,000

700,000

392,465

16,691,247

3,392,110

15 ,000,000

3,816,058

260,658,654

The First National Bank of Allentown, Allentown
(373)

3,722,110

15 ,700,000

4,178,523

277,349,902

The Citizens Bank of Wind Gap, Wind Gap
Easton National Bank and Trust Company, Easton
(1233)

100,000

400,000

238,039

7,835,984

1,350,000

4 ,000,000

2,155,697

91,385,965

Easton National Bank and Trust Company, Easton
(1233)

1,510,000

4 ,400,000

2,337,736

99,221,949

The First National Bank of Edinboro, Edinboro (7312).
Marine National Bank, Erie (870)

300,000
3,900,000

300,000
4 ,100,000

275,478
1,187,470

10,464,946
118,134,273

Marine National Bank, Erie (870)

4,680,000

,920,000

1,462,948

128,599,219

Grange National Bank of Potter County, Ulysses
(8739)
First Citizens National Bank, Mansfield (13618)

192,320
500,000

206,060
500,000

63,625
468,372

5,872,245
19,052,692

First Citizens National Bank, Mansfield (13618)

601,000

706,060

623,318

24,924,937

See footnote at end of table.

206




TABLE B-l 7—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1970
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

SOUTH DAKOTA

Jan. 9

Sept. 10

Community State Bank of Lake Preston, Lake Preston.
Northwestern National Bank of Sioux Falls, Sioux
Falls (10592)

$150,000

$200,000

$245,046

$6,502,795

3,250,000

2,500,000

1,665,496

129,971,893

Northwestern National Bank of Sioux Falls, Sioux
Falls (10592)

3,500,000

3,500,000

1,111,067

136,325,911

Security Bank, Madison

300,000
4,000,000

450,000
4,000,000

249,379
4,418,399

10,472,960
191,741,613

4,300,000

4,450,000

4,667,779

202,214,573

-0-

277,892

10,734,254

National Bank of South Dakota, Sioux Falls (12881).
National Bank of South Dakota, Sioux Falls (12881).
VERMONT

July 9

50,000

Barre Trust Company, Barre
The Merchants National Bank of Burlington, Burlington (1197)

650,000

810,000

570,517

33,728,785

The Merchants National Bank of Burlington, Burlington (1197)

650,000

810,000

457,149

44,021,777

The First National Bank of Harrisonburg, Harrisonburg (1572)
Virginia National Bank, Norfolk (9885)

1,200,000
18,680,000

1,300,000
24,501,275

915,780
15,831,511

39,328,751
915,449,691

Virginia National Bank, Norfolk (9885).

20,000,000

25,681,275

16,747,291

954,254,957

The Merchants and Farmers Bank, Smithfield.
Virginia National Bank, Norfolk (9885)

134,100
20,000,000

500,000
25,681,275

327,513
19,339,239

9,760,533
958,154,895

Virginia National Bank, Norfolk (9885).

20,268,200

26,047,175

19,666,752

967,583,357

Suburban National Bank of Virginia, Fairfax County
(14965)
First and Merchants National Bank, Richmond (1111).

1,314,000
18,652,700

1,429,048
31,587,300

-016,900,059

49,353,508
769,096,943

First and Merchants National Bank, Richmond (1111).

19,966,700

33,223,300

16,693,107

816,282,176

VIRGINIA

Mar. 13

June 1

July 31

Aug. 31

Nov. 23

The National Bank of Orange, Orange (5438)
National Bank and Trust Company, Charlottesville
(10618)

225,000

500,000

624,137

16,090,627

1,780,785

3,545,000

2,974,086

102,033,911

National Bank and Trust Company, Charlottesville
(10618)

2,005,785

4,045,000

3,960,348

124,566,561

Carroll County Bank, Hillsville.
Virginia National Bank, Norfolk (9885).

400,000
20,268,200

400,000
26,047,175

139,982
20,494,410

14,747,939
1,036,189,871

Virginia National Bank, Norfolk (9885).

20,552,290

26,563,085

20,634,393

1,050,427,829

See footnote at end of table.




207

TABLE B-l 7—Continued
Mergers* of National banks, or National and State banks, by States, calendar 1970
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Undivided
profits and
reserves

Surplus

Total assets

WASHINGTON

Apr. 30

Sept. 25

Commercial Bank of Washington, Twisp
Old National Bank of Washington, Spokane (4668). . .

300,000
5,333,900

145,060
10,062,386

41,417
8,221,466

5,495,805
291,760,801

Old National Bank of Washington, Spokane (4668). . .

5,573,900

10,799,886

7,724,773

298,114,823

North West Bank, Seattle
Old National Bank of Washington, Spokane (4668). . .

1,710,000
5,573,900

318,100
10,821,290

907,306
8,257,252

15,998,718
316,064,001

Old National Bank of Washington, Spokane (4668). . .

6,642,650

10,775,040

10,170,158

332,062,719

The Home Bank, Milwaukee .
Midland National Bank, Milwaukee (15510)

1,000,000
2,191,875

900,000
1,571,952

38,965
942,705

24,740,760
78,826,911

Midland National Bank, Milwaukee (15510)

2,941,875

2,721,952

981,670

100,572,816

WISCONSIN

Sept. 1

*Excludes mergers involving only 1 operating bank, effected pursuant to corporate reorganization.

TABLE B-18

Mergers resulting in National banks, by assets of acquiring and acquired banks, 1960-1970*
Assets of acquired bank *
Assets of acquiring bank]

Under $10 million
.
. . .
$10 million to $24.9 million
$25 million to $49.9 million
$50 million to $99.9 million
$100 million and over
Total.

Acquiring
bank

Under $10
million

$10 million to $25 million to $50 million to
49.9
24.9
99.9
million
million
million

80
127
130
147
420

80
113
88
95
187

0
14
34
33
143

0
0
8
16
46

0
0
0
3
21

0
0
0
0
23

$904

563

224

70

24

23

*Includes all forms of acquisitions involving two or more banks, from May 13, 1960 through December 31,1970.
fin each transaction, the bank with larger total assets was considered to be the acquiring bank.
{Comprises 871 transactions, 18 involving 3 banks, 6 involving 4 banks, and 1 involving 5 banks.

208




$100 million
and over

TABLE R-19
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Local

Total

280

Other than
local

643

ALABAMA

12455
15473
3185
15797
14414
14664
5249
15658
15316
15441
1814
11635

The First National Bank of Auburn, Auburn
City National Bank of Birmingham, Birmingham
The First National Bank of Birmingham, Birmingham
First National Bank, Brewton
State National Bank of Alabama, Decatur
City National Bank of Dothan, Dothan
The First National Bank of Dothan, Dothan
Fort Rucker National Bank, Fort Rucker
The American National Bank of Huntsville, Huntsville
The Capitol National Bank of Montgomery, Montgomery
The First National Bank of Montgomery, Montgomery
Opelika National Bank, Opelika
ALASKA

14651
12072

National Bank of Alaska, Anchorage
The First National Bank of Anchorage, Anchorage
ARIZONA

3728
14324

First National Bank of Arizona, Phoenix
The Valley National Bank of Arizona, Phoenix

10609
14606
13949
15608

ARKANSAS

The City National Bank of Fort Smith, Fort Smith
First National Bank of Jonesboro, Jonesboro
The First National Bank in Little Rock, Little Rock
Fidelity National Bank of West Memphis, West Memphis
CALIFORNIA

15437
14695
15434
10120
12904
15239
15453
11330
2490
15547
15220
6268
8181
15532
15276
15489
15032
15349
3050
10391
13044
9655
1741
15660
15357

American National Bank, Bakersfield
City National Bank, Beverly Hills
Commercial National Bank, Buena Park
The First National Bank of Dixon, Dixon
The Capital National Bank, Downey
Gateway National Bank, El Segundo
Escondido National Bank, Escondido
National Bank of Agriculture, Fresno
Security Pacific National Bank, Los Angeles
Santa Clarita National Bank, Newhall
West Coast National Bank, Oceanside
First National Bank and Trust Company, Ontario
The First National Bank of Orange County, Orange
Commercial and Farmers National Bank, Oxnard
Palm Springs National Bank, Palm Springs
Riverside National Bank, Riverside
Placer National Bank, Rocklin
Valley National Bank, Salinas
Southern California First National Bank, San Diego
United States National Bank, San Diego
Bank of America National Trust and Savings Association, San Francisco
The Bank of California, National Association, San Francisco
Crocker-Citizens National Bank, San Francisco
Wells Fargo Bank, National Association, San Francisco
San Joaquin Valley National Bank, Tulare




20

0
1
1
1
3
24
2
2
18
1

209

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

COLORADO

15170
15114
9907
15480
15786
1833
14400

Northern National Bank, Colorado Springs
Northeast Colorado National Bank, Denver
The First National Bank of Englewood, Englewood
Republic National Bank of Englewood, Englewood
First National Bank, Evergreen
The First National Bank of Pueblo, Pueblo
The Routt County National Bank of Steamboat Springs, Steamboat Springs
CONNECTICUT

335
4
1314
15496
1338
2
15584

The Connecticut National Bank, Bridgeport
The State National Bank of Connecticut, Bridgeport
The Clinton National Bank, Clinton
The Hamden National Bank, Hamden
Hartford National Bank and Trust Company, Hartford
The First New Haven National Bank, New Haven
The Atlantic National Bank, Stamford
DELAWARE

15060

The First National Bank of Wilmington, Wilmington
DISTRICT OF COLUMBIA

2038
3425
5046

The First National Bank of Washington, Washington
The National Bank of Washington, Washington
The Riggs National Bank of Washington, D.C., Washington
GEORGIA

1559
9617
15541
2338
3983
15572
10270
13068
13472

The First National Bank of Atlanta, Atlanta
The Fulton National Bank of Atlanta, Atlanta
The National Bank of Georgia, Atlanta
The First National Bank of Columbus, Columbus
The First National Bank of Gainesville, Gainesville
First National Bank of Griffin, Griffin
The First National Bank & Trust Company in Macon, Macon
The Citizens and Southern National Bank of Savannah, Savannah
The Liberty National Bank & Trust Company of Savannah, Savannah, Georgia,
Savannah
HAWAII

14911

Hawaii National Bank, Honolulu, Honolulu
IDAHO

1668
12256

The Idaho First National Bank, Boise
Cassia National Bank, Burley
ILLINOIS

13236
13672
5584
14820
14738
5638
13709
13695
14516
14662

Belleville National Savings Bank, Belleville
National Boulevard Bank of Chicago, Chicago
Truitt-Matthews First National Bank, Chillicothe
Des Plaines National Bank, Des Plaines
Citizens National Bank of Downers Grove, Downers Grove
The First National Bank of Dundee, Dundee
First National Bank and Trust Company of Evanston, Evanston
First National Bank of Freeport, Freeport
Lawrenceville National Bank & Trust Co., Lawrenceville
First National Bank of Morton Grove, Morton Grove

210




Total

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

3267
206
13818
14468
14379
869
984
14175
13580
15784
14921
2234
17
5756
14874
14813

The Riddell National Bank of Brazil, Brazil
The First National Bank, Elkhart
Fort Wayne National Bank, Fort Wayne
Gary National Bank, Gary
Calumet National Bank, Hammond
Merchants National Bank & Trust Company of Indianapolis, Indianapolis
The Indiana National Bank, Indianapolis
Lafayette National Bank, Lafayette
The National Bank of Logansport, Logansport
Citizens National Bank of Grant County, Marion
American National Bank and Trust Company of Muncie, Muncie
The Merchants National Bank of Muncie, Muncie
The First National Bank of Richmond, Richmond
The Tell City National Bank, Tell City
First National Bank, Valparaiso, Valparaiso
Northwest Bank of Indiana, National Association, Whiting
IOWA

994
15133
15524
2763

The Clinton National Bank, Clinton
First National Bank of Davenport, Davenport
First National Bank of Eldora, Eldora
First National Bank Fort Dodge, Iowa, Fort Dodge
KANSAS

5498
6311
3849
14999
11010

Citizens National Bank and Trust Company, Emporia
Commercial National Bank of Kansas City, Kansas City
The Lawrence National Bank and Trust Co., Lawrence
Parklane National Bank of Wichita, Wichita
Union National Bank of Wichita, Wichita
KENTUCKY

3944
3381
6028
109
14320
7030

The Second National Bank of Ashland, Ashland
The Citizens National Bank of Danville, Danville
The First-Hardin National Bank of Elizabethtown, Elizabethtown
First National Bank of Louisville, Louisville
Liberty National Bank and Trust Company of Louisville, Louisville
Pikeville National Bank & Trust Company, Pikeville.
LOUISIANA

15642
14687
14503
14753
5023
15279
4154
11169
13851
13688
14477
13689
14977
11795

Parish National Bank of Bogalusa, Bogalusa
The National Bank of Bossier City, Bossier City
Citizens National Bank & Trust Company of Houma, Houma
The National Bank of Commerce in Jefferson Parish, Jefferson Parish
The First National Bank of Lafayette, Lafayette
Riverlands National Bank in LaPlace, LaPlace
The First National Bank of Lake Charles, Lake Charles
First National Bank in Mansfield, Mansfield
The Citizens National Bank of Morgan City, Morgan City
The Hibernia National Bank in New Orleans, New Orleans
National American Bank of New Orleans, New Orleans
The National Bank of Commerce in New Orleans, New Orleans
Whitney National Bank of New Orleans, New Orleans
The First National Bank of Ruston, Ruston




211

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo openings merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

MAINE

1437
14303
4459
13843
941
4128

Merchants National Bank of Bangor, Bangor
The Liberty National Bank in Ellsworth, Ellsworth
The First National Bank of Farmington, Farmington
The First National Bank of Aroostook, Fort Fairfield
Canal National Bank, Portland
Maine National Bank, Portland

0
1
0
0
1
1

1
0
2
1
1
3

0
0
0
0
0
1
0
0

2

MARYLAND

1413
13745
14864
4364
5623
15365
14937
15154
5471

The First National Bank of Maryland, Baltimore City
Maryland National Bank, Baltimore
State National Bank of Bethesda, Bethesda
The Citizens National Bank, Laurel
The First National Bank of Oakland, Oakland
University National Bank, Rockville
American National Bank of Maryland, Silver Spring
Peoples National Bank of Maryland, Suitland
The First National Bank of Southern Maryland of Upper Marlboro, Upper
Marlboro
MASSACHUSETTS

15052
200
475
590
528
1129
1939
7452
2275
13241
261
799
5944
736
1082
14798
2232
1135
79

Suburban National Bank of Arlington, Arlington
The First National Bank of Boston, Boston
New England Merchants National Bank of Boston, Boston
The Fall River National Bank, Fall River
The Framingham National Bank, Framingham
Merrimack Valley National Bank, Haverhill
Holyoke National Bank, Holyoke
Security National Bank, Lynn
The Home National Bank of Milford, Milford
Needham National Bank, Needham
The First National Bank of New Bedford, New Bedford
The Merchants National Bank of New Bedford, New Bedford
Manufacturers National Bank of Bristol County, North Attleboro
First National Bank of Cape Cod, Orleans
First Agricultural National Bank of Berkshire County, Pittsfield
South Shore National Bank, Quincy
First Bristol County National Bank, Taunton
The Mechanics National Bank of Worcester, Worcester
Worcester County National Bank, Worcester
MICHIGAN

14641
13833
13522
13738
13671
14740
8496
14144
3806
15367
191
390
12971
13753
13739
14773
1918
3886
14934
15008

Peoples National Bank & Trust Company of Bay City, Bay City
Farmers and Merchants National Bank in Benton Harbor, Benton Harbor
The Citizens National Bank of Cheboygan, Cheboygan
Manufacturers National Bank of Detroit, Detroit
National Bank of Detroit, Detroit
First National Bank of East Lansing, East Lansing
Northern Michigan National Bank, Escanaba
First National Bank in Howell, Howell
The First National Bank of Iron Mountain, Iron Mountain
City Bank & Trust Co., National Association, Jackson
The First National Bank and Trust Company of Michigan, Kalamazoo
The First National Bank and Trust Company of Marquette, Marquette
First National Bank in Mount Clemens, Mount Clemens
First National Bank of Southwestern Michigan, Niles
Community National Bank of Pontiac, Pontiac
National Bank of Royal Oak, Royal Oak
Second National Bank of Saginaw, Saginaw
First National Bank of St. Ignace, St. Ignace
The Empire National Bank of Traverse City, Traverse City
Troy National Bank, Troy

212



7
1
1

2

4
1
2

Total

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

MISSISSIPPI

14538
3765
15548
6681
7266
13551
15672
9865
3258

National Bank of Commerce of Corinth, Corinth
The First National Bank of Greenville, Greenville
Deposit Guaranty National Bank, Jackson
The First National Bank of Laurel, Laurel
The Citizens National Bank of Meridian, Meridian
First National Bank in Meridian, Meridian
First National Bank of Ocean Springs, Ocean Springs
The First National Bank of Oxford, Oxford
First National Bank of Vicksburg, Vicksburg

1
1
2
1
1
1
0
1
1

0
0
5
0
0
0
1
0
0

1
1
1

0
0
0

1
1
1

0
0
0

MISSOURI

170
15302
15793

First National Bank in St. Louis, St. Louis
The First National Bank of Sikeston, Sikeston
Springfield National Bank, Springfield
NEBRASKA

14017
14480
13568

The First National Bank in Aurora, Aurora
First National Bank in Kearney, Kearney
The National Bank of Neligh, Neligh
NEVADA

7038

First National Bank of Nevada, Reno, Nevada, Reno
NEW HAMPSHIRE

12889
559
808
574
1310
15100

The Rockingham National Bank of Exeter, Exeter
The Cheshire National Bank of Keene, Keene
The National Bank of Lebanon, Lebanon
The Amoskeag National Bank of Manchester, Manchester
The Indian Head National Bank of Nashua, Nashua
White Mountain National Bank of North Conway, North Conway
NEW JERSEY

10823
13363
10712
11543
13855
2999
1222
1209
7945
15709
3168
15646
2076
8501
15430
1326
2331
15035
3843
8267
4147
15360
12942
13125
6440
8779
288
4274

The First National Bank of Absecon, Absecon
First Merchants National Bank, Asbury Park, Asbury Park
The Citizens National Bank of Bloomsbury, Bloomsbury
Bankers National Bank, Bogota
The National Bank of Sussex County, Branchville
The Bridgeton National Bank, Bridgeton
Mechanics National Bank of Burlington County, Burlington
South Jersey National Bank, Camden
The First National Bank of Cape May Court House, Cape May Court House
New Jersey Bank (National Association), Clifton
The First National Bank of Cranbury, Cranbury
Peoples National Bank of Denville, Denville
The National Union Bank of Dover, Dover
The First National Bank of Dunellen, Dunellen
Raritan Valley National Bank, Edison Township
First National Bank of South Jersey, Egg Harbor Township
The Flemington National Bank and Trust Company, Flemington
Franklin Lakes National Bank, Franklin Lakes
The First National Bank of Glassboro, Glassboro
The Peoples National Bank of Hackettstown, Hackettstown
Peoples National Bank of Monmouth County, Hazlet Township
Madison National Bank, Madison
The Manville National Bank, Manville
The First National Bank of Marlton, Marlton
The Farmers and Merchants National Bank of Matawan, Matawan
The First National Bank of Milford, Milford
First Charter National Bank, Monroe Township
American National Bank & Trust, Montclair




213

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No,

Title and location of bank
Other than
local
NEW JERSEY—continued

1113
12771
1452
1316
587
14240

925
15790
329
1239
4872
5005
3866
15845
2509
1327
2918
15790
12861
13848
12022
1199
13265
12606

The First National Iron Bank of New Jersey, Morristown
Broad National Bank, Newark, Newark
First National State Bank of New Jersey, Newark
National Newark and Essex Bank, Newark
The National Bank of New Jersey, New Brunswick
First National Bank in Newfield, Newfield
The Sussex and Merchants National Bank of Newton, Newton
Bank of Passaic and Clifton, N.A., Passaic
First National Bank of Passaic County, Paterson
The Phillipsburg National Bank and Trust Company, Phillipsburg
The First National Bank of Princeton, Princeton
National Community Bank of Rutherford, Rutherford
First National Bank of Central Jersey, Somerville
The Edison Bank, National Association, South Plainfield
The First National Bank of Toms River, N.J., Toms River
New Jersey National Bank, Trenton
The Vineland National Bank and Trust Company, Vineland
Bank of Passaic and Clifton, N.A., Wayne
The Prospect Park National Bank, Wayne
Belmar-Wall National Bank, West Belmar
Peoples National Bank of New Jersey, Westmont
National Bank and Trust Company of Gloucester County, Woodbury
The Wood Ridge National Bank, Wood-Ridge
The Yardville National Bank, Yardville

,
,

,

NEW MEXICO

13814
8767
7720
8880

First National Bank in Albuquerque, Albuquerque
The Clovis National Bank, Clovis
First National Bank of Dona Ana County, Las Cruces
The First National Bank of Lordsburg, Lordsburg
NEW YORK

5178
15758

1301
15625

976
9990
15464
11511
980
5336
6587
7703
15626
13956
12997
10111
2370
1461
1354
14734
13493
465
15641
4230
15556
11708
14763
15627
1342
10155
4988

The First National Bank of Addison, Addison
First Trust Company of Albany, National Association, Albany
National Commercial Bank and Trust Company, Albany
First City National Bank of Binghamton, N.Y., Binghamton
The Putnam County National Bank of Carmel, Carmel
The Central Valley National Bank, Central Valley
First National Bank of East Hampton, East Hampton
Marine Midland Tinker National Bank, East Setauket
The First National Bank of Glens Falls, Glens Falls
The First National Bank of Highland, Highland
Security National Bank, Huntington
National Bank of North America, New York
The First National Bank of Jamestown, Jamestown
Empire National Bank, Middletown
Franklin National Bank, Mineola
The First National Bank of Newark Valley, Newark Valley
The Chase Manhattan Bank (National Association), New York
First National City Bank, New York
The National Bank and Trust Company of Norwich, Norwich
Tappan Zee National Bank, Nyack
Finger Lakes National Bank, Odessa
,
Marine Midland Bank of Southeastern New York, Poughkeepsie
The State of New York National Bank, Poughkeepsie
The Suffolk County National Bank of Riverhead, Riverhead
First National Bank of Rochester, Rochester
Scarsdale National Bank and Trust Company, Scarsdale
Eastern National Bank of Long Island, Smithtown
Lincoln National Bank and Trust Company of Central New York, Syracuse
The Merchants National Bank & Trust Company of Syracuse, Syracuse. ..
The Valley National Bank, Wallkill, N.Y., Walden
The Citizens National Bank and Trust Company, Wellsville

214




0
0
1
0
0
0
0
0
0
0
0
8
1
0
0
0
4
14
1
0
0
0
0
0
1
1
0
1
1
0
0

6
5
0
1
8
1
3
4
0
1
1
17
1
1
0
0
1
1
1
1
1

Total

TABLE B-19—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

NORTH CAROLINA

11091
8953
15650
13761
13779
14676
6744
10610
10608
15165
15673

The First National Bank of Albermarle, Albemarle
The First National Bank of Asheboro, Asheboro
First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
The Citizens National Bank in Gastonia, Gastonia
First National Bank of Eastern North Carolina, Jacksonville
First National Bank of Lincolnton, Lincolnton
Southern National Bank of North Carolina, Lumberton
The Planters National Bank and Trust Company, Rocky Mount
First National Bank of Smithfield, Smithfield
Wachovia Bank and Trust Company, N.A., Winston-Salem

0
0
0
2
1
0
0
0
0
1
0

1
1
10
7
0
12
1
3
1
0
19

NORTH DAKOTA

8881

The First National Bank of McClusky, McClusky
OHIO

15609
13749
15416
13740
14501
76
14879
14761
786
7621
7745
5065
1788
10
15573
12008
5100
2705
10105
56
4336
1903
652
9547
15340
15456
2577
13912
858
9179
14686
5370
3291
973
238
2160
14586
3157
2350
13586

Akron National Bank and Trust Company, Akron
Bellefontaine National Bank, Bellefontaine
First National Bank, Bowling Green
The Citizens National Bank, Bryan
The Canton National Bank, Canton
First National Bank of Canton, Canton
The Geauga County National Bank of Chardon, Chardon
Society National Bank of Cleveland, Cleveland
The National City Bank of Cleveland, Cleveland
The City National Bank & Trust Company of Columbus, Columbus
The Huntington National Bank of Columbus, Columbus
The Ohio National Bank of Columbus, Columbus
The First National Bank, Dayton, Ohio, Dayton
The Third National Bank and Trust Company of Dayton, Ohio, Dayton. .
Euclid National Bank, Euclid
The Community National Bank of Flushing, Flushing
The Franklin National Bank, Franklin
The First National Bank of Georgetown, Georgetown
The Peoples National Bank of Greenfield, Greenfield
The First National Bank and Trust Company of Hamilton, H a m i l t o n . . . .
The Citizens National Bank of Ironton, Ironton
The First National Bank of Jackson, Jackson
The Portage National Bank, Kent
The Lancaster National Bank, Lancaster
Tower National Bank of Lima, Lima
The Central Security National Bank of Lorain County, Lorain
First National Bank of Mansfield, Mansfield
National Bank of Montpelier, Montpelier
The First National Bank of Newark, Newark
The Park National Bank of Newark, Newark
The Lake County National Bank of Painesville, Painesville
The First National Bank and Trust Company of Ravenna, Ravenna
The Citizens National Bank of Ripley, Ripley
The Farmers National Bank of Salem, Ohio, Salem
The First National Bank of Springfield, Springfield
The First National Bank and Trust Company of Steubenville, Steubenville
First National Bank of Toledo, Toledo
The First National Bank of Wapakoneta, Wapakoneta
The Mahoning National Bank of Youngstown, Youngstown
The Union National Bank of Youngstown, Youngstown
OKLAHOMA

14278
5911
6358

First National Bank in Blackwell, Blackwell
The First National Bank of Cleveland, Cleveland
First National Bank in Hobart, Hobart




215

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

15583
1553
15491
4514

Crater National Bank of Medford, Medford
First National Bank of Oregon, Portland
Great Western National Bank, Portland
United States National Bank of Oregon, Portland
PENNSYLVANIA

373 The First National Bank of Allentown, Allentown
6645 The Merchants National Bank of Allentown, Allentown
723 Central Penn National Bank, Bala-Cynwyd
5823 First National Bank of Somerset County, Berlin
12526 The Cheltenham National Bank, Cheltenham
355 Southeast National Bank of Pennsylvania, Chester
5307 The First National Bank of Confluence, Confluence
325 The First National Bank of Danville, Danville
4505 The First National Bank of Dushore, Dushore
1233 Easton National Bank and Trust Company, Easton
5118 The Northampton National Bank of Easton, Easton
5084 The First National Bank of Ebensburg, Ebensburg
870 Marine National Bank, Erie
13992 The First National Bank in Frackville, Frackville
13826 Valley National Bank, Freeport
5351 Southwest National Bank of Pennsylvania, Greensburg
5857 The Citizens National Bank of Greencastle, Greencastle
1081 The First National Bank of Green Castle, Greencastle
580 Commonwealth National Bank, Harrisburg
13994 Tri-Valley National Bank, Hegins
12098 The Moxham National Bank of Johnstown, Johnstown
2526 National Bank and Trust Company of Kennett Square, Kennett Square. .
5073 The Merchants National Bank of Kittanning, Kittanning
683 Lancaster County Farmers National Bank, Lancaster
694 National Central Bank, Lancaster
14133 Commercial National Bank of Westmoreland County, Latrobe
9207 Community National Bank of Southern Pennsylvania, Littlestown
13618 First Citizens National Bank, Mansfield
870 Marine National Bank, Meadville
7003 Swineford National Bank, Middleburg, Middleburg
357 Tri-County National Bank, Middleburg
5879 The First National Bank of Monaca, Monaca
2223 County National Bank of Montrose, Montrose
5686 The Second National Bank of Nazareth, Nazareth
324 The First National Bank and Trust Company of Newtown, Newtown
7910 The First National Bank of Nicholson, Nicholson
5227 The Cement National Bank, Northampton, Pa., Northampton
9149 The National Bank of North East, North East
11058 The Columbia County Farmers National Bank of Orangeville, Orangeville
539 The Philadelphia National Bank, Philadelphia
15422 Provident National Bank, Philadelphia
252 Pittsburgh National Bank, Pittsburgh
705 The Union National Bank of Pittsburgh, Pittsburgh
2222 Western Pennsylvania National Bank, Pittsburgh
649 The Miners National Bank of Pottsville, Pottsville
1663 Pennsylvania National Bank and Trust Company, PottsviHe
13947 Scranton National Bank, Scranton
834 The First National Bank of Shippensburg, Shippensburg
2333 Union National Bank and Trust Company of Souderton, Souderton
42 The First National Bank of Strasburg, Strasburg
39 The First National Bank of Towanda, Towanda, Pennsylvania, Towanda.
4984 The First National Bank of Troy, Troy
5034 Gallatin National Bank, Uniontown
4879 The Warren National Bank, Warren
5920 First National Bank & Trust Co., Washington, Pa., Washington
30 The First National Bank of Wilkes-Barre, Wilkes-Barre

216




1
1
9
1
1
2
1
0
1
1
1
1
1
0
1
1
1
1
3
2
0
1
0
1
11
0
1
1
1
1
0
2
1
1
2
1
1
1
1
4
0
1
2
3
1
3
1
0
1
1
2
2
1
1
1
1

Total

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Other than
local

RHODE ISLAND

1492
13981
15664

The Newport National Bank, Newport
Columbus National Bank of Rhode Island, Providence
Industrial National Bank of Rhode Island, Providence
SOUTH CAROLINA

14425
2044
13720
10635
14448
15619
10660

The Citizens and Southern National Bank of South Carolina, Charleston. . .
The South Carolina National Bank of Charleston, Charleston
The First National Bank of South Carolina, Columbia
The Peoples National Bank, Greenville
Rock Hill National Bank, Rock Hill
National Bank of Commerce of Spartanburg, Spartanburg
The National Bank of South Carolina of Sumter, Sumter
SOUTH DAKOTA

12881
10592
15639

National Bank of South Dakota, Sioux Falls
Northwestern National Bank of Sioux Falls, Sioux Falls
United National Bank of Vermillion, Vermillion, South Dakota, Vermillion
TENNESSEE

14611
7848
14760
12790
10842
13539
8934
14279
336
13681
13103
9629

American National Bank and Trust Company of Chattanooga, Chattanooga
The Hamilton National Bank of Chattanooga, Chattanooga
Hamilton First National Bank, Clinton
The National Bank of Commerce of Jackson, Jackson
The First National Bank of Sullivan County, Kingsport
The Hamilton National Bank of Knoxville, Knoxville
The First National Bank of Lewisburg, Lewisburg
The Blount National Bank of Maryville, Maryville
The First National Bank of Memphis, Memphis
National Bank of Commerce, Memphis
Third National Bank in Nashville, Nashville
Old & Third National Bank of Union City, Union City
UTAH

2597
15196
4341

First Security Bank of Utah, National Association, Ogden
Granite National Bank, Salt Lake City
Zions First National Bank, Salt Lake City

2
0
10

VERMONT

1197
1698
1368
122

The
The
The
The

Merchants National Bank of Burlington, Burlington
Howard National Bank and Trust Company, Burlington
National Bank of Derby Line, Derby Line
First National Bank of Springfield, Springfield

,

VIRGINIA

14223
7093
15390
15221
10618
14904
5683
1582
1572
15315
5290
5032
10253
14965

The Washington County National Bank of Abingdon, Abingdon
Alexandria National Bank, Alexandria
First Virginia Bank-Monticello National Bank, Charlottesville
The American Bank N.A., Falls Church
National Bank and Trust Company, Charlottesville
Security National Bank, Bailey's Cross Roads, Falls Church
The First National Bank of Farmville, Farmville
The National Bank of Fredericksburg, Fredericksburg
The First National Bank of Harrisonburg, Harrisonburg
Fairfield National Bank of Highland Springs, Highland Springs
Chesapeake National Bank, Kilmarnock
First Virginia Bank-Manassas National, Manassas
Marshall National Bank and Trust Company, Marshall
Suburban National Bank of Virginia, McLean




,
,
,

217

TABLE B-l 9—Continued
Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1970
Branches opened for business
Charter
No.

Title and location of bank
Local

Other than
local

Total

VIRGINIA—continued

15461
10194
9885
5438
11381
1111
15530
15027
15567
11817
1620
6123
6084

First National Bank of Norfolk, Norfolk
United Virginia-Seaboard National, Norfolk
Virginia National Bank, Norfolk
The National Bank of Orange, Orange
American National Bank, Portsmouth
First & Merchants National Bank, Richmond
Metropolitan National Bank, Richmond
Richmond National Bank, Richmond
Second National Bank of Richmond, Richmond
The Colonial-American National Bank of Roanoke, Roanoke.
United Virginia Bank/National Valley, Staunton
Tazewell National Bank, Tazewell
Farmers and Merchants National Bank, Winchester
WASHINGTON

14990
11285
4375
13230
3417
14394
11280
4668
12292

Northshore First National Bank, Bothell
The First National Bank of Poulsbo, Poulsbo
The National Bank of Commerce of Seattle, Seattle
The Pacific National Bank of Seattle, Seattle
Pacific National Bank of Washington, Seattle
Peoples National Bank of Washington, Seattle
Seattle-First National Bank, Seattle
Old National Bank of Washington, Spokane
Puget Sound National Bank, Tacoma
WISCONSIN

2725
555
144
1602
6604
4312
5633
1086

The First National Bank and Trust Company of Beloit, Beloit
First Wisconsin National Bank of Fond Du Lac, Fond Du Lac
First Wisconsin National Bank of Madison, Madison
The First National Bank of Neenah, Neenah
First National Bank in Oshkosh, Oshkosh
The First National Bank of Rhinelander, Rhinelander
First National Bank of Sturgeon Bay, Sturgeon Bay
First National Bank of Waukesha, Waukesha
VIRGIN ISLANDS

14335

Virgin Islands National Bank, Charlotte Amalie, St. Thomas.

218




1
1
5
1
1
3
6
7
1

TABLE

R-20

Domestic branches of National banks closed, by States, calendar 1970
Branches closed
Charter
No.

Title and location of bank
Local

Total

Other than
local

44

60

1
0

2
5

4
0

1
1

2
1
0

0
0
1

0
1
1
0
1
0

2
1

2

1
0

0
1

CALIFORNIA

15331
2491
3050
15330
13044
1741
15660
15216
15488

Republic National Bank and Trust Company, Beverly Hills
Security-Pacific National Bank, Los Angeles
Southern California First National Bank, San Diego
Commonwealth National Bank, San Francisco
Bank of America National Trust and Savings Association, San Francisco
Crocker-Citizens National Bank, San Francisco
Wells Fargo Bank, National Association, San Francisco
Citrus National Bank, West Covina
Southland National Bank, Yucaipa
CONNECTICUT

13704

The Tradesmens National Bank of New Haven, New Haven
DISTRICT OF COLUMBIA

2038

The First National Bank of Washington, Washington
GEORGIA

14900

The Chamblee National Bank, Chamblee
INDIANA

9381

The First-Merchants National Bank of Michigan City, Michigan City. .
IOWA

117 The First National Bank of Marion, Marion
MAINE

4128

Maine National Bank, Portland
MARYLAND

15102
14985

National City Bank of Baltimore, Baltimore
Metropolitan National Bank of Maryland, Wheaton
MASSACHUSETTS

15399
6077

Commonwealth National Bank, Boston
Union National Bank, Lowell
MICHIGAN

14925
13671
13739

City National Bank of Detroit, Detroit
National Bank of Detroit, Detroit
Community National Bank of Pontiac, Pontiac
NEW JERSEY

10471
15419
8267
1113
15327
10142

The Clayton National Bank, Clayton
Eatontown National Bank, Eatontown
The Peoples National Bank of Hackettstown, Hackettstown
The First National Iron Bank of New Jersey, Morristown
First National Bank of Scotch Plains, Scotch Plains
The National Bank of Westfield, Westfield

1
1
1

NEW YORK

2370
465

The Chase Manhattan Bank (National Association), New York
Marine Midland Bank of Sotheastern New York, N.A., Poughkeepsie. . .




219

TABLE B-20—Continued
Domestic branches of National banks closed, by States, calendar 1970
Branches closed
Charter
No.

Title and location of bank
Local

Other than
local

Total

NORTH CAROLINA

15650
13761
10608
15673

First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
The Planters National Bank and Trust Company, Rocky Mount
Wachovia Bank and Trust Company, N.A., Winston-Salem
OHIO

183

The First National Bank of Ashland, Ashland
OKLAHOMA

5911
12890
15333
13891
9942

The First National Bank of Cleveland, Cleveland
The Commercial National Bank in Muskogee, Muskogee
Founders National Bank of Oklahoma City, Oklahoma City
First National Bank and Trust Company, Ponca City
The National Bank of Commerce of Tulsa, Tulsa
OREGON

15583

Crater National Bank of Medford, Medford
PENNSYLVANIA

593
573
5019
4011
5879
252
705
694

National Valley Bank and Trust Company, Chambersburg
The Doylestown National Bank and Trust Company, Doylestown
Dubois Deposit National Bank, Dubois
The East Stroudsburg National Bank, East Stroudsburg
The First National Bank of Monaca, Monaca
Pittsburgh National Bank, Pittsburgh
The Union National Bank of Pittsburgh, Pittsburgh
National Bank & Trust Company of Central Pennsylvania, York
SOUTH CAROLINA

2044
9407
15619

The South Carolina National Bank of Charleston, Charleston
The Peoples National Bank of Rock Hill, Rock Hill
National Bank of Commerce of Spartanburg, Spartanburg
TENNESSEE

14611

American National Bank and Trust Company of Chattanooga, Chattanooga
VIRGINIA

5290
11817

Chesapeake National Bank, Kilmarnock
The Colonial-American National Bank of Roanoke, Roanoke

220




12
5
1
1
1
1
1
2

TABLE B-21
Outstanding balances, credit cards and related plans of National banks, Dec. 31, 1970
Credit cards

Outstanding
volume

Number
of banks

[dollar amounts
in millions]

Other revolving credit plans

Average
balance
per card\

Outstanding
volume

Number
of banks

[dollar amounts
in millions]

United States

688

$2,755

$211

660

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

17
1
2
3
32
26
5
0
1
58

49

229

8
515
56
37
0
*
81

283
238
157
254
0
185

7
0
2
6
16
25
11
0
1
40

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

21
0
3
28
33
5
4
30
5
13

123
0
12
83
35
9
21
29
32
6

260
0
223
190
221
126
159
191
268
175

8
0
1
49
13
13
10
7
5
7

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

3
45
18
2
2
6
3
5
3
28

39
50
84
*
*
53
1
34
11
7

New Jersey
New Mexico
New York
North C a r o l i n a . . . .
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island

15
4
28
8
0
102
6
2
20
4

19
11
350
76
0
171
38
*
88
22

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

5
0
11
32
6
5
16
6
6
3
7
0

32
0
70
111
17
3
74
73
9
28
1
0

194
198
178
*
*
199
139
153
218
177
165
214
229
237
0
268
200
*
215
245
223
0
200
186
243
173
221
230
258
198
112
0

Wisconsin
Wyoming
Virgin Islands

$753

Average
balance
per account %

$661
643

1
139
10
6
0
*
23

1,320

11
0

1,338
0

23
9
2
1
3
6
1

800
460
370
417
637
751
395

3
34
19
50
3
14
8
14
1
6

5
59
26
18
2
9

1,092
753
736
635
542
676
291
386

20
2
27
5
6
45
14
1
34
2

28
*
157
26
1
19
3
*
74

2
4
9
32
1
2
17
5
5
42
12
0

2
*

316
517
553
598
0

669

8
8
14
2
0

1,095
793
486
476
429
424
1,075

518
443
409
*
*
474
493
363
564
453
0

*State figures are withheld when they represent less than three banks. However, these amounts are included in the National
totals.
tAverage balance for cards with outstanding balances on Dec. 31, 1970.
jAverage balance for accounts with outstanding balances on Dec. 31, 1970.
NOTE: Dashes indicate amounts less than $500,000.




221

ISO
IsO

TABLE

B-22

Principal assets, liabilities, and capital accounts of National banks, by deposit size, year-end 1969 and 1970
[Dollar amounts in millions]
Securities*
Number
of banks

Total
assets

Cash and Loans*
cash items
Total

U.S.
Treasury
securities

Deposits
Fixed
assets
Total

Demand

Time
and
savings

Capital
Surplus,
Capital notes and undivided
stock
deben- profits, and
tures
reserves

1970
Deposit Size
Less than $1.0
1 0 to 1 9
2 0 to 4 9
5 0 to 9 9
10.0 to 24.9
25 0 to 49 9
50 0 to 99 9
100.0 to 499.9
500.0 and over
Total

24
97
636
1,132
1,456
624
305
265
82

$40
184
2,581
9,384
25,616
24,413
23,928
66,737
188,023

$8
30
377
1,287
3,374
3,279
3,366
11,814
32,505

$10
77
1,176
4,443
12,346
12,093
12,094
33,661
101,302

$18
62
874
3,078
8,290
7,479
6,980
17,006
40,459

$14
43
536
1,553
3,801
3,002
2,860
8,470
13,944

$1
4
39
160
456
464
456
1,214
3,117

$18
154
2,278
8,373
22,856
21,580
21,046
57,498
149,981

$14
94
1,120
3,911
10,257
9,774
9,705
30,345
79,902

$4
60
1,157
4,462
12,598
11,806
11,341
27,155
70,079

$8
7
60
187
491
473
480
1,326
3,488

$0
0
0
3
22
36
49
166
885

$11
19
190
578
1,423
1,270
1,216
3 328
9,159

4,621

340,906

56,040

177,202

84,246

34,223

5,911

283,784

145,122

138,662

6,520

1,161

17,194

21
120
758
1,184
1,403
584
272
253
74

21
217
3,070
9,813
24,607
22,745
21,301
61,624
170,650

5
37
456
1,325
3,283
3,126
3,065
11,246
32,184

7
93
1,429
4,761
12,228
11,811
11,151
32,756
97,466

7
77
1,013
3,185
7,782
6,720
6,095
14,662
30,576

5
58
635
1,643
3,612
2,880
2,594
6,125
12,037

1
2
46
164
437
424
385
1,148
2,673

16
187
2,725
8,765
21,939
20,098
18,733
52,977
130,982

12
116
1,382
4,207
10,174
9,557
9,066
29,753
76,823

4
71
1,343
4,558
11,765
10,541
9,666
23,224
54,160

2
6
70
203
488
463
444
1,296
3,256

0
0
1
3
20
39
42
155
861

3
20
218
591
1,357
1,174
1,065
3,112
8,366

4,669

314,048

54,727

171,702

70,117

29,589

5,280

256,426

141,092

115,334

6,228

1969
Deposit Size
Less than $1.0
1 0 to 1 9
2 0 to 4 9
5.0 to 9 9
10.0 to 24.9
25.0 to 49.9
50.0 to 99.9
100.0 to 499.9
500.0 and over
Total

.

*Loans and securities figures are shown gross; reserves are not deducted from the respective assets.
NOTE : Data may not add to totals because of rounding.




1,120

15,906

TABLE

B-23

Dates of reports of condition of National banks, 1914—70
[For dates of previous calls see Annual Report for 1920, vol. 2, table No. 42, p. 150]
Year
1914
1915
1916
1917
1918
1919
1920
1921
1922
1923
1924
1925
1926
1927
1928
1929
1930
1931
1932
1933
1934
1935
1936
1937
1938
1939
1940
1941
1942
1943
1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970

See Notes on next page.




Jon.

Feb.

13

Mar.

Apr.

4
4
7
5
4
4
28
21

May

June

1
1
1
10
12
4
28

10

5
3

31
6
12
23
28
27
27
25
5
4
4
31
7
29
26
4
4
13
20
12
11
24
9
31
20
15
11
10
14
4
12
15
12
26
18

'..

15
26
5
25
18
30
30

30
23
30
20
29
30
30
30
30
30
30
30
30
30
30
29
30
30
30
30
30
29
30
30
30
30
29
30
30
30
30
30
29
30
30
30
30
30
30
30
30
30
30
6
23
10
15
30
30
29
30
30
30
30
29
30
30

July

Aug.

Sept.
12
2
12
11

Oct.

Nov.

31
10
17
20
1
17
15

31
12
8
6
15
14
10
28
10
3
4
24
29
30
25
17

1
28
2
24
18
30
6
1
4
10
5
30
7
5
26
11
24
6
3
27
28
30
1
13
20
4
30
21
28

Dec.
31
31
27
31
31
31
29
31
29
31
31
31
31
31
31
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
31
31
31
31
31
31
30
28
20
31
31
31
30
31
31
31

NOTES

Act of Feb. 25, 1863, provided for reports of condition on
the 1st of each quarter before commencement of business.
Act of June 3, 1864— 1st Monday of January, April, July,
and October, before commencement of business, on form prescribed by Comptroller (in addition to reports on 1st Tuesday of each month showing condition at commencement of
business in respect to certain items; i.e., loans, specie, deposits, and circulation).
Act of Mar. 3, 1869, not less than 5 reports per year, on
form prescribed by Comptroller, at close of business on any
past date by him specified.
Act of Dec. 28, 1922, minimum number of calls reduced
from 5 to 3 per year.
Act of Feb. 25, 1927, authorized a vice president or an
assistant cashier designated by the board of directors to
verify reports of condition in absence of president and
cashier.
Act of June 16, 1933, requires each National bank to
furnish and publish not less than 3 reports each year of
affiliates other than member banks, as of dates identical with
those for which the Comptroller shall during such year require reports of conditions of the bank. The report of each
affiliate shall contain such infomation as in the judgment of
the Comptroller shall be necessary to disclose fully the
relations between the affiliate and the bank and to enable
the Comptroller to inform himself as to the effect of such
relations upon the affairs of the bank.
Sec. 21 (a) of the Banking Act of 1933 provided, in part,
that after June 16, 1934, it would be unlawful for any private bank not under State supervision to continue the trans-




action of business unless it submitted to periodic examination by the Comptroller of the Currency or the Federal
Reserve bank of the district, and made and published
periodic reports of condition the same as required of National banks under sec. 5211, U.S.R.S. Sec. 21(a) of the Banking Act of 1933, however, was amended by sec. 303 of the
Banking Act of 1935, approved Aug. 23, 1935, under the
provisions of which private banks are no longer required to
submit to examination by the Comptroller or Federal Reserve bank, nor are they required to make to the Comptroller and to publish periodic reports of condition. (Five calls
for reports of condition of private banks were made by the
Comptroller, the first one for June 30, 1934, and the last one
for June 29, 1935.)
Sec. 7 (a) (3) of the Federal Deposit Insurance Act (Title
12, U.S.C., sec. 1817(a)) of July 14, 1960, provides, in part
that, effective Jan. 1, 1961, each insured National bank shall
make to the Comptroller of the Currency 4 reports of condition annually upon dates to be selected by the Comptroller,
the Chairman of the Board of Governors of the Federal Reserve System, and the Chairman of the Board of Directors of
the Federal Deposit Insurance Corporation, or a majority
thereof. Two dates shall be selected within the semiannual
period of January to June, inclusive, and 2 within the semiannual period of July to December, inclusive, Sec. 161 of
Title 12 also provides that the Comptroller of the Currency
may call for additional reports of conditions, in such form
and containing such information as he may prescribe, on
dates to be fixed by him, and may call for special reports
from any particular association whenever in his judgment the
same are necessary for use in the performance of his supervisory duties.

TABLE

B-24

Total and principal assets of National banks, by States, June 30, 1970
[Dollar amounts in millions]
Securities, gross]
Number
of banks

Total
assets

Cash
assets*

Loans,
gross
U.S. Gov- State and
ernment
local
obligations%

Other

Federal
Direct
funds
lease
sold§ financing

United States

4,638

$312,621

$51,953

$33,003

$37,064

$1,460

$169,915

$6,544

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

89
5
4
68
64
121
26
5
11
213

3,351
449
2,631
1,574
42,650
3,283
2,622
35
2,067
8,932

519
67
340
265
6,387
597
392
4
383
1,618

420
73
156
199
3,621
322
145
9
355
1,263

450
75
264
216
4,865
321
357
1
174
1,312

8
1
5
5
186
9
11

1,753
208
1,736
792
24,473
1,830
1,556
17
1,057
4,059

95
7
32
41
836
62
72
3
35
342

62
1
8
414
123
99
171
80
49
20

4,431
79

290
17
90
3,538
961
332
439
336
622
56

420
9
148
3,180
677
237
344
253
453
115

30

25,698
6,958
2,235
2,673
2,204
3,789
684

863
11
137
3,387
1,287
460
428
359
653
98

2
160
28
5
15
8
9
2

2,500
38
588
13,769
3,568
1,129
1,279
1,126
1,827
377

114
0
4
525
262
20
94
69
107
15

11
0
0
68
13
1
1
1
2

44
85
99
199
38
98
49
126
4
50

2,798
8,674
12,310
6,341
1,622
5,144
881
2,430
821
699

471
1,632
1,869
977
259
930
116
467
98
111

300
679
1,479
756
221
600
128
322
99
80

321
950
1,368
711
187
543
116
255
97
70

11
33
73
25
4
25
2
8
1
2

1,481
4,828
6,928
3,623
855
2,767
484
1,260
450
399

137
129
252
56
40
129
5
48
43
20

3
49
13
19
0
21

131
33
172
22
42
217
208
10
304
5

10,560
1,020
49,226
4,801
769
13,344
4,349
3,485
19,266
1,643

1,352
158
10,804
814
91
1,854
781
561
2,536
156

1,200
126
3,528
381
118
1,740
598
290
2,101
165

1,785
124
4,747
670
92
1,907
547
435
2,541
225

72
2
245
11
1
63
80
7
111
4

5,709
539
26,536
2,734
441
7,195
2,009
2,022
10,913
1,047

179
41
487
16
4
258
223
8
487
3

3
1
160
6
0
14
8
6
20

20
33
77
527
10
26
102
27
84
122
40
1

1,492
912
5,181
19,251

168
135
550
1,970
84
47
543
449
312
481
90
21

162
109
570
2,542
90
57
642
573
204
470
64
19

4
2
19
72
3
3
14
13
5
15
2

785
531
2,713
9,701
534
297
2,950
2,977
700
2,445
307
74

65
1
189
501
14
7
74
234
58
80
11
10

0

5,047
5,242
1,534
4,330
574
141

260
105
983
3,698
161
53
669
725
206
705
80
12

14

3,057

554

502

292

14

1,576

48

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

. ..
. .

.. .
.

Maryland
Massachusetts
Michigan.
Minnesota. .
Mississippi.
Missouri . .
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New M e x i c o . . .
New York
North Carolina
North Dakota
Ohio
Oklahoma.
Oregon
Pennsylvania
Rhode Island

. .
. . .

.

. .
. .

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

997

918
475

9
30

$759

1
296
4
1
0
2
6

_
0

2
6
3
1
3
2
8
0

2

*Cash, balances with other banks, and cash items in process of collection.
tIncludes investment securities and securities held in trading accounts.
{Includes U.S. Treasury securities and obligations of other U.S. Government agencies.
§Also includes securities purchased under agreements to resell.
||Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the




TABLE B-25
Total and principal liabilities of National banks, by States, June 30, 1970
[Dollar amounts in millions]
Deposits
Total
liabilities
Total
deposits

Demand
deposits,
total

Time and
savings
deposits,
total

Demand
deposits
IPC*

Time
deposits
IPC

Federal
funds purchasedf

United States

$284,710

$254,382

$133,342

$121,040

$98,207

$105,859

$11,346

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

3,023
416
2,428
1,422
39,458
2,999
2,389
32
1,875
8,173

2,899
408
2,326
1,369
34,817
2,761
2,255
31
1,817
7,726

1,568
201
1,025
762
14,787
1,517
1,253
14
1,121
4,175

1,331
207
1,302
607
20,030
1,244
1,002
17
696
3,551

1,197
161
815
583
11,976
1,155
1,040
13
981
3,093

1,237
109
1,184
565
16,637
1,072
941
17
674
3,180

25
0
25
28
1,850
117
25
0
15
213

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

3,997
73
920
23,251
6,381
2,043
2,401
1,998
3,415
619

3,396
71
873
20,176
5,928
1,978
2,309
1,925
3,236
586

2,093
26
403
10,598
3,077
1,076
1,290
1,062
1,837
294

1,303
44
470
9,577
2,852
902
1,019
863
1,399
292

1,529
22
315
7,723
2,040
700
846
867
1,348
246

1,164
26
446
8,365
2,695
851
870
823
1,126
281

356
0
12
981
226
24
27
28
74
8

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

2,559
7,863
11,334
5,810
1,475
4,608
812
2,204
753
622

2,383
6,398
10,457
5,081
1,372
4,140
758
2,043
732
578

1,392
4,569
4,076
2,613
796
2,648
315
1,142
330
354

991
1,829
6,382
2,468
576
1,492
443
901
402
223

1,045
3,137
3,167
1,739
533
1,833
244
807
263
287

967
1,536
5,494
2,370
501
1,401
410
874
330
218

92
456
266
389
62
342
18
123
0
7

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

9,640
934
44,634
4,367
705
12,102
3,911
3,218
17,291
1,491

9,205
890
36,038
3,904
675
11,208
3,677
3,030
15,915
1,277

4,185
482
23,280
2,184
265
5,153
2,170
1,301
7,370
571

5,020
408
12,758
1,720
410
6,055
1,507
1,728
8,544
706

3,396
359
15,039
1,653
217
3,965
1,560
1,083
5,916
443

4,860
338
10,019
1,473
390
5,631
1,290
1,529
7,749
700

85
15
2,346
207
8
413
155
53
480
150

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

1,361
836
4,711
17,466
842
435
4,606
4,805
1,380
3,971
518
133

1,288
805
4,378
15,871
760
422
4,321
4,277
1,311
3,679
500
121

916
329
2,299
9,449
345
154
1,916
2,003
634
1,651
236
32

371
476
2,079
6,421
414
268
2,405
2,275
676
2,029
264
88

738
261
1,525
6,819
264
130
1,554
1,662
483
1,253
168
15

351
433
1,710
5,210
367
262
2,271
2,125
663
1,827
239
57

6
3
148
904
52
1
111
289
30
93
6
0

2,774

2,657

1,601

1,056

1,412

1,005

57

District of Columbia—allj

Reserves
on loans
and
securities

*IPC deposits are those of individuals, partnerships, and corporations.
fAlso includes securities sold under agreements to repurchase.
{Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.




TABLE

B-26

Capital accounts of National banks, by States, June 30, 1970
[Dollar amounts in millions]
Total
capital
accounts

Debentures

Preferred
stock

$63

Common
stock

Undivided
Surplus

profits

$6,357

$10,438

$5,437

—
—
26
6
193
5
12
0
1
30

84
9
37
36
701
74
50
1
39
223

120
10
72
52
1,163
103
104
1
81
274

72
8
43
40
575
67
36
1
47
138

509
170
250
181
335
58

54
2
0
26
4
2
7
0
8
0

76
2
19
616
122
41
68
37
76
20

136
1
33
903
227
66
98
94
173
20

84
1
15
374
148
57
74
46
75
16

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

211
700
829
465
129
481
58
199
61
69

3
22
122
23
6
27
1
3
0
—

52
155
202
130
32
116
22
48
22
14

96
340
318
163
83
177
22
67
21
37

52
155
169
143
7
151
12
77
18
17

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

798
76

39
1
280
50
2
28
21
0
61
—

215
24
995
74
16
295
106
80
360
29

354
24
1,719
164
20
502
137
83
858
73

174
15
640
83
15
266
132
67
405
33

25
18
108
500
21
10
116
113
30
87
6

54
24
173
620
34
13
169
141
68
125
24
4

32
19
109
361
11
11
101
112
35
80
18
2

50

113

76

United States

$24,112

$1,136

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

288
27
177
138

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

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

2,675

251
202
3
171
684
384
5
67
2,067

3,824

375
54
1,097

399
230
1,746

135
114
63
418
66
36
388
377
139
307
51
7

0
1
19
41
0
1
2
0
2
4
2
0

256

13

1,568

0
41
0
0
0
0
7
0
0
0
0
1
0
1
0
0
0
0
0
0

Capital
reserves

•Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.




227

TABLE

B-27

Total and principal assets of National banks, by States, Dec. 31, 1970
[Dollar amounts in millions]
Securities, grossf
Number
of banks

Total
assets

Cash
assets*

State
U.S. Govand local
ernment
obligations'^

Loans,
gross
Other

United States

4,621

$340,906

$56,040

$40,905

$41,542

$1,800

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

89
5
3
69
60
122
26
5
11
215

3,792
484
2,897
1,759
45,938
3,676
2,913
39
2,219
10,196

655
71
341
338
6,600
691
444
4
391
2,078

512
75
209
243
5,233
397
163
10
374
1,503

559
98
356
228
5,002
360
515
1
209
1,509

8
2
7
4
247
10
13

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

62
1
7
414
122
99
171
80
49
19

4,639
82
1,066
27,821
7,758
2,463
2,928
2,495
4,161
730

841
10
131
3,896
1,534
519
493
432
784
108

335
14
110
4,240
1,107
378
541
400
715
71

436
8
180
3,362
757
265
353
272
475
96

34

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

42
86
101
199
38
98
49
125
4
48

2,935
9,369
13,483
6,938
1,733
5,953
978
2,643
884
768

544
1,714
2,207
1,204
276
1,250
123
519
103
116

325
958
1,683
1,016
254
770
175
383
127
103

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

129
33
169
22
42
217
203
10
299
5

11,531
1,135
51,565
5,376
836
14,349
4,914
3,865
21,135
1,696

1,518
189
9,063
903
100
2,101
913
606
3,154
170

19
33
77
530
10
26
101
25
85
125
41
1

1,652
1,003
5,770
22,088
1,021
521
5,523
5,905
1,696
4,799
646
141

14

3,233

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

,

,

District of Columbia—all

Federal
Direct
funds
lease
financing
sold§

$177,202 $10,436
1,810
216
1,875
818
25,349
1,960
1,668
19
1,072
4,297

138
2
1
67
1,221
111
10
3
102
441

3
170
25
8
32
7
10
2

2,540
44
606
14,268
3,668
1,170
1,321
1,175
1,902
401

213
3
7
678
486
67
107
151
160
32

393
1,104
1,597
747
193
618
129
274
114
66

9
111
75
15
6
25
3
6
1
2

1,488
4,859
7,444
3,643
896
2,830
498
1,318
485
409

95
211
109
109
51
308
24
73
19
52

1,489
137
4,623
526
155
2,148
649
362
2,372
116

1,947
165
5,644
807
104
2,052
639
574
2,942
236

81
3
309
17
1
73
96
8
127
4

5,927
572
28,315
2,843
443
7,175
2,104
2,104
11,028
1,101

280
38
796
73
12
448
395
41
937
23

314
125
1,128
4,291
181
58
737
895
222
838
104
12

218
161
636
2,455
97
50
627
590
344
589
117
21

184
132
658
2,762
104
59
723
696
219
529
70
19

7
2
20
110
5
3
17
14
6
20
2

814
545
2,909
10,591
572
318
3,150
2,998
744
2,508
317
74

62
9
240
1,123
30
21
106
446
110
170
14
10

571

531

326

17

1,576

134

11
28

*Cash, balances with other banks, and cash items in process of collection.
•("Includes investment securities and securities held in trading accounts,
jlncludes U.S. Treasury securities and obligations of other U.S. Government agencies.
§Also includes securities purchased under agreement to resell.
||Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.




TABLE

B-28

Total and principal liabilities of National banks, by States, Dec. 31, 1970
[Dollar amounts in millions]
Deposits
Total
liabilities
Total
deposits

Demand
deposits,
total

Time and
savings
deposits,
total

Demand
deposits
IPC*

Time
deposits
IPC

Federal
funds
purchased f

Reserves
on loans
and
securities

United States

$312,194

$283,784

$145,122

$138,662

$107,768

$119,843

$11,830

$3,836

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

3,457
449
2,691
1,601
42,671
3,379
2,674
36
2,022
9,398

3,302
437
2,533
1,558
38,829
3,141
2,504
35
1,951
8,957

1,829
197
1,053
890
15,737
1,671
1,374
15
1,181
4,871

1,473
241
1,480
667
23,092
1,470
1,131
20
770
4,086

1,319
159
883
669
13,114
1,285
1,157
14
1,015
3,457

1,349
121
1,308
614
18,691
1,278
1,019
20
743
3,474

47
0
72
16
1,675
100
51
0
26
181

40
6
27
15
513
34
31

4,196
76
985
25,344
7,161
2,264
2,643
2,281
3,779
663

3,705
74
941
22,362
6,502
2,187
2,529
2,198
3,614
630

2,285
31
439
11,445
3,467
1,181
1,433
1,258
2,071
315

1,420
43
502
10,917
3,034
1,005
1,096
939
1,543
314

1,651
24
340
8,494
2,200
781
938
992
1,501
266

1,255
29
471
9,707
2,901
942
948
881
1,286
296

274
0
2
1,453

51
10
376

399

68

36
45
37
56
8

24
22
26
43
8

2,691
8,524
12,477
6,390
1,581
5,406
906
2,418
813
688

2,539
7,178
11,363
5,858
1,493
4,853
862
2,323
788
636

1,470
4,811
4,462
3,001
866
3,201
369
1,340
348
397

1,068
2,367
6,901
2,857
627
1,652
493
983
440
239

1,130
3,431
3,363
1,970
607
2,054
277
925
287
304

1,017
2,009
5,857
2,653
552
1,575
447
950
364
230

65
747
360
303
43
433
9
52
0
10

28
113
149
66
21
53
11
27
7
8

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

10,572
1,045
46,884
4,913
770
13,070
4,469
3,594
19,095
1,541

10,134
1,003
39,610
4,516
742
12,268
4,187
3,367
17,804
1,434

4,692
514
23,051
2,479
306
5,602
2,399
1,358
8,467
581

5,442
489
16,558
2,038
436
6,666
1,788
2,009
9,337
853

3,752
395
15,477
1,935
244
4,390
1,734
1,140
6,740
484

5,165
380
13,312
1,655
415
6,064
1,516
1,651
8,467
805

61
13
1,741
99
2
359
173
73
638
43

124
11
773
58
9
144
40
38
234
17

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

1,517
922
5,280
20,232

1,415
892
4,906
18,385

1,020
369
2,630
10,714

395
524
2,276
7,671

827
295
1,745
7,659

372
469
1,942
6,176

19
1

18
13

185

943
480

872
467

402
173

470
294

315
143

392
281

5,068
5,453
1,537
4,424

4,749
4,851
1,446
4,168

2,102
2,284

2,647
2,567

1,750
1,910

2,456
2,339

705

741

539

721

1,956

2,212

1,471

1,963

588
133

569
121

278
32

291
88

200
15

259
57

28
0
125
418
44
67
4
0

51
226
9
5
55
61
15
52
5
1

2,942

2,851

1,717

1,134

1,488

1,099

30

27

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky .
Louisiana
Maine
Maryland .
Massachusetts.
Michigan . . .
Minnesota
Mississippi
Missouri
M^ on tan a
Nebraska
Nevada.
New Hampshire.

. .

. .

. .

....

District of Columbia—allj

1,238

20
77

*IPC deposits are those of individuals, partnerships, and corporations.
fAlso includes securities sold under agreements to repurchase.
{Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data mav not add to totals because of rounding. Dashes indicate amounts less than $500,000.




TABLE

B-29

Capital accounts of National banks, by States, Dec. 31, 1970
[Dollar amounts in millions]

Debentures

United States

$24,875

$1,161

$63

$6,457

$10,659

$5,864

$671

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

296
29
179
143
2,754
263
208
3
176
721

1

OOOO

Preferred
stock

Total
capital
accounts

85
9
35
37
702
74
50
1
39

123
10
80
55
1,220
110
112
1
92
298

77
9
39
40
594
68
34
1
42
146

10
1
0
4
51
1

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

392
6
71
2,101
530
175
262
187
339
59

19

138
1
37

86
1
15

37
0
0

616

147

.

. .

...

53

2
0

0
0
0
2
0
0
0
0

28

77
2

profits

Capital
reserves

1
19

970

340

0
0
1
0
3
0

123
42
69
38
76
21

237
68
102
95
171
21

157
60
80
50
81
17

216
732
857
483
132
494

3
23
121
24
6
27

0
0
4
0
0
3

51
162
207
131
33
116

97
348
348
176
89
179

57
172
164
146
2
161

8
28
14
6
1

61
198

1
3

0

22
51

23
74

15
66

3

63
72

0

0
0

22
14

21
38

20
18

1

835

39

222

364

191

24

24

18

0
0

1,001
102
16

1,492
165
20

14
991

0

297

545

261

0
7
0

106
80
372
29

138
93
915
73

136
60
399
36

24
20
114
506
22
10
117
114
30
93
6

53
26
181
626
36
13
172
148
70
142
24
4

36
19
99
395
12
12
108
118
37
78
18
2

51

124

73

New Jersey
New M e x i c o . . .
New York
North Carolina
North Dakota. .
Ohio
Oklahoma .
Oregon
Pennsylvania
Rhode Island . .

79

1

3,908
404
56
1,135
405
232
1,806
138

272
65
2

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

117
67
439
1,631
69
37
401
391
144
322
53
6

0
1
19
56
0
1
2
0
2
4
2
0

264

13

2

District of Columbia—all *

227

Undivided
Surplus

4
2
7
0
8
0

oooooo — o —

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

....

25
7
187
9
12
0
1
31

Common
stock

28

22
0
61

0
41

0
0
0

69
16

8
4
3
4
1
1

7

16
110

4
2

4
3
53
4

1
26
47
0
1

2
10
5
5
1
2

"Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

230




TABLE

B-30

Loans of National banks, by States, Dec. 31, 1970
[Dollar amounts in millions]

Loans

Loans
secured
by real
estate

Loans to
financial
institutions

Loans to
purchase
or carry
securities

Loans to
farmers

Commercial
and
industrial
loans

Personal
loans to
individuals

United States

$177,202

$41,561

$11,447

$5,032

$5,438

$70,080

$38,740

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

1,810
216
1,875
818
25,349
1,960
1,668
19
1,072
4,297

305
91
497
207
7,521
390
549
11
327
993

76

23

165
24
1,443
133
149
1
121
183

18
18
327
21
43
0
13
75

36
0
193
57
727
232
2

645
69
485
245
10,122
590
452
2
325
1,494

656
55
498
258
4,524
546
427
4
254
1,405

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

2,540
44
606
14,268
3,668
1,170
1,321
1,175
1,902
401

441
17
160
2,577
1,150
290
195
304
341
133

170

25

23

8
1,312
203
35
43
61
134
5

6
546
74
23
28
10
41
1

101
350
87
235
307
70
21
8

903
20
138
6,806
1,019
301
397
305
792
131

919
7
185
2,307
1,053
273
338
391
522
116

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

1,488
4,859
7,444
3,643
896
2,830
498
1,318
485
409

431
726
2,888
959
186
514
130
154
174
110

109
501
568
224
33
238
4
38
17
6

36
38
219
112
19
102
1
57
7
1

18
4
52
188
36
118
103
434
9
4

451
2,605
2,109
1,296
277
1,203
120
323
128
129

397
872
1,349
814
316
622
137
297
147
151

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

5,927
572
28,315
2,843
443
7,175
2,104
2,104
11,028
1,101

2,339
86
4,362
327
142
2,076
366
517
3,019
472

192
13
2,480
97
3
312
127
108
549
54

53
4
1,944
43
1
89
53
17
104
4

11
56
9J
32
79
88
231
101
136

1,654
199
15,000
1,324
119
2,064
709
956
4,199
347

1,492
187
3,701
947
96
2,296
525
387
2,590
208

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

814
545
2,909
10,591
572
318
3,150
2,998
744
2,508
317
74

105
129
418
1,186
205
150
938
' 735
242
861
66
46

31
4
182
858
22
1
98
174
20
115
5
0

13
177
46
501
26
8
66
161
9
65
70
0

291
120
1,208
4,694
170
66
796
1,199
159
817
92
17

319
107
943
2,309
127
84
1,045
653
300
494
79
10

1,576

477

200

8
1
51
629
13
4
34
30
5
56
3
0
=
25

0

432

394

District of Columbia—all*

55

Other
loans

*Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts of less than $500,000.




231

N3

TABLE

B-31

Income and expenses of National banks, * by States, year ended Dec. 31, 1970
[Dollar amounts in thousands]
United States

Number of banks

4,621

Operating income:
Interest and fees on loans
$13,698,354
Income on Federal funds sold and securities purchased under agreements to resell
602,927
Interest and dividends on investments:
U.S. Treasury securities
1,654,123
Securities of other U.S. Government agencies and
corporations
326,990
Obligations of States and political subdivisions.
1,535,309
Other securities
90,675
Trust department income
626,202
Service charges on deposit accounts
686,411
Other service charges, collection and exchange
534,791
charges, commissions, and fees
677,949
Other operating income
Total operating income

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income



Alabama

Alaska

Arizona

89

Arkansas

California

Colorado

69

60

122

26

$63,185 $2,038,079

$162,192

$125,582

$1,274

Connecticut Delaware

$145,157

$19,375

$148,376

8,161

1,001

881

4,448

75,901

6,354

3,427

204

22,595

2,428

8,337

10,009

179,161

17,608

5,465

409

3,567
19,139
532
5,238
11,757
5,944
2,847

2,178
3,875
60
232
2,442

1,886
12,165
223
4,388
8,579

2,385
8,722
225
1,279
4,709

39,720
182,355
13,220
76,872
127,822

3,108
13,968
636
11,270
12,709

2,150
17,953
676
10,768
7,468

106
36
6
0
84

2,373
505

3,741
4,402

1,353
1,199

106,260
117,035

10,248
4,203

4,337
3,446

38
34

20,433,731

224,937

34,469

192,978

97,514

2,956,425

242,296

181,272

2,191

3,838,556
625,174
6,215,245

46,625
7,656
64,141

8,600
1,045
11,188

44,070
7,736
67,647

20,277
2,710
29,589

594,280
90,819
1,081,466

51,031
7,045
64,501

46,060
7,871
46,397

511
63
712

937,495
169,780
55,165
723,788

2,541
454
27
6,928

17
0
9
1,371

5,102
0
1,043
6,907

2,067
258
311
4,241

130,078
29,718
8,884
119,882

7,453
3,333
506
8,680

2,708
1,225
551
9,397

0
0
0
85

546,553
405,564
2,784,676

7,486
7,001
26,971

1,285
1,301
3,867

6,269
3,199
20,140

3,622
3,702
12,283

58,372
53,542
351,795

8,852
6,448
37,533

5,944
2,811
22,340

74
3
265

16,301,996

169,830

28,683

162,113

79,060

2,518,836

195,382

145,304

1,713

4,131,735
1,239,931
2,891,804
-64,512
2,827,292
+2,081
-39

55,107
18,036
37,071

5,786
862
4,924

30,865
9,677
21,188

437,589
128,921
308,668
-3,447
305,221
-283
0

46,914
15,940
30,974

35,968
10,739
25,229

478
146
332

-236
30,738
+ 303
0

25,279
-117
0

336
0
0

2,829,334

37,473

304,938

31,041

25,162

336

+299
37,370
+ 103
0

5,022
-4
0

+83
21,271
0
0

18,454
4,874
13,580
-584
12,996
+484
0

5,018

21,271

13,480

+98

+50

+4

Changes in capital accounts:
Increases:
Net income transferred to undivided profits....

2,829,334

37,473

5,018

21,271

13,480

304,938

31,041

25,162

336

327,335

3,708

0

16,439

2,707

11,835

7,072

3,997

176

135,797
28,217
148,007

254
228
2,940

0
127
181

0
0
0

175
111
2,492

3,156
1,322
2,764

0
141
2,370

4,074
53
31

0
0
48

639,356

7,130

308

16,439

5,485

19,077

9,583

8,155

224

1,273,039
4,677

14,604
0

838
0

8,215
0

3,803
0

153,701
0

12,247
65

14,295
0

87
0

82,861

0

20

367

78

7,271

62

0

27,779
153,010
158,364

49
702
3,321

130
93
195

0
563
539

0
1,051
1,591

4,413
5,601
6,978

0
2,370
1,637

350
775
329

0
19
19

1,699,730

18,676

1,276

9,674

6,523

177,964

16,381

15,749

125

1,768,960

25,927

4,050

28,036

12,442

146,051

24,243

17,568

435

24,080,719

284,542

27,212

170,226

136,797

2,692,094

250,004

200,560

2,975

Ratios:
Net income before dividends to capital accounts
(percent)

11.75

13.17

18.44

12.50

9.85

11.33

12.42

12.55

11.30

Total operating expense to total operating revenue (percent)

79.77

75.50

83.21

84.00

81.07

85.19

80.63

80.15

78.18

Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers from reserves on loans and securities. .
All other increases
Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities. . . .
All other decreases
Total decreases

Net change in capital accounts
Capital accounts!

See footnotes at end of table.




TABLE B-31—Continued
Income and expenses of National banks, * by States, year ended Dec. 31, 1970
[Dollar amounts in thousands]
District of
Columbia

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

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

414

122

99

171

$49,343

1,050,538

$278,060

$87,263

$102,673

156

935

39,346

20,082

3,843

6,615

15,272

1,074

5,515

162,193

46,290

16,364

23,211

23,492
57,910
1,723
17,063
24,692

2,964
19,076
1,296
10,066
16,857

1
397
5
0
13

191
7,147
101
500
3,647

39,999
132,546
9,256
62,791
29,774

11,120
28,666
1,286
12,294
14,652

3,954
9,616
357
3,346
4,788

4,959
13,942
329
2,791
6,913

1,878
1,832

22,879
12,444

5,430
16,290

228
33

1,888
290

26,435
84,523

11,113
7,999

5,143
1,579

5,644
2,650

138,274

586,422

337,741

5,756

69,557

1,637,401

431,562

136,253

169,727

30,538
3,499
35,930

112,623
15,141
177,412

75,114
13,047
65,280

1,369
158
2,470

14,729
2,237
22,300

253,889
45,420
487,140

81,478
12,875
133,172

26,531
3,582
43,735

32,123
4,304
51,223

1,283
1,171
55
5,280

16,024
1,558
1,708
15,799

18,785
21,274
1,934
13,520

9
0
75
336

313
515
0
1,509

109,511
29,243
1,605
52,753

18,590
2,820
72
15,682

2,725
357
97
4,364

2,996
991
468
5,179

3,886
2,199
20,025

20,203
14,430
84,979

11,447
12,207
42,744

155
175
693

1,844
1,182
7,810

33,968
39,270
238,571

13,637
10,079
47,206

6,824
1,779
16,219

5,398
4,241
19,573

103,866

459,877

275,352

5,440

52,439

1,291.,370

335,611

106,213

126,496

34,408
14,006
20,402
+ 751
21,153
-378
0

126,545
32,669
93,876
-2,233
91,643
+564
0

62,389
20,480
41,909

316
42
274

+92

366
0
0

346,031
100,671
245,360
-13,827
231,533
-2,185
-18

95,951
30,433
65,518
-562
64,956
-89
0

30,040
10,300
19,740

-906
41,003
-634
0

17,118
5,536
11,582
-62
11,520
0
0

+251
19,991
+47
-18

43,231
13,762
29,469
-65
29,404
-26
0

20,775

92,207

40,369

366

11,520

229,330

64,867

20,020

29,378

11

215

62

1

$86,804

$343,755

$238,951

$3,849

5,755

29,721

11,539

20,217

52,743

2,804
7,091
654
5,348
5,891

Changes in capital accounts:
Increases:
Net income transferred to undivided p r o f i t s . . . .

366

11,520

229,330

64,867

20,020

29,378

29,576

713

7,184

2,341

646

976

1,150
696
4,257

799
79
2,245

2,087
0
37

450
3,799
25,047

1,773
1,677
4,188

223
68
2,321

804
79
4,907

851

26,960

32,699

2,837

36,480

9,979

3,258

6,766

8,626
638

28,192
0

19,529
0

3,588
0

110,000
5

20,158
0

6,748
0

9,216
18

31

3,806

2,711

0

307

3,466

0

55

0
-40
478

500
3,883
3,240

0
4,170
2,913

0
208
15

246
13,827
24,668

1
2,152
3,021

300
1,269
2,434

25
981
5,752

9,733

39,621

29,323

80

3,811

149,053

28,798

10,751

16,047

11,893

79,546

43,745

286

10,546

116,757

46,048

12,627

20,097

170,544

681,605

374,406

5,210

66,877

2,052,706

507,184

169,485

251,694

Ratios:
Net income before dividends to capital accounts
(percent)

12.18

13.53

10.78

7.02

17.22

11.17

12.79

11.81

11.67

Total operating expense to total operating revenue (percent)

75.12

78.42

81.53

94.51

75.39

78.87

77.77

77.95

74.53

Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers from reserves on loans and securities. .
All other increases
Total increases
Decreases:
Cash dividends declared:
On common stock
O n preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities....
All other decreases
Total decreases
Net change in capital accounts
Capital accounts f

See footnotes at end of table.

ISO




20,775

92,207

40,369

502

20,857

0
77
272

80
0

TABLE

B-31—Continued

Income and expenses of National banks, * by States, year ended Dec. 31, 1970
[Dollar amounts in thousands]

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

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




Kentucky

Louisiana

Maine

80

49

19

42

$87,756

$147,394

$31,896

5,955

9,068

18,629
2,306
10,933
372
2,153
5,023

Massachusetts

Michigan

Minnesota

Mississippi

86

101

199

38

98

$118,621

$405,348

$535,165

$276,653

$71,523

$217,186

1,569

8,947

19,223

16,880

6,763

2,844

11,015

32,507

3,250

16,695

44,342

75,666

31,702

10,692

33,612

167
4,152
100
1,679
1,734

2,505'
13,659
573
3,663
8,198

4,062
36,185
1,794
39,240
17,217

10,273
57,745
4,598
20,600
21,478

8,681
28,229
726
14,325
12,475

1,252
7,565
264
1,365
6,119

4,375
21,688
944
13,256
6,384

2,220
1,490

4,781
18,122
613
2,578
10,104
7,025
3,258

1,238
640

2,646
2,158

23,023
20,459

13,541
13,275

15,376
18,569

3,476
4,404

7,960
16,213

136,837

235,450

46,425

177,665

610,893

769,221

413,499

109,504

332,633

27,696
3,955
40,697

42,914
6,385
69,695

10,781
1,636
12,950

37,819
5,652
41,222

128,823
21,477
101,859

134,154
22,457
318,019

67,854
11,306
128,098

20,464
3,217
26,608

57,315
8,737
78,679

1,981
173
0
4,513

6,425
2,113
305
9,112

615
123
0
1,899

5,529
948
163
7,823

47,555
10,165
1,102
24,227

25,974
5,424
6,032
27,826

27,651
8,864
1,271
10,071

5,066
105
298
3,312

32,139
1,503
1,272
9,293

4,434
3,313
17,102

7,904
5,600
29,510

2,036
708
6,692

6,192
3,092
24,272

16,223
12,680
111,451

20,536
9,069
65,729

15,646
4,668
45,947

3,867
4,145
16,463

8,977
5,566
37,209

103,864

179,963

37,440

132,712

475,562

635,220

321,376

83,545

240,690

32,973
10,322
22,651

8,985
1,732
7,253
-168
7,085
g
0

44,953
15,876
29,077
29,848
-17
0

135,331
52,896
82,435
-354
82,081
-646
0

134,001
38,017
95,984
-3,258
92,726
+ 189
0

92,123
34,431
57,692
-859
56,833
-57
-1

25,959
8,279
17,680
+ 129
17,809
-149
0

91,943
34,907
57,036

+271
22,922
4-189
0

55,487
19,523
35,964
+938
36,902
+92
0

23,111

36,994

7,076

29,831

81,435

92,915

56,775

17,660

57,711

Maryland

+771

Missouri

+393
57,429
+282
0

Changes in capital accounts:
Increases:
Net income transferred to undivided p r o f i t s . . . .

23,111

36,994

7,076

29,831

81,435

92,915

56,775

17,660

57,711

1,006

978

3,505

1,801

3,115

10,151

3,965

1,330

1,029

98
149
1,826

34
752
1,524

470
24
273

1,326
153
935

1,512
113
909

979
153
2,967

524
298
3,784

6
588
1,459

83
3,376
1,698

3,079

3,288

4,272

4,215

5,649

14,250

8,571

3,383

6,186

7,223
0

12,518
140

3,205
0

10,070
0

37,509
0

30,782
220

22,482
0

7,080
0

23,371
204

0

150

0

133

40

1,326

372

50

0

0
1,763
1,853

0
6,137
874

1,421
331
115

0
1,137
1,253

50
4,192
1,935

0
3,045
4,149

425
1,954
1,876

0
2,057
1,818

0
6,762
2,852

10,839

19,819

5,072

12,593

43,726

39,522

27,109

11,005

33,189

15,351

20,463

6,276

21,453

43,358

67,643

38,237

10,038

30,708

180,031

331,178

57,584

209,764

705,344

825,290

463,786

127,434

479,068

Ratios:
Net income before dividends to capital accounts
(percent)

12.84

11.17

12.29

14.22

11.54

11.26

13.86

12.05

Total operating expense to total operating revenue (percent)

75.90

76.43

80.65

74.70

77.85

82.58

76.29

72.36

Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers from reserves on loans and securities. .
All other increases
Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities....
All other decreases
Total decreases
Net change in capital accounts
Capital accounts t

See footnotes at end of table.




ISO
GO

TABLE B-31—Continued

00

Income and expenses of National banks, * by States, year ended Dec, 31, 1970
[Dollar amounts in thousands]

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

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income



Montana

Nebraska

49

125

$38,417

$102,858

1,225

Nevada

New
Hampshire

New
Jersey

New
Mexico

New
York

North
Carolina

North
Dakota

48

129

33

169

$39,116

$33,222

$429,028

$45,526

$2,116,299

$234,235

6,143

2,983

2,288

19,571

2,825

60,954

3,510

6,698

14,471

5,634

4,894

57,072

6,554

182,731

17,130

1,147
4,898
137
346
2,995

4,999
10,624
348
4,271
5,113

1,065
4,141
79
1,529
2,936

253
3,097
160
806
3,115

14,773
74,457
4,478
15,885
28,139

940
5,619
259
1,250
3,766

21,528
203,536
18,929
106,735
64,833

7,863
29,193
533
11,277
12,214

1,707
492

5,919
5,143

946
1,617

523
1,031

9,223
9,027

2,567
706

72,041
184,965

9,868
13,730

58,062

159,889

60,046

49,389

661,653

70,012

3,032,551

339,553

49,380

10,506
1,820
21,996

31,875
4,674
44,125

12,115
1,520
19,314

11,329
1,733
10,453

133,259
23,274
225,058

14,060
1,796
20,875

519,907
102,277
746,531

80,339
14,184
91,002

8,156
1,376
20,668

1,496
158
53
1,712

6,239
317
167
5,550

21
60
0
2,304

579
67
28
2,095

4,962
1,705
1,960
27,727

1,185
215
70
2,209

190,363
9,066
13,461
117,439

11,176
1,390
2,769

13,102

192
78
123
1,312

1,798
517
7,940

7,343
2,412
21,310

1,487
2,149
7,071

1,502
912
8,041

18,529
7,543
76,651

2,154
2,363
8,814

59,375
64,560
623,198

12,364
5,364
39,822

1,539
645
5,010

47,996

124,012

46,041

36,739

520,668

53,741

2,446,177

271,512

39,099

10,066
2,505
7,561
-66
7,495
-205
0

35,877
11,585
24,292
-28
24,264
-178
0

14,005
4,837
9,168

12,650
4,276
8,374

+280
8,654
+327
0

16,271
5,548
10,723

9,266
-77
0

140,985
28,874
112,111
-1,894
110,217
-352
0

+80
10,803
+ 17
0

586,374
170,801
415,573
-25,639
389,934
+3,395
0

68,041
20,604
47,437
-384
47,053
-12
0

7,290

24,086

9,189

8,981

109,865

10,820

393,329

47,041

+98

22
=====

7,072

Changes in capital accounts:
Increases:
Net income transferred to undivided profits....
Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers from reserves on loans and securities. .
All other increases

7,290

24,086

9,189

350

8,981

109,865

10,820

393,329

47,041

7,072

190

23,560

39

20,262

29,964

617

0
386
468

0
62
3,018

0
0
77

659
61
564

28,985
578
4,298

0
14
634

21,389
2,008
13,567

4,374
188
1,363

31
43
261

860

3,430

77

1,474

57,421

687

57,226

35,889

952

3,596
0

15,343
6

2,966
0

2,849
0

49,611
3

4,140
0

260,057
2,936

18,263
0

2,524
0

0

0

0

0

55

16,053

10,000

0

0
638
149

82
1,369
2,315

0
408
47

0
348
581

617
3,206
5,746

0
100
1,012

1,799
27,364
8,379

2,892
2,039
733

0
266
519

4,388

19,115

3,421

3,778

59,183

5,307

316,588

33,927

3,309

3 , 762

8, 401

5,845

6,677

108,103

6,200

133,967

49,003

4,715

58, 847

195, 360

60,560

68,989

794,456

75,845

3,836,879

378,532

53,754

Ratios:
Net income before dividends to capital accounts
(percent)

12 .39

12 .33

15.17

13.02

13.83

14.27

10.25

12.43

13.16

Total operating expense to total operating revenue (percent)

82.66

77.56

76.68

74.39

78.69

76.76

80.66

79.96

79.18

Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities....
All other decreases
Total decreases
Net change in capital accounts
Capital accounts t

See footnotes at end of table.




TABLE B-31—Continued
Income and expenses of National banks, * by States, year ended Dec. 31, 1970
[Dollar amounts in thousands]
Ohio

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

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




Oklahoma

Oregon

Pennsylvania

Rhode
Island

South
Carolina

South
Dakota

Tennessee

Texas

19

33

77

530

$84,105

$68,174

$40,867

$223,700

$802,327

36,719

803

2,327

676

15,684

55,185

13,680

108,055

5,246

7,462

7,218

27,201

91,607

2,410
21,266
4,057
5,452
10,682

2,163
19,397
308
5,651
14,167

16,708
102,806
6,574
47,804
23,528

778
8,991
266
7,413
1,473

3,518
6,567
167
2,276
6,519

1,330
4,931
136
775
3,052

25,312
104,665
4,605
33,136
39,991

18,752
13,097

6,615
4,530

5,916
2,642

26,120
25,708

2,874
2,507

1,879
3,834

1,939
861

4,269
23,017
940
7,358
11,628
8,844
9,201

856,521

265,321

239,157

1,236,770

114,456

102,723

61,785

331,842

1,209,509

152,770
20,382
287,928

50,244
6,762
75,917

54,915
8,572
89,577

207,807
38,016
410,154

19,267
4,505
34,943

27,605
4,927
15,761

10,666
1,853
24,566

63,232
10,045
104,739

205,696
28,972
354,497

33,310
4,937
1,396
26,973

12,682
955
1,002
6,313

5,175
1,139
0
9,630

42,665
5,126
3,603
40,266

5,713
2,425
22
3,773

939
36
0
3,484

175
76
36
1,931

15,020
1,157
916
10,362

83,288
12,508
1,170
31,769

22,497
14,528
105,347

7,648
6,925
31,971

6,080
3,456
22,344

31,721
14,008
151,979

2,952
2,411
14,353

4,216
1,290
15,737

2,092
1,015
5,863

11,713
8,021
39,995

36,356
34,856
143,893

670,068

200,419

200,888

945,345

90,364

73,995

48,363

265,200

933,005

186,453
47,685
138,768
-3,445
135,323

64,902
18,971
45,931

+512
0

291,425
81,401
210,024
-9,769
200,255
+409
0

24,092
7,654
16,438
-578
15,860
0
0

28,728
10,835
17,893

+476
46,407
+231
-4

38,269
10,724
27,545
+214
27,759
0
0

-54
17,839

13,422
4,261
9,161
-53
9,108

66,642
20,079
46,563
-653
45,910

+49
+3

276,504
82,775
193,729
-413
193,316
-495
0

135,835

46,634

27,759

200,664

15,860

17,877

9,118

45,962

192,821

217

203

10

299

$552,955

$162,202

$172,624

$842,748

26,806

15,072

2,609

97,140

33,035

13,829
81,053
3,995
21,344
27,550

+38
0

+ 10
0

26,752
25,929

Changes in capital accounts:
Increases:
Net income transferred to undivided p r o f i t s . . . .

135,835

46,634

7,748

1,943

2,153
4,063
4,473

1,874
113
4,531

18,437

200,664

15,860

17,877

9,118

45,962

192,821

33,351

200

0

901

2,269

50,629

3
0
12

17,953
621
11,268

50
0
18

0
46
231

1,355
142
962

136
2,492
7,232

3,610
2,511
17,245

8,461

18

63,193

268

277

3,360

12,129

73,995

53,589
0

19,162
21

12,423
0

88,786
361

8,709
0

7,034
0

3,685
0

14,905
0

71,031
32

0

46

0

183

13

0

25

25

35,111

1,041
7,596
3,298

0
2,016
6,843

0
1,163
4,891

3,487
6,690
19,591

0
1,023
202

0
1,273
583

0
464
692

0
2,734
3,541

3,357
20,135
16,482

65,524

28,088

18,477

119,098

9,947

8,890

4,866

21,205

146,148

88,748

27,007

9,300

144,759

6,181

9,264

7,612

36,886

120,668

1,092,730

398,808

228,587

1,748,710

134,562

113,447

63,147

419,639

1,564,560

Ratios:
Net income before dividends to capital accounts
(percent)

12.43

11.69

12.14

11.47

11.79

15.76

14.44

10.95

12.32

Total operating expense to total operating revenue (percent)

78.23

75.54

84.00

76.44

78.95

72.03

78.28

79.91

77.14

Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers from reserves on loans and securities. .
All other increases
Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities....
All other decreases
Total decreases

Net change in capital accounts
Capital accounts f

See footnotes at end of table.




27,759

TABLE B-31— Continued
Income and expenses of National banks, * by States, year ended Dec, 31, 1970
[Dollar amounts in thousands]
Utah

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

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

Income before income taxes and securities gains or losses.
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income




Vermont

Virginia

Washington

West
Virginia

Wisconsin

Wyoming

Virgin
Islands

District of
Columbia—all%

10

26

101

25

85

125

41

1

14

$45,454

$22,989

$246,904

$256,588

$52,996

$184,459

$25,778

$6,493

$126,080

1,219

947

6,420

21,871

5,258

9,192

872

359

6,626

4,758

2,483

28,279

23,761

15,219

24,919

5,435

1,046

28,417

848
4,626
167
1,159
3,617

307
2,250
168
363
1,417

6,616
26,270
757

2,962
8,071
311
1,711
1,871

6,155
20,450
1,136
6,139
6,594

482
2,757
102
314
1,923

0
826
10
0
155

3,161
11,472
725
8,963
8,758

2,696
474

384
514

9,182
12,515
11,459
4,986

2,564
25,058
1,417
10,253
22,842
13,778
12,118

1,147
1,408

8,394
10,597

1,189
455

269
278

2,631
2,094

65,018

31,822

353,388

390,250

90,954

278,035

39,307

9,436

198,927

11,411
1,512
21,286

6,646
975
12,656

72,476
10,656
117,207

91,182
13,194
113,610

15,746
1,901
30,398

50,156
9,081
101,971

7,724
939
12,837

1,799
198
4,046

41,641
4,901
53,459

2,559
1,390
0
1,677

97
37
43
1,254

5,886
2,058
82
2,308

30,764
565
0
15,966

2,186
57
105
2,841

7,374
1,313
254
9,582

312
243
117
1,510

0
367
0
297

2,239
1,248
649
8,851

1,625
980
7,805

1,106
342
3,556

12,230
6,284
46,790

11,693
5,876
43,738

2,481
1,230
11,186

9,641
3,805
29,067

1,243
1,480
4,937

87
92
869

5,350
2,910
25,593

50,245

26,712

286,390

326,588

68,131

222,244

31,342

8,755

146,841

14,773
5,409
9,364

5,110
1,255
3,855
-47
3,808

66,998
17,958
49,040
-1,521
47,519

63,662
18,763
44,899

55,791
18,065
37,726

681

+ 130
0

+212
6,058
+7
0

+65
746
+4
750
0
0

52,086
21,110
30,976

+500
38,226
+ 1,005
0

7,965
2,119
5,846

45,652
-42
-1

22,823
6,774
16,049
-152
15,897
-437
0

47,649

45,609

15,460

39,231

6,065

750

+42

9,406
0
0
9,406

+94
0

3,902

+ 753

+909
31,885
-378
0
31,507

Changes in capital accounts:
Increases:
Net income transferred to undivided profits

9,406

3,902

47,649

45,609

15,460

39,231

6,065

750

31,507

26

17

3,900

7,737

2,195

5,468

351

0

502

0
0
195

25
64
403

6,299
107
1,545

24,167
3
1,341

0
27
1,839

2,757
625
2,325

0
0
662

0
0
0

0
77
272

221

509

11,851

33,248

4,061

11,175

1,013

0

851

4,107
0

1,507
28

21,788
0

16,106
0

4,588
0

15,860
0

2,243
0

0
0

12,949
638

0

42

75

0

30

963

0

0

31

1,771
390
244

32
397
415

53
1,720
1,583

4,738
2,332
2,422

0
743
1,920

0
3,228
1,692

0
291
622

0
75
7

0
311
478

6,512

2,421

25,219

25,598

7,281

21,743

3,156

82

14,407

3,115

1,990

34,281

53,259

12,240

28,663

3,922

668

17,951

66,918

35,669

387,235

376,882

137,516

307,487

51,017

6,983

226,512

Ratios:
Net income before dividends to capital accounts
(percent)

14.06

10.94

12.30

12.10

11.24

12.76

11.89

10.74

13.91

Total operating expense to total operating revenue (percent)

77.28

83.94

81.04

83.69

74.90

79.93

79.74

92.78

73.82

Capital stock, notes and debentures sold or
issued, including premium received
Addition to surplus, undivided profits and reserves incident to mergers and consolidations. .
Transfers from reserves on loans and securities. . .
All other increases
Total increases

Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures retired,
including premium paid
Reduction in surplus, undivided profits and reserves incident to mergers and consolidations. .
Transfers to reserves on loans and securities
All other decreases
Total decreases

Net change in capital accounts
Capital accounts f

*Includes
flncludes
December call
^Includes




all banks operating as National banks at year end, and full year data for those State banks converting to National banks during the year,
the aggregate book value of debentures, preferred stock, common stock, surplus, undivided profits, and reserves. These are averages from the June and
dates in the year indicated and the previous December call date.
National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.

TABLE

B-32

Income and expenses of National banks, * by deposit size, year ended Dec. 31, 1970
[Dollar amounts in thousands]
Banks operating full year with deposits in December 1970, ofTotal

Number of banks

4,621

Operating income:
$13,698,354
Interest and fees on loans
Income on Federal funds sold and securities
602,927
purchased under agreements to resell
Interest and dividends on investments:
1,654,123
U.S. Treasury securities
Securities of other U.S. Government
agencies and corporations
326,990
Obligations of States and political subdivisions
1,535,309
Other securities
90,675
Trust department income
626,202
Service charges on deposit accounts
686,411
Other service charges, collection and exchange charges, commissions, and f e e s . . . .
534,791
Other operating income
677,949
Total operating income



20,433,731

$100,000.1
$50,000.1
$10,000.1
$25,000.1
$2,000.0
$2,000.1
$5,000.1
and under to $5,000.0 to $10,000.0 to $25,000.0 to $50,000.0 to $100,000.0 to $500,000.0

121

636

1,132

1,456

624

$5,992

$86,610

$335,866

$931,542

$917,722

700

7,821

26,948

68,251

54,506

3,239

29,254

83,558

198,937

665

8,769

27,050

289
101
16,791
491

6,987
685
100
6,639

240
258
28,766

Over
$500,000.0

265

82
=

$914,771 $2,603,967

$7,901,884

47,032

127,548

270,121

159,849

150,010

332,526

696,750

58,250

54,695

37,823

56,465

83,273

39,881
2,331
694
28,852

132,705
5,918
6,448
75,964

134,374
6,392
17,620
69,970

128,417
5,295
31,538
57,506

325,875
16,037
126,574
142,041

766,781
53,916
426,437
304,948

2,914
1,741

10,556
5,741

27,703
16,195

29,897
17,901

31,521
20,468

121,336
82,225

310,624
533,420

151,520

561,477

1,521,913

1,462,926

1,424,381

3,934,594

11,348,154

305

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

3,838,556
625,174
6,215,245

10,583
1,253
2,372

35,954
3,405
47,845

118,167
13,643
190,406

292,039
38,817
544,903

281,074
41,168
515,890

274,878
41,023
501,002

787,224
122,696
1,191,637

2,038,637
363,169
3,221,190

937,495
169,780
55,165
723,788

0
7
2
981

53
218
16
4,960

640
681
173
18,372

3,656
2,061
1,227
53,115

7,055
2,682
2,139
53,300

15,212
2,696
2,773
53,689

134,232
21,575
8,603
145,058

776,647
139,860
40,232
394,313

546,553

476

3,762

14,743

41,029

43,346

44,720

138,351

260,126

Other operating expenses.

405,564
2,784,676

353
4,391

4,215
20,207

16,613
73,154

36,743
192,669

29,475
186,015

26,821
172,565

78,778
477,068

212,566
1,658,607

Total operating expense. . .

16,301,996

20,418

120,635

446,592

1,206,259

1,162,144

1,135,379

3,105,222

9,105,347

4,131,735
1,239,931
2,891,804
-64,512
2,827,292
+2,081
-39

8,348
3,965
4,383
-46
4,337
-89
0

30,885
8,520
22,365
-126
22,239
-6
-1

114,885
31,686
83,199
+484
83,683
+286
-1

315,654
86,701
228,953
-380
228,573
+ 193
-39

300,782
81,539
219,243
-297
218,946

+ 1,177
0

289,002
77,735
211,267
+2,167
213,434
+ 1,253
0

829,372
246,165
583,207
-4,759
578,448
-695
-1

2,242,807
703,620
1,539,187
-61,555
1,477,632
-38

Net income

2,829,334

4,248

22,232

83,968

228,727

220,123

214,687

577,752

1,477,597

Gash dividends declared:
On common stock. .
On preferred stock. .

1,273,039
4,677

3,434
0

6,442
0

23,698
70

66,946
62

68,931
26

71,697
232

238,011
508

793,880
3,779

1,277,716

3,434

6,442

23,768

67,008

68,957

71,929

238,519

797,659

Income before income taxes and securities gains or
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect). . . .
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries. . . .

Total cash dividends declared.

"Includes all banks operating as National banks at year end, and full year data for those State banks converting to National banks during the year.




+3

TABLE

B-33

Capital accounts, net income, and dividends of National banks, 1944-70
[Dollar amounts in thousands]

Tear (last call) Number
Preferred

Common

Total

Total
capital
accounts*

$110,597
80,672
53,202
32,529
25,128
20,979
16,079
12,032
6,862
5,512
4,797
4,167
3,944
3,786
3,332
3,225
2,050
2,040
9,852
24,304
27,281
28,697
29,120
38,081
57,704
62,453
62,572

$1,440,519
1,536,212
1,646,631
1,736,676
1,779,362
1,863,373
1,949,898
2,046,018
2,171,026
2,258,234
2,381,429
2,456,454
2,558,111
2,713,145
2,871,785
3,063,407
3,257,208
3,464,126
3,662,603
3,861,738
4,135,789
4,600,390
5,035,685
5,224,214
5,503,820
6,165,757
6,326,508

$1,551,116
1,616,884
1,699,833
1,769,205
1,804,490
1,884,352
1,965,977
2,058,050
2,177,888
2,263,746
2,386,226
2,460,621
2,562,055
2,716,931
2,875,117
3,066,632
3,259,258
3,466,166
3,672,455
3,886,042
4,163,070
4,629,087
5,064,805
5,262,295
5,561,524
6,228,210
6,389,080

$4,114,972
4,467,618
4,893,038
5,293,267
5,545,993
5,811,044
6,152,799
6,506,378
6,875,134
7,235,820
7,739,553
7,924,719
8,220,620
8,769,839
9,412,557
10,003,852
10,695,539
11,470,899
12,289,305
13,102,085
14,297,834
16,111,704
17,971,372
19,095,324
20,585,402
22,158,066
24,080,719

of banks

1944
1945
1946
1947
1948
1949
1950
1951
1952
1953 .
1954
1955
1956
1957
1958..
1959
1960
1961
1962
1963.
1964..
1965
1966
1967
1968
1969
1970.

. .

5,031
5,023
4,013
5,011
4,997
4,981
4,965
4,946
4,916
4,864
4,796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,503
4,615
4,773
4,815
4,799
4,758
4,716
4,669
4,621

Ratios (percent)

Cash dividends

Capital stock (par value)*

Net income
before
On
dividends preferred
stock

$411,844
490,133
494,898
452,983
423,757
474,881
537,610
506,695
561,481
573,287
741,065
643,149
647,141
729,857
889,120
800.311
1,046,419
1,042,201
1,068,843
1,205,917
1,213,284
1,387,228
1,582,535
1,757,491
L931.556
2,534,029
2,829,334

$5,926
4,131
2,427
1,372
1,304
1,100
712
615
400
332
264
203
177
171
169
165
99
119
202

1,126
1,319
1,453
1,348
2,124
4,344
4,428
4,677

On
common
stock

$139,012
151,525
167,702
182,147
192,603
203,644
228,792
247,230
258,663
274,884
299,841
309,532
329,777
363,699
392,822
422,703
450,830
485,960
517,546
547,060
591,491
681,802
736,591
794,056
892,934
1,063,647
1,273,039

Net income
before
dividends
to capital
accounts

10.01
10.97
10.11
8.56
7.64
8.17
8.74
7.79
8.17
7.92
9.58
8.12
7.87
8.32
9.45
8.00
9.78
9.09
8.70
9.20
8.49
8.61
8.81
9.20
9.38
11.44
11.75

Cash dividends to
net income
before
dividends

35.04
31.76
34.38
40.51
45.76
43.11
42.69
49.04
46.14
48 01
40.50
48.16
50.99
49.85
44.20
52.84
43.09
46.64
48.44
45.46
48.86
49.25
46.63
45.30
46.45
42.15
45.16

*These are averages of data from the Reports of Condition of the previous December, and June and December of the respective years.
NOTE: For earlier data, see Annual Reports of the Comptroller of the Currency, 1938, p. 115, and 1963, p. 306.



Cash dividends on
preferred
stock to
preferred
capital

4.79
5.12
4 56
4.22
5.19
5 24
4.43
5.11
5.83
6 02
5.50
4.87
4.49
4.52
5.07
5.12
4.83
5.83
2.05
4.63
4.83
5.06
4.63
5.58
7.53
7.09
7.46

Total cash
dividends
to capital
accounts

3.53
3.48
3 48
3.47
3.50
3 52
3 73
3.81
3.77
3 80
3 88
3.91
4.01
4.15
4 18
4.23
4.22
4.24
4.21
4.18
4.15
4.24
4.11
4.17
4.36
4.82
5.31

TABLE B-34
Loan losses and recoveries of National banks, 1945-70
[Dollar amounts in thousands]

Tear

Total loans end
of year, net

Ratio of net
losses or net
Net losses or
recoveries ( + ) recoveries ( + )
to loans

Year

Total loans end
of year, net

Net losses or
recoveries ( + )

$63,693,668
67,308,734
75,548,316
83,388,446
95,577,392
116,833,479
126,881,261
136,752,887
154,862,018
168,004,686
173,456,091

$130,177
112,412
97,617
121,724
125,684
189,826
240,880
279,257
257,280
303,357
601,734

Percent
.20
.17
.13
.15
.13
.16
.19
.20
.17
.18
.35

68,978,975

108,518

.16

Percent

1945
1946...
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959

+ $7,740
3,207
29,913
19,349
33,199
14,445
22,108
19,326
32,201
25,674
29,478
41,006
35,428
38,173
25,767

$13,948,042
17,309,767
21,480,457
23,818,513
23,928,293
29,277,480
32,423,777
36,119,673
37,944,146
39,827,678
43,559,726
48,248,332
50,502,277
52,796,224
59,961,989

+0.06
.02
.14
.08
.14
.05
.07
.05
.08
.06
.07
.08
.07
.07
.04

1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
Average for
1945-70...

Ratio of net
losses or net
recoveries ( + )
to loans

NOTE: For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Report of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 233.

TABLE B-35
Securities losses and recoveries of National banks, 1945-70
[Dollar amounts in thousands]

Year

Total securities
end of year,
net

Losses and
chargeoffs*

Ratio of net
losses to
securities

Year

Total securities
end of year,
net

Losses and
chargeoffs*

$43,852,194
49,093,539
51,705,503
52,601,949
54,366,781
57,309,892
57,667,429
69,656,371
76,871,528
70,216,983
84,157,505

$154,372
51,236
47,949
45,923
86,500
67,898
302,656
149,545
344,068
286,215
137,704

Percent
.30
.08
.08
.07
.15
.11
.52
.21
.44
.41
.16

51,364,796

130,597

.25

Percent

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959

$55,611,609
46,642,816
44,009,966
40,228,353
44,207,750
43,022,623
43,043,617
44,292,285
44,210,233
48,932,258
42,857,330
40,503,392
40,981,709
46,788,224
42,652,855

$74,627
74,620
69,785
55,369
23,595
26,825
57,546
76,524
119,124
49,469
152,858
238,997
151,152
67,455
483,526

0.04
.09
.10
.07
.04
.04
.12
.15
.25
.08
.32
.56
.35
.12
1.09

1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
Average for
1945-70...

Ratio of net
losses to
securities

NOTE : For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Report of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 234.




247

00

TABLE

B-36

Assets and liabilities of National banks, date of last report of condition, 1950-70
[Dollar amounts in thousands]

Tear

1950....
1951....
1952....
1953
1954
1955....
1956
1957....
1958....
1959....
1960
1961....
1962....
1963....
1964
1965
1966....
1967....
1968....
1969
1970....

Number
of banks

4,965
4,946
4,916
4,864
4,796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,505
4,615
4,773
4,815
4,799
4,758
4,716
4,669
4,621

Total assets*

$97,240,093
102,738,560
108,132,743
110,116,699
116,150,569
113,750,287
117,701,982
120,522,640
128,796,966
132,636,113
139,260,867
150,809,052
160,657,006
170,233,363
190,112,705
219,102,608
235,996,034
263,374,709
296,593,618
310,263,170
337,070,049

Cash and
due from
banks

Total
securities,
net

Loans, net

$23,813,435
26,012,158
26,399,403
26,545,518
25,721,897
25,763,440
27,082,497
26,865,134
26,864,820
27,464,245
28,674,506
31,078,445
29,683,580
28,634,500
34,065,854
36,880,248
41,689,580
46,633,658
50,952,691
54,727,953
56,040,460

$43,022,623
43,043,617
44,292,285
44,210,233
48,932,258
42,857,330
40,503,392
40,981,709
46,788,224
42,652,855
43,852,194
49,093,539
51,705,503
52,601,949
54,366,781
57,309,892
57,667,429
69,656,371
76,871,528
70,030,342
84,157,465

$29,277,480
32,423,777
36,119,673
37,944,146
39,827,678
43,559,726
48,248,332
50,502,277
52,796,224
59,961,989
63,693,668
67,308,734
75,548,316
83,388,446
95,577,392
116,833,479
127,453,846
136,752,887
154,862,018
168,004,686
173,455,791

Other assets

Total
deposits

Liabilities

for

Other
liabilities

Capital

$1,304,828
1,621,397
1,739,825
1,754,099
1,889,416
1,488,573
1,716,373
1,954,788
1,999,002
2,355,957
3,141,088
3,198,514
3,446,772
5,466,572
5,148,422
7,636,524
9,975,692
11,973,852
16,496,707
28,284,638
27,130,131

$2,001,650
2,105,345
2,224,852
2,301,757
2,485,844
2,472,624
2,638,108
2,806,213
2,951,279
3,169,742
3,342,850
3,577,244
3,757,646
4,029,243
4,789,943
6,089,792
6,299,133
6,602,519
7,008,482
7,347,948
7,680,597

borrowed
money

$1,126,555
1,259,008
1,321,382
1,416,802
1,668,736
1,569,791
1,867,761
2,173,520
2,347,698
2,557,024
3,040,499
3,328,334
3,719,607
5,608,468
6,102,678
8,078,989
9,185,179
10,331,793
13,907,381
17,500,189
23,416,333

$89,529,632
94,431,561
99,257,776
100,947,233
106,145,813
104,217,989
107,494,823
109,436,311
117,086,128
119,637,677
124,910,851
135,510,617
142,824,891
150,823,412
169,616,780
193,859,973
206,456,287
231,374,420
257,883,926
256,426,791
283,784,496

$76,644
15,484
75,921
14,851
11,098
107,796
18,654
38,324
43,035
340,362
110,590
224,615
1,635,593
395,201
299,308
172,087
1,015,147
296,821
689,087
2,283,717
1,280,365

Surplus
undivided
profits and
reserves

$4,327,339
4,564,773
4,884,369
5,107,759
5,618,398
5,463,305
5,834,024
6,278,004
6,717,522
7,132,375
7,755,488
8,298,062
8,992,104
9,518,935
10,258,252
11,334,232
12,159,775
13,127,097
14,515,416
15,906,249
17,194,460

NOTE: For earlier data, revised for certain years and made comparable to those in this table, references should be made as follows: years 1863 to 1913, inclusive,
Annual Report of the Comptroller of the Currency, 1913; figures 1914 to 1919, inclusive, report for 1936; figures 1920 to 1939, inclusive, report for 1939; and figures 1936 to
1949, inclusive, report for 1966.
*After deduction of securities and loan reserves.




TABLE

B-37

Foreign branches of National banks, by region and country, Dec. 31, 1970
Region and country

Number

Central America

44

El Salvador
Guatemala
Honduras
Mexico
Nicaragua
Panama

1
3
3
5
3
29

South America

139

Argentina
Bolivia
Brazil
Chile
Colombia
Ecuador
Guyana
Paraguay
Peru
Uruguay
Venezuela

38
5
18
17
26
12
1
6
8
4
4

West Indies (Caribbean)
Antigua
Bahamas
Barbados
Cuba
Dominican Republic
French West Indies
Grenada
Jamaica
Netherlands Antilles
Trinidad and Tobago
British Virgin Islands
West Indies Federation of States
Europe
Austria
Belgium
England
France
Germany
Greece
Ireland
Italy
Luxembourg
Netherlands
Northern Ireland
Switzerland




89
2
49
3
0
12
1
2
6
2
6
3
3
90
1
8
23
9
18
9
3
4
1
7
1
6

Region and country

Africa

Number

2

Liberia

2

Middle East

12

Bahrain
Israel
Lebanon
Qatar
Saudi Arabia
Trucial States
Asia and Pacific
Fiji Islands
Hong Kong
India
Indonesia
Japan
Korea
Malaysia
Okinawa
Pakistan
Philippines
Republic of China
Singapore
Thailand
Vietnam
U.S. overseas areas and trust territories
Panama (Canal Zone)
Caroline Islands
Guam
Marianas Islands
Marshall Islands
Puerto Rico
Virgin Islands
Total
Military banking facilities

78
1
13
11
6
12
3
5
2
4
4
2
11
2
2
43
2
1
3
1
1
19
16
497
31

249

TABLE

B-38

Total assets of foreign branches * of National banks, year-end 1953—70
[Dollar amounts in thousands]
1962
1953
$1,682,919
1954.
1,556,326
1963
1955.
1,116,003
1964
1956.
1,301,883
1965
1957.
1,342,616
1966
1958.
1,405,020
1967
1959.
1,543,985
1968
1960.
1,628,510
1969
1961
1,780,926
1970
*Includes military facilities operated abroad by National banks in 1966 and thereafter.

TABLE

$2,008,478
2,678,717
3,319,879
7,241,068
9,364,278
11,856,316
16,021,617
28,217,139
38,877,627

B-39

Foreign branches of National banks, 1960-70

End of year

National bank
Number of branches branches as a percentage of total
operated by
foreign branches of
National banks
U.S. banks

1960
1961
1962
1963
1964

93
102
111
124
138

75.0
75.6
76.6
77.5
76.7

National bank
Number of branches branches as a peroperated by
centage of total
National banks
foreign branches of
U.S. banks

End of year

1965
1966 .
1967
1968
1969
1970

. .
. .

196
230
278
355
428
497

93.5
94.3
95.5
95.0
93.0
92.7

TABLE

Assets and liabilities of foreign branches* of National banks, Dec. 31, 1970: consolidated statement
Gash and cash items
Due from banks (time and demand)
Securities
Loans, discounts and overdrafts
Customers' liability on acceptances
Fixed assets
Other assets
Due from head office and branches (gross)
Total

[Dollar amounts
266,931
8,852,471
565,116
15,057,401
1,217,900
126,228
531,526
12,260,054
38,877,627

in thousands]
Total demand deposits
Total time deposits
U.S. Government deposits
Certified checks, officers' checks, official checks.
Total deposits
Other liabilities and borrowed funds
Liabilities on acceptances
Due to head office and branches (gross, including
capital)
Total

"Includes military facilities.

250




3,448,280
24,765,018
236,166
99,813

28,549,277
890,927
1,221,091
8,216,332
38,877,627

TABLE

B-41

Trust assets * and income of National banks, by States, calendar 1970
[Dollar amounts in millions]

Number
of banks

United States

Employee
benefit
accounts^

Other
trust
accounts%

Total
trust
accounts

Agency
accounts §

Total,
trust and
agency
accounts

Trust
department
income
{Dollar amounts
in thousands)

1,696

45,254

74,441

119,695

30,609

150,305

629,817

30
4
2
31
16
29
11
1
6

240
27
54
29
4,592
296
316
0
312

795
15
530
212
7,778
1,118
1,490
0
1,137

1,035
42
584
241
12,370
1,414
1,806
0
1,449

144
31
38
17
1,572
305
791
0
989

1,179
74
622
258
13,942
1,719
2,596
0
2,438

5,238
232
4,388
1,279
76,872
11,270
10,768
0
8,963

86
27
0
2
162
96
46
48
53
20
16

307
382
0
26
6,365
400
82
53
43
153
29

2,971
1,120
0
57
6,011
2,196
432
418
311
237
230

3,278
1,502
0
83
12,376
2,596
514
471
354
390
259

458
1,217
0
40
3,857
787
246
117
150
83
85

3,737
2,719
0
123
16,233
3,384
760
588
503
474
344

17,063
10,066
0
500
62,791
12,294
3,346
2,791
2,153
2,578
1,679

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

11
55
38
21
19
35
12
19
3
19

123
1,588
3,938
895
46
679
5
147
6

582
2,327
2,505
1,685
185
2,296
45
493
268
131

705
3,915
6,443
2,580
231
2,975
50
640
274
139

213
992
1,262
744
8
1,005
13
172
24
69

919
4,906
7,705
3,324
239
3,981
63
812
298
208

3,663
39,240
20,600
14,325
1,365
13,256
346
4,271
1,529
806

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

76
18
78
16
11
60
40
2
131
3

286
18
13,226
857
16
1,570
198
229
4,609
224

1,625
213
8,188
1,676
83
3,890
770
658
8,615
1,116

1,911
231
21,414
2,533
99
5,460
968
887
13,224
1,340

676
34
6,102
533
15
988
313
98
2,820
373

2,587
265
27,516
3,066
115
6,448
1,281
984
16,045
1,713

15,885
1,250
106,735
11,277
668
21,334
5,452
5,651
47,804
7,413

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

8
10
32
139
2
10
47
10
33
38
14

128
23
170
1,710
75
3
197
314
20
236
4

379
85
1,180
3,847
162
43
1,201
1,321
304
1,458
51

507
108
1,350
5,557
237
46
1,398
1,635
324
1,694
55

92
35
553
1,151
16
12
698
251
30
368
24

599
143
1,903
6,708
253
58
2,095
1,886
355
2,062
79

2,276
775
7,358
33,136
1,159
363
9,182
10,252
1,711
6,139
314

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

*As of December 31, 1970.
fEmployee benefit accounts include all accounts for which the bank acts as trustee, regardless of whether investments are
partially, or wholly, directed by others. Insured plans or portions of plans funded by insurance are omitted, as are employee benefit accounts held as agent.
{Includes all accounts, except employee benefit accounts and corporate accounts, for which the bank acts in the following, or
similar capacities: Trustee (regardless of whether investments are directed by others), executor, administrator, guardian; omits all
agency accounts and accounts for which the bank acts as registrar of stock and bonds, assignee, receiver, safekeeping agent, custodian, escrow agent, or similar capacities.
§Includes both managing agency and advisory agency accounts.
| [Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of
the Currency.
NOTE: Data may not add to totals because of rounding.




251

APPENDIX G

Addresses and Selected Congressional Testimony of
the Comptroller of the Currency




Addresses and Selected Congressional Testimony
Date and Topic
May 15, 1970, Statement of William B. Camp, Comptroller of the Currency, before the Senate Banking and Currency Committee, on One-bank Holding Company Legislation
Oct. 12 1970, Remarks of William B. Camp, Comptroller of the Currency, before the National Bank Division of the
American Bankers Association, Miami Beach, Fla
Mar. 18, 1970, Remarks of David C. Motter, Deputy Comptroller of the Currency (Economics), before the Montgomery County Bankers Association, Montgomery County, Md
July 22, 1970, Remarks of Dean E. Miller, Deputy Comptroller for Trusts, before the American Bankers Association
Fiduciary Responsibility Seminar, Washington, D.C
Nov. 19, 1970, Remarks of Dean E. Miller, Deputy Comptroller for Trusts, before the Mid Continent Trust Conference of the American Bankers Association, Chicago, 111

254




Page
255
257

261
264
267

STATEMENT BY WILLIAM B. CAMP, COMPTROLLER OF THE CURRENCY,
BEFORE THE SENATE BANKING AND CURRENCY COMMITTEE,
ON ONE-BANK HOLDING COMPANY LEGISLATION, MAY 15, 1970

I would like to discuss with you this morning
two topics relating to the bills under study by
this Committee: first, the so-called "laundry list"
approach, which is of crucial importance to the
banking industry and, I believe, to the whole
economy; second, the allocation of agency responsibility under the legislation passed, a matter of
considerable importance for our Office.
H.R. 6778 includes a "laundry list" of activities
which would be prohibited for subsidiaries of
holding companies controlling one or more banks.
We must note, however, that although this bill,
and the other bills before this Committee on the
same topic, purport to relate only to bank holding companies, their supporters are really attempting to define and delineate the business of banking. It was stated on the floor of the House that
a broadly-based organizational form with a variety
of subsidiaries, including a bank, would not be
barred from a particular line of endeavor if a
bank itself could carry out this same activity.
The fact that we are dealing with the delineation of the allowable activities for the banking
industry is, in my view, very crucial as we search
for that governmental policy which will be most
consistent with the public interest. It is unfortunate, I believe, that the public discussion of
H.R. 6778, and the other bills before this Committee, has been almost entirely in terms of holding companies and their activities, rather than
in terms of banks and their activities. In the public
mind, holding companies tend to be thought of
as something far removed from day-to-day experience and, often perhaps, as a phenomenon associated with financial manipulation and financial
legerdemain. On the other hand, virtually everyone
has had considerable day-to-day contact with
banks.
It may be useful for us to examine briefly the
recent history of banking leading up to the formation of a number of bank-centered one-bank holding companies. Our Office, during the decade of the




1960's, was in the forefront in the examination and
re-examination of existing banking regulations in a
painstaking effort to determine whether each regulation was still serving a useful purpose. Many
regulations were carryovers from the financiallytroubled era of the early 1930's. Many financial
markets today are so different from their counterparts of that time, that the connection between
them is little more than historical. The degree of
sophistication required to meet many of the financial needs of our complex and dynamic economy is
so great that the institutions and markets as constituted in the thirties could simply not perform
adequately today. Yet, the framework of regulation
created at that time was, in general, still being
applied at the beginning of this decade.
Our process of examining the current validity of
banking regulations, therefore, exposed a number
of cases in which regulations not required by current statute could be eliminated, and others could
be modified, within the statutory framework. As a
result, over time, National banks were able to
operate in a regulatory climate which provided a
greater, and healthier, degree of discretion to bank
management.
In part due to the elimination of regulatory restrictions just described, and in part due to the
advent of a more innovative spirit within bank
management itself, banks began to expand their
offering of certain financial services, and began to
offer some new ones. The public was the immediate
beneficiary because the expansion of bank activity
provided the benefits of additional competition.
However, when competition increases there can be
no guarantee that individual competitors will not
be subjected to greater pressures. In fact, in competitive markets it is generally understood that the
public benefits of competition do not come painlessly, from the standpoint of the competitors.
One result, and a quite proper one under our
system, was the filing of lawsuits by firms in a number of functional areas. Each felt itself damaged by
255

the added competition generated by commercial
banks. It is interesting to note the arguments advanced by the plaintiffs in these suits. Rarely, if at
all, was it claimed that the public interest was being
harmed by the provision of the particular services
by commercial banks. Rather, the suits rested on
the quite narrow issue of whether National banks,
under their charters, had the right to provide the
services in question.
It is important to emphasize that there have been
no complaints about those bank activities by the
general public, or by the consumers, at any level,
of the services in question. On the other hand, it
is difficult to conceive of a more anticompetitive
thrust than that contained in, as an example, the
suit brought by the association of data processing
companies. Very simply, that association charged
that banks simply had no right to provide data
processing services to their customers, despite the
fact that banking is essentially a data processing
activity, whether that processing is done by a gentleman with a green eye shade, sitting on a high stool,
or by the latest computer system. It was natural for
banking, given its need for a variety of voluminous
record-keeping operations, to become heavily involved in data processing as we know it today, aided
by the most sophisticated computer systems which
man has been able to devise.
What has all this to do with the immediate issue
before the Committee? Commercial banks, tiring of
continual harrassment from litigation brought by a
variety of non-bank competitors, attempted to devise an organizational form which might have immunity from such suits. The device of creating a
parent holding company, under whose corporate
umbrella a number of the bank operations could be
spun-off as holding company subsidiaries, seemed to
provide a possible answer. In the period from mid1968 through April 30, 1970, 75 National banks
took the steps necessary to reorganize their corporate structure in the form of a so-called one-bank
holding company.
When we examine the subsidiaries of these holding companies, we find that the vast majority of
them were capitalized by the parent as new enterprises, or as corporations to absorb operations spunoff from the bank. Acquisitions of existing enterprises are much fewer in number, and have typically involved relatively small firms. As you know,
this Office, in approving the steps necessary to
create a parent holding company, applies a proviso
which requires approval by this Office for any addi-




tional subsidiaries of the holding company, whether
acquired, or newly established. We have restricted
such subsidiary operations to the financial sector,
and to activities that we considered properly related
to the functioning of a bank-centered financial
organization.
I offer this brief history of some of the relevant
events leading up to the one-bank holding company controversy in the hope that it may allow a
somewhat better understanding of the essential issues. I repeat that we should not forget that the
legislation under discussion involves an attempt to
define and delineate the activities which banking
organizations will be allowed to perform. It is conceivable that a more constructive public discussion
would have occurred had the issue been put in that
fashion, rather than being related constantly to a
holding company superstructure.
If this Committee, and later, the Senate, decides
to place one-bank holding companies under the
same regulation as multi-bank holding companies,
it is my earnest hope that the legislation will not include a so-called "laundry list" of prohibited activities, like that contained in H.R. 6778. For that
matter, a positive "laundry list" would be almost as
unhealthy. Imagine the listing of "proper" banking activities which might have been drawn up in
1950, or even in 1960. The list that any knowledgeable observer would draw today would differ considerably from a comparable list of a decade ago.
That is simply to say that in a dynamic, growing,
complex economy such as ours, financial institutions, including commercial banks, must be free to
respond to financial needs as they occur. Those
needs can not be predicted very far in advance, and
they change materially over periods of time. T o
place commercial banking in a statutory straight
jacket would be, in my view, an action decidedly
against the public interest.
Insofar as existing statutes have allowed it, our
Office has permitted banks to engage in any financial activity which will not endanger the liquidity
or solvency of the bank in question, or the banking
system, and which appears to be consistent with the
public interest, taking proper account of the competitive impact. Our preference would be for a
statutory test along those lines, to determine the
activities in which banks and bank holding companies may engage.
Before leaving the topic of the definition of the
banking business, I would like to read from my
letter in the 1969 record of the House hearings. I

believe the letter is consistent with the views which
I have just stated, and it further provides some relevant quotations from various court decisions.
This quotation deals with an interpretation of
the meaning of the "incidental powers" provision
found in the New York Free Banking Act of 1837.
This provision was very similar to the incidental
powers clause of the National Bank Act, 12 U.S.C.
24 (7). In construing this section of the New York
Act in 1857, the New York Court of Appeals held,
in Curtis v. Leavitt, 15 N. Y. 9, that the implied
powers of a bank
are not enumerated and defined; because no
human sagacity can foresee what implied powers
may, in the progress of time, the discovery and
perfection of better methods of business, and the
ever varying attitude of human relations, be required to give effect to the expressed powers.
They are therefore left to implication.
Now, may I briefly turn to a topic which falls
under the general category of administrative housekeeping. Under any one of the bills before the
Committee, responsibility for administering the
terms of the legislation will be given to one or more
agencies. As Administrator of National Banks, my
Office has more than a passing interest in this decision. As long as the tripartite division of Federal
regulatory powers over banking continues, my preference would be that the respective Federal agencies
be made responsible for regulating those holding
companies controlling their respective banks. That
is, our Office would be responsible for regulating
those one-bank holding companies having National
banks as subsidiaries, the Federal Reserve would
regulate those having State member banks as subsidiaries, and the Federal Deposit Insurance Corporation would be responsible for those companies
having State non-member banks as subsidiaries.
This would not require any change from the existing allocation of responsibility for regulation of
multi-bank holding companies to the Federal
Reserve.
Let me point out that there is a very meaningful
distinction between the appropriate regulation of a
multi-bank holding company and a one-bank holding company. We have had no problems in continuing to supervise the National banks in a multibank holding company system although the Federal
Reserve has had regulatory powers over the parent
company. For example, a particular system might




include 10 National banks, 5 State member banks,
and 5 State non-member banks. Each of the three
Federal agencies would exert its appropriate regulatory and supervisory authority over the subsidiary
banks. However, in the case of bank-centered onebank holding companies, the bank subsidiaries are
by far the most important subsidiary of the parent
company. In one case, for example, the subsidiary
bank has $22.8 billion in assets, while the parent
holding company has $23.1 billion, only about 1
percent more. It is abundantly clear that to place
the parent holding company in this situation under
the Federal Reserve, and to keep the subsidiary
bank under our supervision, would effect a substantial shift in regulatory powers. Further, we
should not ignore the substantial degree of regulatory duplication and overlap that would be created.
The President's Commission on Financial Institutions should, and undoubtedly will, explore
fully the structure of bank regulation, and undoubtedly will make appropriate recommendations.
It would appear that, with the Commission now
being constituted, major restructuring of bank
regulation should await the findings of the Commission. As I have indicated, the placement of the
regulatory powers in question in the hands of any
one agency would result in a substantial shift in
bank regulatory structure. Therefore, I am hopeful that the Congressional verdict will be to retain
the tripartite responsibility for the time being.
REMARKS OF WILLIAM B. CAMP,
COMPTROLLER OF THE CURRENCY,
BEFORE THE NATIONAL BANK DIVISION OF THE
AMERICAN BANKERS ASSOCIATION
MIAMI BEACH FLA., OCT. 12, 1970

It is a real pleasure, indeed, a signal honor, to
again be invited to address the National Bank
Division of the American Bankers Association at
this convention.
As some of you may know, I was a National
Bank Examiner for more than 20 years, and while
I have been received by different people in different
ways in different sets of circumstances, I can
honestly say that some of the happiest days of my
life have been spent while directly engaged in the
bank examination process. Some people, however,
do not hold examiners in the highest esteem. For
example, Elbert Hubbard wrote:
257

The typical bank examiner is a man past middle age, spare, wrinkled, intelligent, cold, passive,
non-committal, with eyes like a codfish, polite in
contact, but at the same time unresponsive, cold,
calm and damnably composed as a concrete post
or a plaster of paris cast; a human petrification
with a heart of feldspar and without charm of
a friendly germ, minus bowels, passion or a sense
of humor.
Happily, they never reproduce and all of them
finally go to Hell.
I should also point out that the Comptroller is
often subject to criticism. Many years ago Mark
Twain wrote:
Nothing in this world is palled in such impenetrable obscurity as a U.S. Treasury Comptroller's
understanding. The very fires of the hereafter
could get up nothing more than a fitful glimmer
in it.
As I have indicated, bank examiners are not always the most popular visitors wherever they go.
Bank regulatory authorities, themselves, are being
examined disapprovingly in some quarters. Banks
and bankers are being criticized from all sides,
often for things they don't do as much as for things
they do.
Not long ago, a senior Congressman, whom I
shall not name, although I am sure you all know
who he is because he is the one who picks on you
the most, must have had a slow day. The only
criticism of the banking industry he could find that
day was that bank-controlled small business investment corporations had received too many Small
Business Administration loans last year. The
amount that he considered disproportionate was
about two-sevenths of the $70,000,000 loaned by the
agency last year. Mr. Hilary Sandoval, the Administrator of the Small Business Administration, when
informed of the Congressman's criticism, made a
remark with which I don't think anyone could disagree. Mr. Sandoval said: "Banks, whether anyone
likes them or not, I imagine are here to stay, for
they are part of America." The Journal of Commerce, in an editorial, said that Mr. Sandoval's
reply indicated that Mr. Sandoval "knows on what
burner one should cook the goulash/'
I am here today to underscore Mr. Sandoval's
belief that banks are here to stay, and I, for one,
am glad of it. The fact remains that this industry,
notwithstanding all the competitive, political, legal,
and, lately, even physical attacks to which it has
258




been subjected, has performed and is continuing to
perform outstanding service to our great Nation,
and, indeed to the world at large. Bank participation in the Small Business Administration program,
far from calling for criticism, is one of the more
obvious aspects of that contribution.
It is extremely difficult for me to understand
how those who proclaim themselves as staunch
defenders of the people against vested interests can
so vigorously oppose any effort by banks to compete
with other financial institutions in order to improve public services, reduce costs to customers, and
achieve greater efficiencies in their operations.
Other critics, with different points of view, contend that the banks are not doing enough, particularly in the broad field of social reform. These
critics want to see banks compelled to make preferential loans to particular classes of borrowers, regardless of the collateral pledged or the business
judgment of the debtor. Some of them want to see
banks loans channeled to one industry in preference to others. Some want bank credit concentrated
behind activities they deem most important, without attaching much significance to a balance of
priorities among contending applicants. Still others
contend that banks should be restrained from lending to certain industries because of objections to
the products they manufacture.
The most radical and revolutionary critics of
banking are not content with merely making demands; they seem to be unwilling or unable to
press their demands with reasoned arguments, or
to justify them with persuasive facts. They prefer,
instead, to register their discontent with bombs or
bombing threats, with arson of bank buildings, or
with destruction of bank records and facilities by
angry mobs.
A speech was made on the floor of the Senate
some time ago by a member who was dismayed at
the turn of events he had seen. He declared:
. . . There are persons who constantly clamor.
They complain of oppression, speculation, and
pernicious influence of wealth. They cry out
loudly against all banks and corporations, and
a means by which small capitalists become united
in order to produce important and beneficial results. They carry on mad hostility against all
established institutions. They would choke the
fountain of industry and dry all streams . . . .
The speech went on at some length, but what
I have quoted is enough to show the general nature

of the remarks of Senator Daniel Webster to his
colleagues on March 12, 1838.
Even today's less violent bank critics, I suspect,
seldom stop to think that whatever the banks are
doing, they're doing with other people's money;
the loans that banks make and the risks that they
assume are accomplished with the savings entrusted
to their care, accepted with the promise that interest and dividends will be earned and paid to
their depositors and shareholders. I often wonder
if some of the more liberal critics of banking would
be willing to invest their own savings in all the
ways they urge the banks to invest the savings of
others.
Fortunately, good bankers are level-headed
enough not to panic under attack. They know
from long experience, in times less troublesome
than these, that a lender is usually regarded as a
benefactor when a needed loan is made and all
too often is considered an ogre when the loan
comes due.
Good bankers have a sense of self-discipline that
is strong enough to help them make firm distinctions between the desirable and the possible. At
the same time, they have a deep concern for the
well-being of their customers and their communities which leads them to make sound loans for any
good purpose. Good bankers are alert to opportunities to expand and improve their financial services
in order to meet any of their customers' valid demands that do not threaten the solvency and liquidity of the bank, itself.
There is certainly a strong element of self-interest in this approach to banking, for the wise banker
knows that his institution can prosper only through
the sound growth of the community he serves. In
turn, as is true in any service industry, he knows
that his bank can attract customers and depositors
only when it earns their confidence and supplies
their worthwhile needs.
Banking has been alert to find new ways to meet
those needs. Under the encouragement of more
far-sighted regulatory policies, the banking industry
has, in recent years, responded enthusiastically to
the abundant prospects for broadened service.
Banks have sought to enlarge their resources by
introducing or expanding the use of certificates of
deposit, capital debentures, preferred stock, and
promissory notes—and thus, they have completed
more actively and more effectively for savings in
their communities. They have begun to apply the
new technology to their own operations, although,




as always in such periods of transition, there have
been problems of adaptation and questions of the
suitability of techniques. To carry out these growing endeavors, banks have been strengthening their
staffs through the recruitment of greater numbers
of highly trained and able young men and women.
This new vitality has found expression in the
more active pursuit of new markets and functions.
Consumer loan and mortgage markets, long neglected, have become the focus of increased attention. Credit cards, check guarantees, and overdraft
facilities have made banking facilities more convenient for a broader range of consumers. Growing
expenditures for travel have elicited expanded
traveler's check and related services; and the expert
investment-management capabilities of banks have
been brought within the reach of many of the growing number of small investors.
Industrial and commercial enterprises have also
found banks more responsive to their needs. Leasing and factoring activities have grown more common. Foreign trade financing has attracted the
efforts of larger numbers of banks. The computerization of operations has enabled banks to offer
excess capacity to others, and to expand their performance of payroll and accounting functions for
customers. Larger staffs of expert personnel have
permitted banks to broaden their advisory services,
both to business and individuals. And, through the
underwriting of revenue bonds and community
development loans, their aid to local governments
has been enlarged.
There are many additional illustrations of the
new functions that banks have been undertaking,
and the list will grow larger still. Some competing
groups have complained to Congress and to the
courts that the list is already too large, and that
banks should be stopped, by law, from expanding
their functions. As a result of research for a Congressional inquiry, I was quite fascinated to find
that, in 1870, there was a law suit in which one
bank challenged another on the legality of bank
certification of checks. The suit was before the
United States Supreme Court. In the case the Court
was asked to define what the proper powers of a
bank should be. The Court said, in part:
The practice of certifying checks has grown out
of the business needs of the country. Customs
have sprung from the necessities and the convenience of business and prevailed in duration
and extent until they acquired the force of law.
This mass of our jurisprudence has thus grown,
259

and will continue to grow, by successive accretions.
In a decision of the New York Court of Appeals,
in 1857, the court was asked to define the implied
powers clause of the New York Free Banking Act.
The New York Court of Appeals, in language
which I consider more classical than the Supreme
Court language of one hundred years ago, stated:
The implied powers of a bank are not enumerated and defined; because no human sagacity
can foresee what implied powers may, in the
progress of time, the discovery and perfection of
better methods of business, and the ever varying
attitude of human relations, be required to give
effect to the expressed powers. They are therefore left to implication.
I think these two court decisions are the best
answers that I have ever seen to the suggestions
that the list of activties in which banks are presently engaged is already too large.
Today, in our cities, in our universities, in our
economic affairs—both domestic and international
—we face mounting challenges to our cherished
principles of personal freedom and individual initiative. The viability of these principles rests upon
our capacity to demonstrate that they can be made
to work in serving today's needs as well as those of
the future.
I am not one to despair at the • rospect of solving
the huge problems which seem to be closing in on
us today. One would have to be foolish indeed to
minimize the problems of ecology, race, inflation,
violence, crime, the generation gap, and the rest
of the seemingly endless list of horrors presented to
us every day in our morning newspaper. I do
not despair of our being able to successfully meet
and resolve those problems for the simple reason
that we have already overcome many problems
which at the time seemed just as formidable.
When we look back over the last five decades,
1919 to 1969, we find that our life expectancy has
been increased by approximately 50 percent. We
find the working day decreased by a third at the
same time that per capita output more than doubled.
We find a people who no longer have to fear the
epidemics of flu, typhus, diphtheria, smallpox,
scarlet fever, measles, or mumps that they knew in
their childhood. Once dreaded TB is almost unheard of and, just in the last 10 years, the great
maimer, polio, has been conquered.
260




We find a generation that, having lived through
history's greatest depression, determined that it
would not happen to its children and that, according to virtually all of our most learned economists,
has succeeded in that determination.
We find a new generation of children who, despite the apparent efforts of some of them to hide
it, are the tallest, healthiest, brightest, and probably
best-looking generation to inhabit the land. These
children will work fewer hours, learn more, have
more leisure time, travel to more distant places,
and have more of a chance to follow their life's
ambition than any generation ever has.
I do not doubt that a nation that has done all
those things, in such a short period of time, can
accomplish the great tasks remaining undone, finding alternatives for war, for racial hatred, for pollution of the environment, and for inflation.
The banking industry stands at the center of
these crucial struggles. It is in a unique position to
exercise leadership for its spirit and its attitudes
color the outlook, the sentiment, and the posture of
men and women of enterprise throughout the
country. An energetic, far-seeing, and responsive
banking system can do much to assure that our
great wealth of resources and the unbounded capabilities of our people are put to work fully and
effectively in the realization of our national aims.
I believe, therefore, that we must continue to
work for the full realization of the great potential
of the banking industry. Our aim should be to
fashion and sustain a banking system that responds
swiftly to new demands and opportunities, that
alertly applies new techniques to enhance proficiency of operations, and that persistently searches
for new functions that can be performed safely and
prudently. In the process, I believe that growth in
size of units, through effective combination of complementary functions, is a necessary corollary to
growth in service capacity.
These goals are fully consonant with the best
traditions of our private free enterprise system.
Nothing less will allow our banking system to fulfill its essential role in the Nation's future. Remarkable as our past has been, I am confident that
we are entering a new era of achievement in banking service that will far outdistance any other accomplishment we have known.
The ferment we find today in the field of banking is the outcome of a re-birth of enterprise in an
industry long accustomed to protection against

this vital force in our economy. Some portray these
developments as a growth of governmental power,
but, in truth, they reflect a relaxation of governmental power over the exercise of initiative by
privately-owned enterprises.
Our commercial banks lie at the heart of our
financial system, and the capability of our financial
system critically affects the progress of our entire
economy. A banking system alert to its positive responsibilities, and equipped to carry out those responsibilities, is thus indispensable to the success of
our private enterprise system. This objective can
be achieved only by allowing the forces of individual initiative to be expressed more fully and more
actively in this industry.
The present advanced level of our economic development was not achieved by preserving the status
quo. Those of you who have lived and worked in
the world of industry and commerce are intimately
aware of the vitality that private initiative imparts
to our economy. Our past achievements, under
the influence of that initiative, are well known to
us all. Ahead lie vistas which none of us today can
fully realize. The strength of our productive power,
the skills of our new generation of young men and
women, the rate of our technological progress are
all at levels unmatched in our past experience. We
stand poised for new achievements beyond our
imagination. It will not take another 75 years to
attain the advances we have achieved in the past 75.
To meet the needs of our great Nation, indeed,
the needs of the world at large, we will require a
banking system free to employ its innovative capabilities, its ingenuity, and its vast skills most efficiently in furthering the progress of the world.
Working together, I am certain that we can reach
this compelling objective so acutely important to
our Nation's future.
In closing, I wish to assure you that our Office
will continue to be responsive to the efforts of our
banks to serve the ever-growing needs of their customers, their communities, and our Nation as a
whole.
REMARKS OF DAVID C. MOTTER,
DEPUTY COMPTROLLER OF THE CURRENCY
(ECONOMICS) , BEFORE THE
MONTGOMERY COUNTY BANKERS ASSOCIATION
MONTGOMERY COUNTY, MD., MAR. 18, 1970

I would like to bring you some thoughts tonight
concerning two not unrelated topics: first, the




proper role of banking in our complex, dynamic
economy and, second, the shorter-run problems
posed for banking by its involuntary, but inescapable, role in the transmission of monetary policy's
impact to the economy.
The "proper" role for banking, the delineation of
banking's product and service mix, remains, after a
decade of discussion and controversy, the most
crucial question for the future of the industry. Conflicting forces have been contending for their points
of view before courts, Congress, and various governmental agencies, including the banking agencies.
Among the banking agencies themselves, considerable differences in points of view have existed at
various times.
In our Office we are proud that the policies and
rulings of the Comptroller of the Currency have,
we believe, fostered and encouraged an innovative
spirit and attitude in the banking industry. It is
clear that banking in 1970 is significantly different
from banking in 1960. In fact, the differences are
sufficiently great that one may make a case for the
view that they do not represent differences in degree but rather differences in kind.
I will not take time to indicate the long line of
actions by the Comptroller of the Currency which
provided significant support to bank innovation
during the 1960's. Let it suffice to note only a few
of those actions. The image of a closed structure
for the National Banking System was dispelled. Significant increases in the number of banking offices
available to provide for the banking needs of the
public occurred. We think that the combination
of branching, charter, and merger policies of the
Comptroller during the past 10 years, has had a
profoundly favorable effect upon the ability of National banks to meet the diverse and complex financial needs of our economy.
One area of great expansion for U.S. banking has
been that of international banking. From a total of
85 offices operated abroad by National banks in
1960, the figure reached 428 at the end of 1969, an
increase of 369 percent. Of all offices operated
abroad by U.S. commercial banks at the end of
1968, 95 percent were operated by National banks,
and the percentage was similar a year later. Total
assets of foreign branches of National banks spurted
tenfold, from $1.6 billion, in 1960, to $16.0 billion,
by the end of 1968. Our Office holds the view that
expansion into foreign markets by those National
banks with sufficient resources and expertise to allow them to perform properly is in the best interest

of the banks themselves, of the United States, and
of the foreign countries concerned.
The offering of certain services by commercial
banks has been initiated, and the offering of others
has grown considerably in importance. Those services include direct lease financing, the sale of data
processsing services to bank customers, travel services, the offering of credit-related insurance services, the underwriting of securities issued by various
governmental entities, and the provision of additional trust-related activities.
You will note that National banks and the Comptroller of the Currency have been involved in litigation in connection with most of the above-named
services. It is, of course, of prime relevance to ask
who has instigated those suits. In no instance have
consumers, or groups of consumers, of the services
brought court action. Quite the contrary. By and
large the consumers of those and other expanded
banking services have benefited from the additional
competition which resulted from the enlarged role
of commercial banks in those various markets.
The suits in question have, without exception,
been brought by competitors of commercial banks,
competitors who opposed the additional competitive pressures imposed upon them by bank activity.
It is interesting to read the briefs filed by litigants
in such cases. It is rare to find, even in a plaintiff's
brief, a charge that the broad public interest has
been harmed by the banks' provision of the services
in question. Commonly, the litigants have rested
their cases primarily on the view that National
banks do not have the power to offer such services.
We should note that the ruling on March 2 by
the Supreme Court virtually confers "standing" to
any group of bank competitors desiring to block, by
court action, the performance of specific activities
by commercial banks. This means that, in the cases
in question, courts will hold at the outset that the
plaintiffs have the right to sue commercial banks for
engaging in particular activities. Then, of course,
the court inquiry will be directed to the merits of
the issue. We have to hope that, in this exploration
of the merits, the prime question will be the ultimate effect on the public interest.
The question of the appropriate regulation of
one-bank holding companies is tied very closely to
the question of the proper activities of banks and
bank affiliates. The litigation mentioned above
was certainly a major factor in leading many bank
officials to consider favorably the establishment of
parent one-bank holding companies. It was thought
262




by some observers that the creation of a parent
holding company would allow certain activities to
be carried on by a banking organization without
the threat of harassment in the form of litigation
brought by bank competitors. I am sure that you
are all aware of the House of Representatives' consideration of the one-bank holding company issue
in 1969, and the provisions of the bill finally passed
by that body.
It should be noted that in the discussions in the
House and the forthcoming deliberations in the
Senate on the one-bank holding company bill
vitally affect all commercial banks, not just those
that have formed, or are contemplating the formation of, a parent holding company. That is because
it is quite clear that if legislation prohibits a broad
holding company organization from engaging in a
particular activity, that activity will almost certainly be barred for an individual bank. Therefore,
any prohibitions that find their way into the final
act passed by Congress in that area will effectively
apply to all commercial banks.
The Administration has taken a well-reasoned
position on the one-bank holding company issue.
There is proper concern that the boundary lines
between banking and industry remain unblurred.
In point of fact, of course, the efforts to blur this
line have not come from the banking side, but have
come from takeovers, or attempts to takeover, banks
by non-financial corporations. The Administration
proposals and the bill that was passed by the House
Banking Committee avoided the creation of specific
"laundry lists", that is, lists of activities that would
be prohibited for commercial banks and their
affiliates.
The wisdom of that stance is obvious if we think
of the recent history of our financial institutions
and markets. Imagine a "laundry list" of prohibited activities that might have been drawn up in
1960. Or even more dramatic, imagine the list of
acceptable activities for banking that might have
been drafted at the same time. A number of important current banking activities would almost certainly not have appeared on the latter list.
The lesson is obvious. The financial needs of our
economy are so complex, and the demands upon
our banking system are so dynamic in their nature,
that one cannot possibly foresee the evolution of
banking services and products over time. Yet, under
the "laundry list" approach, if specific activities are
barred for commercial banks and their affiliates at
this time, one can well imagine the difficulty of

securing a statutory change, reversing such a prohibition, in the face of strong opposition by affected
competitors of banks.
The bill that the House Banking Committee approved was altered so drastically on the floor of the
House that it bears little resemblance to the Committee product. The "laundry list" approach was
incorporated in the House-passed bill. The Senate
Banking Committee has not yet set a date for hearings on this legislation.
One possible benefit for the banking industry in
the widespread discussion of one-bank holding companies is that the attention of a number of very
able people has been, and will be, directed to the
question of the proper role of the banking system.
You, perhaps, have read the article, by Professor
Henry Wallich, entitled "Banks Need More Freedom to Compete", that appeared in the March 1970
issue of Fortune Magazine. If you have not read it,
I believe you will find it to be a stimulating article.
I say this without meaning to imply that I necessarily endorse the positions taken in the article.
Professor Wallich's major point is that if statutes
and regulations consistently impede the performance of new functions by banks the outcome may
well be to place the banking system "in danger of
going the way of the railroads". He recommends a
very considerable increase in the flexibility of the
scope of banking operations. In fact, the path he
envisions could well lead to a financial system quite
different from that which we currently have. Undoubtedly the most controversial of Wallich's
views, from the standpoint of the banking industry,
is his position that banks can defend the right of
flexibility in their own product and service mix
only if the barriers to provision of unique banking
functions by other institutions are lowered.
Now, we come to my second topic: banking's
problems posed by being a transmission belt for
monetary policy. Commercial banks are in a
unique, and unenviable, position, in that the initial
brunt of monetary policies must be carried out
through the banking system. However, one may
properly distinguish between the two principal
weapons used by the monetary authority in recent
years. By far the most basic is the control over the
total money supply and the total monetary base,
exerted by the monetary authority primarily
through its open-market operations. Within some
ranges, the monetary authority, over any period of
a few months, is able to control rather directly the
growth in the money supply. That control is ad-




mittedly a very powerful weapon in influencing the
overall level of economic activity, although controversy continues between so-called "monetarists"
and "fiscalists" as to the force and timing of that
influence.
The banking system is in the front line, so to
speak, in the transmission of the effects of overall
monetary policy to the economy. That transmission
mechanism functions through the general availability, or non-availability, of loanable funds in the
banking system, and through the pricing device of
rates of interest. The recent past shows again that
the banking industry tends to be blamed for high
interest rates, even when those rates are a direct
result of the monetary policy prescribed by the
monetary authorities.
The banking industry cannot duck its responsibility for transmitting the effects of monetary
policy. However, a second weapon of monetary
policy in recent years has been Regulation Q, imposing ceiling rates on time and savings deposits of
commercial banks. Those ceiling rates were well
below market rates for comparable savings instruments for many months. Even the January 1970
increases in ceilings are still somewhat below prevailing rates. The runoff of large CD's from over
$24 billion to less than $11 billion in a little over a
year, provides an excellent illustration of the fact
that a money market instrument which is subject
to below market ceilings cannot long compete with
other money market instruments not subject to
ceilings.
There is a responsible school of thought which
holds that the use of regulations that divert funds
from one deposit institution to another or, for that
matter, from the credit instruments of deposit-type
institutions to other financial instruments, is not
necessary to the attainment of desired monetary
policy. Let me quote two paragraphs from the New
York Times of March 3:
In its report, the . . . bank leveled some polite,
but nonetheless sharp, criticism at the Federal
Reserve Board in Washington for using its power
to prevent banks from paying competitive interest rates on their time deposits.
This policy, the bank said, did not take fully
into account the ability of borrowers to bypass
the banking system and obtain funds directly in
the open market. The distortions and supervisory problems this policy produced, the bank said,
"suggest that more sparing use of this type of
263

restriction on market competition is probably
desirable."
That statement could be interpreted as a substantial challenge to existing policies of the Federal Reserve. It could have emanated from any number
of commercial banks. Be that as it may, the source
is the Federal Reserve Bank of New York. I could
give you additional quotations which illustrate that,
even within the Federal Reserve System, there is
no monolithic view as to the proper use of rate
ceilings.
In defense of the Federal Reserve Board, we
should note that the most recent upward change in
ceilings are a move in the direction of eventually
converting ceiling rates to standby ceilings. In fact,
there is some indication that a majority of the
Board now favors placing ceilings on a standby
basis just as soon as practicable. Secondly, we cannot ignore the problems of the housing industry in
connection with any discussion of Regulation Q.
The most common interpretation of the handling
of Regulation Q controls from 1966 to the present
is that the ceilings have been structured to allow
thrift institutions, the prime suppliers of housing
credit, to hold more funds than they would otherwise have been able to do.
Whatever justificatons for Regulation Q are advanced, bankers have seen their deposit totals dropping in recent months, and have been unable to
sweeten the pot to hold those deposits. In turn,
the banker was forced to turn down loan requests
from long-standing customers. The customer, then,
if sufficiently large and well-known, often resorted
to a direct sale of commercial paper, which in turn
could be purchased by the erstwhile depositor of
the commercial bank. The banker who observes
such a series of transactions may be at a loss to
understand how it advances monetary policy goals.
REMARKS OF DEAN E. MILLER, DEPUTY
COMPTROLLER FOR TRUSTS, BEFORE THE
AMERICAN BANKERS ASSOCIATION FIDUCIARY
RESPONSIBILITY SEMINAR, WASHINGTON,
D.C., JULY 22, 1970

Shortly after being asked to give this talk, a
booklet, entitled The Economic Power of Commercial Banks, by Carter Golembe Associates came
into my possession, and there, in Chapter 4, was
my talk, already written for me. A cursory reading showed me that it obviously was comprehensive,
for it cited me twice, and anyone who pores
264




through my old talks must be a scholar of the
most extreme devotion.
Seriously, I have read Chapter 4 of the Golembe
report, concerning the regulation of bank trust
departments, and would like to begin by making
a couple of general observations with reference to
it. First, it is in many respects, photographic. A
year from now it may be out of date by reason
of being incomplete, if the banking agencies continue to keep pace with the legitimate demands
for supervision as this business becomes more and
more complex. The attitude at the agencies is
somewhat different from that which has occasionally
existed. At times, trust department supervision
has been in the position of the poor relation, with
the priorities for assigning personnel, scheduling
examinations, and determining corrective actions
in trust departments extremely low, and with the
incidence of original and innovative thought virtually absent. We have enjoyed a significant period
of innovation in trust supervision in more recent
years; it is continuing and, I warn you, may, in
time, make the specifics mentioned in Golembe's
Chapter 4 obsolete.
While I'm on this point, let me make clear that
by innovation I do not mean simply an increase
of permissiveness. We have, in recent years, removed controls which served no useful purpose,
and, I do not refer solely to collective investment
of agency accounts. The Comptroller made numerous changes in Regulation 9, for example, to remove its unwarranted rigidity in trust department
organization and operations, and to remove investment limitations when they were more restrictive than the local law of trusts. The other agencies
have generally followed these precedents. But the
Comptroller has also imposed controls in areas
which have not always been recognized by persons
outside the industry. The placing of all forms of
collective investment, including pooled pension and
profit sharing trusts, not just traditional common
trust funds, under regulatory limitation and supervision is probably the most significant example,
but there are others.
In another vein, the Comptroller's Office took
a significant step toward more responsive trust
supervision several years ago when it established
a separate trust division reporting directly to the
Comptroller. This permitted prompt staff work on
trust problems and speedy resolution of management decisions and initiation of corrective action.
It also fostered the acquisition of greater expertise

by transferring, to a few specialists, work that many
had shared on a part-time, low-priority basis. I
believe that this must eventually be the pattern
followed by all the banking agencies, whether they
continue under their present divided structure or
are consolidated into one.
To return again to the Golembe study, the
second observation I would like to make is that it
does not explicitly express the philosophy of regulation followed by the banking agencies. It has
been the policy, over the years, to keep the absolute prohibitions to a minimum. This policy
has two aspects. First, the mere possibility that
a particular practice could result in abuse if a
bank were to depart from recognized fiduciary
principles has not been deemed sufficient cause
for forbidding the practice outright, if it provides
a desirable service when performed responsibly.
Only when existing regulations prove insufficient to
control abuses has it been felt that specific bans
should be imposed. Secondly, there is the belief that
it is an unrewarding practice to compile a list of
restrictions and limitations, in regulatory form,
purporting to be all-inclusive. The position taken
by our Office is, almost always, analysis, premised
upon conformity to sound fiduciary principles.
Therefore, short shrift is given to those who seek
to justify a breach of fiduciary duty because of the
absence of specific statutory or regulatory language
forbidding the precise act. It is misleading, in seeking to apprise oneself of the activity of the banking agencies in this area, to look, somewhere in
federal law or regulations, for a vast catalogue of
do's and don'ts.
Also, with reference to Mr. Golembe's report,
I recommend that you not conclude from it that
the banking agencies are infallible. I am the first
to admit that they stumble and fall occasionally.
When we do, we try to pull ourselves up and learn
from the experience.
As Carter Golembe points out, the various federal
bank supervisors regularly examine the trust departments of banks for which they are responsible. Thus, the Comptroller examines trust departments of National banks, the Federal Reserve
examines State member banks, and the FDIC examines State non-member insured banks. In addition, trust companies, and the trust departments of
State banks are examined by the State bank supervisors. Corrective actions required by those supervisors as a result of such examinations are carried
out without public disclosure, to minimize the pos-




sibility of jeopardizing the soundness of the bank,
or breaking the confidentiality implicit in fiduciary
accounts administered by banks. This modus operandi, which is characteristic of the banking agencies and is, I believe, most appropriate for this industry, naturally has had the side effect that these
activities are not always known to the casual observer, and even the not so casual one. Thus it is
that I welcome the opportunity to come to this
lectern today and review for you the story of the
bank supervisor.
When the federal bank examiners first began
to look at trust departments, they brought with
them procedures evolved from examining the commercial side of the bank. They physically verified
the assets and checked the accuracy of the bookkeeping systems, using forms adapted from the
commercial examining function. Line cards were
fashioned, onto which were transcribed cash and
investment balances, in a fashion similar to the
taking of loan balances on the commercial side.
The question of compliance with sound fiduciary
practices did not get much play in those days, but
an excellent system for checking the adequacy of
the books and records, and the integrity of the
assets of the department was established at an
early date.
The course of supervision since then has been
primarily characterized by the addition of procedures and techniques aimed at the question of
compliance with applicable laws, regulations, and
sound fiduciary principles in the administration
of trust department accounts. In the early 1930's,
specialized procedures for checking investments
were adopted by the agencies. Our examiners began to brief the appropriate governing instruments
on the line cards, and they do so to this day for
all accounts where the bank has some measure of
investment responsibility. They look at the assets
of the account to see if the investments conform
to the "law" for that account, the "law" being an
admixture of the governing instrument provisions
and the law of the State on investments by fiduciaries. They pay special attention to substandard
assets and those involving a conflict of interest with
the bank, or any person with whom there exists
an interest such that it might affect the exercise
of the best judgment of the bank, in making or
retaining the investment. They also look for concentrations, both within individual accounts, and
in the totals of particular issues held by trust departments. Any of the latter that are large enough
265

to raise the question of possible control or affiliation are reported by our examiners. They can
also, and well might, criticize, as an investment
matter, a holding of a particular issue which, in
their judgment, is too large. The banking agencies
have not attempted to formulate and impose any
broad scale policy for larger holdings where there
does not appear to be any question of lack of
authority, of affiliation, of ulterior motive, or of
poor investment practices. Neither have they attempted to make any policy judgments on economic or social desirability or the effect of the
large holdings of stocks that do generally exist in
trust departments. Such judgments require the
resolution of questions of national policy, and thus
must be made by Congress. Once made, it would
appear that the decision can most appropriately
and effectively be implemented by the banking
agencies.
To return to my chronicle of the development
of trust department examination, the next stage,
if you can call it that, began when the examiners
started to pursue a number of diverse possibilities
for bank misuse of its fiduciary franchise, or neglect
of its attendant duties. That "stage" didn't really
have a formal beginning. It developed that, as the
Washington or Regional Office, or the examiners
themselves, became aware of a particular matter
which warranted scrutiny, that matter was added
to the examination. Such things as checking the
filings of accountings, tax returns, or forms under
the Welfare and Pension Plans Disclosure Act are
but a few examples. Holdings of restricted or control stock, and the incidence of security fails are
more recent additions, and inquiry is now being
made into the banks' policy in allocating brokerage business. Many such checks pertain to local
requirements, such as filings of accountings, and
may vary from region to region, reflecting the wide
divergence in probate practices and requirements.
To date, this has rendered it impossible for us to
establish a complete and uniform standard operating procedure for nationwide use, even though the
report of examination questions, and relevant instructions are universal for our examiners. Thus,
while the questions to be answered are the same,
as are the underlying regulations and policies, there
has existed a certain discretion in the examiner in
determining in what order, and in some cases, how,
he obtains the answers to these questions. In every
case, our examiners must obtain them through
their own scrutiny of the records, or the use of
266




written questionnaires which must be signed by a
responsible bank officer. As you know, giving a
false reply to a bank examiner is a crime. We do
not accept verbal replies. Currently, we are working on a standard procedure, adaptable to all regions and all sizes of departments; the draft is
presently some 90 pages long.
Today the trust examiner is concerned with
proper record keeping and the probate, trust, tax,
securities, and pension and welfare laws, as well as
with the myriad administrative regulations and
rulings that accompany them. In addition, it appears that future additions to that list might include antitrust laws and some of the various proposals presently being made regarding the advancement of particular social purposes. For, however
far these laws may go in conferring enforcement
authority upon other agencies, the bank supervisors cannot, as a result, ignore the possibility
of undetected potential losses because of a breach
of their provisions. I can't imagine anyone exonerating the banking supervisors if a violation of one
of these "other laws" was uncovered in a bank that
had been examined regularly for years, simply because the law was someone else's primary responsibility.
Let me close with a bit of philosophy. What I
have just said is not a complaint; rather, I think
that this is, as it should be, a matter of public
administration, and should serve as a guide as to
other regulated businesses. The growth of governmental supervision, regulation, control, whatever
you may wish to call it, over business has now
proceeded to the point that there are many federal
and State agencies with which any businessman
must cope. Each particular set of governmental
policies has its own agency, its own laws and regulations, and, all too often, its own army of enforcers.
Rather than taking cognizance of this waste and
inefficiency on the part of government, and the
resulting confusion and obstacles faced by business, the present proposals for new controls only
promise to worsen the picture. It would make more
sense in terms of economy and efficiency, coordination of governmental policies, and the removal of
impediments to business activity, to follow the
pattern suggested by the bank supervisory setup;
one agency can serve as the point of initial application of all governmental policies to a particular industry. While I have not grown old in
the federal service, I have assembled enough experience to have some authority when I say that

there is precious little merit in the oft-expressed
bureaucratic assertion that "only we have the expertise to see that our responsibilities are carried
out—we couldn't possibly rely on someone else."
None of us are either omniscient or indispensable.
In all candor, I would have to admit that in some
cases my proposal would require the acquisition of
new skills and the performance of additional functions by the banking agencies, but, I also think
that their recent history demonstrates their capability, when motivation is present at the top.
Thank you.

REMARKS OF
DEAN E. MILLER,
DEPUTY COMPTROLLER FOR TRUSTS,
BEFORE THE MID CONTINENT TRUST CONFERENCE
OF THE AMERICAN BANKERS ASSOCIATION,
CHICAGO, I I I . ,

Nov. 19, 1970
The professional fiduciary business today is in an
era which might be characterized as one of transformation; some might say that "transfiguration"
is a better word, while to others, "transmogrification" would appear more apt. Whether this process,
however you label it, will affect only the outward
appearance of the industry or will result in an alteration of its basic structure remains a matter of
uncertainty. You can obtain opinions on both
sides and in the middle. Going beyond opinions,
you can find those conclusions, reflected, both
consciously and unconsciously, by the actions of
various banks and their trust departments.
The relatively recent widespread interest in the
activities of bank trust departments certainly has
implications of possible structural change. Already
there are legislative and administrative proposals
being advanced in the Congress, in the courts, and
in the Federal Register which will accomplish such
alterations. Some have already come to fruition.
They are seen in the tax, antitrust, labor, pension,
and communication fields, to name a few. The
fact that one has to apply so many labels to those
proposals, all affecting this one business, tells us
something rather basic about the administrative
process, but that's another speech.
There are also more far-reaching portents of
change: Banks and their trust departments have
become the subject of scholarly study. Speaking in
terms of eras, this has become one in which studies




themselves have become suspect, increasingly subject to the accusation that they do no more than
provide a platform of respectability for conclusions
already held by those causing the study to be made.
I have heard such accusations about some studies
being made of bank trust departments, but that
also is another speech, one that someone else may
have to make.
A different factor in the transformation of bank
trust business gives rise to my topic today. It is the
change largely being brought about by the banks
themselves. Competition for trust business has increased to a marked degree. One of competition's
natural by-products is stimulation of the development of features that appear to make one competitor's product superior to that of another. We
see that in the drive for performance in the trust
area, which has raised new theories as to what the
"Prudent Man Rule" is. We see it also in the promotion of new trust department services, and in
unique variations of the old ones, which raises the
question of what legitimate banking services are,
and what bona fide fiduciary activities are. (That
dog just won't die.) We also see it in the broadening of bank activities in general, which sometimes
has implications for the trust department.
Those phenomena have given birth to a number
of questions which form the frontier of the law of
trusts today. That frontier exists, whether we like
it or not, and we might as well face it and talk
about it. That some may already have crossed that
frontier in some of their activities may mean only
that they are living among savages, not that they
have succeeded in pushing the border further. It
rests with the courts, faced with a bank and that
legendary fundless widow, to settle the boundary
disputes; rhetoric will not be sufficient toward that
end.
Now let me make the transition from the beautiful broad generality to the ugly narrow specifics.
The first specific frontier I would like to deal with
is the present location of the "Prudent Man Rule,"
and how far it extends. That rule, when it was first
stated, in the case of Harvard College v. Amory,
was an investment rule. It supplanted the legal
lists, the general prohibitions on categories of investments, and all that had gone before. It was not
conceived as a general qualifier of the entire range
of a trustee's duties as recognized in common law
over the years. It did not proclaim that the trustee
could do as he wished as long as he was prudent.
It did not furnish a qualification to the conflict of
267

interest rules. It did not provide that a trustee
could deal with himself as long as he was prudent.
It did not provide that he could speculate prudently.
That last probably presents the question a bit
unfairly. More objectively, and in contemporary
terms, in an account where growth is the primary
or most significant objective—although it is perhaps not expressly stated—how consistent with the
"Prudent Man Rule" is an investment in a new
and untried enterprise, a restricted stock, investment partnerships, or some of the other forms of
long-term joint ventures?
No court, to my knowledge, has upheld a trustee
under the "Prudent Man" theory, or any other
theory, in a situation involving losses by widows
and orphans because of that type of investment.
Thus, we have no concrete indication that the principles of fiduciary administration which have
evolved over the years, and which are a part of the
law of trusts, have changed that much. Can we rely
on such factors as an allegedly more sophisticated,
or more enlightened, climate existing today? Do
these theories of selectivity rest on anything else?
If one reads some of the journals of the twenties,
one finds similar assertions as to the growth of the
common law. In the thirties, it was found that it
hadn't grown nearly as much as was thought in the
previous decade. Are things different now?
One of the less precisely illuminated areas of the
law of trusts today is the extent to which a trustee
is improperly delegating his investment responsibility, if at all, when he participates in a joint undertaking in which the selection of the underlying
assets rests with someone else. Perhaps the conventional examples of this would be investment companies, and, more recently, real estate investment
trusts. There is disagreement, in the decisions and
commentaries, as to whether an investment in
mutual fund shares is an improper delegation, with
more recent views denying it. Even if such an investment were an improper delegation under the
common law, the question is now academic because
of the enactment, in many States, of laws giving
trustees specific authority to invest in investment
companies. Query whether such statutes also cover
real estate investment trusts, however.
I have had mixed emotions about the delegation
question. On the one hand, I think there is something inconsistent about a professional fiduciary
claiming that it does not have enough expertise in
investment management, and therefore must en268




trust another with the funds. It would seem that
the trustee who, in effect, does that, through investment in a real estate investment trust, for example,
should take a lesser fee than if it invests the trust
funds itself. But, it is said, on the other hand, that
the expertise of the trustee is called for in choosing
the management of the particular fund, and that
that process is little different from evaluating the
management of any conventional company. In this
day, as "conventional" companies become more and
more diversified, this consideration carries much
force. In addition, in the case of the real estate
investments, there exist unique difficulties which
might well be beyond the usual capability of the
trust department. Real estate is unique, and real
estate located in other parts of the country often
presents the trust officer with insuperable difficulties
in evaluation. You might, therefore, make a strong
case for the proposition that the most prudent way
for a trustee to invest in real estate is through a real
estate investment trust.
From the foregoing we might conclude that a
trustee may well delegate his investment responsibility, if prudent, although determining where
prudence ends and speculation or unwarranted reliance upon others begins would present more problems than usual. It may be that the boundary is
crossed in some investment partnerships available
today. Of course, none of this assumes the presence
of a conflict of interest on the part of the trustee.
That is another frontier, to which it might be appropriate to turn our attention at this time.
Here I would like to challenge the product of
one of your local courts, the Glos case. More correctly, it is the case of Elmhurst National Bank v.
Glos, 99 111. App. 74, 241 N.E. 2d 12 1 (1968). In
that case, the Appellate Court of the Second District of Illinois ruled, to summarize very briefly,
that a bank trustee could retain shares of its own
stock in a trust account with specific authority, if
prudent. To put it bluntly, we believe that the
case is wrong, that the court erroneously extended
the "Prudent Man Rule" beyond its proper application, and that it is highly doubtful that a court
of final jurisdiction would rely on it. For that
reason, you might say that we do not acquiesce.
There are related questions on this subject that
are raised by the rationale of the Glos decision.
What if the shares of the trustee bank's stock have
been exchanged for that of a holding company?
In many States there are retention statutes broad
enough to cover this situation; in others, there are

not, and the governing instrument provisions may
be of doubtful help. Can the holding company
shares be retained under the "Prudent Man Rule"?
If so, then the holding company shares will be retained in every case, for what banker is going to
believe that his decision to move into a holding
company is an imprudent one? The problem that
I am suggesting is one of the separation of the functions of a banker in such a situation. If prudence
is the sole guide, then it would seem that there is
little limitation upon the use of trust funds to
acquiesce, if not assist, in the expansionary moves
of the bank. Indeed, you can make a compelling
case in logic for the outright use of trust funds in
the bank's commercial lending business. I don't
suggest that anyone here believes that the "Prudent
Man Rule" can be taken that far, and I don't mean
to imply that this is taking place. Rather, I think
I have shown the absurdity of trying to stretch that
rule to cover all of the duties of the trustee, the
trend shown in some of the recent, hasty, and illconsidered legal and judicial opinions, exemplified
by the Glos decision.
The law of trusts has not "progressed" so far. It
still requires that decisions pertaining to trust accounts be made with sole reference to the purposes
of the account and the best interests of the beneficiaries. It requires, also, that before a bank trustee
can perform an act, consistent with that standard,
but involving self-dealing or a conflict of interest,
he must have specific authority to do so in the
governing instrument or local law. In seeking to
determine whether any investment is proper, or
prudent, the inquiry must be twofold: first, is it
within the authority given; and, second, is it consistent with the purposes of the trust and in the
best interests of the beneficiaries?
The necessity of that second inquiry has eluded
some of the outside detractors, whose tactics, thus
far, have been to study the business only so far as
necessary to uncover a supposed flaw, however
superficial, and then to proclaim it with their new
found authority as experts. The same oversight has
also been the failing of some of the casual legal and




judicial opinion writers, who, even when exposed
to this rule, fail to comprehend it. For example,
recently, a learned attorney, upon being informed
that we believed that properly authorized investments must also be consistent with the purposes of
the trust, opined that the purpose of a direction
pension trust was for the trustee to make investments as directed. Obviously, it is to provide a
pension for employees upon their retirement, and
that must control.
I have occasionally complained of detractors of
bank trust departments, and trust supervision, who
seek to make their cases after either superficial, or
extremely unobjective, investigations. Equally irritating, however, is the defender of trust department practices who employs similar methods. The
bank lawyer, or the trust officer, who fails to subject his proposed transactions to thorough, introspective, and objective analysis does the bank fiduciary business, and the public interest, as much
of a disservice as do the critical outsiders. And, I
would especially include in that indictment those
commercial banking chief executives who give their
trust activities so little considered attention. In this
era of increased awareness of bank trust department activities, the substanceless platitudes that
seem to be all that some commercially-oriented
bank chief executives can come up with, simply
won't do.
The corporate fiduciary business, and its applicable laws and regulations, are exceedingly complex.
Dealing properly with these matters requires a
great deal of thought and study, bottomed on a
thorough knowledge of the principles of the law of
trusts. It is very tempting, when facing a problem
in this area, to rely instead upon simplistic characterizations of the effect of applicable laws and
regulations on bank activities, both present and
proposed. No one, neither the banks, the bank
supervisors, nor the critics of banking, should make
this mistake if they are sincerely interested in providing the public with the most competent and
convenient professional fiduciary services.
Thank you.

269

INDEX
Addresses of the Comptroller of the Currency, 255-61
Administration of the Comptroller's Office, 21-23
Administrative Assistants to the Comptrollers, listed, 184
Administrative Services Division, 22
Armored car service, 16
Assets of the Comptroller's Office, 26
Assets of National banks:
of acquiring and acquired banks, 1960-1970, 208
by deposit size, 222
of foreign branches, 1953-1970, 250
of foreign branches, Dec. 31, 1970, 250
at last condition report, 1950-1970, 248
in 1969 and 1970, 2
by States, June 30, 1970, 225
by States, Dec. 31, 1970, 228
of trust accounts, 251
Balances per credit card, 221
Bank chartering. (See Charters and chartering.)
Bank examination:
administration of, 22
new procedures in, 13
summary of 1970 activities in, 13
of trust departments, 265-66
Bank holding companies, 255-57, 262-63
Bank mergers. (See Mergers.)
Bank regulation, 255-57
Banking:
criticism of, 258-59
expansion of, 255-57
litigation on, 14-15, 262
monetary policy transmitted by, 263-64
new functions of, 259-61
potential of, 260
proper role of, 261-63
supervision of, 264-67
Banking offices, by States, Dec. 31, 1970, 6
Branches of National banks:
in calendar 1970, 10
closed in 1970, 219-20
de novo, 5, 10-12
foreign, 20, 249, 250, 261
litigation on, 16-17
opened in 1970, 209-18
by States, Dec. 31, 1970, 6
Camp, William B.:
addresses of, 257-61
Congressional testimony of, 255—57
Capital accounts of National banks:
by deposit size, 222
from 1944 to 1970, 246
in 1969 and 1970, 2
by States, June 30, 1970, 227
by States, Dec. 31, 1970, 230
Capital stock of National banks, 187
Cases in litigation, 14-18, 177-79
Changes in structure of National Banking System, 186
Charters and chartering:
applications by States, 1970, 7, 188-89
applications pursuant to corporate reorganization, 8, 189
and conversion by State banks, 9, 195
issued in 1970, by States, 7, 190-91
issued pursuant to corporate reorganization, 8, 196
litigation on, 15
Clayton Act, 18
Closing of branches in 1970, by States, 219-20
Collective investment funds, 14
Commingled managing agency accounts, 14
Comptroller of the Currency, Office of:
administration of, 21-23
Administrative Assistants to the Comptrollers, listed, 184
Comptroller's addresses and Congressional testimony, 255-61
Comptrollers, listed, 183
Deputy Comptrollers, listed, 184




Deputy Comptrollers' addresses, 261-69
financial operation of, 25-28
litigation, 14-18
organization chart of, 24
regulation of holding companies, 257
trust supervision, 264-66
Comptroller's equity, 25-27
Condition of National Banking System, 1-2
Condition report dates, 1914-1970, 223-24
Congressional testimony of William B. Camp, 255-57
Consolidations:
of National banks, 199-200
of National with State banks, 197, 199-200
(see also Mergers.)
Conversions:
of National into State banks, 198
of State into National banks, 9, 195
Corporate reorganization:
charter applications pursuant to, 8, 189
charters issued pursuant to, 8, 192-94, 196
Credit card balances, 221
Credit card transactions, 15
Criticism of banking, 258-59
Data processing services, 256
Dates of reports of condition, 223-24
De novo branches, 5, 10-12
Deposits of National banks. (See Assets of National banks.)
Deputy Comptrollers of the Currency, listed, 184
Dividends of National banks, 246
Electronic data processing (EDP), 13
Equity, Comptroller's, 25-27
Examination of banks. (See Bank examination.)
Expansion of bank activities, 255-57
Expenses of Comptroller's Office, 27-28
Expenses of National banks:
by deposit size, 244-45
in 1969 and 1970, 3-4
by States. 232-43
Fiduciary activities. (See Trust departments.)
Financial operation of the Comptroller's Office, 25-28
Fiscal Management Division, 21
Foreign branches:
assets of, 1952-1970, 250
assets and liabilities of, Dec. 31, 1970, 250
expansion of, 261
and international finance, 20
number of, 1960-1970, 250
by region and country, 249
Golembe report, 264-65
Holding companies, 255-57, 262-63
Incidental powers, litigation on, 14, 257
Income of National banks:
by deposit size, 244-45
from 1944 to 1970, 246
in 1969 and 1970, 3-4
by States, 232-43
of trust accounts, 251
Interest on credit card transactions, 15
Internal Audit Division, 23
International banking, 20, 261
Investment funds, 14
"Laundry list" of banking activities, 255-56, 262-63
Law of trusts, 267-69
Liabilities of Comptroller's Office, 26
Liabilities of National banks:
by deposit size, 222
of foreign branches, 250
at last condition report, 1950-1970, 248

271

Office of the Comptroller of the Currency. (See Comptroller
of the Currency.)
One-bank holding companies, 256-57, 262-63
Opinion of independent accountant, 28
Organization chart of the Comptroller's Office, 24
Outstanding balances on credit plans, 221

in 1969 and 1970, 2
by States, June 30, 1970, 226
by States, Dec. 31, 1970,229
Liquidation of National banks, 197
Listing of National banks, by States, 6
Litigation on:
banking activities, 262
branches, 16-17
collective investment funds, 14
incidental powers, 14, 257
interest on credit card transactions, 15
main office relocations, 15-16
mergers, 17-18, 177-179
new banks, 15
Loans of National banks:
from 1945 to 1970, 247
by States, 231
Losses of National banks, 1945 to 1970, 247

Personnel Division, 21, 22
Potential of banking industry, 260-61
"Prudent Man Rule", 267-69
Purchases of State banks by National banks, 199

Main office relocations, 15-16
Management Services Division, 23
Managing agency accounts, 14
Mergers, 30-179:
approval opinions, 34-179
approvals, listed, 30-33
in 1970, 12, 30-33
involving 2 or more operating banks, 30-32, 34-158
litigation on, 17-18, 177-79
of National with State banks, 197
pursuant to corporate reorganization, 32-33, 159-76, 192-94
resulting in National banks, by assets, 1960-1970, 208
by States, 1970, 201-8
Miller, Dean E., remarks of, 264-69
Monetary policy, 263-64
Motter, David C, remarks of, 261-64

Securities of National banks:
losses and recoveries on, 1945 to 1970, 247
in 1969 and 1970, 2
Services of banks, 255-57, 262
State banks:
consolidations of National banks with, 197, 199-200
conversion of National banks into, 198
conversion to National banks, 9, 195
mergers with National banks, 197, 201-8
purchased by National banks, 199
Structural changes in National Banking System, 5-12, 186

Newly organized National banks:
litigation on, 15
by States, 190-91
Number of National banks in each State, 6

272




Recoveries of National banks, 1945 to 1970, 247
Regional Administrators of National banks, listed, 185
Regulation of banking, 255-57
Regulation Q, 263-64
Rejected applicants, litigation by, 15
Relocation of main offices, 15-16
Reports of condition, 223-24
Revenue of Comptroller's Office, 27

Trust departments:
activities summarized, 19
assets and income of, by States, 251
litigation on, 14
and "Prudent Man Rule", 267-69
supervision of, 264-67
transformation in, 267-69