View original document

The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.

Annual Report 1971
Comptroller of the Currency




The Administrator of National Banks

William B. Camp
Comptroller of the Currency

Letter of Transmittal
O ffice
S

of the

T reasury D epartment,
C omptroller of the C urrency,
Washington, D.C., September 29, 1972

:

irs Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1971 Annual Report of
the Comptroller of the Currency.
Respectfully,

William B. Camp,

Comptroller of the Currency.

T he President of the Senate
T he Speaker of the H ouse of R epresentatives




Contents
Title of Section
I. Condition of the National Banking System...............................................................................................
II. Incom e and Expenses of National Banks....................................................................................................
III. Structural Changes in the National Banking System................................................................................
IV . Bank Examinations and Related Activities...........................................................................................
V . Litigation...........................................................................................................................................................
V I. Fiduciary Activities of National Banks..................... ..................................................................................
V II. International Banking and Finance.............................................................................................................
V III. Administrative and Management Developments.....................................................................................
IX . Financial Operations of the Office of the Comptroller of the Currency.......................................

Page
1
3
5
13
14
18
19
20
23

Appendices
A. Merger Decisions, 1971..........................................................................................................................................
B. Statistical Tables......................................................................................................................................................
C. Addresses and Selected Congressional Testimony of the Comptroller o f the Currency...........................

29
147
215

Index..................................................................................................................................................................................

257




V

Statistical Tables
Table No.
1
2

Title

Page

Assets, liabilities, and capital accounts of National
banks, 1970 and 1971..................................................
Income and expenses of National banks, 1970 and
1971...................................................................................

3

Applications

7
2
8
4
9

National banks and banking offices, by States,

4

Dec. 31, 1971..................................................................
for

National

bank

charters,

7

Applications for National bank charters to be issued
pursuant

to

corporate

reorganizations,

and

charters issued, by States, calendar 1971.............
6

6

and

charters issued, by States, calendar1971................
5

Applications for

conversion

to

National

8

bank

1971...................................................................................




10
11
12

charters, and charters issued, by States, calendar

VI

Table No.

13
9

Title

Branches of National banks, by States, calendar
1971...............................................
De novo branch applications of National banks, by
States, calendar 1971...............................
De novo branches of National banks opened for
business, by community size and by size of bank,
calendar 1971..................................................................
Mergers, calendar 1971................
Office of the Comptroller of the Currency: balance
sheets, 1970 and 1 9 7 1 . . . . .........................................
Office of the Comptroller of the Currency: state­
ments of revenue, expenses, and Comptroller’s
equity................................................................................
Office of the Comptroller of the Currency: state­
ment of changes in financial position......................

Pag
10
11

12
12
24

25
26

I. Condition of the National Banking System
The year 1971 was a period of relative ease in the
money markets and of declining interest rates. Na­
tional banks were able to add significantly to their
total deposits since they were free to compete vigor­
ously for funds at the lower rate levels. Total resources
of National banks reached $376.5 billion at year-end,
a 10.4 percent increase for the year.
Markedly different growth rates for demand depos­
its and time and savings deposits led to an important
first— time and savings deposits of National banks ex­
ceeded their demand deposits at the end of 1971.
While demand deposits increased by 4.7 percent, from
$145.1 billion to $152 billion, time and savings depos­
its spurted 17 percent, from $138.7 billion to $162.2
billion. Thus time and savings deposits represented
51.6 percent of the total deposits of National banks on
December 31, 1971.




For the second year in a row, total securities held by
National banks increased faster than total loans, al­
though the difference in rates of growth was less pro­
nounced than in 1970. Total securities advanced by
14 percent, from $84.2 billion to $96 billion. M ean­
while, total loans increased 9.6 percent, from $177.2
billion to $194.1 billion. Within the securities category,
the holdings of U.S. agency issues vaulted by 29.2 per­
cent, from $6.7 billion to $8.6 billion. Municipal hold­
ings also showed a sharp increase, from $41.5 billion
to $48.6 billion.
The total capital of National banks reached $27.1
billion at year-end, an increase of 8.8 percent during
1971. Outstanding capital notes and debentures in­
creased by 24.8 percent, from $1.2 billion to $1.5
billion.

1

T able 1
Assets, liabilities, and capital accounts of National banks, 1970 and 1971
[Dollar amounts in millions]

Dec. 31, 1971
4,600 banks

Dec. 31, 1970
4,621 banks
Percent
distribution

Amount

Change 1970-71

Percent
distribution

Amount

Amount

Percent

ASSETS
Gash and due from banks...........................................................

$56, 040

16.44

$59, 201

15. 73

$3, 161

5. 64

U.S. Treasury securities..............................................................
Obligations of other U.S. Government agencies and cor­
porations ......................................................................................
Obligations of States and political subdivisions...................
Other securities..............................................................................

34, 223

10. 04

36, 396

9. 67

2, 173

6. 35

6, 681
41, 542
1,800

1.96
12. 19
.5 3

8, 634
48, 648
2, 351

2. 29
12. 92
.6 2

1,953
7, 106
551

29. 2 3
17. 11
30.61

84, 246

24. 71

96, 029

25.51

11,783

13. 99

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

3. 06
.2 3
51. 98
1. 73
.6 0
1.24

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

3. 37
.2 3
51.57
1. 76
.5 8
1.25

2, 269
81
16, 943
700
143
470

21. 74
10. 25
9. 56
11.84
6. 96
11. 12

340, 906

100.00

376, 456

100.00

35, 550

10. 43

107, 768

31.61

113,210

30. 07

5, 442

5. 05

119, 843
5,061
25, 053

35. 15
1.48
7. 35

138, 222
6, 389
29, 036

36. 72
1.70
7. 71

18, 379
1,328
3, 983

15. 34
26. 24
15. 90

3, 386
18, 494
4, 179

. 99
5.43
1.23

3, 390
18, 620
5, 346

.9 0
4. 95
1.42

4
126
1, 167

. 12
.6 8
27. 93

283, 784

83. 24

314,212

83. 47

30, 429

10. 72

145, 122
138, 662

42. 57
40. 67

151,985
162, 227

40. 37
43. 09

6, 863
23, 565

4. 73
16. 99

11,830
1,280

3. 47
. 38

17, 302
866

4. 60
.2 3

5, 472
-4 1 4

46. 26
- 3 2 . 34

.......................................

2, 096
13, 204

. 61
3. 87

2, 242
10, 842

.6 0
2. 88

146
- 2 , 362

6. 97
- 1 7 . 89

312, 194

91.57

345, 465

91. 77

33,271

10. 66

Minority interest in consolidated subsidiaries......................

1

—

1

0

0

Reserves on loans..........................................................................
Reserves on securities...................................................................

3, 747
89

1. 10
.0 3

3, 837
80

1.02
.0 2

90
-9

2. 40
- 1 0 . 11

Capital notes and debentures....................................................
Preferred stock................................................................................
Common stock................................................................................
Surplus..............................................................................................
Undivided profits..........................................................................
Reserves............................................................................................

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

.3 4
.0 2
1.89
3. 13
1. 72
.2 0

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

. 38
.01
1.80
3. 14
1.67
. 18

288
-2 0
328
1, 159
436
5

24.81
- 3 1 . 75
5. 08
10. 87
7 .4 4
. 75

24, 875

7. 30

27, 072

7. 19

2, 197

8. 83

340, 906

100.00

376,456

100.00

35, 550

10. 43

.......................................

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

..........................................
LIABILITIES

Diemand deposits of individuals, partnerships and cor­
porations....................................................................................
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 apd securties sold under agree­
ments to repurchase.................................................................
Liabilities for borrowed money.................................................
Acceptances executed by or for account of reporting banks
and outstanding.........................................................................
Other liabilities..............................................................................

Total liabilities

RESERVES ON LOANS AND SECURITIES
CAPITAL ACCOUNTS

.................................
...................

Total capital accounts
Total liabilities and capital accounts

—

N ote : Data may not add to totals because of rounding.
The 1970 and 1971 data reflect consolidation of all majority-owned bank premises, subsidiaries, and all significant domestic
majority-owned subsidiaries, with the exception of Edge Act subsidiaries.
2




II. Income and Expenses of National Banks
The sources of operating income for National banks
reflected both the faster growth of securities holdings
than loans, and the more pronounced impact of lower
rates on the latter. Total interest and fees on loans ac­
tually declined in 1971 by $30 million, or 0.2 percent.
Total interest and dividends on investments showed a
healthy increase of 18.4 percent during the year, from
$3.6 billion to $4.3 billion. The proportion o f total op­
erating income accounted for by interest and fees on
loans declined from 67 percent in 1970 to 64.1 percent
in 1971.
Total operating income of National banks showed
only a 4.3 percent increase-in 1971 over that of 1970,
$21.3 billion to $20.4 billion. With total operating ex­
pense increasing by 6.9 percent, from $16.3 billion to
$17.4 billion, income before income taxes and secu­




rities transactions registered a 6.1 percent decline, from
$4.1 billion to $3.9 billion. Lower applicable income
taxes and a net gain on securities transactions of $107
million, compared with a net loss on similar transac­
tions of $65 million in 1970, led to a gain of 7.5 per­
cent in net income, from $2.8 billion to $3 billion.
Interest paid on deposits totalled $7.2 billion, rep­
resenting 41.5 percent of total operating expense of
National banks. In 1970, interest paid on deposits had
accounted for 38.1 percent of total operating expense.
Salaries and wages of officers and employees increased
by 7.9 percent, from $3.8 billion to $4.1 billion. That
item accounted for 23.8 percent o f all operating ex­
pense for National banks in 1971, compared to 23.6
percent in 1970.

B

T able 2
Income and expenses of National banks*, 1970 and 1971
[Dollar amounts in millions]

Dec. 31, 1971

Dec. 31, 1970
Amount
Number of banks......................................................................
Operating income:
Interest and fees on loans..............................................
Income on Federal funds sold and securities pur­
chased under agreements to resell..........................
Interest and dividends on investments:
U.S. Treasury securities........................................
Obligations of other U.S. Government agen­
cies and corporations.........................................
Obligations of States and political subdivi­
sions ........................................................................
Other securities........................................................
Trust department income......................................................
Service charges on deposit accounts...................................
Other service charges, collection and exchange charges,
commissions, and fees..........................................................
Other operating income..........................................................

Percent
distribu­
tion

2

Amount

Change, 1970-71

Percent
distribu­
tion

4, 600

4, 621

Amount

Percent

-2 1

-.4 5

$13, 69 8.4

67. 04

$13,668. 1

64. 14

-3 0 . 3

-.2 2

60 2.9

2. 95

533. 8

2. 50

-6 9 . 1

-1 1 .4 6

1, 654. 1

8. 09

1, 849. 5

8. 68

195.4

11.81

327.0

1.60

442. 9

2. 08

115. 9

35. 44

1, 535. 3
90. 7
626.2
68 6.4

7.51
.4 4
3. 07
3. 36

1 ,8 4 1 .0
137.8
700.9
709. 7

8.6 4
.6 5
3. 29
3. 33

305. 7
47. 1
23. 3

19. 91
51 .92
11.92
3. 39

534. 8
677.9

2. 62
3. 32

624.6
801.2

2. 93
3. 76

8 9 .8
123. 3

16. 79
18. 18

20, 433. 7

100. 00

2 1 ,3 0 9 .5

100. 00

87 5.8

4. 29

3, 838. 6
625.2
6 ,2 1 5 .2

23. 55
3. 84
38. 12

4, 140. 2
698.4
7, 228. 7

23. 75
4.01
41 .47

301.6
73.2
1 ,0 1 3 .5

7. 86
11. 71
16. 30

937.5
169.8
55 .2
723.8

5. 75
1.04
. 34
4. 44

739.6
80 .7
6 7 .8
811.0

4. 24
.4 6
. 39
4. 65

-1 9 7 . 9
-8 9 . 1
12.6
87 .2

Total operating expense...................................................

546.6
40 5.6
2, 784. 7

3. 35
2 .4 9
17. 08

606.6
514. 1
2, 543. 3

3. 48
2. 95
14. 59

6 0 .0
108.5
-2 4 1 .4

10. 97
26. 75
- 8 . 66

16, 302. 0

100. 00

17, 4 3 0.4

100. 00

1, 128. 4

6. 92

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 ...............

4, 131. 7
1 ,2 3 9 .9
2, 89 1.8
-6 4 .5
2, 827. 3
2. 1

3, 879. 1
942. 7
2, 936. 3
106.9
3, 043. 3
-1 .8

-2 5 2 .6
-2 9 7 . 2
4 4 .5
171.4
21 6.0
-3 .9

- 6 . 11
- 2 3 . 97
1 .5 4
265. 74
7 .6 4
- 1 8 5 .7 1

Net income.................................................................................

2, 829. 3

3 ,0 4 1 .3

2 1 2 .0

7.4 9

Cash dividends declared:
On common stock............................................................
On preferred stock...........................................................

1, 273. 0
4 .7

1, 386. 2
4 .0

113.2
-.7

8 .8 9
- 1 4 . 89

1, 277. 7

1, 390. 2

112. 5

8. 80

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 cash dividends declared.........................................

\ \ .7

-2 1 .
-5 2 .
22.
12.

10
47
83
04

; - z..r:r-r:,r =
T-^

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

30.01
1. 56
.0 5

24. 30
2. 76
.0 5

Ratio to total operating income:
Salaries and wages...............................................
Interest on deposits.........................................................
All other operating expenses........................................

18. 79
30. 42
13. 63

19. 43
33. 92
11.94

79. 78

81. 80

13. 85

14.27

......................

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

4



III. Structural Changes in the National
Banking System

As of the end of 1971,13,106 branches were operated
by 1,688 National banks, while the remaining 2,912 Na­
tional banks were unit banks. The total of 4,600 Na­
tional banks represented a decline of 21 from the fig­
ure one year earlier, due to mergers and consolidations.
However, the 6 percent increase in branches led to a
total of 17,706 National bank offices serving the public
within the United States at year-end, a record high.
The unit banking states of Texas and Illinois led in
total number of National banks, with 530 and 415,
respectively. California, New York, and Pennsylvania
led in total number of National banking offices, with
2,530, 1,503 and 1,373, respectively.
During 1971, 731 de novo branches were added to
the system. These are new offices offering banking
services to the public for the first time at their specific
sites. O f the de novo branches, almost 71 percent were
located in communities with populations of less than
50,000, while 8.6 percent were located in communities
having 500,000 or more people. Banks having total
resources of less than $50 million accounted for 33.7
percent of the de novo branch openings during 1971;
billion-dollar banks opened 26.1 percent of those




branches. California, with 102 de novo branches, New
York, with 74, and New Jersey, with 53, led the States
in this category. The difference between 738 net
branch additions to the system and 731 de novo
branches was accounted for by the entry of 97 branches
via merger or conversion and the exit of 90 branches
through closing merger, or conversion.
Thirty-eight charters were issued for newly orga­
nized National banks in 1971, compared with 39 in
1970. The Comptroller gave preliminary approval to
55 charter applications; the comparable figure during
1970 was 42. In addition to the charters issued to
newly organized banks, 21 charters were issued to
State banks converting to the National system, and 30
charters were issued pursuant to corporate reorganiza­
tion.
There were 55 merger, consolidation, or purchase
transactions during 1971 involving two or more oper­
ating banks in which the resulting bank was a Na­
tional bank. The comparable figure in 1970 was 80.
Also, 29 mergers pursuant to corporate reorganization
and involving only one operating bank were consum­
mated during 1971.

5

T able 3
National banks and banking offices, by States , D ec.

31

, 7977

National banks
Total

Number of
branches

With
branches

Unit

Number of
offices

1,688

13, 106

17, 706

40
0 •
1
32
7
109
4
3
1
230

48
5
2
37
50
13
22
2
10
0

209
53
225
87
2, 473
13
250
4
71
0

297
58
228
156
2, 530
135
276
9
82
230

60
1
7
415
122
99
171
80
49
19

24
0
2
349
48
56
138
35
11
3

36
1
5
66
74
43
33
45
38
16

221
9
113
66
359
62
33
150
185
107

281
10
120
481
481
161
204
230
234
126

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

39
84
104
198
38
98
52
125
4
48

12
20
31
195
5
74
49
100
1
24

27
64
73
3
33
24
3
25
3
24

268
441
581
7
145
24
3
26
64
54

307
525
685
205
183
122
55
151
68
102

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

120
33
166
23
42
218
197
8
286
5

17
7
62
3
32
66
155
1
127
0

103
26
104
20
10
152
42
7
159
5

741
79
1,337
606
10
772
42
259
1,087
96

861
112
1,503
629
52
9^0
239
267
1,373
101

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

19
32
77
530
9
26
101
24
86
126
42
1

4
22
17
530
5
11
25
6
86
90
42
0

15
10
60
0
4
15
76
18
0
36
0
1

251
63
292
0
75
50
506
460
0
69
0
8

270
95
369
530
84
76
607
484
86
195
42
9

District of Columbia— a ll*.................................................

14

1

13

106

120

United States.....................

.............................................

4 ,6 0 0

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

88
5
3
69
57
122
26
5
11
230

Georgia..............................................................................................
Hawaii...............................................................................................
Idaho..................................................................................................
Illinois................................................................................................
Indiana..............................................................................................
Iowa......................................................................................
Kansas...............................................................................................
Kentucky...........................................................................................
Louisiana...........................................................................................
M aine................................................................................................

2,912

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

6



Applications f o r

T able 4
National bank charters,* and charters issued,* by States, calendar
Receivedf

Approved

Rejected

Abandoned

1971

Pending
Dec. 31,1971

Charters
issued

United States..........................................

185

55

54

5

71

38

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

1
0
0
1
6
12
2
0
0
38

1
0
0
0
1
1
1
0
0
13

0
0
0
0
2
6
1
0
0
18

0
0
0
0
0
1
0
0
0
0

0
0
0
1
3
4
0
0
0
7

0
0
0
0
0
2
0
0
0
14

Georgia..................................................................
Hawaii...................................................................
Idaho......................................................................
Illinois....................................................................
Indiana..................................................................
Iowa........................................................................
Kansas....................................................................
Kentucky...............................................................
Louisiana...............................................................
M aine.....................................................................

2
1
0
8
1
2
2
0
1
1

1
0
0
5
0
1
0
0
1
1

1
0
0
1
0
1
1
0
0
0

0
0
0
0
0
0
0
0
0
0

0
1
0
2
1
0
1
0
0
0

0
0
0
5
0
0
0
0
0
0

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

0
0
5
1
2
4
0
0
0
0

0
0
2
0
1
1
0
0
0
0

0
0
1
0
1
0
0
0
0
0

0
0
1
0
0
0
0
0
0
0

0
0
1
1
0
3
0
0
0
0

0
1
2
0
0
0
0
0
0
0

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

16
2
7
1
0
1
3
0
0
0

4
0
4
0
0
1
0
0
0
0

5
0
0
0
0
0
1
0
0
0

0
1
1
0
0
0
0
0
0
0

7
1
2
1
0
0
2
0
0
0

3
0
2
1
0
0
0
0
0
0

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

1
0
1
49
3
0
2
2
3
1
2
0
1

0
0
0
11
1
0
1
0
1
0
1
0
1

1
0
0
10
0
0
1
1
0
1
1
0
0

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

0
0
1
27
2
0
0
1
2
0
0
0
0

0
0
0
5
0
0
1
0
0
1
1
0
0

♦Excludes conversions and corporate reorganizations,
f Includes 62 applications pending as of December 31, 1970.




7

T able 5
Applications for National bank charters to be issued pursuant to corporate reorganizations, and charters issued, by States,
calendar 1971

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

Approved

60
4
0
0
0
2
0
0
0
0
0
0
0
0
0

Rejected

55

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

Abandoned
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

Pending
Dec. 31,1971
5

4
0
0
0
0
0
0
0
0
0
0
0
0
0

Charters
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0

1
0
1
0
0
0

1
0
1
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
3
0
0
1
0
1
0
0

0
0
3
0
0
1
0
1
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
4
0
0
0
0

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

9
0
9
0
0

4

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
1
0
0
0
0

5
0
3
0
0

0
1
2
0

9
0
9
0
0
3
0
1
2
0

1
0
0
0

South Carolina....................................................
South Dakota.......................................................
Tennessee..............................................................
Texas......................................................................
U tah........................................................................
Vermont................................................................
Virginia.................................................................
Washington..........................................................
West Virginia.......................................................
Wisconsin..............................................................
Wyoming...............................................................
Virgin Islands......................................................
Puerto Rico..........................................................

1
0
3
13
1
0
4
0
0
0
0
0
0

• 1
0
3
13
1
0
4
0
0
0
0
0
0

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

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

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

0
0
2
6
0
0
4
0
0
0
0
0
0

♦Includes one application pending as of December 31, 1970.

8



4

T able 6

,

,

,

Applications f o r conversion to National bank charters and charters issued by States calendar 1971

Received*

Rejected

Approved

Abandoned

Pending
Dec. 31, 1971

Chartered

United States..........................................

16

10

3

1

2

21

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

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
1
0
0
0
0

Georgia..................................................................
Hawaii...................................................................
Idaho......................................................................
Illinois....................................................................
Indiana..................................................................
Iowa.......................................................................
Kansas...................................................................
Kentucky..............................................................
Louisian i ..............................................................
Maine.....................................................................

0
0
0
0
1

0
0
0
0

0
0
0
0

0
0
0
0

0
0
0
2

0
0
0
0
0

0
0
0
0
0
0

0
0
0
0
0
0

0
0
0
0
1

0
0
0
0
0
0

0
0
0
0
0
0

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

0
0

0
0

0
0
0
0
0

1

1

0
0

0
0

0
0
0
0
0

2
6

1
3

1
2

0
0
0

0
0
0

0
0
0

0
0
0
0
0
0
0
0
0
0

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

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
0
0
0
0

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

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

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

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

0
0
0
0
0
0

1

0
0
1
2

0
0

0
0
0
0

0

0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
1
0
0
0
6
0
2
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
4
0
0
1
0
0
0
0
0

1

*Includes three applications pending as December 31, 1971.




9

T able 7
Branches o f National banks, by States , calendar 1971
Branches in
operation
Dec. 31, 1970

United States...............................................

12, 368r

De novo
branches
openfor
business
fan. 1 to
Dec. 31, 1971

Branches
acquired
through
merger or
conversion
Jan. 1 to
Dec. 31, 1971

Existing
branches
discontinued
or consoli­
dated
Jan. 1 to
Dec. 31, 1971

731

97

90

13,106

Branches in
operation
Dec. 31, 1971

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

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

19
310
6
102
4
15
0
5
0

4
0
0
0
10
0
16
0
0
0

3
0
0
1
9
0
2
0
0
0

209
53
225
87
2, 473
13
250
4
71
0

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

165
9
108
54
339
54
32
141
181
101

50
0
5
12
22
8
1
9
4
7

6
0
0
1
0
0
0
0
0
0

0
0
0
1
2
0
0
0
0
1

221
9
113
66
359
62
33
150
185
107

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

253
428
560
6
142
23
1
25
60
51

18
17
24
1
6
3
2
2
4
2

2
1
1
0
0
0
0
0
0
1

5
5
4
0
3
2
0
1
0
0

268
441
581
7
145
24
3
26
64
54

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

682
73
1,261
551 r
10
742
35
249
1,050
92

53
6
74
51
0
28
7
11
44
5

10
0
7
7
0
3
0
0
10
0

4
0
5
3
0
1
0
1
17
1

741
79
1,337
606
10
772
42
259
1,087
96

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

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

13
1
18
0
2
0
34
19
0
3
0
1

5
4
0
0
0
1
4
3
0
1
0
0

7
0
2
0
1
0
7
2
0
0
0
0

251
63
292
0
75
50
506
460
0
69
0
8

District of Columbia— all*...................................

101

5

0

0

106

TRevised.
♦Includes National and non-national banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
10




T able 8

D e novo branch applications o f National banks, by States, calendar 1971

Received*

Pending
Dec. 31, 1971

Abandoned

Rejected

Approved

United States................................................

1, 157

786

104

27

240

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

30
4
18
7
144
0
10
0
14
0

18
3
16
6
95
0
7
0
12
0

2
0
1
0
30
0
0
0
0
0

0
0
0
0
4
0
1
0
1
0

10
1
1
1
15
0
2
0
1
0

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

75
0
5
20
35
4
2
16
13
11

62
0
3
16
20
3
2
11
12
8

0
0
1
0
4
1
0
0
0
1

0
0
0
0
0
0
0
1
1
0

13
0
1
4
11
0
0
4
0
2

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

29
24
72
2
12
13
0
1
2
9

12
18
28
1
9
12
0
1
2
5

3
1
12
0
1
0
0
0
0
0

4
0
3
0
0
0
0
0
0
0

10
5
29
1
2
1
0
0
0
4

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

65
12
127
62
2
51
7
17
82
4

40
9
84
49
1
35
7
11
58
4

12
0
10
0
0
2
0
1
5
0

4
0
5
0
0
0
0
0
0
0

9
3
28
13
1
14
0
5
19
0

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

20
1
31
0
7
7
69
14
0
6
0
1

12
1
25
0
3
4
45
11
0
4
0
1

3
0
3
0
1
0
7
3
0
0
0
0

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

5
0
3
0
2
3
15
0
0
2
0
0

District of Columbia— a llf.....................................

17

15

0

1

1

♦Includes 268 applications pending as of December 31, 1970.
■(■Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

11

46&-4991
O— 72i------- 2




T able 9
De novo branches of National banks openedfor business, by community size and by size of bank, calendar 1971

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.........

140
277
100
58
53
40
32
31

Total...............

731

Less than 10.0......................................................................
44
10.0 to 24 .9............................................................................
133
25.0 to 49 .9............................................................................
69
50.0 to 99.9...........................................................................
61
100.0 to 999.9........................................................................
233
Over 1,000.0..........................................................................
191
---------Total...........................................................................
731

T able 10
Mergers * calendar 1971

Applications carried over from 1970.
Applications received 1971..................
Disposition of applications 1971:
Approved..........................................
Withdrawn.......................................
Applications pending December 1971
Transactions completed 1971:
Mergers.............................................
Consolidations.................................
Purchase of assets...........................
Total completed

Transactions
involving
two or more
operating banks

Other pursuant
to corporate
reorganization

12
59

5
46

56
3
12

32
0
19

38
7
10

29
0
0

55

29

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

12




,

IV. Bank Examinations and Related Activities
The National Bank Act requires that all National
banks be examined twice in each calendar year, but
the Comptroller, in the exercise of his discretion, may
waive one such examination in a 2-year period, or may
cause such examinations to be made more frequently,
if considered necessary. In addition, the District Code
authorizes the Comptroller to examine each non-National bank and trust company in the District of
Columbia.
For the year ended December 31, 1971, the Office
examined 6,587 banks, 22,889 branches, 522 facilities,
411 affiliates, 2,019 trust departments, and conducted
438 visitations and special examinations. In addition,
the Office received 182 applications to establish new
banks. That included 59 corporate reorganizations.
The Office also received 889 applications to establish
de novo branches and 10 applications to convert State
banks to National banking associations.
National bank examinations are designed to deter­
mine the condition and performance of banks, the
quality of their operations, the capacity of manage­
ment, and whether the banks are complying with Fed­
eral laws. All facets of an examination have, as their
end result, the determination of liquidity and sol­
vency, present and prospective, and the determination
of whether the bank is operating within the frame­
work of applicable banking laws and regulations. The
appraisal of a bank’ s loans and lending policies, in­
vestments and investment policies, and the ability and
capacity of its management constitute the most exact­
ing phases of the examination process.
Most of our training is directed toward the newlyappointed Assistant National Bank Examiner, the
newly-commissioned National Bank Examiner, and to
those commercial examiners who participate in the
examination of EDP departments. An increasing
amount of instruction is also being afforded to those
examiners who participate in the examination of for­
eign branches and affiliates of National banks.
A self-instructional program intended to acquaint
the new assistant examiner with the structure and re­
sponsibilities of the three federal banking supervisory
agencies, the operation of the country’s banking in­
dustry, and the more basic examining functions was
established during 1970. All new assistant examiners
must complete that program. After approximately 6




months, and at the option of Regional Administrators,
assistant examiners are assigned to attend Assistant Na­
tional Bank Examiner Schools. Training is given in
the reconcilment of correspondent bank accounts, in­
ternal controls and audit procedures, accrual account­
ing, proper documentation of loans, investments, and
other areas of the banking process. Instructors are gen­
erally experienced assistant and commissioned examin­
ers. College and university professors or bank econo­
mists lecture on subjects such as monetary and fiscal
policy and bank competition.
National Bank Examiner Schools for the benefit of
all newly-commissioned National Bank Examiners are
conducted on a semi-annual basis at the University of
Nebraska, Lincoln. Those 2-week seminars are very
important to the development of our examining per­
sonnel. The curriculum includes an in-depth study of
all types of loans, investment securities, bank borrow­
ings, fixed assets, capital adequacy, earnings, manage­
ment capabilities, and the examiner’s responsibilities
relative to branch, charter, and merger investigations.
Lectures are also presented on trust and international
examining, as well as enforcement responsibilities per­
taining to the various types of consumer legislation.
During 1971, the Office conducted 5-day seminars
in each of our 14 regions about the use of EDP tech­
niques in bank examinations. Instruction covers the
capabilities and the limitations of EDP systems in com ­
mercial banks. Approximately 350 examiners attended;
the program will continue until all examining per­
sonnel receive that necessary training. In addition,
examiners from each region have been selected for
specialized instruction in Advanced Electronic Data
Processing. Those examiners generally work independ­
ently of the commercial or trust examiner, and prepare
the EDP Report of Examination, copies of which are
sent to the banks examined.
Finally, and in keeping with past practice, the O f­
fice encourages its examiners to attend the various
graduate schools of banking, and to participate in the
host of courses offered by the American Institute of
Banking and Dun and Bradstreet. W e will continue to
review and update training programs and examining
techniques and to keep abreast of the ever changing
world of banking.

18

V. Litigation
New litigation challenging administrative actions or
rulings o f the Comptroller of the Currency continued
at a brisk pace through 1971. Nineteen new cases were
filed during 1971; 28 cases were pending on January 1,
1971; 21 cases were terminated during the year; and
26 cases were pending at the end of the year.
The Comptroller’s ruling was overturned by the
courts in only 2 of the 21 cases terminated. The more
significant cases involve the following subjects:

A . Administrative Enforcement
Authority
In the first case of its kind, a plaintiff has sought to
enjoin the Comptroller from enforcing provisions of
the Financial Institutions Supervisory Act of 1966
which permit the summary suspension of persons in­
dicted and convicted of certain felonies from partici­
pating in the affairs of the association. Manges v.
Camp, W.D. Texas, Civil No. SA 71-CA -362. Plaintiff
in the Manges case has asked that a 3-judge federal
court be convened to declare that the provision o f the
Supervisory Act which permitted the Comptroller to
exercise summary suspension authority, 12 U.S.C.
§ 1818(g) (1 ), is unconstitutional as an ex post facto
law, bill of attainder, unconstitutional delegation of
legislative power, and denial of due process. No pro­
ceedings had taken place in the case at year-end 1971,
other than the filing of the complaint. In a similar case,
involving the Federal Savings and Loan Insurance
Corporation, a 3-judge federal court in Philadelphia
determined, in 1970, that a challenge to the summary
suspension authority exercised by a bank regulatory
agency under the Supervisory Act could be raised only
by way of defense to a criminal prosecution for failure
to abide by the agency order. Hykel v. FSLIC, 317
F. Supp. 332 (E.D. Pa. 1970).

National Bank Act, 12 U.S.C. § 2 4 (Seventh), were
voluntarily dismissed by the plaintiffs in the district
courts after the Supreme Court had held that plaintiffs
had standing to bring the actions. A D APS O v. Camp,
Civil No. C -67-165, D. M inn.; The Wingate Corp. v.
Industrial National Bank of Rhode Island, Civil No.
3847, D. R.I. In a third lawsuit, challenging the inci­
dental power of a National bank to operate a travel
agency, the District Court had, at year-end 1971, taken
the case under advisement after argument on the
merits. Arnold Tours, Inc. v. Camp, Civil No.
67-372-C , D. Mass.

C. Other Banking Powers
1. Collective Investment Funds.— In a precedent­
making opinion which overruled a unanimous decision
by the Court o f Appeals for the District of Columbia,
the Supreme Court ruled, during 1971, that the GlassSteagall Act of 1933 prohibits the operation o f a
commingled managing agency account by First Na­
tional City Bank, despite the fact that the commingled
agency fund involved had received the specific approv­
al of the Comptroller of the Currency, the SEC, and
the Board o f Governors of the Federal Reserve System.
I C I v . Camp, 401 U.S. 617 (1971).
Writing for a divided Court, Mr. Justice Stewart
ruled that the operation of a collective investment fund
of the kind there approved by the regulatory agencies,
that is, in direct competition with the mutual fund
industry, involved a bank’s issuing, underwriting, sell­
ing, and distributing securities, in violation of sections
16 and 21 of the Glass-Steagall Act. Justices Harlan
and Blackmun dissented, with Mr. Justice Harlan ex­
pressing the view

T w o cases that allege that the data processing activi­
ties of particular National banks exceeded the author­

[T]here is, for me, an element o f illogic in the
ready admission by all concerned, on the one hand,
that a National bank has the power to manage,
by way of a common trust arrangement, those
funds that it holds as fiduciary in the technical
sense, and to administer separate agency accounts,
and in the rejection, on the other hand, of the

ity contained in the incidental powers clause o f the

propriety of the bank’s placing agency assets

B. Incidental Powers Cases

14




into a mutual investment fund. The Court draws
its decisional line between the two. I find it im­
possible to locate any statutory root for that line
drawing. T o use the Glass-Steagall Act as a tool
for that distinction is, I think, a fundamental
misconception of the statute.
Chief Justice Burger did not participate in the decision
because he had ruled on the case while a member of
the Court of Appeals.
2.
Interest Permissible to National Banks under
12 U.S.C. § 85.— Tw o cases, commenced during 1969
by the State of Idaho, against two National banks
headquartered in Boise, Idaho, were voluntarily dis­
missed by plaintiffs prior to trial. State of Idaho v.
First Security Bank, N.A. and Camp, Civil No. 1 -6 9 83 and State of Idaho v. Idaho First National Bank
and Camp, Civil No. 1-69-101. The State of Idaho
had alleged that the rates charged by the National
banks on credit card transactions were usurious and in
violation of 12 U.S.C. § 85, and that the Comptroller’s
ruling permitting the rates (12 C.F.R. § 7.7310) was
erroneous. At the request of the Comptroller, the De­
partment of Justice filed a brief amicus curiae in a
case filed against a National bank in Michigan, also
challenging the bank’s reliance upon the Comptroller’s
Interpretive Ruling 7.7310, that a National bank may
charge interest at the maximum rate permitted by
State law to competing State-licensed institutions.
Northway Lanes v. Hackley Union National Bank,
Civil No. 6072, W.D. Mich. Agreeing with the Com p­
troller’s interpretation of the interest rates allowed to
be charged by National banks under 12 U.S.C. § 85,
the district court filed an opinion during 1971 dismiss­
ing the action on the ground that National banks
were permitted to exact the charges involved because
competing institutions in Michigan— savings and loan
associations— were authorized to do so. At year-end
1971, plaintiffs had appealed the lower court deci­
sion but the case had not yet been argued before the
court of appeals.

Davie v. Camp, 431 F.2d 514 (5th Cir. 1970), cert,
denied, 401 U.S. 925 (19 7 1 ); Humble State Bank v.
Camp, Civil No. 69-H -1209, S.D. Texas. In Sterling,
the Supreme Court declined to review, and thus left
standing, a Fifth Circuit decision which had 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 Com p­
troller’ s approval was not invalidated either (1) by his
receipt of information from the applicant ex parte,
or (2) by a lack o f an opinion accompanying the
Comptrollers determination. In both the Somerset
and Pineland cases, the district court granted judg­
ment for the Comptroller after rejecting contentions
that New Jersey State law prohibited the chartering
of new National banks under the circumstances there
involved. The Humble case was voluntarily dismissed
by plaintiffs after the district court had denied plain­
tiffs’ request for a preliminary injunction and the new
bank involved had been open and operating for a
number of months.
2. Cases brought by Applicants.— At the end of 1971,
two cases were pending by organizers of proposed Na­
tional banks challenging the Comptroller’s denial of
their charter applications. Pitts v. Camp, 329 F. Supp.
1302 (D. S.C. 1971), appeal pending; Meisel, et al. v.
Camp, Civil No. 71C 4 3 7 (4 ), E.D. M o. The Pitts case
awaited appellate review after the district court had
granted judgment for the Comptroller on the ground
that his administrative record demonstrated that his
denial of the charter application was rational and in
accordance with law. The Meisel case was pending in
the district court at year-end on the Comptroller’s
motion for summary judgment. The decision of a dis­
trict court granting judgment for the Comptroller in a
third case challenging the refusal of the Comptroller
to charter a National bank become final during 1971
when plaintiffs did not appeal. Klanke v. Camp, 327 F.
Supp. 592 (S.D. Texas 1971).

E. Main Office Relocations
D. New Banks
1. Cases Brought by Competitors. T w o suits against
the Comptroller’ s Office in which existing banks al­
leged that the Comptroller’s chartering of new com ­
peting National banks was unlawful were pending at
the end of 1971. Somerset Trust Co. v. Camp, Civil
No. 659-70, D. N.J.; and Pineland State Bank v.
Camp, Civil No. 613-71, D. N.J. Tw o additional cases
resulted in final orders during the year upholding
the Comptroller’ s decision. Sterling National Bank of




1. Cases Brought by Competitors.— A decision
granting judgment for the Comptroller in a lawsuit
brought by a competitor to overturn the Comptroller’s
approval of the relocation of a National bank’s main
office became final during 1971. Midland Bank &
Trust Co. v. Camp and Hackensack Trust Co., N.A.
(D. N.J., Civil No. 1174-69). In the Midland case,
plaintiffs asked the Third Circuit Court o f Appeals
to reverse the district court judgment and overturn the
Comptroller’s approval of a relocation of the main

15

office o f a New Jersey National bank to a different town
and a simultaneous relocation of an existing branch
to the old main office site. However, the Court of
Appeals rejected plaintiff’s attempt at reversal in a
summary order affirming the lower court judgment.
2. Cases Brought by Applicants.— A federal district
court in Mississippi granted judgment for the Comp­
troller, during 1971, in a novel case wherein a rejected
applicant sought to have the court compel the Com p­
troller to approve applicant’s simultaneous applications
to relocate its main office to another municipality and
retain its former main office structure as a branch. First
National Bank of Southhaven v. Camp, N.D. Miss.,
Civil No. D C 7074-K. On the basis of the record made
before the Comptroller, the district court concluded
that the Comptroller had a rational basis for disapprov­
ing the application although he had received recom­
mendations of approval from each one of his reviewing
subordinates. Plaintiffs have asked the Court of Appeals
for the Fifth Circuit to reverse the district court judg­
ment.

F. Branches
State banking supervisors brought, or participated in,
a number of cases during 1971 challenging the Comp­
troller’s interpretation of the branch location provisions
of State statutes and the application of those provisions
to National bank branching under 12 U.S.C. § 3 6 (c).
In each decided case, the courts held the Comptroller’s
interpretation of the statute in question to be both
reasonable and correct. Thus, in First National Bank
of Fairbanks v. Camp, 326 F. Supp. 541 (D. D.C.
1971), the plaintiff bank filed an affidavit executed
by the State banking director and argued that the
Comptroller must follow the “ binding and conclusive”
authority of both the Alaska statute and the interpreta­
tion of that statute by the banking director. The court
granted judgment for the Comptroller, however, hold­
ing that the “ interpretative declarations of the State
banking director” are not “ statute law” which the
Comptroller is required to follow in considering Na­
tional bank branch applications. At year-end 1971,
plaintiffs had asked the Court of Appeals for the
District o f Columbia to reverse the district court
decision.
Similarly, plaintiffs in Commonwealth of Virginia
ex rel State Corporation Commission v. Camp, 333 F.
Supp. 847 (E.D. Va. 1971), contended that the Com p­
troller was bound to follow the interpretation of the
Virginia State banking authorities in construing the
term “ contiguous” as it was used in Virginia banking

16



statutes which permit the establishment o f branch
banks in certain “ contiguous” areas. The Comptroller
had declined to follow the State banking supervisor’s
interpretation of the language in granting a branch
for a Norfolk-headquartered National bank in H am p­
ton, Va. After reviewing the Comptroller’s ad­
ministrative record and some additional evidence, the
district court granted judgment for the Comptroller,
holding that the Comptroller was not bound to fol­
low an interpretation advanced by the Virginia State
Corporation Commission and that the Comptroller’s
resolution of the issue was both reasonable and correct.
At year-end 1971, plaintiffs had not appealed the lower
court decision.
Tw o additional cases involving a challenge by State
banking departments to the Comptroller’s decision
granting branch applications for National banks were
pending before lower courts at year-end 1971. First
National Bank of Southaven v. Camp, N.D. Miss.,
Civil No. 7145-K and Jackson v. The First National
Bank of Cartersville, N.D. Ga., Civil No. 2375. In the
Southaven case, the Mississippi banking supervisor in­
tervened in a lawsuit against the Comptroller, asserting
that the Comptroller’s interpretation of Mississippi
branching statutes to permit the establishment o f a
branch by a National bank in an unincorporated area
within 100 miles of its main office but not in the same
county or in a county adjacent to its home office county
was improper. In the Cartersville case, the Comptroller
intervened in a lawsuit brought initially by the super­
visor against a National bank for which the Comptrol­
ler had approved a branch office. In each case, the ac­
tions were pending in the district courts at the end of
the year on motions by the Comptroller for summary
judgment.
In First National Bank of Catawba County v. Camp,
448 F.2d 637, the Court of Appeals for the Fourth
Circuit upheld a district court judgment which had
overturned the Comptroller’s approval of a branch for
a National bank in North Carolina, holding that he
was bound to consider North Carolina’ s “ needs and
convenience” criteria in granting the National bank
branch application involved. The court held, contrary
to the Comptroller’s contention, that under the cir­
cumstances of the case there was no conflict between
the antitrust considerations of federal law and the
“ needs and convenience” requirements of State law.
Eleven additional cases, brought by competing
banks in 1971, resulted in voluntary dismissals or in
orders upholding the Comptroller’ s approval of chal­
lenged branch applications. Citizens National Bank of
Southern Maryland v. Camp, D. M d., Civil No. 7 0-

1 47 3-T ; Alaska State Bank v. Camp, D. Alaska, Civil
No. A 101 70; Cottage Grove State Bank v. Camp,
W .D. Wise., Civil No. 7 0 -C -5 0 ; First National Bank
of Crown Point v. Camp, N.D. Ind., Civil No. 7 0 -H 147; Citizens National Bank in Gastonia v. Wachovia
Bank& Trust Co. and Camp, 329 F. Supp. 585 (M .D .
N.C. 1971); Clermont National Bank v. Citizenshank,
N .A . and Camp, 329 F. Supp. 1331 (S.D. Ohio 1971);
Farmers National Bank of Annapolis, et al. v. Camp,
D. M d., Civil No. 71 -7 0 W ; First Citizens Bank & Trust
Co. v. Camp and Southern National Bank of North
Carolina, 329 F. Supp. 186 (E.D. N.C. 1971); Con­
cord National Bank v. Camp, M.D. N.C., Civil No.
C -1 3 0 -S -7 0 ; The Northwestern Bank, et al. v. Camp,
et al., W.D. N.C., Civil No. ST -635; and American
National Bank v. United Virginia/Seaboard National,
E. D. Va., Civil No. 436-70-N . In ruling for the Com p­
troller in each of those cases, the district courts re­
jected contentions (1) that the Comptroller was re­
quired to issue opinions or make findings in acting
upon applications, (2) that the Comptroller’s ad­
ministrative procedures were unfair, (3) that the
Comptroller incorrectly construed applicable statutes,
and (4) that the Comptroller’ s decision on the basis
of the facts before him was arbitrary and capricious.
At year-end 1971, plaintiff’s had appealed the An­
napolis, Citizens National, Alaska State, and Crown
Point cases.

G. Merger Cases
In 1971, the Comptroller was a party to four merger
cases. One case has been tried and is under submis­
sion, while in another the court has denied motions
for summary judgment filed by all parties. In the
other two cases, pre-trial discovery is underway with
no trial dates set.
In United States v. United Virginia Bankshares,
Inc., and Manassas Bank, N.A. and Camp, Civil No.
85-70-A , E.D. Va., the Court granted the Comp­
troller’ s motion to lift the statutory stay provided by
12 U.S.C. § 1849(b), rejecting the plaintiff’ s argu­
ment that it was precluded by the Supreme Court de­
cision in United States v. First City National Bank,
et al., 386 U.S. 361 (1967). That case has now been
tried on the merits and is awaiting decision.
In United States v. County National Bank of Ben­
nington, et al., Civil No. 6088, D. Vt., the Comptrol­
ler and the defendant banks moved for summary judg­
ment on the grounds that the Bennington area (the
geographical area designated by the plaintiff as that
within which the competitive effects of the merger




should be judged) was not, as a matter of law, eco­
nomically, demographically, or geographically of suf­
ficient size to constitute a “ section of the country”
within the meaning of § 7 of the Clayton Act. The
plaintiff filed a cross-motion for summary judgment
claiming that the Bennington area was a “ section of
the country” for that purpose. The Court, however,
denied all motions for summary judgment on the
grounds that there were unresolved issues of material
fact (330 F. Supp. 155). Since that decision, all par­
ties have stipulated to substantially all of the facts in
the case and have jointly petitioned the court for a re­
hearing and reconsideration of cross-motions for sum­
mary judgment to determine this legal question.
On August 23, 1971, the Department of Justice filed
suit to block the consolidation of The Connecticut Na­
tional Bank, Bridgeport, Conn., and The First New
Haven National Bank, New Haven, Conn., alleging
that the consolidation would eliminate actual and po­
tential competition between the consolidating parties
in violation of § 7 of the Clayton Act. United States v.
The Connecticut National Bank and The First New
Haven National Bank, et al., Civil No. 14583, D. Conn.
Discovery is in progress, and no trial date has been set.
On October 22, 1971, the Department of Justice
filed suit to block the merger of Washington Trust
Bank, Spokane, Wash., into the National Bank of
Commerce and its parent holding company, the M a­
rine Bancorporation, both of Seattle, Wash. The suit
alleges that actual and potential competition between
the two banks will be eliminated by the merger, in
violation of § 7 of the Clayton Act. The complaint al­
leges that the merger would eliminate the National
Bank of Commerce as a potentially substantial com ­
petitor in the Spokane Metropolitan Area, and would
eliminate the Washington Trust Bank as a potentially
substantial competitior in that part of Spokane County
outside of the Spokane Metropolitan Area and in un­
specified banking markets in other parts of eastern
Washington. The suit further alleges that the merger
would reduce competition by eliminating the Wash­
ington Trust Bank as a potential member of a new
banking organization capable of entering other un­
specified markets throughout the State, and would
eliminate actual and potential competition between the
two merging banks in supplying correspondent bank­
ing services in eastern Washington. United States v.
Marine Bancorporation, The National Bank of Com­
merce of Seattle, and Washington Trust Bank, et al.,
Civil No. 237-71C2, W.D. Wash. Pre-trial discovery
is underway, and no trial date has been set.

17

VI. Fiduciary Activities of National Banks
During 1971, 32 applications for permits to act in
fiduciary capacities were received, and 19 were
approved. In addition, 3 State banks with trust de­
partments converted to National banks. On the other
hand, during the year, several units were merged or
consolidated into others. As a result, at the end of 1971,
1,943 National banks had fiduciary powers, the same
number as at the end of the preceding year. Even so,
the number o f accounts and total assets subject to the
supervision of this Office continued to grow. (See
Appendix Table B -41.)
Several new challenges in trust department super­
vision were isolated, and steps initiated to meet them.
Early in the year, representatives of the three banking
agencies were invited to meet with officials of the Secu­
rities and Exchange Commission to discuss problems
relating to the performance of stock transfer activities
by banks. At the request of the Commission, repre­
sentatives of the banking agencies took steps to develop
a system for reporting stock transfer delays by banks,
to be used, by the banking agencies, as a means of
supervision and, by the Commission, as a source of
statistics. However, the Commission later indicated
that it would prefer to have supervisory authority over
banks in that area. Due to the improvement in per­
formance of bank transfer agent activity, the report­
ing system was not instituted. In the event that serious
delays again began to occur on effecting transfers by
National banks, such a system may be instituted, with
the management of any bank experiencing a signifi­
cant delay being required, periodically, to advise this
Office of the extent of the delay, and the steps being
taken to correct it.
Continued attention was given to National banks’
choice of brokerage houses for trust department pur­
chases and sales of securities. It appears to this Office,
based upon the reports of examination of trust depart­
ments, that the choice of brokers by National banks, in
accounts where that choice is the responsibility o f the
bank, is, almost without exception, made for consid­
erations of best execution of orders and such considera­
tions solely concerned with the best interests o f the
accounts.

18




In September, proposed changes in Regulation 9
were published in the Federal Register. The purpose
of those proposals was threefold, (1) to eliminate Na­
tional banks’ authority to establish common trust
funds for agency accounts, (2) to incorporate expressly
into the Regulation previous interpretations of its pres­
ent language, and (3) to modify the rules concerning
the publication of reports and information concern­
ing collective investment funds. Numerous comments
had been received from interested parties by year-end,
and it was hoped that the revisions would be made
effective by early in 1972.
During the year, the Supreme Court, in the case of
Investment Company Institute v. Camp, decided that
the Commingled Investment Account, established by
the First National City Bank of New York, with the
approval of this Office, contravened the Banking Act
of 1933. Accordingly, the account was liquidated. The
decision did not, in our opinion, compel an amend­
ment of Regulation 9; however, it did furnish the
Office with an occasion to amend it, by removing the
authority to invest managing agency accounts collec­
tively. The common trust fund authorized by that
section o f the Regulation was, in the opinion of the
SEC, a non-conforming investment company; in addi­
tion, few banks had expressed any interest in establish­
ing such a fund. For those reasons it was proposed to
delete the authority. However, it remains the opinion o f
this Office that it is in the public interest for banks to
be able to make their investment expertise available
to persons of modest means, and it is hoped that legis­
lation will be enacted to that end.
Training trust examiners continued to receive a high
priority. During the year, seven men were promoted to
the rank o f Representative-in-Trusts, and six to the
intermediate position of Associate. This Office noted a
fall-off in resignations, so, a school for new Assistants in
Trusts was not deemed necessary; however, one is
planned for the latter half of 1972. In addition, because
of the pending changes in Regulation 9, the conference
for Representatives-in-Trusts that would have been
held in 1971 was delayed until the first part of 1972.

VII. International Banking and Finance
The growth of the international activities of National
banks slowed in 1971, evidencing the caution bom of
the nearly constant monetary uncertainties which
plagued the world’s financial markets. That conserva­
tive approach enabled National banks to avoid any
unusual losses due to the rapid and often unpredictable
variations in exchange and interest rates.
National banks continued to expand their overseas
branch networks although not at the rate experienced
in recent years. Seventeen banks opened 47 foreign
branches (nine opened their first foreign branches)
while 16 branches were closed or converted to sub­
sidiary banking operations, resulting in a net increase
of 31 foreign branches. That compares to an average
net annual increase of 73 foreign branches during the
preceding 3 years. The greatest activity continued to be
in Nassau, Bahamas, where nine new branches were
opened, compared to 23 the year before. A total of 54
National banks now operate Nassau branches. The
greatest concentration of assets continued to be in
the United Kingdom, primarily in London, where 18
National banks have branches. Assets in the United
Kingdom grew 25.4 percent during the year to $23.1
billion, 45.6 percent of all foreign branch assets. Signif­
icant growth also occurred in continental Europe where
a 35.2 percent increase to $11.0 billion in assets was
recorded. The percentage increases for 1970 were 31.2
percent and 70.2 percent respectively. At year-end, 68
National banks were operating 528 branches with total
assets of $50.6 billion. In addition, 21 National banks
had 32 approved, but unopened, foreign branches.
National banks also continued to expand through
direct investments made by their Edge Act and agree­
ment corporations. Some 35 National banks whollyowned 54 Edge corporations and one agreement cor­
poration with total assets as of December 31, 1971, of
4.1 billion, 73.9 percent of total assets of all such cor­
porations. In addition, a number of National and other
banks jointly own Edge corporations, and some Na­




tional banks have access to Edge corporations owned
by their parent bank holding companies. A significant
development in recent years has been the establishment
by major banks of additional Edge corporations in
cities other than New York, principally in Miami, San
Francisco, Chicago, and Houston.
Examinations of the international activities of Na­
tional banks were conducted both in domestic offices
and at overseas branches and regional offices. During
the year, 45 men examined 202 branches o f 16
banks in 27 countries. In addition to their regular
examination duties, examiners often met with local
banking authorities for mutually interesting and bene­
ficial discussions. In one case, two examiners conducted
a 1-day seminar in Djakarta on bank examination
techniques and procedures which was attended by
about 75 Indonesian examiners.
A number of foreign bankers and regulatory officials
visited the International Division during the year. The
visitors expressed interest in current banking trends,
particularly holding companies, truth-in-lending legis­
lation, and the attitudes of regulatory officials regard­
ing those topics. The Division provided informal train­
ing for visiting foreign examiners in sessions lasting
from 3 days to 2 weeks.
International examination techniques and proce­
dures were improved through a major revision of the
International Section of the Comptroller’s Handbook
of Examination Procedure. Five examiners received in­
tensive training at the American Bankers Association’s
2-week School for International Banking.
A major revision of the Comptroller’ s International
Operations Regulation, 12 C FR 20, resulted in sub­
stantially reducing the reporting requirements of Na­
tional banks pertaining to their international activities.
Minor changes were also made in the form for the
Foreign Branch Report of Condition, which foreign
branches of National banks annually file with the
Comptroller.

19

VIII. Administrative and Management
Developments

During 1971, the Office of the Comptroller of the
Currency continued to refine administrative proce­
dures to meet the needs of regional and headquarters
staffs.
The Fiscal Management Division experienced an
eventful year owing to the general uncertainty of eco­
nomic conditions. For several years, the Comptroller’ s
Office has invested a great deal of time and effort in
the development and improvement of a financial in­
formation system responsive to the needs of manage­
ment. The economic uncertainties of the last 2 years
demonstrate the merits of that investment. As with
most businesses and other government agencies, the
Comptroller’ s Office faced rapidly rising costs and a
slower rate of income growth. Because of that, the
Comptroller faced the possibility of increasing assess­
ment rates and other fees or of initiating a cost control
program. Although the application fee for charters,
mergers, and consolidations was increased, emphasis
was placed on cost control. The financial information
system provided management with the data necessary
to make decisions that resulted in the successful cost
control program. (See Section IX .) That success can
be measured by the fact that the rise in expenses was
less than 1 percent greater than the increase in income.
A change in the method of investing assessment
funds, in July 1971, generated an additional $62,000

offset by savings in travel costs. Usually, those reloca­
tion costs are offset during the first year of establish­
ment, and genuine savings accrue during later years.
Through a reorganization of the accounting branch,
and further refinement and modification of operating
procedures, the Fiscal Management Division was able
to reduce its staff for the fourth consecutive year. The
staff was reduced by three employees, resulting in
recurring annual salary savings of $40,000. The overall
staff reduction in 4 years, amounts to 13 employees, or
a savings o f annual salary costs in excess of $100,000.
The Personnel Management Division, in 1971, estab­
lished a personnel management evaluation program to
improve personnel management practices. Regular on­
site reviews in the Washington headquarters and each
regional office every 3 years were initiated.
The first in-house supervisory/managerial training
courses were held in Washington in late 1971. The
program was designed to help supervisors and man­
agers update and reinforce their skills to better achieve
Office objectives. In the course, discussion of personnel
management and other internal administrative re­
sponsibilities was supplemented by a handbook for
supervisors, developed within the Office and designed
to give a broad view of the managerial responsibilities
necessary for more effective utilization of human
resources.

in interest income for the year. Under the earlier

T o improve communication with field offices about

method, interest income would have actually decreased.

personnel matters, all formal issuances were systemati­

Since its inception, the Fiscal Management Division

cally consolidated and were distributed to regional ad­

has followed a policy aimed at keeping funds fully in­

ministrators. That has proved to be a ready reference

vested in order to maximize interest income.

for implementing personnel management programs.

Effective January 1, 1971, a revision of relocation

During 1971, the Office continued to operate under

allowance regulations substantially increased allow­

personnel ceilings to facilitate minimum staffing for

ances for real estate transactions, to more equitably

each organizational segment. In response to the Presi­

compensate an employee required to relocate for the

dent’s recent economic program and the Office of

benefit o f the Office. Most transfers during 1971 were

Management and Budget’s request to reduce the aver­

in connection with the establishment of sub-regional

age grade by one-tenth of a grade before June 30,1972,

offices; the cost of relocating employees is more than

further restrictions were established in late 1971. Those

20




measures increased the necessity for quality staffing and
effective manpower utilization. Also, efforts were re­
newed to increase the number of financial interns in
the cooperative work-study program. The program,
designed to train and develop college students for fu­
ture bank examiner positions, has proven an effective
means of recruiting minority personnel.
Additional progress was realized in the Comptroller’ s
equal employment opportunity program during 1971.
The number of minority employees increased signifi­
cantly. At year-end, there were over 150 minority group
employees on the roles, and substantial achievements
had been made in the advancement of minority
individuals.
A guide for determining grade levels of National
bank examiner positions was implemented in 1971.
The guide includes descriptions of typical responsibili­
ties of National bank examiners and provides for a bet­
ter matching of skill levels with bank examination as­
signments, thus assuring more effective manpower
utilization. Approximately 80 percent of our commis­
sioned examining force is covered by the guide. A
study was initiated which will result in descriptions of
typical trust examiner positions.
During 1971, pilot staffing patterns were developed
for several regional offices. Based upon systematic
analysis of workload, manpower requirements and skill
levels were projected for these regions. That will per­
mit a more meaningful and systematic review by R e­
gional Administrator as a basis for more effective
manpower planning. It will also provide top manage­
ment with comparative data of regional workload and
manpower requirements necessary to meet statutory
requirements.
During 1971, employees received $66,227 for their
participation in the incentive awards program. Seven­
teen awards were granted for adopted suggestions and
special achievements which resulted in $108,750 in
tangible savings. High quality increases, in recognition
of superior performance, were approved for 167
employees.
The overall thrust of the activities of the Administra­
tive Services Division was toward maintaining a highly
responsive and effective organization and monitoring
the implementation of established administrative pro­
grams, policies, and procedures.
During 1971, regional offices in Boston and Denver
were relocated, completing the planned relocation and
upgrading of regional offices into modern facilities.
Also, seven subregional offices were relocated, four were
newly established, and three were closed.
A visitation program to regional offices was initiated




to better acquaint regional personnel with records re­
tention and disposition requirements and to encourage
greater utilization of federal records centers for stor­
age and safekeeping of records. A new personal prop­
erty inventory and control system was implemented,
based upon a new, standardized numbering system that
greatly simplifies the physical inventory process and
produces more accurate property records. A completely
revised Comptroller’s Manual for National Banks was
published and distributed in 1971. A major revision of
the Comptroller’s Handbook of Examination Proce­
dures is currently underway.
The function of controlling the issuance and distri­
bution of publications was assumed by the Office of
Administrative Assistant to the Comptroller. Also, sig­
nificant changes occurred in the Comptroller’s han­
dling of information available to the public under the
Securities and Exchange Commission Act of 1934.
Henceforth, such information will be available at the
Federal Deposit Insurance Corporation and in each
of the Comptroller’s regional offices. That change re­
sulted in modifying administrative methods and pro­
cedures regarding receipt and distribution of docu­
ments, and maintenance of information files at FDIC.
New procedures were devised and implemented with
FDIC cooperation.
In addition to reviews made in the Washington of­
fices, the Internal Audit Division made comprehensive
reviews in three regional offices and two of the five
computerized payroll centers. O f a total o f 81 recom­
mendations in audit reports, 59 were accepted.
Consistent with the Comptroller’s request for opera­
tional efficiency with a minimum of positions, the In­
ternal Audit Division has, in the last 3 years, reduced
total salary costs by $17,000, despite several statutory
pay increases and grade promotions. That was accom­
plished by successful recruitment of highly qualified
personnel and a decrease in the work force, through
attrition.
In 1971, the Management Services Division partici­
pated in the successful automation of foreign branches
data. Both basic bank information and related re­
ports of condition now are handled in a more efficient
and accurate way. Other automated projects com­
pleted encompass such diverse areas as common trust
fund survey data, bank liquidity data, and a structured
file for all National banks.
The

year’s management improvement program

yielded tangible savings in the amount of $184,525,
along with several refined procedures in daily office
operations.
21

OFFICE OF THE COMPTROLLER OF THE CURRENCY

IA D V I S O R S I




■EXAMINING

IC O R P O R A T E I

■AD M IN ISTRATIVE!

IX. Financial Operations of the Office of the
Comptroller of the Currency

During 1971, the Office of the Comptroller of the
Currency continued the cost control program imple­
mented during the last half of 1970 to combat rising
expenses. That cost control program has been very
effective, as detailed below, and has resulted in a net
income for the year of $2,601,000, which is only
$55,000 lower than the previous year. The net result
is that increased costs have been kept in line with in­
creased revenues.
Total income for the year was $40.6 million, an in­
crease of 10.08 percent over 1970. That increase is
principally due to the $3.1 million rise in assessment
income, resulting from a $26.9 billion rise in National
bank assets. National bank assets affecting 1971 assess­
ment income rose 8.55 percent, compared to an in­
crease of 5.88 percent the prior year.
Revenue from trust examinations for the year in­
creased $208,000, to $2.2 million. One thousand six
hundred and sixty-five examinations were made in
1971, compared to 1,590 in 1970. Branch investiga­
tions continued to show a high rate of activity, but
income decreased by $25,000. Eight hundred and
seventy-two branch applications were received in 1971,
compared to 932 in 1970.
Income from new charter applications increased
$221,000, while merger and consolidation fees increased
by $93,000. Those increases were mainly due to higher
application fees which became effective January 1,
1971. New charter income was also higher, because of
a greater number of applications.
Interest on investments, while continuing to be a
significant income factor, increased only $29,000, to a
total of $1,866,000. That represents almost 72 percent
of the excess o f revenue over expenses for the year.
The greatest single factor contributing to the significant




drop in the year-to-year increase in interest income
was the substantial decline in Treasury bill yields
(prior to 1971, the growth in interest income exceeded
25 percent for three consecutive years).
All other income categories remained fairly constant
with 1970 levels.
Total expenses amounted to $38 million, an increase
of $3.8 million as compared to $34.2 million the pre­
vious year. That 11.03 percent increase, which is only
0.95 percent greater than the increase in revenue, rep­
resents a significant reversal of the trend in 1970,
when the increase in expenses was 5.9 percent greater.
The reduction in the year-to-year percentage increase
for expenses is the result o f management cost control
actions instituted during the last half of 1970 to main­
tain a proper balance between income and expense.
Salaries, personnel benefits, and travel expenses
amounted to $35.7 million, or 94.1 percent of the total
expenses for the year. Those expenses amounted to
$32.2 million in 1970. The 6 percent congressional pay
raise, which became effective January 1971, was the
principal reason for the rise in that category o f ex­
penses. Travel expenses increased by only $221,000,
which is the smallest annual increase in several years.
The remaining expenses totaled $2.2 million, an in­
crease of $236,000, which represented higher costs for
printing and communications. Those expenses also in­
cluded a contribution of $122,000 to provide financial
assistance to the Presidential Commission on Financial
Structure and Regulations.
The equity account is in reality a reserve for con­
tingencies. Transfers of $2.6 million increased the
equity to $22.5 million at year-end. That represents a
7-month reserve for operating expenses, based on the
level of expenses over the last 6 months of 1971.

T able 11
OFFICE OF T H E C O M PTR O LLER OF T H E C U R R E N C Y
BALANCE SHEET
Assets
Current assets:
Cash.......................................................................................................................................................................
Obligations of U.S. Government, at cost adjusted for amortization of discount and premium
(approximates market value)..................................................................................................................
Accrued interest on investments.................................................................................................................
Accounts receivable........................................................................................................................................
Travel advances...............................................................................................................................................
Prepaid expenses and other assets..............................................................................................................

December 31
1971

1970

$264, 986
958
399
056
105
655

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

Total current assets.....................................................................................................................................

8, 177, 159

8, 524, 987

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

20, 742, 646

17,284,418

863, 620
424, 288

872, 788
398, 784

1, 287, 908
671, 564

1,271,5 72
581, 368

616, 344

690, 204

$29, 536, 149

$26, 499, 609

Liabilities and Comptroller’s Equity
Current liabilities:
Accounts payable and other accruals..............................................
Taxes and other payroll deductions.................................................
Accrued travel and salaries................................................................

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

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

Total current liabilities. . ...............................................................
Accumulated annual leave..........................................................................
Closed receivership funds (Note 2 ) ...........................................................

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

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

Total liabilities...................................................................................
Comptroller’s equity (Note 3 )....................................................................

6, 990,811
22, 545, 338

6, 554, 820
19, 944, 789

Total liabilities and Comptroller’s equity..................................

$29, 536, 149

$26, 499, 609

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

Less accumulated depreciation

Total assets

See Notes at end of Section.

24




6, 737,
516,
169,
406,
82,

$67,875

T able 12
OFFICE OF TH E C O M P TR O LLE R OF TH E C U R R EN CY
STA TEM E N TS OF REVENUE, EXPENSES, AND C O M P TR O LLE R ’ S E Q U IT Y
Year ended December 31
Revenue (Note 1):
Semi-annual assessments.............
Examinations and investigations
Investment income.........................
Examination reports sold.............
Other.................................................

1971
$34, 439, 052
3,356,0 12
1,866, 431
517, 680
374, 741

1970
$31,336,
2, 927,
1, 836,
500,
238,

670
733
908
520
041

40, 553, 916
Expenses:
Salaries............................................................................................................................
Per diem.........................................................................................................................
Retirement and other contributions (Note 3 ) .....................................................
Travel..............................................................................................................................
Rent and maintenance (Note 3 ) .............................................................................
Communications..........................................................................................................
Printing, reproduction and subscriptions.............................................................
Employees education and training.........................................................................
Moving and shipping.................................................................................................
Depreciation (straight-line method).......................................................................
Office machine repairs and rentals........................................................................
Supplies..........................................................................................................................
Remodeling.............................................................................................................
Grant to Presidential Commission on Financial Structure and Regulation
Other...............................................................................................................................

36, 839, 872

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

24,
3,
1,
1,

37, 953, 367
Excess of revenue over expenses..................
Comptroller’s equity at beginning of year
Comptroller’s equity at end of year

157, 573

781, 477
604, 529
949, 486
868, 782
509, 129
369, 040
194, 533
243, 631
98, 136
125, 280
96, 939
89, 347
68, 963
50, 000
134, 293

34, 183, 565

2, 600, 549
19, 944, 789

2, 656, 307
17, 288, 482

$22, 545, 338

$19, 944, 789

122, 000

See Notes at end of Section.




25

T able 13
OFFICE OF TH E C O M P TR O LLE R OF T H E C U R R E N C Y
STA TEM E N TS OF CHANGES IN F IN AN C IAL P O SITIO N
Year ended December 31
Financial resources were provided by:
Excess of revenue over expenses...................................................................................................................
Add income charges not affecting working capital in the period:
Additions to accumulated annual leave................................................................................. ...........
Depreciation............................................. , ...............................................................................................
Amortization of premium and discount on long-term U.S. Government obligations (net).
Net loss on sales of fixed assets.............................................................................................................

1971

1970

$2, 600, 549

$2, 656, 307

347, 562
128, 722
17, 923
12, 656

402, 145
125, 280

Working capital provided by operations for the period........................................................................
3, 107, 412
Long-term U .S. Government obligations:
Redeemed...................................................................................................................................................
218,881
Transferred to current assets................................................................................................................................................
Proceeds received on sale of fixed assets.....................................................................................................
4, 737

” ” io,’ i48
3, 193, 880
........................
3, 470, 874
17, 008

Total..................................................................................................................................................................

3, 331, 030

6, 681, 762

Financial resources were used for:
Purchase of long-term U.S. Government obligations.............................................................................
Payments of accrued annual leave...............................................................................................................
Purchase of furniture and fixtures................................................................................................................
Purchase of office machinery and equipment...........................................................................................
Payments of closed receivership funds (net).............................................................................................

3, 695, 032
137, 793
36, 048
36, 207
1, 292

7, 640, 010
138,913
106,580
48,172
1,704

Total.................................................................................................................................................................

3, 906, 372

7, 935, 379

Decrease in working capital....................................................................................................................................

($575, 342)

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

$197,111
(505, 457)
61, 329
( I l l , 383)
(2 ,0 4 7 )
12,619

($128,665)
(1, 175, 738)
133, 306
203, 424
32,554
16,542

Total.................................................................................................................................................................

(347,828)

(918,577)

(Increase) decrease in current liabilities:
Accounts payable and other accruals..........................................................................................................
Taxes and other payroll deductions............................................................................................................
Accrued travel and salaries............................................................................................................................

33, 171
(1 1 ,6 6 4 )
(249, 021)

(10, 236)
6 ,5 2 4
(331, 328)

Total..................................................................................................................................................................

(227, 514)

(335, 040)

Decrease in working capital....................................................................................................................................

($575, 342)

($ 1 ,2 5 3 ,6 1 7 )

See Notes at end of Section.

26



($1, 253, 617)

OPINION OF INDEPENDENT ACCOUNTANT
T o the Comptroller of the Currency
Office of the Comptroller of the Currency
In our opinion, the accompanying balance sheets, the related statements of reve­
nue, expenses and Comptroller’s equity and the statements of changes in financial
position present fairly the financial position of the Office of the Comptroller of the
Currency at December 31, 1971 and 1970, the results o f its operations and the changes
in financial position for the years then ended, in conformity with generally accepted
accounting principles consistently applied. Our examinations of these statements were
made in accordance with generally accepted auditing standards and accordingly in­
cluded such tests of the accounting records and such other auditing procedures as we
considered necessary in the circumstances, including confirmation of securities owned
by correspondence with the depositary.
PRICE W A TE R H O U SE & CO.
ashington D.C.
February. 2, 1971.

W

,

N otes to F inancial S tatements

Note 1— Organization and Operations
The Office of the Comptroller of the Currency was cre­
ated for the purpose of establishing and regulating a Na­
tional Banking System. The National Currency Act of 1863,
rewritten and reenacted as The National Banking Act of
1864, created the Office, provided for its supervisory func­
tions and the chartering of banks. The income of the Comp­
troller’s Office is derived principally from assessments paid
by the National banks and interest on investments in U.S.
Government obligations. Assessments paid by National banks
are not construed to be Government funds. No funds de­
rived from taxes or Federal appropriations are allocated to
or used by the Comptroller’s Office in any of its operations.

Note 2— Closed Receivership Funds
This amount represents a liability for unclaimed depositors
account balances, resulting principally from the failure and
closing of certain National banks during the 1930’s. At such
time the assets of the banks were transferred to the custody
of the Comptroller to be held in trust for their depositors.

These funds have been invested in government securities
pending claim by depositors.

Note 3— Commitments and Contingencies
Regional and sub-regional offices of the Comptroller of the
Currency lease office space under agreements generally ex­
tending to 5 years. As of December 31, 1971, total lease com­
mitments of these offices approximated $400,000 annually.
At December 31, 1971, the Washington, D .C., office located
in Federal Government facilities was occupied on a rentfree basis.
The Office of the Comptroller contributes to the Civil
Service Retirement plan for the benefit of all of its eligible
employees. The plan is participatory, with 7 percent of salary
being contributed by each party.
Various banks in the District of Columbia have deposited
securities with the Office of the Comptroller of the Currency
as collateral for those banks entering into and administer­
ing trust activities. These securities are not assets of the
Comptroller and accordingly are not included in the ac­
companying financial statements.

27
463-499 O— '72-

-3







APPENDIX A

Merger Decisions, 1971

Merger* Decisions, 1971
/.

M ergers consummated, involving two or more operating banks

Jan. 1, 1971:
National Bank of Westchester, White Plains, N .Y.
The Millerton National Bank, Miller ton, N .Y.
Merger..................................................................................
Jan. 4, 1971:
First National Bank in Indiana, Indiana, Pa.
Kiski Valley National Bank, Vandergrift, Pa.
Purchase............................................................................
Jan. 11, 1971:
American National Bank, Bakersfield, Calif.
Santa Ynez Valley Bank, Solvang, Calif.
Merger..................................................................................
Jan. 22, 1971:
The National State Bank, Elizabeth, N.J.
The First National Bank of Milford, Milford, N.J.
Merger..................................................................................
Jan. 29, 1971:
First National Bank of South Carolina, Columbia,
S.C.
Bank of Clinton, Clinton, S.C.
Merger..................................................................................
Jan. 29, 1971:
North Carolina National Bank, Charlotte, N.C.
Bank of Washington, Washington, N.C.
Merger..................................................................................
Jan. 29, 1971:
The First National Bank of Maryland, Baltimore,
Md.
Patapsco National Bank in Ellicott City, Ellicott
City, Md.
Merger..................................................................................
Feb. 1, 1971:
Garden State National Bank, Hackensack, N.J.
North Jersey National Bank, Jersey City, N.J.
Consolidation......................................................................
Feb. 5, 1971:
Peoples National Bank of New Jersey, Westmont,
Haddon Township, N.J.
Broadway National Bank & Trust Co. of Pitman,
Pitman, N.J.
Merger..................................................................................
Feb. 16, 1971:
The National Bank & Trust Co. of Norwich, Nor­
wich, N .Y.
The Farmers National Bank of Deposit, Deposit,
N .Y.
Merger..................................................................................
Mar. 1, 1971:
The First National Bank of Atlanta, Atlanta, Ga.
First Bank of South DeKalb, Decatur, Ga.
Merger..................................................................................
Mar. 1, 1971:
The First National Bank of Atlanta, Atlanta, Ga.
First National Bank of Doraville, Doraville, Ga.
Merger..................................................................................

Page
34

35

37

38

39

40

42

44




Page

52

53

55

56

57

59

P a.

46

48

49

Provident Trust Co., Pittsburgh, Pa.
Purchase...............................................................................
May 24, 1971:
The First National Bank of Belleville, Belleville,

60

in .

The St. Clair National Bank of Belleville, Belle­
ville, 111.
Merger..................................................................................
May 28, 1971:
Marine Midland Bank-Eastern, N .A ., Troy, N .Y .
Catskill National Bank & Trust Co., Catskill, N .Y.
Merger.............................................................. ...................
June 1, 1971:
United Virginia Bank/Seaboard National, Norfolk,

62

64

V a.

51

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

30

Mar. 5, 1971:
First National Bank of South Jersey, Egg Harbor
Township, N.J.
The First National Bank of Bordentown, Bordentown, N.J.
Merger..................................................................................
Mar. 8, 1971:
The First National Bank & Trust Co. of Augusta,
Augusta, Ga.
Southgate National Bank of Richmond County,
Augusta, Ga.
Merger..................................................................................
Mar. 19, 1971:
Puget Sound National Bank, Tacoma, Wash.
National Bank of Mason County, Shelton, Wash.
Merger..................................................................................
Mar. 20, 1971:
The Clinton County National Bank & Trust Co.
of Wilmington, Wilmington, Ohio
The Port William Banking Co., Port William,
Ohio
Purchase...............................................................................
Apr. 2, 1971:
Northeastern Pennsylvania National Bank &
Trust Co., Scranton, Pa.
Pocono Bank, East Stroudsburg, Pa.
Merger..................................................................................
Apr. 5, 1971:
Peoples National Bank of Washington, Seattle,
Wash.
Bank of Vancouver, N ?
A., Vancouver, Wash.
Purchase...............................................................................
Apr. 30, 1971:
Western Pennsylvania National Bank, Pittsburgh,

Eastern Shore Citizens Bank, Onancock, Va.
Merger..................................................................................
June 4, 1971:
American National Bank & Trust, Montclair,
N.J.
The Second National Bank of Phillipsburg, Phillipsburg, N.J.
Merger..................................................................................

65

67

June 4, 1971:
New Jersey Bank (N .A.), Clifton, N.J.
Phillipsburg Trust Co., N .A ., Phillipsburg, N.J.
Merger..................................................................................
June 15, 1971:
First National Bank in Manitowoc, Manitowoc,
Wis.
State Bank of Francis Creek, Francis Creek, Wis.
Purchase................................................
June 25, 1971:
United States National Bank, San Diego, Calif.
Hollywood National Bank, Los Angeles, Calif.
Merger..........................................
June 30, 1971:
City Trust Co., Bridgeport, Conn.
The Waterbury National Bank, Waterbury, Conn.
Consolidation......................................................................
July 1, 1971:
First National Bank of Archbold, Archbold, Ohio
The Farmers State Bank Co., Fayette, Ohio
Consolidation.....................................................................
July 30, 1971:
First Union National Bank of North Carolina,
Charlotte, N.C.
Bank of Rocky Mount, Rocky Mount, N.C.
Merger..............................................
July 31, 1971:
United National Bank of Vermillion, Vermillion,
S. Dak.
Rushmore State Bank, Rapid City, S. Dak.
The Security National Bank of Viborg, Viborg,
S. Dak.
Consolidation.....................................................................
Aug. 2, 1971:
The Bank of California, N .A., San Francisco,
Calif.
Inland Bank, Pomona, Calif.
Merger.................................................................................
Aug. 31, 1971:
First National Bank of South Carolina, Columbia,
S.C.
Bank of Kershaw, Kershaw, S.C.
Merger........................................................................
Aug. 31, 1971:
Maryland National Bank, Baltimore, Md.
First National Bank & Trust Co., Havre de Grace,
Md.
Merger.................................................................................
Sept. 10, 1971:
Peoples National Bank of New Jersey, Westmont,
Haddon Township, N.J.
The First National Bank of Tuckerton, Tuckerton,
N.J.
Merger.................................................................................
Sept. 10, 1971:
The First National Bank of Eastern Pennsylvania,
Wilkes-Barre, Pa.
The First Stroudsburg National Bank, Stroudsburg,
Pa.
Merger..................................................................................
Sept. 10, 1971:
The St. Lawrence County National Bank, Canton,
N .Y .
United Bank, Star Lake, N .Y.
Merger..................................................................................
Sept. 20, 1971:
The Farmers National Bank of Malone, Malone,
N .Y .
The First National Bank of Winthrop, Winthrop,
N .Y.
Merger...............................................................................
Sept. 23, 1971:
Southern California First National Bank, San
Diego, Calif.
Newport National Bank, Newport Beach, Calif.
Merger..................................................................................




Page

68

70

71

Page

Sept. 24, 1971:
Citizens National Bank of Morris County, Succasunna, N.J.
The Warren County National Bank, Washington,
N.J.
Merger..................................................................................
Sept. 30, 1971:
First National Bank of South Jersey, Egg Harbor
Township, N.J.
The First National Bank of Glassboro, Glassboro,
N.J.
Merger.................................................................................
Oct. 1, 1971:
Northern National Bank & Trust Co., Wellsboro,

90

92

Pa.

73

74

76

78

79

81

82

84

85

86

87

89

The Citizens National Bank & Trust Co. of Towanda, Towanda, Pa.
Consolidation.....................................................................
Oct. 15, 1971:
The First National Bank of Russellville, Russell­
ville, Ala.
City National Bank of Russellville, Russellville,
Ala.
Purchase..............................................................................
Oct. 22, 1971:
Provident National Bank, Philadelphia, Pa.
The National Bank of Chester Valley, Coatesville,
Pa.
Merger.................................................................................
Oct. 29, 1971:
The Bank of California, N .A., San Francisco,
Calif.
Bank of Redding, Redding, Calif.
Purchase......................................................................
Nov. 1, 1971:
Opelika National Bank, Opelika, Ala.
Midway Bank, Opelika, Ala.
Merger..................................................................................
Nov. 1, 1971:
The Merchants National Bank of Burlington,
Burlington, Vt.
Northfield Trust Co., Northfield, Vt.
Merger.................................................................................
Nov. 30, 1971:
The First Machinists National Bank of Taunton,
Taunton, Mass.
Manufacturers National Bank of Bristol County,
North Attleboro, Mass.
Consolidation.....................................................................
Dec. 8, 1971:
The Citizens and Southern National Bank, Sa­
vannah, Ga.
The Citizens and Southern Bank of Chatham
County, Savannah, Ga.
The Citizens and Southern Bank of Richmond
County, Augusta, Ga.
Purchase...............................................................................
Dec. 27, 1971:
The Wayne County National Bank of Wooster,
Wooster, Ohio
The Farmers Bank, Shreve, Ohio
Purchase..............................................................................
Dec. 31, 1971:
Dominion National Bank, Baileys Cross Roads, Va.
Dominion Bank, Alexandria, Va.
Merger.................................................................................
Dec. 31, 1971:
First National Bank, Orrville, Ohio
The Farmers and Merchants Bank Co., Smithville,
Ohio
Merger..................................................................................
Dec. 31, 1971:
First Union National Bank of North Carolina,
Charlotte, N.C.
Bank of Windsor, Windsor, N.C.

93

94

95

96

97

98

99

101

102

104

105

31

Page

Bank of Farmville, Farmville, N.C.
Merger..................................................................................
Dec. 31, 1971:
National Bank of the Commonwealth, Indiana, Pa.
First National Bank at Patton, Patton, Pa.
Purchase...............................................................................

107

109

Page

Dec. 31, 1971:
The Framingham National Bank, Framingham,
Mass.
Newton National Bank, Newton, Mass.
Waltham Citizens National Bank, Waltham, Mass.
Consolidation......................................................................

110

IL M ergers consummated, pursuant to corporate reorganization, involving a single operating bank
Jan. 1, 1971:
The National Bank of Commerce in New Orleans,
New Orleans, La.
N.B.C. National Bank, New Orleans, La.
Merger..................................................................................
Jan. 4, 1971:
The First National Bank of Boston, Boston, Mass.
Old Colony Trust, N .A ., Boston, Mass.
The Massachusetts Bank, N .A., Boston, Mass.
Merger..................................................................................
Jan. 4, 1971:
The National Bank of New Jersey, New Brunswick,
N.J.
The National Bank of New Jersey, New Brunswick,
New Brunswick, N.J.
Merger..................................................................................
Mar. 1, 1971:
The Peoples National Bank of Manassas, Manassas,
Va.
Manassas Bank, N .A ., Manassas, Va.
Merger..................................................................................
Mar. 10, 1971:
Belt National Bank of St. Joseph, St. Joseph, Mo.
Belt Bank of St. Joseph, N .A ., St. Joseph, Mo.
Merger..................................................................................
Mar. 10, 1971:
The American National Bank of St. Joseph, St.
Joseph, Mo.
American Bank of St. Joseph, N .A ., St. Joseph, Mo.
Merger..................................................................................
Mar. 11, 1971:
Mercantile Trust Co., National Association, St.
Louis, Mo.
Locust National Bank, St. Louis, Mo.
Merger..................................................................................
Mar. 31, 1971:
First National Bank & Trust Co. of Ithaca, Ithaca,
N .Y.
Bank of Ithaca, N .A., Ithaca, N.Y.
Merger..................................................................................
Mar. 31, 1971:
Williamsburg National Bank, Williamsburg, Va.
Bank of Williamsburg, N .A ., Williamsburg, Va.
Merger..................................................................................
Apr. 1, 1971:
First City National Bank of Houston, Houston, Tex.
First City Bank National Association, Houston, Tex.
Merger..................................................................................
Apr. 30, 1971:
The Citizens National Bank of Wooster, Wooster,
Ohio
The F.B.G. National Bank of Wooster, Wooster,
Ohio
Merger..................................................................................
Apr. 30, 1971:
The First National Bank of Wapakoneta, Wapakoneta, Ohio
The F.B.G. National Bank of Wapakoneta, W a ­
pakoneta, Ohio
Merger..................................................................................
May 3, 1971:
First National Bank of Joplin, Joplin, Mo.
First Bank of Joplin National Association, Joplin,
Mo.
Merger..................................................................................

32



Page
Ill

112

112

113

113

114

115

116

116

117

118

119

119

June 1, 1971:
The Security Central National Bank of Portsmouth,
Portsmouth, Ohio
The F.B.G. National Bank of Portsmouth, Ports­
mouth, Ohio
Merger..................................................................................
June 30, 1971:
The United States National Bank of Galveston,
Galveston, Tex.
Twenty-Second Street National Bank, Galveston,
Tex.
Merger..................................................................................
July 1, 1971:
New Jersey National Bank, Trenton, N.J.
Second New Jersey National Bank, Trenton, N.J.
Merger..................................................................................
July 7, 1971:
Texas Commerce Bank National Association,
Houston, Tex.
Commerce Bank National Association, Houston,
Tex.
Merger..................................................................................
July 15, 1971:
First American National Bank of Nashville, Nash­
ville, Tenn.
American National Bank of Nashville, Nashville,
Tenn.
Merger...................................................................................
Aug. 31, 1971:
The First National Bank of Corsicana, Corsicana,
Tex.
Bancorp National Bank of Corsicana, Tex., Cor­
sicana, Tex.
Merger...................................................................................
Sept. 1, 1971:
Security National Bank of Roanoke, Roanoke, Va.
Roanoke Bank, N .A ., Roanoke, Va.
Merger...................................................................................
Sept. 30, 1971:
Southwest National Bank of El Paso, El Paso, Tex.
Second Southwest National Bank of El Paso, El
Paso, Tex.
Merger...................................................................................
Sept. 30, 1971:
The First National Bank of Danville, Danville, Va.
Danville Bank, N .A ., Danville, Va.
Merger...................................................................................
Oct. 29, 1971:
The Fourth National Bank of Tulsa, Tulsa, Okla.
The Fourth Bank of Tulsa, N .A ., Tulsa, Okla.
Merger...................................................................................
Nov. 1, 1971:
South Jersey National Bank, Camden, N.J.
Second South Jersey National Bank, Camden, N.J.
Merger...................................................................................
Nov. 1, 1971:
The First National Bank of Princeton, Princeton,
N.J.
Second National Bank of Princeton, Princeton,
N.J.
Merger...................................................................................
Nov. 1, 1971:
The First National Iron Bank of New Jersey,
Morristown, N.J.

Page

120

121

122

122

123

124

125

125

126

127

127

128

P age

Second National Iron Bank of New Jersey, Morris­
town, N.J.
Merger..................................................................................
Dec. 31, 1971:
Central National Bank of Cleveland, Cleveland,
Ohio
Central Cleveland Bank, N .A ., Cleveland, Ohio
Merger..................................................................................
Dec. 31, 1971:
Liberty National Bank & Trust Co., Buffalo, N .Y.

129

129

P age

Court Street National Bank & Trust Co., Buffalo,
N .Y .
Merger..................................................................................
Dec. 31, 1971:
National Commercial Bank & Trust Co., Albany,
N .Y .
Capital City National Bank, Albany, N .Y.
Merger..................................................................................

130

131

III. Additional approvals

Page

Page
A.
Approved, but in litigation
Jan. 20, 1971:
The First National Bank of Atlanta, Atlanta, Ga.
The First National Bank of Tucker, Tucker, Ga.
Merger..................................................................................
July 26, 1971:
The Connecticut National Bank, Bridgeport, Conn.
The First New Haven National Bank, New Haven,
Conn.
Consolidation.....................................................................
Sept. 24, 1971:
The National Bank of Commerce of Seattle, Seattle,
Wash.
Washington Trust Bank, Spokane, Wash.
Merger.........................................................................




132

134

138

Oct. 29, 1971:
Seattle-First National Bank, Seattle, Wash.
The First National Bank of Ferndale, Ferndale,
Wash.
Purchase...............................................................................
B. Approved, but abandoned after litigation
Apr. 27, 1971:
Old National Bank of Washington, Spokane, Wash.
Oroville State Bank, Oroville, Wash.
Merger..................................................................................
C. Approved, but abandoned (no litigation)
Aug. 5, 1971:
Pacific National Bank of Washington, Seattle,
Wash.
Bothell State Bank, Bothell, Wash.
Merger.....................................................................

141

143

14

I. M ergers consummated, involving two or more operating banks

N ational Bank of W estchester, W hite Plains, N .Y., and T he M illerton N ational Bank, M illerton, N .Y.
Banking offices

Name of bank and type of transaction

Total assets

To be
operated

In

operation
The Millerton National Bank, Millerton, N Y . (2661), with.......................................
and National Bank of Westchester, White Plains, N .Y . (10525), which had...............
merged Jan. 1, 1971, under charter and title of the latter bank (10525). The
merged bank at date of merger had.....................................................................................

comptroller’s decision
On August 20, 1970, the $456.2 million National
Bank of Westchester, White Plains, N.Y., and the
$7 million Millerton National Bank, Millerton, N.Y.,
applied to the Comptroller of the Currency to merge
under the charter and with the title of the former.
The National Bank of Westchester was acquired
by Lincoln First Banks, Inc., Rochester, N.Y., a reg­
istered bank holding company which ranks 11th in
size in New York State. The applicant, the second
largest bank in the Third Banking District of New
York State, presently operates 33 banking offices and
has total IPC deposits of $359.1 million.
The primary service area of the receiving bank is
Westchester County and the Poughkeepsie section of
Dutchess County. That area is continguous to, and di­
rectly north of, New York City, and supports a popula­
tion of 977,400. The southern portion of the trade area
is highly urbanized, and such commercial firms as IBM,
General Foods, Pepsico, Continental Baking, Dicta­
phone, American Metal Climax, Reader’s Digest,
Reichhold Chemicals, Flintkote, United Nuclear, and
General Precision Equipment have offices in the area.
White Plains, N.Y., is the headquarters for the charter
bank and is the county seat for Westchester County.
It is located approximately 20 miles north of New
York City, and has a population exceeding 55,000.
The Millerton National Bank, Millerton, N.Y., or­
ganized in 1882, is a single-unit institution recording
IPC deposits of $5 million. It serves Millerton and
nearby parts of Connecticut. Within that market area,

34



$7, 442, 172
491, 641, 076
499, 083, 248

1
33
34

the merging bank competes with nine commercial in­
stitutions and their branches, two savings banks, and
one credit union.
Millerton, with a population of 1,500, is an agricul­
tural village in the northeast corner of the Third Bank­
ing District, some 75 miles northeast of White Plains,
N.Y. The economy o f the Millerton area is diverse.
The New York part engages in dairying and farming,
and the Connecticut section is residential, with 800 or
more residents employed by several large public and
private schools.
The applicant banks are not competitive with each
other. Their main offices are 68 miles apart, and the
nearest office of the charter bank is 35 miles from
Millerton. There is no common ownership or manage­
ment, and the duplication of borrowers and depositors
is insignificant. Potential for future competition be­
tween the applicants is nonexistent. Presently the re­
ceiving bank cannot branch into Millerton because
New York banking law prevents a competing bank
from branching de novo into a town or city where
a main office of another bank is located. Likewise,
the merging bank has shown no inclination for branch­
ing in the past, and the expense of branching in
White Plains in the future would be prohibitive. Con­
summation of the merger will have a favorable effect
on future competition in the Millerton area as it will
open Millerton to de novo branching by eliminating
the head office protection now in effect.
Approval of the merger will not adversely affect the
competing commercial banks in Millerton or the Third
Banking District. The nine Millerton area competitive

banks presently have aggregate deposits of $970 mil­
lion. That figure includes deposits of the $695 million
National Commercial Bank & Trust Co., Albany, N .Y .;
the $200 million Colonial Bank & Trust Co., Waterbury, Conn.; the $8 million Salisbury Bank & Trust
Co., Lakeville, C onn.; and the $7 million Dover Plains
National Bank, Dover Plains, N.Y. Millerton Na­
tional Bank ranks fifth in size, with only $6.2 million
of the $970 million in area aggregate deposits.
Considering all commercial institutions in the Third
Banking District, the anticompetitive implications of
this merger are nil. Total deposits in the district were
$2.8 billion, as of December 31, 1969, and the appli­
cant’s direct competitors, who retain a majority of
those deposits, include the $831 million County Trust
Co., White Plains, N.Y., a member of the $2.7 billion
Bank o f New York Co., a registered bank holding
company; the $284 million Empire National Bank,
Middletown, N .Y .; and the $213 million Marine M id­
land Bank of Southeastern New York, N.A., Pough­
keepsie, N.Y., a member of the $5.9 billion Marine
Midland Banks, Inc., a registered bank holding com­
pany. In addition, New York City’s largest banks pro­
vided intense competition through 47 branches that
operate in the district. The resulting bank, with total
deposits of $401 million, will continue to rank second
among all commercial banks in the Third Banking
District. Likewise, the parent holding company, Lin­
coln First Banks, Inc., will continue to rank 11th among
the registered holding companies in New York State.
The proposed merger will provide improved and
expanded service to Millerton area residents, including
a greatly increased lending limit, customer electronic
*

First N ational Bank

in Indiana, I ndiana,

P a .,

data processing, credit card services, and trust depart­
ment facilities. This merger will also resolve the im­
pending management succession problem that will
surface in the near future when two senior members
of the merging bank retire.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest. The
application is, therefore, approved.
ovember 17, 1970.

N

SUMMARY OF REPORT BY ATTORNEY GENERAL
National Bank of Westchester’s Poughkeepsie
branch is 38 miles southwest of Millerton National
Bank. Many banking alternatives intervene. Neither
bank originates substantial loans in the service areas
of the other. The amount of deposit overlap is nomi­
nal. It is unlikely that the proposed merger would
eliminate any existing competition between the banks
for deposits and loans.
New York banking law permits intradistrict de novo
branching. The State’s home office protection law pre­
cludes, however, a consideration of National Bank o f
Westchester as a potential de novo entrant into Miller­
ton. While Lincoln First could enter Millerton by
chartering a new bank, the size, location, and area
economy of Millerton National Bank make the elimi­
nation of this possibility insubstantial in terms of the
elimination of potential competition.
Although the proposed merger would add slightly to
the position of one of upstate New York’s more power­
ful banks, we do not believe that it would have a
significantly adverse effect on potential competition.
*

and

*

K iski V alley N ational Bank, V andergrift,

Pa -

Banking offices
Name of bank and type of transaction

Total assets

Kiski Valley National Bank, Vandergrift, Pa. (14514), with.........................................
was purchased Jan. 4, 1971, by First National Bank in Indiana, Indiana, Pa.
(14098), which had......................................................................................................................
After the purchase was effected, the receiving bank had...................................................

comptroller’s decision
On June 12, 1970, the $34.6 million First National
Bank in Indiana, Indiana, Pa., applied to the Comp­
troller of the Currency for permission to purchase the
assets and assume the liabilities of the $11.9 million
Kiski Valley National Bank, Vandergrift, Pa.




In
operation

To be
operated

$11,885, 422

1

36, 619, 361
48, 504, 783

7
8

The First National Bank in Indiana, Indiana
County, Indiana, Pa., was chartered in 1934 as a
National bank. It is the third largest bank in deposits
in the county and, at the date of application, it had
seven offices recording IPC deposits of $29.5 million.
Six of its offices are located in Indiana County, its
35

primary service area, and the seventh is situated in
South Fork, Cambria County, contiguous to and east
of Indiana County.
Indiana County, the principal service area of the
applicant bank, is situated in west-central Pennsyl­
vania, approximately 45 miles east of Pittsburgh. It
supports a population of 78,428, and has a mixed
economy depending principally on soft coal mining,
higher education, farming, Christmas tree production,
and some light industry. Recent construction of three
large mine-mouth powerplants now provides some
3,300 mining jobs and 300 in-plant positions, with a
total payroll of approximately $4 million annually. In­
diana University of Pennsylvania, the largest Stateowned institution, enrolls some 10,240 students, and
expends $10.9 million yearly for its 600-member faculty
and for construction. Farming, although following the
national trend of decline, still is a major factor in the
local economy, with approximately 1,500 farms in op ­
eration. Dairy products account for $6 million in reve­
nue, and crops and com account for $2 and $1.3 mil­
lion, respectively. Christmas tree production is signif­
icant in that the county is the headquarters of the
largest producer in the Eastern United States. It pro­
vides employment for about 300 and produces revenue
of $2.2 million. Light industrial plants in the county
employ in excess of 3,000 people and provide annual
payrolls of approximately $30 million.
South Fork, Cambria County, is 36 miles east of
Indiana and 64 miles east of Vandergrift. Its current
population of 1,600 depends upon coal production in
Johnstown, 9 miles south. The population in South
Fork is static.
Kiski Valley National Bank is a single-unit insti­
tution with IPC deposits of $10.1 million. It is a com ­
munity-oriented bank serving Vandergrift, Pa., and the
surrounding mountainous area. The total trade area
population of 11,500 is drawn from Vandergrift,
Apollo, and three satellite towns.
Vandergrift is a town of 8,600 in the northern part
of Westmoreland County, situated on the Kiskiminetas
River. It is located 28 miles west of Indiana and 35
miles northeast of Pittsburgh. The economic posture
of the trade area is industrial, with four employers
accounting for 75 percent of area employment. Those
four employ 2,500 people, and have payrolls totaling
$22 million. It appears that the economic, housing,
and population figures in Vandergrift will remain
fairly stable in the next decade.
Competition between the participating banks is
virtually nonexistent. Although each bank has a
nominal number of borrowers and depositors from the

36



other’s service area, distance and terrain severely re­
strict competition. Vandergrift is 28 miles west of the
purchasing bank’s main office in Indiana, and 26 miles
northwest of the purchasing bank’s Blairsville branch.
The topography is hilly, and the road system is not so
developed as to make it advantageous for an inhabitant
of Vandergrift to bank in Indiana, or vice versa.
The impact of the proposal on competitor banks
should be to intensify rather than to stifle competition.
Indiana County, which is the primary service area of
the purchasing bank, supports nine banks with 20
banking offices. In that context, the purchasing bank
ranks third in size and operates six of the offices. The
selling bank is the smallest of three competing banks
in the Vandergrift service area. The resulting bank will
continue to rank third in size among the 12 competing
banks in the combined service area. However, the pro­
posed acquisition will permit the purchasing bank to
improve its competitive posture toward Indiana
County’s largest commercial banks, the $58 million
Savings & Trust Co. of Indiana and the $39.9 million
First National Bank of Ebensburg, Ebensburg, Pa. It
will also introduce a bank, into the Vandergrift-Apollo
area, that can more readily compete with the present
branch facility of Union National Bank of Pittsburgh,
which has assets approaching $800 million. Competi­
tion in the area, provided by 11 competing commercial
banks, two savings and loan associations, 11 discount
company offices, and a building and loan association,
all of which are competing for lending and deposit
business, will remain keen.
The convenience and needs of the VandergriftApollo area will be enhanced by approval of this appli­
cation. The expanded deposit base o f the resulting bank
will enable it to improve and enlarge its banking ac­
tivities to more fully meet the needs of the area it
serves. Trust services, which are not presently offered,
will become available. Charge card banking will be
offered, and the purchasing bank will establish an
on-site computer center. A passbook savings program
offering the highest interest rates will be instituted to
attract; area savers. Management succession problems
in the selling bank will be remedied upon conclusion
of this acquisition.
Applying the statutory criteria to the proposed pur­
chase, we find that it is in the public interest. The
application is, therefore, approved.
ecember 3, 1970.

D

SUMMARY OF REPORT BY ATTORNEY GENERAL
The closest offices of the merging banks are approxi­
mately 26 miles apart, and are separated by rugged

mountainous terrain. According to the application,
neither bank draws significant deposit or loan business
from the service area of the other. The proposed trans­
action is unlikely to have any adverse effect on existing
competition.
Under Pennsylvania law, either bank could be per­
mitted to open de novo branch offices in the markets
served by the other. In view of its relative size, however,
Kiski could not be considered one of the more
significant potential entrants into Indiana County.
FNB is the third largest bank operating offices in
*

A merican N ational Bank, Bakersfield, Calif.,

Indiana County. It is not among the larger banks which
could branch into the service area of Kiski, which
include the largest banks in Pittsburgh, some 35 miles
to the southwest. Competing banks in the Kiski service
area include a branch of the Union National Bank of
Pittsburgh, and one other locally-headquartered bank.
In view of these facts, and the relatively static
nature of population and industry in Kiski5 service
s
area, we conclude that the proposed transaction would
be unlikely to have a significantly adverse effect on
potential competition.
*

*

and Santa

Y nez V alley Bank, Solvang, Calif.
Banking offices

Name of bank and type of transaction

Total assets

To be
operated

In

operation
Santa Ynez Valley Bank, Solvang, Calif., with...................................................................
and American National Bank, Bakersfield, Calif. (15437), which had......................
merged Jan. 11, 1971, under charter and title of the latter bank (15437). The
merged bank at date of merger had.....................................................................................

c o m p t r o l l e r ’s

On October 7, 1970, Santa Ynez Valley Bank,
Solvang, Calif., and American National Bank, Bakers­
field, Calif., applied to the Comptroller of the Currency
for permission to merge under the charter and with
the title of the latter.
American National Bank, with IPC deposits of $27
million, was organized in 1964 as Bakersfield National
Bank. It assumed its present title in January 1970, and
now maintains six branches, three in the Bakersfield
area, and three in the Antelope Valley region of
northern Los Angeles County.
Santa Ynez Valley Bank, with IPC deposits of $10
million, was organized in 1913. In 1964, it established
its only branch at Buellton, 3 miles west of its head
office in Solvang. The bank’s principal competitor is
a branch of the $5.7 billion Security Pacific National
Bank, which is headquartered in Los Angeles.
American National Bank competes with 11 other
banks, including the seven largest banks in the State,
which have a total of 46 offices in its trade area. Bank
of America National Trust & Savings Association
maintains 12 offices, Security Pacific National Bank
and Crocker-Citizens National Bank each have six
offices, and United California Bank has four offices.
Consummation of the proposed merger will not re­
duce competition in the service areas of the two banks.
The nearest offices of the charter and merging banks




2
7

49, 814, 338

9

are located approximately 140 miles apart. Inasmuch
as the service areas of the two banks do not overlap,
the merger will not result in the loss of an alternate
source of banking services. Rather, the merger will
afford the merging bank greater depth of management
and an increased lending limit. In addition, the charter
bank will be able to compete more effectively with
the large branch banking institutions now located in
its region. Generally, it can be said that the competitive
impact in the Bakersfield area will be negligible, and
competition in Solvang will be enhanced.
It is concluded that the merger will have no adverse
competitive effect and is in the public interest. The
application is, therefore, approved.
D e c e m b e r 9, 1970.

d e c is io n

*

$11, 729, 006
38, 192, 537

SU M M AR Y OF REPORT B Y A T TO R N E Y GENER AL

The proposed merger would not appear to eliminate
any substantial direct competition between the two
banks. The banks’ closest offices are approximately 80
miles apart.
Santa Ynez Bank held approximately 2 percent of
total deposits in Santa Barbara County as of June 30,
1968, and was among the smallest of 10 banks operat­
ing in the county. Because of the small sizes o f the
merging banks, and the large number of other banks
which must be considered to be more likely potential
entrants, the proposed merger would not have an ad­
verse effect upon potential competition.
*

*

37

T he National State Bank, Elizabeth, N.J.,

and

T he First National Bank

of

M ilford, M ilford, N.J.

Bankingl offices
Total assets

Name of bank and type of transaction

The First National Bank of Milford, Milford, N.J. (8779), with..................................
and The National State Bank, Elizabeth, N.J. (1436), which had..................................
merged Jan. 22, 1971, under charter and title of the latter bank (1436). The merged
bank at date of merger had.......................................................................................................

comptroller’s decision
On August 14, 1970, The First National Bank of
Milford, Milford, N.J., and The National State Bank,
Elizabeth, N.J., filed an application with the Comp­
troller of the Currency for permission to merge under
the charter and with the title of the latter.
The National State Bank, with IPC deposits of $283
million, was established in 1812 as a State bank; in
1865, it converted to a National bank. It operates 25
offices in Union and Middlesex counties, and has one
approved but unopened branch. The bank ranks sec­
ond in size, with 7.9 percent of the total deposits of the
63 commercial banks in the Second Banking District
of New Jersey.
The service area of The National State Bank consists
of Union and Middlesex counties, which are located
adjacent to the metropolitan New York area. Those
counties, with a population of 1.1 million, are a mix­
ture of highly industrialized communities, affluent resi­
dential areas, and agricultural areas; they have the
advantage of being served by an excellent highway,
railway, and waterway system. The area has enjoyed
substantial economic growth which is expected to
continue.
The bank faces intense competition from 32 com ­
mercial banks operating 157 offices in the service area.
In addition to the New Jersey National Bank, Tren­
ton, N.J., with deposits of $508 million, and the Union
County Trust Co., Elizabeth, N.J., with deposits of
$195 million, the large financial institutions in Newark,
N.J., and New York City provide competition.
The First National Bank of Milford, with IPC de­
posits of $26 million, was established in 1907. It op­
erates three offices in Hunterdon County, which is on
the Pennsylvania border. The bank ranks 41st in size,
with 0.7 percent of the total deposits of the 63 commer­
cial banks in the Second Banking District of New
Jersey. The bank’s capital structure is inadequate, and
its two top officers are planning to retire. That has
created a management succession problem.
38



$33, 081, 666
369, 181,028
402, 924, 643

U
operation

To be
operated

4
28
32

The service area of The First National Bank of M il­
ford encompasses the major portion of Hunterdon
County, which has an approximate population of
70,000, and the northwest section of Bucks County,
Pa. This area is predominately rural. Hunterdon
County is the second largest in area o f the six counties
in the Second Banking District o f New Jersey, but is
the smallest in population. The northeast section o f
Hunterdon County has started to grow industrially and
residentially. That growth is expected to continue
throughout the county.
The competition in the service area of the merging
bank consists of eight commercial banks with 28 operat­
ing or approved offices, including the Girard Trust Co.,
Philadelphia, Pa., with $1.7 billion in deposits; the
New Jersey National Bank, Trenton, N.J., with $508
million in deposits; and, the Hunterdon County Na­
tional Bank of Flemington, Raritan, N.J., with $68
million in deposits.
Competition between the two subject banks is vertually nonexistent. Their closest offices are approxi­
mately 30 miles apart.
Consummation of the merger will not result in the
elimination o f any potential competition. The New Jer­
sey Banking Act prohibits the establishment o f branch
offices in any municipality, with a population of less
than 7,500, in which another bank has an office. Only
one of the 26 municipalities in Hunterdon County has
a population of more than 7,500, and it is already
served by three banks. Only four o f the other munici­
palities do not contain a banking office. The popula­
tion of the largest of those is 2,211. It is clearly not
economically feasible for The National State Bank to
branch de novo into any of those four communities.
Competition in the Hunterdon County area will be
increased by the introduction of a larger bank offering
a greater variety of services.
Consummation of the merger will allow The First
National Bank of Milford to solve its problems of inade­
quate capital and management succession. The re-

suiting bank will have a lending limit greater than that
of any bank in Hunterdon County. That will be espe­
cially important as the industrial growth of the area
continues. The industrial lending expertise of The Na­
tional State Bank will prove invaluable to a growing in­
dustrial base. The resulting bank will be able to offer
services to the customers of The First National Bank
of Milford that are not presently available. Those in­
clude computerized accounting and financial record­
keeping, complete investment advisory service, com­
plete trust services, and credit card services.
After consideration of all the facts of this case and
of the statutory criteria, we find the proposed merger
is in the public interest and the application is, therefore,
approved.
ecember 22, 1970.

novo branching, or in the alternative through merger
with smaller competitors in new markets, thereby avoid­
ing concentration of the leading positions in an inordi­
nate number of banking markets in a few very large
institutions, and eliminating the benefit that potential
competition from new competitors provides. Since Na­
tional State is the second largest bank in the Second
Banking District, it is clearly among the most significant
potential entrants into areas of the district in which it
does not now operate. As indicated above, Hunterdon
County is such an area.
National State could legally branch de novo into the
following communities in northwestern Hunterdon
County: Alexandria Township (population 1,629);
Bethlehem Township (population 1,090); Hampton
Borough (population 1,135); and Union Township
(population 1,717). Rates of growth in Hunterdon
County are moderate, and the attractiveness of the
area for new branches should increase.
The structure of commercial banking in Hunterdon
County indicates that only its leading bank, The Hun­

D

SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

The closest offices of National State and Milford
Bank are about 30 miles apart, with many banks in the
intervening area. Thus, it would not appear that the
proposed transaction would eliminate any significant
degree of competition which may presently exist be­
tween the merging banks.
Under New Jersey law, banks may branch within an
entire banking district, except that there exists com­
munitywide home office protection against de novo
branching, and branch office protection in communities
of less than 7,500 persons.
Since the passage of New Jersey’s present branch
banking statute, many of the State’s larger (and some
smaller) banks have expanded their service areas
through de novo branching and through merger. Given
this obvious trend, we think it important that the larg­
est banks in the State enter new markets through de
*

First N ational Bank

of South

terdon County National Bank of Flemington (39 per­
cent of county deposits), could be considered a lead­
ing countywide competitor; its 10 offices are distributed
throughout the county. The second leading bank in the
county, The Flemington National Bank & Trust Co.
(18 percent of county deposits), operates all four of its
offices in the Flemington area, while Milford Bank and
First Clinton National Bank (each holding about 15
percent of county deposits) operate their offices in the
northwestern and north-central areas of the county.
There are two other locally-headquartered banks in
the county, substantially smaller than Milford Bank,
and one office of the district’s largest commercial bank
in Lambertville.
*

*

Carolina, Columbia,

S.C.,

and

Bank

of

Clinton, Clinton,

S.C.

Banking offices
Name of bank and type of transaction

Total assets

In

operation
Bank of Clinton, Clinton, S.C., with........................................ ..........................................
and First National Bank of South Carolina, Columbia, S.C. (13720), which had. . . .
merged Jan. 29, 1971, under charter and title of the latter bank (13720). The
merged bank at date of merger had.......................................................................................

comptroller’s decision
On October 12, 1970, the Bank of Clinton, Clinton,
S.C., and First National Bank of South Carolina, C o­
lumbia, S.C., filed an application with the Comptroller




$4, 772, 357
280, 040, 808
284, 908, 067

To be
operated

1
44
45

of the Currency to merge under the charter and title
of the latter.
Bank o f Clinton, with I PC deposits of $2.8 million,
commenced operation in 1948 after acquiring the Com ­
mercial Depository, Clinton, S.C., which was estab­

89

lished in 1934. The bank operates one office in
Clinton, Laurens County. The merging bank’s only
banking competitor in the town of Clinton is M . S.
Bailey & Sons, Bankers, which is more than four times
as large as the bank.
Laurens County is located in the piedmont section
of South Carolina. Manufacturing is the dominating
economic factor in the county, accounting for 48 per­
cent of all jobs. Because 62 percent of the manufactur­
ing jobs are in the textile and apparel industry, the
county has attempted, with some success, to diversify
its economic base by attracting nontextile related in­
dustry. Several mobile home manufacturers have lo­
cated in the county in the last few years. However, the
area’ s economic future continues to depend on the sta­
bility of the textile industry.
While agriculture contributes modestly to the eco­
nomic well being of the county, it appears to have
reached its full potential. The output of farm products
has remained relatively steady over the past decade.
The First National Bank of South Carolina was or­
ganized in 1933 under another name. Following a se­
ries of mergers and name changes, the bank adopted
the present name in 1965. The bank, with I PC de­
posits o f $165.6 million, operates 46 offices in 19 cities
and towns throughout the State.
There is no competition between the subject banks.
Although First National of South Carolina operates
in 14 counties, it has no offices in Laurens County. The
nearest offices of the subject banks are 33 miles apart,
with several banks located between them.
The charter bank has been an aggressive de novo
branching organization. O f its 46 offices, 20 were es­
tablished in that manner. However, the economy of
Laurens County will not, at this time or in the near fu­
ture, support a de novo branch. Therefore, consum­

mation of the merger will not eliminate any potential
competition.
This merger will have its greatest impact in the
Clinton area. It will allow the resulting bank to com ­
pete in this area with the full range o f bank services
not presently offered by the merging bank. Those in­
clude trust services, data processing services, invest­
ment counseling, and a bond department, among
others. In addition, the larger loan limit o f the acquir­
ing bank will be of immeasurable help in assisting
Laurens County in its drive to diversify its economy.
Applying the statutory criteria, we find the proposal
is in the public interest. The application is, therefore,
approved.
ecember 29, 1970.

D

SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

First National operates no offices in Laurens County.
It operates several offices in Greenville, Spartanburg,
and Union, located in adjacent counties to the north.
Its Union office is closest to Clinton, about 33 miles
distant. Other banking offices intervene between Clin­
ton and most of these First National offices. Thus, the
merger would not appear to eliminate any significant
direct competition between the two banks.
Clinton Bank is the second largest bank headquar­
tered in Clinton, and the smallest of four banks head­
quartered in Laurens County, holding 19.0 percent
of the total deposits held by the two Clinton banks,
and 9.3 percent of total Laurens County deposits. First
National could branch de novo into Laurens County
and into Clinton, and thus compete with Clinton Bank.
First National has established a total of 24 de novo
branches since its inception, indicating a capability of
further expansion by that method. Thus, the proposed
merger would eliminate some potential competition.

*

N orth Carolina N ational Bank, Charlotte,

N .C.,

and

Bank

of

W ashington, W ashington,

N.C.

Banking offices
Name of bank and type of transaction

Total assets

In

operation
Bank of Washington, Washington, N .C ., with.....................................................................
and North Carolina National Bank, Charlotte, N .C . (13761), which had.................
merged Jan. 29, 1971, under charter and title of the latter bank (13761). The
merged bank at date of merger had........................................................................................

40



$24, 513, 422
1, 422, 955, 180
1, 438, 029, 155

To be
operated

3
102
105

comptroller’s decision
On September 17, 1970, the $1.1 billion North Caro­
lina National Bank, Charlotte, N.C., and the $18.4
million Bank of Washington, Washington, N.C., ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter and with the title of
the former.
The North Carolina National Bank, Charlotte, N.C.,
is a statewide institution operating 101 offices in 30
communities in North Carolina. The bank was formed
in 1960 through the consolidation of American Com ­
mercial Bank of Charlotte, Charlotte, N.C., and the
Security National Bank of Greensboro, Greensboro,
N.C. During the decade of the 1960’s, the bank ex­
panded through a series of mergers and de novo
branches, and presently is the second largest bank in
the State, recording IPC deposits of $818.4 million.
The charter bank, although the second largest com ­
mercial bank in the State, is only the fifth largest with
regard to the number of branch offices which it oper­
ates. Many of its offices are sizeable, and in the State’ s
two largest cities, Charlotte and Greensboro, the char­
ter bank is the leading bank. The bulk of the bank’ s
business lies within the piedmont region of the State,
wherein the major portion of the State’s industry is
situated. However, in the last 10 years, the charter bank
has gained a competitive foothold in the mountain
and coastal regions.
The Bank of Washington, the merging bank, was
chartered in 1893 following reorganization of a finan­
cial institution that predated the Civil War. The merg­
ing bank presently maintains three offices in Washing­
ton, N.C., and holds aggregate IPC deposits of $15.4
million.
The service area of the Bank of Washington ap­
proximates the western and central portion of Beau­
fort County, which lies in the east-central portion of
the coastal plain section of North Carolina. Washing­
ton, the county seat and only urban center in the
county, serves as the trading center for the western
and central portions of the county. The economy of
the area is divided between manufacturing and farm­
ing. The principal farm products are tobacco, soy­
beans, com , potatoes, and peanuts. Timber cutting and
finishing also accounts for a significant source of em­
ployment in the area. Industrial employment in Beau­
fort County presently stands at approximately 3,900,
due to such employers as Hamilton Beach, National
Spinning Co., Samson’s Manufacturing, Hackney
Body Co., Singer Co., and Texas Gulf Sulphur.
The banking structure of Washington and the sur­
rounding market area will not be adversely affected




by the proposed merger. Tw o banks are situated in
Washington, the merging bank and two branches of
Wachovia Bank & Trust Co., N.A., the State’s largest
bank. First Citizens Bank & Trust Co., the State’s
fourth largest bank, has applied and received approval
to branch de novo into Washington. The $40 million
in deposits in Beaufort County are fairly evenly di­
vided between the merging bank and Wachovia Bank
& Trust, N.A. Approval of the proposed merger will
bring the State’s second largest bank into the Washing­
ton market area, benefiting area residents who will
receive the bank’s specialized banking services. Rather
than eliminate an alternate banking choice for the
public, the merger will merely replace the merging
bank with the resulting bank. In addition to the afore­
mentioned commercial institutions, there are two sav­
ings and loan associations in Washington, which have
aggregate deposits of approximately $17 million, two
finance companies, a Federal Land Bank office, and a
Farmers Home Administration office.
Competition between the applicants is not signifi­
cant. The head office of the North Carolina National
Bank in Charlotte is 200 miles southwest of the Bank
of Washington, and the nearest branch offices of the
charter bank are located in Greenville, N.C., some 22
miles west of Washington. Moreover, the North Caro­
lina National Bank competes directly in the Greenville
market area with offices of Wachovia Bank & Trust
Co., N.A., The Planters National Bank & Trust Co.,
and an office of the Bank of Winterville.
The resulting bank will introduce to the merging
bank’s customers automated bookkeeping services,
home mortgage financing, dealer financing, and a
greatly increased lending limit. Since the merging bank
is weak in nonagrarian services, the applicant will
strengthen that deficiency by offering such services as
concentration accounts, lock-box services, master re­
tirement plans for corporations and partnerships,
commingled investment funds, automated payroll proc­
essing and withholding of taxes, and participation in
commercial paper revolving accounts.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest. The
application is, therefore, approved.
ecember 17, 1970.

D

SUMMARY OF REPORT BY ATTORNEY GENERAL
NCNB’s only offices in eastern North Carolina are
in Greenville, Pitt County, 22 miles west o f Wash­
ington, and in Tarboro, Edgecombe County, 36 miles
northwest o f Washington. The Greenville office is the
result of the 1969 acquisition of State Bank & Trust

41

Co., which represented the first indication in recent
years of NCNB’s intention to move into the eastern
portion of the State. The proposed merger is NCNB’s
second attempt at expansion in this area.
None of NCNB’s offices draws as much as 1 percent
of its business from Beaufort County. Washington Bank
draws just over $500,000 in deposits from counties in
which NCNB has branches. Thus, it appears that only
a limited amount of existing competition will be elimi­
nated by the proposed merger.
North Carolina law allows banks to branch through­
out the State. Therefore, NCNB could establish
de novo branches in Beaufort County. In addition,
NCNB is the largest bank in the State which does not
have offices in Beaufort County, and NCNB has indi­
cated a desire to expand into eastern North Carolina,
the only part of the State where it does not have a
substantial number of offices. As the second largest
bank in the State, with assets of $1.3 billion, NCNB
clearly has the objective capability to open de novo
branches in Beaufort County. In the last 3 years, NCNB
has established 14 de novo branches throughout North
Carolina.
Although there are a limited number of other banks
which appear to have the capability to establish de
novo branches in Beaufort County, NCNB must be
considered one of the most likely potential entrants
for at least two reasons. First, it is considerably larger
than any other likely entrant. Secondly, because of
its statewide distribution of offices, there are a limited
number of areas in North Carolina which NCNB has
not already entered. Any other likely entrants, in large
part regional as opposed to statewide banks, have many
more de novo branching possibilities than NCNB. The
county’ s population has been relatively stable in recent
years, and the State’s fourth largest bank, FirstCitizens, has recently received approval for a de novo
branch in the county. These factors would tend to dis­
courage less powerful banks than NCNB from estab­
lishing de novo offices in Beaufort County, especially

considering the numerous alternatives available to the
less widely spread banks. Therefore, while Beaufort
County may not be as attractive to less widespread
banks who may prefer to enter more rapidly growing
areas, NCNB, with a much smaller number o f alterna­
tives, may find Beaufort County comparatively more
attractive than other areas it has not yet entered.
Beaufort County does appear to hold some attrac­
tion for new bank entry. First-Citizens has recently
received approval for a de novo branch in Washington.
The deposits o f Washington Bank increased by 33 per­
cent during the 1967-69 period, even though it was
directly competing with the State’s largest bank. Thus,
for large North Carolina banks, Beaufort County
evidently holds some attraction.
In addition, this proposed merger is part of a trend
toward concentration in North Carolina commercial
banking. Over 65 percent of State deposits are held
by the five largest banks, including NCNB. Particu­
larly significant is the elimination of small- to medium­
sized independent banks which, nonetheless, are among
the leading competitors in their respective local mar­
kets, such as Washington Bank. It is one of only about
25 independent banks with deposits approaching $20
million or more which still exist in North Carolina.
These banks represent very significant sources of future
competition for the largest North Carolina banks in
their respective local markets. Also, through affiliation
with one another, such banks could potentially com­
pete with the largest banks for the business of large
commercial customers.
NCNB is clearly one of the most likely potential
entrants into Beaufort County should that county sus­
tain sufficient growth to support a new entrant in ad­
dition to First-Citizens. Because o f this, the elimination
of Washington Bank as an independent banking alter­
native, and the continuing trend toward concentration
in commercial banking in North Carolina, we con­
clude that the proposed merger would have an adverse
effect on potential competition.
*

T he First N ational Bank

M aryland, Baltimore, M d ., and Patapsco N ational Bank
Ellicott City, Ellicott City, M d .

of

in

Banking offices
Name of bank and type of transaction

Total assets

In

operation

Nation’al Bank in Ellicott Oity, Ellicott CJity Md. (13773), w ith...........
(1413),
29, 1971,
(1413).

Patapsco
and The First National Bank of Maryland, Baltimore, M d.
which had. . . .
merged Jan.
under charter and title of the latter bank
The
merged bank at date of merger had........................................................................................

42



$13, 739, 330
755, 156,457
766, 907, 838

To be
operated

2
54
56

comptroller’s decision
O n October 28, 1970, Patapsco National Bank in
Ellicott City, Ellicott City, M d., and The First National
Bank of Maryland, Baltimore, M d., applied to the
Office of the Comptroller of the Currency for per­
mission to merge under the charter and with the title
of the latter.
The First National Bank of Maryland, the charter
bank, with IPC deposits of $482.4 million, was char­
tered in 1928. The charter bank operates 52 offices, of
which 16 are in the city of Baltimore and 1 in Howard
County in Columbia, which is located some 6 or 7 miles
southwest of the merging bank’s home office in Ellicott
City. Its other offices are located in the Baltimore
suburbs; the Maryland Eastern Shore; Hagerstown,
in Washington County; Harford County; and
Montgomery County.
Patapsco National Bank in Ellicott City, the merging
bank, with IPC deposits of $9.4 million, was reorga­
nized in 1933. It operates two banking offices with its
only branch located at St. John’s Lane on Route 40,
4 or 5 miles from Ellicott City proper.
Ellicott City, home of the merging bank, is an
unincorporated community with a population of ap­
proximately 3,500, and a trade area of 20,000 persons.
It is the county seat of Howard County and serves as
a “ bedroom” community to persons employed in the
Baltimore area. Howard County, which is adjacent
to Baltimore, is considered the merging bank’ s principal
service area, and has a current population of 61,181.
It is undergoing a transition from a predominantly
rural economy based on agriculture and related serv­
ices to one based on manufacturing and service in­
dustries. The new city of Columbia is located in the
county about 6 miles southwest of Ellicott City.
Banking competition in the county consists of 10
banks, including the merging bank, which together
have 13 offices.
The merger would serve the convenience and needs
of the Howard County area by introducing, through
present offices of the merging bank, the wide variety

be helpful to assist in present and future development
of the area. The merging bank has experienced diffi­
culty attracting and retaining executive personnel, and
that problem would be solved.
Competition will not be adversely affected. Although
one existing office of the Baltimore-based charter bank
operates in Howard County, competition between the
two banks is thought to be insignificant. Although
State law permits statewide branching, it is highly
unlikely that the charter bank would establish a de novo
branch in the merging bank’s service area, because
the area presently contains four offices of two local
banks and the third largest bank in the State has re­
ceived permission to establish a branch there. In addi­
tion, a medium-sized bank headquartered in Laurel
has an application pending for a branch 2 miles south
of Ellicott City. In Baltimore, combining the much
smaller merging bank with the larger charter bank
will have a de minimus effect on competition. In
Howard County, the resulting bank would offer
stronger competition to the large Baltimore-based banks
and the several large statewide banks that have re­
ceived approval to open offices in the county. Antici­
pated future economic growth in Howard County will
require diversified banks with sufficient capital strength
to meet these economic needs.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest and, therefore, is
approved.
ecember 28, 1970.

D

SUMMARY OF REPORT BY ATTORNEY GENERAL
First of Maryland’s closest offices to those of Patapsco
are in Columbia and Catonsville, 6 and 8 miles away,
respectively. The application indicates that the serv­
ice area of Patapsco is so narrow in scope, and so
heavily centered along Route 40, that little competi­
tion presently exists between the merging banks.
Although Maryland law permits de novo branching
anywhere in the State, Patapsco is not among the more
significant potential entrants into areas presently

of complete banking services possessed by the much

served by First of Maryland. While developing Colum­

larger charter bank. Among those are complete services

bia presents a naturally attractive market for expansion

in commercial and retail banking, savings, safe deposit,

by established banks in nearby Howard County, several

trusts, and international activities. The charter bank

of the largest banks in the State have already secured

is a member of Bank Americard, a nationwide credit

approval of new branches therein.

card network which would also become available

First of Maryland, clearly a capable potential de novo

following the merger. Services through automation

entrant into any attractive market in the State, re­

would be made available, as would services of trained

cently withdrew an application for a new branch near

management personnel. The larger lending limit which

Patapsco’s branch on Route 40, and has secured ap­

present offices of the merging bank would have would

proval for a branch in Columbia. In view of its lack

4G3-49i9 0—72

4




43

of growth, however, the immediate vicinity of Ellicott
City does not appear to be an attractive branch site.
As indicated above, Patapsco is also a relatively small
bank, with a limited service area. Thus, any adverse
effect of this merger on the potential for increased
*

Garden State N ational Bank, H ackensack, N.J.,

competition between the merging banks is most likely
to be felt at some time in the future, when Columbia
and metropolitan Baltimore become more closely inte­
grated, making de novo branching in the intervening
area more attractive.
*

and

*

N orth J ersey N ational Bank, J ersey City, N J .
Banking offices

Name of bank and type of transaction

Total assets

North Jersey National Bank, Jersey City, N.J. (1182), with ......................................
and Garden State National Bank, Hackensack, N.J. (15570), which had.................
consolidated Feb. 1, 1971, under charter and title of the latter bank (15570). The
consolidating bank at date of consolidation had.................................................................

comptrollers’s decision
On October 20, 1970, North Jersey National Bank,
Jersey City, N.J., and Garden State National Bank,
Hackensack, N.J., applied to the Office of the Com p­
troller o f the Currency for permission to merge under
the charter and with the title of the latter.
Garden State National Bank, the charter bank, with
IPC deposits of $147.6 million, was organized in 1889.
This bank operates 14 branches in Bergen County and
has three approved but unopened branches. In March
1969, the bank was acquired by Kinney National Serv­
ices, Inc., a New York-hased conglomerate.
Bergen County, N.J., in which Garden State Na­
tional Bank is headquartered and operates all its
branches, has an estimated population of 924,160. It
reflects varied economic characteristics: residential;
commercial; and industrial. The commercial and trade
patterns of Bergen County are strongly oriented toward
New York City and toward Paterson, Clifton, and
Passaic, N.J., the major centers in eastern Passaic
County. The substantial economic growth which Ber­
gen County has experienced in the past 10 years is
expected to continue.
As of December 31, 1969, Garden State National
Bank ranked fourth in size and held $156 million, or
8.2 percent, of the aggregate $1.9 billion in deposits
held in the 30 commercial banks headquartered in
Bergen County. It ranked 13th in size and held 2.1 per­
cent of total deposits of the 89 commercial banks with
$7.4 billion in deposits located in the First Banking
District of New Jersey. Competition includes the Peo­
ples Trust of New Jersey, Hackensack, witji $527 mil­
lion in deposits; the First National Bank of Passaic

44



$168, 845, 100
200, 380,211
369,225,311

In
operation

To be
operated

13
11
24

County, Towota, with $374 million in deposits; the N a­
tional Community Bank of Rutherford, Rutherford,
with $332 million in deposits; the Citizens National
Bank, Englewood, with $193 million in deposits; and
the Citizens First National Bank, Ridgewood, with
$130 million in deposits. Additional competition is pro­
vided by the large New York City commercial banks.
North Jersey National Bank, the consolidating bank,
with IPC deposits of $136.2 million, was established in
1851. In addition to its head office, located in Jersey
City, it operates 12 branches, all in Hudson County.
Hudson County, N.J., in which North Jersey Na­
tional Bank is headquartered and has its 12 branches,
has an estimated population o f 609,340. O f that num­
ber, 270,700 are estimated to reside in Jersey City,
where the charter bank operates its head office and
four branches. Hudson County owes its existence as a
major industrial area to its favorable location as a
transportation terminus and transfer point for the
movement o f goods throughout the New York Metro­
politan Area. In recent years, the economic growth of
the area has experienced a declining trend and urban
blight has affected the cities. Prospects for future
growth are heavily dependent upon the successful ini­
tiation and completion of massive urban renewal
programs.
As of December 31, 1969, North Jersey National
Bank ranked fourth in size and held $147 million, or
12.8 percent, of the aggregate $1.1 billion in deposits
held by the 10 commercial banks headquartered in
Hudson County. It ranked 15th in size and held 2
percent of the total deposits of all commercial banks
in the First Banking District. Competition includes the
larger First National Bank, Jersey City; the Commer­

would have a significantly adverse effect on direct com ­
petition.
Under New Jersey law, banks may operate branches
throughout the banking district in which they are
located, but may not open de novo offices in communi­
ties subject to home or branch office protection. Only
three communities in Hudson County are presently
open to de novo branching by Garden State Bank.
Tw o of these have shown slight population declines in
the past decade, and the third only moderate growth.
In view of these factors and the number of other large
potential entrants into Hudson County it does not ap­
pear that the elimination of Garden State Bank as a
de novo entrant into Hudson County would have a
significantly adverse effect on potential competition.
Demographic factors indicate that Bergen County is
a more attractive area for market expansion by First
District banks. The application states that about 30 of
its 70 municipalities are open to de novo branching.
According to the application, many of these communi­
ties are already heavily banked, and their attractive­
ness has been lessened by the approval of 25 new
branches since the recent change in New Jersey bank­
ing law. Nonetheless, in view of expected population
and industrial growth, it seems clear that developing
sections of Bergen County will continue to provide at­
tractive new branch sites. However, North Jersey Bank
is not among the largest banks capable of entering Ber­
gen County de novo. It is the 15th largest bank in the
district, and 10 of the larger banks are not primarily
Bergen County banks, although some have probably
secured approval for de novo branches therein, and
one, based in Passaic County, has entered through
merger with a relatively small bank in River Edge.
Each of the merging banks could expand into the
home county of the other through merger with a
smaller bank: Garden State Bank holds the fourth
largest share of Bergen County commercial bank de­
posits, about 8 percent, while North Jersey Bank holds
the fourth largest share of Hudson County commercial
bank deposits, about 15 percent. If the proposed
merger is approved, the resulting bank would become
the 10th largest bank in the district, but would be only
one-fourth the size of its leading institutions.

cial Trust Co. of New Jersey, Jersey City; The First
Trust Co. of New Jersey, Jersey City; and the smaller
Hudson Trust Co., Union City. Additional competition
is provided by the large New York City commercial
banks.
The proposed consolidation would resolve a man­
agement succession problem presently experienced by
the consolidating bank due to an inability to attract
qualified officers. It would eliminate what has been
called the marginally adequate capital base of the
charter bank by providing it with the necessary funds
to continue its expansion program in the First Bank­
ing District. The resulting bank would provide present
and potential customers with improved and expanded
services, such as a substantially larger lending limit,
overdraft banking, customer electronic data processing
facilities, investment advisory services, and higher in­
terest rates on several kinds of savings plans.
Competition will not be adversely affected. Because
the service areas of the two banks do not overlap, there
is no present competition between them. In Hudson
and Bergen counties, and in the First Banking District,
the transaction will improve competition between the
resulting institution and its larger New Jersey-based
competitors. This is particularly true in view of the
recent formation of four registered bank holding com ­
panies involving some of the State’s largest banks, and
the concomitant changing nature of competition which
that portends. Smaller banks will be largely unaffected.
The resulting bank will also be better able to meet the
competitive challenges always presented by the large
billion-dollar New York banks. Because of statutory
de novo branching restrictions, potential competition
is not affected.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
ecember 18, 1970.

D

SUMMARY OF REPORT BY ATTORNEY GENERAL
According to the application, the service areas of the
merging banks do not overlap. Their head offices are
about 16 miles apart, and their closest branches about
6.5 miles. Several other banks operate offices in the
intervening area. In addition, topographical features
such as the Jersey Meadows and the Hackensack
River separate their service areas. Although the banks
are large enough to compete for the business of me­
dium-sized customers who would consider banks in a
larger area of northern New Jersey as reasonable alter­
natives, there are many other alternatives of this na­
ture, and it does not appear that the proposed merger




*

We have repeatedly stressed our objection to mergers
combining the largest banking institutions in an area
with substantial banks in adjacent areas in such a man­
ner as to preclude the development of a more competi­
tive regional banking structure. The number and
relative size of other major banks in the First District
indicate that the proposed merger itself would be
unlikely to have such an effect.
*
45

Peoples N ational Bank of N ew J ersey, W estmont, H addon T ownship, N.J.,
Broadway N ational Bank & T rust C o . of Pitman, Pitman, N.J.

and

Banking offices
Total assets

Name of bank and type of transaction

To be
operated

In

operation
Broadway National Bank & Trust Co. of Pitman, Pitman, N.J. (15518), w ith .. . .
and Peoples National Bank of New Jersey, Westmont, Haddon Township, N.J.
(12022), which had.......................................................................................................................
merged Feb. 5, 1971, under charter and title of the latter bank (12022). The
merged bank at date of merger had.......................................................................................

comptroller’s decision
O n March 3, 1970, the $7.1 million Broadway Na­
tional Bank & Trust Co. of Pitman, Pitman, N.J., and
the $144 million Peoples National Bank of New Jersey,
Westmont, Haddon Township, N.J., applied to the
Comptroller of the Currency to merge under the
charter and with the title of the latter.
Peoples National Bank of New Jersey, Wesmont,
Haddon Township, N.J., was organized in 1918 as the
Clementon National Bank. At present, the bank op­
erates seven branches in Camden County, three in
Cumberland County, and three in Gloucester County,
and holds IPC deposits of $128.4 million. In addition,
the charter bank has several approved but unopened
branches including five in Camden County, one in
Cumberland County, one in Gloucester County, and
one in Atlantic County. Under aggressive manage­
ment, the charter banks has shown rapid growth in re­
cent years.
Westmont, headquarters of the charter bank, is an
unincorporated community of approximately 19,000
people in Haddon Township. It is located 5 miles
southeast of Camden and 6 miles southeast of
Philadelphia.
Broadway National Bank & Trust Co. of Pitman,
Pitman, N.J., was organized in 1921 as a State-char­
tered institution, and converted to a National char­
ter and adopted its present name in 1965. The bank
holds IPC deposits of $6.1 million in its main office and
single branch. With members of senior management
approaching retirement age, the bank must make pro­
vision for management succession. The borough o f Pit­
man, site of the merging bank and its one branch, is a
residential town of approximately 9,700. It is situated
15 miles south o f Camden in Gloucester County.
Westmont and Pitman both lie in the FhiladelphiaDelaware River industrial complex which is one of
the major industrial centers of the Eastern United

46



$8, 786, 138

2

186, 397, 560

15

194, 873, 698

17

States. The Philadelphia-Camden port facility is the
second largest in the United States, and the first in
volume o f foreign trade. The economic vitality of the
area stems from its navigable rivers, excellent inland
transportation facilities, and abundance o f fertile farm­
lands in the interior of southern New Jersey. Phila­
delphia is the cultural and industrial center for this
entire region. The industries o f the PhiladelphiaCamden area are widely diversified, with over one-half
of the largest 100 industrial firms in the United States
located in the area. Within 15 miles o f Camden, abun­
dant acreage is available for agriculture and related
industries. Peach and apple orchards, vineyards, poul­
try, cattle, pigs, and truck farming provide numerous
employment opportunities. An excellent highway sys­
tem in southern New Jersey, and railroad transporta­
tion for persons commuting to Philadelphia, have
contributed greatly to the economy of the region.
Population growth in the Philadelphia-Camden area
has been rapid during the past decade, and official esti­
mates project 50 percent growth again in the next
5 years. M ajor shopping centers and residential areas
have been constructed in southern New Jersey, and
further construction is expected as the population con­
tinues to increase.
Competition between the applicant banks is insig­
nificant. The head offices of the participating banks
are approximately 19 miles apart, and the nearest
branch of the charter bank is 5 miles from the merging
bank, with two competitive banking alternatives be­
tween them. Within a radius of 5 miles from Pitman
there are 11 other banking offices, including offices of
the first and second largest banks in New Jersey’s Third
Banking District. Moreover, the possibility of competi­
tion developing between the banks is limited since
Pitman remains closed to de novo branch entry by
virtue of New Jersey’s home office protection rule.
There are 47 commercial banks, with 191 branches,
and total deposits o f approximately $1.8 billion com ­

peting in this area, of which the resulting bank, with
$151 million in deposits, will hold only 8.1 percent. In
addition to the competition experienced from New
Jersey banks, the large Philadelphia-based banks are
able to compete effectively in the area, especially with
respect to those persons who commute to work in
Philadelphia and to large corporate clients. The offices
of 52 credit unions and 109 savings and loan associa­
tions also compete actively in this area.
Consummation of the proposed merger will intro­
duce new and expanded services for customers of the
resulting bank in the merging bank’s service area.
Several savings programs will be instituted with inter­
est rates that will be equal to or higher than others
in the area. Credit card services, installment loans, and
expanded banking hours will improve the quality of
retail banking services in this area, and computer and
armored car services will be available to meet the needs
of the merging bank’s business customers. The lending
limit of the resulting bank will be $1.2 million, or 20
times greater than the present lending limit of the
merging bank; that larger lending limit will enable the
resulting bank to effectively serve present and future
business around Pitman, and to compete against the
larger banks which compete for commercial accounts
in the Pitman area.
Applying the statutory criteria to the proposed
merger, we find that it is in the public interest. The
application is, therefore, approved.
J

u ly

28, 1970.

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENER AL

Pitman is served by two banks, Broadway and the
Pitman National Bank & Trust Co., which has an­
nounced a merger with The First National Bank &
Trust Co. of Paulsboro and the First County National
Bank & Trust Co., Woodbury. Nearby banks include
the National Bank of Mantua, the Peoples Bank of
South Jersey, and the First National Bank of Glassboro, in that adjoining borough.
Peoples operates no offices in Pitman; its closest
branch is in Wenonah, some 4.9 miles north. Tw o
banks operate offices in the intervening area, but it is




likely that the proposed merger would eliminate some
amount of direct competition.
Under recent amendments in New Jersey banking
law, commercial banks may operate branches anywhere
in the banking district in which they are located. They
may not, however, open de novo branches in municipilaties in which the head office of another bank is
located, or in municipalities of less than 7,500 popula­
tion if another bank operates a branch therein. A c­
cordingly, Peoples may branch de novo in Gloucester
County, but not into Pitman. We note that if the pro­
posed merger is approved, along with that of Pit­
man National Bank & Trust Co. into First County
National Bank & Trust Co., Pitman will be opened to
branching by other commercial banks.
Through its merger with the Farmers and Mechanics
National Bank, Peoples acquired the second largest
share of commercial bank deposits in Gloucester
County, about 23 percent. The proposed merger with
Broadway would add another 4 percent of deposits in
Gloucester County to Peoples’ deposit structure.
A number of the largest banks in the district are ex­
panding into Gloucester County, both through mer­
ger and through de novo branching where possible.
Since several of the county’s more attractive banking
areas are presently closed by home or branch office
protection, smaller independent banks, like Broad­
way, may provide vehicles for entry by other bank­
ing institutions, including registered bank holding
companies. Since entry by a larger number of able com­
petitors can only preserve or enhance banking com ­
petition, acquisition of a number of the county’s banks
by a single competitor may have the ultimate effect of
deterring the development of a competitive banking
structure, as well as unduly increasing the market share
of the acquiring bank.
Through its recent mergers, Peoples has enhanced its
position as one of the largest commercial banks operat­
ing in Camden and surrounding areas. It has the re­
sources to expand its service area through de novo
branching. Although other larger commercial banks
are finding their way into Gloucester County, we con­
clude that Peoples’ acquisition of a second bank in the
county may have an adverse effect on potential
competition.
*

47

T he N ational Bank & T rust G . of N orwich, N orwich, N .Y.,
T he Farmers N ational Bank of D eposit, D eposit, N.Y.
o

and

Banking offices
Total assets

Name of bank and type of transaction

The Farmers National Bank of Deposit, Deposit, N .Y . (9434) with......................
and The National Bank & Trust Go. of Norwich, Norwich, N .Y . (1354), which
had..................................................................................................................................................
merged Feb. 16, 1971, under charter and title of the latter bank (1354). The
merged bank at date of merger had.....................................................................................

comptroller' s decision
On November 5, 1970, The Farmers National Bank
of Deposit, Deposit, N.Y., and The National Bank &
Trust Co. of Norwich, Norwich, N.Y., applied to the
Office of the Comptroller of the Currency for per­
mission to merge under the charter and with the title
of the latter.
The National Bank & Trust Co. of Norwich, the
charter bank, with IPC deposits of $64.7 million, was
organized as a State bank in 1856, and converted to
National status in 1865. The charter bank operates
eight branches throughout Chenango County, and two
branches in Delaware County.
Norwich, with a population of 9,175, is the largest
town in Chenango County, which lies in the southcentral portion of the State. In the immediate Nor­
wich area there are 19 diverse industrial enterprises,
nine o f which employ over 200 persons in manufac­
turing, pharmaceuticals, turbine ignition systems,
knitwear, and shoes. The charter bank’s major service
area extends a radius of 30 to 35 miles from its head
office, encompassing a population of about 50,000,
while its two offices in eastern Delaware County service
a relatively small area about 60 to 70 miles from the
head office. The economy of the major service area
is primarily devoted to dairy farming and related serv­
ices, but includes some industrial employment.
As of June 30, 1970, the charter bank ranked as the
largest of four commercial banks based in Chenango
County which together held deposits of $101.2 million.
The next largest bank in Chenango County is the First
National Bank in Greene, with total deposits of $12.2
million. O f the 10 banks based in Delaware County,
with aggregate deposits of $70.7 million, the largest
is The National Bank of Delaware County, Walton,
with total deposits of $14.3 million. The National Bank
& Trust Co. of Norwich holds 7.7 percent of the de­
posits and ranks third in size among the 33 commer­

48



In
operation

$4, 875, 449

1

82, 500, 054

11

87,400 ,24 6

......................

To be
operated

12

cial banks in the Seventh Banking District which hold
aggregate deposits of $943.5 million. In the broadly
defined market area of the charter bank it ranks 10th
in total assets among 63 listed banks, with 5 percent
of total deposits and 5.1 percent of total loans.
The Farmers National Bank of Deposit, the merging
bank, with IPC deposits of $3.5 million, was organized
in 1909 and is a unit bank. This bank lacks manage­
ment succession and, because of its small size, finds it
difficult to attract adequately qualified management
personnel.
Deposit, home of the merging bank, has a popula­
tion o f 2,055 and is located about 30 miles east of
Binghamton on Route 17, the major east-west high­
way across the southern part of the State. This village
is a rural residential community containing several
small industrial concerns. The surrounding area con­
tains many small dairy farms. The service area of the
merging bank extends 15 miles in all directions. Those
residents of the community who are not employed by
the several small local industrial firms travel to Bing­
hamton or Sidney for industrial employment.
The merging bank, with 1.6 percent of the aggre­
gate deposits of $250.4 million of the four commercial
banks based in Broome County, is the smallest of the
four. The other banks are First-City National Bank,
Binghamton, with total deposits of $144.4 million; En­
dicott Trust Co., Endicott, with total deposits of
$66.4 million; and Endicott Bank of New York, Endi­
cott, with total deposits of $35.5 million. The merging
bank is located in the Seventh Banking District of New
York; it holds 0.4 percent of the deposits and ranks
27 th in size among the 33 commercial banks in the
district.
The resulting bank will provide additional and ex­
panded services to residents of the Deposit area, includ­
ing a larger lending limit, more liberal mortgage
terms, FH A and V A mortgages, trust department
services, an agricultural credit department, and spe-

cialists in commercial loans and installment loans. The
serious problem of management succession in the merg­
ing bank will be eliminated.
Competition will not be adversely affected. Because
the nearest branch of the charter bank is 14 miles
from Deposit, there is little significant competition
between the merging banks. The addition of the much
smaller merging bank to the charter bank will have
little effect on the competitive strength of the charter
bank in its present service area. Replacing the merging
bank with an office of the larger charter bank will
improve competition vis-a-vis the other larger banks
serving Deposit. In the Seventh Banking District the
resulting bank will continue to rank as third largest
and overall competition will not be affected greatly. *
Applying the statutory criteria, we conclude that the

tional Bank’s Afton office, however, is one of the closest
banking offices to Deposit, and there are no banks in
the intervening area. It would appear that some com ­
petition may be eliminated by the proposed merger.
New York permits branching within the banking
districts in which commercial banks are located. De
novo branching, however, is still subject to home office
protection in cities with populations equal to or less
than 1 million people. Therefore, National Bank could
branch into Broome County, subject to the home
office limitation, but not into Deposit.
As of June 30, 1968, National Bank was the largest
commercial bank of four in Chenango County. It
held 74 and 67.5 percent, respectively of the county­
wide I PC demand deposits and total deposits.
The merged bank, Farmers National, occupies a less
prominent spot in the banking structure of Broome
County. As of 1969, it was the smallest, by a wide
margin, of the six banks serving Broome County. The
other five banks have total deposits ranging from $14
to $222 million. All five are affiliated with registered
bank holding companies.
In view of the size and limited service area of Farm­
ers National, and the home office protection it affords
to Deposit (which will be eliminated by the proposed
merger), we do not believe that the proposed merger
would have a significantly adverse effect on potential
competition.

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

January

12, 1971.

SU M M A R Y OF REPORT B Y A T TO R N E Y G ENER AL

The closest office of National Bank to Farmers Na­
tional is located 19 miles northwest of Deposit in
Afton, N .Y .; National Bank’s main office is 43 miles
north of Deposit in Norwich, N.Y. The application
indicates that Farmers National has a compact service
area centered around the small town of Deposit. Na*

T he First N ational Bank of A tlanta, A tlanta,

*

G a .,

*

and F irst Bank of South

D eK alb, D ecatur,

Ga.

Banking offices
Name of bank and type of transaction

Total assets

In

operation
First Bank of South DeKalb, Decatur, Ga., with.................................................................
and The First National Bank of Atlanta, Atlanta, Ga., (1559), which had..................
merged Mar. 1, 1971, under charter and title of the latter bank (1559). The
merged bank at date of merger had.......................................................................................

comptroller’s decision
On September 3, 1970, the First Bank of South
DeKalb, Decatur, Ga., and The First National Bank of
Atlanta, Atlanta, Ga., 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 Atlanta, with IPC depos­
its of $546 million, maintains 21 offices within the city
of Atlanta, where it is the second largest bank, and




$2, 143, 265
978,013, 997
982, 401, 096

To be
operated

1
25
26

two offices in the city of Decatur, DeKalb County. Be­
cause of restrictive State statutes, the applicant’s
branching and merging efforts in recent years have
been confined to the city limits of Atlanta and Decatur.
As a result of recent changes in Georgia statutes relat­
ing to branching and merging, the applicant is able to
branch and merge in any county where it had previ­
ously established a branch. Since the applicant main­
tains branches in Decatur, located in DeKalb County,
the new laws now permit the applicant to establish

49

branches and consummate mergers throughout the
county.
The First Bank of South DeKalb, with IPG deposits
of $1.1 million, is located in the community of Deca­
tur, approximately 9 miles from the applicant’s main
office in Atlanta, and 5 miles from the applicant’s
nearest branch. The merging bank was established in
November 1969, with the assistance of officers of the
applicant. Both of the merging bank’s officers, includ­
ing its president, are former officers of the applicant
and retain their retirement benefits from the applicant.
The close relationship between the two institutions is
reflected by the existence of a service contract through
which the applicant provides the merging bank with
non-officer staff needs and several technical staff
services.
In view of the status of the merging bank as an
affiliate of the applicant, consummation of the pro­
posed merger will not result in a lessening of competi­
tion between the two banks; the merger transaction
appears to be merely the substitution of a branch for
an affiliate. In addition, the applicant’s acquisition of
merging bank’s total deposits of $1.3 million will not
result in any significant increase in applicant’s share
of the market. The impact within the relevant market
area of the merging bank will also be minimal as the
merging bank is significantly impeded from competing
with the applicant’s affiliate, The First National Bank
of Glenwood, Decatur, Ga., by the presence of Inter­
state 20 just north of the merging bank’s main office.
Competition in the market area will be afforded by
DeKalb Exchange Bank, which opened in 1970, and
by a branch of The Citizens and Southern South
DeKalb Bank, to be opened in early 1971. The Citizens
and Southern South DeKalb Bank is an affiliate of
The Citizens and Southern National Bank, Atlanta,
Ga., a $1.3 billion institution.
Approval of the application will enable the merging
bank, as a branch of the applicant, to draw more
effectively upon the services and expertise now pos­
sessed by the applicant. The convenience and needs
of the community require the expanded and more
sophisticated services that will become available to the
merging bank’s customers. In particular, the demand
for construction loans and permanent mortgage funds
can be accommodated through the merger. The merg­

ing bank will also be able to provide trust services,
payroll services, lock-box services, accounts receivable
financing, letters of credit, and other specialized serv­
ices to commercial and industrial firms in its service
area.
It is concluded that the merger will have no adverse
competitive effect and is in the public interest. The
application is, therefore, approved.
J a n u a r y 20, 1971.
S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

Doraville Bank and South DeKalb Bank were or­
ganized by parties friendly to Atlanta Bank, with A t­
lanta Bank’s assistance. They have always been oper­
ated as Atlanta Bank affiliates in DeKalb County, since
Georgia branching laws prohibited Atlanta Bank from
establishing new branches in DeKalb County.
Almost all of the shareholders of Doraville Bank,
including all its directors, financed their stock pur­
chases with loans from Atlanta Bank. The loans were
represented by notes payable on demand and secured
by the pledge of the Doraville stock purchased. The
principal amounts of the loans have not been reduced
and interest on the notes has been accrued but not
paid. In addition, the shares initially were subject to
a written option agreement in favor of Atlanta Bank
and, although the written agreement has been can­
celed, an understanding based on the option still exists.
South DeKalb Bank was organized in a similar man­
ner with identical financial assistance from and agree­
ments with Atlanta Bank. The only significant differ­
ence is the fact that a written option agreement in
favor of Atlanta Bank apparently still exists in the
South DeKalb situation.
The Georgia branching laws have recently been
changed to allow, as of January 1, 1971, branching in
any county in which a bank has its home office or a
branch office. Since Atlanta Bank has two branch o f­
fices in DeKalb County, it may now branch further
in the county. These mergers are apparently intended
to substitute official branches of Atlanta Bank for the
de facto branches it had established by setting up these
“ affiliated” banks. There seems to be no question that
Atlanta Bank in fact now controls these banks and
always has done so. Thus, these mergers, standing
alone, would have little or no effect on competition.
*

50



T he First N ational Bank

of

A tlanta, A tlanta, G .,
D oraville, G
a

a

and

First N ational Bank

D oraville,

of

.

Banking offices
Total assets

Name of bank and type of transaction

First N atio n a l Rank n f DnraviJlf* D n ra ville Cl^ (157Q4) yyith
and T h p First ^ a fin n a l
n f Atlanta Atlanta Cl a (I.^^Q)
merged Mar. 1, 1971, under charter and title of the latter bank (1559). The
merged bank at date of merger had.......................................................................................

comptroller’s decision




$2, 418, 567
978,013,997

To be
operated

1
26

982, 401, 096

27

ing bank’s total deposits of $824,000, representing 1.8
percent of the market’s deposits, will not result in any
meaningful increase in the applicant’s share of the
market. The impact within the relevant market area
of the merging bank will also be minimal, and com ­
petition will still be afforded by seven other banks
within, or immediately adjacent to, the merging bank’s
primary service area. Competitors include the $17
million deposit Citizens and Southern National Bank
of Chamblee, Chamblee, Ga., an affiliate of the $1.3
billion deposit Citizens and Southern National Bank,
Atlanta, Ga.; the $14 million deposit Peachtree Bank
& Trust Co., Chamblee, Ga., an affiliate of the $757
million deposit Trust Company of Georgia, Atlanta,
G a .; and, the $2 million deposit Northeast Commercial
Bank, Doraville, Ga., an affiliate of the $376 million
deposit Fulton National Bank, Atlanta, Ga. Banks on
the periphery of the merging bank’s service area in
Norcross, Ga., include Gwinnett Bank & Trust Go. and
The Bank of Norcross, each of which has $5 million

On September 3, 1970, First National Bank of Dora­
ville, Doraville, Ga., and The First National Bank of
Atlanta, Atlanta, Ga., applied to the Comptroller of
the Currency for permission to merge under the char­
ter and with the title of the latter.
The First National Bank of Atlanta, with I PC de­
posits of $546 million, maintains 21 offices within the
city of Atlanta, where it is the second largest bank, and
two offices in the city of Decatur, DeKalb County. Be­
cause of restrictive State statutes, the applicant’s
branching and merging efforts in recent years have
been confined to the city limits of Atlanta and De­
catur. As a result of recent changes in Georgia statutes
relating to branching and merging, the applicant is
now able to branch and merge in any county where it
has previously established a branch. Since the appli­
cant maintains branches in Decatur, located in DeKalb
County, the new laws permit the applicant to establish
branches and consummate mergers throughout that
county.
First National Bank of Doraville, with IPC deposits
of $605,000, is located in the community of Doraville,
approximately 14 miles from the main office of the ap­
plicant in Atlanta, and 8.7 miles from the applicant’s
nearest branch. The merging bank opened for business
in April 1970, with the assistance of officers of the ap­
plicant. Both officers of the merging bank are former
officers o f the applicant and retain their retirement
benefits from the applicant. The close relationship be­
tween the two institutions is reflected in the existence
of a service contract through which the applicant pro­
vides the merging bank with non-officer staff needs and
several technical staff services.
In view of the status of the merging bank as an af­
filiate of the applicant, consummation of the proposed
merger will not result in a lessening of competition be­
tween the two banks; the merger transaction is, in
essence, merely the substitution o f a branch for an af­
filiate. In addition, the applicant’s acquisition of merg­
*

In
operation

in deposits.
Approval of the application will enable the merging
bank, as a branch of the applicant, to draw more ef­
fectively upon the services and expertise now possessed
by the applicant. The convenience and needs of the
community require the expanded and more sophisti­
cated services that will become available to the merg­
ing bank. In particular, the demand for construction
loans and permanent mortgage funds should be ac­
commodated through the merger. The merging bank
will also be able to provide trust services, payroll serv­
ices, lock-box services, accounts receivable financing,
letters of credit, and other specialized services to com­
mercial and industrial firms in its service area.
It is concluded that the merger will have no adverse
competitive effect and is in the public interest. The
application is, therefore, approved.

January 20, 1971.

N ote .— 'See

page 50 for the “ Summary of Report by

Attorney General.”

*

*

51

First National Bank

of

S outh J ersey, Egg Harbor T ownship, N.J.,
of Bordentown, Bordentown, N.J.

and

T he First National Bank

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Bordentown, Bordentown, N .J. (9268), with..................
and First National Bank of South Jersey, Egg Harbor Township, N.J. (1326),
which had........................................................................................................................................
merged Mar. 5, 1971, under charter and title of the latter bank (1326). The
merged bank at date of merger had.......................................................................................

comptroller’s decision
On November 16, 1970, The First National Bank of
Bordentown, Bordentown, N.J., and First National
Bank of South Jersey, Egg Harbor Township, N J .,
applied to the Comptroller o f the Currency for permis­
sion to merge under the charter and title of the latter.
First National Bank of South Jersey, with IPC de­
posits of $233 million, was organized in 1907 as The
Boardwalk National Bank of Atlantic City. In 1969
it acquired its present name. The applicant presently
operates 20 offices in Atlantic County, four offices in
Gloucester County, and three offices in Salem County.
The First National Bank of Bordentown, with IPC
deposits of $10.8 million, was organized in 1908, and
maintains one branch. It is located in rapidly develop­
ing Burlington County in the city of Bordentown,
which has a population of 5,470. Like the applicant, the
merging bank is located in New Jersey’s Third Bank­
ing District, which encompasses the eight southernmost
counties of the State.
Competition between the merging banks is negli­
gible; the head offices of the two banks are approxi­
mately 60 miles apart, and the nearest branch of the
applicant is 37 miles from Bordentown. Consumma­
tion of the merger should have a favorable effect on
competition as “ head office protection” in the city of
Bordentown will be eliminated and that community
will be open to de novo branching by other banks.
Numerous other banks within the Third Banking
District and within the Burlington County area adja­
cent to Bordentown provide substantial competition to
the merging bank. Competitors within the Third Bank­
ing District, where the resulting bank will remain third
in size after the merger, include the $374 million Bank
of New Jersey and the $346 million South Jersey Na­
tional Bank, both of which are located in Camden; the
$167 million Peoples National Bank of New Jersey,
Westmont, N.J.; the $165 million First National Bank
of Toms River, Toms River, N.J.; and, the $149 mil­
52




In
operation

To be
operated

$14, 158, 280

2

297, 483, 713

27

311,641,993

29

lion Colonial National Bank, Haddonfield, N.J. In ad­
dition, competition is provided by the $25 million
Third National Bank & Trust Co., of Camden, Cam­
den, N.J., and the $30 million Cumberland National
Bank, Bridgeton, N.J., both of which are affiliated with
United Jersey Banks, Inc., Hackensack, N.J., which
has total deposits of $695 million; the $10 million El­
mer Bank & Trust Co., Elmer, N.J., an affiliate of the
$684 million Midatlantic Banks, Inc., Newark, N .J.;
and by the $25 million Bank of West Jersey, Delran,
N.J., a member of a proposed registered bank holding
company, Fidelity Union Bank Corp., Newark, N.J.,
which will have total deposits of $694 million. Com­
petition within the immediate area of the merging
bank includes the $385 million New Jersey National
Bank, Trenton, N.J.; Trenton Trust Co., Trenton,
N.J., with total deposits of $171 million; the $43 mil­
lion Bank of Mid-Jersey, Bordentown, N .J.; and the
$65 million Mechanics National Bank of Burlington
County, Burlington, N.J.
The resulting bank will provide additional and ex­
panded services to present and potential customers in
the Bordentown area, including a larger lending limit,
a variety of savings programs, computer services, and
expanded trust department services. It will also relieve
the merging bank’s management succession problem.
It is concluded that the merger will have no ad­
verse competitive effect and is in the public interest.
The application is, therefore, approved.

January

28, 1971.

SU M M AR Y OF R EPOR T B Y A T T O R N E Y G ENER AL

The head offices of the applicant banks are 60 miles
apart; the closest offices are 37 miles distant. Numer­
ous competitive alternatives lie in the intervening area.
It is likely that there is little or no overlap in the
geographic sources of deposits and loan accounts of
the merging banks. Thus, the merger would not appear

to eliminate any significant amount of existing compe­
tition between the two banks.
According to New Jersey law, commercial banks
may now establish branches anywhere throughout the
banking districts in which they are located. De novo
branching is limited, however, by complete home of­
fice protection and branch office protection in com­
munities of less than 7,500 population. South Jersey
and Bordentown National are both located in the
Third Banking District, comprised of eight counties
in southern New Jersey.
South Jersey is the largest bank in Atlantic County
and holds 65.4 percent of countywide total deposits.
In addition, it is the third largest bank in the Third
Banking District. Clearly, South Jersey has sufficient
resources to open de novo branch offices. By virtue of
one consolidation and two mergers this year, South
Jersey has demonstrated its intent to expand its service
area. Although several communities in Burlington
County, including Bordentown, are protected against
de novo branching, growth patterns indicate that at­
tractive sites for new branches will become more
available.
We believe it important, from a competitive stand­
point, that the largest banks in the district enter new
areas through de novo branching, or in the alternative,
*

through merger with smaller banks. Systematic ac­
quisition 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 banking institutions.
As of June 30, 1968, 15 commercial banks were
headquartered in Burlington County. Since that date,
with the passage of more liberal branching laws in
New Jersey, three of these banks have merged into
banks located outside the county, two of these into
the two largest banks in Camden and the Third Bank­
ing District. The application indicates that four other
commercial banks also operate branches in the county.
Bordentown National is the eighth largest of the 12
remaining independent banks in the county, and holds
about 4 percent of total county deposits. It is not one
of the larger county banks in terms of deposits or
immediate service area, and is only one-third and
one-fifth as large as its two nearest Burlington County
competitors.
Thus, although South Jersey is one of the largest
potential entrants into Burlington County, we con­
clude that its merger with Bordentown National would
be unlikely to have a significantly adverse effect on
potential competition.
*

*

T he First N ational Bank & T rust Co. of A ugusta, A ugusta, G
N ational Bank of R ichmond County, A ugusta, G

a

.,
.

and

Southgate

a

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Southgate National Bank of Richmond County, Augusta, Ga. (15219), with..........
and The First National Bank & Trust Co. of Augusta, Augusta, Ga. (1860), which
had..................................................................................................................................................
merged Mar. 8, 1971, under charter and title of the latter bank (1860). The
merged bank at date of merger had.....................................................................................

c o m p t r o l l e r ’s

d e c is io n

On October 22, 1970, Southgate National Bank of
Richmond County, Augusta, Ga., and The First Na­
tional Bank & Trust Co. of Augusta, Augusta, Ga., ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter and with the title of
the latter.
The First National Bank & Trust Co. of Augusta,
with I PC deposits of $35 million, was established in
1871, and maintains four offices within the corporate




$5, 412,018

1

54, 791, 656

5

60, 387, 026

6

limits o f Augusta. The applicant is a subsidiary of
Trust Company of Georgia Associates, a registered
bank holding company which owns approximately 86
percent of the applicant’s stock. Because of restrictive
State statutes, the applicant’s branching and merging
efforts in recent years have been confined to the city
limits of Augusta. As a result of recent changes in
Georgia statutes relating to branching, the applicant is
now able to branch in any county where it had previ­
ously established a branch. Since the applicant main­
tains branches in Augusta, located in Richmond Coun­
53

ty, the new laws now permit the applicant to establish
branches throughout that county.
Southgate National Bank of Richmond County, with
IPC deposits of $3.4 million, is located near the city
limits of Augusta in an unincorporated section of
Richmond County. The merging bank is approxi­
mately 4.1 miles from the applicant’s main office and
2.5 miles from the applicants nearest branch. The
bank was established in 1963 with the assistance of
the applicant, and close relations between the two in­
stitutions have been maintained since that time. Exten­
sive cooperation is evident from the data processing
and auditing services provided to the merging bank
by the applicant, as well as by the extensive sale of
loan participations between the two banks. Three offi­
cers of the merging bank were formerly officers of the
applicant. In addition, there are believed to be a con­
siderable number o f common stockholders of the two
banks, including Trust Company o f Georgia Asso­
ciates, which owns 5 percent of the merging bank.
In view of this close relationship, consummation of
the proposed merger will not result in a lessening of
competition between the two banks. The merger
should, instead, increase competition and aid the
merging bank in resolving several serious difficulties,
including a management succession problem. The ac­
quisition, by the applicant, of the merging bank’s $5.4
million in total resources will not significantly add to
the applicant’s share o f the market. Its two principal
competitors in the Greater Augusta Area are the Geor­
gia Railroad Bank & Trust Co., with deposits of $133
million, and The Citizens and Southern National Bank,
with deposits of $73 million. The latter bank is affil­
iated with the $1.3 billion Citizens and Southern Na­
tional Bank, Savannah, Ga. The Citizens and Southern
Bank o f Richmond County, which maintains two
offices near the city limits of Augusta is another affil­
iate of The Citizens and Southern National Bank,
Savannah. Also competing in this area are several
banks in North Augusta, S.C., where the $484 million
deposit South Carolina National Bank and the $190
million Bankers Trust of South Carolina have offices.
Those banks and several other small institutions in
Richmond County will provide substantial competi­
tion to the resulting bank.

In addition to making available a means of manage­
ment succession to the merging bank when its presi­
dent retires in 1971, the merger will provide other
benefits to the banking public. An expanded array of
trust services will be more readily available, as will
the bond, factoring, and international departments of
the applicant’s affiliated banks and an increased lend­
ing capability.
It is concluded that the merger will not have a sig­
nificantly adverse competitive effect and is in the public
interest. The application is, therefore, approved.
J a n u a r y 11, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y GENERAL

According to the application, Southgate National’s
office is located 4.1 miles southwest of First National’s
main office. T w o of First National’s branch offices
appear to be slightly closer to Southgate National,
while the third branch is approximately 5 miles from
Southgate National’s office.
As of December 31, 1969, there were eight com ­
mercial banks in Richmond County. Four of these
banks, including First National, were located within
the corporate limits of Augusta, while the remaining
four, including Southgate National, were located in
the unincorporated part of Richmond County.
The four largest banks control 93.5 percent of total
deposits in Richmond County and 94.0 percent of IPC
demand deposits in the county. First National controls
13.7 percent of total deposits and 15.4 percent of IPC
demand deposits, and is the third largest bank in
Richmond County. Southgate National is a less sig­
nificant banking factor in the county with 1.9 percent
of total deposits and 2.3 percent of IPC demand de­
posits. It is the fifth largest bank in Richmond County.
Although competition between these banks may be
negligible because of their current relationship, its
relatively short existence and Southgate National’s
prior viability enhances the possibility that, should this
merger not be approved, Southgate National could
become an independent competitive force. Because of
this possibility, and because of the already high con­
centration existing in Richmond County, we conclude
that the proposed merger would have an adverse effect
on competition.
*

54



Puget S ound National Bank, T acoma, W ash.,

and

National Bank

of

M ason C ounty, S helton, W ash .

Banking offices
Name of bank and type of transaction

Total assets

In

operation

and Puget Sound National Bank, Taroma, Wash. (12292), whieh had........

$6, 867, 684
221, 256, 072

merged Mar. 19, 1971, under charter and title of the latter bank (12292). The
merged bank at date of merger had.......................................................................................

228,011,351

National Bank of Mason County, Shelton, Wash. (15418), with..................................

comptroller’s decision
On December 1, 1970, the National Bank of Mason
County, Shelton, Wash., and Puget Sound National
Bank, Tacoma, Wash., applied to the Office of the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
Puget Sound National Bank, the charter bank, with
IPC deposits of $163.8 million, was founded in 1890.
It operates 24 banking offices and has three approved
but unopened offices that are expected to be opened
shortly.
Tacoma, the head office city of the charter bank, is
located on Puget Sound and surrounds Commence­
ment Bay, an excellent natural harbor. It is the Puget
Sound area’s second major urban center and third
largest city in the State, with a population of 151,061.
The service area of the charter bank includes western
Pierce County and southwestern King County to the
north. Pierce County is Washington’s second largest
county with a population of about 405,000 persons,
while the charter bank’s service area has an estimated
population of 500,000. The economy is diversified with
dominance in the areas of the logging and wood prod­
ucts, aerospace, and marine industries. Other signifi­
cant
support
comes
from
the
metallurgical,
electrochemical, and chemical processing industries,
agriculture, and warehousing and distribution facili­
ties. Fort Lewis, one of the largest permanent Army
posts in the United States, borders Tacom a on the
south. The area is experiencing an economic decline,
however, owing to cutbacks in both the construction
and aerospace industries.
The charter bank is one of seven commercial banks
operating in the Tacom a area. Among its competitors
are the Seattle-First National Bank, the State’s largest
bank, with total deposits of $1.7 billion; the Pacific
National Bank of Washington, the State’s third largest
bank, with total deposits of $566 million; and the
Peoples National Bank of Washington, the State’s
fourth largest bank, with $369 million in deposits. The




To be
operated

2
25
27

charter bank is the sixth largest bank in the State and,
in terms of percent of area deposits held, ranks second
in the Tacom a area.
National Bank of Mason County, the merging bank,
with IPC deposits of $4.9 million, was organized in
1964 and operates a single branch located in Belfair,
Wash., 22 miles northeast of Shelton, its head office
city. While the condition of the bank is generally good,
it faces the likelihood of future capital inadequacy,
and a lack o f management succession to replace the
present managing officer of the bank.
Mason County, roughly the service area of the
merging bank, contains the towns of Shelton and Belfair. It lies on the western side o f Puget Sound at its
southern tip, and is separated from the charter bank’s
service area by the Sound and by the city of Olympia,
the State’s capital. Mason County has a population of
19,975, while Shelton, home office city of the merging
bank and the county’s only incorporated area, has a
population of 6,360. Mason County is in a moun­
tainous area, heavily forested and devoted substantially
to lumbering interests. The local economy is domi­
nated by Simpson Timber Co. which employs about
1,500 people. It owns about 160,000 acres of forest
land in the county and manages 100,000 more. R ec­
reational property development has recently become
an increasingly strong economic influence.
Competition with the merging bank comes from one
banking office, the Shelton branch of the Seattle-First
National Bank, the State’s largest bank.
The resulting institution would be able to offer serv­
ices to residents of the Mason County area not now
available from the merging bank, including trust serv­
ices, investment services, customer EDP services, credit
cards, dealer financing, and international banking. A
much larger lending limit would enable the resulting
bank to service customers whose needs exceed the
$50,000 limit of the merging banks. The management
hiring and succession problem will be solved. The usual
economies of scale resulting in better service at lower
cost will also result.
55

Competition will not be adversely affected. Because
the head offices of the merging banks are 50 miles
apart, and their nearest offices 31.5 miles apart, there
is little present competition between them. In the
Tacoma banking market, the charter bank’s competi­
tive position will be little affected after the addition
of the much smaller merging bank. In Mason County,
competition with the local office of the State’s largest
bank will be enhanced. Statewide, the resulting insti­
tution will remain as sixth largest bank, increasing its
share of deposits and loans only slightly. Potential
competition will not be affected since present restrictive
branching laws preclude either bank from branching
into the service area of the other.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
ebruary 4, 1971.

SU M M AR Y OF REPORT B Y A T T O R N E Y G EN ER AL

The head offices of the participating banks are 52
road miles apart, and their closest offices are 31 road
miles apart. It does not appear that the proposed
merger would eliminate any significant existing com ­
petition between the merging banks.
Only two banks presently serve Mason County. The
other bank is Seattle-First National Bank, the State’s
largest bank, which has a single branch in Shelton.
This branch had total deposits of $12.2 million at yearend 1969.
Washington State law prohibits banks from branch­
ing outside of the county in which the bank is based,
except into an incorporated area not otherwise served
by a commercial bank. Therefore, no other bank can
presently enter either Shelton or Belfair by de novo

F

*

branching.
*

*

T he Clinton County N ational Bank & T rust Co. of W ilmington, W ilmington, O hio,
T he Port W illiam Banking Co., Port W illiam, O hio

and

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation

Go., Port William, Ohio, with. . .
20, 1971,
Ohio (1997), which had ..........................................

The Port William Banking
was purchased Mar.
by The Clinton County National Bank & Trust Co.
of Wilmington, Wilmington,
After the purchase was effected, the receiving bank had.................................................

$1, 975, 002
28, 899, 794
30,615, 403

1
6

7

selling bank, which is located 7 miles from Wilmington,

The economy of Clinton County, the home county
of both banks, is primarily dependent upon agricul­
ture and farm-related businesses. Most o f the farmland
in the service area is fertile and highly productive. The
farms range in size from 50 to 2,000 acres, with the
average farm containing approximately 200 acres. The
per acre price of the land ranges from a low of $250
per acre to a high o f $800 per acre. Industrial produc­
tion in Clinton County is centered in Wilmington and
Sabina. Wilmington has nine manufacturing plants em­
ploying 1,894 persons, and Sabina has one small manu­
facturing plant employing 275 persons.
While there is some competition between the pur­
chasing and selling banks due to their proximity, the
loss of any existing competition will be far outweighed
by the benefits to be derived by the community to be
served. The lending limit of the selling bank ($21,000)
has proved inadequate to serve the increasing credit

operates no branches, and has deposits of slightly less
than $2 million.

bank has experienced difficulty in attracting and re­

c o m p t r o l l e r ’s

d e c is io n

On November 12, 1970, The Clinton County Na­
tional Bank & Trust Co. of Wilmington, Wilmington,
Ohio, applied to the Comptroller of the Currency for
permission to purchase the assets and assume the lia­
bilities of The Port William Banking Co., Port William,
Ohio.
Clinton County National Bank & Trust Co. of W il­
mington, Wilmington, Ohio, the purchasing bank, was
organized in 1872, and operates five branches in Clin­
ton County. The purchasing bank, the largest bank in
Clinton County, has assets of $26.5 million.
The Port William Banking Co., Port William, Ohio,
the selling bank, is located in the hamlet o f Port W il­
liam along the northern border of Clinton County. The

56




needs of the local community. Additionally, the selling

taining competent management. That difficulty was
reflected in the severe loan losses uncovered at the
last regular examination. Approval of the subject ap­
plication will provide the Port William community
with a substantially increased lending capacity, im­
proved and more efficient management, and the only
corporate fiduciary in Clinton County.
Applying the statutory criteria to the proposed ap­
plication, we conclude that it is in the public interest
and the application is, therefore, approved.
ebruary 8, 1971.

vening area. Thus, it would appear that the proposed
merger would eliminate some direct competition that
presently exists between the merging banks.
A total of 13 banks, including National Bank, oper­
ate 30 offices within a radius of around 20 miles of
the Port William Bank. Consummation of the pro­
posed merger would allow National Bank to increase
its share of total deposits in this area (which may some­
what overstate the size of the appropriate market)
from 16 to 18 percent and, likewise, increase its share

SU M M A R Y OF REPORT B Y A T T O R N E Y G ENER AL

competition between the participants and would elim­

The head office of National Bank, located in W il­
mington (population 8,915), is 7 miles distant from the
Port William Bank’s single office in Port William (pop­
ulation 450). There are no banking offices in the inter­

inate an independent banking unit in Port William.

F

of total loans from 17 to 19 percent.
The proposed merger would eliminate some direct

*

Additionally, it would somewhat increase concentra­
tion among commercial banking institutions in a multi­
county market.
*

*

N ortheastern Pennsylvania N ational Bank & T rust C ., Scranton, Pa ., and Pocono Bank,
East Stroudsburg, Pa .
o

Banking offices
Total assets

Name of bank and type of transaction

Pa., with

...........................
(77),

Pocono Bank, Past Stroudsburg,
and Northeastern Pennsylvania National Bank & Trust Co., Scranton, Pa.
which had.......................................................................................................................................
merged Apr.
under charter of the latter bank
and title “ Northeastern
National Bank of
.9
9
bank
date of

2, 1971,
Pennsylvania The rperged

at

(77)

merger had .........

comptroller’s decision
On November 27, 1970, Pocono Bank, East Strouds­
burg, Pa., and Northeastern Pennsylvania National
Bank & Trust Co., Scranton, Pa., applied to the Office
of the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
of “ Northeastern National Bank of Pennsylvania.”
Northeastern National Bank & Trust Co., the char­
ter bank, with IPC deposits of $266 million, was orga­
nized in 1863. In addition to its head office in Scranton,
it operates eight branch offices and one facility to serve
a three-county area.
The service area of the charter bank includes Lacka­
wanna County, where it operates its head office and
four branches; Luzerne County, where it operates one
branch in Wilkes-Barre and two in Hazleton; and
M oroe County, where it operates an office at Mount
Pocono and a facility at the U.S. Army Signal Corps
Depot at Tobyhanna. The economy of that rather ex­




$36, 908, 031
337, 036,311
373, 926, 831

To be
operated

In
operation

3
9

12

tensive service area is diversified, ranging from mining
of mineral resources (anthracite coal) to heavy and
light manufacturing to tourism. Once considered an
economically distressed area marked by high unem­
ployment, it is now enjoying steady employment and
a reasonably high per capita income; its future pros­
pects are good. Scranton, the head office city, has a
population of 112,000. The Scranton area is chiefly
residential with industrial manufacturing and service
industries present, including many nationally-known
corporations, and some agriculture in the outlying
areas.
Competition for the charter bank comes from, among
others, United Penn Bank, Wilkes-Barre, with IPC
deposits of $162 million; The First National Bank of
Wilkes-Barre, with IPC deposits of $137 million; Third
National Bank & Trust Co. of Scranton, with IPC de­
posits of $835 million; The Wyoming National Bank
of Wilkes-Barre, with IPC deposits of $635 million;
and Peoples First National Bank & Trust Co., Hazle57

ton, with IPG deposits of $55 million. In Scranton,
the charter bank competes with two other National
banks and five State banks, all of which are smaller in
size.
Pocono Bank, the merging bank, with I PC deposits
of $29.4 million, was organized in 1889. It operates
two branches, one each in Stroudsburg and Pocono
Pines, both of which are located in Monroe County.
The latter branch is 19 miles northwest of the bank’s
main office.
The Stroudsburg area is located in the southeastern
section of Monroe County. Stroudsburg, the county
seat, and East Stroudsburg are connected by two
bridges over Brodhead Creek. East Stroudsburg has a
population of 6,500, and serves an additional 203
000 to
25,000 in a trading area which overlaps that of the
Stroudsburg banks. Monroe County is traditionally
known as a Pocono Mountain resort area, and 75 per­
cent of the county’s economy is predicated on, or related
to, resort and tourist operations and real estate develop­
ment. A small amount of farming is done in outlying
sections of the county and light industry also lends
support to the economy. A local State teachers’ college
with 1,300 students also contributes to the economy.
The merging bank is the third largest bank in M on­
roe County. The two larger banks are the First Strouds­
burg National Bank, with deposits of $32.7 million,
and Monroe Security Bank & Trust Co., with deposits
of $35.4 million. First National Bank of Palmerton,
with deposits of $2.1 million, and the Pocono Mountain
office of the charter bank, with deposits of $6.1 million,
also operate in the county. The East Stroudsburg Build­
ing & Loan, with deposits of $6.2 million, and the
Stroudsburg office of First Federal Savings & Loan As­
sociation, Wilkes-Barre, with deposits of $2.2 million,
offer additional competition.
The merger would be of particular benefit to the
area in which the merging bank operates. A larger in­
stitution will emerge able to provide area business and
industry with much larger lines of credit, lower loan
rates, competitive deposit rates, sophisticated invest­
ment and trust counseling, and a reservoir o f lendable
funds, a commodity rapidly becoming depleted among
the Stroudsburg banks. The usual economies of scale
will be effected resulting in better service at lower cost.
Competition will not be adversely affected. The near­
est offices of the two banks are over 6 miles apart, and
serve essentially different areas. Accordingly, little
present competition between the banks exists. In the
service area of the charter bank, the resulting bank
would continue as the largest bank in the area, but its
lead will not be increased significantly. The other
58



banks in the area are strong and aggressive, and would
be unaffected. In the merging bank’ s service area, the
resulting bank would become the largest bank, but it
would not be in a position to dominate the other banks
in the area or monopolize the banking market.
Applying the statutory criteria, it is concluded that
the proposal is in the public interests. The application
is, therefore, approved.
M arch 2, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y G EN ER AL

The application indicates that Northeastern’ s Mount
Pocono office draws most of its deposits from the north­
western section of Monroe County, consisting of the
borough of Mount Pocono and adjacent townships of
Coolbaugh, Tobyhanna, Pocono, Paradise, and Bar­
rett. Its facility at the Tobyhanna Army Depot prob­
ably serves primarily employees there, which include
residents of neighboring counties, but it is also the only
banking office located in Coolbaugh Township. Until
recently, Pocono Bank operated no office in this area,
and the application indicates that the merging banks
drew little business from the two different sections
of the county which they served.
However, Pocono Bank recently opened an office in
Pocono Pines, in Tobyhanna Township, about 5 miles
from Mount Pocono. This office is still operating out
of a trailer, but it is the closest banking alternative to
Mount Pocono. It seems clear that the proposed
merger would eliminate competition between the merg­
ing banks that is presently developing in this area.
Four banks operate six banking offices in this north­
western section of the county, which has a total popula­
tion of about 9,300. The other two banks in Strouds­
burg, both comparable in size to Pocono Bank, operate
three of these offices, Northeastern two, and Pocono
Bank the sixth. As of June 30, 1968, Northeastern held
by far the largest share of deposits in the five offices
then existing, about 72 percent.
Under Pennsylvania law, Northeastern could be per­
mitted to open branch offices anywhere in Monroe
County. The Stroudsburg area, served by Pocono Bank,
is the most attractive possible site of such new branches,
but is not growing rapidly.
Stroudsburg and East Stroudsburg and adjacent sec­
tions of Stroud and Smith townships make up the only
major trading center in Monroe County. At present,
the Stroudsburg area is served by three banks, Monroe
Security Bank & Trust Co. (total deposits of $32 mil­
lion), First Stroudsburg National Bank (total de­
posits $31 million), and Pocono Bank. Pocono Bank
is slightly the smaller of the three.

Because the merger will eliminate growing compe­
tition between Pocono Bank’s new Pocono Pines office
and Northeastern’s Monroe County offices, and be­
cause of the elimination of the leading potential en­
trant into the Stroudsburg vicinity, it is clear that the
proposed merger would have an adverse effect on
competition.

O f the possible potential entrants into this area,
only three other banks have deposits of over $100
million, and all are substantially smaller than North­
eastern. The three banks in the Stroudsburg area are
approximately equal in size; there are no alternative
entry vehicles into the area whose acquisition by North­
eastern would present lesser anticompetitive effects.
*

*

*

Peoples N ational Bank of W ashington , Seattle , W ash ., and Bank of V ancouver , N.A.,
V ancouver , W ash .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Bank of Vancouver, National Association, Vancouver, Wash. (15538), with...........
was purchased Apr. 5, 1971, by Peoples National Bank of Washington, Seattle,
Wash. (14394), which had.........................................................................................................
After the purchase was effected, the receiving bank had.................................................

comptroller’ s decision

On December 2, 1970, Peoples National Bank of
Washington, Seattle, Wash., filed an application to
purchase the assets and assume the liabilities of Bank
of Vancouver, N.A., Vancouver, Wash.
Peoples National Bank of Washington, with IPC de­
posits of $337 million, was chartered as a State bank
in 1889. It was converted to a National bank in 1937.
The bank operates 50 branch offices in two distinct
market areas of Washington. A total of 38 of the
branches are located in the populous Puget Sound area
in the western portion of the State, and the remaining
12 branches are located in the Columbia Basin in the
east-central area of the State. The bank ranks fourth in
size among all commercial banks operating in Wash­
ington. Its two largest competitors, Seattle-First Na­
tional Bank, and The National Bank of Commerce of
Seattle, Seattle, Wash., together hold deposits repre­
senting over 50 percent of the total commercial bank
deposits in the State, and over seven times the deposits
of applicant bank.
Seattle’s metropolitan area has a population of 1.3
million persons. It has a fine deep water seaport and an
international airport, both of which are being ex­
panded. The city is known as the gateway to Alaska
and the Orient. It is considered by many to be the finan­
cial, educational, and cultural center of the Pacific
Northwest.
The economy of the city developed around the lum­
bering industry and the port facilities. While those

$4, 010, 447

1

504, 619, 151
506, 473, 110

52
53

remain important, Seattle has developed, since World
War II, into a wholesale and retail distribution center
and a major manufacturing center. The economy is
presently dominated by the aerospace industry, prin­
cipally the Boeing Co. This dominance subjects the
area to substantial cyclical swings.
The Columbia Basin, in which 12 of applicant’s
branches are located, is an area of farmland developed
as a U S. Government reclamation project made possi­
ble by construction of the Grand Coulee Dam. This
irrigation project has turned an arid desert into lush
farmland. Today, the area produces record crops of
sugar beets, hay, wheat, vegetables, and all kinds of
fruit, except citrus. There are 11 food processing plants
in the basin which annually process hundreds of mil­
lions of tons of food.
Bank of Vancouver, N.A., with IPC deposits of $3
million, was organized in 1965 under the sponsorship
of applicant bank. It operates one office in the city of
Vancouver. The bank experienced management diffi­
culties until 1968 when applicant bank provided ex­
perienced and qualified management. It is the smallest
of the four commercial banks operating in Vancouver.
Its competitors include branches of the two largest
banks in Washington, Seattle-First National Bank,
Seattle, and The National Bank of Commerce of
Seattle.
Vancouver, located across the Columbia River from
Portland, Oreg., has a trade area of approximately
100,000 persons. It is a port city and has a stable and
diversified economy with no one industry or firm domi-

59
4681-499 0 — 72-------- 5




nating. Its industries include aluminum processing,
metal fabricating, wood and paper products, textiles,
and electrical products. Vancouver’s port handles over
1.5 million tons annually, primarily exports of lumber,
aluminum, and agricultural products.
The nearest offices of the subject banks are more
than 120 miles apart which precludes any direct com­
petition between them. Therefore, approval of the ap­
plication will not lessen competition. Applicant bank
can not legally branch into Vancouver so there will be
no loss of potential competition. Consummation of the
proposed union will have the positive competitive effect
of introducing a strong viable competitor into the V an­
couver area and the surrounding market.
Approval of the application will allow the resulting
bank to offer services that are not presently available
to the customers of Bank of Vancouver, N.A. Those in­
clude trust services, automatic data processing services,

SU M M AR Y OF REPORT B Y A T T O R N E Y GENER AL

The closest offices of the participating banks are 120
miles apart. Therefore, it would not appear that any
significant amount of direct competition would be
eliminated by the proposed merger.
Washington law prevents banks from establishing
a de novo branch in any city or town where another
bank regularly transacts business (although it does per­
mit statewide expansion by acquisition or m erger).
Vancouver Bank is the smallest bank operating in the
city o f Vancouver, and one of the smallest banks serv­
ing Clark County. In Vancouver, it competes with
three other banks, including the two largest banks in the
State, Seattle-First National and National Bank of
Commerce. The third largest bank in the State also
operates an office in Clark County a few miles from
Vancouver. Thus, Peoples National is the largest bank
in the State not serving Clark County, and one of only
a few banks in the State large enough to expand into
new markets at will. It can enter Vancouver directly
only by acquisition of an existing bank, but it could
open an office in any community adjacent to V an­
couver which did not presently have a banking office,
and thus become an additional competitor in the highly
concentrated Vancouver banking market. This merger
will eliminate such potential competition, and elimi­
nate a bank which would provide a suitable foothold
for entry by a smaller competitor.

and, very important in the Vancouver area, interna­
tional services. The lending limit, which is now un­
realistically low, will be increased to a competitive
level. In addition, real estate loans, not previously
offered because of lack of funds and trained personnel,
will be available.
Applying the statutory criteria, we find the proposal
is in the public interest. The application is, therefore,
approved.
M arch 5, 1971.
*

*

*

W estern Pennsylvania N ational Bank , Pittsburgh, Pa ., and Provident T rust C o .,
Pittsburgh, Pa .

Banking offices
Name of bank and type of transaction

Total assets

Provident Trust Co., Pittsburgh, Pa., with..........................................................................
was purchased Apr. 30, 1971, by Western Pennsylvania National Bank, Pittsburgh,
Pa. (2222), which had.................................................................................................................
After the purchase was effected, the receiving bank had.................................................

comptroller’ s decision

On January 22, 1971, the Western Pennsylvania
National Bank, Pittsburgh, Pa., filed an application
with the Comptroller of the Currency for permission
to purchase the assets and assume the liabilities of
Provident Trust Co., Pittsburgh, Pa.
Provident Trust Co., with IPC deposits of $5.6 mil­
lion, was chartered in 1901. The bank operates from
one office in northside Pittsburgh. The president of the

60



In
operation

To be
operated

$7, 176,284

1

1, 090, 976, 777
1,098, 153.061

77
78

bank, a young man who took over the management
after his father’s recent death, wants to pursue other,
nonbanking, interests. All attempts to find successor
management have failed because of the bank’s inability
to properly compensate a competent individual. The
only reasonable alternative appears to be the sale of
the bank.
Western Pennsylvania National Bank, with IPC de­
posits of $759 million, was organized in 1871, in M c-

Keesport, Pa. It operates 73 offices serving a six-county
area surrounding Pittsburgh. The bank is an aggres­
sive full-service institution.
Western Pennsylvania National Bank receives com­
petition from the Mellon National Bank, which has
deposits of $4.4 billion, and the Pittsburgh National
Bank, which has deposits of $1.4 billion. Western
Pennsylvania National Bank ranks a distant third to
those competitors.
The economy of the Pittsburgh Standard Metropoli­
tan Statistical Area has, for many years, been based
on coal mining and the manufacturing of steel, ma­
chinery, electrical equipment, and glass. Although the
area now accounts for over one-fifth of the Nation’s
total annual steel production, its share has been de­
clining because most steel plants constructed since
W orld War II have located farther west, to be nearer
the steel consuming industries. Other important indus­
tries in the area are fabricated metal products and elec­
trical and nonelectrical machinery. Approximately
6.000 different products are made in area factories
which together employ 290,000 people. Research and
development, a relatively new industry, has grown to be
the third largest in the Pittsburgh area, employing over
15.000 persons. Not only is Pittsburgh a great industrial
city, but the four counties surrounding the city pro­
duce farm products valued at $42 million each year.
The nearest offices of the subject banks are 0.9 mile
apart. However, the Allegheny River separates those
two offices. Even though several bridges provides access
to both shores of the river, those two offices serve dif­
ferent trade areas. Therefore, consummation of the
purchase would not eliminate any significant competi­
tion in the area.
The service area of Provident Trust Co., the north
side area of Pittsburgh, is an older and economically
depressed section of the city. There are approximately
5,147 persons per banking office in this area. For the
remainder of Allegheny County, the corresponding
ratio is 6,516. For the other five counties in the Pitts­
burgh area, the corresponding ratio is 6,160. Those fig­
ures, in addition to the declining population in Provi­
dent National Bank’s service area, indicate that this
area could not support another banking office. Since
de novo branching into this area by Western Pennsyl­
vania National Bank is not feasible, consummation of
this purchase will not eliminate any potential
competition.

cies, will be of little assistance to the redevelopment
program. In contrast, Western Pennsylvania National
Bank has a reputation and history of molding its of­
fices to meet the specific needs of the communities they
serve. Its larger lending limit would make it a definite
asset to the redevelopment program in the area.
Consummation o f the purchase will allow Western
Pennsylvania National Bank to provide present cus­
tomers of Provident Trust Co. with many services that
they do not now enjoy. Those include guaranteed
check cashing service, revolving credit programs, com ­
puter services for local merchants, automobile sales
financing, and others.
Applying the statutory criteria, we find the pro­
posal is in the public interest. The application, there­
fore, is approved.
M a r c h 26, 1971.
SU M M AR Y OF REPORT B Y A T TO R N E Y G ENER AL

The nearest offices of Western Pennsylvania National
Bank and Provident are less than a mile apart, and
several other “ downtown” offices of Western Pennsyl­
vania National Bank are within close proximity of
Provident. Western Pennsylvania National Bank also
operates a branch in Millvale, about 2 miles from
Provident. The downtown Western Pennsylvania Na­
tional Bank offices are separated from Provident by
the Allegheny River, but five bridges link the down­
town area to the north side of Pittsburgh, where Provi­
dent is located. The proposed transaction will eliminate
some existing competition between Western Pennsyl­
vania National Bank and Provident.
Western Pennsylvania National Bank presently does
not operate offices in Pittsburgh’ s north side. However,
in view of proposed redevelopment activities in this
area, Western Pennsylvania National Bank, as one of
Pittsburgh’ s leading banks, should be considered a
likely potential entrant as the area becomes more
attractive. Accordingly, the proposed merger would
eliminate some potential competition.
As of June 30, 1968, 11 commercial banks operated
88 banking offices in the city of Pittsburgh. O f these
11 banks, three— Mellon National Bank & Trust Co.,
Pittsburgh National Bank, and Western Pennsylvania
National Bank— controlled 67 of the offices and over
90 percent of the total deposits held by all commercial
banking offices in Pittsburgh. Western Pennsylvania

Redevelopment has started in the service area of

National Bank, with 13 offices at that time, held about

Provident Trust Co. but the process is expected to take

6 percent of such deposits, while Provident held about

years to be fully effective. Provident Trust Co., because

0.2 percent.
Because of the high degree o f concentration in com-

of its limited lending authority and its conservative poli­




61

mercial banking in the city of Pittsburgh (which may
actually overstate the market h ere), we conclude that
*

the proposed transaction would have some advers
effect on competition.
*

*

T he First N ational Bank of Belleville , Belleville , III ., and T he St . C lair N ational Bank of
Belleville , Belleville , I I I .

Banking offices
Name of bank and type of transaction

Total assets

The St. Clair National Bank of Belleville, Belleville, 111. (11478), with......................
and The First National Bank of Belleville, Belleville, 111. (2154), which had............
merged May 24, 1971, under charter of the latter bank (2154) and title “ First
National Bank of Belleville.” The merged bank at date of merger had......................

comptroller’ s decision

On December 3, 1970, the $70 million First Na­
tional Bank o f Belleville, Belleville, 111., and the $19.7
million St. Clair National Bank of Belleville, Belleville,
111., applied to the Comptroller of the Currency for per­
mission to merge under the charter and with the
title of “ First National Bank o f Belleville.”
The First National Bank of Belleville was chartered
in 1874 to meet the needs of the city of Belleville.
It is now a full-service bank with a large trust depart­
ment, and it records IPC deposits of $49.4 million.
Growth during the last 10 years has been excellent;
however, the bank ranks second in size to the Belleville
National Savings Bank which has had even more
remarkable growth, and now has IPC deposits of $62
million. The First National Bank of Belleville main­
tains driveup facilities in the rear of, and attached to,
its main office. In addition, it maintains a military
facility at Scott Field Air Force Base. The charter
bank has adequate capital, and growth prospects for
the future are good.
The St. Clair National Bank of Belleville, with
IPC deposits of $17.3 million, was chartered in 1919.
Over the years it has acquired a reputation as a con­
servative bank dealing largely in real estate loans and
loans secured by stocks or insurance. In 1964, the
bank undertook a much more liberalized program.
The bank began its own credit card operation, leased
computer facilities, acquired new banking headquar­
ters, and set up a consumer credit department based
on purchased dealer paper. Because the new programs
were initiated without adequately trained personnel,
mistakes and losses were significant. Consequently, the
capital structure of the bank declined.
62




$19, 121,306
70, 939, 305

In
operation

To be
operated
2
1

90,060,611

2

Belleville, with a population o f 41,100, is the county
seat of St. Clair County, population 279,000. The city
is located about 15 miles southeast of St. Louis, and
about 12 miles east of East St. Louis. Belleville is af­
fected to some extent by the political and economic
conditions of St. Louis and East St. Louis. It is the site
of approximately 70 small manufacturing plants, in­
cluding producers of stoves, shoes, garments, stencil
machines, and beer. While the city has a good retail
center, congestion in downtown Belleville inhibits re­
tail growth. Instead, there is much growth and devel­
opment in a commercial area between Belleville and
East St. Louis. A large number of strip mines are
located in the vicinity o f Scott Air Force Base, the
headquarters for the Military Air Transport Service,
the Air Weather Service, the Air Rescue and Recovery
Service, and the 1400th Air Base Wing, northeast of
the city. Base personnel, in 1968, totaled 6,400 military
and 3,600 civilian employees, making the base
the largest single employer in the portion o f that
Standard Metropolitan Statistical Area that lies east
of the Mississippi. The base annually injects about
$75 to $80 million into the area economy.
The St. Clair National Bank and the The First
National Bank of Belleville are located within three
blocks of each other. Until the middle 1960’s the
merging bank was largely noncompetitive, seeking no
new customers and accepting only secured or “ safe”
loans. Consequently deposits remained around $12
million. With the advent of their new aggressive bank
policies in 1964, the bank entered a period designed
to compete directly with the other banks in Belleville
and other banks that serve the Belleville-East St. Louis
area. Bank deposits increased, but losses also grew. A l­

though the merger will remove a competitor, the merg­
ing bank’s financial affairs warrant this help. It appears
to this Office that the public needs and convenience
of this merger clearly outweigh whatever anticom­
petitive effects may be attributed to it.
The merger will not have an adverse effect on the
area banking structure. Although the charter bank
will become the largest institution in Belleville, its office
will be in the downtown area rather than in the devel­
oping area toward East St. Louis, and Illinois law pre­
vents de novo branching, thereby negating any poten­
tial for future branches. In this proposal, the charter
bank is taking over a bank whose internal problems
will require time and experienced personnel to solve.
In the meantime, aggressive competition can be ex­
pected from other financial institutions in the imme­
diate vicinity of Belleville, the $70 million Belleville
National Savings Bank, the $27 million Midwest Home
Savings & Loan, the $75 million Greater Belleville
Citizens Savings & Loan, the $18.9 million Bank of
Bellville, the $10.6 million Security Savings & Loan
Association, and the $5 million Bankers Trust Co., as
well as those banks in the city of St. Louis and the
other suburban cities within 10 miles of Belleville, in­
cluding East St. Louis, Collinsville, Granite City, and
National City.
The proposed merger will resolve many of the prob­
lems now clouding the future of the merging bank.
Management of the charter bank is able and equipped
to carry out the aggressive banking policies initiated by
the merging bank. There will be no reduction in serv­
ices to the merging bank’ s customers, and the increased
lending limit of the charter bank will allow it to in­
crease its loans both to private individuals and busi­
nesses and to the municipality of Belleville.
Applying the statutory criteria to the proposed mer­
ger, we find that it is in the public interest. The appli­
cation is, therefore, approved.
A

p r il

20, 1971.*




SU M M ARY OF REPORT B Y A T TO R N E Y G ENERAL

The head offices of the two institutions are both
located in downtown Belleville, just three blocks
apart. It is clear, therefore, that substantial existing
competition would be eliminated by the proposed
merger.
As of June 30, 1970, five commercial banks operated
offices in Belleville, and held $158.5 million in total
deposits. First National, the largest of the five banks,
held 39.2 percent of such deposits, while St. Clair Na­
tional, the city’s third largest bank, controlled 13.2 per­
cent of such deposits. The resulting bank would thus
control 52.4 percent of the total deposits held in the
Belleville banks, and the share of the two largest Belle­
ville commercial banks would increase from 73.5 to
86.7 percent.
As of the same date, 25 commercial banks main­
tained offices in St. Clair County, and held total de­
posits of $505.8 million. First National, the second
largest of such banks, had 12.2 percent of county de­
posits, while St. Clair National, the sixth largest, held
4.1 percent. The resulting bank, while still ranking
second in the county, would control 16.3 percent of
total county deposits, and the shares held by the four
largest banks in the county would increase from 51.5
to 55.6 percent.
The proposed merger would eliminate the substan­
tial existing competition between the merging banks,
and substantially increase concentration in commer­
cial banking both in Belleville and in St. Clair County;
and therefore it would have a significantly adverse
effect on competition in the area. However, under Illi­
nois law, there is no other less anticompetitive merger
alternative for St. Clair National which has experi­
enced substantial operating losses and declining de­
posits in recent years; therefore, it appears that this
merger may well qualify under the “ convenience and
needs” defense (12 U.S.C. § 1 82 8(c)) as interpreted
in United States v. Third National Bank in Nashville,
390 U.S. 171.

*

63

M arine M idland Bank -E astern , N .A., T roy , N.Y., and C atskill N ational Bank
C atskill, N .Y.

& T rust C o .,

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Catskill National Bank & Trust Co., Catskill, N .Y . (1294), with................................
and Marine Midland Bank-Eastern, National Association, Troy, N .Y . (721),
which had........................................................................................................................................
merged May 28, 1971, under charter and title of the latter bank (721). The merged
bank at date of merger had.......................................................................................................

comptroller ’ s decision

O n December 31, 1970, Catskill National Bank &
Trust Co., Catskill, N.Y., and Marine Midland BankEastern, National Association, Troy, N.Y. applied to
the Office of the Comptroller of the Currency for per­
mission to merge under the charter and with title of
the latter.
Marine Midland Bank-Eastern, National Associa­
tion, the charter bank, with I PC deposits of $109.9
million, was organized in 1852. In addition to its head
office, it operates 14 branch offices in various parts of
the Fourth Banking District and has three approved
but unopened branches. This bank is a member of the
$5.9 billion Marine Midland Banks, Inc., a registered
bank holding company.
Most o f the charter bank’s offices are located in the
Capital District which comprises Albany, Rensselaer,
and Schenectady counties. That area has an approx­
imate population of 690,000, and is the third largest
trade area in the State. It contains the cites o f A l­
bany, the trade center of the district and the State capi­
tal; Schenectady; and Troy, which is the head office
location of the charter bank. The city of Troy, with
a population of 62,000, is a commercial, educational,
and industrial center. The products o f its industries in­
clude abrasives, guns, surveying instruments, clothing,
tools, paper, springs, paints, and automotive and air­
plane parts. The Fourth Banking District generally re­
flects the varied economic characteristics of residential,
agricultural, commercial, and industrial activity.
As of June 30, 1970, the charter bank was the largest
of the four banks based in Rensselaer County. It held
$126.8 million in deposits. It ranked fourth in size
among the 36 banks in the Fourth Banking District. Its
competitors includes the $845 million State Bank of
Albany, Albany; the $815 million National Commer­
cial Bank & Trust Co., Albany; the $197 million First
Trust Co. of Albany, National Association, Albany;
the $124 million Schenectady Trust Co., Schenectady;

64



$6, 930,086

1

171,800,719

15

178,613,694

16

and the $107 million First National Bank o f Glens
Falls, Glens Falls, N.Y. In addition, competition is fur­
nished by the savings banks located in the AlbanySchenectady-Troy area.
Catskill National Bank & Trust Co., the merging
bank, with IPC deposits of $4.7 million, was or­
ganized in 1813, and received its National charter in
1965. This is a unit bank and its condition is good. The
bank does have a management succession problem
since the bank’s chief executive officer in 82 years old
and there is no depth o f management within the bank.
The village of Catskill, in which the only office of
the merging bank is located, has a population of 5,233,
and is the county seat and economic center of Greene
County, which has a population of 32,000. Greene
County is basically rural, with its population concen­
trated along its eastern border. The economic base o f
the county consists of agriculture, manufacturing, and
retail trade and services supporting the tourist indus­
try. Its economic future is largely dependent upon its
ability to maintain and successfully promote its tourist
industry. The majority of the hotel, motel, and tourist
establishments in the county are located in or near
the village of Catskill.
As of June 30, 1970, the merging bank was the
smallest of three banks based in Greene County, hold­
ing $6 million in deposits. It ranked 30th in size among
the 36 commercial banks in the Fourth Banking Dis­
trict which together hold aggregate deposits of $2.6
billion. Competitors o f the merging bank include the
$845 million State Bank of Albany, Albany; the $815
million National Commercial Bank & Trust Co., A l­
bany; the $197 million First Trust Co. of Albany,
National Association, Albany; the $10 million Tanners
National Bank of Catskill; and the $8 million National
Bank of Coxsackle, Coxsackle, N .Y .
The resulting bank would introduce additional and
expanded services to residents and businessmen of
Greene County, including a substantially larger lend­

ing limit, overdraft banking, customer electronic data
processing facilities, trust investment, advisory services,
and higher interest rates on several types of savings
plans. It would also provide international banking fa­
cilities and specialized lending services. The severe
management succession problem in the merging bank
would also be resolved.
Competition will not be adversely affected by con­
summation of the proposed transaction. Because the
nearest office of the charter bank is 34 miles from the
merging bank, existing competition between the two
is nonexistent. Further, under New York law, the home
office protection afforded the merging bank and the
Farmers National Bank of Catskill prevents de novo
branching into Catskill by the charter bank. In the
present service area of the charter bank, the addition
to it of the much smaller merging institution would
have a negligible effect. The merger would have a
favorable effect on Greene County. In the Fourth
Banking District, the resulting institution would con­
tinue to rank as fourth largest of the 35 commercial
banks.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
A pril 23, 1971.

ing city of Albany. Catskill Bank does not draw any
banking business from Marine-Eastern’s service area;
the amount of banking business drawn by MarineEastern from Catskill Bank’s service area is negligible.
The merger would not have a substantially adverse ef­
fect on existing competition between these two banks.
Another subsidiary of Marine Midland Banks, Inc.,
Marine Midland Bank of Southeastern New York,
N.A., operates banking offices in the Third District, to
the south of Greene County. This bank has pending an
application to merge with The National Bank of
Orange and Ulster Counties, which operates three
offices in northern Ulster County, not far from the
Greene County border. These offices are somewhat
closer to Catskill Bank than those of Marine-Eastern.
However, according to the application filed by Marine
Southeastern, the service area of these three offices does
not extend into Greene County. Substantial forest re­
serves intervene. Thus, it does not appear that the pro­
posed merger would eliminate substantial direct com­
petition between Catskill Bank and any other affiliate
of Marine Midland Banks.
Under New York law, Marine-Eastern could be
permitted to open de novo branch offices in Greene
County, but not in communities subject to home office
protection, including Catskill. In view of the economy

S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

and static population of Greene County, and the size

Catskill Bank is 34 miles south of Marine-Eastern’s
closest branch in Albany County. Numerous banking
alternatives intervene, including those in the interven­

merger would have a significantly adverse effect on po­

of Catskill Bank, we do not believe that the proposed
tential competition.
*

U nited V irginia Bank /S eaboard N ational , N orfolk , V a ., and E astern Shore C itizens Bank ,
O nangogk, V a .

Banking offices
Name of bank and type of transaction

Total assets

Eastern Shore Citizens Bank, Onancock, Va., with..........................................................
and United Virginia Bank/Seaboard National, Norfolk, Va. (10194), which h a d ..
merged June 1, 1971, under charter and title of the latter bank (10194). The
merged bank at date of merger had......................................................................................

$11,379, 332
204, 230, 352

comptroller’ s decision

On February 16, 1971, Eastern Shore Citizens Bank,
Onancock, Va., and United Virginia Bank/Seaboard
National, Norfolk, 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.




213, 599,458

In
operation

To be
operated

4
19
23

United Virginia Bank/Seaboard National, the char­
ter bank, with I PC deposits of $141.8 million, was the
result of a merger, in 1928, of the Citizens Bank of Nor­
folk, chartered in 1867, and The Seaboard National
Bank, incorporated in 1904. In addition to its head of­
fice, it operates 17 offices throughout tidewater
Virginia.

65

Norfolk, Va., population 307,951, is an independent
city in the tidewater area of Virginia, adjacent to the
cities of Virginia Beach, Portsmouth, and Chesapeake.
The area is highly industrialized and constitutes the
southern portion of the port complex of Hampton
Roads. A concentration of military activities in the
area also influences the local economy. The area is
separated geographically from the Eastern Shore area
by some 18 miles of water, and is now connected by a
toll bridge.
Competition in the Norfolk-Portsmouth-tide water
area is intense among 16 banks, which, besides the
charter bank’s 18 offices, operate 101 offices. The
charter bank’s four largest competitors are the $1 bil­
lion Virginia National Bank, the $783 million First &
Merchants National Bank, the $70 million First V ir­
ginia Bank of Tidewater, and the $65.5 million Ameri­
can National Bank of Portsmouth. Three of the re­
maining banks are in the $20 to $30 million range, and
some of the smaller banks are affiliated with holding
companies. Other financial institutions include nine
savings and loan associations, four industrial loan or­
ganizations, 10 sales finance, and 22 personal loan com ­
panies. Various insurance companies, 61 credit unions,
and government lending agencies are also active.
Eastern Shore Citizens Bank, the merging bank,
with IPC deposits of $9.6 million, was chartered in
190& in Onancock, Va. It operates four offices, at
Onancock, Keller, Painter, and Accomack, all in
Accomack County.
Onancock, Va., with a population of 1,614, is lo­
cated on the Eastern Shore of Virginia. That area has
been largely dependent upon farming, seafood, and
timbering for its economic base. In recent years, farm­
ing has tended toward larger units. Poultry raising and
poultry processing plants provide employment for sev­
eral hundred area inhabitants. The National Aero­
nautical and Space Administration has a facility at
Wallops Island, 25 miles from Onancock. The 1960-70
population trends in Accomack and adjacent North­

Co. Nearby, in adjacent Northampton County, are the
single-office $2.9 million deposit National Bank of
Northampton, Nassawadox, and the single-office $6.7
million deposit Peoples Trust Bank, Exmore. Compet­
ing nonbank financial institutions include savings and
loan associations, finance companies, commercial loan
companies, insurance companies, and credit unions.
Approval of the proposed merger should prove bene­
ficial to the merging bank’s customers because, as an
office of the resulting bank, it will have a larger lending
limit, a greater reservoir of deposits, more sophisticated
banking services, and management continuity which
will be provided by the charter bank. At the present
time, the large-scale banking needs of agriculture, light
industry, and other businesses are reportedly handled
by the larger out-of-area banks in Maryland and Dela­
ware, because of their proximity and accessibility. The
charter bank will benefit from the merger because it
will be able to expand its operations into the Eastern
Shore area and, through its expertise in banking, will
be able to assist in serving the economic needs of the
area. The resulting bank’s operations in the merging
bank’s service area should continue to be profitable.
Competition will not be adversely affected by con­
summation of this transaction. Because the closest
offices of the two banks are 50 miles apart there is
no present competition between them. In the present
service area of the merging bank, introduction of the
charter bank should stimulate competition without dis­
advantaging the smaller banks operating in the area.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application
is, therefore, approved.
A pril 20, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y G EN ER AL

Seaboard, the United Virginia Bankshares affiliate
nearest to Eastern Shore, operates offices about 60 to
80 miles southwest of Eastern Shore’s offices. The East­
ern Shore is separated from the Norfolk-Portsmouth

ampton counties show declines of 5.3 and 14.9 per­

SMS A by a toll bridge which spans 18 miles of water.

cent, respectively; current county populations total

The amount of business each bank derives from the

29,004 and 14,442, respectively.

service area of the other bank is very small. The pro­

In Accomack County, the merging bank competes
with the $15.4 million deposit Hailwood branch of the

posed merger would not have an adverse effect on di­
rect competition.

$388.6 million Bank of Virginia, Richmond, V a .; with

Under Virginia law, a bank cannot establish a de

the single-office $8.8 million deposit Farmers and

novo office more than 5 miles beyond the limits of the

Merchants National Bank in Onley; with the single­
office $9.0 million deposit First National Bank in

ty in which it is headquartered. Thus, United V ir­

city in which it is headquartered, or outside the coun­

Onancock; and with the Parksley and Bloxom offices

ginia Bankshares cannot expand its banking operations

of the $6.2 million deposit Metompkin Bank & Trust

into the service area o f Eastern Shore through the es­

66



bank of Virginia Commonwealth Bankshares, held the
largest share, 27 percent. The third and fourth largest
banks held about 15 and 14 percent, respectively.
United Virginia Bankshares (aggregate deposits $1
billion) has the capability to enter this area by estab­
lishing a de novo bank or by acquiring a bank with a
small share of the deposits in the area. The proposed
merger would eliminate this source o f potential
competition.

tablishment of a branch office by Seaboard or another
affiliate bank. However, United Virginia Bankshares
could enter Eastern Shore’s service area by establishing
a new bank.
Eastern Shore holds the second largest share of de­
posits held among the seven banks which operate offices
in its service area. As of June 30, 1970, it held about
17 percent of the total deposits of banks in its service
area. A branch office of Bank of Virginia, a subsidiary
*

*

*

A merican N ational Bank & T rust, M ontclair , N.J., and T he Second N ational Bank of Phillipsburg,
Phillipsburg, N.J.

Banking offices
Total assets

Name of bank and type of transaction

The Second National Bank of Phillipsburg, Phillipsburg, N.J. (5556), w ith ...........
and American National Bank & Trust, Montclair, N.J. (4274), which had............
merged June 4, 1971, under charter and title of the latter bank (4274). The merged
bank at date of merger had......................................................................................................

comptroller' s decision

On February 17, 1971, The Second National Bank
of Phillipsburg, Phillipsburg, N.J., and American Na­
tional Bank & Trust, Montclair, N.J., applied to the
Comptroller of the Currency requesting permission to
merge under the charter and title of the latter.
The Second National Bank of Phillipsburg, which
presently has IPC deposits of $18.3 million, was estab­
lished in 1900, and operates two banking offices in
Phillipsburg. The bank is reported to be in good con­
dition, but because of its small size it lacks sufficient
experienced management staff to assure continued suc­
cessful operation upon the imminent retirement of its
present responsible executives.
Phillipsburg is a small industrial city on the Delaware
River in the southwest corner of Warren County, N.J.
Its population was 18,500 in 1960, 28,500 if the popu­
lation of the bordering suburbs is included. In 1970,
Phillipsburg had a population of 17,800. Easton, Pa.,
lies directly across the river. It had a 1960 population
of 32,000; 60,000 counting its surrounding suburbs.
Its population, like that of Phillipsburg, has declined
somewhat over the past decade, while its suburbs have
shown an increase. The two cities are linked by two
bridges, and may, for certain purposes, be considered
as one. Seven other banks serve the PhillipsburgEaston complex. Three o f those banks are located in
Phillipsburg itself. All of those banks have been charac­




$22, 755, 785
367, 548, 851
390, 288, 412

In
operation

To be
operated

2
30
32

terized as small. The Second National Bank is one o f the
smallest. While Phillipsburg is primarily a residential
and industrial area, the surrounding Warren County
countryside is devoted largely to dairy farming and
some light industry. Prospects for growth in the metro­
politan area are favorable.
American National Bank & Trust is the result of
the consolidation of Montclair National Bank & Trust
Co. and the Trust Co. National Bank, which is located
in Morristown. This bank has IPC deposits of $273.5
million, is in good condition, and enjoys competent
management. It is headquartered in Montclair, Essex
County, N.J., and operates a total of 30 banking offices
in Morris, Sussex, and Warren counties.
Montclair is an old and wealthy residential suburb
of New York City and of Newark, the largest city in
New Jersey. It has a population of 43,000, and local
competition is provided by The Montclair Savings
Bank and a branch of National Newark and Essex
Bank.
The bank also maintains an administrative head­
quarters in Morristown, in Morris County. Morristown
is also an established residential suburb, however, it is
located in a more rapidly growing area of New Jersey
than is Montclair. Local competition is provided by
First Morris Bank, The First National Iron Bank of
New Jersey, and The Morris County Savings Bank.
The vast majority of American Bank & Trust’s business

67

This Office is of the opinion that the proposed
merger will have no adverse competitive effect and is
in the public interest. The application is, therefore,
approved.
A pril 23, 1971.

is derived from Morris County and the western part of
Essex County. Competition is keen in that market area.
Both Second National Bank of Phillipsburg and
American National Bank & Trust are located in the
recently created First Banking District of New Jersey.
Until July 1969, the New Jersey statutes limited com­
mercial and savings bank branching and merging to
one county. The new law, which became effective at
that time, divides the State into three banking dis­
tricts and permits branching and mergers within the
district in which the bank’s head office is located. Head
office protection is complete. The First District is com­
posed of the counties of Bergen, Essex, Hudson, Morris,
Passaic, Sussex, and Warren. The northern and eastern
part of the district is heavily industrialized, while the
southern and eastern portions, where Phillipsburg is
located, is rather rural, with many farms. The middle
portion of the district is primarily residential, and is the
home of many wealthy families and executives who
commute to New York City. That is where American
National Bank & Trust finds its market area. The
district has a population of 3.5 million, and supports
the operation of 84 commercial banks.
There is no direct competition between the appli­
cant banks. American National Bank & Trust operates
one branch in Warren County at Harmony, 3.8 miles
from Second National Bank of Phillipsburg’s only
branch office. It has been determined that no com­
petition exists between those two banks. American Na­
tional Bank & Trust’s position as ninth largest bank
in the seven-county district will not change as a result
of the merger.
The competitive atmosphere in the PhillipsburgEaston area, however, will be greatly enhanced as a
result of the merger. Continued operation of the
Phillipsburg facilities will be assured. In addition, the
Phillipsburg offices will offer that area new services not
now available at The Second National Bank of
Phillipsburg.
*

SU M M AR Y OF REPORT B Y A T TO R N E Y GENERAL

The home offices of the two banks are about 60
miles apart. American National Bank & Trust’s single
office in Warren County, however, is located at Har­
mony, only about 4 miles from the closest office of
Phillipsburg Bank, with no other banking offices inter­
vening. Thus, there is undoubtedly some competition
between the two banks. The Harmony office of Ameri­
can National Bank & Trust, however, is new to the
area, having been opened de novo, in December of
1970. Thus, American National Bank & Trust is not
presently a major factor in the Phillipsburg area.
The home office protection provision of New Jersey
law prohibits American National Bank & Trust from
branching de novo into Phillipsburg. Likewise, the
Warren County communities immediately adjacent to
Phillipsburg are closed to de novo branching by Ameri­
can National Bank & Trust, by virtue of the branch
office protection provision in New Jersey law, which
applies to communities having a population of less
than 7,500. Even should Phillipsburg and the sur­
rounding communities be open to de novo entry in the
future, the relative size of Phillipsburg Bank and the
existence of several other large New Jersey banks
which could enter the area would diminish the impact
upon potential competition from this proposed merger.
Nevertheless, it is clear that as the Harmony office of
American National Bank & Trust grows, competition
between it and Phillipsburg Bank would increase. We
conclude, therefore, that the proposed merger would
have some adverse effect upon potential competition.
*

*

N e w J ersey Bank (N .A .), C lifton , N.J., and Phillipsburg T rust C o ., N .A., Phillipsburg, N.J.

Banking offices
Name of bank and type of transaction

Phillipsburg Trust Co., National Association, Phillipsburg, N.J. (15648), w ith .. . .
and New Jersey Bank (National Association), Clifton, N.J. (15709), which h a d ...
merged June 4, 1971, under charter and title of the latter bank (15709). The
merged bank at date of merger had.......................................................................................

68




Total assets

$15, 918, 650
584, 769, 524
600, 688, 157

In
operation

To be
operated

2
26
28

comptroller ’ s decision

On March 1, 1971, the Phillipsburg Trust Co., Na­
tional Association, Phillipsburg, N.J., and the New
Jersey Bank (National Association), Clifton, N.J., ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter and title of the latter.
Phillipsburg Trust Co., N.A., which presently has
IPC deposits of $13.3 million, was originally organized
as a State-chartered institution in 1917. It established
its only branch office at Pohatcony Township in 1961,
and in February 1968, converted to a National bank,
adopting its present name. It is the smallest of the com ­
peting banking institutions in the Phillipsburg area. A l­
though the bank is in good condition, it lacks sufficient
management depth to ensure continued successful op­
eration past the retirement of its key executive officers.
Phillipsburg is a small industrial city on the Dela­
ware River in the southwestern corner of Warren
County, N.J. Its population was 18,500 in 1960 and
17,850 in 1970. The population of Warren County,
however, increased from 63,200 to 73,800 in the same
period. Easton, Pa., lies directly across the river. It had
a population of 32,000 in 1960. Its population pattern
has paralled that of Phillipsburg. The cities are linked
by two bridges, and, for certain purposes, may be
considered as one town. While the economy of the city
has shown some signs of decay, the surrounding coun­
tryside, which is largely farmland with some light in­
dustry, has shown increasing signs of development for
residential purposes. This trend is expected to continue.
New Jersey Bank (N .A.) was established in 1869 un­
der a State charter, with the title The Paterson Savings
Institution. The bank acquired the charter for a trust
company in 1947, and changed its name to The Pater­
son Savings & Trust Co. In April 1969, the bank, then
known as New Jersey Bank & Trust Co., received a
charter as a National bank, and adopted its present
title. The bank also acquired The Peoples National
Bank of Sussex County, located in Sparta, N.J., and the
Jersey State Bank, located in River Edge, N.J., in
.1970. As of December 31, 1970, it had IPC deposits of
$412.1 million. This bank enjoys an experienced and

plex, and is a popular residence for many persons work­
ing in Manhattan.
Passaic County is within 15 miles of midtown M am
hattan. In the past decade, the county’s population has
increased to 500,000. The local economy is largely resi­
dential but with a continuing emphasis on industry.
Many industries have recently moved from New York
City to New Jersey. Continued rapid growth is
expected.
Bergen County, located to the northeast of Passaic
County, has experienced much the same growth pat­
terns as its neighbor. Ready access to New York City
is provided by the George Washington Bridge. Popu­
lation forecasts indicate that the county may expect
continued rapid growth. Sussex County is largely rural
in nature.
Competition is keen throughout the bank’s market
area. Effective competition is also provided by the
New York City banks, not only because many local
residents work in the city, but also because many of
the industries which have relocated in New Jersey
have maintained New York banking connections.
Both Phillipsburg Trust Co., N.A., and New Jer­
sey Bank (N.A.) are located in the First Banking
District of New Jersey. Until a recent change in the
law, New Jersey statutes limited commercial and sav­
ings bank branching and merging to one county. The
new law, effective July 1969, divided the State into
three banking districts and permitted branching and
mergers within the district in which the bank’s head
office is located. The First District is composed of
the counties of Bergen, Essex, Hudson, Morris, Passaic,
Sussex, and Warren. The northern and eastern part
of the district is generally heavily industrialized and
the location of many suburban residential towns, while
the southern and western portions, where Phillipsburg
is located, is generally rural in nature. The entire
district has a population of about 3.5 million, and sup­
ports the operation of 84 commercial banks.
There is no direct competition between the appli­
cant banks. The proposed merger will not eliminate
any competition. All offices of the Phillipsburg bank

capable management staff of sufficient depth to as­

will be maintained so that the convenience of the

sure sound operation for the future.

Phillipsburg banking public will not be diminished.

New Jersey Bank (N .A.) is headquartered in Clif­

In addition, the resulting bank will bring a higher

ton, Passaic County, N.J. The bank operates 26 offices

lending limit to the Phillipsburg area along with the

in 22 communities. Eleven of those communities are

other services unique to a large bank.

in Passaic County, eight in Bergen County, and three

This Office finds that the merger will have no

in Sussex County. The population of the three coun­

anticompetitive effect and is to the public benefit.

ties is estimated to be 1.5 million. The entire area is

The application is, therefore, approved.

located within the New York City metropolitan com ­




A pril

21, 1971.

69

in the New Jersey law, which proscribes de novo
branching into communities having a population of
less than 7,500 which are already served by a branch
office of a commercial bank.

SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

The home offices of the merging banks are about
62 miles apart and the closest branch of New Jersey
Bank is more than 40 miles from Phillipsburg. Thus,
it would not appear that the proposed merger would
eliminate any substantial existing competition between
the two institutions.
The home office protection provision of New Jersey
law prohibits New Jersey Bank from branching de
novo into Phillipsburg. The Warren County commu­
nities immediately adjacent to Phillipsburg are also
closed to de novo

branching by New Jersey Bank,

by virtue of the branch office protection provision

However, even if Phillipsburg and its surrounding
communities were to open de novo branching in the
future, the relative size of Phillipsburg Trust, and the
existence of several other large northern New Jersey
banks which have the capability and resources to enter
the area de novo, would diminish the impact upon
potential competition from this proposed merger. We
conclude, therefore that the proposed merger would
not have a significantly adverse effect on competition
in the Phillipsburg area.
*

First N ational Bank in M anitowoc , M anitowoc , W is., and State Bank of Francis C reek , Francis C reek
W

is .

Banking offices
Name of bank and type of transaction

Total assets

State Bank of Francis Creek, Francis Creek, Wis., with...................................................
was purchased June 15, 1971, by First National Bank in Manitowoc, Manitowoc,
Wis. (4975), which had..............................................................................................................
After the purchase was effected, the receiving bank had.................................................

c o m p t r o l l e r ’s

d e c is io n

On February 23, 1971, First National Bank in M ani­
towoc, Manitowoc, Wis., applied to the Comptroller
of the Currency for permission to purchase the assets
and assume the liabilities of State Bank of Francis
Creek, Francis Creek, Wis.
First National Bank in Manitowoc has IPC deposits
of $22 million, and was established in 1894. It operates
one office in Manitowoc. It is reported that the appli­
cant bank is adequately capitalized, soundly managed,
and has no serious asset problems. Competition is pro­
vided by M anitowoc County Bank and Manitowoc
Savings Bank. Manitowoc is the county seat of Mani­
towoc County, has a population of approximately
33,000, and is characterized as primarily industrial.
State Bank of Francis Creek was established in 1916,
and operates as a unit bank. As of December 1970, it
had IPC deposits of $3.6 million. Francis Creek is
located 8.5 miles northwest of Manitowoc, and its
economy is primarily agricultural. Because of its small
size and rural location, State Bank of Francis Creek
has had difficulty in attracting an adequate banking
staff that could successfully manage the bank upon the
70



In
operation

To be
operated

’ $4, 202, 000

1

33, 567, 792
33, 020, 103

1
2

retirement of the majority of the present staff. The
present ownership has therefore decided that a sale
of the bank’s assets and an assumption of its liabilities
by a more viable banking institution would be in the
interest of the bank and the community it serves. There
is little significant competition between the banks and
consummation of the proposed transaction will not
lessen competition in the area served by the banks.
It is therefore concluded that the purchase of the
assets and the assumption of the liabilities of State
Bank of Francis Creek by First National Bank of
Manitowoc will have no anticompetitive effect and is
in the public interest. The application is, therefore,
approved.
M ay 3, 1971.
SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

The participating banks are located 9.5 miles apart
in separate communities. There is one banking alterna­
tive in the intervening area. It would appear that the
proposed acquisition would eliminate some existing
competition between these banks.
A total of five banks, including the parties to this

The proposed acquisition would eliminate some di­
rect competition between the participants and would
eliminate an independent banking unit in Francis
Creek. Additionally, it would somewhat increase con­
centration among commercial banking institutions in
Manitowoc County, particularly in the northeastern
third of the county.
We conclude that the proposed merger would have
at least some adverse effect on competition.

transaction, operate seven offices within the north­
eastern third of Manitowoc County where the effects
of this acquisition will be felt. If the proposed acquisi­
tion were consummated, First National would increase
its share of deposits in this area from 32.6 to 38.3
percent. First National would entrench its position as
the largest commercial bank in this area. It would
also maintain its rank of second among the 16 com ­
mercial banks operating in Manitowoc County.

*

*

*

U nited States N ational Bank , San D iego, C alif ., and H ollywood N ational Bank , L os A ngeles, C alif .

Banking offices
Name of bank and type of transaction

Total assets

Hollywood National Bank, Los Angeles, Calif. (15442), with......................................
and United States National Bank, San Diego, Calif. (10391), which had...............
merged June 25, 1971, under charter and title of the latter bank (10391). The
merged bank at date of merger had.....................................................................................

c o m p t r o l l e r ’s

d e c is io n

On February 17, 1971, the United States National
Bank, San Diego, Calif., and the Hollywood National
Bank, Los Angeles, Calif., applied to. the Comptroller
of the Currency for permission to merge under the
charter and with the title of the “ United States Na­
tional Bank.”
The $596 million United States National Bank,
which opened in 1913 in San Diego, Calif., presently
operates 58 branches and has IPC deposits of $394.4
million. Since 1950, the bank has experienced rapid
growth commensurate with the dynamic growth of
southern California. Its main office and 12 of its
branches are situated in San Diego County. It also has
12 branches in Orange County, two branches in River­
side County, four branches in San Bernardino County,
and 28 branches in Los Angeles County. In addition,
the bank has received approval to open another branch
in Orange County.
The $10.7 million Hollywood National Bank opened
for business in December 1964, in the Hollywood sec­
tion of Los Angeles. In February 1966, it established
a branch 3 miles southeast of the bank’s head office.
The bank has not shown spectacular growth and, due
to managerial problems, in late 1966 and early 1967,
some loan losses developed. The losses have been re­
duced, but they have not been stopped.




$10, 309, 629
644, 805, 670
655, 115, 300

In
operation

To be
operated

2

59

61

The five counties in southern California which are
served by the charter bank are highly diversified in
agriculture, industry, foreign and domestic finance,
fishing, motion picture production, general manufac­
turing, aerospace, and retail trade. A substantial por­
tion of the State’s population growth in recent years
has taken place in southern California. The 1970 census
registered 11.6 million people in that five-county
region; that constitutes 59.1 percent of California’s
total.
The primary market area served by Hollywood Na­
tional Bank lies 15 miles west o f downtown Los An­
geles and encompasses the Hollywood, Los Feliz, and
Silver Lake districts of the city of Los Angeles. That
area extends in a 3-mile radius from the two offices of
the bank, and comprises an area of about 22 square
miles with an estimated population of 322,406 resi­
dents. The major categories of employment in Holly­
wood include services (92,700); wholesale and retail
trades (52,700); finance, insurance, and real estate
(27,500); manufacturing (13,700); and transporta­
tion, communications, and utilities (9,400). The sin­
gle major source of employment in Hollywood remains
the motion picture, television, radio, and recording
studios. The areas surrounding the offices of the merg­
ing bank are fully developed and contain a mixture of
older residential sections and commercial establish­
71

ments. While Hollywood National Bank’s offices oc­
cupy two of the better locations in the Hollywood area,
the bank has not gained public acceptance.
Within the described service area of the merging
bank there are 81 offices representing 18 different
banks, several of which are the largest in the United
States, including 24 branches of Bank America Na­
tional Trust & Savings Association, nine branches of
Crocker-Citizens National Bank, 20 branches o f Secu­
rity Pacific National Bank, and eight branches of
United California Bank. There are a host of small
banks that operate three or fewer branches, including
the United States National Bank, with two branches
in the area. In addition to those commercial banks,
there are numerous savings and loan associations which
compete rather aggressively for available deposit and
loan business. Additional competition is derived from
credit unions, sales finance companies, personal loan
companies, mortgage companies, and factors and lend­
ing agencies of the U.S. Government. With the result­
ing bank retaining only 2 percent of the deposit busi­
ness and 1 percent of the loan business derived by the 81
banks serving the Hollywood market area, the com ­
petitive impact of the merger described on the banking
structure will be nominal. Considering the loans and
deposits of the resulting institution compared to those
of all financial institutions the ratios become very
insignificant.
The head offices of the banks participating in the
merger are approximately 115 miles apart. Although
two branches of United States National Bank are situ­
ated within 3 miles of the head office o f the merging
bank, there appears to be no significant overlap of
the respective banks’ service areas due to the type of
customers each bank tries to serve; the charter bank
is commercially oriented, while the merging bank does
very little consumer business. There is no significant
depositor or borrower relationships in common to both
banks, other than certain loans that were purchased by
Hollywood National Bank from companies in which
the principal owner of both banks is interested. Such
purchases took place only after Westward Realty Co.
acquired control of the merging bank. Prospects for
future competition between the participant banks are
considered to be negligible in light of the affiliation

that presently exists between the participating banks.
Due to the past managerial problems of Hollywood
National Bank, the bank’s operations are now closely
supervised by the charter bank.
The proposed merger is not expected to reduce the
alternative sources of bank services for residents of the
described trade area. The offices of the merging bank
will remain open as branches of the charter bank, en­
abling the resulting bank to offer the following ex­
tended services to the merging bank’s customers: a
trust department, extensive EDP services, and greatly
increased lending limits. Commercial services, as well
as personal banking needs, will be emphasized by the
resulting bank. Specifically, it will offer accounts re­
ceivable, warehouse receipt financing, business loans,
V A and FH A construction loans, and commercial take­
out real estate mortgage loans.
Applying the statutory criteria to this proposal, we
find that it is in the public interest. The application is,
therefore, approved.
M ay 14, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y GENER AL

Both banks operate offices within Los Angeles
County and the Hollywood-Beverly Hills-Wilshire
area. Five offices of United States National Bank are
located within a 5-mile radius of Hollywood Bank.
Thus, although there are many intervening and alter­
native sources of commercial banking services, this
proposed merger will eliminate direct competition be­
tween the merging banks.
Within Los Angeles County, 67 commercial banks
operate 882 banking offices. As of June 30, 1970,
United States National Bank had less than 1 percent,
and Hollywood Bank had about 0.06 percent of total
deposits in commercial banking offices in the county.
Within the Hollywood-Beverly Hills-Wilshire area, 17
commercial banks operate 139 banking offices. The
market shares of United States National Bank and
Hollywood Bank within this area would not be sig­
nificantly higher than their shares of Los Angeles
County as a whole.
W e conclude that although this merger would elimi­
nate direct competition between the participants, it
would not have a significantly adverse effect on
competition.
*

72



C ity T rust C o., Bridgeport, C onn.,

and

T he W aterbury National Bank, W aterbury, C onn.

Bankingg offices
Total assets

Name of bank and type of transaction

Gity Trust Co., Bridgeport, Conn., with...............................................................................
and The Waterbury National Bank, Waterbury, Conn. (780), which had................
consolidated June 30, 1971, under charter of the latter bank (780) and title “ The
City National Bank of Connecticut. ’ ’The consolidated bank at date of consolidation
had
..........................................................................................................................

comptroller’ s decision

On January 28, 1971, City Trust Co., Bridgeport,
Conn., and The Waterbury National Bank, Waterbury,
Conn., applied to the Office of the Comptroller of the
Currency for permission to consolidate under the char­
ter of the latter and with the title of “ The City Na­
tional Bank of Connecticut,” with headquarters in
Bridgeport, Conn.
The Waterbury National Bank, the charter bank,
with I PC deposits of almost $56 million, was organized
originally in 1848. In addition to its main office, it op­
erates eight branches in strategic sections of Waterbury
and neighboring towns.
Waterbury, home of the charter bank, is located in
northern New Haven County, 30 miles north of Bridge­
port and 29 miles southwest of Hartford. The service
area of the charter bank, which includes Waterbury
and 13 neighboring municipalities in Litchfield and
New Haven counties, can be broadly described as a
residential, commercial, and industrial region. Water­
bury itself can be categorized as a commercial and
heavily industrialized community. Industry is varied,
but with particular emphasis on metal production and
fabrication in many manufacturing plants, both large
and small. The city serves as a trade center for people
residing in smaller communities in the surrounding
area.
With resources of $70 million, the charter bank
ranks as 13th largest in the State. There are five
competing institutions in Waterbury, including one
commercial bank, two savings and loan associations,
one mutual savings bank, and a branch of a commercial
bank based in Bridgeport. In its service area, The
Waterbury National Bank ranked fourth in size. In the
combined service area of the two consolidating banks,
Waterbury National ranked as 10th largest commercial
bank. In Waterbury, The Colonial Bank & Trust Co.,
with assets of $283 million, offers particularly vigorous
commercial bank competition.




$299, 620, 685
82, 666, 951

375, 465, 153

In
operation

To be
operated

16
10

26

City Trust Co., the consolidating bank, with IPC
deposits of $206.5 million, traces its lineage to 1854,
and assumed its present name in 1957, following the
acquisition of The South Norwalk Trust Co. by The
Bridgeport City Trust Co. In addition to its head office
in Bridgeport, it now operates 15 branch offices, all
but one of which are located in Fairfield County, in
the southwestern section of the State.
Bridgeport, home of the consolidating bank, with
a population of about 155,000 and a trade area draw
estimated at 360,000, is the second largest city in the
State. It is located in Fairfield County, on Long Island
Sound, approximately 19 miles southwest of New
Haven and about 60 miles northeast of New York City.
Its economy is diversified and, until the recent eco­
nomic downturn, has been relatively stable. The city,
with its good harbor facilities, is one of the leading in­
dustrial and commercial centers of the State. Industry
is varied, both light and heavy, and there are many
manufacturing plants, large and small. The service
area of the consolidating bank covers 21 communities,
and can be broadly described as a residential, commer­
cial, and industrial region.
With resources of $281 million, City Trust Co. ranks
as seventh largest commercial bank in the State. Sev­
eral commercial banks compete vigorously in the
Bridgeport region. The State National Bank of Con­
necticut, with assets of $363 million, and The Connect­
icut National Bank, with assets of $351 million, provide
particularly intense competition. Significant com ­
petition also derives from several mutual savings banks,
savings and loan associations, and credit unions in the
general area. Because of their proximity, the impact of
the New York City banks is also felt. Among commer­
cial banks in its service area, City Trust Co. ranked
fifth in size. Among commercial banks in the com ­
bined service area of the consolidating banks, City
Trust Co. ranks sixth in size.
The resulting bank, with its larger bank facilities,
will be able to offer additional services in both the

73

Bridgeport and Waterbury areas. A larger lending lim­
it will be available to attract business that is presently
going elsewhere. Customers of Waterbury National will
benefit from the expanded services presently being of­
fered by City Trust Co., including broader and more
specialized trust services, credit card financing, munic­
ipal financing, and improvements in the area of au­
tomated accounting. Also, some degree of flexibility in
the matter of the shifting of funds would result.
Competition will not be adversely affected by con­
summation of the proposed transaction. Because the
service areas of the two consolidating banks do not
overlap, their nearest branches being 17 miles apart,
there is no meaningful competition between them to be
eliminated. The resulting bank will be in a better posi­
tion than either bank operating individually to compete
with the much larger institutions presently operating
in the service areas of the consolidating banks; that is
to say, competition will be improved. At the same time,
the smaller banks operating in the area will continue
to capture a fair share of available banking business.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application is,
therefore, approved.
M ay 11, 1971.
SUM M AR Y OF REPORT B Y A T TO R N E Y GENERAL

All but one of City Trust’s 16 offices are located in
Fairfield County. Seven of Waterbury Bank’s nine of­
fices are located in New Haven County. The banks’
closest offices are 17 miles apart, with several offices

of competing banks located in the intervening area.
The application indicates that each bank derives little
business from the area served by the other. The pro­
posed consolidation would not appear to eliminate sub­
stantial direct competition between the two banks.
As of June 30, 1970, Waterbury Bank’s nine branches
accounted for 24 percent o f the commercial bank de­
posits attributable to commercial bank branches lo­
cated in Waterbury Bank’s service area. It was the
second leading bank in an extremely concentrated com ­
mercial banking market in which the leading two banks
accounted for 85 percent of deposits. As of the end of
1970, City Trust was the seventh largest bank in the
State, with total deposits of $260.1 million.
Connecticut law permits a bank to branch de novo
statewide, except into a town in which another bank’s
main office is located. Waterbury, Bridgeport, and Nor­
walk are closed to de novo entry. However, as the sev­
enth and 13 th largest commercial banks in Connecti­
cut, both City Trust and Waterbury Bank possess the
resources and skills to open de novo offices in parts of
each other’s service areas where such branching is
permitted. Moreover, it may also be possible for either
bank to establish a holding company and organize a
bank in the home city of the other. Therefore, their
merger would eliminate potential competition between
them.
In view of the capabilities and prominent market
positions o f the merging banks, we conclude that the
proposed merger would have some adverse effect
on potential competition.
*

First N ational Bank of A rchbold , A rchbold , O hio , and T he Farmers State Bank C o .,
Fayette , O hio

Banking offices
Name of bank and type of transaction

Total assets

The Farmers State Bank Co., Fayette, Ohio with. ...........................................................
and First National Bank of Archbold, Archbold, Ohio (15227), which had.............
consolidated July 1, 1971, under charter of the latter bank (15227), and title
“ Tiffin Valley National Bank.” The consolidated bank at date of consolidation
had.....................................................................................................................................................

comptroller ’ s decision

On February 12, 1971, the First National Bank of
Archbold, Archbold, Ohio, and The Farmers State
Bank Co., Fayette, Ohio, applied to the Office of the
Comptroller of the Currency for permission to con­

74



$5, 138, 524
8, 262, 535

13,401,059

In
operation

To be
operated
1
2
3

solidate under the charter of the former and with the
title o f “ Tiffin Valley National Bank.”
The $8.4 million First National Bank o f Archbold
was organized in 1906 as The People’s State Bank Co.
It operated under a State charter until January 1,
1964, when it converted into a National Association

and adopted its present title. The bank, which operates
one branch that it established in 1965 in Archbold,
records aggregate IPG deposits of $6.9 million. There
is one other commercial bank located in Archbold, the
$23.4 million Farmers and Merchants State Bank.
The Farmers State Bank, the consolidating bank,
with total resources of approximately $5 million, was
chartered in 1906 under its present title. It acquired
the Bank of Fayette, Fayette, Ohio, in 1913, and The
Alvordton Banking Co. of Alvordton, Ohio, in 1923. It
presently operates no branches. The bank records ap­
proximately $4 million in I PC deposits. There are no
other commercial banks in Fayette.
The applicant banks serve a majority of Fulton
County and portions of Williams County. Archbold,
headquarters for the charter bank, has an estimated
population of 3,047, and is situated in southwestern
Fulton County, approximately 50 miles west of Toledo,
26 miles east of the Indiana border, and 13 miles south
of the Michigan border. Fayette, headquarters for the
consolidating bank, has a population estimated to be
1,170. It is located 11 miles north of Archbold, and 2
miles south of the Michigan border.
The economy of both banks’ service areas is predi­
cated upon agriculture, livestock, and related industrial
activities. The largest employer in Archbold is the Bea­
trice Food Corp., which employs in excess of 400 full­
time employees. Other employers in Archbold include
23 industrial businesses and 196 commercial and retail
outlets. Archbold is considered to be one of the wealthi­
est rural communities in the State, with an average in­
come per household in excess of $11,120. On the other
hand, growth in Fayette has been slow in the last dec­
ade. Population has increased less than 100, and there
has been a steady decline in retail establishments. De­
spite the slow growth, there has been no unemployment
in Fayette, largely because of the recent entrance of
three manufacturing concerns that currently provide
employment for 600 persons. Within the described serv­
ice area there are five commercial banks and branches
of several large savings and loan associations. The com­
mercial competitors include the $25 million Citizens

banking houses from seven to six, and increase the
concentration of area deposits in the top three institusions, it will not result in a significant concentration of
assets in the resulting institution.
The proposed consolidation will not significantly
affect the competition that presently exists between
area financial institutions. Neither bank has an aggres­
sive management, and, due to an unexpected resigna­
tion at the consolidating bank in 1970, its key executive
is a 27-year-old cashier who is still learning the banking
trade and is not in a position to initiate new, aggressive
policies. An analysis of the respective accounts for each
bank reveals very little competition between the banks.
The charter bank derives $4,600 from 70 checking ac­
counts in the consolidating bank’s trade area, and the
consolidating bank holds none from the charter bank’s
area. In savings accounts from each other’s area, the
charter bank holds 78, with a total dollar value of
$66,000, and the consolidating bank records 12, with a
dollar value of approximately $37,000. Considering
loan portfolios, each bank has six accounts from the
other’s service area that total $3,873 and $13,659 for
the charter and consolidating bank, respectively.
The needs and convenience of the public will be
enhanced in several respects upon approval of this
consideration. The lending limit will be raised to
$100,000 for the resulting bank from the $60,000 and
$40,000 limits of the charter and consolidating banks.
The consolidating bank, with no experienced execu­
tive officer, will have the benefit of the charter bank’s
experienced personnel. Moreover, the larger resulting
bank, with additional resources, will recruit additional
executive personnel. Other services to be instituted
included a modern installment lending program, pro­
posed servicing of FHA and V A loans, computerization,
and more aggressive use of each bank’s present
programs.
Applying the statutory criteria, we find that the
proposed consolidation is in the public interest. The
application is, therefore, approved.
A p r i l 22, 1971.
SU M M AR Y OF REPORT B Y A T TO R N E Y GENER AL

National Bank, Bryan, O hio; the $14.4 million Peoples
State Bank of Wauseon, O hio; the $6.7 million Na­

The proposed merger involves two very small banks

tional Bank of Fulton County, Delta, O hio; and the

located 11 miles apart in separate villages, with no

$3.1 million Farmers State Bank of Strykes, Ohio. The

banking alternatives in the intervening area. Thus,

charter bank ranks third in size and the consolidating

it would appear that the proposed consolidation would

bank ranks fifth, among those banks. The resulting

eliminate the direct competition that presently exists

bank, with assets of $13.5 million, will continue to rank
third in the trade area commercial banking structure.

between these banks.
First Financial is the third largest bank in Fulton

Although this consolidation will reduce the number of

County, which is a concentrated banking market. There

75
463-499




are presently six commercial banks in the county, with
the largest three accounting for 77 percent of total
deposits. If the merger is approved, the three largest
*

banks would control about 82 percent of county deposits. Thus, concentration in the local market would
be substantially increased.
*

*

First UftiON N ational Bank of N orth C arolina , C harlotte , N .C., and Bank of R ocky M ount ,
R ocky M ount, N.C.

Banking offices
Total assets

Name of bank and type of transaction

S 3 .nL of Rocky Mount Rocky IVToimt N C. with...........................................................
and First Union National Bank of North Carolina, Charlotte, N .C. (15650),
which had
..
...........................................................................................................
merged July 30, 1971, under charter and title of the latter bank (15650). The
merged bank at date of merger had.......................................................................................

com ptro ller 's

d e c is io n

O n April 26, 1971, die First Union National Bank
of North Carolina, Charlotte, N.C., applied to the
Comptroller o f the Currency for permission to merge
with the Bank of Rocky Mount, Rocky Mount, N.C.,
under the charter and with the title of the former.
Charlotte, with a 1970 estimated population of
240,000, is the county seat of, and largest city in
Mecklenburg County. It is not only North Carolina’s
largest urban area, but it is also one of the fastest
growing cities in the southeastern United States. L o­
cated in the south-central piedmont section of North
Carolina, Charlotte is one o f the State leaders in manu­
facturing and is an important wholesale and retail
trade center. Although the Charlotte area contains
many important industrial firms, the largest employers
are transportation and distribution companies.
First Union National Bank of North Carolina, fol­
lowing an aggressive policy, has grown from $74 mil­
lion in total resources, in 1955, to its present size of
$1.1 billion in total resources, thereby becoming the
third largest commercial bank in North Carolina. The
bank presently operates through 147 offices in 70 com ­
munities. Principal competition for this bank derives
from the $1.8 billion Wachovia Bank & Trust Co.,
operating 140 offices in 52 communities; the $1.5 bil­
lion North Carolina National Bank, operating 101 of­
fices in 30 communities; and the $753 million First
Citizens Bank & Trust Co., operating 170 offices in
63 communities. Competition is also provided by the
strong regional systems of the $583 million North­
western Bank and the $280 million Branch Banking &
Trust Co.

76



To be
operated

In
operation

$13, 797, 092

4

1, 114, 132,313

150

1, 127, 762, 357

154

Rocky Mount, home of the merging bank, is located
in both Nash and Edgecombe counties in the northern
coastal region of North Carolina. The economy of
that two-county area is supported primarily by agri­
culture and manufacturing. The importance of farming
is indicated by the fact that it provides jobs for nearly
20 percent of the area’s labor force. A major activity
is the growing and processing of tobacco, and the
future of that industry is uncertain. During the period
from 1963 to 1967, the area experienced a significant
increase in the number of manufacturing firms and
retail establishments. In 1967, there were 144 manu­
facturing firms and approximately 1,200 retail estab­
lishments in Nash and Edgecombe counties. A large
number of those businesses were located in the Rocky
Mount area. While that market area compares favor­
ably with the rest of the State in industrial growth
and expansion, nearly 50 percent of the area’s firms
are engaged in textile and apparel manufacturing,
a traditionally labor-intensive and low-wage type in­
dustry. The population of the two counties appears
to be declining. During the period from 1960 to 1970,
the population of Nash County declined from 61,002
to 59,122, and that of Edgecombe County declined
from 54,276 to 52,341. During the same period, the
population of Rocky Mount increased from 32,147
to 34,284; a portion of that increase can be attributed
to the expansion of the city’s corporate limits. Per
capita and total personal income in the two counties
is far below that of the State. The average weekly
wage in those counties is also below the State average.
The Bank of Rocky Mount, with total resources
of $12.6 million, was originally organized in 1928, as
the City Industrial Bank, and presently operates three

branch offices in Rocky Mount. The bank has been
generally conservative through the years, and, in many
respects, still maintains many of the characteristics
of an industrial bank, with a large number of time de­
posits and installment loans to finance consumer pur­
chases. The bank presently provides only limited
services to its community. Any program of expansion
to meet the needs of the community better would
require a greater management depth than is presently
available to the bank. Because of its size, the salaries
it is able to pay, and the career opportunities it can.
offer, the bank has not been able to compete for the
needed management talent in a highly competitive
market. Since 1968, the bank has experienced a decline
in both total assets and deposits.
Banking competition in the two-county area is prin­
cipally provided by the $132 million Planters National
Bank & Trust Go., with 29 banking offices, and the
$121 million Peoples Bank & Trust Co., with 28 offices.
Both of those banks are headquartered in Rocky
Mount, and most of their offices are located within
the two-county market area. The other independent
area banks are the $21 million Edgecombe Bank &
Trust Co., operating two banking offices in Tarboro,
and the $3.3 million Merchants and Farmers of M ac­
clesfield. The $8 million Lucama-Kenly Bank in Lucama, Wilson County, operates a branch office in
Bailey, Nash County. Competition to the merging bank
is also provided by North Carolina National Bank,
which operates two branch offices in Tarboro, and the
First Citizens Bank & Trust Co., which operates a
branch office in Spring Hope. The latter bank has
recently received approval by the State banking com ­
mission to establish a branch in Rocky M ount; that
application, however, is presently the subject of litiga­
tion. The Wachovia Bank & Trust Co. also has applied
for a branch in Rocky Mount.
The addition of $12.6 million in assets to the charter
bank will have no significant effect on concentration
of banking resources in North Carolina. On consum­
mation of the proposed transaction, the resulting bank
will have gained but 0.14 percent of the State’s total
deposits. There is no competition presently existing
between the participating banks that will be eliminated
by this merger. The charter bank has no offices in
Nash or Edgecombe counties. The closest office of the
charter bank to the merging bank is located in Wilson
County, over 18 miles to the south of Rocky Mount.
The amount of business derived by the charter bank
from the service area of the merging bank is minimal.
This merger will not eliminate a banking alternative
for the residents of Rocky M ou n t; it will, in fact, give




them another highly competitive alternative with a
broad range of banking services.
The effect of this merger on potential competition
is more illusory than real. As indicated, the merging
bank is relatively small and provides only limited
services to its customers. The bank lacks management
depth and has been unable to attract the additional
executive talent it needs. The addition o f another
strong competitor in the area through de novo entry
can only worsen the situation at the merging bank.
Furthermore, in light of the general economic condi­
tions and the banking competition presently existing in
the Nash-Edgecombe County area, it does not appear
that the charter bank would enter the area through
de novo branching.
Applying the statutory criteria to the proposed
merger, we conclude that it is in the public interest,
and the application is, therefore, approved.
une 24, 1971.

J

S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

First Union does not operate any branches in the
two-county market area of Rocky Mount Bank; how­
ever, it does operate five branches in Wilson, Wilson
County, 23 miles south of Rocky Mount, with a U.S.
highway connecting the two cities. Although several
banks are located in the intervening area, some com­
petitive overlap exists between the two service areas.
While most of Rocky Mount’s business is derived from
the two-county market area of Nash and Edgecombe
counties, as of March 1970', about 10 percent of de­
mand and savings deposits and 20 percent of total
loans were with customers outside this market. First
Union’s branches in Wilson derived most of their
business outside Rocky Mount Bank’s service area;
however, $435,000 in demand and savings deposits and
$2,097,000 commercial and consumer loans did over­
lap. This amounted to about 3 percent of First Union’s
Wilson branches’ total demand and savings deposits,
and approximately 13 percent of its total commercial
and consumer loans, the latter type loan accounting
for the overwhelming share. In terms of Rocky Mount
Bank’s business, this competition amounted to 6 per­
cent of its deposits and 43 percent of its loans. Outside
the two-county market area, about 2 percent of Rocky
Mount Bank’s demand and time deposits and 6 percent
of total loans were in areas in close proximity to First
Union’s branches. However, several alternative banks
also exist for the customers in these areas.
Since North Carolina permits statewide branching,
First Union could enter the two-county area de novo.
First Union is clearly one of the most significant and
77

most capable potential entrants. However, because of
the declining population in the two-county market
area, the relatively low personal income, and the large
*

number o f existing banking facilities in Rocky Mount
and the entire market area, it is questionable whether
or not the area could attract the entry o f another bank.
*

*

U nited N ational Bank of V ermillion, V ermillion, S. D a k ., and R ushmore State Bank , R apid
C ity , S. D a k ., and T he Security N ational Bank of V iborg , V iborg , S. D a k .

Banking offices
Name of bank and type of transaction

Total assets

The Security National Bank of Viborg, Viborg, S. Dak. (13589), with......................
Rushmore State Bank, Rapid City, S. Dak., with.............................................................
and United National Bank of Vermillion, Vermillion, S. Dak. (15639), which had.
consolidated July 31, 1971, under charter of the latter bank (15639) and title
“ United National Bank of South Dakota.” The consolidated bank at date of con­
solidation had.................................................................................................................................

c o m p t r o l l e r ’s

D E C IS IO N

On April 28, 1971, the United National Bank of
Vermillion, Vermillion, S. Dak., The Security Na­
tional Bank of Viborg, Viborg, S. Dak., and the Rush­
more State Bank, Rapid City, S. Dak., applied to the
Office of the Comptroller of the Currency for permis­
sion to consolidate under the charter of the United
National Bank of Vermillion and with the title of the
“ United National Bank of South Dakota,” with its
main office in Rapid City, S. Dak.
The United National Bank of Vermillion, Vermil­
lion, S. Dak., was opened in 1914, and presently op­
erates 10 branches. With the exception of the two
branches which are situated in Kennebec and Pine
Ridge, S. Dak., most of the branches are located in
the southeast com er of the State. The main office
and 10 branches have aggregate I PC deposits of $19.7
million.
The Security National Bank of Viborg was chartered
in 1932. This institution, which records IPC deposits
of $3.2 million, is a unit bank. It is located approxi­
mately 35 miles from Vermillion and is about 10 miles
from the nearest branch of the United National Bank
of Vermillion. Since the managing officer of the V er­
million bank is also president of the Viborg bank, bank
policies o f the two institutions are very similar.
The Rushmore State Bank of Rapid City was or­
ganized in 1946 at Hill City, S. Dak., but in 1951 it
moved to Rapid City, retaining its office at Hill City
as a branch. In addition to the Hill City office, the bank
also operates another branch in downtown Rapid City.
The bank and its branches have aggregate IPC de­
posits o f $8.1 million.

78



$4, 573, 759
12, 469, 890
29, 077, 441

46, 121,090

In
operation

To be
operated

1
3
11

15

The service areas to be served by the banks partak­
ing in this proposed consolidation lie at opposite ends
of the State. The Vermillion and Viborg banks are
situated in southeastern South Dakota, within 50 miles
of Sioux Falls, the State’s largest city and its chief com ­
mercial center. Vermillion is dominated by the pres­
ence of the University of South Dakota. However, it
is also an agricultural center and the county seat. V i­
borg, with a static population of about 700, also derives
its economic stability from agriculture. Rapid City lies
in western South Dakota at the perimeter of the westcentral plains and the Black Hills mountain area. The
regional economy relies on ranching, agriculture, tour­
ism, lumbering, and mining. Rapid City is similar to
Sioux Falls in that it is the second largest city in the
State and is the distribution point for western South
Dakota and eastern Wyoming. Ellsworth Air Force
Base, a Strategic Air Command facility, is located 10
miles east of Rapid City. With its complement of over
15,000 men, the base has a significant economic im­
pact on the community.
The United National Bank of Vermillion, the Rush­
more State Bank, and The Security National Bank of
Viborg do not compete with each other. The banks in
Viborg and Vermillion, although only 10 miles apart
at their closest facilities, do not actually compete due
to their affiliation under common ownership and their
common bank management. Potential competition is
negligible for the same reasons.
Approval of the proposed consolidation will not ad­
versely affect the banking structures in the cities served
by the banks in question. In Rapid City, the Rush­
more State Bank is the smallest of three banks. The

Applying the statutory criteria to this proposal, we
find the advantages of this consolidation outweigh the
disadvantages, and it is in the public interest. The ap­
plication is, therefore, approved.
June 25, 1971.

other two, the First National of Black Hills and the
National Bank of South Dakota, have combined de­
posits totaling $311 million and 16 branches in the
area. Since two Minnesota holding companies, First
Bank Systems Inc. and Northwestern Bancorporation,
with combined resources of over $8 billion, are the par­
ent corporations for these two banks, their size and
services give them almost unlimited competitive ad­
vantage. There are no banks operating in Viborg other
than The Security National Bank of Viborg. However,
several small banks of approximately the same size as
Security National operate in neighboring communities
within the service area of Security National, and con­
solidation could potentially intensify competition in
the Viborg area. The United National Bank of V er­
million has no direct competition in Vermillion or in
any of the small towns its branches service. It does
attract competition from banks situated in towns ad­

SU M M A R Y OF REPORT B Y A T T O R N E Y GENERAL

Rushmore Bank’s home office is located approxi­
mately 320 miles west of Viborg Bank and 400 miles
west of Vermillion Bank’s home office; and the lat­
ter is 34 miles southeast of Viborg Bank. The western­
most branch o f Vermillion Bank, at Pine Ridge, is 110
miles southeast of Rushmore Bank, in Rapid City. The
closest branch of Vermillion Bank (the Wakonda
branch) is 12 miles from Viborg Bank, raising the
possibility of some overlapping competition in service
areas, but significant banking alternatives exist in
the intervening areas. Hence, no significant direct com ­
petition will be eliminated by this consolidation.
South Dakota law does not permit banks to branch
de novo into any of the cities or towns where any one
of the consolidating banks presently operates, although
branches might be established in communities where
no bank is presently located. Because of the relative
size of the consolidating banks in their respective mar­
kets, the virtually static or declining population in two
of the three counties, the net income condition of all
three banks, and the presence of other potential en­
trants into the counties, the proposed consolidation
would not appear to eliminate significant potential
competition.

joining those towns that it serves. Probably its greatest
competition is derived from three banks located in
Yankton, and from the bank serving Sioux Falls.
It appears that the public will benefit by this con­
solidation. The loan limit will be substantially in­
creased, thereby enabling each bank to service a wider
range of borrowers, especially those customers involved
in agriculture. Trust services and an agricultural spe­
cialist are contemplated for all locations. The appli­
cants state that approval of the consolidation will en­
able them to attract more qualified personnel, thereby
strengthening present management.
*

*

*

T he Bank of C alifornia , N .A., San Francisco, C alif ., and I nland Bank , Pomona, C alif .

Banking offices
Name of bank and type of transaction

Total assets

Inland Bank, Pomona, Calif., with.........................................................................................
and The Bank of California, National Association, San Francisco, Calif. (9655),
which had.......................................................................................................................................
merged Aug. 2, 1971, under charter and title of the latter bank (9655). The merged
bank at date of merger had.......................................................................................................

c o m p t r o l l e r ’s d e c is io n

On December 21, 1970, the Inland Bank, Pomona,
Calif., and The Bank of California, National Associa­
tion, San Francisco, 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.




In
operation

To be
operated

$33, 746, 069

3

1, 962, 100, 715

68

1, 991, 243, 367

71

The Bank of California, National Association, the
charter bank, with total deposits of $1.5 billion, was
established in 1864, with headquarters in San Fran­
cisco, and now operates 68 branches and has approval
for 10 branches which it has not yet opened. The char­
ter bank offers a wide range of services, including inter­
national banking, automatic data processing services,
fiduciary activities, insurance premium financing, as

79

well as such services as advice on conducting payroll
departments, accounting supervisory services, economic
research services, public relations, and advertising su­
pervisory services.
The Bank of California, National Association, serves
the cities of Seattle and Tacoma, in Washington, and
Portland, in Oregon, and 44 communities in all sec­
tions of California. The economy of that service area in
California is diversified, with agriculture, industry, for­
eign and domestic finance, and many other commercial
and service activities, including lumbering, fishing,
tourism, mining, oil production, manufacturing, mili­
tary establishments, and retail trade, playing important
roles. In its service area, the charter bank, the seventh
largest commercial bank in California, competes with
numerous banking offices throughout the State. It also
competes with numerous offices of other financial
institutions.
Inland Bank, the merging bank, with I PC deposits of
$24.8 million, was chartered in July 1964. In addition
to its head office in Pomona, it operates two branches,
one in Claremont and the other in Ontario. The merg­
ing institution offers the usual complement of banking
services, with the exception of trust services and the
more sophisticated and extensive services which the
charter bank and other larger California banks offer.
The service area of the merging bank, with a popula­
tion of about 285,000, is an area known as the Pomona
Valley; it includes the eastern end o f San Bernardino
County and the western end of Los Angeles County.
The three towns in which the merging bank presently
has offices are the major towns in the Pomona Valley
area. Pomona, the head office city, is located approxi­
mately 30 miles east of downtown Los Angeles and
25 miles west of downtown San Bernardino. For many
years, the economy of that portion of southern Cali­
fornia was primarily rurabagricultural, with grapes
and oranges the main crops. In recent years, however,
the nature of the area has changed to residential, and
the local economy is now based upon commercial
and industrial activity, with steel production and
aerospace manufacturing as important contributors.
There are 23 competing banking offices in the market
area of the Inland Bank. Except for the three offices
of the regional First National Bank & Trust Co.,
Ontario, all are offices of large statewide branch bank­
ing institutions. Those include branches of the Bank of
America National Trust & Savings Association and four

mortgage lending. Competition is also offered by credit
unions, sales finance companies, mortgage companies,
factors, and lending agencies of the U.S. Government.
This merger will enable the Pomona Valley offices
of the resulting bank to offer more extended customer
services, including credit extensions to larger borrowers,
a trust department, international banking services,
and an extensive E.D.P. service to the bank’s clients
in the market area that will be more commensurate
with the services offered by branches of large statewide
banking institutions presently located there. The
merger will result in the usual economies of scale
effecting better service at lower cost.
Competition will not be adversely affected since the
nearest offices of the two banks involved are 15 miles
apart; their service areas do not overlap and there is,
in consequence, no present competition between them
to be eliminated. In the present service area of the
charter bank, the addition of the much smaller merging
bank will have a negligible effect. The charter bank
will continue as the seventh largest bank operating in
California. In the present service area of the merging
bank, the introduction of the much larger and aggres­
sive charter bank will enhance competition with respect
to the large regional and statewide institutions pres­
ently operating offices in the Pomona Valley area.
Applying the statutory criteria, we conclude that
the proposal is in the public interest. The application
is, therefore, approved.
J u n e 29, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y GENERAL

The Bank of California’s nearest branch is 15 miles
west of Inland’s Ontario branch. The distance between
the other offices of the banks is 20 to 25 miles. Neither
bank draws customers or banking business from the
service area of the other. Hence, the proposed merger
would not have any substantially adverse effect upon
existing competition between the banks.
As of June 29,1968, Inland held less than 10 percent
of deposits in commercial banking offices in the cities
of Pomona, Ontario, and Claremont. In the city of
Pomona alone,
deposits.

Inland held

11 percent of

such

Statewide de novo branching is permitted in Cali­
fornia. The Bank o f California could, therefore, branch
de novo into the area served by Inland. The Bank o f

branches of the United California Bank, Los Angeles.

California, the seventh largest bank in the State, is

There are also nine offices of savings and loan associa­

one of three banks with deposits in southern California

tions in the market area o f the Inland Bank competing

in excess of $200 million which is not serving this area.

actively with commercial banks for deposit funds and

The Bank of California is actively expanding in south­

80



has achieved a significant market position in its service
area while competing with the largest banks in the
State. Hence, its elimination will remove a significant
independent competitive force in this area.

ern California and has the resources and ability to
branch de novo into this area. Hence, this merger will
eliminate the potential competition of Bank of Cali­
fornia. Furthermore, Inland, in its 6 years of existence,
*
F

ir s t

N

a t io n a l

Bank

of

So

uth

C

a r o l in a

, C

*

*

o l u m b ia

,

S.C.,

and

Bank

of

K

ershaw

, K

ershaw

,

S.C.

Banking offices
Name of bank and type of transaction

Total assets

Bank of Kershaw, Kershaw, S.C., with.................................................................................
and First National Bank of South Carolina, Columbia, S.C. (13720), which h a d ..
merged Aug. 31, 1971, under charter and title of the latter bank (13720). The
merged bank at date of merger had.......................................................................................

c o m p t r o l l e r ’s

d e c is io n

On May 7, 1971, Bank of Kershaw, Kershaw, S.C.,
and First National Bank of South Carolina, Columbia,
S.C., applied to the Office of the Comptroller of the
Currency for permission to merge under the title and
charter of the latter.
First National Bank of South Carolina, the charter
bank, with I PC deposits of $188.3 million, was orga­
nized in 1933. It operated as a unit bank until 1948,
when it acquired one branch by merger. Since then, 25
branches have been added de novo and 21 have been
acquired by merger. First National now operates 48
branches and facilities in 20 communities statewide;
it is the third largest bank in South Carolina.
The Bank of Kershaw, the merging bank, with I PC
deposits of $7.6 million, was organized in 1904. This
unit bank, whose condition is good, has a management
succession problem resulting from the recent death of
its chief executive officer and the severe illness of its
president. There is no depth of management within
the bank.
The primary service area of the merging bank in­
cludes approximately equal portions of Kershaw
County, to the south, and Lancaster County, to the
north. Primary service area of Bank of Kershaw is
estimated to include about 5,000 persons. Camden,
S.C., 21 miles southeast o f Kershaw, serves as the trade
and financial center, as well as the county seat, of
Kershaw County. An expanse of approximately 15
miles of pulpwood forest serves as a natural barrier
in restricting business and residential development be­
tween Kershaw and Camden. Kershaw, in recent
years, has gravitated 19 miles northwest to Lancaster,
which is dominated by the Springs Mill, Inc., textile
company, for its economy. As a result, Kershaw’s eco­




$8, 739, 378
297, 835, 389
306, 226, 828

In
operation

To be
operated

1
46

47

nomic future is largely dependent upon the uncertain
future of the textile industry.
The merging bank is the only commercial bank
located in Kershaw. Its competitors include the three
banks located in Lancaster: First-Citizens Bank &
Trust Co., with deposits of $62 million; Lancaster
Trust Co., with deposits of $3 million; and the Bank
of Lancaster, with deposits of $22 million. The Springs
Co., the largest employer in Kershaw, owns or controls
71.13 percent of the Bank of Lancaster and 100 percent
of the Lancaster Trust Co. That fact, together with
the merging bank’s very conservative lending policies,
have resulted in substantial loss of merging bank’s busi­
ness to Lancaster banks and other local institutions.
The resulting bank will provide residents ajid busi­
nessmen of Kershaw with additional and expanded
banking services including larger credit lines, com ­
puter and automated accounting, international credit
arrangements, trust services, and mortgage lending.
It will also resolve the severe management succession
problem in the merging bank. Additionally, the greater
range of banking serviecs will enhance the town’s ef­
forts to attract new industries for its future growth
and economic stability.
Competition will not be adversely affected by con­
summation of the proposed transaction. The proposed
merger will not lessen competition in the market area
of Kershaw since no competition now exists in this
one-bank town. Because the nearest office of the char­
ter bank is 21 miles from the merging bank and is sep­
arated by a pulpwood expanse, existing competition
between the two banks is nonexistent. While the char­
ter bank is permitted by law to enter the Kershaw
community de novo, such entry would not appear to
be economically feasible in the foreseeable future. In
81

although two other de novo applications by other banks
to open branches in Kershaw are pending; two other
banks operate five offices in Camden.
Bank of Kershaw holds 26 percent of total de­
posits held by the six banks operating in Kershaw
County, and 12 percent of total deposits held by the
10 banks operating in Kershaw and Lancaster coun­
ties (Kershaw-Lancaster area). First National’s Cam­
den office, open only 1 year, holds market shares of 3
and 1 percent, respectively. Kershaw County and the
Kershaw-Lancaster area are concentrated banking
markets. The top three banks hold 87 and 62 percent,
respectively. Bank of Kershaw is the second largest
bank in Kershaw County and the third largest in the
Kershaw-Lancaster area. Because the merger would

the present service area of the charter bank, the addi­
tion to it of the much smaller merging institution
would have a negligible effect. The merger would have
a favorable effect on Kershaw County as it would in­
troduce a more complete line of banking services
and facilities, benefiting both local businesses and resi­
dents of the community.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. This applica­
tion is, therefore, approved.
J u l y 13, 1971.
SU M M ARY OF REPORT B Y A T TO R N E Y GENERAL

Since 1948, First National has established 25 de novo
offices and acquired 21 by merger, and Kershaw is a
likely direction for additional expansion. First Na­
tional’s closest office to Bank of Kershaw was opened
de novo in 1970 in Camden, Kershaw County, 21 miles
south of Kershaw. No other banks operate in Kershaw
*

appear to eliminate existing competition and increase
concentration, we conclude that this merger will have
an adverse effect on competition in Kershaw County
and the Kershaw-Lancaster area.
*

*

M aryland N ational Bank , Baltimore, M d ., and F irst N ational Bank & T rust C o .,
H avre de G race , M d .

Banking offices
Name of bank and type of transaction

Total assets

In

operation
First National Bank & Trust C!o., Havre de Grace, M d. (3010), with......................
and Maryland National Bank, Baltimore, M d. H3745), which had...........................
merged Aug. 31, 1971, under charter and title of the latter bank (13745). The
merged bank at date of merger had.......................................................................................

c o m p t r o l l e r ’s

d e c is io n

On April 5, 1971, First National Bank & Trust Co.,
Havre de Grace, M d., and Maryland National Bank,
Baltimore, Md., applied to the Comptroller of the Cur­
rency for permission to merge under the charter and
with the title of the latter.
Maryland National Bank, the charter bank, with
IPC deposits of $775.7 million, was organized in 1933.
It operates 104 offices in 15 of Maryland’s 23 counties
and in the city of Baltimore. It is Maryland’s largest
bank. Its offices range from Hagerstown, in the west,
to Pocomoke City and Snow Hill, in the southeast. As
its size and growth would indicate, this bank is in good
condition and offers a wide array of banking services
to its customers.
Baltimore, the home of the charter bank, has a met­
ropolitan area population of almost 4 million, and it is
82




$17, 305, 000
1,377, 595, 483
1, 393, 615, 771

To be
operated

3
109
112

the 11th largest metropolitan area in the Nation. It is
an important deep water port, industrial area, and
educational center. Its industrial area is notable for the
diversity of its factories, which include plants produc­
ing airplanes, radio and telephone equipment, and steel
for shipbuilding. Among other products are spices,
clothing, and liquors. The port of Baltimore is one of
the most important in the Nation. The economy of
other areas served by the charter bank is diverse and
includes commercial and retail activity, agriculture ac­
tivity, and residential areas, as well as building
construction.
Maryland National Bank is in competition for cer­
tain services with every major bank in the East. In
Maryland, the primary competitors are The First Na­
tional Bank of Maryland, with deposits of $658
million; Equitable Trust Co., with $598 million in de­
posits; Suburban Trust Co., with $552 million in de-

This merger will benefit the Harford County and
Havre de Grace areas by replacing the limited services
offered by the merging banks with the broader array
of services that the charter bank provides. The larger
lending limit, trust department facilities, data process­
ing and computer program, international activities, as
well as other services, should prove helpful to the com­
munity. The aggressive nature of the charter bank will
give a boost to present and future economic develop­
ment in Harford County.
Competition will not be adversely affected. Since the
nearest offices of the merging banks are 17 miles apart.
and are separated by a number of intervening com­
munities containing the offices of other banks, they do
not compete. In Baltimore, the addition of the much
smaller merging bank to the State’s largest will have a
negligible competitive effect. Introduction of the
State’s largest bank into Harford County and Havre de
Grace will have a beneficial effect on competition with
respect to the other large statewide banks already in
operation there without disadvantaging smaller com­
petitors. Potential competition will not be affected
since there appears little economic incentive for Mary­
land National to enter the merging bank’s market area
de novo.
Applying the statutory criteria it is concluded that
the proposal is in the public interest. This application
is, therefore, approved.
J u l y 12,1971.

posits; Union Trust Go., with $472 million in deposits;
Citizens Bank of Riverdale, with deposits of $243 mil­
lion ; and Mercantile-Salem Deposit & Trust Co., with
deposits of $204 million. In addition, savings banks in
Baltimore provide substantial competition for local
business. The Provident Savings Bank has deposits in
excess of $316 million, the Savings Bank of Baltimore
has deposits in excess of $388 million, and Eutaw Sav­
ings Bank has deposits in excess of $19 million.
First National Bank & Trust Co., the merging bank,
with I PC deposits of $14.1 million, was established in
1883. Its two branches and its head office are located in
the extreme eastern edge of Harford County. The
merging bank has been generally conservative through
the years and its growth has not kept pace with the
growth of its service area. The merging bank offers
only limited trust services and no automation. The
larger and more specialized credit needs of the area
are being furnished by the large regional or statewide
banks.
Harford County, with an estimated population of
about 116,000, has a land area of 448 square miles and
is located near the head of the Chesapeake Bay. That
county is rapidly changing from a dairy-agriculture
economy to one of urban-industry. Harford County has
60 manufacturers and over 1,000 separate businesses.
The major economic factors in the county are Edgewood Arsenal and the Aberdeen Proving Grounds,
which make the Federal Government the county’s larg­
est employer. Havre de Grace has a population of
17,712, and is located in the northwest section of the
county at the mouth of the Susquehanna River on the
Chesapeake Bay. It is part of an industrial corridor
in eastern Harford County, which also includes the
Aberdeen Proving Grounds and the Edgewood Arsenal.
Banking services in the county are being offered by
five banks headquartered in the county and by 14 of­
fices of three Baltimore-based banks. The five banks
headquartered in the county are the $3.3 million Aber­
deen National Bank, the $8.7 million Forest Hill State
Bank, the $22 million Commercial and Savings Bank,

SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER AL

The nearest offices of Maryland National and First
National are about 17 miles apart with several com ­
peting banking offices in the intervening area. Thus,
it is unlikely that the proposed acquisition will elim­
inate substantial existing competition.
Banking in Harford County is highly concentrated
with four banks holding 84 percent of the county’s total
deposits, First National holds 12.2 percent of the
county’s deposits, the fourth largest share. Maryland
National, as the largest bank not located in Harford
County, is clearly the most significant potential entrant
into the county. Maryland law permits statewide de
novo branching, and Maryland National has significant
incentive to enter rapidly growing Harford County.
We conclude that the proposed merger will have an
adverse effect on potential competition.

the $5.2 million Citizens National Bank in Havre de
Grace, and the $14.1 million merging bank. The three
Baltimore-based banks with offices in Harford County
are the $770 million First National Bank of Maryland,
the $684 million Equitable Trust Co., and the $546
million Union Trust Co.




*

*

*

83

Peoples N ational Bank of N e w Jersey , W estmont, H addon T ownship , N.J., and T he First N ational
Bank of T ugkerton, T ugkerton, N.J.

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Tuckerton, Tuckerton, N.J. (14667), with......................
and Peoples National Bank of New Jersey, Westmont, Haddon Township, N.J.
(12022), which had. .....................................................................................................................
merged Sept. 10, 1971, under charter and title of the latter bank (12022). The
merged bank at date of merger had.......................................................................................

In
operation

To be
operated

$17, 145, 127

3

215, 696, 569

18

232, 841, 695

21

Westmont, Haddon Township, Camden County, N.J.,

and Gloucester counties. The bank was originally
organized in 1881 as the Clementon National Bank,
and reorganized in 1934, after the banking holiday,
under the title of The National Bank of Clementon.
Since that time, the bank has merged with other banks
on several occasions, and its present name was adopted
in March 1969. It is reported that the bank had nor­
mal growth until 1964. Since then, it has become the
fastest growing bank in southern New Jersey, and pres­
ently has IPC deposits of $151.5 million.
Westmont, N.J., is part of the Camden Metropoli­
tan Area, which is located directly across the Delaware
River from Philadelphia, Pa., and is one o f the coun­
try’s largest industrial complexes. The port of Phila­
delphia is the second largest port facility in the Nation,
and processes the largest tonnage of any port in the
United States. In addition, most major industries are
represented in the area. While the economy of the en­
tire region is considered stable, substantial growth is
expected in the future.
Banking competition in the Camden-Westmont area
is described as keen. Competition is provided by The
Bank o f New Jersey, South Jersey National Bank, and
The Third National Bank & Trust Co. of Camden, all
of which are located in Camden, as well as by larger
banks headquartered in Philadelphia. In addition,
there are 60 other commercial banks in the Third
Banking District of New Jersey, many of which provide
competition. Those include First National Bank of
South Jersey, located at Egg Harbor Township; C olo­
nial National Bank at Haddonfield; and the National
Bank & Trust Co. of Gloucester County, at Woodbury.
Both Peoples National Bank of New Jersey and First
National Bank of Tuckerton are located in the recently
created Third Banking District of New Jersey. Until
July 1969, New Jersey statutes limited commercial and
savings bank branching and merging to one county.
The new law, which became effective at that time,

and operates 17 branches in Camden, Cumberland,

divides the State into three banking districts, and per­

comptroller’ s decision

O n May 12, 1971, The First National Bank of
Tuckerton, Tuckerton, N.J., and Peoples National
Bank of New Jersey, Westmont, N.J., applied to the
Office of the Comptroller of the Currency for permis­
sion to merge under the charter and title of the latter.
The First National Bank of Tuckerton with IPC
deposits of $10.3 million, was established in 1952, and
operates three banking offices in Ocean County, N.J.,
and expects to open an approved branch in nearby
Burlington County. At its last examination, the bank
was reported to be in good condition and under con­
servative management. The center of its market area
is Tuckerton, West Creek, and Mystic Island, N.J.,
where it operates banking offices.
Tuckerton, a small rural town in Ocean County,
N.J., is located on one of the major routes to that
State’s popular beach resorts. Its history dates back
some 265 years, and it is the shopping and business
center for many of the people in the area. M ajor in­
dustries in the area include farming and clamming;
however, the locale is increasingly popular as a sum­
mer residence and resort area because of its proximity
to New Jersey’ s beaches. Both Ocean and Burlington
counties expect to enjoy continued growth in both
population and economic importance largely because
they are part of the Pine Barrens, the only remaining
area between New York City and Washington, D.C.,
that has not been fully developed. Banking competi­
tion is provided by the First National Bank of Toms
River; Beach Haven National Bank & Trust Com ­
pany, Beach Haven; First National Bank of Absecon;
the Peoples Bank of South Jersey, Piles Grove Tow n­
ship; and four other banks, all of which are larger
in size than First National Bank of Tuckerton.
Peoples National Bank of New Jersey is located in

84



intervening area. Therefore, it does not appear that the
proposed merger would eliminate any significant exist­
ing competition between the merging banks.
Under recent amendments to New Jersey banking
law, commercial banks may operate branches any­
where in the banking district in which they are located.
They may not, however, open de novo branches in
municipalities of less than 7,500 population if another
bank operates a branch therein. Peoples Bank may
branch de novo in Ocean County, but not into Tucker­
ton, due to head office protection. It has the resources
to expand its services through de novo branching, since
its recent mergers have enhanced its position as the
third largest commercial bank operating in Camden
and surrounding areas.

mits branching and mergers within the district in which
the bank’s head office is located. Due to head office
protection, Peoples National Bank cannot enter Tuckerton by any route other than merger. No competition
presently exists between the two banks; their closest
offices are some 30 miles apart. As it is the intention
of the Peoples National Bank of New Jersey to retain
all offices of The First National Bank of Tuckerton, the
convenience of the public’s banking needs will continue
to be served.
The merger will not change the competitive status in
Peoples National Bank’s present market area. However,
it will bring a new and larger banking facility to the
Tuckerton-Atlantic City-Toms River market.
This Office is, therefore, of the opinion that the
proposed merger will have no adverse competitive ef­
fect and is in the public interest. The application is,
therefore, approved.
Ju ly 16, 1971.

Tuckerton Bank is the smallest of the three banks
operating offices in the rural southern section of Ocean
County, and holds about 3 percent of county deposits.
In view of the size of Tuckerton Bank, the nature of
its service area, and the existence of other larger po­

SU M M A R Y OF REPORT B Y A T TO R N E Y GENER AL

tential entrants should future growth support further
offices, we conclude that the proposed merger would

The head offices of the participating banks are 64
miles apart, and their closest offices are some 40 miles
apart. There are numerous banking alternatives in the
*

not have a significantly adverse effect on potential
competition.
*

*

T he First N ational Bank of E astern Pennsylvania , W ilkes-B arre , Pa ., and T he First-S troudsburg
N ational Bank , Stroudsburg, Pa .

Banking offices
Name of bank and type of transaction

Total assets

The First-Stroudsburg National Bank, Stroudsburg, Pa. (3632), with......................
and The First National Bank of Eastern Pennsylvania, Wilkes-Barre, Pa. (30),
which had.....................................................................................................................................
merged Sept. 10, 1971, under charter and title of the latter bank (30). The merged
bank at date of merger had....................................................................................................

c o m p t r o l l e r ’s

d e c is io n

On June 11, 1971, The First-Stroudsburg National
Bank, Stroudsburg, Pa., and The First National Bank
of Eastern Pennsylvania, Wilkes-Barre, 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 Eastern Pennsylvania,
the charter bank, with I PC deposits of $127.7 million,
was organized in 1863, and now operates 15 offices,
and has one approved but unopened office.




To be
operated

In
operation

$46, 557, 694

4

213, 765, 334

16

259, 095, 750

20

The charter bank, with headquarters in WilkesBarre, which has a population of 58,856, services the
eastern three-fourths of Luzerne County, small por­
tions of southern Wyoming and Lackawanna counties,
the extreme northern portion of Carbon County, and
central Columbia County. The economy of this rather
extensive service area is marked by diversification, in­
dustries range from mining of mineral resources, in­
cluding anthracite coal, through heavy and light
manufacturing, to tourism. Once considered an eco­
nomically distressed area, marked by high unemploy­
ment, it is now enjoying steady employment and a
85

present competition between them to be eliminated.
This merger will improve competition rather than
reduce it since the combined institution will be able
to offer greater competition to the larger banks in the
area than can either participating bank operating inde­
pendently. In the service area of the charter bank, the
resulting bank will continue to rank third.
It is concluded that the merger will have no ad­
verse competitive effect and is in the public interest.
The application is, therefore, approved.
Ju ly 30, 1971.

reasonably high per capita income. Prospects for future
growth are good.
The First-Stroudsburg National Bank, the merging
bank, with IPC deposits o f $32.1 million, was organized
in 1857, and presently operates three branches. The
merging bank has been experiencing management
problems that have compelled it to resort to merger
for a cure.
Stroudsburg, Pa., the home of the merging bank,
is located in Monroe County, and has a population
of 5,451. The service area of the merging bank in­
cludes the southern two-thirds of Monroe County
which is composed almost entirely of the nationallyknown Pocono Mountains. While some light industry
lends support to the economy of the “ Stroudsburgs,”
tourism and recreation are the economic mainstays
of Monroe County.
The charter bank is third in size in Wilkes-Barre,
and the merging bank is second in size in its service
area. In the combined service area, there are such
larger banks as the $328 million Northeastern National
Bank of Pennsylvania and the $226 million United
Pennsylvania Bank, Wilkes-Barre. Other aggressive
competitors are the Third National Bank & Trust
Co. of Scranton, Scranton, Pa., with resources of $108
million; The Wyoming National Bank of Wilkes-Barre,
with $80 million; and the Peoples First National Bank
& Trust Co., Hazleton, with $69 million in resources.
This merger will particularly benefit the Strouds­
burg area. A larger institution will emerge, able to
solve the current problems of the merging bank, and
able to provide area business and industry with much
larger lines of credit, lower loan rates, competitive
deposit rates, sophisticated investment and trust coun­
seling, and a reservoir of lendable funds, a commodity
that is rapidly becoming depleted in Stroudsburg
banks.

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENERAL

The closest branches of the two banks (the White
Haven branch of First National and the Blakeslee
branch of Stroudsburg Bank) are about 10 miles apart
and the area between them is fairly rugged and con­
sists largely of State forest and game lands traversed by
both the Tobyhanna and Lehigh rivers. While there
are no banks located in the intervening area, the
amount of competition between these banks would
appear to be quite limited.
Under Pennsylvania law, branching is permitted in
either the county where an applicant bank’s main
office is located or in a county contiguous to that of
the main office. Therefore, First National could be
permitted to open branch offices anywhere in Monroe
County. While the “ Stroudsburgs” themselves have
not experienced significant growth in recent times, the
more favorable predictions for the county indicate
that some potential competition would be eliminated
by the proposed merger.
Stroudsburg Bank controls 29.6 percent of the
county’s total deposits. O f the possible potential en­
trants into this area, only one other bank (United Penn
Bank, Wilkes-Barre, deposits $203.2 m illion), is larger
than First National.
Because the merger will eliminate one of the leading
potential entrants into M onroe County, it would have
an adverse effect on competition.

Competition will not be adversely affected. The
service area of the two banks overlap only slightly
and there is in consequence very little in the way of
*

*

*

T he St . L awrence C ounty N ational Bank , C anton , N .Y., and U nited Bank , Star L ake , N .Y.

Banking offices
Name of bank and type of transaction

United Bank, Star Lake, N .Y ., with.......................................................................................
and The St. Lawrence County National Bank, Canton, N .Y . (8531), which h a d ..
merged Sept. 10, 1971, under charter and title of the latter bank (8531). The
merged bank at date of merger had.......................................................................................




Total assets

$6,318, 394
41, 109, 472
47, 666, 696

To be
operated

In
operation
3

6
9

c o m p t r o l l e r ’s

St. Lawrence County. It ranks 13th in size, and holds
1.3 percent of the $416 million in total deposits held
by banks headquartered in the Fifth Banking District
of New York.
Not only is existing competition between the pro­
ponents insignificant, but there is only a remote pos­
sibility for potential competition between them. The
proponents’ main offices are 42 road-miles apart, and
their closest offices are 23 road-miles apart. Thus, con­
summation of the proposed merger will not eliminate
present or foreseeable future competition between the
subject banks. The resulting bank will occupy the
merged bank’s same relative rank in St. Lawrence
County and in the Fifth Banking District.
The resulting bank plans to introduce new and ex­
panded services to merchants and residents of the
merging bank’s market area, including a credit card
program, trust department services, investment ad­
visory services, a larger lending limit, customer elec­
tronic data processing facilities, and higher interest
rates on savings accounts. In addition, the merging
bank’s management succession problem will be solved
by the availability o f the merging bank’s reservoir of
management talent.
Applying the statutory criteria, we conclude that the
proposed merger is not anticompetitive and will serve
the needs and convenience of the community affected.
The application is, therefore, approved.
A u g u s t 15,1971.

d e c is io n

O n June 24, 1971, United Bank, Star Lake, N.Y.,
and The St. Lawrence County National Bank, Canton,
N.Y., applied to the Comptroller of the Currency for
permission to merge under the charter and title of the
latter.
The St. Lawrence County National Bank, Canton,
N.Y., was organized in 1866, and now holds IPC de­
posits of $27.6 million. This bank, with five branches,
is the largest of the 12 commercial banks operatingun
the county. Although it is the third largest bank in
the Fifth Banking District of New York, it holds only
7.7 percent of the $416 million aggregate deposits in
the 25 commercial banks in the district. Competition
in the Fifth District includes Marine Midland BankNorthern, Watertown, with total deposits of $134
million, a subsidiary of the $6.7 billion Marine M id­
land Banks, Inc., and The National Bank of Northern
New York, Watertown, with total deposits of $89 mil­
lion, a proposed subsidiary of the $2 billion Lincoln
First Banks, Inc.
United Bank, Star Lake, N.Y., was organized in 1914
as The Edwards National Bank, Edwards, N.Y. Having
merged in 1959 with First National Bank of Harrisville, Harrisville, N.Y., the merging bank presently
holds IPC deposits of $1.65 million. The bank, head­
quartered in Star Lake, ooerates two branches, both
in St. Lawrence County. The bank ranks sixth in size
among

the

commercial

banks

headquartered

N ote .— No

in
*

*

Attorney General’s report received.

*

T he Farmers N ational Bank of M alone , M alone , N .Y ., and T he First N ational Bank of
W lN T H R O P , W lN T H R O P ,

N .Y.

Banking%offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The First National Bank of Winthrop, Winthrop, N .Y . (10747), w ith .....................
and The Farmers National Bank of Malone, Malone, N .Y. (598), which had...........
merged Sept. 20, 1971, under charter and title of the latter bank (598). The
merged bank at date of merger had.......................................................................................

C O M P T R O L L E R ^ D E C IS IO N

On June 23, 1971, The Farmers National Bank of
Malone, Malone N.Y., and The First National Bank
of Winthrop, Winthrop N.Y., applied to the Office of
the Comptroller of the Currency for permission to
merge under the charter and title of the former.




$3, 915, 637
32, 070, 894
35, 986, 531

1
3
4

The Farmers National Bank of Malone, the charter
bank, with IPC deposits of $23.5 million, was organized
in 1864. It is headquartered in Malone and maintains
two branch offices, one in the village of Fort Covington,
and the other in the village o f Chateaugay.
The First National Bank of Winthrop, the merging
bank, with IPC deposits of $3.2 million was established
87

in 1915. It is headquartered in Winthrop and has no
branch offices. The merging bank is plagued by man­
agerial problems and has an inadequate capital
structure.
The charter bank’s primary service area extends in
a 15- to 25-mile radius from its head office in Malone,
Franklin County. The estimated population of the vil­
lage o f Malone is 8,045, that of the total service area
is 25,000. The Malone area’s economy is predicated
upon shoe and apparel manufacturing industries while
the surrounding service area is economically depend­
ent upon agriculture and dairy farming.
The merging bank’s primary service area lies in a
10- to 15-mile radius from its headquarters in W in­
throp, St. Lawrence County. The area has no indus­
trial activity; its economy is primarily supported by
farming, with milk production as the principal source
of income.
There are 26 competing commercial banks in the
Fifth Banking District, the resulting bank’s proposed
service area. The charter bank, with 5.4 percent of ag­
gregate deposits, ranks fifth in size; the merging bank,
with 0.8 percent of the aggregate deposits, ranks 18th
in size. Larger competitors providing intense competi­
tion with the participating banks include Marine M id­
land Bank-Northern, Watertown, with total deposits of
$133.6 million; National Bank of Northern New York,
Watertown, with total deposits of $89.7 million; St.
Lawrence County National Bank, Canton, with total
deposits of $32.9 million; and Ogdensburg Trust Co.,
Ogdensburg, with total deposits of $26.2 million. A d­
ditional competition is provided by mutual savings
banks, savings and loan associations, credit unions, and
personal and sales finance companies.

offer an increased lending limit, trust department
services, and investment advisory and agency serv­
ices to the merging bank’s customers. In addition,
the resulting bank will make available to the merging
bank’s customers the advice and counsel of the charter
bank’s competent management staff. Approval of this
merger will, in fact, create a new alternative for com ­
plete commercial banking services for the Winthrop
community. In addition, consummation of the pro­
posed merger will eliminate the home office protection
feature o f New York law in Winthrop and open that
town to de novo branching by other banks.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. This application
is, therefore, approved.
A u g u s t 19, 1971.
SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

Farmers National operates no offices in St. Law­
rence County. The closest offices of the two banks
are approximately 25 miles apart, with two banks in
the intervening area. Although the banks have a few
customers in common, it does not appear likely, that
the proposed merger would eliminate substantial direct
competition.
St. Lawrence and Franklin counties, adjoin one an­
other and are in the Fifth Banking District. New York
law permits intradistrict de novo branching but, within
a district, home office protection exists. Because of this
home office protection, Farmers National is prohibited
from entering Winthrop de novo but could enter one
of three larger communities within 5 to 10 miles of
Winthrop, which do not have home office protection.

Competition will not be adversely effected by con­

These communities and their 1970 populations, are as

summation of the proposed merger. The service areas

follows: Potsdam, 9,985; Norwood, 2,031; and Mas-

of participating banks do not overlap. The distance be­
tween the closest offices of subject banks is 28 miles,

sena, 13,882.
Fanners National is the second largest of the five

with a competing commercial bank intervening. Com­

banks in Franklin County, with 31.9 percent of total

mon deposit and loan accounts are minimal. There will

deposits and 27.7 percent of IPC demand deposits, and

be no appreciable effect on the commercial banking

is the largest bank in the Fifth District which does not

structure in the service area. Present competitor banks

have an office in St. Lawrence County.

will continue to provide competition for the resulting

There are 14 banks operating in St. Lawrence

bank.The two largest commercial banks, Marine M id­

County, with a total o f 25 offices. Twelve of the banks

land Bank-Northern and National Bank of Northern

are headquartered in the county. As of June 30, 1970,

New York, will continue to have over 50 percent of the

First National was the ninth largest, with 2.5 percent

total assets, loans, and deposits held by the commercial
banks in the area.

of both total deposits and IPC demand deposits. The

Approval of the proposed merger will result in ad­

four largest banks account for 68.5 percent of total
deposits and 65.6 percent of IPC demand deposits.

ditional banking services for the residents and business­

The proposed merger would eliminate Farmers Na­

men of the Winthrop area. The resulting bank will

tional as a potential de novo entrant into the Winthrop

88



area. However, in view of the existence of other potential entrants, and the size of First National, we do not
*

believe the proposed merger would have a significantly
adverse effect on potential competition.
*

*

Southern C alifornia First N ational Bank , San D iego, C alif ., and N ewport N ational Bank ,
N ewport Beach , C alif .

Banking offices
Total assets

Name of bank and type of transaction

In

operation

merged Sept. 23, 1971, under charter and title of the latter bank (3050). The
merged bank at date of merger had.....................................................................................

C O M P T R O L L E R ^ D E C IS IO N

On April 28, 1971, the Southern California First
National Bank, San Diego, Calif., and the Newport
National Bank, Newport Beach, Calif., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
Newport National Bank, the merging bank, with
IPC deposits of $68.2 million, was opened for business
on January 6, 1964. The bank is headquartered in
Newport Beach, a coastal community in the southern
portion of Orange County, and operates eight other
offices in the county.
Southern California First National Bank, the char­
ter bank, with IPC deposits of $510 million, was estab­
lished as the First National Bank of San Diego on
August 26, 1883. It presently operates, exclusive of the
main office, 58 branches of which 37 are in San Diego
County, 12 in Los Angeles County, and nine in Orange
County. The bank also has approval for four additional
banking offices, one of which would be located in San
Diego County, two in Orange County, and one in Los
Angeles County.
The market area served by the Southern California
First National Bank encompasses the whole of San
Diego

County,

with

a

population

estimated

at

1,358,000, half of whom reside in the city o f San Diego.
The bank, with 12 branches in Los Angeles County
and nine in Orange County, also competes in those
counties. Los Angeles County, with the heaviest con­
centration of its population in the cities of Los Angeles
and Long Beach, has a present population estimated
at 7 million, and Orange County has a population of
approximately 1.4 million.




$89, 419, 007

10

728, 642, 847

Newport National Bank, Newport Beach, Calif. (15235), with...................................
and Southern California First National Bank, San Diego, Calif. (3050), which

To be
operated

60

818, 061,854

70

The economy of San Diego, Orange, and Los An­
geles counties is stable and highly diversified in in­
dustry, agriculture, foreign and domestic trade, and
many other commercial and service activities, includ­
ing aircraft and aerospace research and development,
fishing, tourism, oil production, manufacturing of all
types, military establishments, and retail trade.
Compared to other California banks, Southern Cali­
fornia First National Bank ranks ninth in deposits and
has only 1 percent of the total deposits in the State.
Newport National Bank ranks 35th, with only 0.1 per­
cent of the State totals. The charter bank will remain
ninth in the State after the merger. For the counties of
Los Angeles, Orange, and San Diego, the merging
bank ranks 21st and the charter bank sixth, a position
the resulting bank would also occupy. In the area
where offices of the two banks are closest, viz., Orange
County, Newport National Bank has 2.6 percent of the
total deposits while Southern California First National
has only 2.1 percent. Although the Costa Mesa branch
of the Southern California First National Bank is lo­
cated approximately 1 mile from the offices of the
Newport National Bank, in Newport Beach, and ap­
proximately 4.5 miles from the Bayside branch of the
Newport National Bank, there is little, if any, direct
competition between the two banks as there are few
common depositors or borrowers.
The resulting bank would provide more sophisti­
cated banking services in Orange County and give the
charter bank an improved competitive position in re­
lation to the larger statewide branch banks in the
county. Perhaps more important, the merger will cor­
rect the managerial problems of the merging bank as
most of the pre-merger directors seemed to have little
interest in the bank’ s operation.
89

This merger will not cause a substantial decrease in
competition. The proportion of the total Orange
County bank deposits held by Southern California
First National Bank will amount to only approximately
4.6 percent after the merger.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. The application,
is, therefore, approved.
A ugust 9, 1971.
SU M M ARY OF REPORT BY A T TO R N E Y G ENER AL

First National operates nine offices in Orange
County, as does Newport Bank. The closest Orange
County offices of the merging banks are within 2 miles
of one another, and are located in the Newport Beach

in Orange County, generally, and most specifically in
the Newport Beach area, where they operate one and
four offices, respectively.
Although Newport Bank and First National were
the seventh and 10th largest banks, respectively, of
25 banks operating in Orange County, as of June 1970,
and their shares of total county deposits were 3.7 per­
cent and 2.2 percent, respectively, they are much more
significant competitors in the Newport Beach area. In
that area, Newport Bank ranked third, and held al­
most 20 percent of the deposits in commercial bank­
ing offices, as of June 30, 1970, while First National
held almost 2 percent. Four banks held almost 89 per-r
cent of such deposits, and this merger would increase
that share to over 90 percent.

area. This area is defined as including all banking

Hence, because this merger will eliminate banking
competition in the Newport Beach area and Orange

offices within the area bounded by the Pacific Ocean
in the southwest, the Santa Ana River on the north­

County, generally, and will result in a substantial in­
crease in concentration of control over baulking de­

west, the San Diego Freeway on the northeast, and the

posits in the Newport Beach area, we conclude that

Irvine subdivision on the southeast. This merger will

this merger may have a significantly adverse effect on
competition.

eliminate existing competition between the two banks

*
C itizens N ational Bank of M orris C ounty , Sucgasunna, N.J., and T he W arren C ounty N ational Bank ,
W ashington , N.J.
’

Banking offices
Name of bank and type of transaction

Total assets

Citizens National Bank of Morris County, Succasunna, N.J. (6692), with..................
and The Warren County National Bank, Washington, N.J. (860), which had...........
merged Sept. 24, 1971, under charter of the latter bank (860) and title “ First Na­
tional State Bank of Northwest Jersey.” The merged bank at date of merger had.

c o m p t r o l l e r ’s d e c is io n

O n June 21, 1971, Citizens National Bank of Morris
County, Succasunna, N.J., and The Warren County
National Bank, Washington, N. J., applied to the Office
of the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title, “ First National State Bank of Northwest Jersey,”
with headquarters in Succasunna.
The Warren County National Bank, the charter
bank, with IPC deposits of $32.4 million, was orga­
nized in 1864. As a result o f a 1970 merger with The
Second Warren County National Bank, the charter
bank became a subsidiary of First National State
Bancorporation, a registered bank holding company
with principal offices in Newark.

90



$48, 099, 372
44, 297, 397
92, 396, 769

In
operation

To be
operated
4
4
8

The charter bank is headquartered in Washington
Borough, Warren County. It presently operates offices
in Hackettstown, Mansfield Township, Washington,
and Washington Township. The Warren County Na­
tional Bank ranks 33d in size among the 87 commer­
cial banks in New Jersey’s First Banking District, with
0.4 percent of the district’s aggregate deposits of $8.1
billion.
The primary service area of the charter bank in­
cludes the eastern and southeastern portion of Warren
County. That area encompasses 11 of the county’ s 24
municipalities, and serves an approximate population
of 33,168. The area’s economy is predicated on farm­
ing and forestry, with additional support from local
manufacturing.

Banks competing with the charter bank in its service
area include National Newark and Essex Bank,
Newark, with total assets of $763.9 million; Peoples
Trust of New Jersey, Hackensack, with total assets of
$733.9 million; Orange Savings Bank, Hackettstown,
with total assets of $105.8 million; and The Phillipsburg National Bank & Trust Co., Phillipsburg, with
total assets of $33.8 million.
Citizens National Bank of Morris County, the merg­
ing bank, with IPC deposits of $30.4 million, was orga­
nized in 1903. Headquartered in Succasunna, Roxbury
Township, it maintains three branch offices and has
one approved but unopened office in Flanders, Mount
Olive Township. Citizens National Bank ranks 29th
in size among the 87 commercial banks in New Jersey’ s
First Banking District, with 0.5 percent of the district’s
aggregate deposits of $8.1 billion.
The primary service area of the merging bank in­
cludes the northwestern portion of Morris County and
a small southeastern section of Sussex County. Morris
County is the third fastest growing county in the State,
with an approximate population of 383,484. M uch of
the area is still in farm and forest land; however, ex­
tensive industrial, commercial, and residential devel­
opment has occurred in recent years.
Banks in direct competition with the merging bank
include American National Bank & Trust, Montclair,
with total assets of $367.7 million; First National Iron
Bank of New Jersey, Morristown, with total assets of
$181.9 million; and, The Sussex and Merchants Na­
tional Bank, Hopatcong, with total assets of $56.3
million. Additional competition is provided by branches
of larger out-of-county banks, an office of Morris
County Savings Bank, Morristown, with total assets
of $206.2 million, and by two savings and loan institu­
tions. Existing competitor banks do not include
any

subsidiary

banks

of

First

National

State

Bancorporation.
Competition will not be adversely affected by con­
summation of the proposed merger. Existing competi­
tion between participating banks is insignificant, and

Approval of this merger will not materially increase
the position of Bancorporation in relation to the bank­
ing structure o f New Jersey. Bancorporation’s 5.5 per­
cent of aggregate deposits of New Jersey’s commercial
banks would be increased by only 0.2 percent by the
addition of Citizens National Bank deposits. Also, the
holding company’s operation of 5.3 percent of the
State’s commercial and savings banks’ offices would be
increased by only 0.4 percent with the addition of the
offices of Citizens National Bank.
Consummation of the proposed merger will enhance
competition in the service areas of participating banks.
The resulting bank will increase the lending capacity
in the two areas and will introduce such additional and
expanded services as data processing, personal and
corporate trust, and international banking.
Applying the statutory criteria to this application,
it is concluded that the proposed merger is in the public
interest. The application is, therefore, approved.
A u g u s t 9, 1971.
SU M M A R Y OF REPORT B Y A T TO R N E Y G ENER AL

The main offices of Citizens Bank and Warren Bank
are located 25 miles apart, with their closest offices
6.5 miles from each other and no other banks in the
intervening area. The application states that geo­
graphic barriers separate the markets served by Warren
Bank and Citizens Bank. However, each bank does
draw a limited amount of business from areas pri­
marily served by the other. No significant competition
exists between Citizens Bank and any other banking
subsidiary of First Bancorporation.
New Jersey law permits districtwide branching and
statewide operation of holding companies, subject to
complete home office protection and branch office
protection in municipalities of less than 7,500 popu­
lation. First Bancorporation has embarked on a pro­
gram of market expansion, having acquired two sub­
sidiaries in New Jersey’s First District, as well as
subsidiaries in the Second District. In view of its patent
capabilities, First Bancorporation, and its subsidiaries,

prospects for future competition are considered remote

must be regarded as among the most significant poten­

as the subject banks have separate and distinct service
areas. The banks’ main offices are 25 miles apart. While

tial entrants into new banking markets.

their nearest offices are only 6.5 miles distant, they are

point that large, expansion-oriented banking institu­

separated by a State park with no direct line of com­

tions enter new market either de novo or through ac­

munication between them. The number of common

quisition of smaller competitors, in order to promote

borrowers and depositors is negligible. De novo branch­

the development of a highly competitive banking struc­

We regard it important from a competitive stand­

ing is not an available alternative to merger due to the

ture. Additionally, it may be important to prevent

home office protection provision in the State statute
and the population requirements.

an undue number of acquisitions by a single banking




institution in any particular area, not only to avoid
91

alternative mergers eliminate home office protectioi
barriers), or through increased efforts of nearby sub
sidiaries, should not be discounted. First Bancorpora
tion’s subsidiary, Warren Bank, holds a leading positior
in an immediately adjacent area. While several oi
New Jersey’s other large banking institutions have
effected entry into the service areas of both Warren
Bank and Citizens Bank, we conclude that the pro­
posed merger may have some adverse effect on com ­
petition, particularly if further expansion and
affiliations alter the present localized character of bank­
ing competition in this area to a more regional nature.
As of June 30, 1970, Warren Bank ranked first in
Warren County, with 23.5 percent of total county
deposits. Citizens Bank ranked sixth in Morris County,
with 6.2 percent of total county deposits.

the elimination of whatever direct competition may
exist between the acquired banks, but also in recog­
nition of the fact that the service areas of commercial
banks usually expand, and banks serving adjacent areas
may well find the level of competition between them
consistently increasing. Moreover, because of New
Jersey’s home and branch office protection statutes,
entry into particular local banking markets may be
more difficult; therefore, it is desirable to preserve
and promote the existence of alternative banking
choices in adjacent areas.
In this case, de novo entry into the area served by
Citizens Bank is seriously impeded by home and branch
office protection, although in view of the capabilities
of First Bancorporation, its presence in this market,
either through actual de novo entry (particularly if
*

*

*

First N ational Bank of South Jersey, Egg H arbor T ownship , N.J., and T he First N ational Bank
of G lassboro, G lassboro, N.J.

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The First National Bank of Glassboro, Glassboro, N.J. (3843), with..........................
and First National Bank of South Jersey, Egg Harbor Township, N.J. (1326),
which had........................................................................................................................................
merged Sept. 30, 1971, under charter and title of the latter bank (1326). The
merged bank at date of merger had.......................................................................................

co m ptro ller 's

d e c is io n

On July 12, 1971, The First National Bank of Glass­
boro, Glassboro, N.J., and First National Bank of
South Jersey, Egg Harbor Township, 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 Bank of South Jersey, Egg Harbor
Township, N.J., the charter bank, with I PC deposits
of $243.6 million, is headquartered in Atlantic County.
The charter bank was organized in 1907, and cur­
rently operates 29 offices in four counties, 20 of which
are in Atlantic County.
The service area of the charter bank is estimated
to be one of the most rapidly expanding regions in
the Nation. Its proximity to New York and Philadel­
phia, its excellent transportation facilities, and its large
amount of undeveloped land have accounted for the
phenomenal growth rate.
92




$17, 533, 262

4

351, 832, 388

29

369, 365, 650

33

In the Third Banking District, First National Bank
of South Jersey ranks third behind the South Jersey
National Bank, with total resources of $404.6 million,
and The Bank of New Jersey, with total resources of
$397.2 million. That ranking ignores the three hold­
ing companies that have subsidiary banks in the Third
District. Further competition to the charter bank
emanates from Philadelphia and Wilmington banks
which actively solicit demand and savings deposits
in the area.
The First National Bank o f Glassboro, Glassboro,
N.J., the merging bank, with IPC deposits of $21.4
million, is headquartered in Gloucester County. The
bank operates three offices in addition to its main of­
fice within the borough of Glassboro.
Gloucester County is experiencing a population
boom as the suburban exodus from the PhiladelphiaCamden Metropolitan Area continues. Glassboro has
historically been considered a “ college town,” but in
recent years the town has expanded industrially.

merger. Existing competition between the charter and
merging banks is de minimus; there are no common

The First National Bank of Glassboro is ranked third
in deposits among the nine commercial banks head­
quartered in Gloucester County. Its competition de­
rives from the Peoples National Bank of New Jersey,
in Westmont, with deposits of $165 million; National
Bank & Trust Co. of Gloucester County, in Woodbury,
with deposits of $79 million; National Bank of Mantua,
in Sewell, with deposits of $18 million; and The Peo­
ples Bank of South Jersey, in Washington Township,
with deposits of $16 million.
This merger will improve services in the Glassboro
area, offering a substantially larger lending limit, cus­
tomer electronic data processing facilities, and trust
department services. Also, the resulting bank will pro­
vide a credit card program, specialized services, and
eight different savings plans.
Competition will not be adversely affected by this
*

borrowers or depositors. The main offices of the two
banks are 42 miles apart. The closest branch of the
charter bank to an office of the merging bank is 7 miles
distant. While the merger will eliminate The First
National Bank of Glassboro as a banking alternative,
it will also eliminate the “ home office protection” fea­
ture of the New Jersey law from Glassboro, and will
open that municipality to de novo branching by com­
peting banks.
Applying the statutory criteria, we find the merger
to be in the public interest. The application is, there­
fore, approved.
A ugust 18, 1971.
N ote .— No Attorney General’s Report received.
*

*

N orthern N ational Bank & T rust C o ., W ellsboro, Pa ., and T he C itizens N ational Bank & T rust C o
of T owanda , T owanda , Pa .

Banking offices
Name of bank and type of transaction

Total assets

The Citizens National Bank & Trust Co. of Towanda, Towanda, Pa. (2337),
with...................................................................................................................................................
and Northern National Bank & Trust Co., Wellsboro, Pa. (328), which had.........
consolidated Oct. 1, 1971, under charter of the latter bank (328) and title “ Citi­
zens & Northern National Bank and Trust Co.” The consolidated bank at date
of consolidation had.....................................................................................................................

c o m p t r o l l e r ’s

d e c is io n

On June 1, 1971, the Northern National Bank &
Trust Co., Wellsboro, Pa., and The Citizens National
Bank & Trust Co. of Towanda, Towanda, Pa., applied
to the Office o f the Comptroller of the Currency for
permission to consolidate under the charter of the
former and with the title, “ Citizens & Northern Na­
tional Bank and Trust Company,” with its main office
to be located in Towanda, Bradford County, Pa.
Northern National Bank & Trust Co., Wellsboro, Pa.,
the charter bank, with deposits of $27.5 million, was
organized in 1864. In addition to its main office, the
bank currently operates four branches.
The service area of the charter bank encompasses
all of Tioga County and portions o f Lycoming County
and southern New York State. The main office of the
bank is located in Wellsboro, the county seat of Tioga
County. The borough of Wellsboro has a well-diver­




$17, 585, 348
34, 572, 557

52, 157, 312

In
operation

To be
operated
4
4

8

sified economy which provides employment for about
6,000 persons. The rest of Tioga County is devoted
chiefly to dairy farming. Although Tioga County has
lately been undergoing development as a future resort
area, the county is at present not a prosperous one.
There are three banks located in Tioga County:
Northern National; the Wellsboro office of Common­
wealth Bank & Trust Co., Muncy, Pa.; and the First
Citizens National Bank of Mansfield, Mansfield, Pa.
Also, as many of the residents commute to New York,
the banks in the lower New York State area should be
considered

as providing competition to Northern

National.
The Citizens National Bank & Trust Co. of T o ­
wanda, Towanda, Pa., the consolidating bank, with de­
posits of $14.2 million, was organized in 1876. The
bank operates four offices, all of which are located in
Bradford County.
93

The service area of the consolidating bank includes
the lower two-thirds of Bradford County. Although
dairy farming is the cornerstone of the local economy,
there is some industry in Towanda. Most residents find
employment in Towanda or Sayre, with some com­
muting to employment in New York State. While
Bradford County is more densely populated than Tioga
County, the difference is merely relative as Bradford
County must still be considered to be lightly populated
by any reasonable standard.
There are 11 banks in Bradford County. Although
Citizens is the third largest bank in the county, it holds
only 14 percent of the total bank deposits, and cannot,
therefore, be claimed to be in a dominant position.
The consolidation will have no adverse effect on
competition, as the two service areas involved are
separated by a natural barrier— a mountain which
separates the Mansfield and Troy areas. Further, none
of the charter bank’s offices is within 25 miles of a

home offices are located and all counties contiguous

consolidating bank office, and, between the nearest

thereto. Therefore, either of the merging banks could

offices, there are at least two intervening offices main­

enter the service area of the other de novo, entering

the added public benefits of an increased lending limit
more sophisticated trust services, package bank state­
ments, and investment counseling.
Applying the statutory criteria, this consolidation is
in the public interest. Therefore, the consolidation
application is approved.
A ugust 25, 1971
SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

The closest offices of the consolidating banks are
over 25 miles apart. Although located in adjacent
counties, each appears to draw little banking business
from areas served by the others. Therefore, their pro­
posed merger is unlikely to eliminate significant exist­
ing competition.
Pennsylvania law permits commercial banks to open
and operate branches in the county in which their

tained by other banks. Finally, there are very few

into competition with the other. In general, however,

customers maintaining accounts at both banks.

neither county is growing rapidly.

Consummation of the proposed consolidation will

There are several other larger banks eligible to

benefit the communities in which the resulting bank

branch de novo into both Tioga and Bradford counties.

will operate by introducing an institution more capable

Citizens Bank is the fourth largest bank operating

of accommodating credit requests. The resulting bank

offices in Bradford County and, as of June 30, 1970,

will be able to compete effectively with the larger

held about 14 percent of total county deposits. North-

and more aggressive Commonwealth Bank & Trust

Pennsylvania law permits commercial banks to open

Co. of Muncy, Pa., a result that will benefit the bank­
ing public. The same beneficial situation will prevail

ating offices in Tioga County, but holds the leading
share of deposits in the county’s banking offices, about
43 percent.

in the service area of the consolidating bank with
*

*

*

T he First N ational Bank of R ussellville, R ussellville, A l a ., and C ity N ational Bank of
R ussellville, R ussellville, A l a .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
City National Bank of Russellville, Russellville, Ala. (15466), with.............................
was purchased Oct. 15, 1971, by The First National Bank of Russellville, Russell­
ville, Ala. (11846), which had..................................................................................................
After the purchase was effected, the receiving bank had.................................................

comptroller ' s decision

On October 15, 1971, application was made to the
Comptroller of the Currency by The First National
Bank, Russellville, Ala., for permission to purchase
94




$9, 470, 222
9, 364, 273
18, 834, 495

3
1
4

assets and assume deposit liabilities of the City Na­
tional Bank of Russellville, Russellville, Ala.
In accordance with the provisions of 12 U.S.C. 181
and 12 U.S.C. 1828(c), it is found that an emergency

sale agreement is waived and The First National Bank
is authorized to proceed with the purchase and assump­
tion transaction.
O ctober 15, 1971.

exists and that this Office must act immediately to pre­
vent the probable failure of the City National Bank
of Russellville and to protect its depositors, creditors,
and shareholders.
Accordingly, approval by the shareholders of the

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

City National Bank of Russellville of the purchase and
*

*

*

Provident N ational Bank , Philadelphia , Pa ., and T he N ational Bank of C hester V alley ,
C o ATESVILLE, P a .

Bankin,? offices
Name of bank and type of transaction

Total assets

In

operation
The National Bank of Chester Valley, Coatesville, Pa. (575), with.............................
and Provident National Bank, Philadelphia, Pa. (15422), which had........................
merged Oct. 22, 1971, under charter and title of the latter bank (15422). The
merged bank at date of merger had..................................................................... .................

comptroller ’ s decision

On July 6, 1971, The National Bank of Chester
Valley, Coatesville, Pa., and Provident National Bank,
Philadelphia, Pa., applied to the Office of the Comp­
troller of the Currency for permission to merge under
the charter and with the title of the latter, with head­
quarters in Bryn Mawr, Lower Merion Township.
Provident National Bank, Philadelphia, Pa., the
charter bank, with IPC deposits of $801.2 million, was
originally chartered in 1865. With a network of 39
banking offices, the bank serves all of Philadelphia
County, the southern half of Montgomery County,
and the extreme northern and southern portions of
Bucks County. That service area encompasses most of
metropolitan Philadelphia and its surrounding sub­
urbs. The economy of that section of southeastern
Pennsylvania is oriented toward Philadelphia, and
is supported by a wide array of heavy and light in­
dustries combined with a sizable number of service
organizations.
In its service area, the charter bank ranks fifth in
size. Among the competitors of the charter bank are
the $2.7 billion First Pennsylvania Banking & Trust
Co., the $2.0 billion Girard Bank, the $2.3 billion
Philadelphia National Bank, and the $1.5 billion Fi­
delity Bank.
The National Bank of Chester Valley, Coatesville,
Pa., the merging bank, with IPC deposits of $24.7
million, was originally chartered in 1857. The bank,
headquartered in Coatesville, serves the central and




$29, 024, 752
1, 081, 667, 266
1, 111,218,599

To be
operated

3
39
42

western portions of Chester County through its three
offices. Although Chester County has long been con­
sidered to be agricultural in character, the expansion
of the Philadelphia suburbs has made it the fastest
growing residential and industrial area in southeast­
ern Pennsylvania.
The merging bank is ranked 10th in size among
the banks in Chester County. Those competitors are
all considerably larger than the merging bank.
Competition will not be adversely affected by the
consummation of the proposed merger. Because the
charter and merging banks operate in different serv­
ice areas, there is no existing competition between
them. Furthermore, the charter bank may not pres­
ently open branches in Chester County because it is
not contiguous to Philadelphia County where Provi­
dent National Bank has its main office. The charter
bank, however, by relocating its main office to M ont­
gomery County, as an incident of this merger, will be
able to branch into Chester County. In the present
service area of the charter bank the addition of the
much smaller merging bank will have a de minimus
effect on concentration. Competition will be enhanced
in the service area of the merging bank since the
resulting bank will provide the same sophisticated
sendees provided by the metropolitan Philadelphia
banks.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The sub­
ject application requesting permission to merge, to
locate the main office in Bryn Mawr, and to retain

95

the present main office of Provident National Bank
as a branch is, therefore, approved.
September 21, 1971.
SU M M A R Y OF REPORT B Y A T TO R N E Y G EN ER A L

The nearest offices of these two banks are 18 miles
apart with many intervening banks. Although Provi­
dent is o f such a size as to draw business from well
beyond the immediate vicinities of its offices, it ap­
pears that the proposed merger would eliminate no
more than a limited amount of direct competition.
At present, Provident may not operate branches in
Chester County, which is not contiguous to Phila­
delphia County where Provident has its main office.
However, Provident, like many other large Philadel­
phia banks, is moving its main office to Montgomery
County, which will enable it to branch in Chester
County, as well as Berks and Lehigh counties.

At present, Provident is the smallest of the three
very large Philadelphia banks which have not yet
entered Chester County. However, Provident’s re­
sources and the promising nature of the economy of
Chester County make Provident a significant poten­
tial entrant. Provident clearly has the resources to
enter the county de novo, rather than through merger
with an existing bank. National Bank of Chester V al­
ley is not among the leading banks in Chester County,
either in terms of absolute size or local market share.
It is the fourth largest of the eight banks headquartered
in the county, significantly smaller than some distant
banks which operate offices in Chester County, and
holds about 6 percent of total county deposits.
In view o f the size and market position of National
Bank of Chester Valley, we do not believe that the
proposed merger would have any significantly adverse
effect on potential competition.
*

T he Bank of C alifornia , N .A., San Francisco, C alif ., and Bank of R edding , R edding , C alif .

Banking offices
Name of bank and type of transaction

Total assets

Bank of Redding, Redding, Calif., with................................................................................
was purchased Oct. 29, 1971, by The Bank of California, National Association,
San Francisco, Calif. (9655), which had...............................................................................
After the purchase was effected, the receiving bank had.................................................

COM PTR OLLER ^

D E C IS IO N

On July 30, 1971, The Bank of California, National
Association, San Francisco, Calif., applied to the O f­
fice of the Comptroller of the Currency for permission
to purchase the assets and assume the liabilities of
Bank o f Redding, Redding, Calif.
The Bank of California, National Association, the
applicant, was chartered in 1864. Headquartered in
San Francisco, the applicant presently operates 71 do­
mestic branches in three States, and has approval for
12 additional branches as yet unopened. Presently the
seventh largest bank in California, the applicant has
total resources of approximately $2 billion.
The Bank of Redding, Redding, Calif., the selling
bank, was chartered in 1964. With total resources of
$26.1 million, the selling bank has experienced rapid
growth.
The service area of the selling bank encompasses
the southwestern portion of Shasta County which has

96



In
operation

To be
operated

$25, 280, 000

3

2, 060, 019, 427
2, 085, 299, 427

72
75

an estimated population of 70,000 persons. The city
of Redding, located 160 miles northeast o f Sacra­
mento, is the marketing center for the entire northcentral California area. The economy is heavily de­
pendent upon lumbering and agriculture, as well as
on the growing tourist trade.
While there are nine competing bank offices in R ed­
ding, all but one are branches of large statewide bank­
ing institutions. The Bank of Redding holds only a
small percentage of the total bank deposits in Redding.
Competition will not be adversely affected by con­
summation of the proposed acquisition. There is no
service area overlap and no common customer rela­
tionship of any significance. The nearest branch of the
applicant is some 160 miles away in Sacramento. Fur­
thermore, the addition of the selling bank, because of
its small size, will have a de minimus effect upon The
Bank of California’ s competitive position in the three
States in which it operates banking offices. The acqui­
sition will in fact enhance competition within Redding

because The Bank of California, National Association,
will be more able to compete with the branches of the
larger statewide banks in Redding than is the selling
bank.
Applying the statutory criteria, it is concluded that
the proposed acquisition is in the public interest. The
application is, therefore, approved.
September 24,1971.

ding and both of these are based in Los Angeles and
have only recently expanded into northern California.
The result of this merger, therefore, will be to eliminate
one of the most significant potential entrants into
Redding.
Finally, and most importantly, BCNA is one of
eight banks which dominate California banking. These
eight institutions hold over 88 percent o f all com­
mercial bank deposits and dominate all banking mar­
kets in the State. The continued pattern of acquisitions
by these leaders o f independent banks with significant
shares of local markets has two undesirable competitive
effects. It serves to entrench the existing statewide
oligopoly structure of banking in particular markets by
removing those banks most able to disrupt such con­
duct within their own market. Secondly, it eliminates
those banks which can, by combining together or by
internal expansion, create new regional and perhaps
statewide entities able to compete with the existing
market leaders.

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENERAL

Approximately 160 miles separate the closest office
of BCNA (Sacramento office) and Redding Bank. It,
therefore, appears that little existing competition be­
tween the two banks will be eliminated.
As of June 1970, Redding Bank held 16.6 percent of
deposits held by commercial banking offices in Shasta
County, 15.2 percent in the city of Redding and 15.3
percent in Redding Bank’s service area as defined in
the application. Redding Bank, the only bank head­
quartered in Redding, ranked third out of five banks
serving the city, as of June 1970. The other four are
branches of much larger statewide banks: Bank of
America, Wells Fargo Bank, Crocker National Bank,
and United California Bank. Thus, the Redding mar­
ket is concentrated and Redding Bank is one of the
leading banks in that market.

In addition, Redding Bank has shown itself to be a
viable and dynamic bank since its establishment in
1964. It has achieved a significant market position in
the Redding area while competing with four of the
five largest banks in the State. Therefore, its elimina­
tion will remove a significant, as well as, the only
independent competitive bank in this area.

Since statewide branching is permitted in Cali­
fornia, BCNA could branch de novo into the Redding
area. Moreover, it is one of only a few likely entrants.
Only two banks larger than BCNA do not serve Red*

W e conclude that this merger will have an adverse
effect on competition in the city of Redding and in
Shasta County.
*

*

O pelika N ational Bank , O pelika , A l a ., and M idw ay Bank , O pelika , A l a .

Banking offices
Name of bank and type of transaction

Total assets

Midway Bank, Opelika, Ala., with.........................................................................................
and Opelika National Bank, Opelika, Ala. (11635), which had...................................
merged Nov. 1, 1971, under charter and title of the latter bank (11635). The
merged bank at date of merger had.......................................................................................

comptroller’ s decision

On May 28, 1971, Midway Bank, Opelika, Ala.,
and Opelika National Bank, Opelika, Ala., applied to
the Office of the Comptroller of the Currency for per­
mission to merge under the charter and title of the
latter.




$3, 308, 155
19, 104, 475
23, 038, 021

To be
operated

In
operation
1
2

3

Opelika National Bank, the charter bank, with IPC
deposits of $12.6 million, was organized in 1854. It is
headquartered in Opelika and maintains one branch
in Auburn, about 3.5 miles west of Midway Bank.
Midway Bank, the merging bank, with IPC deposits
of $2.3 million, is a single-unit institution located in
Opelika. It was established in 1966 as a separate bank­

97

ing institution affiliated with Opelika National Bank
because the law prohibited branch banking at that
time. The two banks are under common ownership,
share the same board of directors, and are served by
the same president.
The service area of participating banks includes the
cities o f Opelika and Auburn, and the immediately
surrounding territory. Opelika is the county seat of
Lee County, the third fastest growing area in the State.
Both Opelika, with a population of 19,027, and Au­
burn, with a population of 22,767, have experienced
steady growth in the past two decades. The economy
of Lee County is predicated upon industry, with addi­
tional support from farming.
Competition with participating banks in the service
area is provided by Farmers National, Opelika, with
total deposits of $16.4 million; First National, Opelika,
with total deposits of $12.3 million; Auburn National,
Auburn, with total deposits of $16.8 million; and First
National, Auburn, with total deposits of $15.5 million.
In addition, competition is provided by two savings
and loan associations, one in Opelika and the other in
Auburn.
Competition will not be adversely affected by con­
summation of this transaction. Because of their present

affiliation, the participating banks do not operate on a
competitive basis with each other. The proposed mer­
ger will not result in the elimination of an alternative
choice for the public since both banks are regarded as
one institution both by competitors and by area resi­
dents. The proposed merger will enable participating
banks to operate more effectively and efficiently and
will have no adverse effect on the competitive bank­
ing situation that presently exists in Lee County.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
September 30, 1971.
SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

M id-W ay Bank was established in 1966 by the Board
of Directors of Opelika National and has been under
that same management and stock control from organi­
zation to the present. M id-W ay Bank was established
because State law did not permit branch banking in
Lee County. Since September of 1969, branch banking
has been permitted there. Since it appears that no com ­
petition has ever existed between these two banks nor
is likely to develop, this merger would have no effect
on competition.
#

T he M erchants N ational Bank of Burlington , Burlington , V t ., and N orthfield T rust C o.,
N orthfield , V t .

Banking offices
Name of bank and type of transaction

Total assets

Northfield Trust Co., Northfield, V t., with..........................................................................
and The Merchants National Bank of Burlington, Burlington, Vt. (1197), which
had.....................................................................................................................................................
merged Nov. 1,1971, under charter and title of the latter bank (1197). The merged
bank at date of merger had.......................................................................................................

comptroller' s decision

O n July 22, 1971, Northfield Trust Co., Northfield,
Vt., and The Merchants National Bank of Burlington,
Burlington, Vt., applied to the Office of the Com p­
troller o f the Currency for permission to merge under
the charter and with the title of the latter.
The Merchants National Bank of Burlington, the
charter bank, is headquartered in Burlington, Vt. With
IPC deposits of $38.9 million, and total assets of $45.8
million, the charter bank is the fifth largest bank in
Vermont.

98



To be
operated

In
operation

$5, 534, 241

1

50,637,711

7

56, 171,952

8

The service area of the charter bank is comprised
of two separate and distinct sections o f the State. One
section includes Chittenden and Addison counties,
and is served by the main office and five branches.
The other section is around Barre, in central Vermont,
about 40 miles from Burlington. That area is served
by a branch acquired by a merger in 1970.
Northfield Trust Co., the merging bank, is head­
quartered in Northfield, approximately 12 miles south
of Montpelier. With IPC deposits of $4.7 million, the
merging bank is approximately the same size as its
chief competitor, Northfield National Bank.

The service area of the merging bank is separated
from the two service areas of the charter bank by
mountains. Northfield is essentially a residential com ­
munity with most residents commuting to jobs in
Montpelier.
Competition will not be adversely affected by con­
summation of the proposed merger. Because there is
no overlap of the service areas of the charter and
merging banks, the two banks are not in competition
with each other. While the effect on competition in
the Charter bank’s service areas, as a result o f the
merger, would be infinitesimal, the merger would
considerably enhance the competitive atmosphere in
Northfield as the resulting bank will introduce many
sophisticated banking services not now available.
Applying the statutory criteria, it is concluded that
the proposal is in the public interest. Therefore, the
application is approved.
September 23, 1971.

While applicable State law would permit either bank
to branch de novo into the service area of the other, the
size of Northfield would appear to preclude it as a
likely potential entrant into the Burlington area. It
seems unlikely that Merchants would establish a de
novo branch in Northfield.
Northfield is slightly larger than the other commer­
cial bank serving the community o f Northfield, and
it is next to the smallest o f the nine banks serving
Washington County, with 3.3 percent o f total deposits,
and 6.4 percent o f IPC demand deposits. Merchants
has the sixth largest share o f deposits held by Washing­
ton County banking offices, with 7.3 percent o f total
deposits, and 5.1 percent o f IPC demand deposits.
After the proposed merger, Merchants would continue
to hold the sixth largest share o f Washington County
deposits, but its locally derived deposits would increase
to 10.5 percent o f total deposits, and 11.5 percent o f
IPC demand deposits in the county. The banks with

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENERAL

The towns of Northfield and Barre (site of a M er­
chants branch) are only 9 miles apart in Washington
County; however, geographical barriers make it neces­
sary to go through Montpelier to get from Northfield

the four largest shares of county deposits account for
about 70 percent o f total and IPC demand deposits.
In the three-county area served by Merchants (A d­
dison and Chittenden counties in addition to Wash­
ington C ounty), Merchants is the third largest bank,

to Barre, making the Merchants branch in Barre effec­

with about 12.7 percent o f total deposits, and 14.7

tively 20 miles from the Northfield facility. There is

percent o f IPC demand deposits. The four largest

very little commercial intercourse between the cities of

banks with offices in this area account for 76.2 percent

Northfield and Barre. While Northfield has some de­

of total deposits, and 77.1 percent of IPC demand de­

posit accounts originating in the areas now served by

posits. After the proposed acquisition, these ratios

Merchants, it would appear that no significant amount

would increase by about 1.5 to 2 percentage points.
W e conclude that the proposed merger is unlikely

of direct competition will be eliminated by the pro­

to have a significantly adverse effect on competition.

posed merger.

*
T he FiRST-MACHiNtsTs N ational Bank of T aunton , T aunton , M ass., and M anufacturers N ational Bank
of Bristol C ounty , N orth A ttleboro , M ass.

Banking offices
Name of bank and type of transaction

The First-Machinists National Bank of Taunton, Taunton, Mass. (416), with. . . .
and Manufacturers National Bank of Bristol County, North Attleboro, Mass.
(5944), which had........................................................................................................................
consolidated Nov. 30, 1971, under charter of the latter bank (5944) and title
“ United National Bank.” The consolidated bank at date of consolidation h a d .. . .




Total assets

In
operation

To be
operated

$38, 191, 621

6

28, 572, 312

5

66, 763, 942

11

99

c o m p t r o l l e r ’s d e c is io n

On June 21, 1971, Manufacturers National Bank
of Bristol County, North Attleboro, Mass., and The
First-Machinists National Bank o f Taunton, Taunton,
Mass., applied to the Office of the Comptroller of the
Currency for permission to consolidate under the
charter o f the former and with the title “ United Na­
tional Bank,” with headquarters in Taunton, Mass.
Manufacturers National Bank of Bristol County,
North Attleboro, Mass., the charter bank, has total
deposits of $24.0 million. The bank was organized in
1922, and presently operates three branches and its
main office within the immediate vicinity of North
Attleboro. The Baystate Corp., a registered bank hold­
ing company, effectively controls the charter bank.
The service area of the charter bank is dominated by
manufacturing firms, with the jewelry industry as the
most important. The population of North Attleboro,
now about 18,455, has expanded at a tremendous rate
over the past decade. The cities of Attleboro and
Mansfield must also be included in the charter bank’s
area, as 79.1 percent of the bank’s total deposits come
from the three municipalities.
The First-Machinists National Bank of Taunton,
Taunton, Mass., the consolidating bank, has total de­
posits o f $31.5 million. This bank was founded in 1847,
and operates five branch offices centered around the
main office.
The service area of the consolidating bank is domi­
nated by manufacturing firms, with the silver industry
as the largest employer.

Competition will not be adversely affected by con­
summation o f the proposed consolidation. The service
areas of the two banks do not overlap. Competition
between the banks is minimal as is evidenced by the
lack of common customers and the geographical sepa­
ration accentuated by the poor road between North
Attleboro and Taunton. Consummation of the con­
solidation will allow the resulting bank to effectively
compete against the larger city banks from Providence
and Boston. While the Baystate Corp. will increase its
share of the combined financial institution deposits
in Bristol County, the holding company will still con­
trol far below the 13 percent held by the New Bed­
ford Institution for Savings, New Bedford, Mass.
Applying the statutory criteria, it is concluded that
the consolidation is in the public interest and is, there­
fore, approved.
Se p t e m

ber

14, 1971.

SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

Manufacturers’ offices in Mansfield and Machinists’
office in Norton are only 5.3 miles apart. While there
is little commercial intercourse between North Attle­
borough and Taunton, each o f the consolidating banks
draws a limited amount of business from the service
area of the other. Since Massachusetts law allows coun­
tywide branching, there is reason to believe that com ­
petition between these two consolidating banks may
increase in the future.

Both of the consolidating banks, although not com­

This consolidation will reduce the number of com ­

peting with each other to a significant degree, do

mercial banks located in northern Bristol County from

compete with the dominant commercial banking in­

four to three. The resulting bank will be the second

stitution in Bristol County, the $66.5 million First

largest in the area, with 35.5 percent of the deposits

Bristol County National Bank. That bank operates in

held by banks operating in this section o f the county.

both the North Attleboro and the Taunton service

The largest bank in the area, the product of a recent

areas. Further, recent joint studies made by the con­

merger, controls 48.4 percent of the deposits held in

solidating banks indicate that when sophisticated bank­

this area. Thus, if this consolidation is consummated,

ing services are desired, the local customers go to large

the two largest banks located in northern Bristol Coun­

banks in either Providence, R .I., or Boston, Mass.

ty would control almost 84 percent o f deposits held

Substantial amounts of local funds are kept at larger

in this area, which has a population o f well over 150,-

banks in those cities. Additional competition is pre­

000. Moreover, Baystate Corp., the parent o f the re­

sented by the various thrift institutions which virtually

sulting bank, would solidify its position as the largest

dominate the banking scene in Massachusetts, hold­

commercial banking organization operating in Bristol

ing more than half of the total bank assets in the State.

County; its share of county deposits would increase

Currently there is a movement in the State legislature

from 17.1 to 24 percent. The share of deposits held

to allow savings banks to hold demand deposits; it is

by the four largest banking organizations with offices

obvious that the competitive picture is incomplete

in Bristol County would increase from 56.6 to 68.5

without including other financial institutions.

percent.

100



Because of the elimination of existing and potentially increasing competition between the merging
banks and the increased concentration of commercial
*

banking alternatives which would accompany the proposed consolidation, we conclude that it would have
an adverse effect on competition.
*

*

T he C itizens & Southern N ational Bank , Savannah , G a ., and T he C itizens & Southern Bank of C hatham
C ounty , Savannah , G a ., and T he C itizens & Southern Bank of R ichmond C ounty , A ugusta , G a .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The Citizens & Southern Bank of Richmond County, Augusta, Ga., with..............
and The Citizens & Southern Bank of Chatham County, Savannah, Ga., with. . .
were purchased Dec. 8, 1971, by The Citizens & Southern National Bank, Savan­
nah, Ga. (13068), which had....................................................................................................
After the purchase was effected the receiving bank had.................................................

comptroller ’ s decision

On August 6, 1971, The Citizens & Southern Na­
tional Bank, Savannah, Ga., applied to the Comp­
troller of the Currency for permission to purchase the
assets and assume the liabilities of The Citizens &
Southern Bank of Richmond County, Augusta, Ga.,
and The Citizens & Southern Bank of Chatham
County, Savannah, Ga.
The Citizens & Southern National Bank, with IPC
deposits of $975 million, was originally organized in
1887. While its home office is in Savannah, its prin­
cipal executive offices are in Atlanta. It operates one
or more branches in Athens, Atlanta, Augusta, Macon,
and Valdosta, Ga., established prior to 1919 when
no legal restrictions existed on branching in Georgia.
It is also affiliated with a number of other banks
through its relationship with The Citizens & Southern
Holding Co.
The Citizens & Southern Bank of Chatham County,
with IPC deposits of $3 million, was organized in 1969
under the auspices and control of the purchasing bank.
It operates a single office located in the Oglethorpe
Mall Shopping Center. Five percent of the stock of the
bank is held by The Citizens & Southern Holding Co.,
while the remainder is held by close friends and affili­
ates of the Citizens & Southern system.
The Citizens & Southern Bank of Richmond County,
Augusta, with IPC deposits of $5 million, was orga­
nized in 1904. It was originally the Bank of Sharon,
located in Taliaferro County, before moving to Au­
gusta and changing its name to The Citizens State
Bank o f Augusta. That followed the purchase of the
bank by the former president of The Citizens & South­
ern National Bank, who then distributed the stock of




$6, 480, 000
4, 152, 000

2
1

.
.

1, 608, 787, 807
1, 687, 591, 741

71

.
74

the bank to The Citizens & Southern Holding Co. and
to numerous officers, directors, and friends o f The
Citizens & Southern National Bank. Since its incep­
tion, The Citizens & Southern National Bank has
completely dominated its activities. The bank has one
branch office opened in August 1970.
Savannah, home o f the purchasing bank and the
county seat of Chatham County, is located on the
Savannah River, 24 miles from the Atlantic Ocean,
approximately 110 miles south of Charleston, S.C.,
150 miles north of Jacksonville, Fla., and 270 miles
southeast of Atlanta, Ga. The city of Savannah has
an estimated population of 124,975 persons, and
Chatham County has approximately 187,920 persons.
The economy of the area is based on industry, with
the largest single manufacturing industry being paper
and allied products. Another large industry is repre­
sented by Grumman Aircraft. The presence of the
Savannah River is, and has been, a prime factor
in Savannah’s economic development. The port of
Savannah is the southeast’s leading trade port between
Baltimore and New Orleans. Its presence has attracted
many new industries to the area in recent years.
Augusta, the county seat of Richmond County, is
located on the eastern boundary of Georgia in the
approximate geographic center o f the States o f
Georgia and South Carolina. The fifth largest city in
the State, Augusta is located at the head o f navigation
on the Savannah River, approximately 170 miles east
of Atlanta, 130 miles northwest of the port of Savan­
nah, and 70 miles south of Columbia, S.C. It is the
principal trade center for a broad band of counties in
Georgia and South Carolina which, when considered
together, are known as the Central Savannah River
101

area. Augusta has an estimated population o f 59,864
persons, and Richmond County has a population of
162,937 persons. Manufacturing is the most significant
economic activity in the area while military activity
is also important.
Competition will not be adversely affected by con­
summation of this proposal. By virtue of the recent
change in Georgia law pertaining to branching, the
Citizens & Southern group of banks no longer need to
operate as separate banks, but may combine to form
one bank with separate branches. Because of the close
relationship existing between the purchasing bank and
the two selling institutions, with the latter being oper­
ated as de facto branches, the proposed transaction
will be only a change in form and not in substance.
N o truly independent institution will be eliminated
and competition will, therefore, not be affected.
It is concluded that the merger will have no adverse
competitive effect and is in the public interest. The
application is, therefore, approved.
N ovember 4, 1971.
SUM M ARY OF REPORT B Y A TTO R N E Y GENERAL

Richmond County. C&S Richmond was formerly
the Bank of Sharon and was located in Sharon, Tali­
aferro County, Ga. In 1963, the controlling interest
in the Bank of Sharon was sold to Mills B. Lane, Jr.,
at that time president of C&S National. In 1964, the
Bank o f Sharon (then known as the Citizens State
Bank of Augusta) was moved from Taliaferro County
to Richmond County. At about the same time, Mr.
Lane sold 5 percent of the outstanding stock in the
bank to the Citizens & Southern Holding Co. (the
maximum it could own under State law) and the re­
mainder of the stock to “ numerous officers, directors,
and friends” of C&S National. In 1969, the bank’s
name was changed to “ The Citizens and Southern
Bank of Richmond County.”
C&S National operates eight offices in Richmond

County, at distances from the offices o f C&S Rich­
mond ranging from about 1 mile to about 9 miles.
Although there are several intervening banks, the
proposed merger would seem to eliminate existing
competition.
Richmond County is a highly concentrated banking
market. The three largest banks in the county hold
about 97 percent of total county deposits. C&S Na­
tional holds the second largest share, about 29 per­
cent. C&S Richmond is the smallest bank in the
county, holding about 2 percent o f total county de­
posits. The proposed acquisition would increase al­
ready serious concentration and clearly eliminate exist­
ing and potential future competition. The acquisition
of C&S Richmond and C&S National would have an
adverse effect on competition in Richmond County.
Chatham County. C&S Chatham was organized in
1969. The application states that C&S National par­
ticipated in its organization, and Citizens & Southern
Holding Co. has held 5 percent of its outstanding com ­
mon stock since its organization.
C&S National operates nine offices in Chatham
County, at distances from C&S Chatham ranging from
about 1.5 miles to about 6 miles. Although there are
several intervening bank offices, the proposed merger
would seem to eliminate existing competition.
Chatham County is also a highly concentrated bank­
ing market. The three largest banks in the county hold
about 82 percent o f total county deposits. C&S National
holds the largest share, about 43 percent. C&S Chatham
is the smallest of eight banks in Chatham County,
holding only 0.8 percent of total county deposits. The
proposed acquisition, o f a competing bank by the lead­
ing bank in a highly concentrated market, would in­
crease already serious concentration and eliminate
existing and potential future competition. Thus* al­
though C&S Chatham is a small bank in both absolute
terms and market share, the proposed acquisition of
C&S Chatham by C&S National would have an adverse
effect on competion in Chatham County.
*

T he W ayne C ounty N ational Bank of W ooster, W ooster, O hio , and T he F armers Bank , Shreve , O hio

Banking offices
Name of bank and type of transaction

The Farmers Bank, Shreve, Ohio, with.................................................................................
was purchased Dec. 27, 1971, by The Wayne County National Bank of Wooster,
Wooster, Ohio (828), which had..............................................................................................
After the purchase was effected, the receiving bank had.................................................

102



Total assets

To be
operated

In
operation

$ 3 ,440 ,00 0
45,272 ,42 3
4 9 ,8 8 7 ,4 9 4

3
4

c o m p t r o l l e r ’s

d e c is io n

O n August 18, 1971, The Wayne County National
Bank o f Wooster, Wooster, Ohio, applied to the Office
of the Comptroller of the Currency for permission to
purchase the assets and assume the liabilities of The
Farmers Bank, Shreve, Ohio.
The Wayne County National Bank o f Wooster, the
purchasing bank, with IPC deposits of $35.3 million,
was organized in 1845, and presently operates two
branches in Wooster. The condition, management, and
earnings of this bank are all considered to be excellent.
Wooster, home of the purchasing bank, has a popu­
lation of 18,700, and is the county seat of Wayne

Competition will not be adversely affected. The
transaction will slightly improve the purchasing bank’ s
ability to compete with larger holding company sub­
sidiaries in the service area. There will remain adequate
alternatives for the banking public, notwithstanding
the elimination o f one unit bank which appears to be
providing little more than minimal service.
Applying the statutory criteria, it is concluded the
transaction is in the public interest. Therefore, the ap­
plication is, hereby, approved.
O

c to b er

22, 1971.

SU M M A R Y OF REPORT B Y A T TO R N E Y G EN ER A L

County. Situated in the northeast quadrant of the

The offices of the merging banks are located just 8

State, approximately 50 miles southwest of Cleveland,

miles apart. There are no banking offices located be­

Wooster has an economy predicated upon abundant

tween Wooster and Shreve, although a bank in Fred­

and diversified light industry with further support

ericksburg is located about 8 miles east of Shreve and a

derived from some 1,700 students and faculty members

similar distance south of Wooster. There are two other

of the College of Wooster.

commercial banks in Wooster. Farmers Bank and

In addition to the purchasing bank, Wooster is

Wayne National each derive loans and deposits from

directly served by two other banking institutions: The

the town in which the other is located. The proposed

Citizens National Bank of Wooster, with $20.8 million

merger will eliminate some existing competition be­

in deposits; and T h e Commercial Bank & Trust Co.

tween Farmers Bank and Wayne National.

of Wooster, with $21.1 million in deposits. Wayne

As o f June 30,1970, Wayne National was the largest

County is additionally served by eight other smaller

of the five banks in the southwestern part of Wayne

commercial banks, including the selling bank. Three

County, with about 50 percent of total deposits, and

smaller commercial banks in Holmes County and one

47 percent of IPC demand deposits held by these five

in Ashland County also offer competition in the

banks. As o f the same date, Farmers Bank accounted

service area.

for about 3.5 percent of the area’s total deposits, and 2.5

The Farmers Bank, with IPC deposits o f $2.7 mil­

percent o f IPC demand deposits in the area.

lion, was organized in 1889, and operates no branches.

Wayne County is currently served by 12 banks with

It has a management succession problem in that its
chief executive, who is its only male employee, is ap­

22 banking offices. Wayne National is the largest, with

proaching retirement age, and the bank is unable to

deposits, as of June 30, 1970. Farmers Bank is the ninth

attract adequate qualified personnel due to its loca­

largest bank in the county, with 0.2 percent of total

tion and salary scale.

deposits, and 1.4 percent of IPC demand deposits.

27.5 percent o f both total deposits and IPC demand

Shreve, Ohio, home of the selling institution, is lo­

Wayne National received approval, in 1969, to es­

cated 8 miles southwest of Wooster. The village’s popu­

tablish a branch office to the southwest of Wooster

lation is about 1,600, and its livelihood is based upon
local farming. There is no direct outlet o f any com­

which would have served the Shreve area. The branch
was never opened. Wayne National remains a signifi­

peting bank in Shreve. Competition stems from the 11

cant potential entrant into the Shreve area. Thus,

other banks in Wayne County.

approval of this acquisition would eliminate poten­

Consummation o f this proposal will resolve the man­

tially increasing competition between the participating

agement succession problem at the selling bank and
make available to the Shreve area a considerably in­

banks.
In addition, this acquisition by Wayne National will

creased lending limit, the functions o f a corporate

eliminate Farmers Bank as an entry vehicle for other

fiduciary, and a greater number of more sophisticated

potential entrants which are not already in the Wayne

lending services than can be provided by the existing

County market. First Bank Group, a large Ohio multi­

institution.

bank holding company,




recently

entered

Wayne
103

very small local bank by the leading local competitor.
W e conclude that it will have an adverse effect on
competition in the immediate area served by the
merging banks.

County by the acquisition of one of the smaller Wooster
banks, and other multibank holding companies may
be seeking entry vehicles into this market.
The proposed merger involves the acquisition of a
*

44-

*

D ominion N ational Bank, Baileys Cross R oads,, V

a

.,

and

D ominion Bank, A lexandria,

V

a

.

Banking offices
Total assets

Name of bank and type of transaction

Dominion Bank, Alexandria, V a., with...............................................................................
and Dominion National Bank, Baileys Gross Roads, Va. (14904), which had.
merged Dec. 31, 1971, under charter and title of the latter bank (14904). The
merged bank at date of merger had.....................................................................................

c o m p tr o ll e r ’s

d e c is io n

On September 20, 1971, Dominion Bank, Alex­
andria, Va., and Dominion National Bank, Baileys
Crossroads, Va., applied to the Office of the Comp­
troller of the Currency for permission to merge under
the charter and with the title of the latter.
Dominion National Bank, the charter bank, with
IPC deposits of $31.1 million, was organized in 1960 as
the Security National Bank. The bank currently oper­
ates a main office and five branches in Fairfax County,
one branch in Falls Church, and one branch in
Alexandria. It has also obtained permission to estab­
lish an additional de novo office in Fairfax County. In
1969, the charter bank became a subsidiary of Domin­
ion Bankshares Corp., a registered bank holding com ­
pany, headquartered in Roanoke, Va.
Dominion Bank, the merging bank, with IPC de­
posits of $9.1 million, was organized in 1964 as the
City Bank & Trust Co., and was subsequently acquired
by Dominion Bankshares Corp. in 1968. The merging
bank operates its main office and two branches in the
city o f Alexandria.
Dominion Bankshares Corp., the parent company of
the two banks involved in this application, is the fifth
largest banking organization in Virginia. That regis­
tered bank holding company, with its main office in
Roanoke, controls total deposits of approximately $600
million, and has subsidiaries with 61 banking offices in
Virginia, none of which is located within 95 miles of

$11,289, 626
45, 524, 111
5 5 ,447 ,43 4

To be
operated

In
operation
3

8

11

an insufficient capital structure and inefficient man­
agement. U pon acquisition, the parent holding com ­
pany introduced new funds and aggressive, coordinated
banking policies under the guidance of new manage­
ment teams which has acted to establish sounder struc­
ture in both banks. As a direct result of that policy,
Dominion National Bank has expanded within its
trade area by successfully opening new offices and at­
tracting substantial new customers. In the last 12
months, deposits have increased 28 percent, and net
earnings for fiscal 1970 have increased significantly.
Dominion Bank, however, has not freed itself o f its
operating difficulties to the same extent as the charter
bank has done. Dominion Bank has a poor record of
retained earnings and its deposit base is too small, re­
lative to the normal cost o f conducting business, to
provide adequate net operating profits.
At present, there is no competition between the
charter and merging banks. Dominion Bank primarily
serves the city of Alexandria, while Dominion National
Bank principally serves Fairfax County. Each o f the
banks in question serves a primary trade area which
is separate and distinct, and only a small amount of
loan and deposit business is derived from the primary
service area of the other bank.
Consummation of the proposed merger will have no
adverse effect on banking competition in the service
area of the resulting bank. Both the merging and char­
ter banks already have the same ownership, and the

the closest office of either the Dominion National

Dominion National Bank is presently supplying the

Bank or the Dominion Bank.

active management of the Dominion Bank. It is ex­

When Dominion Bankshares Corp. acquired both the

pected that the resulting bank will more actively pro­

charter and merging banks, each was suffering from

mote the existing offices of Dominion Bank, thereby

104




the public interest and the application is, therefore,
approved.
ovember 17,1971.

providing better service for residents and more efficient
competition with the larger Alexandria banks. Thus,
the subject merger is essentially a corporate reorganiza­

N

tion with the immediate objective of reducing overhead

SU M M A R Y OF REPORT B Y A T TO R N E Y G ENER AL

and eliminating duplicate operating costs, and with the

Both of these banks are, and have been since their
organization, subsidiaries of Dominion Bankshares
Corp., a registered bank holding company. Because of
this, the proposed merger is simply a corporate reor­
ganization and as such would have no effect on
competition.

ultimate purpose of obtaining greater future earnings
and providing better service in Alexandria. The re­
maining 23 commercial banks in the service area will
insure adequate banking alternatives to the resulting
bank. It is concluded that the proposed merger is in
*

First N ational Bank, O rrville, O hio,

and

*

#

T he F armers & M erchants Bank

C o .,

Smithville, O hio
Banking offices

Name of bank and type of transaction

Total assets

The Farmers & Merchants Bank Co., Smithville, Ohio, with....................................
and First National Bank, Orrville, Ohio (13742), which had......................................
merged Dec. 31, 1971, under charter and title of the latter bank (13742). The
merged bank at date of merger had.....................................................................................

c o m p t r o l l e r ’s

D E C IS IO N

On August 20, 1971, The Farmers & Merchants
Bank Co., Smithville, Ohio, and the First National
Bank, Orrville, Ohio, applied to the Office of the

$3, 509, 837
32, 209,427

To be
operated

In
operation
1
5

6
35, 719, 264

adjacent Stark County; and Paint Township in Holmes
County, are all served by the charter bank.
Industry in the service area shows a concentration
of manufacturing facilities which produce trucking
and transportation supplies, milk products, gray iron,

Comptroller of the Currency for permission to merge

bronze and aluminum castings, fiberglass products,

under the charter and with the title of the latter.

and valves for the oil and gas industry. The aggregate

The First National Bank, the charter bank, with

employment for those industries is approximately 4,000.

total IPC deposits of $24.6 million, was reorganized in
1933, and is the direct successor to the National Bank

In addition, all of Wayne County is known for its
fertile farmlands and farm products of all kinds. The

of Orrville, previously the Orrville Banking Co., which

growing of such crops as corn, soybeans, wheat, and

was established in 1881. The charter bank operates one

oats, as well as the raising of cattle, hogs, and sheep,

in-town branch which began de novo in 1965. Through

is of prime importance to the economic base of the

mergers with the First National Bank of Dalton, in

area.
The residential community consists, for the most

February 1968, and the Bank of Mt. Eaton, in Novem­
ber 1969, the charter bank has acquired and now

part, of individually owned and occupied houses, com­

operates three other branches, one each in Dalton,

plemented by a growing number of trailer parks. A l­

Kidron, and Mt. Eaton.

though there are houses as costly as $100,000, the

The service area of the charter bank is composed

average price for the majority of recently built houses

of the townships of Green, Baughman, Sugar Creek,

would be between $20,000 and $40,000. The trailer

East Union, Paint, Salt Creek, Wayne, Milton, Canaan,

parks are composed of the more expensive class of

Chippewa; the city of Orrville; and the villages of

trailers, costing an average of $10,000 each, and are

Dalton, Kidron, Mt. Eaton, and Smithville, all in

used as a first step toward individual home ownership

Wayne County, Ohio. In addition, the townships of

by people whose financial means do not allow them

Sugar Creek, Tuscarawas, Lawrence, and Perry, in

to buy a home immediately.




105

The Farmers & Merchants Bank Co., the merging
bank, with I PC deposits of $2.5 million, was chartered
in 1925. It does not operate any branches, nor has it
ever been involved in any merger transactions. The
managerial structure o f the bank consists of elderly
officers who seek a release from their banking responsi­
bilities. The chief teller, the man responsible for run­
ning the internal affairs o f the bank, is 69 years old
and wishes to retire immediately upon consumma­
tion of this proposed merger. The lower strata of
workers in this bank are young and too inexperienced
to assume successful control of the bank. There has
been a very large turnover of employees in the bank
due to the low wages that are paid, a fact which also
accounts for the difficulty in attracting experienced,
competent people with a good potential for advance­
ment in the management of the bank. The merging
bank, with a lending limit of $25,000, has difficulty
in meeting the credit needs of the customers in its
immediate service area, causing many of its potential
credit customers to be lost to other, larger financial
institutions in the area, such as the three commercial
banks in Wooster.

10 other unit banks in Wayne County, and by two
large banks headquartered in Massillon which have

The economy of the service area of the merging
bank is based on agriculture, with a trend toward
increasingly larger farms, producing the same agri­
cultural products as those in the service area of the
charter bank. The population in 1970 was 1,278, with
indications of only modest growth prospects. There
are 10 commercial and industrial firms in Smithville;
the largest is the Singer Products Corp., a manu­
facturer o f component parts for agricultural equipment
and trailers. Adding to the economic prospects of
Smithville are the Wayne County Joint Vocational
School, with an enrollment o f 2,100 and a faculty of

Applying the statutory criteria to this application, it

125, which was completed 2 years ago; and, a branch
of the University of Akron, now under construction, the

service areas extending into eastern Wayne County.
Those competitors include the $43.6 million Wayne
County National Bank, and the $37 million First Na­
tional Bank of Massillon, both o f which are larger than
the resulting bank.
This merger will solve two specific problems that
now bother the merging bank. First, it will increase the
lending limit to allow the resulting bank to accom­
modate the increasingly larger lines of credit demanded
by customers in the Smithville area. Secondly, this
transaction will remedy the management crisis of the
merging bank.
Approval of the proposed merger will bring many
benefits to the residents of the service area of the result­
ing bank. Among those benefits would be an increase
in the savings interest rate, the introduction of a credit
card, extended banking hours, automated services, and
competitive loan interest rates. Those improved serv­
ices will greatly enhance banking services in Smithville,
thereby adding to the public convenience in the area.
is concluded that the proposed merger is in the public
interest. The application is, therefore, approved.
N

ovem ber

9, 1971.

SUM M ARY OF REPORT B Y A T T O R N E Y G EN ER AL

This proposed merger would eliminate direct com ­
petition between Farmers Bank and First National in
the Smithville-Orrville area. Farmers Bank is the only
bank in Smithville. In addition to First National, there
is one other commercial bank in Orrville, the Orrville
Savings Bank (total deposits $12.0 m illion). The
closest other competing banks are in Wooster.

first phase o f which is to be completed in 1972. That

Thus, the proposed merger would reduce the num­

school, to be known as the Wayne State Community

ber of commercial banking alternatives in the Smith­

and Technical College, should attract both people and

ville-Orrville area from three to two.

the necessary service businesses to cater to the needs of
the new school community.

Wayne County is currently served by 12 banks with
22 banking offices. First National holds the second

At present there is no meaningful competition be­

largest share of deposits held by Wayne County banks,

tween the two banks in this proposed merger. The

with 18.8 percent of total deposits, and 20.6 percent

merging bank has almost no accounts in Orrville due to

of IPC demand deposits, as of June 30, 1970. The four

the bank’s small size and limited services. Conversely,

largest banks in the county have 74.4 percent of total

those banking with the charter bank and residing in,

deposits, and 79.9 percent of IPC demand deposits.

or near, Smithville do so because the smaller bank

Farmers Bank is the 11th largest, with 1.9 percent of

cannot meet their financial needs.

total deposits, and 1.7 percent o f IPC demand de­

U pon consummation of the merger, significant com ­

posits. After the proposed merger, First National would

petition will still be afforded the resulting bank by the

account for 20.7 percent of total deposits, and 22.3 per-

106



cent of IPG demand deposits, and the four largest
would account for 76.3 percent of total deposits, and
81.6 percent of IPC demand deposits.
*

W e conclude that the proposed merger will have an
adverse effect on competition in the immediate area
served by the merging banks.
*

*

First U nion N ational Bank of N orth Carolina, Charlotte, N .C., and Bank of W indsor, W indsor,
and Bank of F armville, F armville, N.C.

N .C.

Banking offices
Name of bank and type of transaction

Total assets

Bank of Farmville, Farmville, N .C ., with.............................................................................
Bank of Windsor, Windsor, N .C ., with..................................................................................
and First Union National Bank of North Carolina, Charlotte, N .C . (15650), which
had..................................................................................................................... ...............................
merged Dec. 31, 1971, under charter and title of the latter bank (15650). The
merged bank at date of merger had.......................................................................................

c o m p tr o ller 's

d e c is io n

On September 14, 1971, the Bank of Farmville,
Farmville, N.C., and Bank of Windsor, Windsor, N.C.,
applied to the Comptroller of the Currency for per­
mission to merge into the First Union National Bank
of North Carolina, Charlotte, N.C., under the char­
ter and with the title of the latter.
First Union National Bank of North Carolina, Char­
lotte, N.C., was chartered in 1908, and through a
series of mergers and through de novo branching has
become the third largest bank in North Carolina. With
$1 billion in total deposits, the bank operates 153 of­
fices in 71 communities throughout North Carolina.
For large corporate customers, the First Union Na­
tional Bank competes with every major bank in the
southeast, and is in that sense a regional bank. In
North Carolina, the bank’s principal competitors are:
Wachovia Bank, N.A., with total resources of approxi­
mately $1.8 billion, and 154 offices in approximately
55 communities throughout the State; the North Caro­
lina National Bank, with total assets of $1.5 billion, and
105 offices in approximately 29 communities; First
Citizens Bank & Trust Co., with total resources of
$772 million, and 158 offices in 70 communities;
Northwestern Bank, with total resources of $583 mil­
lion; and Branch Banking & Trust Co., with resources
of $280 million. The charter bank is the chief subsidi­
ary of First Union National Bancorp, Inc., a registered
one-bank holding company.
The Bank of Farmville, Farmville, N.C., was char­
tered in 1904, and now holds total deposits o f $6.4
million. The bank’s service area, which is the town of

To be
operated

In
operation

$10,631,998
14, 674, 169

1
2

1,291,712, 722

158

1 ,3 11,3 93 ,4 84

161

Farmville and a radius of 7 miles in surrounding Green
and Pitt counties, has a population of 8,600. Bank of
Farmville’s rate o f growth during the period between
1965 and 1970 was considerably less than that of com ­
mercial banks in North Carolina generally; the bank’s
loan portfolio growth was 75 percent, and its deposit
growth was 56 percent, of the growth rates averaged
for all commercial banks in the State.
The economy of the service area of the Bank of
Farmville is supported mainly by agriculture, with
tobacco the main cash crop. Over half the work force
in Green County is agriculturally employed. In Pitt
County, 70 percent of the work force is employed in
agriculture or trade. During the period between 1960
and 1970, Green County recorded a 10 percent de­
crease in population, whereas Pitt County’s popula­
tion grew at a slow rate, greatly below that of the State
as a whole.
The principal competitor of the Bank of Farmville
is the Bank of North Carolina, N.A., with an office in
Farmville. Bank of North Carolina, N.A., has total
assets of approximately $134 million. Other banks
exerting some competitive influence in the Farmville
area include offices of the $1.8 billion Wachovia Bank
& Trust Co., N.A., located at Walstonburg, approxi­
mately 7 miles west, and at Snow Hill, approximately
12 miles southwest. The $22 million Edgecombe Bank
& Trust Co. has an office located at Fountain, approxi­
mately 6 miles north, and the Bank of North Carolina,
N.A., Bank of Winterville, North Carolina National
Bank, Planters National Bank & Trust Co., as well as
Wachovia Bank & Trust Co., N.A., have offices in
Greenville, approximately 15 miles east. The closest
107

4/63-499' O — 72'--------- &




First Union office of the merging bank is located at
Wilson, approximately 25 miles northwest.
The principal competitor of the Bank o f Windsor is
an office o f the $23 million Southern Bank & Trust
Go. located at Windsor. Otherwise, there is an office
of the Planters National Bank & Trust Go. at Colerain,
approximately 24 miles northeast; an office of
Wachovia Bank & Trust Co., N.A., at Aulander, ap­
proximately 25 miles northwest; and, an office of the
$9 million Tarheel Bank & Trust Co., located at
Lewiston, approximately 18 miles northwest. The
closest First Union National Bank offices to this merg­
ing bank are in Elizabeth City, approximately 52 miles
northeast, and in Rocky Mount, approximately 55
miles west.
The Bank of Windsor, Windsor, N.C., the other
merging bank, was chartered in 1901, and presently
holds deposits o f $11.4 million. Th e bank, like The
Bank of Farmville, has been generally conservative in
its operations, and its loans and deposits are primarily
agriculturally oriented. Although the rate of growth
in loans shown by the Bank of Windsor compares
favorably with other commercial banks in North Caro­
lina, the bank’s nearest competitor quadrupled the
Bank o f Windsor’s deposit growth during the 1965-70
period.
The economy of Bertie County, where the Bank of
Windsor is located, is supported primarily by agri­
culture, with approximately 70 percent of its labor
force employed in agriculture and trade. From 1960
to 1970, the population of the county decreased
slightly. Bertie County has one of the lowest per capita
incomes in North Carolina.
Consummation of the proposed merger will not
eliminate any present competition between the First
Union National Bank and the merging banks. Due
to the decline in populations and resulting stagnant
economic conditions in the areas served by the merg­
ing banks, there is little economic incentive for First
Union to enter the market areas of those banks de
novo, and it is doubtful whether those areas would sup­
port an additional bank. First Union’s entrance will
provide specialized banking services such as computer
services, mortgage financing and servicing, specialized
loan services for small businesses, equipment lease
loans, a charge plan system, and trust services, none
of which are presently offered by the merging banks.
Applying the statutory criteria to the proposed

mergers, we conclude that consummation o f the pro­
posal will serve the public interest. The application is,
therefore, approved.
N




24, 1971.

SUM M ARY OF REPORT B Y A T TO R N E Y G ENERAL

The closest offices o f First Union to Bank of Farmville are about 20 miles distant, with several offices of
another large bank in the intervening area. Th e near­
est offices of First Union to those of Bank of Windsor
are over 50 miles distant. Loan and deposit overlap
statistics are minimal. The areas served by the two
smaller merging banks are in noncontiguous counties.
Therefore, the proposed mergers would not appear to
eliminate any significant amount of direct competition
among the merging banks.
North Carolina permits statewide branching, and
First Union could be permitted to establish de novo
branches in the areas served by Bank o f Farmville and
Bank of Windsor. First Union is the third largest bank
in North Carolina and has the capability to establish
such offices. It is the largest bank eligible to enter
de novo into Pitt County, and it is the second largest
bank eligible to enter into Bertie County.
Five banks presently operate seven offices in Bertie
County, including the State’s largest, and seventh and
ninth largest banks. Bank of Windsor is the fourth
largest of these five banks, but holds 58.7 percent of
county IPC demand deposits. Although the merger of
First Union and Bank of Windsor would eliminate
the only remaining independent bank headquartered
in Bertie County, and permit First Union to obtain
immediately the largest share of county deposits, it is
questionable whether the declining state of the county’s
economy would attract new bank entrants.
In Pitt County, nine banks operate 21 offices; these
banks include six of the State’s 10 largest (and the
two largest). Three banks hold about 75 percent o f
county IPC demand deposits, and Bank of Farmville
holds 9.6 percent, the fourth largest share. The merg­
ing bank is the larger of the two independent banks
headquartered in Pitt County and the eighth largest of
the banks operating in the county. T h e merger of
Bank of Farmville into First Union would eliminate
the largest eligible potential entrant into Pitt County,
eliminate the larger of only two remaining independ­
ents in the county, and permit First Union to assume
immediately a substantial position in the area.

*

108

ovem ber

National Bank

of the

C ommonwealth, Indiana, Pa .,

and

First National Bank

at

Patton, Patton, Pa .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
First National Bank at Patton, Patton, Pa. (14263), with...............................................
was purchased Dec. 31, 1971, by National Bank of the Commonwealth, Indiana,
Pa. (14098), which had...............................................................................................................
After the purchase was effected, the receiving bank had.................................................

On October 27, 1971, the National Bank of the
Commonwealth, Indiana, Pa., applied to this Office
for permission to purchase the assets and assume the
liabilities of the First National Bank at Patton, Patton,
Pa.
The purchasing bank has total deposits of $48.9
million, and operates eight branches to serve Indiana
County and portions of Westmoreland, Armstrong,
Cambria, and Jefferson counties. The selling bank
has total deposits of $4 million, and operates no
branches.
The selling bank is located in a declining economic
area once supported by the soft coal industry. At
present, only one industry provides employment; many

54, 704, 987
61, 905, 777

9
10

SU M M A R Y OF REPORT B Y A T TO R N E Y G EN ER A L

Competition between Commonwealth and Patton
Bank is not significant, Patton Bank’s service area is
limited in geographic scope, and does not overlap with
those areas of Indiana and Cambria counties served by
Commonwealth. Neither bank draws any appreciable
deposit or loan business from the service area of the
other. The proposed transaction would not eliminate
any substantial existing competition.
Under Pennsylvania law, which permits branching
by commercial banks in the county in which their
home offices are located, and counties contiguous
thereto, either of the parties to the proposed trans­
action could be permitted to branch into the service
area of the other. In view of Patton Bank’s size, how­
ever, it is not a source of significant potential competi­
tion in areas served by Commonwealth. While Com ­
monwealth appears to be capable of de novo branching
into attractive new markets, the economy and declining
population of the area served by Patton Bank indicates
that it is not a particularly attractive branching site.
Moreover, Patton Bank is among the smallest banks
serving northern Cambria County; its larger com ­
petitors include banks headquartered in Johnstown
which operate branch systems throughout the county.
We conclude that the proposed transaction is un­
likely to have any significantly adverse effect on
potential competition.

residents commute elsewhere to work. Prospects for
growth are limited.
The management of the selling bank is elderly,
faces competition from four other banks, three of
which are larger, and wishes to sell rather than to
attempt to maintain service in a rather unproductive
climate. The purchasing bank will be able to stimulate
competition by providing added services and more
liberal lending policies.
The two banks do not compete with each other; the
closest office of the purchasing bank is 22 miles from
the selling bank. The purchasing bank would con­
tinue to be subject to competition from the nine com ­
peting banks in its present service area, as well as the
four other banks in the Patton area.
Applying the statutory criteria it is the conclusion of




1

this Office that the proposal is in the public interest.
It is, therefore, approved.
D e c e m b e r 1,1971.

c o m p t r o l l e r ' s d e c is io n

*

$5, 144, 111

*

*

109

T he Framingham N ational Bank , Framingham , M ass., and N ewton N ational Bank , N ew to n ,
M ass., and W altham C itizens N ational Bank , W altham , M ass.

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Newton National Bank, Newton, Mass. (13252), with.....................................................
Waltham Citizens National Bank, Waltham, Mass. (14541), with...............................
and The Framingham National Bank, Framingham, Mass. (528), which had........
consolidated Dec. 31, 1971, under charter of the latter bank (528) and title
“ Community National Bank.” The consolidated bank at date of consolidation
had.....................................................................................................................................................

comptroller ’ s decision

On October 4, 1971, The Framingham National
Bank, Framingham, Mass., the Newton National Bank,
Newton, Mass., and the Waltham Citizens National
Bank, Waltham, Mass., applied to the Office of the
Comptroller of the Currency for permission to consoli­
date under the charter o f The Framingham National
Bank and with the title “ Community National Bank.”
The Framingham National Bank was originally
chartered as a State bank in 1833, and has been in con­
tinuous operation since that date. In 1864, it converted
to a National bank, and in December 1970, it became
a subsidiary of Shawmut Association, Inc., a registered
bank holding company which owns 97.8 percent of
the bank’s shares. The bank has seven branches and
total deposits of $37.3 million, an increase o f $18.9 mil­
lion in the last 10 years.
The Newton National Bank was organized in 1928,
and, since August 1945, has been a subsidiary of Shaw­
mut Association, Inc., which owns 97.4 percent of its
shares. The bank operates four branches, has an addi­
tional branch application pending, and currently has
deposits of $21.8 million.
The Waltham Citizens National Bank was organized
in 1946, as a subsididary of Shawmut Associates, the
predecessor of Shawmut Association, Inc., which owns
95.9 percent o f its shares. Th e bank has no branches
and currently has deposits of $11.3' million. Over the
past 10 years it has experienced little growth.
The primary service area of the resulting bank con­
sists of the cities o f Framingham, Marlborough, Ash­
land, Natick, Sudbury, Holliston, Hopkinton, Newton,
Watertown, and Waltham, all of which are located in
South Middlesex County, and, to a more limited extent,
includes the adjacent cities of Boston, in Suffolk
County; Brookline and Wellesley, in Norfolk County;
and Southborough, in Worcester County. Excluding
the cities and towns outside South Middlesex County,
110



$27, 205, 320
13, 651,672
45, 306, 681

86, 163, 674

5
1
9

15

the combined population of the service area is approx­
imately 355,000. The towns and communities which
make up this service area are residential in character
and their economies are based on diversified manufac­
turing, which employs 10,700 people in Newton, 7,800
people in Watertown, 36,150 people in Waltham, and
22,200 people in Framingham. The combined pay­
roll for those workers in manufacturing firms exceeds
$566 million. Framingham is also an important retail
trade center serving surrounding towns as well as its
own population.
Although the primary service area of the consolidat­
ing banks includes Boston, Brookline, Wellesley, and
Southborough, State laws do not permit branching
across county lines. Therefore, the basic service area
of the resulting bank is considered to be only those
cities in South Middlesex County. The major banking
competitors headquartered in this county include the
Newton-Waltham Bank & Trust Co., Waltham, with 19
offices and total deposits of $141 million; Framingham
Trust Co., Framingham, operating 14 offices with total
deposits of $80.7 million; and the Coolidge Bank &
Trust Co., Watertown, with eight offices and deposits
of $80 million. Approval o f the proposed acquisition
will leave 10 banks headquartered in South Middlesex
County to provide adequate banking alternatives to
residents and local businesses. Also, limited competi­
tion will be provided by the large Boston banks based
outside the perimeter of the primary service area.
Consummation of the proposed acquisition will have
no adverse effects in South Middlesex County. None
of the consolidating banks have branches in any town
in which another of the consolidating banks operates a
branch. Thus, it is clear that the degree o f market
overlap is negligible. The consolidation will enable the
resulting bank to compete more effectively by estab­
lishing a larger lending limit and a competitive trust
service, and will eliminate operating inefficiences and
needless duplications in their banking practices. The

no adverse competitive effects. The consolidation is,
therefore, approved.
N ovember 24, 1971.

proposed consolidation will not significantly alter the
allocation of deposits in the service area since all three
banks are already commonly owned.
One of the major reasons for the proposed consoli­
dation is the absence of management continuity in
both the Newton and Waltham banks. The president
of the Waltham bank has recently died, and the sen­
ior officers at the Newton bank are approaching retire­
ment age. It is expected that approval o f this applica­
tion will alleviate the management succession issue.
Accordingly, it is the view of this Office that the pro­
posed acquisition is in the public interest and will have
*

SU M M AR Y OF REPORT B Y A T T O R N E Y G ENER AL

All of the participating banks are owned and con­
trolled as subsidiaries of Shawmut Association, Inc., a
registered bank holding company. Because o f this, the
proposed consolidation is simply a corporate reorgani­
zation and as such would have no effect on competi­
tion.
*

*

I I . M e r g e r s con su m m a ted pursuant to c o rp o ra te reorganization, involving a single o p era tin g bank
T he N ational Bank of C ommerce in N e w O rleans, N e w O rleans, L a ., and N.B.C. N ational
Bank , N e w O rleans, L a .

Banking offices
Name of bank and type of transaction

Total assets

The National Bank of Commerce in New Orleans, New Orleans, La. (13689), with.
and N.B.C. National Bank, New Orleans, La. (13689), which had.............................
merged Jan. 1, 1971, under charter of the latter bank (13689) and title “ First
National Bank of Commerce” . The merged bank at date of merger had..................

c o m p t r o l l e r ’s

On October 8, 1970, The National Bank of Com ­
merce in New Orleans, New Orleans, La., and N.B.C.
National Bank (organizing), New Orleans, La., applied
to the Comptroller of the Currency for permission to
merge under the charter and with the title of the First
National Bank of Commerce.
The National Bank of Commerce in New Orleans,
the merging bank, is headquartered in New Orleans,
and has 14 branches, all located in New Orleans. This
bank, with total resources of $446.4 million, and IPC
deposits of $269.5 million, was originally chartered in
1933.
N.B.C. National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the First Commerce Corp. The
charter bank will not be operating as a commercial
bank prior to the merger.

0
15

521, 307, 980

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENER AL

The proposed merger is part of a plan under which
First Commerce Corp., a registered bank holding com­
pany, proposes to acquire all of the voting shares of
NBC National Bank (organizing), a nonoperating in­
stitution, and as a contemporaneous transaction, to
effect the merger of National Bank of Commerce in
New Orleans and NBC National Bank (organizing).
The effect of these transactions will be to transfer con­
trol of an existing bank to a registered bank holding
company. In and of itself, however, the proposed mer­
ger would merely combine an existing bank with a non­

Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank
will conduct the same banking business at the same




15

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.
N o v e m b e r 23,1970.

d e c is io n

*

$521,055,312
252, 668

To be
operated

In
operation

operating institution: as such, and without regard to
acquisition of the surviving bank by First Commerce
Corp., the proposed merger would have no effect on
competition.
*

*
111

T he First National Bank

Boston, Boston, M ass ., and O ld C olony T rust, N.A., Boston, M ass .,
T he M assachusetts Bank, N.A., Boston, M ass .

of

and

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Boston, Boston, Mass. (200), with....................................
Old Colony Trust, National Association, Boston, Mass. (15847), with....................
and The Massachusetts Bank, National Association, Boston, Mass. (200), which
had...................................................................................................................................................
merged Jan. 4, 1971, under charter of the latter bank (200) and title “ The First
National Bank of Boston.” The merged bank at date of merger had........................

co m ptro ller 's

To be
operated

In
operation
3

$4, 042, 109, 396
14, 765, 009

0

253, 165

0
3

4, 054, 523, 630

commercial banking activities, Old Colony Trust con­
fines its activities to the rendering of trust services.
In addition to having identical beneficial ownership,
The First National Bank of Boston and Old Colony
Trust Co. are closely associated in policies, manage­
ment, and operations. They are regarded as one in
the public mind. The proposed merger will merely
formalize an existing identity of ownership. Therefore,
the proposed merger will have no anticompetitive ef­
fect on banking competition.
Applying the statutory criteria, we find the proposal
is in the public interest. The application is, therefore,
approved.
D ecember 2, 1970.

d e c is io n

On October 23, 1970, The First National Bank of
Boston, Boston, Mass., Old Colony Trust Co. (con­
verting to Old Colony Trust, National Association),
Boston, Mass., filed an application with the C om p­
troller of the Currency for permission to merge under
the charter of The Massachusetts Bank, National As­
sociation, and with the title of The First National
Bank o f Boston.
The merger of The First National Bank of Boston,
with IPC deposits of $1.5 billion, and the Old Colony
Trust Co., the trust affiliate of First National, into The
Massachusetts Bank is part of a plan of reorganiza­
tion whereby First National and Old Colony will be­

S U M M A R Y OF R EPO R T B Y A T T O R N E Y G E N E R A L

come a wholly owned subsidiary (except for directors5
This merger is part o f a corporate reorganization
whereby The First National Bank of Boston and Old
Colony Trust Co. will be merged into a nonoperating
institution. The First National Bank of Boston and
Old Colony Trust Co. have been jointly owned and
controlled since 1929; the application’s characteriza­
tion of Old Colony Trust *Co. as the bank’s “ trust
affiliate” appears accurate. Thus, their merger into the
same new bank would not have any adverse compet­
itive effects.

qualifying shares) of The First National Boston Corp.,
a Massachusetts business corporation.
The receiving bank, The Massachusetts Bank, Na­
tional Association, is a newly organized National bank
formed solely to facilitate the proposed plan of
reorganization.
In 1929, Old Colony Trust Co. became the trust af­
filiate o f The First National Bank of Boston. While the
First National Bank engages in the entire spectrum of
*

*

*

T he N ational Bank of N e w Jersey , N e w Brunswick , N.J., and T he N ational Bank of N e w J ersey ,
N e w Brunswick , N e w Brunswick , N.J.

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The National Bank of New Jersey, New Brunswick, N.J. (587), with...........................
and The National Bank of New Jersey, New Brunswick, New Brunswick, N.T.
(587), which had........................................ .....................................
merged Jan. 4, 1971, under charter of the latter bank (587) and title “ The National
Bank of New Jersey.” The merged bank at date of merger had...................................

112



$87, 806, 147

6

128, 500

0

87, 809, 749

6

comptroller’ s decision

O n October 23, 1970, The National Bank of New
Jersey, New Brunswick, N.J., and The National Bank
of New Jersey, New Brunswick (organizing), New
Brunswick, 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 National Bank of New Jersey, the merging bank,
is headquartered in New Brunswick, and has six offices
located throughout Middlesex County. This bank has
total resources of $77.4 million, and IPC deposits of
$56 million.
The National Bank of New Jersey, New Brunswick,
the charter bank, is being organized to provide a ve­
hicle to transfer ownership of the merging bank to the
Fidelity Union 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 consum­

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.
D ecember 4, 1970.
S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

The proposed merger is part of a plan under which
Fidelity Union Bancorporation, a registered bank
holding company, proposes to acquire all of the voting
shares of The National Bank of New Jersey, New
Brunswick (organizing), a nonoperating institution,
and as a contemporaneous transaction, to effect the
merger of The National Bank of New Jersey and The
National Bank of New Jersey, New Brunswick (orga­
nizing). 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 pro­
posed merger would merely combine an existing bank
with a nonoperating institution; as such, and without
regard to acquisition of the surviving bank by Fidelity

mation of the proposed merger. The resulting bank

Union Bancorporation, the proposed merger would

will conduct the same banking business at the same

have no effect on competition.
*

T he Peoples N ational Bank of M anassas, M anassas, V a ., and M anassas Bank , N .A., M anassas, V

.

a

Banking offices
Name of bank and type of transaction

The Peoples National Bank of Manassas, Manassas, Va. (6748), with.......................
and Manassas Bank, N .A., Manassas, Va. (6748), which had....................................
merged Mar. 1, 1971, under charter of the latter bank (6748) and title “ The Peoples
National Bank of Manassas.” The merged bank at date of merger had....................

Total assets

To be
operated

In
operation
4

$20, 906, 050
125, 000

0
4

21,031,050

The “ Comptroller’s Decision” and the “ Summary of Report by Attorney General” for this case appeared in
the 1970 Annual Report under the heading “ Approved, hut consummation deferred due to related litigation.”

Belt N ational Bank of S t . J oseph, S t . J oseph, M o ., and Belt Bank of S t . J oseph, N.A.,
St . J oseph, M o .

Banking? offices
Name of bank and type of transaction

Belt National Bank of St. Joseph, St. Joseph, M o. (15176), with.................................
and Belt Bank of St. Joseph, National Association, St. Joseph, Mo. (15176), which
had....................................................................................................................................................
merged Mar. 10, 1971, under charter of the latter bank (15176) and title “ Belt Na­
tional Bank of St. Joseph.” The merged bank at date of merger had.............................




Total assets

To be
operated

In
operation

$9, 121,837

2

240, 000

0

9, 404, 806

2

113

comptroller’ s decision

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

On December 1, 1970, the Belt National Bank of
St. Joseph, St. Joseph, M o., and the Belt Bank of St.
Joseph, National Association (organizing), St. Joseph,
M o., applied to the Comptroller of the Currency for
permission to merge under the charter o f the latter and
with the title of the former.
Belt National Bank of St. Joseph, the merging bank,
is headquartered in St. Joseph, and is a unit bank. This
bank, with total resources of $8 million, and IPC
deposits of $7.1 million, was chartered originally in
1919.
Belt Bank o f St. Joseph, National Association, the
charter bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to Ameribanc,
Inc. The charter bank will not be operating as a com ­
mercial 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 consum­
mation o f the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
*

February 3, 1971.
SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

The proposed merger is part of a plan under which
Ameribanc, Inc., a registered bank holding company,
proposes to acquire all of the voting shares of Belt Bank
of St. Joseph, N.A. (organizing), a nonoperating insti­
tution, and as a contemporaneous transaction, to effect
the merger of Belt National Bank of St. Joseph and
Belt Bank of St. Joseph, N.A. (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 Ameribanc, Inc., the proposed
merger would have no effect on competition.
*

*

T he A merican N ational Bank of S t . J oseph, S t . J oseph, M o ., and A merican Bank of S t . J oseph,
N .A., St . J oseph, M o .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The American National Bank of St. Joseph, St. Joseph, M o. (6272), with...............
and American Bank of St. Joseph, National Association, St. Joseph, M o. (6272),
which had........................................................................................................................................
merged Mar. 10, 1971, under charter of the latter bank (6272) and title “ The
American National Bank of St. Joseph.” The merged bank at date of merger had. .

comptroller’ s decision

O n December 1,1970, The American National Bank
of St. Joseph, St. Joseph, M o., and the American Bank
of St. Joseph, National Association (organizing), St.
Joseph, M o., applied to the Comptroller of the Cur­
rency for permission to merge under the charter of
the latter and with the title of the former.
The American National Bank of St. Joseph, the
merging bank, is headquartered in St. Joseph. It
maintains no branch offices. This bank, with total
resources of $96.3 million, and IPC deposits of $70.2
million, was chartered originally in 1889.
114



$101, 092, 790

2

240,000

0

101, 207, 599

2

American Bank of St. Joseph, National Association,
the charter bank, is being organized to provide a ve­
hicle to transfer ownership of the merging bank to
Ameribanc, Inc. The charter bank will not be operat­
ing 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.
F e b r u a r y 3, 1971.

action, to effect the merger of American National Bank
of St. Joseph and American Bank of St. Joseph, N.A.
(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

SU M M AR Y OF REPORT B Y A T TO R N E Y G ENER AL

proposed merger would merely combine an existing

The proposed merger is part of a plan under which
Ameribanc, Inc., a registered bank holding company,
proposes to acquire all of the voting shares of Ameri­
can Bank of St. Joseph N.A. (organizing), a nonop­
erating institution, and as a contemporaneous trans­

bank with a nonoperating institution; as such, and
without regard to acquisition of the surviving bank by
Ameribanc, Inc., the proposed merger woud have
no effect on competition.
*

M ercantile T rust C o ., N ational A ssociation, S t . L ouis, M o ., and
L ocust N ational . Bank , S t . L ouis, M o .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Mercantile Trust Co., National Association, St. Louis, Mo. (15452), with...............
and Locust National Bank, St. Louis, M o. (15452), which had...................................
merged Mar. 11, 1971, under charter of the latter bank (15452) and title “ Mer­
cantile Trust Company National Association.” The merged bank at date of merger
had....................................................................................................................................................

c o m p t r o l l e r ’s

On December 23, 1970, the Mercantile Trust Co.,
National Association, St. Louis, M o., and the Locust
National Bank (organizing), St. Louis, M o., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.

2

1, 267, 685, 208

SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

Mercantile Trust Co., National Association, the
merging bank, is headquartered in St. Louis, and
has one facility located in St. Louis. This bank, with
total resources of $1.2 billion, and IPC deposits of
$688.4 million, was chartered originally in 1855.

The proposed merger is part of a plan under which
Mercantile Bancorporation, Inc., a registered bank
holding company, proposes to acquire all of the voting
shares o f Locust National Bank (organizing), a nonop­
erating institution, and as a contemporaneous trans­
action, to effect the merger of Mercantile Trust Co.,
N.A. and Locust National Bank (organizing). The
effect of these transactions will be to transfer control
of an existing bank to a registered bank holding com ­
pany. 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 Mercantile
Bancorporation, Inc., the proposed merger would have
no effect on competition.

Locust National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the Mercantile Bancorporation,
Inc. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank
will conduct the same banking business at the same




2
0

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.
F e b r u a r y 26, 1971.

d e c is io n

*

$1, 267, 676, 008
998,000

*

*

115

First National Bank & T rust C o.

of

Ithaca, I thaca, N .Y .,

and

Bank

of

I thaca, N .A ., Ithaca, N .Y .

Banking offices
Name of bank and type of transaction

Total assets

First National Bank & Trust Co. of Ithaca, Ithaca, N .Y . (222), with.......................
and Bank of Ithaca, National Association, Ithaca, N .Y . (222), which had...............
merged Mar. 31, 1971, under charter of the latter bank (222) and title “ First
National Bank & Trust Co. of Ithaca.” The merged bank at date of merger h a d ... .

comptroller ’ s decision

On October 7, 1970, First National Bank & Trust
Co. of Ithaca, Ithaca, N Y ., and Bank of Ithaca, N.A.
(organizing), Ithaca, N.Y., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
First National'Bank & Trust Co. of Ithaca, the
merging bank, is headquartered in Ithaca, N.Y., and
has three offices located in Ithaca and Tompkins
County. This bank, with total resources of $55 million
and I PC deposits of $39 million, was chartered origi­
nally in 1864.
Bank of Ithaca, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to Security New York State Corp.,
a 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 consum­
mation of the proposed merger. The resulting bank
will conduct the same banking business at the same

In
operation

$54, 936, 235
238, 294

To be
operated
3

0

55 ,174,529

3

locations and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
February 26, 1971.
SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

The proposed merger is part of a plan under which
Security New York State Corp., a registered bank
holding company, proposes to acquire all of the voting
shares of Bank o f Ithaca, N.A. ( organizing), a non­
operating institution, and as a contemporaneous trans­
action, to effect the merger of First National Bank &
Trust Co. of Ithaca and Bank of Ithaca, N.A.
(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
Security New York State Corp., the proposed merger
would have no effect on competition.
*

W illiamsburg N ational Bank , W illiamsburg, V a ., and Bank of W illiamsburg, N .A ., W illiamsburg , V a .

Bankirg offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Williamsburg National Bank, Williamsburg, Va. (15562), with....................................
and Bank of Williamsburg, N .A ., Williamsburg, Va. (15562), which had. ; ............
merged Mar. 31, 1971, under charter of the latter bank (15562) and title “ Williams­
burg National Bank.” The merged bank at date of merger had...................................

116



$9, 204, 555
125, 000
9, 209, 682

1
0
1

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.
F e b r u a r y 22, 1971.

comptroller’ s decision

On January 20, 1971, the Williamsburg National
Bank, Williamsburg, Va., and the Bank of Williams­
burg, N.A. (organizing), Williamsburg, Va., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the

SU M M AR Y OF REPORT B Y A T T O R N E Y G ENER AL

title of the former.

The proposed merger is part of a plan under which
Southern Bankshares, Inc., a proposed registered bank
holding company, proposes to acquire all of the voting
shares of Bank of Williamsburg, N.A. (organizing), a
nonoperating institution, and as a contemporaneous
transaction, to effect the merger of Williamsburg Na­
tional Bank and Bank of Williamsburg, N.A. (orga­
nizing) . 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 Southern Bankshares, Inc., the proposed merger
would have no effect on competition.

Williamsburg National Bank, the merging bank, is
headquartered in Williamsburg, and has no branches.
This bank, with total resources of $8 million, and IPC
deposits of $5.7 million, was chartered in 1965.
Bank of Williamsburg, N.A., the charter bank, is
being organized to provide a vehicle to transfer owner­
ship of the merging bank to Southern Bankshares Inc.
The charter bank will not be operating as a commer­
cial 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 consum­
mation of the proposed merger. The resulting bank
will conduct the same banking business at the same
*

*

*

First C ity N ational Bank of H ouston, H ouston, T e x ., and First C ity Bank N ational A ssociation,
H ouston, T e x .

Banking offices
Name of bank and type of transaction

Total assets

First City National Bank of Houston, Houston, Tex. (13943), with............................
and First City Bank National Association, Houston, Tex. (13943), which had. . . .
merged Apr. 1, 1971, under charter of the latter bank (13943) and title “ First
City National Bank of Houston.” The merged bank at date of merger had.............

$1, 278, 604, 634
250, 000

c o m p t r o l l e r ’ s d e c is io n

On January 11, 1971, the First City National Bank
of Houston, Houston, Tex., and the First City Bank
National Association (organizing) Houston, Tex., ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter of the latter and with
the title of the former.
First City National Bank of Houston the merging
bank, is headquartered in Houston, Tex., and has an
office located in Houston, Tex. This bank, with total
resources of $1.2 billion and IPC deposits of $728 mil­
lion was chartered originally in 1934.




1, 278, 606, 134

To be
operated

In
operation
1
0

1

First City Bank National Association, the charter
bank, is being organized to provide a vehicle to trans­
fer ownership of the merging bank to the C. B. Invest­
ment Corp. 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 consum­
mation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
tions and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that

117

the proposed merger is in the public interest and the
application is, therefore, approved.
M arch 2, 1971.

transaction, to effect the merger of First City National
Bank of Houston and First City Bank, National Asso­
ciation (organizing). The effect of these transactions

SU M M ARY OF REPORT B Y A T TO R N E Y G ENERAL

registered bank holding company. In and of itself,
however, the proposed merger would merely combine

will be to transfer control of an existing bank to a
The proposed merger is part of a plan under which
G. B. Investment Corp., a registered bank holding
company, proposes to acquire all o f the voting shares
of First City Bank, National Association (organizing),
a nonoperating institution, and as a contemporaneous
*

an existing bank with a nonoperating institution; as
such, and without regard to acquisition of the sur­
viving bank by G. B. Investment Corp., the proposed
merger would have no effect on competition.
*

*

T he C itizens N ational Bank of W ooster, W ooster, O hio , and T he F.B.G. N ational Bank of W ooster,
W ooster, O hio

Banking offices
Total assets

Name oj bank and type of transaction

To be
operated

In

operation
The Citizens National Bank of Wooster, Wooster, Ohio (7670), with.........................
and The F.B.G. National Bank of Wooster, Wooster, Ohio (7670), which had........
merged Apr. 30, 1971, under charter of the latter bank (7670) and title “ The
Citizens National Bank of Wooster.” The merged bank at date of merger h a d .. . .

c o m p t r o l l e r ’s

On February 2, 1971, The Citizens National Bank
of Wooster, Wooster, Ohio, and The F.B.G. National
Bank o f Wooster (organizing), Wooster, Ohio, ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter of the latter and with
the title of the former.
The Citizens National Bank of Wooster, the merg­
ing bank, is headquartered in Wooster, and has two
branch offices located in Wooster. This bank, with
total resources o f $23.5 million, and IPC deposits of
$18.4 million, was chartered originally in 1905.

3

The proposed merger is part of a plan under which
First Banc Group of Ohio, Inc., a registered bank
holding company, proposes to acquire all of the voting
shares of F.B.G. National Bank of Wooster (organiz­
ing), a nonoperating institution, and as a contem­
poraneous transaction, to effect the merger o f Citizens
National Bank of Wooster and F.B.G. National Bank
of Wooster (organizing). The effect of this transaction
will be to combine an existing bank with a nonoperat­
ing institution; as such, and without regard to the
acquisition of the surviving bank by First Banc Group
of Ohio, Inc., the proposed merger would have no
effect on competition.

The F.B.G. National Bank of Wooster, the charter
fer ownership of the merging bank to First Banc 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 consum­
mation of the proposed merger. The resulting bank




23, 576, 774

SU M M A R Y OF REPORT B Y A T T O R N E Y G ENER AL

bank, is being organized to provide a vehicle to trans­

118

3
0

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.
M arch 30, 1971

d e c is io n

*

$23, 456, 774
120, 000

*

*

T he First N ational Bank of W apakoneta , W apakoneta , O hio , and T he F.B.G. N ational Bank of
W apakoneta , W apakoneta , O hio

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Wapakoneta, Wapakoneta, Ohio (3157), with..............
and The F.B.G. National Bank of Wapakoneta, Wapakoneta, Ohio (3157), which
had....................................................................................................................................................
merged Apr. 30, 1971, under charter of the latter bank (3157) and title “ The First
National Bank of Wapakoneta.5 The merged bank at date of merger had...............
5

comptroller’ s decision

O n February 2, 1971, The First National Bank o f
Wapakoneta, Wapakoneta, Ohio, applied to the
Comptroller of the Currency for permission to merge
with The F.B.G. National Bank of Wapakoneta (or­
ganizing) , Wapakoneta, Ohio, under the charter of the
latter and with the title of the former.
The First National Bank of Wapakoneta, the merg­

To be
operated

In
operation

$32,817,098

3

120,000

0
3

32, 937,026

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.
M arch 30, 1971.
SU M M A R Y OF REPORT B Y A T TO R N E Y G ENER AL

ing bank, is headquartered in Wapakoneta, and has
two other offices located in Auglaize County. This bank,
with total resources o f $29.8 million, and IPC deposits
of $23.3 million, was chartered originally in 1884.
The F.B.G. National Bank of Wapakoneta, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to First
Banc 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 consum­
mation of the proposed merger. The resulting bank

The proposed merger is part of a plan under which
First Banc Group of Ohio, Inc., a registered bank hold­
ing company, proposes to acquire all of the voting
shares of The F.B.G. National Bank o f Wapakoneta
(organizing), a nonoperating institution, and as a con­
temporaneous transaction, to effect the merger of First
National Bank of Wapakoneta and The F.B.G. Na­
tional Bank of Wapakoneta (organizing). The effect
of these transactions will be to transfer control of an
existing bank to a nonoperating institution; as such,
and without regard to acquisition of the surviving bank
by First Banc Group of Ohio, Inc., the proposed
merger would have no effect on competition.

*

First N ational Bank of J oplin , J oplin , M

o ., and

First Bank of J oplin N ational A ssociation, J oplin, M

o.

Banking offices
Name of bank and type of transaction

First National Bank of Joplin, Joplin, M o. (13162), with...............................................
and First Bank of Joplin National Association, Joplin, M o. (13162), which h ad ...
merged May, 3, 1971, under charter of the latter bank (13162) and title “ First
National Bank and Trust Company of Joplin.” The merged bank at date of merger
had....................................................................................................................................................




Total assets

$69, 086, 435
120,000

68, 657, 343

To be
operated

In
operation
1
0

1

119

adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
tion 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.
M arch 15, 1971.

comptroller’ s decision

On February 3, 1971, the First National Bank of
Joplin, Joplin, M o., and the First Bank of Joplin Na­
tional Association (organizing), Joplin, M o., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the title
“ First National Bank and Trust Company of Joplin.”
First National Bank of Joplin, the merging bank, is
headquartered in Joplin, and is a unit bank. This bank,
with total resources of $60.3 million, and I PC deposits
of $46.3 million, was chartered originally in 1928.
First Bank o f Joplin National Association, the
charter bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the First
Community 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
*

SUM M ARY OF REPORT B Y A T T O R N E Y GENERAL

The proposed merger is part of a plan through
which First National Bank of Joplin would become a
subsidiary o f First Community Bancorporation, a bank
holding company. The instant merger, however, would
merely combine an existing bank with a nonoperating
institution; as such, and without regard to the acquisi­
tion of the surviving bank by First Community Bancorporation, it would have no effect on competition.
*

*

T he Security C entral N ational Bank of Portsmouth, Portsmouth, O hio , and
T he F.B.G. N ational Bank of Portsmouth, Portsmouth, O hio

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The Security Central National Bank of Portsmouth, Portsmouth, Ohio (7781),
with....................................................................................................................................................
and The F.B.G. National Bank of Portsmouth, Portsmouth, Ohio (7781), which
had.....................................................................................................................................................
merged June 1, 1971, under charter of the latter bank (7781) and title “ The Secur­
ity Central National Bank of Portsmouth.” The merged bank at date of merger had.

c o m p t r o l l e r ’ s d e c is io n

On February 2, 1971, The Security Central National
Bank of Portsmouth, Portsmouth, Ohio, and The
F.B.G. National Bank of Portsmouth (organizing),
Portsmouth, 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 Security Central National Bank of Portsmouth,
the merging bank, is headquartered in Portsmouth and
operates one branch there. It has three offices located
elsewhere in Scioto County. This bank, with total re­
sources of $62.8 million, and IPC deposits of $50.4 mil­
lion, was chartered originally in 1893.
The F.B.G. National Bank of Portsmouth, the

120



$62, 585, 949

5

120, 000

0

62, 705, 949

5

charter bank, is being organized to provide a vehicle
to transfer ownership o f the merging bank to the First
Banc 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 consum­
mation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
tions and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
A pril 30, 1971.

Security Central National Bank of Portsmouth and

SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

F.B.G. National Bank of Portsmouth (organizing).

The proposed merger is part of a plan under which
First Banc Group of Ohio, Inc., a registered bank
holding company, proposes to acquire all o f the voting
shares of F.B.G. National Bank of Portsmouth (or­
ganizing), a nonoperating institution, and as a con­
temporaneous transaction, to effect the merger of
*

The effect of this transaction will be to combine an
existing bank with a nonoperating institution; as such,
and without regard to acquisition of the surviving bank
by First Banc Group of Ohio, Inc., the proposed
merger would have no effect on competition.
*

*

T he U nited States N ational Bank of G alveston , G alveston , T e x ., and
T w en ty -S econd Street N ational Bank , G alveston , T e x .

Banking offices
Name of bank and type of transaction

Total assets

The United States National Bank of Galveston, Galveston, Tex. (12475), with.........
and Twenty-Second Street National Bank, Galveston, Tex. (12475), which had. . . .
merged June 30, 1971, under charter of the latter bank (12475) and title “ United
States National Bank of Galveston.” The merged bank at date of merger had. . . .

co m ptr o ller 's

d e c is io n

On March 11, 1971, The United States National
Bank of Galveston, Galveston, Tex., and the TwentySecond Street National Bank (organizing), Galveston,
Tex., applied to the Comptroller of the Currency for
permission to merge under the charter of the latter
and with the title “ United States National Bank of
Galveston.”
The United States National Bank of Galveston,
the merging bank, is headquartered in Galveston, Tex.,
and has one office located in Galveston. This bank,
with total resources of $50.9 million, and IPC deposits
of $25 million, was chartered originally in 1874.
Twenty-Second Street National Bank, the charter
bank, is being organized to provide a vehicle to trans­
fer ownership of the mergingbank to the United States
National Bancshares, Inc. The charter bank will not
be operating as a commercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no




$50, 177, 300
250, 000

To be
operated

In
operation
1
0

1

50, 427, 300

adverse effect on competition resulting from consum­
mation 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.
M ay 3, 1971.
SU M M AR Y OF REPORT B Y A T T O R N E Y G ENER AL

The proposed merger is part of a plan through which
Twenty-Second National Bank (organizing) would
become a subsidiary of United States National Baneshares, Inc., a bank holding company. The instant
merger, however, would merely combine an existing
bank with a nonoperating institution; as such, and
without regard to the acquisition of the surviving bank
by United States National Bancshares, Inc., it would
have no effect on competition.
*

121

New J ersey National Bank, T renton, N.J.,

and

S econd New J ersey National Bank, T renton, N.J

Bankin,g offices
Total assets

Name of bank and type of transaction

Motirtnal "Rant iic n tn n
with...................................................
XNcw jersey iNaiionai jDd.nK., T rp u iu n , NT T
...........................................................
and Second New Jersey National Bank, Trenton, N.J. (1327), which had...............
merged July 1, 1971, under charter of the latter bank (1327) and title “ New Jersey
National Bank.” The merged bank at date of merger had.............................................

c o m p t r o l l e r ’s

$608, 128, 606
250, 000

To be
operated

25
0
25

608, 378, 606

mation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
tions and with the same name as presently used by the
merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
M a y 24, 1971.

d e c is io n

On January 22, 1971, the New Jersey National Bank,
Trenton, N J ., and the Second New Jersey National
Bank (organizing), Trenton, N J., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of the
former.
New Jersey National Bank, the merging bank, head­
quartered in Trenton, has 22 offices located throughout
Mercer and Monmouth counties, and one in Hunter­
don County, as well as six approved but unopened
branches in Monmouth, Middlesex and Mercer coun­
ties. This bank, with total resources of $536.6 million,
and IPC deposits o f $392.6 million, was chartered

sum m ary of

report b y a tto r n e y

general

The proposed merger is part o f a plan under which
NJN Bancorporation, which will become a registered
bank holding company, proposes to acquire all o f the
voting shares of the New Jersey National Bank, a non­
operating institution, and as a contemporaneous trans­
action, to effect the merger of Second New Jersey Na­
tional Bank and New Jersey 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 nonoperating
institution; as such, and without regard to acquisition
of the surviving bank by NJN Bancorporation, the pro­
posed merger would have no effect on competition.

originally in 1804.
Second New Jersey National Bank, the charter bank,
is being organized to provide a vehicle to transfer
ownership of the merging bank to the NJN Bancor­
poration. 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 consum­
*

In
operation

*

*

T exas C ommerce Bank N ational A ssociation, H ouston, T e x ., and C ommerce Bank N ational A ssociation
H ouston, T e x .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Texas Commerce Bank National Association, Houston, Tex. (10225), with................
and Commerce Bank National Association, Houston, Tex. (10225), which had. . . .
merged July 7, 1971, under charter of the latter bank (10225) and title “ Texas
Commerce Bank National Association.” The merged bank at date of merger had. . .

122



$1, 234, 177, 204
237, 377
1, 234, 184, 404

1
0
1

comptroller’ s decision

On December 15, 1970, the Commerce Bank Na­
tional Association (organizing), Houston, Tex., applied
to the Office of the Comptroller of the Currency for
permission to merge with the Texas Commerce Bank

locations under title of Texas Commerce Bank Na­
tional Association.
Applying the statutory criteria, we conclude that the
proposal is in the public interest. The application is,
therefore, approved.
Ju ne 1, 1971.

National Association, Houston, Tex., under the charter
of the former and with the title of the latter.
The Texas Commerce Bank National Association,
the merging bank, is located in Houston, Tex., a city of
1.1 million. The bank was chartered July 8, 1912, and
presently has IPC deposits of $666.6 million.
The Commerce Bank National Association, owned
by Texas Commerce Bancshares, Inc., is being orga­
nized 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.
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

SU M M AR Y OF REPORT B Y A T T O R N E Y G ENER AL

The proposed merger is part o f a plan under which
Texas Commerce Bancshares, Inc., a registered bank
holding company, proposes to acquire all of the voting
shares o f Commerce Bank, N.A. (organizing), a non­
operating institution, and as a contemporaneous trans­
action, to effect the merger of Texas Commerce Bank,
N.A. and Commerce Bank, N.A. ( organizing). The
effect o f these transactions will be to transfer control
of an existing bank to a registered bank holding com­
pany. 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 Texas Commerce
Bancshares, Inc., the proposed merger would have
no effect on competition.
*

First A merican N ational Bank of N ashville , N ashville , T enn ., and A merican N ational Bank of
N ashville , N ashville , T enn .

Banking offices
Name of bank and type of transaction

Total assets

First American National Bank of Nashville, Nashville, Tenn. (3032), with..............
and American National Bank of Nashville, Nashville Tenn. (3032), which had. . .
merged July 15, 1971, under charter of the latter bank (3032) and title “ First
American National Bank of Nashville.” The merged bank at date of merger had.

c o m p t r o l l e r ’s

d e c is io n

On January 9, 1969, the First American National
Bank o f Nashville, Nashville, Tenn., and the Ameri­
can National Bank of Nashville (organizing), Nash­
ville, Tenn., 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 First American National Bank of Nashville,
Nashville, Tenn., was organized in 1883, and presently
holds IPC deposits of $349 million in its main office
and 21 branches.

$700, 331, 563
257, 200
700,331,563

In
operation

To be
operated

22
0
22

The American National Bank of Nashville (orga­
nizing), Nashville, Tenn., is a nonoperating institution
which is being organized as a step in the corporate re­
organization of the merging bank. With the exception
of the directors’ qualifying shares, all o f the stock of
the charter bank is owned by the First American Na­
tional Corp., a Tennessee corporation.
Since the charter bank is a nonoperating institution,
approval of this application will have no effect on com ­
petition. Service to the public will not be affected by
this transaction as the resulting bank will operate

123
463-499 0—72

-9




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.
M arch 10, 1969.
*

SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER AL

[This merger] * * * is part o f a transaction which
will result in a presently existing bank becoming a
wholly owned subsidiary of a one-bank holding com­
pany. Thus, * * * [it] is merely part of a corporate
reorganization, and as such will have no effect on
competition.
*

*

T he First N ational Bank of C orsicana, C orsicana, T e x ., and Bancorp N ational Bank of
C orsicana, T e x ., C orsicana, T e x .

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Corsicana, Corsicana, Tex. (3506), with.........................
and Bancorp National Bank of Corsicana, Tex., Corsicana, Tex. (3506), which
had................................................................................................................................ : .................
merged Aug. 31, 1971, under charter of the latter bank (3506) and title “ The
First National Bank of Corsicana, Tex.” The merged bank at date of merger had.

C O M P T R O L L E R ^ D E C IS IO N

On February 1, 1971, The First National Bank of
Corsicana, Corsicana, Tex., and the Bancorp Na­
tional Bank of Corsicana, Tex. (organizing), Corsi­
cana, Tex., 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
Corsicana, Tex.”
The First National Bank of Corsicana, the merging
bank, is headquartered in Corsicana. This bank, with
total resources of $47.4 million, and IPC deposits of
$34.5 million, was chartered originally in 4871.
Bancorp National Bank of Corsicana, Tex., the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to First
Bancorp, Inc. The charter bank will not be operating
as a commercial bank prior to the merger.
Because the merging bank is the only operating




$47, 320, 433

1

120, 000

0

47, 324, 033

1

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 20, 1971.
SU M M AR Y OF REPORT B Y A T TO R N E Y G ENER AL

This merger is part of a plan of corporate reorganiza­
tion whereby the First National Bank of Corsicana
will become a wholly owned subsidiary of a newly
organized bank holding company. It will combine an
existing bank with a nonoperating institution and will
have no effect on competition.
*

124

To be
operated

In
operation

Security National Bank

of

R oanoke, R oanoke, V a .,

and

R oanoke Bank, N.A., R oanoke, V a .

Banking offices
Total assets

Name of bank and type of transaction

Security National Bank of Roanoke, Roanoke, Va. (15117), with...............................
and Roanoke Bank, N .A ., Roanoke, Va. (15117), which had............ ................. ........
merged Sept. 1, 1971, under charter of the latter bank (15117) and title “ United
Virginia Bank/Security National.5 The merged bank at date of merger had...........
5

comptroller' s decision

On May 24, 1971, the Security National Bank of
Roanoke, Roanoke, Va., and the Roanoke Bank, N.A.,
(organizing), Roanoke, Va., applied to the Comp­
troller of the Currency for permission to merge under
the charter of the latter and with the title “ United V ir­
ginia Bank/Security National.” The main office of the
resulting bank will be in Roanoke County.
Security National Bank of Roanoke, the merging
bank, is headquartered in Roanoke, Va., and operates

To be
operated

In
operation

$25, 947, 677
252, 756

3
0
3

26, 200, 433

Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no
adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank
will conduct the same banking business as the merging
bank, but from a main office located in Roanoke
County.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore approved.
Ju ly 20, 1971.

two branch offices in the area. This bank, with total
resources o f $25 million, and I PC deposits of $16
million, was chartered originally in June 1963. It is
the smallest of the seven banks presently competing
in the Roanoke Metropolitan Area.
Roanoke Bank, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to United Virginia Bankshares
Inc. The charter bank will not be operating as a
commercial bank prior to the merger.

SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

The proposed merger is part of a plan through which
Roanoke Bank, N.A. (organizing) would become a
subsidiary of United Virginia Bankshares, Inc., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a nonoperating
institution; as such, and without regard to the acquisi­
tion of the surviving bank by United Virginia Bankshares, Inc., it would have no effect on competition.
*

Southwest N ational Bank of E l Paso, E l Paso , T e x ., and Second Southwest N ational Bank of E l Paso ,
E l Paso, T e x .

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
Southwest National Bank of El Paso, El Paso, Tex. (14581), with...............................
and Second Southwest National Bank of El Paso, El Paso, Tex. (14581), which had.
merged Sept. 30, 1971, under charter of the latter bank (14581) and title “ South­
west National Bank of El Paso.5 The merged bank at date of merger had...............
5




$73,615,410
245, 000
73, 860, 410

1
0
1

125

bank involved in the proposed transaction, there can be
no adverse effect on competition resulting from con­
summation 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.
A u g u s t 19, 1971.

comptroller’ s decision

On January 12, 1971, Southwest National Bank of
El Paso, El Paso, Tex., and the Second Southwest Na­
tional Bank of El Paso, El Paso, Tex. (organizing),
applied to the Comptroller of the Currency for permis­
sion to merge under the charter of the latter and with
the title of the former.
Southwest National Bank of El Paso, the merging
bank, is headquartered in El Paso, Tex. This bank,
with total resources of $68 million, and I PC deposits
of $42 million, was chartered originally in 1947.
Second Southwest National Bank of El Paso, the

SU M M AR Y OF REPORT B Y A T TO R N E Y GENER AL

The proposed merger is part of a plan through
which the Southwest National Bank of El Paso would
become a subsidiary of a one-bank holding company.
The instant merger would merely combine an existing
bank with a nonoperating institution; as such it would
have no effect on competition.

charter bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the United
Bank Shares, Inc. The charter bank will not be operat­
ing as a commercial bank prior to the merger.
Because the merging bank is the only operating
*

*

*

T he First N ational Bank of D anville , D anville , V a ., and D anville Bank , N.A., D anville , V a .

Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Danville, Danville, Va. (1985), with.................................
and Danville Bank, N .A ., Danville, Va. (1985), which had...........................................
merged Sept. 30, 1971, under charter of the latter bank (1985) and tide “ The
First National Bank of Danville.5 The merged bank at date of merger had.............
5

c o m p t r o l l e r ’s

d e c is io n

On June 15, 1971, The First National Bank of Dan­
ville, Danville, Va., and the Danville Bank, N.A. (or­
ganizing), Danville, Va., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
The First National Bank of Danville, the merging
bank, is headquartered in Danville, and has five offices

$58, 382, 219
130, 000

To be
operated

In
operation
5
0

58, 385,819

5

adverse effect on competition resulting from consum­
mation 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.
A u g u s t 10, 1971.

located in Danville. This bank, with total resources
of $55.4 million, and IPC deposits of $44.5 million, was
chartered originally in 1872.
Danville Bank, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the First & Merchants Corp.
The charter bank will not be operating as a com­
mercial bank prior to the merger.
Because the merging bank is the only operating bank
involved in the proposed transaction, there can be no

126



SU M M AR Y OF REPORT B Y A T T O R N E Y G ENER AL

The proposed merger is part of a plan through which
Danville Bank, N.A. (organizing), would become a sub­
sidiary of First & Merchants Corp., a bank holding
company. The instant merger, however, would merely
combine an existing bank with a nonoperating institu­
tion; as such, and without regard to the acquisition of
the surviving bank by First & Merchants Corp., it
would have no effect on competition.

T he F ourth N ational Bank of T ulsa , T ulsa , O kla ., and T he F ourth Bank of T ulsa , N .A .,
T ulsa , O k la .

Banking offices
Total assets

Name of bank and type of transaction

In
operation

To be
operated

merged Oct. 29, 1971, under charter of the latter bank (13480) and title “ The
Fourth National Bank of Tulsa.” The merged bank at date of merger had...........

c o m p t r o l l e r ’s

d e c is io n

On August 6, 1971, The Fourth National Bank of
Tulsa, Tulsa, Okla., and The Fourth Bank of Tulsa,
National Association (organizing), Tulsa, Okla., ap­
plied to the Comptroller of the Currency for permission
to merge under the charter of the latter and with the
title of the former.
The Fourth National Bank of Tulsa, the merging
bank, is headquartered in Tulsa, Okla. This bank, with
total resources of $92.3 million, and total deposits of
$81.1 million, was chartered originally in 1930.
The Fourth Bank of Tulsa, National Association, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to The
Fourth National Corp. 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

$99, 545, 713

2

250,000

The Fourth National Bank of Tulsa, Tulsa, Okla. (13480), with........................ ..
and The Fourth Bank of Tulsa, National Association, Tulsa, Okla. (13480), which

0
2

99, 552, 913

adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank will
conduct the same banking business at the same location
with the same name as presently used by the merging
bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
S e p t e m b e r 23, 1971.
su m m ar y of report b y a tto r n e y g ener al

The proposed merger is part of a plan through which
Fourth Bank of Tulsa, N.A. (organizing), would be­
come a subsidiary of Fourth National Corp., a bank
holding company. The instant merger, however, would
merely combine an existing bank with a nonoperating
institution; as such, and without regard to the acquisi­
tion of the surviving bank by Fourth National Corp.,
it would have no effect on competition.
*

South J ersey N ational Bank , C amden , N J ., and Second South J ersey N ational Bank , C amden , N.J.

Bankin,g offices
Name of bank and type of transaction

Total assets

South Jersey National Bank, Camden, N.J. (1209), with...............................................
and Second South Jersey National Bank, Camden, N.J. (1209), which had............
merged Nov. 1, 1971, under charter of the latter bank (1209) and title “ South
Jersey National Bank.” The merged bank at date of merger had..................................

c o m p t r o l l e r ’s d e c is io n

On M ay 11, 1971, the South Jersey National Bank,
Camden, N.J., and the Second South Jersey National
Bank (organizing), Camden, N.J., applied to the
Comptroller of the Currency for permission to merge




$429, 016, 602
241, 670
429, 258, 272

In
operation

To be
operated

36
0
36

under the charter of the latter and with the title of the
former.
South Jersey National Bank, the merging bank, is
headquartered in Camden, and has offices throughout
southern New Jersey and one in Philadelphia, Pa. This
bank, with total resources o f $392.4 million, and IPC

127

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
A ugust 19, 1971.

deposits of $303.7 million, was chartered originally in
1812.
Second South Jersey National Bank, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to the Heritage Corp.
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 consum­
mation of the proposed merger. The resulting bank

S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

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

will conduct the same banking business at the same
locations and with the same name as presently used by
the merging bank.
*

*

*

T he First N ational Bank of Princeton, Princeton, N.J., and Second N ational Bank of
Princeton, Princeton, N.J.

Banking offices
Name of bank and type of transaction

Total assets

To be
operated

In

operation
The First National Bank of Princeton, Princeton, N.J. (4872), with.............................
and Second National Bank of Princeton, Princeton, N.J. (4872), which had.............
merged Nov. 1, 1971, under charter of the latter bank (4872) and title “ The First
National Bank of Princeton.5 The merged bank at date of merger had....................
’

On July 8, 1971, The First National Bank of Prince­
ton, Princeton, N.J., and the Second National Bank
of Princeton (organizing), Princeton, 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 First National Bank of Princeton, the merging
bank, is headquartered in Princeton, and has four
offices located throughout Mercer County. This bank,
with total resources of $89.4 million, and IPC deposits

4

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

The Second National Bank of Princeton, the charter
bank, is being organized to provide a vehicle to transfer
ownership of the merging bank to United Jersey Banks,
a registered bank holding company. The charter bank
will not be operating as a commercial bank prior to
the merger.
Because the merging bank is the only operating bank




94, 680, 862

S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

of $78.4 million, was chartered in 1893.

128

4
0

involved in the proposed transaction, there can be no
adverse effect on competition resulting from consum­
mation 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.
A ugust 30, 1971.

comptroller’ s decision

*

$94, 677, 190
120, 000

*

*

T he F irst N ational I ron Bank of N e w J ersey , M orristown , N.J., and Second N ational I ron
Bank of N ew J ersey, M orristown , N.J.

Banking offices
Name of bank and type of transaction

Total assets

The First National Iron Bank of New Jersey, Morristown, N.J. (1113), with.............
and Second National Iron Bank of New Jersey, Morristown, N.J. (1113), which
had....................................................................................................................................................
merged Nov. 1, 1971, under charter of the latter bank (1113) and title “ The First
National Iron Bank of New Jersey.” The merged bank at date of merger had...........

comptroller’ s decision

O n May 10, 1971, The First National Iron Bank of
New Jersey, Morristown, N.J., and the Second Na­
tional Iron Bank of New Jersey (organizing), Morris­
town, 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 First National Iron Bank of New Jersey, the
merging bank, is headquartered in Morristown, N.J.,
and has 19 offices located throughout New Jersey.
This bank, with total resources of $181 million, and
IPC deposits of $130 million, was chartered originally
in 1865.
The Second National Iron Bank of New Jersey, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to the
Heritage 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

To be
operated

In
operation

$194, 785, 688

18

121,034

0
18

194, 906, 722

adverse effect on competition resulting from consum­
mation of the proposed merger. The resulting bank will
conduct the same banking business at the same loca­
tions and with the same name as presently used by
the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
A u g u s t 19, 1971.
SU M M AR Y OF REPORT B Y A T TO R N E Y GENERAL

The proposed merger is part of a plan through
which Second National Iron Bank of New Jersey
(organizing) would become a subsidiary of Heritage
Bancorporation, a bank holding company. The in­
stant merger, however, would merely combine an
existing bank with a nonoperating institution; as such,
and without regard to the acquisition o f the surviving
bank by Heritage Bancorporation, it would have no
effect on competition.
*

C entral N ational Bank of C leveland , C leveland , O hio , and C entral C leveland Bank , N.A.,
C leveland , O hio

Banking offices
Name of bank and type of transaction

Total assets

Central National Bank of Cleveland, Cleveland, Ohio (4318), with...........................
and Central Cleveland Bank National Association, Cleveland, Ohio (4318), which
had....................................................................................................................................................
merged Dec. 31, 1971, under charter of the latter bank (4318), and title “ Cen­
tral National Bank of Cleveland.” The merged bank at date of merger had...........

$1, 308, 891, 000

49

250, 000

0




1,309, 141,000

To be
operated

In
operation

49

129

comptroller ’s

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.
S e p t e m b e r 2, 1971.

decision

On February 25, 1971, the Central National Bank
of Cleveland, Cleveland, Ohio, and the Central Cleve­
land Bank, N.A. (organizing), Cleveland, Ohio, ap­
plied to the Comptroller of the Currency for permis­
sion to merge under the charter of the latter and with
the title of the former.
Central National Bank of Cleveland, the merging
bank, is headquartered in Cleveland, and has 48
branches located throughout Cleveland and Cuya­

S U M M A R Y OF R E P O R T B Y A T T O R N E Y G E N E R A L

hoga County. This bank, with total resources of $1.4
billion, and IPC deposits of $815.6 million, was char­

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

tered originally in 1890.
Central Cleveland Bank, N.A., the charter bank, is
being organized to provide a vehicle to transfer owner­
ship of the merging bank to the CNB Bancorporation. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating
*

*

*

Liberty N ational Bank & T rust Co., Buffalo, N.Y.,
T rust C ., Buffalo,
o

and

Court Street N ational Bank &

N.Y.

Banking offices
Name of bank and type of transaction

Total assets

Liberty National Bank & Trust Co., Buffalo, N .Y. (15080), with...............................
and Court Street National Bank & Trust Co., Buffalo, N .Y. (15080), which had.
merged Dec. 31, 1971, under charter of the latter bank (15080) and title “ LibertyNational Bank & Trust Co.5 The merged bank at date of merger had .............
5

c o m p t r o l l e r ’s

d e c is io n

On October 4, 1971, the Liberty National Bank &
Trust Co., Buffalo, N.Y., and the Court Street Na­
tional Bank & Trust Co. (organizing), Buffalo, N.Y.,
applied to the Comptroller of the Currency for per­
mission to merge under the charter of the latter and
with the title of the former.
Liberty National Bank & Trust Co., the merging
bank, is headquartered in Buffalo and has 35 offices
located throughout Buffalo and other communities in
the general area. This bank, with total resources of
$497.3 million, and IPC deposits of $376 million, was
chartered originally in 1882.
Court Street National Bank & Trust Co., the char­

180




$513, 624, 992
240, 000
513, 864, 992

In
operation

To be
operated

35
0
35

ter bank, is being organized to provide a vehicle to
transfer ownership of the merging bank to the United
Bank Corp. of New York. 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 consum­
mation 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.
N o v e m b e r 17, 1971.

S U M M A R Y OF R EPO R T B Y A T T O R N E Y G EN ER AL

merger, however, would merely combine an existing

The proposed merger is part of a plan through which
Court Street National Bank & Trust Co. (organizing)
would become a subsidiary of United Bank Corp.
of New York, a bank holding company. The instant

bank with a nonoperating institution; as such and

#

without regard to the acquisition of the surviving bank
by United Bank Corp. of New York, it would have no
effect on competition.
#

*

N ational C ommercial Bank & T rust C o ., A lbany , N .Y ., and C apital C ity N ational Bank , A lbany , N .Y .

Banking offices
Name of bank and type of transaction

Total assets

National Commercial Bank & Trust Co., Albany, N .Y . (1301), with........................
and Capital City National Bank, Albany, N .Y. (1301), which had.............................
merged Dec. 31, 1971, under charter of the latter bank (1301), and title “ National
Commercial Bank & Trust Co.” The merged bank at date of merger had...............

c o m p t r o l l e r ’s

$877, 827, 655
250, 020

To be
operated

58

0

877, 835, 655

58

mation of the proposed merger. The resulting bank

d e c is io n

will conduct the same banking business at the same

On July 8, 1971, the National Commercial Bank &
Trust Co., Albany, N.Y., and the Capital City Na­
tional Bank (organizing), Albany, N.Y., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.

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.
O

National Commercial Bank & Trust Co., the merg­
ing bank, is headquartered in Albany, N.Y., and
maintains 57 offices in New York’s Fourth Banking
District. This bank has I PC deposits of $413.4 million.

*

cto b er

5, 1971.

SU M M AR Y OF REPORT B Y A T T O R N E Y G EN ER AL

The proposed merger is part of a plan through which

Capital City National Bank, the charter bank, is
being organized to provide a vehicle to transfer own­
ership of the merging bank to First Commercial Banks,
Inc. (formerly Heartland, Central New York C orp.).
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 consum­




In
operation

Capital City National Bank (organizing) would be­
come a subsidiary of First Commercial Banks, Inc., a
bank holding company. The instant merger, however,
would merely combine an' existing bank with a non­
operating institution; as such, and without regard to
the acquisition of the surviving bank by First Com­
mercial Banks, Inc., it would have no effect on
competition.
*

*

131

II I. Additional approvals
A. Approved, but in litigation
T

he

F ir s t N

a t io n a l

Bank

of

A tlanta, A

tlanta,

T

G a ., a n d T
Ga.

he

F ir s t N

a t io n a l

Bank

of

T

ucker3

ucker,

r
Bankin,g offices

Total assets

Name of bank and type of transaction

The First National Bank of Tucker, Tucker, Ga. (15531), with....................................
and The First National Bank of Atlanta, Atlanta, Ga. (1559), which had................
applied for permission to merge Sept. 3, 1970, under charter and title of the latter
bank (1559). The application was approved Jan. 20, 1971. The pending merger
. „ _ challenged L.. Justice nonorfmAnt 17aU IQ, 1Q7 1, <uiu 1Cnrpcpntlv iu j.iu.ga.uui.I . .
___ _ J by
T
) 1 'J T
was
uepartmeni reu. 1 0 i i U lH picscuuy IT 1 t"lO lt’lO 1

To be
operated

In
operation

$5,684, 097

1

1, 018,432, 730

35

purchased. Three of the merging bank’ s five officers,

applicant. The close relationship between the two in­
stitutions is reflected by the existence of a service con­
tract through which the applicant provides the merg­
ing bank with non-officer staff needs and several tech­
nical staff services.
In view of the status of the merging bank as an
affiliate of the applicant, consummation of the pro­
posed merger will not result in a lessening of com pe­
tition between the two banks; the merger transaction
is, in essence, merely the substitution of a branch for
an affiliate. In addition, the applicant’s acquisition of
merging bank’s total deposits of $5 million will not
result in any meaningful increase in the applicant’s
share of the market. The impact within the relevant
market area of the merging bank will also be minimal,
and competition will still be afforded by other banks
within, or immediately adjacent to, the merging bank’s
primary service area. T w o of these competitors, The
Citizens and Southern Emory Bank, with total deposits
of $37 million, and The Citizens and Southern Bank
of Tucker, with total deposits of $20 million, are in the
process of being merged. The bank resulting from that
merger will be an affiliate of Atlanta’s largest bank, the
$1.3 billion deposit Citizens and Southern National
Bank. Other competitors include The Citizens and
Southern Bank of Stone Mountain, with deposits of
$7 million, and Citizens Bank of Clarkston, which
opened in 1970. Among those rivals, the three largest,
with 91 percent of the area’s deposits, are all affiliates
of The Citizens and Southern National Bank, the
merging bank ranks fourth. In light of those facts,
it is apparent that competition in the area will be
enhanced by the proposed merger which will have the
effect of ensuring the continued existence of a healthy

including its president, are former officers of the appli­

banking outlet that can effectively challenge the domi­

cant, and retain their retirement benefits from the

nance of Citizen and Southern affiliates in the area.

co m ptro ller 's

d e c is io n

O n September 3, 1970, The First National Bank of
Tucker, Tucker, Ga., and The First National Bank of
Atlanta, Atlanta, Ga., applied to the Comptroller of
the Currency for permission to merge under the char­
ter and with the title of the latter.
The First National Bank of Atlanta, with I PC de­
posits of $546 million, maintains 21 offices within the
city of Atlanta, where it is the second largest bank, and
two offices in the city of Decatur, DeKalb County.
Because of restrictive State statutes, the applicant’s
branching and merging efforts in recent years have
been confined within the city limits of Atlanta and
Decatur. As a result of changes in Georgia statutes
relating to branching and merging, the applicant is
now able to branch and merge in any county where
it had previously established a branch. Since the appli­
cant maintains branches in Decatur, located in DeKalb County, the new laws permit the applicant to
establish branches and consummate mergers through­
out that county.
The First National Bank of Tucker, with IPC de­
posits of $4.3 million, is located in the community of
Tucker, approximately 16 miles from the main office
of the applicant in Atlanta, and 7.6 miles east of the
applicant’s nearest branch. The merging bank was es­
tablished in 1965 with the assistance of officers of
the applicant. In 1969, when it appeared that the
State’ s banking laws would be changed, a director of
the applicant acquired approximately 90 percent of
the merging bank’s outstanding stock with proceeds
o f a loan from the applicant, secured by the shares

132




County until control passed to Atlanta Bank under the

nearest branch of Atlanta Bank. Atlanta Bank’ s main
office is 7 miles distant from Glenwood Bank and 16
miles distant from Tucker Bank. The application states
that Atlanta Bank draws $5 million in deposits from
Glenwood Bank’ s “ service area” and $1 million in de­
posits from Tucker Bank’s “ service area.” Although
there are intervening banks, it is clear that a significant
amount of competition which existed between Atlanta
Bank and each of the other banks (particularly Glen­
wood Bank) at the time of their “ affiliation,” as well
as the not insignificant amount which still exists, would
be permanently eliminated by this merger.
The competitive implications must be seen in the
light of banking structure in DeKalb County (an area
which may overstate the m arket). Twenty-three banks
operate 38 banking offices in the county, but most of
these are subject to affiliations of various kinds and de­
grees with leading Atlanta banks. In fact, after making
allowances for such affiliations, we find that five bank­
ing groups, each dominated by a large Atlanta bank,
control over 95 percent of DeKalb County deposits.
There appear to be only four banks not affiliated with
these groups, and with one exception, these are under
$1 million in deposits and less than 1 year old. The
only bank o f any size at all remaining in DeKalb
County which has no known affiliation with an Atlanta
bank is Peoples Bank of Lithonia, with deposits of $5.9
million. Thus, DeKalb County is in reality a highly
concentrated banking market, completely dominated
by the large Atlanta banks.
Atlanta Bank is one of the leaders in the county. It
holds, directly at its DeKalb County offices, about 13
percent of total county deposits; and, when allowance
is made for its “ affiliate” banks, this figure becomes
about 20 percent. This makes it the third largest bank­
ing group in the county. T h e largest share o f county
deposits is controlled by the Citizens and Southern
Holding Co., which owns or is affiliated with eight
banks with offices in DeKalb County. These include
the bank holding the largest single share o f county
deposits (14 percent), and together these eight banks
hold about 45 percent of DeKalb County deposits.
Glenwood Bank, the largest “ affiliate” controlled by
Atlanta Bank, holds about 4.6 percent of total county
deposits, and Tucker Bank holds about 1.8 percent of
such deposits. Both banks have a history o f viable and
independent banking predating the acquisition of con­
trol by Atlanta Bank. The kind o f affiliation, and its

arrangement described above.

short duration, does not preclude the possibility that

Approval of the application will enable the merging
bank, as a branch of the applicant, to draw more
effectively upon the services and expertise now pos­
sessed by the applicant. The convenience and needs
of the community require the expanded and more so­
phisticated services that will become available to the
merging bank. In particular, the need for greater ca­
pacity to provide consumer credit should be accom­
modated through consummation of the merger. The
merging bank will also be able to provide payroll
services, lock-box services, accounts receivable financ­
ing, letters of credit, and other specialized services to
commercial and industrial firms in its service area.
It is concluded that the merger will have no adverse
competitive effect and is in the public interest. The
application is, therefore, approved.
J a n u a r y 20, 1971.
SUM M ARY OF REPORT B Y A TTO R N E Y GENERAL

These two banks, as well as two others in DeKalb
County (which are the subject of separate applica­
tions) , are now controlled by Atlanta Bank. These two
banks became affiliated with Atlanta Bank as a result
o f recent share acquisitions by individuals apparently
acting on behalf of Atlanta Bank.
Glen wood Bank was opened in 1952, and operated
as an independent and viable banking competitor in
DeKalb County until 1968. At that time, a director
of Atlanta Bank purchased over 96 percent of the
outstanding stock of Glenwood Bank. The stock pur­
chase was made with the proceeds of a loan from
Atlanta Bank, represented by a note payable on de­
mand and secured by the Glenwood Bank stock pur­
chased. The principal amount of the loan has not
been reduced, and interest, at the rate of 1 percent
per annum, has been accrued but not paid. In addi­
tion, Atlanta Bank holds an option, evidenced by writ­
ten agreement, to purchase the shares pledged as
collateral for the loan.
Tucker Bank was acquired in a similar manner. A
former director (presently an “ Honorary Director7 )
’
of Atlanta Bank purchased controlling interest in
Tucker Bank in 1969 with similar financial assistance
from and arrangements with Atlanta Bank. Tucker
Bank had opened in 1965, and operated as an inde­
pendent and viable banking competitor in DeKalb

Glenwood Bank’s home office is located some 3 miles

Glenwood Bank and Tucker Bank could again become

from the nearest branch of Atlanta Bank. Tucker

entirely independent competitors in an area where de­

Bank’ s only office is located some 7 miles from the

concentration is sorely needed.




It seems clear that the indirect acquisitions o f Glenwood Bank and Tucker Bank, subjected to no regula­
tory scrutiny, had an adverse effect on competition at
the time they were made; and that the consummation
of these mergers would permanently foreclose the po­
tential for future competition between these banks and
Atlanta Bank in the future. This is particularly true of
Glenwood Bank which is larger, closer to the offices of
Atlanta Bank, and more directly competitive with it.
*

The consummation of these mergers would thus be a
significant step toward complete and permanent con­
trol of banking in DeKalb County by five large Atlanta
banks. Because of these factors, we conclude that the
proposed merger of Tucker Bank into Atlanta Bank
would have an adverse effect on competition; and that
the proposed merger of Glenwood Bank into Atlanta
Bank would have a significantly adverse effect on
competition.
*

*

T he C onnecticut N ational Bank , Bridgeport, C onn ., and T he First N e w H aven N ational Bank ,
N e w H aven , C onn .

Banking offices
Name of bank and type of transaction

Total assets

The Connecticut National Bank, Bridgeport, Conn. (335), with..................................
and The First New Haven National Bank, New Haven, Conn. (2), which had___
applied for permission to consolidate Feb. 2, 1971, under charter of the latter bank
(2) and title “ The First Connecticut National Bank.” The application was ap­
proved July 26, 1971. The pending consolidation was challenged by Justice
Department Aug. 23, 1971, and is presently in litigation................................................

comptroller’ s decision

On February 2, 1971, The Connecticut National
Bank, Bridgeport, Conn., and The First New Haven
National Bank, New Haven, Conn., applied to the
Office of the Comptroller of the Currency for permis­
sion to consolidate under the charter of the latter and
with the title o f “ The First Connecticut National
Bank,” with its main office in Bridgeport.
The First New Haven National Bank, the charter
bank, with I PC deposits of $237.2 million, was origi­
nally chartered in 1792 through its predecessor, The
New Haven Bank, N.B.A., and is the oldest bank in
existence under the National system. It operates 22
branch offices in New Haven County, and has one
approved but unopened branch. It is the seventh largest
bank in the State in terms of total resources.
New Haven, the home office city of the charter bank,
has a population of approximately 133,000, and is the
third largest city in the State. Occupying 17.9 square
miles, it is located in New Haven County on Long
Island Sound, approximately 36 miles south o f Hart­
ford, and serves as the hub of a rapidly growing in­
dustrialized area. The population of New Haven has
decreased by some 12 percent in the last decade. The
population of New Haven County, on the other hand,
has increased by 11 percent to 733,846.
134




$398,313, 449
315, 269, 949

In
operation

To be
operated

51
21

The Connecticut National Bank, with IPC deposits
of $301.6 million, can trace its beginnings to 1806. In
1865, it converted to a National Association and, in
1955, assumed its present name. This bank operates 48
branch offices of which 39 are concentrated in Fairfield
County, 8 are in New Haven County, and 1 is in
Litchfield County. It is ranked as the fourth largest
bank in the State in terms of total resources.
Bridgeport, the home office city of The Connecticut
National Bank, is the second largest city in the State,
with a population of about 155,000, and a trade area
population of 360,000. It is located in Fairfield County
on Long Island Sound, approximately 19 miles south­
west of New Haven, and about 60 miles northeast of
New York City. Its economy is diversified and is rela­
tively stable. The city, with its good harbor facilities,
is one o f the leading industrial and commercial centers
in the State. Varied industrial plants, both large and
small, dot the area around Bridgeport. While the
population of the city has been relatively stable in
recent years, the population of the surrounding area
has shown very substantial growth.
The consolidation of the applicant banks will give
the resulting bank some 71 branch offices to serve the
two southwestern counties o f Connecticut, viz, Fairfield and New Haven. That breadth of coverage will
enable the applicants to achieve the goal of this applica­

tion; namely, to become a regional bank o f sufficient
size to compete effectively in its market. The appli­
cants hope, by combining their resources, to continue to
serve the customers who are now outgrowing their in­
dividual capabilities, and, through their combined
resources, to compete more effectively with the larger,
statewide Connecticut banks and with the out-of-State
banks that canvass the area for profitable banking
business.
Inasmuch as Connecticut statutes encourage state­
wide branching through mergers, the two southwest­
ern counties must be viewed in the context o f the
economy of the State as a whole. Not only does Con­
necticut lie midway between Boston and New York on
the axis of the eastern megalopolis, but Fairfield County
has long been considered to be a commuter’s suburb of
New York City. The excellent highway and transporta­
tion systems, including seaways, that connect Con­
necticut to its two adjacent metropolitan areas, have
contributed significantly to its marked population in­
crease in the last decade. The same transportation sys­
tems have encouraged the growth of industrial activity
in the State, with all its concomitant benefits, until
the area has become one of the leading industrial areas
in the Nation.
Connecticut, unlike its neighboring States, is handi­
capped because it lacks large metropolitan centers in
which, normally, large banks coexist with large indus­
trial, manufacturing, business, and service concerns.
The population of Connecticut has, historically, been
spread out over its 169 towns, each of which operates
independently as a trading area and a bank service
area. Connecticut’s spectacular growth has occurred
along a corridor reaching from New York City, through
Bridgeport and New Haven to Hartford, in the cen­
tral portion of the State. Between 1963 and 1967,
annual new capital expenditures for plants and equip­
ment increased 84.9 percent for Fairfield County, the
headquarters of Connecticut National Bank, and 73.2
percent for New Haven County, the headquarters of
The First New Haven National Bank. For the same
period, the value added by manufacture increased by
47.3 percent for the Bridgeport bank, and 36.3 percent,
for the charter bank. Between 1960 and 1970, the
population in Fairfield County increased 20.2 percent;
in New Haven County the increase was 11.1 percent.
Concomitant with its population growth, the econ­
omy of the State has continued to expand. It now
ranks first in the Nation in per capita income and
per capita value added by manufacture, and second in
per capita effective buying income. Constituting, as it
does, such a lush banking market, the large billion-




and near-billion-dollar institutions in New York,
Boston, and Providence have canvassed it from border
to border in search of business— and rightfully so. T o
withstand the competitive inroads of the out-of-State
institutions, the local banking structure needs more
large banks. They are essential to Connecticut if the
wealth it generates is to remain within the State, and
redound to the advantage of the people who created it.
Connecticut banks have been limited to a minor
share in the State’s growth.1 In 1970, First New Haven
National Bank had a lending limit of approximately
$1.5 million. O f its 23 customers borrowing that
amount, 18 have gone out of the area for additional
financing. Connecticut National Bank, with a lending
limit of $2 million, has had similar experiences. Both
banks are able to provide only small portions of major
commercial borrowing requirements, and both suffer
from the lack of resources to service the international
financing and corporate counseling needs of the large
customers. By the consolidation of these banks, new and
better services will be offered to their customers,
thereby making the resulting bank more competitive.
Even though both participants in this proposal are
located in southwestern Connecticut, they do not now
compete with each other in any legally meaningful
degree. First New Haven National Bank, which pri­
marily serves New Haven County, draws less than
2 percent of its IPC deposits from Fairfield County,
which is served by The Connecticut National Bank. On
the other hand, The Connecticut National Bank ob­
tains only 5.6 percent of its IPC deposits from areas in
New Haven County where the First New Haven
National Bank has its offices. With respect to loans,
Connecticut National Bank derives less than 4 percent
of its dollar volume from New Haven County, while
the First New Haven National Bank derives some­
what less than 3 percent from Fairfield County.
The applicant banks do not compete substantially
even in the three small areas where each operates one
or more branch offices. In the Derby-Ansonia area,
each bank has one branch on the town line; Connecti­
cut National Bank has had its small branch in Ansonia
since 1958, and First New Haven National Bank
opened its branch several hundred yards away in
Derby in 1966. Connecticut National Bank has had a
branch office in Orange since 1956, and First New
Haven National opened its branch, 1 mile away, in
1963. Neither of those offices has yet reached a $10
1 See opinion of the Comptroller of the Currency dated
Apr. 14, 1969, approving the application of the Connecticut
Bank & Trust Co., Hartford, Conn., and The Connecticut
National Bank, Bridgeport, Conn., to merge.

135

million deposit base. First New Haven National entered
Milford by merger in 1955, when it acquired two
offices. In 1959, it opened a third branch in Milford.
Those three offices are
2, and 2/2 miles from
Connecticut National’s branch, which opened in 1956.
The aggregate deposits of each bank, in those branch
offices, in those three areas, constitute a very minute
share of their total deposits.
Applicant banks have stated that, as a matter of
prudent banking practice, the resulting bank will not
wish to operate two separate offices in Orange or in
the Ansonia-Derby area. It plans to sell one of the
offices to another competing commercial bank which is
not yet represented in the area, and which probably
could not enter the area except by the purchase of such
a branch. The same plan is proposed for one of the
branches in Milford.
One o f the advantages of this consolidation is the
continuing existence of multiple banking offices. There
are 23 commercial banks and 24 savings banks pres­
ently operating a total of 475 offices in the combined
service areas of the applicant banks. O f the total
deposits held by those institutions, Connecticut Na­
tional Bank holds only 5.0 percent, and The First New
Haven National Bank holds 3.7 percent; of the total
loans, Connecticut National Bank holds 4.9 percent,
and First New Haven National holds 3.8 percent.
The impact of this proposal on potential competi­
tion in the State’s banking market derives from the
application of the State’s banking statutes, rather than
from the effects of the union of the applicants. The
Connecticut State statute on branch banking has cre­
ated a crazy-quilt design of towns that are “ open” or
“ closed” to de novo branch banking. One or the other

This application does not present any problem of
concentration of banking resources. Connecticut Na­
tional Bank ranks sixth and First New Haven Na­
tional Bank ranks 10th among the 49 commercial and
savings banks operating competing offices in south­
west Connecticut. While the bank resulting from this
consolidation will rank fourth in size in the area, a
gain of two places, it will possess combined deposits
of only $569 million, and loans of $432 million, which
represent less than 9 percent of those held by compet­
ing banks in their service areas. That percentage does
not represent an undue concentration of resources in
view of the growth o f the 11 new commercial banks
chartered, for the same area, since 1960. Since 1960,
both banks’ share of the market has decreased sig­
nificantly, thereby rendering them less competitive in
the overall market.
The banking market in the two-county area, as in
all of Connecticut, is fragmented rather than con­
centrated. The eight leading banks 2 in the area hold
approximately 60 percent of the deposits of the 47
banks maintaining offices in the area. Between 1962
and 1967, acquisitions by three of the four leading
competitors in the area represented less than 3.5 per­
cent of the total assets of banks competing in the area.
Between 1962 and 1968, 11 commercial banks were
chartered in Fairfield and New Haven counties.
Those factors indicate that the general banking public
in these counties is well served; however, they fail to
disclose that the large commercial accounts, which
represent the industrial concerns on which the econ­
omy of Connecticut depends, are not able to find bank­
ing resources in these counties.
The slight increase in the concentration of banking

of the applicants has a branch office in each o f the 22

resources that will result from this consolidation will

towns open for branch banking in the two counties.

put the participants in a stronger competitive position

In addition, there are 12 towns open to branch bank­
ing in which neither applicant has a branch. The ap­
plicants’ experience in entering “ open towns” by de

in the State, and in the various sections of the State
they both serve. That increase will not result in a sub­
stantial lessening of competition among commercial

novo branching reveals that the potential business in

banks anywhere in the State. Experience has shown

rural communities cannot support or justify the high

that the combination of banking resources through1

initial costs of opening a branch, nor can it justify the
protracted operating period through which a branch
must function before it becomes operationally viable.
Those economic considerations, from a prudent point
of view, foreclose those towns to de novo branching in
the foreseeable future. Thus, the only local markets
that can support a competitive de novo branch are
the population centers of Bridgeport and New Haven,
Stanford, Waterbury, and Norwalk, all of which are
closed to de novo entry by State statute.
136




2 As of June 20, 1971:

Name of bank—

Resources in
millions

Hartford National Bank---------------$ 1 ,2 5 4 .0 0
Connecticut Bank & Trust----------1, 176. 80
Union Trust C o ._________________
591. 20
Connecticut National Bank----------4 1 2 .4 0
State National Bank of Connecti­
cut _____________________________
4 0 3 .8 0
6. City National Bank----------------------377. 40
7. First New Haven National_______
299. 00
8. Second National Bank____________
206. 70

1.
2.
3.
4.
5.

nergers and holding company acquisitions, especially
where those forms of bank expansion are specifically
encouraged by State laws, has stimulated competition
to an unusually high degree without danger to the via­
bility o f competing banks, and has thereby contri­
buted considerably to the good of the banking public.
Those beneficial effects are found in North Carolina,
Virginia, Maryland, Pennsylvania, New York, Cali­
fornia, and, to a limited degree, in Connecticut.
It is well documented that industrial development
in Connecticut is largely financed by out-of-State banks,
particularly those located in New York and Boston, and
so banking profits are being drained from the State.
The only method open for applicants to compete with
those banks is to consolidate their resources, to raise
their lending limits, and to provide the sophisticated
banking services demanded by industrial and com­
mercial customers, de novo branching, even if it were
feasible, would not serve that purpose. Smaller con­
solidations, likewise, would not result in an aggregation
of resources sufficiently large to meet the requirements
of large corporations located in Fairfield and New
Haven counties. The banking structure in southwest
Connecticut, together with the proximity of the New
York banks, poses a unique situation in which the
applicants are likely to be uninvolved bystanders as
their corporate markets are taken over by out-of-State
banks that already have the resources to conduct bank­
ing business on the large scale demanded by today’s
economy.
Applying the statutory criteria, it is concluded that
the consolidation proposed is in the public interest.
Therefore, the application to consolidate is approved.
J u l y 26, 1971.
SU M M A R Y OF REPORT B Y A T T O R N E Y G EN ER A L

All of First New Haven’ s 21 offices are in New Haven
County, where it has a leading market position. Con­
necticut National Bank operates eight offices in New
Haven County in addition to its 39 offices in Fairfield
County and one in Litchfield County. The main offices
of the consolidating banks are approximately 19 miles
apart. Both banks operate offices in the towns of
Milford and Orange. In addition, Connecticut Na­
tional Bank’s Ansonia office is within 1 mile of the
First New Haven office in Derby. These four towns are
all located between Bridgeport and New Haven. The
application indicates that the bulk of the business of
both banks is derived from those towns in which they
operate offices. It is thus apparent that the proposed
consolidation will eliminate direct competition be­




tween Connecticut National Bank and First New
Haven, particularly in the Orange-Milford-AnsoniaDerby area (total population 97,000).
First New Haven is the second largest of nine com­
mercial banks headquartered in New Haven County.
It holds the largest share of deposits in New Haven
County banking offices, about 24.1 percent, while Con­
necticut National Bank’s eight New Haven County
offices hold about 5.3 percent. If the proposed con­
solidation is approved, the resulting bank would in­
crease its share to 29.4 percent, and the share of the
four leading banks in the county would increase from
68.1 to 73.4 percent.
The effects of the proposed consolidation will be most
immediate in the Orange-Milford-Derby-Ansonia area,
where seven commercial banks operate 16 offices. First
New Haven and Connecticut National Bank hold
39.0 and 19.5 percent (first and second largest shares),
respectively, of the total deposits in these offices. If
the proposed consolidation is approved, the resulting
bank would hold almost 60 percent of commercial
bank deposits in this area, and would operate eight of
its 16 offices.
Connecticut banking law permits statewide de novo
branching into any incorporated city or town which
is not the site of the head office of another bank. Both
Bridgeport and New Haven are presently closed to
de novo entry by new banks. O f a total of 50 towns
in Fairfield and New Haven counties, however, 36,
containing a total population of 680,000, are open to
de novo entry by outside banks.
Five New Haven County towns in which First New
Haven presently operates offices are open to branching
by Connecticut National Bank. In at least three of
these towns, as well as in New Haven itself, First New
Haven holds the leading market position. It may also
be possible for Connecticut National Bank to organize
a holding company and charter a de novo bank in the
city of New Haven.
First New Haven also has branching opportunities
in three towns in northern New Haven County, and
12 towns in Fairfield County in which Connecticut
National Bank presently operates offices. Connecticut
National Bank holds the second largest share of de­
posits, only slightly below the leader, in the immediate
Bridgeport area. It may also be possible for First New
Haven to organize a holding company which could
charter a de novo bank in the city of Bridgeport.
Finally, in the remaining six counties in Connecti­
cut, 103 of a total of 127 towns, containing a popula­
tion of about 870,000, are open to de novo entry by
both Connecticut National Bank and First New

137

to the State as a whole, there is significant potential for
increased competition between Connecticut National
Bank and First New Haven which would be eliminated
by the consolidation.
Because of its elimination of existing and potential
competition between the two banks and the effect on
concentration, we conclude that this consolidation
would have a significantly adverse effect on
competition.

Haven. As the State’s fourth and sixth largest commer­
cial banks, Connecticut National Bank and First New
Haven appear to be two of the most likely de novo en­
trants into these 103 open towns, as well as any that
may become open in the future as a result of mergers.
Each has the resources and ability to open new
branches throughout the State. Thus, whether the im­
pact of the proposed consolidation is considered with
respect to individual towns in the State, or with respect

*

T

he

N

a t io n a l

W

Bank

of

C

a s h in g t o n

o f Se a t t l e , Se a t t l e , W
B a n k , Sp o k a n e , W a s h .

om m erce

T

rust

ash

.,

and

Banking offices
Name of bank and type of transaction

Total assets

In

operation
Washington Trust Bank, Spokane, Wash., with...............................................................
and The National Bank of Commerce of Seattle, Seattle, Wash. (4375), which had.
applied for permission to merge Mar. 9, 1971, under charter and title of the latter
bank (4375). The application was approved Sept. 24, 1971. The pending merger
was challenged by Justice Department Oct. 21, 1971, and is presently in litigation.

c o m p t r o l l e r ’s d e c is io n

On March 9, 1971, Washington Trust Bank, Spo­
kane, Wash., and The National Bank of Commerce of
Seattle, Seattle, Wash., applied to the Comptroller of
the Currency for permission to merge under the char­
ter and with the title of the latter. A public hearing
on this application called by this Office was held in
Portland, Oreg., on July 27, 1971.
The National Bank of Commerce of Seattle, the
charter bank, with total deposits of approximately $1.3
billion, was organized in 1889. It operates through a
statewide network of 104 branches, and is a wholly
owned subsidiary of Marine Bancorporation, a onebank holding company. The charter bank is the only
one of the five largest banks in Washington not repre­
sented in either Spokane, Tacoma, or Everett, three of
the four largest population centers in the State; it can­
not enter those areas with de novo branches because of
the restrictive State laws.
Seattle, the site of the charter bank’s head office, has
a population of 531,000, with 1.3 million persons liv­
ing in the metropolitan area. It is the State’s largest
city. Not only is Seattle the financial, educational, and
cultural center of the Pacific Northwest, but it is the
principal industrial, manufacturing, and wholesale and
retail distributing center as well. Its economy has been
138




$102, 633, 000
1,320,714,000

To be
operated

1
106

dominated, since World War II, by the aerospace in­
dustry, principally, the Boeing Go. It has a fine harbor
and international airport. As a trade center, it is im­
portant as a gateway to Alaska and the Orient. The
economy of the State west of the Cascade Mountain
range, where 76 of the charter bank’s branches are
located, is based on lumbering activity, forest products,
the aerospace industry, manufacturing, and retail and
international commerce.
The charter bank is the second largest bank in the
State. It competes with the Seattle-First National Bank,
the largest bank in the State, with deposits of almost
$2 billion; with the Pacific National Bank of Wash­
ington, the third largest bank in the State, with total
deposits of $659 million; and with the Washington
Mutual Savings Bank, the largest mutual savings bank
in the State, all of which are headquartered in Seattle.
In Seattle there are 10 commercial banks with 106
banking locations and $2 billion in total area deposits.
Seattle-First National Bank leads in Seattle area de­
posits with $783 million; the charter bank is second
with $486 million; Peoples National Bank of Wash­
ington is third with $258 million; Pacific National Bank
of Washington, with $226 million, is fourth; and the
Bank of California branch ranks fifth, with $116 mil­
lion. Savings and loan associations and mutual savings

banks are important competitors for deposits both
statewide and in Seattle, while other financial institu­
tions also offer competition.
Washington Trust Bank, the merging institution,
with total deposits of $87 million, was organized in
1902. All o f its eight branch offices are located in the
Spokane area. While substantial growth has occurred
in the merging bank in the last 10 years, its customers
do not enjoy the more comprehensive services larger
institutions provide.
Spokane, Wash., home of the merging bank, with a
population of 170,516, and a trade area population of
over 1 million, is the second largest city in the State.
Located 288 miles east of Seattle, between the Cascade
Mountain range and the Continental Divide, it is in a
generally arid part of the State. A stable economy has
been produced by diversification among agriculture,
lumbering, light manufacturing, mining, military in­
stallations, and retail and wholesale trade; agriculture
and lumbering have the major roles. The merging
bank, the seventh largest of Washington’s 85 commer­
cial banks, controls 1.6 percent of statewide deposits.
In Spokane there are seven commercial banks with 38
banking locations and $459 million in total deposits. O f
those, Old National Bank of Washington is largest,
with 14 offices and $160 million in total area deposits.
Seattle-First National Bank is second largest, control­
ling $134 million in deposits. The merging institution
is third largest, with $87 million in area deposits. First
National Bank in Spokane is fourth largest, controlling
$37 million in deposits, and is followed by Pacific Na­
tional Bank of Washington with $26 million in deposits,
and American Commercial Bank with $10 million in
deposits. The $5 million Farmers and Merchants Bank
of Rockford, located 18 miles south of Spokane, has an
office in Opportunity, a suburb of Spokane, which
competes with a branch of the merging bank in the
same town.
Any competition which now exists between the par­
ticipating banks in this proposal is de minimus. The
National Bank of Commerce has no branches in the
city of Spokane, and has only two small branches in
Spokane County, located in the small communities of
Deer Park and Medical Lake. Washington Trust Bank
has no offices outside Spokane County. Each branch
of The National Bank of Commerce is located at
least 15 miles from the nearest office of Washington
Trust Bank. A close examination of the business done
by National Bank of Commerce at those two branches
indicates that they cannot realistically be regarded as
providing significant competition to Washington Trust
Bank. The public hearing produced evidence showing

that slightly over one-half of 1 percent of the demand
deposits at Washington Trust Bank have addresses
at Deer Park or Medical Lake. Even less, viz, 0.01 per­
cent of passbook savings at Washington Trust come
from Deer Park and only 0.02 percent come from M ed­
ical Lake. The same general pattern was shown to
be true of loans at Washington Trust Bank. Approxi­
mately 5 percent of the deposits, and less than 3 per­
cent of the loans, at the Deer Park Branch of charter
bank originated within the Spokane city limits. The
evidence showed the figures on the Medical Lake
Branch of charter bank to be slightly higher.
The National Bank of Commerce is prohibited by
the branch banking laws of Washington from de novo
branching into Spokane, or any other city or town in
which any other bank has an office, except Seattle.
Similarly, Washington laws effectively prevent The
National Bank of Commerce from causing a new
Spokane bank to be formed, to later serve as a merger
partner. Any such new bank would, under Washington
law, be prohibited from entering any sale, merger, or
consolidation agreement for not less than 10, and for
as many as 20 years, without prior approval of the
State Supervisor of Banking. Accordingly, the only
available method by which The National Bank of
Commerce can lawfully enter Spokane is by merger
with one of the existing banks; the advisory opinions
on the competitive effects of this merger stress that
such a merger should be with the smallest commercial
bank in Spokane. The smallest bank in Spokane is the
$10 million State-chartered American Commercial
Bank. The evidence received at the public hearing
on this application demonstrated that this small bank,
chartered in 1965, cannot legally merge with any other
bank until it is at least 10 years old.
Another question is whether Washington Trust Bank
may reasonably be expected to enter statewide com ­
petition with The National Bank of Commerce. There
is no evidence that Washington Trust Bank has ever
seriously considered so drastic an expansion of its pres­
ent size and position. It is pertinent that Washington
Trust Bank does not now have any office outside Spo­
kane County, and, indeed, until 1957 it did no branch­
ing even within the city of Spokane. Washington Trust
Bank has no prior merger or acquisition history. It is
prevented by the branch banking laws of Washington
from de novo branching in any city or town, other than
Spokane, in which any other bank now has an office.
The bank’s size and history, together with the barriers
created by the laws of Washington, indicate that
Washington Trust Bank may not realistically be ex­
pected to enter statewide competition with The

139
463-499 0 — 72

-10




National Bank of Commerce within the reasonably
foreseeable future. Accordingly, potential competition
will not be adversely effected by this merger.
Consummation of this proposed merger will serve
the public interest of the Spokane area by bringing,
to the city and its environs, an alternative source of
sophisticated banking services, and by promoting com ­
petition among the financial institutions serving the
area. Evidence adduced at the hearing demonstrated
that the Washington Trust Bank, because of its rela­
tively small size, cannot adequately meet the banking
needs of many Spokane borrowers who, as a result,
have been forced to deal with larger commercial banks.
This merger will not only bring another alternative
source of larger credit to Spokane for the convenience
of potential borrowers, but it will also provide another
source of broad range banking services to all in the area
who have a need. Those expanded services will include
expertise in agricultural and mining loans. Student
loans, economic opportunity loans, low-income hous­
ing lending, SBA loans, and turnkey low-cost housing
construction loans for the elderly will all become avail­
able after the merger. FHA and V A mortgage lend­
ing, which Washington Trust does not now offer its
customers, will also be provided. The National Bank
of Commerce will also bring, to Spokane, considerable
expertise in international banking through its large
international banking department which has offices in
Hong Kong, Singapore, London, Tokyo, and New
York City.
The enhanced competition that this merger will
produce will contribute to the convenience and needs
of bank customers in Spokane, the Spokane area, and,
therefore, the State of Washington. The National Bank
of Commerce alone among the five largest banks of
the State, is now restricted to only one of the four
principal cities of the State. As indicated earlier, the
only method available by which The National Bank
of Commerce may lawfully enter the city of Spokane
is by merger with Washington Trust Bank. In contrast,
the first and third largest banks in the State, SeattleFirst National Bank and the Pacific National Bank of
Washington, are represented in each of the State’s four
principal cities. The other banks in Spokane will be
strengthened by the fact that, because of State laws,
the merged bank will not be permitted to branch de
novo in Spokane. That will enable the locally-based
banks to grow and acquire competitive muscle.
It is concluded that the merger will have no ad­
verse competitive effect, and is in the public interest.
The application is, therefore, approved.
Se p te m

ber

24, 1971.

140



SU M M AR Y OF REPORT B Y A T TO R N E Y GENERAL

National Bank of Commerce of Seattle ( “ NBC” )
operates two branch offices in Spokane County: one
in Deer Park (22 miles north of Spokane), and the
other in Medical Lake (15 miles west of Spokane).
Washington Trust Bank ( “ W TB ” ) draws deposits
from these areas, and there are no banking offices
in the areas between these communities and the
Spokane city limits. Therefore, the proposed merger
will eliminate some existing competition.
Under Washington’s restrictive branch banking
laws, a bank may establish de novo branches only in
the city in which it has its principal place of business,
in unincorporated areas in the county in which it is
headquartered, and in incorporated cities and towns
which do not have a banking office of any commercial
bank. Thus, NBC cannot establish de novo branch
offices in the city of Spokane. Nonetheless, NBC could
acquire the city’s smallest bank, or, through nominees,
it could assist in chartering a new bank in Spokane,
with which it might subsequently merge.
NBC is the second largest of the five statewide banks,
which dominate commercial banking in Washington
and together hold about 75 percent of all commercial
bank deposits. The combined shares of NBC and the
State’ s largest bank exceed 50 percent of such deposits.
NBC’s dominant position is perhaps even greater in
the area surrounding Spokane. NBC is one of the three
major statewide banking organizations which operate
major regional systems in this area and control the
bulk of its deposits, but it is the only one of these three
which does not have offices in the city of Spokane it­
self. In view of the city’ s status as the most important
economic center in the area, NBC has a very great
incentive to enter Spokane in order to make its entire
regional operation more efficient and profitable.
Clearly, NBC is the most significant potential entrant
into the city of Spokane.
Banking in the city of Spokane is highly concen­
trated. Three banking organizations hold over 90
percent of commercial bank deposits in the city, and
operate 85 percent of its banking offices. W TB is the
third largest banking organization in the city, in terms
of deposits in banking offices in the city, and holds
17.6

percent of city deposits. In view of NBC’ s

status as a most significant potential entrant into the
city o f Spokane, and the substantial position held by
W TB, it is clear that the proposed merger would result
in the loss of significant potential competition in
Spokane.

The proposed merger would also eliminate W TB
as a most significant potential entrant into other areas
of eastern Washington which surround Spokane, and
in which NBC is a major existing competitor. M ore­
over, in combination with one or more middle-sized
banks located elsewhere in the State, W TB could orga­
nize a new statewide banking organization able to com­
pete throughout the State with the five present leaders.
Since Washington is characterized both by substantial
statewide concentration and substantial concentration
in every local market, the loss of such a potential
for deconcentration has significant adverse economic
effects.
Finally, NBC is one of two banks which dominate
correspondent services in Washington. W TB presently
holds a very small share, but it does appear to offer
correspondent services to at least six of the 18 inde­
pendent banks operating in eastern Washington. Given
*

that base, it would appear that W TB is either a pres­
ent competitor or is on the threshold of being one in
providing general correspondent services to small banks
in Washington. Its acquisition by one of the two domi­
nant firms in this field will also produce a substantial
anticompetitive effect.
T o summarize, this merger will eliminate actual and
potential competition in commercial banking between
the merging banks in the city and county of Spokane,
the eastern portion of the State of Washington, and
the State as a whole, and will have similarly anti­
competitive effects in correspondent services. Also,
the trend of consolidations among leading banks in
the State, of which this merger is but the most recent
example, is likely to be further stimulated. W e con­
clude that this merger would have a significantly ad­
verse effect on competition.
*

*

Seattle -F irst N ational Bank , Seattle , W ash ., and T he First N ational Bank of Ferndale ,
Ferndale , W ash .

Banking offices
Name of bank and type of transaction

Total assets

Seattle-First National Bank, Seattle, Wash. (11280), with.....................................
applied June 15, 1971, for permission to purchase The First National Bank of
Ferndale, Ferndale, Wash. (11667), which had..................................................................
The application was approved Oct. 29, 1971. The pending purchase was chal­
lenged by Justice Department Nov. 26, 1971, and is presently in litigation.............

c o m p t r o l l e r ' s d e c isio n

On June 17, 1971, Seattle-First National Bank,
Seattle, Wash., applied to the Comptroller of the Cur­
rency for permission to purchase the assets and assume
the liabilities of The First National Bank of Ferndale,
Ferndale, Wash.
The Seattle-First National Bank, the applicant, was
organized in 1870, and through its statewide network
of 142 branches holds total deposits of $1.97 billion.
The bank has followed a policy of aggressive branch
expansion but often has been hampered by a restrictive
State law that prohibits de novo branching outside the
bank’s home county and into any community in which
another bank has its main office.
Seattle, the service area of the applicant, is the cen­
ter of commerce in the northwest. The economy of
this area has suffered considerably as a result of the
recent troubles of the aerospace industry. Conse­




To be
operated

In
operation

$2, 447, 138, 000

143

10, 807, 000

1

quently, the unemployment rate for the Seattle M etro­
politan Area is presently 16 percent.
First National Bank of Ferndale, the selling bank,
was chartered in 1904. With total deposits of $10
million, the bank is considered to be financially sound.
The single office of the selling bank is located in Fern­
dale, Wash., a small town of 2,100 inhabitants. Its
economy, although chiefly agricultural, shows signs of
industrial development.
Applicant’s branch nearest to Ferndale is located
12 miles southeast, in the town of Bellingham. The
selling bank’s chief competition stems from the Fern­
dale branch of The Bellingham National Bank, a bank
holding deposits of $30.1 million. The Bellingham Na­
tional Bank is planning to relocate its present branch
in Ferndale to a more advantageous location in that
town.
Consummation of the proposed acquisition will have
no adverse competitive effect. As the nearest office of

141

mote its service, FNB Ferndale can increase its com ­
petition with Seattle-First’s office and the other
banking offices in Bellingham.
In addition, FNB Ferndale provides the only foot­
hold by which major banks in the State not serving the
urbanized, industrial areas of W hatcom County could
enter the county. It is also one o f the few vehicles
through which major banks not in this area can market
their services. Hence, this merger also serves to fore­
close a substantial source o f potential competition.
Six commercial banks operate 15 banking offices in
Whatcom County. The three largest banks are Na­
tional Bank of Commerce (the second largest bank in
the State, with four branches in Whatcom County),
Bellingham National Bank (headquartered in Belling­
ham with five offices in the county), and Seattle-First;
together these three banks held about 76 percent of
total deposits in the county, as of June 30, 1970. Seat­
tle-First’s two branches held about 21.6 percent of
county deposits, while FNB Ferndale, the fifth largest
bank in the county, held about 7.2 percent of such de­
posits. Thus, if this merger is consummated, the result­
ing institution would hold the second largest share of
county deposits, 28.8 percent, and the three largest
banks in the county would hold 83.2 percent of such
deposits.
It should be noted that W hatcom County is an un­
realistically large geographic market in which to as­
sess the competitive effects of this transaction. But us­
ing a more limited area such as the western half of the
county would not significantly change the above con­
centration figures (the three largest banks in this area
have 74.9 percent, Seattle-First has 20.8 percent and
FNB Ferndale has 7.5 percent).

the applicant is 12 miles from the selling bank’s single
office, the service areas, because of natural barriers, do
not overlap. There is no meaningful degree of actual
competition between the two banks. Furthermore, the
introduction into Ferndale of the applicant will result
in the offering of many new and sophisticated bank­
ing services to area residents, including trust services,
a credit card system, and FH A and V A mortgage
lending. O f great importance is the fact that the pro­
posed acquisition will solve the critical management
succession problem that prompted the controlling
shareholders to offer to sell The First National Bank
of Ferndale.
In view of the above considerations, the proposed
acquisition is in the public interest and is, therefore,
approved.
O c t o b e r 29, 1971.
SU M M AR Y OF REPORT B Y A T TO R N E Y G ENERAL

Seattle-First operates two offices in Whatcom
County, one in Sumas and one in Bellingham. The
Sumas branch is located 27 miles east of Ferndale;
there is only a slight competitive overlap between this
branch and FNB Ferndale. The Bellingham branch is
located only 10 miles southeast of Ferndale and, as o f
June 30, 1970, was the largest single banking office in
Whatcom County ($22.3 million in total deposits).
While there are offices of other banks located be­
tween, or in the immediate proximity of the Belling­
ham branch and FNB Ferndale, each presently draws
a not insubstantial amount of business from the other’s
area. In addition, a number of people live in either
Bellingham or Ferndale and commute to work in the
other city. This factor, in addition to the short distance
between these two offices, indicates that they are pre­
sently alternative sources of banking to people in their
area. As the area undergoes further industrialization
and as population continues to increase, this commuta­
tion will likely increase, as will the degree of competi­
tion between the two banks. Thus, this transaction will
result in the elimination o f direct competition. Further­
more, by branching into unincorporated areas around
Bellingham, a n d /or by using Bellingham media to pro*

142



Commercial banking in either W hatcom County as
a whole, or in the western section o f the county, is
highly concentrated. The effect of this transaction
would be to eliminate existing competition and to sub­
stantially increase the level of concentration in these
areas, and to foreclose the potential for new entry by
other banks in the State. Consequently, we conclude
that this transaction would have a significantly ad­
verse effect on competition.
*

*

B. A pproved, but abandoned after litigation
O ld N ational Bank of W ashington , Spokane , W ash ., and O roville State Bank , O roville , W ash .

Banking offices
Total assets

Name of bank and type of transaction

Oroville State Bank Oroville, Wash, with...........................................................................
and Old National Bank of Washington, Spokane, Wash. (4668), which had...........
applied for permission to merge Jan. 4, 1971, under charter and title of the latter
bank (4668). The application was approved Apr. 27, 1971, but was abandoned by
the banks June 25 1971 after filing of antitrust suit by the Justice Department..

c o m p t r o l l e r ’s

d e c is io n

On January 4, 1971, Oroville State Bank, Oroville,
Wash, and Old National Bank of Washington, Spo­
kane, Wash., applied to the Comptroller of the Cur­
rency for permission to merge under the charter and
with the title of the latter.
Old National Bank of Washington, the charter bank,
with IPC deposits of $268.3 million, was organized in
1891, and presently operates 44 branches in various
parts of the State, 16 of which are in Spokane. This
bank is a full-service institution and the fifth largest
bank in the State in terms of the deposits, controlling
5.5 percent of the State’s total. It is controlled by Wash­
ington Bancshares, Inc., Spokane, a registered bank
holding company which owns 98.37 percent of its out­
standing shares. The charter bank is an aggressive
competitor.
Spokane, home of the charter bank and the center of
its service area in eastern Washington, is the recognized
capital and, with a population of 169,000 in the
city, and 700,000 in its retail trade area, the largest
city in the Inland Empire, an area encompassing
eastern Washington, northern Idaho, and western
Montana. The Inland Empire, with a population of
almost 1.2 million is a unique area, bounded on the
west by the Cascade Mountain Range, on the north
by the Canadian border, on the east by the Rockies and
Bitterroot Mountains, and on the south by the Blue
Mountains. The nucleus of the economy is provided
by forest products, mining, and agriculture. The
Columbia Basin Project, lying within the Inland Em­
pire, is located in east-central Washington. M anufac­
turing is important to the metropolitan Spokane area,
with 350 manufacturing establishments in the area.
There are a number of retail trade outlets and whole­
sale establishments in this area. Mining is also a factor
in the Inland Empire area. In Seattle, where two of the




$6,713, 115
336, 687, 238

In
operation

To be
operated

1
46

charter bank’s branches are located, the aerospace and
aircraft industries are important; however, due to cut­
backs in these industries, the economy is depressed.
Statewide, as noted above, the charter bank is fifth
largest, with $276 million in total deposits, ranking
behind the Seattle-First National Bank, with $1.7 bil­
lion in total deposits; The National Bank of Commerce
of Seattle, with deposits of slightly over $1 billion;
Pacific National Bank of Washington, with deposits of
$566 million; and the Peoples National Bank of Wash­
ington, with deposits of $369 million. The Puget Sound
National Bank, with deposits of $179 million, is the
State’s sixth largest bank. In Spokane, the charter bank
competes with offices of the Seattle-First National
Bank; Washington Trust Bank, Spokane; the First Na­
tional Bank in Spokane; the Pacific National Bank of
Washington, Seattle; and the American Commercial
Bank, Spokane. Other financial institutions also com­
pete in Washington and in the charter bank’s service
area.
Oroville State Bank, the merging bank, with IPC
deposits of $5.7 million, was organized in 1942, and is
a unit bank. Its lending limit is inadequate to handle
the needs of larger borrowers within the area.
Oroville, home of the merging bank, is located some
200 miles northwest of the charter bank’s head office
city, 17 miles northwest of its nearest branch office
in Tonasket, and approximately 4 miles south of the
Canadian border on Highway 97. Oroville is at the
confluence of the Similkameen and Okanogan rivers.
Its population is 1,500, while its trade area population
is 4,500. Oroville is the headquarters of the sprawling
Tonasket-Oroville irrigation district, encompassing
about 9,000 acres with some 400,000 apple trees.
Growing, harvesting, and warehousing of apples is the
basis for approximately 75 percent of the economy, with
livestock adding 15 percent, and lumbering the remain­
ing 10 percent.

143

better serve customers of the Tonasket bank who lived
in the Oroville area. Even today over 10 percent of
the Tonasket office’s deposits come from the Oroville
postal area. No banking office exists in the intervening
area.
Until recently, no banking competition was possible
in the Oroville-Tonasket area. The dissolution of the
common ownership ties between the Oroville and
Tonasket offices has created some banking competi­
tion in the area although the service areas of the two
banking offices might be more accurately described as
contiguous, and to some extent overlapping, rather
than coextensive. Most importantly, O ld National
Bank’s Tonasket office is the only banking alternative
within 40 miles of Oroville. Given the relative dis­
tances, it is apparent that this acquisition would elim­
inate the only reasonable banking alternatives in the
Oroville-Tonasket area of Okanogan County and this
would substantially eliminate any competition for the
banking business in Oroville and Tonasket.
Banking in Washington, as a whole, is dominated
by a few large organizations; the five largest organi­
zations control over 75 percent of all commercial bank
deposits in the State. Old National Bank is among
these market leaders, ranking fifth. In Okanogan
County, it has already acquired two banks with com ­
bined deposits of almost $14 million. The offices now
controlled by Old National Bank, as of June 30, 1970,
held over 30 percent of all commercial bank deposits
in the county. T w o other of the major banks in the
State controlled 50 percent of such deposits in the
county, and Oroville State Bank held most of the
rest of the deposits, some 16 percent.
This merger thus would increase Old National
Bank’s share of county deposits to 46 percent, and the
combined control of the three major statewide banks
to 97 percent. In the Oroville-Tonasket area, Old
National Bank would control 100 percent of all com ­

The nearest branch to Oroville is the branch of the
charter bank in Tonasket, 14 miles south. The nearest
branch of any other bank is a branch of the SeattleFirst National Bank in Omak, 42 miles south o f O ro­
ville and 25 miles south of Tonasket.
The merger will benefit the community of Oroville
by introducing a bank more capable of effectively
servicing the credit needs of that community, and by
offering specialized agricultural lending. The com ­
munity will be afforded the benefit of trust services
and a credit card program. Old National’s manage­
ment trainee program will provide for future and
successor management at branches of the merging
bank.
Competition will not be adversely affected. Because
the nearest office of the charter bank is 17 miles away,
there is little present competition to be eliminated be­
tween the two banks. In Oroville, the merging institu­
tion will be replaced by offices of the charter bank
and competition will not be affected. In the present
service area of the charter bank the addition of the
much smaller merging institution would have a
negligible effect. Statewide, the charter bank’s share
of loans and deposits would increase by an insignificant
0.1 percent and 0.2 percent, respectively, while its
position as fifth largest bank in the State of Washing­
ton will remain unchanged.
Applying the statutory criteria, we conclude the
proposal is in the public interest. The application is,
therefore, approved.
A pril 27,1971.
SU M M AR Y OF REPORT BY A T TO R N E Y G ENER AL

In the past year, Old National Bank has acquired
First National Bank of Tonasket, and Commercial
Bank of Washington, both of which operated offices in
Okanogan County.
Until Old National Bank absorbed First National
Bank in Tonasket, that bank and Oroville State Bank
had been commonly owned; since then, Old National
Bank and Oroville State Bank have been competitors.

mercial bank deposits.
We conclude that the proposed merger will result
in a monopoly in the Tonasket-Oroville area and hence
will have an adverse effect on competition.

Oroville State Bank was originally established to

*

144



*

*

C. Approved, but abandoned, no litigation
P a c if ic

N

a t io n a l

Bank

of

W

a s h in g t o n

, Se

a ttle

, W

ash

.,

and

Bo

th ell

St a

te

Ban

k

, Bo

th e ll

, W

ash

.

Banking offices
Total assets

Name of bank and type of transaction

Bothell State Bank Bothell Wash, with
.....................................................
and Pacific National Bank of Washington, Seattle Wash. (3417), which had.........
applied for permission to merge Apr. 22, 1971, under charter and title of the latter
bank (3417). The application was approved Aug. 5, 1971, but was abandoned by
the banks Dec 1 1971
............................................................................

c o m p t r o l l e r ’s

d e c is io n

On April 22, 1971, Bothell State Bank, Bothell,
Wash., and Pacific National Bank of Washington,
Seattle, Wash., applied to the Office of the Comptrol­
ler of the Currency for permission to merge under the
charter and with the title of the latter.
The Pacific National Bank of Washington, the char­
ter bank, with total deposits of $630 million, has its
head office in Seattle, Wash. It operates 61 branches
and two facilities, with three approved but unopened
branches; approximately two-thirds of the branches
are centered in King and Pierce counties, in western
Washington. The primary service area of the charter
bank, as a result of the concentration of its branches, is
in King County, around Seattle, and in Pierce County,
around Tacoma. The population of those two coun­
ties comprises 46 percent of the State’s total popula­
tion, which exceeds 3 million. A heavy concentration
of industries oriented toward aerospace, shipbuilding,
and natural resources is centered in this two-county
area. That area is experiencing a severe recession at
the present time, directly attributable to cutbacks in
the construction and aerospace industries. Unemploy­
ment in the Seattle area is the highest of that in any
major city in the Nation.
The Pacific National Bank of Washington is one
of 19 commercial banks operating in King County, and
one of nine commercial banks operating in Pierce
County. Among its competitors are the $1,975 billion
Seattle-First National Bank, the largest in the State;
the $1,128 billion National Bank of Commerce of
Seattle; and the $414 million Peoples National Bank
of Washington, the State’s fourth largest bank.
Bothell State Bank, the merging bank, has deposits
of $13 million, and maintains its head office in Both­
ell, Wash., which is situated 16 miles northeast of the
charter bank’s head office. The merging bank was or­




$15,503,000
766, 353,000

In
operation

To be
operated

4
62

ganized in 1908, and has remained a closely held cor­
poration since that time; the family that has owned 95
percent of the stock has provided management since
its founding. The recent death, in Vietnam, of the heir
apparent, has created a serious management problem
for the bank. The city of Bothell is located in King
County and is considered a part of metropolitan Se­
attle. While the distance between the cities is only 16
miles, Lake Washington forms a natural barrier be­
tween the two areas. The city of Bothell has a present
population of 4,883, and a service area population of
39,500. The service area is primarily residential, pro­
viding a “ bedroom” community for people employed
in Seattle and Everett. Its commercial activity is lim­
ited to small, strip-type developments to serve local
community needs. The city is surrounded by a large
unincorporated area of King County that is sparsely
populated. It would seem certain that a resurgence of
the Seattle economy will contribute to future develop­
ment of all unincorporated areas in King County.
The primary competition for the merging bank is
from the Northshore First National Bank in Bothell.
There are no branches of the charter bank within the
city of Bothell because State law prevents de novo
branch banking in incorporated cities where a main
office of a bank is domiciled. Competition will not be
adversely effected by the consummation of the pro­
posed merger. Because the nearest office of the char­
ter bank is some 6 miles from the merging bank, com ­
petition between the two is minimal.
The greater resources and expanded services that
will be provided by the resulting bank will benefit the
residents of Bothell and will resolve the management
problem. In the service area of the charter bank, the
addition to it of the much smaller merging institu­
tion will have only a negligible competitive effect.
The charter bank’s State ranking will be unaffected by
the merger.
145

Applying the statutory criteria, it is concluded that
the merger proposal is in the public interest and is,
therefore, approved.
A u g u s t 5, 1971.
SUM M ARY OF REPORT B Y A T TO R N E Y GENERAL

Pacific National has branches located on three sides
of the Bothell area. The nearest offices of Pacific Na­
tional and Bothell Bank are 6 miles apart, but they
are separated by a ridge of land and direct connec­
tions are difficult. Pacific National also has offices 10
miles south and 15 miles north of Bothell Bank’s
offices. In each case, other banks have offices in the
intervening area. Applicants contend, moreover, that
the Pacific National draws almost no deposits from
the Bothell area. Nevertheless, considering the mobility
of the King County residents, it is likely that the pro­
posed merger may eliminate some existing competition.
Pacific National holds over 11 percent of deposits
in commercial banking offices in King County, while
Bothell Bank holds less than 1 percent. However, King
County would appear to overstate the geographic
area of any appropriate market in which to measure
the competitive effects of the proposed merger.
King County and the State of Washington each
have a highly concentrated banking structure. Four
banks, including Pacific National, dominate banking
in King County. The five largest banks in Washing­
ton, including Pacific National, hold over 75 percent
of total bank deposits.
Even under Washington’s restrictive branch bank­
ing 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 is
headquartered, and in incorporated cities and towns
which do not have a banking office o f any commercial
bank. Hence, although neither of the merging banks
can establish a branch in the headquarters city of the
other, they can expand into the unincorporated areas
of King County served by each other. Furthermore,
both Pacific National and Bothell Bank have demon­
strated an interest in and ability to expand de novo into
the unincorporated areas of King County.
In the Bothell area, much of which is unincorpo­
rated, Bothell Bank holds about 50 percent of all bank
deposits. This area is also served by one small independ­
ent bank and branches of the two largest banks in King
County and in the State. In addition, a smaller bank,
based in Bellevue, has a branch in the area. Pacific
National is the largest of three banks over $100 million
in deposits eligible to branch into the Bothell area; the
next largest holds less than $17 million. In addition,
both banks are opening new offices in the area south
of Bothell and east of Lake Washington; they are,
therefore, potential competitors in that area as well.
Thus, the proposed merger would eliminate a sub­
stantial potential for increased competition in the de­
veloping unincorporated areas of King County,
especially the northeastern section of the county.
This merger would eliminate some existing competi­
tion and substantial potential competition in King
County, particularly in the Bothell area. Also, the
proposed merger would continue the concentration of
the State’s banking resources in its very largest banks.
We conclude that the proposed merger will have an
adverse effect on competition.
*

146







APPENDIX B

Statistical Tables

Statistical Tables
Table No.
R -l
B -2

B -3
R-4
B -5
Br-6
B-7

B~8
B -9

B -10
B -l 1
B -l2
B -l3
B -l4
B -l5
B -l6
B -l7
B -l8
B -l9
B-20

Title

Comptrollers of the Currency, 1863 to the
present........................................................................
Administrative Assistants to the Comptroller of
Currency and Deputy Comptrollers of the
Currency....................................................................
Regional Administrators of National banks.........
Changes in the structure of the National Bank­
ing System, by States, 1863-1971 .......................
Charters, liquidations, and changes in issued
capital stock of National banks, calendar 1971.
Applications for National bank charters, ap­
proved and rejected, by States, calendar 1971.
Applications for National bank charters, by
States, pursuant to corporate reorganization,
calendar 1971............................................................
Newly organized National banks, by States,
calendar 1971...............
National bank charters issued and mergers con­
summated pursuant to corporate reorganiza­
tions, by States, calendar 1971...........................
State-chartered banks converted to National
banks, by States, calendar 1971..........................
National bank charters issued pursuant to corpo­
rate reorganizations, by States, calendar 19 71 ..
National banks reported in voluntary liquida­
tion, by States, calendar 1971..............................
National banks merged or consolidated with
State banks, by States, calendar 1971...............
National banks converted into State banks, by
States, calendar 1971..............................................
Purchases of State banks by National banks, by
States, calendar 1971..............................................
Consolidations of National banks, or National
and State banks, by States, calendar 1 9 7 1 ... .
Mergers of National banks, or National and
State banks, by States, calendar 1971...............
Mergers resulting in National banks, by assets
of acquiring and acquired banks, 1960-1971.
Domestic branches entering the National Bank­
ing System, by
opening, merger, or
conversion, by States, calendar 1971................
Domestic branches of National banks closed, by
States, calendar 1971..............................................

Page
149

B-22
150
151

B-23

152

B-24

153

B-25

154

B-26
B-27

156
B -28
157
B-29
158

B -30

161

B-31

162

B-32

163

B~33

164

B-34

165

B-35

166

B-36

167

B-3 7

168

B-38

171

de novo

148




Table No.
B-21

B-39
B-40

171
B—
41
181

Title

Outstanding balances, credit cards and related
plans of National banks, Dec. 31, 1971............
Principal assets, liabilities, and capital accounts
of National banks, by deposit size, year-end
1970 and 1971............................................................
Dates of reports of condition of National banks,
1914-71........................................................................
Total and principal assets of National banks, by
States, June 30, 1971...............................................
Total and principal liabilities of National banks,
by States, June 30, 1971........................................
Capital accounts of National banks, by States,
June 30, 1971............................................................
Total and principal assets of National banks, by
States, Dec. 31, 1971...............................................
Total and principal liabilities of National banks,
by States, Dec. 31, 1971........................................
Capital accounts of National banks, by States,
Dec. 31, 1971.............................................................
Loans of National banks, by States, Dec. 31,
1971
.....................................................................
Income and expenses of National banks, by
States, year ended Dec. 31, 1971........................
Income and expenses of National banks, by
deposit size, year ended Dec. 31, 1971..............
Capital accounts, net income, and dividends of
National banks, 1944-71.......................................
Loan losses and recoveries of National banks,
1945-71.......................................................................
Securities losses and recoveries of National banks,
1 9 4 5 -7 1 ... . ...........................
Assets and liabilities of National banks, date of
last report of condition, 1950-71.........................
Foreign branches of National banks, by region
and country, Dec. 31, 1971...................................
Total assets of foreign branches of National
banks, year-end 1953-71......................................
Foreign branches of National banks, 1 9 6 0 -7 1 ...
Assets and liabilities of National banks, Dec. 31,
1971: consolidated statement...............................
Trust assets and income of National banks, by
States, calendar 1971...............................................

Page
183

184
185
187
188
189
190
191
192
193
194
206
208
209
209
210
211
212
212
212
213

T able 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 ........................................................................................
McIntosh, Joseph W .................................................................................
Pole, John W ...............................................................................................
O ’ Connor, J. F. T .....................................................................................
Delano, Preston...........................................................................................
Gidney, Ray M ...........................................................................................
Saxon, James J ............................................................................................
Camp William B .......................................................................................




Date of
appointment
May
Mar.
Feb.
Apr.
May
Apr.
May
Aug.
Apr.
Jan.
Oct.
Apr.
Feb.
Mar.
May
Dec.
Nov.
May
Oct.
Apr.
Nov.
Nov.

9,
21,
1,
25,
12,
20,
1,
2,
26,
1,
1,
27,
2,
17,
1,
20,
21,
11,
24,
16,
16,
16,

1863
1865
1867
1872
1884
1886
1889
1892
1893
1898
1901
1908
1914
1921
1923
1924
1928
1933
1938
1953
1961
1966

Date of
resignation
Mar.
July
Apr.
Apr.
Mar.
Apr.
June
Apr.
Dec.
Sept.
Mar.
Apr.
Mar.
Apr.
Dec.
Nov.
Sept.
Apr.
Feb.
Nov.
Nov.

8,
24,
3,
30,
1,
30,
30,
25,
31,
30,
28,
27,
2,
30,
17,
20,
20,
16,
15,
15,
15,

1865
1866
1872
1884
1886
1889
1892
1893
1897
1901
1908
1913
1921
1923
1924
1928
1932
1938
1953
1961
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.

149

T able

B-2

Administrative Assistants to the Comptroller of the Currency and Deputy Comptrollers of the Currency

No.

Name

Dates of tenure

State

ADMINISTRATIVE ASSISTANTS TO THE COMPTROLLER
1
2
3
4
5
6

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.

May
Aug.
Mar.
Aug.
Jan.
Jan.
Aug.
Apr.
Mar.
Sept.
June
July
May
July
Jan.
July
July
Dec.
Jan.
Feb.
Jan.
Jan.
Oct.
May
July
Sept.
Oct.
Jan.
Sept.
Mar.
Feb.
Sept.
May
Apr.
Aug.
Sept.
Dec.
Jan.
July
Sept.
Sept.
July
July
Feb.

9,
1,
12,
8,
5,
27,
11,
7,
12,
1,
29,
1,
21,
1,
6,
1,
6,
1,
24,
24,
16,
16,
1,
1,
7,
1,
1,
1,
1,
1,
18,
15,
16,
2,
4,
3,
23,
1,
13,
1,
1,
19,
1,
21,

1863
1865
1867
1872
1886
1887
1890
1893
1896
1898
1899
1908
1923
1923
1925
1927
1927
1928
1933
1936
1938
1938
1938
1939
1941
1941
1944
1949
1950
1951
1952
1959
1960
1962
1962
1962
1962
1963
1964
1964
1964
1965
1966
1967

Aug.
Jan.
Apr.
Jan.
Jan.
May
Mar.
Mar.
Aug.
June
Mar.
Feb.
Dec.
June
Nov.
Feb.
Oct.
Jan.
Jan.
Jan.
Sept.
Sept.
Dec.
Aug.
Mar.
Sept.
Feb.
Aug.
May
Apr.
Dec.
Aug.
Aug.
Nov.
Oct.

1,
31,
24,
3,
3,
25,
16,
11,
31,
27,
2,
14,
19,
30,
30,
15,
16,
23,
15,
15,
30,
30,
31,
31,
1,
30,
17,
31,
16,
1,
31,
31,
3,
15,
26,

1865
1867
1872
1886
1887
1890
1893
1896
1898
1899
1923
1927
1924
1927
1928
1936
1941
1933
1938
1938
1938
1938
1948
1941
1951
1944
1952
1950
1960
1962
1962
1962
1962
1966
1963

New York.
Ohio.
Minnesota.
New York.
New York.
Virginia.
Indiana.
Kentucky.
South Carolina.
New York.
Dist. of Columbia.
Indiana.
Illinois.
Illinois.
Virginia.
Maryland.
Indiana.
Washington.
Georgia.
California.
Texas.
California.
Iowa.
Iowa.
Iowa.
Nebraska.
Nebraska.
Texas.
New York.
Virginia.
Colorado.
Ohio.
Missouri.
Texas.
Connecticut.
Ohio.
Iowa.
Virginia.
Iowa.
Massachusetts.
Wisconsin.
Louisiana.
Ohio.
Mississippi.

DEPUTY COMPTROLLERS OF THE CURRENCY
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44

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 ...............................................................................................
McIntosh, Joseph W .....................................................................................
Collins, Charles W .........................................................................................
Stearns, E. W ...................................................................................................
Await, F. G ......................................................................................................
Gough, E. H ....................................................................................................
Proctor, John L ...............................................................................................
Lyons, Gibbs....................................................................................................
Prentiss, William, J r.....................................................................................
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, Tohn D ..................................................................................................

150




June 30, 1966
June

1, 1967

T ab le B -3

Regional Administrators of National banks

Name

Headquarters

1

John L. Donovan......................

Boston, Mass.............................

2
3
4
5

Charles M . Van Horn.............
R. Coleman Egertson..............
John W . Shaffer, Jr.................
Page Cranford...........................

New York, N .Y .......................
Philadelphia, Pa......................
Cleveland, O hio......................
Richmond, V a .........................

6
7
8
9
10
11
12
13
14

Joseph M . Ream ......................
Joseph G. Lutz..........................
Kenneth W . Leaf......................
Donald B. Smith.......................
John R. Burt..............................
Michael Doman........................
John R. Thomas.......................
H. Joe Selby...............................
Arnold E. Larson......................

Atlanta, G a ...............................
Chicago, 111...............................
Memphis, Tenn.......................
Minneapolis, M in n ................
Kansas City, M o .....................
Dallas, T ex ................................
Denver, Colo............................
Portland, O re...........................
San Francisco, Calif...............

Region




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

1ft1

T able B -4
Changes in the structure of the National Banking System, by States, 1863-1971

Organized
and opened
for busi­
ness 18631971

Consolidated and merged
under 12 U.S.C. 215
Consoli­
dated

12 U.S.C. 214
Insol­
vencies

Merged

Liqui­
dated

In
operation
Merged or Dec. 31,
Converted to consolidated 1971
State banks with State
banks

United States......................

15, 929

715

542

2, 821

6, 748

180

323

4, 600

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

204
8
33
166
608
272
137
32
39
318

4
0
1
1
21
5
11
0
8
2

4
0
0
2
47
0
8
0
0
1

45
0
6
39
66
57
7
1
7
43

63
2
21
55
394
86
69
18
13
42

0
0
1
0
4
2
1
0
0
0

0
1
1
0
19
0
15
8
0
0

88
5
3
69
57
122
26
5
11
230

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

209
7
112
985
450
565
459
250
123
128

8
1
0
20
14
4
6
11
4
8

4
0
2
9
5
2
2
2
1
8

42
0
35
227
98
205
77
37
16
13

87
4
65
299
205
243
198
110
53
79

8
1
1
14
2
11
5
8
0
0

0
0
2
1
4
1
0
2
0
1

60
1
7
415
122
99
171
80
49
19

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

157
390
358
519
100
332
209
413
18
86

3
42
11
8
5
13
4
2
1
3

17
16
4
0
4
10
1
1
0
7

17
28
77
116
16
58
76
83
4
5

69
208
157
193
35
148
76
199
8
23

1
1
0
4
2
4
0
3
0
0

11
11
5
0
0
1
0
0
1
0

39
84
104
198
38
98
52
125
4
48

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

467
97
1,031
164
263
730
782
153
1,295
70

54
1
126
8
3
32
12
2
108
3

54
1
80
22
0
24
6
3
100
2

60
25
130
44
100
112
85
31
211
2

153
37
441
58
118
336
454
103
494
58

1
0
12
0
0
2
28
0
8
0

25
0
76
9
0
6
0
6
88
0

120
33
166
23
42
218
197
8
286
5

South Carolina................................
South Dakota...................................
Tennessee...........................................
Texas..................................................
U tah....................................................
Vermont............................................
Virginia.............................................
Washington......................................
West Virginia...................................
Wisconsin..........................................
Wyom ing...........................................
Virgin Islands..................................
Puerto R ico......................................

137
224
222
1,353
46
85
289
245
203
304
80
1
1

8
14
9
45
4
3
23
19
11
9
0
0
0

13
2
2
13
0
3
51
9
0
0
0
0
0

43
93
36
142
6
17
28
51
38
54
12
0
0

49
81
94
574
22
29
74
141
68
115
26
0
1

1
2
2
45
3
1
2
0
0
0
0
0

4
0
2
4
2
6
10
1
0
0
0
0
0

19
32
77
530
9
26
101
24
86
126
42
1
0

152




0

T able B-5
Charters, liquidations, and changes in issued capital stock of National banks, calendar 1971

Number of
banks

Capital stock
Common

Preferred

Capital notes and
debentures

Increases:
Banks newly chartered:
........................................................
Conversions of State banks..................................................

66*
10

P rim ary organ ization

Capital stock:
Preferred: 7 cases by new issue..........................................
Common:
445 cases by statutory sale..........................................
600 cases by statutory stock dividends....................
5 rases b y statutory c o n s o lid a tio n ..............................
25 cases by statutory m e rg e r ........................................
6 cases by conversion of preferred stock.................
41 rases b y con version o f cap ital n o te s....................
Capital notes and debentures: 153 cases by new issue........

22, 622, 503
3, 352, 490

2, 432, 200
77,
234,
8,
8,

996, 684
137, 329
823, 125
370,416
21,457
1, 535, 707
356, 707, 452

76

Total increases...........................................................
Decreases:
Banks ceasing operations:
Voluntary liquidations:
Succeeded by National banks....................................
Succeeded by State banks..........................................
Statutory consolidations.......................................................
Statutory m ergers
...............................
Converted into State banks
......................................
Merged or consolidated with State banks......................
Insolvent...................................................................................
Capital stock:
Preferred: 12 retired..............................................................
Common:
5 cases by statutory reduction...................................
2 rases by statutory ron solid ation
...
10 cases by statutory merger. .
........................
Capital notes and debentures:
43 retirements.................................................................
34 converted to common stock..................................

4
3
5
53|
21
10
1

356, 859,711

2, 432, 200

356, 707, 452

800, 000
1,030, 398

10, 046, 000
3, 080, 568
50, 000
21,253, 873
696, 000
2, 641,485
9, 736, 135
6, 563,412
5, 348, 452

Total decreases..........................................................

97

28, 080, 586

21, 253, 873

11,911,864

Net change........................................................................................
Charters in force Dec. 31, 1970, and issued capital.............

— 21
4, 629

328, 779, 125
6, 438, 119, 253

— 18, 821,673
62, 673, 634

344, 795, 588
1, 172, 368, 627

Charters in force Dec. 31, 1971, and issued capital.............

4, 608

6, 766, 898, 378

43, 851,961

1, 517, 164, 215

♦Includes 29 reorganized banks with capital stock of $4,302,502.
flncludes 29 reorganized banks.
N

ote:

Premium on sale of common stock........................ $224,030,098 (437 cases)
Premium on sale of convertible notes....................
5,200,193 ( 41 cases)
Total................................................................... $229,230,291
(478 cases)




153

T able B-6
Applications f o r National bank charters, approved and rejected , by States, calendar 1971 *

ALABAMA
Cheaha National Bank, Oxford

Approved Rejected
Jan.

IOWA

Arnolds Park.......................................................
The Lakes National Bank, Arnolds Park. . Sept. 29

18 ...............

CALIFORNIA
Los Angeles.............................................................................. Mar. 24
Santa Rosa.............................................................................. Oct.
1
Gavilan National Bank, Gilroy..................... Nov. 17 ................

COLORADO
Arvada......................................................................................
Broomfield...............................................................................
Westland National Bank, Longmont........... Apr. 13
Denver.......................................................................................
Aurora.......................................................................................
Unincorporated Area of Arapahoe County..................
Castle Rock.............................................................................

Mar. 5
Apr. 13
................
Apr. 27
May 19
Aug. 6
Nov. 8

CONNECTICUT
East Hartford.......................................................................... May 17
Liberty National Bank, Stamford................. Sept. 20 ................

FLORIDA
First National Bank of Palm Beach Gar­
dens................................................................... Jan. 27
Longwood..............................................................................
Hobe Sound National Bank, Unincorpo­
rated Area of Martin County....................Feb, 12
Naples................
Naples................
Boca Raton. . . .
Boca R aton .. . .
Deerfield Beach
Deerfield Beach
Bradenton.........
North Miami. .
Village Plaza Palmer National Bank........... Apr. 13
Dunedin....................................................................................
Marine National Bank of St. Petersburg... May 19
Tequesta...................................................................................
Barnett Bank of Brandon, National Associa­
tion.................................................................... June 10
Orlando....................................................................................
Hollywood...............................................................................
Peoples National Bank, Naples..................... June 18
United National Bank of Westland, Hia­
leah.......................................................................July 21
National Bank of Commerce.......................... Aug. 2
Palm Beach Gardens..........................................................
The Orlando National Bank W est............... Aug. 19
Orlando..................................................................................
North Bay..............................................................................
North Palm Beach................................................................
First National Bank of Palm Bay................. Sept. 27
Second National Bank of West Hollywood,
Hollywood....................................................... Nov. 11
First National Bank of Seminole................... Nov. 18
Cape Coral............................................................................
Jefferson National Bank of Kendall............. Dec. 8

Feb.

9

May 19
June

8

June 10
June 11

Aug. 11
Aug. 19
Sept 7
Sept. 9

KANSAS
Overland Park....................................................

June 10

LOUISIANA
Century National Bank in New Orleans... Dec. 29 ................

MAINE
Central National Bank.....................................

Mar.

4 ................

MICHIGAN
West Oakland Bank, National Association
Novi............................................... ................ May 20 ................
The American National Bank in Portage.. Oct. 26 ................
Flint............................................................................................ Oct. 28

MISSISSIPPI
MISSOURI
NEW JERSEY
Bank of Wayne, National Association......... Jan. 4 ...................
Township of Maplewood..................................................... Feb. 11
Shore National Bank, Township of Brick. . Apr. 14 ................
Township of Franklin........................................................... May 18
Bayonne....................................................................................... Aug. 3
Borough of Bernardsville...................................................... Sept. 2
Midlantic National Bank, Township of
Parsippany-Troy Hills.................................. Oct. 26 ................
Township of Westfield........................................................... Nov. 19
The Hillsborough National Bank................. Nov. 4 ................

NEW YORK
Union National Bank, Albany....................... Mar. 11 ................
Citibank (Suffolk), National Association,
Islip.................................................................... July 15 ..................
Chase Manhattan Bank of Long Island
(National Association), Melville............... July 23 ...................
Hudson Valley National Bank, Yonkers. . . Dec. 21 ................

OHIO
Community National Bank, Loveland. . . .

Sept. 30 ................

OKLAHOMA
Bethany...................................................................................... Feb.
Nov. 30

ILLINOIS
The National Bank of Oak Brook................ June 16 ...................
First National Bank of Lincolnshire................................ Aug. 23
Pekin..................................................................... Aug. 9 ................
Community National Bank of Quincy. . . . Aug. 26 ................
Gurnee National Bank..................................... Sept. 22 ................
First National Bank of Wilmette.................. Dec. 22 ................




Jan. 26

The Affton National Bank.............................. Oct. 28 ................
Mar. 3
Mar. 3
Mar. 9
Mar. 9
Mar. 9
Mar. 9
Mar. 15
Mar. 30

Commerce National Bank of Warner Rob­
ins....................................................................... Aug. 16 ................
Ellijay........................................................................................ Dec. 15

154

Rejected

Wiggins......................................................................................June 15
Citizens National Bank, Pascagoula............ Nov. 10 ...................

GEORGIA

See fo o t n o t e a t end o f table.

Approved

3

PUERTO RICO
First National Bank of Puerto Rico, Hato
Rey..................................................................... Nov. 17

SOUTH CAROLINA
Township of Hilton Head Island......................................

Oct. 13

TEXAS
Lovelady....................................................................................Jan.
11
Pasadena................................................................................... Jan.
27
Union National Bank, Austin........................ Feb. 9 ................
San Antonio............................................................................. Mar. 10
Houston..................................................................................... Mar. 29

T able B -6—-Continued

Applications fo r National bank charters, approved and rejected, by States , calendar 1971 *
Approved Rejected

Approved Rejected
continued
D allas.....................................................................
Fidelity Bank, National Association, D al­
las........................................................................ M ay
T h e V alley National Bank, M cA llen .......... M ay
M etropolitan National Bank, M c A lle n .. . . M ay
Nueces National Bank, Corpus Christi. . . . June
First National Bank o f Colley ville................ Aug.
First National Bank o f D eer P ark................ Aug.
Fort W o rth .......................................................... .
Chevy Chase National Bank, Austin........... Sept.
M ontgom ery County National Bank........... Sept.
Heritage National Bank, T y le r...................... N ov.
U nincorporated Area o f F u lton ......................
Braes Bayou National Bank, H o u sto n .. . . . D ec.
H ouston.................................................................
H ouston.................................................................
R ou n d M ountain.................................................

VIRGINIA

Te x a s —

M ay 21
21
21
21
16
10
10

Arlington C ou n ty................................................................
First & Merchants National Bank o f the
Peninsula, W illiam sburg............................. D ec. 29

Feb. 23

WASHINGTON

M ay 18

Everett
Aug. 26

21
23
2
N ov. 24

WEST VIRGINIA

T h e Teays Valley National Bank, Scott
D ep ot................................................................ D ec. 29

21
D ec. 29
D ec. 29
D ec. 29

WISCONSIN

St. Francis

Feb. 24
WYOMING

UTAH

First Security Bank o f Bountiful, National
Association......................................................

Aug.

4

Jackson ....................................................................................
T h e First National Bank erf Jackson Hole,
Jackson............................................................ Apr. 27

Apr. 27

♦Excludes conversions, and charters to be issued pursuant to corporate reorganization.

155
4 6 3 -4 9 9 0 — 72

11




T able B—
7
Applications for National bank charters, by States, pursuant to corporate reorganization, calendar 1971

CALIFORNIA
B.C. National Bank, San Francisco.. . . . . .
SECPAC National Bank, Los Angeles. . . .

Approved Rejected
Dec. 7
Dec. 29 . . . .

INDIANA
Meridian National Bank, Indianapolis. . . . Aug. 20

Oct.

8

PENNSYLVANIA

MICHIGAN

Mellon Bank, N .A ., Pittsburgh..................... Aug. 26
The King Street Bank, N .A ., Lancaster.. . Dec. 13

The American Bank of Michigan, National
Association, Kalamazoo.............................. Apr. 27
American Bank of Niles, National Associa­
tion, Niles........................................................ Sept. 28
Three Rivers National Bank, Three Rivers. Sept. 29

SOUTH CAROLINA
Security National Bank, Charleston............ Nov. 18

MISSOURI

TENNESSEE

Livestock Bank of Kansas City, National
Association, Kansas City........................... Oct. 29

NEBRASKA
First National Bank in Grand Island, Grand
Island................................................................ Nov.

4 ....

NEW JERSEY

The National Bank of Kingsport, Kings­
port..................................
June 18
Fourth and Church Street National Bank,
Nashville.......................................................... Oct. 5
Union Planters Bank, National Associa­
tion, Memphis................................................ Nov. 8

TEXAS
Feb.

16

Apr. 23
Apr. 23
May

4 . . ..

July

13

Aug.

4

Aug. 20
Sept.

2

Nov. 16

NEW YORK
The Bank of Tappan Zee, N .A ., Nyack. . Feb.
East Bank, N .A ., Smithtown......................... Feb.
National Bank of Northern New York,
Watertown, Watertown.............................. Mar.
The Nanuet National Bank of Rockland
County, Nanuet............................................. Apr.
Court Street National Bank and Trust
Company, Buffalo......................................... Apr.
Empire Bank, National Association, Mid­
dletown.............................................................. May
First Bank of Bay Shore, National Associa­
tion, Bay Shore.............................................. Oct.
Citibank (Western), National Association,
Village of Silver Creek................................... Nov.
Citibank (Mid-Western), National Asso­
ciation, Village of Honeoye Falls................Dec.




Central Cleveland Bank, National Associa­
tion, Cleveland............................................. Feb.
1
The F.B.G. National Bank of Milford,
Milford............................................................. Sept. 13
Cambridge National Bank,Cambridge.. . . Dec. 22

DB National Bank, Roseburg........................

Polaris National Bank, Hutchinson............. July 13

156

Approved

OREGON

KANSAS

New Citizens National Bank, Englewood
N.J., Englewood...........................................
Second South Jersey National Bank, Cam­
den.....................................................................
Second National Iron Bank of New Jersey,
Morristown.....................................................
Second National Bank of Princeton,
Princeton.........................................................
New Madison National Bank (Madison,
New Jersey), Madison.................................
The Second American National Bank,
Montclair........................................................
Second New Jersey Bank (National As­
sociation), Clifton..........................................
The Second City National Bank of Mill­
ville, Millville.................................................
First National State Bank of Central Jer­
sey, Trenton....................................................

OHIO

17
24
3
23. . . .
30
3

Bancorp National Bank of Corsicana,
Texas, Corsicana........................................... Jan.
Twenty-Second Street National Bank,
Galveston......................................................... Feb.
Alamo Bank National Association, San
Antonio............................................................. Mar.
State Bank, National Association, El Paso. June
Park Street Bank National Association,
Beaumont.........................................................June
Sabine Bank, National Association, Port
Arthur............................................................... July
Bank of Commerce, National Association,
Antonio............................................................. July
Macgregor Bank National Association,
Houston............................................................ July
Kilgore Bank, National Association, Kil­
gore.................................................................... Aug.
Long Bank, National Association, Houston. Aug.
Continental Bank, National Association,
Fort W orth...................................................... Aug.
First National Bank of North Richland
Hills, North Richland Hills........................ Sept.
Burnett Plaza National Bank of Fort
Worth, Fort W orth....................................... Nov.

12
10
19
8
30
16
23
27
10
11
30
9
18

UTAH
Zions Bank, N .A ., Salt Lake C ity................ Dec. 29

VIRGINIA

26
10
14

Danville Bank, N .A ., Danville.......................
Roanoke Bank, N .A ., Roanoke.....................
Virginia Bank, N .A ., Norfolk........................
Colonial Bank, NA, Roanoke County.........

Apr.
Apr.
June
June

27
28
29
29

Rejectee

XABLE

B —8

N ew ly organized National banks, by States, calendar 1971*

Title and location of bank

Charter
No.

Total capital
accounts

Total, United States: 38 banks..................................... ....................................................................................

$38, 020, 000

COLORADO
Arapahoe Colorado National Bank, unincorporated area of Arapahoe County.............................................
Skyline National Bank, Denver......................................................................................................................................

400,000
700, 000

Total: 2 banks........................................................................................................................................................

15885
15919

1, 100, 000

FLORIDA
Barnett Bank of Seminole County, National Association, Atlamonte Springs.................................................
Midway National Bank, unincorporated area of Dade County...........................................................................
East First National Bank, Fort Myers..........................................................................................................................
Security National Bank, unincorporated area of Lee County..............................................................................
First National Bank of Hallandale, Hallandale........................................................................................................
Hobe Sound National Bank, unincorporated area of Martin County...............................................................
Lauderdale Lakes National Bank, Lauderdale Lakes.............................................................................................
Worth Avenue National Bank, Palm Beach...............................................................................................................
First National Bank of Palm Beach Gradens, Palm Beach Gardens..................................................................
Security First National Bank, Plantation....................................................................................................................
Charlotte County National Bank, Port Charlotte....................................................................................................
Marine National Bank of St. Petersburg, St. Petersburg......................................................................................
Village Plaza Palmer National Bank, unincorporated area of Sarasota County............................................
Barnett Mall Bank, National Association, Winter Park.........................................................................................

600, 000
600, 000
900,000
750,000
1, 500, 000
1, 000, 000
750, 000
1,000,000
1,005,000
1,000,000
1,075,000
1, 000, 000
1, 200, 000
740, 000

Total: 14 banks......................................................................................................................................................

15858
15870
15865
15855
15874
15914
15868
15894
15890
15859
15923
15905
15901
15900

13, 120,000

ILLINOIS
Tollway-Arlington National Bank of Arlington Heights, Arlington Heights...................................................
Suburban National Bank of Elk Grove Village, Elk Grove Village...........................................................
Lake Forest National Bank, Lake Forest.....................................................................................................................
The National Bank of Oak Brook, Oak Brook..........................................................................................................
Community National Bank of Quincy, Quincy........................................................................................................

600,000
500,000
500,000
1,600,000
500, 000

Total: 5 banks.........................................................................................................................................................

15921
15916
15886
15915
15920

3, 700, 000

MASSACHUSETTS
15892

The Colonial National Bank of Danvers, Danvers...................................................................................................

1, 500, 000

15877
15899

National Bank of Marshall, Marshall...........................................................................................................................
West Oakland Bank, National Association, Novi................................................................ .....................................

700,000
750,000

Total: 2 banks.........................................................................................................................................................

1, 450, 000

MICHIGAN

NEW JERSEY
15913
15857
15888

Shore National Bank, Brick Township................... ......................................................................................................
Fairfield National Bank, Fairfield Borough.................................................................................................................
Pan American National Bank, Union City.................................................................................................................

2, 500, 000
1,250,000
1, 500, 000

Total: 3 banks.........................................................................................................................................................

5, 250, 000

NEW YORK
15917
15922

Citibank (Suffolk), National Association, Islip..........................................................................................................
Chase Manhattan Bank of Long Island (National Association), Melville........................................................

1, 500, 000
2, 000, 000

Total: 2 banks.........................................................................................................................................................

3, 500, 000

NORTH CAROLINA
15912

Greensboro National Bank, Greensboro...............................................

.........

700,000

See fo o t n o t e a t en d o f tab le.




157

T able B -8 — Continued
t

N ew ly organized National banks, by States , calendar 1971*

Charter
No.

Title and location of bank

Total capital
accounts

TEXAS

15929
15880
15896
15904
15856

Brookhollow National Bank, D allas...............................................................................................................................
T h e V illage Bank (National Association), D allas......................................................................................................
T h e V illage National Bank, H ouston............................................................................................................................
T h e Valley National Bank, M cA llen .............................................................................................................................
Promenade National Bank, R ichardson........................................................................................................................

$ 1 ,5 0 0 ,0 0 0
50 0,000
8 0 0,00 0
1 ,0 0 0 ,0 0 0
1 ,0 0 0 ,0 0 0

T o ta l: 5 banks.........................................................................................................................................................

4 ,8 0 0 ,0 0 0

VIRGINIA

15895

Atlantic National Bank, N orfolk......................................................... ...........................................................................

15878

University National Bank, M ilw aukee..........................................................................................................................

1 ,0 0 0 ,0 0 0

WISCONSIN

1 ,5 0 0 ,0 0 0

WYOMING

15903

T h e First National Bank o f Jackson Hole, Jackson ...................................................................................................

40 0 ,0 0 0

♦Excludes charters issued pursuant to corporate reorganizations.

T

able

B-9

,

,

National bank charters issued* and m
ergers consum ated pursuant to corporate reorganizations by States calendar 1971
m

Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

LOUISIANA

Jan.

1, 1971

T h e National Bank o f Com m erce in N ew Orleans, New Orleans
N BC National Bank, N ew Orleans
Charter issued D ecem ber 29, 1970
First National Bank o f Com m erce, New O rleans............................

$43, 77 9,454

$521, 307, 980

356,813, 201

4 ,0 5 4 ,5 2 3 ,6 3 0

8, 116,311

101,207, 598

707, 193

9 ,4 0 4 ,8 0 6

131, 107, 182

1, 267, 685, 208

5, 607, 789

68, 657, 343

MASSACHUSETTS

Jan.

4,1971

T h e First National Bank o f Boston, Boston
O ld C olony Trust, National Association, Boston
T h e Massachusetts Bank, National Association, Boston
Charter issued D ecem ber 30, 1970
T h e First National Bank o f Boston, Boston.....................
MISSOURI

M ar. 10, 1971

M ar. 10, 1971

M ar. 11, 1971

M ay

3,1971

T h e Am erican National Bank o f St. Joseph, St. Joseph
Am erican Bank o f St. Joseph, National Association, St. Joseph
Charter issued M arch 8, 1971
T h e Am erican National Bank o f St. Joseph, St. J osep h ..............
Belt National Bank o f St. Joseph, St. Joseph
Belt Bank o f St. Joseph, National Association
Charter issuea M arch 8, 1971
Belt National Bank o f St. Joseph, St. Joseph ..................................
M ercantile Trust Com pany National Association, St. Louis
Locust National Bank, St. Louis
Charter issued M arch 10, 1971
M ercantile Trust Com pany National Association, St. L ou is. . .
First National Bank o f Jop lin , Joplin
First Bank o f Jop lin , National Association, Joplin
Charter issued April 26, 1971
First National Bank and Trust Com pany o f Joplin, J o p lin .........

See footnote a t end of table.

158




T able B -9 — Continued

National bank charters issued * and mergers consummated pursuant to corporate reorganizations, by States , calendar 1971

Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

NEW JERSEY

Jan.

4, 1971

July

1, 1971

N ov.

1, 1971

N ov.

1, 1971

N ov.

1, 1971

T h e National Bank o f N ew Jersey, New Brunswick
T h e National Bank o f N ew Jersey, N ew Brunswick, N ew Brunswick
Charter issued D ecem ber 30, 1970
T h e National Bank o f New Jersey, New Brunswick.............................................
New Jersey National Bank, Trenton
Second New Jersey National Bank, Trenton
Charter issued June 25, 1971
N ew Jersey National Bank, T ren ton ..........................................................................
South Jersey National Bank, Cam den
Second South Jersey National Bank, Cam den
Charter issued O ctober 21, 1971
South Jersey National Bank, C a m d en ......................................................................
T h e First National Iron Bank o f N ew Jersey, M orristown
T h e Second National Iron Bank o f New Jersey, Morristown
Charter issued O ctober 22, 1971
T h e First National Iron Bank o f New Jersey, M orristow n.................................
First National Bank o f Princeton, Princeton
Second National Bank o f Princeton, Princeton
Charter issued O ctober 28, 1971
T h e First National Bank o f Princeton, Princeton.................................................

$7, 733, 937

$87,809, 749

39, 734, 387

608, 378, 606

31,461, 152

429,25 8,27 1

14, 657, 384

194,906,722

5, 693, 706

94, 680, 861

4, 997, 675

55, 174, 529

67, 228, 411

877, 835,65 4

33, 856, 913

51 3 ,8 6 4 ,9 9 2

2, 117, 332

32,937, 026

2, 504, 525

2 3 ,5 7 6 ,7 1 4

4, 781, 180

62, 705, 948

111,045, 290

1, 309, 141,000

NEW YORK

M ar. 31, 1971

D ec. 31, 1971

D ec. 31, 1971

First National Bank and Trust Com pany National Association, Ithaca
Bank o f Ithaca, National Association, Ithaca
Charter issued M arch 29, 1971
First National Bank and Trust Com pany o f Ithaca, Ith a ca ..............................
National Com m ercial Bank and Trust Com pany, Albany
Capital City National Bank, Albany
Charter issued D ecem ber 20, 1971
National Com m ercial Bank and Trust Com pany, A lban y.................................
Liberty National Bank and Trust Com pany, Buffalo
Court Street National Bank and Trust Com pany, Buffalo
Charter issued D ecem ber 20, 1971
Liberty National Bank and Trust Com pany, Buffalo...........................................
OHIO

Apr. 30, 1971

Apr. 30, 1971

June

1, 1971

D ec. 31, 1971

First National Bank o f W apakoneta, W apakoneta
T h e F.B.G. National Bank o f W apakoneta, W apakoneta
Charter issued April 29, 1971
T h e First National Bank o f W apakoneta, W apakoneta......................................
T h e Citizens National Bank o f Wooster, W ooster
T h e F.B.G. National Bank o f Wooster, W ooster
Charter issued April 29, 1971
T h e Citizens National Bank o f Wooster, W ooster.................................................
T he Security Central National Bank o f Portsmouth, Portsmouth
T h e F.B.G. National Bank o f Portsmouth, Portsmouth
Charter issued June 1, 1971
T h e Security Central National Bank o f Portsmouth, Portsm outh....................
Central National Bank o f Cleveland, Cleveland
Central Cleveland Bank, National Association, Cleveland
Charter issued D ecem ber 22, 1971
Central National Bank o f Cleveland, Cleveland...................................................
OKLAHOMA

O ct. 29, 1971

T h e Fourth National Bank o f Tulsa, Tulsa
T h e Fourth Bank o f Tulsa, National Association, Tulsa
Charter issued O ctober 26, 1971
T h e Fourth National Bank o f Tulsa, T u lsa .............................................................

8, 690, 304

9 9 ,5 5 2 ,9 1 3

See footnote at end of table.




159

T able B -9 — Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States , calendar 1971
Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

TENNESSEE

July 15, 1971

First American National Bank of Nashville, Nashville
American National Bank of Nashville, Nashville
Charter issued July 14, 1971
First American National Bank of Nashville, Nashville...........................................

$49,899,926

$700, 331, 563

100, 215, 188

1, 278, 606, 133

5,033,7 11

50, 427, 300

98, 392, 553

1, 234, 184, 404

4, 756, 446

47, 324, 032

4, 944, 372

73, 860,410

1, 915, 635

22, 871,993

861, 568

9, 209, 681

2, 185, 715

26, 200, 432

6 ,2 21,0 47

58, 385,818

TEXAS

Apr.

1, 1971

June 30, 1971

July

7,1971

Aug. 31, 1971

Sept. 30, 1971

First City National Bank of Houston, Houston
First City Bank National Association, Houston
Charter issued April 1, 1971
First City National Bank of Houston, Houston......................................................
The United States National Bank of Galveston, Galveston
Twenty-Second Street National Bank, Galveston
Charter issued June 21, 1971
United States National Bank of Galveston, Galveston.........................................
Texas Commerce Bank National Association, Houston
Commerce Bank National Association, Houston
Charter issued July 1, 1971
Texas Commerce Bank National Association, Houston......................................
First National Bank of Corsicana, Corsicana
Bancorp National Bank of Corsicana, Corsicana
Charter issued August 23, 1971
The First National Bank of Corsicana, Corsicana................................................
Southwest National Bank of El Paso, El Paso
Second Southwest National Bank of El Paso, El Paso
Charter issued September 22, 1971
Southwest National Bank of El Paso, El Paso........................................................
VIRGINIA

Mar.

1, 1971

Mar. 31, 1971

Sept.

1, 1971

Sept. 30, 1971

The Peoples National Bank of Manassas, Manassas
Manassas Bank, National Association, Manassas
Charter issued February 26, 1971
The Peoples National Bank of Manassas, Manassas.............................................
Williamsburg National Bank, Williamsburg
Bank of Williamsburg, National Association, Williamsburg
Charter issued March 25, 1971
Williamsburg National Bank, Williamsburg...........................................................
Security National Bank of Roanoke, Roanoke
Roanoke Bank, National Association, Roanoke
Charter issued August 25, 1971
United Virginia Bank/Security National, Roanoke..............................................
The First National Bank of Danville, Danville
Danville Bank, National Association, Danville
Charter issued September 23, 1971
The First National Bank of Danville, Danville......................................................

♦Includes only charter issuances related to mergers consummated during 1971. For a full listing of all charters issued during
1971, pursuant to corporate reorganization, see Table B - l l .

160




T able B-10
State-chartered banks converted to National banks,

Charter
No.

Title and location of bank

Effective
date of
charter

by States, calendar
Outstanding
capital stock

1971

Surplus, undi­
vided profits
and reserves

Total assets

$3, 202, 490

$9, 900, 154

$163, 103,517

Nov. 30

600, 000

1, 269, 998

25, 554, 171

Aug.

2

357, 500

267, 821

6, 203, 204

July 19

300, 000

376, 973

9, 593, 657

Oct. 15

100, 000

258, 248

4, 347, 286

Oct. 11

75, 000

92, 290

2, 798, 375

Total: 9 banks...................................................................

FLORIDA
15913

First National Bank & Trust Company, Jupiter/Tequesta,
Florida, Tequesta..................................................................
Conversion of First Bank and Trust Company, Jupiter/
Tequesta.

MICHIGAN

15889

The American Bank of Three Rivers, National Association,
Three Rivers...........................................................................
Conversion of The American Bank of Three Rivers.

MONTANA
15884
15907
15902

Montana National Bank of Bozeman, Bozeman..................
Conversion of Gallatin Trust and Savings Bank.
United National Bank, Libby....................................................
Conversion of Lincoln Security Bank.
Montana National Bank of Richey, Richey..........................
Conversion of First State Bank of Richey.

OHIO
15861

Mar.

8

100, 000

174, 346

2, 199, 566

First Peoples National Bank of South Carolina, Hartsville.. June
Conversion of The Peoples Bank of Hartsville.

3

300, 000

1,297,515

14, 182,611

Oct.

14

200, 000

1, 120, 764

13, 287, 354

Kanawha Banking and Trust Company, N .A ., Charleston. July
Conversion of Kanawha Banking & Trust Company.

1

1, 169, 990

5, 042, 199

84, 937, 293

Citizensbank National Association, Felicity...........................
Conversion of Citizens Bank Company.

SOUTH CAROLINA
15875

WASHINGTON
15906

Olympic National Bank, Port Angeles....................................
Conversion of Olympic State Bank.

WEST VIRGINIA
15882




161

T able B—
11

National bank charters issued pursuant to corporate reorganizations, by States , calendar 1971

Charter
No.

T itle and location o f bank

Date oj
issuance

T o ta l: 30 banks
INDIANA

869

M eridian National Bank, Indianapolis

D ec. 30
MISSOURI

13162
6272
15176
15452

First Bank o f Joplin National Association, J o p lin .........................
Am erican Bank o f St. Joseph, National Association, St. Joseph
Belt Bank o f St. Joseph, National Association, St. J osep h ..........
Locust National Bank, St. L ou is.........................................................

A pr. 26
M ar. 8
M ar. 8
M ar. 10

N EW JERSEY

1209
4274
1113
4872
1327

Second South Jersey National Bank, C a m d e n .................
T h e Second Am erican National Bank, M on tcla ir...........
Second National Iron Bank o f N ew Jersey, M orristown
Second National Bank o f Princeton, P rinceton.................
Second N ew Jersey National Bank, T ren ton .....................

O ct.
D ec.
O ct.
O ct.
June

21
23
22
28
25

NEW YORK

1301
15080

222

Capital City National Bank, A lb a n y ..........................................
Court Street National Bank and Trust C om pany, Buffalo
Bank o f Ithaca, National Association, Ith a ca ........................

D ec. 20
D ec. 20
M ar. 29

OHIO

4318
7781
3157
7670

Central Cleveland Bank, National Association, C levela nd.
T h e F.B.G. National Bank o f Portsmouth, Portsm outh. .
T h e F.B.G. National Bank o f W apakoneta, W apakoneta
T h e F.B.G . National Bank o f W ooster, W ooster................

D ec.
M ay
A pr.
A pr.

22
28
29
29

OKLAHOMA

13480

T h e Fourth Bank o f Tulsa, National Association, Tulsa

O ct. 26

TENNESSEE

13103
3032

Fourth and Church Street National Bank, Nashville
Am erican National Bank o f Nashville, N a sh ville.. . .

D ec. 30
July 14

TEXAS

3506
14581
12475
13943
10225
4525

Bancorp National Bank o f Corsicana, Texas, Corsicana
Second Southwest National Bank o f El Paso, El P a s o ...
Tw enty-Second Street National Bank, G alveston............
First City Bank National Association, H ou ston ................
C om m erce Bank National Association, H ou ston ..............
A lam o Bank, National Association, San A n ton io.............

Aug. 23
Sept.
June
M ar. 31

21

22

J«iy 1
D ec.

21

VIRGINIA

1985
6748
15117
15562

D anville Bank, N .A ., D a n ville.......................
Manassas Bank, N .A ., M anassas...................
R oanoke Bank, N .A ., Roanoke C o u n ty . . .
Bank o f Williamsburg, N .A ., W illiamsburg

162



22

Sept.
Feb. 25
Aug. 25
M ar. 25

T able

B—
12

National banks reported in voluntary liquidation , by States , calendar 1971
Title and location of bank

Date of Total capital
liquida­ accounts of
tion
banks

T o ta l: 7 National banks

$8, 755, 348
ALABAMA

City National Bank o f Russellville, Russellville, Ala. (15466), absorbed by First National Bank o f Russell­
ville, Russellville (11846).................................................................................................................................................

O ct. 15

826, 331

June 30

1, 337,827

June 25

3, 179,517

D ec. 31

730,000

MASSACHUSETTS

T h e Arlington National Bank, Arlington, Mass. (11868), absorbed by Coolidge Bank and Trust Com pany,
W atertow n.............................................................................................................................................................................
NEW JERSEY

T h e Bergen County National Bank o f Hackensack, Hackensack, N.J. (13364), absorbed by Com m ercial
Trust C om pany o f N ew Jersey, Jersey C ity ................................................................................................................
PENNSYLVANIA

First National Bank at Patton, Patton, Pa. (14263), absorbed b y National Bank o f the Com m onwealth,
Indiana (1 4 0 9 8 )...................................................................................................................................................................
Kiski Valley National Bank, Vandergrift, Pa. (14514), absorbed by First National Bank in Indiana, In­
diana (1 4 0 9 8 )................................ ....................................................................................................................................

Jan.

4

1, 176,006

D ec. 31

1 ,0 8 3 ,6 4 6

5

422,021

UTAH

Granite National Bank, Salt Lake City, Utah (15196), absorbed by Com m ercial Security Bank, O d g e n ...
WASHINGTON

Bank o f Vancouver, N .A ., V ancouver, Wash. (15538), absorbed by Peoples National Bank o f Washing­
ton, Seattle (1 4 3 9 4 ).............................................................................................................................................................




Apr.

163

T able B-13

National banks merged or consolidated with State banks, by States, calendar 1971
Title and location of bank

Effective
date

Total capital
accounts of
National
banks
$15, 160, 516

T otal: 11 banks . . .
CALIFORNIA

Bank o f L ong Beach, N .A ., L on g Beach, Calif. (15585), merged into U nion Bank, Los Angeles, Calif.,
under the title “ Union Bank” ..........................................................................................................................................

July 26

1,912, 226

D ec. 31

3, 190, 448

Aug. 20

2, 614, 785

June 14

4 5 3,61 9

July 30

556, 754

ILLINOIS

T he South East National Bank o f Chicago, Chicago, 111. (14327), merged into Civic Center Bank and
Trust Com pany, Chicago, 111., under the title “ Civic Center Bank and Trust Com pany” .........................
NEW JERSEY

T h e Farmers and M erchants National Bank o f M atawan, M atawan Tow nship, N.J. (6440), merged into
Franklin State Bank, Franklin Tow nship, N.J., under the title “ Franklin State Bank” ...............................
OREGON

First National Bank in Clatskanie, Clatskanie, Oreg. (14001), merged into Western Bank, Coos Bay,
O rcg., under the title “ Western Bank” .........................................................................................................................
First National Bank o f Harrisburg, Harrisburg, Oreg. (9146), merged into Citizens Bank o f O regon,
Eugene, O reg., under the title “ Citizens Bank o f O regon” ..................................................................................
T ota l: 2 banks..............................................................................................................................................................

1, 010, 373

PENNSYLVANIA

T h e First National Bank o f Lansford, Lansford, Pa. (5234), merged into First Valley Bank, Bethlehem, Pa.,
under the title “ First Valley Bank” ...............................................................................................................................
T he First National Bank o f Nesquehoning, Nesquehoning, Pa. (10251), merged into First Valley Bank,
Bethlehem, Pa., under the title “ First Valley Bank” ................................................................................................
T h e First National Bank o f Sayre, Pa. (5666), merged into Com m onwealth Bank and Trust Com pany,
M uncy, Pa., under the title “ Com m onwealth Bank and Trust C om pany” ........................................................
Slatington National Bank and Trust Com pany, Slatington, Pa. (2293), merged into Am erican Bank and
Trust Com pany o f Pennsylvania, Reading, Pa., under the title “ Am erican Bank and Trust Com pany o f
Pennsylvania” ........................................................................................................................................................................
T h e First National Bank o f State College, State College, Pa. (7511), merged into Lock Haven Trust
Com pany, Lock Haven, Pa., under the title “ Central Counties Bank” .............................................................

June 24

574, 348

Sept. 30

366,018

1

1,353, 153

Aug. 20

1, 170, 559

June 30

2, 471,382

D ec.

T ota l: 5 banks..............................................................................................................................................................

5, 935, 460

SOUTH CAROLINA
T h e First National Bank o f Laurens, Laurens, S.C. (14950), merged into Southern Bank and Trust C om ­
pany, Greenville, S.C., under the title “ Southern Bank and Trust Com pany” ..............................................

164




N ov. 15

497, 224

T able B-14

,

National banks converted into State banks by States, calen
dar 1971

Title and location of bank

Charter
No.

Effective
date

T ota l: 21 banks.......................................................................................................................................

Total capital
accounts of
National
banks
$35, 129, 720

COLORADO

9013

T h e First National Bank o f Eagle County, Eagle, converted into First Bank o f Eagle C o u n ty .. .

M ay

3

436, 625

O ct.

1

6, 008, 098

June 28

472, 607

Aug. 17

1, 138, 685

ILLINOIS

14498
14354

Oak Park National Bank, O ak Park, converted into First Bank o f O ak P ark..................................
T h e Citizens National Bank o f Warren, W arren, converted into Citizens Bank and Trust
C o m p a n y ............................................................................................................................... ............................
MARYLAND

15098

Citizens National Bank o f Southern M aryland, Lexington Park, converted into M aryland
Bank and Trust C om p a n y ............................................................................................................................
MINNESOTA

9253

T he Farmers National Bank o f Waseca, Waseca, converted into First State Bank o f W a seca .. . .

Feb.

16

734, 658

Feb.
July

9
13

892, 717
641, 082

Apr. 19

2, 198, 522

MISSISSIPPI

15552
14754

Citizens National Bank o f Belzoni, Belzoni, converted into Citizens Bank & Trust Com pany
B elzoni.................................................................................................................................................................
Attala National Bank o f Kosciusko, Kosciusko, converted into Attala Bank o f K osciu sko.........
NEW YORK

2655

First National Bank and Trust Com pany o f Corning, Corning, converted into First Bank and
Trust o f C orn in g...............................................................................................................................................

OKLAHOMA
9985
10548
10317
15246
15210
10014

T h e O klahom a National Bank, Clinton, converted into O klahom a Bank and Trust C o m p a n y .. M ay 18
T h e First National Bank o f Ringling, Ringling, converted into Ringling State Bank.................... Apr. 1
T h e First National Bank, Snyder, converted into Bank o f the W ich itas............................................. Sept. 1
University National Bank o f Stillwater, Stillwater, converted into University B ank....................... Tune 1
M ercantile National Bank, Tulsa, converted into M ercantile Bank and Trust C om p a n y............ Apr.
1
4
T h e First National Bank o f Yale, Y ale, converted into First Bank and Trust C om p a n y .............. Jan.

759,
267,
599,
431,
1, 479,
507,

467
039
668
969
502
966

PENNSYLVANIA
8913
15393

T h e First National Bank o f Bernville, Bernville, converted into Bernville Bank...............................
Lincoln National Bank, Philadelphia, converted into Lincoln Bank....................................................

1
7

379, 868
5, 706, 271

O ct. 21

1, 858, 228

Apr. 12
Jan. 20
Apr. 19

4, 246, 794
639, 170
4, 171,336

M ar. 22

1, 559, 448

Ju ly
Sept.

TEXAS
15112
14867
15142
12091

Southwest National Bank o f Fort W orth, Fort W orth, converted into Southwest B ank................
M edical Center National Bank, Houston, Houston, converted into M edical Center Bank,
H ou ston ................................................................................................................................................................
Northshore National Bank, Houston, Houston, converted into Northshore Bank, H ou ston .........
T he Merchants National Bank o f Port Arthur, Port Arthur, converted into M erchants B a n k ...

VIRGINIA
15221

T h e Am erican Bank, N .A ., Falls Church, converted into T h e Am erican Bank o f Fairfax............




165

T able B-15

Purchases of State banks by National banks, by States, calendar 1971
Tide and location o j banks

Elective Total capital
date
accounts of
Stale banks

T ota l: 6 banks.............................................................................................................................................................

$ 4 ,9 7 5 ,0 7 6

CALIFORNIA

T h e Bank o f California, N .A ., San Francisco, Calif. (9655), purchased the Bank o f R edding, R ed d in g ...........

O ct. 29

2, 142,507

GEORGIA

T h e Citizens and Southern National Bank, Savannah, G a. (13068), purchased the Citizens and Southern
Bank o f R ich m on d County, Augusta..............................................................................................................................
and T h e Citizens and Southern Bank o f Chatham County, Savannah..............................................................

D ec.
D ec.

8
8

726, 227
497, 762

M ar. 20

231, 127

D ec. 27

2 6 3,00 0

Apr. 30

83 1 ,3 6 2

Ju n e 15

283,091

OHIO

T h e Clinton County National Bank and Trust Com pany o f W ilm ington, W ilm ington, O h io (1997),
purchased T h e Port .William Banking Com pany, Port W illia m .............................................................................
T h e W ayn e County National Bank o f W ooster, W ooster, O h io (828), purchased the Farmers Bank,
S h r e v e .......................................................................................................................................................................................
PENNSYLVANIA

Western Pennsylvania National Bank, Pittsburgh, Pa. (2222), purchased the Provident Trust C om pany,
Pittsburgh.................................................................................................................................................................................
WISCONSIN

First National Bank in M anitow oc, M anitow oc, Wis. (4975), purchased the State Bank o f Francis Creek,
Francis C reek...........................................................................................................................................................................

166




T able B-16

Consolidations* o f National banks, or National and State banks, by States, calendar 1971

Effective
date

Consolidating banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

$ 1 ,2 5 0 ,0 0 0
6, 898, 125
8, 398, 125

$ 2 ,0 0 0 ,0 0 0
1 1 ,6 5 0 ,0 0 0
15 ,0 0 0 ,0 0 0

$1 ,031 ,4 41
6, 985,035
6,4 89, 847

$82, 666, 950
299, 620, 685
375,465, 152

700,000

700,000

8 3 8,42 5

38, 191,620

370,000
1,0 0 0 ,0 0 0
735,000
60 0,000
30 0,000
2, 085, 000

1, 030, 000
2 ,0 0 0 ,0 0 0
1, 20 5,000
80 0,00 0
350,000
2, 355,000

492, 055
l, 130, 300
638, 773
1, 181,698
731,127
2, 101, 599

2,317, 700
6 ,6 0 0 ,0 0 0
6 ,3 4 6 ,2 1 5

4 ,0 0 0 ,0 0 0
6 ,6 0 0 ,0 0 0
15 ,000,000

3,422, 804
2, 189, 821
3, 784, 110

20 0,380,211
168, 845, 100
369,225,311

40 0,00 0

1, 140,000

541,000

34, 572, 556

300,00 0

800,000

311,429

17, 585, 348

1,4 0 0 ,0 0 0

1 ,4 00,00 0

692, 492

52, 157,312

65 0,000
300,000
5 0 ,000
1,0 7 5 ,0 0 0

750,000
300,000
100,000
1,0 7 5 ,0 0 0

483, 706
302, 034
245,015
1, 030, 756

Total assets

T o ta l: 6 consolidations
CONNECTICUT

June

30

T h e W ater bury National Bank, W aterbury (7 8 0 )....................
City Trust Com pany, Bridgeport...................................................
T h e City National Bank o f Connecticut, Bridgeport (78 0). .
MASSACHUSETTS

N ov.

30

D ec.

31

T h e First-Machinist National Bank o f Taunton, Taunton
(4 1 6 )...................................................................................................
M anufacturers National Bank o f Bristol County, North
Attleboro (5 9 4 4 )..............................................................................
United National Bank, Taunton (5 9 4 4 )......................................
T h e Framington National Bank, Framington (5 2 8 )................
N ewton National Bank, Newton (1 3 2 5 2 )....................................
W altham Citizens National Bank, W altham (1 4 5 4 1 ).............
Com m unity National Bank, Framington (5 2 8 ).........................

28,
66,
45,
27,
13,
86,

572, 312
763, 942
306, 681
205, 320
651,672
163, 673

NEW JERSEY

Feb.

1

G arden State National Bank, Hackensack (15570)..................
North Jersey National Bank, Jersey City (1 1 8 2 )......................
Garden State National Bank, Hackensack (15570)..................
PENNSYLVANIA

O ct.

1

Northern National Bank and Trust Com pany, W ellsboro
(3 2 8 )...................................................................................................
T h e Citizens National Bank and Trust Com pany o f T o wanda, T ow an da (2 3 3 7 )..............................................................
Citizens and Northern National Bank and Trust Com pany,
Tow an da (3 2 8 )................... ............................................................
SOUTH DAKOTA

July

31

United National Bank o f Verm illion, Verm illion (15639). .
Rushm ore State Bank, R a pid C ity ...............................................
T h e Security National Bank o f V ib org, V iborg (13589). . . .
United National Bank o f South Dakota, R apid City (15639).

29,
12,
4,
46,

077, 441
469, 890
573, 759
121,090

♦Excludes consolidations involving only one operating bank, effected pursuant to corporate reorganization.




167

T able B-17

Mergers * of National banks, or National and State banks, 6? States , calendar 1971

Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Total: 36 merger actions
ALABAMA

Nov.

1

Midway Bank, Opelika.................................................................
Opelika National Bank, Opelika (11635)...............................
Opelika National Bank, Opelika (11635)...............................

$175,000
250,000
320,000

$100,000
625,000
830,000

300,000
870, 930
1, 146, 780
510, 155
16, 524, 000
17, 340, 240
1,718, 595
43, 728, 285
43, 728, 285
1, 938, 640

300,000
568, 410
623, 632
386, 084
11,500,000
11,500,000
377, 502
27, 774, 430
27, 774,430
711,000

499
742
324
072
254
326
0
11,319, 527
8, 812, 207
1, 186, 661

11, 729, 005
38, 192, 537
49, 814, 338
1,489,311
38, 192, 537
655, 115, 299
33, 746, 068
1,962, 100,715
1, 991, 243, 366
89, 419, 006

7, 062, 495

13, 285, 305

9, 805, 955

728, 642, 847

7, 062, 500

15, 934, 940

10, 992,616

81 8,061,854

300,000
325,000
14, 912, 340
14, 912, 340

200,000
226, 571
30, 924, 750
32, 034, 397

40,715
0
21,373, 674
21,373, 674

2,
2,
978,
982,

165,000

75,000

242,317

5,4 1 2 ,0 1 8

600,000

1,900,000

1, 257, 599

54, 791, 656

600,000

1,900,000

745, 957

60, 387, 026

600,000
1, 250, 000
1, 550, 000

0
2, 000,000
3, 300, 000

0
3,001, 158
1,922,401

19, 121,305
70, 939, 304
90, 060, 610

300,000
12, 526, 260
12, 856, 260

300,000
27, 473, 740
29, 643, 740

1, 043, 290
15, 993, 467
14, 963,611

13, 739, 330
755, 156, 457
766, 907, 837

302, 500
17, 000, 000
17, 000, 000

500,000
38, 000, 000
38, 000, 000

267,019
42, 037, 683
43, 136,819

17, 304, 999
1,377, 595,483
1,393,615, 771

630,000
9, 000,000
9, 000, 000

807, 500
14, 000, 000
14, 000, 000

451, 337
2, 850, 092
362, 712

33, 081, 666
369, 181,028
402, 924, 643

150,000
3, 502, 629
3, 745, 629

225, 000
4,419, 853
4,5 5 1 ,8 5 3

227, 233
3, 550, 564
3, 777, 788

8, 786, 138
186, 397, 559
194, 873, 698

$81, 758
274,231
349, 945

$3, 308, 154
19, 104,475
23, 038, 020

CALIFORNIA

Jan.

11

June

25

Aug.

2

Sept.

23

Santa Ynez Valley Bank, Solvang.............................................
American National Bank, Bakersfield (15437)......................
American National Bank, Bakersfield (15437)......................
Hollywood National Bank, Los Angeles (15442)..................
United States National Bank, San Diego (10391)................
United States National Bank, San Diego (10391)...............
Inland Bank, Pomona...................................................................
The Bank of California, N .A., San Francisco (9655)..........
The Bank of California, N .A., San Francisco (9655).........
Newport National Bank, Newport Beach (15235)...............
Southern California First National Bank, San Diego
(3050).............................................................................................
Southern California First National Bank, San Diego
(3050)........................................................................................ . .

290,
325,
91,
593,
6, 103,
6, 776,

GEORGIA

Mar.

Mar.

1

3

First National Bank of Doraville, Doraville (15794)...........
First Bank of South DeKalb, Decatur.....................................
The First National Bank of Atlanta, Atlanta (1559)...........
The First National Bank of Atlanta, Atlanta (1559)...........
Southgate National Bank of Richmond County, Augusta
(15219)..........................................................................................
The First National Bank and Trust Company of Augusta
(1860).............................................................................................
The First National Bank and Trust Company of Augusta
(1860).............................................................................................

418,
143,
013,
401,

567
265
997
095

ILLINOIS

May

24

The St. Clair National Bank of Belleville, Belleville
(11478)..........................................................................................
The First National Bank of Belleville, Belleville (2154). . .
First National Bank of Belleville, Belleville (2154)..............
MARYLAND

Jan.

Aug.

29

31

Patapsco National Bank in Ellicott City, Ellicott City
(13773)..........................................................................................
The First National Bank of Maryland, Baltimore (1413). .
The First National Bank of Maryland, Baltimore (1413). .
First National Bank and Trust Company, Havre de Grace
(3010).............................................................................................
Maryland National Bank, Baltimore (13745)........................
Maryland National Bank, Baltimore (13745)........................
NEW JERSEY

Jan.

Feb.

21

5

The First National Bank of Milford, Milford (8779)..........
The National State Bank, Elizabeth (1436)......... .................
The National State Bank, Elizabeth (1436)...........................
Broadway National Bank and Trust Company of Pitman,
Pitman (15518)...........................................................................
Peoples National Bank of New Jersey, Westmont (12022).
Peoples National Bank of New Jersey, Westmont (12022).

See footnote at end of table.

168




T able

B-17—Continued

M ergers * o f National banks, or National and State banks, by States, calendar 1971

Merging banks
Resulting bank

Effective
date

new jersey—

Mar.

June

June

Sept.

Sept.

Sept.

5

4

4

10

24

30

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

continued

The First National Bank of Bordentown, Bordentown
(9268)...................................................................................
First National Bank of South Jersey, Egg Harbor Township (1326)...................................................................................
First National Bank of South Jersey, Egg Harbor Township (1326)...................................................................................
Phillipsburg Trust Company, N .A., Phillipsburg (15648).
New Jersey Bank, N .A., Clifton (15709)................................
New Jersey Bank, N .A., Clifton (15709)................................
The Second National Bank of Phillipsburg, Phillipsburg
(5556)............................................................................................
American National Bank and Trust, Montclair (4274). . .
American National Bank and Trust, Montclair (4274). . .
The First National Bank of Tuckerton, Tuckerton
(14667)..........................................................................................
Peoples National Bank of New Jersey, Westmont
(12022)..........................................................................................
Peoples National Bank of New Jersey, Westmont
(12022)..........................................................................................
Citizens National Bank of Morris County, Succasunna
(6692)............................................................................................
The Warren County National Bank, Washington (860). .
First National State Bank of Northwest Jersey, Succasunna
(860)..............................................................................................
The First National Bank of Glassboro (3843).......................
First National Bank of South Jersey, Egg Harbor Town­
ship (1326) ................................................................................
First National Bank of South Jersey, Egg Harbor Town­
ship (1326)...................................................................................

$281, 980

$553, 720

$204, 911

$14, 158, 280

8, 022, 000

8, 022, 000

3, 738, 157

297, 483, 713

8, 797, 440
206, 025
9, 170, 392
9, 691,632

8, 797,
304,
13, 107,
13, 096,

312, 500
8, 334, 940
8, 866, 188

550, 000
9, 735, 260
10, 285, 260

305, 608
10, 761,316
11,005, 107

22, 755, 784
367, 548, 851
390, 288,411

171,600

400, 000

106, 170

17, 145, 126

3, 748, 389

4, 568, 332

3, 582, 062

215, 696, 568

3, 980, 049

4, 908, 272

3, 688, 233

232, 841,695

1,058,750
430,000

1, 058, 750
1, 420, 000

1, 040, 900
1,251,068

48, 099, 372
44, 297, 397

1, 488, 750
100, 000

2, 478, 750
1, 000, 000

2, 291,969
444, 015

92, 396, 769
17, 533, 261

8, 797, 440

8, 797, 440

4, 127,518

351,832, 388

9, 697, 440

9, 697, 440

3, 871,533

369, 365, 050

200, 000
10,314, 425
10,514, 425
50,000

200,000
10, 340, 000
10, 540, 000
350, 000

222, 410
11,240, 870
11,452,780
137, 395

7, 442, 172
491,641,076
499, 083, 248
4, 875, 449

2, 799, 260

2, 799, 260

2, 166, 031

82, 500, 053

3,019, 260

3, 149, 260

2, 110, 982

87, 400, 246

150, 000
2, 033, 750
2, 183, 750
150, 000
493,018
555,518
150, 000
448, 000
498, 000

450, 000
3, 966, 250
4,4 1 6 ,0 0 0
200, 000
1, 206, 194
1, 687, 636
175, 000
565, 750
840, 750

244, 751
5, 798, 166
6, 043, 168
159, 877
1, 135, 037
1, 138, 632
26, 637
819, 434
846, 072

6, 930, 086
171,800,718
178,613, 694
6, 318, 393
41, 109, 472
47, 666, 696
3,915, 636
32, 070, 893
35, 986, 530

478, 220
16, 082,610
17, 158, 605
150, 000

771, 780
53, 917, 390
54, 091,395
750, 000

693, 091
16, 552,918
17, 311, 691
151,560

24,513,
1,422, 955,
1,438, 029,
13, 797,

18, 068, 825

37, 000, 000

13, 338, 351

1, 114, 132,313

18, 368, 825

37, 600, 000

13, 475,015

1, 127, 762, 356

440
095
608
470

3, 227,
418,
13, 158,
13, 577,

888
961
479
440

311,641,
15,918,
584, 769,
600, 688,

993
650
523
157

NEW YORK
Jan.

1

Feb.

16

May

28

Sept.

10

Sept.

20

The Millerton National Bank, Millerton (2661)...............
National Bank of Westchester, White Plains (10525). . . .
National Bank of Westchester, White Plains (10525). . . .
The Farmers National Bank of Deposit, Deposit (9 4 3 4 )...
The National Bank and Trust Company of Norwich, Nor­
wich (1354)..................................................................................
The National Bank and Trust Company of Norwich, Nor­
wich (1354)..................................................................................
Catskill National Bank and Trust Company, Catskill
(1294)............................................................................................
Marine Midland Bank— Eastern, N .A., Troy (721)...........
Marine Midland Bank— Eastern, N .A., Troy (721)...........
United Bank, Star Lake...............................................................
The St. Lawrence County National Bank, Canton (8531). .
The St. Lawrence County National Bank, Canton (8531). .
The First National Bank of Winthrop, Winthrop (10747). .
The Farmers National Bank of Malone, Malone (598). . .
The Farmers National Bank of Malone, Malone (598). . .

NORTH CAROLINA
Jan.

29

July

30

Bank of Washington, Washington............................................
North Carolina National Bank, Charlotte (13761).............
North Carolina National Bank, Charlotte (13761).............
Bank of Rocky Mount, Rocky Mount.....................................
First Union National Bank of North Carolina, Charlotte
(15650)..........................................................................................
First Union National Bank of North Carolina, Charlotte
(15650)..........................................................................................

422
180
155
091

See footnote at end of table.




169

T able B -17— Continued

*

,

,

Mergers of National banks, or National and State banks by States calendar 1971

Effective
date

Merging banks
Resulting bank
north

Dec.

31

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Carolina— continued

Bank of Farmville, Farmvillc......................................................
Bank of Windsor, Windsor..........................................................
First Union National Bank of North Carolina, Charlotte
(15650)..........................................................................................
First Union National Bank of North Carolina, Charlotte
(15650)..........................................................................................

$100,000
160,000

$ 1 ,0 0 0 ,0 0 0
840,000

$493,216
408,262

$1 0,631,998
14,674, 169

18, 368, 825

37 ,6 0 0 ,0 0 0

14, 873,002

1,291,712,721

19,088, 825

39, 000,000

15, 754,476

1,3 11,3 93 ,4 83

60,000
800,000
920,000

190,000
1,200,000
1,5 80,000

123,626
1,021, 176
894, 802

3, 509,836
32, 209,426
35, 719, 263

625,000

1,0 00,0 00

455, 361

36, 908,031

7 ,4 1 4 ,0 0 0

7, 586,000

8,406, 259

33 7,03 6,3 10

9, 164,000

9, 164, 000

7, 158,621

37 3,926,830

1,000,000

1,500,0 00

1, 397, 884

46, 557,693

3, 726, 800

6, 786,400

3, 751,874

213, 765,333

4, 926,800
800,000
14,958,216
14, 958, 216

8, 286,400
1,200,0 00
45, 296, 784
4 8 ,4 7 0 ,5 4 4

4, 949, 758
647, 179
28, 162,475
28, 162,475

259,095, 749
29,024 ,75 2
1,0 81,6 67 ,2 65
1, 111,218,598

100,000
3, 999, 775
4 ,0 9 9 ,7 7 5
200,000
5,0 0 0 ,0 0 0
5 ,0 0 0 ,0 0 0

200,000
8, 740, 975
8, 900, 225
40 0,00 0
10,000,000
10,000,000

224, 501
9 ,6 5 1 ,4 0 8
9,947, 392
314,875
9 ,2 33, 556
10, 163,602

4,7 72, 357
28 0,04 0,8 08
284, 908,067
8, 739,378
297, 835, 389
306,226, 828

51,000

175,000

272, 277

5,534, 241

700,000

810,000

807,913

50 ,637 ,71 0

785,000

810,000

1,221,191

56, 171,951

100,000
6 ,0 0 0 ,0 0 0
6, 282,050
724, 720
1,2 35,2 80
1,663, 920

400,000
7 ,0 0 0 ,0 0 0
7 ,2 1 7 ,9 5 0
300,000
1,340,627
1, 936, 540

234,669
2 ,6 4 7 ,8 1 2
2,882,481
96, 898
573, 260
670, 159

11,379,332
204,230, 351
213, 599,458
11,289,626
45, 524, 110
55, 447,433

201,000
6, 250, 000
6 ,5 5 1 ,5 5 0

140,000
5 ,0 0 0 ,0 0 0
5 ,0 0 0 ,0 0 0

99,482
1, 154,079
1,304, 175

6, 867,684
221,256,071
228,01 1,3 50

OHIO

Dec.

31

The Farmers and Merchants Bank Company, Smithville.
First National Bank, Orrville (13742)......................................
First National Bank, Orrville (13742)......................................
PENNSYLVANIA

Apr.

2

Sept.

Oct.

10

22

Pocono Bank, East Stroudsbuxg.................................................
Northeastern Pennsylvania National Bank and Trust
Company, Scranton (7 7 ).........................................................
Northeastern National Bank of Pennsylvania, Scranton
(7 7 ).................................................................................................
The First Stroudsburg National Bank, Stroudsburg
(3632)............................................................................................
The First National Bank of Eastern Pennsylvania, WilkesBarre (3 0 ).....................................................................................
The First National Bank of Eastern Pennsylvania, WilkesBarre (3 0 ).................. ..................................................................
The National Bank of Chester Valley, Goatesville (575). .
Provident National Bank, Philadelphia (15422)...................
Provident National Bank, Philadelphia (15422)...................
SOUTH CAROLINA

Jan.

29

Aug.

31

Bank of Clinton, Clinton..............................................................
First National Bank of South Carolina, Columbia (13720).
First National Bank of South Carolina, Columbia (13720).
Bank of Kershaw, Kershaw.........................................................
First National Bank of South Carolina, Columbia (13720).
First National Bank of South Carolina, Columbia (13720).
VERMONT

Nov.

1

Northfield Trust Company, Northfield....................................
The Merchants National Bank of Burlington, Burlington,
(1197).............................................................................................
The Merchants National Bank of Burlington, Burlington,
(1197).............................................................................................
VIRGINIA

June

1

Dec.

31

Eastern Shore Citizens Bank, Onancock.................................
United Virginia/Seaboard National, Norfolk (10194)........
United Virginia/Seaboard National, Norfolk (10194).........
Dominion Bank, Alexandria.......................................................
Dominion National Bank, Baileys Cross Roads (1 4 9 0 9 )...
Dominion National Bank, Baileys Cross Roads (1 4 9 0 9 )...
WASHINGTON

Mar.

19

National Bank of Mason County, Shelton (15418)..............
Puget Sound National Bank, Tacoma (12292).....................
Puget Sound National Bank, Tacoma (12292).....................

♦Excludes mergers involving only one operating bank, effected pursuant to corporate reorganization.

170




T able B—
18

,

Mergers resulting in National banks, by assets of acquiring and acquired banks 1960-71*

Assets of acquired bank*
Assets of acquiring bank\

Acquiring
bank

Under $10 $10 million to $25 million to $50 million to $100 million
million
$24.9
$49.9
$99.9
and over
million
million
'million

U nder $ 10 m illion..............................................
$10 million to $24.9 m illion............................
$25 million to $49.9 m illion............................
$50 million to $99.9 m illion............................
$100 million and o v e r.......................................

82
128
146
152
454

82
114
95
99
199

0
14
40
34
156

0
0
11
16
52

0
0
0
3
23

0
0
0
0
24

T o ta l.........................................................

962 J

589

244

79

26

24

♦Includes all forms o f acquisitions involving tw o or m ore banks, from M ay 13, 1960, through D ecem ber 31, 1971.
f i n each transaction, the bank with larger total assets was considered to be the acquiring bank.
{Com prises 925 transactions, 22 involving three banks, six involving four banks, and one involving five banks.

T

able

,

B-19

,

,

Domestic branches entering the National Banking System by de n opening, m
ovo
erger, or conversion by States calendar 1971

business
Branches openedfor <

Charter
No.

Title and location of bank

Total....................................................................................................................................

Local

Outside
branches

Total

257

573

830

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

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

2
3
2
2
2
1
1
2
2
1
1
1
3

1
1

1
0

2
1

0
2

2
6

2
8

0
1
0
1
1
1

1
0
1
0
0
0

1
1
1
1
1
1

ALABAMA
14569
3185
14414
14664
5249
15427
8765
13414
1595
11635
15053
15604
11846

Birmingham Trust National Bank, Birmingham.................................................................
The First National Bank of Birmingham, Birmingham.....................................................
State National Bank of Alabama, Decatur............................................................................
City National Bank of Dothan, Dothan..................................................................................
The First National Bank of Dothan, Dothan........................................................................
Shoals National Bank of Florence, Florence..........................................................................
The Henderson National Bank of Huntsville, Huntsville.................................................
The American National Bank & Trust Company of Mobile, Mobile.........................
The First National Bank of Mobile, Mobile..........................................................................
Opelika National Bank, Opelika...............................................................................................
Phenix National Bank, Phenix..................................................................................................
The Deposit National Bank of Mobile County, Prichard.................................................
The First National Bank of Russellville, Russellville..........................................................
ALASKA

12072
14651

The First National Bank of Anchorage, Anchorage............................................................
National Bank of Alaska, Anchorage.......................................................................................
ARIZONA

3728
14324

First National Bank of Arizona, Phoenix................................................................................
The Valley National Bank of Arizona, Phoenix..................................................................
ARKANSAS

11580
13719
15504
14000
11113
6758

The Farmers National Bank of Clarksville, Clarksville.....................................................
T h e First National Bank o f Conw ay, C o n w a y .....................................................................
First National Bank o f Crossctt, Crossett...............................................................................
T h e Com m ercial National Bank o f Little R ock, Little R o c k ..........................................
T h e First National Bank o f Nashville, Nashville.................................................................
T h e First National Bank o f Newport, N ew p ort...................................................................

171
403-40U 0 - 72--------42




T able

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States , calendar 1971
Branches openedfor business

Charter
No.

Title and location of bank

Local

Total

Outside
branches

CALIFORNIA
15437
14695
15434
11282
15089
15557
15453
15329
15007
15478
15495
15585
2491
6919
15220
15532
15276
15349
3050
10391
13044
9655
1741
15660
2158
15180
15443

American National Bank, Bakersfield......................................................................................
City National Bank, Beverly Hills............................................................................................
Commercial National Bank, Buena Park................................................................................
The First National Bank of Cloverdale, Cloverdale............................................................
First National Bank of Daly City, Daly City........................................................................
Imperial Valley National Bank, El Centro............................................................................
Escondido National Bank, Escondido......................................................................................
Humboldt National Bank, Eureka............................................................................................
First National Bank of Fresno, Fresno.....................................................................................
Mechanics National Bank, Huntington Park........................................................................
Mid-Cal National Bank, Lodi....................................................................................................
Bank of Long Beach, National Association, Long Beach...................................................
Security Pacific National Bank, Los Angeles, Los Angeles...............................................
Central Bank, National Association, Oakland......................................................................
West Coast National Bank, Oceanside....................................................................................
Commercial and Farmers National Bank, Oxnard.............................................................
Palm Springs National Bank, Palm Springs..........................................................................
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 National Bank, San Francisco...................................................................................
Wells Fargo Bank, National Association, San Francisco...................................................
The First National Bank of San Jose, San Jose...................................................................
Security National Bank, Walnut Creek...................................................................................
National Bank of Whittier, Whittier........................................................................................

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

2
1
1
1
1
1
0
1
0
1
1
0
24
1
0
2
1
1
4
2
25
9
6
10
1
1
1

2
1
1
1
1
1
1
1
1
1
1
1
26
2
1
2
1
2
6

0
0
0
0

1
1

4
0
0
0
1
1
1
0
1
1
1

12
2

16

0
0
0

3
1
1
1
1
1
1

1
2
1
1

0
0
0
0

1
2
1
1

2
0
2
1
0
0
1

0
11
2
6

2
11
4
7

1
0

1
1

2

1
0
0

2

25
9
7
12
2
1

1

COLORADO

7501
1016
14248
14826

1
1
1

The First National Bank of Arvada, Arvada........................................................................
The First National Bank of Denver, Denver.........................................................................
Union National Bank in Denver, Denver..............................................................................
First National Bank in Walsenburg, Walsenburg................................................................

1

1
1

CONNECTICUT

780
335
4
15542
1338
720
2

227
15294
15549
780

The City National Bank of Connecticut, Bridgeport..........................................................
The Connecticut National Bank, Bridgeport........................................................................
The State National Bank of Connecticut, Bridgeport. . . ..................................................
The Constitution National Bank, Hartford............................................................................
Hartford National Bank and Trust Company, Hartford...................................................
The Home National Bank and Trust Company, Meriden...............................................
The First New Haven National Bank, New Haven............................................................
The Second National Bank of New Haven, New Haven..................................................
The Fairfield County National Bank, Norwalk....................................................................
Citizens National Bank of Southington, Southington.........................................................
The Waterbury National Bank, Waterbury..........................................................................

3
1
2

0
0
1

3

2

1

DISTRICT OF COLUMBIA

2038
15208
3425
15700

The First National Bank of Washington, D .C ., Washington...........................................
Madison National Bank, D .C ., Washington..........................................................................
The National Bank of Washington, D .C ., Washington......................................................
Security National Bank, D .C., Washington...........................................................................
GEORGIA

14907
1559
9617
15541
1860
14483
4944

The National Bank of Albany, Albany...................................................................................
The First National Bank of Atlanta, Atlanta........................................................................
The Fulton National Bank of Atlanta, Atlanta....................................................................
The National Bank of Georgia, Atlanta..................................................................................
The First National Bank and Trust Company of Augusta, Augusta.............................
American National Bank of Brunswick, Brunswick.............................................................
The First National Bank of Brunswick, Brunswick..............................................................

172




1

3

3

T able

B-19—Continued

Dom
estic branches entering th National Banking System, by de n opening, m
e
ovo
erger, or conversion, by States, calen
dar 1971

Branches openedfor business

Charter
No.

Title and location of bank

Outside
branches

Local

Total

Georgia— continued
7549
4012
9613
15148
3907
3983
15572
15614
3830
2368
10302
13068
15616
15651

The Calhoun First National Bank, Calhoun.........................................................................
The First National Bank of Cartersville, Cartersville.........................................................
The First National Bank of Cornelia, Cornelia....................................................................
First National Bank of Newton County, Covington............................................................
The First National Bank of Dalton, Dalton..........................................................................
The First National Bank of Gainesville, Gainesville...........................................................
First National Bank of Griffin, Griffin.....................................................................................
The First National Bank of Wayne County, Jesup.............................................................
The First National Bank of Cobb County, Marietta..........................................................
The First National Bank of Rome, Rome..............................................................................
The National City Bank of Rome, Rom e..............................................................................
The Citizens and Southern National Bank, Savannah......................................................
The Security National Bank, Smyrna.....................................................................................
First National Bank of Trion, Trion........................................................................................

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

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

1
1
1
1
1
1
1
1
2
1
2
12
1
1

0
0
0
1

1
1
1
1

1
1
1
2

1
1
1
1
1
1
1
1
1
1
1
1
1

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

1
1
1
1
1
1
1
1
1
1
1
1
1

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

0
0
0
0
1
0
0
1
4
3
1
0
0
0

1
1
2
1
1
1
1
2
5
3
1
1
1
1

1
1
1
1
1
1
0
1

0
0
0
0
0
0
1
0

1
1
1
1
1
1
1
1

IDAHO

14444
1668
11076
4773

First Security Bank of Idaho, National Association, Boise...............................................
The Idaho First National Bank, Boise.....................................................................................
The Farmers National Bank of Buhl, Buhl............................................................................
The First National Bank of Wallace, Wallace......................................................................
ILLINOIS

2154
14402
13146
6125
15612
4003
14387
14509
14439
14494
13886
14555
14521

First National Bank of Belleville, Belleville...........................................................................
The Belvidere National Bank and Trust Company, Belvidere........................................
La Salle National Bank, Chicago.............................................................................................
The First National Bank of Collinsville, Collinsville..........................................................
First National Bank of Eureka, Eureka..................................................................................
The First National Bank of Harrisburg, Harrisburg..........................................................
The Harrisburg National Bank, Harrisburg.........................................................................
Montgomery County National Bank, Hillsboro..................................................................
Union National Bank and Trust Company of Joliet, Joliet............................................
Palatine National Bank, Palatine.............................................................................................
The National Bank of Savanna, Savanna..............................................................................
First National Bank of Skokie, Skokie....................................................................................
Busey First National Bank, Urbana.........................................................................................
INDIANA

5267
12132
13818
7725
10718
14468
14292
14529
13759
984
869
11148
13816
3864

The Riddell National Bank of Brazil, Indiana, Brazil.......................................................
The National City Bank of Evansville, Evansville..............................................................
Fort Wayne National Bank, Fort W ayne..............................................................................
Lincoln National Bank and Trust Company of Fort Wayne, Fort Wayne.................
The First National Bank of Fremont, Fremont...................................................................
Gary National Bank, Gary.........................................................................................................
The National Bank of Greenwood, Greenwood...................................................................
Mercantile National Bank of Indiana, Hammond..............................................................
American Fletcher National Bank and Trust Company, Indianapolis.........................
The Indiana National Bank, Indianapolis............................................................................
Merchants National Bank & Trust Company of Indianapolis, Indianapolis............
Purdue National Bank of Lafayette, Lafayette.....................................................................
First National Bank in New Castle, New Castle..................................................................
The American National Bank of Vincennes, Vincennes...................................................
IOW A

2511
14868
317
13707
15579
107
10812
13112

The Merchants National Bank of Cedar Rapids, Cedar Rapids.................................
Northwest Des Moines National Bank, Des Moines...........................................................
The First National Bank of Dubuque, Dubuque...............................................................
The Community National Bank & Trust Company of Knoxville, Knoxville...........
First National Bank of Muscatine, Muscatine......................................................................
First National Bank of Ottumwa, Ottumwa.......................................................................
The First National Bank of Paullina, Paullina.....................................................................
The Clay County National Bank of Spencer, Spencer......................................................




173

T able B -19— Continued

Domestic branches entering the National Banking Systemy by de novo opening, merger, or conversion, by States , calendar 197.

Branches openedfor business

Charter
No.

Title and location of bank

Local

Outside
branches

Total

KANSAS
3180

T h e First National Bank o f Hutchinson, H utchinson.........................................................

1

0

1

1
1
0
1
0
1
1
1

o
0
1
0
2
0
0
0

1
1
1
1
2
1
1
1

1
1
0
1

0
0
1
0

1
1
1
1

KENTUCKY
9365
6028
2901
10254
109
14320
13763
995

T h e Am erican National Bank & Trust Com pany o f Bowling Green, Bowling
G re e n .............................................................................................................................................
T h e First-Hardin National Bank o f Elizabethtown, Elizabethtow n.............................
T h e Second National Bank and Trust C om pany o f Lexington, L exington...........
Second National Bank o f L ondon, L o n d o n ...........................................................................
First National Bank o f Louisville, Louisville..........................................................................
Liberty N ational Bank and Trust Com pany o f Louisville, Louisville...........................
T h e First National Bank o f Paintsville, Paintsville..............................................................
T h e Clark County National Bank o f Winchester, W inchester.......................................
LOUISIANA

9834
5023
14849
13689

Louisiana National Bank o f Baton R ouge, Baton R o u g e ..................................................
T h e First National Bank o f Lafayette, Lafayette...............................................................
Lakeside National Bank o f Lake Charles, Lake Charles....................................................
First National Bank o f Com m erce, N ew O rleans.................................................................
MAINE

498
3941
1089
2260
941
13768
13730

Bank o f M aine, N .A ., Augusta..................................................................................................
T h e First National Bsrnk o f Bar H arbor, Bar H a rb o r ........................................................
T h e First National Bank o f Biddeford, B iddeford................................................................
First-Manufacturers National Bank o f Lewiston and Auburn, L ew iston.....................
Canal National Bank, P ortland.................................................................................................
Northern National Bank, Presque Isle....................................................................................
Springvale National Bank, Sprm gvale.....................................................................................

1

0
0
1
t
1
1
0

1
0
0
0
0
1

1
1
1
1
1
1

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

1
8
1
0
1
1
1
2
1
1
1
1

1
9
1
1
l
1
1
2
1
1
1
1

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

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

2

MARYLAND
1413
13745
15285
1267
15051
4364
13776
15365
14937
15154
5471
15%

T h e First National Bank o f M aryland, Baltim ore...............................................................
M aryland National Bank, Baltim ore................................................. ......................................
Belair National Bank, B ow ie.......................................................................................................
Farmers and M echanics National Bank, Frederick.............................................................
T h e Central National Bank o f M aryland, H illandale........................................................
T h e Citizens National Bank, L au rel........................................................................................
T h e Garrett National Bank in Oakland, O akla nd..............................................................
University National Bank, R ock ville.......................................................................................
Am erican National Bank o f M aryland, Silver Sprin g........................................................
Peoples National Bank o f M aryland, Suitland.....................................................................
T h e First National Bank o f Southern M aryland o f U pper M arlboro, U pper M a rlb o ro .
T h e U n ion National Bank o f Westminster, W estminster..................................................
MASSACHUSETTS

15483
475
2504
779
614
2153
528
6077
14834
13241
1144
2232
5944
2108
79
516

H arbor N ational Bank o f Boston, Boston...............................................................................
N ew England M erchants National Bank o f Boston, Boston.............................................
First County National Bank, B rockton....................................................................................
Plym outh-H om e National Bank, Brockton.............................................................................
M iddlesex Bank, N .A ., Everett...............................................................................................
First Safety Fund National Bank, Fitch bu rg.........................................................................
T h e Fram ingham National Bank, Fram ingham ..................................................................
U nion National Bank, L ow ell....................................................................................................
First N ational Bank o f Natick, N atick.....................................................................................
N eedham National Bank, N eedham .........................................................................................
T h e Shelburne Falls National Bank, Shelburne Falls........................................................
First Bristol County National Bank, T a u n ton .......................................................................
United National Bank, T a u n ton ...............................................................................................
T h e U nion M arket National Bank o f W atertown, W atertow n .......................................
W orcester County National Bank, W orcester.......................................................................
T h e First National Bank o f Yarm outh, Yarm outh P ort....................................................

174




2

T able B -19— Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by States, calendar 1971

Branches openedfor business

Charter
No.

Title and location of bank

Local

Outside
branches

Total

MICHIGAN
15001
15164
14641
14948
13671
3761
15446
15575
13741
191
14032
1731
14843
12027
14582
13753
13739
1918
14523
13874
15889

Central National Bank o f Alm a, A lm a ...................................................................................
H uron Valley National Bank, Ann A rb o r.............................................................................
Peoples National Bank & Trust Com pany o f Bay City, Bay C ity .................................
M ichigan Bank, National Association, D etroit.....................................................................
National Bank o f D etroit, D etroit.............................................................................................
T h e First National Bank and Trust Com pany, Escanaba................................................
First National Bank o f Fenton, F en ton ...................................................................................
U nion Bank and Trust Com pany, National Association, Grand R a p id s.....................
T h e National Bank o f Jackson, Ja ckson ......................................... ....................................
T h e First National Bank and Trust Com pany o f M ichigan, K ala m a zoo....................
M ichigan National Bank, Lansing...........................................................................................
T h e First National Bank o f Lapeer, L a p eer..........................................................................
Security National Bank o f Manistee, M anistee....................................................................
T h e U nion National Bank and Trust Com pany o f M arquette, M arquette................
First National Bank & Trust Com pany o f M idland, M id la n d ......................................
First National Bank o f Southwestern M ichigan, Niles.......................................................
Com m unity National Bank o f Pontiac, Pontiac...................................................................
Second National Bank o f Saginaw, Saginaw ........................................................................
First National Bank & Trust Com pany, Sturgis.................................................................
National Bank W yandotte-Taylor, T a y lo r ............................................................................
T h e Am erican Bank o f Three Rivers, National Association, Three R ivers................

0
0
1
1
1
0
1
0
a
i
i
i

1
2
1
1

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

i
l
l
l
2
0
0
0

1
1
2
1
1
1
1
1
1
1
1
1
3
1
1
1

1

0

1

0
0
1
0
0

1
2
0
1
1

1
2
1
1
1

1
1
1

0
0
0

1
1
1

1
1

0
0

1
1

1
1

0
0

1
1

1
0

2
1

3
1

0
0
0

1
1
1

1
1
1

i

MINNESOTA

12922

Northwestern National Bank o f St. Paul, St. P aul..............................................................
MISSISSIPPI

3656
5176
15539
15851
15386

T h e First National Bank o f Aberdeen, A berdeen................................................................
First Mississippi National Bank, H attiesburg........................................................................
Southern National Bank o f Hattiesburg, H attiesburg........................................................
First National Bank, R osedale...................................................................................................
First National Bank o f Iuka, Iu k a ............................................................................................
MISSOURI

1467
13875
12916

First National Bank and T rust Com pany, C olu m b ia .........................................................
T h e National Com m ercial Bank o f Liberty, L ib erty..........................................................
T h e Boatmen’ s National Bank o f St. Louis, St. L ou is.......................................................
MONTANA

15564
12407

First National Bank and Trust Com pany, Billings..............................................................
T h e M idland National Bank o f Billings, Billings.................................................................
NEBRASKA

2994
209

T h e First National Bank o f Fairbury, Fairbury...................................................................
First National Bank o f O m aha, O m a h a .................................................................................
NEVADA

7038
15645

First National Bank o f Nevada, R eno, Nevada, R e n o .......................................................
Nevada National Bank, R e n o ....................................................................................................
NEW HAMPSHIRE

8038
1885
1059

First National Bank o f Derry, D erry .......................................................................................
T h e Littleton National Bank, L ittleton..................................................................................
Bank o f New Hampshire, National Association, M anchester..........................................




T able

B-19—Continued

Domestic branches entering the National Banking System , by de novo opening, merger, or conversion,

States, calendar 1971

Branches openedfor business

Charter
No.

Title and location of bank

Local

Outside
branches

Total

NEW JERSEY
15781
11658
9498
1222
1209
13203
14975
15709
1114
2076
15430
1326
1436
4365
2331
3843
12014
15570
12022
8227
4147
1737
1191
14673
4274
6728
13363
15505
12732
14145
13174
5712
12984
5005
3922
15228
3866
860
2509
1327
3709
860
12022
12977

Atlantic National Bank, Atlantic City....................................................................................
Beach Haven National Bank and Trust Company, Beach Haven.................................
The Farmers and Merchants National Bank of Bridgeton, Bridgeton..........................
Mechanics National Bank of Burlington County, Burlington..........................................
South Jersey National Bank, Camden....................................................................................
The Third National Bank and Trust Company of Camden, Camden.........................
Delaware Valley National Bank, Cherry Hill......................................................................
New Jersey Bank (National Association), Clifton................................................................
First Clinton National Bank, Clinton......................................................................................
The National Union Bank of Dover, Dover..........................................................................
Raritan Valley National Bank, Edison Township................................................................
First National Bank of South Jersey, Egg Harbor Township..........................................
The National State Bank, Elizabeth, New Jersey, Elizabeth..........................................
Citizens National Bank, Englewood........................................................................................
The Flemington National Bank and Trust Company, Flemington...............................
The First National Bank of Glassboro, Glassboro...............................................................
First National State Bank of North Jersey, Hackensack...................................................
Garden State National Bank, Hackensack............................................................................
Peoples National Bank of New Jersey, Haddon Township...............................................
The Hardyston National Bank of Hamburg, Hamburg....................................................
Peoples National Bank of Monmouth County, Hazlet.......................................................
The First National Bank of Hightstown, Hightstown........................................................
The Burlington County National Bank of Medford, Medford........................................
The City National Bank of Millville, Millville.....................................................................
American National Bank & Trust, Montclair.....................................................................
The Farmers National Bank of Mullica Hill, Mullica Hill..............................................
First Merchants National Bank, Neptune Township..........................................................
Security National Bank, Newark..............................................................................................
Meadowlands National Bank, North Bergen.......................................................................
The Cape May County National Bank, Ocean City.........................................................
United National Bank of Central Jersey, Plainfield...........................................................
Ocean County National Bank, Point Pleasant.....................................................................
The First National Bank of Burlington County, Riverside..............................................
National Community Bank of Rutherford, Rutherford....................................................
The City National Bank and Trust Company of Salem, Salem.....................................
Plaza National Bank, Secaucus................................................................................................
The First National Bank of Central Jersey, Somerville.....................................................
First National State Bank of Northwest New Jersey, Succasunna.................................
The First National Bank of Toms River, Toms River.......................................................
New Jersey National Bank, Trenton......................................................................................
The Broad Street National Bank of Trenton, Trenton.....................................................
The Warren County National Bank, Washington..............................................................
Peoples National Bank of New Jersey, Westmont...............................................................
Citizens National Bank of South Jersey, Woodbine...........................................................

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

1
1
1
1
3
5
0
2
1
1
0
2
2
1
1
0
1
2
1
1
1
1
1
0
2
1
1
1
0
0
1
1
0
4
1
1
2
1
0
1
1
1
5
1

1
1
1
1
3
5
1
2
1
1
1
2
2
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
4
1
1
2
1
1
1
1
1
5
1

1
0
0
3

0
1
1
0

1
1
1
3

0
1
0
0
1
0
0
0
1
0
0

3
1
1
1
6
1
1
3
0
1
2

3
2
1
1
7
1
1
3
1
1
2

NEW M
EXICO
13814
14577
15108
14912

First National Bank in Albuquerque, Albuquerque...........................................................
Liberty National Bank, Lovington...........................................................................................
Los Alamos National Bank, Los Alamos................................................................................
Security National Bank of Roswell, Roswell.........................................................................
NEW YORK
’

15758
1301
1253
15625
12997
15080
13590
8531
976
9990
11511

First Trust Company of Albany, National Association, Albany.....................................
National Commercial Bank and Trust Company, Albany...............................................
Ballston Spa National Bank, Ballston Spa.............................................................................
First-City National Bank of Binghampton, N .Y ., Binghampton.....................................
Franklin National Bank, Brooklyn..........................................................................................
Liberty National Bank and Trust Company, Buffalo........................................................
United National Bank, Callicoon.............................................................................................
The St. Lawrence County National Bank, Canton............................................................
The Putnam County National Bank of Carmel, Carmel..................................................
The Central Valley National Bank, Central Valley...........................................................
Marine Midland Tinker National Bank, East Setauket....................................................

176



T able

B-19—Continued

branches entering the National Banking System , by de novo opening, merger, or conversion, by

Branche

Charter
No.

Title and location of bank

new

11087
6587

222

7703
15626
1753
598
13956
13955
2370
1461
15029
13295
1354
15641
465
11708
14763
1342
721
1392
8158
10525

york—

Local

c o n tin u e d

Long Island National Bank, Hicksville...........................................................................
Security National Bank, Huntington................................................................................
First National Bank and Trust Company of Ithaca, Ithaca.....................................
National Bank of North America, Jamaica....................................................................
The First National Bank of Jamestown, Jamestown...................................................
Keesville National Bank, Keesville...................................................................................
The Farmers National Bank of Malone, Malone.........................................................
Empire National Bank, Middletown................................................................................
First Westchester National Bank, New Rochelle..........................................................
The Chase Manhattan Bank (National Association), New York.............................
First National City Bank, New Y o rk ...............................................................................
Royal National Bank of New York, New Y o rk .................................... ........................
Sterling National Bank & Trust Company of New York, New York....................
The National Bank and Trust Company of Norwich, Norwich...............................
Bankers Trust Hudson Valley, National Association, Poughkeepsie..............
Marine Midland Bank of Southeastern New York, N .A ., roughkeepsie___
Scarsdale National Bank and Trust Comapny, Scarsdale.........................................
Eastern National Bank of Long Island, Smithtown.....................................................
The Merchants National Bank & Trust Company of Syracuse, Syracuse, . . . . . .
Marine Midland Bank-Eastern National Association, Troy.....................................
The Oneida National Bank and Trust Company of Central New York, U tica..
Seaway National Bank, Watertown . .. . ; ....................................................................
National Bank of Westchester, White Plains..................................................................

0
0

1

0

0
0

0
0
1
3
3

1
1
0
0
1
0
0
0
0
0

1
0

1
1
4
1
1
1
1
1
3

2
9

1
1
1

1
7

2

l
2
3

2

1

1

NORTH CAROLINA

15636
15650
15650
13761
4597
14676
6744
10610
11229
10608
15165
6776
15673

City National Bank, Charlotte................................................................................................
First Union National Bank of North Carolina, Charlotte..............................................
First Union National Bank of North Carolina, Charlotte..............................................
North Carolina National Bank, Charlotte...........................................................................
First National Bank of Catawba County, Hickory...........................................................
Bank of North Carolina, National Association, Jacksonville.........................................
Carolina First National Bank, Lincolnton...........................................................................
Southern National Bank of North Carolina, Lumber ton................................................
First National Bank of Reidsville, Reidsville......................................................................
The Planters National Bank and Trust Company, Rocky Mount...............................
First National Bank of Smithfield, Smithfield....................................................................
The First National Bank of Shelby, Shelby.........................................................................
Wachovia Bank and Trust Company, N .A., Winston-Salem........................................

1

2

0
1
0
0
0
0
1
0
0
1
0

1
14

1
1
1

1
1
3
1
2
1
1
7

15

OHIO

15609
14579
3721
15227
7744
911
24
14761
7745
5065
2604
15861
36
4884
13767
4164
3234
43
14586
15470
2479
1997

Akron National Bank and Trust Company, Akron..........................................................
First National Bank of Akron, Akron....................................................................................
First National City Bank of Alliance, Alliance...................................................................
Tiffin Valley National Bank, Archbold................................................................................
The Athens National Bank, Athens.......................................................................................
The First National Bank of Barnesville, Barnesville.........................................................
The First National Bank of Cincinnati, Cincinnati..........................................................
Society National Bank of Cleveland, Cleveland................................................................
The Huntington National Bank of Columbus, Columbus..............................................
The Ohio National Bank of Columbus, Columbus..........................................................
The Winters National Bank and Trust Company of Dayton, Dayton.......................
Citizensbank National Association, Felicity........................................................................
The First National Bank of Findlay, Eindlay.....................................................................
The First National Bank of Girard, Girard.........................................................................
First National Bank and Trust Company of Lima, Lima...............................................
The Citizens National Bank of Marietta, Marietta..........................................................
Clermont National Bank, Milford..........................................................................................
The First National Bank of Salem, Salem.........................................................................
First National Bank of Toledo, Toledo................................................................................
Progress National Bank of Toledo, Toledo.........................................................................
The Second National Bank of Warren, Warren................................................................
The Clinton County National Bank and Trust Company of Wilmington, Wilming­
ton ...............................................................................................................................................




0
0

1

0
1
1
0
0

2
2

0
0

2
2
1
1
1

1
1
1

3

2

1
1

1
0

1
1
2
1
1
1
1
1
1

0

1

1
1
1

0
0
0

1

T able

B-19— Continued

Domestic branches entering the N ational Banking System , by de novo opening, merger, or conversion, by States , calendar 1971

Branches openedfor business

Charter
No.

Title and location of bank

Local

Outside
branches

Total

o h io —continued

828
13586

T h e W ayne County National Bank, W ooster.......................................................................
T h e U nion National Bank o f Youngstown, Y oun gstow n ....................................... ...........

1
0

1
1

2
1

1
1
1
1

0
0
0
0

1
1
1
1

1
l
1

o
0
0

1
1
1

0
0
1
1

2
5
0
2

2
5
1
3

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

0
0
1
2
1
1
1
1
0
l
1
1
1
2
1
0
1
1
0
1
1
2
1
1
1
5
1
1
0
1
l
3
1
3
1
1
1
2

1
1
1
2
1
1
1
1
1
1
1
1
1
2
1
1
2
1
1
1
1
2
1
1
1
6
1
1
1
2
2
3
1
3
1
1
1
2

OKLAHOMA
12169
10051
12918
5248
11230
9564
14751

T h e First National Bank o f Bethany, Bethany.....................................................................
T h e Peoples National Bank o f Chccotah, C h ecota h ...........................................................
T h e Citizens National Bank o f M uskogee, M u s k o g e e ......................................................
T h e First National Bank and Trust Com pany, N orm a n ...................................................
T h e Liberty National Bank and Trust C om pany o f O klahom a City, O klahom a
C ity ................................................................................................................................................
City National Bank and Trust Com pany, O klahom a City, O klahom a C ity ...........
Security National Bank o f Sapulpa, Sa pu lpa........................................................................
OREGON

15583
1553
15491
4514

Crater National Bank, M e d fo rd ................................................................................................
First National Bank o f O regon, P ortland...............................................................................
Great Western National Bank, P ortland................................................................................
United States National Bank o f O regon, P ortland..............................................................
PENNSYLVANIA

373
6645
9139
15422
14170
664
355
6037
5084
7702
580
6445
4965
14098
694
10506
9207
11524
4625
13618
11244
870
2252
14542
4352
539
15422
4832
6301
252
2222
77
2333
328
5034
4879
11866
30

T h e First National Bank o f Allentown, A llentow n..............................................................
T h e M erchants National Bank o f Allentown, A llentow n ..................................................
T h e National Bank o f Arendtsville, Arendtsville..................................................................
Provident National Bank, Bryn M a w r...................................................................................
First National Bank in Bangor, Bangor...................................................................................
First National Bank, Carbondale, Pennsylvania, C a rb on d ale.........................................
Southeast National Bank o f Pennsylvania, Chester.............................................................
T h e D enver National Bank, D en ver........................................................................................
T h e First National Bank o f Ebensburg, Ebensburg.............................................................
Peoples National Bank o f Susquehanna County, H allstead..............................................
T h e Com m onw ealth National Bank, H arrisburg.................................................................
T h e First National Bank o f Hawley, H aw ley........................................................................
U nion National Bank & Trust C om pan y o f H untingdon, H untingdon......................
National Bank o f the Com m onwealth, In d ia n a ....................................................................
National Central Bank, Lancaster............................................................................................
T h e Russell National Bank, Lew iston.....................................................................................
Com m unity National Bank o f Southern Pennsylvania, Littlestown...............................
T h e First National Bank o f Loysville, Loysvillc...................................... .............................
M cK eesport National Bank, M cK eesport...............................................................................
First Citizens National Bank, M an sfield.................................................................................
T h e First National Bank o f M apleton, M apleton D e p o t...................................................
U pp er D auphin National Bank, M illersburg.........................................................................
Cum berland County National Bank and Trust Com pany, N ew C um berland...........
T h e First National Bank o f Pen Argyl, Pen A rgy l...............................................................
T h e Philadelphia National Bank, Philadelphia....................................................................
Ptovident National Bank, Philadelphia...................................................................................
T h e First National Bank o f Philipsburg, Philipsburg..........................................................
M ellon National Bank and Trust Com pany, Pittsburgh....................................................
Pittsburgh National Bank, Pittsburgh......................................................................................
Western Pennsylvania National Bank, Pittsburgh...............................................................
Northeastern National Bank o f Pennsylvania, Scranton....................................................
U nion National Bank and Trust C om pany o f Souderton, Souderton...........................
Citizens & Northern National Bank and Trust C om pany, T ow a n d a ...........................
Gallatin National Bank, U n ion tow n ........................................................................................
T h e W arren National Bank, W arren .......................................................................................
First National Bank and Trust C om pany, W a yn esb oro....................................................
T h e First National Bank o f Eastern Pennsylvania, Wilkes-Barre....................................

178



T able B-19—
~Continued

Domestic branches entering the National Banking System , by de novo opening, merger, or conversion, by States , calendar 1971

Branches openedfor business

Charter
No.

Tide and location of bank

Local

Outside
branches

Total

RHODE ISLAND
13981
15723

Colum bus National Bank o f R h od e Island, Providence....................................................
R h ode Island Hospital Trust National Bank, Providence................................................

1
1

1
2

2
3

0
0
1
1
1
1
1

3
2
3
2
3
0
0

3
2
4
3
4
1
1

1
0

0
4

1
4

0
1
1
1
0
l
1
1
1
1
0
2
1
0
0

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

2
1
1
1
1
1
1
1
2
1
1
2
1
1
1

0
0

1
1

1
1

0

1

1

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

1
1
1
0
0
0
0
1
0
1
1
0
1
0
1
5
2

1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
6
3

SOUTH CAROLINA
14425
2044
13720
10635
15875
13918
14448

T h e Citizens and Southern National Bank o f South Carolina, Charleston................
T h e Southern National Bank o f Charleston, Charleston...................................................
First National Bank o f South Carolina, C olum bia.............................................................
T h e Peoples National Bank, G reenville..................................................................................
First Peoples National Bank o f South Carolina, Hartsville..............................................
First National Bank in Orangeburg, O rangeburg...............................................................
R ock Hill National Bank, R ock H ill.......................................................................................
SOUTH DAKOTA

3578
15639

T h e M itchell National Bank, M itch ell...................................................................................
United National Bank o f South Dakota, R apid C ity .........................................................
TENNESSEE

14611
8443
4177
12031
15056
13635
10842
336
13681
13349
3032
13103
14828
8889
8640

Am erican National Bank & Trust Com pany o f Chattanooga, C hattanooga.............
T h e Harpeth National Bank o f Franklin, Franklin............................................................
T h e First National Bank o f Greeneville, Greeneville.........................................................
First National Bank in Harriman, H arrim an.......................................................................
T h e First National Bank o f G ibson County, H u m b old t...................................................
T h e H am ilton National Bank o f Johnson City, Johnson C ity ........................................
T h e First National Bank o f Sullivan County, K ingsport...... ............................................
T h e First National Bank o f M emphis, M em p h is................................................................
National Bank o f Com m erce, M em phis.................................................................................
U nion Planters National Bank o f M em phis, M em ph is.....................................................
First Am erican National Bank o f Nashville, N ashville......................................................
T h ird National Bank in Nashville, N ashville.......................................................................
National Bank o f N ew port, N ew port......................................................................................
T h e First National Bank o f Savannah, Savannah..............................................................
T h e Farmers National Bank o f Winchester, W inchester...................................................
UTAH

2597
4341

First Security Bank o f Utah, National Association, O g d en ..............................................
Zions First National Bank, Salt Lake C ity ............................................................................
VERMONT

1197

T h e M erchants National Bank o f Burlington, Burlington................................................
VIRGINIA

7093
9375
10618
7973
5394
12240
15353
14904
15334
1582
12290
12267
5261
10834
6748
10194
9885

Alexandria National Bank, A lexandria..................................................................................
T h e Buchanan National Bank, Buchanan......... ................................................................
National Bank and Trust C om pany, Charlottesville..........................................................
T h e First National Bank o f Christiansburg, Christiansburg............................................
T h e Second National Bank o f Culpeper, C u lpeper............................................................
T h e Citizens National Bank o f Em poria, E m poria............................................................
W oodlaw n National Bank, Fairfax C ou n ty...........................................................................
D om inion National Bank, Baileys Cross Roads, Falls C h u rch ........................................
Am erican National Bank, Fredericksburg..............................................................................
T h e National Bank o f Fredericksburg, Fredericksburg.....................................................
T h e First National Bank o f Fries, Fries..................................................................................
T h e O ld Point National Bank o f Phoebus, H a m p ton ........................................................
Rockingham National Bank, H arrisonburg...........................................................................
T h e Grayson National Bank, Independence.........................................................................
T h e Peoples National Bank o f Manassas, M anassas...........................................................
United Virginia Bank/Seaboard National Bank, N orfolk.................................................
Virginia National Bank, N orfolk ..............................................................................................




179

T able

B-19—Continued

Domestic branches entering the National Banking System , by de novo opening, merger, or conversion ,

States, calendar 1971

Branches openedfor business

Charter
No.

Title and location of bank

Local

Total

Outside
branches

Virginia— continued
10080

mi

15530
15567
2737
15117
1620
6126
6235

The Central National Bank of Richmond, Richmond.......................................................
First & Merchants National Bank, Richmond....................................................................
Metropolitan National Bank, Richmond................................................................................
Second National Bank of Richmond, Richmond.................................................................
The First National Exchange Bank of Virginia, Roanoke................................................
United Virginia Bank/Security National Bank, Roanoke.................................................
United Virginia Bank/National Valley, Staunton...............................................................
The Fauquier National Bank of Warrenton, Warrenton............................ ......................
The Wise County National Bank, Wise..................................................................................

1
1
0
0
2
1
1
0
0

0
3
1
1
0
0
0
1
1

1
4
1
1
2
1
1
1
1

1

0

1

1
0
1
1
3
0
0
2
2
0

0
2
1
0
2
2
1
2
0
2

1
2
2
1
5
2
1
4
2
2

VIRGIN ISLANDS
14335

Virgin Islands National Bank, St. Thomas............................................................................
WASHINGTON

12114
15640
15906
13
4375
3417
14394
11280
4668
12292

The First National Bank of Enumclaw, Enumclaw............................................................
South Sound National Bank, Lacey.........................................................................................
Olympic National Bank, Port Angeles....................................................................................
The First American National Bank of Port Townsend, Port Townsend......................
The National Bank of Commerce 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
13645
8281
212
4975

The American National Bank and Trust Company of Eau Claire, Eau Claire.........
First Wisconsin National Bank of Eau Claire, Eau Claire...............................................
The First National Bank of Kenosha, Kenosha...................................................................
First National Bank in Manitowoc, Manitowoc...................................................................

180




0
0
0
0

1
1
1
1

1
1
1
1

T able

B-20

Domestic branches o f National banks closed , by States, calendar 1971

13ranches closeri

Charter
No.

Title and location of bank

Local

Total

Outside
branches
38

52

90

1
1

1
0

2
1

...........

1

0

1

Bank of Long Beach, National Association, Long Beach..................................................
Bank of America National Trust and Savings Association, San Francisco..................
Crocker National Bank, San Francisco..................................................................................

2
0
0

0
5
2

2
5
2

0
1

1
0

1

Total.....................................................................................................................................
ALABAMA
15466
6173

City National Bank of Russellville, Russellville...................................................................
The City National Bank of Tuscaloosa, Tuscaloosa...........................................................
ARKANSAS

11113

The First National Bank of Nashville, Nashville.....................
CALIFORNIA

15585
13044
1741

CONNECTICUT
4
720

The State National Bank of Connecticut, Bridgeport........................................................
The Home National Bank and Trust Company, Meriden.............................................
ILLINOIS

11478

The St. Clair National Bank of Belleville, Belleville..........................................................

1

0

1

14468
12444

INDIANA
Gary National Bank, Gary.........................................................................................................
Old National Bank in Evansville, Evansville........................................................................

1
1

0
0

1
1

M
AINE
Maine National Bank, Portland.......................................................................

.........

0

1

1

The First National Bank of Maryland, Baltimore...............................................................
Maryland National Bank, Baltimore.......................................................................................
Citizens National Bank of Southern Maryland, Lexington Park....................................

2
0
0

0
1
2

2
1
2

0
1
1
1

2
0
0
0

2
1
1
1

2
0
0

0
1
1

2
1
1

0
1

0

2
1

1
1

0
0

1
1

1

0

L

4127

MARYLAND
1413
13745
15098

M
ASSACHUSETTS
11868
200
475
1135

The Arlington National Bank, Arlington...............................................................................
The First National Bank of Boston, Boston...........................................................................
New England Merchants National Bank of Boston, Boston.............................................
The Mechanics National Bank of Worcester, Worcester...................................................

MICHIGAN
13671
13995
1918

National Bank of Detroit, Detroit............................................................................................
The National Bank of Eaton Rapids, Eaton Rapids..........................................................
Second National Bank of Saginaw, Saginaw........................................................................

MISSISSIPPI
15552
14754

Citizens National Bank of Belzoni, Belzoni............................................................................
The Attala National Bank of Kosciusko, Kosciusko..................................................... ..

2

MISSOURI
4939
15793

The First National Bank of St. Joseph, St. Joseph..............................................................
Springfield National Bank, Springfield...................................................................................

NEBRASKA
209

First National Bank of Omaha, Omaha.................................................................................




181

T able

B-20— Continued

,

,

Domestic branches of National banks closed by States calen
dar 1971

Branches closed

Charter
No.

Title and location of bank

Local

Total

Outside
branches

NEW JERSEY

6440

T h e Farmers and Merchants National Bank o f M atawan, M ataw an T ow n s h ip .. . .

1

3

4

0
0
0
1
0

1
1
1
0
1

1
1
1
1
1

0
0

1
2

1
2

1

0

1

0

1

1

1
1
1
1
1
1

0

0
2
0
3

1
7
1

1
4

0

1

1

1
1
0
1

0
2
0

2

3

1
2
1

1

1

2

1

0

1

1
1
1
0

3
0
0
1

4
1
1
1

1

1

2

NEW YORK

1301
2655
12997
1106
1461

National C om m ercial Bank and Trust C om pany, A lb a n y .............................................
First National Bank and Trust Com pany o f Corning, C orn in g......................................
Franklin National Bank, M in eola.............................................................................................
H ighland National Bank o f Newburgh, N ew bu rgh ......................
First National City Bank, New Y o rk .......................................................................................
NORTH CAROLINA

13761
15673

North Carolina National Bank, Charlotte..............................................................................
W achovia Bank and Trust C om pany, N .A ., W inston-Salem ...........................................
OHIO

5214

T h e First National Exchange Bank o f Sidney, Sidney.......................................................

15583

Crater National Bank, M ed ford ................................................................................................

OREGON

PENNSYLVANIA

15422
694
6301
15393
5666
7511

Provident National Bank, Bryn M a w r.....................................................................................
National Central Bank, Lancaster............................................................................................
M ellon National Bank and Trust C om pany, Pittsburgh.............................................
L incoln National Bank, Philadelphia.......................................................................................
T h e First National Bank o f Sayre, Sayre................................................................................
T h e First National Bank o f State College, State C pllege..................................................

6

3

RHODE ISLAND

15664

Industrial National Bank o f R h ode Island, P rovidence....................................................
SOUTH CAROLINA

14425
13720
2044
14950

T h e Citizens and Southern National Bank o f South Carolina, Charleston................
First National Bank o f South Carolina, C olu m b ia .............................................................
T h e South Carolina National Bank o f Charleston, Charleston.......................................
T h e First National Bank o f Laurens, Laurens.....................................................................
TENNESSEE

15056

T h e First National Bank o f Gibson County, H u m b o ld t .................................... .............
UTAH

15196

Granite National Bank, Salt Lake C ity ..................................................................................
VIRGINIA

15221
9885
1111
15117

T h e Am erican Bank National Association, Falls C h u rch .................................................
V irginia National Bank, N o r f o lk .............................................................................................
First & M erchants National Bank, R ich m on d ....................................................................
Security National Bank o f R oanoke, R oa n ok e.....................................................................
WASHINGTON

11280

Seattle-First National Bank, Seattle.........................................................................................

182




,

T able B-21

,

,

O
utstanding balances credit cards and relatedplans of National banks Dec. 31 1971

Credit cards
Outstanding
volume

Number
oj banks

(dollar amounts
in thousands)

Other related credit plans
Average
balance
per card]

Outstanding
volume

Number
of banks

(dollar amounts
in thousands)

Average
balance
per accountJ

United States...............

740

3, 246, 962

$235

701

817, 538

$539

A labam a.....................................
Alaska..........................................
Arizona........................................
Arkansas......................................
California....................................
C olora d o.....................................
C on n ecticu t...............................
D elaw are....................................
District o f C olum bia...............
F lorid a.........................................

15
1
2
2
29
37
6
0
1
55

53, 316
*
*
*
633, 332
76, 245
43, 842
0
*
104, 109

233
*
♦
*
267
189
280
0
*
222

8
0
2
5
18
28
10
0
1
42

2 ,3 4 5
0
*
593
151,829
10, 758
11, 192
0
*
13,960

435
0
*
221
328
495
102
0
*
633

G eorgia........................................
H aw aii.........................................
Id a h o ...........................................
Illinois..........................................
Indiana........................................
Io w a .............................................
Kansas.........................................
K entuck y....................................
Louisiana....................................
M a in e ...........................................

23
0
3
24
37
6
4
32
4
13

138,846
0
13, 170
115,319
4 4 ,743
12, 423
24 791
32, 891
35 ,346
7, 985

258
0
232
226
211
154
187
200
275
197

9
0
1
62
12
12
8
7
6
7

10,985
0
♦
28, 150
8, 177
1,737
863
3 ,9 6 4
5, 361
1,067

625
0
*
765
444
326
356
548
593
671

M aryland....................................
Massachusetts............................
M ich ig a n ....................................
M innesota..................................
Mississippi..................................
M issouri......................................
M on tan a.....................................
N ebraska.....................................
N evada........................................
New H am pshire.......................

3
44
29
3
2
7
4
5
3
23

40, 147
55, 033
110,947
8 ,9 2 5
*
66, 139
1,107
43, 205
11,669
8, 628

198
230
188
139
*
218
167
187
238
216

5
32
24
61
3
13
7
14
1
5

8 ,5 1 5
60,816
30 ,250
22, 919
1,333
9 ,3 8 0
759
2, 375
♦
1,656

306
822
812
532
546
734
312
485
♦
538

New Jersey........... ..................
New M e x ic o .............................
N ew Y o rk ...................................
North C a rolin a.........................
North D a k ota ............................
O h io .............................................
O k la h om a ..................................
O re g o n ........................................
Pennsylvania..............................
R h od e Island.............................

18
4
28
8
1
102
6
2
19
4

2 7 ,6 6 4
12, 333
390, 205
74, 330
*
189,219
49, 737
*
110,864
22, 649

203
246
259
237
♦
261
220
*
233
256

22
3
28
5
10
44
12
0
30
2

33, 794
646
180,986
2 6 ,4 6 0
1, 105
20, 203
2 ,2 4 3
0
79, 326
*

1, 134
602
842
460
514
481
324
0
1,056
*

South C a rolin a .........................
South D ak ota............................
Tennessee....................................
T e x a s............................................
U ta h .............................................
V e rm o n t......................................
V irg in ia .......................................
W ashington................................
West V irg in ia ............................
W isconsin....................................
W y o m in g ....................................
V irgin Islands............................

5
1
13
41
4
6
18
6
7
22
8
0

31 ,2 6 8
♦
75, 579
150, 774
17,880
4, 542
8 1 ,4 2 4
85,011
10, 929
4 2 ,6 0 0
776
0

235
♦
222
203
212
212
226
253
271
226
139
0

2
4
7
33
2
1
19
5
4
53
12
0

*
237
5, 220
8 ,8 9 7
♦
♦
8 ,0 5 5
8 ,8 7 2
412
14,193
1,645
0

*
600
324
405
♦
♦
470
465
510
560
498
0

♦State figures are withheld when they represent less than three banks. How ever, these amounts are included in the National
totals.
t Average balance for cards with outstanding balances on D ec. 31, 1971.
Average balance for accounts with outstanding balances on D ec. 31, 1971.

t




183

T able

B -2 2

Principal assets, liabilities , and capital accounts o f National banks ,

deposit size , year-end 1970 and 1971

[Dollar amounts in millions]

Securities*
Number
of banks

Total
assets

Cash and Loans*
cash items

Total

U.S.
Treasury
securities

Deposits
Fixed
assets

1971

Deposit size

Total

Demand

Time
and
savings

Capital Surplus,
Capital notes and undivided
stock
deben­ profits, and
tures
reserves

\

Less than $ 1 . 0 . . . . .........
$1.0 to $ 1 .9 .........................
$2.0 to $ 4 .9 .........................
$5.0 to $ 9 .9 .........................
$10.0 to $ 2 4 .9 ....................
$25.0 to $ 4 9 .9 ....................
$50.0 to $ 9 9 .9 ....................
$100.0 to $ 4 9 9 .9 ................
$500.0 and o v e r .................

15
75
549
992
1,556
690
338
289
96

$17
$3
140 1
22
2 ,2 6 0
313
1,068
8, 270
27, 566
3, 366
27, 546
3, 462
26, 447
3, 421
71,275
11,646
212, 935
35, 900

$6
59
1,007
3, 875
13, 145
13, 600
13, 231
35, 699
113, 522

2,
9,
8,
8,
19,
46,

$4
47
775
786
263
752
155
395
853

$3
33
445
1 ,3 50
3, 930
3, 328
3, 027
8, 320
15, 959

$2
34
138
481
509
507
1,311
3, 628

$10
116
1,9 90
7, 367
24, 631
24, 377
2 3 ,293
6 1 ,2 7 8
171, 151

$7
71
946
3, 322
10, 565
10, 521
10, 139
3 0 ,4 1 6
85, 997

$3
46
1,0 44
4 ,0 4 4
14,066
13, 856
13, 153
30, 861
85, 153

$3
6
54
159
493
506
484
1,346
3, 777

3
25
49
62
203
1, 107

$4
15
167
516
1,517
1,409
1,321
3, 477
10, 368

T o t a l.........................

4 ,6 0 0

376,45 6

59, 201

194, 145

96, 029

36, 396

6,611

31 4,212

151,985

162, 227

6, 828

1 ,4 49

18, 795

Less than $ 1 .0 ....................
$1.0 to $ 1 .9 .........................
$2.0 to $ 4 .9 .........................
$5.0 to $ 9 .9 .........................
$10.0 to $ 2 4 .9 .....................
$25.0 to $ 4 9 .9 ....................
$50.0 to $ 9 9.9.....................
$100.0 to $4 99 .9................
$500.0 and o v e r .................

24
97
636
1, 132
1,4 56
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 ,4 43
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 ,0 0 2
2, 860
8, 470
13, 944

1
4
39
160
456
464
456
1 ,2 1 4
3, 117

18
154
2, 278
8, 373
22, 856
2 1 ,5 8 0
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 ,4 6 2
12, 598
11 ,806
11,341
27, 155
70, 079

8
7
60
187
491
473
480
1,3 26
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

T o ta l.........................

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

—

$0
—
—

1970

Deposit size

♦Loans and securities figures are shown gross; reserves are not deducted from the respective assets.

N ote : D ata m ay not add to totals because o f rounding.




T

able

B-23

Dates of reports of condition of National banks, 1914-71
dates of previous calls see

Jan.
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.
1971.




Feb.

Mar.

Annual Report for 1920, vol. 2, table No. 42, p.
June

May

Apr.

13

1
1

1
12
10
4

28

21

10
3\
23

28

3

6

12

28
27
27
25

5
4
4
31
7
29
26

13

20
12

11

24
9
31

20
15

11

10

12

30
23
30

2
12

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
23

12

26
18

Sept.

31

11
12

8
6

15
14
28

24
29
30

28

24
18

30

5
30
26

6

14
4
15

July

24

10

12
15
26
5
25
18
30
30

20

15
30
30
29
30
30
30
30
29
30
30
30

27
28
30

20

30

31
31
27
31
31
31
29
31
29
31
31
31
31
31
31
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
31
31
31
31
31
31
30
28

20
31
31
31
30
31
31
31
31

N otes
A ct o f Feb. 25, 1863, provided for reports o f condition on
the 1st o f each quarter before com m encem ent o f business.
A ct o f June 3, 1864— 1st M on da y o f January, April, July,
and O ctober, before com m encem ent o f business, on form
prescribed by C om ptroller (in addition to reports on 1st
Tuesday o f each m onth showing condition at com m encem ent
o f business in respect to certain items; i.e., loans, specie, de­
posits, and circu lation ).
A ct o f M ar. 3, 1869, not less than 5 reports per year, on
form prescribed by Com ptroller, at close o f business on any
past date by him specified.
A ct o f D ec. 28, 1922, minimum num ber o f calls reduced
from 5 to 3 per year.
A ct o f Feb. 25, 1927, authorized a vice president o r an
assistant cashier designated by the board o f directors to verify
reports o f condition in absence o f president and cashier.
A ct o f June 16, 1933, requires each National bank to fur­
nish and publish not less than 3 reports each year o f affiliates
other than m em ber banks, as o f dates identical with those
for w hich the Com ptroller shall during such year require re­
ports o f conditions o f the bank. T h e report o f each affiliate
shall contain such inform ation as in the judgm ent o f the
Com ptroller shall be necessary to disclose fully the relations
between the affiliate and the bank and to enable the C om p ­
troller to inform himself as to the effect o f such relations
upon the affairs o f the bank.
Sec. 2 1 (a ) o f the Banking A ct o f 1933 provided, in part,
that after June 16, 1934, it w ould be unlawful for any pri­
vate bank not under State supervision to continue the trans­
action o f business unless it submitted to periodic exam ina­

186



tion by the C om ptroller o f the Currency o r the Federal R e ­
serve bank o f the district, and made and published periodic
reports o f condition the same as required o f National banks
under sec. 5211, U .S.R .S. Sec. 2 1 ( a ) o f the Banking A ct o f
1933, however, was am ended by sec. 303 o f the Banking A ct
o f 1935, approved Aug. 23, 1935, under the provisions o f
w hich private banks are no longer required to submit to
examination by the C om ptroller or Federal Reserve bank,
nor are they required to make to the C om ptroller and to
publish periodic reports o f conditions. (Five calls for reports
o f condition o f private banks were made by the Com ptroller,
the first one for June 30, 1934, and the last one for June 29,
1935.)
Sec. 7 ( a ) ( 3 ) o f the Federal D eposit Insurance A ct (T itle
12, U .S.C ., sec. 1 8 1 7 ( a ) ) o f July 14, 1960, provides, in part
that, effective Jan. 1, 1961, each insured National bank shall
make to the Com ptroller o f the Currency 4 reports o f con di­
tion annually upon dates to be selected by the Com ptroller,
the Chairm an o f the Board o f G overnors o f the Federal R e ­
serve System, and the Chairm an o f the Board o f Directors o f
the Federal D eposit Insurance C orporation, or a m ajority
thereof. T w o dates shall be selected within the semiannual
period o f January to June, inclusive, and 2 within the semi­
annual period o f July to D ecem ber, inclusive, Sec. 161 of
T itle 12 also provides that the Com ptroller o f the Currency
may call for additional reports o f conditions, in such form and
containing such inform ation as he m ay prescribe, on dates
to be fixed by him, and may call for special reports from
any particular association w henever in his judgm ent the
same are necessary for use in the perform ance o f his super­
visory duties.




T able B-24
4al and principal assets o f National banks, by States, June 30, 1971

[Dollar amounts in millions]

Securities, gross]\

Number
of banks

Total
assets

Cash
assets*

4, 599

$352, 964

$57, 255

$41,207

$46, 254

89
5
3
69
59
121
26
5
11
222

3, 932
528
3, 129
1,831
48, 487
3, 824
3, 261
40
2, 316
10, 610

579
66
330
290
7, 573
610
546
8
455
1,833

512
66
260
267
5, 670
402
166
10
344
1,636

667
119
428
252
5, 526
414
517
1
285
1, 756

60
1
7
412
122
99
171
80
49
19

4,8 70
81
1, 112
29, 029
7, 745
2, 570
3,011
2, 535
4, 394
767

902
10
122
3, 879
1, 128
498
445
393
714
108

326
15
109
4, 133
1,085
386
540
423
846
61

507
8
194
3, 881
969
290
402
320
566
126

41
84
102
198
39
98
49
125
4
48

3,
9,
13,
7,
1,
5,

034
375
939
177
794
793
987
2, 685
943
779

470
1,745
2, 492
1, 128
271
1,091
116
462
91
124

335
799
1,654
960
258
652
145
352
148
94

122
33
165
22
42
218
198
9
296
5

11, 967
1,268
53, 485
5, 645
861
14, 583
5, 073
3, 837
21, 779
1, 784

1,490
184
11, 122
981
96
1,877
895
550
2, 955
187

20
33
77
529
10
26
100
23
85
126
41
1

1, 719
1,050
5, 942
22, 473
1,057
538
5, 841
5, 859
1,818
4, 977
674
157

14

3, 351

,

Loans
gross

Federal
funds
sold§

$2, 071

$182, 867

$9, 574

13
2
8
7
205
17
25

1,927
246
1,983
882
26, 082
2, 087
1,857
21
1, 146
4,511

122
5

1

—

3

71
920
139
46
3
20
436

12
257
28
18
8
8
12
2

2, 722
42
640
14, 983
3, 828
1,238
1,376
1,227
1,954
437

118
2
3
831
499
81
158
99
170
8

478
1, 309
1,806
848
208
687
129
291
123
90

28
50
121
36
5
54
3
11
6
2

1,502
4, 800
7, 284
3, 849
963
2, 835
544
1,457
493
432

134
212
185
146
29
321
17
39
46
16

1,564
165
4, 359
600
145
2, 060
670
346
2, 454
117

2, 182
181
5, 328
816
117
2, 333
824
533
3, 498
287

133
4
291
27
1
127
18
8
147
4

6, 054
644
28, 583
2, 942
468
7, 384
2, 241
2, 172
11,278
1, 136

214
57
869
68
9
425
291
7
805
8

296
115
1,079
4, 139
153
57
708
776
232
783
92
11

164
162
698
2, 496
102
50
702
607
380
585
114
12

269
139
780
3, 093
123
72
827
687
283
574
80
28

4
2
41
131
9
3
20
16
7
23
2
—

887
583
3,009
10, 780
611
332
3, 294
3, 223
797
2, 668
347
87

41
18
144
1,046
24
10
114
260
63
193
15
15

634

524

410

21

1,661

28

U.S. Gov­ State and
ernment
local
obligationsX

Other

—
13
67
35
—

r banks, and cash items in process of collection.
rities and securities held in trading accounts.
ecurities and obligations of other U.S. Government agencies.
purchased under agreements to resell.
lon-National banks in the District of Columbia, all of which are supervised by the Coinj

totals because of rounding. Dashes indicate amounts of less than $500,000.

101
5

1
1
5
9

1
72

20
1
1

2

4

3
60

12
17

20

11

1
177

6
14

8

10

31
1

1

10
3

1
3
1

8
1

1

• of

T able

B -2 5

Total and principal liabilities o f National banks, by States, June 30, 1971

[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

Reserves on
loans and
securities

United States......................

$323, 155

$294, 138

$142,818

$151,320

$105, 000

$130, 685

$14, 473

$3, 802

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

3, 581
492
2,905
1,665
45, 082
3,517
2, 989
37
2, 114
9, 767

3, 409
477
2,714
1,606
40, 456
3, 299
2, 786
36
2,017
9,277

1, 713
215
1,084
853
15, 760
1,683
1,502
14
1,206
4, 861

1,696
262
1,630
753
24, 696
1,617
1,284
22
811
4,417

1,295
168
908
656
13, 082
1,270
1,209
13
1,041
3, 572

1,520
128
1,462
688
20, 254
1,377
1, 176
22
793
3, 833

56
1
102
30
2, 456
83
80
0
45
232

39
5
26
14
507
34
32

Georgia..............................................
Hawaii...............................................
Idaho..................................................
Illinois................................................
Indiana..............................................
Iow a...................................................
Kansas...............................................
Kentucky..........................................
Louisiana..........................................
Maine.................................................

4, 409
75
1,027
26, 456
7, 127
2, 361
2,716
2, 310
3, 994
698

3, 793
73
973
23, 675
6,467
2, 264
2, 567
2,213
3, 788
643

2, 241
30
420
11, 154
3, 114
1, 149
1,351
1, 158
2, 022
304

1, 552
44
553
12, 521
3, 353
1, 115
1,216
1,056
1, 766
340

1,666
26
334
8, 323
2, 170
758
886
932
1,449
259

1,339
30
514
10, 836
3, 189
1,033
1,049
998
1,432
316

325
0
10
1,676
405
52
81
45
93
22

9
390
69
24
23
27
43
7

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

2, 779
8, 501
12, 894
6, 604
1,635
5, 233
911
2,449
869
696

2,612
7,318
12,213
6, 039
1, 547
4, 645
862
2,318
843
637

1,457
4,6 18
4, 825
2, 933
835
2, 749
331
1,226
378
366

116
341
252
827
599
1, 761
486
1,045
381
255

89
759
336
325
40
480
13
89
2
10

28
110
150
66
18
51
11
28
8
8

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

10,
1,
48,
5,

981
174
706
149
791
13, 262
4,606
3, 533
19, 663
1,626

10,
1,
42,
4,

438
126
487
644
758
12, 375
4, 221
3, 295
18, 092
1,513

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

1,575
962
5, 435
20, 561
975
495
5, 371
5, 397
1,647
4, 587
614
148

District of Columbia— all J..........

3, 050

1,
2,
7,
3,

—

20
77
52
—

155
700
387
106
711
1,896
531
1,091
465
271

1, 143
3, 327
3, 394
1,853
574
1,894
262
859
303
305

4 ,5 14
554
24, 118
2, 462
280
5, 281
2, 252
1,396
8, 034
586

5, 924
573
18, 369
2, 182
478
7, 094
1, 969
1,898
10, 058
927

3, 658
416
14, 940
1, 918
221
4, 097
1,595
1, 173
6, 259
453

5, 576
439
14,813
1,802
448
6, 416
1,663
1,696
9, 145
872

75
20
1,929
216
5
450
286
92
920
51

121
11
765
59
9
139
39
39
232
19

1,465
928
5, 065
18, 471
876
476
5, 020
4,837
1,560
4,217
594
113

1,016
357
2, 502
10,310
376
164
2, 115
2, 169
713
1,771
266
30

449
571
2, 563
8, 161
500
312
2,9 04
2, 668
847
2, 446
328
83

833
276
1,707
7, 506
294
140
1,749
1,752
539
1,345
187
13

423
507
144
566
436
304
653
429
827
146
286
45

29
1
193
1,514
56
5
153
379
37
119
4
0

18
14
48
214
9
4
54
57
15
52
5
1

2, 928

1, 758

1, 171

1, 511

1, 149

54

28

1,
2,
6,
2,

2,
6,

2,
2,
2,

*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.
N ote

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

188



T

able

B -26

Capital accounts o f National banks , by States, June 3 0 , 1971
[Dollar amounts in millions]

Total
capital
accounts

Preferred
stock

Debentures

Common
stock

United States..................

$26, 007

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

311
31
199
151
2, 898
273
239
3
182
766

Georgia...........................................
Hawaii............................................
Id a h o ;...........................................
Illinois.............................................
Indiana..........................................
Iowa................................................
Kansas............................................
Kentucky.......................................
Louisiana.......................................
Maine.............................................

409
6
75
2, 182
550
186
273
198
356
61

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

227
765
895
507
140
509
65
208
66
75

3
34
123
29
6
27
3
4
0

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

864
83
4,015
437
60
1, 182
427
265
1,884
139

42
1
273
70
4
30
34
25
73
—

—

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

126
75
459
1,698
72
39
415
405
155
338
55
8

District of Columbia— a ll* . . . .

273

Surplus

Undivided
profits

Capital
reserves
$668

$1,314

$64

$6, 681

$11,325

$5, 955

1

0
0
0
0
0

0
0
2
—

87
9
37
38
739
78
58
1
40
238

131
13
90
58
1,240
112
127
1
96
311

82
9
47
44
610
71
43
1
44
166

0
0
0
2
0
0
1
0
3
0

108
2
20
631
127
42
72
39
78
21

125
1
40
977
241
72
109
98
175
21

87
1
16
396
169
62
82
57
91
18

40
0
0
148
8
4
2
4
8
1

0
0
4
0
0
3
0

52
158
211
144
34
118
24
53
23
14

100
369
353
170
90
182
24
75
21
40

63
176
191
159
9
175
14
74
22
20

9
28
13
6
1
4

367
26
1, 895
177
21
568
142
93
930
73

213
17
684
83
18
273
139
68
434
37

18
14
110
4
1
4
3

0
7
0

225
25
1,013
103
17
307
108
80
387
29

0
5
19
55
0
1
2
0
2
5
2
0

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

27
20
125
520
22
10
117
116
31
97
6
—

56
26
183
650
38
13
178
178
73
149
25
4

38
23
115
422
13
13
117
100
44
81
20
3

4
1
16
50
0
1
1
11
5
5
1
—

13

2

51

128

78

1

—
25
8
259
10
12
0
1
31
50
2
0
29
3
5
7
0

—
—

—

—

—
0
0

0
41
0
0
0

—

11

—
0
4
51
1

—
—
1
19

—
2

—
1

—
53
—

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

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




189

T able B-27
Total and principal assets o f National banks, by States , D ec. 31, 1971

[Dollar amounts in millions]

Securities, gross]
Number
of banks

Total
assets

Cash
assets*

United States................

4,600

$376, 456

$59, 201

$45, 030

$48, 648

$2, 351

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

88
5
3
69
57
122
26
5
11
230

4, 336
554
3, 752
2, 057
52, 370
4, 182
3, 382
42
2, 332
11,566

670
83
492
380
7,717
736
519
4
427
2,087

560
86
360
295
6,412
413
172
10
259
1,675

715
100
515
262
5, 924
445
574
2
270
1,851

17
1
7
6
251
24
26
0
13
87

2, 082
258
2, 220
953
27, 840
2, 244
1,933
22
1,216
4, 950 •

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

60
1
7
415
122
99
171
80
49
19

5, 204
91
1, 193
30, 091
8, 554
2, 744
3, 356
2, 792
4, 863
786

1,009
12
129
3, 832
1,557
540
527
446
865
101

329
12
139
4, 381
1,206
406
593
424
829
66

512
13
208
3, 973
988
318
425
389
664
104

51
—
8
325
36
8
10
10
22
2

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

39
84
104
198
38
98
52
125
4
48

3, 185
9, 655
14, 883
8, 130
1, 944
6,512
1, 112
3, 084
1,024
855

483
1,953
2, 370
1,300
335
1,238
129
551
117
125

350
836
1,796
1,249
273
797
208
432
150
120

546
1,067
1,830
883
212
788
145
303
139
76

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

120
33
166
23
42
218
197
8
286
5

12, 838
1,385
52, 890
6, 365
955
15, 655
5, 435
4,261
22, 842
1,879

1, 579
196
9, 029
1,086
110
2, 102
1,001
630
3, 037
159

1,769
182
4,592
687
191
2,411
679
395
2, 650
124

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

19
32
77
530
9
26
101
24
86
126
42
1

1,887
1, 155
6, 652
25, 137
1, 176
583
6, 224
6, 250
2,013
5, 369
738
138

381
142
1, 181
4, 842
211
57
745
885
243
733
108
10

197
194
781
2, 756
109
57
717
521
397
634
132

District of Columbia— all||. .

14

3, 373

607

440

U.S.
Government State and
obligations% local

10

Other

Loans,
gross

Federal
funds
sold§

$194, 145

$12, 705

Direct
lease
financ­
ing
$871

168
3
16
97
1,687
163
50
2
92
533

1
3
—
330
6
—
—
1
4

2, 860
46
669
15, 596
4,0 48
1,309
1,469
1,305
2, 101
463

177
5
8
759
479
104
248
151
242
25

—
72
21
1
1
2
5
—

14
52
126
57
6
41
3
10
6
6

1,578
5,0 10
8, 056
4, 137
1,016
2, 956
566
1,588
515
459

121
279
273
274
41
544
31
122
60
46

3
61
12
25
1
18
—
—
2
—

2, 274
219
5, 606
922
137
2, 362
903
670
3,617
303

161
6
302
19
1
153
29
8
160
4

6, 342
704
29, 935
3, 264
473
7, 790
2, 421
2, 309
11,689
1, 179

349
44
424
162
19
433
258
79
1,025
59

16
—
165
5
—
16
9
8
34
1

278
162
838
3, 306
125
60
851
726
305
626
94
21

5
2
53
120
10
4
19
26
8
34
2

944
608
3, 272
11,668
671
364
3, 567
3, 298
928
2, 807
361
85

27
16
316
1,597
14
27
141
435
69
386
18
7

—
—
1
11
4
—
2
4
2
11
1
0

393

23

1,719

117

3

—

9
—

♦Gash, balances with other banks, and cash items in process of collection.
■[Includes investment securities and securities held in trading accounts.
Includes U.S. Treasury securities and obligations of other U.S. Government agencies.
§Also includes securities purchased under 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.

X

N ote:

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




T able B-28
Total and principal liabilities o f National banks, by States , D ec. 3 f 1971

[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

Reserves
on loans
and
securities

United States......................

$345, 465

$314,212

$151,985

$162, 227

$113,210

$138, 222

$17,302

$3,917

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

3, 965
514
3, 520
1,881
48, 859
3, 863
3, 102
38
2, 121
10, 676

3, 751
498
3,013
1,802
43, 803
3, 628
2, 956
38
2, 033
10, 162

1,937
220
1, 166
989
16, 800
1,885
1,632
15
1,221
5, 355

1,813
278
1,847
813
27, 002
1, 743
1,324
22
812
4, 807

1,438
181
1,010
756
13, 958
1,477
1,350
14
1,041
3, 966

1,616
137
1,619
746
21,230
1,533
1, 175
22
793
4, 112

77
0
403
42
3, 234
94
44
0
42
254

41
6
29
16
525
36
36

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

4, 730
85
1, 105
27, 459
7,918
2, 526
3, 051
2, 556
4,4 48
716

4, 098
84
1,056
24,912
7, 090
2, 421
2, 793
2, 434
4, 199
680

2, 465
36
469
11,580
3, 523
1,253
1,516
1, 309
2, 246
327

1,634
48
587
13, 332
3, 567
1, 168
1,277
1, 125
1,954
353

1,838
31
370
8, 728
2, 499
829
1,006
1,038
1,576
272

1,398
31
542
11,491
3,376
1,097
1, 108
1,054
1,511
332

394
0
2
1,442
530
60
174
68
126
7

10
380
71
25
24
28
47
8

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

2, 921
8, 776
13, 798
7, 533
1, 783
5, 951
1,032
2, 841
947
770

2, 689
7, 659
12, 851
6, 841
1,698
5, 236
979
2, 655
921
717

1,441
4, 964
5, 200
3, 436
956
3, 298
402
1,441
400
428

1,248
2, 695
7, 652
3, 405
742
1,938
576
1,214
521
289

172
285
541
107
641
1,815
532
1, 151
419
269

149
724
605
446
35
615
15
127
0
9

29
113
152
71
19
55
11
28
7
8

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

11,816
1,276
47, 804
5, 849
882
14, 290
4, 950
3, 949
20, 661
1, 719

11,324
1,214
41,524
5, 245
846
13, 303
4, 585
3, 702
19, 038
1,595

5, 084
558
22, 229
2, 754
343
5, 737
2, 406
1,545
8,317
601

6, 241
656
19, 296
2, 492
503
7, 566
2, 179
2, 158
10, 720
995

3, 968
435
14, 855
2, 129
273
4, 503
1, 736
1,277
6, 724
489

5, 799
477
15, 361
2,011
477
6, 847
1,855
1, 768
9, 637
923

73
23
2, 361
288
4
521
249
140
1,001
50

125
14
774
61
10
144
41
41
238
16

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

1, 734
1,063
6, 113
23, 172
1,093
538
5, 712
5, 774
1,830
4, 949
675
129

1,602
1,020
5, 641
20, 821
992
521
5, 393
5, 191
1,716
4, 464
651
126

1, 103
413
2,811
11,897
438
184
2, 258
2, 390
768
1,936
286
19

499
607
2, 830
8, 924
554
338
3,. 134
2, 801
949
2, 528
365
107

906
326
1,919
8, 352
344
149
1,883
2,012
584
1,474
215
14

467
552
361
037
458
325
841
574
927
268
317
81

49
3
287
1, 744
55
3
104
352
45
228
5
0

18
14
54
226
9
5
58
62
17
53
5
1

District of Columbia— all J..........

3, 060

2, 952

1, 772

1, 179

1,516

1, 155

45

30

1,
3,
3,
2,

153
564
637
165
668
2, 141
305
978
326
326

1,
2,
6,
3,

2,
7,

2,
2,
2,

—

22
82
53
—

*IPC deposits are those of individuals, partnerships, and corporations.
fAlso includes secruities sold under agreements to repurchase.
JIncludes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
N ote

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




191

T able

B -2 9

Capital accounts o f National banks, by States, D ec. 31, 1971
[Dollar amounts in millions]

Total capital
accounts

Debentures

Preferred
stock

Common
stock

Surplus

Undivided
profits

Capital
reserves

United States..............

$27, 072

$1,449

$43

$6, 785

$11,818

$6, 300

$676

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

330
35
203
161
2, 985
283
245
3
189
808

3
—
25
12
281
11
12
0
1
33

0
0
0
0
0
—
0
0
2
—

89
13
37
38
738
78
58
1
40
245

142
13
90
59
1,293
116
131
1
96
326

86
13
51
48
611
77
44
1
49
185

11
—
0
4
62
1
—
—
1
19

Georgia......................................
Hawaii........................................
Idaho..........................................
Illinois........................................
Indiana......................................
Iowa............................................
Kansas........................................
Kentucky...................................
Louisiana...................................
M aine.........................................

420
6
78
2, 251
565
193
281
208
368
63

46
2
0
36
3
5
7
0
1
—

0
0
0
2
0
0
1
0
3
0

109
2
20
635
128
43
72
39
79
21

128
1
41
996
248
72
114
101
178
22

97
1
17
433
177
68
84
63
102
19

40
0
0
149
10
5
3
4
6
1

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

235
765
933
527
142
506
69
215
70
78

3
36
124
32
6
27
4
4
0
1

0
0
4
0
0
3
0
—
0
0

51
159
213
145
37
118
25
53
23
14

100
373
391
172
96'
183
25
76
22
43

71
169
189
172
1
172
15
79
25
20

10
28
12
7
1
1
—
4
—
1

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

897
96
4, 311
454
63
1,221
443
271
1,942
144

41
11
296
70
4
31
37
25
77

—

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

135
78
485
1, 739
74
40
454
413
167
367
57
8

0
5
19
60
0
2
27
0
3
26
2
0

District of Columbia— all* . .

283

14

—

234
25
1,071
105
17
309
109
80
388
29

380
37
2,071
182
21
587
147
102
960
73

223
18
743
94
20
292
148
64
460
42

18
5
no
4
2
2
2
0
51
—

0
0
0
0
0
0

28
21
126
522
21
10
118
121
32
98
7
—

57
27
194
662
38
13
180
179
80
150
25
4

44
25
131
444
14
14
126
97
47
88
22
3

6
1
16
50
0
1
3
15
5
5
1
—

2

51

128

87

1

0
20
0
0
0
—
0
7
0
0
0
0
1
0
—

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

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

192



T able B-30
Loans o f National banks, by States, D ec. 31> 1971

[Dollar amounts in millions]

Loans

Loans
secured
by real
estate

Loans to
financial
institutions

Loans to
purchase
or carry
securities

Loans to
farmers

Commercial Personal
loans to
and
industrial individuals
loans

Other
loans

$5, 610

$6, 165

$73, 532

$43, 495

$5, 108

14

39
0
192
61
841
251
2

681
80
599
299
10, 394
638
570
2
352
1,613

790
61
588
307
4, 986
658
494
6
267
1,643

68
1
30
9
917
48
87

113
380
97
268
363
76
23
7

1,086
20
147
6, 892
1,093
332
434
318
836
143

1,053
7
203
2, 598
1, 182
314
376
439
576
134

55
1
6
460
73
16
11
33
70
6

17
62
131
158
18
135
1
63
3
1

18
8
54
215
37
138
109
524
10
5

441
2,613
2, 197
1,490
307
1, 164
136
387
132
143

462
925
1,645
874
372
702
163
364
163
172

34
78
224
54
30
37
3
22
3
8

193
22
2, 974
142
3
347
146
107
706
60

63
12
2, 089
32
1
110
75
26
162
6

13
75
100
34
86
106
248
107
162

1,699
217
15, 323
1,497
127
2, 298
829
1,037
4, 071
350

1,631
232
3, 977
1, 156
107
2, 429
563
434
2, 876
212

170
12
725
45
5
230
99
20
399
21

134
143
498
1, 545
209
176
1,038
875
288
991
78
62

35
5
230
826
26
1
104
177
20
122
4
0

11
2
61
659
26
2
30
47
6
55
3
0

13
197
47
629
29
10
70
170
8
77
76
0

312
129
1,321
4, 982
214
73
1,018
1,270
226
880
104
14

385
126
1,056
2, 605
141
95
1,210
693
366
579
92
8

53
6
60
423
25
8
98
66
14
104
5
1

525

237

37

0

444

403

74

United States......................

$194, 145

$46, 640

$13, 593

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

2, 082
258
2, 220
953
27, 840
2, 244
1,933
22
1,216
4, 950

382
114
567
232
8, 429
485
688
13
358
1,221

108
1
232
23
1,897
150
75
1
158
271

12
21
376
14
15
0
27
66

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

2, 860
46
669
15, 596
4, 048
1, 309
1,469
1,305
2, 101
463

465
18
180
2, 765
1,267
332
204
348
400
166

154
0
13
1, 767
221
17
47
75
159
6

23
0
7
733
115
31
33
16
38
2

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

1,578
5,010
8, 056
4, 137
1,016
2, 956
566
1,588
515
459

493
811
3, 111
1,043
207
541
152
183
193
127

112
514
695
302
46
238
2
45
9
4

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

6, 342
704
29, 935
3, 264
473
7, 790
2, 421
2, 309
11,689
1, 179

2, 574
134
4, 747
357
143
2, 270
461
579
3, 312
530

South Carolina................................
South Dakota...................................
Tennessee..........................................
Texas..................................................
U tah...................................................
Vermont............................................
Virginia.............................................
Washington......................................
West Virginia..................................
Wisconsin..........................................
W yom ing...........................................
Virgin Islands..................................

944
608
3, 272
11,668
671
364
3, 567
3, 298
928
2, 807
361
85

District of Columbia— all*...........

1, 719

—

—

0
54
23
—

—

—

54
82

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

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




193

T able B -31

SO

Income and expenses o f National banks * by S tates,year ended D ec. 31, 1971

[Dollar amounts in thousands]

United States
Number of banks.................................................................

Alabama

Arizona

Alaska

Arkansas

California

Colorado

Connecticut Delaware

4, 600

88

5

3

69

57

122

26

5

$13, 668, 075

$155, 421

$22, 711

$158,314

$67, 111

$1, 996, 798

$175, 573

$139, 841

$1, 586

533, 833

6, 956

477

211

4, 971

64, 284

6, 386

2, 190

129

1, 849, 539

25,319

2, 059

12, 314

10,617

237, 257

17, 887

8, 053

463

442, 894

4, 845

2, 647

3, 206

4, 737

50, 713

4, 963

2, 449

140

1,841,008
137,819
700, 894
709, 657

26, 896
709
5, 595
12, 496

5, 232
1,032
364
2, 576

18, 226
289
5, 093
8, 915

10, 737
368
1,485
4, 943

706
116
690
286

17, 719
846
12,016
13, 173

21, 430
1,272
13, 780
8, 235

55
6
0
80

624, 598
801, 183

7,372
4, 515

2, 492
393

4,371
5 ,8 12

1,647
2, 203

121, 749
139, 865

12, 102
5, 994

5, 095
4,5 93

42
36

21, 309, 500

250, 124

39, 983

216, 751

108,819

3 ,0 6 1 ,4 6 4

266, 659

206, 938

2, 537

4, 140,212
698, 418
7, 228,718

51,476
8, 365
81,591

9, 918
1,264
13, 597

49, 447
7, 744
81,497

21,846
3, 157
36, 653

644,419
101, 894
1, 188, 052

55, 884
8, 374
78, 481

54, 359
9, 845
56, 372

596
89
926

565
744
788
972

2, 843
202
80
6, 888

66
61
8
1,631

7, 280
0
1,035
8, 162

1, 715
10
517
4,4 12

716
156
658
505

5, 302
1,936
941
9, 756

4, 221
185
589
11,368

2
0
0
101

606, 574

8, 798

1,486

7, 452

3, 832

65, 979

10, 150

7, 439

120

514, 125
2,543,301

7, 174
30, 684

577
4, 085

4, 145
21,816

1,885
13, 994

73, 574
321, 115

7, 516
43, 323

4 ,2 7 9
24, 954

0
317

Total operating expense...........................................

17,430,417

198, 101

32, 693

188, 578

88, 021

2, 651,068

221,663

173,611

2, 151

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, 879, 083
942, 747
2, 936, 336
106, 939
3, 043, 275
— 1, 836
— 117

52, 023
12, 582
39,441
1,366
40, 807
— 192
+ 1

7, 290
1,085
6, 205
572
6, 777
+ 3
0

28, 173
5, 089
23, 084
115
23, 199
0
0

20, 798
4,2 52
16, 546
743
17, 289
+58
0

410, 396
94, 938
315, 458
3,9 16
319, 374
+ 568
0

44, 996
13, 278
31, 718
1,270
32, 988
+671
— 34

33, 327
7, 475
25, 852
676
26, 528
+ 67
0

386
177
209
23
232
0
0

3,041,322

40,616

6, 780

23, 199

17, 347

319, 942

33, 625

26, 595

232

Operating income:
Interest and fees on loans........................................
Income on Federal funds sold and securities
purchased under agreements to resell.............
Interest and dividends on investments:
U .S. Treasury securities......................................
Obligations of other U .S. Government
agencies and corporations..............................
Obligations of States and political sub­
divisions ................................................................
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 se­
curities sold under agreements to repur­
chase ...........................................................................
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.......................................


http://fraser.stlouisfed.org/
Net income.............................................................
Federal Reserve Bank of St. Louis

739,
80,
67,
810,

209,
26,
84,
130,

107,
1,
12,
134,

Changes in capital accounts:
Increases:
Net income transferred to undivided prof­
its .......................................................................
Capital stock, notes and debentures sold
or issued including premium received. .
Addition to surplus, undivided profits and
reserves incident to mergers and con­
solidations .......................................................
Transfers from reserves on loans and se­
curities .............................................................
All other increases............................................

3, 041, 322

40, 616

6, 780

23, 199

17, 347

319, 942

33, 625

26, 595

232

733, 659

5, 810

0

12, 302

5, 184

112, 784

4, 180

3, 838

0

63, 707

3, 797

0

0

0

5, 371

20

2, 778

0

39, 881
177,610

387
2, 370

0
137

0
37

47
1,200

225
3, 027

182
1,565

1
71

0
44

1,014, 857

12, 364

137

12, 339

6, 431

121,407

5,947

6, 688

44

1, 386, 154
4,013

15, 863
0

794
0

9, 089
0

4, 075
0

168, 397
0

12, 836
19

13, 801
0

78
0

77, 115

1

20

196

162

14, 403

63

21

0

11,584

0

0

0

0

2, 635

258

250

0

157, 940
143, 406

653
1,631

167
83

1,620
176

709
807

21, 100
4, 275

1,627
2, 759

1,809
259

23
70

Total decreases..................................................

1, 780,212

18, 148

1,064

11,081

5, 753

210,810

17, 562

16, 140

171

Net change in capital accounts......................................

2, 275, 967

34, 832

5, 853

24, 457

18, 025

230, 539

22, 010

17, 143

105

Capital accountsf.............................................

25, 986, 951

312, 485

31, 593

193, 588

151, 701

2, 879, 610

272, 976

230, 684

3, 281

Ratios:
Net income before dividends to capital
accounts (percent).......................................

11. 70

13. 00

21 .46

11. 98

11.43

11. 11

12. 32

11. 53

7. 07

81. 79

79. 20

81. 77

87. 00

80. 89

86. 59

83. 13

83. 90

84. 79

Total inci eases.................................................
Decreases:
Cash dividends declared:
On common stock...................................
On preferred stock..................................
Capital stock, notes and debentures, re­
tired 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 operating expense to total operating
revenue (percent)........................................
See footnotes at end o f table.




T able

so

05

B -31 — C ontinued

Income and expenses o f National banks, * by States, year ended D ec. 31, 1971

[Dollar amounts in thousands]

District of
Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

11

230

60

1

7

415

122

99

171

$83, 512

$358, 310

$249, 228

$4, 174

$52, 871

$1,019, 668

$284, 915

$93, 084

$106, 063

3, 731

24, 542

8, 459

159

667

37, 007

19, 161

4 ,3 10

6,2 18

17, 535

59, 595

15, 559

727

6, 682

176, 277

50, 166

18, 233

26, 495

2, 591
9, 554
703
5, 431
6, 164

33, 221
71, 795
3, 534
20, 123
26,313

3,437
21,203
1,957
11,297
17, 853

106
384
5
0
13

302
8, 174
801
634
3, 694

55,
158,
15,
70,
29,

12,
37,
3,
13,
15,

241
904
132
253
639

5, 132
11,991
467
3, 743
5, 028

6, 243
15, 629
394
3, 145
7, 237

2, 026
1,829

26, 944
14, 171

7,002
20, 475

266
48

1,460
448

31, 791
74, 401

11,444
10, 845

6, 149
1,630

5, 933
2, 940

133, 076

638, 548

356, 470

5, 882

75, 733

1 ,6 69,5 19

458, 700

149, 767

180, 297

32, 169
4, 628
36, 573

122, 101
17, 856
214, 181

84, 139
15,015
75, 494

1,639
173
2, 178

15, 861
2, 501
26, 525

273, 630
47 ,716
604, 655

86, 484
13, 843
160„232

28, 446
3, 846
53, 726

34, 065
4, 844
58, 832

1, 729
24
1,044
5, 868

12, 492
957
1,827
17, 737

15,
12,
1,
15,

154
124
738
839

3
0
75
390

198
992
0
1, 796

84, 142
11,282
1,690
60, 722

18, 833
590
144
19, 556

2, 289
384
223
4,7 43

3, 318
349
464
5, 908

4,576

21,217

13, 549

201

2, 114

38, 026

15, 070

7, 252

6, 077

4,291
16, 379

16, 965
102, 079

10, 821
49, 224

400
849

1, 384
7,707

44, 530
168, 091

11,379
52, 770

1,673
17, 082

4 ,3 94
20, 793

Total operating expense.....................................................

107, 281

527,412

293, 097

5 ,9 08

59, 078

1, 334, 484

378, 901

119,664

139, 044

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....................

25, 795
8, 091
17, 704
1,851
19, 555
+ 982
0

373
608
765
709
474
352
0

-2 6
42
-6 8
443
375
0
0

16, 655
4, 736
11, 919
-2 8 0
11,639
-2 0
0

335, 035
83, 157
251,878
16, 741
268,619
+ 311
0

79,
18,
60,
4,
65,
+

799
851
948
351
299
173
0

30, 103
9, 151
20, 952
786
21, 738
+ 10
10

41, 253
12, 406
28, 847
1,316
30, 163
+ 276
0

46, 826

375

11,619

268, 930

65, 472

21, 738

30, 439

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

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


Net income.......................................................................


20, 537

111,
17,
93,
4,
98,
+

136
707
429
868
297
595
0

98, 892

63,
19,
43,
2,
46,
+

629
309
876
565
996

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 re­
serves incident to mergers and consolidations.
Transfers from reserves on loans and securities.
All other increases.....................................................

20, 537

98, 892

46, 826

375

11,619

268, 930

65, 472

21, 738

30, 439

1,006

22, 574

8, 495

0

0

20, 721

1, 169

3, 359

377

7
832
121

21
1,454
4, 493

2, 204
835
1,455

0
0
0

0
0
1

664
2, 856
16, 860

1,200
667
3, 464

0
77
1,301

21
334
2, 197

1,966

28, 542

12, 989

0

1

41, 101

6, 500

4, 737

2, 929

8, 430
637

33, 982
0

19, 348
0

132
0

4, 329
0

102, 497
58

17,811
0

7, 329
0

9, 795
39

34

1,916

7, 732

0

0

3, 670

930

0

55

0
466
335

0
3, 106
2, 741

0
2, 266
1,575

0
0
0

0
137
12

79
11,256
34, 958

949
3, 358
13, 846

0
468
1,328

0
929
3, 141

Total decreases..........................................................

9,902

41, 745

30, 921

132

4, 478

152,518

36, 894

9, 125

13, 959

Net change in capital accounts...............................................

12, 601

85, 689

28, 894

243

7, 142

157,513

35, 078

17, 350

19, 409

Capital accountsf.....................................................

182, 285

764, 908

407, 048

5, 489

74, 653

2, 177, 839

548, 209

184, 372

271, 744

Ratios:
Net income before dividends to capital ac­
counts (percent)..................................................

11. 27

12. 93

11.50

6. 83

15. 56

12. 35

11.94

11. 79

11.20

Total operating expense to total operating rev­
enue (percent).......................................................

80.61

82. 60

82. 22

100.44

78.01

79. 93

82. 60

79. 90

77. 11

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 consolida­
tions ...........................................................................
Transfers to reserves on loans and securities. . .
All other decreases....................................................

See footnotes at end of table.




00

T

able

B -3 1 —

Continued

Income and expenses of National banks,* by States,year ended D ec. 31, 1971
[D ollar amounts in thousands]

Kentucky
Number of banks..............................................................................
Operating income:
Interest and fees on loans.....................................................
Income on Federal funds sold and securities purchased
under agreements to resell...............................................
Interest and dividends on investments:
U .S. Treasury securities...............................................
Obligations of other U .S. Government agencies
and corporations.........................................................
Obligations of State 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............................................................ ...............


Louisiana

Maine

Maryland

Massa­
chusetts

Michigan

Minnesota Mississippi Missouri

80

49

19

39

84

104

198

38

98

$94,477

$147, 962

$35, 304

$118,542

$354, 047

$542, 378

$281, 304

$77, 323

$198, 841

6,227

9,701

916

5,6 42

14,594

18,092

6, 876

2, 755

16, 161

21,443

40, 185

3, 470

16, 990

43, 739

8 1 ,6 2 8

37, 085

11,305

32, 873

2 ,5 44
13,736
454
2,513
5, 275

5,0 25
23, 833
905
2, 920
10, 312

203
4 ,6 4 8
102
2, 043
1,806

4 ,6 07
18, 660
692
3, 914
8, 978

5, 153
43, 234
2 ,6 6 6
4 1 ,496
17, 722

13,486
72, 374
6 ,7 3 9
21, 977
2 2 ,696

10, 721
33, 118
1,009
16, 290
12, 423

2, 176
8, 576
226
1,514
5, 751

6, 183
26, 248
1,201
14, 899
6, 657

2, 797
4,2 95

9, 554
3 ,8 89

1,532
642

4 ,5 5 8
3, 111

20, 107
29,451

16, 345
18, 559

18, 388
17, 235

4 ,4 6 9
3, 764

9,6 14
19, 228

153, 761

254, 286

50 ,666

185, 694

572, 209

814, 274

434, 449

117, 859

331,905

30, 085
4,4 68
50,130

45, 974
7, 245
85, 031

11,839
1,888
14,894

40,273
5 ,9 1 0
48 ,562

133, 756
22, 865
124, 827

146, 131
24, 499
350, 130

72 ,904
12, 354
151,611

21, 836
3, 532
32 ,646

59, 898
9, 952
90, 533

2,4 19
59
7
5, 530

4, 676
1,538
24
9,3 49

610
104
9
2, 435

4 ,8 6 0
733
169
8 ,8 8 8

36, 932
4 ,5 1 6
2, 099
27, 697

19,
2,
6,
31,

085
873
236
520

19, 481
2, 673
1,678
10, 932

2, 639
66
250
3, 598

22, 233
206
1,272
10, 198

4 ,9 79
3, 028
20, 595

8, 777
5, 652
32, 240

2 ,0 6 8
846
7, 709

6 ,4 0 5
3, 356
23, 082

19, 562
14, 936
73, 470

2 1 ,890
9 ,9 8 0
74,449

11,216
6, 140
49, 877

4 ,5 7 2
5, 278
15, 743

9,551
7, 360
42 ,7 1 0

121,300

200, 506

42, 402

142, 238

460, 660

686, 793

338, 866

90, 160

253, 913

32,461
8, 025
24, 436
+ 2,110
26, 546
+259
0

53,
14,
38,
+ 4,
42,
+

780
933
847
118
965
311
0

8 ,2 6 4
1,613
6,651
+407
7, 058
+ 73
0

43, 456
12,944
30, 512
+870
31, 382
-1 0 0
0

111,549
36, 132
75, 417
+ 6 ,8 0 0
82 ,217
-2 1 0
0

127, 481
26, 874
100, 607
+ 3 ,4 8 4
104, 091
+ 65
0

95, 583
34, 642
60,941
+ 2, 396
63, 337
+ 190
0

27, 699
8, 842
18, 857
+ 38
18, 895
+ 3
0

77, 992
25, 086
52, 906
+ 1, 728
54, 634
-3 0 1
0

43, 276

7, 131

31,282

82, 007

104, 156

63, 527

18, 898

54, 333

26, 805

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 re­
serves incident to mergers and consolidations..
Transfers from reserves on loans and securities...
All other increases.........................................................

26, 805

43, 276

7, 131

31, 282

82, 007

104, 156

63, 527

18, 898

54, 333

1, 764

1,383

151

1,210

17, 641

7, 794

9, 185

1,565

1,948

0
2, 294
893

153
1, 158
7, 683

0
17
117

2, 177
171
485

12,019
607
3, 071

460
478
2 ,2 10

20
104
2, 256

0
1,679
436

100
5,847
3, 301

4, 951

10, 377

285

4 ,0 43

33, 338

10,942

11,565

3, 680

11, 196

7, 681
0

13, 754
133

3, 221
0

10, 591
0

58, 592
0

33, 170
220

24, 194
0

9,3 19
0

38, 325
204

0

7, 321

0

134

40

1,983

20

120

0

0
3, 014
949

100
2, 723
848

0
402
137

0
520
1,270

1,379
4, 982
4 ,4 4 0

129
2, 252
1,922

0
2, 884
1,359

0
1,203
748

0
8, 475
7, 128

Total decreases..............................................................

11,644

24, 879

3, 760

12,515

69, 433

39, 676

28, 457

11,390

54, 132

Net change in capital accounts...................................................

20, 112

28, 774

3, 656

22, 810

45, 912

75, 422

46, 635

11, 188

11,397

Capital accounts')"..........................................................

197, 675

354, 529

61,291

225, 999

754, 221

895, 338

505, 707

137, 757

502, 380

Ratios:
Net income before dividends to capital accounts
(percent).......................................................................

13. 56

12.21

11.64

13. 84

10.87

11. 63

12. 56

13. 72

10. 82

Total operating expense to total operating reve­
nue (percent)................. ............................................

78. 89

78. 85

83. 69

76. 60

80. 51

8 4 .3 4

8 0 .0 0

76.50

76. 50

Total increases...............................................................
Decreases:
Cash dividends declared:
On common stock.................................................
On preferred stock...............................................
Capital stock, notes and debentures, retired
including premium paid.........................................
Reduction in surplus, undivided profits and
reserves incident to mergers and consolidations.
Transfers to reserves on loans and securities..........
All other decreases........................................................

See footnotes a t end o f table.




200

T able B-31— Continued
Income and expenses of National banks * by States, year ended Dec. 31, 1971
[Dollar amounts in thousands]

Ohio
Number of banks.........................................................................

Oklahoma

Pennsylvania

Oregon

Rhode
Island

South
Carolina

South
Dakota

Tennessee

Texas

218

197

8

286

5

19

32

77

530

$553, 686

$175,015

$172, 528

$804, 458

$83, 764

$73, 851

$47, 007

$234, 615

$821,047

24,064

13, 168

1, 513

37, 472

1,342

2, 849

1,284

12, 980

57, 522

103, 326

34, 657

13,986

120, 501

5, 255

7, 354

7,807

31,451

102,519

16, 956
94, 984
8,003
23, 865
29, 965

3, 602
32, 959
960
5, 840
10, 856

3, 836
24, 281
485
6, 168
14, 407

21,866
126, 606
10, 080
54,312
24, 040

1,342
10,213
279
8, 076
2, 761

3, 752
9, 743
280
2 ,9 1 0
7, 149

1,456
5 ,9 8 6
131
876
3, 072

7,
32,
2,
8,
12,

146
361
206
765
383

34, 127
119, 032
7, 073
38,217
41, 718

22, 321
18, 655

8, 609
5, 094

5, 827
4, 670

34, 172
42, 673

2, 174
1,891

2 ,4 46
3, 383

2, 700
514

12, 329
11,514

37, 862
33, 096

895, 825

290, 760

247, 701

1,276, 180

117,097

113,717

70, 833

365, 750

1,292,213

163, 633
22, 303
326, 772

53, 222
7, 478
96, 349

57,417
9, 968
93, 254

226, 799
41 ,293
458, 203

20, 281
4, 937
4 1 ,450

31,033
5, 230
20,016

11,591
2, 036
29, 580

70, 505
11,204
123, 183

221, 384
31,656
417, 654

22, 140
878
1,522
29, 761

11,604
695
1,674
7, 239

2, 859
179
1,012
10, 574

889
779
847
987

2,2 18
755
21
4, 055

1,853
28
0
4 ,4 1 0

103
34
216
2, 034

11,852
394
914
12, 258

68, 814
12,015
1, 533
28, 144

25, 314
23, 396
116, 657

7, 561
7, 649
37, 730

6, 755
4, 361
23, 622

34, 879
18, 804
140, 251

2, 119
3, 117
14, 789

4, 642
1,985
16, 888

2 ,2 1 4
1,475
6, 543

13,614
10, 713
44, 173

39, 615
40, 885
163, 042

Total operating expense......................................................

732, 376

231,201

210,001

1,020, 731

93, 742

86, 085

55, 826

298,810

1, 024, 742

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....................

163,449
30,219
133, 230
6,435
139, 665
+645
-3

59, 559
12,444
47, 115
2, 157
49, 272
-1 6 4
-4

37, 700
8, 303
29, 397
465
29, 862
+2
0

255, 449
48, 107
207, 342
1,658
209, 000
+ 161
0

23, 355
7,0 68
16, 287
259
16, 546
0
0

27, 632
8, 555
19, 077
983
20, 060
+85
0

15,007
4, 527
10, 480
233
10, 713
0
0

66, 940
16, 095
50, 845
2, 153
52, 998
+ 347
-2 6

267, 471
69,412
198, 059
10, 228
208, 287
-9
0

140,307

49, 104

29, 864

209, 161

16, 546

20, 145

10, 713

53, 319

208, 278

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

Total operating income......................................................
Operating expense:
Salaries and wages of officers and employees............
Pensions and other employees 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.................................................


Net income........................................................................


46,
4,
3,
44,

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 re­
serves incident to mergers and consolida­
tions ...........................................................................
Transfers from reserves on loans and securi­
ties ..............................................................................
All other increases.....................................................

140, 307

49, 104

29, 864

209, 161

16, 546

20, 145

10,713

53,319

208, 278

4,9 85

15, 985

25, 000

35, 342

0

1, 127

2, 636

1,672

18, 331

545

51

0

6, 465

0

1,281

727

2, 040

804

4, 935
2, 069

933
3, 372

0
22

1,052
13,827

96
434

988
1, 190

24
1,094

189
9, 454

5, 901
11,734

12, 534

20, 341

25, 022

56, 686

530

4, 586

4,481

13, 355

36, 770

55, 507
0

20, 948
17

12, 897
0

90,315
683

8, 536
0

6,941
0

4, 125
0

16, 924
0

83, 150
37

248

188

0

1, 135

14

0

25

65

897

139
8, 840
2,961

0
1, 768
2, 961

0
1,639
31

777
8, 721
5, 690

0
228
2, 159

0
742
116

0
127
793

243
2, 974
1,996

760
16, 521
20, 233

Total decreases..........................................................

67, 695

25, 882

14, 567

107, 321

10, 937

7, 799

5, 070

22, 202

121,598

Net change in capital accounts...............................................

85, 146

43, 563

40 ,319

158, 526

6, 139

16, 932

10, 124

44,472

123, 450

Capital accountsf......................................................

1, 179, 447

425, 073

256, 194

1, 877, 800

140, 062

125, 886

73, 357

460, 976

1,690, 164

Ratios:
Net income before dividends to capital accounts
(percent)..................................................................

11. 90

11. 55

11. 66

11. 14

11.81

16.00

14. 60

11.57

12. 32

Total operating expense to total operating rev­
enue (percent).......................................................

81. 75

79.52

84. 78

79. 98

80. 05

75. 70

78.81

81. 70

79. 30

Total increases..........................................................
Decreases:
Cash dividends declared:
O n 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 consolida­
tions ...........................................................................
Transfers to reserves on loans and securities.. .
All other decreases....................................................

See footnotes at end of table.




202

T able B-31— Continued
Income and expenses o f National banks,* by States,year ended Dec. 31, 1971
[Dollar amounts in thousands]

Montana
Number of banks.........................................................................
Operating income:
Interest and fees on loans.................................................
Income on Federal funds sold and securities pur­
chased under agreements to resell............................
Interest and dividends on investments:
U.S. Treasury securities.................... ......................
Obligations of other U.S. Government agen­
cies 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 exoense 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.......................................................................


Nebraska

New
Hampshire

Nevada

New
Jersey

New
Mexico

New York

North
Carolina

North
Dakota

52

125

4

48

120

33

166

23

42

$44, 160

$114,419

$40,944

$35, 049

$434, 394

$53, 503

$1,989, 138

$239, 035

$35, 502

1,378

3,715

2, 338

1,571

14,319

3,001

34, 389

4, 868

874

7, 608

15, 452

6 ,6 18

5, 628

68, 326

7, 741

195, 101

23, 457

6,915

1,490
5, 435
170
420
2,808

5, 331
12,315
392
4 ,8 4 6
5, 362

2, 191
5,0 18
286
1,818
3, 170

320
3, 555
151
928
3, 147

21,813
86, 890
9,4 33
18, 062
27, 899

1,054
7, 826
289
1,208
4 ,0 0 0

27,
222,
19,
119,
66,

878
980
341
740
232

14, 059
35, 272
1,201
12, 642
13, 822

1,593
4, 836
63
839
2, 205

2, 083
498

6,917
5,4 13

1,079
1,052

555
1,203

11,509
11,316

2, 976
1,026

79, 841
218, 256

11,356
16, 662

1,798
437

66, 050

174, 162

64 ,514

52, 107

703, 961

82, 624

2, 972, 896

372, 374

55, 062

11,383
1,947
27, 408

33, 471
5, 112
53, 847

13, 048
1,910
22, 038

12, 186
2, 183
12, 556

146, 176
25, 368
260, 778

15, 830
2, 265
29, 129

550, 185
117, 129
885, 368

88, 275
15, 609
108, 477

8, 839
1,499
24, 675

543
27
137
1,770

3, 861
130
211
6, 600

18
56
0
2, 692

297
35
35
2, 596

3 ,7 16
561
2, 096
30,994

973
78
99
2, 342

128, 583
11,586
13,417
131,688

8, 440
756
4, 269
15, 439

69
7
186
1,393

2, 129
888
8, 694

8, 095
3, 457
21,942

1,611
2, 336
7, 195

1,914
1,072
9, 229

21 ,690
13, 937
82, 007

2, 494
2, 588
10, 245

68, 646
89, 854
396, 652

14, 672
5, 791
43, 785

1,628
600
5, 355

54, 926

136, 726

50,904

42, 103

587, 323

66, 043

2, 393, 108

305,513

44, 251

11, 124
2, 671
8, 453
305
8, 758
-2 9 6
0

37, 436
11,346
26, 090
417
26, 507
+ 134
0

13,610
4, 126
9,4 84
91
9,5 75
+ 15
0

10, 004
2, 659
7, 345
1, 185
8, 530
+43
0

116, 638
11,729
104, 909
4, 172
109, 081
+ 31
-4 1

16, 581
4, 608
11,973
441
12,414
+ 56
0

579, 788
146,813
432, 975
6, 204
439, 179
- 6 , 952
0

66, 861
16, 897
49 ,964
- 1 , 116
48, 848
+ 71
0

10,811
2, 890
7, 921
234
8, 155
-2 0
0

8, 462

26,641

9 ,5 90

8, 573

109,071

12,470

432, 227

4 8 ,919

8, 135

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 consol­
idations .....................................................................
Transfers from reserves on loans and securities. .
All other increases.....................................................

8,462

26, 641

9,5 90

8, 573

109, 071

12, 470

432, 227

48, 919

8, 135

2, 873

1,220

0

347

21,537

10, 767

274, 865

12, 331

1,901

0
328
245

5
1,379
1, 780

0
0
0

2
216
692

15, 300
1,666
4 ,2 0 8

802
3
708

2, 578
1,007
4 9 ,706

829
192
11,074

0
21
405

3,4 46

4 ,3 8 4

0

1, 257

42,711

12, 280

328, 156

24, 426

2, 327

3, 666
0

11, 119
6

2, 979
0

3, 002
0

49, 429
3

4 ,6 7 4
0

290,217
1,931

20,901
0

2 ,7 19
0

80

20

0

0

311

60

34, 790

0

0

0
689
252

0
1,524
887

0
225
0

0
234
319

3, 063
4, 180
2, 909

0
2,2 47
371

366
19,434
5,901

0
1, 782
461

0
32
574

Total decreases..........................................................

4,6 87

13, 556

3, 204

3, 555

59, 895

7, 352

352, 639

23, 144

3, 325

Net change in capital accounts...............................................

7, 221

17, 469

6, 386

6, 275

91, 887

17, 398

407, 744

50, 201

7, 137

Capital accounts f ...................................................

65, 325

206, 859

66 ,444

74, 697

865, 124

86, 074

4, 078, 965

431, 780

59, 773

Ratios:
Net income before dividends to capital accounts
(percent)..................................................................

12. 95

12. 88

14. 43

11.48

12.61

14.49

10. 60

11. 33

13.61

Total operating expense to total operating
revenue (percent)................................................

83. 16

78.51

78 .90

80. 80

83 .43

79.93

80. 50

8 2 .04

80. 37

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 consoli­
dations ......................................................................
Transfers to reserves on loans and securities.. .
All other decreases....................................................

See footnotes at end o f table.




T

able

B-31— Continued

Income and expenses o f National banks,* by S tates,year ended D ec. 31, 1971

[Dollar amounts in thousands]

Utah

Vermont

Virginia

Washington

West
Virginia

Wisconsin

Wyoming

District of
Columbia—

Virgin
Islands

all|

9

26

101

24

86

126

42

1

14

$49, 715

$25,812

$268,660

$256, 405

$63,412

$196, 463

$28, 990

$7, 192

$119,237

801

939

4, 699

22, 610

4, 135

10, 494

664

14

4, 644

4, 924

2, 565

29, 689

23, 658

17, 874

26, 905

5, 676

583

27, 696

1,411
5, 779
196
1,308
3, 761

423
2, 596
241
396
1,435

10, 336
33, 483
839
9, 661
11,370

5, 068
30, 156
2, 165
11,655
22, 807

5, 832
11,720
433
2,011
1,991

6 ,5 14
23, 354
1,467
7, 123
7, 035

789
3, 432
135
426
1,890

0
818
9
0
105

3, 310
14, 094
1,098
9, 498
9, 052

2, 760
881

269
577

13, 556
7, 620

13, 893
11,461

1,548
1,540

9, 470
10,440

1, 156
750

136
184

2, 867
2,5 14

71, 536

35, 253

389,913

399, 878

110, 496

299, 265

43, 908

9,041

194,010

12, 143
1,641
24, 081

7,2 16
1,056
14, 464

79, 186
13, 843
137, 326

94, 161
14, 726
124, 781

17, 987
2, 463
40, 245

54, 871
10, 399
118,793

8, 260
1,051
16, 296

1, 959
237
4 ,0 9 8

43, 753
6, 579
52, 392

1,971
1,821
0
1,742

56
97
88
1, 312

4, 602
1, 103
383
14, 225

27, 970
366
0
18, 962

1,923
85
172
3, 224

7, 777
242
1,049
11,012

195
242
129
1,692

0
776
0
290

2, 069
76
1, 638
9, 259

1,699
1,082
8, 284

1, 192
603
4, 239

13, 712
8, 293
50, 972

13,274
11,032
44, 598

2,941
1,692
13, 480

10, 469
4, 761
31,272

1, 164
1,848
5, 655

163
339
854

5,918
5, 026
22, 300

Total operating expense...........................................................

54, 464

30, 323

323, 645

349, 870

84,212

250, 645

36, 532

8 ,7 16

149, 010

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.........................

17, 072
6, 092
10, 980
-5 6 6
10,414
-1
0

4 ,9 3 0
831
4, 099
+ 230
4, 329
+ 12
0

66, 268
15, 385
50, 883
+ 1,892
52, 775
+ 99
0

50, 008
9, 139
40, 869
+ 2, 232
43,101
-1 2 6
0

26, 284
6 ,4 08
19, 876
+ 1,293
21, 169
-1 5 5
0

48, 620
12, 823
35, 797
+ 1,619
37,416
+40
0

376
140
236
315
551
+ 3
0

325
-2 6 1
586
-2
584
0
0

45, 000
15, 697
29, 303
2, 033
31,336
+ 982
0

10,413

4,341

52, 874

42, 975

21 ,014

37,456

5, 554

584

32,318

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

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


Net income............................................................................


7,
2,
5,
+
5,

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 re­
serves incident to mergers and consolidations..
Transfers from reserves on loans and securities...
All other increases.........................................................

10,413

4, 341

52, 874

42, 975

21,014

37,456

5, 554

584

32, 318

0

1,376

28, 546

535

2, 252

25, 093

500

0

1,006

0
142
88

498
68
508

648
134
2,6 15

120
44
66

0
84
970

0
183
1,870

0
43
679

0
0
0

7
832

230

2, 450

31, 943

765

3, 306

27, 146

1,222

0

1,966

4, 342
0

1,622
26

21,812
0

17,513
0

5, 138
0

17, 930
0

2, 303
0

0
0

13, 355
637

0

43

75

200

30

114

0

0

34

0
182
197

0
761
511

55
3, 888
4, 309

402
2, 785
272

0
742
1,201

0
971
1,061

0
339
443

0
221
0

0
785
335

Total decreases...............................................................

4, 721

2, 963

30, 139

21, 172

7, 111

20, 077

3, 085

221

15, 146

Net change in capital accounts...................................................

5, 922

3, 828

54, 678

22, 568

17, 209

44, 525

3, 691

363

19, 138

Capital accountsf..........................................................

71,551

38,479

423, 112

402, 923

155, 223

342, 300

54, 492

7,494

273, 522

Ratios:
Net income before dividends to capital accounts
(percent).......................................................................

14. 55

11. 28

12. 50

10. 66

13. 53

11. 10

10. 19

7. 79

11. 81

Total operating expense to total operating rev­
enue (percent).........................................................

76. 14

86. 02

83. 00

87. 49

76. 21

83. 75

83. 20

96 .40

76.81

Total increases...............................................................
Decreases:
Cash dividends declared:
On common stock.................................................
On preferred stock...............................................
Capital stock, notes and debentures, retired in­
cluding premium paid.............................................
Reduction in surplus, undivided profits and re­
serves incident to mergers and consolidations. .
Transfers to reserves on loans and securities.........
All other decreases........................................................

121

♦Includes all banks operating as National banks at year-end and full-year data for those State banks converting to National banks during the year,
f Includes the aggregate book value of debentures, preferred stock, common stock, surplus, undivided profits, and reserves. These are averages from the June and
December call dates in the year indicated and the previous December call date.
{Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.




0

01

T able B -32

Income and expenses o f National banks,* by deposit size, year ended Dec. 31, 1971
[Dollar amounts in thousands]

Banks operating full year with deposits in December 1971, cf —
Total
Number of banks..............................................................

4,6 00

Operating income:
Interest and fees on loans...................................... $13, 668, 075
Income on Federal funds sold and securities
purchased under agreements to resell. . . .
533, 833
Interest and dividends on investments:
1, 849, 539
U .S. Treasury securities...............................
Obligations of other U .S. Government
agencies and corporations.......................
442, 894
Obligations of States and political sub­
1, 841, 008
divisions .........................................................
137,819
Other securities...............................................
Trust department income.....................................
700, 894
709, 657
Service charges on deposit accounts..................
Other service charges, collection and ex­
624, 598
change charges, commissions, and fees. . . .
801, 183
Other operating income........................................

Total



operating income...........................................

21, 309, 500

$2,000.0 $2,000.1 $5,000.1 $10,000.1 $25,000.1 $50,000.1 $100,000.1
Over
and under to $5,000.0 to $10,000 0 to $25,000.0 to $50,000.0 to $100,000.0 to $500,000.0 $500,000.0
89

549

992

1,556

690

338

290

96

$4, 202

$74, 798

$288, 130

$981, 112

$998, 675

$959, 403

$2, 558, 186

$7,803, 570

383

5 ,0 0 4

16,942

54, 833

48, 936

41, 900

102, 549

263, 286

1, 784

24, 574

74,240

213,587

179, 898

167, 745

357, 298

830,413

503

8, 330

25, 570

73, 806

66, 049

55, 348

91, 643

121,644

158
68
0
256

6,6 37
1,008
122
5,2 05

37, 597
2, 804
588
23, 160

150, 016
'/tfd
5, 695
78, 119

134
127

2 ,4 00
1,602

9, 136
5, 366

30, 251
19, 106

7,615

129, 680

483, 533

475
730
528
220

153, 185
10, 575
33, 092
62, 093

33,312
19, 142

1,6 1 5 ,3 1 4 1 1, 606, 965

b,

160,
9,
18,
72,

387,
25,
134,
141,

296
582
144
741

945,644
79, 263
508, 725
326, 863

36, 715
22, 355

129, 652
89, 771

382, 998
643, 714

1,542,411

4 ,0 1 7 ,8 6 2

11,906, 120

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......................................

4, 140,212
698, 418
7, 228, 718

2, 464
186
1,790

30, 712
2, 978
44,077

101, 025
12,214
174, 192

304, 982
42, 797
619, 985

301,731
45, 553
616,211

294.69 4
4 6 ,278
586, 678

811,824
130, 116
1, 359, 699

2, 292, 780
418, 296
3, 826,085

739, 565
8 0 ,7 4 4
67, 788
810, 972

2
10
3
330

99
130
16
4 ,3 5 0

478
200
112
15, 462

2, 172
1,010
1,401
55, 550

5, 286
1,542
2, 574
58, 921

10, 325
1,502
3 ,5 6 2
6 0 ,390

91,068
9,4 39
9,447
156,011

630, 135
66,911
50,673
459, 958

606,574

227

3, 390

13, 437

43, 948

48, 133

48, 439

147, 448

301, 552

514, 125
2, 543, 301

187
1,463

3, 776
17, 523

14, 264
64, 153

39, 523
206, 519

32, 112
205, 124

33, 283
193, 335

87, 615
497, 125

303, 365
1, 358,060

Total operating expense..........................................

17,430,417

6, 661

107,051

395, 537

1, 317, 887

1,317, 187

1, 278, 486

3, 299, 792

9, 707, 815

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............................................................

3, 879, 083
942, 747
2, 936, 336
+ 106, 939
3, 043, 275
-1 ,8 3 6
-1 1 7
3, 041, 322

954
345
609
+50
659
-2
0
657

22, 629
6, 293
16, 336
+860
17, 196
+64
-3 5
17, 225

87, 996
23, 228
64, 768
+ 3 , 692
68 ,460
+446
0
68 ,906

297, 427
71, 475
225, 952
+ 14,014
239, 966
+399
-1 0
240, 355

289, 778
64 ,460
225,318
+ 16,280
241, 598
+370
-6
241, 962

263, 925
56, 413
207, 512
+ 14,906
222, 418
+ 1,482
+ 1
223, 901

718, 070
161,500
556, 570
+ 3 1 ,6 3 1
588, 201
+369
-5 2
588, 518

2, 198, 305
559, 033
1, 639, 272
+ 2 5 , 505
1, 664, 777
-4 ,9 6 4
-1 5
1, 659, 798

Gash dividends declared:
On common stock...................................................
On preferred stock..................................................

1, 386, 154
4 ,0 1 3

443
0

5 ,2 25
0

19,574
5

64,992
67

77, 552
130

75, 207
26

245, 279
1,012

897,881
2, 773

Total cash dividends declared................................

1, 390, 167

443

5, 225

19, 579

65, 059

77, 682

75, 233

246, 291

900,654

♦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.




to

o

00

T able B -3 3

Capital accounts, net income, and dividends of National banks, i 944—
71
[Dollars amounts in thousands]

Capital stock (par value)*
Year (last call)

1944.......................
1945.......................
1946.......................
1947.......................
1948.......................
1949.......................
1950.......................
1951.......................
1952.......................
1953.......................
1954.......................
1955.......................
1956.......................
1957.......................
1958.......................
1959.......................
1960.......................
1961.......................
1962.......................
1963.......................
1964.......................
1965.......................
1966.......................
1967.......................
1968.......................
1969.......................
1970.......................
1971.......................

Number
of banks

5, 031
5, 023
4 ,0 1 3
5,011
4 ,9 9 7
4, 981
4, 965
4 ,9 4 6
4 ,9 1 6
4, 864
4, 796
4, 700
4 ,6 5 9
4 ,6 2 7
4 ,5 8 5
4 ,5 4 2
4, 530
4 ,5 1 3
4, 503
4 ,6 1 5
4, 773
4 ,8 1 5
4, 799
4, 758
4, 716
4 ,6 6 9
4, 621
4, 600

Cash dividends

Preferred

Common

Total

Total
capital
accounts*

$110, 597
80, 672
53, 202
32, 529
25, 128
20, 979
16, 079
12, 032
6, 862
5,5 12
4, 797
4, 167
3, 944
3, 786
3, 332
3, 225
2, 050
2, 040
9, 852
24, 304
27, 281
28, 697
29, 120
38, 081
57, 704
62, 453
62, 572
56, 761

$1,440 ,51 9
1,536,212
1, 646, 631
1, 736, 676
1, 779, 362
1, 863, 373
1, 949, 898
2, 046, 018
2, 171,026
2, 258, 234
2, 381, 429
2, 456, 454
2, 558, 111
2, 713, 145
2,871, 785
3, 063, 407
3, 257, 208
3, 464, 126
3, 662, 603
3, 861, 738
4, 135, 789
4, 600, 390
5, 035, 685
5, 224, 214
5, 503, 820
6, 165, 757
6, 326, 508
6, 640, 849

$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
6, 697, 610

$4, 114,972
4 ,4 6 7 ,6 1 8
4, 893, 038
5, 293, 267
5, 545, 993
5 ,8 1 1 ,0 4 4
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
25, 986, 802

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 ,0 4 6 ,4 1 9
1, 042, 201
1, 068, 843
1,2 0 5 ,9 1 7
1, 213, 284
1, 387, 228
1, 582, 535
1, 757, 491
1, 931, 556
2, 534, 029
2, 829, 334
3, 041, 122

$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 ,4 2 8
4, 677
4,011

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
1, 386, 166

Ratios (percent)
Net income Cash divi­ Cash divi­
dends to
before
dends on
dividends net income preferred
to capital
stock to
before
accounts dividends preferred
capital
10.01
10. 97
10. 11
8 . 56
7. 64
8 . 17
8 . 74
7. 79
8 . 17
7. 92
9. 58
8 . 12
7. 87
8 . 32
9. 45
8 . 00
9. 78
9. 09
8 . 70
9. 20
8 . 49
8.61
8.81
9. 20
9. 38
11.44
11.75
11. 70

35. 04
3 1 .7 6
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
4 8 .4 4
4 5 .4 6
48. 86
49. 25
46. 63
45. 30
46. 45
42. 15
45. 16
45. 71

*These are averages of data from the Reports of Condition of the previous December, and June and December of the respective years.
, 1938, p. 115, and 1963, p. 306.

N ote : For earlier data, see




Annual Reports of the Comptroller of the Currency

4. 79
5. 12
4. 56
4. 22
5. 19
5. 24
4. 43
5. 11
5. 83
6 . 02
5. 50
4. 87
4. 49
4. 52
5. 07
5. 12
4. 83
5. 83
2. 05
4. 63
4. 83
5. 06
4. 63
5. 58
7. 53
7. 09
7. 46
7. 07

Total cash
dividends
to capital
accounts
3. 53
3. 48
3. 48
3. 47
3. 50
3. 52
3. 73
3.81
3. 77
3. 80
3. 88
3.91
4.01
4. 15
4. 18
4. 23
. 4. 22
4. 24
4.21
4. 18
4. 15
4. 24
4. 11
4. 17
4. 36
4. 82
5.31
5. 35

T able B -34
Loan losses and recoveries of National banks, 1945-71
[Dollar amounts in thousands]

Ratio of net
Total loans end Net losses or losses or net
of year, net recoveries ( + ) recoveries ( + )
to loans

Tear

Tear

Ratio of net
Total loans end Net losses or losses or net
of year, net recoveries ( + ) recoveries ( + )
to loans

Percent
1945.........................
1946.........................
1947.........................
1948.........................
1949.........................
1950.........................
1951.........................
1952.........................
1953.........................
1954.........................
1955.........................
1956.........................
1957.........................
1958.........................
1959.........................

$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

+ $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

+ 0. 06
.0 2
. 14
.0 8
. 14
.0 5
.0 7
.0 5
.0 8
.0 6
.0 7
.0 8
.0 7
.0 7
.0 4

I9 60.........................
1961.........................
1962.........................
1963.........................
1964.........................
1965.........................
1966.........................
1967.........................
1968.........................
1969.........................
1970.........................
1971.........................
Average
for
1 9 4 5 -7 1 ...

Percent
$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 !
190,308,412 |

73,472, 658

N ote : For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see

of the Currency,

$130, 177
112,412
97,617
121,724
125, 684
189, 826
240, 880
279, 257
257, 280
303, 357
601,734
666, 190

.2 0
. 17
. 13
. 15
. 13
. 16
. 19
.2 0
. 17
. 18
.3 5
.3 5

129, 746

. 18

Annual Report of the Comptroller

1947, p. 100 and 1968, p. 233.

T able B-35

Securities losses and recoveries of National banks, 1945-71
[Dollar amounts in thousands]

Tear

Total securities
end of year,
net

1945.........................
1946.........................
1947.........................
1948.........................
1949.........................
1950.........................
1951.........................
1952.........................
1953.........................
1954.........................
1955.........................
1956.........................
1957.........................
1958.........................
1959.........................

$55,611,609
46 ,642 ,81 6
44, 009, 966
40, 228, 353
44, 207, 750
43, 022, 623
43, 043,617
44, 292, 285
44, 210, 233
48 ,932 ,25 8
42, 857, 330
40, 503, 392
40, 981, 709
46, 788, 224
42, 652, 855

Losses and
chargeoffs

*

Ratio of net
losses to
securities

Tear

Total securities
end of year,
net

Losses and
chargeoffs

$43,
49,
51,
52,
54,
57,
57,
69,
76,
70,
84,
95,

$154,
51,
47,
45,
86,
67,
302,
149,
344,
286,
137,
+ 189,

Percent
$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 .0 4
.0 9
. 10
.0 7
.0 4
.0 4
. 12
. 15
.2 5
.0 8
.3 2
.5 6
. 35
. 12
1.09

Ratio of net
losses to
securities
Percent

1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
Average for
1 9 4 5 -7 1 ...

852,
093,
705,
601,
366,
309,
667,
656,
871,
216,
157,
948,

194
539
503
949
781
892
429
371
528
983
505
647

53,016, 050

♦Excludes transfers to and from valuation reserves beginning in 1948.

N ote : For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see

of the Currency,

*

372
236
949
923
500
898
656
545
068
215
704
347

.3 0
.0 8
.0 8
.0 7
. 15
. 11
.5 2
.21
.4 4
.41
. 16
+ .2 0

118,748

.2 2

Annual Report of the Comptroller

1947, p. 100 and 1968, p. 234.




209

T able B -36
Assets and liabilities of National banks, date of last report of condition, 1950-71
[Dollar amounts in thousands]

Year

1950____
1951____
1952____
1953____
1954____
1955____
1956____
1957____
1958____
1959____
1960____
1961____
1962____
1963____
1964____
1965____
1966____
1967____
1968____
1969____
1970____
1971____

Number
of banks
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,
4,

965
946
916
864
796
700
659
627
585
542
530
513
505
615
773
815
799
758
716
669
621
600

*

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
372, 538, 487

,

Cash and due Total securities
from banks
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
59, 200, 995

$43, 022, 623
43, 043,617
44, 292, 285
44, 210, 233
48, 932, 258
42, 857, 330
40, 503, 392
40, 981, 709
46, 788, 224
42, 652, 855
43, 852, 194
49, 093, 539
51, 705, 503
52, 601,949
54, 366, 781
57, 309, 892
57, 667, 429
69, 656, 371
76, 871,528
70, 030, 342
84, 157, 465
95, 948, 647

,

Loans net

$29,
32,
36,
37,
39,
43,
48,
50,
52,
59,
63,
67,
75,
83,
95,
116,
127,
136,
154,
168,
173,
190,

277, 480
423, 777
119, 673
944, 146
827, 678
559, 726
248, 332
502, 277
796, 224
961, 989
693, 668
308, 734
548, 316
388, 446
577, 392
833, 479
453, 846
752, 887
862,018
004, 686
455, 791
308,412

Other assets

$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
27, 080, 433

Liabilities
Total deposits for borrowed
money
$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
31 4,21 1,6 16

1,

1,
2,

1,

$76,644
15,484
75, 921
14, 851
11,098
107, 796
18, 654
38, 324
43, 035
340, 362
110, 590
224, 615
635, 593
395, 201
299, 308
172, 087
015, 147
296, 821
689, 087
283, 717
280, 365
866, 103

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
30, 387, 265

$2, 001,65 0
2, 105, 345
2, 224, 852
2, 301, 757
2, 485, 844
2, 472, 624
2, 638, 108
2, 806, 213
2, 951,279
3, 169, 742
3, 342, 850
3, 577, 244
3, 757, 646
4, 029, 243
4, 789, 943
6, 089, 792
6, 299, 133
6, 602,519
7, 008, 482
7, 347, 948
7, 680, 597
8, 277, 752

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
18, 794, 699

♦After deduction of securities and loan reserves.

N ote : 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,
to 1949, inclusive, report for 1966.




1913; figures 1914 to 1919, inclusive, report for 1936; figures 1920 to 1939, inclusive, report for 1939; and figures 1936

T able B-37

Foreign branches of National banks, by region and country, Dec. 31, 1971

Region and country

Region and country

Number

Central America......................................

44

El Salvador......................................
Guatemala.......................................
Honduras..........................................
Mexico..............................................
Nicaragua........................................
Panama.............................................

3
3
5
3
29

South America........................................

Number

Luxembourg.........
Netherlands...........
Northern Ireland.
Scotland.................
Switzerland...........

137

1

Africa.
Liberia.

Argentina.........................................
Bolivia...............................................
Brazil.................................................
Chile..................................................
Colombia..........................................
Ecuador............................................
Guyana.............................................
Paraguay..........................................
Peru...................................................
Uruguay...........................................
Venezuela.........................................
West Indies Caribbean.........................
Antigua.............................................
Bahamas...........................................
Barbados...........................................
British Virgin Islands...................
Cayman Islands.............................
Dominican Republic....................
French West Indies.......................
Grenada............................................
Haiti West Indies...........................
Jamaica.............................................
Netherlands Antilles......................
St. Lucia...........................................
Trinidad and Tobago..................
West Indies Federation of States
Europe........................................................
Austria...............................................
Belgium.............................................
England.............................................
France...............................................
Germany...........................................
Greece...............................................
Ireland..............................................
Italy...................................................




38
5
19
9
28
15
1
5
8
4
4
107
2
59
4
3
1
14
1
2
1
7
3
1
5
3
97
1
4
26
10
18
13
3
6

Bahrain........................................................................
Israel............................................................................
Lebanon .....................................................................
Qatar...........................................................................
Saudi Arabia.............................................................
Trucial States............................................................
Asia and Pacific.................................................................
Fiji Islands..................................................................
.
India............................................................................
.
Tapan...........................................................................
Korea...........................................................................
Malaysia.....................................................................
Okinawa.....................................................................
Pakistan.......................................................................
Phillippines.................................................................
Republic of China...................................................
Singapore....................................................................
Thailand.....................................................................
Vietnam......................................................................

Hong Kong.
Indonesia

3
1
3
1
2
5
81
1
15
11
6
13
3
5
2
4
4
2

11
2
2

U.S. overseas areas and trust territories.....................

45

Panama (Canal Zone)............................................

2

Caroline Islands
Guam...........................................................................
Mariana? Islands
Marshall Islands.......................................................
Puerto Rico................................................................
Virgin Islands............................................................

Total....................................................................
Military banking facilities...............................................

1
1
1
19
17
528
30
4

211

T able B-38
Total assets of foreign branches* of National banks, year-end 1953-71

1953
1954
1955
1956
1957
1958
1959
1960
1961
1962

[Dollar amounts in thousands]
1963
......
1964
......
1965
1966
1967
1968
1969
1970
1971...................................................................................

.............................................................. $1,682,919
.............................................................. 1,556,326
.............................................................. 1,116,003
.............................................................. 1,301,883
.............................................................. 1,342,616
.............................................................. 1,405,020
.............................................................. 1,543,985
.............................................................. 1,628,510
.............................................................. 1,780,926
................................................................ 2,008,478

$2, 678,717
3,319, 879
7, 241,068
9, 364, 278
11,856,316
16, 021,617
28,217, 139
38, 877, 627
50, 550, 727

♦Includes military facilities operated abroad by National banks in 1966 and thereafter.

T

able

B -39

Foreign branches of National banks, 1960-71

End of year

National bank
Number of branches branches as a per
operated by
centage of total
National banks foreign branches of
U.S. banks

-

93
102
111
124
138
196

1960
1961
1962
1963
1964
1965

75 .0
75.6
76.6
77.5
76. 7
93 .5

T

able

End of year

National bank
Number of branches branches as a per­
operated by
centage of total
National banks foreigh branches of
U.S. banks

1966......................................
1967......................................
1968......................................
1969......................................
1970......................................
1971......................................

230
278
355
428
497
528

94. 3
95 .5
9 5 .0
9 3 .0
92. 7
91 .5

B -40

Assets and liabilities of foreign branches* of National banks, Dec. 31, 1971: consolidated statement

Assets

[Dollar amounts in thousands]

$248, 081
Cash and cash items in process of collection..........
Demand balances with other banks...............................
955,503
Time balances with other banks................................. 12, 674, 591
Securities.................................................................................
719,349
Loans, discounts, and overdrafts, etc.......................... 19, 379, 739
Customers’ liability on acceptances outstanding. . .
1, 052, 536
Fixed assets........................................................................
134, 714
Due from other foreign branches............................... 11, 280, 045
Due from head office and other branches in the
United States................................................................
3, 396, 921
Other assets............................................................................
709,248
Total assets........................................................... 50, 550, 727

Liabilities

Certified and officers’ checks, etc.............................
Demand deposits of individuals, partnerships,
and corporations.......................................................
Demand deposits of other banks..............................
Time deposits of individuals, partnerships, and
corporations................................................................
Time deposits of other banks....................................
U .S. Government deposits.........................................
Liabilities for borrowed money................................
Acceptances executed..................................................
Other liabilities..............................................................
Due to other foreign branches....................................
Due to head office and other branches in the
United States.............................................................
Capital and undivided profits...................................
Total liabilities and capital accounts........

♦Includes military facilities.

212



$109, 748
3, 222, 741
933, 938
8, 906, 220
22, 250, 356
260, 474
395, 857
1, 053, 707
782,873
10, 668, 272
1, 699, 123
267, 418
50, 550, 727

T able B-41
Trust assets * and income of National banks, by States, calendar 1971
[Dollar amounts in millions]*
§

Number
of banks

Employee
benefit
accounts f

Other
trust
accounts X

Total
trust
accounts

Agency
accounts

§

,

Total
trust and
agency
accounts

Trust depart­
ment income
(Dollar
amounts in
thousands)

Total United States.............................

1, 729

56, 505

88, 985

145, 490

36, 638

182, 128

704, 959

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

30
4
2
32
16
31
12
1
6

270
36
184
36
5, 960
430
438
0
397

943
18
652
222
9, 196
1,347
2, 089
0
1,322

1,213
54
836
259
15, 156
1,777
2, 527
0
1, 719

216
26
40
21
1,889
378
988
0
1,249

1,430
80
875
279
17, 045
2, 155
3,515
0
2, 968

5, 595
364
5, 093
1,485
84, 690
12,016
13, 780
0
9,498

Florida..................................................................
Georgia.................................................................
Hawaii..................................................................
Idaho.....................................................................
Illinois...................................................................
Indiana.................................................................
Iowa.......................................................................
Kansas...................................................................
Kentucky.............................................................
Louisiana.............................................................
M aine....................................................................

91
28
0
2
165
99
47
50
53
21
16

387
533
0
37
6, 988
488
101
67
57
195
41

3, 672
1,238
0
65
7, 065
2, 485
491
530
370
284
263

4, 059
1,771
0
103
14, 053
2, 973
592
598
426
478
304

1, 151
1,328
0
36
4, 683
901
285
138
138
95
110

5,210
3, 099
0
139
18, 736
3, 873
877
736
564
574
414

20, 123
11,297
0
634
70, 565
13, 253
3, 743
3, 145
2,513
2, 920
2,0 43

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

10
55
38
21
20
37
14
21
3
22

199
3, 440
4, 986
1, 143
59
802
6
155
8
11

611
4, 526
3, 062
1,979
221
2, 676
65
553
306
168

810
7, 966
8 ,0 48
3, 122
280
3, 478
71
709
314
180

230
1,720
1,437
855
7
1,255
13
194
28
71

1,040
9, 687
9,4 85
3,976
287
4, 733
84
902
341
251

3,9 14
41,496
21,977
16, 290
1,514
14, 899
420
4, 846
1,818
928

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

73
18
75
16
11
62
42
2
126
3

425
21
15, 687
1, 142
18
1,804
243
251
5,516
269

1,892
250
9, 658
2, 023
107
4, 581
868
703
9, 246
1, 189

2,317
272
25, 345
3, 165
125
6, 385
1, 111
954
14, 762
1,459

811
41
6 , 343
677
22
1,326
398
133
3, 071
419

3, 128
313
31,688
3, 842
147
7, 712
1,509
1,087
17,832
1,878

18, 062
1,208
119, 740
12, 642
839
23, 865
5, 840
6, 168
54,312
8, 076

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

8
10
32
144
2
11
49
10
34
38
16

147
28
272
2, 153
88
5
276
408
28
265
4

445
97
1, 374
4, 549
184
57
1,390
1, 732
406
1, 750
63

592
125
1,646
6, 702
272
62
1,666
2, 140
435
2,015
68

119
38
666
1,368
29
13
868
284
58
445
27

710
164
2,312
8, 070
301
75
2, 534
2, 424
493
2, 459
94

2,9 10
876
8, 765
38,217
1,308
396
9, 661
11,655
2,011
7, 123
426

*As of December 31, 1971.
f Employee benefit accounts include all accounts for which the bank acts as trustee, regardless of whether investments are par­
tially, 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, cus­
todian, 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.
N ote : Data may not add to totals because of rounding.




213

APPENDIX C

Addresses and Selected
Congressional Testimony of
the Comptroller of the Currency




Certain of those changes were fostered by the revision
of regulations by our Office, largely in the direction of
granting more discretion to bank management.
Some of these new or expanded services have been
very much in the limelight in recent years as a result
of litigation brought by non-bank competitors, and
proposed legislation supported by those same competi­
tors. The same banking services were further spot­
lighted by the passage, in the late 1970, o f the amend­
ments to the Bank Holding Company Act, and by the
recent issuance of the Federal Reserve Board’s draft
regulation to implement the holding company
legislation.
In my view, when the “ competitive” policy touch­
stone is applied to the regulatory actions which
spurred the provision o f such services by the banking
industry, the actions pass the test with flying colors.
In every instance, whether involving data processing
services, leasing activity, travel services, insurance
services, or others, the effect of bank entry has been
to increase the number of alternative sources of sup­
ply available to consumers of the services. That in­
crease in alternative supply sources has, of course,
created added competition in the markets involved. It
is our belief that that added competition has re­
dounded to the benefit of the public; no one has been
able to support a challenge to this view.
Note that banks did not bring suit to prevent certain
firms from offering competition, nor did they ask Con­
gress to provide legislative protection for them. The
posture of the banking industry in the area of expand­
ing financially related services has been, and is, highly
procompetitive. It seems to me, in retrospect, that this
simple but crucial point was never adequately made

of financial manipulators, robber barons, and a related
cast of characters in the minds of the general public.
The Congress finally rejected, in my view fortu­
nately, the concept o f a statutory “ laundry list” of pro­
hibited activities. Even were the regulatory “ laundry
list” to be identical with the proposed statutory list, it
is evident that the greater far greater flexibility of the
former would make it preferable.
The proposed Federal Reserve Board regulation to
implement the 1970 legislation should be studied ex­
tremely carefully by the banking industry and by other
interested parties. It is, I believe, too early to make an
assessment of those regulations. However, it is fair to
note that the proposed provisions relating to data pro­
cessing services and leasing services could be somewhat
restrictive for banks. Other services now offered by a
number o f commercial banks were not included in the
initial Fed regulation. Among those are travel serv­
ices. The Federal Reserve Board has promised that
additional activities will be added to the approved list
over time. I would personally hope that the provision
of travel services will be one of those added in the near
future.
Before leaving the topic o f the appropriate product
and service mix for commercial banks, we should note
that the very same issue has come to the fore in con­
nection with most financial institutions. The savings
and loan industry, for example, continues to push for
added powers, powers which would bring the product
mix of savings and loan associations closer and closer
to that of commercial banks.
What appears to be the appropriate stance on these
savings and loan proposals when we apply the com ­
petitive touchstone? I believe that the bank regulatory

during the long congressional discussions of bank hold­

agencies and the banking industry itself would not

ing companies and their proper activities. Certainly,

oppose added competition from savings and loan

the general public was never sufficiently exposed to this

associations provided the rules of the competitive game

position to understand its implications. As I indicated

were made equitable. In other words, if savings and

in my testimony on the bank holding company legisla­

loan associations are to be granted powers which make

tion last May, I believe the position of the banking

them increasingly like commercial banks, then the sav­

industry would have been better understood had the

ings and loan associations should also assume the re­

issue been couched in these terms: applying a public

sponsibilities and burdens of commercial banks. Those

interest criterion, what products and services should

fall primarily in the area of taxation and reserve re­

the commercial banking industry be allowed to offer?

quirements. I must say that that even-handed approach

The end result o f the legislation, of course, was to

has apparently not generated great enthusiasm in the

define the limits of banking activity, or at least to call

savings and loan industry.

for their definition through regulation. However, in
the context of both congressional and public discussion,

its relationship to competition, we recently made the

Turning to another aspect of banking structure and

concentration on “ holding companies” masked some­

following statement, concerning branching, to the

what the essential question. The term, “ holding com ­

Financial Commission on Banking Structure and

panies” , tends, quite unfairly, to conjure up pictures

Regulation:




By far the most important gap in the array of
structural alternatives available to the Comptroller
is the highly restrictive nature of the branching
statutes of many States, including an absolute bar
to branching in the “ unit-banking” States. Those
State restrictions limit the ability of banks to serve
the banking needs of local areas, inhibit the proper
execution of merger policy, and often bar the opti­
mum method of handling bank emergency situations.
A basic premise of bank regulation is that a regula­
tor can come closer to attaining that banking structure
consistent with the best banking performance, from
the standpoint of the public, when he has, at his dis­
posal, all avenues for change in structure. In other
words, within the context of a given banking market,
the regulator can best apply the criterion of the public
interest when it is possible to charter new banks, to
approve branches of existing banks, to approve mer­
gers of existing banks, and to approve acquisitions of
existing banks by holding companies.
The alternative of branching is needed in every one
of our States. It is quite clear, that the broad man­
date given to the Financial Commission on Banking
Structure and Regulation makes it appropriate for the
Commission to examine the question: Should the
branching powers of National banks be determined by
the individual States?
Before leaving the topic of branching, we may note
two other developments which have some relevance.
First, there are no geographical barriers to acquisition
and expansion by bank holding companies insofar as
their “ nonbank” activities are concerned. Second, the
tremendous expansion of credit cards, both within and
without banking, and of related credit plans of all sorts,
have tended to make branching restrictions somewhat
less important than they once were. There is every
indication that further technological developments will
continue that trend.
I presume that the activities of our Office in con­
nection with bank mergers are the best known element
of our policies relating to banking competition. Most
of the publicity concerning bank mergers has ema­
nated from the court suits brought by the Antitrust
Division against mergers approved by one of the bank­
ing agencies. In the context of those suits, of course,
our Office unfortunately is pictured by some as overly
“ liberal” on bank mergers, and as paying too little
attention to the effects of mergers on competition. In
light of this Office’s overall policies relating to competi­
tion, as I have outlined them to you, I think you will
see why I find that criticism ironic. In the context of
the whole financial sector, with all of its interrelated

banking and financial markets, I doubt that any other
single agency has done as much to encourage compe­
tition over the past decade as has ours.
The differences that have been exposed in the area
of bank mergers relate to differing views of the char­
acteristics, quality, and effectiveness of banking com­
petition. In a word, I believe we take a broader view
of competition than some of our critics.
Our bank merger policy is based on several princi­
ples. First, in our market economy, competition is the
means to an end, not an end in itself. Second, the end
sought in the operation of the commercial banking in­
dustry is the best attainable performance in meeting
the financial needs of the public. Third, no unique re­
lationship has been found between structure and
performance in banking. Fourth, the additional ability
to serve better the “ convenience and needs” of the
community gained through merger by a bank must
also be recognized as reflecting a stronger competitive
ability. Fifth, the added ability to meet the financial
needs of the public gained through certain mergers is
traceable to gaining the benefits of economies of scale
over some range of bank size.
The wording of the Bank Merger Act has caused
our Office some problems in our court presentations.
Specifically, those problems center around the some­
what artificial separation of the impact of a merger on
“ competition” and on the ability of the banks in ques­
tion to meet “ the convenience and needs of the com­
munity to be served.” We believe that the anticipated
competitive strength of a bank resulting from a merger
is a factor which cannot be separated either logically,
or realistically, from the ability of that bank to meet
the convenience and needs of the community. In the
cases that have reached the Supreme Court to date,
the Court has first reached an adverse competitive find­
ing, without reference to the question of convenience
and needs. The Supreme Court in the recent Phillipsburg decision restated and emphasized their views that
the two factors must be considered separately. It ap­
pears that as long as an artificial wall is maintained
between “ competition” and “ convenience and needs,”
it will be difficult for defendant banks to achieve a
favorable court ruling.
Finally, in the area of chartering as well, we attempt
to implement a policy consistent with the achievement
of maximum competition compatible with the mainte­
nance of liquidity, solvency, and continuity of our
banking system. One aspect of our chartering policy
has been recently highlighted by a spirited discussion
of the role of black-owned banks and minority-owned
banks in our urban society. In my own view, those
219

463-4)99 O —12 ------- 15




banks, along with all other urban financial institu­
tions, can play a significant role in the rebuilding of our
inner city areas, and in the encouragement of new
minority-owned enterprises. Although the minoritysponsored banks, being new institutions, may not seem
statistically significant, their importance in opening
opportunities for new minority-owned businesses and
for developing financial expertise should not be
minimized.
The decade of the 1970’ s promises to be a period of
dynamic growth for banking and banking’ s financially
related enterprises. Our Office will try to continue to
maintain a regulatory climate which will encourage
the responsiveness of the banking industry to the
financial needs of the public.
R emarks of W illiam B. C am p , C omptroller of
the

C urrency, Before the Sixty - sixth A nnual

C onvention of the M assachusetts Bankers
A ssociation , H amilton , Bermuda , A pr. 20, 1971

T o all of us, it is obvious that the “ business of bank­
ing” must be an evolutionary concept. In banking, only
change is certain. For the banking industry to do its
job responsively and responsibly, it must be geared to
anticipate and to meet the ever-evolving financial
needs of the public.
Recent confrontations between banking representa­
tives and the Congress exposed a widespread lack of
understanding of the necessity of evolution in banking
products and services. That was most dramatically
demonstrated in the bill passed by the House of Repre­
sentatives in 1969 which contained the so-called
“ negative laundry list” of activities to be prohibited
for bank holding companies, and, by implication, for
banks. Fortunately, this “ laundry list” was not con­
tained in the legislation finally passed in December
1970. Also, in my view very fortunately, the basic
banking statute under which our Office operates, the
National Bank Act, contains an “ incidental powers”
provision. That provision gives to National banks “ all
such incidental powers as shall be necessary to carry
on the business of banking.” That flexible provision
has allowed the National Bank Act to continue to serve

National Banking System. The net effect of the re­
visions was to grant bank management greater discre­
tion to use its imagination and initiative in meeting
new financial needs of our ever more complex
economy.
The process involved a determination of which reg­
ulations were excess baggage— unneeded remnants of
another age. Both in the elimination of existing re­
straints, and in the promulgation of additional regula­
tions giving recognition to certain implied powers, we
have kept a competitive criterion in mind. In fact, we
could summarize our “ acid test” for regulatory action
in this way: those actions, consistent with existing
statutes, which are aimed at achieving maximum com­
petition compatible with maintenance of the liquidity,
solvency, and continuity of the banking system are in
the public interest and, therefore, should be adopted.
We are all aware that the shape of banking in the
1970’s will be determined in considerable part bv the
implementation of the 1970 amendments to the Bank
Holding Company Act. We are also conscious that the
recommendations of the President’s Commission on
Financial Structure and Regulation are likely to have
a substantial impact on the operation of banks and
other financial institutions.
It is, of course, much too .early to predict the prob­
able thrust of the Commission’s recommendations.
However, we are encouraged by the high caliber of
its members and by the broadness of the Commission’s
mandate. It is healthy for the Nation to have, periodi­
cally, a complete survey and evaluation of our financial
institutions, their operation, and their supervision. The
Commission has been receptive to ideas and recom­
mendations from all quarters. That stance is fully con­
sistent with the Commission’s mandate.
The 1970 amendments to the Bank Holding Com ­
pany Act will exert a great influence on the evolving
definition of the business of banking, even though the
legislations’ provisions are in terms of activities of bank
holding companies. While some activities may, over
time, be considered permissible for holding companies
but not for banks, the reverse situation is unlikely to
persist indefinitely.

for well over 100 years as the statute underlying the

Perhaps the absence of geographic restrictions on

operation of the National Banking System. We are

the acquisition or establishment of “ nonbanking” fi­

proud of the role our Office has played in the evolution
of the system.

significant part of the 1970 legislation. As far as the

nancially related activities will prove to be the most

We made many changes in our own regulations and

competitive factor is concerned, it is evident that fewer

rulings, with the aim of eliminating holdover regula­

problems will be raised by the acquisition of a company

tions from the 1930’s that were no longer needed to

thousands of miles from the location of the base bank

maintain the liquidity, solvency, and continuity of the

than by an acquisition in the bank’ s own territory.

220




Various interesting possibilities present themselves. For
example, the acquisition or establishment of savings
and loan associations by bank holding companies may
eventually be allowed. Since savings and loan associa­
tions are allowed to branch in a number of States in
which commercial banks cannot do so, control of a
subsidiary savings and loan association is likely to be
attractive.
In part due to a liberalization of our regulations, a
steady increase in the total volume of direct lease fi­
nancing by National banks has occurred over the past
8 years. The “ full payout” criterion incorporated in
the draft Federal Reserve regulation would eliminate a
significant amount of bank leasing activity. Our expe­
rience has uncovered no abuses stemming from bank
participation in that area. On the plus side, bank leas­
ing activity has significantly increased the ability of
lessees, in a number of industries, to serve the public.
Electronic data processing may well hold the key for
shaping the banking frontiers of the 1970’s. By the
nature of bank operations, commercial banks are data
processing institutions. The advent of large, high-speed
computers simply allowed the data processing job to
be done more quickly and more efficiently. Banks are
natural sources of data processing services for many
of their customers. It is vital that banks and bank hold­
ing companies be allowed to continue to pioneer in the
data processing field.
A number of newer banking services which are
expected to increase rapidly in importance during the
1970’s are tied, directly or indirectly, to electronic data
processing activity within banks. One cannot visualize
even the current scope of bank credit card activity in
the absence of computerized operations. All indications
are that bank credit cards and related revolving credit
operations will continue to grow in importance in the
next decade. Credit cards have brought the day of
automatic credit for bank customers closer than ever
before.
Automatic deposits and cash disbursement machines
will almost certainly grow in importance. Considera­
tions of both customer convenience and labor cost
appear to dictate that development. “ Super-checks,”
or multiple-payment checks, are likely to become a part
of the service package of more banks. A side benefit
will be some reduction in the number of checks that
our banking system must process. However, it does not
appear likely that the 1970’s will see the advent of the
full “ checkless society.”
It is difficult to predict what the exact role of the
specialized financial institutions will be during the
1970’s. It is anticipated that the President’s Commis­




sion will make some significant recommendations on
that score. As you know, savings and loan associations,
their trade associations, and their regulatory agency,
the Federal Home Loan Bank Board, are all exerting
strong pressure to increase the powers of the associa­
tions. Each such step taken makes the product-service
mix of savings and loan associations more like that of
commercial J>anks. In my view, if special-purpose insti­
tutions are to become more and more like generalpurpose institutions, then they should also assume the
responsibilities and obligations of the latter. Specifi­
cally; it appears to be quite inequitable for savings and
loan associations to be given more and more of the
powers held by commercial banks without at the same
time assuming comparable tax and reserve burdens.
In terms of the evolution of banking structure in our
country, I would anticipate that many additional bank
mergers will occur, with the purpose of many being to
gain the size necessary to achieve the economies o f large
scale. It is unlikely, in my view, that antimerger activ­
ity by the Antitrust Division can substantially deter
this movement, insofar as it is based on principles of
efficiency and optimum resource allocation. It would
appear that, on occasion, we lose sight o f the fact that
competition is not an end in itself but rather a means
toward an end. The end is the achievement of lower
prices for better products and services for the con­
sumer. It is inconsistent with the public interest to
equate safeguarding “ competition” with safeguarding
“ competitors.”
Branch banking is likely to reach additional areas in
the 1970’s. In my view, it is unfortunate that some
States have seen fit to deny to their citizens the de­
monstrable benefits of branch banking. In our Office,
we will not make any attempt to force branching in
those areas which have not made their own positive
decision. However, the mandate given to the Presi­
dent’s Financial Commission certainly encompasses the
question: Can an adequate banking performance for
the economy of today and tomorrow be achieved in
the absence of a national policy for branching?
As bank supervisors, it is essential that we continue,
and augment, our efforts to keep up with the constantly
changing and evolving facets of the banking industry.
In fact, we strive to forecast new developments insofar
as possible; doing so gives us valuable leadtime to
change elements of our supervisory mechanism.
Our aim in the 1970’s will be to maintain a regula­
tory framework which allows banking to utilize its
unique financial expertise and its related technological
expertise to the fullest extent, insofar as that utiliza­
tion is consistent with maintaining the liquidity, solv­
221

ency, and continuity of the banking system. Our pur­
pose and the purpose of the industry will be one— to
assure that the financial needs of the public are an­
ticipated and met.
Statement of W illiam B. C amp , C omptroller of
the

C urrency , on H .R. 5700 and H .R. 3287,
A pr. 21, 1971

Sections 2 through 9 . Interlocking Relationships.—
The bill would amend the Federal Deposit Insurance
Corporation Act (and other banking law sections) to
prohibit the following: (1) any officer, director, or
employee of eight types of financial institutions from
serving in a similar capacity with any other such insti­
tution; (2) any officer, director, or employee o f such
financial institution from serving in similar capacities
with a corporation which does substantial and con­
tinuing loan or pension trust business with the financial
institution; (3) commercial banks, savings and loan
associations, and mutual savings banks from control­
ling or having interlocking relationships with a title
company, property appraisal firm, or other company
which offers services in connection with the closing of
real estate transactions; (4) service as an officer or
director or employee of a commercial bank or savings
institution, by any lawyer who performs legal services
for a customer of the institution in connection with
transactions with it; and, (5) any interlocking rela­
tionship between any of the eight types of financial
institutions and any corporation in which the institu­
tion has voting control of 5 percent or more of the
stock.
The present Federal law (Section 8 of the Clayton
Act, 15 U.S.C. 19) prohibits interlocking relationships
between a member bank of the Federal Reserve System
and any other bank located in the same city with such
member bank or in any city, town, or village contigu­
ous or adjacent thereto. There are presently no statu­
tory prohibitions against interlocks between the other
seven types of institutions listed in the bill or against
interlocks between institutions more geographically
separated than adjoining towns.
W e agree that some strengthening of the present law
on interlocking directorates is desirable. The adminis­
tration presently is developing a proposal which would
correct the existing deficiencies without disrupting
legitimate business relationships. Under this approach,
the regulatory agencies would be given authority to
regulate interlocks with a mandate to protect the pub­
lic from anticompetitive situations or other abuses.
W e have not seen documented examples of practices
against the public interest sufficient to justify the
222



sweeping dislocation of accepted business practices
which would be caused by the adoption of the other
prohibitions in sections 2 through 9. On the contrary,
we think it would be most detrimental to the public
interest to curtail the use of scarce executive manage­
ment talent in this way.
W e see no possible justification for prohibiting, for
example, a New York City banker who maintains a
winter home in Florida or some other section of the
country from contributing his banking knowledge to a
small local bank in the latter community. Similarly we
see no reason why a large commercial bank specializing
in making loans to the chemical, furniture, or some
other industry, should not be able to have on its board
a business executive skilled in such field. It is no an­
swer to say that such an executive could be found in
a corporation doing no business with a particular bank.
Service on a bank’s board of directors, is not an un­
mixed privilege. There is substantial risk o f liability
involved in serving on the board o f directors o f any
corporation, especially a bank, and, unless a finan­
cially responsible person has some good reason, such
as a continuing business relationship, he will not
assume such responsibility.
The possible abuses which sections 2 through 9 ap­
pear designed to prevent, fall into three main cate­
gories: (1) abuses of the competitive process; (2)
unfair use o f insider information to the detriment of
the general investing public; and, (3) untenable con­
flicts of interest created by a single individual occupy­
ing positions of fiduciary responsibility to different sets
o f beneficiaries.
It is our opinion that there is sufficient Federal law
on the books to deal with problems (2) and (3) and
that the proposal I have just outlined would ade­
quately take care of problem (1 ).
I do not think it is necessary to take the time o f the
committee to detail the elaborate set o f statutory, judi­
cial, and administrative apparatus which exists to con­
trol abuses of the competitive process. Although, as the
committee knows, we do not always agree with the
views of the Antitrust Division of the Department of
Justice, we do not think that anyone, least of all our
Office, could fault them for lack o f zeal or conscien­
tiousness in pursuing their statutory assignment.
The abuse of insider information is also specifically
outlawed by existing Federal statutes, supplemented
by strict judicial interpretations. I refer to the pro­
visions of law administered by the Securities and Ex­
change Commission as interpreted by the Texas Gulf
Sulphur decision.

With respect to conflicts of interest, there are many
legal tools presently available. The common and statu­
tory law of corporate and fiduciary responsibility pro­
vide effective civil remedies to aggrieved stockholders.
In addition to this potential civil liability, questionable
or improper actions of any bank director are subject to
scrutiny, control, and effective sanctions by the bank
supervisory agencies.
In addtion, Section 22 of the Federal Reserve Act
(12 U.S.G. 375, 375A) and Regulation O, issued there­
under, control loans to executive officers.
A powerful deterrent to self-dealing practices in in­
stitutions with more than 500 shareholders is the public
disclosure requirements imposed by the Securities Act
amendments of 1964. The hand of the Federal bank­
ing agencies in controlling conflicts of interest was
greatly strengthened in 1966 by the passage of the
Financial Institutions Supervisory Act. (12 U.S.C.
1 8 1 8 (b )). That act empowered the agencies to issue
a cease and desist order against any practice deemed
detrimental to sound banking.
The philosophy underlying sections 2 through 9
appears to be one of suspicion of the integrity of the
average businessman and banker. M y more than 34
years of service with the Office o f the Comptroller of
the Currency has not led me to any such conclusion.
M y experience has been to the contrary— that with
few exceptions, bankers and businessmen conduct their
lives and affairs with integrity. We think that present
law, if amended in accordance with the suggestion
above, would be adequate to take care of the excep­
tions as they may arise.
Section 10. Mutual Savings3 Bank Stockholdings in
Other Financial Institutions.— Section 10 would com­
pletely eliminate the present practice of some mutual
savings banks of owning shares of commercial banks,
insurance companies, savings and loan associations,
bank and S&L holding companies, and brokerage firms.
W e believe that a better approach would be to pro­
hibit such ownership only in those cases where inter­
locking relationships would be similarly prohibited.
Section 11. Commercial Bribery.— Section 11 would
amend the Federal Criminal C ode to make it a crimi­
nal offense for a financial institution to offer to give a
bribe to an employee of any customer or potential
customer of the bank.
This Office is not aware of any instance in which a
National bank has sought to obtain business or influ­
ence a customer’s conduct, by bribing the customer’s
agent or employee. In the absence of such instances,
it is not apparent to us why Federal legislation is neces­
sary. Some States now make commercial bribery a




crime, and we know of no legal reason why such State
laws would not be available for use against a financial
institution.
O f course, if the committee has evidence of, or rea­
son to believe that, banks, S&L’s, and the other types
of institutions listed in Section 11 have been guilty o f
abuses in this area, we would have no objection to the
adoption o f Section 11.
Sections 12 and 13. Trust Department Stockhold­
ings.— Section 12 o f the bill would require every in­
sured bank to file, with the FDIC, a list of the aggregate
holdings in a fiduciary capacity of all securities, other
than Government securities. Specifically, it would re­
quire filing information as to the name, class, value,
number held, and voting rights of the bank, and how
the shares were voted by the bank in the previous year.
This list would be available for public inspection.
We do not believe that the benefits to be achieved
from this proposal justify the costs which it will in­
volve, both to the Government and to the banks. This
information would constitute a vast mass of statistics,
requiring large storage areas and numbers of house­
keeping personnel at the FDIC. Its very size would
pose a severe limitation upon its utility. In addition,
we question the usefulness, from a standpoint of most
governmental policies, of such a listing. It presumably
will reflect holdings as of a given date and have no
transactional information. W e believe that information
with respect to specific holdings and transactions, ob­
tained from specific banks as of specific times, is more
relevant to the responsibilities of the various Govern­
ment agencies having an interest in bank trust depart­
ments. Sufficient power to obtain such information
presently exists in those agencies, in our opinion. If
deficiencies exist, correction should be considered in
the context of specific policy areas and agency needs.
The accumulation of a vast storehouse of abstract data
of this nature called for by Section 12 will not be of
material aid in detecting or bringing appropriate cor­
rective action in cases of abuse. Its primary utility, in
our opinion, would be the facilitation o f broad-scale
policy studies, such as the recently completed institu­
tional investors study of the SEC. We do not believe
that the ready availability of this information for such
inquiries, which appear to be best conducted at peri­
odic intervals, furnishes sufficient justification for the
cost involved.
This requirement would also be extremely burden­
some upon the banks. Compilation of the information
would require many man-hours of work on the part of
bank personnel, and many hours o f machine time in
automated departments. In smaller banks, the cost in­

223

volved could represent the difference between a profit
and a loss in the operation of their trust departments.
Thus, it would greatly increase the cost of operation
as a corporate fiduciary and have the tendency to drive
smaller competitors from the field and concentrate the
business in the hands of the larger institutions. This
effect is manifestly undesirable.
Section 13 would prohibit insured banks from hold­
ing, in the aggregate, in their trust departments, more
than 10 percent of any class of stock in any corpora­
tion for which a registration statement has been filed
under the Securities Act of 1933. In addition, it would
forbid the holding of any stock, which has been issued
by the bank or its parent company, in the bank’s trust
department.
These limitations would, we believe, be of question­
able benefit. They would eliminate certain conflicts of
interest and limit the potential for concentrations of
control of corporations by banks through their trust
departments. However, in so doing, they would cripple
the effectiveness of professional corporate fiduciaries.
A person planning the administration of his estate
would have no assurance that the trust department of
his selection would be able to accept his account, be­
cause some of his holdings might push the trust depart­
ment aggregate over the 10 percent limit in a particular
security. These considerations would become particu­
larly acute in the case of family owned corporations.
If the stock were registered under the Securities Act of
1933, the use of a corporate fiduciary would not be
available to the family for estate planning purposes.
The flat prohibitions upon holding stock of the bank
or its holding company pose even greater problems for
the person planning his estate. If he holds stock of a
bank, he would simply have to utilize the services of a
different bank or individual. Large holdings of stock
of a bank or bank holding company on the part of an
individual reflects great confidence on his part in the
management of that bank. It is natural that such a per­
son would also have great confidence in such bank’s
ability to manage his estate. This provision might de­
prive him of his constitutional freedom of choice and
even drive his holdings into the hands of a competitor
bank. Even if the alternative institution were not a
competitor, the implications from an antitrust stand­
point, of encouraging the flow of blocs of stock of one
bank to the trust department of another bank, are
serious.
Finally, we believe that the net effect of this section
would be to drive trust and estate business into the
hands of individuals. Because of their mortality, fre­
quent lack of expertise, and virtually complete freedom
224



from governmental supervision, we do not regard this
as a desirable result. We believe that the desirable ends
sought to be achieved by this section are now being
obtained through banking supervision. If it is felt that
increased statutory safeguards are required, the bank
supervisors can readly implement them. For example,
Section 61 of Title 12 presently imposes a most effective
restriction on the voting of National bank stock held
in a trust department, in the election of directors of
the fiduciary bank. This provision might well be ex­
tended to all insured banks.
Section 14. Equity Participation Loans.— Section 14
would make it a Federal crime for any insured bank,
insured S&L holding company, mutual savings bank, or
insurance company to take, as consideration for any
loan, a share in the ownership or profits of the
borrower.
This Office, in August of 1970, made a survey relat­
ing to equity participation loans by National banks.
A sample of 502 National banks was surveyed, includ­
ing all 149 National banks with deposits of $225 mil­
lion or more. The remaining 353 banks in the sample
were selected to provide representative coverage of
geographic areas and bank size.
The results indicate that equity participation loans
are relatively insigificant in the National Banking Sys­
tem. The sample banks reported only 112 such loans,
totaling $159 million, as of August 31, 1970. That
amount represented only 0.27 percent of the $58 bil­
lion volume of outstanding commercial and industrial
loans on the books of the sample banks. Only 42 of the
502 banks in the sample reported any equity partici­
pation loans.
The volume of such loans by affiliates of banks in the
sample was also small. Fourteen banks in the sample
reported one affiliate each with equity participation
loans. In all, 117 loans by these 14 affiliates totaled
$28 million.
It is apparent from our sample that National banks
are not making equity participation loans to any sig­
nificant degree. We have no reason to believe that
the attitude and practice of State member banks is
different in this regard. Given the small amount of
activity, it could be argued that no great harm or incon­
venience would be caused (at least to banks) by the
enactment of the prohibition of Section 14. However,
we believe that the stronger considerations and argu­
ments are to the contrary.
First, the enactment of Section 14 would represent a
marked departure from the approach of past Con­
gresses to the field of law commonly referred to as the

usury statutes. Substantive regulation in this area has,
almost without exception been left to the States. In the
absence of compelling necessity, we do not think it
advisable to take what might become the first step
toward a general Federal usury law.
Second, we believe strongly in the principle that
markets should be left free of any forms of price con­
trol, in the absence of compelling necessity. The tradi­
tional approach to the regulation of loan interest has
been to impose only such controls necessary to protect
the unsophisticated consumer. Interest rates on com ­
mercial loans have been left to find their natural level
based on competition. The commercial loan segment
of our free market has always been one of the most
sensitive to changing money supply and general eco­
nomic conditions.
Third, the restriction of Section 14 would apply only
to banks, S&L’s, their holding companies, and insur­
ance companies. The omission of mortgage companies,
pension funds, and other possible sources of construc­
tion and commercial loans, would give such lenders
an obvious and unfair competitive advantage.
Sections 15, 16, 17, and 18. Insider Loans.— Sec­
tion 15 would amend the Federal Deposit Insurance
Act to require the following of insured banks:
(1) A report to the FDIG (for the purpose of place­
ment in a public file) of the nature and amount of any
loan to a director, officer, or employee of the bank, or
any member of such person’s immediate family.
(2) No loan to be made to any person acting as
agent for another, except on condition that the bank
be informed of the identity of the person receiving the
beneficial interest of the loan.
(3) No loan to be made to any corporation of which
5 percent or more of the outstanding stock is owned
in the aggregate by directors, officers, or employees of
the bank.
We believe that the statutory tools presently avail­
able to the supervisory agencies to combat self-dealing
are adequate. These tools are described in our earlier
discussion of sections 2 through 9. The existing tools
provide for more flexibility and fairness than the flat
prohibition contained in the bill.
Also the interaction of the proposed public disclosure
provision in Section 17(b) with the prohibition con­
tained in Section 18 would result in an undue invasion
of privacy of many bank employees and needless public
disclosure of many harmless transactions. Section
22(g) of the Federal Reserve Act (12 U.S.C. 375A) as
amended in 1967 expressly permits a member bank to
make certain types of loans to its own executive offi­
cers. The permitted loans include a residential mort­




gage loan of up to $30,000; a children’s education
loan of up to $10,000; and, a general purpose loan of
not more than $5,000. We see no supervisory purpose
to be served by requiring such loans to be made a mat­
ter of public record as does proposed Section 1 7(b).
Sections 19, 20, and 21. Brokered Deposits.— Sec­
tions 19 and 20 prohibit any insured bank or S&L
from making any payment to anyone as compensation
for obtaining a deposit for the bank or S&L. A pay­
ment made by a person, other than the bank or S&L,
for the purpose of obtaining a deposit for the bank or
S&L is deemed to have been made by the bank or S&L
if it had, or reasonably should have had, knowledge of
the payment when it accepted the deposit.
The acceptance of deposits and loans placed through
money brokers has been a significant contributing
factor to several bank failures in the past few years.
All of the Federal banking agencies now have out­
standing directives designed to curb the practice.
We also support the principle of outlawing the
troublesome aspects of brokered deposits by statute. In
the National banks, the trouble-causing aspect has
been the acceptance of questionable out-of-territory
loans from the money broker as a condition of his
obtaining deposits for the bank. However, we under­
stand that the FDIC has found other types of broker­
age abuses in some closed State banks.
We, therefore, support in principle a prohibition of
brokered deposits. We think it important, however,
that the charter supervisor, or some other banking
agency, be given exemptive and regulatory authority
to define the terms used in the statute. There are a few
compensated deposit gathering services which are
unobjectionable and even essential in certain markets.
Section 22. Gifts To Attract Deposits.— This section
would prohibit the practice of offering merchandise or
other premiums to depositors as an inducement to
make or add to any deposit.
The use of merchandise premiums promoting retail
deposits is presently closely limited by rulings of all the
Federal banking agencies. The banking agencies’ coor­
dinating committee agreed some time ago to restrict
the value of such premiums to a wholesale cost of $5
in connection with deposits of under $5,000 and $10 if
the deposit is $5,000 or more.
It is our view that the existing regulatory approach
to the giveaway problem is preferable to a flat prohibi­
tion since it provides a measure of flexibility to permit
at least minimal competition to the benefit of the small
depositor who at present is restricted to a much
smaller percentage of interest than are depositors
possessing over $100,000.
225

Sections 25, 26, and 27. Deposit Insurance for Pub­
lic Units.— Sections would extend 100 percent insur­
ance for deposits of Federal, State, and local govern­
ments in insured banks and S&L’s.
Exempting public depositors from the $20,000 limit
on insurance would appear to conflict with the objec­
tive under existing law of providing protection for the
savings of individual families of moderate income who
frequently lack the technical ability to appraise accu­
rately the soundness of available outlets for their funds,
while maintaining the incentive to holders of large
accounts to investigate institutions before placing
deposits in them. Moreover, exempting one class of
depositors from the limitation on insurance coverage
could lead to pressures to extend the exception to other
classes.

(2) One of the principal problems inherent in take­
over loans, is the almost inevitable sequel of some of
the taken-over bank’s liquid funds being transferred to
the lending bank as an interbank deposit. This inter­
bank deposit is often a prearranged condition of the
takeover loan. The Department of Justice, in a letter to
the banking agencies, has taken the position that the
use of an interbank deposit as a compensating balance
for a loan to controlling persons of the depositing bank
may constitute a misapplication of the depositing bank’s
funds. This position was made known to all banks by
the Federal banking agencies in a circular letter in
October 1970.

Local law now requires in almost all cases that public
deposits be secured in full by the depositor pledging
Federal, State, or municipal bonds. Some States kill
two birds with one stone by specifying that only home
State bonds shall be eligible collateral for this purpose.

W e understand another concern behind H .R. 3287
to be the prevention of bank takeovers in general by
undesirable persons through the use of funds borrowed
from other banks.

Adoption of Section 25 would eliminate any need for
pledging and probably would have a substantial nega­
tive effect on the demand for municipal bonds, a mar­
ket which already suffers from serious structural
problems.
For these reasons we do not favor the adoption of
Section 25.
H .R. 3287. Bank Stock Loans.— The bill flatly pro­
hibits any insured bank from making a loan, the pro­
ceeds of which are used to buy any stock or bonds of
any bank.
W e understand the purpose of H.R. 3287 to be to
stop the practice of one bank financing the takeover
of control of another bank. However, the language of
the bill goes much further and apparently prohibits
any bank loan for the purpose of purchasing even one
share of bank stock. This would make unlawful many,
many routine loans for investment purposes. We know
of no reason why an investor should not be able to
purchase bank stock on margin in accordance with the
prevailing margin requirements, in the same way as
any other security.
Even if the bill were amended to prohibit only take­
over loans, we feel that it would be still inadvisable for
the following reasons:
(1) Our Office, and we are sure other bank super­

W e believe that the distribution of the Justice letter
has been effective in minimizing one of the most
troublesome aspects inherent in takeover loans.

This is a laudable purpose with which we as bank
supervisors could not agree more. However, the bill
draws no distinction between the desirable and undesir­
able purchaser-borrower. We fear that the effect of cut­
ting off prospective desirable bidders for banks from
the conventional source of financing might be to pro­
mote one of the very things the bill is designed to
prevent— the use of underworld money by undesirable
elements.
It has been our experience that the great majority of
bankers would never knowingly finance the takeover
of another bank by dishonest persons. This is not to
say that misjudgments have not and cannot occur.
When one does occur, we feel that the tools presently
available are sufficient to take care of the situation.
Under the provisions of the Barr bill (12 U.S.C. 1817
(i) ( 1 ) ) , passed in 1966, a bank which makes a take­
over loan must notify the supervisory agency of the
takeover bank. This serves to alert the agency to watch
out for possible changes in management competence.
For the above reasons, we do not favor the adoption
of H .R. 3287.
R emarks of W illiam B. Gam p , C omptroller of
th e

C urrency , Before th e I ndiana Bankers

A ssociation and th e G raduate School of
Banking , I ndiana U niversity , H onoring

visors, have had occasion to call on a financially strong

Joseph W . Barr, Bloomington , I nd .,

institution to finance the purchase of control of a falter­

Sept . 24, 1971

ing one. This bill would take away that supervisory
tool.

I have been asked, as speakers often are, to take a
look at the future— to discuss the opportunities and

226



challenges for American banking in the fast-moving
world in which we live.
But, I can never meet with any group of bankers
from Indiana without reflecting on the enormous con­
tributions your State has made in the past, and is con­
tinuing to make, to sound banking progress.
The occasion for today’s meeting is a tribute to my
friend, Joe Barr, one of Indiana’s most outstanding
recent contributions to good banking. I have known
him well and fondly since he came to Washington as
a Congressman in 1958. He served on the House Bank­
ing Committee, unfortunately not long enough to be­
come its chairman.
I knew him still more closely when he served as
Assistant to the Secretary of the Treasury for Congessional Relations. We had a most harmonious relation­
ship when he was chairman of the Federal Deposit
Insurance Corporation.
When he returned to the Treasury as Under Secre­
tary, we worked even more closely together. Joe, quite
literally, became my boss when he was appointed Sec­
retary of the Treasury. Now he works across the street
from me as president of American Security and Trust,
and I can look over his shoulder and second-guess him
on every loan decision he makes.
Needless to say, of all the problems that might come
before me, that worries me the least.
I am here today because I value his friendship, I
admire his ability and talent, and I wish him every
success as a progressive banking leader.
But Joe is not the only Indiana banker whose
achievements are important to us.
In our Office, we are ever mindful of the powerful
role played by Hugh McCulloch, first Comptroller of
the Currency, in molding the shape and nature of the
National Banking System. He gave it the stamp of his
character in establishing its rectitude and reliability.
He gave it the promise of his vision in setting its creative
goals. He imparted to the new system much of his re­
markable energy in promoting its progressive growth.
Yet, in his own words, from his memoirs:
In ) 862 I went to Washington, to oppose the pas­
sage of the bill to establish a national banking
system, which, if it passed, might be greatly prejudi­
cial to the State banks, of one of the largest of which
I was president.
M cCulloch’s efforts were unsuccessful, but his dili­
gence, his talents, and his capabilities were so impres­
sive that he was offered appointment as the first
Comptroller, and was urged by Treasury Secretary
Salmon P. Chase to accept.
Here is how McCulloch described his dilemma and
his solution of it :




It had become quite certain that the war was not
to be brought to an early close, and that the expense
of prosecuting it, already exceeding its anticipated
cost when hostilities were commenced, must be
enormously increased before it was ended. It was
also equally certain that the notes of the State banks,
imperfectly secured as most of them were, could not
be safely received in the collection of the public
revenues.
I had, therefore, been forced to the conclusion
that banks with a perfectly secured circulation,
which would be current throughout the Union, were
an absolute necessity, and a careful examination of
the Bank Act had satisfied me that this necessity had
been met by it.
But I was president of a bank which I knew was
sound to the core, and in whose welfare I was deeply
interested. The offer of Mr. Chase was, therefore,
not only unexpected but embarrassing. I was wedded
to the bank which I had worked hard to place in a
perfectly solvent condition. I could not resign the
presidency of it without severing very agreeable offi­
cial relations, nor without considerable pecuniary
loss, and I had no desire to go to Washington. On
the other hand, I had been forced to admit that
there was a necessity for a National Banking System,
and I felt that the Government had a right to any
services that I might be able to render in the tre­
mendous struggle in which it was engaged.
Being thus in a straight, I did what all men who
have sensible wives ought to do, when important
questions are to be considered and acted upon— I
consulted my wife. The conclusion was that I should
resign the presidency of the bank and go to Wash­
ington . . .
In addition to the many parallels between this ac­
count of more than a hundred years ago and some of
the dilemmas that face us today, I think there is a sig­
nificant lesson to be learned. It is that the abiding love
of a good woman is strong enough, and beneficial
enough, to change even the most vigorous critic of a
banking system into one of its most ardent supporters.
So, if any in my audience here have any talent as
matchmakers, and if any of you know a good woman
who would be willing to marry and reform Ralph
Nader, I hope you will rise to the challenge on behalf
of the entire banking system of the country.
Well, all of us can be changed in our thinking and
improved in our attitudes. And the inevitability of
change is one of the few constants on which we can
rely.
227

Aware of the universal frailty of mankind, many
critics of our system of representative democracy pre­
dicted shortly after its establishment that it could not
long endure. They reasoned that, when the common
man realized that it lay within his power to raid the
public treasury by majority vote, he would soon do so,
and, in the process, quickly bankrupt both the Gov­
ernment and the free enterprise economy it sought to
foster.
The “ Robin H ood” philosophy, that of taking from
the rich and giving to the poor, has such widespread
appeal that its preachment comes naturally to any
demagogue willing to prey on the gullibility of his
constitutents.
Some time ago, a speech was made on the floor of
the Senate 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 all 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.
On occasion, both our form of government and our
type of economic system have come perilously close to
foundering from just such assaults referred to by
Daniel Webster.
Yet, always, the sober commonsense of free men and
women, and the marvelous flexibility of our system has
permitted us to change with the changing times, to
adjust to new circumstances, and to compensate for
different pressures and demands.
Instinctively, the American people bring to bear on
their problems a self-disciplined rationality that is the
enduring proof of their ability to govern themselves.
Government, they reflect, always is the exercise of dis­
cipline, and self-government is inescapably the exer­
cise of self-discipline.
If a better way of achieving our goals can be de­
vised, the people seem to say, let’s think it through,
make our plans accordingly, and carry them out, cooly,
confidently, and rationally.
Was this not the philosophy of Hugh M cCulloch?
Did he not adapt rationally to significant changes that
faced him in his time and place? D o we not have a

228



similar challenge and a similar obligation today? I
think the answer must be in the affirmative on each
point.
Today, commercial banks are demonstrating a new
awareness of the relationship between their well-being
and that of their communities. A few examples of
specific programs initiated and operated by individual
banks and groups of banks should suffice to illustrate
my major thesis. M y principal source is a volume re­
cently published by the Bank Marketing Association,
entitled “ Public Affairs and Banking . . . An Action
Report.” A bank in Arizona recently pioneered a new
program wherein some 60 minority businesses were
given special attention and their owners received the
capital, know-how, and encouragement they needed to
build independence and success. The program goes
into considerable depth with each business offered
assistance in capital structuring, organization, and
management.
Since its initiation, this program has helped small
businesses of all types become realities for individuals
belonging to minority groups, and millions o f dollars
have been put to work through these businessmen
in establishing supermarkets, service stations, beauty
shops, clothing stores, and many other classifications
of business that, in turn, help the area economy and
stabilize business conditions.
In 1969 our Office chartered a new National bank
in Minneapolis, located in a ghetto area which for two
summers had been the scene of demonstrations and
unrest. The bank was financed by a registered bank
holding company and headed by a dynamic and dis­
tinguished member of the black community.
The new bank, housed in one of the few buildings
still left standing on an almost-deserted street, became
a rallying point for new businesses and new outlooks.
The bank has not wrought major changes on the
near north side during its short life, nor has it been
responsible for any great outpouring of funds. It is too
small for that. But the bank has been solidly estab­
lished in a neighborhood with a wide mixture of races,
with income levels from poverty to middle-class, all
needing assistance in upgrading the opportunities for
employment, better housing, and better schools in the
area.
The bank will no doubt play a key part in the fur­
ther renewal and redevelopment work in the area, and
make the Plymouth Avenue business district take on
greater life and activity to replace the scarred, boarded
up buildings that mar part of the avenue’s facade.
An antipollution code was drafted and adopted by
the Maine Bankers Association, and has also been

adopted, with only minor alterations by the New
Jersey and Vermont associations. It is reported that a
similar code has been adopted by the Missouri associa­
tion. The Maine code requires that credit decisions
relating to the financing of new industries and the
expansion of existing industries, ensure that such fi­
nancing shall not encourage or abet pollution of the
air, land, or water of the State. A number of bank
boards have specifically endorsed the code. Such action
recognizes that the extension of a loan which would
lead to substantial pollution in the bank’s area, how­
ever profitable immediately, would not be in the bank’s
long-run best interest. If enough banks become accus­
tomed to applying that test for loans in their own
areas, it may be hoped that the test will be extended to
outside-area loans.
An Indiana bank has a program of granting com­
mercial loans of up to $500,000 each, on special terms,
to companies wishing to finance antipollution equip­
ment for existing facilities. Several banks are supple­
menting the funds available for “ environmental” loans
by selling specially designated certificates of deposit.
Certain bank programs can most properly be con­
sidered community contributions, because even their
long-run profit connection is too tenuous to be measur­
able. Such programs do reflect a recognition by bank
boards that an institution has certain civic responsi­
bilities that lie outside direct market considerations.
A good example is a program established by a bank in
Chicago. The program has provided instructions in
personal financial management to thousands of schoolchildren and adults. The bank’s out-of-pocket expense
has been about $100,000.
I would like to emphasize that I think of my message
as essentially optimistic. I believe that we can have
the continuing benefits of an enterprise economy and
yet make rapid strides toward alleviating some of the
social problems which have arisen as a byproduct of
our growth. I feel confident that the banking industry
will continue to play a vital and enlightened role as
we move toward the achievement of new goals in our
society.
R emarks of W illiam B. C amp , C omptroller of
the

C urrency, Before the N ational Ban k

D ivision of the A merican Bankers
A ssociation , San Francisco , C alif .,
O ct.

18, 1971

“ The Evolution of the ‘Business of Banking’ ”
Today I would like to discuss commercial banking
in the 1970’s. T o all of us, it is obvious that, in banking,




only change is certain. For the banking industry to do
its job responsively and responsibly, it must be geared
to anticipate and to meet the ever-evolving financial
needs of the public.
Sometime ago, a friend gave me a copy of a 1905
issue of The American Banker. Some items which ap­
peared in it sound all too familiar. It reported, for
example, that “ the question of whether gross fiving
expenses have risen during the past year . . . is re­
ceiving a great deal of attention . . . in Washing­
ton . . . ” One expert predicted “ an era of rising
prices.”
The Pinkerton agency reported to the ABA that,
during the previous 10 months, 26 “ forgers and swin­
dlers” and 25 burglars were convicted. It also reported
that one gentleman who had drawn numerous small
checks with which he swindled hotels was a “ source of
annoyance” to the bank in question.
The revolution in transportation wrought by the
automobile was then just beginning. A banker, address­
ing a 1905 session of the Tennessee Bankers Conven­
tion which was held on Lookout Mountain that year,
referred to “ this age of wonderful advancements, . . .
fast transportation like the Pennsylvania Flyer,” a train
which had just been placed in service between New
York and Chicago. The speaker said, “ Think of what
a marvelous age we live in. We now have a train which
can cover 900 miles in just 18 hours.”
A bank in Texas advertised that it made collections
in “ Indian Territory.” A bank in New York, by implica­
tion, was not yet cultivating the “ friendly banker” im­
age. It advertised that it offered to depositors “ every
facility which their balances, businesses, and responsi­
bility warrant.”
As we think of all the changes that have occurred in
our economy and its mode of operations since 1905, it
is clear that the banking industry has no choice but
to try to keep pace.
During the course of congressional consideration of
amendments to the Bank Holding Company Act, we
were asked to provide an enumeration of the “ specific
areas of activity in addition to banking functions which
bank holding companies should be permitted to engage
in.”
In replying, we stated that it would be “ most un­
wise” to include in a statute an enumeration of the
functions which could be performed by banks and bank
holding companies. In support of this position, we
quoted from an 1870 decision o f the U.S. Supreme
Court. In the case before the Court, one bank had
actually sued another because the defendant had insti­
tuted the practice of certifying checks. Just think of

229

that! The Court held that a National bank had the
implied power to certify a check because
. . the
practice of certifying checks had grown out of the busi­
ness needs of the country.”
During the course of the litigation, the Court was
requested to define the business of banking. In its wis­
dom, the Court said, in effect, “ we cannot do this and
it would not be proper even if we could. We live in a
changing world, new products, new techniques, new
and better methods of doing business are constantly
coming into being.” The introduction of check certifi­
cation, the Court said, is a classic example of a “ new
and better method of doing business.”
The Court added:
Time and experience, if slower, are wiser law­
makers than legislative bodies. 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 juris­
prudence has thus grown, and will continue to grow,
by successive accretions.
The New York Free Banking Act of 1837 gave New
York banks the “ . . . power to carry on the business
of banking . . . by exercising such incidental powers
as shall be necessary to carry on such business.” In
1857 the New York Court of Appeals was asked to
define the powers of a bank. That Court, in language
I consider quite classical, 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.
Just 10 years ago, our Office embarked on a com ­
plete reexamination of its regulatory role. Since then,
a large number of regulatory innovations have been
adopted. As must be the case in any period of wide­
spread change, some errors and false starts occurred.
By and large, however, our policies, although often
initially controversial, have gained widespread accept­
ance. We are indeed proud of the part which our Office
has played in the dynamic growth of the banking in­
dustry during those 10 years. It is appropriate at this

industry’s response to new financial needs of the public,
both business enterprises and individuals. In my view,
the responsiveness of an industry to newly emerging
requirements of its customers is the best single test
of how well that industry is serving the public. O f
course, since the special nature of banking operations
subjects the industry to a high degree of regulation,
banks are not as free to respond immediately to new
public demands as are the firms in nonregulated in­
dustries. It is in that area of regulation— our recog­
nition of and response to emerging financial needs—
that our Office has striven to be especially vigilant.
In a series of actions, ranging from data processing
through direct lease financing to travel services, we
have endeavored to create a regulatory climate that
rests on a recognition of the dynamics of our financial
system. Put another way, we endeavored to alter or
eliminate those regulatory restrictions, not required by
statute, whose effects were to place barriers in the path
of bank innovation. Aside from the statutory test, of
course, we also had to ascertain whether the omission
or modification of a given regulation would endanger
the liquidity, solvency, or continuity of the National
Banking System.
The movement o f National banks into additional
product and service lines increased the degree of
competition in the markets for those products and
services. The benefits of competition for the public,
primarily more sources of supply at lower prices, need
not be labored here. You will recall that the reaction
of a number of nonbank competitors was to file law­
suits, against both National banks and our Office,
charging that there was no statutory basis for the
entry of National banks into those lines.
Several generalizations can be drawn about those
suits. First, they were inherently anticompetitive. V ir­
tually absent from the suits was the charge that, some­
how, the public interest would not be served, were
National banks to offer the services in question. The
broad public interest test was simply not applied by the
plaintiffs. Rather, it was asserted that National banks
would have an undue competitive advantage in those
service lines and, that further, there was no basis in
law for National banks to engage in such activities.
The results of those various suits were mixed, but

time, I believe, to review the major developments of

the harassment of banks took its toll. Obviously, the

the decade, and to take stock of banking’s current posi­
tion and its future course.

attractiveness of entering a particular service line was
reduced when such action seemed almost certain to

The expansion of banking’s product and service mix

generate prolonged, expensive litigation. W e hope that

during the past decade is perhaps the most striking

those challenges will not unduly deter banks from seek­

single development. That expansion represented the

ing new ways to serve the public.

230



When the times change and banks do not, I become
concerned for the future of us all. I take very much
to heart the warning in a recent report by a Presiden­
tial commission which found that “ regulatory agencies
are marked by rigidity and lack of adaptability.” The
same report noted that, in the face of rapidly changing
situations, the regulatory agencies “ lack flexibility and
imagination” to carry out their objectives. The report
warned that they “ tend, with time, to become pris­
oners of old philosophies and outworn procedures.”
In my view, all bankers, and, indeed, all bank regu­
latory authorities, have an obligation to continually
participate in the learning process in order that they
may have a better understanding of the public inter­
est. For many years, the thinking of regulatory officials
was shackled by the repressive and damaging attitude
that the primary purpose of bank regulation was to
take the risk out of banking by substituting the judg­
ments of regulatory officials for the judgment of
operating bankers.
Let me discuss with you some of the forces for
change that I think are a challenge to us all and sug­
gest some guidelines that I believe can be useful in
many of the adjustments that must come about.
We live in an age of legitimate concern about a
number of problems that seem to be byproducts of
our complex, urban-oriented, interdependent economy.
Among others, these include a marked deterioration
of the cores of our urban centers; inadequate housing
for a significant segments of our population; a sharp
rise in the level of air, water, and noise pollution; and,
our failure thus far to achieve completely equal em­
ployment opportunity for people of all races and
backgrounds.
A broadly worded statement of national goals, aimed
at alleviation and eventual elimination of those prob­
lems, can be drafted in such a way as to gain virtually
universal support. Controversy arises when the gen­
eralities are translated into specific operating policies.
I would like to give attention today to certain specifics
dealing with the role of commercial banking and to
some extent the role of business in general, in our
efforts to progress with our national agenda.
In my view, much of the current criticism directed
at the business sector reflects a lack of knowledge and
understanding of the functioning of our free enter­
prise system, and of the crucial contribution by this
system in making our economy the richest and the
most productive in the world today. I believe that
the banking industry, and to some extent the business
sector in general, is receiving a “ bum rap” from a
number of its “ social activist” critics. However, it will




be plain as I proceed that I am not suggesting that
anyone should rest on his laurels. There is much to be
done, in both the public and private sectors, if our
Nation is to fulfill the hopes and dreams of its citizens.
Certain key relationships underlie the functioning of
financial institutions in our enterprise economy. I
should note in passing that the temporary wage-price
freeze now in effect will alter a number of relation­
ships in the short term. However, the basic principles
discussed here will again be fully applicable over the
longer term.
Over 80 percent of bank funds stem from depositors
who have every reason to believe that their funds will
be carefully safeguarded. The banking industry can
properly perform its principal functions only if in­
dividual institutions are operated in a way that main­
tains their solvency, and thus, the safety of their de­
posits. This point appears to escape some banking
critics. The banking industry is faced with the sort of
massive misconception about its role that recently led
to a description of a branch system’s operation as “ being
like a regressive tax, taking money from those who can
least, afford to lose it and giving it to those who need
it least.”
Commercial banks primarily serve as an inter­
mediary between savers and borrowers. The savers seek
the safety of their principal and, in the case of time
deposits, a return on that principal. The credit made
available to borrowers, both individuals and busi­
nesses, provides a vital lubricant in the functioning of
our enterprise economy. In general, those borrowers
who are able to provide reasonable assurance of their
ability to repay loans will become the preferred risks.
Where insufficient funds are available to meet the
needs of all prospective borrowers, the interest rate
mechanism serves as one allocative device.
It is clear that profits play a crucial role as a guiding
force in this operation. The borrowers’ anticipation of
profitable operations leads them to the banker’ s win­
dow in the first place. The ability of the banker to
make accurate assessments of the likelihood of profit­
able operations by prospective borrowers will, in turn,
largely determine the eventual profits of the bank itself.
Those for whom the term “ profit” is a dirty word have
failed, in my view, to study and to comprehend the
dynamics of our economic history. The economic
growth in this Nation over two centuries is firmly and
unquestionably related to the incessant drive for profits
on the part of both business enterprises and individuals.
I am certain that any self-styled “ social activists” in
the audience are at this point writing off my message
as that of one more tired voice defending our system
281

and all its results without qualification. If such is the
case, I hope these listeners will not yet close their ears.
One hears the term “ social responsibility of business”
very often today. This is a useful and meaningful
phrase if defined within appropriate limits. However,
if defined by those who fail to understand the function­
ing of an enterprise economy, it may be used, perhaps
unwittingly, as a wedge to undermine the heart of our
economic system.
I believe there are several key elements in the social
responsibility of all who are engaged in the banking
business. First, the banking business, indeed all busi­
ness, must adhere strictly to the letter and the spirit of
our laws. O f course, in a viable democratic society, the
same adherence on the part of individuals is a necessity.
Second, an important element of social responsibility is
the involvement by bank officers and employees in the
legislative, administrative, and electoral processes. The
aim of this involvement should be to improve the body
of law, or to aid in its proper interpretation. Finally,
to carry out its social responsibility, the banking busi­
ness must be operated in a manner consistent with the
achievement of an efficient allocation of resources for
the economy as a whole. Within the context of a com ­
petitive market economy, the appropriate guideline for
the bank in achieving an approximation of that result,
is to pursue its long-run profit goals.
The last requirement, in my view, is the key to a
proper and consistent interpretation of true “ social
responsibility.” Several points need to be made in con­
nection with this requirement. Those who would re­
move the profit test as the basic operating guideline for
businesses leave a dangerous vacuum. Banking, and all
businesses, are simply called upon by these selfappointed guardians of the consumer and the public
to follow the policies which those same paragons have
decided, in their wisdom, are correct. Yet we know
that differences of opinion and quite divergent order­
ings of priorities exist within any democratic society.
The safeguard of the objective test of the marketplace
is lost when enterprises succumb to the pressures of
those critics of business. The full consequences of such
a surrender can easily be overlooked.
Although the above may sound essentially negative,
we can now turn to the positive aspects involved in our
operating rule. Many critics of the profit motive as an
operating principle fail to perceive that narrowly con­
strued, short-term profit goals are often utterly incon­
sistent with broadly based long-term profit goals. When
the “ long view” is taken, as it should be, I believe, we
find that the interests of business enterprises and of
society are much closer to convergence. Let me now
232



turn to some specific problem areas in our society, to
show you how expansive and flexible this rule is. A
leading banker recently made this statement:
At a dinner o f a group who know the financial
community well, the question was raised: Can a
commercial bank afford to respond to the escalating
demands for more socially responsible behavior
within our present, profit-oriented market system?
M y answer was that, given the current business
environment, neither banks nor any other business
enterprises can afford not to respond.
No greater inducement needs to be offered for
directing our attention and our resources as business­
men to the root problems of our society than that
they exist, that they are impediments to human ful­
fillment and that they obviously require correction.
I hasten to point out, however, that there is both
self-concern and social concern in that conclusion,
for businessmen must live in, as well as work in, the
community environment— with all its ills.
It is clear, as we enumerate the principal social con­
cerns of our day, that commercial banks operating in
cities and towns across the country, must be, and are,
involved in the manifold efforts to alleviate those con­
cerns. Billion-dollar banks cannot leave the polluted
atmosphere of large urban centers to resettle in our
wilderness. The labor force for our banks is. and
must be, drawn principally from urban areas. Bank
customers and bank employees live in housing of all
qualities found within our urban environment. The
financing of the construction of adequate housing, and
the holding of mortgages for individual homeowners,
must be an important segment of the business of com ­
mercial banks. The maintenance of the competitive
industrial structure by making available funds to new
business entrepreneurs is also in the best interest of
the banking system, individual banks, and the enter­
prise economy.
In a phrase, the long-run profit motive allows com ­
mercial banks to identify the interests of their institu­
tions with the broad interests of the community where
the bank is located. The profit prospects for an urban
bank 10 years hence will not be bright in a situation
where the urban core is deteriorating and in which
social unrest permeates all activities.
In connection with the ability of commercial banks
to identify their interest with that of the community
in which they are located, I would like to point out one
relationship which takes on considerable importance.
Because of the economies of scale present in commer­
cial banking, banks within most major urban centers
have grown large in absolute terms. In a number of

cities, this large absolute size is accompanied by a sig­
nificant share of the total banking business within the
city. T o use a favorite phrase of the Antitrust Divi­
sion, with which we have had occasional “ friendly”
differences, the banking structure in a number of cities
is “ concentrated.” Without offering any general de­
fense of such “ concentration,” it is clear that a closer
identification of the long-run interest of the bank, and
the long-run interest of the community is possible when
the bank holds a significant share of the total banking
business. Let me hasten to add that I am fully aware
that this point, if misused, could lead to a defense of
banking “ monopoly.” It would be both inappropriate
and illogical so to use it. This audience is sufficiently
knowledgeable to recognize the intense competition
which exists among the leading banks in our major
cities. I hope that other thoughtful observers will also
be aware of the competitive milieu.
In conclusion, I would like to emphasize that I am
essentially optimistic that we can have the continuing
benefits of an enterprise economy and yet can make
rapid strides toward alleviating some of the social prob­
lems that have arisen as a byproduct of our growth.
I feel confident that the banking industry will continue
to play a vital and enlightened role as we move toward
the achievement of new goals in our society.
We should find not fear, but excitement, not doubt,

Anyone interested in the current role commercial
banks play in our growth and development, and in the
projection of that role tomorrow, must examine the
place of banks in our economic history. The dichotomy
of monetary and credit functions of banking during the
first decades of our Nation created difficult, and at
times impossible, demands upon our early commercial
banks. Even so, their contribution to our development
was monumental. I shall first look briefly at that early
period.
Then, I shall turn to a special case, and one of par­
ticular significance today, involving the contribution
of one group of banks to urban development and
growth. I refer to the important and newly contro­
versial role of black banks in our urban ghetto areas.
Finally, I shall give attention to the changing cluster
of bank products and services. The emergence o f a
new mix of products and services during the decade of
the 1960’s represented a response by the banking in­
dustry and, to a considerable extent, by the banking
regulatory authorities, to the new and ever more
sophisticated financial needs spawned by our rapid
economic growth. The determination of the productservice mix to be offered by banking during the 1970’s
is a crucial question for banking today.
Banks3 historical role in economic growth; the dichot­
omy of monetary and credit functions

but confidence, not anxious concern, but eagerness to
explore the many new responsibilities and opportuni­
ties which lie ahead. We must continue to look confi­
dently ahead, not backwards, nor sideways. The needs
are clear.
R emarks of D avid G. M otter, D eputy C omptrol­
ler of th e C urrency (E conom ics ), Before the
D istrict of C olumbia Bankers A ssociation
A udit, C ontrol, and O perations Section ,
W ashington , D.C., Feb . 11, 1971

“ Banking and Economic Growth: Old and New
Horizons”
Introduction
I would like to confine my remarks to three areas,

Many scholars have devoted a very considerable
amount of research to an exploration of the role of
commercial banks in the economic growth and devel­
opment of the United States. As a result, when the
non-specialist turns his attention to that topic, he is
fortunate to find a variety of sources waiting for him.
However, a perusal of those sources demonstrates that
economic historians have paid primary attention to the
monetary functions of the banking system. The explo­
ration of the credit function of commercial banks and,
more specifically, the contribution of bank credit ex­
tension to the development of particular industries and
firms, has been slighted. In so stating, it is unfair to
ignore the important work of Professor Trescott in
attempting to reverse this imbalance.

itself to a short discussion; for that reason I have

The inconsistancy, and often, the incompatibility of
monetary and credit goals for the commercial bank­
ing system, often placed individual commercial banks
in an impossible position. Throughout virtually all of
the 19th century, there was a continuing need for ex­
panded bank credit in the United States. Small firms
engaged in a variety of economic activities were at­

chosen to spotlight several subtopics that have, I trust,

tempting to make use of our country’s great wealth of

considerable interest and relevance today.

natural resources by steadily expanding their opera­

each relating to a quite specific aspect of the relation­
ship between commercial

banking and

economic

growth. It should be evident that this multifaceted
topic can be approached in a variety of ways. The
general relationship is so complex that it does not lend




233

tions. New firms and whole new industries sprang up
almost overnight. The demands for short-term credit
and, of course, for long-term capital, were tremendous.
The valiant attempt of a number of banks to supply
the necessary funds to new business enterprises pro­
vided enormous, invaluable assistance to our economy’s
rapid development. In doing so, however, individual
banks often became overextended. Their assets, largely
in the form of relatively illiquid business loans, did not
match the maturities of their volatile short-term liabili­
ties. In the early part of the 19th century, those liabili­
ties were largely in the form of individualized bank
notes, although, by the time of the Civil War, total
deposit liabilities exceeded total note liabilities in the
system.
In a word, relative stability in the economy required
a relatively stable monetary system. At the same time,
the burgeoning credit demands of our new industries
placed such a strain upon our commercial banking sys­
tem that monetary stability remained an unattained
goal. In the period between 1800 and 1860, a number
of severe monetary panics created widespread economic
distress.
This audience, in the context of the plentiful
criticisms of banking put forward in recent years, can
well appreciate the impossible position faced by our
early commercial banks. The public tended to blame
bankers for the financial panics. The public somehow
expected bankers to provide monetary stability, yet that
could be achieved only by a centralized monetary au­
thority. The responsiveness of commercial banks to the
credit needs of the economy itself generated the seeds of
monetary fluctuations. A number of individual bankers
were able to hold their own extensions of credit to
prudent levels. However, it lay far beyond the power
of individual bankers to achieve, simultaneously,
monetary stability and expanding credit over any con­
siderable period of time.
The advent of the National Banking System brought
considerable stability to the financial sector, but the
relative inflexibility of the system’s mechanism created
problems. With the formation of the Federal Reserve
System, adequate centralized monetary control was
finally achieved.
However, commercial banks are still the unwitting
recipients of public ill-will during periods of monetary
tightness. The central monetary authority carries out
its policies principally through the commercial banking
system in the first instance. As a result, banks often
bear the brunt of unjustified public criticism for both
high interest rates and lack of loanable funds. The
banking industry will presumably never escape this,

234



although a more extensive program in economic educa­
tion might alleviate it.
A special case: the role of black banks in urban de­
velopment and growth
I am sure that you are aware of a recent spirited dis­
cussion in connection with the proper role of blackowned commercial banks. Recently we have had three
formal presentations on that subject, plus a variety of
comments generated by those presentations. I would
like to give some attention to the question of the place
of such banks in our economy, as a special case of the
relationship between commercial banks and economic
development.
There are now more than 20 commercial banks that
are classified by their own trade association as blackowned or minority-owned banks. The majority of those
banks have been chartered since 1960. The bulk of the
total assets and total deposits of such banks are held
by those chartered since 1963. All of them are located
in inner city, ghetto-type areas.
It is clear at the outset, then, that we are talking
about a set of comparatively new banks, each facing a
particular type of urban economic environment. The
comparative newness of the banks, in and of itself,
distinguishes them from the mass of commercial banks
in our country. In any recent year, the number of
newly chartered commercial banks has been well below
1 percent of the total population of banks existing at
the beginning of that year.
When we look at the group of minority-owned banks,
we are also looking at comparatively small banks. That
is only a slight extension of the truism that newly
chartered banks, by definition, are “ small” banks. No
new bank has been chartered at a capitalization ex­
ceeding $5 million in recent years, and the capitaliza­
tion of most new banks is well below that figure. In
other words, “ large” new banks do not spring into
existence.
The inner city location of the minority-owned banks
provides a particular set of economic characteristics for
their environment. These institutions, to meet their ex­
pressed purpose of fostering minority economic devel­
opment, are located in the very areas which have seen
an unfortunately large exodus of other economic enter­
prises in recent decades. It should be evident that the
financial resources of the immediate communities
within which such banks have been located are ex­
tremely limited. That fact will inevitably shape the
banks’ deposit activity, and will also determine, in
large part, the characteristics of their loan demand.
Quite naturally, the attempt has been made to staff

would, I believe, indicate that the black banks were
pursuing a much too cautious course in their efforts to
provide financial backing to ghetto entrepreneurs.
Reference has also been made by black bank critics
to the regulatory agencies’ ratings of the management
of such banks. It has been pointed out that, on the
average, the management of black banks secures a
lower rating than is true for other banks of about the
same size. Again, that is largely a function of the short
supply of qualified minority bank officers. Even more
important, however, is the fact that the management
ratings for black banks are considerably more favorable
today than they were 2 years ago. Thus, the movement,
the evolution, is definitely in the right direction.
The whole controversy concerning the economic
justification of black banks is rather surprising, in one
sense. Should one logically expect that, at this point
in time, the cold statistics would provide a comparison
favorable for those banks relative to all other banks
of the same size in our country? The combination of
newsness, smallness, location, and specific purpose,
when combined, could hardly now yield a favorable
statistical conclusion. Having said that, however, I
should hasten to add that in many respects the per­
formance of black banks has already been surprisingly
good. A majority of those black banks which have been
in existence for a significant period of time are returning
profits to their owners. None of the newer black-owned
banks have failed, which in itself is a significant statis­
tic. Rates of return on assets and on capital have been
improving, although they are not likely, in the near
future, to match those of other banks of the same size.
The most positive factors in the operations of those
banks, unfortunately, do not lend themselves to statis­
tical treatment. Conversations with the officers of

minority-owned banks mainly with blacks and mem­
bers of other minority groups. That goal has been
largely achieved for the teller and clerical positions
within the banks. However, there have been some
staffing problems at the executive level because the
supply of financially trained members of minority
groups is extremely limited.
Any bank, regardless of its ownership, presents a
different picture during its first several years of opera­
tion than does a mature bank. Typically, deposit funds
come in at a faster rate than can be absorbed pru­
dently by the loan demand within the bank’s area of
operations. Also, certain internal operations have to
go through a shakedown period; initial unit expenses,
therefore, are often high relative to those of older
banks. For those reasons, it appears mandatory in any
analysis of black-owned banks to remove those that
were recently chartered from the sample group. The
convention adopted by one of the recent analyses, the
exclusion of banks less than 5 years old, 'appears to be
quite defensible.
Black banks have been criticized for exporting large
amounts of their funds to borrowers outside their own
communities. That is a typical pattern for new banks,
which must, during the period when loan demand
within their own area of operation is small relative
to funds available, rely heavily on participations in
loans extended by correspondent banks. The addi­
tional criticism that black banks tend to have rela­
tively low loan-to-deposit ratios, is due to the same
phenomenon of “ newness.1 Relatively heavy invest­
”
ments in securities are characteristics of new banks, in
the absence of sufficient loan demand.
It has also been pointed out that black banks’ ratios
of service charges to total demand deposits are relatively
high. It is well known that the areas served by black
banks generate many low-balance, high-activity ac­
counts. Inevitably, the servicing of those accounts
leads to service charges that are high relative to the
deposit base.
Next, we come to a criticism that is immediately and
directly related to the question of the proper role of
the black banks in the development of new ghetto busi­
nesses. It has been pointed out that the ratio of total
classified loans to total capital of the black banks is
approximately double the same ratio for other banks
of the same size. That statistic should hardly be surpris­
ing, given the nature of the purposes of the black banks,
and the nature of the markets being served. In fact, in
my view, a more severe criticisim of the black banks
would be forthcoming if, in fact, these banks had classi­

The significance of that pool of executive talent will

fied ratios similar to those of all other banks. That

carry far beyond black-owned institutions.

black banks, and with minority entrepreneurs who
have secured loans from them, reveal the primary
justification for their existence. It is clear that a num­
ber of ghetto-based enterprises have secured loans from
them when the possibility of finding alternative loan
sources was small. Further, the existence of blackowned banks in inner city areas has been a factor in
the decision of many large commercial banks to re­
study and revamp their entire procedures relating to
loans to minority enterprises. Over time, the most
important results of black bank operations may well
be the impact on other banks’ operations, the “ demon­
stration effect” for other ghetto enterprises, and the
training of a number of topflight black bank executives.

235
463—49*9 0 — 72

16




The changing cluster of banking products and serv­
ices: Banks' response to the financial needs
spawned by growth.
I would now like to turn to a subtopic which I feel
is vitally related to banking’s contribution to economic
growth and development, although, by its nature, the
relationship is sometimes overlooked. The products
and services offered by the banking industry today are
vastly different from those offered by banking 100
years ago. W e need not go back that far in time,
however, to note very substantial changes in the cluster
of banking products and services. The decade of the
1960’ s saw the emergence of a sizable number of new
banking services, and the pronounced expansion of a
number of other services which previously had been
unimportant. Within our Office, we are proud that a
number of regulatory changes during the 1960’s, largely
in the direction of granting more discretion to bank
management, played no small part in the development
of a new product-service mix.
It should be clear that an ever-evolving set of prod­
ucts and services is vital if banking is to meet the needs
of a dynamically growing economy. Those needs tend
to become more and more specialized and sophisti­
cated, as the interrelationships within our economy
become more complex.
Both litigation instituted by competitors of banks
and legislative thrusts inspired by these competitors
have placed certain newer banking activities in the
limelight.
In one sense, it is quite misleading to include data
processing operations under “ newer services;” banks,
and most bank employees have been engaged in data
processing, in one form or another, since the inception
of banking. The head of one of the major New York
City banks stated a number of years ago that he was
essentially the chief executive of a data processing firm.
The magnitude of financial records required in a bank­
ing operation dictates that that be the case. However,
the technological revolution in data processing— the
emergence of very large, highspeed computers— has
drastically altered data processing activity. Banking,
quite naturally, was one of the first industries to make

It is for that reason that data processing suits brought
by nonbank data processing firms and associations
have become crucially important for the banking in­
dustry. However, the most important development in
that area in recent months relates not to litigation, but
to the December 1970 legislation passed by Congress to
bring one-bank holding companies under Federal
regulation.
Fortunately, for both the public and the banking
industry, Congress finally rejected the concept of a
“ laundry list” of activities specifically prohibited to
one-bank holding companies and their subsidiaries.
However, the Federal Reserve Board’s draft regula­
tion to implement the 1970 legislation should be scru­
tinized exceedingly carefully by the banking industry,
just as it will be examined and commented upon by
nonbank competitors.
A ruling by the Comptroller of the Currency in the
early 1960’s fostered and encouraged the entry of Na­
tional banks into direct-lease financing activity. That
is one o f the few newer activities of commercial banks
that has not been subject to litigation by nonbank
competitors. One result has been that the total out­
standing volume of direct-lease financing by National
banks has moved steadily upward during the past few
years, and now stands well above $600 million. The
“ laundry list” that was incorporated in the bill passed
by the House o f Representatives included a leasing
criterion that would have substantially reduced bank
activity in that area. As we have seen, that “ laundry
list” was eliminated from the final legislation.
Insurance activity by National banks increased dur­
ing the 1960’s, again in part due to liberalizing actions
by the Comptroller o f the Currency. Litigation brought
by the association of insurance agents consumed a large
amount of time and resources for all parties. The gen­
eral rule which has emerged restricts the insurance
activity of commercial banks to those transactions re­
lated to direct extension o f credit. The association of
insurance agents was one of the most active lobbyists

was a natural and inevitable development. It reflected

during the prolonged congressional debates on the onebank holding company issue. The Federal Reserve
draft regulation in that area would allow a holding
company to control a subsidiary which acts “ as insur­
ance agent or broker principally in connection with
extensions of credit by the holding company or any of
its subsidiaries.” Given the history of bank activity in
that area, and the related litigation, the draft Federal
Reserve regulation appears to be consistent with politi­
cal reality. Under the circumstances, a regulation rely­
ing upon broader criteria may not have been available

economies of scale relating both to machines and men.

to the Federal Reserve.

great use of the new computers. Indeed, it seems clear
that if the computer revolution had not occurred, the
banking industry today would be virtually smothered
in a sea of paper.
The performance of data processing operations for
customers of banks, as well as for the banks themselves,

236



One of the more interesting aspects of the draft Fed­
eral Reserve regulation is the omission of two activites:
the provision of travel services by holding company
subsidiaries, and the offering of commingled funds as
a part of trust operations. The omission of any ref­
erence to commingled funds is not surprising; Con­
gress, itself, this past session failed to pass draft legisla­
tion which would have empowered commercial banks
to operate such funds. The effect of the congressional
inaction is to give great importance to the U.S.
Supreme Court’s forthcoming decision in that matter.
One hopes, however, that when other activities are
later added by the Federal Reserve, as promised, that
the provision of travel services will be included. There
are a number of commercial banks that have operated
travel services for many decades. One view even holds
that in some old banking houses, the travel services
preceded the banking services.
Tw o additional comments concerning the Federal
Reserve regulation and the forthcoming hearings ap­
pear appropriate. First, it should be clear that the legis­
lation itself, and the regulation to implement the
legislation, vitally affect the entire banking industry
and every individual bank, whether or not individual
banks are subsidiaries of holding companies. While it
is likely that over time the corporate umbrella of the
bank holding company will be allowed to shelter some
activities which could not be carried out by banks
themselves, it is obvious that the converse is not true. In
other words, it is doubtful that a situation will ever
arise, or at least persist, in which a particular bank is
allowed to carry on a certain activity directly, when
that same activity is forbidden to the holding company
complex.
Thus, in a very real sense, the final regulations of the
Federal Reserve under the Holding Company Act
amendments, will define the outer limits of banking
and related financial enterprises. In my view, it is
crucial not only to the banking industry but, more im­
portantly, to the public, that the limits of bank-related
activities be sufficiently flexible to allow continued re­
sponsiveness of the banking system to emerging fi­
nancial needs.
When Congress finally agreed to delete the restrictive
“ laundry list” there was a feeling of relief, if not elation,
on the part of many knowledgeable students of bank­
ing. Even were a regulation to imitate, in large part,
the omitted statutory list, the greater flexibility of the
former would make it clearly preferable.
The next few months are bound to be a busy and
hectic period for our sister agency. We can only wish
the Federal Reserve well as it embarks upon a new




regulatory chapter. From the standpoint of the public,
we must hope that the implementation of the recent
legislation will allow the banking industry to continue
to meet the financial demands associated with dynamic
growth and development of our economy.
R emarks of D ean E. M iller, D eputy C omptroller
for

T rusts , at the Southeastern T rust

School , C ampbell C ollege, B uies
C reek , N.C., June 22, 1971

The supervision of the trust department, like that
of the remainder of the bank, has been built around
the examination process. Once each year, the examiners
of this Office go, on a surprise basis, into each National
bank trust department. At that time, the examiner
seeks to detect any departures from law,'from Regula­
tion 9, and from sound fiduciary principles. Those
matters are discussed with management at the close
of the examination. Correction may be made while
the examiner is present; if not, a criticism is made in the
report of examination. That criticism is followed by this
Office until the matter is resolved.
The entire process is confidential for two principal
reasons. First, we are dealing with very personal re­
lationships between the bank and its customer. This is
particularly apparent in the trust department, where
we may find a family’s entire fortune. Confidentiality
in such circumstances is desirable; as long as the proper
protections can be supplied, confidentiality should be
retained for that reason alone. But there is another rea­
son as well, the protection of the bank.
Throughout our Nation’s history, the public image of
banks has been a very critical matter. More than once
a bank has been closed after a loss of public confidence
caused a run that put the bank into a hopeless con­
dition. That lethal loss of public confidence can result
from disclosure of the bank’s departure, or alleged de­
parture, from Federal laws or regulations. And it is
by no means an historical phenomenon. We have seen
it happen relatively recently. Since the primary public
aim is to protect assets, rather than to exact retribution,
the confidential means of corrective action is most ap­
propriate. Anything that would unnecessarily weaken
the bank’s condition is contrary to the public interest.
If matters subject to criticism can be corrected and
abuses stopped or forestalled, and if the bank’s con­
dition can be protected, or even strengthened, in the
process, the maximum benefit is received. That is the
way the system works.
But I must acknowledge that banking and bank
supervision pays a price for that method of operation.

237

The confidential nature of bank supervisory activity
leads many who are not privy to such actions to con­
clude that none exist. That is apparently an easy con­
clusion for one to form if he is in disagreement with
some basic aspect of the bank supervisory officials’
policy. Experience also shows that it is one readily
reached by those who compete with some aspect of a
bank’s operations, but are subject to a different system
of regulation. Public statements to the effect that there
is no bank supervision have had a demoralizing effect
on some of our trust department examiners; more than
one has indicated that to me. The trust examiners from
the Comptroller’s Office are good, hard-working, career
Government employees. Their job is not an easy one.
They spend long hours on the road, and nights and
weekends away from their families. They are dedicated.
They think they are doing a good job. I know they are
trying, conscientiously, to do so. I can understand their
frustration at the blanket characterizations of them
as incompetent and ineffective. A more unfair accusa­
tion is difficult to conceive.
I think all of these things are evident in the current
proposals for the imposition of a requirement that
trust department security holdings be filed with some
Federal agency, proposals which this Office has op­
posed. They reflect, we believe, a failure to appreciate
the work of the bank examiner. The Government,
through its bank examiners, scrutinizes the holdings of
bank trust departments during their annual examina­
tions. As noted above, they correct matters of criticism
in a manner calculated not to jeopardize the confi­
dentiality of the customer’s property or the soundness
of the bank. In contrast, I believe that a system of
supervision based principally upon disclosure would
only result in more haphazard governmental oversight,
and the loss of the protections of confidentiality.
Please do not misunderstand me, I do not have the
arrogance necessary to stand here and assert that that
aspect of the public interest which the banking agen­
cies oversee is supreme, and that all other interests
must yield to it— that all other, and therefore lesser,
governmental interests must accommodate themselves
to our means of accomplishing our supervisory respon­
sibilities. That is not what I am saying, and, obviously,
is nonsense. M y point is merely that before additional
burdens are imposed upon an industry in the name
of the public interest, there should be firm and con­
vincing proof of the need. I do not believe that such a
case has been made. The allegedly missing govern­
mental interest in this situation is not that an uncor­
rected abuse is occurring, rather, it is that not enough
is known about banking, on a continuing basis, by peo­

238



ple other than bank supervisors, who may feel, there­
fore, that banks may have an unjustified advantage
over their nonbank competitors because banks are
supervised differently. Some people may call that an
unfair characterization, but it is my analysis of the basic
reasons being advanced. What is proposed is a system
of regular reporting of holdings and either voting or
transactional data, to the FD IC or the SEC. For
smaller banks, that could be a prohibitive burden—
there is no way around it. The cost experience of the
banks that furnished similar information requested for
the Institutional Investor Study shows that burden. I
know of no bank where it cost less than $50,000. At
many, the cost was much higher.
W e are all aware of the relative unprofitability of
bank trust departments. The cost increases of recent
years have not been matched by revenues. An added
burden such as this proposal is simply going to tend
to drive many smaller banks out of the business. Per­
sons in the areas served by such banks will find their
choice of available corporate fiduciaries more limited
and may have to go to bigger cities or to individuals
for fiduciary services. Either result is undesirable.
The desire to have, continually on hand, broadscale information on what is occurring in banks, or
to impose an “ equality” upon all institutional investors,
regardless of the different needs and approaches of
their basic regulatory structures, is not sufficient justifi­
cation for the proposal. It is my contention that the
fact that the present bank supervisory authorities may
not be presently supplying every feature o f every gov­
ernmental concern, does not reflect a permanent in­
ability on their parts to do so. And it does not,
therefore, justify the conclusion that what is needed
is in effect an additional system of bank supervision.
In the absence of a demonstrated inability of the
existing mechanism to provide essential protections, a
new mechanism should not be so blithely considered
acceptable. There appears to be a prevailing belief
that one can never be negative— that to be effective,
only positive suggestions can be submitted. Applied
to the present situation, that attitude has been por­
trayed as imposing the need for coming forward with
counterproposals indicating how much of a reporting
burden would be acceptable. Speaking personally, I
think that approach is totally wrong. W e are talking
casually about the erection of another governmental
imposition upon private industry! Such matters should
never be approached in this light. Although we have
seen much lip service given to the idea that he governs
best who governs (and imposes regulations) least, it
remains the unhappy truth that the standard answer

to every problem— both real and potential— seems to
be more government. Not only is the answer usually
more government, but it is more diverse government—
a new agency, a different breed of specialists, another
bureaucracy designed to deal with one fragment of
the concern. We see it happening here, in the trust
business, which is perhaps the most susceptible to such
inroads. It is the least profitable area of banking, and
as a result, it is the area where banks and their trade
associations have been most willing to accept com ­
promises and have been least willing to take strong,
continuing stands. But, somewhere in the process a
desirable service to the public is being cut away, and
the bureaucratic snarl is being enlarged. That is what
concerns me.
Another of the questions facing the bank trustee
these days relates to social responsibility. A frequently
made criticism is that the fiduciary’s responsibility is
not properly served by the policy of many bank trust
departments of voting with management when they
agree, and of selling out when they don’t. The trustee
has a responsibility to utilize his power, so it is claimed,
to attempt to make a better world, largely through the
application of that power to influence the management
o f portfolio companies to carry out socially desirable
practices. Banks have differed in their acceptance of
that idea. Some, such as the First Pennsylvania in
Philadelphia, apparently have accepted it. Others
have stated that concern with factors other than the
financial strength of a company, and similar considera­
tions directly relating to the value of its securities, is an
inappropriate intrusion by the fiduciary shareholder
into an area of discretion rightfully belonging to others.
Such an intrusion, they believe, brings with it a poten­
tial liability for involvement in areas outside the bank’s
expertise, and, possible responsibility for managerial
errors in which it acquiesced or even participated.
Some banks have simply said that our Office’s Regula­
tion 9 would not permit such a course of action.
Because Regulation 9 is a subject with which I have
a modest familiarity, let me devote some time to that
last assertion. I think it is false. The Regulation does no
more that track the law of trusts in this regard. There­
fore, if the law of a particular State permits, or re­
quires, fiduciaries to act in accordance with their social
responsibilities in handling the pr