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Annual Report 1974
Comptroller of the Currency

The Administrator of National Banks

James E. Smith
Comptroller of the Currency

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

OCTOBER 1,

1975

SlRS: Pursuant to the provisions of Section 333 of the United States
Revised Statutes, I am pleased to submit the 1974 Annual Report of the
Comptroller of the Currency.
Respectfully,
JAMES E. SMITH,

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

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

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

Page
1
3
5
13
15
19
21
23
27
29

Appendices
A.
B.
C.
D.

Merger Decisions, 1974
Statistical Tables
Addresses and Selected Congressional Testimony
Selected Rulings and Correspondence of the Comptroller of the Currency

Index

35
175
251
299
327

Statistical Tables
Table No.
1
2
3
4
5

Title

Assets, liabilities, and capital accounts of National
banks, 1973 and 1974
Income and expenses of National banks, 1973 and
1974
National banks and banking offices, by States, Dec.
31, 1974
Applications for National bank charters, and charters
issued, by States, calendar 1974
Applications for National bank charters issued pursuant to corporate reorganizations, and charters
issued, by States, calendar 1974
Applications for conversion to National bank charters,
and charters issued, by States, calendar 1974

Page

Table No.
7

2
8
4
9
6
7

10
11

Title

Branches of National banks, by States, calendar
1974
De novo branch applications of National banks, by
States, calendar 1974
De novo branches of National banks opened for business, by community size and by size of bank,
calendar 1974
Mergers, calendar 1974
Office of the Comptroller of the Currency: balance
sheets
Office of the Comptroller of the Currency: statements
of revenue, expenses, and Comptroller's equity...
Office of the Comptroller of the Currency: statements
of changes in financial position

Page

1(
1]

IS
IS
3(
31
31

I. Condition of the National Banking System
Recessionary and inflationary factors in the economy during 1974 exerted an important influence on
the operations of National banks. In contrast to a
17.8 percent rise in total loans in 1973, the increase
registered during 1974 was 9.7 percent. Total securities held, which had grown only 0.9 percent during
1973's strong loan demand, edged upward 2.2 percent in 1974. The major source of new funds for the
system during 1974 was a 15.7 percent increase in
time and savings deposits, an increase nearly as
great as the 16.0 percent figure for 1973. Demand
deposits continued to show relatively small increases; 1973's growth rate of 3.8 percent eased to a
minuscule 0.8 percent in 1974. In consequence, by
the end of 1974, total time and savings deposits
accounted for 58.2 percent of total deposits, a proportion that has climbed from 52.0 percent at the
end of 1972 and 54.8 percent at the end of 1973.
Within the securities category, the 1974 decline of
6.1 percent in Treasuries held was more than offset
by increases of 11.4 percent in securities of Government agencies and corporations and of 3.7 percent
in municipals. Federal funds purchased and securities sold under agreement to repurchase grew only
a nominal 1.0 percent as a source of funds. Among

the relatively smaller accounts, acceptances outstanding increased sharply, from $2.9 billion at the
end of 1973 to $7.1 billion at year-end 1974.
For the second consecutive year, the rate of
growth in total assets was less than that of the prior
year. At year-end 1974, total assets of National
banks reached $534.4 billion, a figure 9.2 percent
above the December 1973 amount. The two previous
years' rates were 15.5 percent in 1972 and 12.6 percent in 1973.
In the composition of National bank assets, the
proportion accounted for by loans increased very
slightly in 1974, from 55.5 percent to 55.7 percent,
while the proportion represented by securities
dropped slightly, from 21.4 percent to 20.0 percent.
Total reserves on loans rose by 10.5 percent, from
$4.6 billion to $5.1 billion, a slightly higher rate of
increase than the 9.7 percent shown by total loans.
Total capital of National banks reached $35.8 billion
at year-end 1974, reflecting an 8.1 percent increase
over the prior year figure of $33.1 billion. As in 1973,
the capital markets were relatively unreceptive to
bank debenture issues during 1974, and the total
outstanding only inched upward, from $2.2 billion to
$2.3 billion.

TABLE 1

Assets, liabilities, and capital accounts of National banks, 1973 and 1974
[Dollar amounts in millions]

Amount

Change, 1973-1974

Dec. 31, 1974
4,708 banks

Dec. 31, 1973
4,661 banks
Percent
distribution

Amount

Percent
distribution

Amount

Percent

ASSETS

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

$70,724

14.45

$76,557

14.33

$5,833

30,966

6.32

29,081

5.44

-1,885

15,072
55,236
3,411

3.08
11.28
.70

16,788
57,2%
3,835

3.14
10.72
.72

1,716
2,060
424

104,685

21.38

107,000

20.02

2,315

22,091
1,573
271,572
8,144
2,847
7,965

4.51
.32
55.47
1.66
.58
1.63

23,751
2,426
297,852
9,052
7,037
10,747

4.44
.45
55.73
1.69
1.32
2.02

1,660
853
26,280
908
4,190
2,782

489,600

100.00

534,422

100.00

44,822

136,056

27.79

137,829

25.79

1,773

181,215
6,193
37,072

37.01
1.26
7.57

207,794
2,711
40,206

38.88
.51
7.52

26,579
-3,482
3,134

6,030
23,379
5,935

1.23
4.78
1.21

7,472
29,552
5,662

1.40
5.53
1.06

1,442
6,173
-273

395,881

80.86

431,225

80.69

35,344

179,046
216,835

36.57
44.29

180,391
250,834

33.75
46.94

1,345
33,999

35,975
3,722

7.35
.76

36,323
3,286

6.80
.61

348
-436

2,921
13,251

.60
2.71

7,142
15,424

1.34
2.89

4,221
2,173

451,749

92.27

493,400

92.32

41,651

LIABILITIES

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

-1

RESERVES ON LOANS AND SECURITIES

Reserves on loans
Reserves on securities

4,634
79

.95
.02

5,119
70

.96
.01

485
-9

2,200
37
7,904
13,513
8,998
484

.45
.01
1.61
2.76
1.84
.10

2,258
13
8,336
14,067
10,652
503

.42
1.56
2.63
1.99
.09

58
-24
432
554
1,654
19

33,135

6.77

35,830

6.70

2,695

489,600

100.00

534,422

100.00

44,822

CAPITAL ACCOUNTS

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

NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than .01 percent.
The 1973 and 1974 data reflect consolidation of all majority-owned bank premises subsidiaries, and all significant domestic major
owned subsidiaries, with the exception of Edge Act subsidiaries.

II. Income and Expenses of National Banks
The combination of real growth in the National
Banking System and strong inflationary pressures
led to steep increases in both total operating income
and total operating expense in 1974; 29.6 percent for
the former and 34.3 percent for the latter. Those
high rates of increase were, however, slightly less
than the comparable rates in 1973 of 32.6 percent
and 35.9 percent, respectively. The figures for both
1973 and 1974 are in sharp contrast to those of 1972,
when operating income rose by 10.5 percent and
operating expense by 10.8 percent.
Applicable income taxes decreased slightly in
1974 compared to 1973, from $1.2 billion to $1.1
billion. With net security losses totalling $42.4
million in 1974, net income reached $4.0 billion for
all National banks, a 7.4 percent increase over
1973. That rate of increase in net income compares
with 13.9 percent in 1973 and 8.8 percent in 1972.
Since the rate of growth of net income was slightly
less than the 9.2 percent rate of growth in total
assets, the rate of return on assets fell slightly in
1974 compared to 1973.
Interest and fees on loans totalled $28.4 billion in
1974, a 35.0 percent increase over 1973. Loanrelated income accounted for 70.3 percent of total
operating income, an increase from the 67.5 percent
figure for 1973. Total revenues from securities holdings were $5.6 billion in 1974, an increase over 1973
of 11.6 percent. The proportion of operating income
accounted for by income from securities continued
to slip, from 16.0 percent in 1973 to 13.8 percent in
1974.
As dollar volume of Treasuries held declined for
the third straight year, revenues from Federal funds
sales and purchases of securities under agreement

to resell surpassed revenues from Treasury holdings
in 1974, $2.2 billion to $1.8 billion. Revenues from
municipals held totalled $2.5 billion, a 13.5 percent
increase over 1973, and holdings of securities of
agencies and government corporations accounted
for $1.0 billion in revenues, an increase of 40.3 percent over 1973.
On the expense side, the total cost of funds continued to burgeon, reflecting the growth in the proportion of time deposits to total deposits and evergreater reliance on purchased non-deposit funds.
Total interest on deposits reached $16.6 billion, an
increase of 42.2 percent over 1973. The proportion
of total operating expense accounted for by interest
on deposits continued to increase, from 44.5 percent
in 1973 to 47.1 percent in 1974. Similarly, the expense of Federal funds purchased and securities
sold under agreements to repurchase spurted from
$2.7 billion to $4.3 billion, a 59.5 percent increase.
As a result, the proportion of operating expense
accounted for by the cost of those purchased funds
moved from 10.2 percent in 1973 to 12.1 percent in
1974.
Salaries and wages of officers and employees
increased by 13.6 percent, but the proportion of
operating expense represented by salaries and
wages continued its decline. The figure has dropped
from 23.8 percent in 1971 to 23.1 percent in 1972, to
18.8 percent in 1973, to 15.9 percent in 1974. Occupancy expense has shown a similar decline in relative importance, as the cost of funds has continued
to jump upward.
Total cash dividends of $1.7 billion were declared
by National banks in 1974, a 15.3 percent increase
over 1973's $1.4 billion. The 1974 dividends reflected
a payout ratio of 41.3 percent.

TABLE 2

Income and expenses of National banks*, 1973 and 1974
[Dollair amounts in millions]
1973
Amount
Number of banks

4,661

Operating income:
Interest and fees on loans
$21,054.5
Income on Federal funds sold and securities purchased
under agreements to resell
1,454.7
Interest and dividends on investments:
U.S. Treasury securities
1,821.8
Obligations of other U.S. Government agencies
and corporations
725.7
Obligations of States and political subdivisions...
2,230.8
Other securities
203.7
Trust department income
820.4
Service charges on deposit accounts
752.7
Other service charges, collection and exchange charges,
commissions, and fees
815.7
Other operating income
1,334.3
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

Change, 1973-1974

1974

Percent
distribution

Amount

Percent

1.01

70.26

$7,364.1

34.98

Percent
distribution

4,708
67.45 $28,418.6
4.66

2,173.1

5.37

718.4

49.38

5.84

1,752.7

4.33

-69.1

-3.79

2.32
7.15
.65
2.63
2.41

1,018.4
2,531.3
258.9
853.7
827.2

2.52
6.26
.64
2.11
2.05

292.7
300.5
55.2
33.3
74.5

40.33
13.47
27.10
4.06
9.90

2.61
4.27

938.5
1,676.0

2.32
4.14

122.8
341.7

15.05
25.61

31,214.2

100.00

40,448.3

100.00

9,234.1

29.58

4,922.0
905.3
11,666.0

18.75
3.45
44.45

5,593.0
1,034.0
16,585.0

15.87
2.94
47.06

671.0
128.7
4,919.0

13.63
14.22
42.17

2,681.2
304.0
130.4
999.2

10.22
1.16
.50
3.81

4,277.2
519.3
147.8
1,146.6

12.14
1.47
.42
3.25

1,596.0
215.3
17.4
147.4

59.53
70.82
13.34
14.75

718.7
758.1
3,161.9

2.74
2.89
12.05

811.9
1,391.8
3,734.9

2.30
3.95
10.60

93.2
633.7
573.0

12.97
83.5S
18.12

26,246.9

100.00

35,241.4

100.00

8,994.5

34.21

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

4,967.3
1,194.9
3,772.5
-13.5
3,758.9
9.0

5,206.9
1,122.6
4,084.3
-42.4
4,041.9
2.8

239.6
-72.3
311.8
-28.9
283.0
-6.2

4.85
-6.0!
8.2'
-214.0'
7.5,'
-68.8!

Net income

3,767.7

4,044.5

276.8

7.3!

Cash dividends declared:
On common stock
On preferred stock

1,447.0
2.4

1 670 2
1.0

223 2
-1.4

15.4
-58.3

1,449.4

1,671.2-

221.8

15.3

Total cash dividends declared
Ratio to income before income taxes and securities:
Applicable income taxes
Net securities gains
Extraordinary charges or credits

24.06
-.27
.18

21.56
-.81
.05

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

15.77
37.37
10.13

13.83
41.00
9.23

84.09

87.13

12.07

10.00

Total operating expenses
Met income

* Includes all banks operating as National banks at year-end, and full year data for those State banks converting to National ban
during the year.
NOTE: Dashes indicate amounts of less than $500,000. Data may not add to totals because of rounding.

III. Structural Changes in the National
Banking System
The total number of National banks increased
from 4,661 to 4,708 during 1974. Of those, 2,756
were unit banks and the remaining 1,952 operated
15,565 branches at year-end: a grand total of 20,273
National banking offices. The numbers of branches
increased during the year by 5.5 percent and the
total number of offices by 4.4 percent. Three unit
banking states, Texas, Illinois, and Florida, led in
total number of National banks with 569, 420, and
282, respectively. The largest number of branches
per state are located in California, with 2,662, New
York, with 1,544, and Pennsylvania, with 1,320.
National banks opened 939 de novo branches in
1974. Mergers and conversions led to the entry into
the National Banking System of 246 additional preexisting branches, while 378 branches left the
system through closings, mergers, and conversions.
Of the 939 de novo branches, 742 or 79 percent,
were located in communities with populations of
less than 100,000. Only 33, or less than 4 percent,
were located in cities with 1 million or more people.
Banks with total assets under $100 million established 470 of the de novo branches, or slightly over
50 percent of the total. Billion-dollar banks opened

204 de novo branches, about 22 percent of the total.
New York led all states in de novo branches with 130,
followed by Pennsylvania with 83 and California
with 75.
Charters were issued for 92 newly organized National banks during 1974, compared with 94 in 1973.
Texas, with 23, and Florida, with 19, were far ahead
of other states in the number of new National banks,
with third-place Missouri accounting for six. Sixty
additional charters were issued pursuant to corporate reorganizations and 12 for banks converting
from State systems to the National system.
Preliminary approval was granted to 92 de novo
charter applications, compared to 134 in 1973. Florida and Texas led all other states, with 21 and 17
respectively, while Illinois ranked third with seven
preliminary approvals.
During 1974, 66 merger, consolidation or purchase
transactions involving two or more operating banks,
and in which the resulting bank was a National bank,
were completed. In 1973, there were 53 such transactions. In addition, 62 transactions were completed
that involved only one operating bank, to effectuate
corporate reorganizations.

TABLE 3

National banks and banking offices, by States, Dec,31, 1974
National banks
Total

With
branches

Unit

Number
of
branches

Number
of
offices

United States

4,708

2,756

1,952

15,565

20,273

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

93
5
3
74
55
127
24
5
13
282

36
0
1
20
9
106
3
3
2
257

57
5
2
54
46
21
21
2
11
25

267
65
265
144
2,662
21
251
4
86
25

360
70
268
218
2,717
148
275
9
99
307

Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine

64
2
6
420
121
99
171
80
52
20

17
1
1
326
38
52
129
29
13
4

47
1
5
94
83
47
42
51
39
16

311
10
154
93
441
76
52
192
227
124

375
12
160
513
562
175
223
272
279
144

Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire

40
78
117
202
39
110
55
121
4
47

8
13
25
189
6
68
52
87
1
16

32
65
92
13
33
42
3
34
3
31

336
492
696
17
212
51
3
45
74
78

376
570
813
219
253
161
58
166
78
125

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

122
34
154
26
43
217
193
8
250
5

20
5
38
4
28
53
142
1
94
0

102
29
116
22
15
164
51
7
156
5

917
101
1,544
761
16
904
51
289
1,320
113

1,039
135
1,698
787
59
1,121
244
297
1,570
118

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

18
31
75
569
11
17
109
23
100
128
44
1
1

3
20
13
569
6
5
17
7
89
85
44
0
1

15
11
62
0
5
12
92
16
11
43
0
1
0

289
69
353
0
93
46
625
501
11
81
0
7
0

307
100
428
569
104
63
734
524
111
209
44
8
1

124

140

District of Columbia — all*

...

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

TABLE 4

Applications for National bank charters*, and charters issued*, by States, calendar 1974
Withdrawn

Disapproved

Approved

Received^

Pending
Dec. 31, 1974

United States

313

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

9
1
0
2
12
8
0
0
1
89

1
1
0
0
4
4
0
0
0
21

2
0
0
1
4
1
0
0
0
28

141
6
0
0
1
4
3
0
0
1
39

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

3
0
0
23
2
0
1
1
3
0

2
0
0
7
0
0
0
0
0

1
0
0
3
0
0
0
0
0
0

0
0
0
13
1
0
1
1
2
0

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

4
1
11
6
4
7
1
1
0
0

3
0
3
1
0
1
0
1
0
0

1
0
0
1
3
1
0
0
0
0

0
0
7
3
1
4
1
0
0
0

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

10
9
6
1
1
1
3
0
0
0

4
3
2
0
0
0
1
0
0
0

2
4
0
1
0
0
0
0
0
0

2
2
4
0
1
1
1
0
0
0

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

3
0
3
60
2
0
9
2
2
6
3
0
2

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

0
0
0

* Excludes conversions and corporate reo
t Includes 151 applications pending as of

itions.
ember 31, 1973.

11
2
0
3
0
0
0
0
0
1

1
0
1
31
0
0
2
0
0
4
1
0
1

Chartered

TABLE 5

Applications for National bank charters issued pursuant to corporate reorganizations, and charters issued, by
States, calendar 1974
Received*

Disapproved

Approved

United States

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

6
0
0
1
1
0
0
0
0
0

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

0
0
0
7
0
0
0
1
0
0

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

0
6
5
0
1
0
0
0
0
0

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

1
0
2
0
0
5
2
0
1
0

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

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

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

Includes 6 applications pending as of December 31, 1973.

Withdrawn

Pending
Dec. 31, 1974

Chartered

TABLE 6

Applications for conversion to National bank charter and charters issued, by States, calendar 1974
Received
United States
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Virgin Islands

Approved
13

Disapproved
11

Withdrawn

Pending
Dec. 31, 1974

Chartered

TABLE 7

Branches of National banks by States, calendar 1974
Branches in
operation
Dec. 31, 1973

United States.

De novo
branches opened
for business
Jan. 1 to
Dec. 31, 1974

Branches
acquired
through
merger or
conversion
Jan. 1 to
Dec. 31, 1974

Existing
branches discontinued or
consolidated
Jan. 1 to
Dec. 31, 1974
378t

939

246

2,603
15
243
4
78
0

23
5
13
27
75
6
12
0
8
25

1
0
0
1
9
0
0
0
0
0

2
0
1
0
25
0
4
0
0
0

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

283
10
147
87
408
70
40
174
215
116

30
0
7
8
33
4
11
20
12
8

0
0
0
0
2
4
1
0
0
0

2
0
0
2
2
2
0
2
0
0

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

306
473
657
11
182
45
3
32
68
73

20
18
37
6
22
7
0
13
6
4

10
7
8
0
15
0
0
0
0
1

0
6
6
0
7
1
0
0
0
0

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

857
96
1,518
724
12
856
49
281
1,206
113

39
6
130
41
6
45
3
8
83
0

22
0
24
5
0
3
0
0
93
0

1
1
128
9
2
0
1
0
62
0

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

345
65
329
0
89
43
578
493
2
77
0
8

21
3
23
0
4
10
36
8
9
4
0
0

12
1
1
0
0
3
18
3
0
2
0
0

89
0
0
0
0
10
7
3
0
2
0
1

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

District of Columbia - allt

14,758*
245
60
253

116

115

Branches in
operation
Dec. 31, 1974

* 1973 totals adjusted in New York and Washington.
f Includes 1 adjustment made in Michigan.
$ Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.

TABLE 8

De novo branch applications of National banks, by States, calendar 1974
Approved

Received*

Withdrawn

Disapproved

Pending
Dec. 31, 1974
42

United States.

1,246

924

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

26
8
17
22
120
6
9
1
10
64

18
4
12
21
86
5
7
1
6
52

1
0
2
0
18
0
0
0
0
1

7
2
3
1
13
1
1
0
2
7

34
1
7
11
41
4
10
22
19
5

26
1
5
8
28
4
9
17
13
4

1
0
0
0
2
0
0
0
2
0

6
0
0
2
9
0
0
5
4
1

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

31
23
123
9
18
15
2
9
3
7

27
19
47
6
16
14
2
8
2
5

2
1
20
0
2
0
0
0
0
0

2
2
49
2
0
0
0
1
1
2

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

110
9
143
34
8
40
3
15
69
0

74
8
117
30
5
32
2
13
62
0

10
0
9
2
1
2
0
0
1
0

22
1
16
2
2
5
0
2
4
0

South Carolina
South Dakota..
Tennessee
Texas
Jtah
/ermont
Virginia
Washington . . .
Vest Virginia .
Wisconsin . . . .
Wyoming
irgin Islands .
'uerto Rico . . .

23
4
26
1
9
2
42
18
5
6
0
0
2

21
3
23
1
7
2
33
10
4
4
0
0
0

2
0
0
0
1
0
5
0
0
1
0
0
2

0
1
2
0
0
0
3
8
0
1
0
0
0

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

District of Columbia - allt

192

* Includes 370 applications pending as of December 31, 1973.
t Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
urrency.

TABLE 9

De novo branches of National banks opened for business, by community size and by size of bank, calendar 1974
Population of cities
Less than 5,000
5,000 to 24,999
25,000 to 49,999
50,000 to 99,999
100,000 to 249,999
250,000 to 499,999
500,000 to 1,000,000
Over 1,000,000
Total

Total resources of banks
(millions of dollars)

Branches

Branches
34
168
150
118
265
204

Less than 10.0.
10.0 to 24.9 . . .
25.0 to 49.9 . . .
50.0 to 99.9 . . .
100.0 to 999.9 .
1,000 and over.

190
315
134
103
74
40
50
33

939*

Total

939*

* Includes six automated teller machines beginning operation during 1974.

TABLE 10

Mergers,* calendar 1974
Transactions
involving two or
more operating
banks

Total

45
5
11

54
0
0

99
5
11

115

42
7
14

60
0
0

102
7
14

123

6
1
0

oooo

Applications received, 1974:
Mergers
Consolidations
Purchases and Assumptions

Others pursuant
to corporate
reorganization

14
1
0

Consummated, 1974:
Mergers
Consolidations
Purchases and Assumptions

43
8
15

62
0
0

105
8
15

Total consummated

128

Total received
Approvals issued, 1974:
Mergers
Consolidations
Purchases and Assumptions
Total decisions
Abandoned, 1974:
Mergers
Consolidations
Purchases and Assumptions
Total abandoned

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

IV. Bank Examinations and Related
Activities
The National Bank Act requires that all National
)anks 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,
3r 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, 1974, the Office
examined 6,436 banks, 18,063 branches and facilities, 1,701 trust departments, and 250 affiliates and
subsidiaries, as well as conducting 648 special
examinations and visitations. In addition, the Office
received 221 applications to establish new banks;
those included 59 corporate reorganizations. The
Office also received 876 applications to establish
ie novo branches, and 13 applications to convert
State banks to National banking associations.
National bank examinations are designed to determine the condition and performance of banks, the
quality of their operations, the capacity of management, and whether the banks are complying with
federal laws. All facets of an examination have, as
heir end result, the determination of liquidity and
solvency, present and prospective, and the determilation of whether the bank is operating within the
ramework of applicable banking laws and regulaions. The appraisal of a bank's loans and lending
olicies, investments and investment policies, and
ie ability and capacity of its management constitute
ie most exacting phases of the examination proess.
As of December 31, 1974, the Office employed
152 examining personnel: 2,009 commercial examers and 143 trust examiners.
The Office is constantly trying to improve the
lality and efficiency of examinations and this year
augurated a comprehensive review of examination
actices and procedures. The review is being conicted by a consortium headed by the firm of Hasns and Sells. New examination methods are being
rmulated to effectively deal with the changing face

of the banking industry. The career development
program for examining personnel is placing increased emphasis on various schools for all personnel, from the newly appointed Assistant National
Bank Examiner to the experienced National Bank
Examiner. The National Bank Examiner's school
occupies a key role in that program; it is attended by
all recently commissioned National Bank Examiners
and is very important in the development of our
examining personnel. The curriculum covers all
aspects of commercial examinations. Loan and
investment analysis, determination of asset quality,
and evaluation of bank management receive the
greatest emphasis. Time is also devoted to diversification of risk, liquidity, capital adequacy, earnings,
bank operations, investment in fixed assets, borrowings, future prospects, and review of the various
laws and regulations affecting National banks. There
are also lectures on trust and international examining and enforcement responsibilities for various
types of consumer legislation. Instruction is provided by Washington Office personnel and several
experienced National Bank Examiners. Knowledgeable bankers serve as guest speakers on topics in
their fields of specialization.
All newly appointed Assistant National Bank
Examiners are now assigned to a training crew for 6
months. The training crew is composed of a National
Bank Examiner, two experienced Assistant National
Bank Examiners and four new employees. The training crew performs examinations of the smaller National banks. Additional examination time is provided so that the new Assistants can be thoroughly
trained in all phases of the examination. Assignments are arranged so that each Assistant performs
a particular task in several successive examinations
in order to assure that he is familiar with the procedure. It is anticipated that that new training approach will result in the Assistant being able to perform most tasks independently after the initial 6
months of training.
Following 6 months on a training crew, all newly
appointed Assistant National Bank Examiners

attend a special school held on the regional level. A
new curriculum has been developed for that school,
and all phases of the examination are covered with
emphasis on those areas of the examination in which
the Assistants will be performing most of their work.
The material for that school has been improved and
is now uniform throughout the country. Instruction
is provided by experienced Assistants and commissioned examiners from the region.
All training programs of the Office are presently
being studied to determine how they can be improved. An additional school is being planned for
Senior Assistant National Bank Examiners. A curriculum is being planned that will help the Senior
Assistant prepare for his increased responsibilities.
Training is a very important part of any organization
and increased emphasis is being placed on that area.
Ninety-seven National banks with 650 foreign
branches require examiners with additional training
to examine their international activities. That training is being provided through week-long seminars
held quarterly in Washington, D.C., and through
frequent, but temporary, international examining
assignments at interregional and overseas locations.

In 1970, the Office inaugurated a 5-day EDP
seminar to be held in the regions and to continue
until all examining personnel have received the
necessary training. In 1974, the Office conducted 11
of those regional EDP seminars. Instruction covers
the capabilities and limitations of EDP systems in
commercial banks. In addition, examiners from each
region have been selected for specialized instruction
in advanced electronic data processing. Those
examiners generally work independently of the commercial or trust examiner and prepare the EDP
Report of Examination, copies of which are sent to
the banks examined. During 1974, a trust school was
held in Washington, D.C., in addition to regional
schools for trust personnel.
Finally, and in keeping with past practices, the
Office encourages its examiners to attend the various graduate schools of banking and to participate
in the host of courses offered by the American Institute of Banking and Dun and Bradstreet. We will
continue to review and update training programs and
examining techniques and to keep abreast of the
ever-changing world of banking.

V. Law Department
The Law Department is charged with providing
legal counsel to the Comptroller, with interpreting
and enforcing banking laws and regulations, and
with responding to litigation concerning the Office.
Some of the major activities are described below.

A. Litigation
On January 1, 1974, 42 cases were pending in
which the Comptroller was defendant. During the
year, 24 of these cases reached disposition: 12 by
stipulation of the parties, and 12 upon the merits. Of
those cases decided on the merits, a preponderance,
10, represented challenges to the Comptroller's
decisions upon new bank charters and branch bank
applications. The most significant of these was the
decision of the United States Court of Appeals for
the Eighth Circuit in First National Bank ofFayetteville v. Smith, 508 F.2d 1371, upholding the Comptroller's arguments as to the limited scope of judicial
review of the Comptroller's chartering decisions.
None of those cases was decided adversely to the
Office. The remaining two cases decided upon the
merits litigated issues arising under the Currency
and Foreign Transactions Reporting Act.
In June 1974, the Supreme Court decided two
cases to which the Comptroller was a party involving
the Bank Merger Act of 1966. United States v.
Marine Bancorporation, 418 U.S. 602; and United
States v. Connecticut National Bank, 418 U.S. 656.
Each case involved allegations that a merger of two
banks would eliminate potential future competition
between the banks in violation of §7 of the Clayton
Act. The Supreme Court's opinions made clear that
the application of potential competition theories to
banking must take into account the extensive Federal and State regulatory barriers to entry into banking, and that such barriers make it difficult to invalidate a bank merger on the basis of alleged future
potential competition between the merging banks.
At year's end, 30 cases were pending, either in
trial courts or upon appeal. Of special interest, three
pending cases concerned issues springing from the
receivership of United States National Bank, San
Diego, Calif.

B. Enforcement
On the administrative side, the procedures of the
Financial Institutions Supervisory Act of 1966 were
used 20 times to rectify operations and improve
administration of National banks. Those proceedings
involved written agreements with this Office or
orders to cease and desist enforceable through the
injunctive powers of United States district courts.
Such proceedings commonly involved a coordinated
effort among examining personnel, regional authorities, and the Law Department.
The Law Department supervised investigation of a
large number of suspected bank crimes and the
preparation of reports for referral to the several
United States Attorneys for possible prosecution.
Those referrals represented the full gamut of bankrelated crimes, ranging from common embezzlement
to complex, nationwide fraud schemes.

C. Securities Disclosure
Considerable Law Department activity involved
securities laws. The Department reviewed approximately 400 annual reports, 550 proxy statements,
1,100 quarterly reports, 1,000 current reports, and
9,600 ownership reports, filed by banks pursuant to
the Securities and Exchange Act of 1934. In addition, numerous registration statements filed with the
Securities and Exchange Commission by bank holding companies were reviewed at the SEC's request.
In October, the Congress amended Section 12(i)
of the 1934 Act, to require that Part 11 of the Comptroller's regulations be rendered substantially similar
to the comparable regulations of the Securities and
Exchange Commission, or that any divergencies be
explained. Accordingly, a survey of National banks
was undertaken to determine the contours of trading
markets for their shares, preparatory to revising
Part 11.
The Law Department continued to cooperate with
the Securities and Exchange Commission in areas of
overlapping jurisdiction or common concern, including questions arising under the Glass-Steagall Act,
reorganizations of banks into bank holding com-

panies, disclosures, accounting policy, gold sales,
automatic investment services for small investors,
and financial consulting services for corporate
customers.

D. Interpretations and Regulations
The Law Department received over 2,000 requests
from other members of Comptroller's staff, from
banks, from attorneys, from bank customers, and
from members of Congress for interpretations of
banking laws and regulations. Additionally, rulings
and circulars were promulgated announcing new
policies or revision of standing regulations. The
following represents a digest of that activity.
L Banking Circular No. 58. By the end of 1974,
the ban on private ownership of gold by United
States citizens was removed. Since the National
Bank Act authorizes National banks to deal in "exchange, coin and bullion," National banks were
permitted to participate in the developing market.
Banking Circular No. 58, issued in December, 1974,
cautioned about the volatility of the gold market,
reminded that an investment in gold provides no
yield or interest, and discussed insurance needs,
accounting procedure, collateralizing loans, amount
of inventory, and public relations.
2. Fair Housing Lending Practices Pilot Project.
The Comptroller, in conjunction with the Board of
Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation, and the
Federal Home Loan Bank Board, undertook a Fair
Housing Lending Practices Pilot Project, to test the
relative effectiveness of three different approaches
designed to collect information relating to the directive of the Civil Rights Act of 1968 that no Federally
regulated lending institution discriminate on the
basis of race, color, religion, sex, or National origin
in making residential real estate loans. The pilot
project ran from June 1, 1974, to November 30, 1974,
in 18 selected Standard Metropolitan Statistical
Areas throughout the Nation. Each participating
institution was required to request loan applicants
to indicate their race and other characteristics,
depending on the approach being tested, and to
maintain a record of all applications for review by
the appropriate regulatory agency. Results of the
pilot project are being evaluated, in order to determine the feasibility of a uniform, nation-wide recordkeeping and reporting program.
3. Regulations: a. 12 C.F.R., Part 22—Flood
Insurance Regulations. Pursuant to the Flood Disaster Protection Act of 1973, the Comptroller issued
regulations (12 C.F.R., Part 22), effective March 2,

1974, requiring a National bank to make no loan
secured by improved real estate or a mobile home
located in a special flood hazard area, unless the
borrower purchased flood insurance on the securing
property. The regulations further required that a
National bank make no such loans after July 1,1975,
or 1 year after notification to the community in which
the securing property is located that it has been
identified by the Secretary of Housing and Urban
Development as a special flood hazard area, whichever is later, unless that community is participating
in the National Flood Insurance Program. A pamphlet, entitled "Flood Insurance Guidelines," was
published by the Comptroller, and distributed to all
National banks in an effort to simplify the legal and
technical aspects of those regulations.
b. 12 C.F.R., Part 23—Statements of Business
Interests. The Comptroller added a new Part 23 to
Title 12 of the Code of Federal Regulations, to be
effective May 1, 1975, requiring directors and principal officers of National banks to maintain on file at
the banks, by July 1, 1975, statements of their outside business interests. Those regulations were
issued in order to monitor more closely self-dealing
transactions which may lead to unsafe and unsound
banking practices. Specifically, directors and principal officers must list all business enterprises over
which they or their immediate families hold some
significant influence, and all transactions between
their National bank and those enterprises, which
transactions are not evident from the bank's books.
Form CC-9030-29 (Rev. 4/75) was designed for compliance with those requirements.
4. Rulings: a. Customer-Bank Communications
Terminals (CBCT). On December 12, 1974, the
Comptroller announced an interpretation of the
National Bank Act stating that National banks could
make available, without geographic restriction, foi
use by their customers one or more electronic
devices or machines, through which an existing banl
customer may communicate to the bank a request t<
withdraw money either from his account or from <
previously authorized line of credit, or an instructioi
to receive or transfer funds for the customer'
benefit. Examples of such electronic devices o
machines are point-of-sale terminals, automati
teller machines, and the touch-tone telephone, whe
it is possible to use such a telephone to communicat
directly with a bank's computer. The interpretiv
ruling also stated that use of such devices at locf
tions other than the main office or a branch office c
the banks does not constitute branch banking
Accordingly, National banks were permitted 1
establish such customer-bank communicatio

terminals without filing formal applications, provided that prior written notice, including descriptive
information with regard to the device or machine
prescribed in the ruling, was given to the Comptroller's Office. The ruling imposes few limitations on
the establishment and use of CBCT's in order that
sellers and users of the service may be given the
widest latitude in determining how, when, and where
such devices can be used efficiently. In conjunction
with the issuance of the ruling, the Comptroller has
given public notice that the Office will continually
review developments arising from this interpretive
ruling, and that he will exercise his regulatory
authority to modify the ruling should developments
warrant such action.
b. Standby Letter of Credit and Ineligible Acceptances. On August 12, 1974, the Office announced
the adoption of interpretive rulings on the subject of
standby letters of credit and ineligible acceptances.
The rulings require that standby letters of credit and

ineligible acceptances be treated as ordinary loans
for the purpose of statutory limits on loans to a single
borrower, and loans to borrowers affiliated with the
lending bank. Under the rulings, National banks
must disclose, in a footnote to annual financial statements, the aggregate amount of outstanding standby
letters of credit. Similar regulations were issued by
the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation.

E. Legislative
The Law Department also responded to numerous
requests for comments on assistance with various
legislative proposals. Prominent among those was
the proposed Financial Institutions Act, the legislative proposal based upon recommendations of the
President's Commission on Financial Structure and
Regulation. The Comptroller strongly supports that
legislation.

VI. Fiduciary Activities of National Banks
Enactment of the Employee Retirement Income
Security Act of 1974 had a great impact on trust
department administration yet, in 1974, the number
of trust departments administered by National banks
continued to increase. Fifty-six applications for permits to exercise fiduciary powers were received
during the year of which 38, or 68 percent, were
approved. Among those were nine conversions from
State banks, two of them major, and two de novo
trust companies organized as National banks solely
to exercise fiduciary powers and administer fiduciary
business. It is contemplated that the trust companies
will engage in commercial banking business only in
connection with the exercise of their fiduciary
powers and related activities. A total of four trust
companies now operate under such charters.
At year-end, trust examining personnel in the 14
National bank regions consisted of 52 Representatives-in-Trusts, eight of whom were commissioned
during 1974; 24 Associates-in-Trusts; and 59 Assistant s-in-Trusts, a total of 135.
Regulation 9 was amended in 1974 to provide for
the collection and public dissemination of information concerning the holdings of and transactions in
equity securities held in a fiduciary capacity by
National banks and their non-bank subsidiaries or
affiliates. Those banks with total equity securities
holdings of $75 million or more, as reflected in the
Trust Department Annual Report for the preceding
year, were requested to file certain information with
the Comptroller of the Currency. All holdings over
10,000 shares, their fair market value, and the
degree of investment authority and voting control
being exercised is to be reported annually. A quarterly report of all purchases or sales of any equity
security with a total fair market value of $500,000 or
nore, or involving 10,000 shares or more effected
luring that quarter is also requested. Those reports
ire to be available for public inspection. A further
imendment to Regulation 9 is in process with repect to the authorization of variable amount notes.
Legislation pertaining to employee benefit plans

was enacted by Congress during 1974. The Employee Retirement Income Security Act, the socalled Pension Reform Act, is the most comprehensive and sweeping law concerning the administration
of one type of fiduciary activity ever passed by
legislators of the United States. Its enforcement in
trust departments of National banks will cause
examiners to review and re-evaluate employee
benefit plans from the standpoint of a new set of
rules, some embodying old principles, some completely new. Bank and non-bank fiduciaries alike will
have to review and re-evaluate the employee benefit
plans they administer, not only because of their
duties and responsibilities but also because of the
new penalty provisions in the Act.
The Comptroller's Manual for Representatives in
Trusts is in process of extensive revision, especially
on the scope of audits performed in trust departments. It is contemplated that several existing
requirements will be modified, particularly to require test-checking instead of 100 percent verification for a number of audit functions. On the other
hand, requiring administrative audits of selected
accounts as well as the reconcilement of corporate
trust issues as a matter of audit procedure are also
under consideration.
In addition, a program of required minimum
standards of output for electronic processing of
bookkeeping records is in process of completion and
will apply to all National banks. It is anticipated that
some former standard bookkeeping requirements,
such as the classification of investments by type of
assets, will be eliminated in order to make the program realistically minimal.
In order to standardize the scope of examination
and the manner of reporting on a nationwide basis,
questionnaires are being prepared for the trust
officer in charge at each bank and for banks'
auditors. Another questionnaire is designed for use
and application by the examiner in conducting his
examination.

VII. International Banking and Finance
1974 proved to be a chastening experience for
most international bankers. Quadrupled energy
costs, inflation, balance of payments deficits, and
recycling of OPEC surpluses seemed to be the major
challenges when the year began. As months passed,
however, massive foreign exchange losses, significant bank failures, and market tiers appeared.
Those elements, together, shook confidence in international financial markets, humbling even the most
prestigious institutions. Calm was restored slowly as
central banks and bank supervisors reacted with
lender of last resort policies and with closer controls
on lending in foreign exchange activities. The year
finished with the international financial system intact
and with a more seasoned international banking
community.
International bankers, during 1974, became reacquainted with the need for effective credit supervision and operating controls. While there is little
doubt that certain international banks experienced
losses from outright foreign exchange speculation,
the problems most institutions encountered arose
from speculating with inadequate personnel resources, credit procedures, and operating controls
relative to the volume of international activity being
conducted. The suddenness of negative events during 1974 caused international banks to contract their
exchange and lending business to more moderate
levels. At year-end, National banks had reduced
their foreign exchange dealings and overall positions. Conservative credit policies were instituted
requiring realistic spreads and short-term maturities. Inter-bank activities declined sharply as counerparty analysis became more thorough. Balance of
jayment lending ceased as banks narrowed their
country exposure limits in recognition of the mountng deficits of most oil importing countries.
In the midst of all that activity, National banks
ontinued to service their multinational relationships
fhile also adjusting their operational strategies.
National banks opened 51 foreign branches and
losed 21 during 1974. Twenty-two foreign branches
rere approved but unopened at year-end. A good
eal of that branch activity represented relocations
) the Cayman Islands from the Bahamas, as well

as recognition of Tokyo, Singapore, and the Middle
East as more important financial areas. Total foreign
assets stood at $99.8 billion on December 31, 1974,
a 19.8 percent increase over 1973. Forty-eight National banks continued to hold investments in foreign
banks or bank-related organizations at year-end.
There was a general trend toward investment in
OPEC areas during 1974. Many investments were
made with OPEC partners.
The International Division is charged with the
responsibility of supervising those activities. That
supervision is effected through examinations of head
offices, foreign branches, and foreign affiliates. In
addition to reviewing asset quality and internal controls, international examinations place special emphasis on foreign exchange dealings and the accuracy of reports submitted by the foreign units to their
head offices. The always sensitive and difficult
quality determination of loans to countries is another
area of supervision, and one in which the International Division became deeply involved during
1974, as industrial nations and lesser developed
countries struggled to adjust to new terms of trade
brought about by increased energy costs.
During the year, the International Division
assigned 96 National bank examiners to 26 countries
to conduct routine examinations of 114 foreign
branches and/or subsidiaries of National banks.
Examinations of four foreign computer functions
were also performed. On every assignment, examiners visited with host country banking supervisors
for mutually beneficial discussions. In certain cases,
our personnel conducted examining seminars for the
local central bank examining staff. Such cooperation
and communication with foreign bank supervisors is
a continuing program for the International Division.
During August, approval was granted to increase
the International Division's London Embassy staff
to six examiners. Those examiners are responsible
for supervising the activities of the 23 National banks
operating in the United Kingdom, the location of
National banks9 largest concentration of foreign
assets and foreign exchange activities. During
November, the International Division began requiring weekly and monthly foreign exchange reports

from National banks active in foreign exchange
dealings.
The International Division, during 1974, continued
to improve its educational and training responsibilities. A weekly newsletter of pertinent and financial
media articles now reaches 220 examining personnel, the 14 regional offices, and the staffs of Treasury, the Federal Reserve Board of Governors, and
the Congress. During the year, 120 examiners
attended quarterly seminars on all aspects of international banking supervision. Thirteen examiners
received 1-month foreign exchange training in
London. Four examining personnel attended the
school for International Banking at the University of

Colorado; a Division staff member also instructs ai
the school. As in the past, this Office cooperatec
fully with the staffs of Congress, the Board of Gov
ernors of the Federal Reserve, FDIC, the Bankers
Association For Foreign Trade, and the Conference
of State Banks Supervisors toward the mutual goa
of better banking supervision. Finally, the events o:
1974 have led to the development of an interna
tional correspondent relationship among foreigi
bank supervisors who now recognize the interde
pendence of multinational banking. The Office looks
forward to working with its international colleagues
in order to maintain confidence in internatioiia
banking systems.

VIII. Administrative and Management
Developments
During 1974, Administrative Operations increased
ubstantially in breadth and depth to guide impletientation of the Comptroller's many varied pro;rams. The skills required to complete these projcts ranged from coordinating establishment of
omplete National headquarters facilities to preparaion of weekly accounts detailing the status of
oreign currency transactions from banks having
aore than a $1 million net position in any foreign
urrency. Such expansive activity was accompanied
>y significant changes in the Bureau's administrative
rganization.
Relocation of the Comptroller's Washington, D.C.
>ffices to 490 L'Enfant Plaza East was completed
he weekend of September 7-8, 1974. Consolidation
it the new headquarters was facilitated by preparaion of an information packet containing a brochure
let ailing transportation routes, nearby businesses
nd shops, and maps showing the location of offices
or all employees. Other items in the packet included
elephone listings of fellow employees, directories of
hops in L'Enfant Plaza, bus route maps for access
:> downtown Washington, and locator cards. Carool assistance was provided where possible. Immeiately after relocation, work was started toward
squiring and planning use of additional space on
le second and eighth floors to accommodate fore;eable staff expansion.
One result of the consolidation of offices has been
broadening of administrative responsibilities in the
ea of facilities management. An example of such
Iministrative involvement in directing facilities use
establishment of a complete library whose opera>ns are placed under the supervision of the Dictor, Administrative Operations. The library occues 8,000 feet of core space adjacent to the Law and
inking and Economic Research Departments. Cre?d as a research facility, it was designed to house
,000 volumes, most related to banking, economics,
d law. Current and past issues of periodicals are
salable to readers, who may use them either at
nished carrels or in the general reading area.

Services offered readers include a microfilm library,
microfilm reader printer, a cassette series on bankrelated subjects, and interlibrary loan facilities.
Other space management activities carried out
during the year included: (1) relocation of regional
headquarters offices in Richmond and Denver; (2)
preliminary planning for relocation of offices in Chicago and San Francisco; (3) expansion of offices in
Portland, Memphis, Minneapolis, and Atlanta; (4)
establishment of three additional subregional
offices; and, (5) expansion or relocation of others.
Procurement activity multiplied due to preparation of the new offices. Procurement officers ordered
all equipment used in finishing the space and all furniture and accessories acquired. Efficient management of bank records was assisted by electronic
retrieval files obtained for the Records Management
Branch. Printing operations were enhanced by the
acquisition of advanced equipment including a 24
station collator, double sided printing press, and a
1500 Copy System which makes its own electrostatic
plates. Spacious work and storage facilities combined with better machinery improved services of
the Supply, Printing & Services Branch. Other
branches of the Administrative Operations Division
increased both in staff proficiency and equipment
sophistication to meet the growing requirements of
the Bureau.
While there were no major changes made to the
financial reporting system during the year, the Fiscal
Management Division continued to review its operations and implemented a number of changes to provide more efficient processing of voucher payments.
One such change in travel voucher processing substantially reduced keypunch and machine time
required to prepare reimbursement checks. A significantly greater volume of vendor payments was
processed during 1974. A large part of that increased
workload was attributable to the move to new space
in Washington.
Preliminary discussions began with regard to converting the present EAM accounting system to a

computer operation. The computer system will
provide more timely and detailed data than are available under the present system.
The Bureau's travel regulations are administered
by the Fiscal Management Division. During 1974,
per diem and mileage allowances were increased
after extensive analysis disclosed such increases
were warranted to adequately compensate employees. Additionally, the Fiscal Management Division
analyzed and reviewed regional requests for additional subregional offices. Establishment of those
offices reduced travel costs and permitted examiners
to spend less time away from home.
The investment portfolio contributed $3.5 million
to the Bureau's operating funds in 1974, an increase
of 19 percent over the previous year. The interest
earned on investments over the past several years by
virtue of the policy of keeping all available funds
fully invested to maximize interest revenue has contributed substantially to financing the Bureau's
operating costs.
In late 1974, the Personnel Management Division
was reorganized into five branches: employee relations, position management and classification, placement, training, and personnel operations. The reorganization was planned first to provide qualified
applicants for positions and to furnish information to
assist officials making decisions affecting employees. Second, it was designed to establish a career
ladder to facilitate progression of employees into
more responsible positions.
The reorganization completed, attention was
focused on evaluating the existing position classification program to determine improvements required to
develop a viable, management-oriented position
management classification program. Other improvements in daily operations included more timely
service in processing personnel action requests,
assurance of compliance with position management
objectives prior to undertaking classification actions,
assurance position descriptions reflected duties
actually performed, and creation of an effective
follow-up system of projected positions established
to permit expedient recruitment.
During 1974, a pilot program based on training
crew concepts was devised for Assistant National
Bank Examiners and is scheduled for implementation in 1975. The training crew concept involves a
6-month program of planned rotating assignments in
various phases of the bank examination process. A
second program was initiated to establish on-going
training programs for examiners and support staff.

A comprehensive supervisory-management training
program was developed and implementation set for
1975.
The executive development program received
special attention as Regional Administrators, department and division heads nominated 32 candidates
from a total of 78 applicants. Six employees were
selected to participate in the program.
At the end of 1974 there were 256 financial interns
enrolled in the cooperative education program, a 70
percent increase over 1973. Approximately 35 percent of the financial interns are members of
minority groups and 27 percent are women.
Increased program activity and intensified examination functions resulted in an increase in the number of examiners and support staff from 2,366 to
2,505. Special progress was made in hiring members
of minority groups and women for the examining
force. Of a total of 541 minority employees in the
regions, 505 are in examination, 278 of whom are
women.
Evaluations were conducted in six regions to
assess the effectiveness of regional personnel
management programs. Those evaluations helped
resolve individual and regional problems and
assisted institution of new practices.
The incentive awards program produced 14
awards for adopted suggestions and superior
achievements. One hundred thirty-three employees
were recognized with high quality increase awards
for their superior performance. Awards distributed
totalled $75,105 for the year.
Changes in laws affecting maternity and annual
leave carry-over were implemented during 1974, in
addition to pay adjustments for all employees.
During the past year, the Management Services
Division substantially increased its activities in
support of Bureau programs and organizations. That
increase in support resulted partly through the utilization of large-scale computers, including an IBM
370/168 and 370/158, and two Univac 1108's. This
was accomplished through the installation of both
high and low speed remote access terminals.
Major systems developed during the year included: (1) bi-monthly reports from all National
banks outlining the status of past due loans; (2) quarterly reports from large National banks detailing the
schedule of maturities; (3) weekly accounts from
banks with a $1 million or more net position in any
foreign currency, detailing the status of foreign currency transactions; (4) computer generated mailing
lists, labels, and addressed documents; and (5) com-

mter-generated microfilm containing National bank
eports of condition and income, stored on an inlexed microfilm retrieval system.
Interdisciplinary project teams were established
o conduct a number of special studies. Among those
vas the fair housing lending practices pilot project
n which the mortgage lending practices of banks in
.8 Standard Metropolitan Statistical Areas were surr
eyed. The study was carried out in cooperation
vith the Federal Reserve Board, the Federal Deposit
nsurance Corporation, and the Federal Home Loan
Jank Board.
Management analysts investigated the qualities
ind disadvantages of various word processing sysems to evaluate the feasibility of utilizing them
vithin the Bureau. Other special studies carried out
>y the Division included automation of personnel
tatistics reporting, evaluation of examination soft-

ware, automation of fixed assets inventory and call
reports, processing of data on direct lease financing,
and development of data base management systems.
The staff has been instrumental in Bicentennial
planning at both the Bureau and Departmental
levels.
Throughout 1974 the Division actively supported
several on-going programs. Included were management by objectives, emergency planning (including
vital records preservation), energy conservation,
rechartering and use of advisory committees, maintenance and operation of 53 data processing systems
applications, and conduct of functional and procedural reviews.
In order to provide more comprehensive support
to the Bureau, the Division was restructured into
four operating entities: systems and programming;
data operations; management analysis; and technical analysis.

IX. Other Activities
In September, 1974, a Strategic Policy Planning
Group was established at the National Office. The
new unit reports directly to the Comptroller.
Broadly defined, its mission is to assist the Comptroller and his senior associates in strategic policy
planning. One of the principle objectives of this unit
is to track the developing financial functions of the
larger National banks. Such a mission requires individuals in the Group with expertise in such key functional areas as liability management, financial analysis, electronic funds transfers, leasing and so on.
The Group is expected to play a major role in identifying problem areas and developing conditions which
require attention of the Office.
In recognition of growing consumer awareness in
this country, the Comptroller of the Currency announced the establishment of the Consumer Affairs
Division in March 1974. The Division became operational in September 1974, when the Office moved
into new quarters. Concern has been expressed in
Congress and by public interest groups that bank
regulatory agencies have not always given bank customers the same consideration they give banks. It
was to alleviate that concern and to coordinate the
activities that this Office has traditionally undertaken on behalf of consumers that the Comptroller
created the Division.
1974 was very significant in the area of consumer
legislation. This Office, for the past few years, has
been involved in the enforcement of the Truth-inLending and Fair Credit Reporting acts, which have
had direct bearing and considerable impact on protecting consumers' interests. The Federal thrust of
such legislation was expanded with the enactment of
the Fair Credit Billing Act, the Equal Credit Opportunity Act, the Federal Trade Commission Improvement Act, and the Real Estate Settlement Procedures Act. The first two of those new acts become
effective October 28, 1975. The first provides for the
correction of billing errors and protects the customer
from the creditor during the procedural process, and
the second forbids a creditor from discriminating
against any applicant on the basis of sex or marital

status. Interestingly, the latter act is not limited to
consumer credit, but applies to all credit.
The third piece of legislation, the Improvement
Act, attempts to provide sanctions against unfair or
deceptive acts or practices by banks. For the first
time, banks have been made subject to the prohibitions contained in the Federal Trade Commission
Act. The term "unfair or deceptive acts or practices" is broad and flexible and as yet there is no
determination as to how this will be applied to the
banking industry.
The Real Estate Settlement Procedures Act becomes effective June 20, 1975, and will provide
reforms in the complex real estate settlement process. Its basic thrust is that customers are provided
with greater and more timely information regarding
settlement costs.
National bank examiners continue to be trained to
administer, enforce, and interpret consumer laws
and regulations as they apply to banks and their
customers. The various complaints lodged against
National banks because of their consumer activity
are investigated by the Division, as well as by the
regional offices. Current and proposed consumer
banking practices are studied to determine if they
contain abuses.
The Consumer Affairs Division has maintained
close contact with State banking commissioners,
other Federal regulatory agencies, and consumer
interest groups in order that there might be an interchange of ideas and mutual assistance in the field of
banking consumer protection.
The Department of Banking and Economic Research, coupled with the Statistics Division, has
oversight responsibility for most of the data sources
currently available to the Office, except for examination reports. Those sources include the Report of
Condition and the Report of Income, the basic interagency statistical reports submitted by all insured
banks. Other report series include the Bank Liquidity Analysis form, initiated on a quarterly basis in
December 1966 and modified from time to time since
then; trust department annual reports and common

trust fund annual reports; the Maturity Schedule of
Assets and Liabilities; and the Past-Due Loans
Report. In addition, one-time surveys are conducted
as required, such as the comprehensive leasing survey of 1974.
The Maturity Schedule of Assets and Liabilities
was developed during 1974 with the aid of valuable
advice from other staff members and from the banking industry. The 200-plus largest National banks
completed that report for the first time as of October
31, and the plan is to collect those data every 3
months. The basic approach of the Schedule is to
secure a multiperiod maturity breakdown for each
asset and liability account for which the concept of

maturity has meaning. A large number of ratios have
been computed from the Schedule data, and reporting banks are receiving summary information allowing them to compare their positions with that of
fellow respondents.
The Past-Due Loans report was also developed
during 1974, with November 30 the first report date.
That report, which secures the ratios of past-due
loans to total loans for four loan categories, is being
submitted by all National banks every 2 months.
Indispensable programming and processing support has been provided for all these reporting
systems by the Management Services Division.

X. Financial Operations of the Office of the
Comptroller of the Currency
Total revenue for the year was $56.8 million, an
increase of 10.86 percent over 1973. However, that
represents a decrease of 3.2 percent when compared
to the 14.06 percent revenue growth rate experienced in 1973. Assessment receipts, which account
for 86 percent of total revenue, amounted to $48.7
million, an increase of $5.6 million. That resulted
from a $54.7 billion rise in National bank assets.
National bank assets affecting 1974 assessment receipts rose 12.57 percent, compared to an increase
of 15.54 percent in the previous year. Thus, the
decline in bank asset growth was the prime factor in
the decrease in total revenue growth.
Revenue from trust examinations totaled $2,585,000, an increase of $83,000. There were approximately 1,630 trust examinations made in 1974,
compared to 1,668 in 1973. Revenue from branch
investigation applications was down sharply, decreasing $237,000. Eight hundred and thirty-nine
branch applications were received in 1974, compared to 1,284 in 1973. Revenue from new bank
charter and merger and consolidation fees decreased
by $206,000 and $86,000, respectively. There were
216 new bank charter applications in 1974, compared to 299 in 1973, and the number of bank merger
applications dropped to 110, compared to 142 in
1973. Revenue from the sale of bank examination
reports decreased $291,000, owing to a reduction in
the charge made for such reports provided to the
Federal Reserve.
Interest on investments increased $544,000, a rise
of 19 percent, for a total of $3,481,000. That rise
was due to combination of a larger amount of funds
available for investment and a full year's revenue
from higher interest bearing securities acquired in
the latter part of 1973.
The other revenue categories remained at substantially the same levels when compared to 1973.
Total expenses amounted to $55.5 million, compared to $45.8 million for 1973, an increase of $9.7

million. That amounts to a 21.14 percent increase
for 1974, compared to 13.20 percent for 1973.
Salaries, personnel benefits and travel expenses
amounted to $50.1 million, or 90.3 percent of the
total expenses for the year. Those three expenses
amounted to $43.3 million in 1973. Salary increases
were caused by (1) a full year under the governmentwide general pay increase of 4.77 percent, effective
October 1973, and another general pay increase of
5.5 percent, effective October 1974, (2) a 3-month
retroactive pay increase for October 1972 to January
1973, resulting from a judicial decision in 1974, and
(3) an increase in our examining staff and support
personnel. Travel expenses totaled $8.1 million, a
rise of $1.6 million over 1973. That rise was caused
by higher per diem and mileage allowances as well
as the increase in the examining staff.
The remaining expenses totaled $5.4 million, an
increase of $2.8 million over the previous year. The
most significant increases occurred in rent, consultants, education, remodeling and moving, and shipping. The increase in rent results from leasing commercial space for the purpose of consolidating the
Washington staff at one location and from rent payments for previously rent-free space in government
buildings. Remodeling and moving and shipping
costs were also up because of the moves to commercial space. Another factor in the rise in moving and
shipping was the increased costs associated with
employee transfers. Consulting services were up
because of the study of examination procedures by
a consulting firm and the increased use of consultants in other matters.
The equity account is, in reality, a reserve for
contingencies. Transfers of $1.3 million increased
the equity to $33.7 million at year-end. That represents a 6.3 months' reserve for operating expenses,
based on the level of expenses over the last 3 months
of 1974. The equity account has been administratively restricted in the amount of $2.0 million as
explained in Note 2 of the financial statements.

TABLE 11

OFFICE OF THE COMPTROLLER OF THE CURRENCY
BALANCE SHEETS
December 31
Assets
Current assets:
Cash
Obligations of U.S. Government, at amortized cost (approximates market value)
Accrued interest on investments
Accounts receivable
Travel advances
Prepaid expenses and other assets
Total current assets
Long-term obligations of U.S. Government, at amortized cost (approximates market value)
Fixed assets and leasehold improvements, at cost (Note 1):
Furniture and
fixtures
Office machinery and equipment
Leasehold improvements
Less accumulated depreciation and amortization

Total assets

1974
$121,237
8,970,646
699,359
252,243
536,885
198,552

1973
$1,620,642
3,749,000
738,230
245,010
483,440
105,329

10,778,922

6,941,651

27,069,661

33,256,668

1,632,599
645,857
2,655,248

886,466
509,110

4,933,704

1,395,576

719,026

798,609

4,214,678

596,967

$42,063,261

$40,795,286

$923,858
178,650
1,636,130

$343,459
155,372
2,604,320

2,738,638

3,103,151

2,917,160
2,706,932

2,581,794
2,706,492

8,362,730

8,391,437

2,000,000
31,700,531

32,403,849

Liabilities and Comptroller's Equity
Current liabilities:
Accounts payable and accrued expenses
Taxes and other payroll deductions
Accrued travel and salaries
Total current liabilities
Long-term liabilities:
Accumulated annual leave
Closed Receivership Funds (Note 2)
Total liabilities
Comptroller's equity:
Administratively restricted (Note 2)
Unrestricted

Total liabilities and Comptroller's equity
See Notes at end of section.

33,700,531

32,403,849

$42,063,261

$40,795,286

TABLE 12

OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENTS OF REVENUE, EXPENSES AND COMPTROLLER'S EQUITY
Year ended December 31
1974
1973
Revenue (Note 1):
Semiannual assessments
Examinations and investigations
Investment income
Examination reports sold
Other

$48,749,470
4,271,273
3,481,139
216,279
83,998

$43,178,771
4,520,905
2,936,677
507,080
92,353

56,802,159

51,235,786

Expenses:
Salaries
Retirement and other employee benefits (Note 3)
Per diem
Travel
Rent and maintenance (Note 3)
Communications
Moving and shipping
Employee education and training
Printing, reproduction and subscriptions
Office machine repairs and rentals
Depreciation and amortization
Supplies
Consulting services
Conferences
Remodeling
Other

38,550,745
3,493,216
5,244,786
2,861,221
1,522,938
567,172
548,531
401,686
355,609
193,866
228,139
182,602
841,122
152,328
147,426
214,090

33,985,944
2,854,360
4,195,473
2,263,484
629,907
495,468
181,498
244,917
256,977
155,204
121,418
111,890
128,590
37,954
20,248
134,844

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

55,505,477
1,296,682
32,403,849

45,818,176
5,417,610
26,986,239

$33,700,531

$32,403,849

Comptroller's equity at end of year
See Notes at end of section.

TABLE 13

OFFICE OF THE COMPTROLLER OF THE CURRENCY
STATEMENTS OF CHANGES IN FINANCIAL POSITION
Year ended December 31
1974
1973
Financial resources were provided by:
Excess of revenue over expenses
Add charges and credits not affecting working capital in the period:
Additions to accumulated annual leave
Depreciation and amortization
Amortization of premium and accretion of discount on long-term U.S. Government, obligations (net)
Net (gain) loss on sale of fixed assets
Working capital provided by operations for the period
Long-term U.S. Government obligations transferred to current assets
Proceeds received from sales of fixed assets
Net Closed Receivership Funds' receipts
Total
Financial resources were used for:
Purchases of long-term U.S. Government obligations
Payments of accrued annual leave
Purchase of furniture, fixtures, machinery and equipment
Purchase of leasehold improvements
Total

$1,296,682

$5,417,610

592,548
228,139

666,850
121,418

(4,340)
(18,326)

(5,753)
2,613

2,094,703
9,188,347
119,794
440

6,202,738
1,350,000
9,971
134

11,403,284

7,562,843

2,997,000
257,182
1,292,070
2,655,248

12,932,950
293,202
137,863

7,201,500

13,364,015

Increase (decrease) in working capital

$4,201,784

$(5,801,172)

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

$(1,499,405)
5,221,646
(38,871)
7,233
53,445
93,223

$1,457,879
(5,340,412)
175,943
(254,129)
47,623
30,507

3,837,271

(3,882,589)

Decrease (increase) in current liabilities:
Accounts payable and other accruals
Taxes and other payroll deductions
Accrued travel and salaries

Increase (decrease) in working capital
See Notes at end of section.

(580,399)
(23,278)
968,190

(150,265)
(21,836)
(1,746,482)

364,513

(1,918,583)

$4,201,784

$(5,801,172)

OPINION OF INDEPENDENT ACCOUNTANT
To the Comptroller of the Currency
Office of the Comptroller of the Currency
In our opinion, the accompanying balance sheets, the related statements of revenue, expenses and
Comptroller's equity and the statements of changes in financial position present fairly the financial position
of the Office of the Comptroller of the Currency at December 31, 1974 and 1973, the results of its operations
and the changes in financial position for the years then ended, in conformity with generally accepted accounting principles consistently applied. Our examinations of these statements were made in accordance with
generally accepted auditing standards and accordingly included such tests of the accounting records and such
other auditing procedures as we considered necessary in the circumstances, including confirmation of securities owned by correspondence with the depositary.
PRICE WATERHOUSE & CO.
WASHINGTON,

D.C.

April 15, 1975.

NOTES TO FINANCIAL STATEMENTS

Note 1 — Organization and Accounting Policies
The Office of the Comptroller of the Currency was created for
the purpose of establishing and regulating a National Banking
System. The National Currency Act of 1863, rewritten and reenacted as the National Banking Act of 1864, created the Comptroller's Office, provided for its supervisory functions and the
chartering of banks. The revenue of the Comptroller's Office is
derived principally from assessments and fees paid by the National banks and interest on investments in U.S. Government
obligations. Assessments paid by National banks are not construed to be government funds. No funds derived from taxes or
federal appropriations are allocated to or used by the Comptroller's Office in any of its operations. However, since the
Comptroller's Office was created by an Act of Congress, its
operations are not subject to federal income taxes.
The accounts of the Comptroller's Office are maintained on the
accrual basis. Furniture, fixtures, office machinery and equipment are depreciated on the straight-line basis principally over
an estimated useful life of 10 years. Leasehold improvements are
amortized over the terms of the related leases (including renewal
options) or the estimated useful lives, whichever is less* Premiums and discounts on investments in U.S. Government obligations are amortized or accreted ratably over the terms of the
obligations. U.S. Government obligations having a maturity date
more than 12 months from the date of the financial statements
are classified as long-term investments.
Note 2 - Closed Receivership Funds
Prior to the assumption of closed National bank receivership
functions by the Federal Deposit Insurance Corporation in 1936,
the Comptroller of the Currency appointed individual receivers
for all closed National banks. After settling the affairs of the
closed banks and issuing final distributions to the creditors of the
banks, principally depositors, the receivers transfered to the custody of the Comptroller's Office all remaining funds which represented distributions which were undeliverable or had not been
presented for payment. Closed Receivership Funds in the accompanying balance sheets represent the potential claims for such
funds by the original creditors of the receiverships. Since inception of the receivership function, unclaimed funds have been
invested in U.S. Government securities. The income from investments has been applied as an offset to expenses incurred by the
Comptroller's Office in performing this function and accordingly
has been recorded as revenue in its statements of revenue
expenses and Comptroller's equity. Through December 31, 1974,
income has exceeded direct expenses by approximately $2,000,000 (including $155,000 and $156,000 in 1974 and 1973, respectively), which excess amount is included in the Comptroller's
equity. An analysis of allocable indirect expenses has not been
made.
In a recent reexamination of the legal status of Closed Receivership Funds and related excess income earned thereon, the

Comptroller's legal staff has been unable to locate any definitive
statutory or case law which specifies the ultimate disposition of
such funds. In the absence of legal precedent, the legal staff is
unable to currently give a definitive opinion as to the appropriate
disposition of either the unclaimed receivership funds or the
excess income from investment of such funds. Accordingly, the
Comptroller intends to seek legislative resolution of those
matters.
Pending a resolution of the legal uncertainties surrounding
those funds, the Comptroller's Office has continued to include a
liability for Closed Receivership Funds in its balance sheet and
continued to recognize income from investment of such funds as
revenue in its statements of revenue, expenses, and Comptroller's equity. However, in recognition of those uncertainties, the
Comptroller has administratively restricted a portion of the
Comptroller's equity in an amount that approximates the excess
income earned from investment of Closed Receivership Funds
since custody of the funds commenced.
Note 3 - Commitments and Contingencies
Regional and sub-regional offices of the Comptroller of the
Currency lease office space under agreements which expire at
varying dates through 1984. In addition, the Comptroller's Office
occupied new office space in Washington, D.C. during 1974
under a lease agreement providing for an initial 5-year term
with five consecutive 5-year renewal options. The options provide
for renegotiation of the rental at each renewal. Prior to July 1,
1974, the Washington, D.C. office and certain regional offices,
located in Federal Government facilities were occupied on a rentfree basis.
Minimum rental commitments under 80 leases in effect at
December 31, 1974 aggregate approximately $1,800,000 for 1975
and varying lesser amounts each year thereafter, to approximately $1,400,000 for 1979 and insignificant amounts thereafter
through 1984.
The Comptroller's Office contributes to the Civil Service Retirement plan for the benefit of all its eligible employees. Contributions aggregated $2,628,454 and $2,311,708 in 1974 and 1973,
respectively. The plan is participatory, with 7 percent of salary
being contributed by each party. The accompanying balance
sheets include a liability for annual leave, accumulated within
specified limits, which if not taken by employees prior to retirement is paid at that date.
Various banks in the District of Columbia have deposited
securities with the Comptroller's Office as collateral for those
banks entering into and administering trust activities. Those
securities, having a par or stated value of $11,991,000, are not
assets of the Comptroller's Office and, accordingly, are not
included in the accompanying financial statements.
The Comptroller is a defendant, together with other bank
supervisory agencies and other persons, in litigation generally
related to the closing of certain National banks in 1974 and 1973.
In the opinion of the Comptroller's legal staff, the Comptroller
will be able to defend successfully against those complaints and
no liability to the Comptroller is expected to result therefrom.

APPENDIX A

Merger Decisions, 1974

Merger* Decisions, 1974
/. Mergers consummated, involving two or more operating banks
Jan. 1, 1974:
Page
First National Bank and Trust Company, Ontario,
Calif.
Palm Springs National Bank, Palm Springs, Calif.
43
Merger
Jan. 1, 1974:
The United National Bank & Trust Company, Canton,
Ohio
Beach City Banking Company, Beach City, Ohio
44
Merger
Jan. 2, 1974:
United Virginia Bank/First & Citizens National, Alexandria, Va.
United Virginia
Zirginia Bank of Fairfax, Vienna (Fairfax
Count
nty),
r)9 Va.
Consolidation.
45
Jan. 4, 1974:
Maryland National Bank, Baltimore, Md.
Sykesville State Bank, Sykesville, Md.
46
Merger
Jan. 22, 1974:
Wells Fargo Bank, National Association, San Francisco, Calif.
Beverly Hills National Bank, Beverly Hills, Calif.
47
Purchase
Feb. 11, 1974:
The Shelby National Bank of Shelbyville, Shelbyville,
Ind.
The Union State Bank, Morristown, Ind.
48
Purchase
Feb. 26, 1974:
People's National Bank of Georgetown, Georgetown,
Ohio
Citizens Bank Co., Hamersville, Ohio
49
Purchase
Feb. 28, 1974:
The American National Bank in Battle Creek, Battle
Creek, Mich.
The Athens Branch of The American National Bank
and Trust Company of Michigan, Kalamazoo, Mich.
50
Purchase
Mar. 1, 1974:
First National Bank of Monroe County, Aberdeen,
Miss.
Peoples Bank, Starkville, Miss.
51
Consolidation
Mar. 29, 1974:
The First National Bank of Hancock, Hancock, N.Y.
The First National Bank of Hamden, Hamden, N.Y.
52
Purchase
Mar. 31, 1974:
Midlantic National Bank, Newark, N.J.
Millburn-Short Hills Bank, Millburn, N.J.
53
Merger
Mar. 31, 1974:
Midlantic National Bank/Morris, Morristown, N.J.
Midlantic National Bank/Parsippany, ParsippanyTroy Hills, N.J.
54
Merger

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

Page
Apr. 1, 1974:
Dominion National Bank, Baileys Cross Roads, Va.
Peoples Bank and Trust Company of Fairfax, Fairfax
County, Va.
55
Merger
Apr. 1, 1974:
The First National Bank of Versailles, Versailles,
Ohio
The Peoples Bank Company, Versailles, Ohio
56
Consolidation
Apr. 11, 1974:
Maryland National Bank, Baltimore, Md.
Eutaw Savings Bank of Baltimore, Baltimore, Md.
59
Purchase
Apr. 12, 1974:
The Baraboo National Bank, Baraboo, Wis.
Farmers State Bank, Rock Springs, Wis.
59
Purchase
Apr. 22, 1974:
Bankers Trust of South Carolina, N.A., Columbia,
S.C.
The Peoples Bank, Beaufort, S.C.
60
Merger
Apr. 30, 1974:
The First National Bank of Jasper, Jasper, Ala.
Dora Banking and Trust Company, Dora, Ala.
61
Consolidation
Apr. 30, 1974:
The Peoples National Bank and Trust Company of
Washington, Washington, Ind.
Farmers State Bank, Plainville, Ind.
62
Merger
May 1, 1974:
Fidelity National Bank, Halifax County, Va.
The Halifax Branch of The Fidelity National Bank,
Lynchburg, Va.
63
Purchase
May 10, 1974:
The Fulton National Bank of Lancaster, Lancaster,
Pa.
The Hummelstown National Bank, Hummelstown,
Pa.
64
Merger
May 17, 1974:
North Carolina National Bank, Charlotte, N.C.
The First National Bank of Mount Airy, Mount Airy,
N.C.
65
Merger
May 17, 1974:
The St. Lawrence National Bank, Canton, N.Y.
Lewis County Trust Company, Lowville, N.Y.
66
Merger
May 31, 1974:
Pennsylvania National Bank and Trust Company,
Pottsville, Pa.
The Dime Bank of Lansford, Lansford, Pa.
67
Merger
May 31, 1974:
Peoples National Bank of Monmouth County, Hazlet
Township, N.J.
Madison State Bank, Madison Township, N.J.
68
Merger
May 31, 1974:
The National Bank of Jackson, Jackson, Mich.
Farmers State Bank of Concord, Concord, Mich.
69
Merger

June 7, 1974:
Page
First National Bank of Ocean County, Lakewood, N.J.
First National State Bank of the Jersey Coast, Spring
Lake, N.J.
Merger
70
June 10, 1974:
The National Bank of South Carolina of Sumter,
Sumter, S.C.
The Farmers Bank, Loris, S.C.
Merger
71
June 10, 1974:
The Wyoming National Bank of Wilkes-Barre, WilkesBarre, Pa.
The First National Bank of Factoryville, Factoryville, Pa.
Merger
72
June 28, 1974:
Deposit Guaranty National Bank, Jackson, Miss.
Leflore Bank & Trust Company, Greenwood, Miss.
Merger
73
June 28, 1974:
The National Bank and Trust Company of Norwich,
Norwich, N.Y.
The National Bank of Hobart, Hobart, N.Y.
Merger
74
July 1, 1974:
Republic National Bank of New York, New York,
N.Y.
Kings Lafayette Bank, New York, N.Y.
Republic Bank, National Association, New York,
N.Y.
Merger
75
July 1, 1974:
The Okey-Vernon National Bank of Corning, Corning, Iowa
First State Bank, Prescott, Iowa
Purchase
77
July 15, 1974:
The First National Bank of the City of Superior,
Superior, Wis.
Wisconsin State Bank, Superior, Wis.
Purchase
78
July 29, 1974:
First National Bank of Somerset County, Berlin, Pa.
The First National Bank of Confluence, Confluence,
Pa.
Consolidation
79
July 31, 1974:
The First National Bank of San Jose, San Jose, Calif.
Hayward National Bank, Hayward, Calif.
Merger
80
Aug. 2, 1974:
The First Jersey National Bank, Jersey City, N.J.
Belmar-Wall National Bank, Wall Township, N.J.
Merger
81
Aug. 16, 1974:
The County Bank, N.A., Cambridge, Mass.
Lexington Trust Company, Lexington, Mass.
Consolidation
82
Aug. 23, 1974:
Wells Fargo Bank, National Association, San Francisco, Calif.
Commercial National Bank, Orange County (P.O.
Buena Park), Calif.
Merger
83
Sept. 16, 1974:
The Toy National Bank of Sioux City, Sioux City,
Iowa
Farmers Loan & Trust Company, Sioux City, Iowa
Merger
84
Sept. 28, 1974:
Michigan National Bank of Macomb, Warren, Mich.
Tri-City Bank, Warren, Mich.
Purchase
85
Sept. 30, 1974:
Cumberland County National Bank and Trust Company, New Cumberland, Pa.
The Duncannon National Bank, Duncannon, Pa.
Merger
86

Oct. 1, 1974:
Page
First National Bank of Aberdeen, Aberdeen, S. Dak.
The First National Bank in Bristol, Bristol, S.Dak.
Merger
87
Oct. 1, 1974:
National Bank of Mississippi, Starkville, Miss.
The National Bank of Commerce of Columbus, Columbus, Miss.
Consolidation
88
Oct. 29, 1974:
Citizens Bank of Marlton, National Association, Marlton, N.J.
Citizens State Bank, Vineland, N.J.
Citizens National Bank of South Jersey, Bridgeton,
Bridgeton, N.J.
Continental Bank of New Jersey, Maple Shade, N.J.
Merger
89
Oct. 31, 1974:
Citizens First National Bank of New Jersey, Ridgewood, N.J.
Oakland State Bank, Oakland, N.J.
Merger
91
Oct. 31, 1974:
New Jersey Bank (National Association), Clifton,

N.J.
Fairneld National Bank, Fairfield, N.J.
Merger
Nov. 14, 1974:
First Mississippi National Bank, Hattiesburg, Miss.
Citizens National Bank, Jackson, Miss.
Purchase
Nov. 15, 1974:
Pittsburgh National Bank, Jeanette, Pa.
Blairsville National Bank, Blairsville, Pa.
Purchase
Nov. 15, 1974:
The First National Bank of Eastern Pennsylvania,
Wilkes-Barre, Pa.
The Berwick National Bank, Berwick, Pa.
Merger
Nov. 18, 1974:
National Bank of the Commonwealth, Indiana, Pa.
The Houtzdale Bank, Houtzdale, Pa.
Purchase
Nov. 29, 1974:
Bankers Trust Company of Albany, National Association, Albany, N.Y.
The First National Bank of Cooperstown, Cooperstown, N.Y.
Merger
Nov. 29, 1974:
Indian Head National Bank of Nashua, Nashua, N.H.
Indian Head National Bank of Manchester, Manchester, N.H.
Consolidation
Nov. 29, 1974:
Mechanics National Bank of Delaware Valley, Burlington Township, N.J.
Egg Harbor Bank and Trust Company, Egg Harbor
City, N.J.
Merger
Nov. 29, 1974:
Security National Bank of Kansas City, Kansas City,
Kans.
The Victory State Bank, Kansas City, Kans.
Merger
Nov. 29, 1974:
Vermont National Bank, Brattleboro, Vt.
Montpelier National Bank, Montpelier, Vt.
Merger
Dec. 2, 1974:
Old National Bank of Washington, Spokane, Wash.
Guaranty National Bank of White Center, Seattle,
Wash.
Purchase
Dec. 2, 1974:
Third National Bank of New Jersey, Camden, N.J.
United Jersey National Bank of Cherry Hill, Cherry
Hill, N.J.
Merger

100

101

102

103

Dec. 21, 1974:
Harrison County National Bank, Hopedale, Ohio
The Freeport State Bank, Freeport, Ohio
Merger
Dec. 30, 1974:
First National Bank of Springfield, Springfield, Vt.
The First National Bank of Fair Haven, Fair Haven,
Vt.
The Northfield National Bank, Northfield, Vt.
Merger
Dec. 30, 1974:
New Jersey Bank (National Association), Clifton, N.J.
The First National Bank of Westwood, Westwood,

Page
104

105

N.J.
Merger
Dec. 30, 1974:
Wachovia Bank and Trust Company, N.A., WinstonSalem, N.C.
Citizens Bank, Marshall, N.C.
Merger

106

Dec. 31, 1974:
First National Bank of South Carolina, Columbia, S.C.
Palmetto Bank & Trust Company, Lake City, S.C.
Merger
Dec. 31, 1974:
First National Bank of South Carolina, Columbia, S.C.
The Bank of Walterboro, Walterboro, S.C.
Merger
Dec. 31, 1974:
The Central Trust Company of Montgomery County,
National Association, Dayton, Ohio
The Farmers and Merchants Bank of Englewood,
Englewood, Ohio
Merger
Dec. 31, 1974:
The National Bank of Richmond, Richmond, Mich.
New Haven Savings Bank, New Haven, Mich.
Merger

Page
109

112

107

//. Mergers consummated, pursuant to corporate reorganization
Jan. 1, 1974:
Page
The Farmers National Bank of Salem, Salem, Ohio
Northern Columbiana County National Bank, Salem,
Ohio
Merger
114
Jan. 2, 1974:
Fidelity Bank, National Association, Oklahoma City,
Okla.
Fidelity National Bank, Oklahoma City, Okla.
Merger
115
Jan. 2, 1974:
The First National Bank of Cincinnati, Cincinnati,
Ohio
FN National Bank, Cincinnati, Ohio
Merger
115
Jan. 18, 1974:
First National Bank in Grand Prairie, Grand Prairie,
Tex.
Second National Bank in Grand Prairie, Grand
Prairie, Tex.
Merger
116
Jan. 18, 1974:
Texas National Bank of Dallas, Dallas, Tex.
Stemmons National Bank, Dallas, Tex.
Merger
117
Jan. 28, 1974:
Hamilton National Bank of Loudon, Loudon, Tenn.
Loudon Bank, N.A., Loudon, Tenn.
Merger
118
Jan. 28, 1974:
The Farmers Bank of Winchester, Winchester, Tenn.
Winchester Bank, N.A., Winchester, Tenn.
Merger
119
Feb. 1, 1974:
The First National Bank in Onancock, Onancock, Va.
Onancock Bank, N.A., Onancock, Va.
Merger
119
Feb. 4, 1974:
The Homer National Bank, Homer, N.Y.
Homer Bank, N.A., Homer, N.Y.
Merger
120
Feb. 28, 1974:
National Bank and Trust Company of Ann Arbor, Ann
Arbor, Mich.
National Bank of Ann Arbor, Ann Arbor, Mich.
Merger
121
Feb. 28, 1974:
National Bank of Murfreesboro, Murfreesboro, Tenn.
The Second National Bank of Murfreesboro, Murfreesboro, Tenn.
Merger
122

Feb. 28, 1974:
Page
The First National Bank of Canton, Canton, N.Y.
Chase Manhattan Bank of Northern New York (National Association), Canton, N.Y.
Merger
123
Mar. 8, 1974:
First National Bank of Lake City, Lake City, Mich.
LCM National Bank, Lake City, Mich.
Merger
124
Mar. 8, 1974:
National Bank of Rochester, Rochester, Mich.
NBR National Bank, Rochester, Mich.
Merger
125
Mar. 18, 1974:
The First National Bank of Crockett, Crockett, Tex.
The New National Bank of Crockett, Crockett, Tex.
Merger
126
Mar. 27, 1974:
The Selma National Bank, Selma, Ala.
Selma Bank, N.A., Selma, Ala.
Merger
127
Mar. 29, 1974:
First National Bank of Athens, Athens, Ala.
First Bank of Athens, N.A., Athens, Ala.
Merger
128
Mar. 29, 1974:
The First National Bank of Hancock, Hancock, N.Y.
Hancock National Bank, Hancock, N. Y.
Merger
129
Apr. 1, 1974:
The First National Bank of Nordheim, Nordheim, Tex.
The New National Bank of Nordheim, Nordheim, Tex.
Merger
130
Apr. 29, 1974:
First National Bank in Aspen, Aspen, Colo.
Second National Bank in Aspen, Aspen, Colo.
Merger
130
Apr. 29, 1974:
The First National Bank of Glenwood Springs, Glenwood Springs, Colo.
Second National Bank in Glenwood Springs, Glenwood Springs, Colo.
Merger
131
Apr. 29, 1974:
First National Bank in Grand Junction, Grand Junction, Colo.
Second National Bank in Grand Junction, Grand Junction, Colo.
Merger
132

Apr. 29, 1974:
Page
First National Bank-North in Grand Junction, Grand
Junction, Colo.
Second National Bank-North, Grand Junction, Grand
Junction, Colo.
Merger
133
Apr. 30, 1974:
Concord National Bank, Concord, N.H.
The Concord Bank, National Association, Concord,
N.H.
Merger
134
Apr. 30, 1974:
Laconia Peoples National Bank & Trust Company,
Laconia, N.H.
The Laconia Bank, National Association, Laconia,
N.H.
Merger
135
Apr. 30, 1974:
The City National Bank of Selma, Selma, Ala.
Dallas County National Bank, Selma, Ala.
Merger
136
Apr. 30, 1974:
The Merchants National Bank of Manchester, Manchester, N.H.
The Merchants Bank, National Association, Manchester, N.H.
Merger
137
May 8, 1974:
The First National Bank of Sault Ste. Marie, Sault
Ste. Marie, Mich.
Sault National Bank, Sault Ste. Marie, Mich.
Merger
138
May 9, 1974:
Old & Third National Bank of Union City, Union
City, Tenn.
The National Bank of Union City, Union City, Tenn.
Merger
139
May 9, 1974:
Republic National Bank of Dallas, Dallas, Tex.
Ervay Bank, National Association, Dallas, Tex.
Merger
140
May 10, 1974:
The First National Bank of New Bedford, New Bedford, Mass.
Second National Bank of New Bedford, New Bedford,
Mass.
Merger
140
May 20, 1974:
The Union National Bank and Trust Company of Marquette, Marquette, Mich.
UNB National Bank, Marquette, Mich.
Merger
141
May 31, 1974:
Baldwin National Bank of Robertsdale, Robertsdale,
Ala.
Gulf Coast National Bank of Robertsdale, Robertsdale, Ala.
Merger
142
May 31, 1974:
Delaware Valley National Bank, Cherry Hill, N.J.
New Jersey National Bank-South, Cherry Hill, N.J.
Merger
143
June 4, 1974:
First Safety Fund National Bank, Fitchburg, Mass.
Montachusett National Bank, Fitchburg, Mass.
Merger
144
June 28, 1974:
Colonial First National Bank, Red Bank, N.J.
New Colonial First National Bank, Red Bank, N.J.
Merger
145
June 28, 1974:
Glen National Bank and Trust Company, Watkins
Glen, N.Y.
Bank of Watkins Glen, National Association, Watkins Glen, N.Y.
Merger
146

June 28, 1974:
Page
The First National Bank of Easthampton, Easthampton, Mass.
Easthampton Bank (National Associaton), Easthampton, Mass.
Merger
147
June 30, 1974:
The First National Bank of Cranbury, Cranbury, N.J.
Midlantic National Bank/Cranbury, Cranbury, N.J.
Merger
148
July 1, 1974:
First National Bank & Trust Company in Alton, Alton, 111.
First National Bank & Trust Company, Alton, 111.
Merger
149
July 1, 1974:
Seattle-First National Bank, Seattle, Wash.
SeaFirst National Bank, Seattle, Wash.
Merger
149
July 8, 1974:
The First National Bank of Maryland, Baltimore, Md.
Charles Street National Bank, Baltimore, Md.
Merger
150
July 18, 1974:
The Cleveland National Bank, Cleveland, Tenn.
Cleveland Interim Bank, N.A., Cleveland, Tenn.
Merger
151
July 26, 1974:
Guaranty National Bank and Trust of Corpus Christi,
Corpus Christi, Tex.
Guaranty Commerce National Bank, Corpus Christi,
Tex.
Merger
152
Aug. 1, 1974:
The Prospect Park National Bank, Wayne, N.J.
First Prospect Park National Bank, Wayne, N.J.
Merger
153
Aug. 2, 1974:
First National Bank of Hurst, Hurst, Tex.
Hurst Commerce National Bank, Hurst, Tex.
Merger
154
Aug. 7, 1974:
First City National Bank of Gadsden, Gadsden, Ala.
Bank of Gadsden, N.A., Gadsden, Ala.
Merger
155
Aug. 19, 1974:
Lafayette National Bank, Lafayette, Ind.
Tippecanoe National Bank, Lafayette, Ind.
Merger
156
Aug. 26, 1974:
Farmers-First National Bank of Stephenville, Stephenville, Tex.
Stephen ville National Bank, Stephen ville, Tex.
Merger
157
Aug. 30, 1974:
Plaza National Bank, Secaucus, N.J.
Second Plaza National Bank, Secaucus, N.J.
Merger
158
Sept. 16, 1974:
The Athens National Bank, Athens, Ohio
The F.B.G. National Bank of Athens, Athens, Ohio
Merger
159
Sept. 30, 1974:
The Citizens Baughman National Bank, Sidney, Ohio
The C.B. National Bank of Sidney, Sidney, Ohio
Merger
160
Oct. 10, 1974:
The First National Bank of Evart, Evart, Mich.
Evart Bank, N.A., Evart, Mich.
Merger
161
Oct. 31, 1974:
The Colonial-American National Bank of Roanoke,
Roanoke, Va.
Colonial Bank, N.A., Roanoke, Va.
Merger
162

Nov. 1, 1974:
The First National Bank in Cleburne, Cleburne, Tex.
Johnson County National Bank, Cleburne, Tex.
Merger
Nov. 14, 1974:
Phenix National Bank, Phenix City, Ala.
Bank of Phenix, N.A., Phenix City, Ala.
Merger
Nov. 18, 1974:
Virginia National Bank/Fairfax, Springfield, Va.
Community Bank and Trust Company, Springfield,
Va.
Merger
Dec. 9, 1974:
Central Bank, National Association, Grand Rapids,
Mich.
C. Bank, National Association, Grand Rapids, Mich.
Merger

Page
162

163

164

165

Dec. 9, 1974:
Page
Valley National Bank of S agin aw, Saginaw, Mich.
V. National Bank, Saginaw, Mich.
Merger
166
Dec. 13, 1974:
The Gogebic National Bank of Ironwood, Ironwood,
Mich.
GNB National Bank, Ironwood, Mich.
Merger
167
Dec. 30, 1974:
First National Bank of Ironwood, Ironwood, Mich.
The Second National Bank of Ironwood, Ironwood,
Mich.
Merger
168
Dec. 31, 1974:
National Bank of Commerce of Pine Bluff, Pine Bluff,
Ark.
Jefferson National Bank, Pine Bluff, Ark.
Merger
169

777. Additional Approvals
A. Approved, but abandoned, no ligitation
Page
May 8, 1974:
The First National Bank of Paris, Paris, Tex.
New National Bank of Paris, Paris, Tex.
Merger
170
May 8, 1974:
The First National Bank of San Angelo, San Angelo,
Tex.
New National Bank, San Angelo, Tex.
Merger
171
Nov. 12, 1974:
First Mississippi National Bank, Hattiesburg, Miss.
Citizens National Bank, Jackson, Miss.
Merger
172

B. Approved, but abandoned, due to litigation
Page
July 9, 1974:
The Merchants National Bank of Burlington, Burlington, Vt.
Montpelier National Bank, Montpelier, Vt.
Merger
173
Aug. 22, 1974:
The Connecticut National Bank, Bridgeport, Conn.
The First New Haven National Bank, New Haven,
Conn.
Consolidation
173
Oct. 3, 1974:
The National Bank of Commerce of Seattle, Seattle,
Wash.
Washington Trust Bank, Spokane, Wash.
Merger
173

/. Mergers consummated, involving two or more operating banks
FIRST NATIONAL BANK AND TRUST COMPANY, ONTARIO, CALIF., AND PALM SPRINGS NATIONAL BANK,
PALM SPRINGS, CALIF.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Palm Springs National Bank, Palm Springs, Calif. (15276), with
and First National Bank and Trust Company, Ontario, Calif. (6268), which had
merged Jan. 1, 1974, under charter and title of the latter bank (6268). The merged bank at date
of merger had

COMPTROLLER S DECISION

On May 17, 1973, Palm Springs National Bank,
Palm Springs, Calif., and First National Bank and
Trust Company, Ontario, Calif., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
First National Bank and Trust Company, the charter bank, was organized in 1887, and possesses total
assets of $113.9 million and IPC deposits of $84.6
million. It is headquartered in Ontario, Calif., and
operates 14 branch offices in San Bernardino and
Riverside counties. It has received authorization to
establish two additional branches in the cities of
Upland and Riverside.
The service area of the charter bank encompasses
the "West End" of San Bernardino County and the
western portion of Riverside County. That area,
which has a population of approximately 350,000
people, is economically dependent on industry and
agriculture. Competitors for the charter bank include Bank of America National Trust and Savings
Association, with deposits of $33.3 billion; Security
Pacific National Bank, with deposits of $10 billion;
and Crocker National Bank, with deposits of $6.2
billion.
Palm Springs National Bank, the merging bank,
was organized in 1964, and has total assets of $24.2
million and IPC deposits of $19.9 million. Headquartered in Palm Springs, it operates five branches in
Riverside County and has received approval to open
another branch in Palm Springs. The merging bank
has been beset by management and asset problems.
The merging bank's service area is the central
portion of Riverside County around Palm Springs.
The population of that area is approximately 130,000, and the economy is based on agriculture, recreation, and retirement facilities. Palm Springs National Bank competes with Bank of America National Trust and Savings Association, Security

$ 24,710,462
128,773,855

To be
operated

6
15

153,484,317

Pacific National Bank, United California Bank,
Crocker National Bank, City National Bank, with
deposits of $498 million, and First National Bank in
Coachella, with deposits of $8.8 million.
Competition between the subject banks is virtually
nonexistent as their closest offices are separated by
a distance of 30 miles. Consummation of the proposed merger will enhance rather than diminish
competition. Expanded and improved services such
as trust services, electronic data processing, and an
increased lending limit, will be offered by the resulting bank. In addition, the management and loss
problems of the merging bank will be resolved.
Applying the statutory criteria, it is the conclusion of this Office that the proposed merger is in
the public interest and will result in no adverse competitive effects. The application is, therefore, approved.
OCTOBER 10,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National Bank and Trust Company of Ontario ("Ontario Bank") operates 16 banking offices
in San Bernadino and Riverside counties in Southern
California. As of March 31, 1973, Ontario Bank held
total deposits of $103.6 million (including IPC demand deposits of $34.5 million) and total loans of $57
million.
Palm Springs National Bank ("Palm Springs
Bank") operates six banking offices in Palm Springs
and nearby communities in Central Riverside
County. An additional branch in Palm Springs has
been approved but has not been opened. As of
March 31, 1973, Palm Springs Bank held total deposits of $22.3 million (including IPC demand deposits of $10 million) and total loans of $13 million.
Although Palm Springs Bank has enjoyed substantial growth since its formation in 1964, it has recently
experienced substantial operating losses.
43

The parties to this merger are headquartered
about 70 miles apart, and the nearest offices are
located about 25 miles apart with the San Jacinto
Mountains situated in the intervening area. It appears that the proposed transaction would eliminate
no substantial existing competition. Nor, because of

the relatively modest size of the bank to be acquirec
and the existence of other significant potential en
trants, does it appear that the proposed merger wil
eliminate substantial potential competition.
Therefore, we conclude that the proposed transac
tion will not have a substantial competitive impact

THE UNITED NATIONAL BANK & TRUST COMPANY, CANTON, OHIO, AND BEACH CITY BANKING COMPANY,
BEACH CITY, OHIO

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Beach City Banking Company, Beach City, Ohio, with
and The United National Bank & Trust Company, Canton, Ohio (14501), which had
merged Jan. 1, 1974, under charter and title of the latter bank (14501). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On June 15, 1973, Beach City Banking Company,
Beach City, Ohio, and The United National Bank &
Trust Company, Canton, Ohio, applied to the Comptroller of the Currency for permission to merge under the charter and with the title of the latter.
The United National Bank & Trust Company, the
charter bank, was organized in September 1972 by
the merger of Canton National Bank, Canton, Ohio,
organized in 1854, and Mount Union Bank, Alliance,
Ohio, organized in 1930. The bank, with assets of
$93 million and IPC deposits of $73.9 million, is
headquartered in Stark County, Ohio, and through
seven branches, serves Canton, Plain Township,
Jackson Township, and Alliance.
The charter bank is the fourth largest of five banks
headquartered in Canton and also the fourth largest
of the 13 banks in Stark County. Competition for the
charter bank is provided by The Harter Bank and
Trust Company, Canton, with deposits of $242 million; First National Bank of Canton, with deposits of
$177 million; and Peoples-Merchants Trust Company, Canton, with deposits of $120 million.
Beach City Banking Company, the merging bank,
was chartered in 1898 and, with assets of $10 million
and IPC deposits of $8 million, has operated as a
unit bank since its inception. The active management of this bank is supervised by its president, who
is 72 years old. There is, at present, no middle level
management personnel who can take control of the
daily functions of the bank when the president retires. Beach City is located in the extreme southwest corner of Stark County.

$ 10,286,299
100,413,248
109,383,244

To be
operated
1
8
9

Beach City Banking Company is the 10th largest
of the 13 commercial banks in Stark County. Competition for this bank comes from the Brewster branch
office of Peoples-Merchant Trust Company, which
has total deposits of $120 million, and from Navarre
Deposit Bank Company, with deposits of $8.8 million.
The primary service area of the merging bank is
limited to Beach City, with a population of 1,151,
and its immediate environs including Sugar Creek
Township and a small portion of both Tuscarawas
County and Holmes County. That area is almost entirely devoted to small farms and has no other significant employers. Many residents of this area commute to Canton, Dover, or other cities for employment. The service area of the charter bank is central
and northeast Stark County including Canton, its
environs, and Alliance. Canton's economy is concentrated in the basic steel and fabricated metal
fields and in machine production.
Competition between The United National Bank
& Trust Company and Beach City Banking Company is insignificant. The main office of the charter
bank is 16 miles from Beach City and the charter
bank's nearest branch is 15 miles from the merging
bank. Those distances, and the numerous financial
institutions located in the intervening area, confirm
that very little competition exists between the
charter and merging banks.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank. The resulting bank will offer improved and
expanded services to the residents of Beach City
including a larger lending limit, expansion of lending

ervices, and the introduction of trust services,
^hile the merger will solve the problem of managenent succession at Beach City Banking Company,
he resulting bank will neither increase its ranking
imong competing banks nor will it significantly increase its position among other commercial banks
operating in Stark County.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
The application is, therefore, approved.
NOVEMBER 29,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Union National Bank and Trust Company ("Union
Bank") operates its head office and seven branches
in and around Canton in Stark County, Ohio. On
June 30, 1972, Union Bank held total deposits of
$80.9 million (including IPC demand deposits of

$24.5 million) and had total loans outstanding of approximately $51 million.
Beach City Banking Company ("Beach City
Bank") operates its only office in Beach City, Stark
County, Ohio. On June 30, 1972, Beach City Bank
held total deposits of $8.2 million (including IPC
demand deposits of $1.3 million) and had total loans
outstanding of approximately $5.2 million.
Though both Union Bank and Beach City Bank
operate in Stark County, Ohio, their nearest offices
are about 16 miles apart, with several other banking
offices intervening. Thus, while the proposed transaction may eliminate a limited amount of existing
competition, it does not appear that banking concentration would be substantially increased in any
relevant market.
Therefore, we conclude that the proposed acquisition would not have a substantial competitive impact.

UNITED VIRGINIA BANK/FIRST & CITIZENS NATIONAL, ALEXANDRIA, VA., AND UNITED VIRGINIA BANK OF
FAIRFAX, VIENNA (FAIRFAX COUNTY), VA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
United Virginia Bank of Fairfax, Vienna (Fairfax County), Va., with
and United Virginia Bank/First & Citizens National, Alexandria, Va. (651), which had
consolidated Jan. 2, 1974, under charter of the latter bank (651) and title "United Virginia Bank/
National." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On June 5, 1973, United Virginia Bank/First &
Citizens National, Alexandria, Va., and United Virginia Bank of Fairfax, Vienna (Fairfax County), Va.,
applied to the Comptroller of the Currency for permission to consolidate under the charter of the
former and with the title "United Virginia Bank/
National," with headquarters in Vienna, Va.
United Virginia Bank/First & Citizens National,
the charter bank, was organized in 1864 and, with
assets of $266 million and IPC deposits of $216.7
million, operates 20 offices and has 6 approved but
unopened branches. Its service area includes the
city of Alexandria and adjacent sections of Arlington
and Fairfax counties.
United Virginia Bank of Fairfax, Vienna, Va., the
consolidating bank, was chartered in 1929 and, with
assets of $99.5 million and IPC deposits of $73.2
million, operates 10 offices in Fairfax County, its
service area.

$108,584,051
302,480,978
411,065,029

To be
operated

10
22
32

While both banks serve adjacent areas in Northern Virginia, there is very little competition between
the banks. The Alexandria bank can legally branch
no more than 5 miles into Fairfax County and has no
office closer than 5 miles from an office of the Fairfax bank. Furthermore, both the charter and consolidating banks are wholly-owned subsidiaries of
United Virginia Bankshares, Inc., a registered bank
holding company and the proposed transaction is,
therefore, a corporate reorganization and will have
no effect on competition. Consummation of the consolidation will allow an improvement in operating
and administrative efficiencies and provide a larger
lending limit for customers.
Applying the statutory criteria, it is the conclusion of this Office that the proposed consolidation
will result in no adverse competitive effects and will
benefit the public interest. This application is, therefore, approved.
NOVEMBER 30,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Both of the consolidating banks are essentially
wholly-owned subsidiaries of United Virginia Bank-

shares, Inc., a registered bank holding company.
Thus, the proposed transaction is essentially a corporate reorganization and will have no effect on
competition.

MARYLAND NATIONAL BANK, BALTIMORE, MD., AND SYKESVILLE STATE BANK, SYKESVILLE, MD.

Banking offices
Name of bank and type of transaction

Total assets

$ 14,481,227
Sykesville State Bank, Sykesville, Md., with
1,732,138,222
and Maryland National Bank, Baltimore, Md. (13745), which had
merged Jan. 4, 1974, under charter and title of the latter bank (13745). The merged bank at date
1,745,392,289
of merger had

COMPTROLLER S DECISION

On September 24, 1973, Maryland National Bank,
Baltimore, Md., and Sykesville State Bank, Sykesville, Md., applied to the Comptroller of the Currency for permission to merge under the charter
and with the title of the former.
Maryland National Bank, the charter bank, was
organized in 1933 and now, with assets of $1.6 billion
and IPC deposits of $1 billion, is the largest commercial bank in Maryland. The charter bank operates 118 banking offices throughout the State, 56
of which serve the Baltimore Metropolitan Area.
Since 1969, Maryland National Bank has been the
principal subsidiary of Maryland National Corporation, a one-bank holding company headquartered in
Baltimore.
The retail service area of the charter bank includes portions of the Eastern Shore, Harford
County, western Maryland, Montgomery and Prince
Georges counties, southern Maryland, and metropolitan Baltimore. The bank's specialized departments enable it to compete on a statewide basis for
large commercial customers and National concerns.
In Maryland, competition for the charter bank is
provided by Equitable Bancorporation, whose four
subsidiary banks have aggregate deposits of $986
million; The First National Bank of Maryland, Baltimore, with deposits of $802 million; Suburban Trust
Company, Hyattsville, with deposits of $684 million;
and Union Trust Company of Maryland, with deposits of $611 million.
Sykesville State Bank, the merging bank, was
chartered in 1934, and is now the sixth in deposit
size of banks headquartered in Carroll County and
64th of the 114 commercial banks in the State of
Maryland. The merging bank has assets of $14.4
46

In
To be
operation operated
3
120
123

million and IPC deposits of $12.5 million and operates two branches, one each in Eldersburg and
Friendship. Both of those branches are within 4
miles of the bank's main office.
The service area of the merging bank consists of
the southern portion of Carroll County and the northern portion of adjoining Howard County where its
Friendship branch is situated. The economy of that
area is traditionally primarily agricultural but is now
becoming more industrialized. The only direct competition in the area is provided by the Eldersburg
branch of The Woodline National Bank, which has
total deposits of $8.7 million. Carroll County Bank
and Trust Company, Westminister, with deposits of
$65 million, has, however, received permission to
open a new branch office in Eldersburg.
Competition between the charter and merging
banks is nominal because of the distance which
separates their closest two offices. The branches of
the charter bank nearest to those of the merging
bank are in Randalls town and O wings Mills which
are 11 miles and 13 miles northeast of Sykesville,
in Baltimore County. Maryland National Bank does
not operate any branches in Carroll County.
Consummation of the proposed merger will allow
the resulting branches in Carroll County to provide
new and improved services to customers in its service area, particularly in the areas of business
financing, accounts receivable financing, and international banking. Because of the small size of the
merging bank, this merger will not significantly affect the statewide size of Maryland National Bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
NOVEMBER 30,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are separated by
a distance of approximately 9 miles with five competitive alternatives in the intervening area. Although the proposed acquisition will eliminate some
existing competition, it does not appear that banking
concentration would be substantially increased in
any relevant banking market. While Maryland Na-

tional Bank could expand de novo into the communities presently served by State Bank, the latter's
relatively small absolute size and the nature of the
communities which it serves diminish the effect of
this transaction on potential competition.
Therefore, we conclude that this proposed acquisition would not have a substantial competitive impact.

WELLS FARGO BANK, NATIONAL ASSOCIATION, SAN FRANCISCO, CALIF., AND BEVERLY HILLS NATIONAL
BANK, BEVERLY HILLS, CALIF.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Beverly Hills National Bank, Beverly Hills, Calif. (13348), with
was purchased Jan. 22, 1974, by Wells Fargo Bank, National Association, San Francisco,
Calif. (15660), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On January 22, 1974, application was made to the
Comptroller of the Currency for permission for
Wells Fargo Bank, National Association, San Francisco, Calif., to purchase certain of the assets and
assume certain of the liabilities of Beverly Hills
National Bank, Beverly Hills, Calif. Wells Fargo
Bank, National Association, also applied pursuant to
12 U.S.C. 36(c) to establish branches at the banking
locations now occupied by Beverly Hills National
Bank.
In accordance with the provisions of 12 U.S.C.
181 and 12 U.S.C. 1828(c), it is found that an emergency exists and that this Office must act immediately to prevent the probable failure of Beverly Hills
National Bank, Beverly Hills, Calif., and to protect
its depositors, creditors, and shareholders.
Accordingly, approval by the shareholders of Beverly Hills National Bank of the Agreement to As-

% 140,714,528

10,658,110,142
9,013,936,840

305

To be
operated

308

sume Liabilities and to Acquire Assets executed
between Wells Fargo Bank, National Association,
and Beverly Hills National Bank is hereby waived;
the purchase of certain assets and assumption of
certain liabilities as contemplated by that Agreement is approved; and Wells Fargo Bank, National
Association, is authorized to consummate the transaction immediately.
Wells Fargo Bank, National Association, is hereby
given permission to establish and operate branches
at 9600 Santa Monica Boulevard, Beverly Hills,
Calif.; 9101 Wilshire Boulevard, Beverly Hills,
Calif.; and at 143 Barrington Place, Los Angeles,
Calif.
JANUARY 22,

1974.

NOTE: Due to the emergency nature of the situation, no report on competitive factors was requested.

THE SHELBY NATIONAL BANK OF SHELBYVHLLE, SHELBYVILLE, IND., AND THE UNION STATE BANK,
MORRISTOWN, IND.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Union State Bank, Morristown, Ind., with
was purchased Feb. 11, 1974, by The Shelby National Bank of Shelbyville, Shelbyville, Ind.
(7946), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On September 20, 1973, The Shelby National
Bank of Shelbyville, Shelbyville, Ind., applied to the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of The
Union State Bank, Morristown, Ind.
The Shelby National Bank of Shelbyville, the purchasing bank, was organized in 1955 and operates
two branch offices. With total assets of $41.2 million
and IPC deposits of $33.5 million, the bank is the
largest bank operating in Shelby County. The service area of the purchasing bank encompasses Addison Township, an industrial area which has a population of approximately 18,000 people.
Competitors of the purchasing bank include Farmers National Bank, with deposits of $28.3 million;
The State Bank of Waldron, with deposits of $11.4
million; and Fairland National Bank, with deposits
of $11.3 million.
The Union State Bank, the selling bank, was organized in 1894, and operates as a unit institution.
With total assets of $4 million and IPC deposits $3.2
million, it is the smallest bank in Shelby County.
The service area of the bank encompasses Hanover
Township, an agricultural area which has a population of approximately 2,350 people.
Competitors of the selling bank include The
Greenfield Banking Company, with deposits of $37.9
million; Rushville National Bank, with deposits of
$25 million; and Hancock County Bank, with deposits of $19 million.
Competition between the subject banks is minimal because they are separated by a distance of

To be
operated

$ 4,208,362
45,215,863
47,339,182

approximately 19 miles and because an inconvenient
highway system exists between them. Consummation of the proposed transaction will result in no
significant adverse competitive effects. The resulting bank will better serve the Morristown area by
offering an increased lending limit and by the influx
of a more aggressive managerial staff.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JANUARY 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Both Shelby Bank and Union Bank operate in
Shelby County, Ind., with their nearest offices separated by a distance of about 13 miles. There are no
competitive alternatives in the intervening area.
Thus, it appears that the proposed acquisition may
eliminate some existing competition.
Commercial banking in Shelby County is highly
concentrated. Shelby Bank, with approximately 41
percent of county deposits, ranks first among the
county's five banks, while the three largest banks
hold approximately 84 percent of total county deposits. The proposed acquisition will increase
Shelby Bank's share of the Shelby County market to
45 percent and increase the share of the top three
banks from 84 percent to 88 percent.
The proposed transaction would eliminate some
existing competition and increase banking concentration in Shelby County.

PEOPLE'S NATIONAL BANK OF GEORGETOWN, GEORGETOWN, OHIO, AND CITIZENS BANK CO.,
HAMERSVILLE, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Citizens Bank Co., Hamersville, Ohio, with
was purchased Feb. 26, 1974, by The People's National Bank of Georgetown, Georgetown,
Ohio (5996), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On August 23, 1973, The People's National Bank
of Georgetown, Georgetown, Ohio, applied to the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of the
Citizens Bank Co., Hamersville, Ohio.
The People's National Bank of Georgetown, the
applicant, was organized in 1901 and operates as a
unit institution. It possesses total assets of $8.1 million and IPC deposits of $6.2 million. The service
area of the applicant, which, with an estimated population of 7,500 people, is agricultural in nature,
encompasses the area surrounding Georgetown.
Competitors for the applicant include The Bank of
Russellville, with deposits of $18.9 million; The Citizens National Bank of Ripley, with deposits of $6.5
million; The First National Bank of Georgetown,
with deposits of $6.4 million; and The Ripley National Bank, with deposits of $6 million.
Citizens Bank Co., the selling bank, was organized
in 1906 and operates as a unit institution. With total
assets of $2 million and IPC deposits of $1.8 million,
it is the smallest bank in Brown County. Its service
area encompasses Hamersville and its environs, an
area with a population of 2,500 people which is economically dependent on agriculture.
The only significant competitor of the selling bank
is The First National Bank of Bethel in Clermont
County, which has deposits of $4.4 million. The
selling bank is unable to compete effectively with
the larger banks in Brown County because of its
small size, inadequate lending limit, lack of service,
and ineffective management. Consequently, even
though the service areas of the subject banks do
overlap, competition between them is minimal. In
fact, most of the applicant's business in the Hamersville area is generated from loans which the selling

$ 2,123,355

9,388,332
10,826,132

To be
operated

bank is too small to accommodate and which it refers
to the applicant. In addition, the applicant is already
furnishing personnel to assist the selling bank in its
daily operations; an interlocking directorate relationship exists between the two banks; and they have a
number of common shareholders.
Consummation of the proposed transaction will
result in no adverse competitive effects. Competition in the Hamersville area will be increased
through the introduction by the resulting bank of
new and expanded services such as an increased
lending capacity, money orders, travelers checks, a
night depository, Christmas and vacation club accounts, drive-up window facilities, and the monthly
mailing of checking account statements. In addition,
the Hamersville office will be operated by experienced banking personnel.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JANUARY 21,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

People's Bank and Citizens Bank are located
about 10 miles apart with several competing banking
offices in the intervening area. It appears that the
proposed acquisition would eliminate only a limited
amount of existing competition. And in view of the
modest size of the parties and the existence of other
potential entrants into their respective markets, we
conclude that the proposed transaction would not
eliminate substantial potential competition.
Therefore, we conclude that the proposed transaction would not have a substantial competitive impact.

THE AMERICAN NATIONAL BANK IN BATTLE CREEK, BATTLE CREEK, MICH., AND THE ATHENS BRANCH OF
THE AMERICAN NATIONAL BANK AND TRUST COMPANY OF MICHIGAN, KALAMAZOO, MICH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Athens Branch of The American National Bank and Trust Company of Michigan, Kalamazoo, Mich. (13820), with
was purchased Feb. 28, 1974, by The American National Bank in Battle Creek, Battle Creek,
Mich. (16185), which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On October 12, 1973, The American National
Bank in Battle Creek, Battle Creek, Mich., applied
to the Office of the Comptroller of the Currency for
permission to purchase the assets and assume the
deposit liabilities of the Athens Branch of The American National Bank and Trust Company of Michigan,
Kalamazoo, Mich.
The American National Bank in Battle Creek, the
purchasing bank, was chartered on October 1, 1973,
and now operates one banking office. The bank is a
wholly-owned subsidiary of American National Holding Company, Kalamazoo, Mich., a multi-bank
holding company, and currently has total assets of
$3.5 million and IPC deposits of $1.8 million.
Competition for the purchasing bank is provided
by The First National Bank and Trust Company of
Michigan, Kalamazoo, with deposits of $298.4 million; Michigan National Bank, Battle Creek, with deposits of $1.3 billion; and Security National Bank of
Battle Creek, with deposits of $91.6 million.
The American National Bank and Trust Company
of Michigan, the selling bank, was organized in 1933
and is now the second largest of three commercial
banks headquartered in Kalamazoo with total assets
of $232.1 million and IPC deposits of $171.6 million.
The bank currently operates 16 branch offices and is
also a wholly-owned subsidiary of American National
Holding Company.
Competition for the selling bank is provided by
The First National Bank and Trust Company of
Michigan, Kalamazoo, with deposits of $298.4 million, and Industrial State Bank and Trust Company,
Kalamazoo, with deposits of $104.5 million.
The Athens branch office of The American National Bank and Trust Company of Michigan, the
subject of the proposed transaction, holds deposits
of $3.3 million and is the only bank operating in the
village of Athens. Competition for the branch office
is provided primarily by banks headquartered in
Coldwater, including Branch County Bank with de50

$3,294,000

9,102,721
9,721,838

To be
operated

posits of $31.1 million, and Southern Michigan National Bank with deposits of $39.5 million.
The principal service area of the Athens branch
includes the village of Athens, with an estimated
population of 996 persons, and small portions of
Calhoun, Kalamazoo, St. Joseph, and Branch counties. The economy of Calhoun County, where the
subject branch office is located, is primarily supported by a major cereal manufacturer in Battle
Creek which employs nearly half the work force of
the area. Rural farmland predominates in the area
surrounding Athens, but diversified manufacturing
enterprises in nearby Battle Creek insure a balanced
employment pattern.
At present there is no competition between the
purchasing and selling banks. The Athens branch
of the selling bank is the closest office of that bank
to Battle Creek, located 18 miles distant, with an
adequate number of alternative banking facilities
operating in the intervening distance. In addition,
American National Holding Company controls both
the purchasing and selling banks. In view of that
close affiliation, the subject application represents a
corporate reorganization of commonly owned assets,
primarily for the convenience of the two banks, and
will not adversely effect competition. More efficient
operations and more personalized service to customers of the resulting bank will come from consummation of the proposed transaction.
Accordingly, it is the view of this Office that the
proposed transaction is in the public interest and
will not result in any adverse competitive effects.
The application is, therefore, approved.
JANUARY 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed transaction is part of a plan through
which the Athens office of The American National
Bank and Trust Company of Michigan would be
transferred to a newly organized bank. Since both
the transferring bank and the acquiring bank are

subsidiaries of American National Holding Company, a bank holding company, the proposed trans-

action is simply a corporate reorganization and
would have no competitive effect.

FIRST NATIONAL BANK OF MONROE COUNTY, ABERDEEN, MISS., AND PEOPLES BANK, STARKVILLE, MISS.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Peoples Bank, Starkville, Miss., with
and First National Bank of Monroe County, Aberdeen, Miss. (3656), which had
consolidated Mar. 1, 1974, under charter of the latter bank (3656) and title "First United
National Bank." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On November 1, 1973, First National Bank of
Monroe County, Aberdeen, Miss., and Peoples
Bank, Starkville, Miss., applied to the Comptroller
of the Currency for permission to consolidate under
the charter of the former and the title, "First United
National Bank," and with its main office in Starkville.
First National Bank of Monroe County, the charter bank, was organized in 1887 and now, with three
branch offices, has assets of $16.8 million and IPC
deposits of $10.6 million. The service area of the
bank includes Monroe County, which has a population of 34,043. The area is mainly agricultural with
an increasing amount of commercial and industrial
development near Aberdeen and Amory.
Competition for the charter bank is provided by
Monroe Banking and Trust Company, Aberdeen,
with deposits of $12 million; Bank of Amory, with
deposits of $17.5 million; and Security Bank of
Amory, with deposits of $11.8 million. The Nettleton, Lee County, branch of the Bank of Mississippi,
with deposits of $101.8 million, provides additional
competition on the outer fringe of the service area.
Peoples Bank, the consolidating bank, was organized in 1889 and presently, with assets of $33.2
million and IPC deposits of $26.1 million, operates
three branches at Starkville and Maben. Its service
area includes all of Oktibbeha County which has a
population of 28,752, western Webster County,
northeastern Choctaw County, and southwestern
Clay County. The economy of that service area is
primarily agricultural with minor commercial and
industrial activity in Maben and Starkville where the
area's largest employer, Mississippi State University, is located.
Competition for the consolidating bank is provided
by Security State Bank, Starkville, with deposits of

$37,504,693
21,453,037

To be
operated

4
4

58,957,729

$33.4 million; Bank of Mantee, with deposits of $5
million; and Grenada Bank, with deposits of $121.9
million.
There is minimal competition between the charter
and consolidating banks because of the great distance between them and because an adequate number of alternative banking facilities exist in the area.
The nearest offices of the charter and consolidating
banks are 35 miles apart.
Consummation of the proposed consolidation will
resolve a managerial succession problem at First
National Bank of Monroe County and will offer the
residents and businesses of its service area new and
sophisticated services such as trust services. The
consolidation will also result in a higher lending
limit to satisfy the increasing needs of the farming
and business communities.
Applying the statutory criteria, it is concluded
that the proposed consolidation is in the public interest and this application is, therefore, approved.
JANUARY 25,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the two banks are approximately 36 miles apart, and the closest offices are
more than 30 miles apart. In view of the distance
between the two banks and the fact that they operate
in different counties, it does not appear that the
merger would eliminate significant existing competition.
Both banks, however, could branch de novo into
the area served by the other. Peoples Bank is the
smaller of the two banks operating in Oktibbeha
County, holding 46.5 percent of total county deposits
as of December 31, 1972. Monroe Bank is the largest
of four banks operating in Monroe County, holding
30.5 percent of total county deposits. Several other

larger banks, however, may also be considered to be
potential entrants into these areas. In view of the
existence of other significant potential entrants into

the areas served by the parties to this transaction,
we conclude that the merger will not eliminate substantial potential competition.

THE FIRST NATIONAL BANK OF HANCOCK, HANCOCK, N.Y.,
HAMDEN,

AND THE FIRST NATIONAL BANK OF HAMDEN,

N.Y.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Hamden, Hamden, N.Y. (12017), with
was purchased Mar. 29, 1974, by The First National Bank of Hancock, Hancock, N.Y. (8613)
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On September 14,1973, Hancock National Bank*,
Delaware County, Hancock, N.Y., applied to the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of The
First National Bank of Hamden, Hamden, N.Y.
The First National Bank of Hamden, the selling
bank, with approximately $4 million in deposits, was
chartered in 1921. It is headquartered in the hamlet
of Hamden in the central portion of Delaware
County. The selling bank's primary service area
consists of the townships of Hamden and Walton
which have an approximate population of 7,000.
The selling bank ranks eighth in deposit size of the
10 commercial banks headquartered in Delaware
County. Financial institutions in direct competition
with the selling bank include The National Bank of
Delaware County, Walton, with approximately $17.3
million in deposits; The Delaware National Bank of
Delhi, Delhi, with approximately $14.1 million in deposits; and Delaware County Federal Savings and
Loan Association, Walton, with approximately $33.8
million in assets.
Hancock National Bank, the purchasing bank,
was organized by Charter New York Corporation, a
multi-bank holding company, to effectuate its purchase of The First National Bank of Hamden. Charter New York Corporation proposes to operate The
First National Bank of Hamden as a branch of the
bank resulting from its merger of Hancock National
Bank with The First National Bank of Hancock,
N.Y.
Charter New York Corporation, with total assets
* Hancock National Bank was a non-operating bank merged
with The First National Bank of Hancock under the title of the
latter, just prior to this purchase.

$ 3,572,245

10,363,718
14,164,799

To be
operated

of approximately $7.8 billion, ranks seventh in size
of the 14 multi-bank holding companies in New
York. The largest of its 10 subsidiary banks is Irving
Trust Company, New York City, N.Y., with approximately $5 billion in total assets as of June 30,
1973. The larger New York multi-bank holding companies which compete with Charter New York Corporation include First National City Corporation,
with total assets of approximately $34.3 billion;
Chase Manhattan Corporation, with assets of $28.8
billion; Manufacturers Hanover Corporation, with
total assets of approximately $16.3 billion; Chemical
New York Corporation and Bankers Trust New
York Corporation, each with total assets of approximately $13.4 billion.
The proposed purchase will not adversely affect
competition. The nearest subsidiary office of Charter New York Corporation to The First National
Bank of Hampden is the Binghampton office of Endicott Trust Company which is 60 miles distant.
Furthermore, there is no competition between The
First National Bank of Hamden and The First National Bank of Hancock. Neither bank has any loans
or deposits which have originated from each other's
service area. The Binghampton subsidiary office is
43 miles distant from The First National Bank of
Hancock. The proposed purchase will not change
the relative position of Charter New York Corporation with regard to the other New York bank holding companies. The resulting bank would only rank
fifth in deposit size of the 10 banks in Delaware
County.
Consummation of the proposed purchase will enhance competition. The proposed purchase will remove head office protection in Hamden and open
that community to de novo branching of other banks,

thereby assuring adequate banking services to the
Hamden community. The First National Bank of
Hamden presently provides inadequate services to
area residents due to limited resources and decreasing capital position. As a result of the proposed
transaction, the bank could provide continuing and
expanding banking services including a credit card,
complete trust department services, and agricultural

loan expertise.
Accordingly, applying the statutory criteria, it is
concluded that the proposed transaction is in the
public interest. This application is, therefore, approved.
FEBRUARY 21,

1974.

NOTE: NO Attorney General's report received.

MIDLANTIC NATIONAL BANK, NEWARK, N.J., AND MILLBURN-SHORT HILLS BANK, MILLBURN,

N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Millburn-Short Hills Bank, Millburn, N.J., with
and Midlantic National Bank, Newark, N.J. (1316), which had
merged Mar. 31, 1974, under charter and title of the latter bank (1316). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On August 10, 1973, Millburn-Short Hills Bank,
Millburn, N.J., and Midlantic National Bank, Newark, N.J., applied to the Comptroller of the Currency for permission to merge under the charter
and title of the latter.
Midlantic National Bank, the charter bank, was
organized in 1804 and operates 37 offices with assets
of $968.9 million and IPC deposits of $681.6 million.
The charter bank is the lead bank in Midlantic
Banks, Inc., a multi-bank holding company with
deposits of $1.5 billion. The service area of this bank
includes all of Essex and Warren counties with a
total estimated population of 1.02 million persons.
The charter bank is the second largest bank
among Essex County-based commercial banks and
the third largest bank in deposit size in the State of
New Jersey. Competition is provided by First National State Bank of New Jersey, Newark, with deposits of $1.03 billion, which is the lead bank in First
National State Bancorporation, a multi-bank holding company; and Peoples Trust of New Jersey,
Hackensack, with deposits of $976.6 million, which
is a member of United Jersey Banks, a multi-bank
holding company. Further competition is provided
by all of the State's multi-bank holding companies
with statewide affiliations and by the multi-billion
dollar banks based in nearby New York City.
Millburn-Short Hills Bank, the merging bank, was
chartered in 1960 as a State bank and has operated

49,402,960
1,004,152,034
1,053,554,995

To be
operated

1
38
39

since that time as a unit institution. It presently has
assets of $18.7 million and IPC deposits of $16.5
million. The service area of the merging bank encompasses Millburn Township which has an estimated population of 21,140 persons.
The merging bank ranks 13th in deposit size
among the 18 commercial banks headquartered in
Essex County and competes primarily with First
National State Bank of New Jersey, Newark, also a
competitor of the charter bank; and American National Bank & Trust of New Jersey, Montclair, with
deposits of $369 million, which is the lead bank in
Princeton American Bancorporation, a multi-bank
holding company. Further competition is provided
by The National State Bank, Elizabeth, with deposits of $628 million; Summit and Elizabeth Trust
Company, with deposits of $189 million; United
Counties Trust Company, Elizabeth, with deposits
of $323 million; and Springfield State Bank, Springfield, with deposits of $11 million.
There is minimal competition between the charter
and merging banks because their closest two offices
are separated by a distance of 5 miles with an adequate number of alternative banking facilities operating in the intervening distance. The South
Orange office of the charter bank is also the closest
branch office of any Midlantic Banks, Inc. affiliate.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branch in Millburn will
be able to offer a larger lending limit, student loans,
53

overdraft checking accounts, a wider range of savings plans, installment loan services, and trust services. That will make the resulting branch a far more
viable competitor in the Millburn service area. Furthermore, the competitive hierarchy in the banking
industry in New Jersey will not be significantly altered as Midlantic Banks, Inc. will move from third
to second fn ranking of size among multi-bank holding companies in the State.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest, and
this application is, therefore, approved.
FEBRUARY 20,

1974

SUMMARY OF REPORT BY ATTORNEY GENERAL

The impact of this proposed acquisition will be felt
largely in Millburn Township, situated about 8 miles
from Newark in the sprawling New York-Newark
urban complex. Applicant's nearest offices are located about 5 and 8 miles, respectively, from
Bank's Millburn headquarters, and it appears that
Applicant derives a significant volume of business
from Bank's service area. Thus, the proposed acquisition will eliminate some existing competition in the
Millburn Township area. It does not, however, appear that the proposed merger will substantially
increase concentration in any relevant banking
market.

MIDLANTIC NATIONAL BANK/MORRIS, MORRISTOWN, N.J., AND MIDLANTIC NATIONAL BANK/PARSIPPANY,
PARSIPPANY-TROY HILLS, N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Midlantic National Bank/Parsippany, Parsippany-Troy Hills, N.J. (15975), with
and Midlantic National Bank/Morris, Morristown, N.J. (15360), which had
merged Mar. 31, 1974, under charter and title of the latter bank (15360). The merged bank at
date of merger had

COMPTROLLER S DECISION

On October 4, 1973, Midlantic National Bank/
Morris, Morristown, N.J., and Midlantic National
Bank/Parsippany, Parsippany-Troy Hills, N.J., applied to the Comptroller of the Currency for permission to merge under the charter and with the
title of the former.
Midlantic National Bank/Morris, the charter bank,
was organized in 1964 as Madison National Bank.
The bank, with assets of $12.1 million and IPC deposits of $4.4 million, presently operates three
branches in Morris County.
Midlantic National Bank/Parsippany, the merging
bank, was chartered in 1972 as Midlantic National
Bank. The bank, with assets of $5.3 million and
IPC deposits of $2.9 million, operates one branch in
its home office community.
Both the charter and merging banks are subsidiaries of Midlantic Banks, Inc., a registered bank
holding company which controls aggregate deposits
of $1.4 billion from its eight member banks. Because
the proposed merger is between banks which are
totally owned by Midlantic Banks, Inc., this proposal
will have no effect on this bank holding company's
54

$ 8,997,817
12,315,879
21,313,697

To be
operated

2
4

present competitive position as third among New
Jersey's bank holding companies and will not eliminate any competition.
The primary service area of these two banks is
Morris County. That county, with a population of
383,000 people has shown a steady rate of growth
with considerable industrial development. There are
seven major employers in Morris County, numerous
major highways, and four commercial airports.
Banking competition is adequate because 21
commercial banks are represented in Morris
County, 12 of which are headquartered there. The
resulting bank will have total deposits of $14.8 million, and will rank 18th among commercial banks
in the county. Nine of the competing banks are
members of multi-bank holding companies, those
include subsidiaries of First National State Bancorporation and United Jersey Banks, New Jersey's
two largest bank holding companies.
Consummation of the proposed merger will help
to eliminate earnings problems at both the charter
and merging banks by allowing the resulting bank
to achieve significant operating efficiencies. The
two Midlantic National Bank/Parsippany facilities
will be operated as branches of the Midlantic

National Bank/Morris. There is no present competition between these two banks as they are
separated by 6 miles and adequate banking alternatives intervene.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
FEBRUARY 19,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Both banks are wholly-owned subsidiaries (except for directors' qualifying shares) of Midlantic

Banks, Inc., a multi-bank holding company controlling eight banks holding total deposits of $1.4
billion on December 31, 1972. Morris Bank was
acquired by Midlantic Banks in 1972, and Parsippany Bank was organized de novo by Midlantic
Banks in 1972.
In view of the common ownership of the two
banks, and also because the two banks do not
hold significant market shares in the area in which
they compete (1.8 percent combined of total Morris County commercial bank deposits), we conclude that the proposed transaction would not have
a substantial competitive impact.

DOMINION NATIONAL BANK, BAILEYS CROSS ROADS, VA., AND PEOPLES BANK AND TRUST COMPANY OF
FAIRFAX, FAIRFAX COUNTY, VA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Peoples Bank and Trust Company of Fairfax, Fairfax Countv. Alexandria, Va., with
and Dominion National Bank, Baileys Cross Roads, Va. (14904), which had
merged Apr. 1, 1974, under charter and title of the latter bank (14904). The merged bank
at date of merger had

COMPTROLLER'S DECISION

On October 26, 1973, Dominion National Bank,
Fairfax County, Va., and Peoples Bank and Trust
Company of Fairfax, Fairfax County, Va., applied
to the Comptroller of the Currency for permission
to merge under the charter and with the title of
the former.
Dominion National Bank, the charter bank, was
organized in 1960 and now has assets of $78.5 million and IPC deposits of $64 million. The charter
bank operates 11 offices in Fairfax County and in
the cities of Alexandria and Falls Church. Since
December 1971, Dominion National Bank has been
a wholly-owned subsidiary of Dominion Bankshares Corporation, Roanoke, Va., the fifth largest
banking organization in Virginia, controlling assets
of $969.1 million. That holding company controls
eight subsidiary banks with 71 banking offices in
the State of Virginia; the largest of its subsidiaries
is The First National Exchange Bank of Virginia,
Roanoke, with deposits of $597 million.
Peoples Bank and Trust Company of Fairfax,
the merging bank, was organized in 1963 and now
has assets of $19 million and IPC deposits of $15.6

$ 19,496,742
94,885,747
112,274,685

To be
operated

5
12
17

million. The merging bank operates five offices in
Fairfax County.
Competition in Fairfax County is provided by 23
banks operating 217 banking offices. Twelve of
those banks, with 169 offices, are affiliated with
bank holding companies. The largest of those competitors include First Virginia Bank, Falls Church,
with deposits of $371 million; United Virginia
Bank/First & Citizens National, Alexandria, with
deposits of $244.6 million; Arlington Trust Company, Arlington, with deposits of $198 million; and
Clarendon Bank and Trust Company, Arlington,
with deposits of $200 million.
The main offices of the charter and merging
banks are approximately 10 miles apart with all of
the offices of the two banks separated or circumscribed by numerous competing banks and savings
and loan associations. In general, each bank
serves a separate and distinct area because the
offices of Dominion National Bank are concentrated in the northern and central portions of
Fairfax County and the city of Alexandria, and
those of Peoples Bank and Trust Company are concentrated in the south-central and southeastern portions of Fairfax County. The closest offices of the
55

two banks are the Lincolnia Branch of Dominion
National Bank, located in the Virginia Plaza Shopping Center on the north side of Little River Turnpike, and the Brighton Mall Branch of the merging
bank, located in the Brighton Mall Shopping Center on the south side of the Little River Turnpike.
Although those two branches are located approximately 0.5 mile apart, the heavily-travelled highway which separates them serves as a geographic
barrier. As shopping center branches, each derives
a substantial portion of their business from the retail establishments in their respective shopping
centers as well as regular shoppers and residents
of the areas adjacent to each shopping center.
Thus, while some overlap in the service areas of
the two banks does exist, it is minimal.
Consummation of the proposed merger will
allow the present branches of the merging bank to
become effective competitors in the area which
they now serve. The growth of Peoples Bank and
Trust Company has not kept pace with that of
other banks in Northern Virginia due to its limited
capital base and its restricted lending limit, both
of which will be expanded as a result of this merger. Those branches will be able to offer a greater
variety of sophisticated banking services which,
with added management depth, will further increase their ability to compete. The resulting bank
will serve an expanded trade area and will be a

more viable competitor for the 21 other banks
serving the area.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
FEBRUARY 28,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Dominion Bank's offices are centered in northern Fairfax County and in Alexandria, while Peoples Bank's offices are centered in southern Fairfax County. There is some existing competition
between the two banks, however. Each bank operates one office in the busy commercial area near
the intersection of Virginia Route 236 and Interstate Highway 95. Three other offices of Peoples
Bank are located within 4 miles of one or more
offices of Dominion Bank.
Neither bank, however, is a major factor in
Northern Virginia. Dominion Bank and Peoples
Bank control, respectively, 6.3 percent and 1.5
percent of total commercial bank deposits in Fairfax County, Falls Church, and Alexandria. There
are approximately eight banks larger than Dominion Bank serving this area. Accordingly, we conclude that the effect of the merger on competition would not be significantly adverse.

THE FIRST NATIONAL BANK OF VERSAILLES, VERSAILLES, OHIO, AND THE PEOPLES BANK CO.,
VERSAILLES, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Peoples Bank Co., Versailles, Ohio, with
and The First National Bank of Versailles, Versailles, Ohio (9336), which had
consolidated Apr. 1, 1974, under charter of the latter bank (9336) and title "Peoples National
Bank." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On August 28, 1973, The First National Bank of
Versailles, Versailles, Ohio, and The Peoples
Bank Co., Versailles, Ohio, applied to the Comptroller of the Currency for permission to consolidate under the charter of the former and with the
title "Peoples National Bank."
The First National Bank of Versailles, the charter bank, was originally chartered in 1891 and has
operated as a unit institution since that time with
56

$ 7,274,631
9,719,392
16,994,023

To be
operated

1
1

present assets of $8.1 million and IPC deposits of
$6.3 million. The service area of the charter bank
encompasses the northeastern section of Darke
County, of which Versailles is the principal city
with an estimated population of 2,441 persons, and
extends to Shelby and Miami counties to include
the rural communities of Russia and Bradford.
Of the 10 banks headquartered in Darke County,
the charter bank ranks sixth in deposit size and
ranks 15th in size among the 18 banks in its service area. Principal competitors for the bank in-

elude The Citizens Baughman National Bank, Sidney, with deposits of $35.4 million and The Miami
Citizens National Bank and Trust Company,
Piqua, with deposits of $44.8 million. Further competition is provided by The Citizens Bank Company, Ansonia, with deposits of $5.4 million; The
Osgood State Bank, Osgood, with deposits of $5.8
million; The Citizens State Bank of Greenville,
Ohio, with deposits of $8.7 million; Greenville National Bank, Greenville, with deposits of $26.3
million; and The Second National Bank of Greenville, Ohio, with deposits of $27.4 million.
The Peoples Bank Co., the consolidating bank,
was chartered in 1905 and has operated as a unit
institution since that time with present assets of
$6.7 million and IPC deposits of $5.7 million. The
service area of the consolidating bank is identical
to that of the charter bank.
The consolidating bank ranks eighth in deposit
size of the 10 banks headquartered in Darke
County, and 16th in size among the 18 banks in its
service area. The bank competes directly with the
charter bank and all competitors of the charter
bank since it is physically adjacent to that institution and is the only other commercial bank in Versailles. The resulting bank would rank fourth in
deposit size among Darke County banks and 10th
among service area banks.
The charter bank is by far the more aggressive
of the two subject institutions; it is larger in size,
has a greater lending limit, and a considerably
greater loan-to-deposit ratio. Still, both are small,
conservative institutions and neither has kept pace
with the growth of the Versailles economy.
Although the two subject institutions are the
only commercial banks in the town of Versailles,
keen competition for services such as real estate
mortgage loans, time and savings deposits, and instalment credit is provided by Versailles Savings
and Loan Company and American Budget Company. Thus, consummation of the proposed consolidation will not eliminate alternative sources of
financial services.
In addition to those non-bank competitors, there
are sufficient banking offices located within the
service area of the charter and consolidating banks
and within reasonable distance over good roads to
allow the public several competitive alternatives for
the services they offer. For example, the Russia,
Ohio, branch office of The Citizens Baughman
National Bank is located 3 miles east of Versailles
and actively solicits business and services the small
Versailles community. With approximately 35 percent of the Darke County labor force commuting

outside the county for employment, banks located
along major arteries in the communities of Piqua,
Celina, Covington, and Greenville are also important
competitors for the Versailles banks.
The significance of the competition between the
two subject banks is reduced considerably by the
extremely conservative lending policy of the consolidating bank. The absence of an active instalment loan program at that institution also contributes to the fact that the consolidating bank
makes loans at an overall rate only one-half that of
the charter bank. Consolidation will result in a
lessening of that restrictive attitude.
Effectuation of the proposed consolidation will
result in a much needed increase in management
depth and a better utilization of management expertise. Management at the consolidating bank is
aging with no replacements presently being trained
and management at the charter bank is considerably younger and more aggressive. Combining
those management teams will enable competent
personnel to devote more time to the solicitation of
business and to serving the banking needs of the
resulting bank's customers. The outgrowth of that
greater expertise will be an improvement in the
personal financial leadership by commercial bankers within the community and an increase in the
public benefits of such leadership.
Physical facilities at both banks have been remodeled recently but remain cramped and overcrowded, creating poor working conditions. Both
managements and boards of directors have been
aware of the problems for several years but recent
earnings have precluded financing any solution.
Upon consummation of the proposed consolidation,
the resulting bank will have the capacity to modernize its offices and to begin construction of a
new, customer-oriented commercial bank in downtown Versailles.
Consolidation of the charter and consolidating
banks will result in the offering of several improved and expanded services including higher interest rates on savings accounts, more frequent
compounding of savings interest, fully automated
processing of all types of accounts, and additional
drive-in facilities. Further, improvements in operational standards will free employees to deal with
customers on a more personal level, resulting in
heightened customer satisfaction.
Consummation of the proposed transaction appears likely to have a pro-competitive effect by
stimulating larger commercial banks in the area to
apply for branch offices in Versailles. While the
major banks located in the relevant service area

present a competitive threat at present, permission
to branch inside Versailles under current conditions would not likely be granted. Consolidation
will convert a small, two-bank town, which is unable to support a new entrant, into a town with
one stronger commercial bank able to tolerate
intensified competition. Regulatory authorities will
be more favorably disposed to entertain applications for new branch banking offices in such a
community.
Because both the charter and consolidating
banks are located in a small community, a significant percentage of the local population holds stock
in these institutions. Few of those stockholders own
shares in both banks and none holds a majority in
either. Thus, any improvement in the financial
condition of the two subject banks is a boon to the
inhabitants of the community, not only as customers, but also as interested investors in the institutions.
Consummation of the proposed consolidation
will result in further benefit by allowing an increased lending limit more in keeping with the
needs of the community. In recent years both
banks have been unable to service the financial
requirements of the large agricultural segment of
the area economy, thus forcing local businessmen
and farmers to turn to other financial institutions
in- and outside of Darke County. Also, consolidation will enable the stronger resulting bank to hold
itself available for participations with other banks
on local business, an opportunity it is presently
denied. At the same time, the consolidation will
create the capacity in the resulting bank to service other community businesses on a strictly local basis. Finally, significant ramifications of a
larger lending limit include the attraction of new

businesses to the Versailles area and the presence
of the heretofore lacking capability to loan funds
to the town government for municipal improvements. On balance, this transaction will result in
better banking for the area.
Applying the statutory criteria, it is concluded
that the proposed consolidation is in the public interest, and this application is, therefore, approved.
JANUARY 17,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First Bank and Peoples Bank are located next
door to each other in Versailles, and are the only
two banks in that community. The closest banking office to Versailles is The Citizens Baughman
National Bank, Sidney, Ohio which operates a
branch in Russia, about 5 miles east of Versailles,
in Mercer County. About 10 banks operate offices
within 15 miles of Versailles, among them two
banks in Greenville, each holding total deposits in
excess of $25 million. There is probably some
competition between the Versailles banks and
these other nearby banks.
The application does not make clear the extent
to which other banks in the general vicinity draw
deposits from, or make loans to, customers in the
immediate Versailles area. However, in view of the
importance of customer convenience in commercial banking, we conclude that the proposed merger would have significantly adverse competitive
effects in the Versailles area. To the extent that
the application argues that the merger will bring
competitive and other benefits to the communities
to be served, comparable benefits might be
achieved by affiliation with a bank holding company not already competing in Darke County.

MARYLAND NATIONAL BANK, BALTIMORE, MD., AND EUTAW SAVINGS BANK OF BALTIMORE,
BALTIMORE, MD.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Eutaw Savings Bank of Baltimore, Baltimore, Md., with
was purchased Apr. 11, 1974, by Maryland National Bank, Baltimore, Md. (13746), which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On April 11, 1974, application was made to the
Comptroller of the Currency by the Maryland National Bank, Baltimore, Md., for permission to purchase the assets and assume deposit liabilities of the
Eutaw Savings Bank of Baltimore, Baltimore, Md.
In accordance with the provisions of 12 U.S.C.
1828(c)(6), it is found that an emergency exists and
that this Office must act immediately to prevent the

$ 128,826,293
1,810,246,603
1,938,200,461

To be
operated

7
123
130

probable failure of the Eutaw Savings Bank of Baltimore, and to protect its depositors and creditors.
Accordingly, the application of the Maryland
National Bank to purchase the assets and assume
the deposit liability of the Eutaw Savings Bank of
Baltimore, is approved.
APRIL 11,

1974.

NOTE: Due to the emergency nature of the situation, no report on competitive factors was requested.

THE BARABOO NATIONAL BANK, BARABOO, WIS., AND FARMERS STATE BANK, ROCK SPRINGS, WIS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Farmers State Bank, Rock Springs, Wis., with
was purchased Apr. 12, 1974, by The Baraboo National Bank, Baraboo, Wis. (14397), which
had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On November 1, 1973, The Baraboo National
Bank, Baraboo, Wis., applied to the Comptroller of
the Currency for permission to purchase the assets
and assume the liabilities of Farmers State Bank,
Rock Springs, Wis.
The Baraboo National Bank, Baraboo, Wis., the
purchasing bank, was organized in 1857 and now,
with assets of $30.9 million and IPC deposits of
$25.6 million, operates one branch office. The
service area of the bank includes the town of Baraboo and peripheral rural areas with an estimated
total population of 8,000 persons. The economy of
Baraboo is supported by a mixture of light and heavy
industry, retail commerce, tourism, and agriculture.
The purchasing bank is now the larger of two
banks located in the town of Baraboo. It competes
directly with The First National Bank and Trust

$ 2,061,633

35,032,916
34,974,525

To be
operated

Company of Baraboo, which has deposits of $12.2
million.
Farmers State Bank, Rock Springs, Wis., the
selling bank, was organized in 1912 and has operated
since that time as a unit institution. It currently has
assets of $1.9 million and IPC deposits of $1.7
million. The service area of the selling bank includes
the community of Rock Springs and surrounding
areas within a 3- to 8-mile radius, including the
towns of Reedsburg, Loganville, and North Freedom. Economic activity in the Rock Springs area is
centered primarily on dairy farming and such other
agricultural pursuits as cash cropping and feed lot
operations.
Principal competitors of the selling bank are The
Reedsburg Bank and its branch at North Freedom,
with total deposits of $22.2 million, and Farmers and
Merchants Bank of Reedsburg and its branch at
Loganville, with total deposits of $17 million.

There is minimal competition between the purchasing and selling institutions because their two
closest offices are separated by a distance of 8 miles
and because the small size of the geographical area
served by the selling bank prevents it from being a
significant competitor for the purchasing bank.
Also, an adequate number of alternative banking
facilities operate in the area.
Consummation of the proposed purchase would
provide the area now served by Farmers State Bank
with expanded banking services, including an increased lending limit, trust department services,
consumer installment loans, family financial counseling, and a specialized farm loan officer. In addition, plans include the building of a new banking
facility in Rock Springs which would be more convenient for customers than the existing antiquated
structure.
Accordingly, it is the conclusion of this Office
that the proposed transaction is in the public interest

and this application is, therefore, approved.
MARCH 11,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The offices of the parties to the instant transaction are approximately 8 miles apart with one competitive alternative in the intervening community of
North Freedom. According to the application,
neither bank draws substantial deposit or loan business from the immediate service area of the other.
It does not appear that the proposed transaction
would eliminate substantial existing competition.
Restrictions on branching and the nature of the
community in which Bank is located indicate that
the prospects for additional branching in that area
by Applicant are not great.
Thus, although the proposed transaction would
slightly increase concentration in commercial banking in Sauk County, we do not believe that its overall
competitive effect would be significantly adverse.

BANKERS TRUST OF SOUTH CAROLINA, N.A., COLUMBIA, S.C., AND THE PEOPLES BANK, BEAUFORT, S.C.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Peoples Bank, Beaufort, S . C , with
and Bankers Trust of South Carolina, N.A., Columbia, S.C. (10635), which had
merged Apr. 22, 1974, under charter and title of the latter bank (10635). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On November 8, 1973, The Peoples Bank, Beaufort, S . C , and Bankers Trust of South Carolina,
N.A., Columbia, S . C , applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
Bankers Trust of South Carolina, the charter
bank, was organized in 1886 and now, with assets of
$479.6 million and IPC deposits of $342.2 million,
operates 78 branch offices. The service area of the
bank includes 35 communities throughout the State,
with the heaviest concentration in the central, westcentral, and northwestern sections of the State.
Operating a statewide system of branch offices,
Bankers Trust of South Carolina serves a complete
cross-section of the State's economic strata.
The charter bank is now the third largest commercial bank in the State and competes primarily

$ 33,698,335
519,892,860
553,591,195

To be
operated

6
83
89

with The South Carolina National Bank, Charleston,
with deposits of $702.6 million; The Citizens and
Southern National Bank of South Carolina, Charleston, with deposits of $418 million; First National
Bank of South Carolina, Columbia, with deposits of
$335.6 million; and First-Citizens Bank and Trust
Company of South Carolina, Columbia, with deposits of $135 million.
The Peoples Bank, the merging bank, was organized in 1902 and now, with assets of $34.6 million
and IPC deposits of $27.8 million, operates five
branch offices. The merging bank is located in
Beaufort County and its service area includes the
city of Beaufort, Parris Island, and Hilton Head
Island, all of which are located within Beaufort
County. The Beaufort County economy has, for
many years, been heavily dependent upon extensive
military operations; limited light industry, truck
farming, commercial fishing, tourism, and residen-

tial resort development comprise the remaining
economic base.
The merging bank is the largest of three commercial banks headquartered in Beaufort County and
competes primarily with the Bank of Beaufort, with
deposits of $23.4 million, and The First Carolina
Bank, Yemassee, with deposits of $4.8 million.
There is no competition between the charter and
merging banks because their closest two offices are
separated by relatively large distances and an adequate number of alternative banking facilities operate in the intervening distance. The closest offices
of the two banks are approximately 69 miles apart,
and the small size of the merging bank prevents it
from being a significant competitor for the charter
bank.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branch in Beaufort will
offer a more complete line of banking services and
facilities to include expanded lending limits and
improved trust services. That will generally improve
the bank's quality of operation and contribute to
the area's appeal for increased and diversified industrial development. In addition, the proposed merger
will favorably resolve a number of serious management problems experienced by the merging bank.
The resulting bank will remain the third largest
commercial bank in South Carolina.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
MARCH 19,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The head offices of the respective banks are about
112 miles from each other. The nearest offices of
Bankers Trust—in the Charleston area—are approximately 70 miles from the nearest office of Peoples
Bank. The amount of direct competition that would
be eliminated by the proposed acquisition would be
de minimis.
Beaufort County is served by three local independent banks of which Peoples Bank is the largest.
Total deposits in the county as of December 31,
1972 were $57.4 million. Peoples Bank held total
deposits of $29.2 million, or 50.7 percent of county
deposits.
Of the some 95 banking organizations in South
Carolina, the five largest currently hold 60.1 percent
of the total deposits in the State. Consummation of
the proposed acquisition would raise this ratio to 60.9
percent. There are at present seven banks in the
State with deposits in excess of $100 million. Five
of these operate offices throughout the major portions of the State and may be considered significant
potential entrants into Beaufort County to the extent
its present rate of economic expansion would support such new entry.
Bankers Trust, as the third largest bank in the
State, with approximately 11.6 percent of total State
deposits, is among the significant potential entrants
into Beaufort County. Its entry into the county
through the acquisition of Peoples Bank, the largest
in the county and also relatively prosperous, will
have some adverse effects on potential competition.

THE FIRST NATIONAL BANK OF JASPER, JASPER, ALA., AND DORA BANKING AND TRUST COMPANY,
DORA, ALA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Dora Banking and Trust Company, Dora, Ala., with
and The First National Bank of Jasper, Jasper, Ala. (7746), which had
consolidated Apr. 30, 1974, under charter and title of the latter bank (7746). The consolidated
bank at date of consolidation had

COMPTROLLER'S DECISION

On November 9, 1973, The First National Bank of
Jasper, Jasper, Ala., and Dora Banking and Trust
Company, Dora, Ala., applied to the Comptroller of
the Currency for permission to consolidate under the
charter and with the title of the former.

$ 7,334,748
52,221,754
59,584,573

To be
operated

1
3
4

The First National Bank of Jasper, the charter
bank, was organized in 1905, and operates two
branch offices. It possesses total assets of $46.1
million and IPC deposits of $33.7 million. The
service area of the bank encompasses western
Walker County, an industrial and rural area. Local
competitors of the charter bank include Walker

County Bank, with deposits of $13.5 million; Bank
of Carbon Hill, with deposits of $5.5 million; Bank
of Parrish, with deposits of $5.3 million; and Cordova Citizens Bank, with deposits of $4.1 million.
Dora Banking and Trust Company, the consolidating bank, was organized in 1906 and operates as a
unit institution. It has total assets of $6.5 million
and IPC deposits of $5.3 million. The consolidating
bank serves the eastern section of Walker County
and a small portion of Jefferson County, an economically depressed rural area where many of the residents commute to employment in Birmingham.
Local competitors of the consolidating bank include
a branch of The First National Bank of Birmingham,
with branch deposits of $8.5 million, and Sumiton
Bank, with deposits of $4.3 million.
While competition between the subject banks is
minimal because the eastern and western portions
of Walker County are divided by the Warrior River,
they both feel the competitive impact of the large
Birmingham banks which canvass their area.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
competition will be enhanced in eastern Walker
County because the management succession problems of the consolidating bank will be resolved and
because increased and more efficient services will
be offered, for example, a larger lending limit,
expanded loan policies, and higher interest rates on

time and savings deposits.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
MARCH 6,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The communities of Jasper and Dora are both
located in Walker County, at a distance of approximately 15 miles. According to the application, First
National, the largest bank in the county, draws a
minor percentage of its deposit and loan business
from the eastern part of the county where Dora
Bank's service area is located. However, these
deposits appear more substantial when compared to
the total banking business done by Dora Bank. Thus,
the proposed transaction would eliminate some
existing competition and increase concentration in
commercial banking in Walker County. These
effects may be lessened by the fact that Dora is
approximately as close to the city of Birmingham
and its environs as it is to Jasper, and the Warrior
River provides a natural barrier, which, according
to the application, limits commercial intercourse
between the eastern and western sections of the
county.

THE PEOPLES NATIONAL BANK AND TRUST COMPANY OF WASHINGTON, WASHINGTON, IND., AND FARMERS
STATE BANK, PLAINVILLE, IND.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Farmers State Bank, Plainville, Ind., with
and The Peoples National Bank and Trust Company of Washington, Washington, Ind. (3842),
which had . . . . . . . . . . . . . . _ .
merged Apr. 30, 1974, under charter and title of the latter bank (3842). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On January 3, 1974, The Peoples National Bank
and Trust Company of Washington, Washington,
Ind., and Farmers State Bank, Plainville, Ind.,
applied to the Comptroller of the Currency for permission to merge under the charter and with the
title of the former.
The Peoples National Bank and Trust Company
of Washington, the charter bank, was organized in

To be
operated

% 1,876,645
24,867,345
26,682,905

1888 and presently, with total assets of $23.1 million
and IPC deposits of $19.5 million, operates one
drive-in branch. It is the largest of six banks in
Daviess County, the service area of the charter
bank. Agriculture comprises the basis for the economy of the service area.
Direct competition for the charter bank is provided by the three other banks located in Washington: Citizens Bank and Trust Company, with deposits of $19.3 million; State Bank of Washington,

with deposits of $12.3 million; and Washington
National Bank, with deposits of $12.3 million.
Farmers State Bank, the merging bank, was organized in 1908 and presently operates a single office
with total assets of $2.1 million and IPC deposits of
$1.7 million. Because of its relatively small size and
scope of operations, the merging bank's service area
is limited to the immediate vicinity of Plainville
where it is the only bank. The economy of this
service area is based on agriculture.
There is only minimal competition between the
charter and merging banks because of the distance
between them. The charter and merging banks are
located 11 miles apart. Even though the small
service area of the merging bank comprises a minor
portion of the service area of the charter bank, the
merging bank is not an effective competitor for the
charter bank because of its size, lack of aggressiveness, and isolated location.
Consummation of the proposed merger will
resolve the acute management succession problem
of the merging bank and enable the resulting bank
to provide new and improved services to the residents of Plainville such as a larger lending limit, a
greater variety of time deposits, trust services, real
estate mortgage loans, and automated bookkeeping
for demand deposits including monthly statements.

The resulting bank will remain the largest bank in
Daviess County but only by a small margin. Therefore, the resulting bank will have little, if any,
advantage over its nearest competition in economy
of operation and scope of services.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
MARCH 29,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The banks are located 10 miles apart, with no
banking offices intervening. Thus, there is probably
some competition between the two which would be
eliminated by the merger. Six commercial banks
presently operate in Daviess County. Peoples Bank
is the largest of these, holding 28.3 percent of total
county commercial bank deposits. Farmers Bank is
the smallest bank in the county, holding 2.5 percent.
Thus, the resulting bank would increase its leading
share of Daviess County deposits to 30.8 percent.
Competition between these two banks may be
limited by the distance which separates them and by
Farmers Bank's small size; however, the proposed
merger would probably have some adverse competitive effect.

FIDELITY NATIONAL BANK, HALIFAX COUNTY, VA., AND THE HALIFAX BRANCH OF THE FIDELITY NATIONAL
BANK, LYNCHBURG, VA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Halifax Branch of The Fidelity National Bank, Lynchburg, Va. (1522), with
was purchased May 1, 1974, by Fidelity National Bank, Halifax County, Va. (16313), which had.
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On December 7, 1973, Fidelity National Bank,
Halifax County, Va., applied to the Comptroller of
the Currency for permission to purchase the assets
and assume the liabilities of the Halifax Branch of
The Fidelity National Bank, Lynchburg, Va.
Fidelity National Bank, Halifax County, Va., the
purchasing bank, is a new National banking association in the process of organization. The proposed
location of the main office of the purchasing bank is
the Centerville area of Halifax County, midway be

$20,681,724
2,000,000
22,681,724

To be
operated

1
0
2

tween South Boston and Halifax. Fidelity American
Bankshares. Inc., Lynchburg, a registered multibank holding company, has submitted an application
to the Board of Governors of the Federal Reserve
System for permission to acquire all the voting
shares, except for directors' qualifying shares, of the
purchasing bank. The Board of Governors of the
Federal Reserve System announced its approval of
that application on September 24, 1973.
The Fidelity National Bank, Lynchburg, the
selling bank, with assets of $20.6 million and IPC
deposits of $19.9 million, desires to sell its existing

Halifax branch to the purchasing bank. Fidelity
American Bankshares, Inc., presently owns a controlling interest in the selling bank.
Since both the purchasing and selling banks are
owned by the same bank holding company, Fidelity
American Bankshares, Inc., the proposed transaction essentially constitutes an internal corporate
reorganization. As a wholly-owned subsidiary of
Fidelity American Bankshares, Inc., the purchasing
bank would be able to establish branch offices
throughout Halifax County under Virginia law. The
purchasing bank will conduct the same banking
business at the same location as presently used by
the selling bank.

Applying the statutory criteria, it is concluded
that the proposed transaction is in the public interest
and this application is, therefore, approved.
MARCH 11,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed transaction is part of a plan through
which the Halifax Branch of The Fidelity National
Bank would be transferred to a newly organized
bank. Since both the transferring bank and the
acquiring bank are subsidiaries of Fidelity American
Bankshares, Inc., a bank holding company, the proposed transaction is simply a corporate reorganization and would have no competitive effect.

THE FULTON NATIONAL BANK OF LANCASTER, P A . , AND THE HUMMELSTOWN NATIONAL BANK,
HUMMELSTOWN, P A .

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Hummelstown National Bank, Hummelstown, Pa. (2822), with
and The Fulton National Bank of Lancaster, Lancaster, Pa. (2634), which had
merged May 10,1974, under charter and title of the latter bank (2634). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On November 28, 1973, The Hummelstown National Bank, Hummelstown, Pa., and The Fulton
National Bank of Lancaster, Lancaster, Pa., applied
to the Comptroller of the Currency for permission to
merge under the charter and title of the latter.
The Fulton National Bank of Lancaster, the
charter bank, was organized in 1882 and, with assets
of $224 million and IPC deposits of $178 million,
operates 13 branch offices. The service area of the
bank consists of the northern three-quarters of Lancaster County and southwestern Dauphin County,
including the city of Harrisburg. The strong economy
of that service area is supported by a wide array of
industry and commerce combined with the agricultural activities in Lancaster County.
The charter bank ranks fifth in size in the very
active banking community of Lancaster and the surrounding counties. Competition is provided by the
$745 million deposit American Bank and Trust Company, Reading, Pa.; the $684 million deposit National Central Bank, Lancaster, Pa.; the $455 million
deposit Commonwealth National Bank, Harrisburg,
Pa.; the $300 million deposit Dauphin Deposit Trust

$ 19,652,739
255,255,958
274,908,698

To be
operated

2
15
17

Company, Harrisburg, Pa.; and 20 other commercial
banks.
The Hummelstown National Bank, the merging
bank, was organized in 1868 and, with assets of
almost $19 million and IPC deposits of over $16
million, operates one branch office. The bank has
placed emphasis on serving the local community of
Hummelstown, a residential and farming area,
located on the fringe of Harrisburg, Pa.
The merging bank ranks 20th among the 25 banks
competing in this area. Although growth has been
slow, the bank has continued to operate profitably
and is in sound condition. A key figure in the bank's
management, however, is in ill health and is expected to retire in the near future.
Competition in the service areas of the two banks
involved will not be detrimentally affected by this
proposal despite the fact that they operate in an area
dominated by the same group of commercial banks.
The resulting bank will be more able to compete
with the four larger banks in this service area and
the merging bank, which will become a branch of the
charter bank, will be able to draw from the managerial resources of the charter bank.
Applying the statutory criteria, it is the conclusion

of this Office that the proposed merger will result in
no adverse competitive effects and will benefit the
public interest. This application is, therefore,
approved.
APRIL 9,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

While the main offices of Fulton Bank and Hummelstown Bank are over 25 miles apart, both banks

operate offices in the Greater Harrisburg Area.
Thus, the proposed merger would eliminate at least
some existing competition. However, it does not
appear that the proposed merger would substantially
increase concentration in any relevant geographic
market. Fulton Bank is one of the larger banks
legally capable of expanding its operations in
Dauphin County, but its acquisition of the relatively
small Hummelstown Bank would not appear to eliminate substantial potential competition.

NORTH CAROLINA NATIONAL BANK, CHARLOTTE, N.C., AND THE FIRST NATIONAL BANK OF MOUNT AIRY,
MOUNT AIRY, N.C.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

$ 19,174,569
The First National Bank of Mount Airy, Mount Airy, N.C. (4896), with
and North Carolina National Bank, Charlotte, N.C. (13761), which had
3,109,145,446
merged May 17, 1974, under charter and title of the latter bank (13761). The merged bank at
3,128,334,357
date of merger had

COMPTROLLER'S DECISION

On September 17, 1973, North Carolina National
Bank, Charlotte, N . C , and The First National Bank
of Mount Airy, Mount Airy, N . C , applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
The First National Bank of Mount Airy, the merging bank, was organized in 1893, and operates two
branch offices and one seasonal facility. With total
assets of $21 million and IPC deposits of $16.7
million, it ranks 37th among the 87 banks located in
North Carolina. The service area of the bank encompasses the eastern and northern portions of Surry
County, a marketing and agricultural area, and a
small portion of mountainous southern Virginia.
Approximately 50,000 people reside in that area.
The primary competitors of the merging bank
include branches of The Northwestern Bank, which
has deposits of $791 million, and a branch of
Planters National Bank and Trust Company, which
has deposits of $176.8 million. In addition, First
Citizens Bank and Trust Company, which has
deposits of $867 million, has received approval to
open a branch in Mount Airy.
North Carolina National Bank, the charter bank,
was organized in 1933 and operates 148 domestic
branches and two foreign branches. With total

To be
operated

4
149
153

assets of $3 billion and IPC deposits of $1.5 billion,
it is the second largest bank in North Carolina. Its
service area encompasses portions of the entire
State of North Carolina.
Competitors for the charter bank include Wachovia Bank and Trust Company, N.A., with
deposits of $2 billion; First Union National Bank of
North Carolina, with deposits of $1.3 billion; First
Citizens Bank and Trust Company; and the Northwestern Bank.
Direct competition between the subject banks is
minimal since their closest offices are separated by
a distance of approximately 36 miles. Few common
customers exist and the bulk of the charter bank's
business from the service area of the merging bank
is of "National account" character or is generated
through a dealer relationship.
Consummation of the proposed transaction will
result in no adverse competitive effects. Competition within the service area of the merging bank will
be enhanced through the input of aggressive management personnel and policies and through the
establishment of new and expanded services such as
accounts receivable loans, an agricultural business
department, certificates of deposit, correspondent
bank facilities, equipment loans, estate planning, an
international department, letters of credit, and trust
services.
65

Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
MARCH 5,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are located about
36 road miles apart with several banking offices in

the intervening area. Thus, it appears that the proposed transaction would eliminate only a limited
amount of existing competition. Although NCNB
could legally establish de novo offices in Surry
County, the effects of this transaction on potential
competition are diminished somewhat by the existence of other significant potential entrants. The
proposed merger would also slightly increase statewide concentration of commercial banking in North
Carolina, where the four largest banks, as of December 31, 1972, held more than 60 percent of statewide
deposits.

THE ST. LAWRENCE NATIONAL BANK, CANTON, N.Y., AND LEWIS COUNTY TRUST COMPANY,
LOWVILLE, N.Y.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Lewis County Trust Company, Lowville, N.Y., with
and The St. Lawrence National Bank, Canton, N.Y. (8531), which had
merged May 17,1974, under charter and title of the latter bank (8531). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On January 23, 1974, Lewis County Trust Company, Lowville, N.Y., and The St. Lawrence National Bank, Canton, N.Y., applied to the Comptroller of the Currency for permission to merge under
the charter and with the title of the latter.
Lewis County Trust Company, the merging bank,
was established in 1863 and operates one branch
office in Lewis County and one on the eastern border
of Jefferson County. With total assets of $24.2 million and IPC deposits of $17.3 million, it ranks sixth
in size among the 19 commercial banks headquartered in the Fifth Banking District. The economy of
the service area is dependent on a variety of influences including mining, manufacturing, agriculture,
and retailing.
Competitors for the merging bank include Marine
Midland Bank-Northern, with deposits of $168
million, a member of Marine Midland Banks, Inc.;
The National Bank of Northern New York, with
deposits of $118 million; Seaway National Bank,
with deposits of $11.3 million; and The Lyons Falls
National Bank, with deposits of $3.7 million.
The St. Lawrence National Bank, the charter
bank, was established in 1866 and operates 10
branch offices in St. Lawrence County and one
branch office each in Lewis and Jefferson counties.
66

$ 26,017,160
79,901,518
107,033,826

To be
operated

3
13
16

With total assets of $73.8 million and IPC deposits
of $53.9 million, it ranks third in size among the 19
commercial banks headquartered in the Fifth Banking District. The economy of the service area is
diversified and includes mining, higher education,
agriculture, and retailing.
Competitors for the charter bank include Marine
Midland Bank-Northern, The National Bank of
Northern New York, and Farmers National Bank of
Malone which, with deposits of $41 million, is a
member of Bankers Trust New York Corporation.
Competition between the subject banks is negligible since their closest offices are separated by a
distance of approximately 12 miles and their other
offices are separated by a distance of at least 20
miles.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather, the
resulting bank will provide more effective competition for the larger banks in the area by providing
improved and expanded services such as a larger
lending limit, more competitive interest rates on
time deposits, expanded trust department, investment advisory services, and data processing services. In addition, the "head office protection" that
exists in Lowville will be removed thus allowing de
novo branching into that community by other banks.
Applying the statutory criteria, it is the conclusion

of this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
APRIL 1,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

St. Lawrence Bank's newly opened (December
1973) de novo branch in Black River is located about
13 miles from the nearest Lewis Trust office. No
other St. Lawrence Bank offices are situated within
25 miles of Lewis Trust. Thus, it does not appear

that the proposed transaction will eliminate substantial existing competition between the parties or
significantly increase concentration in any relevant
banking market. St. Lawrence Bank is one of the
larger banks in New York's Fifth Banking District,
and already serves many of its local markets. Although the proposed transaction may eliminate some
potential for increased competition between the
parties, the existence of other significant potential
entrants into the areas served by these banks indicates that the overall competitive effect of this transaction would not be significantly adverse.

PENNSYLVANIA NATIONAL BANK AND TRUST COMPANY, POTTSVILLE PA., AND THE DIME BANK OF
LANSFORD, LANSFORD, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Dime Bank of Lansford, Lansford, Pa., with
and Pennsylvania National Bank and Trust Company, Pottsville, Pa. (1663), which had
merged May 31, 1974, under charter and title of the latter bank (1663). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On December 3, 1973, The Dime Bank of Lansford, Lansford, Pa., and Pennsylvania National
Bank and Trust Company, Pottsville, Pa., applied to
the Comptroller of the Currency for permission to
merge under the charter and with the title of the
latter.
Pennsylvania National Bank and Trust Company,
the charter bank, was organized in 1866 and presently operates 17 branches. It has total assets of
$182 million and IPC deposits of $160 million. The
service area of the charter bank encompasses all of
Schuylkill County, south-central Northumberland
County, southwestern Dauphin County, and the
extreme southern tip of Columbia County. The economy of that area depends upon a variety of light and
medium industries.
The charter bank ranks 10th in size among the
banks in its service area and competes primarily
with American Bank and Trust Company, Reading,
with deposits of $717 million; National Central Bank,
Lancaster, with deposits of $684 million; Northeastern National Bank of Pennsylvania, Scranton, with
deposits of $383 million; First Valley Bank, Lansford, with deposits of $320 million; First National

$ 10,719,813
206,100,697
216,877,111

To be
operated

1
18
19

Bank of Eastern Pennsylvania, Wilkes-Barre, with
deposits of $304 million; Commonwealth National
Bank, Harrisburg, with deposits of $300 million;
Merchants National Bank of Allentown, with deposits of $272 million; Fulton National Bank, Lancaster,
with deposits of $199 million; and Cumberland
County National Bank, New Cumberland, with
deposits of $155 million.
The Dime Bank of Lansford, the merging bank,
was organized in 1912 and presently operates a
single office. It has total assets of $9.9 million and
IPC deposits of $8.8 million. The service area of the
merging bank is confined to a region known as Panther Creek Valley, a long narrow valley including the
communities of Coaldale, Lansford, Nesquehoning,
and Summit Hill. The economy of that area is based
upon a wide array of light manufacturing and textiles.
Direct competition for the merging bank in Panther Creek Valley is provided by American Bank
and Trust Company of Pennsylvania, Reading, with
deposits of $717 million, and First Valley Bank,
Lansford, with deposits of $320 million.
There is only minimal competition between the
charter and merging banks. Although the nearest
office of the charter bank is located in Tamaqua, 5
67

miles west of Lansford, because of its limited resources and unaggressive management, the merging
bank has confined its limited services to Panther
Creek Valley.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the branch in Lansford will offer new
and improved services such as a substantially increased lending limit, increased rates on time
deposits, 90-day passbook savings, a credit card
plan, and trust services. The merging bank will also
be able to alleviate its acute management succession
problem by availing itself of the charter bank's
management expertise.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
APRIL 23,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Pennsylvania Bank's office nearest Dime Bank is
located in Tamaqua, Schuylkill County, about 5
miles southwest of Lansford. There is one competitive alternative in the intervening community of
Coaldale. Thus, some existing competition will be
eliminated as a result of the proposed merger. However, it does not appear that the proposed transaction would substantially increase concentration in
any relevant banking market.
Although Pennsylvania Bank could legally establish de novo offices in Carbon County, the relatively
small absolute size of Dime Bank and the existence
of other potential entrants diminish the effect of the
proposed merger on potential competition.
Therefore, we conclude that the proposed transaction would not have a substantial competitive
impact.

PEOPLES NATIONAL BANK OF MONMOUTH COUNTY, HAZLET TOWNSHIP, N.J.,
MADISON TOWNSHIP,

AND MADISON STATE BANK,

N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Madison State Bank, Madison Township, N.J., with
and Peoples National Bank of Monmouth County, Hazlet Township, N.J. (4147), which had . .
merged May 31, 1974, under charter of the latter bank (4147), and title "United Jersey Bank/
Mid State, National Association." The merged bank at date of merger had

COMPTROLLER'S DECISION

On January 22, 1974, Madison State Bank, Madison Township, N.J., and Peoples National Bank of
Monmouth County, Hazlet Township, N.J., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title "United Jersey Bank/Mid State, National Association."
Peoples National Bank of Monmouth County, the
charter bank, was organized in 1889 and presently is
a member of United Jersey Banks, Princeton, a
registered bank holding company. With total assets
of $66.6 million and IPC deposits of $41.1 million,
the charter bank operates 11 branches from which
it serves the northern portion of Monmouth County.
The economy of that area is based on agriculture
and recreational activity.
Competition for the charter bank is provided by
New Jersey National Bank, Trenton, with deposits
of $485 million, which is a member of New Jersey

$ 9,895,881
72,047,509
83,449,286

To be
operated

3
12

National Corporation; The Central Jersey Bank and
Trust Company, Freehold Township, with deposits
of $360 million; United Counties Trust Company,
Elizabeth, with deposits of $329 million; Colonial
First National Bank, Red Bank, with deposits of
$294 million; Franklin State Bank, Franklin Township, with deposits of $202 million; and Community
State Bank and Trust Company, Linden, with
deposits of $103 million.
Madison State Bank, the merging bank, was
organized in 1968, became a member of United
Jersey Banks in 1972, and presently, with total
assets of $10.9 million and IPC deposits of $7.2
million, operates one branch office. The primary
service area of the merging bank encompasses all of
Madison Township, a largely residential area in
which industrial development has not been encouraged.
Competition for the merging bank is provided by
The Central Jersey Bank and Trust Company, Freehold Township, with deposits of $360 million; Frank-

lin State Bank, Franklin Township, with deposits of
$202 million; The National Bank of New Jersey,
New Brunswick, with deposits of $177 million, which
is a member of Fidelity Union Bancorporation; First
Charter National Bank, Monroe Township, with
deposits of $129 million, which is a member of Heritage Bancorporation; Amboy-Madison National
Bank, Madison Township, with deposits of $66 million; and Midlantic National Bank/Raritan Valley,
Edison, with deposits of $51 million, which is a
member of Midlantic Banks, Inc.
Although the primary service areas of the charter
and merging banks are adjacent, competition between the two banks is insignificant because of the
distance between them and the existence of an adequate number of alternative banking facilities in the
intervening area. The nearest offices of the two
banks are located 7 miles apart.
Consummation of the proposed merger will stimu-

late competition in the service area of the merging
bank because the resulting branches in Madison
Township will offer new and improved services such
as an increased lending limit and commercial and
municipal loans. The resulting bank will remain the
fourth largest of the nine banks headquartered in
Monmouth County.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
APRIL 25,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The merging banks are both majority-owned subsidiaries of the same registered bank holding company. As such, their proposed merger is essentially
a corporate reorganization and would have no effect
on competition.

THE NATIONAL BANK OF JACKSON, JACKSON, MICH., AND THE FARMERS STATE BANK OF CONCORD,
CONCORD, MICH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Farmers State Bank of Concord, Concord, Mich., with
and The National Bank of Jackson, Jackson, Mich. (13741), which had
merged May 31, 1974, under charter and title of the latter bank (13741). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On January 27, 1974, The Farmers State Bank of
Concord, Concord, Mich., and The National Bank
of Jackson, Jackson, Mich., applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Farmers State Bank of Concord, the merging
bank, was chartered in 1884 and operates as a unit
institution. It has total assets of $7.1 million and IPC
deposits of $6 million. The service area of the bank
encompasses Concord and Pulaski townships and
the western portions of Spring Arbor and Hanover
townships, which are changing in nature from agricultural to rural-residential. Competitors of the
merging bank include branches of City Bank and
Trust Company, N.A., Jackson, with deposits of
$171.3 million; several branches of Litchfield State
Savings Bank, with deposits of $18.5 million; and
Bank of Albion, with deposits of $9.1 million.

% 7,553,765
172,221,639
179,775,404

To be
operated

1
13
14

The National Bank of Jackson, the charter bank,
was organized in 1933 and operates 12 branch offices
with total assets of $166.9 million and IPC deposits
of $119.3 million. The city of Jackson and the eastern and southeastern portions of Jackson County,
which are becoming rural-residential in character,
comprise the service area of the charter bank. The
bank's major competitors include City Bank and
Trust Company, Jackson, and The Midwest Bank,
Jackson, with deposits of $23.5 million.
Competition between the subject banks is minimal
because their closest offices are separated by a distance of approximately 12 miles and their customer
overlap is insignificant.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
competition in the service area of the merging bank
will be enhanced because improved and expanded
services will be offered such as a larger lending
limit, expertise in installment and mortgage lending,

and a credit card service. In addition, the merging
bank's management succession problem will be
resolved and the resulting bank will become a more
effective competitor against the larger banks within
its service area.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
APRIL 30,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Bank is situated in the village of Concord (population 983) about 15 miles southwest of Applicant's

nearest office. There is one competitive alternative
in the intervening area. Thus, it appears that the
proposed acquisition would eliminate some existing
competition.
Commercial banking in Jackson County is highly
concentrated. Applicant, with approximately 43.4
percent of county deposits, ranks first among the
county's eight commercial banks, while the two
largest banks hold approximately 86.4 percent of
total county deposits. The proposed acquisition will
increase Applicant's share of county deposits to
45.4 percent and increase the share of the two largest banks from 86.4 percent to 88.4 percent.
Thus, we conclude that the proposed transaction
would eliminate some existing competition and
increase banking concentration in Jackson County.

FIRST NATIONAL STATE BANK OF OCEAN COUNTY, LAKEWOOD, N.J.,
OF THE JERSEY COAST, SPRING LAKE,

AND FIRST NATIONAL STATE BANK
N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National State Bank of Ocean County, Lakewood, N.J. (16035), with
and First National State Bank of the Jersey Coast, Spring Lake, N.J. (13898), which had
merged June 7, 1974, under charter and title of the latter bank (13898). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On November 13, 1973, First National State Bank
of the Jersey Coast, Spring Lake, N.J., and First
National State Bank of Ocean County, Lakewood,
N.J., applied to the Comptroller of the Currency for
permission to merge under the charter and title of
the former.
First National State Bank of the Jersey Coast, the
charter bank, was organized in 1933, and presently,
with assets of $34.9 million and IPC deposits of
$28.1 million, operates two offices. It is a member of
First National State Bancorporation, Newark, the
third largest bank holding company in New Jersey.
The charter bank is located in the Asbury Park
market area of Monmouth County with its primary
service area consisting of the municipalities of
Spring Lake, Sea Girt, and Spring Lake Heights, a
total population of 11,000.
Twelve other banks compete with First National
State Bank of the Jersey Coast in the Asbury Park
market area. The most direct competition is provided by Central Jersey Bank and Trust, Freehold
Township, with deposits of $354 million which is a

$44,837,737
37,317,025
82,605,008

To be
operated

7
2
9

member of Central Bancorporation, and by First
Merchants National Bank, Neptune Township, with
deposits of $191 million.
First National State Bank of Ocean County, the
merging bank, was organized in 1934 and, with
assets of $42.6 million and IPC deposits of $33.1
million, operates six offices in Ocean County. It is
also affiliated with First National State Bancorporation, Newark. The merging bank is located in the
Toms River market area of Ocean County and its
primary service area includes a number of small
municipalities with a total population of 170,000.
Competition for the merging bank is provided by
The First National Bank of Toms River, Toms River,
with deposits of $111 million, which is a member of
American Bancorporation; Ocean County National
Bank, Point Pleasant, with deposits of $63 million;
The Bank of Mid Jersey, Bordentown, with deposits
of $54 million; Pineland State Bank, Bricktown,
with deposits of $50 million; and three other smaller
banks.
There is minimal competition between the charter
and merging banks because of the distance between
them and the existence of four other banks in the

intervening area. The closest offices of the charter
and merging banks are 12 miles apart. Additionally,
both First National State Bank of the Jersey Coast,
and First National State Bank of Ocean County are
wholly-owned subsidiaries of First National State
Bancorporation, Newark.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and represents a reorganization of commonly-owned
assets. This application is, therefore, approved.
MARCH 6,

SUMMARY OF REPORT BY ATTORNEY GENERAL

Both First National State Bank of the Jersey Coast
and First National State Bank of Ocean County are
wholly-owned subsidiaries (except for directors'
qualifying shares) of First National State Bancorporation, New Jersey's second largest multi-bank holding company. As such, their proposed merger is
essentially a corporate reorganization and would
have no effect on competition.

1974.

THE NATIONAL BANK OF SOUTH CAROLINA OF SUMTER, SUMTER, S.C., AND THE FARMERS BANK,
LORIS, S.C.
Banking offices
Total assets

Name of bank and type of transaction

In
To be
operation operated

The Farmers Bank, Loris, S.C, with
and The National Bank of South Carolina of Sumter, Sumter, S.C. (10660), which had
merged June 10, 1974, under charter of the latter bank (10660) and title "The National Bank of
South Carolina." The merged bank at date of merger had

COMPTROLLER S DECISION

On February 25, 1974, The Farmers Bank, Loris,
S.C, and The National Bank of South Carolina of
Sumter, Sumter, S.C, applied to the Comptroller of
the Currency for permission to merge under the
charter of the latter and with the title "The National
Bank of South Carolina."
The National Bank of South Carolina of Sumter,
the charter bank, was organized in 1905 and presently operates nine branches. It has total assets of
$87 million and IPC deposits of $67 million. The
primary service area of the charter bank encompasses the central and east-central portions of South
Carolina. The economic character of the area varies
from predominantly agricultural in the Bishopville
and Manning areas, to commercial, industrial, and
governmental activities in Columbia, the State
capital.
Competition for the charter bank is provided by 17
other banks, the largest of which are South Carolina National Bank, Columbia, with deposits of $703
million; Citizens and Southern National Bank of
South Carolina, Columbia, with deposits of $418
million; and First National Bank of South Carolina,
Columbia, with deposits of $336 million.
The Farmers Bank, Loris, S.C, the merging
bank, was organized in 1919 and presently operates
three branches. It has total assets of $18.1 million

$ 16,784,082
97,918,723
114,702,805

4
10
14

and IPC deposits of $15.1 million. The primary
service area of the merging bank encompasses
northern Horry County. The economic character of
that area ranges from predominantly agricultural,
near Loris, to tourist and retirement oriented pursuits, in North Myrtle Beach.
Competition for the merging bank is provided by
many of the same large banks that compete with
the acquiring bank. There is no competition between
the charter and merging banks because a large
distance separates them and an adequate number of
alternative banking facilities operate in the intervening area. The closest offices of the two banks are
90 miles apart.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branches in Horry
County will offer new and improved services such as
a larger lending limit, commercial loans, payroll
service, foreign credit information, a trust department, and a package of consumer services known as
the Gold Key Account. In addition, consummation
of the proposed merger will alleviate the management succession problem at The Farmers Bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and this
application is, therefore, approved.
MAY

6, 1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Neither bank operates an office in the areas
served by the other. The nearest offices of the banks
are separated by a distance of more than 80 miles.
Therefore, the proposed transaction would not
appear to eliminate substantial existing competition.
Bank accounts for the third largest share of
deposits (13.1 percent) held by the six banks operat-

ing in Horry County. The State's largest and second
largest banks rank first and second, respectively, in
the county and account for over 54 percent of
deposits. Under South Carolina law NBSC could
branch de novo into Loris and Horry County; however, in view of the existence of a number of other
potential entrants larger than NBSC, the proposed
transaction would not appear to have a significantly
adverse effect on potential competition.

THE WYOMING NATIONAL BANK OF WILKES-BARRE, WILKES-BARRE, P A . , AND THE FIRST NATIONAL BANK
OF FACTORYVILLE, FACTORYVILLE, PA.

Banking offices
Total assets

Name of bank and type of transaction

In
To be
operation operated
The First National Bank of Factoryville, Factoryville, Pa. (9130), with
and The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre, Pa. (732), which had
merged June 10, 1974, under charter and title of the latter bank (732). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On January 2, 1974, The First National Bank of
Factoryville, Factoryville, Pa., and The Wyoming
National Bank of Wilkes-Barre, 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 Factoryville, the merging bank, was organized in 1908 and operates as a
unit institution. It has total assets of $5.6 million and
IPC deposits of $4.7 million. The service area of the
bank encompasses Factoryville and the surrounding
area within a 3-mile radius. The economy of the
service area, which has a population of approximately 4,300, is dependent on agriculture and the
Keystone Junior College.
Competitors of the merging bank include a branch
of First National Bank, Carbondale, which has
deposits of $40.6 million and The First National
Bank of Nicholson which has deposits of $14.6
million.
The Wyoming National Bank of Wilkes-Barre, the
charter bank, was established in 1829 and operates
six branch offices. It has total assets of $128.3
million and IPC deposits of $109 million. The service area of the charter bank encompasses the
northern two-thirds of Luzerne County, central
Wyoming County, and Lackawanna County, an area
which is dependent on industry and agriculture.
Competitors of the charter bank include North-

$ 5,750,662
134,948,599

1
7

140,735,261

eastern Bank of Pennsylvania, with deposits of $383
million; First Valley Bank, with deposits of $320 million; United Penn Bank, with deposits of $318
million; and The First National Bank of Eastern
Pennsylvania, with deposits of $304 million.
Competition between the subject banks is insignificant since their closest offices are separated by a
distance of approximately 10 miles and neither bank
generates many accounts from the service area of
the other.
Consummation of the proposed transaction will
result in no adverse competitive effects. Competition in the Factoryville area will be increased because the resulting bank will offer new and improved
services, such as a larger lending limit, trust services, credit card services, automation services, free
checking accounts, and higher interest rates on certificates of deposit. In addition, the management
succession problem of the merging bank will be
resolved.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MAY 7, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Wyoming Bank, with one office in Tunkhannock,
Wyoming County, ranks second among the five
banks with offices in that county. Factoryville Bank,

located in Wyoming County on the Wyoming-Lackawanna County line in a community with a population
of about 950, is situated 10 miles east of Wyoming
Bank's Tunkhannock office and about 10 miles
northwest of Scranton. Factoryville Bank ranks fifth
among the five banks with offices in Wyoming
County. Although the application indicates that
neither bank draws substantial deposit or loan busi-

ness from the immediate service area of the other,
the Tunkhannock office of Wyoming Bank is one of
the closest banking alternatives for customers in the
service area of Factoryville Bank. Other alternatives
are provided by banks to the southeast, toward the
city of Scranton.
We conclude that the proposed merger may eliminate some competition.

DEPOSIT GUARANTY NATIONAL BANK, JACKSON, MISS., AND LEFLORE BANK & TRUST COMPANY,
GREENWOOD, MISS.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Leflore Bank & Trust Company, Greenwood, Miss., with
and Deposit Guaranty National Bank, Jackson, Miss. (15548), which had
merged June 28, 1974, under charter and title of the latter bank (15548). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On December 13, 1973, Deposit Guaranty National Bank, Jackson, Miss., and Leflore Bank &
Trust Company, Greenwood, Miss., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
Leflore Bank & Trust Company, Greenwood,
Miss., the merging bank, was organized in 1944 and
operates two branch offices in Greenwood. It has
total assets of $16.7 million and IPC deposits of
$12.9 million. The merging bank ranks next to last
in size among the four banks headquartered in
Greenwood and third among the five banks operating
in Leflore County. Its growth has been slowed in
recent years and it is in danger of being overtaken in
size by what is now the smallest bank headquartered
in Greenwood. Leflore Bank & Trust Company does
not operate as a full-service bank and has a restricted lending limit which retards the banks efforts
to obtain new business. The senior management of
the merging bank is in poor health and past retirement age and the bank has been unable to attract
competent successor management. In addition, the
bank needs new or remodeled banking facilities.
The service area of the merging bank encompasses Leflore County, a primarily agricultural area
which has experienced a decline in population in
recent years. The competitors for the bank include
The Bank of Greenwood, with deposits of $32.5
million which is a branch of the $521 million First

$ 17,544,879
775,645,596
789,457,648

To be
operated

3
34
37

National Bank of Jackson; Bank of Commerce, with
deposits of $15 million; and First National Bank of
Greenwood, with deposits of $12.9 million.
Deposit Guaranty National Bank, Jackson, Miss.,
the charter bank, was organized in 1925 and operates 30 branch offices within 100 miles of Jackson.
With total assets of $691 million and IPC deposits of
$392 million, the charter bank is the largest commercial bank in Mississippi. Deposit Guaranty National
Bank operates as a full-service bank, employs an
excellent management team, and conducts personnel programs to attract, train, and retain management personnel.
The charter bank operates in the southern portion
of Mississippi, the poorest State in the Nation. Competitors within its service area include First National
Bank of Jackson, with deposits of $521.2 million;
Hancock Bank, Gulfport, with deposits of $120.3
million; and First Mississippi National Bank, Hattiesburg, with deposits of $119.8 million. In addition,
because the charter bank serves as a regional financial institution, it also competes with the largest
banks located in Memphis, New Orleans, Baton
Rouge, Mobile, Birmingham, and other cities in the
South.
Direct competition between the charter and merging banks is insignificant because their closest
offices are separated by a distance of approximately
50 miles and each maintains only a minimal number
of accounts in the service area of the other.
De novo entry by the charter bank into Leflore

County is not an attractive alternative as Greenwood
presently has an adequate number of banks. The
only feasible means of entry into Leflore County by
the charter bank is through merger. Leflore Bank &
Trust Company is clearly an acceptable and legally
available merger partner1 and its merger with
Deposit Guaranty National Bank will allow the
charter bank to begin operations in Leflore County
with an unobjectionable volume of deposits and
banking assets. When the subject merger is consummated, the charter bank's share of commercial bank
deposits attributable to the State of Mississippi will
not be increased to any significant degree. Accordingly, consummation of the proposed transaction will
not result in any adverse competitive effects in any
area.
Rather, the entrance of the charter bank into
Leflore County will increase competition because
1
United States v. Deposit Guaranty National Bank et al.,
(Civil No. 4311, March 21, 1974)

new and expanded services will be offered by the
resulting bank such as a larger lending capacity,
emphasis on consumer loans, trust department
services, increased expertise in agricultural financing, foreign department services, and petroleum
department services. In addition, competent management personnel will be placed in the resulting
branch office. Finally, in light of present operating
difficulties of the merging bank, Deposit Guaranty
National Bank will be able to expend the necessary
time, manpower, and money to make its resulting
branch in Greenwood a viable banking facility again.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
MAY 21, 1974.
NOTE: NO

Attorney General's Report received.

THE NATIONAL BANK AND TRUST COMPANY OF NORWICH, NORWICH, N.Y.,

AND THE NATIONAL BANK OF

HOBART, HOBART, N.Y.
Banking offices
Name of bank and type of

Total assets

transaction

In
operation
The National Bank of Hobart, Hobart, N . Y . (4497), with
and The National Bank and Trust Company of Norwich, Norwich, N . Y . (1354), which had . . .
merged June 28, 1974, under charter and title of the latter bank (1354). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On March 26, 1974, The National Bank of Hobart,
Hobart, N.Y., and The National Bank and Trust
Company of Norwich, Norwich, N.Y., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The National Bank and Trust Company of Norwich, the charter bank, with assets of $139 million
and IPC deposits of $111 million, was organized in
1856 and now operates 14 branch offices. The service area of the bank is primarily rural and extends
throughout Chenango County, and portions of Tioga,
Broome, Delaware, and Otsego counties.
The charter bank is now the largest of the three
banks headquartered in Chenango County. Competition is provided by numerous banks including offices
of Marine Midland Bank-Southern, Elmira, with
deposits of $295 million, which is a member of

6,251,306
143,864,859
150,157,667

To be
operated

1
14
15

Marine Midland Banks, Inc., a multi-bank holding
company with total deposits of $6.6 billion; FirstCity National Bank of Binghamton, N.Y., with
deposits of $206 million, which is a member of
Lincoln First Banks, Inc., a multi-bank holding company with total deposits of $2.1 billion; Bankers
Trust of Binghamton, with deposits of $25 million,
which is a member of Bankers Trust New York
Corporation, a multi-bank holding company with
total deposits of $8.0 billion; and Endicott Bank of
New York, with deposits of $51 million, which is a
member of The Bank of New York Company, Inc., a
multi-bank holding company with total deposits of
$4.2 billion.
The National Bank of Hobart, was organized in
1891 and still, with assets of $6 million and IPC
deposits of $4.7 million, operates as a unit bank. The
merging bank is located in Delaware County and its
service area contains an estimated population of

5,000 persons. This bank ranks seventh of the 10
commercial banks headquartered in Delaware
County. Competition is provided by The National
Bank of Stamford with deposits of $16 million; The
National Bank of Roxbury with deposits of $3
million; Deak National Bank, Fleischmanns, with
deposits of $8 million, and The Delaware National
Bank of Delhi, with deposits of $14 million. There is
minimal competition between the charter and merging banks because their closest two offices are 14
miles apart and an adequate number of alternative
banking facilities operate in this area.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branch in Hobart will
provide residents and businesses, especially
farmers, with new and improved services including
a larger lending limit, an agricultural credit department, data processing and trust services, and a
wider variety of mortgage and consumer loans,
including a charge card. That will make the resulting
branch in Hobart a more viable competitor within its
service area. The resulting bank will remain the
third largest commercial bank in the Seventh Banking District of New York.
Applying the statutory criteria it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
MAY

28, 1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Eleven banks operate 15 offices in Delaware
County (population 45,000). National Bank of Hobart
is located in Hobart (population 531) in the eastern
part of the county in an agricultural area. Norwich
Bank also operates two offices in the eastern part of
the county; one in Grand Gorge (population 600)
about 12 road miles east of Hobart and one in Margaretville (population 816) about 31 road miles south
of Hobart. In addition to the three offices of the
merging banks, there are only three other competitive offices in the eastern part of the county. The
proposed merger would thus appear to eliminate
existing competition.
Norwich Bank is the fourth largest bank in Delaware County, holding 13.2 percent of county deposits on June 30, 1973. The three largest banks held
44.6 percent of such deposits. National Bank of
Hobart, the eighth largest bank, held 4.7 percent of
such deposits. The proposed merger would give
Norwich Bank the largest share, 17.9 percent, of
county deposits, and 42.0 percent of deposits in the
six banking offices in the eastern part of Delaware
County.
Although one office of a competing bank intervenes between the immediate service area of National Bank of Hobart and the closest office of
Norwich Bank, we conclude that the proposed transaction would have an adverse competitive effect.

REPUBLIC NATIONAL BANK OF NEW YORK, NEW YORK, N.Y., AND KINGS LAFAYETTE BANK, NEW YORK,
N.Y., AND REPUBLIC BANK, NATIONAL ASSOCIATION, NEW YORK, N.Y.

Name of bank and type of transaction

Total assets

Kings Lafayette Bank, New York, N.Y., with
Republic National Bank of New York, New York, N.Y. (15569), with
and Republic Bank, National Association, New York, N.Y. (15569), which had
merged July 1, 1974, under charter of the latter bank (15569) and title "Republic National Bank
of New York." The merged bank at date of merger had

$224,190,575
565,630,656
965,000

COMPTROLLER'S DECISION

On December 18, 1973, Kings Lafayette Bank,
New York, N.Y., Republic National Bank of New
York, New York, N.Y., and Republic Bank, National Association (organizing), New York, N.Y.,
applied to the Comptroller of the Currency for permission to merge under the charter of Republic
Bank, National Association, and with the title "Republic National Bank of New York."

782,781,076

Banking offices
In
To be
operation operated
19
2
0
19

Republic National Bank of New York, the first
merging bank, was organized in 1966 and operates
one branch in mid-Manhattan and one in London,
England. It also owns and operates Republic National Bank of New York (International), Limited, a
Nassau, Bahamas-based subsidiary. With total
assets of $827.3 million and IPC deposits of $328
million, it ranks 14th among the 42 commercial
banks headquartered in the Second Banking District. The service area of the bank includes the
75

Greater New York Metropolitan Area. International
banking is the primary concern of Republic National
Bank of New York.
Competition for Republic National Bank of New
York is principally provided by the multi-billion
dollar New York banks, including the Chase Manhattan Bank (National Association), with deposits of
$29.9 billion; First National City Bank, with deposits
of $29.6 billion; Manufacturers Hanover Trust Company, with deposits of $15.2 billion; and Chemical
Bank, with deposits of $12.9 billion.
Kings Lafayette Bank, the second merging bank,
was chartered in 1899 and operates 18 branch
offices. With total assets of $231.4 million and IPC
deposits of $173.3 million, it ranks fifth among the 32
commercial banks headquartered in the First Banking District. The service area of the bank is comprised of 14 separate segments of New York, Kings,
Queens, and Suffolk County communities. Kings
Lafayette Bank operates principally as a retail bank
with emphasis on individual borrowers, real estate
mortgages, and small businesses. Kings Lafayette
Corporation, New York, N.Y., a one-bank holding
company, owns controlling interest in the second
merging bank.
Competitors of Kings Lafayette Bank include the
large banks located in New York City and also
Marine Midland Tinker National Bank, East Setauket, which has deposits of $183 million and is a member of Marine Midland Banks, Inc.; Bankers Trust
of Suffolk, N.A., Patchogue, which has deposits of
$83 million and is a member of Bankers Trust New
York Corporation; and Chemical Bank of Suffolk,
National Association, Smithtown, which has deposits of $79 million and is a member of Chemical New
York Corporation.
Republic Bank, National Association, the charter
bank, has been organized by Republic National
Bank of New York and will be established as a
wholly-owned subsidiary of Republic New York
Corporation, a proposed bank holding company
which was also organized by Republic National Bank

of New York. The charter bank will be used to provide a vehicle by which to transfer ownership of the
merging banks to Republic New York Corporation.
Prior to consummation of the proposed transaction,
Republic New York Corporation, an organization
incorporated under the laws of Maryland, will merge
with Kings Lafayette Corporation. The charter bank
will not be operating as a commercial bank prior to
the proposed mergers.
Although the service areas of the merging banks
do overlap, in some degree competition between
them is insignificant since they serve different segments of the banking community. In addition, the
two banks are commonly controlled since the same
shareholders own a controlling interest in each.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather, the
resulting bank will be a stronger competitor because
it will offer new and improved services such as a
larger lending limit, consumer credit and mortgage
lending, and international and trust department
services. In addition, the management succession
problem of Kings Lafayette Bank will be resolved.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MAY 30, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

With the exception of its four offices in Suffolk
County, all of Kings Bank's offices are located within
25 miles of Republic. The nearest branch is only a
few blocks from Republic's headquarters. Thus, the
proposed merger will eliminate existing competition
between the parties in the New York City area. However, it does not appear that the transaction will
substantially increase concentration in commercial
banking in that area.
Therefore, we conclude that the proposed merger
would not have a substantial competitive impact.

THE OKEY-VERNON NATIONAL BANK OF CORNING, CORNING, IOWA, AND FIRST STATE BANK,
PRESCOTT, IOWA

Banking offices
Name of bank and type of transaction

Total assets
In
To be
operation operated

First State Bank, Prescott, Iowa, with
was purchased July 1, 1974, by The Okey-Vernon National Bank of Corning, Corning, Iowa
(8725), which had
After the purchase was effected, the receiving bank had
COMPTROLLER S DECISION

On October 19, 1973, The Okey-Vernon National
Bank of Corning, Corning, Iowa, applied to the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of The
First National Bank of Prescott, Prescott, Iowa.*
The Okey-Vernon National Bank of Corning, the
purchasing bank, was organized in 1907 and since
that time has operated as a unit institution. The bank
has assets of $20.1 million and IPC deposits of $16.4
million. The service area of the bank includes the
town of Corning and surrounding Adams County
which has an estimated population of 6,300 persons.
The economy of Corning and the peripheral rural
area is predominantly agricultural where most of the
available farmland is devoted to the raising of corn,
soybeans, and hay.
The purchasing bank is now the largest of two
banks located in the town of Corning; it is in direct
competition with The Bank of Brooks, a private
bank, which has deposits of $2.5 million.
The First National Bank of Prescott*, Prescott,
Iowa, the selling bank, was organized in 1901 and
since that time has operated as a unit institution.
The bank now has assets of $3.4 million and IPC
deposits of $2.5 million. The relevant service area of
the selling bank is also Adams County and includes
mainly the town of Prescott which has a population
of 300 persons. Agriculture is the primary source of
economic activity within the service area.
Like the purchasing bank, the selling bank competes with The Bank of Brooks in Corning. It is also
in competition with eight other banks located in
communities around the perimeter of Adams
County; the largest competitor is The First National
Bank, Creston, with deposits of $20.9 million.
There is no competition between the purchasing
and selling institutions because their closest two
offices are separated by a distance of 7 miles. Traditionally each bank has been content to limit banking
* The First National Bank of Prescott, Prescott, Iowa, charter
number 5912, converted to First State Bank, Prescott, Iowa, on
June 28, 1974.

$. 3,507,214

19,226,345
22,358,930

1
2

services to customers exclusively within their own
territories. In addition, there are an adequate number of alternative banking facilities operating in the
area.
Consummation of the proposed purchase will provide the area now served by The First National
Bank of Prescott with improved and expanded banking services, including an increased lending limit on
farm loans to match the growth of consolidated
farms in the area, access to computerized services,
daily interest on savings accounts, tighter security
for protection of banking records, and incorporation
of younger management personnel to resolve the
selling bank's succession problem. Also, the resulting bank would maintain the Prescott location as a
branch, thereby affording existing customers the
continuance of convenient banking service in that
locale.
Accordingly, it is the conclusion of this Office that
the proposed transaction is in the public interest and
this application is, therefore, approved.
MARCH 5,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Corning Bank operates its single office in Corning
(population 2,095), the county seat of Adams County
(population 6,332). On June 30, 1973, it held total
deposits of $18.7 million (including IPC demand
deposits of $8.5 million) and had loans amounting to
$4.3 million. Prescott Bank, which, as of June 30,
1973, held total deposits of $3.1 million (including
IPC demand deposits of $1.1 million) and had loans
of $543,000 operates one office in Prescott (population 305), also in Adams County.
Corning Bank and Prescott Bank are two of three
banks in Adams County, Corning Bank being by far
the largest. Significant competition probably does
not exist between the two banks, in part due to
extensive common ownership stemming from stock
purchases in 1967. In view of the proximity of
Corning and Prescott, it is likely that the instant
transaction would permanently eliminate any independent competitive prospects of Prescott Bank.
77

THE FIRST NATIONAL BANK OF THE CITY OF SUPERIOR, SUPERIOR, W I S . , AND WISCONSIN STATE BANK,
SUPERIOR, W I S .

Total assets

Name of bank and type of transaction

Wisconsin State Bank, Superior, Wis., with
was purchased July 15, 1974, by The First National Bank of the City of Superior, Superior,
Wis. (3926), which had
/•.••••
After the purchase was effected, the receiving bank had
COMPTROLLER'S DECISION

On April 9, 1973, The First National Bank of the
City of Superior, Superior, Wis., applied to the
Comptroller of the Currency for permission to purchase the assets and assume the liabilities of Wisconsin State Bank, Superior, Wis.
The First National Bank of the City of Superior,
the purchasing bank, was organized in 1887 and
now, with assets of $25 million and IPC deposits of
$21.7 million, operates as a unit bank. Marshall and
Ilsley Bank Stock Corporation, Milwaukee, a multibank holding company, acquired the purchasing
bank as a subsidiary in September 1970.
The purchasing bank is located in the DuluthSuperior Metropolitan Area which has a population
of approximately 265,000 persons. The economy of
that area is based upon commercial and recreational
activities with shipbuilding and the railroad industry
comprising the most important sources of employment. Commercial banking in the Duluth-Superior
Metropolitan Area is dominated by First American
National Bank of Duluth and Northern City National
Bank of Duluth, each of which is a subsidiary of a
large Minneapolis-based holding company. The purchasing bank is the second largest commercial bank
headquartered in Superior and competes directly
with National Bank of Commerce in Superior, with
total deposits of $34 million.
Wisconsin State Bank, the selling bank, was
organized in 1911 and now, with assets of $2.7 million and IPC deposits of $2.3 million, operates as a
unit bank. The bank is a non-competitive institution
as a result of ultra conservative policies imposed by
the founding and controlling family.
The selling bank is located in the small, primarily
residential community known as South Superior
adjacent to the city of Superior. The service area of
the bank contains a population of approximately
3,100 persons and includes the small communities
of Foxboro and Patzau.
Although there is a slight overlap in the service
areas of the purchasing and selling banks, there is

Banking offices
In
To be
operation operated

$ 2,826,119

29,355,056
32,215,967

1
2

little direct competition between the two banking
institutions. Because of its very small size, the selling bank primarily deals in the personal accounts of
the residents within its immediate service area. With
a lending limit of only $28,000, the selling bank is
unable to compete for large commercial loans. Consequently, substantial commercial accounts generrated from within the service area of Wisconsin
State Bank are maintained with the larger downtown
commercial banks which are capable of accommodating the credit needs of those businesses. Furthermore, the remaining subsidiaries of Marshall and
Ilsely Bank Stock Corporation do not compete with
Wisconsin State Bank because its next closest subsidiary bank is located in the city of Merrill, Wis.,
approximately 200 miles southeast of Superior.
Consummation of the captioned proposal will
allow the resulting branch in South Superior to
become more responsive to the needs of its community by increasing the range of service it will offer
including the introduction of trust services, international banking, automated accounting, personal
investment and tax services, an expansion of consumer loan activity, and increased availability of real
estate mortgage loans. The resulting bank will
remain the second largest commercial bank in Superior with total deposits of approximately $27 million
which will not cause an imbalance in the competitive
banking structure in that city.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed transaction is in the
public interest and this application is, therefore,
approved.
AUGUST 2,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

First National Bank of the City of Superior
("FNB") is the second largest of five banks in Superior, Wis. As of December 31, 1972, FNB held total
deposits of $23.2 million (including IPC demand
deposits of $6.3 million) and total loans of $12.7

million. FNB, a unit bank, is a subsidiary of Marshall & Ilsley Corporation, a bank holding company
with 15 banking subsidiaries which hold total deposits in excess of $764 million.
Wisconsin State Bank ("WSB") is a unit bank also
located in Superior, Wis. As of December 31, 1972,
WSB held total deposits of $2.3 million (including
IPC demand deposits of $1.1 million) and total loans
of $420 thousand.

The parties to this acquisition are situated about
4 miles apart with only one competitive alternative
(situated one block from FNB) in the intervening
area. Thus, it appears that the proposed acquisition
would eliminate some existing competition in the
highly concentrated Superior market. However, in
view of the modest size of the bank to be acquired
we conclude that the effect of the transaction on
existing competition will not be significantly adverse.

FIRST NATIONAL BANK OF SOMERSET COUNTY, BERLIN, PA., AND THE FIRST NATIONAL BANK OF
CONFLUENCE, CONFLUENCE, PA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Somerset County, Berlin, Pa. (5823), with
and The First National Bank of Confluence, Confluence, Pa. (5307), which had
consolidated July 29, 1974, under charter of the latter bank (5307) and title "National Bank of
Western Pennsylvania." The consolidated bank at date of consolidation had

COMPTROLLER S DECISION

On January 21, 1974, The First National Bank of
Confluence, Confluence, Pa., and First National
Bank of Somerset County, Berlin, Pa., applied to the
Comptroller of the Currency for permission to consolidate under the charter of the former and with the
title "National Bank of Western Pennsylvania."
First National Bank of Somerset County, the consolidating bank, was organized in 1901 and operates
four branch offices in Somerset County. It has total
assets of $13.8 million and IPC deposits of $12.3
million. The economy of Somerset County is dependent on agriculture, industry, coal mining, and
recreation.
Competitors of the consolidating bank include the
Meyersdale branch of Gallatin National Bank, with
total deposits of $206.2 million; the Somerset branch
of State National Bank, with total deposits of $185.8
million; several branches of Johnstown Bank and
Trust Company, with total deposits of $83.3 million;
and Somerset Trust Company, with total deposits of
$26.3 million.
The First National Bank of Confluence, the
charter bank, was organized in 1900 and operates
two branch offices in the south and southeastern
parts of Fayette County. It has total assets of $19.4
million and IPC deposits of $15.6 million. Mining,
agriculture, lumbering, and recreation support the
economy of its service area. The closest competitors

$22,416,787
15,188,669

To be
operated

5
3

37,605,457

of the charter bank are branches of Gallatin National Bank and the Donegal branch of County Trust
Company, which has deposits of $19.2 million.
Competition between the subject banks is minimal
since their closest offices are separated by a distance of approximately 20 miles; the intervening
mountainous area forms a natural boundary separating the service areas of the two banks.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather, the
resulting bank will become a stronger competitor by
offering new and expanded services such as an increased lending limit, trust department services,
and automated bookkeeping. In addition, the management succession problems of the charter bank
will be resolved.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
JUNE 14,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Somerset Bank and Confluence Bank are headquartered about 33 miles apart and the nearest
offices of the two banks are about 20 miles apart with
no banking offices intervening. Thus, it appears that
79

the proposed acquisition would eliminate only a
limited amount of existing competition. And in view
of the modest size of the parties and the existence of
several significant potential entrants into their
markets, we conclude that the proposed transaction

would not eliminate substantial potential competition.
Therefore, we conclude that the proposed transaction would not have a substantial competitive
impact.

THE FIRST NATIONAL BANK OF SAN JOSE, SAN JOSE, CALIF., AND HAYWARD NATIONAL BANK,
HAYWARD, CALIF.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Hayward National Bank, Hayward, Calif. (15343), with
and The First National Bank of San Jose, San Jose, Calif. (2158), which had
merged July 31, 1974, under charter and title of the latter bank (2158). The merged bank at date
of merger had

COMPTROLLER S DECISION

On February 13, 1974, Hayward National Bank,
Hayward, Calif., and The First National Bank of San
Jose, San Jose, Calif., applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the latter.
Hayward National Bank, the merging bank, with
total assets of $15.4 million and IPC deposits of
$11.1 million, was organized in 1964 and operates as
a unit institution. The service area of the bank encompasses the city of Hayward and a small portion
of the city of Castro Valley. The area is primarily
residential in nature but does contain some commercial activity and light industry.
Competitors of the merging bank include branches
of Bank of America, National Trust and Savings
Association, with deposits of $35.6 billion; branches
of Security Pacific National Bank, with deposits of
$11.3 billion; and branches of Crocker Bank, N.A.,
with deposits of $6.5 billion.
The First National Bank of San Jose, the charter
bank, was organized in 1874, operates 29 branch
offices, and has an application pending for one additional branch. It has total assets of $270 million and
IPC deposits of $225.4 million. The service area of
the bank encompasses Santa Clara County, a small
portion of San Mateo County, and a portion of southwestern Alameda County. That area, which is
experiencing rapid residential and commercial development, is primarily dependent on industry,
agriculture, food processing, and related agricultural businesses.
Competitors of the charter bank include branches
of the Bank of America, National Trust and Savings
Association; Crocker Bank, N.A.; and Bank of
80

$ 16,876,039
283,984,707

To be
operated

1
33

300,860,747

California, National Association, with deposits of
$2.1 billion.
While the service areas of the subject banks do
overlap to a small degree, competition between them
is insignificant as their service areas are generally
considered separate and distinct banking communities. Several large banks have established
branches that provide adequate banking alternatives
in both areas. In addition, access between the
service areas of the two banks is limited by the
Nimitz Freeway.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
competition will be enhanced, particularly in the
service area of the merging bank, by the existence of
a stronger management and by the establishment of
new and expanded services such as a greater lending
limit, trust department services, retail banking
services, electronic data processing services, and
commodity loans and warehouse receipt financing.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JUNE 20,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Hayward is located in western Alameda County
about 17 miles southeast of Oakland. Applicant's
two Alameda County branches, located in San Leandro and San Lorenzo, lie northwest of Hayward
between Hayward and Oakland about 8 and 2.5
miles, respectively, from Bank. Thus, it appears that
the proposed acquisition may eliminate some existing competition between the parties. However, it

does not appear that the transaction would substantially increase concentration in any relevant banking
market.

Accordingly, we conclude that the proposed
merger would not have a substantial competitive
impact.

THE FIRST JERSEY NATIONAL BANK, JERSEY CITY, N.J., AND BELMAR-WALL NATIONAL BANK,
WALL TOWNSHIP, N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Belmar-Wall National Bank, Wall Township, N.J. (13848), with
and The First Jersey National Bank, Jersey City, N.J. (374), which had
merged Aug. 2, 1974, under charter and title of the latter bank (374). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On April 8, 1974, Belmar-Wall National Bank,
Wall Township, N.J., and The First Jersey National
Bank, Jersey City, N.J., applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
Belmar-Wall National Bank, the merging bank,
was organized in 1933. It now operates four branch
offices and has received approval to open an additional branch. With total assets of $56 million and
IPC deposits of $40.8 million, the bank ranks fifth
in size among the nine commercial banks headquartered in Monmouth County. The service area of the
bank encompasses portions of Monmouth and Ocean
counties, a residential area with a population of at
least 26,000 persons.
Competitors of the merging bank include The
Central Jersey Bank and Trust Co., Freehold, with
deposits of $360 million; Colonial First National
Bank, Red Bank, with deposits of $294 million; First
Merchants National Bank, Neptune, with deposits of
$197 million; and Peoples National Bank of Monmouth County, Hazlet, with deposits of $57 million,
which is a member of United Jersey Banks.
The First Jersey National Bank, the charter bank,
was organized in 1894. This bank operates 22 branch
offices and has received approval to operate a
branch in Cliffside Park. It has applied for approval
to open a branch in Union Township. With total
assets of $534.5 million and IPC deposits of $399.5
million, the bank ranks first in size among the 11
commercial banks headquartered in Hudson
County. The service area of the charter bank encompasses Hudson County, the southern portion of
Bergen County, the city of Newark, and the town

$ 56,959,716
486,446,643

To be
operated

5
20

543,281,539

ship of Millburn, an area which is industrial in
nature.
The major competitors of the charter bank include
Commercial Trust Co., Jersey City, with deposits of
$224 million; The Trust Co. of New Jersey, Jersey
City, with deposits of $233 million; and Garden State
National Bank, Hackensack, with deposits of $426
million.
Competition between the subject banks is insignificant as they are separated by a distance of more
than 50 miles and each serves separate and distinct
areas.
Consummation of the proposed transaction will
result in no adverse competitive effects. The resulting bank will better serve the needs of the customers
of the merging bank by providing expanded and improved services, such as accounts receivable financing, trust department services, data processing
services, and international services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JULY 1,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are separated by
approximately 40 miles, with a number of competitive alternatives in the intervening area. Thus, while
First Jersey may derive some deposits and loans
from Monmouth County, it does not appear that the
proposed merger would eliminate substantial existing competition. And although First Jersey could
legally expand de novo into the area served by Bank,
the existence of other potential entrants and the

latter's relatively modest market position diminish
the effect of the proposed merger on potential
competition.

THE COUNTY BANK, N.A.,

Therefore, we conclude that this proposed transaction would not have a substantial competitive
impact.

CAMBRIDGE, MASS., AND LEXINGTON TRUST COMPANY, LEXINGTON, MASS.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Lexington Trust Company, Lexington, Mass., with
and The County Bank, N.A., Cambridge, Mass. (4771), which had
consolidated Aug. 16, 1974, under charter and title of the latter bank (4771). The consolidated
bank at date of consolidation had

COMPTROLLER'S DECISION

On April 8, 1974, Lexington Trust Company, Lexington, Mass., and The County Bank, N.A., Cambridge, Mass., applied to the Comptroller of the
Currency for permission to consolidate under the
charter and with the title of the latter.
Lexington Trust Company, the consolidating
bank, was organized in 1914 and now operates six
branch offices. It has total assets of $49.8 million and
IPC deposits of $37 million. The communities of
Lexington, Bellerica, Chelmsford, Westford, Acton,
Burlington, and Bedford comprise the service area
of the consolidating bank. That area, which has a
population of approximately 156,000, is primarily
residential.
Competitors of the consolidating bank in Lexington include Harvard Trust Company, with deposits
of $210.8 million; Coolidge Bank and Trust Company, with deposits of $94.9 million; and Lexington
Savings Bank, with deposits of $52.8 million.
The County Bank, N.A., Cambridge, Mass., the
charter bank, was organized in 1933 and now operates eight branch offices. It has total assets of $121.8
million and IPC deposits of $91.2 million. The service area of the charter bank includes the communities of Cambridge, Everett, Somerville, Maiden,
and Belmont. That area, which has a population of

To be
operated

$ 45,408,250
111,756,697
157,164,947

approximately 316,000, is residential and industrial
in nature.
Competitors of the charter bank include Cambridge Savings Bank, with deposits of $262.9 million;
Harvard Trust Company; Cambridgeport Savings
Bank, with deposits of $174.9 million; and Coolidge
Bank and Trust Company.
Competition between the subject banks is minimal
since they are both majority-owned subsidiaries of
Shawmut Association, Inc., Boston, Mass.
Consummation of the proposed transaction will
result in no adverse competitive effects rather, the
resulting bank will become a stronger competitor
because of its increased lending limit, capable personnel, credit department services, and aggressive
policies in the areas of loans and deposits.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JUNE 27,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

County Bank and Lexington Trust are both subsidiaries of Shawmut Association, Inc., a registered
bank holding company. As such, their proposed consolidation is essentially a corporate reorganization
and would have no competitive impact.

WELLS FARGO BANK, NATIONAL ASSOCIATION, SAN FRANCISCO, CALIF., AND COMMERCIAL NATIONAL BANK,
ORANGE COUNTY (P.O. BUENA PARK), CALIF.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Commercial National Bank, Orange County (P.O. Buena Park), Calif. (15434), with
$ 33,069,076
9,819,837,927
and Wells Fargo Bank, National Association, San Francisco, Calif. (15660), which had
merged Aug. 23,1974, under charter and title of the latter bank (15660). The merged bank at
date of merger had
9,852,907,003

COMPTROLLER'S DECISION

On April 10, 1974, Wells Fargo Bank, National
Association, San Francisco, Calif., and Commercial
National Bank, Orange County, Calif., applied to the
Comptroller of the Currency for permission to merge
under charter and title of the former.
Wells Fargo Bank, National Association, the
charter bank, was founded in 1862 and now has
assets of $11.6 billion and IPC deposits of $6 billion.
It operates 303 offices throughout the State of California, four of which are located in Orange County
and account for $40.9 million of the bank's total
deposits.
Commercial National Bank, Orange County, the
merging bank, organized in 1964, has $31.6 million
in assets and IPC deposits of $24.1 million. It operates seven offices in Orange County, an area with an
estimated population of 1.6 million.
Competition in Orange County is provided by
branches of eight major banks and numerous smaller
banks. The largest banks include Bank of America,
N.T. & S.A., with total deposits of $1 billion in
Orange County, and Security Pacific National Bank,
with total Orange County deposits of $567.5 million.
Those two banks dominate the banking industry in
Orange County.
There is minimal competition between the merging bank and the charter bank. The merging bank is
primarily retail with a heavy emphasis on consumer
credit loans while the charter bank has more of a
commercial emphasis. Both banks operate branches
in Santa Ana and Anaheim, but competition is
minimal due to other factors. In Santa Ana, the
offices are 5 miles apart, separated by a business
district containing 12 other banking offices. In
Anaheim, although the branches are 2 miles apart,
direct competition is provided by two offices of
Bank of America, one located in the same shopping
center as Commercial National Bank, the other

To be
operated

7
311
318

directly across the street from the Wells Fargo
branch.
Consummation of the proposed transaction will
not result in a decrease of banking alternatives in the
service area nor will it result in an undue increase in
size of the charter bank. Competition in the area will
be stimulated by assuring a succession of capable
management in the merging bank. The resulting
bank will offer improved services, such as escrow
and trust services, international banking, electronic
data processing services, a credit card, and an
expansion of real estate and commercial loans.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
JULY 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The effects of this proposed merger will be felt
primarily in Orange County in Southern California.
Wells Fargo operates four branches in Orange
County and, with total deposits of $29.6 million,
accounts for less than 1 percent of total deposits
held by Orange County banking offices. CNB, with
all seven of its banking offices located in that county,
also accounts for less than 1 percent of total county
deposits. In view of the relatively close proximity of
the parties' offices, particularly in Santa Ana and
Anaheim, it appears that the proposed merger may
eliminate some existing competition in Orange
County. However, it does not appear that concentration in commercial banking would be substantially
increased in any relevant banking market.
Although Wells Fargo possesses the capability to
expand its present Orange County operations de
novo, the modest market position held by CNB in
Orange County diminishes the effects of this proposed transaction on potential competition.
Therefore, we conclude that the proposed merger
would not have a substantial competitive impact.

THE TOY NATIONAL BANK OF SIOUX CITY, SIOUX CITY, IOWA, AND FARMERS LOAN & TRUST COMPANY,
SIOUX CITY, IOWA

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Farmers Loan & Trust Company, Sioux City, Iowa, with
and The Toy National Bank of Sioux City, Sioux City, Iowa (10139), which had
merged Sept. 16, 1974, under charter of the latter bank (10139) and title "The Toy National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On April 22, 1974, Farmers Loan & Trust Company, Sioux City, Iowa, and The Toy National Bank
of Sioux City, Sioux City, Iowa, applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
"The Toy National Bank."
Farmers Loan & Trust Company, the merging
bank, is a noninsured institution which was chartered in 1883 as an Iowa trust company. It has total
assets of $841 thousand and IPC deposits of $542
thousand. The service area of the merging bank
encompasses Sioux City; Sergeant Bluff, Iowa;
North Sioux City, S. Dak.; and South Sioux City,
Nebr. That area, which has a population of 96,915,
is industrial, agricultural, and residential in nature.
Competitors for the charter bank include Security
National Bank, Sioux City, with deposits of $106.9
million, and First National Bank in Sioux City, with
deposits of $86.7 million.
The Toy National Bank of Sioux City, the charter
bank, was organized in 1912 and now operates three
walk-in, drive-in facilities. The bank has total assets
of $90.1 million and IPC deposits of $55.4 million.
The service area of the merging bank is identical to
that of the charter bank. Competitors of the merging
bank include Security National Bank; First National
Bank in Sioux City; and Northwestern National
Bank of Sioux City, with deposits of $56.3 million.
Competition between the subject banks is minimal
as, in many respects, they have been operating as
one institution. They share common stockholders,
many of whom are grandchildren of the founder of
the banks; common directors, officers, and employees; and have always been located in the same
building. In addition, in 1952 the desire to obtain
new trust business led to the decision to expand the
trust department of the charter bank, rather than

375,066
95,337,656

To be
operated

1
3

93,805,519

that of the merging bank, because the former bank
was deemed to be more familiar to the general
public. The consequent advertising campaign was
apparently successful, as seen in the decline in
assets of the merging bank and the increase in trust
assets of the charter bank. The merging bank has
since been used principally to administer family
trusts.
Consummation of the proposed transaction will
result in no adverse competitive effects. Under Iowa
law, the charter of the merging bank, which expires
in 1983, cannot be renewed. This merger, therefore,
represents a more convenient and efficient manner
than liquidation by which to eliminate the merging
bank. In addition, the public will be benefitted by
the increased operating efficiency of the resulting
bank and by its increased lending limit.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
AUGUST 12,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

According to the application, both institutions
share the same quarters, and employees and officers
of one have simultaneously done work as employees
and officers of the other. The application also states
that since a 1952 decision to enlarge the trust department of Bank, the principal use of Farmers Trust has
been to administer family trusts.
Under Iowa law, the charter of Farmers Trust, one
of two remaining trust companies in Iowa, will
expire in 1983, and cannot be renewed.
We do not believe that the proposed transaction
would have any significant adverse competitive
effects.

MICHIGAN NATIONAL BANK OF MACOMB, WARREN, MICH., AND TRI-CITY BANK, WARREN, MICH.
Banking' offices
Name of bank and type of transaction

Tri-City Bank, Warren, Mich., with
was purchased Sept. 28, 1974, by Michigan National
which had
After the purchase was effected t h e receiving b a n k

.
Bank of M a c o m b , W a r r e n , Mich. (16387),
had.

COMPTROLLER S DECISION

On September 27, 1974, request was made to the
Comptroller of the Currency for prior written approval for The Michigan National Bank of Macomb,
Warren, Mich. ("Assuming Bank"), to purchase certain of the assets and assume certain of the liabilities
of the Tri-City Bank, Warren, Mich. ("Tri-City").
As of business on September 27, 1974, Tri-City
was a State bank with one office and deposits of
approximately $14 million. On September 27, 1974,
the Federal Deposit Insurance Corporation ("FDIC")
was appointed as receiver of Tri-City. The present
application is based upon an agreement, which is
incorporated herein by reference, by which the
FDIC as receiver has agreed to transfer certain TriCity assets and liabilities to the Assuming Bank. For
the reasons stated hereafter, the Assuming Bank's
application is approved, and the purchase and
assumption transaction may be consummated
immediately.
Tri-City was organized in 1958, and has total book
resources of approximately $17 million. It operated
one office in Warren, Mich.
Under the Bank Merger Act, 12 U.S.C. 1828(c),
the Comptroller cannot approve a purchase and
assumption transaction which would have certain
proscribed anticompetitive effects unless he finds
those anticompetitive effects to be clearly outweighed in the public interest by the probable effect
of the transaction in meeting the convenience and
needs of the community to be served. Additionally,
the Comptroller is directed to consider the financial
and managerial resources and future prospects of
the existing and proposed institution, and the convenience and needs of the community to be served.
When necessary, however, to prevent the evils
attendant upon the failure of a bank, the Comptroller can dispense with the uniform standards
applicable to usual acquisition transactions, and

Total assets

...

In
To be
operation operated

$16,634,720

1,500,000
16,349,403

need not consider reports on the competitive consequences of the transaction ordinarily solicited from
the Department of Justice and other banking agencies. He is authorized in such circumstances to act
immediately in his sole discretion, to approve an
acquisition, and to authorize the immediate consummation of the transaction.
The proposed acquisition will prevent a disruption
to the community and potential losses to a number
of uninsured depositors. The Assuming Bank is supported by strong financial and managerial resources.
Thus, the approval of this transaction will help to
avert a loss of public confidence in the banking
system, and may actually improve the services
offered to the banking public.
The Comptroller thus finds that the proposed
transaction will not result in a monopoly, be in
furtherance of any combination or conspiracy to
monopolize or attempt to monopolize the business of
banking in any part of the United States; and that the
anticompetitive effects of the proposed transaction,
if any, are clearly outweighed in the public interest
by the probable effect of the proposed transaction in
meeting the convenience and needs of the community to be served. For those reasons, the Assuming
Bank's application to assume certain liabilities and
purchase certain assets of Tri-City as set forth in the
agreement executed with the FDIC as receiver, is
approved. The Comptroller further finds that the
failure of Tri-City requires him to act immediately,
as contemplated by the Bank Merger Act, to prevent
disruption of banking services to the community;
and the Comptroller thus waives publication of
notice, dispenses with the soli citation of competitive
reports from other agencies, and authorizes the
transaction to be consummated immediately.
SEPTEMBER 28,

1974.

NOTE: Due to the emergency nature of the situation, no report on competitive factors was requested.

CUMBERLAND COUNTY NATIONAL BANK AND TRUST COMPANY, N E W CUMBERLAND, PA., AND THE
DUNCANNON NATIONAL BANK, DUNCANNON, PA.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Duncannon National Bank, Duncannon, Pa. (4142), with
and Cumberland County National Bank and Trust Company, New Cumberland, Pa. (14542),
which had
merged Sept. 30, 1974, under charter and title of the latter bank (14542). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On May 7, 1974, the Duncannon National Bank,
Duncannon, Pa., and Cumberland County National
Bank and Trust Company, New Cumberland, Pa.,
applied to the Comptroller of the Currency for permission to merge under the charter and title of the
latter.
Cumberland County National Bank and Trust
Company, the charter bank, is headquartered in
New Cumberland, Cumberland County, Pa. With 17
operating offices and assets of $196.5 million and
$143 million in IPC deposits, the charter bank is the
sixth largest bank in its service area. That service
area consists of the eastern half of Cumberland
County, southwestern Dauphin County, east-central
Adams County, northern York County, and a small
part of northeastern Perry County. The economy of
that area is supported by a wide variety of medium
and light industry, governmental bodies, military
installations, service organizations, and agriculture.
The unemployment rate in the area is low.
Principal competitors for charter bank include National Central Bank, Lancaster, with $763 million in
deposits; The Commonwealth National Bank,
Harrisburg, with $489 million in deposits; Dauphin
Deposit Trust Company, Harrisburg, with $335 million in deposits, The Fulton National Bank, Lancaster, with $206 million in deposits; and Pennsylvania National Bank and Trust Co., Pottsville, with
$183 million in deposits.
The Duncannon National Bank, the merging bank,
is a small unit bank with assets of $10.9 million and
IPC deposits of $8.4 million. The bank is situated in
Duncannon, Pa., about 15 miles north of New Cumberland. Its service area, which includes a very
small portion of eastern Perry County and extreme
western Dauphin County, has an economy completely dependent upon agriculture.
Primary competitors of merging bank are the First
National Bank of Marysville, Marysville, with $7
million in deposits and a branch of Commonwealth
86

$ 10,887,945

225,799,364

To be
operated

236,687,309

National Bank located in New Bloomfield. The
merging bank is a small unaggressive institution
lacking in managerial depth.
The nearest offices of the charter bank to the
merging bank are 9 miles north, in Newport, and
10 miles south, in Enola, with an adequate number
of alternate institutions in the intervening areas.
While distance alone precludes any competition
between the applicant banks, the nonaggressive
nature of the merging bank further reduces the possibility of competition between the two banks. As a
result of the merger, customers in the merging
bank's service area will benefit from more efficient
banking services and larger loan limits which will
serve to stimulate competition in that area.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
AUGUST 22, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

Applicant and Bank are headquartered about 18
miles apart, and their nearest offices are separated
by about 10 miles. Applicant's Perry County office,
located on the eastern border of the county along the
Susquehanna River, is about 10 miles northwest of
Bank, with no competitive alternatives in the intervening area. Applicant's Enola office, in the northeastern corner of Cumberland County, is located
about 10 miles south of Bank, just below the Perry
County line. Thus, it appears that the proposed
transaction would eliminate existing competition
between the parties, particularly in eastern Perry
County.
Bank, with approximately 17 percent of Perry
County deposits, is the second largest of the nine
banks with offices in the county. Applicant, with
approximately 7.2 percent of Perry County deposits,
ranks seventh. If consummated, this transaction will
rank Applicant first among Perry County banks with
nearly 25 percent of total county deposits, with an

even greater share of deposits in the eastern portion
of the county.
We conclude that the proposed merger would

eliminate substantial existing competition and significantly increase concentration in commercial
banking in Perry County.

FIRST NATIONAL BANK OF ABERDEEN, ABERDEEN, S. DAK., AND THE FIRST NATIONAL BANK IN BRISTOL,
BRISTOL, S. DAK.
Banking offices
Name of bank and type of transaction

Total assets
To be
In
operation operated

The First National Bank in Bristol, Bristol, S. Dak. (10868), with
and First National Bank of Aberdeen, Aberdeen, S. Dak. (2980), which had
merged Oct. 1, 1974, under charter and title of the latter bank (2980). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On May 23, 1974, The First National Bank in
Bristol, Bristol, S. Dak., and First National Bank of
Aberdeen, Aberdeen, S. Dak., 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 in Bristol, the merging
bank, was organized in 1916 and now operates only
one banking office with assets of $5.8 million and
IPC deposits of $4.8 million. The merging bank is
located in Day County which encompasses virtually
all of the bank's service area. Day County, with an
estimated population of 9,000 persons, is supported
largely by diversified farming, livestock, and some
milk production. The bank has no local competition
and very little competition is provided by the other
three banks and two branches within the county.
Whatever marginal competition it does experience is
provided by Security Bank and Trust Company,
Webster, with deposits of $13.7 million, which is a
member of Dacotah Bank Holding Company; State
Bank of Waubay, with deposits of $4.3 million; and
First State Bank of Pierpont, with deposits of $3.2
million.
First National Bank of Aberdeen, the charter
bank, was organized in 1881 and now operates seven
branch offices with total assets of $171.1 million and
IPC deposits of $135.2 million. The service area of
the bank is also localized and consists almost exclusively of Brown County, which has approximately
37,000 inhabitants, and, more specifically, the city
of Aberdeen, which contains approximately 26,000
persons. The service area of the charter bank is

$ 6,430,772
180,284,114
186,714,886

1
8
9

located in the northeast corner of South Dakota and,
like Day County, it relies heavily upon diversified
agriculture for its economic base. Up to this time
industrial development has been minimal. The
charter bank is offered competition on a local level
by two other banks and one branch including the
main office and a local branch of Aberdeen National
Bank, with deposits of $45.8 million, and Farmers
and Merchants Bank and Trust Company, Aberdeen, with deposits of $21.9 million. Three other
banks and two branch offices of Aberdeen National
Bank provide nominal competition in the surrounding county.
The major owner of the charter bank is Northwest
Bancorporation, with total deposits of $5.2 billion, a
large regional bank holding company based in Minneapolis. The banking facility closest to the merging
bank owned by that holding company is the branch
of the charter bank located at Groton, 22 miles west
of Bristol.
The applicant banks do not compete. A survey of
customer accounts in April 1974 revealed that there
was virtually no geographical overlap between the
service areas of the two banks and that there exists
only an insignificant number of common customers.
No imbalance in the existing banking structure will
result from this merger in the area surrounding the
merging bank because of the small size of the merging bank, as well as the extremely small size of its
service area.
The proposed merger is quite possibly the only
solution to a crisis in management succession at the
merging bank. Moreover, consummation of the proposed merger will stimulate competition and foster
87

economic growth within the service area of the
merging bank because that bank has heretofore been
conservative in its loan policy while the charter bank
is considered to be very aggressive in that phase of
banking. It will also bring a significantly larger
lending limit to a region where the size of farm debt
has been rapidly increasing. Other benefits that will
accrue to customers of the resulting bank in Bristol
are a full line of trust services, the availability of
expert agricultural advice, student loans, and special checking accounts.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
AUGUST 20,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Bristol is located some 42 miles east of Aberdeen.
The office of Aberdeen Bank nearest Bristol Bank is
in Groton, Brown County, about 22 miles west of
Bristol, with no banking offices directly intervening.
The application indicates that the service areas of
the banks adjoin and to some extent overlap in the
areas nearest the Brown-Day County boundary. The
proposed merger would, therefore, eliminate a
limited amount of existing competition but would not
appear to significantly increase concentration in
banking in any relevant geographic area. We conclude that the competitive effect of this transaction
would not be significantly adverse.

NATIONAL BANK OF MISSISSIPPI, STARKVILLE, MISS., AND THE NATIONAL BANK OF COMMERCE OF
COLUMBUS, COLUMBUS, MISS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The National Bank of Commerce of Columbus, Columbus, Miss. (10361), with
and National Bank of Mississippi, Starkville, Miss. (3656), which had
consolidated Oct. 1, 1974, under charter of the latter bank (3656) and title "National Bank of
Commerce of Mississippi." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On July 1, 1974, National Bank of Mississippi,
Starkville, Miss., and The National Bank of Commerce of Columbus, Columbus, Miss., applied to the
Comptroller of the Currency for permission to consolidate under the charter of the former and with the
title of "National Bank of Commerce of Mississippi."
National Bank of Mississippi, the charter bank,
was organized in 1889 and is headquartered in Starkville in Oktibbeha County which is in northeastern
Mississippi. With IPC deposits of $41 million, the
charter bank operates two branches in Starkville
and operates offices in Maben, Aberdeen, Amory,
and Hamilton. Charter bank serves two distinct
service areas, Oktibbeha County along with small
portions of eastern Webster, northeastern Choctaw,
and southwestern Clay counties, and Monroe
County.
Direct competitors of the charter bank in the
Oktibbeha County service area include Security
State Bank, Starkville, with deposits of $36 million;
Merchants and Farmers Bank, Kosciusko, with
deposits of $36 million; Bank of Mantee, Mantee,

$38,611,251
57,810,852
96,422,102

To be
operated

6
8
14

with deposits of $6 million; and Grenada Bank,
Grenada, located in Eupora and Ackerman, with
deposits of $149 million. There is additional competition provided by other banks in peripheral areas.
Competitors of the charter bank in the Monroe
County service area include Monroe Banking and
Trust Company, Aberdeen, with deposits of $15
million; Bank of Amory, Amory, with deposits of
$19 million; and Bank of Mississippi, Tupelo, with
deposits of $145 million.
The National Bank of Commerce of Columbus,
the consolidating bank, was organized in 1913 and is
headquartered in Columbus in Lowndes County,
Miss. With IPC deposits of $27 million, the consolidating bank operates two branches in Columbus as
well as offices in Artesia, Lowndes County, and
Brooksville, Noxubee County. The service area of
the consolidating bank is defined as Lowndes and
Noxubee counties.
Direct competition is afforded the consolidating
bank by First-Columbus National Bank, Columbus,
with deposits of $45 million; Merchants and Farmers
Bank, Columbus, with deposits of $26 million;
Citizens National Bank of Meridian, Meridian,

Miss., with deposits of $53 million; and Merchants
and Farmers Bank, Macon, with $17 million in
deposits.
There is minimal competition between National
Bank of Mississippi and Bank of Commerce of
Columbus as the banks serve separate areas and do
not have a significant number of common customers.
Consummation of the proposed consolidation will
allow the resulting bank to have a higher lending
limit and a larger capital base. New services will be
offered including in-house automation facilities, specialized assistance to farm customers, and business
development and consumer advisory services.
Applying the statutory criteria it is concluded
that the proposed consolidation is in the public
interest and this application is, therefore, approved.
AUGUST 29,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The main offices of the parties are located about
21 miles apart with the nearest offices (Applicant's

Starkville branches and Bank's Artesia office) separated by a distance of about 13 miles. Thus, it
appears that the proposed consolidation will eliminate some existing competition in the StarkvilleColumbus-Artesia area. However, it does not appear
that concentration will be substantially increased in
any relevant banking markets.
Applicant may legally branch de novo into Columbus and surrounding Lowndes County. Bank is the
second largest among three commercial banks with
offices in the city of Columbus and Lowndes County,
and holds approximately 27 percent of total Lowndes
County deposits. Applicant appears to possess both
the capability and incentive to expand de novo into
Lowndes County, an area which has experienced
relatively strong economic growth. Thus, the proposed consolidation would eliminate Applicant as a
significant potential entrant into the markets presently served by Bank. The effects of this transaction
on potential competition are, however, diminished
somewhat by the existence of other significant potential de novo entrants into Bank's service area, including Grenada Bank and Bank of Mississippi.

CITIZENS BANK OF MARLTON, NATIONAL ASSOCIATION, MARLTON, N.J., AND CITIZENS STATE BANK,
VlNELAND, N . J . , AND CITIZENS NATIONAL BANK OF SOUTH JERSEY, BRIDGETON, N . J . , AND CONTINENTAL
BANK OF NEW JERSEY, MAPLE SHADE, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Citizens National Bank of South Jersey, Bridge ton, N. J. (2999), with
Citizens State Bank, Vineland, N. J., with
Continental Bank of New Jersey, Maple Shade, N.J., with
and Citizens Bank of Marlton, National Association, Marlton, N. J. (13125), which had
merged Oct. 29, 1974, under charter of the latter bank (13125) and title "Citizens United Bank,
N.A." The merged bank at date of merger had

COMPTROLLER'S DECISION

On May 23, 1974, the above banks applied to the
Comptroller of the Currency for permission to merge
under the charter of Citizens Bank of Marlton, National Association, with the title of "Citizens United
Bank, N.A.," and with the head office in Vineland,
N.J. The charter bank and the three merging banks
are all subsidiaries of Citizens Bancorp, a multi-bank
holding company.
Citizens Bank of Marlton, the charter bank, was
organized in 1927. In addition to the head office in
Marlton, it operates two branches in Evesham
Township, and has two unopened but approved

To be
operated

$ 26,441,564
50,685,279
20,129,415
33,498,441
130,754,699

branch locations in Mount Laurel Township. The
charter bank has assets of $32.1 million and IPC
deposits of $23.8 million and its service area is
essentially the southwest quadrant of Burlington
County.
The charter bank competes primarily with an
office of Heritage Bank, Cherry Hill, with deposits
of $466.6 million. Additional competition is also
provided by six nearby offices of Burlington County
Trust Company, Moorestown, with deposits of $126
million; an office of Bank of West Jersey, Delran,
with deposits of $34.4 million, which is a member of
Fidelity Union Bancorporation, Newark; an office of
Third National Bank of New Jersey, Camden, with

deposits of $50.5 million, which is a member of
United Jersey Banks, Hackensack; and an office of
Delaware Valley National Bank, Cherry Hill, with
deposits of $20.6 million.
Citizens National Bank of South Jersey, the first
merging bank, with assets of $30.4 million and IPC
deposits of $20.2 million, was organized in 1883 and
now has three branches. The service area of the
bank consists of Cumberland and Cape May counties. Its competitors include nine nearby offices of
Farmers and Mechanics National Bank, Bridgeton,
which has deposits of $47.7 million; three nearby
offices of Cumberland National Bank, Bridgeton,
which has deposits of $36.2 million, and is a member
of United Jersey Bancorp; two nearby offices of
Cape May County National Bank, Ocean City, which
has deposits of $62.7 million; Marine National Bank,
Wildwood, which has assets of $49.6 million; and
others.
Citizens State Bank, the second merging bank,
was organized in 1967. In addition to the head office
in Vineland, it operates two branches and has one
branch application pending. The bank, whose
service area is essentially Cumberland County, has
assets of $51.5 million and IPC deposits of $36.8
million.
There are two banks, with an aggregate of eight
branch offices, that operate within the service area
of Citizens State Bank and provide substantial competition for that merging bank. The first is Bank of
New Jersey, Camden, with four branch offices, and
deposits of $452.5 million. The second competing
bank is Peoples National Bank of South Jersey,
Westmont, which has four branches within the area
and deposits of $310.4 million. The deposits of each
of those two banks are significantly larger than the
combined deposits of all four banks proposed to be
merged. The resulting bank will have assets of only
$134.5 million and IPC deposits of $97.7 million.
Other competition, but to a lesser degree, is provided by two offices of Heritage Bank, with deposits
of $466.6 million; City National Bank of Millville,
with deposits of $18.5 million; and Minotola National
Bank, Minotola, with deposits of $20.6 million.
The third merging bank, Continental Bank of New
Jersey, Maple Shade, Burlington County, was
organized in 1968. It now has assets of $19.9 million
and IPC deposits of $16.9 million. The service area
of the bank is the area surrounding Maple Shade.
The only other bank operating in that area is the
$126 million deposit Burlington County Trust Company, Moorestown, which operates one office in

Maple Shade and two offices in the vicinity of, but
outside, Maple Shade.
The degree of competition among the merging
banks, including the charter bank, is minimal as
they currently comprise the membership of Citizens
Bancorp. In fact, a criterion for approving the
acquisition of the institutions by the holding company was that they did not compete inter sese. Additionally, there are at least 7 miles between the
nearest offices of any two of the banks involved in
the proposed merger. Consummation of the merger
would also eliminate head office protection from
Maple Shade and open that community to de novo
branching by other banks.
As indicated above, each bank involved in the
proposed transaction has numerous competitors,
many of which are significantly larger than the merging banks. Some of those competing banks will
remain larger than the resulting bank when the proposed merger is consummated. The resulting bank
will become the sixth largest bank operating within
its service area and will have total IPC deposits of
$97.7 million and assets of $134.5 million. Accordingly, the resulting bank will provide more effective
competition for the larger banks and subsidiaries of
bank holding companies operating throughout the
area. The resulting bank will increase competition
by offering improved and expanded services including a larger lending limit, a wider variety of loans,
overdraft banking, data processing services, and
trust department services. The bank would benefit
from economies of combined operations and more
efficient use of management personnel. Because the
area to be served by the resulting bank is undergoing
rapid growth and development in both population
and industry, the improved and expanded services
that will be provided by an additional bank that is
competitive with the larger banks operating in the
area is very much in the public interest.
Applying the statutory criteria, it is concluded
that the proposed transaction is in the public interest
and will not result in any adverse competitive
effects. This application is, therefore, approved.
SEPTEMBER 20,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The merging banks are all majority-owned subsidiaries of the same registered bank holding company. As such, their proposed merger is essentially
a corporate reorganization and would have no effect
on competition.

CITIZENS FIRST NATIONAL BANK OF NEW JERSEY, RIDGEWOOD, N.J., AND OAKLAND STATE BANK,
OAKLAND, N.J.
Banking offices

Name of bank and type of transaction

Total assets

Oakland State Bank, Oakland, N.J., with
and Citizens First National Bank of New Jersey, Ridgewood, N.J. (11759), which had
merged Oct. 31, 1974, under charter and title of the latter bank (11759). The merged bank at
date of merger had

COMPTROLLER S DECISION

On June 14, 1974, Oakland State Bank, Oakland,
N.J., and Citizens First National Bank of New
Jersey, Ridgewood, N.J., applied to the Comptroller
of the Currency for permission to merge under the
charter and with the title of the latter.
Citizens First National Bank of New Jersey, the
charter bank, was organized in 1920 as Citizens
National Bank and now operates 14 offices with
assets of $241.3 million and IPC deposits of $183.9
million. The service area of the bank has a population of approximately 220,000 persons and includes
northwest Bergen County and portions of adjacent
Passaic County, in the northeast sector of the State,
a prosperous, rapidly growing commuting and residential area which is increasingly becoming residential-industrial.
Among 26 commercial banks currently headquartered in Bergen County, the charter bank ranks
fifth in deposit size. Its larger competitors include
Peoples Trust of New Jersey, Hackensack, with
deposits of $957.3 million; National Community
Bank of Rutherford, with deposits of $638.4 million;
Garden State National Bank, Hackensack, with
deposits of $466.6 million; and Midlantic National
Bank/Citizens, Tenafly, with deposits of $263.3
million.
Oakland State Bank, Oakland, N.J., the merging
bank, was organized in 1969 and has operated from
a single office since its inception. It has recently
received approval to open a branch office in Oakland. The merging bank has assets of $9 million and
IPC deposits of $6.6 million. The bank is located in
Bergen County and ranks 25th in deposit size of the
26 banks headquartered there. Like the charter
bank, it competes with Peoples Trust of New Jersey, National Community Bank of Rutherford, and
Garden State National Bank, but it must also contend with several other banks including Urban
National Bank, Franklin Lakes, with deposits of
$28.6 million, and the even larger First National
Bank of New Jersey, Totowa, with deposits of $493.8

$ 8,566,397
241,475,526

In
To be
operation operated
2
16

249,151,711

million. The municipalities of Oakland, Franklin
Lakes, and Mahwah in Bergen County and Wanaque, Pompton Lakes, and Wayne in Passaic
County, with a combined population of nearly
100,000 people, comprise the service area of the
merging bank. That service area is predominantly
residential-commuter mixed with some recently
injected industry.
Although the nearest offices of the merging and
charter banks are 4.2 miles apart and the service
areas of the banks overlap, the substantial difference in the size of the two institutions and the
numerous banking alternatives found in their area
make any competition between them insignificant.
After consummation of the proposed merger the
resulting bank will remain the fifth largest within
its service area. Moreover, competition within the
former service area of the merging bank will be
stimulated because ineffectual management at that
bank will be replaced by strong, innovative management and its customers will derive benefit from the
introduction of trust department services, the availability of data processing, and an expanded lending
capability. Home office protection will also be
removed from Oakland as a result of the merger.
Applying the statutory criteria it is, therefore,
concluded that the proposed merger is in the public
interest and this application is approved.
SEPTEMBER 26,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Citizens First National Bank of New Jersey operates a branch office in Wyckoff, which is only 4.2
miles from Oakland. Thus, it appears that the proposed acquisition would eliminate some existing
competition between Citizens and Oakland State.
However, it does not appear that the acquisition
would substantially increase concentration in any
relevant market. Citizens' share of Bergen County
deposits would increase from 6.61 percent to 6.83
percent, increasing concentration by only 0.22
percent.

NEW JERSEY BANK (NATIONAL ASSOCIATION), CLIFTON, N.J.,
FAIRFIELD,

AND FAIRFIELD NATIONAL BANK,

N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Fairfield National Bank, Fairfield, N.J. (15857), with
and New Jersey Bank (National Association), Clifton, N.J. (15709), which had
merged Oct. 31, 1974, under charter and title of the latter bank (15709). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On May 28, 1974, Fairfield National Bank, Fairfield, N.J., and New Jersey Bank (National Association), Clifton, N.J., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
New Jersey Bank (National Association), Clifton,
N.J., the charter bank, was organized as a State
bank in 1869 and converted to the National system
in 1969. It now operates 32 offices with assets of
$695.9 million and IPC deposits of $523.6 million.
The service area of the bank consists primarily of
Passaic and Bergen counties with a concentration of
activity in the cities of Paterson, Passaic, and Clifton and some activity also in portions of Morris,
Sussex, and Warren counties. The combined estimated population of municipalities in which New
Jersey Bank has offices is 467,080.
The charter bank is the second largest of the 11
banks headquartered in Passaic County and competes primarily with National Community Bank of
Rutherford, with deposits of $638 million. Additional
competition is provided by offices of First National
Bank of New Jersey, Totowa, with deposits of $494
million; Bank of Passaic and Clifton, National Association, Passaic, with deposits of $203 million; Prospect Park National Bank, Wayne, with deposits of
$175 million; and Broadway Bank and Trust Company, Paterson, with deposits of $99 million.
Fairfield National Bank, Fairfield, N.J., the merging bank, was organized in 1971 as an affiliate of
New Jersey Bank (National Association), Clifton,
and operates solely from its Essex County head
office with assets of $8.8 million and IPC deposits of
$7.3 million. The merging bank's service area is
centered in the boroughs of Fairfield, Caldwell,
West Caldwell, and North Caldwell, a combined
estimated population of 34,855.
The merging bank ranks 17th among 19 commercial banks headquartered in Essex County and competes with First National State Bank of New Jersey,

8,095,383
758,661,811
764,858,801

To be
operated

1
32

Newark, with deposits of $1.1 billion, which is the
lead bank in First National State Bancorporation, a
multi-bank holding company with total deposits of
$1.7 billion; Midlantic National Bank, Newark, with
deposits of $860 million, which is the principal subsidiary of Midlantic Banks, Inc., a multi-bank holding company with total deposits of $1.4 billion;
American National Bank and Trust of New Jersey,
Montclair, with deposits of $396 million, which is the
lead bank in Horizon Bancorp, a multi-bank holding
company with total deposits of $506 million; Fidelity
Union Trust Company, Newark, with deposits of
$820 million, which is the principal subsidiary of
Fidelity Union Bancorporation, a multi-bank holding
company with total deposits of $1.0 billion; and
Peoples Trust of New Jersey, Hackensack, with
deposits of $957.3 million, which is the lead bank in
United Jersey Banks, a multi-bank holding company
with total deposits of $1.5 billion.
There is minimal competition between the charter
and merging banks because the two banks are commonly owned and the nearest offices are at least
2.5 miles apart. Additionally, the small size of the
merging bank and the local nature of its service
area prevent it from being a significant competitor of
the charter bank.
The resulting bank would have IPC deposits of
approximately $530.9 million and assets of $703.6
million. Consummation of the proposed merger
would afford expanded and improved services
including a larger lending limit, 24-hour banking
with automated teller machines, overdraft banking,
data processing services, a wider variety of loans,
and international services. The resulting bank will
be a more viable competitor with the much larger
holding company affiliated banks in the area. Also,
consummation of the proposed merger will eliminate
head office protection and open Fairfield to de novo
branching by other banks. Based on the foregoing,
it appears that this transaction will stimulate competition in the service area of the merging and charter
banks.

Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
SEPTEMBER 25,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

We have reviewed this proposed transaction and
conclude that it would not have a substantial competitive impact.

FIRST MISSISSIPPI NATIONAL BANK, HATTIESBURG, MISS., AND CITIZENS NATIONAL BANK,
JACKSON, MISS.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Citizens National Bank, Jackson, Miss. (15516), with
was purchased Nov. 14, 1974, by First Mississippi National Bank, Hattiesburg, Miss. (5176),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER S DECISION

On November 12, 1974, an application was made
to the Comptroller of the Currency by the First
Mississippi National Bank, Hattiesburg, Miss., for
permission to purchase assets and assume deposit
liabilities of the Citizens National Bank, Jackson,
Miss.
Pursuant to the provisions of 12 U.S.C. 181 and
12 U.S.C. 1828(c), it is found that an emergency
exists and that this Office must act immediately to
prevent the probable failure of the Citizens National

$161,540,607

38,404,720
199,939,304

To be
operated

Bank, Jackson, Miss., and to protect its depositors,
creditors, and shareholders.
Accordingly, approval by the shareholders of the
Citizens National Bank of the purchase and sale
agreement is waived and the First Mississippi National Bank is authorized to proceed with the purchase and assumption transaction.
NOVEMBER 14,

1974.

NOTE: Due to the emergency nature of the situation, no report on competitive factors was requested.

* * *
PITTSBURGH NATIONAL BANK, JEANETTE, PA., AND BLAIRSVILLE NATIONAL BANK, BLAIRSVILLE, PA.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

Blairsville National Bank, Blairsville, Pa. (13868), with
$ 26,794,514
was purchased Nov. 15, 1974, by Pittsburgh National Bank, Jeannette, Pa. (252), which h a d . . 2,753,171,005
After the purchase was effected, the receiving bank had
2,779,308,557

COMPTROLLER'S DECISION

On July 8, 1974, Pittsburgh National Bank, Jeannette, Pa., applied to the Comptroller of the Currency for permission to purchase the assets and
assume the liabilities of Blairsville National Bank,
Blairsville, Pa.
Pittsburgh National Bank, the purchasing bank,
was founded in 1864 and now has assets of $2.5
billion and IPC deposits of $1.2 billion. The bank is
headquartered in Westmoreland County and oper

To be
operated

2
94
96

ates 92 offices serving all of Allegheny, Westmoreland, Butler, and Washington counties. As a result
of relocation of its headquarters in 1973, the purchasing bank can legally expand in four additional
counties: Indiana, Cambria, Somerset, and Fayette.
Indiana County is the only one of the four into
which the bank has expanded since the head office
relocation. Two offices are operated in the borough
of Indiana, 15 miles north of Blairsville.
Principal competitors of purchasing bank include,
Mellon Bank, N.A., Pittsburgh, with deposits of $7.4

billion; Equibank, N.A., Pittsburgh, with deposits of
$1.4 billion; Union National Bank of Pittsburgh with
deposits of $768 million; Iron and Glass Bank, Pittsburgh, with deposits of $28 million; Commercial
Bank and Trust Co., Pittsburgh, with deposits of
$65 million; and Allegheny Valley Bank of Pittsburgh with deposits of $27 million.
Blairsville National Bank, the selling bank, was
founded in 1933 and operates a main office and
drive-in facility in Blairsville. With assets of $25.5
million and IPC deposits of $20 million, the selling
bank primarily serves Blairsville. The selling bank
ranks third in size among the banks serving Blairsville and fourth in size among the six banks headquartered in Indiana County.
Primary competitors for the selling bank are The
Savings and Trust Company of Indiana, with deposits of $77 million; National Bank of the Commonwealth, Indiana, with deposits of $105 million; and
Homer City State Bank, Homer City, with deposits
of $28 million.
There is no competition between the buying and
selling banks. The nearest office of Pittsburgh National Bank is 15 miles from the selling bank. Both
the National Bank of the Commonwealth and the
Homer City State Bank are established viable competitors.
Consummation of the proposed transaction will
result in no adverse competitive effects and the

resulting bank will be an aggressive competitor in
the Blairsville service area. A small unaggressive
bank with aged management will be replaced by a
sophisticated metropolitan bank capable of providing better and more efficient banking services to the
customers of selling bank.
Applying the statutory criteria it is concluded that
the proposed transaction is in the public interest and
this application is, therefore, approved.
OCTOBER 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are located about
15 miles apart in Indiana County with several competitive alternatives in the intervening area. It
appears that the proposed acquisition would eliminate some existing competition. However, it does
not appear that the proposed transaction would
substantially increase banking concentration in any
relevant market. And in view of the modest size of
Blairsville Bank and the nature of the community
which it serves, we conclude that the proposed
transaction will not eliminate substantial potential
competition.
Therefore, we conclude that the proposed transaction would not have a substantial competitive
impact.

THE FIRST NATIONAL BANK OF EASTERN PENNSYLVANIA, WILKES-BARRE, PA., AND THE BERWICK
NATIONAL BANK, BERWICK, PA.
Banking offices
Total assets

Name of bank and type of transaction

The Berwick National Bank, Berwick, Pa. (6162), with
and The First National Bank of Eastern Pennsylvania, Wilkes-Barre, Pa. (30), which had
merged Nov. 15, 1974, under charter of the latter bank (30) and title "First Eastern Bank,
National Association." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 3, 1974, Berwick National Bank, Berwick,
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 of the latter and with the title,
"First Eastern Bank, National Association."
First National Bank of Eastern Pennsylvania, the
charter bank, was organized in 1863 and now has
94

$ 22,048,850
381,565,461
403,091,570

In
To be
operation operated
2
21
23

assets of $364 million and IPC deposits of $259
million. Headquartered in Wilkes-Barre, Pa., the
charter bank through its main office and 20 branches
serves all of Luzerne County, the northern 80 percent of Monroe County, and west-central Columbia
County. The bank's influence is felt in Lackawanna
and Carbon counties although it has no offices in
either.
The charter bank is the fourth largest bank in
Wilkes-Barre. The principal competitors of charter

bank include Northeastern Bank of Pennsylvania,
Scranton, with current deposits of $422 million; First
Valley Bank, Lansford, with deposits of $417 million;
United Penn Bank, Wilkes-Barre, with deposits of
$377 million; The Wyoming National Bank of
Wilkes-Barre, with deposits of $123 million; and
Hanover National Bank of Wilkes-Barre with
deposits of $54 million.
The Berwick National Bank, the merging bank,
was organized in 1902 and is headquartered in Berwick, Pa., about 28 miles southwest of WilkesBarre. With assets of $22.3 million and IPC deposits of $19 million, the merging bank operates one
branch in Mifflinville, about 5 miles southwest of
Wilkes-Barre. Its service area is confined to Berwick
and its immediate environs.
The principal competitors in the merging bank's
service area include United Penn Bank, WilkesBarre, with deposits of $377 million; The First
National Bank of Berwick, with deposits of $30
million; The Columbia County Farmers National
Bank of Orangeville, with deposits of $20 million;
and The First National Bank of Mocanaqua, with
deposits of $14.5 million.
The charter bank's East End Office in Bloomsburg
and the merging bank's Mifflinville Office are their
closest offices and are 8 miles apart. Geographic
barriers which consist of hills, farmland, and the
Susquehanna River prevent those two offices from
significantly competing with each other.

Consummation of the proposed merger will stimulate competition as merging bank will be better able
to compete with the larger United Penn Bank. The
resulting bank will offer new and improved services
in Berwick such as specialized lending services and
trust services. The bank will also offer a considerably larger lending limit.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
OCTOBER 9,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Although the main offices of the parties are separated by a distance of about 30 miles, First National's Conyngham (Luzerne County) office is situated about 9 miles east, and its Bloomsburg
(Columbia County) office about 9 miles west, of Berwick Bank's nearest office. Although there are
competitive alternatives in the intervening areas, it
nevertheless appears that the proposed merger
would eliminate some existing competition between
the parties. Moreover, First National could legally
establish de novo offices in the Berwick area in
east-central Columbia County.
Therefore, we conclude that some existing competition, as well as the potential for increased
competition, will be eliminated by this proposed
transaction.

NATIONAL BANK OF THE COMMONWEALTH, INDIANA, PA., AND THE HOUTZDALE BANK, HOUTZDALE, PA.
Banking offices

Name of bank and type of transaction

Total assets

The Houtzdale Bank, Houtzdale, Pa., with
was purchased Nov. 18, 1974, by National Bank of the Commonwealth, Indiana, Pa. (14098),
which had
After the purchase was effected, the receiving bank had

$ 10,707,621

121,653,773
128,460,082

COMPTROLLER'S DECISION

On July 15, 1974, National Bank of the Commonwealth, Indiana, Pa., applied to the Comptroller of
the Currency for permission to purchase the assets
and assume the liabilities of The Houtzdale Bank,
Houtzdale, Pa.
National Bank of the Commonwealth, the purchasing bank, was chartered in 1934 and currently
has assets of $118.7 million and IPC deposits of

In
To be
operation operated

$104.6 million. The bank, headquartered in Indiana
County, operates 11 branches and serves portions
of Indiana, Jefferson, Cambria, Armstrong, and
Westmoreland counties. The economy of the service
area is supported by soft coal production, farming,
and a variety of light industries.
National Bank of the Commonwealth is the eighth
largest bank operating in the Pittsburgh area and all
the large Pittsburgh banks are, in effect, its competitors. If the proposed transaction is approved, the
95

purchasing bank will remain eighth in size and still
be considerably smaller than number seven.
The Houtzdale Bank, Houtzdale, Pa., the selling
bank, was organized in 1918 and operates as a
unit bank about 66 miles northeast of Indiana, Pa.
The bank, with total assets of $9.8 million and IPC
deposits of $7.8 million, is fourth in size among
four banks in its service area which includes the
area surrounding Houtzdale, north to Philipsburg
and south to Coalport.
Competition for the selling bank is provided by the
three larger banks operating in the selling bank's
service area. They are County National Bank, Clearfield, with $54 million in deposits; Clearfield Bank
and Trust Co., Clearfield, with $32 million in deposits; and First National Bank of Philipsburg with $27
million in deposits. Upon consummation of the proposed transaction, the resulting bank will become
the largest in the area. However, if the pending
merger of First National Bank of Philipsburg and
Mid-State Bank and Trust Company, Altoona, is
consummated, the bank resulting from that transaction will be the largest in the area.
Approval of the subject transaction will not
diminish competition in the selling bank's service

area. There is no competition between the purchasing and selling banks, as their nearest offices are
about 26 miles apart. The sparsely inhabited and
densely forested intervening area precludes possibility of competition between the two banks. The insignificant amount of business conducted by the purchasing bank in the selling bank's service area
results from the selling bank's inability to grant and
service the type loans demanded by local industries.
Consummation of the proposed transaction will
result in no adverse competitive effects. Additionally, the resulting bank will provide an expanded
range of services to the residents and businesses of
the Houtzdale area such as larger lending limits and
other services afforded by larger commercial banks.
Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
this application is, therefore, approved.
OCTOBER 16,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

We have reviewed this proposed transaction and
conclude that it would not have a substantial competitive impact.

BANKERS TRUST COMPANY OF ALBANY, NATIONAL ASSOCIATION, ALBANY, N.Y.,
NATIONAL BANK OF COOPERSTOWN, COOPERSTOWN,

AND THE FIRST

N.Y.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank of Cooperstown, Cooperstown, N.Y. (280), with
and Bankers Trust Company of Albany, National Association, Albany, N.Y. (15758), which had..
merged Nov. 29, 1974, under charter and title of the latter bank (15758). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On July 10, 1974, The First National Bank of
Cooperstown, Cooperstown, N.Y., and Bankers
Trust Company of Albany, National Association,
Albany, N.Y., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
Bankers Trust Company of Albany, National
Association, the charter bank, was organized in 1838
and now operates 25 branch offices with assets of
$270.9 million and IPC deposits of $161.2 million. In
addition to the 25 operating branch offices, Bankers
Trust Company of Albany has approval to open
branches at three new locations. The charter bank
96

% 17,791,081
266,520,970
284,312,051

To be
operated

1
26
27

is a member of Bankers Trust New York Corporation, a multi-bank holding company with nine member banks and total deposits of $14.0 billion. Its
service area includes the central and eastern portion
of the Fourth Banking District of New York, with an
estimated population of 505,300.
The charter bank is ranked third in deposit size
among the eight commercial banks headquartered
in Albany County and among the 30 commercial
banks headquartered in the Fourth Banking District
of New York. Competition for the bank is provided
by National Commercial Bank and Trust Company,
Albany, with deposits of $796 million, which is a
member of United Bank Corporation of New York;
Citibank (Eastern), National Association, Castleton-

Consummation of the proposed merger will stimulate competition in the service area of the merging
bank. In Cooperstown the merger will eliminate
head office protection afforded by New York State
law and open the community to de novo branching by
other banks. Additionally, a branch office of the
resulting bank will provide the banking public in
Cooperstown with improved and expanded services
including a larger lending limit, a wider variety of
loans, a credit card program, expanded personal and
corporate trust services, investment services, and
international banking services. The deposit size of
the resulting bank relative to commercial banks
headquartered in Albany County in the Fourth Banking District will not be changed by consummation of
the merger. The resulting bank will have total
deposits of $249 million.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and this
application is, therefore, approved.

on-Hudson, with deposits of $23 million, which is a
member of Citicorp; and Marine Midland BankEastern, National Association, Troy, with deposits
of $189.7 million, which is a member of Marine
Midland Banks, Inc.
The First National Bank of Cooperstown, the
merging bank, with assets of $17.2 million and IPC
deposits of $14.0 million, was organized in 1830 and
has operated as a unit institution since that time. Its
service area includes the northern portion of Otsego
County in the Fourth Banking District of the State of
New York and has an estimated population of
39,000.
The merging bank is the smaller of the two commercial banks headquartered in Otsego County and
ranks 24th in deposit size among the 30 commercial
banks headquartered in the Fourth Banking District
of New York State. In addition to in-county competition provided by Wilber National Bank of Oneonta,
with deposits of $55.6 million, competition is provided by State Bank of Albany; National Commercial
Bank and Trust Company; and Central National
Bank, Canajoharie, with deposits of $69 million.
There is no significant competition between the
charter and merging banks. Bankers Trust Company
of Albany, National Association has no offices in
Otsego County and the closest offices of the charter
and merging banks are approximately 50 miles apart.
Accordingly, the two banks do not provide services
to a common area. The small size of the merging
bank and its conservative nature also preclude the
possibility of significant competition with the charter
bank.

INDIAN HEAD NATIONAL BANK OF NASHUA, N.H.,

OCTOBER 23,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Applicant's office nearest Bank is located in
Johnstown, Fulton County, about 50 miles northeast
of Cooperstown. Thus, it appears that the proposed
transaction would not eliminate substantial existing
competition. And in view of the existence of other
significant potential entrants and Bank's modest
market position in the Coopers to wn-Otsego County
area, we conclude that the proposed merger will not
eliminate substantial potential competition.

AND INDIAN HEAD NATIONAL BANK OF MANCHESTER,

MANCHESTER,

N.H.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Indian Head National Bank of Nashua, Nashua, N.H. (1310), with
and Indian Head National Bank of Manchester, Manchester, N.H. (15563), which had
consolidated Nov. 29, 1974, under charter of the latter bank (15563) and title "Indian Head
National Bank of Nashua." The consolidated bank at date of consolidation had

COMPTROLLER'S DECISION

On July 8, 1974, Indian Head National Bank of
Manchester, Manchester, N.H., and Indian Head
National Bank of Nashua, Nashua, N.H., applied to
the Comptroller of the Currency for permission to

$105,753,788
11,817,634
117,571,421

To be
operated

6
2

consolidate under charter of the former and title of
the latter with the main office in Nashua.
Indian Head National Bank of Manchester, the
charter bank, was organized in 1921 but did not convert to National bank status until 1965. In addition
to its main office, the bank presently operates a

branch office in Goffstown, 4 miles west of Manchester. The charter bank holds assets of $11.9
million and IPC deposits of $9.5 million. The service
area of the bank is southern New Hampshire, and
consists of the city of Manchester, with a population
of 97,000 persons, which is currently undergoing an
economic revival, and portions of surrounding Hillsborough County, a rapidly growing region which is
the center of an electronics industry.
The charter bank encounters vigorous competition
from several of the State's largest commercial institutions. Among the larger are The Manchester Bank
with deposits of $145 million; Bank of New Hampshire, N.A., Manchester, with deposits of $121 million; The Merchants National Bank, Manchester,
with deposits of $36.9 million, which is an affiliate of
First New Hampshire Bancorp, Inc.; and Amoskeag
National Bank and Trust Company, Manchester,
with deposits of $39.7 million.
Indian Head National Bank of Nashua, the consolidating bank, was chartered in 1851 and converted
to National bank status in 1865. The bank operates
five branches, four of which are located in the nearby
towns of Hudson, Merrimack, Salem, and Wilton,
and maintains total assets of $107.4 million and IPC
deposits of $75.9 million. The service area of the
consolidating bank is situated on New Hampshire's
southern border and consists of the thriving retail
trade center of Nashua, one of the State's major
cities, with an estimated population of 63,000
people, as well as portions of Hillsborough County,
the State's fastest growing county with a population
of approximately 256,000.
Branches of New Hampshire's second-largest
banking institution, Bank of New Hampshire, N.A.;
Nashua Trust Company, with deposits of $68.5 million; and Colonial Trust Company, with deposits of
$14.5 million, provide significant competition for the
consolidating bank.

Between the charter and consolidating banks
there is only minimal competition because they serve
distinct service areas. Their closest two offices are
separated by a relatively large distance and an adequate number of banking facilities operate as alternatives in eastern Hillsborough County. The closest
offices of the two banks are approximately 15 miles
apart, and the small size of the charter bank prevents it from being a significant competitor for the
consolidating bank. The fact that both banks are
owned by the same holding company, Indian Head
Banks, Inc., Nashua, N.H., further eliminates the
possibility of meaningful competition.
Within its service area the charter bank has
ceased to be a viable competitor because any sizable
or sophisticated lending request must be forwarded
to the consolidating bank due to the size and management limitations of the charter bank. Consummation of the proposed consolidation will infuse increased competition into the present service area of
Indian Head National Bank of Manchester. To that
area the resulting bank will bring an increased lending limit, specialized trust and investment departments, and various types of lending expertise heretofore unavailable directly from the charter bank.
Those changes will make the resulting branch in
Manchester a more vital participant in the economic
life of the city.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
OCTOBER 15,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The consolidating banks are both majority-owned
subsidiaries of the same bank holding company. As
such, their proposed consolidation is essentially a
corporate reorganization and would have no effect
on competition.

MECHANICS NATIONAL BANK OF DELAWARE VALLEY, BURLINGTON TOWNSHIP, N.J.,
BANK AND TRUST COMPANY, EGG HARBOR CITY,

AND EGG HARBOR

NJ.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Egg Harbor Bank and Trust Company, Egg Harbor City, N.J., with
and Mechanics National Bank of Delaware Valley, Burlington Township, N.J. (1222), which
had
merged Nov. 29, 1974, under charter of the latter bank (1222) and title "First National State
Bank/Mechanics." The merged bank at date of merger had

$ 24,280,566

109,646,386

133,926,951

To be
operated

COMPTROLLER'S DECISION

On July 9, 1974, Egg Harbor Bank and Trust
Company, Egg Harbor City, N.J., and Mechanics
National Bank of Delaware Valley, Burlington Township, N.J., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title, "First National State
Bank/Mechanics.''
Mechanics National Bank of Delaware Valley, the
charter bank, was organized in 1839 and is a subsidiary of First National State Bancorporation,
Newark, N.J. The bank has assets of $106.7 million
and IPC deposits of $76 million and operates 13
branch offices and three facilities in Burlington
County. Ten of the branches are in the Trenton
service area and three are in the Camden service
area.
Competitors of charter bank in Burlington County
include Burlington County Trust Company, Moorestown, with total deposits of $126 million; Bank of
Mid-Jersey, Bordentown Township, with total
deposits of $59 million; Provident Bank of New Jersey, Willingboro, with total deposits of $405 million,
which is a member of Greater Jersey Bancorp, a
multi-bank holding company with total deposits of
$711 million; The Burlington County National Bank,
Medford, with total deposits of $35 million; Bank of
West Jersey, Delran, with total deposits of $34.4
million, which is a member of Fidelity Union Bancorporation, a multi-bank holding company with
total deposits of $1 billion; and Continental Bank of
New Jersey, Maple Shade, with total deposits of
$18 million.
Egg Harbor Bank and Trust Company, the merging bank, was organized in 1925. The bank is headquartered in Egg Harbor City and operates branches
in the townships of Mullica and Galloway. With
assets of $24.5 million and IPC deposits of $18 million, the merging bank is fifth in deposit size among
the seven commercial banks headquartered in
Atlantic County.
Competition from banks headquartered in Atlantic
County is provided by First National Bank of South
Jersey, Pleasantville, with deposits of $403 million;
Guarantee Bank, Atlantic City, with deposits of $120
million; Atlantic National Bank, Atlantic City, with

deposits of $41 million; First National Bank of Absecon, Absecon, with deposits of $25 million; Minotola
National Bank, with deposits of $21 million; and The
Mainland Bank, Linwood, with deposits of $16
million.
There is minimal competition between the charter
and merging banks as their closest offices are more
than 30 miles apart. Moreover, the banks' present
service areas are separated by a sparsely populated
area known as the Pine Barrens. The nearest office
of another subsidiary bank of First National State
Bancorporation is located some 37 miles from the
Pomona office of the merging bank.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting bank will offer improved
services such as an expanded trust department,
lease financing facilities, international bank services, and an increased lending limit. The resulting
bank will remain the second largest commercial
bank headquartered in Burlington County.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and this
application is, therefore, approved.
OCTOBER 9,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are separated by
a distance of approximately 30 miles, with the New
Jersey "Pine Barrens" lying in the intervening area.
Thus, we conclude that the proposed transaction
would not eliminate substantial existing competition.
Commercial banking in Atlantic County is highly
concentrated, with the four largest institutions controlling approximately 88 percent of total county
deposits. Applicant's parent, First National State
Bancorporation, is the largest commercial banking
organization in the State of New Jersey. As such, it
has the capability and incentive to expand de novo
into Atlantic County and elsewhere in southeastern
New Jersey. However, in view of the existence of
other significant potential entrants and Bank's
modest (approximately 4.1 percent of Atlantic
County deposits) market position, we conclude that
the proposed merger would not eliminate substantial
potential competition.

SECURITY NATIONAL BANK OF KANSAS CITY, KANSAS CITY, KANS., AND THE VICTORY STATE BANK,
KANSAS CITY, KANS.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Victory State Bank, Kansas City, Kans., with
and Security National Bank of Kansas City, Kansas City, Kans. (13801), which had
merged Nov. 29, 1974, under charter and title of the latter bank (13801). The merged bank at
date of merger had

COMPTROLLER S DECISION

On June 10, 1974, Security National Bank of
Kansas City, Kansas City, Kans., applied to the
Comptroller of the Currency for permission to merge
with The Victory State Bank, Kansas City, Kans.,
under the charter and title of the former.
Security National Bank of Kansas City, Kansas
City, Kans., the charter bank, was chartered in 1933
and currently has assets of $151.3 million and IPC
deposits of $67 million. The bank is located in the
2-state Kansas City Metropolitan Area, and is the
sixth largest bank in that area. It is the second
largest of the 19 banks in the Kansas sector of the
metropolitan area.
Competition for the charter bank is provided by
Commercial National Bank of Kansas City, Kans.,
with total deposits of $154.4 million; The Brotherhood State Bank, Kansas City, Kans., with total
deposits of $44.5 million; and The First State Bank
of Kansas City, Kans., with total deposits of $23.3
million. Additional competition is provided by the
larger Kansas City, Mo., banks including Commerce
Bank of Kansas City, N.A., with deposits of $583.4
million, and United Missouri Bank of Kansas City,
N.A., with deposits of $461.4 million.
The Victory State Bank, Kansas City, Kans., the
merging bank, was chartered in 1929 and currently
has assets of $9.2 million and IPC deposits of $6.5
million. The merging bank is the 92nd largest of the
107 banks in the Kansas City Metropolitan Area.
Victory State Bank is controlled by the same family
group that controls the charter bank, and, in the
past, has been considered an affiliate of the charter
bank.
Competition between the charter bank and the
merging bank is almost nonexistent, despite the fact
that their offices are located 1 mile apart. That is
because of the nature of the respective banks'

100

To be
operated

9,128,913
169,462,647
178,591,559

business. The merging bank is a small retail bank
serving a local neighborhood. The charter bank is
primarily a wholesale and correspondent bank serving the metropolitan area. The proposed merger will
not significantly increase the charter bank's size and
share of deposits.
Consummation of the proposed transaction will
result in no adverse competitive effects. The merger
will formalize an already strong affiliation between
the two banks and it will resolve the management
succession and staffing problems confronting Victory State Bank. The merger will also enable the
merging bank to provide additional services such as
data processing facilities and an improved trust
department.
Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
is, therefore, approved.
OCTOBER 24,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Applicant is headquartered in downtown Kansas
City with Bank's headquarters situated about 1 mile
to the west. Accordingly, the proposed merger
would apparently eliminate competition between the
parties and slightly increase concentration in commercial banking in the Kansas City area.
The application indicates that the parties are
commonly owned by a group of individuals which
collectively hold 52.5 percent of Applicant's stock
and 81.4 percent of the stock of Bank. The application does not, however, contain sufficient information to evaluate the effects, if any, of this common
ownership on the competitive effects of the proposed
merger. Thus, we express no opinion on the effect
of common stock ownership and management on the
foregoing competitive report.

VERMONT NATIONAL BANK, BRATTLEBORO, V T . , AND MONTPELIER NATIONAL BANK, MONTPELIER, V T .

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Montpelier National Bank, Montpelier, Vt. (13915), with
and Vermont National Bank, Brattleboro, Vt. (1430), which had
merged Nov. 29, 1974, under charter and title of the latter bank (1430). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On July 19, 1974, Montpelier National Bank,
Montpelier, Vt., and Vermont National Bank,
Brattleboro, Vt., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
Vermont National Bank, the charter bank, was
organized in 1821 and now operates 14 branches. It
has assets of $111.5 million and IPC deposits of $92
million. The service area of the bank constitutes
southern Vermont which is primarily rural with
population centered around the towns of Bennington, Brattleboro, Rutland, and Springfield.
The charter bank is presently the fifth largest
bank in Vermont and competes primarily with the
four larger banks. Those competitors are Chittendon
Trust Company, Burlington, with deposits of $216
million; Burlington Savings Bank, Burlington, with
deposits of $207 million; The Howard Bank, Burlington, with deposits of $169 million; and First Vermont Bank and Trust Company, Brattleboro, with
deposits of $143 million.
Montpelier National Bank, the merging bank, was
organized in 1824 and operates one branch 3.5 miles
from its main office in Montpelier. The branch is
halfway between the cities of Montpelier and Barre.
The service area of the merging bank, which has
assets of $34.4 million and IPC deposits of $28
million, includes both Barre and Montpelier.
The merging bank's principal competitors in the
Montpelier-Barre service area are Chittendon Trust
Company, Burlington, with deposits of $216 million;
The Howard Bank, Burlington, with deposits of $169
million; and The First Vermont Bank and Trust
Company, Brattleboro, with deposits of $143 million.
There is no competition between the charter and
merging banks because their closest offices are 55

$ 34,785,131
154,110,108

To be
operated

2
15
17

154,110,108

miles apart. Consummation of the proposed merger
will stimulate competition in the service area of the
merging bank as the resulting bank will offer new
and improved services such as more varied deposit
and loan options. The merger will also solve Montpelier National Bank's management succession
problem. The resulting bank will remain the fifth
largest in Vermont.
Applying the statutory criteria it is concluded that
the proposed merger is in the public interest and the
application is, therefore, approved.
OCTOBER 22,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest offices of the parties are separated by
a distance of more than 50 miles. Thus, it does not
appear that the proposed transaction will eliminate
substantial existing competition.
Montpelier National is presently the second
largest bank in the Montpelier-Barre area with
approximately 20 percent of total deposits. The three
largest banks in the Montpelier-Barre market hold
about 66 percent of total deposits. Vermont National, the fourth largest bank in Vermont, is currently the largest bank in the State not yet represented in the Montpelier-Barre area; clearly, it has
the capability and resources for de novo entry rather
than through acquisition as here proposed. However,
while the economy of the Montpelier-Barre area is
basically sound, its growth rate appears somewhat
limited. Furthermore, there are at present at least
two approved charters for new (but not yet opened)
offices in the area by banks already located there.
Under the circumstances, the proposed acquisition
of Montpelier National by Vermont National would
not have a significantly adverse effect on potential
competition.

101

OLD NATIONAL BANK OF WASHINGTON, SPOKANE, WASH., AND GUARANTY NATIONAL BANK OF
WHITE CENTER, SEATTLE, WASH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Guaranty National Bank of White Center, Seattle, Wash. (14502), with
was purchased Dec. 2, 1974, by Old National Bank of Washington, Spokane, Wash. (4668),
which had
After the purchase was effected, the receiving bank had

COMPTROLLER'S DECISION

On August 8, 1974, Old National Bank of Washington, Spokane, Wash., applied to the Comptroller
of the Currency for permission to purchase the
assets and assume the liabilities of Guaranty National Bank of White Center, Seattle, Wash.
Old National Bank of Washington, the purchasing
bank, was organized in 1891 and presently has total
assets of $478 million and IPC deposits of $383
million. The purchasing bank is headquartered in
Spokane in eastern Washington and 46 of its 54
branches are located east of the Cascade Mountains.
Its eight other branches are located in western
Washington, with one in Ferndale, five in Lynnwood,
and two in downtown Seattle. The economy of the
area served by the purchasing bank in the eastern
part of the State is based on agriculture; that of the
area served in the western part of the State is supported by the aerospace industry and forestry. The
purchasing bank is a subsidiary of Washington Baneshares, Inc., a registered bank holding company.
Competition for the purchasing bank in western
Washington is provided by Seattle-First National
Bank, Seattle, with deposits of $2.9 billion; National
Bank of Commerce of Seattle with deposits of $1.9
billion; Pacific National Bank of Washington,
Seattle, with deposits of $727 million; and Peoples
National Bank of Washington, Seattle, with deposits
of $565 million; and, in eastern Washington, is provided by Fidelity Mutual Savings Bank, Spokane,
with deposits of $329 million; and branches of the
larger Seattle-based banks.
Guaranty National Bank of White Center, the
selling bank, was organized in 1945 and presently
operates two branches. It has total assets of $22.6
million and IPC deposits of $19.8 million. The primary service area of the selling bank encompasses
the western portion of central King County, a residential area with little industry.
Competition for the selling bank is provided by
Seattle-First National Bank, Seattle, with deposits
of $2.9 billion; National Bank of Commerce of

102

$ 23,353,005

516,351,980
564,941,922

To be
operated

Seattle, with deposits of $1.9 billion; Pacific National
Bank of Washington, Seattle, with deposits of $727
million; and Continental Bank of Burien, with
deposits of $11.8 million.
There is little, if any, competition between the
purchasing and selling banks because relatively large
distances separate their closest offices and an adequate number of alternative banking facilities operate in the intervening area. The nearest branch of
the purchasing bank is located in downtown Seattle,
8 miles from Guaranty National Bank of White
Center. In addition, the selling bank is situated west
of the Cascade Mountains, where the purchasing
bank derives a small minority of its total business.
The head offices of the two banks are 283 miles
apart.
Consummation of the proposed transaction will
result in no adverse competitive effects. The purchasing bank will remain the sixth largest bank in
the State. The transaction will have a favorable
effect upon competition by enabling the purchasing
bank to achieve further penetration into the western
part of the State and strengthen its competitive
position among the larger banks in Washington. In
addition, the purchasing bank will introduce new
and improved services to the residents of the service
area of the selling bank such as an increased lending
limit and trust services. Furthermore, consummation of the proposed transaction will alleviate the
management succession problem of Guaranty National Bank of White Center.
Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
this application is, therefore, approved.
OCTOBER 30,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

ONB's headquarters and the bulk of its operations
lie east of the Cascade Mountains. It does, however,
operate two branch offices in Seattle, King County.
As of June 30, 1973, ONB's two Seattle offices held

total deposits of $16.5 million. Guaranty's main
office is located over 8 miles south of downtown
Seattle in the residential community of White
Center; its two remaining offices are located 3 and
13 miles southeast of the headquarters office in
Boulevard Park and Renton. The proposed transaction appears to represent the consolidation of a

downtown Seattle bank which holds a small share of
the area's deposits with a small suburban community
bank. Although the proposal will eliminate some
existing competition as well as the potential for
increased future competition, we conclude that,
overall, the proposal would not have a significantly
adverse effect on competition.

THIRD NATIONAL BANK OF NEW JERSEY, CAMDEN, N.J., AND UNITED JERSEY NATIONAL BANK OF CHERRY
HILL, CHERRY HILL, N J .

Banking offices
Name of bank and type of transaction

Total assets
In
operation

United Jersey National Bank of Cherry Hill, Cherry Hill, N J . (15971), with
and Third National Bank of New Jersey, Camden, N. J. (13203), which had
merged Dec. 2, 1974, under charter of the latter bank (13203) and title "United Jersey Bank/
Third National." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 16, 1974, United Jersey National Bank
of Cherry HiU, Cherry Hill, N.J., and Third National
Bank of New Jersey, Camden, N.J., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and title of "United
Jersey Bank/Third National."
Third National Bank of New Jersey, the charter
bank, was organized in 1928 and currently operates
11 banking offices with assets of $58.2 million and
IPC deposits of $46 million. It is a member of
United Jersey Banks, a multi-bank holding company.
The charter bank's service area includes portions of
Camden, Burlington, and Gloucester counties, an
urban and suburban area with an estimated population of 224,000. The charter bank ranks sixth in size
among the 12 commercial banks headquartered in
Camden, and 10th among the 20 banks in its service
area. Competition is provided by Heritage Bank
National Association, Cherry Hill, with deposits of
$467 million, which is a member of Heritage Bancorporation, a multi-bank holding company; The
Bank of New Jersey, Camden, with total deposits of
$452 million, which is a member of Bancshares of
New Jersey; Peoples National Bank of New Jersey,
Westmont, N.J., with deposits of $310 million; and
Midlantic National Bank/South, Haddonfield, with
deposits of $195 million, which is a member of
Midlantic Banks, Inc. Competition is also provided
by Burlington County-based banks including
Mechanics National Bank of Delaware Valley,

$10,836,278
64,102,809
74,939,087

To be
operated

2
11
13

Burlington Township, with deposits of $97 million,
which is a member of First National State Bancorporation, and Burlington County Trust Company,
Moorestown, with deposits of $126 million.
United Jersey National Bank of Cherry Hill, the
merging bank, was organized in 1972 and currently
has two offices with assets of $10.4 million and IPC
deposits of $8.7 million. The merging bank is a member of United Jersey Banks, the same multi-bank
holding company that owns the charter bank. The
service area of the merging bank is the residential
suburb of Cherry Hill, a rapidly-growing community
with an estimated population of 67,000. The same
banks that are headquartered in Camden and compete with the charter bank also compete with the
merging bank.
Competition between the merging bank and the
charter bank is minimal. The charter bank has only
a small percentage of deposits from the merging
bank's service area. The closest offices of the two
banks are 4 miles apart, in a developed area. The
fact that both banks are members of the same
holding company also has minimized meaningful
competition.
Consummation of the proposed transaction will
result in no adverse competitive effects. The resulting bank will remain the sixth largest bank headquartered in Camden County. The proposed merger
will enable the banks to compete more effectively
with the larger banks in the area. The resulting bank
will have a larger lending limit and will be able to
offer its customers more convenience in the form of

103

an increased number of banking offices. Customers
of the resulting bank will be able to make use of
trust services not previously offered by the merging
bank. The proposed merger will also benefit both
banks in achieving certain economies of scale by
combining administrative and advertising services
and eliminating duplication in other areas.
Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
will result in no adverse competitive effects. This

application is, therefore, approved.
NOVEMBER 1,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

HARRISON COUNTY NATIONAL BANK, HOPEDALE, OHIO, AND THE FREEPORT STATE BANK, FREEPORT, OHIO

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Freeport State Bank, Freeport, Ohio, with
and Harrison County National Bank, Hopedale, Ohio (6938), which had
merged Dec. 21, 1974, under charter and title of the latter bank (6938). The merged bank at date
of merger had

COMPTROLLER S DECISION

On August 21, 1974, Harrison County National
Bank, Hopedale, Ohio and The Freeport State Bank,
Freeport, Ohio applied to the Comptroller of the
Currency for permission to merge under the charter
and title of the former.
Harrison County National Bank, the charter
bank, was organized in 1903 and currently has
assets of $9 million and IPC deposits of $7.7 million.
It is a member of First Steuben Bancorp, Inc.,
Steubenville, Ohio, the 12th largest of 16 multi-bank
holding companies in the State, which controls three
banks with aggregate deposits of $145.3 million. The
charter bank serves a predominantly coal mining
and industrial area with a total population of 7,900.
In October 1974, the charter bank will open its first
branch 4 miles from its Hopewell office in Cadiz,
Ohio, the county seat of Harrison County, which has
an estimated population of 3,200. Competition is
provided by First National Bank of Cadiz, with total
deposits of $15.6 million, which is a member of
BancOhio Corporation, the largest multi-bank holding company in the State, and Scio Bank Company,
Scio, with deposits of $9.3 million.
Freeport State Bank, the merging bank, is a unit
institution chartered in 1915 and currently has assets
of $2.5 million and IPC deposits of $2.1 million.
104

To be
operated

$' 2,866,775
9,505,483
12,372,258

The merging bank serves the village of Freeport and
the surrounding area. Major competitors are First
National Bank of Cadiz; Citizens National Bank of
Flushing, with deposits of $10.7 million; and The
Community National Bank, Flushing, with deposits
of $9.6 million.
Competition between the merging bank and the
charter bank is minimal. The two banks are located
23 miles apart and direct competition is minimized
by the intervening First National Bank of Cadiz.
Geographical barriers effectively split Harrison
County into two parts with the merging and charter
banks situated in separate halves.
Consummation of the proposed transaction will
have no adverse effect on competition. Competition
in the merging bank's service area will be stimulated because the resulting bank will be able to compete more effectively in this area by offering a
significantly higher lending limit, automated accounting to provide monthly statements on demand
accounts, other electronic data processing services,
and trust services through affiliation with the holding
company. The proposed merger will also make available specialized management expertise in such areas
as farm and commercial loans, bond portfolio management, interest control and audit procedures, and
other areas of banking not developed by the merging
bank in the past.

Applying the statutory criteria, it is concluded that
the proposed transaction is in the public interest and
this application is, therefore, approved.
NOVEMBER 21,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

We have reviewed this proposed transaction and
conclude that it would not have a substantial competitive impact.

FIRST NATIONAL BANK OF SPRINGFIELD, SPRINGFIELD, V T . , AND THE FIRST NATIONAL BANK OF FAIR
HAVEN, FAIR HAVEN, V T . , AND THE NORTHFIELD NATIONAL BANK, NORTHFIELD, VT.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Northfield National Bank, Northfield, Vt. (1638), with
and The First National Bank of Fair Haven, Fair Haven, Vt. (344), with
and First National Bank of Springfield, Springfield, Vt. (122), which had
merged Dec. 30, 1974, under charter and title of the latter bank (122). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On August 29, 1974, The Northfield National
Bank, Northfield, Vt., The First National Bank of
Fair Haven, Fair Haven, Vt., and First National
Bank of Springfield, Springfield, Vt., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
First National Bank of Springfield, the charter
bank, was organized in 1863 and presently operates
three branches. It has total assets of $28 million and
IPC deposits of $22.8 million. The primary service
area of the charter bank encompasses the southcentral section of the eastern border of Vermont.
The economy of this service area is supported by the
precision tool industry and agriculture.
Competition for the charter bank is provided by
Vermont National Bank, Brattleboro, Vt., with
deposits of $91.8 million and Connecticut River
National Bank, Charlestown, N.H., with deposits of
$9.4 million.
The Northfield National Bank, one of the two
merging banks, was organized in 1866 and presently
operates as a unit bank with total assets of $4.9
million and IPC deposits of $4.3 million. The primary service area of this merging bank encompasses the town of Northfield and the immediately
surrounding area. Northfield is a bedroom community for commuters employed in Barre and Montpelier.
Competition for The Northfield National Bank is
provided by The Merchants National Bank, Bur

% 4,560,089
5,726,429
30,688,474
39,836,587

To be
operated

1
1
4
6

lington, with deposits of $67.6 million and Northfield
Savings Bank, Northfield, with deposits of $40.1
million.
The First National Bank of Fair Haven, the second merging bank, was organized in 1864 and presently operates as a unit bank with total assets of
$5.7 million and IPC deposits of $5.2 million. The
primary service area of this merging bank encompasses the west-central section of Vermont along the
New York border. While there exists some agricul*tural and commercial activity within this service
area, most of its residents are employed in nearby
Rutland, Vt., and Whitehall, N.Y.
Competition for The First National Bank of Fair
Haven is provided by The First Vermont Bank and
Trust Company, Brattleboro, with deposits of $143
million; Vermont National Bank, Brattleboro, with
deposits of $91.8 million; and Proctor Trust Company, Proctor, with deposits of $44.8 million.
There is no competition among the three banks
involved in the proposed merger because their
nearest two offices are separated by a distance of
40 miles and an adequate number of alternative
banking facilities operate in the intervening area.
Consummation of the proposed merger will have
little effect in the service area of the charter bank.
However, in the service areas of the two merging
banks, the increased lending limit of the resulting
bank will enable it to satisfy the ever growing
demand of the residents and businesses of Fair
Haven and Northfield for a broader range of credit.
In addition, consummation of the proposed merger

105

will alleviate the managerial problems of The Northfield National Bank and The First National Bank of
Fair Haven.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 11,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The city of Northfield is located some 80 miles
north, and Fair Haven some 60 miles northwest, of
Springfield. Northfield and Fair Haven are about 65

miles from each other; no office of the three banks is
closer than 40 miles. The proposed consolidation will
not eliminate significant existing competition.
The economies of the respective areas served by
the three banks are basically sound; over all growth
in each is, however, limited. Springfield Bank, largest of the three, is only the 10th largest bank in the
State with 2.3 percent of total deposits as compared
to 16.2 percent, 13.5 percent and 11.5 percent held
by the three largest banks in the State. None of the
applicant banks is a particularly likely de novo
entrant into the areas served by the others. The proposed consolidation of the three would not have a
significantly adverse effect on potential competition.

NEW JERSEY BANK (NATIONAL ASSOCIATION), CLIFTON, N.J.,
WESTWOOD, WESTWOOD,

AND THE FIRST NATIONAL BANK OF
N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Westwood, Westwood, N.J. (8777), with
and New Jersey Bank (National Association), Clifton, N.J. (15709), which had
merged Dec. 30, 1974, under charter and title of the latter bank (15709). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On August 8, 1974, The First National Bank of
Westwood, Westwood, N.J., and New Jersey Bank
(National Association), Clifton, N.J., applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
New Jersey Bank (National Association), the
charter bank, was organized in 1869 and presently
operates 31 branches. It has total assets of $745
million and IPC deposits of $543 million. The charter
bank is the principal subsidiary of Greater Jersey
Bancorp, Clifton, N.J., the sixth largest bank holding company in the State. The primary service area
of the charter bank encompasses the cities of Passaic and Paterson together with their surrounding
areas. The economy of the service area is supported
by a wide array of commercial and industrial activity. New Jersey Bank (National Association) also has
an application pending to merge with Fairfield National Bank, Fairfield, N.J.
Competition for the charter bank is provided by 11
commercial banks headquartered in Passaic County,
the largest of which are First National State Bank
of New Jersey, Newark, with deposits of $1.1 bil-

106

$ 37,882,853
752,139,150
783,462,337

To be
operated

2
33

lion, which is a member of First National State
Bancorporation; Peoples Trust of New Jersey, Hackensack, with deposits of $957 million, which is a
member of United Jersey Banks; and Midlantic
National Bank, Newark, with deposits of $860 million, which is a member of Midlantic Banks, Inc.
Additional competition is provided by the multibillion dollar banks headquartered in nearby New
York City.
The First National Bank of Westwood, the merging bank, was organized in 1907 and presently operates one branch. It has total assets of $38.2 million
and IPC deposits of $31.9 million. The primary
service area of the merging bank consists of the
borough of Westwood and Washington Township.
That area serves as a bedroom community for those
employed in Newark and New York City.
Competition for The First National Bank of Westwood is provided by Peoples Trust of New Jersey,
Hackensack, with deposits of $957 million, which is
a member of United Jersey Banks; National Community Bank of Rutherford, with deposits of $638
million; Garden State National Bank, Hackensack,
with deposits of $467 million; and Citizens First
National Bank of New Jersey, Ridgewood, with

deposits of $207 million. Additional competition is
provided by the multi-billion dollar banks headquartered in New York City.
Although the closest offices of the charter and
merging banks are separated by a distance of only
1.3 miles, there is minimal competition between
them. The relatively small size of the merging bank
and the limited nature of its services prevent it from
being a significant competitor for the charter bank.
In addition, an adequate number of alternative banking facilities operate in the intervening area. Furthermore, no other subsidiary of Greater Jersey
Bancorp is located within 13 miles of The First
National Bank of West wood.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branches in the borough
of Westwood and Washington Township will offer
new and improved services such as a larger lending
limit, overdraft banking, automatic teller machines,
a wider variety of loans, international banking, trust
department services, and electronic data processing services. Consummation of the proposed merger
will also remove head office protection from the
borough of Westwood and open that community to
de novo branching by other banks. The resulting
bank will become the fifth largest bank in the State
and Greater Jersey Bancorp will continue to rank

sixth in size among the bank holding companies in
the State.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 29,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Applicant operates four branch offices in eastcentral Bergen County in northern New Jersey in
close proximity to Bank's two locations, as well as a
fifth office in the western portion of the county and
sixth office in the county's southeastern corner. Four
of Applicant's branches are clustered within about
7 miles of Bank's two locations, and their nearest
offices are separated by only about 2 miles. Thus, it
appears that the proposed merger would eliminate
existing competition.
While each party to the proposed transaction
holds only a small percentage of Bergen County's
commercial bank deposits, it appears that these
deposits are to a large extent derived from the northcentral portion of the county denominated in the
application as the Pascack Valley. The proposed
merger would increase concentration in commercial
banking in this area, and would have at least some
adverse effect on competition.

WACHOVIA BANK AND TRUST COMPANY, N.A., WINSTON-SALEM, N.C.,
MARSHALL, N.C.

AND CITIZENS BANK,

Banking offices
Name of bank and type of transaction

Total assets

Citizens Bank, Marshall, N . C , with
and Wachovia Bank and Trust Company, N.A., Winston-Salem, N.C. (15673), which had
merged Dec. 30, 1974, under charter and title of the latter bank (15673). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On May 16, 1974, Wachovia Bank and Trust Company, N.A., Winston-Salem, N . C , and Citizens
Bank, Marshall, N . C , applied to the Comptroller of
the Currency for permission to merge under the
charter and with the title of the former.
Wachovia Bank and Trust Company, N.A., the
charter bank, was organized in 1879 and now, with
total assets of $3.2 billion and IPC deposits of $2

$ 16,584,986
2,975,719,479
2,992,304,465

In
To be
operation operated
4
192
196

billion, is the second largest bank in North Carolina.
The charter bank, a subsidiary of Wachovia Corporation, a one-bank holding company, operates 172
offices throughout the State of North Carolina.
Citizens Bank, the merging bank, was established
in 1910 and now operates two offices in Mars Hill
and one office at Hot Springs. The merging bank's
service area is Madison County, which is located in
the extreme northwestern portion of the State adjacent to the Tennessee State line. Citizens Bank has

107

total assets of $16.3 million and IPC deposits of $13
million.
The merging bank competes with offices of First
Union National Bank, Charlotte, the third largest
bank in the State with deposits of $1.5 billion, and
Northwestern Bank, North Wilkesboro, the fifth
largest bank in the State with deposits of $880
million.
The charter bank is a vigorous competitor and
competes with every major bank in the southeast. In
North Carolina its primary competitors are North
Carolina National Bank, Charlotte, with 148 offices
and $3 billion in deposits; First Union National Bank
of North Carolina, Charlotte, with 181 banking
offices and $1.5 billion in deposits; First Citizens
Bank and Trust, Smithfield, with 193 offices and $1
billion in deposits; and Northwestern Bank with 151
offices and $880 million in deposits.
Competition between the charter and merging
banks is minimal, if any exists at all, since Wachovia
Bank and Trust Company's closest office is located
in Asheville, 22 miles south of Marshall. Although
charter bank could branch de novo into the Madison
County service area, there is little economic incentive for such a move since the area is experiencing
a decline in both population and economic growth.
Citizens Bank, like many small town institutions
in similar circumstances, has aging management
and offers limited services. Consummation of the
subject merger will replace this small and struggling
bank with the resources of a well-managed larger
bank. The public will benefit from the availability
of a wider range of banking services including a
significantly larger lending limit which may serve to
stimulate the economic environment in Madison

108

County. The resulting bank will remain the second
largest in North Carolina.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 26,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Wachovia's offices nearest to Citizens are located
in Asheville (population 57,681), Buncombe County,
which is about 25 miles from Citizens' main office in
Marshall and about 21 miles and 37 miles from its
branches in Mars Hill and Hot Springs, respectively.
The application indicates that Wachovia draws some
$1.2 million in deposits (excluding correspondent
balances from Citizens) and $269,000 in loans from
the three towns in which Citizens has offices. The
application also indicates that many workers in
Madison County travel to Asheville for employment.
Accordingly, the proposed transaction would eliminate some existing competition.
Citizens accounts for the largest share of deposits
(about 51 percent) held in banking offices in Madison County. The Marshall branch of First Union
National Bank, the State's third largest bank,
accounts for the second largest share. In addition,
The Northwestern Bank, the fifth largest bank in the
State, recently opened an office in Marshall, and has
approval to open an office in Mars Hill. In view of
below average economic growth in Madison County,
the recent entry of other banks and the existence of
other potential entrants, this proposed transaction
would not appear to have a substantial effect on
potential competition.

FIRST NATIONAL BANK OF SOUTH CAROLINA, COLUMBIA, S.C.,
LAKE CITY, S.C.

AND PALMETTO BANK & TRUST COMPANY,

Banking offices

Name of bank and type of transaction

Total assets

Palmetto Bank & Trust Company, Lake City, S.C, with
and First National Bank of South Carolina, Columbia, S.C. (13720), which had
merged Dec. 31, 1974, under charter and title of the latter bank (13720). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On May 10, 1974, Palmetto Bank & Trust Company, Lake City, S . C , and First National Bank of
South Carolina, Columbia, S . C , applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
First National Bank of South Carolina, the charter
bank, was organized in 1933 and now has assets of
$474 million and IPC deposits of $316 million. It
operates 62 branches in 21 of South Carolina's 46
counties which include the most heavily populated
counties in the State. The retail service area of this
bank includes the areas immediately surrounding its
numerous branches but, for wholesale banking
services, the charter bank serves the entire State of
South Carolina as well as the southeast region of
the United States.
Competition for the charter bank is provided by
offices of South Carolina National Bank, Columbia,
with deposits of $786 million; Citizens and Southern
National Bank of South Carolina, Columbia, with
deposits of $468 million; and Bankers Trust of South
Carolina, Columbia, with deposits of $421 million.
Palmetto Bank and Trust Company, the merging
bank, was organized in 1935 and currently has one
branch. The bank's assets are $12.6 million with
IPC deposits of $10 million. Both the merging bank's
main office and branch are located in Lake City,
Florence County, and its service area extends into
* These figures represent the standing at the start of a business
day on which two mergers were effected, and after those actions
had occurred, and so reflect both this merger and that of The
Bank of Walterboro, following.

$ 14,351,449
511,034,589*

In
To be
operation operated
2
60

532,638,256*

Williamsburg County and Clarendon County. The
entire service area of the bank contains an estimated
population of 23,000 persons.
The merging bank is slightly larger than the only
other commercial bank operating in its service area.
That competitor, Lake City State Bank, has deposits
of $9.8 million.
There is minimal competition between the charter
and merging banks because their closest two offices
are separated by 24 miles and by natural barriers
such as the Lynches River, which is situated in the
intervening area. There are also other alternative
banking facilities operating in the area.
Consummation of the proposed merger should
stimulate competition in the service area of the
merging bank because the resulting branch in Lake
City will offer new and improved services that have
not previously been offered in Lake City. This
should induce Lake City State Bank to develop additional services to offer to the public. The merger
will also resolve the acute management succession
problem at the merging bank. The resulting bank
will remain the fourth largest commercial bank in
South Carolina.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application, is, therefore, approved.
NOVEMBER 4,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

We have reviewed this proposed transaction and
conclude that it would not have a substantial competitive impact.

109

FIRST NATIONAL BANK OF SOUTH CAROLINA, COLUMBIA, S.C.,
WALTERBORO,

AND THE BANK OF WALTERBORO,

S.C.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Bank of Walterboro, Walterboro, S . C , with
and First National Bank of South Carolina, Columbia, S.C. (13720), which had
merged Dec. 31, 1974, under charter and title of the latter bank (13720). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On November 16, 1973, First National Bank of
South Carolina, Columbia, S . C , and The Bank of
Walterboro, Walterboro, S . C , applied to the Comptroller of the Currency for permission to merge
under the charter and with the title of the former.
First National Bank of South Carolina, the charter
bank, was organized in 1933 and presently operates
56 branches throughout the State with total assets of
$415 million and IPC deposits of $337 million. The
charter bank is owned by First Bankshares Corporation of South Carolina, a holding company which
also owns one other subsidiary, First National Properties, Inc., Charleston, a real estate holding company for properties utilized by the charter bank. The
charter bank has also filed an application to merge
into itself The Security Bank, Edgefield, S.C.
Since the charter bank offers a full range of services in 23 communities throughout the State, it is in
competition with most of the State's largest banks.
The major direct competition for the charter bank is
provided by South Carolina National Bank, with
deposits of $664 million; Citizens and Southern National Bank, with deposits of $430 million; Bankers
Trust of South Carolina, with deposits of $399
million; First Citizens Bank and Trust Company,
with deposits of $131 million; Southern Bank and
Trust Company, with deposits of $118 million; and
American Bank and Trust, with deposits of $110
million. All of those competing banks have offices
throughout the State.
The Bank of Walterboro, the merging bank, was
organized in 1923 and presently operates a single
office with assets of $12.7 million and IPC deposits
of $11.5 million. The primary service area of the
merging bank extends for a radius of approximately
10 miles from Walterboro, into the predominantly

* These figures represent the standing at the start of a business
day on which two mergers were effected, and after those actions
had occurred, and so reflect both this merger and that of Palmetto Bank & Trust Company, preceeding.

110

$ 12,621,018
511,034,589*

To be
operated

2
62

532,638,256*

rural low country of Colleton County. The principal
economic activity in its service area is agriculture.
Competition in the service area of the merging
bank is provided by Farmers and Merchants Bank,
Walterboro, with deposits of $36 million, and by the
Walterboro branch of the $42 million deposit First
National Bank in Orangeburg.
There is no direct competition between the
charter and merging banks because of the distance
that separates the two banks. The nearest office of
the charter bank is located in Summerville, 31 miles
from Walterboro. There is no significant commercial
activity between Walterboro and Summerville, and
the intervening area is almost entirely forest and
marshland.
Consummation of the proposed merger will stimulate competition in the service area of the merging
bank because the resulting branch in Walterboro
will be able to offer new and improved services to
the community such as a trust and travel department, real estate loans, a larger lending limit, mortgage banking, and computer services. In addition,
the proposed merger will alleviate the merging
bank's management deficiencies because of the
availability of the charter bank's well-rounded training program and management depth.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 4,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The nearest branch of FNB-SC is located in contiguous Dorchester County in the city of Summerville, some 30 miles northeast of Walterboro. The
amount of direct competition which might be eliminated by the proposed acquisition would be limited.
Colleton County is served by only three banks, all
located in Walterboro. Walterboro Bank is the
second largest of the three banks and holds 35.5
percent of the county's total deposits of $32.5
million.

There are at present seven banks in South Carolina with deposits in excess of $100 million; five of
these, including FNB-SC, operate offices throughout
the major portions of the State and could legally
establish de novo offices in the general Walterboro/

Colleton County area. However, because of limited
economic growth in the area and the number of other
potential entrants, the proposed acquisition of
Walterboro Bank would not, in our view, eliminate
substantial potential competition.

THE CENTRAL TRUST COMPANY OF MONTGOMERY COUNTY, NATIONAL ASSOCIATION, DAYTON, OHIO, AND
THE FARMERS AND MERCHANTS BANK OF ENGLEWOOD, ENGLEWOOD, OHIO

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Farmers and Merchants Bank of Englewood, Englewood, Ohio, with
and The Central Trust Company of Montgomery County, National Association, Dayton, Ohio
(16330), which had
merged Dec. 31, 1974, under charter and title of the latter bank (16330). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On August 28, 1974, The Farmers and Merchants
Bank of Englewood, Englewood, Ohio, and The Central Trust Company of Montgomery County, National Association, Dayton, Ohio, applied to the
Comptroller of the Currency for permission to merge
under the charter and with the title of the latter.
The Central Trust Company of Montgomery
County, the charter bank, commenced operations in
May 1974, and presently operates as a unit bank
with total assets of $3.8 million and IPC deposits of
$1.7 million. The charter bank is a subsidiary of
Central Bancorporation, Cincinnati, Ohio, the eighth
largest bank holding company in the State. The primary service area of the charter bank encompasses
the downtown area of Dayton. The economy of that
service area is supported by a wide array of commercial, financial, and industrial activity.
Competition for The Central Trust Company of
Montgomery County, National Association, is provided by Winters National Bank and Trust Company, Dayton, with deposits of $554 million; The
Third National Bank and Trust Company, Dayton,
with deposits of $287 million; The First National
Bank, Dayton, with deposits of $282 million; and The
Unity State Bank, Dayton, with deposits of $7.3
million.
The Farmers and Merchants Bank of Englewood,
Englewood, Ohio, the merging bank, was organized
in 1969 and presently operates one branch. It has
total assets of $8.2 million and IPC deposits of $5.9
million. The primary service area of the merging
bank encompasses the towns of Englewood and

To be
operated

$ 7,473,617
8,631,213
16,104,831

Brookville and their immediately surrounding areas.
While there is significant agricultural activity in this
service area, most of its residents are employed in
Dayton.
Competition for The Farmers and Merchants
Bank of Englewood is provided by The First National
Bank, Dayton, with deposits of $282 million and
Brookville National Bank, Brookville, with deposits
of $12.2 million.
There is only minimal competition between the
charter and merging banks because they are separated by a distance of 10 miles and an adequate
number of alternative banking facilities operate in
the intervening area. In addition, the relatively
small size and limited scope of operations of the
charter and merging banks prevent them from effectively competing with each other. The closest existing subsidiary of The Central Bancorporation is
Central Trust Company, Cincinnati, which is
approximately 50 miles from Englewood.
Consummation of the proposed merger will stimulate competition in Montgomery County because the
resulting branch in Englewood will be able to offer
new and improved services such as expanded mortgage lending, credit card loans, overdraft checking,
single statement banking, and trust services. In
addition, the merging bank will benefit from the
managerial assistance provided by the charter
bank's experienced lending officers and from the
expertise of other lending specialists employed by
Central Bancorporation's other subsidiaries. Furthermore, the resulting bank would continue to rank
among the smallest banks in Montgomery County.

Ill

Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 4,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

We have reviewed this proposed transaction and
conclude that it would not have a substantial competitive impact.

THE NATIONAL BANK OF RICHMOND, RICHMOND, MICH., AND N E W HAVEN SAVINGS BANK,
NEW

HAVEN, MICH.

Name of bank and type of transaction

Total assets

Banking offices
In
operation

New Haven Savings Bank, New Haven, Mich., with
and The National Bank of Richmond, Richmond, Mich. (13793), which had
merged Dec. 31, 1974, under charter and title of the latter bank (13793). The merged bank at
date of merger had

COMPTROLLER'S DECISION

On July 5, 1974, New Haven Savings Bank, New
Haven, Mich., and The National Bank of Richmond,
Richmond, Mich., applied to the Comptroller of the
Currency for permission to merge under the charter
and with the title of the latter.
The National Bank of Richmond, the charter
bank, was organized in 1915 and now, with assets of
$33.2 million and IPC deposits of $27.9 million,
operates one branch office in Memphis, Mich. The
charter bank has pending two applications for permission to establish new branches. The service area
of the bank is essentially Richmond and its environs,
a rapidly developing area northeast of Detroit that is
currently industrial and agricultural in character,
with an estimated population in excess of 22,685.
The charter bank ranks fourth in size among the
seven banks operating within a 15-mile radius of the
applicant banks. Competition is provided by Macomb County Bank, Richmond, with deposits of
$9.8 million; the Armanda branch of First National
Bank in Mt. Clemens, with deposits of $125.4 million; and the Emmett branch of Commercial and
Savings Bank of St. Clair County, St. Clair, with
deposits of $58.2 million.
New Haven Savings Bank, the merging bank, was
organized in 1901 and now, with assets of $6.2
million and IPC deposits of $4.9 million, operates
one branch office in Meade, Mich. The merging
bank, also located in Macomb County, has a service
area that includes the village of New Haven and its
environs. The economy of the New Haven Savings
Bank's service area is essentially the same as the

112

To be
operated

$ 5,474,903
33,622,896
39,097,799

National Bank of Richmond's service area in character except there has been greater residential development and a greater change from rural to suburban.
The population of the merging bank's service area
is an estimated 13,280.
The merging bank is the smallest of the seven
commercial banking institutions operating in the
vicinity of the Richmond and New Haven communities. It competes primarily with First National
Bank in Mt. Clemens and Mt. Clemens Bank, Mt.
Clemens, with deposits of $91.5 million. Competition is also provided the merging bank by Citizens
State Savings Bank in nearby New Baltimore, with
deposits of $11.8 million; and Macomb County Bank.
There is no significant competition between the
closest offices of the charter and merging banks.
Although the two banks are only separated by a distance of 7.5 miles, a branch office of a competitor
located in the intervening area and the poor quality
of direct roads between the communities in which
each bank has offices precludes the possibility of
significant competition. The small size and unaggressive nature of the merging bank also deters
competition with the charter bank.
Consummation of the proposed merger will not
diminish competition in the service area of the merging bank. On the contrary, the branches of the
resulting bank in New Haven and Meade will offer
new and improved services including a significantly
larger lending limit and the payment of competitive
rates on time and saving deposits. This will make the
branches of the resulting bank more viable competitors within what is now the merging bank's service area.

Additionally, the merger will provide an institution
capable of accommodating the increasing demand
for banking services in this developing area and an
opportunity to expand its services even though its
location prevents attraction of new youthful management to supplement the current staff. The resulting bank, with IPC deposits of $32.8 million, will
remain the fourth largest of the remaining six commercial banks operating in the vicinity of Richmond
and New Haven.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 18,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The main offices of the parties (their closest) are
separated by a distance of about 7 miles, with the
offices of another bank roughly intervening between
them. The proposed transaction would appear to
eliminate some existing competition between the
banks as well as the potential for increased future
competition. However, in view of New Haven Bank's
modest size and the presence of several convenient
banking alternatives in the area immediately surrounding New Haven, we conclude that, overall, the
proposed merger would not have a significantly
adverse effect on competition.

113

//. Mergers consummated, pursuant to corporate reorganization
THE FARMERS NATIONAL BANK OF SALEM, SALEM, OHIO, AND NORTHERN COLUMBIANA COUNTY NATIONAL
BANK, SALEM, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation

On August 3, 1973, The Farmers National Bank of
Salem, Salem, Ohio, and the Northern Columbiana
County National Bank (organizing), Salem, Ohio,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
title of the former.
The Farmers National Bank of Salem, the merging
bank, is headquartered in Salem, Columbiana
County, and has seven offices in the county. The
bank, with total deposits of approximately $52 million, was chartered originally in 1846. It competes
directly with First National Bank of Salem, which
has total deposits of approximately $36 million.
Northern Columbiana County National Bank, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to First Steuben Bancorp, Inc., a registered bank
holding company in Ohio. The charter bank will not
be operating as a commercial bank prior to the
merger.
First Steuben Bancorp, Inc., with total assets of
approximately $95 million was organized in 1969.
The holding company is headquartered in Steubenville, Jefferson County, Ohio, and has two subsidiaries, The First National Bank and Trust Company
in Steubenville, with total deposits of approximately
$88 million, and The First National Bank of Hopedale, Ohio, with total deposits of approximately $9
million. First Steuben Bancorp ranks ninth in size of
10 leading holding companies in Ohio.
The proposed merger will not adversely affect

114

60,043,372

•

COMPTROLLER S DECISION

$59,923,858
119,515

OOO

The Farmers National Bank of Salem, Salem, Ohio (973), with
and Northern Columbiana County National Bank, Salem, Ohio (973), which had
merged Jan. 1, 1974, under charter of the latter bank (973) and title "The Farmers National
Bank of Salem." The merged bank at date of merger had

To be
operated

competition due to the distance and intervening
banking facilities involved. First Steuben Bancorp's
closest subsidiary office to the merging bank is the
Toronto office of The First National Bank and Trust
Company in Steubenville, which is 30 miles distant
from the merging bank's Lisbon office. Furthermore,
the proposed merger will not significantly change the
relative position of First Steuben Bancorp with
regard to other multi-bank holding companies in
Ohio. Consummation of the merger will, however,
significantly enhance the resulting bank's ability to
compete in its service area. Affiliation with First
Steuben Bancorp will enable the resulting bank to
offer more diversified and specialized services to
area customers through the holding company's
expertise.
Accordingly, applying the statutory criteria, it is
concluded that the proposed merger is in the public
interest. The application is, therefore, approved.
NOVEMBER 30,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

FIDELITY BANK, NATIONAL ASSOCIATION, OKLAHOMA CITY, OKLA., AND FIDELITY NATIONAL BANK,
OKLAHOMA CITY, OKLA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
$279,726,714
249,583

Fidelity Bank, National Association, Oklahoma City, Okla. (12016), with
and Fidelity National Bank, Oklahoma City, Okla. (12016), which had
merged Jan. 2, 1974, under charter of the latter bank (12016) and title "Fidelity Bank, N.A."
The merged bank at date of merger had

COMPTROLLER S DECISION

On May 30, 1973, the Fidelity Bank, National
Association, Oklahoma City, Okla., and the Fidelity
National Bank (organizing), Oklahoma City, Okla.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title "Fidelity Bank, N.A."
Fidelity Bank, National Association, the merging
bank, is headquartered in Oklahoma City, and operates as a unit institution. The bank, with total resources of $208.1 million and IPC deposits of $151.5
million was chartered originally in 1908. The merging bank has one affiliate, Capitol Hill State Bank
and Trust, Oklahoma City. Affiliation occurred in
1960, when shareholders owning a majority of the
stock of Capitol Hill State Bank and Trust purchased
a majority of the outstanding shares of the merging
bank.
Fidelity National Bank, the charter bank, is being
organized to provide a vehicle to transfer ownership
of the merging bank to the Fidelity Corporation of
Oklahoma, Oklahoma City, Okla. The charter bank
will not be operating as a commercial bank prior to

To be
operated

2
0
2

279,733,914

the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there can
be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will conduct the same banking business at
the same location and with the same name as presently used by the merging bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
the application is, therefore, approved.
OCTOBER 31,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Fidelity Bank, National Association would
become a subsidiary of Fidelity Corporation of
Oklahoma, 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 Fidelity Corporation of Oklahoma, it would
have no effect on competition.

THE FIRST NATIONAL BANK OF CINCINNATI, CINCINNATI, OHIO, AND FN NATIONAL BANK,
CINCINNATI, OHIO

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Cincinnati, Cincinnati, Ohio (24), with
and FN National Bank, Cincinnati, Ohio (24), which had
merged Jan. 2, 1974, under charter of the latter bank (24) and title "The First National Bank of
Cincinnati." The merged bank at date of merger had

COMPTROLLER S DECISION

On October 12, 1973, FN National Bank (organizing), Cincinnati, Ohio, and The First National Bank
of Cincinnati, Cincinnati, Ohio, applied to the

$1,062,401,438
243,500
1,147,601,909

To be
operated

24
0
24

Comptroller of the Currency for permission to merge
under the charter of the former and with the title of
the latter.
The First National Bank of Cincinnati, the existing
bank, was organized in 1863 and now, with deposits

115

of $719.5 million, is the largest of the six banks headquartered in Cincinnati. The two largest competitors
for the bank are The Central Trust Company, with
deposits of $592 million, which is a member of The
Central Bancorporation, and The Fifth Third Bank,
with deposits of $554.9 million.
FN National Bank, is being organized to provide
a vehicle by which to transfer ownership of the existing bank to First National Cincinnati Corporation,
Cincinnati, Ohio, which will become a one-bank
holding company. FN National Bank will not be
operating as a commercial bank prior to this merger.
Because The First National Bank of Cincinnati 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 existing bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest, and
this application is, therefore, approved.
NOVEMBER 29,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

FIRST NATIONAL BANK IN GRAND PRAIRIE, GRAND PRAIRIE, T E X . , AND SECOND NATIONAL BANK IN
GRAND PRAIRIE, GRAND PRAIRIE, TEX.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank in Grand Prairie, Grand Prairie, Tex. (14576), with
and Second National Bank in Grand Prairie, Grand Prairie, Tex. (14576), which had
merged Jan. 18, 1974, under charter of the latter bank (14576) and title "First National Bank in
Grand Prairie." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 20, 1973, First National Bank in
Grand Prairie, Grand Prairie, Tex., and Second
National Bank in Grand Prairie (organizing), Grand
Prairie, Tex., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
First National Bank in Grand Prairie, the existing
bank, was organized in 1947 and has operated as a
unit institution since that time, as required under
Texas law. The bank currently has deposits of $20.5
million. The primary service area of the bank consists of the city of Grand Prairie with an estimated
population of 50,904 persons.
First National Bank in Grand Prairie is the second
largest of three banks headquartered in Grand
Prairie and ranks 41st in deposit size among all
banks in the Dallas area. Competition for the bank
is provided by Grand Prairie State Bank, with
deposits of $25.2 million, and by Midway National

116

$27,596,826
250,000
28,271,365

To be
operated

1
0
1

Bank, Grand Prairie, with deposits of $16.1 million.
Additional competition will soon be provided by a
recently chartered bank, National Bank of Grand
Prairie, which has not yet opened for business.
Second National Bank in Grand Prairie, the
receiving bank, is being organized to provide a
vehicle by which to transfer ownership of First National Bank in Grand Prairie to First Security National Corporation. The new bank will not be operating as a commercial bank prior to this merger.
First Security National Corporation, the bank
holding company which will acquire the resulting
bank, was organized in June 1969 and now controls
eight banks with aggregate deposits of approximately $230.4 million. The holding company also
controls Security First Mortgage Company, its principal non-banking subsidiary, and has submitted an
application to acquire Texas National Bank, Dallas,
with deposits of $7.6 million.
There is minimal competition between the applicant or its subsidiaries and First National Bank in

Grand Prairie because of the distances that separate
their closest two offices and because an adequate
number of alternative banking facilities operate in
the intervening area. The nearest office of an existing subsidiary of the applicant is in Lancaster, Tex.,
approximately 20 miles from the main office of the
resulting subsidiary. Further, if the applicant receives approval of its pending application to acquire
Texas National Bank of Dallas, Dallas, that bank will
become the nearest subsidiary to First National
Bank in Grand Prairie. It is located 13 miles to the
east.
Consummation of the proposed merger will stimulate competition in Grand Prairie because the resulting subsidiary will be able to offer expanded expertise in all banking services, especially in the field of
development, construction, and real estate loans.

Additionally, the resulting subsidiary will gain stability and continuity of ownership along with greater
depth and continuity of management.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
DECEMBER 18,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through which
the existing banks will become subsidiaries of First
Security National Corporation. [It] * * *, however,
will merely combine an existing bank with a nonoperating institution and without regard to the acquisition of the surviving banks by First Security
National Corporation, will have no effect on competition.

TEXAS NATIONAL BANK OF DALLAS, DALLAS, TEX., AND STEMMONS NATIONAL BANK, DALLAS, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Texas National Bank of Dallas, Dallas, Tex. (15501), with
and Stemmons National Bank, Dallas, Tex. (15501), which had
merged Jan. 18, 1974, under charter of the latter bank (15501) and title "Texas National Bank of
Dallas." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 19, 1973, Texas National Bank of
Dallas, Dallas, Tex., and Stemmons National Bank
(organizing), Dallas, Tex., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
Texas National Bank of Dallas, the merging bank,
was organized in 1964 and operates as a unit institution. It possesses total assets of $8.7 million and IPC
deposits of $6.8 million. The service area of the bank
encompasses a portion of suburban Dallas.
Competitors of Texas National Bank of Dallas
include Republic National Bank of Dallas, with
deposits of $2.8 billion; First National Bank of
Dallas, with deposits of $2.5 billion, which is a member of International Bancshares, Inc.; and Texas
Bank and Trust Company of Dallas, with deposits of
$255.2 million.
Stemmons National Bank, the charter bank, is
being organized to provide a vehicle by which to
transfer ownership of the merging bank to First
Security National Corporation, Beaumont, Tex., a

$10,347,615
250,000
10,597,615

To be
operated

1
0
1

registered bank holding company 14th in size in the
State. It controls eight subsidiary banks with aggregate deposits of $230.4 million and has applied for
approval to acquire one additional bank. First Security National Bank of Beaumont, with deposits of
$180 million, is the applicant's lead subsidiary.
Competition for First Security National Corporation is provided by the banks located in the Beaumont-Port Arthur-Orange area including The American National Bank which has deposits of $116.1
million and is a member of Texas Commerce Bancshares, Inc.; The First National Bank which has
deposits of $83.3 million and is a member of Southwest Bancshares, Inc.; and Merchants Bank which
has deposits of $68.8 million and is a member of
Allied Bancshares, Inc. Additional competition is
generated from the banks located in the Fort Worth
and Dallas markets.
Competition between the subsidiaries of First
Security Corporation and Texas National Bank of
Dallas is minimal as their closest offices are separated by a distance of 19 miles and they operate in
distinct service areas.

117

Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with the holding company will allow the resulting
bank to offer improved and expanded services, such
as an increased lending capacity through loan participations, construction and mortgage lending
expertise, improved physical facilities, and data
processing services. In addition, the resulting bank
will benefit from the improved management expertise which will be provided.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse com-

petitive effects. This application is, therefore,
approved.
DECEMBER 18,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through
which the existing banks will become subsidiaries of
First Security National Corporation. [It] * * *, however, will merely combine an existing bank with a
non-operating institution and without regard to the
acquisition of the surviving banks by First Security
National Corporation, will have no effect on competition.

HAMILTON NATIONAL BANK OF LOUDON, LOUDON, TENN., AND LOUDON BANK, N.A.,

LOUDON, TENN.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Hamilton National Bank of Loudon, Loudon, Tenn. (12080), with
and Loudon Bank, N.A., Loudon, Tenn. (12080), which had
merged Jan. 28,1974, under charter of the latter bank (12080) and title "Hamilton National Bank
of Loudon." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 12, 1973, Hamilton National Bank
of Loudon, Loudon, Tenn., and Loudon Bank, N.A.
(organizing), Loudon, Tenn., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
Hamilton National Bank of Loudon, the existing
bank, was organized in 1922 and now has assets of
$17 million and IPC deposits of $13 million. The
bank operates two branch offices in Loudon County
and competes directly with a branch of Bank of
Loudon County which is situated in the city of Loudon. The majority of the outstanding shares of the
existing bank are owned by Hamilton Bancshares,
Inc.
Loudon Bank, N.A., the new bank, is being organized to provide a vehicle by which to transfer
ownership of the remaining shares of the existing
bank to Hamilton Bancshares, Inc. The new bank
will not be operating as a commercial bank prior to
this merger.

118

$18,662,535
240,000

To be
operated

3
0

19,029,193

The proposed merger will have no effect on the
banking structure in Tennessee and will merely
allow Hamilton Bancshares to acquire the remaining
shares of the existing bank which it does not presently own.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed merger is in the
public interest and this application is, therefore,
approved.
DECEMBER 28,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FARMERS NATIONAL BANK OF WINCHESTER, WINCHESTER, TENN., AND WINCHESTER BANK,
WINCHESTER, TENN.

N.A.,

Banking offices
Total assets

Name of bank and type of transaction

In
operation
$24,413,971
240,000

The Farmers National Bank of Winchester, Winchester, Tenn. (8640), with
and Winchester Bank, N.A., Winchester, Tenn. (8640), which had
merged Jan. 28, 1974, under charter of the latter bank (8640) and title "Farmers National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 12, 1973, The Farmers National
Bank of Winchester, Winchester, Tenn., and Winchester Bank, N.A. (organizing), Winchester, Tenn.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title "Farmers National Bank."
The Farmers National Bank of Winchester, the
existing bank, was organized in 1907 and now has
assets of $21.3 million and IPC deposits of $16
million. The bank operates two branches and competes with a branch of The First National Bank of
Franklin County which is located in Winchester.
The majority of the outstanding shares of the existing bank are owned by Hamilton Bancshares, Inc.
Winchester Bank, N.A., the new bank, is being
organized to provide a vehicle by which to transfer
ownership of the remaining shares of the existing
bank to Hamilton Bancshares, Inc. The new bank
will not be operating as a commercial bank prior to
this merger.

To be
operated

3
0

25,401,014

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK IN ONANCOCK, ONANCOCK, VA., AND ONANCOCK BANK, N.A.,

ONANCOCK, VA.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

The First National Bank in Onancock, Onancock, Va. (13878), with
and Onancock Bank, N.A., Onancock, Va. (13878), which had
merged Feb. 1, 1974, under charter of the latter bank (13878) and title "The First National
Bank in Onancock." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 20, 1973, The First National Bank in
Onancock, Onancock, Va., and Onancock Bank,
N.A. (organizing), Onancock, 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.

$14,718,734
240,000
14,716,635

To be
operated

1
0
1

The First National Bank of Onancock, the existing bank, was organized in 1893 and, with total
deposits of $12.2 million, operates as a unit bank. Its
service area, Accomack County, is one of two Virginia counties located on the State's Eastern Shore,
separated from the remainder of Virginia by Chesapeake Bay. It has an estimated population of 29,000.
The economy of the service area is supported pri-

119

marily by the seafood industry, agriculture, lumber
manufacturing, forest products, food processing
plants, poultry processing plants, small textile
plants, and tourism.
Competition for The First National Bank in Onancock is provided by 11 offices of five commercial
banks including United Virginia Bank/Seaboard
National, with deposits of $215 million, which is a
member of United Virginia Bancshares, Inc.;
Farmers and Merchants National Bank, with deposits of $12.8 million; Metompkin Bank & Trust Company, with deposits of $7.3 million, which is a member of Fidelity American Bankshares, Inc.; and
Bank of Chincoteague, Inc., with deposits of $5
million.
Onancock Bank, N.A., the new bank, is being
organized to provide a vehicle by which to transfer
ownership of The First National Bank of Onancock to First Virginia Bankshares Corporation. The
new bank will not be operating as a commercial
bank prior to this merger.
First Virginia Bankshares Corporation, Falls
Church, Va., the bank holding company which will
acquire the resulting bank, controls 21 affiliated
banks with aggregate deposits of $706 million. The
subsidiaries of that bank holding company operate
140 banking offices in various parts of Virginia
including locations in Northern Virginia, Northern
Neck, Richmond, the tidewater area, Danville,
southwest Virginia, the Shenandoah Valley, and
north-central Virginia. Of the 13 bank holding companies operating in the State, First Virginia Bankshares Corporation ranks sixth in deposit size.
There is no competition between the holding com*

pany or its subsidiaries and The First National Bank
in Onancock because large distances separate their
closest offices and an adequate number of alternative banking facilities operate in the intervening
distances. The nearest subsidiary of First Virginia
Bankshares Corporation is First Virginia Bank of
Tidewater which is located 60 miles south of Onancock. That large distance effectively precludes any
competition between these banks.
Consummation of the proposed transaction will
stimulate competition in Accomack County because
the resulting subsidiary will be able to offer new and
improved services by its access to the specialized
service departments of the holding company, including trust and investment services, and data processing. This will be to the direct benefit of residents and
businessmen who are within the service area of the
resulting subsidiary.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
DECEMBER 26,

1973.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE HOMER NATIONAL BANK, HOMER, N.Y.,

AND HOMER BANK, N.A.,

HOMER,

N.Y.
Banking offices

Name of bank and type of transaction

Total assets
In
operation

The Homer National Bank, Homer, N.Y. (3186), with
and Homer Bank, N.A., Homer, N.Y. (3186), which had
merged Feb. 4, 1974, under charter of the latter bank (3186) and title "The Homer National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 18, 1973, The Homer National Bank,
Homer, N.Y., and Homer Bank, N.A., (organizing),
Homer, 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.
120

$19,233,986
60,000
19,293,986

To be
operated

2
0
2

The Homer National Bank, the merging bank, is
headquartered in Homer, Cortland County, and has
one branch office in Cortlandville. The bank, with
total deposits of $17 million, was chartered originally
in 1884.
Homer Bank, N.A., the charter bank, is being
organized to provide a vehicle to transfer ownership

of the merging bank to First Commercial Banks, Inc.
The charter bank will not be operating as a commercial bank prior to the merger.
First Commercial Banks, Inc. is a multi-bank
holding company headquartered in Albany, N.Y. It
controls three banks: National Commercial Bank
and Trust Company, Albany, with $947 million in
deposits; First Trust and Deposit Company, Syracuse, with $355 million in deposits; and Kingston
Trust Company, Kingston, with $68 million in
deposits. With aggregate deposits of $1.4 billion,
First Commercial Banks, Inc. ranks 10th in deposit
structure among the 20 New York bank holding
companies.
Competition will not be adversely affected by the
proposed merger. Competition between the merging
bank and subsidiaries of First Commercial Banks,
Inc. is negligible because their nearest offices are
approximately 19 miles apart and are located in different banking districts. Furthermore, the proposed
acquisition would not alter First Commercial Bank's
rank among the State's bank holding companies.
Consummation of the proposed merger would en-

hance competition by removing home office protection from Homer thereby opening that community to
de novo branching by other banks. Affiliation with
First Commercial Banks, Inc. will enable the resulting bank to provide residents of Homer with additional services such as credit card, investment
advisory, computer, and trust services.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest.
This application is, therefore, approved.
JANUARY 4,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

NATIONAL BANK AND TRUST COMPANY OF ANN ARBOR, ANN ARBOR, MICH., AND NATIONAL BANK OF ANN
ARBOR, ANN ARBOR, MICH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
National Bank and Trust Company of Ann Arbor, Ann Arbor, Mich. (14933), with
and National Bank of Ann Arbor, Ann Arbor, Mich. (14933), which had
merged Feb. 28, 1974, under charter of the latter bank (14933) and title "National Bank and
Trust Company of Ann Arbor." The merged bank at date of merger had

COMPTROLLER S DECISION

On September 26, 1973, National Bank and Trust
Company of Ann Arbor, Ann Arbor, Mich., and National Bank of Ann Arbor (organizing), Ann Arbor,
Mich., applied to the Comptroller of the Currency
for permission to merge under the charter of the
latter and with the title of the former.
National Bank and Trust Company of Ann Arbor,
the merging bank, is headquartered in Ann Arbor,
Washtenaw County, Mich., and has nine branch
offices. The bank, with total deposits of $159.7
million, was chartered originally in 1892.

$165,639,365
240,000
165,879,365

To be
operated

11
0
11

National Bank of Ann Arbor, the charter bank, is
being organized to provide a vehicle to transfer
ownership of the merging bank to National Ann
Arbor Corporation, a newly created holding company. The charter bank will not be operating as a
commercial bank prior to the merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there can
be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will conduct the same banking business at
the same locations and with the same name as presently used by the merging bank.

121

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
JANUARY 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

which National Bank and Trust Company of Ann
Arbor would become a subsidiary of National Ann
Arbor Corporation, a bank holding company. The
instant merger, however, would merely combine an
existing bank with a non-operating institution; as
such, and without regard to the acquisition of the
surviving bank by National Ann Arbor Corporation,
it would have no effect on competition.

NATIONAL BANK OF MURFREESBORO, MURFREESBORO, TENN., AND THE SECOND NATIONAL BANK OF
MURFREESBORO, MURFREESBORO, TENN.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
National Bank of Murfreesboro, Murfreesboro, Tenn. (14736), with
and The Second National Bank of Murfreesboro, Murfreesboro, Tenn. (14736), which had
merged Feb. 28, 1974, under charter of the latter bank (14736) and title "The National Bank of
Murfreesboro." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 8, 1973, National Bank of Murfreesboro, Murfreesboro, Tenn. and The Second
National Bank of Murfreesboro (organizing), Murfreesboro, Tenn., applied to the Comptroller of
the Currency for permission to merge under the
charter of the latter and with the title "The National
Bank of Murfreesboro."
National Bank of Murfreesboro, the merging bank,
was organized in 1955, operates two branch offices,
and has received approval to open one additional
branch. This bank has total assets of $19.4 million
and IPC deposits of $12.5 million. The service area
of the bank encompasses Rutherford County, an
industrial area which has a population of approximately 59,428 people. Competitors of the merging
bank include a branch of Commerce Union Bank,
which has deposits of $608.1 million and is the
lead subsidiary of Tennessee Valley Bancorp., Inc.;
Murfreesboro Bank and Trust Company, which has
deposits of $49.6 million; and First National Bank of
Smyrna, which has deposits of $5.8 million.
The Second National Bank of Murfreesboro, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to First Tennessee National Corporation, Memphis,
Tenn. The charter bank will not be operating as a
commercial bank prior to the merger.
First Tennessee National Corporation, the multibank holding company that will acquire the resulting

122

$21,983,902
120,000
21,983,902

To be
operated

3
0
3

bank, was organized in 1968, and is the largest bank
holding company in Tennessee. It controls seven
banking subsidiaries and holds aggregate deposits
of $1.2 billion. The lead subsidiary, the First National Bank of Memphis, has deposits of $1 billion.
The applicant has also received approval to acquire
two additional banks and has applications pending to
acquire two other banks.
First Tennessee National Corporation experiences
competition from the six other bank holding companies operating in Tennessee, including Union
Planters Corporation, with deposits of $1 billion;
First Amtenn Corporation, with aggregate deposits
of $855.9 million; Third National Corporation, with
aggregate deposits of $784.7 million; and Hamilton
Bancshares, with aggregate deposits of $688.2
million.
Competition between the merging bank and the
subsidiaries of First Tennessee National Corporation
is minimal since their closest offices are separated
by a distance of approximately 25 miles and because
Nashville, Tenn., is located in the intervening area.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with First Tennessee National Corporation will
allow the resulting bank to offer new and expanded
services, such as trust services, international services, data processing, and money management
services.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed merger is in the

public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
JANUARY 21,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

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

THE FIRST NATIONAL BANK OF CANTON, CANTON, N.Y., AND CHASE MANHATTAN BANK OF NORTHERN
NEW YORK (NATIONAL ASSOCIATION), CANTON, N.Y.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Canton, Canton, N.Y. (3696), with
and Chase Manhattan Bank of Northern New York (National Association), Canton, N.Y. (3696),
which had
merged Feb. 28, 1974, under charter and title of the latter bank (3696). The merged bank at date
of merger had

COMPTROLLER'S DECISION

On August 20, 1973, The First National Bank of
Canton, Canton, N.Y., and Chase Manhattan Bank
of Northern New York (National Association) (organizing), Canton, N.Y., applied to the Comptroller of
the Currency for permission to merge under the
charter and title of the latter.
The First National Bank of Canton, the existing
bank, was organized in 1887 and has operated as a
unit institution since that time with current deposits
of $12.1 million. The bank ranks third in size among
the eight commercial banks headquartered in St.
Lawrence County.
Competition for the existing bank is provided by
Marine Midland Bank-Northern, Watertown, with
deposits of $168 million, which is a member of
Marine Midland Banks, Inc., a multi-bank holding
company with aggregate deposits of $6.4 billion; and
St. Lawrence National Bank, Canton, with deposits
of $61 million.
Chase Manhatten Bank of Northern New York
(National Association), the new bank, is being organized to provide a vehicle by which to transfer
ownership of The First National Bank of Canton to
The Chase Manhattan Corporation. The new bank
will not be operating as a commercial bank prior to
this merger.
The Chase Manhattan Corporation, New York,
N.Y., the bank holding company which will acquire
the resulting bank, was organized in December 1970

$15,711,446

166,860

To be
operated

15,878,306

and now owns six subsidiary banks with aggregate
domestic deposits of $16.9 billion.
There is no competition between The Chase Manhattan Corporation or its subsidiaries and The First
National Bank of Canton because very large distances separate their closest two offices and an adequate number of alternative banking facilities
operate in the intervening area. The closest subsidiary of The Chase Manhattan Corporation is
Chase Manhattan Bank of Central New York (National Association) which is located approximately
150 miles southwest of Canton.
Consummation of the proposed merger will stimulate competition in the service area of the resulting
subsidiary which will be able to offer its customers
improved and expanded banking facilities including
"One Statement Banking," overdraft checking,
Chase Manhattan BankAm eric ard, computer services, international financing, and loan expertise in all
types of financing.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
JANUARY 22,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which The First National Bank of Canton would
become a subsidiary of The Chase Manhattan Cor-

123

poration, a bank holding company. The instant
merger, however, would merely combine an existing
bank with a non-operating institution; as such, and

without regard to the acquisition of the surviving
bank by The Chase Manhattan Corporation, it would
have no effect on competition.

FIRST NATIONAL BANK OF LAKE CITY, LAKE CITY, MICH., AND LCM NATIONAL BANK, LAKE CITY, MICH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank of Lake City, Lake City, Mich. (15234), with
and LCM National Bank, Lake City, Mich. (15234), which had
merged Mar. 8, 1974, under charter of the latter bank (15234) and title "First National Bank of
Lake City." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 8, 1973, First National Bank of
Lake City, Lake City, Mich., and LCM National
Bank (organizing), Lake City, Mich., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
First National Bank of Lake City, the merging
bank, was organized in 1909 and operates three
branch offices. It possesses total assets of $22.4
million and IPC deposits of $18.8 million. The merging bank operates in the Lake City-Cadillac banking
market and in the Roscommon banking market. Its
competitors include The Cadillac State Bank, with
deposits of $80.3 million; The Roscommon State
Bank, with deposits of $42.5 million; and First National Bank of Cadillac, with deposits of $17 million.
LCM National Bank (organizing), the charter
bank, is being organized to provide a vehicle by
which to transfer ownership of the merging bank to
Northern State Bancorporation, Inc., a bank holding
company. The charter bank will not be operating as
a commercial bank prior to this merger.
Northern States Bancorporation, Inc., the multibank holding company that will acquire the resulting
bank, is the sixth largest banking organization in
Michigan. This corporation controls City National
Bank of Detroit, with deposits of $768.7 million;
Bank of Lansing, with deposits of $150.5 million; and
has received approval from the Federal Reserve
Bank of Chicago to acquire the resulting bank. In

124

$24,664,874
60,000

To be
operated

4
0

24,664,874

addition, it has applications pending to acquire three
other banks. Northern States Bancorporation, Inc.,
and its subsidiaries possess total assets of $1.1
billion.
Competition between the merging bank and the
subsidiaries of Northern States Bancorporation,
Inc., is virtually nonexistent as they operate in different sections of Michigan. Affiliation with Northern States Bancorporation, Inc., will allow the
resulting bank to offer improved and expanded
services such as greater lending expertise, international services, and improved managerial resources.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore,
approved.
FEBRUARY 6,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

NATIONAL BANK OF ROCHESTER, ROCHESTER, MICH., AND NBR

NATIONAL BANK, ROCHESTER, MICH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
National Bank of Rochester, Rochester, Mich. (15274), with
and NBR National Bank, Rochester, Mich. (15274), which had
merged Mar. 8, 1974, under charter of the latter bank (15274) and title "National Bank of
Rochester." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 4, 1973, National Bank of Rochester,
Rochester, Mich., and NBR National Bank (organizing), Rochester, Mich., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
National Bank of Rochester, the merging bank,
was organized in 1964, operates one branch office,
and has an application pending for an additional
branch. It possesses total assets of $16.6 million and
IPC deposits of $12.1 million. Its major competitors
include branches of National Bank of Detroit, with
deposits of $5.4 billion, and Community National
Bank of Pontiac, with deposits of $302.2 million.
NBR National Bank, the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to Northern States
Corporation, Inc., and Twin Gates Corporation,
registered bank holding companies. The charter
bank will not be operating as a commercial bank
prior to consummation of the proposed transaction.
Northern States Corporation, Inc., Detroit, Mich.,
the first registered bank holding company which
will acquire the resulting bank, has total consolidated assets of $1.1 billion. It controls two subsidiary banks, has applications pending to acquire
three other banks, and also has applications pending for two de novo National bank charters. City
National Bank of Detroit, with deposits of $768.7
million, is its lead subsidiary. The profit sharing
trust for the employees of City National Bank of
Detroit holds 13.2 percent of the outstanding capital
stock of the merging bank.
Competitors of Northern States Corporation, Inc.,
include National Bank of Detroit, with deposits of
$5.4 billion; Detroit Bank and Trust, with deposits of
$2.3 billion, which is a member of Detroitbank Corporation; and Manufacturers National Bank of
Detroit, with deposits of $2.2 billion.
Twin Gates Corporation, Wilmington, Del., the

$18,604,148
120,000

To be
operated

2
0

18,604,148

second registered bank holding company which will
acquire the resulting bank, has total assets of $4.9
million. It owns 14.2 percent of the outstanding
common shares of Northern States Corporation,
Inc., and 20 percent of the outstanding common
capital stock of the merging bank.
Direct competition between the merging bank and
the subsidiaries of Northern States Corporation,
Inc., and Twin Gates Corporation is insignificant.
Even though a branch of City National Bank of Detroit is located only 3.3 miles south of the merging
bank, a minimal number of accounts are generated
from each other's service area. In addition, the two
banks experience a close working association and
common ownership.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
affiliation with the holding companies will enhance
the competitive position of National Bank of Rochester by allowing it to offer new and expanded services
such as a larger lending capacity through loan participations, lending expertise, management expertise, and international services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
FEBRUARY 6,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which National Bank of Rochester would become a
subsidiary of Northern States 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
Northern States Bancorporation, it would have no
effect on competition.

125

THE FIRST NATIONAL BANK OF CROCKETT, CROCKETT, TEX., AND THE N E W NATIONAL BANK OF CROCKETT,
CROCKETT, TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

The First National Bank of Crockett, Crockett, Tex. (4684), with
and The New National Bank of Crockett, Crockett, Tex. (4684), which had
merged Mar. 18,1974, under charter of the latter bank (4684) and title "The First National Bank
of Crockett." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 1, 1973, The First National Bank of
Crockett, Crockett, Tex., and The New National
Bank of Crockett (organizing), Crockett, Tex.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of the former.
The First National Bank of Crockett, the existing
bank, was organized in 1892 and has operated since
that time as a unit institution in compliance with
Texas State law. It now has assets of $21.4 million
and IPC deposits of $16 million. The service area of
the bank includes the city of Crockett and the surrounding county, in a 12-mile radius. The economy
of the service area consists of light manufacturing,
several retail businesses, and regional shopping
centers serving the 7,300 member community of
Crockett, much of which is made up of retired
individuals.
Competition for The First National Bank of
Crockett is provided by the only other bank located
in Crockett, The Crockett State Bank, with deposits
of $7.9 million.
The New National Bank of Crockett, is being
organized to provide a vehicle by which to transfer
ownership of The National Bank of Crockett to
Allied Bancshares, Inc. The new bank will not be
operating as a commercial bank prior to this merger.
Allied Bancshares, Inc., Houston, Tex., the bank
holding company which will acquire the resulting
bank, is presently the 11th largest bank holding
company in Texas and owns three banking subsidiaries, the largest of which is Continental Bank of

126

$23,958,730
120,000

To be
operated

1
0

23,776,436

Texas, Houston, with total deposits of $167.7
million.
There is no competition between Allied Bancshares, Inc., or its subsidiaries and The First National Bank of Crockett because the closest subsidiary bank of the holding company is located in
Conroe, Tex., which is 79 miles from the existing
bank in Crockett. Also, an adequate number of
alternative banking facilities operate in the intervening distances.
Consummation of the proposed transaction will
stimulate competition in Crockett because the resulting subsidiary will be able to offer the residents of
that community new and more sophisticated banking
services such as a full-service trust department,
investment counseling, computer facilities, and
international banking. Also, the resulting subsidiary
will be able to handle larger loan requests because
of the convenient availability of participation
sources.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
FEBRUARY 15,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE SELMA NATIONAL BANK, SELMA, ALA., AND SELMA BANK, N.A.,

SELMA, ALA.
Banking f

Total assets

Name of bank and type of transaction

In
operation
The Selma National Bank, Selma, Ala. (7084), with
and Selma Bank, N.A., Selma, Ala. (7084), which had
merged Mar. 27, 1974, under charter of the latter bank (7084) and title "The Selma National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 16, 1973, The Selma National Bank,
Selma, Ala., and Selma Bank, N.A. (organizing),
Selma, Ala., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
The Selma National Bank, Selma, Ala., the merging bank, was organized in 1904 and operates one
facility at Craig Air Force Base. It possesses total
assets of $37.2 million and IPC deposits of $30
million. The service area of the bank is Dallas
County, which has a population of 55,000 and is
economically dependent on agriculture, industry,
and business from Craig Air Force Base.
Competition for the merging bank is provided in
Selma by Peoples Bank and Trust Company, with
deposits of $39.7 million; City National Bank of
Selma, with deposits of $29.4 million; and Citizens
Bank and Trust Company, with deposits of $15.8
million.
Selma Bank, N.A., the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to First Alabama
Bancshares, Inc., Birmingham, Ala., a registered
bank holding company. The charter bank will not be
operating as a commercial bank prior to this merger.
First Alabama Bancshares, Inc., the bank holding
company that will acquire the resulting bank, was
incorporated in 1971 and is the second largest banking organization in Alabama. It controls eight banks,
with aggregate deposits of $741.6 million. Its largest
subsidiary is the First National Bank of Montgomery,
which has deposits of $280.3 million.

$39,967,671
120,000

offices
To be
operated

1
0
1

39,971,271

Competitors of First Alabama Bancshares, Inc.,
include Alabama Bancorporation, with aggregate
deposits of $872.7 million; Central Bancshares of the
South, with aggregate deposits of $674.3 million; and
Alabama Financial Group, Inc., with aggregate
deposits of $600.4 million.
Direct competition between the merging bank and
the subsidiaries of First Alabama Bancshares, Inc.,
is minimal as their closest offices are separated by a
distance of approximately 45 miles.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with First Alabama Bancshares, Inc., will allow the
resulting bank to offer a wider range of more sophisticated banking services such as larger commercial
and industrial loans, competitive mortgage lending,
and lease financing.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
FEBRUARY 25,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

127

FIRST NATIONAL BANK OF ATHENS, ATHENS, ALA., AND FIRST BANK OF ATHENS, N.A.,

ATHENS, ALA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank of Athens, Athens, Ala. (15073), with
and First Bank of Athens, N. A., Athens, Ala. (15073), which had
merged Mar. 29, 1974, under charter of the latter bank (15073) and title "First National Bank of
Athens." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 13, 1974, First National Bank of
Athens, Athens, Ala., and First Bank of Athens,
N.A. (organizing), Athens, Ala., applied to the
Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
First National Bank of Athens, the existing bank,
was organized in 1927 and presently operates two
branches in Athens and one branch in Elkmont. It
has total assets of $28.9 million and IPC deposits of
$23 million. The service area of the existing bank
includes all of Limestone County, in the northcentral part of Alabama adjacent to the Tennessee
border, which has a population of 41,000. The economy of the service area is supported mainly by agriculture.
Competition for First National Bank of Athens is
provided by a branch of State National Bank of
Alabama, Decatur, with deposits of $333.2 million,
as well as by two banks which are located in Ardmore, Tenn., 16 miles north of Athens. Direct competition will be provided by Citizens National Bank
of Limestone County, Athens, a newly organizing
bank which will begin operations in the near future.
First Bank of Athens, N.A., the new bank, is
being organized to provide a vehicle by which to
transfer ownership of First National Bank of Athens
to First Alabama Bancshares, Inc. The new bank
will not be operating as a commercial bank prior to
this merger.
First Alabama Bancshares, Inc., Birmingham, the
holding company which will acquire the resulting
bank, was organized in 1971 and currently is the
second largest multi-bank holding company in the
State with aggregate deposits of $620 million. First
Alabama Bancshares controls four subsidiary banks,
one located in each of the cities of Birmingham,
Montgomery, Huntsville, and Dothan. In addition,
First Alabama Bancshares has received approval to

128

$32,035,189
120,000

To be
operated

4
0

32,031,589

acquire the First National Bank of Bay Minette and
has submitted applications to acquire three other
banks, one each in Guntersville, Selma, and Tuscaloosa.
There is no competition between the holding company or its subsidiaries and First National Bank of
Athens because of the distance separating their
closest offices and because an adequate number of
alternative banking facilities operate in the intervening area. The nearest subsidiary of the holding
company is First National Bank of Huntsville, 28
miles southeast of Athens.
Consummation of the proposed merger will enable
the resulting bank to provide residents and businessmen in Limestone County with a wider range of more
sophisticated banking services including the ability
to offer commercial and industrial loans of sufficient
size to encourage growth in the area, specialized
trust services, data processing, lease financing, and
competitive mortgage lending. The resulting subsidiary in Limestone County will also gain the availability of added management depth. As a result of
this application, First Alabama Bancshares will
remain the second largest bank holding company in
Alabama.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
FEBRUARY 27,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF HANCOCK, HANCOCK, N.Y., AND HANCOCK NATIONAL BANK, HANCOCK, N.Y.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Hancock, Hancock, N.Y. (8613), with
and Hancock National Bank, Hancock, N.Y. (8613), which had
merged Mar. 29, 1974, under charter of the latter bank (8613) and title "The First National Bank
of Hancock." The merged bank at date of merger had

COMPTROLLER'S DECISION

On September 14, 1973, The First National Bank
of Hancock, Hancock, N.Y., and Hancock National
Bank (organizing), Hancock, N.Y., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and title of the
former.
The First National Bank of Hancock, the merging
bank, was chartered in 1907 and operates as a unit
bank. The bank has total assets of $9.8 million and
IPC deposits of $7.8 million.
Hancock National Bank, the charter bank, is
being organized to provide a vehicle to transfer
ownership of the merging bank to Charter New York
Corporation. The charter bank will not be operating
as a commercial bank prior to this merger.
Charter New York Corporation, New York, N.Y.,
the holding company which will acquire the resulting
bank, is the seventh largest bank holding company
in New York State, with total deposits of $5.2 billion and assets of $7.8 billion in its 14 banks throughout the State. Its largest subsidiary is Irving Trust
Company, New York, N.Y., with $5 billion in total
assets. The applicant competes with such other bank
holding companies in New York as First National
City Corporation, with assets of $34.3 billion; Chase
Manhattan Corporation, with assets of $28.8 billion;
Manufacturers Hanover Corporation, with assets of
$16.3 billion; Chemical New York Corporation, and
Bankers Trust New York Corporation, each with
assets of $13.4 billion.
Tied in with this merger is the proposed purchase
of assets and assumption of liabilities of The First
National Bank of Hamden, Hamden, N.Y., by the
Hancock National Bank. The Hamden bank, which
has total deposits of $4.1 million and is eighth in size
of the 10 Delaware County-based banks, has experienced serious capital, loan, and management problems to the extent that without additional capital and
experienced management it is improbable that this
bank can continue to operate. The Hamden bank
will operate as a branch of the Hancock bank under

$10,368,754
65,000

To be
operated

1
0
1

14,164,799

the proposal which will allow the Hamden facility to
continue in operation and also remove head office
protection from Hamden allowing further branching
competition by other banks.
There is no competition between any of Charter
New York Corporation's subsidiaries and The First
National Bank of Hancock or The First National
Bank of Hamden because the nearest subsidiary is
43 miles from Hancock with sufficient competition
within the intervening distance.
The proposed transaction will have a negligible
effect on the statewide competitive position of
Charter New York Corporation because of the relatively small size of the merging bank but it will
increase competition in Delaware County where The
First National Bank of Hancock and The First National Bank of Hamden are both headquartered by
enabling the Hamden bank to remain in business
and by removing head office protection from both
Hancock and Hamden which will allow de novo
branching by other banks. It will also allow these
banks to offer expanded services to the people of
Delaware County including larger loans, a wider
variety of time and demand deposits, credit cards,
complete trust services, and the expertise available
through the holding company.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
FEBRUARY 21,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

129

THE FIRST NATIONAL BANK OF NORDHEIM, NORDHEIM, TEX., AND THE NEW NATIONAL BANK OF
NORDHEIM, NORDHEIM, TEX.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Nordheim, Nordheim, Tex. (12390), with
and The New National Bank of Nordheim, Nordheim, Tex. (12390), which had
merged Apr. 1, 1974, under charter of the latter bank (12390) and title "The First National Bank
of Nordheim." The merged bank at date of merger had

COMPTROLLER S DECISION

On October 26, 1973, The First National Bank of
Nordheim, Nordheim, Tex., and The New National
Bank of Nordheim (organizing), Nordheim, Tex.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of the former.
The First National Bank of Nordheim, the merging
bank, was organized in 1910 and has total assets of
$1.5 million and IPC deposits of $1.1 million. The
area surrounding Nordheim and Yorktown in western DeWitt County constitutes the service area of
the bank. Its competitors include First National
Bank, Yorktown, with deposits of $96 million, and
Yorktown Community Bank, with deposits of $4.9
million.
The New National Bank of Nordheim (organizing), Nordheim, Tex., the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to Victoria Bankshares, Inc., Victoria, Tex. The charter bank will
not be operating as a commercial bank prior to the
merger.
Victoria Bankshares, Inc., the organization which
will acquire the resulting bank, has applied for permission to become a bank holding company and to
acquire five banks in addition to the resulting bank.
Upon consummation of these transactions, it will be
the 18th largest bank holding company in Texas.

$1,855,142
60,000

To be
operated

1
0
1

2,001,160

Since 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. Nor will competition be adversely affected if the other five acquisitions proposed by Victoria Bankshares, Inc., are
approved since all of the proposed subsidiaries operate in separate and distinct service areas which have
a sufficient number of alternate banking choices.
Affiliation with Victoria Bankshares, Inc., will allow
the resulting bank to offer new services such as a
trust department, oil and gas department, and investment counsel.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
FEBRUARY 5,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

FIRST NATIONAL BANK IN ASPEN, ASPEN, COLO., AND SECOND NATIONAL BANK IN ASPEN, ASPEN, COLO.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank in Aspen, Aspen, Colo. (15815), with
and Second National Bank in Aspen, Aspen, Colo. (15815), which had
merged Apr. 29, 1974, under charter of the latter bank (15815) and title "First National Bank in
Aspen." The merged bank at date of merger had

130

$14,638,104
60,000
14,698,104

To be
operated

1
0
1

COMPTROLLER S DECISION

On November 1, 1973, First National Bank in
Aspen, Aspen, Colo., and Second National Bank in
Aspen (organizing), Aspen, Colo., 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 in Aspen, the merging bank,
was organized in 1970 and operates as a unit institution. With total assets of $13.2 million and IPC
deposits of $10 million, it is the smaller of two
banks serving the Aspen Metropolitan Area. It competes directly with Bank of Aspen, with deposits of
$20.3 million.
Second National Bank in Aspen, the charter bank,
is being organized to provide a vehicle by which to
transfer ownership of the merging bank to D. H.
Baldwin Company, Cincinnati, Ohio, a registered
bank holding company. The charter bank will not be
operating as a commercial bank prior to this merger.
D. H. Baldwin Company, the holding company
which will acquire the resulting bank, engages in the
manufacture and sale of musical instruments as
well as their electronic components, and provides
financial services to dealers in its products. It now
controls Central Bank and Trust Company, Denver,
with deposits of $331.5 million, and the North

Denver Bank, with deposits of $27 million. In addition, it controls four organizing banks including
Second National Bank of Aspen, which it wishes to
merge with four existing banks.
Competition between the operating subsidiaries of
D. H. Baldwin Company and the merging bank is
virtually nonexistent since they are separated by a
distance of more than 150 road miles. Affiliation of
the resulting bank with D. H. Baldwin Company will
enhance the competitive situation in Aspen since the
resulting bank will be provided with increased capital, improved lending expertise, and trust services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MARCH 28,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through
which the existing banks will become subsidiaries of
D. H. Baldwin Company. [It] * * *, however, will
merely combine an existing bank with a non-operating institution and without regard to the acquisition
of the surviving banks by D. H. Baldwin Company,
will have no effect on competition.

THE FIRST NATIONAL BANK OF GLENWOOD SPRINGS, GLENWOOD SPRINGS, COLO., AND SECOND NATIONAL
BANK IN GLENWOOD SPRINGS, GLENWOOD SPRINGS, COLO.
Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Glenwood Springs, Glenwood Springs, Colo. (3661), with
and Second National Bank in Glenwood Springs, Glenwood Springs, Colo. (3661), which had .
merged Apr. 29, 1974, under charter of the latter bank (3661) and title "First National Bank of
Glenwood Springs." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 1, 1973, First National Bank of
Glenwood Springs, Glenwood Springs, Colo., and
Second National Bank in Glenwood Springs (organizing), Glenwood Springs, Colo., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and title of the former.
The First National Bank of Glenwood Springs, the
merging bank, was organized in 1887 and operates
as a unit institution. It possesses total assets of $36.5

$40,455,126
60,000
40,515,126

In
To be
operation operated
1
0
1

million and IPC deposits of $29.2 million. The
service area of the bank encompasses the southeastern section of Barfield County and an adjoining
portion of western Pitkin County. Competition in
that area is afforded by Bank of Glenwood, which
has deposits of $11.7 million and is a subsidiary of
Colorado National Bankshares, Inc.; First National
Bank in Rifle, which has deposits of $9.3 million; and
Roaring Fork Bank, which was opened in 1973.
Second National Bank in Glenwood Springs, the
charter bank, is being organized to provide a vehicle

131

to transfer ownership of the merging bank to D. H.
Baldwin Company, Cincinnati, Ohio. The charter
bank will not be operating as a commercial bank
prior to this merger.
D. H. Baldwin Company, Cincinnati, Ohio, the
holding company which will acquire the resulting
bank, operates primarily in Colorado and deals in
banking, savings and loan, insurance, and other
financial services. Its wholly-owned subsidiary,
Baldwin-Central, Inc., is a one-bank holding company which controls Central Bank and Trust Company, Denver, Colo., which has deposits of $331.5
million.
The acquiring bank holding company has made
application to acquire several other Colorado banks.
No competition exists between those banks and
Central Bank and Trust Company, the present subsidiary, since their closest offices are separated by
a distance of approximately 169 miles.
Because the merging bank and the other banks to
be acquired by D. H. Baldwin Company are substantially owned by the McKinley family and because
policies of the banks are dominated by their president, George B. McKinley, no adverse competitive
effects will result from consummation of this and the
other pending actions. The economies of the areas

under consideration are expected to expand rapidly
in the near future through increased tourism and
skiing activity, development of an oil shale industry,
renewed activity in uranium and coal mining, and oil
and gas exploration and development. Consummation of the proposed transaction will afford the
resulting bank the increased capital, lending expertise, and trust services which the areas will soon
require, thus enhancing competition. D. H. Baldwin
Company will become the fourth largest bank holding company in Colorado upon consummation of
this and the other pending transactions.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed merger is in the
public interest and this application is, therefore,
approved.
MARCH 28,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

FIRST NATIONAL BANK IN GRAND JUNCTION, GRAND JUNCTION, COLO., AND SECOND NATIONAL BANK IN
GRAND JUNCTION, GRAND JUNCTION, COLO.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank in Grand Junction, Grand Junction, Colo. (13902), with
and Second National Bank in Grand Junction, Grand Junction, Colo. (13902), which had
merged Apr. 29, 1974, under charter of the latter bank (13902) and title "First National Bank in
Grand Junction." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 1, 1973, First National Bank in
Grand Junction, Grand Junction, Colo., and Second
National Bank in Grand Junction (organizing), Grand
Junction, Colo., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and title of the former.
First National Bank in Grand Junction, Grand
Junction, Colo., the merging bank, was organized in
1933 and operates as a unit institution. With total
assets of $46.1 million and IPC deposits of $37
million, it is the largest of the four banks located in
Grand Junction. Its service area encompasses Mesa
132

$51,045,708
120,000
51,165,708

To be
operated

1
0
1

County wherein it competes with United States Bank
of Grand Junction, with deposits of $38.2 million;
Mesa United Bank of Grand Junction, N.A., with
deposits of $13.6 million; First National Bank-North
in Grand Junction, with deposits of $1 million; Fuita
State Bank, with deposits of $6.4 million; and Palisades National Bank, with deposits of $3.8 million.
Second National Bank in Grand Junction, the
charter bank, is being organized to provide a vehicle
to transfer ownership of the merging bank to D. H.
Baldwin Company, Cincinnati, Ohio. The charter
bank will not be operating as a commercial bank
prior to this merger.
D. H. Baldwin Company, Cincinnati, Ohio, the

holding company which will acquire the resulting
bank, operates primarily in Colorado and deals in
banking, savings and loan, insurance, and other
financial services. Its wholly-owned subsidiary,
Baldwin-Central, Inc., is a one-bank holding company which controls Central Bank and Trust Company, Denver, Colo., with deposits of $331.5 million.
The acquiring bank holding company has made
application to acquire several other Colorado banks.
No competition occurs between those banks and
Central Bank and Trust Company, the present subsidiary, as their closest offices are separated by a
distance of approximately 169 miles.
Because First National Bank in Grand Junction
and the other banks to be acquired by D. H. Baldwin
Company, including First National Bank - North in
Grand Junction, are substantially owned by the
McKinley family and because policies of the banks
are dominated by their president, George B. McKinley, no adverse competitive effects will result from
consummation of this and the other pending transactions even though First National Bank in Grand
Junction and First National Bank - North in Grand
Junction are separated by only 2.2 miles. The economies of the areas under consideration are expected
to expand rapidly in the near future through in-

creased tourism and skiing activity, development of
an oil shale industry, renewed activity in uranium
and coal mining, and oil and gas exploration and
development. Consummation of the proposed transaction will afford the resulting bank the increased
capital, lending expertise, and trust services which
the areas will soon require, thus enhancing competition. D. H. Baldwin Company will become the
fourth largest bank holding company in Colorado
upon consummation of this and the other pending
transactions.
Applying the statutory criteria, it is the conclusion
of this Office that the proposed merger is in the
public interest and this application is, therefore,
approved.
MARCH 28,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through which
the existing banks will become subsidiaries of D. H.
Baldwin Company. [It] * * *, however, will merely
combine an existing bank with a non-operating institution and without regard to the acquisition of the
surviving banks by D. H. Baldwin Company, will
have no effect on competition.

FIRST NATIONAL BANK - NORTH IN GRAND JUNCTION, GRAND JUNCTION, COLO., AND SECOND NATIONAL
BANK - NORTH, GRAND JUNCTION, GRAND JUNCTION, COLO.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank - North in Grand Junction, Grand Junction, Colo. (16054), with
and Second National Bank - North, Grand Junction, Grand Junction, Colo. (16054), which h a d . . .
merged Apr. 29, 1974, under charter of the latter bank (16054) and title "First National Bank North in Grand Junction." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 1, 1973, First National Bank - North
in Grand Junction, Grand Junction, Colo., and
Second National Bank - North, Grand Junction
(organizing), Grand Junction, Colo., 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 - North in Grand Junction, the
merging bank, was organized in 1972 and now has
total assets of $2.5 million and IPC deposits of $1.5
million. The merging bank presently operates two
walk-up windows and three drive-in units and its

$3,966,041
120,000
4,086,041

To be
operated

1
0
1

service area consists of a portion of eastern Grand
Junction and environs. The bank is the smallest of
the four banks located in Grand Junction and competes with United States Bank in Grand Junction,
with deposits of $38.2 million, and Mesa United
Bank of Grand Junction, with deposits of $13.6
million.
Second National Bank - North, Grand Junction,
the charter bank, is being organized to provide a
vehicle by which to transfer ownership of the merging bank to D. H. Baldwin Company, Cincinnati,
Ohio, a registered bank holding company. The
charter bank will not be operating as a commercial
bank prior to this merger.
133

D. H. Baldwin Company, the holding company
which will acquire the resulting bank, engages in
the manufacture and sale of musical instruments as
well as their electronic components and provides
financial services to dealers in its products. It now
controls Central Bank and Trust Company, Denver,
with deposits of $331.5 million, and The North
Denver Bank, with deposits of $27 million. In addition, it controls four organizing banks, including
Second National Bank - North, Grand Junction,
which it wishes to merge with four existing banks.
Competition between the operating subsidiaries of
D. H. Baldwin Company and the merging bank is
virtually nonexistent since they are separated by a
distance of more than 200 road miles. Affiliation of
the resulting bank with D. H. Baldwin Company
will enhance the competitive situation in Grand

Junction as the resulting bank will be provided with
increased capital, improved lending expertise, and
trust services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MARCH 28,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through which
the existing banks will become subsidiaries of D. H.
Baldwin Company. [It] * * *, however, will merely
combine an existing bank with a non-operating institution and without regard to the acquisition of the
surviving banks by D. H. Baldwin Company, will
have no effect on competition.

CONCORD NATIONAL BANK, CONCORD, N.H., AND THE CONCORD BANK, NATIONAL ASSOCIATION,
CONCORD, N.H.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Concord National Bank, Concord, N.H. (318), with
and The Concord Bank, National Association, Concord, N.H. (318), which had
merged Apr. 30, 1974, under charter of the latter bank (318) and title "Concord National Bank."
The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 31, 1973, Concord National Bank,
Concord, N.H., and The Concord Bank, National
Association (organizing), Concord, N.H., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
Concord National Bank, the merging bank, was
organized in 1864 and now operates two branch
offices. With total assets of $46.3 million and IPC
deposits of $31.5 million, it ranks as sixth largest
among the commercial banks in New Hampshire.
The service area of the bank includes Concord and
the towns contiguous to it. Competitors for the
merging bank include branches of Bank of New
Hampshire, National Association, with deposits of
$121 million; The New Hampshire Savings Bank,
with deposits of $115 million; Concord Savings
Bank, with deposits of $50.6 million; and Merrimack
County Savings Bank, with deposits of $36 million.
The Concord Bank, National Association, the
charter bank, is being organized to provide a vehicle
134

To be
operated

$49,518,116
120,000
49,638,116

by which to transfer ownership of the merging bank
to First Bancorporation of New Hampshire, Inc.,
Exeter, N.H. The charter bank will not be operating
as a commercial bank prior to the merger.
First Bancorp of N.H., Inc., the registered bank
holding company which will acquire the resulting
bank, was incorporated in 1971. It possesses total
assets of $37.6 million and controls one banking
subsidiary, Exeter Banking Company, with deposits
of $31.6 million. Competitors for that subsidiary
include Indian Head National Bank of Exeter, which
has deposits of $34 million and is a member of
Indian Head Banks, Inc., and Hampton National
Bank, which has deposits of $13 million.
Consummation of the proposed transaction will
result in no adverse competitive effects. Competition between the merging bank and Exeter Banking
Company is minimal because their closest offices
are separated by a distance of 28 miles and because
they serve distinct areas. Rather, competition will
be increased because affiliation with First Bancorp
of N.H., Inc., will allow the resulting bank to offer
improved and expanded services such as easier

access to loan participation, leasing, real estate
financing, and revolving accounts receivable financing. The resulting bank will utilize the same name
and offices as presently used by the merging bank.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MARCH 12,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through which
the existing banks will become subsidiaries of First
Bancorp of N.H., Inc. [It] * * *, however, will merely
combine an existing bank with a non-operating institution and without regard to the acquisition of the
surviving banks by First Bancorp of N.H., Inc., will
have no effect on competition.

LACONIA PEOPLES NATIONAL BANK & TRUST COMPANY, LACONIA, N.H.,
NATIONAL ASSOCIATION, LACONIA,

AND THE LACONIA BANK,

N.H.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Laconia Peoples National Bank & Trust Company, Laconia, N.H. (4037), with
and The Laconia Bank, National Association, Laconia, N.H. (4037), which had
merged Apr. 30, 1974, under charter of the latter bank (4037) and title "Laconia Peoples National Bank and Trust Company." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 28, 1973, Laconia Peoples National
Bank & Trust Company, Laconia, N.H., and The
Laconia Bank, National Association (organizing),
Laconia, N.H., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title "Laconia Peoples
National Bank and Trust Company."
Laconia Peoples National Bank & Trust Company, Laconia, N.H., the merging bank, was organized in 1969, now operates one drive-up branch and
one walk-up branch during the summer months.
With total assets of $26 million and IPC deposits of
$19.3 million, it is the largest commercial bank in
Belknap County. Because the service area of the
bank encompasses Laconia and the towns contiguous to it, a summer resort area, it experiences its
strongest competition from Laconia Savings Bank,
with deposits of $44.5 million, and Meredith Village
Savings Bank, with deposits of $23.7 million.
The Laconia Bank, National Association, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to First Bancorp of New Hampshire, Inc., Exeter,
N.H., a bank holding company. The charter bank
will not be operating as a commercial bank prior to
consummation of the proposed transaction.

$27,687,575
120,000
27,691,175

To be
operated

4
0
4

First Bancorp of New Hampshire, Inc., the bank
holding company that will acquire the resulting
bank, was organized in 1971. It controls one subsidiary bank, Exeter Banking Company, which has
deposits of $31 million. This bank derives its major
competition from Indian Head National Bank of
Exeter, which has deposits of $33.5 million and is a
member of Indian Head Banks, Inc., and from the
banks located in the nearby city of Portsmouth.
Competition between the merging bank and the
existing subsidiary of First Bancorp of New Hampshire, Inc., is virtually nonexistent since they are
separated by a distance of 60 miles. In addition, the
president and a director of the holding company is
also a director of the merging bank.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with First Bancorp of New Hampshire, Inc., will
enable the resulting bank to offer improved and
expanded services including a larger loan capacity
through loan participations and data processing
services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MARCH 12,

1974.

135

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through which
the existing banks will become subsidiaries of First
Bancorp of N.H., Inc. [It] * * *, however, will merely

combine an existing bank with a non-operating institution and without regard to the acquisition of the
surviving banks by First Bancorp of N.H., Inc., will
have no effect on competition.

THE CITY NATIONAL BANK OF SELMA, SELMA, ALA., AND DALLAS COUNTY NATIONAL BANK, SELMA, ALA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The City National Bank of Selma, Selma, Ala. (1736), with
and Dallas County National Bank, Selma, Ala. (1736), which had
merged Apr. 30, 1974, under charter of the latter bank (1736) and title "The City National Bank
of Selma." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 23, 1973, The City National Bank of
Selma, Selma, Ala., and Dallas County National
Bank (organizing), Selma, Ala., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
The City National Bank of Selma, the existing
bank, was organized in 1870 and presently operates
a single office with assets of $33.3 million and IPC
deposits of $24.2 million from which it serves the city
of Selma and the area within a 10-mile radius of the
bank. The existing bank has been granted approval
to open a branch office in northwest Selma.
Competition for the existing bank is provided by
The Peoples Bank and Trust Company, Selma, with
deposits of $41.5 million; The Selma National Bank,
with deposits of $31 million; Citizens Bank and
Trust Company, Selma, with deposits of $16.7 million; and The Peoples Bank at Selma Mall, National
Association, with deposits of $1.3 million.
Dallas County National Bank, the new bank, is
being organized to provide a vehicle by which to
transfer ownership of The City National Bank of
Selma to Alabama Bancorporation, Birmingham, the
largest bank holding company in the State. The
new bank will not be operating as a commercial
bank prior to this merger.
Alabama Bancorporation, the bank holding company which will acquire the resulting bank was
organized in 1970 and presently controls seven
banks throughout the State with aggregate deposits
of $1.1 billion. The largest of those subsidiary banks
is The First National Bank of Birmingham, with
136

$38,037,630
120,000
38,157,630

To be
operated

2
0

deposits of $806 million. The remaining subsidiaries
are located in Decatur, Mobile, Sulligent, Anniston,
Montgomery, and Huntsville. In addition, Alabama
Bancorporation has approval to acquire J. C. Jacobs
Banking Company, Inc., Scottsboro, with deposits
of $17.7 million; Baldwin National Bank, Robertsdale, with deposits of $8.7 million; and Fort Payne
Bank, Fort Payne, with deposits of $14.3 million.
The bank holding company also controls six nonbanking subsidiaries which specialize in mortgage
servicing and financial data operations.
There is no competition between Alabama Bancorporation or its subsidiaries and The City National
Bank of Selma because of the distance that separates their closest two offices and the adequate number of alternative banking facilities which operate in
the intervening area. The closest office of a subsidiary bank of Alabama Bancorporation to The City
National Bank of Selma is 50 miles away in Montgomery.
Consummation of the proposed merger will stimulate competition in Dallas County because the resulting subsidiary in Selma will be able to offer new and
improved services such as FHA and VA long-term
mortgage loans, a wider range of trust services, an
investment bond department, and international
banking. In addition, consummation of the proposal
will enable the resulting bank to serve larger credit
lines and to provide increased services for local
representatives of National accounts. Furthermore,
the acquisition of the resulting bank by Alabama
Bancorporation will not significantly change its size
in relation to that of the other multi-bank holding
companies in Alabama.
Applying the statutory criteria, it is concluded

that the proposed merger is in the public interest
and this application is, therefore, approved.
MARCH 27,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which The City National Bank of Selma would

become a subsidiary of Alabama Bancorporation, a
bank holding company. The instant merger, however, would merely combine an existing bank with
a non-operating institution; as such, and without
regard to the acquisition of the surviving bank by
Alabama Bancorporation, it would have no effect on
competition.

THE MERCHANTS NATIONAL BANK OF MANCHESTER, MANCHESTER, N.H.,
NATIONAL ASSOCIATION, MANCHESTER,

AND THE MERCHANTS BANK,

N.H.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Merchants National Bank of Manchester, Manchester, N.H. (1520), with
and The Merchants Bank, National Association, Manchester, N.H. (1520), which had
merged Apr. 30, 1974, under charter of the latter bank (1520) and title "The Merchants National
Bank of Manchester." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 31, 1973, The Merchants Bank,
National Association (organizing), Manchester,
N.H., applied to the Comptroller of the Currency for
permission to merge with The Merchants National
Bank of Manchester, Manchester, N.H., under the
charter of the former and with the title of the latter.
The Merchants National Bank, the merging bank,
was organized in 1853 and now holds total deposits
of approximately $37.5 million. The bank is headquartered in Manchester, Hillsboro County, N.H.,
and maintains three branch offices. Its primary
service area consists of the city of Manchester and
contiguous towns. Manchester, the largest city in
New Hampshire, has an approximate population of
87,754. The merging bank, ranking third of six
commercial banks located in Manchester, competes
primarily with The Manchester Bank, with $135.3
million in deposits, and Bank of New Hampshire,
with $120.8 million in deposits. Those banks are,
respectively, the second and third largest banks in
New Hampshire. Other competitors include Amoskeag National Bank and Trust Company, with total
deposits of $36.6 million; Amoskeag Savings Bank,
with total deposits of $250 million; and The Merchants Savings Bank of Manchester, with total
deposits of $143.2 million.
The Merchants Bank, National Association, Manchester, N.H., the charter bank, is being organized
to provide a vehicle by which to transfer ownership
of the merging bank to First Bancorp of New Hampshire, Inc. The charter bank will not be operating as

$48,482,913
240,000

To be
operated

4
0
4

48,722,913

a commercial bank prior to the proposed merger.
First Bancorp of New Hampshire, Inc., the holding company which will acquire the resulting bank,
is headquartered in Exeter, Rockingham County,
N.H. The holding company's only subsidiary is The
Exeter Banking Company, a trust company with
total deposits of approximately $30.9 million.
As there is no overlap in the service area of the
present subsidiary of First Bancorp of New Hampshire, Inc. and The Merchants National Bank, the
proposed acquisition will not adversely affect competition. The closest office of the Exeter Banking
Company is in Raymond, 18 miles from the nearest
branch of The Merchants National Bank. The proposed transaction will enable the resulting bank to
offer more complete and sophisticated services
enhancing its ability to compete with its larger
competitors.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest. The
application is, therefore, approved.
MARCH 12,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

137

THE FIRST NATIONAL BANK OF SAULT STE. MARIE, SAULT STE. MARIE, MICH., AND SAULT NATIONAL BANK,
SAULT STE. MARIE, MICH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Sault Ste. Marie, Sault Ste. Marie, Mich. (3547), with
and Sault National Bank, Sault Ste. Marie, Mich. (3547), which had
merged May 8, 1974, under charter of the latter bank (3547) and title "The First National Bank
of Sault Ste. Marie." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 12, 1973, Sault National Bank (organizing), Sault Ste. Marie, Mich., and The First National Bank of Sault Ste. Marie, Sault Ste. Marie,
Mich., applied to the Comptroller of the Currency
for permission to merge under the charter of the
former and with the title of the latter.
The First National Bank of Sault Ste. Marie, the
existing bank, was organized in 1886 and presently
operates two branches with total assets of $25.9
million and IPC deposits of $18.9 million. The existing bank serves Sault Ste. Marie and the northeastern corner of the upper peninsula of Michigan.
Competition for The First National Bank of Sault
Ste. Marie is provided by Sault Savings Bank, Sault
Ste. Marie, which has deposits of $33 million; The
First National Bank of St. Ignace, which has deposits of $17.1 million; Central Savings Bank, Sault
Ste. Marie, which has deposits of $18 million; and
The Citizens State Bank of Rudyard, which has
deposits of $5.2 million.
Sault National Bank is being organized to provide
a vehicle by which to transfer ownership of The First
National Bank of Sault Ste. Marie to First National
Financial Corporation, Kalamazoo, Mich. The new
bank will not be operating as a commercial bank
prior to this merger.
First National Financial Corporation, the holding
company which will acquire the resulting bank, is
currently the 11th largest multi-bank holding company in Michigan. The holding company controls
eight banks with aggregate deposits of $420.2 million. Its lead bank is The First National Bank and
Trust Company of Michigan, Kalamazoo, which has
deposits of $375 million. First National Financial

138

$24,723,196
120,000

To be
operated

2
0

24,954,611

Corporation also controls Great Lakes Computer
Service which furnishes automated services to the
subsidiary banks.
There is no competition between First National
Financial Corporation or its subsidiaries and The
First National Bank of Sault Ste. Marie because
large distances separate their closest two offices and
an adequate number of alternative banking facilities
operate in the intervening area. The closest existing
subsidiary of First National Financial Corporation
is located 45 miles to the south in Mackinaw City.
Consummation of the proposed merger will stimulate competition in the upper peninsula of Michigan
because the resulting subsidiary in Sault Ste. Marie
will be able to ofifer new and improved services such
as an in-plant payroll deduction plan, a Master
Charge credit card program, a trust department, a
Christmas Club, and agricultural services. In addition, the holding company will furnish an experienced commercial loan officer for the resulting bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
APRIL 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

OLD & THIRD NATIONAL BANK OF UNION CITY, UNION CITY, TENN., AND THE NATIONAL BANK OF UNION
CITY, UNION CITY, TENN.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Old & Third National Bank of Union City, Union City, Tenn. (9629), with
and The National Bank of Union City, Union City, Tenn. (9629), which had
merged May 9, 1974, under charter of the latter bank (9629) and title "Old & Third National
Bank of Union City." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 27, 1973, The National Bank of
Union City (organizing), Union City, Tenn., and Old
& Third National Bank of Union City, Union City,
Tenn., applied to the Comptroller of the Currency
for permission to merge under the charter of the
former and with the title of the latter.
Old & Third National Bank of Union City, the
existing bank, was organized in 1910, and presently
operates two branches with total assets of $40.1
million and IPC deposits of $27.5 million. The
service area of the existing bank consists of Obion
County, Tenn., which has a population of 29,936.
The economy of the service area is based on agriculture and manufacturing.
Competition for Old & Third National Bank of
Union City is provided by Farmers Exchange Bank,
Union City, which has deposits of $22 million and is
a member of First Amtenn Corporation, Nashville;
First State Bank, Kenton, which has deposits of
$6.6 million; The Commercial Bank, Obion, which
has deposits of $6.0 million; Bank of Troy, which
has deposits of $5.2 million; Reelfoot Bank, Union
City, which has deposits of $4.9 million; Bank of
Elbridge, which has deposits of $4.1 million; and
Farmers Bank, Woodland Mills, which has deposits
of $3.2 million.
The National Bank of Union City, is being organized to provide a vehicle by which to transfer
ownership of Old & Third National Bank of Union
City to Tennessee Valley Bancorporation, Inc. The
new bank will not be operating as a commercial
bank prior to this merger.
Tennessee Valley Bancorporation, Inc., Nashville, Tenn., the bank holding company which will
acquire the resulting bank, is the fourth largest
multi-bank holding company in the State and presently controls two banks, Commerce Union Bank,
Nashville, which has deposits of $705 million, and

$42,758,868
120,000

To be
operated

3
0
3

42,762,468

Citizens Bank, Elizabethton, which has deposits of
$23.3 million.
There is no competition between the subsidiaries
of Tennessee Valley Bancorporation, Inc., and Old
& Third National Bank of Union City because a
large distance separates their closest two offices and
an adequate number of alternative banking facilities
operate in the intervening area. The nearest subsidiary of the holding company is the branch of Commerce Union Bank in Camden, 63 miles southeast
of Union City.
Consummation of the proposed merger will stimulate competition in Obion County because the resulting subsidiary in Union City will be able to offer
new and improved services such as equipment leasing, mortgage banking, international banking,
investment management, corporate trust services,
commercial data processing, and 24-hour electronic
tellers. In addition, the resulting bank will have
access to the extensive management training and
recruitment program of Tennessee Valley Bancorporation, Inc. Consummation of the proposed merger
will not significantly affect the size of Tennessee
Valley Bancorporation, Inc., in relation to that of the
other multi-bank holding companies in the State.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
APRIL 9,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

139

REPUBLIC NATIONAL BANK OF DALLAS, DALLAS, TEX., AND ERVAY BANK, NATIONAL ASSOCIATION,
DALLAS, TEX.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Republic National Bank of Dallas, Dallas, Tex. (12186), with
and Ervay Bank, National Association, Dallas, Tex. (12186), which had
merged May 9, 1974, under charter of the latter bank (12186) and title "Republic National Bank
of Dallas." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 25, 1974, Ervay Bank, National
Association (organizing), Dallas, Tex., and Republic
National Bank of Dallas, Dallas, Tex., applied to the
Comptroller of the Currency for permission to merge
under the charter of the former and with the title of
the latter.
Republic National Bank of Dallas, the existing
bank, was organized in 1920 and presently operates
as a unit bank with total assets of $2.4 billion and
IPC deposits of $1.3 billion. The existing bank is
currently the largest bank in Texas.
Ervay Bank, the new bank, is being organized to
provide a vehicle by which to transfer ownership of
the existing bank to Republic of Texas Corporation,
Dallas, Tex., which will become a one-bank holding
company upon its acquisition of the resulting bank.
Ervay Bank, National Association, will not be operating as a commercial bank prior to this merger.
Because Republic National Bank of Dallas is the
only operating bank involved in the proposed trans-

$2,862,368,727
248,444

To be
operated

1
0

2,862,376,077

action, there can be no adverse effect on competition resulting from consummation of the proposed
merger. The resulting bank will conduct the same
business, at the same location and with the same
name as presently used by Republic National Bank
of Dallas.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
APRIL 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF N E W BEDFORD, N E W BEDFORD, MASS., AND SECOND NATIONAL BANK OF
N E W BEDFORD, N E W BEDFORD, MASS.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of New Bedford, New Bedford, Mass. (261), with
and Second National Bank of New Bedford, New Bedford, Mass. (261), which had
merged May 10, 1974, under charter of the latter bank (261) and title "The First National Bank
of New Bedford." The merged bank at date of merger had

COMPTROLLER S DECISION

On January 2, 1974, The First National Bank of
New Bedford, New Bedford, Mass., and Second
National Bank of New Bedford (organizing), New
Bedford, Mass., applied to the Comptroller of the

140

$75,629,994
240,000
75,637,193

To be
operated

6
0
6

Currency for permission to merge under the charter
of the latter and with the title of the former.
The First National Bank of New Bedford, the
existing bank, was organized in 1832 and presently
operates five branches with total assets of $73.4
million and IPC deposits of $51.4 million. The pri-

mary service area of the existing bank encompasses
the towns of New Bedford and Dartmouth along with
their immediately surrounding areas in southeastern
Bristol County.
Direct competition for the existing bank is provided by New Bedford Institute for Savings, New
Bedford, with deposits of $220 million; New Bedford
Five Cents Savings Bank, New Bedford, with deposits of $151 million; Fairhaven Savings Bank, Fairhaven, with deposits of $93 million; B.M.C. Durfee
Trust Company, Fall River, with deposits of $63
million; The Merchants National Bank of New Bedford, with deposits of $51.7 million; and Southeastern Bank and Trust Company, New Bedford, with
deposits of $42.2 million.
Second National Bank of New Bedford is being
organized to provide a vehicle by which to transfer
ownership of The First National Bank of New Bedford to First Melville Bancorp, Inc., New Bedford,
Mass., which will become a one-bank holding company upon its acquisition of the resulting bank.
Second National Bank of New Bedford will not be
operating as a commercial bank prior to this merger.

Because The First National Bank of New Bedford
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 existing
bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
APRIL 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE UNION NATIONAL BANK AND TRUST COMPANY OF MARQUETTE, MARQUETTE, MICH., AND
UNB

NATIONAL BANK, MARQUETTE, MICH.

Banking offices

Total assets

Name of bank and type of transaction

To be

operation operated
The Union National Bank and Trust Company of Marquette, Marquette, Mich. (12027), with . .
and UNB National Bank, Marquette, Mich. (12027), which had
merged May 20, 1974, under charter of the latter bank (12027) and title "The Union National
Bank and Trust Company of Marquette." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 1, 1973, The Union National Bank
and Trust Company of Marquette, Marquette,
Mich., and UNB National Bank (organizing), Marquette, Mich., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
The Union National Bank and Trust Company of
Marquette, the merging bank, was organized in 1921
and now operates three branch offices. It possesses
total assets of $39.7 million and IPC deposits of
$27.9 million. The merging bank experiences its
major competition from the only other bank located
in Marquette, The First National Bank and Trust
Company, which has deposits of $57.8 million and

$44,992,581
120,000
44,992,581

4
0

is a member of Michigan National Bank and Trust
Company.
UNB National Bank, the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to Northern States
Bancorporation, Inc., a bank holding company. The
charter bank will not be operating as a commercial
bank prior to this merger.
Northern States Bancorporation, Inc., is the
multi-bank holding company which now controls
City National Bank of Detroit, with deposits of
$768.7 million, and Bank of Lansing, with deposits
of $150.5 million. In addition, it has received approval to acquire First National Bank of Lake City,
with deposits of $20 million, and has applications
pending to acquire three other banks. Northern

141

States Bancorporation, Inc., and its subsidiaries
have total assets of $1.1 billion.
Competition between the merging bank and the
subsidiaries of Northern States Bancorporation,
Inc., is nonexistent since they operate in different
sections of Michigan. Affiliation with Northern
States Bancorporation, Inc., will allow the resulting
bank to offer improved and expanded services, such
as a larger lending limit through increased capital
funds, international services, and improved managerial resources.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse com-

petitive effects. This application is, therefore,
approved.
APRIL 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

BALDWIN NATIONAL BANK OF ROBERTSDALE, ROBERTSDALE, ALA., AND GULF COAST NATIONAL BANK OF
ROBERTSDALE, ROBERTSDALE, ALA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Baldwin National Bank of Robertsdale, Robertsdale, Ala. (15402), with
and Gulf Coast National Bank of Robertsdale, Robertsdale, Ala. (15402), which had
merged May 31, 1974, under charter of the latter bank (15402) and title "Baldwin National Bank
of Robertsdale." The merged bank at date of merger had

COMPTROLLER S DECISION

On November 14, 1973, Baldwin National Bank of
Robertsdale, Robertsdale, Ala., and Gulf Coast
National Bank of Robertsdale (organizing), Robertsdale, Ala., applied to the Comptroller of the Currency for permission to merge under the charter of
the latter and with the title of the former.
Baldwin National Bank of Robertsdale, Robertsdale, Ala., the merging bank, was converted from
the former State-chartered Central Baldwin Bank
of Robertsdale in 1964 and now, with total deposits
of $8.7 million, operates two branches, one each in
the towns of Fairhope and Loxley. The bank's
service area is a section of south-central Baldwin
County extending from Mobile Bay on the west of
the Florida State line on the east and a distance of
some 7 miles north and 11 miles south of Robertsdale, to include the towns of Daphne, Fairhope,
Foley, and Loxley. The service area, with a population estimated at 25,000, has a moderately growing
economy based primarily on agriculture and to a
lesser degree on tourism and light industry.
Competition for Baldwin National Bank of Robertsdale is provided by the $22.8 million-deposit

142

$11,168,649
60,000
11,289,219

To be
operated

3
0
3

First National Bank of Fairhope; the $15.9 milliondeposit Farmers and Merchants Bank, Foley; the
$15.1 million-deposit Baldwin County Bank, Bay
Minette; the $13.7 million-deposit First National
Bank of Bay Minette; and the $11.1 million-deposit
South Baldwin Bank, Foley.
Gulf Coast National Bank of Robertsdale, the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to Alabama Bancorporation, Inc., Birmingham,
Ala., a registered bank holding company. The charter bank will not be operating as a commercial bank
prior to consummation of the proposed transaction.
Alabama Bancorporation, Inc., Birmingham, Ala.,
the bank holding company which will acquire the
resulting bank, was incorporated in 1970 and now,
controlling eight banks with aggregate deposits of
$1.1 billion, it is the largest multi-bank holding company in the State. The principal subsidiary of the
holding company is The First National Bank of
Birmingham, with deposits of approximately $806
million.
There is no significant competition between the
merging bank and the subsidiaries of Alabama Bancorporation, Inc., because 17 miles separate their

closest offices and because Mobile Bay, which is in
the intervening distance, constitutes an effective
geographic barrier.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with the holding company will allow the resulting
subsidiary to compete more effectively with the
larger banks in its service area because it will be
able to offer a wider range of more sophisticated
banking services to the residents and businesses
located therein.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competi-

tive effects. This application is, therefore, approved.
FEBRUARY 5,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

DELAWARE VALLEY NATIONAL BANK, CHERRY HILL, N.J., AND NEW JERSEY NATIONAL BANK - SOUTH,
CHERRY HILL, N.J.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Delaware Valley National Bank, Cherry Hill, N.J. (14975), with
and New Jersey National Bank - South, Cherry Hill, N.J. (14975), which had
merged May 31, 1974, under charter of the latter bank (14975) and title "New Jersey National
Bank - Delaware Valley." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 4, 1974, Delaware Valley National
Bank, Cherry Hill, N.J., and New Jersey National
Bank - South (organizing), Cherry Hill, N.J., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title "New Jersey National Bank - Delaware Valley."
Delaware Valley National Bank, the merging
bank, was chartered in 1961 and now operates one
branch office. With total assets of $23.2 million and
IPC deposits of $19.2 million, it ranks 120th in
deposit size among the 176 banks in New Jersey.
The service area of this bank encompasses Cherry
Hill Township, a residential suburban community
with a population of 67,000.
Competitors for the merging bank include banks
located in Philadelphia and Camden and, also,
South Jersey National Bank, a member of Heritage
Bancorporation; and United Jersey National Bank of
Cherry Hill, with deposits of $8.1 million, a member
of United Jersey Banks.
New Jersey National Bank - South, the charter
bank, is being organized to provide a vehicle by
which to transfer ownership of the merging bank to

$22,544,003
247,438
22,791,440

To be
operated

2
0
2

New Jersey National Corporation, Trenton, N.J. The
charter bank will not be operating as a commercial
bank prior to consummation of the proposed transaction.
New Jersey National Corporation, the registered
bank holding company that will acquire the resulting
bank, was chartered in 1971 and now has two banking subsidiaries. New Jersey National Bank, Trenton, its lead subsidiary, has deposits of $652 million.
Competition between the merging bank and the
existing subsidiaries of New Jersey National Corporation is minimal as their closest offices are separated by a distance of approximately 32 miles and
the intervening area contains more than 40 offices of
other banks.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
affiliation with New Jersey National Corporation will
allow the resulting bank to utilize the services, facilities, management skills, and experience of the holding company's subsidiaries thus making it a stronger
competitive institution.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competi-

143

tive effects. The application, therefore, is approved.
MAY 1, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which Delaware Valley National Bank would become

a subsidiary of New Jersey National Corporation, a
bank holding company. The instant merger, however, would merely combine an existing bank with a
non-operating institution; as such, and without
regard to the acquisition of the surviving bank by
New Jersey National Corporation, it would have no
effect on competition.

FIRST SAFETY FUND NATIONAL BANK, FITCHBURG, MASS., AND MONTACHUSETT NATIONAL BANK,
FITCHBURG, MASS.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

First Safety Fund National Bank, Fitchburg, Mass. (2153), with
and Montachusett National Bank, Fitchburg, Mass. (2153), which had
merged June 4, 1974, under charter of the latter bank (2153) and title "First Safety Fund National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On November 21, 1973, Montachusett National
Bank (organizing), Fitchburg, Mass., and First
Safety Fund National Bank, Fitchburg, Mass.,
applied to the Comptroller of the Currency for permission to merge under the charter of the former and
with the title of the latter.
First Safety Fund National Bank, the existing
bank, was organized in 1874 and now operates five
branches serving Worcester County with assets of
$55 million and IPC deposits of $37.2 million.
Montachusett National Bank is being organized to
provide a vehicle by which to transfer total ownership of First Safety Fund National Bank to The
Safety Fund Corporation. The new bank will not be
operating as a commercial bank prior to this merger.
Because First Safety Fund National Bank is the
only operating bank involved in the proposed transaction, there can be no adverse effect on competi-

144

$54,663,070
120,000

To be
operated

6
0

57,414,272

tion 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 existing bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
MAY 3, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

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

COLONIAL FIRST NATIONAL BANK, RED BANK, N.J., AND NEW COLONIAL FIRST NATIONAL BANK,
RED BANK, N.J.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Colonial First National Bank, Red Bank, N.J. (2257), with
and New Colonial First National Bank, Red Bank, N.J. (2257), which had
merged June 28, 1974, under charter of the latter bank (2257) and title "Colonial First National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 26, 1973, Colonial First National
Bank, Red Bank, N.J., and New Colonial First National Bank (organizing), Red Bank, N.J., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
Colonial First National Bank, the merging bank,
was chartered in 1875, and now operates 18 branch
offices and has received approval to open four additional branches. It has total assets of $325.7 million
and IPC deposits of $256 million. The service area
of the bank encompasses Monmouth County and a
small section of northeastern Mercer County.
Competitors of the merging bank include The
Central Jersey Bank and Trust Company, with
deposits of $360 million; First Merchants National
Bank, with deposits of $197 million; Peoples National Bank of Monmouth County, with deposits of
$57 million, a member of United Jersey Banks; and
First National State Bank of the Jersey Coast, with
deposits of $31 million, a member of First National
State Bancorporation.
New Colonial First National Bank, the charter
bank, is being organized to provide a vehicle by
which to transfer ownership of the merging bank to
Fidelity Union Bancorporation, Newark, N.J. The
charter bank will not be operating as a commercial
bank prior to consummation of the proposed transaction.
Fidelity Union Bancorporation, the registered
bank holding company that will acquire the resulting
bank, has assets of $1.1 billion and deposits of $1
billion. It wholly owns four subsidiary banks and
owns 21 percent of the Latin American Bank,
located in Costa Rica. Its lead subsidiary, Fidelity
Union Trust Company, with deposits of $727.7
million, has an investment in Allied Bank International.
Competitors of Fidelity Union Trust Company

$319,943,314
125,000

To be
operated

18
0

319,943,314

include The Howard Savings Bank, with deposits of
$1.3 billion; First National State Bank of New
Jersey, with deposits of $943 million, a member of
First National State Bancorporation; and Midlantic
National Bank, with deposits of $809.2 million, an
affiliate of Midlantic Banks Inc.
Competition between the merging bank and the
subsidiaries of Fidelity Union Bancorporation is
minimal. While the closest subsidiary of Fidelity
Union Bancorporation, the Spotswood office of The
National Bank of New Jersey, is located only 8 miles
from the merging bank, neither bank generates a
significant volume of loans from the service area of
the other.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather, the
affiliation of the resulting bank with Fidelity Union
Bancorporation will enhance competition because
improved and expanded services will be offered,
such as the availability of funds for larger loans,
expertise in trust services, computer services, an
international department, credit cards, overdraft
banking, and a more competitive rate on time
deposits.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MAY 29, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

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

145

GLEN NATIONAL BANK AND TRUST COMPANY, WATKINS GLEN, N.Y., AND BANK OF WATKINS GLEN,
NATIONAL ASSOCIATION, WATKINS GLEN, N.Y.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
Glen National Bank and Trust Company, Watkins Glen, N.Y. (9977), with
and Bank of Watkins Glen, National Association, Watkins Glen, N.Y. (9977), which had
merged June 28, 1974, under charter of the latter bank (9977) and title "Glen National Bank
and Trust Company." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 9, 1973, Bank of Watkins Glen, National Association (organizing), Watkins Glen, N.Y.,
and Glen National Bank and Trust Company, Watkins Glen, N.Y., applied to the Comptroller of the
Currency for permission to merge under the charter
of the former and with the title of the latter.
Glen National Bank and Trust Company, the
existing bank, was organized in 1911 and now operates one branch office. It has assets of $16.4 million and IPC deposits of $13.1 million. The service
area of the bank includes the village of Watkins
Glen and all of Schuyler County which has an estimated population of 18,000. The economy of the
service area is dependent mainly upon the tourism
generated by international auto racing events which
take place there, dairy farming, and the manufacture of salt, crane equipment, and lumber products.
Competition for Glen National Bank and Trust
Company, which is ranked 19th in size among the 33
banks headquartered in New York's Seventh Banking District, is provided by Marine Midland BankSouthern, Elmira, with deposits of $295 million;
Finger Lakes National Bank, Odessa, with deposits
of $8 million; and Montour National Bank in Montour
Falls, with deposits of $7 million.
Bank of Watkins Glen, National Association, the
new bank, is being organized to provide a vehicle by
which to transfer ownership of Glen National Bank
and Trust Company to Security New York State
Corporation. The new bank will not be operating as
a commercial bank prior to this merger.
Security New York State Corporation, the bank
holding company which will acquire the resulting
bank, was organized in 1966 and now ranks 13th in
size among the 15 multi-bank holding companies
located in New York State. The holding company

146

$17,425,365
60,000

To be
operated

2
0

17,485,364

now owns eight banking subsidiaries in upstate New
York, the largest of which is Security Trust Company, Rochester, with deposits of $438.4 million.
There is minimal competition between the subsidiaries of Security New York State Corporation and
Glen National Bank and Trust Company because
their two closest offices are separated by a distance
of 21 miles and an adequate number of alternative
banking facilities operate in the intervening distances.
Consummation of the proposed merger will both
stimulate competition in Schuyler County and further economic development in the area because the
resulting subsidiary in Watkins Glen will be able to
offer new and improved services such as an increased lending limit, credit cards, cash reserve
checking, payroll service and salary deposit plans,
equipment leasing, and expanded trust services.
Acquisition of the existing bank by Security New
York State Corporation would also remove head
office protection in Watkins Glen and open that
community to de novo branching by other banks.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
MAY 6, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF EASTHAMPTON, EASTHAMPTON, MASS., AND EASTHAMPTON BANK
(NATIONAL ASSOCIATION), EASTHAMPTON MASS.
Banking offices
Name of bank and type of transaction

Total assets

The First National Bank of Easthampton, Easthampton, Mass. (428), with
and Easthampton Bank (National Association), Easthampton, Mass. (428), which had
merged June 28, 1974, under charter of the latter bank (428) and title "The First National Bank
of Easthampton." The merged bank at date of merger had

COMPTROLLER S DECISION

On February 28, 1974, The First National Bank of
Easthampton, Easthampton, Mass., and Easthampton Bank (National Association) (organizing), Easthampton, Mass., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
The First National Bank of Easthampton, the
merging bank, was organized in 1864 and operates
as a unit institution. It has total assets of $11.4 million and IPC deposits of $8 million. Easthampton,
which has a population of 13,018, and its neighboring
communities comprise the service area of the bank.
The major competitor of the merging bank is Easthampton Savings Bank with deposits of $60.2 million.
Easthampton Bank (National Association), the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to Baystate Corporation, Boston, Mass. The charter
bank will not be operating as a commercial bank
prior to consummation of the proposed transaction.
Baystate Corporation, Boston, Mass., the registered bank holding company which will acquire the
resulting bank, controls 10 banking subsidiaries. It
has total consolidated assets of $1.7 billion and total
deposits of $1.4 billion. Norfolk County Trust Company, Brookline, its lead subsidiary, has deposits of
$286.7 million.
Competitors for Baystate Corporation include the
larger Boston banks and also Cambridge Savings
Bank, with deposits of $262.9 million; Third National
Bank of Hampden County, with deposits of $210.8
million; Brookline Savings Bank, with deposits of
$133.8 million; and Waltham Savings Bank, with

$12,412,230
120,000

In
To be
operation operated
1
0
1

12,532,230

deposits of $102.2 million.
Competition between the merging bank and the
existing subsidiaries of Baystate Corporation is insignificant. Even though one existing subsidiary,
Valley Bank and Trust Company, Springfield, has a
number of banking offices located 8 to 22 miles from
the proposed subsidiary, only a limited amount of
competition exists between them.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
application of Baystate Corporation will allow the
resulting subsidiary to expand its service area to
enhance competition, and will allow it to offer new
and improved services such as a drive-up and
walk-up teller facility, credit card services, a larger
lending capacity through loan participations, and
expertise in accounts receivable and inventory
financing, auditing, real estate, and commercial and
installment lending.
Applying the statutory criteria, it is concluded
that the proposed transaction is in the public interest
and will result in no adverse competitive effects.
This application is, therefore, approved.
MAY 29, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

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

147

THE FIRST NATIONAL BANK OF CRANBURY, CRANBURY, N J., AND MIDLANTIC NATIONAL BANK/CRANBURY,
CRANBURY,

N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Cranbury, Cranbury, N.J. (3168), with
and Midlantic National Bank/Cranbury, Cranbury, N.J. (3168), which had
merged June 30, 1974, under charter of the latter bank (3168) and title "The First National Bank
of Cranbury." The merged bank at date of merger had

COMPTROLLER'S DECISION

On January 2, 1974, The First National Bank of
Cranbury, Cranbury, N.J., and Midlantic National
Bank/Cranbury (organizing), Cranbury, 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 Cranbury, Cranbury,
N.J., the merging bank, was organized in 1884 and
now has total assets of $43 million and IPC deposits
of $33.8 million. It operates two branch offices, and
has received approval to open a third branch. The
service area of the merging bank encompasses the
southern third of Middlesex County, a small portion
of northern Monmouth County, and most of Mercer
County.
Competitors of the merging bank include The
National Bank of Jersey, New Brunswick, which has
deposits of $178 million and is a member of Fidelity
Union Bancorporation; First Charter National Bank,
which has deposits of $129 million and is a member
of Heritage Bancorporation; and The Edison Bank,
National Association, South Plainfield, which has
deposits of $75 million and is a member of First
National State Bancorporation.
Midlantic National Bank/Cranbury, Cranbury,
N.J., the charter bank, is being organized to provide
a vehicle by which to transfer ownership of the
merging bank to Midlantic Banks, Inc., Newark,
N.J. It will not be operating as a commercial bank
prior to consummation of the proposed transaction.
Midlantic Banks, Inc., Newark, N.J., the corporation that will acquire the resulting bank, is the third
largest bank holding company in New Jersey. It
controls eight subsidiary banks with aggregate

148

$42,021,786
126,321

To be
operated

3
0

42,146,786

deposits of $1.4 billion. Midlantic National Bank,
Newark, with deposits of $809.2 million, is its lead
subsidiary.
Competitors for Midlantic Banks, Inc., include
First National State Bancorporation, with aggregate
deposits of $1.7 billion, and United Jersey Banks,
with aggregate deposits of $1.5 billion.
Competition between the merging bank and the
existing subsidiaries of Midlantic Banks, Inc., is
minimal because the closest existing subsidiary is
located approximately 14 miles from the merging
bank and each holds only nominal deposits from the
service area of the other.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
affiliation with Midlantic Banks, Inc., will allow the
resulting bank to offer improved and expanded
services in the areas of commercial loans, trust
services, automated services, international financing, and management support.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
MAY 31, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through
which The First National Bank of Cranbury would
become a subsidiary of Midlantic Banks 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 Midlantic
Banks Inc., it would have no effect on competition.

FIRST NATIONAL BANK & TRUST COMPANY IN ALTON, ALTON, I I I . , AND FIRST NATIONAL BANK & TRUST
COMPANY, ALTON, I I I .
Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank & Trust Company in Alton, Alton, 111. (13464), with
and First National Bank & Trust Company, Alton, 111. (13464), which had
merged July 1, 1974, under charter and title of the latter bank (13464). The merged bank at date
of merger had

COMPTROLLER S DECISION

On February 4, 1974, First National Bank & Trust
Company in Alton, Alton, 111., and First National
Bank & Trust Company (organizing), Alton, 111.,
applied to the Comptroller of the Currency for permission to merge under the charter and title of the
latter.
First National Bank & Trust Company in Alton,
the merging bank, is a unit institution located in
Alton. The bank has assets of $63.3 million and IPC
deposits of $51.9 million.
First National Bank & Trust Company, the charter
bank, is being organized as a vehicle by which to
transfer ownership of the merging bank to First
Illinois Bancshares, Wilmington, Del., which will
become a one-bank holding company upon its acquisition of the resulting bank. The charter bank will
not be operating as a commercial bank prior to the
merger.
Because the merging bank is the only operating
bank involved in the proposed transaction, there can

$68,012,524
122,017

To be
operated

1
0
1

68,134,540

be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will conduct the same banking business at
the same location presently used by the merging
bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
MAY 17, 1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

SEATTLE-FIRST NATIONAL BANK, SEATTLE, WASH., AND SEAFIRST NATIONAL BANK, SEATTLE, WASH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Seattle-First National Bank, Seattle, Wash. (11280), with
$3,804,266,937
240,000
and SeaFirst National Bank, Seattle, Wash. (11280), which had
merged July 1, 1974, under charter of the latter bank (11280) and title "Seattle-First National
Bank." The merged bank at date of merger had
3,804,277,833

COMPTROLLER S DECISION

On February 12, 1974, SeaFirst National Bank
(organizing), Seattle, Wash., and Seattle-First
National Bank, Seattle, Wash., applied to the Comptroller of the Currency for permission to merge
under the charter of the former and with the title of
the latter.

To be
operated

148
0

Seattle-First National Bank, the existing bank,
was organized in 1870 and now, with total assets of
$4 billion and IPC deposits of $2.6 billion, is the
largest bank in Washington. With 146 branches
Seattle-First National Bank serves the entire State
of Washington where it competes with five bank
branching systems ranging in size from $250 million
to $2 billion.

149

SeaFirst National Bank, the new bank, is being
organized to provide a vehicle by which to transfer
ownership of the existing bank to SeaFirst Corporation, Seattle, Wash., which will become a one-bank
holding company upon its acquisition of the resulting
bank. SeaFirst National Bank will not be operating
as a commercial bank prior to this merger.
Because Seattle-First National 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 existing bank.

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
MAY 16, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF MARYLAND, BALTIMORE, MD., AND CHARLES STREET NATIONAL BANK,
BALTIMORE, MD.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Maryland, Baltimore, Md. (1413), with
and Charles Street National Bank, Baltimore, Md. (1413), which had
merged July 8, 1974, under charter of the latter bank (1413) and title "The First National Bank
of Maryland." The merged bank at date of merger had

COMPTROLLER'S DECISION

On April 8, 1974, Charles Street National Bank
(organizing), Baltimore, Md., and The First National
Bank of Maryland, Baltimore, Md., applied to the
Comptroller of the Currency for permission to merge
under the charter of the former and with the title of
the latter.
The First National Bank of Baltimore, the existing
bank, was organized in 1806 and presently has total
assets of $1.1 billion and IPC deposits of $697 million. With 59 branches, the existing bank serves the
city of Baltimore and Anne Arundel, Baltimore, Harford, Howard, Montgomery, Washington, and
Wicomico counties. The economy of that area is
based upon a wide array of commercial and industrial activity.
Competition for The First National Bank of Maryland is provided by Maryland National Bank, Baltimore, with deposits of $1.3 billion; Equitable Trust
Bank, Baltimore, with deposits of $846 million,
which is a member of Equitable Bancorporation;
Suburban Trust Company, Hyattsville, with deposits
150

$1,051,922,932
252,802
1,070,965,761

To be
operated

63
0
63

of $684 million; Union Trust Company of Maryland,
Baltimore, with deposits of $611 million; Citizens
Bank and Trust Company of Maryland, Riverdale,
with deposits of $331 million; and Mercantile-Safe
Deposit & Trust Company, Baltimore, with deposits
of $244 million, which is a member of Mercantile
Bankshares Corporation.
Charles Street National Bank, the new bank, is
being organized to provide a vehicle by which to
transfer ownership of The First National Bank of
Maryland to First Maryland Bancorp, Baltimore,
Md., which will become a one-bank holding company upon its acquisition of the resulting bank.
Charles Street National Bank will not be operating
as a commercial bank prior to this merger.
Since The First National Bank of Maryland 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 First National
Bank of Maryland.

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
JUNE 6,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

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

THE CLEVELAND NATIONAL BANK, CLEVELAND, TENN., AND CLEVELAND INTERIM BANK,

N.A.,

CLEVELAND, TENN.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

The Cleveland National Bank, Cleveland, Tenn. (1666), with
and Cleveland Interim Bank, N.A., Cleveland, Tenn. (1666), which had
merged July 18, 1974, under charter of the latter bank (1666) and title "The Cleveland National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 19, 1974, The Cleveland National
Bank, Cleveland, Tenn., and Cleveland Interim
Bank, N.A. (organizing), Cleveland, Tenn., applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
The Cleveland National Bank, the existing bank,
was organized in 1867 and presently operates four
branches with total assets of $46.4 million and IPC
deposits of $37.2 million. The primary service area
of the existing bank encompasses all of Bradley
County which has a population of 51,000. The economy of that area is based on a wide array of industry.
Direct competition for The Cleveland National
Bank is provided by Merchants Bank, Cleveland,
which has deposits of $35.4 million and is a member
of Third National Corporation, and by Cleveland
Bank and Trust Company, Cleveland, which has
deposits of $31.1 million and has reached an agreement-in-principle to be acquired by First Tennessee
National Corporation. In addition, First Citizens
Bank of Cleveland has been issued a new charter
and will soon open.
Cleveland Interim Bank, N.A., the new bank, is
being organized to provide a vehicle by which to

$44,689,570
125,000
45,890,248

To be
operated

5
0
5

transfer ownership of The Cleveland National Bank
to First Amtenn Corporation, Nashville, Tenn. The
new bank will not be operating as a commercial bank
prior to this merger.
First Amtenn Corporation, the bank holding company which will acquire the resulting bank, is the
second largest multi-bank holding company in Tennessee and presently controls six banks with aggregate deposits of $904 million. Its lead bank is First
American National Bank of Nashville, with deposits of $786 million.
There is no competition between the subsidiaries
of First Amtenn Corporation and The Cleveland
National Bank because of the distance which separates their nearest two offices and the adequate
number of alternative banking facilities operating in
the intervening area. The nearest subsidiary of the
holding company is Volunteer-State Bank which is
located in Knoxville, 76 miles northeast of Cleveland.
Consummation of the proposed merger will stimulate competition in Bradley County because the
resulting subsidiary in Cleveland will be able to offer
new and improved services such as corporate trust
and investment management services, data processing services, accounts receivable financing, international banking, and leasing services. In addition,

151

the resulting bank will have access to First Amtenn
Corporation's managerial expertise and training program. Consummation of the proposed merger will
not significantly affect the size of First Amtenn
Corporation in relation to that of the other multibank holding companies in the State.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
JUNE 18,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

GUARANTY NATIONAL BANK AND TRUST OF CORPUS CHRISTI, CORPUS CHRISTI, TEX., AND GUARANTY
COMMERCE NATIONAL BANK, CORPUS CHRISTI, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Guaranty National Bank and Trust of Corpus Christi, Corpus Christi, Tex. (14988), with
and Guaranty Commerce National Bank, Corpus Christi, Tex. (14988), which had
merged July 26, 1974, under charter of the latter bank (14988) and title "Guaranty National Bank
& Trust of Corpus Christi." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 12, 1974, Guaranty National Bank
and Trust of Corpus Christi, Corpus Christi, Tex.,
and Guaranty Commerce National Bank (organizing), Corpus Christi, Tex., applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of "Guaranty National Bank & Trust of Corpus Christi."
Guaranty National Bank and Trust of Corpus
Christi, the merging bank, was organized in 1962
and operates as a unit institution. It has total assets
of $32 million and IPC deposits of $25.6 million. The
service area of the bank is the Corpus Christi
Standard Metropolitan Statistical Area which is
comprised of Nueces and San Patricio counties.
Competitors for the merging bank include Corpus
Christi State National Bank, which has deposits of
$193.3 million and is a subsidiary of Federated
Capital Corporation; Corpus Christi Bank and Trust,
which has deposits of $117 million and is a subsidiary
of First City Bancorporation of Texas, Inc.; and
Parkdale State Bank, which has deposits of $26.3
million and has received permission to become
affiliated with Frost Bank Corporation.
Guaranty Commerce National Bank, Corpus
Christi, Tex., the charter bank, is being organized
to provide a vehicle by which to transfer ownership
of the merging bank to Texas Commerce Banc152

$30,937,598
240,000
31,822,439

To be
operated

1
0
1

shares, Inc., Houston, Tex. The charter bank will
not be operating as a commercial bank prior to consummation of the proposed merger.
Texas Commerce Bancshares, Inc., the bank
holding company that will acquire the resulting
bank, controls 15 banking subsidiaries with aggregate deposits of $1.8 billion and is the fourth largest
bank holding company in Texas. The corporation
also has applications to acquire 10 additional banks
announced or pending. Texas Commerce Bank,
National Association, with deposits of $1.2 billion,
is its lead subsidiary.
Competitors of Texas Commerce Bank, National
Association, include First City National Bank of
Houston, which has deposits of $1.8 billion and is a
subsidiary of First City Bancorporation of Texas,
Inc.; Bank of the Southwest, National Association,
which has deposits of $774.5 million and is a member
of Southwest Bancshares, Inc.; and Houston Citizens Bank and Trust, which has deposits of $237
million. In addition, competition is provided by the
local banks operating in the service areas of Texas
Commerce Bancshares, Inc.'s remaining subsidiaries.
Direct competition between the merging bank and
the existing subsidiaries of Texas Commerce Bancshares, Inc., is nonexistent as their closest offices
are separated by a distance of approximately 210
miles and as Texas Commerce Bank, National Asso-

ciation, has been providing management assistance
to the merging bank.
Consummation of the proposed transaction will
result in no adverse competitive effects. Rather,
affiliation with Texas Commerce Bancshares, Inc.,
will allow the resulting bank to become a stronger
competitor by offering improved and expanded
services such as a larger lending capacity through
loan participation, large real estate financing, leasing services, accounting services to small businesses, a new oil and gas department, and expanded
trust and investment services.
Applying the statutory criteria, it is the view of
this Office that the proposed transaction is in the

public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JUNE 25,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE PROSPECT PARK NATIONAL BANK, WAYNE, N.J.,

AND FIRST PROSPECT PARK NATIONAL BANK,

WAYNE, N.J.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Prospect Park National Bank, Wayne, N.J. (12861), with
and First Prospect Park National Bank, Wayne, N.J. (12861), which had
merged Aug. 1, 1974, under charter of the latter bank (12861) and title "Prospect Park National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On February 25, 1974, The Prospect Park National Bank, Wayne, N.J., and First Prospect Park
National Bank (organizing), Wayne, N.J., applied to
the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title "Prospect Park National Bank."
The Prospect Park National Bank, the merging
bank, was organized in 1925 and now operates four
branch offices. It has total assets of $200.2 million
and IPC deposits of $167.2 million. The service area
of the bank encompasses the eastern sector of
Passaic county and a portion of western Bergen
County.
Competitors of the merging bank include National
Community Bank, Rutherford, with deposits of $610
million; New Jersey Bank (National Association),
Clifton, which has deposits of $598 million and is a
member of Greater Jersey Bancorporation; and First
National Bank of New Jersey, Totowa, which has
deposits of $452 million.
First Prospect Park National Bank, the charter
bank, is being organized to provide a vehicle by

$202,844,663
250,000
203,094,663

To be
operated

5
0
5

which to transfer ownership of the merging bank to
Bancshares of New Jersey, Moorestown, N.J. The
charter bank will not be operating as a commercial
bank prior to consummation of the proposed merger.
Bancshares of New Jersey, Moorestown, N.J., is
the registered bank holding company which will
acquire the resulting bank. It ranks 13th in deposit
size among the commercial banking corporations in
New Jersey. It operates one banking subsidiary, The
Bank of New Jersey, Camden, with deposits of $460
million.
Competitors of Bancshares of New Jersey include
United Jersey Banks, with aggregate deposits of
$1.4 billion; Midlantic Banks, Inc., with aggregate
deposits of $1.4 billion; and First National State
Bancorporation, with aggregate deposits of $1.4
billion.
Direct competition between the merging bank and
the subsidiary of Bancshares of New Jersey is nonexistent as their closest offices are separated by a
distance of approximately 100 miles and an adequate
number of banking alternatives operate in the intervening distance.
Consummation of the proposed transaction will

153

result in no adverse competitive effects. Affiliation
with Bancshares of New Jersey will allow the resulting bank to offer expanded and improved services
such as an automatic teller system, municipal bond
bidding, construction loans, consumer loans, computer services, and trust services.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JUNE 14,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

* * *
FIRST NATIONAL BANK OF HURST, HURST, TEX., AND HURST COMMERCE NATIONAL BANK, HURST, TEX.
Banking offices
Name of bank and type of transaction

Total assets
In
operation

First National Bank of Hurst, Hurst, Tex. (15072), with
and Hurst Commerce National Bank, Hurst, Tex. (15072), which had
merged Aug. 2, 1974, under charter of the latter bank (15072) and title "First National Bank of
Hurst." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 2, 1973, First National Bank of Hurst,
Hurst, Tex., and Hurst Commerce National Bank
(organizing), Hurst, Tex., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
First National Bank of Hurst, Hurst, Tex., the
merging bank was established in 1956 and operates
as a unit institution. With total assets of $31.1 million and IPC deposits of $22 million, it ranks 17th in
size among the 45 banks in the Fort Worth area. Its
service area encompasses a group of suburban cities
in northwest Tarrant County, which includes Hurst,
Bedford, Euless, Richland Hills, North Richland
Hills, Colleyville, and the extreme northeastern
portion of Fort Worth.
The major competitors of First National Bank of
Hurst include Northeast National Bank, Fort Worth,
with deposits of $34.3 million; First State Bank, Bedford, with deposits of $13.4 million; and First National Bank of Euless, with deposits of $11.7 million.
Hurst Commerce National Bank, Hurst, Tex., the
charter bank, is being organized to provide a vehicle
by which to transfer ownership of the merging bank
to Texas Commerce Bancshares, Inc., Houston,
Tex. It will not be operating as a commercial bank
prior to consummation of the proposed merger.
Texas Commerce Bancshares, Inc., Houston,
Tex., the organization that will acquire the resulting
154

$34,699,809
120,000
35,155,066

To be
operated

1
0
1

bank, is the fourth largest bank holding company in
Texas. It controls 15 banking subsidiaries with
aggregate deposits of $1.8 billion, and has applications pending or announced to acquire 10 additional
banks. Texas Commerce Bank, National Association, with deposits of $1.2 billion, is the applicant's
principal subsidiary.
Competitors of Texas Commerce Bancshares,
Inc.'s lead subsidiary include First City National
Bank of Houston, which has deposits of $1.8 billion
and is a subsidiary of First City Bancorporation of
Texas, Inc.; Bank of Southwest, National Association, which has deposits of $774.5 million and is a
member of Southwest Bancshares, Inc.; and Houston National Bank, which has deposits of $366.5
million. Additional competition is provided by the
banks operating in the service areas of the applicant's remaining subsidiaries.
Direct competition between First National Bank
of Hurst and the subsidiaries of Texas Commerce
Bancshares, Inc., is nonexistent since their closest
offices are separated by a distance of approximately
235 miles.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with a holding company will allow First National
Bank of Hurst to offer new and expanded services,
such as investment services, trust services, real
estate financing, and international banking.
Applying the statutory criteria, it is the opinion of

this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
JUNE 19, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

which First National Bank of Hurst would become a
subsidiary of Texas Commerce Bancshares, Inc., a
bank holding company. The instant merger, however, would merely combine an existing bank with
a non-operating institution; as such, and without
regard to the acquisition of the surviving bank by
Texas Commerce Bancshares, Inc., it would have no
effect on competition.

* * *
FIRST CITY NATIONAL BANK OF GADSDEN, GADSDEN, ALA., AND BANK OF GADSDEN, N.A., GADSDEN, ALA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
First City National Bank of Gadsden, Gadsden, Ala. (15481), with
and Bank of Gadsden, N.A., Gadsden, Ala. (15481), which had
merged Aug. 7, 1974, under charter of the latter bank (15481) and title "First City National Bank
of Gadsden." The merged bank at date of merger had

COMPTROLLER'S DECISION

On March 8, 1974, First City National Bank of
Gadsden, Gadsden, Ala., and Bank of Gadsden,
N.A. (organizing), Gadsden, Ala., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
First City National Bank of Gadsden, the merging
bank, was organized in 1965, and now has assets of
$40.2 million and IPC deposits of approximately $28
million. The bank operates no branches since
branch banking is not permitted in the county. The
economy of the service area of First City National
Bank of Gadsden is aided by the presence of the
Coosa River which provides the area with excellent
waterway transportation. By virtue of its location as
county seat of Etowah County, Gadsden serves as
a center of commerce, industry, and finance.
Competition for First City National Bank of Gadsden is provided by Alabama City Bank of Gadsden,
with deposits of $24.8 million; The American National Bank, Gadsden, with deposits of $40.7 million;
Central Bank of Alabama, N.A., with deposits of
$351.4 million; the Coosa Valley Bank, Gadsden,
with deposits of $9.1 million; and East Gadsden
Bank, Gadsden, with deposits of $15.8 million.
Bank of Gadsden, N.A., the new bank, is being
organized to provide a vehicle by which to transfer
ownership of First City National Bank of Gadsden to
First Alabama Bancshares, Inc. Bank of Gadsden,
N.A., will not be operating as a commercial bank
prior to this merger.

$39,865,899
240,000
39,873,099

To be
operated

1
0
1

First Alabama Bancshares, Inc., Birmingham,
Ala., the bank holding company which will acquire
the resulting bank, was organized in April 1971 and
is now the second largest banking organization in
Alabama and the second largest of the seven multibank holding companies in the State. The bank holding company, with aggregate deposits of $774.4
million, presently controls six banks located in
various cities throughout the State. The largest subsidiary bank is The First National Bank of Montgomery, Montgomery, Ala., with deposits of $280.3
million. The remaining five subsidiaries are located
in Birmingham, Huntsville, Dothan, Bay Minette,
and Tuscaloosa. This holding company also controls
two non-banking subsidiaries which sell credit life,
health, and accident insurance, and engage in the
leasing of personal property and business equipment.
There is no competition between the bank holding
company or its subsidiaries and First City National
Bank of Gadsden because large distances separate
their closest two offices and an adequate number of
alternative banking facilities operate in the intervening distances. The holding company's nearest
subsidiary is Exchange Security Bank, Birmingham,
located approximately 61 miles from Gadsden,
which operates in an area that is separate and
distinct from that served by the merging bank.
Consummation of the proposed transaction will
not adversely affect competition in Etowah County,
the primary service area of First City National Bank
of Gadsden. Affiliation of First City National Bank
of Gadsden with First Alabama Bancshares, Inc. will

155

enable the merging bank to increase the range of
banking services available to the customers in its
service area, particularly in the fields of lease financing, trust services, and corporate financing. In addition, approval of this transaction will provide First
National City Bank of Gadsden with the opportunity
to strengthen its internal operations and staff
through the expertise that would be available from
holding company. The bank's ability to satisfy large
lines of credit would also be expanded through its
ability to sell participations to the holding company's
other subsidiaries.
Applying the statutory criteria it is the conclusion
of this Office that the proposed merger is in the
public interest and will not result in any adverse

competitive effects. This application is, therefore,
approved.
JULY 8,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

LAFAYETTE NATIONAL BANK, LAFAYETTE, IND., AND TIPPECANOE NATIONAL BANK, LAFAYETTE, IND.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

On May 3, 1973, Lafayette National Bank, Lafayette, Ind., and Tippecanoe National Bank (organizing), Lafayette, Ind., applied to the Comptroller
of the Currency for permission to merge under the
charter of the latter and with the title of the former.
Lafayette National Bank, the existing bank, was
organized in 1934 and presently operates seven
branches through which it serves the city of Lafayette. It has total assets of $110 million and IPC
deposits of $85 million. The economy of the existing
bank's service area is based on a wide array of
industrial activity.
Competition for Lafayette National Bank is provided by Purdue National Bank of Lafayette, with
deposits of $105 million; Lafayette Bank and Trust,
with deposits of $53 million; and Lafayette Savings
Bank, with deposits of $42 million.
Tippecanoe National Bank, the new bank, is being
organized to provide a vehicle by which to transfer
ownership of Lafayette National Bank to Lafayette
National Corporation, Lafayette, Ind., which will
become a one-bank holding company upon its acquisition of the resulting bank. Tippecanoe National

156

119,487,343

;

COMPTROLLER'S DECISION

$119,363,743
123,600

COO

Lafayette National Bank, Lafayette, Ind. (14175), with
and Tippecanoe National Bank, Lafayette, Ind. (14175), which had
merged Aug. 19, 1974, under charter of the latter bank (14175) and title "Lafayette National
Bank." The merged bank at date of merger had

To be
operated

Bank will not be operating as a commercial bank
prior to this merger.
Since Lafayette National 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 Lafayette National Bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
JULY 2,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

FARMERS-FIRST NATIONAL BANK OF STEPHENVILLE, STEPHENVILLE, TEX., AND STEPHENVILLE NATIONAL
BANK, STEPHENVILLE, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Farmers-First National Bank of Stephenville, Stephenville, Tex. (12730), with
and Stephenville National Bank, Stephenville, Tex. (12730), which had
merged Aug. 26, 1974, under charter of the latter bank (12730) and title "Farmers-First National
Bank of Stephenville." The merged bank at date of merger had

COMPTROLLER'S DECISION

On January 29, 1974, Farmers-First National Bank
of Stephenville, Stephenville, Tex., and Stephenville
National Bank (organizing), Stephenville, Tex.,
applied to the Comptroller of the Currency for permission to merge under the charter of the latter and
with the title of the former.
Farmers-First National Bank of Stephenville, the
existing bank, was organized in 1906 and now has
total assets of $31.1 million and IPC deposits of
$23.5 million. The primary service area of the bank
consists of Stephenville and the surrounding area of
Erath County. The economy of that area is based on
agriculture and livestock production.
Direct competition for Farmers-First National
Bank of Stephenville is provided by Stephenville
Bank and Trust Company, Stephenville, with deposits of $14.5 million. Additional minor competition in
the outlying areas of Erath County is provided by
The Dublin National Bank, Dublin, with deposits of
$12.8 million; First National Bank, Hico, with
deposits of $5.7 million; Citizens State Bank, Somerville, with deposits of $6.5 million; First National
Bank of Granbury, with deposits of $8.7 million; and
Granbury State Bank, with deposits of $4.1 million.
Stephenville National Bank, is being organized to
provide a vehicle by which to transfer ownership of
Farmers-First National Bank of Stephenville to First
United Bancorporation, Inc., Fort Worth. The new
bank will not be operating as a commercial bank
prior to this merger.
First United Bancorporation, Inc., the bank holding company which will acquire the resulting bank,

$31,259,735
120,000

To be
operated

1
0

31,379,735

controls eight subsidiary banks, the largest of which
is The First National Bank of Fort Worth, with
deposits of $590 million.
There is no significant competition between the
subsidiaries of First United Bancorporation, Inc.,
and Farmers-First National Bank of Stephenville
because a large distance separates their two closest
offices and an adequate number of alternative banking facilities operate in the intervening area. The
nearest subsidiary of the holding company is Cleburne National Bank, located over 50 miles away.
Consummation of the proposed merger will stimulate competition in Stephenville because the resulting subsidiary bank will be able to offer new and
improved services to the community such as agricultural credit, long term real estate loans, educational
loans, trust services, letters of credit, and securities
appraisal, custody, and transfer.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
JULY 22,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

157

PLAZA NATIONAL BANK, SECAUCUS, N.J.,

AND SECOND PLAZA NATIONAL BANK, SECAUCUS,

NJ.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Plaza National Bank, Secaucus, N.J. (15228), with
and Second Plaza National Bank, Secaucus, N.J. (15228), which had
merged Aug. 30, 1974, under charter of the latter bank (15228) and title "Plaza National Bank.
The merged bank at date of merger had

COMPTROLLER'S DECISION

On May 3, 1974, Plaza National Bank, Secaucus, N.J., and Second Plaza National Bank (organizing), Secaucus, N.J., applied to the Comptroller of
the Currency for permission to merge under the
charter of the latter and with the title of "Plaza
National Bank."
The Plaza National Bank, the merging bank, was
established in January 1964, and presently operates
three offices in Hudson County. The head office and
one branch are located in Secaucus, the second
branch is in West New York, N.J. The bank's primary service area includes the communities of
Secaucus, West New York, and Union City.
On June 30, 1973, the Plaza National Bank,
with $28.6 million in total assets and $23.5 million in
IPC deposits, ranked eighth among the 11 commercial banks headquartered in Hudson County. Competition is provided by The First Jersey National
Bank, Jersey City, with deposits of $447 million,
which is a member of First Jersey National Corporation, a registered bank holding company with total
deposits of $447 million; The Trust Company of New
Jersey, Jersey City, with deposits of $233 million,
which is a member of Wilshire Oil Company of
Texas, a registered bank holding company with
deposits of $233 million; Commercial Trust Company of New Jersey, Jersey City, with deposits of
$224 million; Hudson United Bank, Union City, with
deposits of $166 million; The First National Bank
and Trust Company of Kearny, with deposits of $59
million; Meadowlands National Bank, North Bergen,
with deposits of $34 million; Broadway National
Bank of Bayonne, with deposits of $25 million; and
Garden State National Bank, Hackensack, with
deposits of $426 million, which is a member of
Warner Communications, Inc., a registered bank
holding company with deposits of $426 million. In
addition, Arcadia National Bank opened for business
in Secaucus on January 25, 1974. Arcadia is an affiliate of National Community Bank of Rutherford,
which holds deposits of $610 million.

158

To be
operated

$28,612,000
120,000
27,341,608

Second Plaza National Bank, the charter bank,
was organized in December 1973 to provide a vehicle
by which to transfer ownership of the merging bank
to the Greater Jersey Bancorp., a registered bank
holding company. The charter bank will not be
operating prior to this merger. The effect of the proposed merger on competition must be measured with
regard to the two existing banking subsidiaries of
Greater Jersey Bancorp.
Greater Jersey Bancorp., Clifton, N.J., the bank
holding company which will acquire the resulting
bank, was organized by its lead subsidiary bank,
New Jersey Bank (National Association), Clifton, in
April 1972. Provident Bank of New Jersey, Willingboro, with deposits of $40 million, is the only other
bank presently owned by Greater Jersey Bancorp.
On December 31, 1973, with $711 million in deposits, it ranked sixth in size among the 20 registered
bank holding companies in New Jersey. The larger
holding companies are First National State Bancorporation, with nine member banks and total deposits
of $1.7 billion; United Jersey Banks, with 17 member
banks and total deposits of $1.4 billion; Midlantic
Banks, Inc., with eight member banks and total
deposits of $1.4 billion; Fidelity Union Bancorporation, with four member banks and total deposits of
$1 billion; and Heritage Bancorporation, with three
member banks and total deposits of $814 million.
Acquisition of Plaza National Bank would result in
Greater Jersey Bancorp, holding $735 million in
deposits and continuing as the sixth largest holding
company in the State.
Competition between the Plaza National Bank
and either subsidiary of Greater Jersey Bancorp, is
insignificant. The closest offices are approximately
4 miles apart and are separated by densely populated communities with numerous banking alternatives.
Consummation of the proposed merger will result
in no adverse competitive effects. Affiliation with
the applicant will allow the proposed subsidiary to
compete more effectively with the larger banks
located in its service area by offering improved and

expanded services such as trust and data processing
services, an international banking department, line
of credit checking, and automated teller machines.
In addition, the physical facilities of the proposed
subsidiary will be improved.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
JULY 23,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE ATHENS NATIONAL BANK, ATHENS, OHIO, AND THE
ATHENS, OHIO

F.B.G.

NATIONAL BANK OF ATHENS,

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Athens National Bank, Athens, Ohio (7744), with
and The F.B.G. National Bank of Athens, Athens, Ohio (7744), which had
merged Sept. 16, 1974, under charter of the latter bank (7744) and title "The Athens National
Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On July 11, 1974, The Athens National Bank,
Athens, Ohio, and The F.B.G. National Bank of
Athens (organizing), Athens, 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 Athens National Bank, the existing bank, was
organized in 1905 and now operates four branch
offices with total assets of $47.9 million and IPC
deposits of $32.8 million. It ranks as the largest bank
among the eight banks in Athens County, its service
area. The Athens National Bank is now owned by
United Dairy Farmers Investment Company, a registered bank holding company which has agreed to
divest itself of ownership of the bank by 1981.
Competitors of The Athens National Bank include
Peoples Bank in Nelsonville, with deposits of $16.7
million; Hockins Valley Bank of Athens Company,
with deposits of $15 million; and First National Bank
of Nelsonville, with deposits of $6.5 million.
The F.B.G. National Bank of Athens, the charter
bank, is being organized to provide a vehicle by
which to transfer ownership of the merging bank to
First Bane Group of Ohio, Inc., Columbus, Ohio, a
registered bank holding company. The charter bank
will not be operating as a commercial bank prior to
this merger.

$47,557,941
120,000

To be
operated

5
0

47,767,192

First Bane Group of Ohio, Inc., is the fifth largest
bank holding company in Ohio, controlling 14 banking subsidiaries with aggregate deposits of $1 billion.
That holding company has an application pending to
acquire a bank in Sidney and has also announced
plans to acquire a bank in Toledo.
Among competitors of the applicant are BancOhio
Corporation, with total deposits of $2.3 billion; Centran Corporation, with total deposits of $1.6 billion;
and Union Commerce Corporation, with total
deposits of $1.1 billion.
Direct competition between the proposed subsidiary and the existing subsidiaries of the applicant is
insignificant since their closest offices are separated
by a distance of approximately 70 miles.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with the applicant will allow the resulting bank to
offer improved and expanded services in such areas
as commercial and educational lending, trust services, and international services.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and the application is, therefore, approved.
AUGUST 15,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

159

which The Athens National Bank would become a
subsidiary of First Bane Group of Ohio, Inc., a bank
holding company. The instant merger, however,
would merely combine an existing bank with a non-

operating institution; as such, and without regard to
the acquisition of the surviving bank by First Bane
Group of Ohio, Inc., it would have no effect on
competition.

THE CITIZENS BAUGHMAN NATIONAL BANK, SIDNEY, OHIO, AND THE C.B.

NATIONAL BANK OF SIDNEY,

SIDNEY, OHIO

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Citizens Baughman National Bank, Sidney, Ohio (7862), with
and The C.B. National Bank of Sidney, Sidney, Ohio (7862), which had
merged Sept. 30,1974, under charter of the latter bank (7862) and title "The Citizens Baughman
National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On March 26, 1974, The Citizens Baughman
National Bank, Sidney, Ohio, and The C.B. National
Bank of Sidney (organizing), Sidney, Ohio, applied
to the Comptroller of the Currency for permission to
merge under the charter of the latter and the title of
the former.
The Citizens Baughman National Bank, the existing bank, was organized in 1870 and now has assets
of $46.6 million and IPC deposits of $33.9 million. It
has six offices in Shelby County, a rural area with an
estimated population of 40,500, and is the largest of
four banks headquartered in the county.
The C.B. National Bank of Sidney, the charter
bank, is being organized to provide a vehicle by
which to transfer ownership of the existing bank to
First Bane Group of Ohio, Inc., a multi-bank holding
company. The charter bank will not be operating as
a commercial bank prior to this merger.
First Bane Group of Ohio, Inc., the sixth largest
of 12 multi-bank holding companies in Ohio, controls
14 banks with $948 million in deposits. The subsidiary closest to the existing bank is located 10 miles
away in Auglaize County. There is no existing competition between those banks due to the lack of

160

$48,629,073
120,000

To be
operated

6
0

48,629,073

major social orientation or economic links between
the communities in which the two banks are located,
and the projected growth patterns of those counties
are not expected to create new links.
Consummation of the proposed transaction will
result in no adverse competitive effects. The resulting bank will conduct the same banking business at
the same location and with the same name as presently used by the existing bank.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and is,
therefore, approved.
AUGUST 7,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF EVART, EVART, MICH., AND EVART BANK, N.A.,

EVART, MICH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
$8,766,912
60,000

The First National Bank of Evart, Evart, Mich. (12561), with
and Evart Bank, N.A., Evart, Mich. (12561), which had
merged Oct. 10, 1974, under charter of the latter bank (12561) and title "The First National
Bank of Evart." The merged bank at date of merger had

COMPTROLLER S DECISION

On May 13, 1974, The First National Bank of
Evart, Evart, Mich., and Evart Bank, N.A. (organizing), Evart, Mich., applied to the Comptroller of the
Currency for permission to merge under the charter
of the latter and with the title of the former.
The First National Bank of Evart, the merging
bank, was organized in 1924 and operates as a unit
institution. It has total assets of $7.4 million and IPC
deposits of $6 million. Evart and the surrounding
area comprise the service area of the merging bank.
Its competitors include Central Michigan Bank and
Trust Company, Barryton, with deposits of $28.4
million; Mid-Michigan Bank, Farwell, with deposits
of $26.8 million; The Reed City State Bank, Reed
City, with deposits of $12.8 million; and LakeOsceola State Bank, Tustin, with deposits of $10.9
million.
Evart Bank, N.A., the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to West Michigan
Financial Corporation, Cadillac, Mich. The charter
bank will not be operating as a commercial bank
prior to consummation of the proposed transaction.
West Michigan Financial Corporation is the bank
holding company that will acquire the resulting
bank. It was organized in 1973 and controls one
banking subsidiary, The Cadillac State Bank, Cadillac, with deposits of $81.2 million. Competitors for
this subsidiary include First National Bank of Lake
City, with deposits of $19.9 million, and First National Bank of Cadillac, with deposits of $17 million.

To be
operated

1
0
1

8,749,913

Direct competition between the merging bank and
the subsidiary of West Michigan Financial Corporation is minimal since their closest offices are separated by a distance of 19 miles.
Consummation of the proposed transaction will
result in no adverse competitive effects. Affiliation
with West Michigan Financial Corporation will allow
the resulting bank to become a stronger competitor
by offering a wider range of more sophisticated
banking services, such as free checking account
plans, larger commercial and industrial loans
through participations, trust services, higher interest rates on time and savings deposits, commercial
data processing, physical improvements, and extended banking hours.
Applying the statutory criteria, it is the opinion of
this Office that the proposed transaction is in the
public interest and will result in no adverse competitive effects. This application is, therefore, approved.
SEPTEMBER 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

161

THE COLONIAL-AMERICAN NATIONAL BANK OF ROANOKE, ROANOKE, VA., AND COLONIAL BANK,

N.A.,

ROANOKE, VA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Colonial-American National Bank of Roanoke, Roanoke, Va. (11817), with
and Colonial Bank, N.A., Roanoke, Va. (11817), which had
merged Oct. 31, 1974, under charter of the latter bank (11817) and title "Colonial-American
National Bank." The merged bank at date of merger had

COMPTROLLER'S DECISION

On August 15, 1974, The Colonial-American National Bank of Roanoke, Roanoke, Va., and Colonial
Bank, N.A. (organizing), Roanoke, Va., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title
"Colonial-American National Bank," with its main
office in Roanoke County, Va.
The Colonial-American National Bank of Roanoke, the merging bank, is headquartered in
Roanoke, Va., and has 11 branch offices located
throughout Roanoke County. The bank, with total
assets of $148.5 million and IPC deposits of $113.6
million, was chartered originally in 1929.
Colonial Bank, N.A., the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to Colonial-American
Bankshares Corporation, Roanoke, Va., which will
become a registered one-bank holding company
upon acquisition of the resulting bank. The charter
bank will not be operating as a commercial bank
prior to this merger.
Because the merging bank is the only operating

$166,217,889
238,500

To be
operated

11
0

166,236,629

bank involved in the proposed transaction, there can
be no adverse effect on competition resulting from
consummation of the proposed merger. The resulting bank will conduct the same banking business at
the same locations as presently used by the merging
bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
SEPTEMBER 30,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK IN CLEBURNE, CLEBURNE, TEX., AND JOHNSON COUNTY NATIONAL BANK,
CLEBURNE, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank in Cleburne, Cleburne, Tex. (13107), with
and Johnson County National Bank, Cleburne, Tex. (13107), which had
merged Nov. 1, 1974, under charter of the latter bank (13107) and title "The First National
Bank in Cleburne." The merged bank at date of merger had

COMPTROLLER'S DECISION

On July 15, 1974, The First National Bank in
Cleburne, Cleburne, Tex., and Johnson County
National Bank (organizing), Cleburne, Tex., applied

162

$35,545,084
125,000
35,670,084

To be
operated

1
0

to the Comptroller of the Currency for permission to
merge under the charter of the latter and with the
title of the former.
The First National Bank in Cleburne, the existing
bank, was organized in 1927 and operates as a unit

institution. It has total assets of $32.4 million and
IPC deposits of $28.6 million. The service area of
First National Bank in Cleburne is Johnson County
where its competitors include Cleburne National
Bank which has deposits of $17.5 million and is a
member of First United Bancorporation, Inc.; First
State Bank, Rio Vista, which has deposits of $20
million; and Farmers and Merchants State Bank,
Burleson, which has deposits of $11 million.
Johnson County National Bank, the new bank, is
being organized to provide a vehicle by which to
transfer ownership of the existing bank to First
International Bancshares, Inc., Dallas, Tex., a registered bank holding company. The new bank will not
be operating as a commercial bank prior to this
merger.
First International Bancshares, Inc., is the largest
bank holding company in Texas, controlling 16 banking subsidiaries with aggregate deposits of $2.6
billion. It has applied for approval to acquire five
additional banks. First National Bank in Dallas, with
deposits of $2.4 billion, is its lead subsidiary.
Competitors for First National Bank in Dallas
include Republic National Bank of Dallas, with
deposits of $3 billion; Mercantile National Bank of
Dallas, with deposits of $746 million; and National

Bank of Commerce, with deposits of $296 million.
Competition between the existing bank and subsidiaries of First United Bancorporation, Inc., is
minimal since their closest offices are 49 miles apart.
Thus, consummation of the proposed transaction
will result in no adverse competitive effects. The
merger will allow The First National Bank in Cleburne to offer new and expanded services such as a
larger lending capacity, trust department services,
investment counseling, and international services.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
OCTOBER 2,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

PHENIX NATIONAL BANK, PHENIX CITY, ALA., AND BANK OF PHENIX, N.A.,

PHENIX CITY, ALA.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
Phenix National Bank, Phenix City, Ala. (15053), with
and Bank of Phenix, N.A., Phenix City, Ala. (15053), which had
merged Nov. 14, 1974, under charter of the latter bank (15053) and title "Phenix National
Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 4, 1974, the Phenix National Bank,
Phenix City, Ala., and the Bank of Phenix, N.A.
(organizing), Phenix City, Ala., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
Phenix National Bank, the merging bank, was
organized in 1963 and now has IPC deposits of $12
million. The service area of the bank is metropolitan
Phenix City, Ala., and Columbus, Ga., as well as the
remaining parts of Russell County and the southeast
tip of Lee County.

$16,302,578
120,000
16,306,178

To be
operated

3
0
3

Primary competitors of Phenix National Bank
include Columbus Bank and Trust Co., with deposits
of $141 million; First National Bank of Columbus,
with deposits of $138 million; Fourth National Bank
of Columbus, with deposits of $65 million; Trust
Company of Georgia, with deposits of $26 million;
Farmers and Merchants Bank of Russell County,
Phenix City, with deposits of $17 million; First Bank
of Russell County, Phenix City, with deposits of $2
million; and Phenix Girard Bank, with deposits of
$17 million.
Bank of Phenix, N.A., the charter bank, is being
organized to provide a vehicle by which to transfer
ownership of the merging bank to First Alabama

163

Bancshares, Inc., a registered bank holding company. The charter bank will not be operating prior to
the merger.
First Alabama Bancshares, Inc., Birmingham,
Ala., was organized in 1971 and now is the second
largest bank holding company in Alabama with
aggregate deposits of $900 million. It controls nine
banking subsidiaries located in various cities
throughout the State. Its largest subsidiary is The
First National Bank of Montgomery, Montgomery,
Ala., with deposits of $282 million. The remaining
subsidiaries are located in Birmingham, Huntsville,
Dothan, Bay Minette, Tuscaloosa, Selma, Athens,
and Guntersville. In addition, the holding company
has received approval to acquire banks in Hartselle
and Gadsden and has an additional application
pending to acquire a bank in Bayou La Batre.
Direct competition between Phenix National Bank
and the subsidiaries of First Alabama Bancshares,
Inc., is minimal since the closest subsidiary of the
holding company, First National Bank of Montgomery, is 80 miles west of Phenix City.
Consummation of the proposed transaction will

result in no adverse competitive effects. Affiliation
with the holding company will enable Phenix National Bank to offer an expanded range of services
such as lease financing, corporate financing, corporate trust, and money market operations. Affiliation
will also strengthen the bank's staff and internal
operations.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
OCTOBER 15,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

VIRGINIA NATIONAL BANK/FAIRFAX, SPRINGFIELD, VA., AND COMMUNITY BANK AND TRUST COMPANY,
SPRINGFIELD, VA.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Community Bank and Trust Company, Springfield, Va., with
and Virginia National Bank/Fairfax, Springfield, Va. (16398), which had
merged Nov. 18, 1974, under charter and title of the latter bank (16398). The merged bank at
date of merger had

COMPTROLLER S DECISION

On June 25, 1974, Community Bank and Trust
Company, Springfield, Va., and Virginia National
Bank/Fairfax (organizing), Springfield, Va., applied
to the Comptroller of the Currency for permission to
merge under the charter of and with the title of the
latter.
The Community Bank and Trust Company,
Springfield, Va., the merging bank, was organized
in 1970 and operates from a single office. With
assets of $5.7 million and IPC deposits of $3.7
million, the merging bank ranks as the smallest bank
in Fairfax County.
Competitors of the merging bank include Bank of
Virginia-Potomac, Falls Church, with deposits of
$147 million; Fairfax County National Bank, Seven
164

$6,686,779
240,000
6,926,779

To be
operated

1
0
1

Corners, with deposits of $46 million; Peoples Bank
and Trust Company of Fairfax, with deposits of $16
million; United Virginia Bank/First & Citizens
National, with deposits of $348 million; and Northern
Virginia Bank, with deposits of $96 million.
Virginia National Bank/Fairfax, the new bank, is
being organized to provide a vehicle by which to
transfer ownership of Community Bank and Trust
Company to Virginia National Bancshares, Incorporated. The new bank will not be operating as a commercial bank prior to this merger.
Virginia National Bancshares, Incorporated,
Norfolk, Va., a registered bank holding company, is
Virginia's second largest banking organization. The
holding company's subsidiary banks are Virginia
National Bank/Norfolk; Virginia National Bank/
Lynchburg; Virginia National Bank/Henry County,

Martinsville; and Virginia Trust Company, Richmond. Those affiliated banks have aggregate
deposits of $1.4 billion and operate 121 banking
offices.
Direct competition between the Community Bank
and Trust Company and the subsidiaries of Virginia
National Bancshares, Incorporated, is minimal as
the closest subsidiary, Virginia National Bank/Norfolk, has an office 6 miles north of the merging bank
in a highly competitive region.
Consummation of the proposed merger will stimulate competition in the Springfield service area
because the resulting bank will be able to offer new
and improved services to customers as a result of its
affiliation with Virginia National Bancshares,
Incorporated.

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
OCTOBER 16,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

CENTRAL BANK, NATIONAL ASSOCIATION, GRAND RAPIDS, MICH., AND C. BANK, NATIONAL ASSOCIATION,
GRAND RAPIDS, MICH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Central Bank, National Association, Grand Rapids, Mich. (16037), with
and C. Bank, National Association, Grand Rapids, Mich. (16037), which had
merged Dec. 9, 1974, under charter of the latter bank (16037) and title "Central Bank, National
Association." The merged bank at date of merger had

COMPTROLLER'S DECISION

On December 29, 1972, C. Bank, National Association (organizing), Grand Rapids, Mich., and Central Bank, National Association, Grand Rapids,
Mich., applied to the Comptroller of the Currency
for permission to merge under the charter of the
former and with the title of the latter.
Central Bank, National Association, the existing
bank, was organized in 1934 and now has deposits of
$43 million. At the present time, 22.4 percent of the
common stock of this bank is owned by Michigan
National Corporation and a majority of the remaining
shares are owned by persons closely associated with
that holding company. Competition for the bank is
provided by Old Kent Bank and Trust Company,
with deposits of $681 million; Union Bank and Trust
Company, National Association, with deposits of
$309 million; and an office of Michigan National
Bank, Lansing, which is a subsidiary of Michigan
National Corporation.

$49,500,402
240,000
49,740,402

To be
operated

9
0
9

C. Bank, National Association (organizing), the
new bank, is being organized to provide a vehicle by
which to transfer ownership of Central Bank, National Association, to Michigan National Corporation, Bloomfield Hills, Mich. C. Bank will not be
operating as a commercial bank prior to this merger.
Michigan National Corporation, the bank holding
company which will acquire the resulting bank, is
a recently organized corporation which controls
several subsidiary banks with aggregate assets of
$2.5 billion. All of those subsidiaries had been
closely associated through common stock ownership
prior to their acquisition by Michigan National Corporation. As already indicated, 22.4 percent of the
stock of Central Bank is now owned by Michigan
National Corporation and a majority of the remaining
shares are owned by persons closely associated with
that holding company. The proposed transaction is,
therefore, merely part of an internal corporate reorganization which will not adversely affect the
banking structure in Michigan.

165

Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and is, therefore, approved.
MAY 16, 1974.
SUMMARY OF REPORT BY ATTORNEY GENERAL

The proposed merger is part of a plan through

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

VALLEY NATIONAL BANK OF SAGINAW, SAGINAW, MICH., AND V. NATIONAL BANK, SAGINAW, MICH.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Valley National Bank of Saginaw, Saginaw, Mich. (15403), with
and V. National Bank, Saginaw, Mich. (15403), which had
merged Dec. 9, 1974, under charter of the latter bank (15403) and title "Valley National Bank of
Saginaw." The merged bank at date of merger had

COMPTROLLER'S DECISION

On October 28, 1973, Valley National Bank of
Saginaw, Saginaw, Mich., and V. National Bank
(organizing), Saginaw, Mich., applied to the Comptroller of the Currency for permission to merge under
the charter of the latter and with the title of the
former.
Valley National Bank of Saginaw, the existing
bank, was organized in 1959 and currently operates
five branch offices with total deposits of $43 million.
Direct competition for the bank is provided by
Second National Bank of Saginaw, with deposits of
$247 million; First State Bank of Saginaw, with
deposits of $15.9 million; and an office of Michigan
National Bank, Lansing.
V. National Bank, the new bank, is being organized to provide a vehicle by which to transfer
ownership of Valley National Bank of Saginaw to
Michigan National Corporation, Bloomfield Hills,
Mich. The new bank will not be operating as a commercial bank prior to this merger.
Michigan National Corporation, the bank holding
company which will acquire the resulting bank, is
headquartered in Bloomfield Hills and controls four
subsidiary banks with aggregate deposits of $2.5
billion. The principal subsidiary of the holding company is Michigan National Bank of Detroit, with

166

$54,197,141
240,000

To be
operated

6
0

54,437,141

deposits of $823 million. The remaining subsidiaries
of this holding company are located in the cities of
Livonia, Southfield, and Troy.
The existing bank is, at the present time, indirectly controlled by Michigan National Corporation which owns a significant amount of the outstanding stock of Valley National Bank of Saginaw. This
transaction is, therefore, merely part of an internal
corporate reorganization which will solidify the
operational relationship between Valley National
Bank of Saginaw and Michigan National Corporation
without altering the competitive banking structure
in Michigan.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
MAY

16, 1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

[This merger is a part] * * * of plans through
which the existing banks will become subsidiaries of
Michigan National Corporation. [It] * * *, however,
will merely combine an existing bank with a nonoperating institution and without regard to the acquisition of the surviving banks by Michigan National
Corporation, will have no effect on competition.

THE GOGEBIC NATIONAL BANK OF IRONWOOD, IRONWOOD, MICH., AND GNB NATIONAL BANK,
IRONWOOD, MICH.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The Gogebic National Bank of Ironwood, Ironwood, Mich. (9517), with
and GNB National Bank, Ironwood, Mich. (9517), which had
merged Dec. 13, 1974, under charter of the latter bank (9517) and title "Gogebic National
Bank." The merged bank at date of merger had

COMPTROLLER S DECISION

On July 15, 1974, The Gogebic National Bank of
Ironwood, Ironwood, Mich., and GNB National Bank
(organizing), Ironwood, Mich., applied to the Comptroller of the Currency for permission to merge
under the charter of the latter and with the title,
"Gogebic National Bank."
The Gogebic National Bank of Ironwood, Ironwood, Mich., the existing bank, was organized in
1909 and now has total deposits of $19 million. The
bank operates solely from its head office in Ironwood
and has an application pending to establish a branch
in the unincorporated village of Watersmeet, Mich.
The bank's principal competitor is First National
Bank of Ironwood, with deposits of $19 million.
Michigan Financial Corporation, Marquette, Mich.,
a registered bank holding company, with assets of
$150 million, has applied for permission to acquire
control of First National Bank of Ironwood. Additional competition in bank's service area is furnished
by the Bessemer National Bank, Bessemer, Mich.,
with deposits of $10 million, and The Iron Exchange
Bank, Hurley, Wis., with deposits of $9 million.
GNB National Bank, the new bank, is being organized to provide a vehicle by which to transfer
ownership of The Gogebic National Bank of Ironwood to First National Financial Corporation, Kalamazoo, Mich. The new bank will not be operating as
a commercial bank prior to this merger.
First National Financial Corporation, Kalamazoo,
Mich., the bank holding company which will acquire
the resulting bank, is the fourth largest bank holding
company in Michigan and controls nine banking
subsidiaries with aggregate deposits in excess of

$21,624,600
120,000

To be
operated

1
0

21,744,600

$450 million and total resources in excess of $505
million. First National Bank and Trust Company of
Michigan, Kalamazoo, Mich., its largest subsidiary,
has deposits of $321 million.
Direct competition between Gogebic National
Bank of Ironwood and the subsidiaries of the applicant is nonexistent since the nearest subsidiary of
the applicant is located 83 miles southeast of Ironwood, Mich., and over 30 miles from the location of
the bank's proposed branch.
Consummation of the proposed merger will stimulate competition in Ironwood because the resulting
subsidiary will expand the services it offers and will
become more effective in its competition with the
First National Bank of Ironwood. The proposed
transaction will enable the resulting subsidiary to
provide trust services, place overlines through the
holding company system, and offer improved and
more efficient banking services.
Applying the statutory criteria, it is concluded that
the proposed merger is in the public interest and
this application is, therefore, approved.
NOVEMBER 12,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

167

FIRST NATIONAL BANK OF IRONWOOD, IRONWOOD, MICH., AND THE SECOND NATIONAL BANK OF IRONWOOD,
IRONWOOD, MICH.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
First National Bank of Ironwood, Ironwood, Mich. (14456), with
and The Second National Bank of Ironwood, Ironwood, Mich. (14456), which had
merged Dec. 30, 1974, under charter of the latter bank (14456) and title "First National Bank of
Ironwood." The merged bank at date of merger had

COMPTROLLER S DECISION

On August 23, 1974, The Second National Bank of
Ironwood (organizing), Ironwood, Mich., and First
National Bank of Ironwood, Ironwood, Mich.,
applied to the Comptroller of the Currency for permission to merge under the charter of the former and
with the title of the latter.
First National Bank of Ironwood, the existing
bank, was organized in 1941 and presently operates
as a unit bank with total assets of $22 million and
IPC deposits of $18.4 million. It now has an application pending for a branch office in Ironwood. The
primary service area of the bank encompasses Ironwood and the surrounding area in the western portion of Michigan's upper peninsula. The principal
economic activity in the service area is winter
tourism.
Competition for First National Bank of Ironwood
is provided by Gogebic National Bank, Ironwood,
with deposits of $18.6 million; The Bessemer National Bank, Bessemer, with deposits of $10 million;
and The First National Bank, Wakefield, with
deposits of $7.5 million.
The Second National Bank of Ironwood, the new
bank, is being organized to provide a vehicle by
which to transfer ownership of the existing bank to
Michigan Financial Corporation, Marquette, Mich.
The new bank will not be operating as a commercial
bank prior to this merger.
Michigan Financial Corporation, the bank holding
company which will acquire the resulting bank, is
the 21st largest of the 38 bank holding companies in
Michigan. It presently controls six banks, with
aggregate deposits of $150 million.
There is no competition between Michigan Finan-

168

$23,732,247
125,000

To be
operated

1
0

23,294,692

cial Corporation or its subsidiaries and First National
Bank of Ironwood because of the great distance
between the banks. The nearest subsidiary of Michigan Financial Corporation, The Miners' First National Bank and Trust Company, is located in
Ishpeming, 130 miles east of Ironwood. Much of the
intervening land consists of public forests.
Consummation of the proposed merger will stimulate competition in Michigan's upper peninsula because the resulting subsidiary in Ironwood will be
able to offer new and improved services such as
trust services, business development loans, Master
Charge, minimum balance-no service charge checking accounts, and an increased rate of interest on
statement savings accounts. In addition, the acquisition of the resulting bank by Michigan Financial
Corporation will not significantly affect its size in
relation to the other bank holding companies in
Michigan.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
NOVEMBER 13,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

NATIONAL BANK OF COMMERCE OF PINE BLUFF, PINE BLUFF, ARK., AND JEFFERSON NATIONAL BANK,
PINE BLUFF, ARK.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
National Bank of Commerce of Pine Bluff, Pine Bluff, Ark. (14056), with
and Jefferson National Bank, Pine Bluff, Ark. (14056), which had
merged Dec. 31, 1974, under charter of the latter bank (14056) and title "National Bank of
Commerce of Pine Bluff." The merged bank at date of merger had

COMPTROLLER'S DECISION

On July 2, 1974, National Bank of Commerce of
Pine Bluff, Pine Bluff, Ark., and Jefferson National
Bank (organizing), Pine Bluff, Ark., applied to the
Comptroller of the Currency for permission to merge
under the charter of the latter and with the title of
the former.
National Bank of Commerce of Pine Bluff, the
existing bank, was organized in 1934 and presently
operates five branches. It has total assets of $97
million and IPC deposits of $68 million. The primary service area of the existing bank encompasses
all of Jefferson County. The economy of this service
area is supported by a mixture of light industry and
agriculturally related pursuits.
Competition for National Bank of Commerce of
Pine Bluff is provided by Simmons First National
Bank of Pine Bluff, with deposits of $131 million;
and Pine Bluff National Bank, Pine Bluff, with
deposits of $8.6 million.
Jefferson National Bank is being organized to
provide a vehicle by which to transfer ownership of
National Bank of Commerce of Pine Bluff to National Bancshares Corp., Pine Bluff, Ark., which
will become a one-bank holding company upon its
acquisition of the resulting bank. Jefferson National

$106,827,438
250,000

To be
operated

6
0
6

107,077,438

Bank will not be operating as a commercial bank
prior to this merger.
Because National Bank of Commerce of Pine
Bluff 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
existing bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
NOVEMBER 29,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

169

///. Additional Approvals
A. Approved, but abandoned, no litigation
THE FIRST NATIONAL BANK OF PARIS, PARIS, TEX., AND NEW NATIONAL BANK OF PARIS, PARIS, TEX.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of Paris, Paris, Tex. (3638), with
and New National Bank of Paris, Paris, Tex. (3638), which had
applied for permission to merge Oct. 24, 1973, under charter of the latter bank (3638) and title
"The First National Bank of Paris." The application was approved Jan. 15, 1974, but was
abandoned by the banks May 8, 1974

COMPTROLLER S DECISION

On October 24, 1973, New National Bank of
Paris (organizing), Paris, Tex., and First National
Bank of Paris, Paris, Tex., applied to the Comptroller of the Currency for permission to merge under
the charter of the former and with the title of the
latter.
First National Bank of Paris, the existing bank,
was organized in 1886 and has operated since that
time as a unit institution pursuant to State law. The
bank now has deposits of $32 million. The service
area of the bank consists of the whole of Lamar
County, which has an estimated population of 36,062
persons.
First National Bank of Paris is the largest of the
five banks headquartered in Lamar County. Principal competitors for the bank include Liberty National Bank, Paris, with deposits of $26 million, and
Citizens State Bank, Paris, with deposits of $13.6
million. Additional competition is provided by The
First National Bank, Deport, with deposits of $4.1
million, and First National Bank, Roxton, with
deposits of $1.1 million.
New National Bank of Paris, the new bank, is
being organized to provide a vehicle by which to
transfer ownership of First National Bank of Paris to
First City Bancorporation of Texas, Inc. The new
bank will not be operating as a commercial bank
prior to this merger.
First City Bancorporation of Texas, Inc., the bank
holding company which will acquire the resulting
bank, is the second largest bank holding company in
Texas and controls 25 banks with aggregate deposits
of $2.3 billion. The applicant's principal subsidiary
is First City National Bank of Houston, Houston,
Tex., with deposits of $1.5 billion.

170

$36,766,293
0

To be
operated

1
0

There is minimal competition between First City
Bancorporation of Texas, Inc., or its subsidiaries
and First National Bank of Paris because large distances separate their closest two offices and an
adequate number of alternative banking facilities
operate in the intervening area. The nearest office
of a subsidiary of the applicant is approximately 104
miles from Paris in Dallas, Tex.
Consummation of the proposed merger will stimulate competition in Lamar County because the
resulting subsidiary will be able to offer new and
improved services including greater depth and
expertise of management, an extensive business
development program, a broader loan policy, a
larger trust department, expanded credit investigation services, real estate loan and appraisal services,
and international banking services. The acquisition
of the resulting bank by First City Bancorporation of
Texas, Inc., will result in modernization of operational procedures which should be reflected in
increased profits for that bank.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest,
and this application is, therefore, approved.
JANUARY 15,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

THE FIRST NATIONAL BANK OF SAN ANGELO, SAN ANGELO, TEX., AND NEW NATIONAL BANK,
SAN ANGELO, TEX.
Banking offices
Total assets

Name of bank and type of transaction

In
operation
The First National Bank of San Angelo, San Angelo, Tex. (2767), with
and New National Bank, San Angelo, Tex. (2767), which had
applied for permission to merge Oct. 30, 1973, under charter of the latter bank (2767) and title
"The First National Bank of San Angelo." The application was approved Jan. 10, 1974, but was
abandoned by the banks May 8, 1974

COMPTROLLER'S DECISION

On October 30, 1973, New National Bank (organizing), San Angelo, Tex., and The First National Bank
of San Angelo, San Angelo, Tex., applied to the
Comptroller of the Currency for permission to merge
under the charter of the former and with the title of
the latter.
The First National Bank of San Angelo, the existing bank, was organized in 1882 and now has deposits of $50.5 million. The service area of the bank
consists of the whole of Tom Green County which
has an estimated population of 71,047 persons.
The First National Bank of San Angelo is the third
largest of five banks headquartered in its service
area. Competition for the bank is provided by San
Angelo National Bank, with deposits of $82.2 million, which is a subsidiary of Texas Commerce
Bancshares, Inc., Houston, the State's third largest
multi-bank holding company; The Central National
Bank of San Angelo, with deposits of $72 million;
West Side National Bank of San Angelo, with
deposits of $12.9 million; and Texas State Bank, San
Angelo, with deposits of $11.3 million.
New National Bank, the new bank, is being
organized to provide a vehicle by which to transfer
ownership of The First National Bank of San Angelo
to First City Bancorporation of Texas, Inc. The new
bank will not be operating as a commercial bank
prior to this merger.
First City Bancorporation of Texas, Inc., the bank
holding company which will acquire the resulting
bank, is the second largest bank holding company in
Texas and controls 25 banks with aggregate deposits
of $2.3 billion. The applicant's principal subsidiary
is First City National Bank of Houston, Houston,
Tex., with deposits of $1.5 billion.

$59,245,185
0

To be
operated

1
0

There is minimal competition between First City
Bancorporation of Texas, Inc., or its subsidiaries
and The First National Bank of San Angelo, because
large distances separate their closest two offices and
an adequate number of alternative banking facilities
operate in the intervening area. The nearest office
of a subsidiary of the applicant is approximately 110
miles from San Angelo in Midland, Tex.
Consummation of the proposed merger will stimulate competition in Tom Green County because the
resulting subsidiary will be able to offer new and
improved services including greater depth and
experience of management, an extensive business
development program, a broader loan policy, a
larger trust department, expanded credit investigation services, real estate loan and appraisal services,
and international banking services. The acquisition
of the resulting bank by First City Bancorporation of
Texas, Inc., will also help to alleviate a strained
capital situation at The First National Bank of San
Angelo.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest
and this application is, therefore, approved.
JANUARY 10,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

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

171

FIRST MISSISSIPPI NATIONAL BANK, HATTIESBURG, MISS., AND CITIZENS NATIONAL BANK, JACKSON, MISS.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
$161,540,607
Citizens National Bank, Jackson, Miss. (15516), with
38,404,720
and First Mississippi National Bank, Hattiesburg, Miss. (5176), which had
applied for permission to merge Aug. 5, 1974, under charter and title of the latter bank (5176).
The application was approved Sept. 24, 1974, but was abandoned by the banks Nov. 12, 1974

COMPTROLLER S DECISION

On August 5, 1974, Citizens National Bank, Jackson, Miss., and First Mississippi National Bank,
Hattiesburg, Miss., applied to the Comptroller of the
Currency for permission to merge under the charter
and the title of the latter.
First Mississippi National Bank, the charter bank,
was organized in 1899, and now has assets of $166.2
million and IPC deposits of $111.2 million. It operates 19 branch offices to serve those parts of Forrest,
Harrison, Jackson, Jefferson Davis, Lamar, and
Rankin counties within 100 miles of Hattiesburg.
The economy of that area is diversified, with manufacturing, seafood processing and agriculture.
The charter bank is the largest of the three banks
headquartered in Hattiesburg. The other two are
Citizens Bank of Hattiesburg, with $31.7 million in
deposits, and Southern National Bank of Hattiesburg, with deposits of $21.9 million. The service
area is also served by 24 other banking offices with
aggregate deposits of $1.8 billion.
Citizens National Bank, the merging bank, with
assets of $51.1 million and IPC deposits of $24.7
million operates six branches. It is the smallest of
the four banks headquartered in Jackson with competition provided by the $645.7 million deposit Deposit Guaranty National Bank, the $591.6 million
deposit First National Bank of Jackson and the $60.9
million deposit Mississippi Bank and Trust Company. Jackson is the financial, commercial, and industrial center of Mississippi.
There is little competition between the charter and
merging banks because of the distance separating
their service areas. First Mississippi National Bank
recently opened a de novo branch in Pearl, within
the service area of Citizens National Bank, but that
branch only held deposits as of June 30, 1974.
Consummation of the proposed merger will have
no adverse effect on competition. The resulting bank

172

To be
operated

7
18

will be in a better position to compete effectively in
the Jackson area, which the merging bank is presently unable to do because of management problems
and the small size of the bank. The two largest banks
have dominated the financial field in Jackson and the
proposed merger will give potential customers a
viable third choice.
Applying the statutory criteria, it is concluded
that the proposed merger is in the public interest and
this application is, therefore, approved.
SEPTEMBER 24,

1974.

SUMMARY OF REPORT BY ATTORNEY GENERAL

Applicant operates one branch office in close
proximity to Bank's main and branch offices. That
office, located in the Jackson SMSA in the community of Pearl, Rankin County, was opened in April
1974, and currently holds total deposits of less than
$1 million. Applicant's other offices are located 60
or more miles south of Bank's service area.
The Jackson Mississippi banking market is highly
concentrated, with the State's two largest banks eontrolling approximately 85 percent of total deposits
in the Jackson SMSA. Bank, with approximately
3.6 percent of SMSA deposits ranks fourth, while
Applicant's single office ranks 13th in the Jackson
SMSA with less than 1 percent of total deposits.
Thus, while the proposed merger may eliminate
some existing competition and the potential for increased competition between the parties in the Jackson area, concentration in commercial banking in
that market would not be substantially increased.
And in view of the relatively modest market position
of Bank in the Jackson market, it does not appear
that the proposed merger would eliminate substantial potential competition.
Therefore, we conclude that the proposed transaction would not have significantly adverse competitive effects.

B. Approved, but abandoned, due to litigation
THE MERCHANTS NATIONAL BANK OF BURLINGTON, BURLINGTON, V T . , AND MONTPELIER NATIONAL BANK,
MONTPELIER, VT.

Banking offices
Name of bank and type of transaction

Total assets
In
operation

Montpelier National Bank, Montpelier, Vt. (13915), with
and The Merchants National Bank of Burlington, Burlington, Vt. (1197), which had
applied for permission to merge June 29, 1973, under charter of the latter bank (1197) and title
"The Merchants National Bank of Burlington, Vermont." The application was approved Nov. 1,
1973. The pending merger was challenged by Justice Department Nov. 29, 1973, and was
abandoned by the banks July 9, 1974

$35,738,000
64,638,000

To be
operated

2
7

The "Comptroller's Decision" and "Summary of Report by Attorney General" for this case appeared in
the 1973 Annual Report under the heading "Approved, but in litigation."
*

THE CONNECTICUT NATIONAL BANK, BRIDGEPORT, CONN., AND THE FIRST NEW HAVEN NATIONAL BANK,
N E W HAVEN, CONN.

Banking offices
Total assets

Name of bank and type of transaction

In
operation
$398,313,449
315,269,949

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 approved July 26, 1971. The
pending consolidation was challenged by Justice Department Aug. 23, 1971, and was abandoned
by the banks Aug. 22, 1974

To be
operated

51
21

The "Comptroller's Decision" and "Summary of Report by Attorney General" for this case appeared in
the 1971 Annual Report under the heading "Approved, but in litigation."
*

THE NATIONAL BANK OF COMMERCE OF SEATTLE, SEATTLE, WASH., AND WASHINGTON TRUST BANK,
SPOKANE, WASH.

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 was abandoned by the banks Oct. 3, 1974

102,633,000
1,320,714,000

To be
operated

1
106

The "Comptroller's Decision" and "Summary of Report by Attorney General" for this case appeared in
the 1971 Annual Report under the heading "Approved, but in litigation."

173

APPENDIX B

Statistical Tables

Statistical Tables
Table
No.
B-l
B-2
B-3
B-4

Title
Page
Comptrollers of the Currency, 1863 to the present 177
Deputy Comptrollers of the Currency
178
Regional Administrators of National banks
178
Changes in the structure of the National Banking
System, by States, 1863-1974
179
B-5
Charters, liquidations, and changes in issued capital stock of National banks, calendar 1974
180
B-6
Applications for National bank charters, approved
and rejected, by States, calendar 1974
181
B-7
Applications for National bank charters, by States,
pursuant to corporate reorganizations, calendar
1974
183
B-8
Newly organized National banks, by States, calendar 1974
184
B-9
National bank charters issued and mergers consummated pursuant to corporate reorganizations,
by States, calendar 1974
187
B-10 State-chartered banks converted to National
banks, by States, calendar 1974
192
B - l l National bank charters issued pursuant to corporate reorganizations, by States, calendar 1974.. 193
B-12 National banks reported in voluntary liquidation,
by States, calendar 1974
194
B-13 National banks merged or consolidated with State
banks, by States, calendar 1974
195
B-14 National banks converted into State banks, by
States, calendar 1974
196
B-15 Purchases of State banks by National banks, by
States, calendar 1974
197
B-16 Consolidations of National banks, or National and
State banks, by States, calendar 1974
198
B-17 Mergers of National banks, or National and State
banks, by States, calendar 1974
199
B-18 Mergers resulting in National banks, by assets of
acquiring and acquired banks, 1960-1974
202
B-19 Domestic branches entering the National Banking
System, by de novo opening, merger, or conversion, by States, calendar 1974
202
B-20 Domestic branches of National banks closed, by
States, calendar 1974
214
B—21 Principal assets, liabilities, and capital accounts of
National banks, by deposit size, year-end 1973
and 1974
216
B-22 Dates of reports of condition of National banks,
1914-1974
217

176

Table
No.

Title

Total and principal assets of National banks, by
States, June 30, 1974
Total and principal liabilities of National banks, by
B-24
States, June 30, 1974
Capital accounts of National banks, by States, June
B-25
30, 1974
Total and principal assets of National banks, by
B-26
States, Dec. 31, 1974
Total and principal liabilities of National banks, by
B-27
States, Dec. 31, 1974
Capital accounts of National banks, by States, Dec.
B-28
31, 1974
B-29 Loans of National banks, by States, Dec. 31, 1974
B-30 Outstanding balances, credit cards and related
plans of National banks, Dec. 31, 1974
B-31 National banks engaged in direct lease financing,
Dec. 31, 1974
B-32 Income and expenses of National banks, by States,
year ended Dec. 31, 1974
B-33 Income and expenses of National banks, by deposit size, year ended Dec. 31, 1974
B-34 Capital accounts, net income, and dividends of
National banks, 1944-1974
B-35 Loan losses and recoveries of National banks,
1945-1974
B-36 Securities losses and recoveries of National banks,
1945-1974
Ratios of classified assets to total loans for National banks, deposit size category under $100
million
B-38 Ratios of classified assets to total loans for National banks, deposit size category $100 million
and over
B-n39 Assets and liabilities of National banks, date of last
report of condition, 1950-1974
B-40 Foreign branches of National banks, by region and
country, Dec. 31, 1974
B-41 Total assets of foreign branches of National banks,
year-end 1953-1974
B-42 Foreign branches of National banks, 1960-1974 . .
B—43 Assets and liabilities of foreign branches of National banks, Dec. 31, 1974: consolidated statement
Trust assets and income of National banks, by
States, calendar 1974

B-23

Page
219
220
221
222
223
224
225
226
227
228
242
244
245
245
246
246
247
248
249
249
249
250

TABLE

B-l

Comptrollers of the Currency, 1863 to the present
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

Name
McCulloch, Hugh
Clarke, Freeman
Hulburd, Hiland R . . .
Knox, John Jay
Cannon, Henry W
Trenholm, William L .,
Lacey, Edward S
Hepburn, A. Barton . . ,
Eckels, James H
Dawes, Charles G
Ridgely, William Barret
Murray, Lawrence O .
Williams, John Skelton,
Crissinger, D. R
Dawes, Henry M
Mclntosh, Joseph W . . ,
Pole, John W
O'Connor, J. F. T
Delano, Preston
Gidney, Ray M
Saxon, James J
Camp, William B
Smith, James E

Date of
appointment
May
Mar.
Feb.
Apr.
May
Apr.
May
Aug.
Apr.
Jan.
Oct.
Apr.
Feb.
Mar.
May
Dec.
Nov.
May
Oct.
Apr.
Nov.
Nov.
July

9,
21,
1,
25,
12,
20,
1,
2,
26,
1,
1,
27,
2,
17,
1,
20,
21,
11,
24,
16,
16,
16,
5,

1863
1865
1867
1872
1884
1886
1889
1892
1893
1898
1901
1908
1914
1921
1923
1924
1928
1933
1938
1953
1961
1966
1973

Date of
resignation
Mar. 8,
July 24,
Apr. 3,
Apr. 30,
Mar. 1,
Apr. 30,
June 30,
Apr. 25,
Dec. 31,
Sept. 30,
Mar. 28,
Apr. 27,
Mar. 2,
Apr. 30,
Dec. 17,
Nov. 20,
Sept. 20,
Apr. 16,
Feb. 15,
Nov. 15,
Nov. 15,
Mar. 23,

1865
1866
1872
1884
1886
1889
1892
1893
1897
1901
1908
1913
1921
1923
1924
1928
1932
1938
1953
1961
1966
1973

State
Indiana.
New York.
Ohio.
Minnesota.
Minnesota.
South Carolina.
Michigan.
New York.
Illinois.
Illinois.
Illinois.
New York.
Virginia.
Ohio.
Illinois.
Illinois.
Ohio.
California.
Massachusetts.
Ohio.
Illinois.
Texas.
South Dakota.

177

TABLE B-2

Deputy Comptrollers of the Currency
No.

Dates of tenure

Name

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47

May 9, 1863
Aug. 1, 1865
Mar. 12, 1867
Aug. 8, 1872
Jan. 5, 1886
Jan. 27, 1887
Aug. 11, 1890
Apr. 7, 1893
Mar. 12, 1 8 %
Sept. 1, 1898
June 29, 1899
July 1, 1908
May 21, 1923
July 1, 1923
Jan. 6, 1925
July 1, 1927
July 6, 1927
__.. 1,1928
Dec.
Jan. 24, 1933
Feb. 24, 1936
Jan. 16, 1938
Jan. 16, 1938
Oct. 1, 1938
May 1, 1939
July 7, 1941
Sept. 1, 1941
Oct. 1, 1944
Jan. 1, 1949
Sept. 1, 1950
Mar. 1, 1951
Feb. 18, 1952
Sept. 15, 1959
May 16, 1960
Apr. 2, 1962
Aug. 4, 1962
Sept. 3, 1962
Dec. 23, 1962
Jan. 1, 1963
July 13, 1964
Sept. 1, 1964
Sept. 1, 1964
July 19, 1965
July 1, 1966
Feb. 21, 1967
July 5, 1973
July 5, 1973
Feb. 2, 1975

Howard, Samuel T . . .
Hulburd, Hiland R . . .
Knox, John Jay
Langworthy, John S ..
Snyder, V. P
Abrahams, J. D
Nixon, R. M
Tucker, Oliver P
Coffin, George M
Murray, Lawrence O .
Kane, Thomas P
Fowler, Willis J
Mclntosh, Joseph W ..
Collins, Charles W . . .
Stearns, E. W
Await, F. G
Gough, E. H
Proctor, John L
Lyons, Gibbs
Prentiss, Jr., William .
Diggs, Marshall R
Oppegard, G. J
Upham, C. B
Mulroney, A. J
McCandless, R. B . . . .
Sedlacek, L. H
Robertson, J. L
Hudspeth, j . W
Jennings, L. A
Taylor, W. M
Garwood, G. W
Fleming, Chapman C .
Haggard, Holus S
Camp, William B
Redman, Clarence B . .
Watson, Justin T
Miller, Dean E
DeShazo, Thomas G ..
Egertson, R. Coleman
Blanc hard, Richard J .
Park, Radcliffe . . . . . . .
Faulstich, Albert J . . . .
Motter, David C
Gwin, John D
Howland, Jr., W. A . . .
Mullin, Robert A

Ream, Joseph M

State

Aug. 1, 1865
Jan. 31, 1867
Apr. 24, 1872
Jan. 3, 1886
Jan. 3, 1887
May 25, 1890
Mar. 16, 1893
Mar. 11, 1896
Aug. 31, 1898
June 27, 1899
Mar. 2, 1923
Feb. 14, 1927
Dec. 19, 1924
June 30, 1927
Nov. 30, 1928
Feb. 15, 1936
Oct. 16, 1941
Jan. 23, 1933
Jan. 15, 1938
Jan. 15, 1938
Sept. 30, 1938
Sept. 30, 1938
Dec. 31, 1948
Aug. 31, 1941
Mar. 1, 1951
Sept. 30, 1944
Feb. 17, 1952
Aug. 31, 1950
May 16, 1960
Apr. 1, 1962
Dec. 31, 1962
Aug. 31, 1962
Aug. 3, 1962
Nov. 15, 1966
Oct. 26, 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.
June 30, 1966 Iowa.
Massachusetts.
June 1, 1967 Wisconsin.
Oct. 26, 1974 Louisiana.
Ohio.
Mississippi.
Georgia.
Kansas.
Pennsylvania.

TABLE B-3

Regional Administrators of National banks
Region

Name

Headquarters

1 Charles H. Paterson . . . . . . . . . Boston, Mass

2 Charles M. Van Horn
3
4

R. Coleman Egertson
Larry T. Gerzema
5 John G. Hensel

6
7
8
9
10
11
12
13
14

178

Billy C. Wood
Charles B. Hall
John W. Schaffer, Jr
Donald B. Smith
John R. Burt
Michael Doman
John R. Thomas
M. B. Adams
H. Joe Selby

. . . . New York, N.Y
: Philadelphia, Pa
Cleveland, Ohio
Richmond, Va
Atlanta, Ga
Chicago, 111
Memphis, Tenn
Minneapolis, Minn
Kansas City, Mo
Dallas, Tex
Denver, Colo
Portland, Oreg
San Francisco, Calif

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

TABLE B-4

Changes in the structure of the National Banking System, by States, 1863-1974
Organized
and opened
for business 1863—
1974

Consolidated and merged
under 12 U.S.C. 215

12 U.S.C. 214
Insol-

Liquidated

Merged or
Converted to consolidated
State banks with State
banks

Merged

Consolidated

United States

16,423

727

802

2,825

6,761

243

357

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

229
8
33
172
619
283
141
32
41
371

4
0
1
21
5
11
0
8
2

23
0
0
3
55
4
9
0
0
2

45
0
6
39
67
58
7
1
7
43

64
2
21
55
397
86
69
18
13
42

0
0
1
0
4
3
5
0
0
0

0
1
1
0
20
0
16
8
0
0

214
8
113
1,000
455
568
463
250
127
131

8
1
0
20
14
4
6
11
4
8

4
0
2
14
8
2
4
2
2
10

42
0
35
227
98
206
77
37
16
13

87
4
65
299
205
243
198
110
53
79

9
1
2
18
5
12
7
8
0
0

0
0
3
2
4
2
0
2
0
1

159
398
396
523
104
346
212
416
18
91

3
44
11
8
6
13
4
2
1
4

18
25
28
0
4
12
1
3
0
11

17
28
77
116
16
58
76
83
4
5

69
208
157
193
36
148
76
199
8
23

1
1
1
4
3
4
0
8
0
1

11
14
5
0
0
1
0
0
1
0

502
98
1,062
168
264
746
788
154
1,301
70

56
1
127
8
3
33
12
2
112
3

82
1
113
23
0
40
9
4
117
2

60
25
131
44
100
112
85
31
211
2

154
37
442
58
118
336
454
103
495
58

1
0
13
0
0
2
35
0
14
0

27
0
82
9
0
6
0
6
102
0

138
224
238
1,447
51
85
307
248
217
309
82
1
2

8
14
9
45
4
3
23
19
11
9
0
0
0

14
3
14
56
2
7
58
10
0
1
0
0
0

43
93
36
142
6
17
28
51
38
54
12
0
0

49
81
94
574
23
29
74
144
68
116
26
0
1

2
2
8
57
3
3
4
0
0
1
0
0
0

4
0
2
4
2
9
11
1
0
0
0
0
0

Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina .
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina .
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia

Wisconsin
Wyoming
Virgin Island
Puerto Rico

,
,
,

In
operation
Dec. 31,
1974

179

TABLE

B-5

Charters, liquidations, and changes in issued capital stock of National banks, calendar 1974
Capital stock
Number of
banks
Increases:
Banks newly chartered:
Primary organization
Conversion of State banks
Capital stock:
Preferred: 1 case by new issue
Common:
545 cases by statutory sale
602 cases by statutory stock dividends
5 cases by statutory consolidation
29 cases by statutory merger
15 cases by conversion of preferred stock
32 cases by conversion of capital notes
Capital notes and debentures: 111 cases by new issue ..
Total increases
Decreases:
Banks ceasing operations:
Voluntary liquidations:
Succeeded by National banks
Succeeded by State banks
Statutory consolidations
Statutory mergers
Converted into State banks
Merged or consolidated into State banks
Insolvent
Capital stock:
Preferred: 32 Retired
Common:
7 cases by statutory reduction
2 cases by statutory consolidation
6 cases by statutory merger
Capital notes and debentures:
44 retirements
32 converted to common stock

152*
12

Common

Preferred

66,310,125
99,933,100

Capital notes
and debentures

95,755,000

$ 1,000,800
128,273,898
194,944,347
6,245,850
22,459,091
1,270,478
1,142,319
108,767,360
164

520,579,208

5
1
3

1,400,405
200,000

1,000,000

45,703,335
9,062,140
39,323,320

14,060,000

83t
19
13
1

1,000,800

17,711,900

204,522,360

28,500,000

3,085,760
1,787,998
599,825
2,380,140
42,557,984
4,025,560

125

100,457,163

20,797,660

90,143,544

+39

Total decreases
Net change
Charters in force Dec. 31, 1973, and issued capital

4,669

420,122,045
7,914,886,509

-19,796,860
33,189,560

114,378,816
2,378,059,050

Charters in force Dec. 31, 1974, and issued capital

4,708

8,335,008,554

13,392,700

2,492,437,866

* Includes 60 reorganized banks with capital stock of $7,524,000.
t Includes 61 reorganized banks.
NOTE: Premium on sale of common stock
Premium on sale of convertible notes
Total

180

$209,147,454 (533 cases)
$ 2,883,246 ( 32 cases)
$212,030,700 (565 cases)

TABLE B-6

Applications for National bank charters, approved and rejected, by States, calendar 1974
ALABAMA
Southern National Bank, Birmingham
Chatom
Tallassee

Approved Rejected
Oct. 17
Nov. 13
July 9

ALASKA

Security National Bank, Anchorage

July

ARKANSAS

North Little Rock

June 10

CALIFORNIA

Los Angeles
Los Angeles
Oxnard
Capistrano Valley National Bank, San Juan
Capistrano
San Leandro
South Coast National Bank, Santa Ana . . . .
El Capitan National Bank, Sonora
Azteca National Bank, Stockton

Mar. 25
Mar. 30
Dec. 31
Mar.

June
Oct.
Mar.

8
30
25

July 12

GEORGIA

COLORADO

Mountain National Bank of Aurora, Aurora
Gunbarrel National Bank, Unincorporated
area of Boulder County
Castle Rock National Bank, Castle Rock ..
Craig
United Bank of Monaco National Association, Denver
Boca Raton
Boca Raton
Coastal National Bank, Boynton Beach
Charlotte Harbor
Coral Springs National Bank, Coral Springs
Citizens First National Bank of Crystal
River, Crystal River
First American National Bank of Dania,
Dania
City National Bank of South Dade, Unincorporated area of South Dade
Pan American Bank of Kendale Lakes, National Association, Unincorporated area of
Dade County
Southeast National Bank of North Dade,
Unincorporated area of Dade County . . . .
Deerfield Beach
First National Bank of Destin, Destin
East Naples
Fort Myers
Fort Pierce
Hialeah
Jacksonville
Jacksonville
Barnett Bank Trust Company, National
Association, Jacksonville
Century National Bank, Jacksonville
Jupiter-Tequesta National Bank, Jupiter . . .
Second National Bank of Lakeland, Lakeland
Southern National Bank of Palm Beach
County, Florida, Lake Worth
Unincorporated area of Lee County
Unincorporated area of Lee County
Unincorporated area of Martin County
Marco Island
Southeast Banks Trust Company, National
Association, Miami
Okeechobee
Unincorporated area of Orange County
Orlando
Pembroke Pines
Unincorporated Area of Pinellas County

Jan.

June
Mar.

8
30

Approved Rejected
Mar. 25
Aug. 25
Jan. 27
Dec. 31
Sewall's Point National Bank, Sewall's Point Jan.
27
Southeast National Bank of Sweetwater,
Sweetwater
Mar. 25
Stuart
Jan. 27
Tamarac
Jan. 26
Tampa
Jan. 16
Citizens National Bank, Tampa
Jan.
16
Islands National Bank, Tampa
Jan.
16
Landmark National Bank of Tarpon Springs,
Tarpon Springs
Jan.
27
Venice
Oct. 30
Vero Beach National Bank, Vero Beach . . . Aug. 25
Flagler National Bank of the Palm Beaches,
West Palm Beach
Feb.
7
West Palm Beach
Feb. " 7
FLORIDA—Continued

Punta Gorda
St. Cloud
St. Petersburg
Sanford

The First National Bank of Chatsworth,
Chatsworth
Mar.
Clayton
First National Bank of Douglasville, Douglasville
Jan.

Jan. 27
Mar.

Mar.

Jan.

Mar.

Jan. 27
Nov. 13
Jan*. 26

Nov.

Mar.

June 10
Mar.

Dec. 30
Aug. 22
July 27
Feb. 9
Jan. 26
June 10

Jan.

June 8
June

June 8
Jan.
Mar.
Aug.

27
25
25

June

July

Feb.* 9

Harbor National Bank, Baltimore . . . .
County National Bank, Bethesda
Fidelity National Bank, Cockeysville .,
St. Charles

Mar.
Apr.
Dec.

4
13
3
23
Mar. 25

Jan.
National Bank of Dearborn, Dearborn
First National Bank of Plymouth, Plymouth June
Michigan National Bank of Macomb, Warren Sept.

26
8
28

MINNESOTA

Burnsville
National City Bank of Burnsville, Burnsville July

July 27
27

MISSISSIPPI

Jan.
Jan.
Dec.
Jan.
July

Buffalo Grove National Bank, Buffalo Grove
Chicago
Washington National Bank of Chicago,
Chicago
Galesburg
First National Bank of Lake Zurich, Lake
Zurich
First National Bank of Marengo, Marengo..
Northbrook National Bank, Northbrook
North Riverside
Butterfield National Bank, Wheaton
First National Bank of Wonder Lake,
Wonder Lake

MARYLAND

25
25
27

ILLINOIS

First National Bank of St. Charles Parish,
Boutte
April

Mar.
Sept.
July

Nov.'i3

LOUISIANA

Aug.
Jan.

26
26
12
27

Jan. 27
Aug. 6
Dec. 31
Mar. 30
June 8

Dec. 31
Mar. 30
Mar. 30

Brookhaven .
Starkville . . .
Tylertown ..
MISSOURI

First National Bank of Arnold, Arnold
Kansas City

Mar.

25
Jan. 27

NEBRASKA

Old Mill National Bank, Unincorporated area
of Douglas County
June

181

TABLE

B-6—Continued

Applications for National bank charters, approved and rejected, by States, calendar 1974
NEW JERSEY

Barnegat Bay National Bank, Brick
Princeton American National Bank, Dover
Evesham
The Montgomery National Bank, Township
of Montgomery
Lenape National Bank, Moorestown
Wildwood

Approved

May
Jan.

15
26
Jan. 27

Dec.
Mar.

31
1
Jan. 2

NEW MEXICO

Alamogordo
Plaza Del Sol National Bank, Albuquerque Jan.
Southeast National Bank, Albuquerque . . . . June
Deming
San Juan National Bank, Farmington
Dec.
Los Lunas
Silver City

Oct. 30
26
10
Oct. 30
12
Mar. 30
July 27

NEW YORK

Capital National Bank of New York, New
York
June
Alliance National Bank, New York
Mar.

July 2
OKLAHOMA

PUERTO RICO

Rio Grande

Oct. 30
SOUTH CAROLINA

Republic National Bank, Columbia
Mar.
Hilton Head National Bank, Hilton Head
Island
Apr.

30
19

TENNESSEE

TEXAS

182

8
8
8
8
June 8

June

July
Apr.
Apr.
May

27
27
27
15
Mar. 25
Mar. 25

Mar.

Mar. 30

Dec. 30
July 8
VIRGINIA

Bassett
First & Merchants National Bank of Fairfax,
Unincorporated area of Fairfax County . .
Gloucester
First & Merchants National Bank of Loudoun, Leesburg
Martinsville
First & Merchants National Bank of Prince
William, Unincorporated area of Prince
William County
The First National Bank of Rocky Mount,
Rocky Mount

June 8
Mar.

25
Aug. 19

Mar.

30
June 8

June

Mar.

Ben Franklin National Bank, Pasco
June
Jefferson National Bank, Port Townsend .. . Jan.

10
12

WASHINGTON

Third National Bank in Memphis, Memphis May
Alpine
Austin
Austin
Austin
Austin
National Bank of Commerce, Austin
United National Bank, Dallas
National Bank of Commerce, Edinburg
El Paso
First International Bank in El Paso, National
Association, El Paso
West Ten National Bank, El Paso
Summit National Bank, Fort Worth

June 8
June
June
June
June

Orem
Richfield

NORTH CAROLINA

Citizens National Bank of Lawton, Lawton Mar.

Houston
Colonial National Bank, Houston
Gulf Southern National Bank, Houston
National Standard Bank, Houston
Parkway National Bank, Houston
League City
First National Bank of League City, League
City
New Braunfels National Bank, New Braunfels
Continental National Bank, San Antonio . . .
Plaza National Bank, San Antonio
South Park National Bank, San Antonio . . .
Seven Points
Seven Points
Citizens National Bank of Temple, Temple
Waxahachie
Ellis National Bank, Waxahachie

Approved Rejected

UTAH

8
25

Rocky Mount

TEXAS—Continued

Rejected

Aug. 23
Dec. 31
Dec. 31
Dec. 31
Dec. 31
Dec.
Apr.
July

31
17
25
30
30
30

31
25

WISCONSIN

Ozaukee First National Bank, Cedarburg . . Aug.
First National Bank of Oregon, Oregon . . . . Mar.
Dec. 30

Dec.
Dec.
Mar.

WEST VIRGINIA

Gulf National Bank, Sophia
Dec.
First National Bank of Weston, Weston . . . . Nov.

19
30

WYOMING

Wyoming National Bank of Gillette, Gillette Mar.
Bank of Wyoming, National AssociationRock Springs, Rock Springs
Jan.

30
26

TABLE B-7

Applications for National bank charters, by States, pursuant to corporate reorganizations, calendar 1974
ALABAMA
Southland National Bank of Birmingham,
Birmingham
Southland National Bank of Fairhope, Fairhope
Shoals Bank, N.A., Florence
Bank of Gadsden, N.A., Gadsden
Southland National Bank of Mobile, Mobile
Bank of Phenix, N.A., Phenix City

Approved Rejected
Mar.

Mar.
5
June 27
Jan. 18
Mar.
5
May
6

ARKANSAS

Jefferson National Bank, Pine Bluff

Apr.

CALIFORNIA

SN National Bank, Walnut Creek

Dec.

ILLINOIS

FoPark National Bank, Village of Forest
Park
Melrose National Bank, Melrose Park
Second National Bank of Mount Prospect,
Village of Mount Prospect
Oak Brook National Bank, Village of Oak
Brook
HNB Bank, N.A., Pekin
INB National Bank, Springfield
Second National Bank of Springfield, Springfield

Nov. 12
July 19
Aug. 28
Dec.
Oct.
Oct.

5
21
2

July

KENTUCKY

FSNB National Bank and Trust Company,
Lexington
Dec.

MASSACHUSETTS

Fall River Bank, National Association, Fall
River
The Ipswich Bank, National Association,
Ipswich
The Blackstone Valley Bank, National Association, Town of Northbridge
Second National Bank of Cape Cod, Town
of Orleans
The Yarmouth Bank, National Association,
Yarmouth

June

Mar.

Apr.

Aug.

Mar.

MICHIGAN

C National Bank, Cassoplis
Sept.
National Bank of Howell, Howell
Jan.
GNB National Bank, Iron wood
May
The Second National Bank of Ironwood,
Ironwood
May
SWM National Bank, Niles
Feb.

26
12
14
23
19

MISSISSIPPI

Hattiesburg Bank, N.A., Hattiesburg

Jan.

NEW JERSEY

Second City National Bank of Salem, Salem Oct.

NEW YORK

American National Bank, New York
Aug.
First Seaway Bank, National Association,
Watertown
June

6
11

OHIO

Approved Rejected
Mar.
June
Aug.
Jan.
May

7
28
7
5
30

Mar.
May

12
24

Mercer County Interim Bank, N.A., Borough
of Greenville
Apr.

The F.B.G. National Bank of Athens, Athens
The Farmers National Bank, Canfield
The G. C. National Bank, Village of Chardon
The C. B. National Bank of Sidney, Sidney
The F. N. National Bank of Toledo, Toledo
OKLAHOMA

National Bank of Stillwater, Stillwater
Mingo Valley National Bank, Tulsa
PENNSYLVANIA

TEXAS

Commercial Bank National Association,
Brady
Johnson County National Bank, Cleburne . .
Casa Linda Commerce Bank National Association, Dallas
Fidelity Commerce Bank National Association, Dallas
Mercantile Bank, National Association,
Dallas
New Citizens National Bank of Dallas, Dallas
Northwest Commerce Bank National Association, Dallas
Royal Commerce Bank National Association,
Dallas
Village Commerce Bank National Association, Dallas
Circle National Bank of Fort Worth, Fort
Worth
Glenbrook & Avenue A National Bank, Garland
South Main & Richardson National Bank,
Henderson
Gulf Bank, National Association, Houston .
First Montgomery County National Bank,
Unincorporated area of Montgomery
County
Nassau Bank, National Association, Nassau
Bay
Rogers Street Bank, National Association,
San Antonio
Texarkana Bank, National Association,
Texarkana

Feb.
Apr.

19
18

May

Mar.
5
Sept. 13
May

May

Jan.

June

June
July

26
11

Nov.

June

Oct.

Sept. 25

VIRGINIA

Colonial Bank, N.A., Unincorporated area
Mar.
of Roanoke County
Feb.
Peoples Bank, N.A., Rocky Mount
Virginia National Bank/Fairfax, Springfield May

21
4
9

WEST VIRGINIA

Second Bank of Warwood, National AssociaJune
tion, Wheeling
Second Community Savings Bank, National
Association, Wheeling
June

19
19

WYOMING

Western National Bank at Casper, Casper

July

183

TABLE B-8

Newly organized National banks, by States, calendar 1974
Charter
No.

Title and location of bank

Total capital
accounts
$123,017,675

Total, United States: 92 banks
ALABAMA

16291 Citizens National Bank of Limestone County, Athens
16285 Eastern Shore National Bank, Daphne

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

Total: 2 banks
CALIFORNIA

1,000,000
1,500,000
1,300,000

16278 Citizen's National Bank, Hanford
16407 Far East National Bank, Los Angeles
16305 Mexican American National Bank, San Diego

3,800,000

Total: 3 banks
j

COLORADO

400,000

16392 Empire National Bank, Canon City
CONNECTICUT

2,500,000

16290 Citizen's National Bank of Fairfield, Fairfield
DISTRICT OF COLUMBIA

1,500,000

16338 Hemisphere National Bank, Washington
FLORIDA

16415
16293
16266
16321
16386
16401
16295
16367
16281
16276
16325
16399
16335
16268
16263
16292
16403
16391
16409

Broward National Bank of Boynton Beach, Boynton Beach
Southern National Bank of Broward County, Unincorporated area of Broward County
The National Bank of Cape Coral, Cape Coral
Clewiston National Bank, Clewiston
Florida Coast Bank of Coral Springs, National Association, Coral Springs
Southeast National Bank of North Dade, Unincorporated area of Dade County
Palmer Bank of Fort Myers, National Association, Fort Myers
Barnett Banks Trust Company, National Association, Jacksonville
The Exchange National Bank of Largo, Largo
Palmer Bank of Bradenton, National Association, Unincorporated area of Manatee County
Continental National Bank of Miami, Miami
Southeast Banks Trust Company, National Association, Miami
First National Bank of Moore Haven, Moore Haven
Palmer Bank and Trust Company of Naples, National Association, Naples
Panama City National Bank, Panama City
First National Bank of Sunrise, Sunrise
City National Bank, Tallahassee
Landmark Bank of Tarpon Springs, National Association, Tarpon Springs
Flagler National Bank of the Palm Beaches, West Palm Beach
Total: 19 banks

1,250,000
1,500,000
2,000,000
1,200,000
2,000,000
1,000,000
1,500,000
2,000,000
1,000,000
1,000,000
2,000,000
4,000,000
1,000,000
1,500,000
1,000,000
1,000,000
1,500,000
1,000,000
2,000,000
29,450,000

GEORGIA

16275 Fidelity National Bank, Decatur
16280 First National Bank of Thomasville-Thomas County, Thomasville

2,500,000
1,300,000
3,800,000

Total: 2 banks
ILLINOIS

16377 Lake Shore National Bank, Danville
16413 American National Bank, Village of Downers Grove
16260 Suburban National Bank of Woodfield, Village of Schaumburg

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

Total: 3 banks
KANSAS

16286 First National Bank of Derby, Derby

1,000,000
LOUISIANA

16339

184

Republic National Bank of Louisiana, New Orleans

1,000,000

TABLE

B-8—Continued

Newly organized National banks, by States, calendar 1974
Title and location of bank

Charter
No.

Total capital
accounts

MAINE

16382 Casco-Northern National Bank, Augusta

$1,200,000
MARYLAND

16337

Atlantic National Bank, Ocean City

16378
16296
16274
16393
16387

National Bank of Dearborn, Dearborn
Grand Rapids Bank, National Association, Grand Rapids .
Michigan National Bank-West, Kalamazoo
First National Bank of Plymouth, Plymouth
Michigan National Bank of Macomb, Warren

1,000,000
MICHIGAN

Total: 5 banks

3,000,000
2,000,250
1,500,000
1,500,175
1,500,000
9,500,425

MINNESOTA

16308 National Bank of Minnetonka, Minnetonka

1,015,000
MISSOURI

16306
16368
16351
16383
16262
16360

United Missouri Bank of Blue Springs, National Association, Blue Springs
Commerce Bank of Independence, National Association, Independence
United Missouri Bank of Jefferson City, National Association, Jefferson City
Harvester National Bank, Unincorporated area of St. Charles County
Boatmen's National Bank of North St. Louis County, Unincorporated area of St. Louis County
Mercantile National Bank of St. Louis County, Unincorporated area of St. Louis County
Total: 6 banks

1,000,000
1,500,000
1,000,000
1,000,000
1,000,000
1,300,000
6,800,000

NEW JERSEY

16397 Lenape National Bank, Moorestown
16267 Arcadia National Bank, Secaucus ..

1,000,000
3,352,250

Total: 2 banks

4,352,250
NEW YORK

16379 Chase Manhattan Bank of the Southern Tier (National Association), Binghamton .
16417 Bessemer Trust Company, National Association, New York City
16319 Peoples National Bank of Rockland County, Ramapo
Total: 3 banks

2,000,000
2,000,000
1,500,000
5,500,000

NORTH CAROLINA

16356 Metrolina National Bank, Charlotte .
16361 Peoples National Bank, Smithfield ..

1,750,000
1,000,000

Total: 2 banks

2,750,000
OHIO

16330 The Central Trust Company of Montgomery County, National Association, Dayton

2,000,000

OKLAHOMA

16405 Quail Creek Bank, National Association, Oklahoma City

1,650,000

TENNESSEE

16307 First National Bank of Lebanon, Lebanon .
16302 City National Bank of Memphis, Memphis .
Total: 2 banks

750,000
5,000,000
5,750,000

185

TABLE

R-8—Continued

Newly organized National banks, by States, calendar 1914
Charter
No.

Total capital
accounts

Title and location of bank

TEXAS

16355
16374
16320
16304
16381
16354
16369
16329
16297
16279
16420
16340
16388
16259
16358
16408
16282
16395
16357
16343
16336
16314
16404

Union National Bank, Austin
Brownsville National Bank, Brownsville
Pan American National Bank of Dallas, Dallas
Western National Bank, Duncanville
Continental National Bank, El Paso
Franklin National Bank, El Paso
Montwood National Bank, El Paso
Meadowbrook National Bank, Fort Worth
American National Bank of Garland, Garland
Plaza National Bank, IJarlingen
First Professional Bank, National Association, Houston
Plaza Commerce Bank, National Association, Houston
West Loop National Bank, Houston
Kingwoocl Commerce Bank, N.A., Humble
The First National Bank in Joshua, Joshua
Commercial National Bank of Longview, Longview
Oak HiU National Bank, Oak Hill
Richardson National Bank, Richardson
,
Lakeside National Bank, Rockwall
Churchill National Bank, San Antonio
Colonial National Bank, San Antonio
Peoples National Bank of San Antonio, San Antonio
Citizens National Bank of Temple, Temple

,
,
,
,

$900,000
1,100,000
750,000
1,000,000
1,000,000
800,000
1,000,000
1,000,000
900,000
1,000,000
2,000,000
2,000,000
1,500,000
1,000,000
500,000
1,400,000
750,000
1,250,000
800,000
750,000
750,000
750,000
1,000,000
23,900,000

Total: 23 banks
VIRGINIA

16277
16313
16402
16406

The Services National Bank, Arlington
Fidelity National Bank, Unincorporated area of Halifax County
First & Merchants National Bank of Prince William, Unincorporated area of Prince William County
The First National Bank of Rocky Mount, Rocky Mount

2,500,000
2,000,000
1,000,000
1,200,000
6,700,000

Total: 4 banks
WEST VIRGINIA

16344 First National Bank, Beckley
16385 Guyan National Bank, Unincorporated area of Cabell County
16341 South Berkeley National Bank, Inwood

600,000
500,000
450,000
1,550,000

Total: 3 banks
WISCONSIN

16353 Tri City National Bank of West Allis, West Allis

1,000,000

WYOMING

16390 Wyoming National Bank of Gillette, Gillette
16365 Bank of Wyoming, National Association, Sheridan
Total: 2 banks

186

500,000
400,000
900,000

TABLE B-9

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States,
calendar 1974
Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

ALABAMA

Mar. 27, 1974

Mar. 29, 1974

Apr. 30, 1974

May

Aug.

31, 1974

7, 1974

Nov. 14, 1974

The Selma National Bank, Selma
Selma Bank, N.A., Selma
Charter issued March 27, 1974
The Selma National Bank, Selma
First National Bank of Athens, Athens
First Bank of Athens, N.A., Athens
Charter issued March 27, 1974
First National Bank of Athens, Athens
The City National Bank of Selma, Selma
Dallas County National Bank, Selma
Charter issued April 29, 1974
The City National Bank of Selma, Selma
Baldwin National Bank of Robertsdale, Robertsdale
Gulf Coast National Bank of Robertsdale, Robertsdale
Charter issued May 30, 1974
Baldwin National Bank of Robertsdale, Robertsdale
First City National Bank of Gadsden, Gadsden
Bank of Gadsden, N.A., Gadsden
Charter issued August 5, 1974
First City National Bank of Gadsden, Gadsden
Phenix National Bank of Phenix City, Phenix City
Bank of Phenix, N.A., Phenix City
Charter issued November 13, 1974
Phenix National Bank, Phenix City

$4,073,260

$39,971,271

2,402,439

32,035,189

3,539,483

38,157,630

856,335

11,289,219

2,914,679

39,873,099

1,583,546

16,306,178

7,502,679

107,077,438

755,403

14,698,104

3,026,299

40,515,126

3,325,197

51,165,708

507,746

4,086,041

6,369,755

68,134,540

8,035,702

119,487,343

75,642,361

1,051,922,932

ARKANSAS

National Bank of Commerce of Pine Bluff, Pine Bluff
Jefferson National Bank, Pine Bluff
Charter issued December 27, 1974
Dec. 31, 1974 National Bank of Commerce of Pine Bluff, Pine Bluff
COLORADO

First National Bank in Aspen, Aspen
Second National Bank in Aspen, Aspen
Charter issued April 26, 1974
Apr. 29, 1974 First National Bank in Aspen, Aspen
First National Bank in Glenwood Springs, Glenwood Springs
Second National Bank in Glenwood Springs, Glenwood Springs
Charter issued April 26, 1974
Apr. 29, 1974 First National Bank in Glenwood Springs, Glenwood Springs ..
First National Bank in Grand Junction, Grand Junction
Second National Bank in Grand Junction, Grand Junction
Charter issued April 26, 1974
Apr. 29, 1974 First National Bank in Grand Junction, Grand Junction
First National Bank-North, Grand Junction, Grand Junction
Second National Bank-North, Grand Junction, Grand Junction
Charter issued April 26, 1974
First National Bank-North, Grand Junction, Grand Junction . . .
ILLINOIS

Apr. 29, 1974

First National Bank & Trust Company in Alton, Alton
First National Bank & Trust Company, Alton
Charter issued June 26, 1974
First National Bank & Trust Company, Alton
July

INDIANA

1, 1974

Lafayette National Bank, Lafayette
Tippecanoe National Bank, Lafayette
Charter issued August 16, 1974
Lafayette National Bank, Lafayette
MARYLAND

Aug. 19, 1974

The First National Bank, Baltimore
Charles Street National Bank, Baltimore
Charter issued June 28, 1974
The First National Bank of Maryland, Baltimore
July 8, 1974

See footnote at end of table.

187

TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States,
calendar 1974
Operating bank
New bank
Resulting bank

Effective date
of merger

Total
capital
accounts

Total
assets

MASSACHUSETTS

The First National Bank of New Bedford, New Bedford
Second National Bank of New Bedford, New Bedford
Charter issued May 8, 1974
May 10, 1974 The First National Bank of New Bedford, New Bedford
First Safety Fund National Bank, Fitchburg
Montachusett National Bank, Fitchburg
Charter issued May 30, 1974
June 4, 1974 First Safety Fund National Bank, Fitchburg
The First National Bank of Easthampton, Easthampton
Easthampton Bank (National Association), Easthampton
Charter issued June 24, 1974
June 28, 1974 The First National Bank of Easthampton, Easthampton

$6,991,238

$75,637,194

6,208,415

57,414,272

1,444,644

12,532,230

13,369,023

165,879,365

1,883,135

24,664,874

787,594

18,604,148

2,041,291

24,954,611

2,396,575

44,992,581

934,254

8,749,913

4,875,970

49,740,402

4,207,665

54,437,141

1,577,385

21,744,600

1,691,000

23,294,692

5,072,490

49,638,116

2,724,094

27,691,175

MICHIGAN

Feb. 28, 1974

Mar.

8, 1974

Mar.

8, 1974

May

8, 1974

May

20, 1974

Oct. 10, 1974

Dec.

9, 1974

Dec.

9, 1974

Dec. 13, 1974

Dec. 30, 1974

National Bank and Trust Company of Ann Arbor, Ann Arbor
National Bank of Ann Arbor, Ann Arbor
Charter issued February 25, 1974
National Bank and Trust Company of Ann Arbor, Ann Arbor
First National Bank of Lake City, Lake City
LCM National Bank, Lake City
Charter issued March 4, 1974
First National Bank of Lake City, Lake City
National Bank of Rochester, Rochester
NBR National Bank, Rochester
Charter issued March 4, 1974
National Bank of Rochester, Rochester
The First National Bank of Sault Ste. Marie, Sault Ste. Marie
Sault National Bank, Sault Ste. Marie
Charter issued May 7, 1974
The First National Bank of Sault Ste. Marie, Sault Ste. Marie
The Union National Bank and Trust Company of Marquette, Marquette
UNB National Bank, Marquette
Charter issued May 10, 1974
The Union National Bank and Trust Company of Marquette, Marquette
The First National Bank of Evart, Evart
Evart Bank, N.A., Evart
Charter issued October 8, 1974
The First National Bank of Evart, Evart
Central Bank, National Association, Grand Rapids
C. Bank, National Association, Grand Rapids
Charter issued December 9, 1974
Central Bank, National Association, Grand Rapids
Valley National Bank of Saginaw, Township of Saginaw
V. National Bank, Township of Saginaw
Charter issued December 9, 1974
Valley National Bank of Saginaw, Township of Saginaw
The Gogebic National Bank of Ironwood, Ironwood
GNB National Bank, Ironwood
Charter issued December 12, 1974
The Gogebic National Bank, Ironwood
First National Bank of Ironwood, Ironwood
Second National Bank of Ironwood, Ironwood
Charter issued December 23, 1974
First National Bank of Ironwood, Ironwood
NEW HAMPSHIRE

Concord National Bank, Concord
The Concord Bank, National Association, Concord
Charter issued April 26, 1974
Apr. 30, 1974 Concord National Bank, Concord
Laconia Peoples National Bank & Trust Company, Laconia
The Laconia Bank, National Association, Laconia
Charter issued April 26, 1974
Apr. 30, 1974 Laconia Peoples National Bank & Trust Company, Laconia
See footnote at end of table.

188

TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States,
calendar 1974
Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

NEW HAMPSHIRE—Continued

Merchants National Bank of Manchester, Manchester
The Merchants Bank, National Association, Manchester
Charter issued April 26, 1974
Apr. 30, 1974 Merchants National Bank of Manchester, Manchester

$6,127,279

$48,722,913

2,444,365

22,791,440

25,105,699

319,943,314

3,032,884

42,146,786

20,716,456

203,094,663

1,840,100

28,119,943

1,399,853

19,293,986

1,676,401

15,878,306

1,089,489

14,164,799

1,278,281

17,485,364

4,439,505

60,043,372

89,178,311

1,147,601,909

4,777,445

47,767,192

3,725,488

48,629,073

NEW JERSEY

May

31, 1974

June 28, 1974

June 30, 1974

Aug.

1, 1974

Aug. 30, 1974

Delaware Valley National Bank, Cherry Hill
New Jersey National Bank-South, Township of Cherry Hill
Charter issued May 22, 1974
New Jersey National Bank-Delaware Valley, Cherry Hill
Colonial First National Bank, Borough of Red Bank
New Colonial First National Bank, Borough of Red Bank
Charter issued June 25, 1974
Colonial First National Bank, Borough of Red Bank
The First National Bank of Cranbury, Cranbury
Midlantic National Bank/Cranbury, Township of Cranbury
Charter issued June 25, 1974
The First National Bank of Cranbury, Cranbury
The Prospect Park National Bank, Township of Wayne
First Prospect Park National Bank, Township of Wayne
Charter issued July 24, 1974
The Prospect Park National Bank, Township of Wayne
Plaza National Bank, Secaucus
Second Plaza National Bank, Secaucus
Charter issued August 28, 1974
Plaza National Bank, Secaucus
NEW YORK

Feb.

4, 1974

Feb. 28, 1974

Mar. 29, 1974

June 28, 1974

The Homer National Bank, Homer
Homer Bank, N.A., Homer
Charter issued January 31, 1974
The Homer National Bank, Homer
The First National Bank of Canton, Canton
Chase Manhattan Bank of Northern New York (National Association), Canton
Charter issued February 26, 1974
Chase Manhattan Bank of Northern New York (National Association), Canton
The First National Bank of Hancock, Hancock
Hancock National Bank, Hancock
Charter issued March 25, 1974
The First National Bank of Hancock, Hancock
Glen National Bank and Trust Company, Watkins Glen
Bank of Watkins Glen, National Association, Watkins Glen
Charter issued June 24, 1974
Glen National Bank and Trust Company, Watkins Glen
OHIO

Jan.

1, 1974

Jan.

2, 1974

Sept. 16, 1974

Sept. 30, 1974

The Farmers National Bank of Salem, Salem
Northern Columbiana County National Bank, Salem
Charter issued December 21, 1973
The Farmers National Bank of Salem, Salem
The First National Bank of Cincinnati, Cincinnati
FN National Bank, Cincinnati
Charter issued December 21, 1973
The First National Bank of Cincinnati, Cincinnati
The Athens National Bank, Athens
The F.B.G. National Bank of Athens, Athens
Charter issued September 12, 1974
The Athens National Bank, Athens
The Citizens Baughman National Bank, Sidney
The C.B. National Bank of Sidney, Sidney
Charter issued September 27, 1974
The Citizens Baugham National Bank, Sidney

See footnote at end of table.

189

TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States,
calendar 1974
Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

OKLAHOMA

Jan.

Fidelity Bank, National Association, Oklahoma City
Fidelity National Bank, Oklahoma City
Charter issued December 19, 1973
2, 1974 Fidelity Bank, National Association, Oklahoma City

$12,787,897

$279,733,914

1,573,251

19,029,193

2,326,289

25,401,014

1,998,274

21,983,902

3,611,976

42,762,468

3,373,668

44,689,570

1,916,522

28,271,365

1,179,812

10,597,615

1,995,536

23,776,436

263,417

2,001,160

173,725,584

2,862,368,727

3,871,418

31,822,439

2,614,514

35,155,066

2,284,262

31,379,735

2,984,620

35,670,084

TENNESSEE

Jan.

Feb.

May

July

Hamilton National Bank of Loudon, Loudon
Loudon Bank, N.A., Loudon
Charter issued January 25, 1974
28, 1974 Hamilton National Bank of Loudon, Loudon
The Farmers National Bank of Winchester, Winchester
Winchester Bank, N.A., Winchester
Charter issued January 25, 1974
28, 1974 The Farmers National Bank, Winchester
National Bank of Murfreesboro, Murfreesboro
The Second National Bank of Murfreesboro, Murfreesboro
Charter issued February 26, 1974
28, 1974 The National Bank of Murfreesboro, Murfreesboro
Old & Third National Bank of Union City, Union City
The National Bank of Union City, Union City
Charter issued May 8, 1974
9, 1974 Old & Third National Bank of Union City, Union City
The Cleveland National Bank, Cleveland
Cleveland Interim Bank, N.A., Cleveland
Charter issued July 15, 1974
18, 1974The Cleveland National Bank, Cleveland
TEXAS

First National Bank in Grand Prairie, Grand Prairie
Second National Bank in Grand Prairie, Grand Prairie
Charter issued January 14, 1974
Jan. 18, 1974 First National Bank in Grand Prairie, Grand Prairie
Texas National Bank of Dallas, Dallas
Stemmons National Bank, Dallas
Charter issued January 14, 1974
Jan. 18, 1974 Texas National Bank of Dallas, Dallas
The First National Bank of Crockett, Crockett
The New National Bank of Crockett, Crockett
Charter issued March 14, 1974
Mar. 18, 1974 The First National Bank of Crockett, Crockett
The First National Bank of Nordheim, Nordheim
The New National Bank of Nordheim, Nordheim
Charter issued March 29, 1974
Apr. 1, 1974The First National Bank of Nordheim, Nordheim
Republic National Bank of Dallas, Dallas
Ervay Bank, National Association, Dallas
Charter issued May 7, 1974
May
9, 1974 Republic National Bank of Dallas, Dallas
Guaranty National Bank and Trust of Corpus Christi, Corpus Christi
Guaranty Commerce National Bank, Corpus Christi
Charter issued July 24, 1974
July 26, 1974Guaranty National Bank and Trust of Corpus Christi, Corpus Christi
First National Bank of Hurst, Hurst
Hurst Commerce National Bank, Hurst
Charter issued July 24, 1974
Aug. 2, 1974 First National Bank of Hurst, Hurst
Farmers-First National Bank of Stephenville, Stephenville
Stephenville National Bank, Stephenville
Charter issued August 21, 1974
Aug. 26, 1974 Farmers-First National Bank of Stephenville, Stephenville
The First National Bank in Cleburne, Cleburne
Johnson County National Bank, Cleburne
Charter issued October 31, 1974
Nov. 1, 1974 The First National Bank in Cleburne, Cleburne
See footnote at end of table.

190

TABLE

B-9—Continued

National bank charters issued* and mergers consummated pursuant to corporate reorganizations, by States,
calendar 1974
Effective date
of merger

Operating bank
New bank
Resulting bank

Total
capital
accounts

Total
assets

VIRGINIA

The First National Bank in Onancock, Onancock
Onancock Bank, N.A., Onancock
Charter issued January 23, 1974
Feb. 1, 1974 The First National Bank in Onancock, Onancock
The Colonial-American National Bank of Roanoke, Roanoke
Colonial Bank, N.A., Roanoke
Charter issued October 29, 1974
Oct. 31, 1974 The Colonial-American National Bank, Roanoke
Community Bank and Trust Company, Springfield
Virginia National Bank/Fairfax, Springfield
Charter issued November 15, 1974
Nov. 18, 1974 Virginia National Bank/Fairfax, Springfield

$1,254,878

$14,716,635

11,570,760

166,236,629

1,030,597

6,926,779

191,507,756

3,804,277,833

WASHINGTON

July

Seattle-First National Bank, Seattle
SeaFirst National Bank, Seattle
Charter issued June 20, 1974
1, 1974 Seattle-First National Bank, Seattle

* Includes only charter issuances related to mergers consummated during 1974. Does not include Republic Bank, N. A., New York,
N.Y., for which a charter was issued pursuant to corporate reorganization because it was merged with two operating banks. For that
action see Table B-17. For a full listing of all charters issued pursuant to corporate reorganizations during the year, see Table B—11.

191

TABLE B-10

State-chartered banks converted* to National banks, by States, calendar 1974
Charter
No.

Title and location of bank

Outstanding
capital stock

Effective
date of
charter

$99,933,100

Total: 12 banks

Surplus, undivided profits
and reserves

Total assets

$178,279,667 $5,593,399,146

ARKANSAS

16272 First National Bank of Russellville, Russellville
Conversion of The Bank of Russellville

Jan.

450,000

1,850,601

33,103,535

Jan.

465,000

1,043,985

23,784,969

Jan.

300,000

369,328

8,714,721

Dec. 19, 1973

500,000

1,311,310

29,649,528

FLORIDA

16261 The First National Bank of Winter Haven, Winter Haven
Conversion of Lake Region Bank of Commerce
GEORGIA

16258 The First National Bank of Alma, Alma
Conversion of Citizens State Bank
ILLINOIS

16249 American National Bank, South Chicago
Conversion of American Savings Bank
IOWA

16324 Valley National Bank, Des Moines
Conversion of Valley Bank and Trust Company

May

1,250,000

3,879,463

64,324,067

Aug.

810,000

2,763,913

53,573,189

Aug.

3,500,000

7,564,304

164,375,684

1 First Pennsylvania Bank, National Association, Bala Cynwyd
Conversion of the First Pennsylvania Banking &
Trust Company . . .
May

91,616,100

158,136,842

5,164,150,852

200,000

1,033,354

12,183,011

300,000

1,297,351

13,641,675

Dec. 19, 1973

242,000

780,124

17,762,228

May

300,000

572,766

7,656,268

MICHIGAN

16371 Commercial National Bank, Cassopolis
Conversion of First Commercial Savings Bank
MONTANA

16362 Security Bank, National Association, Billings
Conversion of Security Trust & Savings Bank
PENNSYLVANIA

TENNESSEE

16410 First Tennessee National Bank, Unincorporated area of Davidson County
Conversion of White's Creek Bank & Trust Company . . . . Dec.
WEST VIRGINIA

16298 Western Greenbrier National Bank, Rainelle
Conversion of The Western Greenbrier Bank
16248 The Bank of Warwood, National Association, Wheeling
Conversion of The Bank of Warwood
16332 Community Savings Bank, National Association, Wheeling
Conversion of Community Savings Bank

Mar.

* Includes only conversions not pursuant to corporate reorganizations. In 1974, there was one such conversion, Community Bank
and Trust Company, Springfield, Va., converted to Virginia National Bank/Fairfax, Springfield, Va., completed on Nov. 18, 1974. For
complete information on that transaction see Table B—9.

192

TABLE B-ll

National bank charters issued pursuant to corporate reorganizations, by States, calendar 1974
Charter
No.

Title and location of bank

Date of
issuance

Total: 60 banks
ALABAMA

15073
15481
15053
15402
1736
7084

First Bank of Athens, N.A., Athens
Bank of Gadsden, N.A., Gadsden
Bank of Phenix, N.A., Phenix City
Gulf Coast National Bank of Robertsdale, Robertsdale
Dallas County National Bank, Selma
Selma Bank, N.A., Selma
Total: 6 banks

Mar.
Aug.
Nov.
May
Apr.
Mar.

27
5
13
30
29
27

Dec.

Apr.
Apr.
Apr.
Apr.

26
26
26
26

June

Aug.

June

June
May
May

24
30
8

Feb.
Oct.
Dec.
Dec.
Dec.
Mar.
May
Mar.
Dec.
May

25
8
9
12
23
4
10
4
9
7

Apr.
Apr.
Apr.

26
26
26

May
June
June
Aug.
July

22
25
25
28
24

Feb.
Mar.
Jan.
June
June

26
25
31
28
24

ARKANSAS

14056 Jefferson National Bank, Pine Bluff
COLORADO

15815
3661
13902
16054

Second National Bank in Aspen, Aspen
Second National Bank in Glenwood Springs, Glenwood Springs
Second National Bank in Grand Junction, Grand Junction
Second National Bank-North, Grand Junction, Grand Junction
Total: 4 banks
ILLINOIS

13464 First National Bank & Trust Company, Alton
INDIANA

14175 Tippecanoe National Bank, Lafayette
MARYLAND

1413 Charles Street National Bank, Baltimore
MASSACHUSETTS

428 Easthampton Bank (National Association), Easthampton
2153 Montachusett National Bank, Fitchburg
261 Second National Bank of New Bedford, New Bedford
Total: 3 banks
MICHIGAN

14933
12561
16037
9517
14456
15234
12027
15274
15403
3547

National Bank of Ann Arbor, Ann Arbor
Evart Bank, N.A., Evart
C. Bank, National Association, Grand Rapids
GNB National Bank, Ironwood
The Second National Bank of Ironwood, Ironwood
LCM National Bank, Lake City
UNB National Bank, Marquette
NBR National Bank, Rochester
V. National Bank, Township of Saginaw
Sault National Bank, Sault Ste. Marie
Total: 10 banks
NEW HAMPSHIRE

318 The Concord Bank, National Association, Concord
4037 The Laconia Bank, National Association, Laconia
1520 The Merchants Bank, National Association, Manchester
Total: 3 banks
NEW JERSEY

14975
3168
2257
15228
12861

New Jersey National Bank-South, Township of Cherry Hill
Midlantic National Bank/Cranbury, Township of Cranbury
New Colonial First National Bank, Borough of Red Bank
Second Plaza National Bank, Secaucus
First Prospect Park National Bank, Township of Wayne
Total: 5 banks

3696
8613
3186
15569
9977

Chase Manhattan Bank of Northern New York (National Association), Canton
Hancock National Bank, Hancock
Homer Bank, N.A., Homer
Republic Bank, National Association, New York
Bank of Watkins Glen, National Association, Watkins Glen ..
Total: 5 banks

NEW YORK

193

B-ll—Continued

TABLE

National bank charters issued pursuant to corporate reorganizations, by States, calendar 1974
Charter
No.

Title and location of bank

Date of
issuance

OHIO

7744 The F.B.G. National Bank of Athens, Athens
7862 The C.B. National Bank of Sidney, Sidney

Sept.
Sept.

12
27

July

15
25
26
8
25

Total: 2 banks
TENNESSEE

1666
12080
14736
9629
8640

Cleveland Interim Bank, N.A., Cleveland
Loudon Bank, N.A., Loudon
The Second National Bank of Murfreesboro, Murfreesboro . . .
The National Bank of Union City, Union City
Winchester Bank, N.A., Winchester
Total: 5 banks

13107
14988
4684
12186
15501
14576
15072
12390
12730

Johnson County National Bank, Cleburne
Guaranty Commerce National Bank, Corpus Christi
The New National Bank of Crockett, Crockett
Ervay Bank, National Association, Dallas
Stemmons National Bank, Dallas
Second National Bank in Grand Prairie, Grand Prairie
Hurst Commerce National Bank, Hurst
The New National Bank of Nordheim, Nordheim
Stephenville National Bank, Stephenville
Total: 9 banks

Jan.

Feb.
May

Jan.

TEXAS

Oct.
July
Mar.
May

Jan.

Jan.
July
Mar.
Aug.

31
24
14
7
14
14
24
29
21

VIRGINIA

Jan.

13878 Onancock Bank, N.A., Onancock
11817 Colonial Bank, N.A., Unincorporated area of Roanoke County
16398 Virginia National Bank/Fairfax, Springfield

Oct.
Nov.

23
29
15

June

Total: 3 banks
WASHINGTON

11280

SeaFirst National Bank, Seattle

TABLE

B-12

National banks reported in voluntary liquidation, by States, calendar 1974
Title and location of bank

Total capital
accounts of
liquidated
banks

Date of
liquidation

Total: 6 National banks

$15,107,691
ALABAMA

The Peoples Bank at Selma Mall, National Association (15995), absorbed by The Peoples Bank & Trust
Jan.
Company, Selma

511,879

7,585,458

2,903,390

Mar

128,554

Nov.

2,674,610

Dec.

1,303,800

CALIFORNIA

Beverly Hills National Bank, Beverly Hills (13348), absorbed by Wells Fargo Bank, National Association,
San Francisco (15660)

Jan.

MISSISSIPPI

Citizens National Bank, Jackson (15516), absorbed by First Mississippi National Bank, Hattiesburg (5176) Nov.
NEW YORK

The First National Bank of Hamden, Hamden (12017), absorbed by The First National Bank of Hancock,
Hancock (8613)
PENNSYLVANIA

Blairsville National Bank, Blairsville (13868), absorbed by Pittsburgh National Bank, Jeannette (252)
WASHINGTON

Guaranty National Bank of White Center, Seattle (14502), absorbed by Old National Bank of Washington,
Spokane (4668)

194

TABLE B-13

National banks merged or consolidated with State banks, by States, calendar 1974
Title and location of bank

Total capital
accounts of
National
banks

Effective
date

$51,599,783

Total: 13 banks
CALIFORNIA

Liberty National Bank, San Francisco (13178), merged into The Chartered Bank of London, San Francisco, under title of "The Chartered Bank of London"

July

5,135,683

May

2,119,095

Jan.

399,905

May

1,217,743

3,060,498

993,950

604,764

24,611,668

CONNECTICUT

The Clinton National Bank, Clinton (1314), merged into The Connecticut Bank and Trust Company,
Hartford, under title of 'The Connecticut Bank and Trust Company"
IOWA

The First National Bank of Klemme, Klemme (6659), merged into State Savings Bank, Goodell, under title
of "North Iowa State Bank"
MASSACHUSETTS

The Buzzards Bay National Bank, Buzzards Bay (13222), merged into Cape Cod Bank and Trust Company,
Barnstable, under title of "Cape Cod Bank and Trust Company"
NEW YORK

United National Bank of Long Island in New York, Forest Hills (13242), merged into Valley Bank of New
Apr.
York, Valley Stream, under title of "Valley Bank of New York"
The First National Bank of Marion, Marion (10546), merged into Central Trust Company Rochester, New
York, Rochester, under title of "Central Trust Company Rochester, New York"
May
Montour National Bank in Montour Falls, Montour Falls (13583), merged into Chemung Canal Trust
Company, Elmira, under title of "Chemung Canal Trust Company"
Apr.
First Westchester National Bank, New Rochelle (13955), merged into Barclays Bank of New York, New
York, under title of "Barclays Bank of New York"
May
PENNSYLVANIA

The First National Bank of Altoona, Altoona (247), merged into Central Counties Bank, State College,
Dec.
31
under title of "Central Counties Bank"
The Loganton National Bank in Loganton, Loganton (9345), merged into The State Bank of Avis, Avis,
Nov.
11
under title of "The State Bank of Avis"
The First National Bank of Montoursville, Montoursville (6997), consolidated with Bank of South WilliamsDec. 31, 1973
port, South Williamsport, under title of "Bank of Central Pennsylvania"
The Plymouth National Bank, Plymouth (6881), merged into Northeastern Bank of Pennsylvania, ScranSept.
30
ton, under title of "Northeastern Bank of Pennsylvania"

7,185,490
285,568
2,372,960
2,785,968

VERMONT

National White River Bank in Bethel, Bethel (13755), merged into Proctor Trust Company, Proctor, under
title of "Proctor Trust Company"

Jan.

826,491

195

TABLE

B-14

National banks converted into State banks, by States, calendar 1974
Charter
No.

Title and location of bank

Total capital
accounts of
National
banks

Effective
date

$146,728,590

Total: 19 banks
ILLINOIS

5638 The First National Bank of Dundee, Dundee, converted into The First Bank of Dundee

1,337,028

1,046,730

June

342,370

Oct.

1,157,756

June

1,180,653

May

1,172,217

10
10

1,632,100
2,720,803

July
July
Mar.

1
1
18

20,896,196
11,585,244
2,238,064

Jan.
July

2
15

32,994,842
10,371,925

Bankers Trust of South Carolina, National Association, Columbia, converted into Bankers Trust
of South Carolina
Dec.

39,443,129

1
9
11

1,141,199
1,356,964
10,064,639

1,547,473

4,499,258

Sept.

INDIANA

9077 The Farmers and Merchants National Bank, Fort Branch, converted into The Farmer's and
Merchants Bank of Fort Branch
AOT.
IOWA

5912 The First National Bank of Prescott, Prescott, converted into First State Bank
MISSISSIPPI
15559 First National Bank of Greenwood, Greenwood, converted into First Greenwood Bank
NEBRASKA

15376

City National Bank and Trust Company of Lincoln, Lincoln, converted into Citibank and Trust
Company of Lincoln
. . . . .
NEW HAMPSHIRE

14100 Berlin City National Bank, Berlin, converted into The Berlin City Bank
OKLAHOMA

10286 The Madill National Bank, Madill, converted into The Madill Bank and Trust Company
Sept.
15350 Republic National Bank of Tulsa, Tulsa, converted into Republic Bank and Trust Company . . . May
PENNSYLVANIA

2634
5773
478
77

The Fulton National Bank of Lancaster, Lancaster, converted into Fulton Bank
Farmers First National Bank, Lititz, converted into Farmers First Bank
The First National Bank of Pittston, Pittston, converted into The First Bank of Greater Pittston .
Northeastern National Bank of Pennsylvania, Scranton, converted into Northeastern Bank of
Pennsylvania
..
5184 Southern Pennsylvania National Bank, York, converted into Southern Pennsylvania Bank
SOUTH CAROLINA

10635

TEXAS

8156
15833
14S30
12789

Apr.
The Elgin National Bank Elgin converted into Elgin Bank of Texas
July
People's National Bank of Spring Branch, Houston, converted into Peoples Bank
Western National Bank of Houston, Houston, converted into Western Bank
July
The First National Bank of Raymondville, Raymondville, converted into Raymondville Bank of
Texas
June
VERMONT

1197 The Merchants National Bank, Burlington, converted into The Merchants Bank

196

Sept.

TABLE B-15

Purchases of State banks by National banks, by States, calendar 1974
Title and location of bank

Effective
date

Total: 8 banks

Total capital
accounts of
State banks
$3,483,272

IOWA

The Okey-Vernon National Bank of Corning, Corning (8725), purchased First State Bank, Prescott

July

342,370

The Shelby National Bank of Shelbyville, Shelbyville (7946), purchased The Union State Bank, Morristown Feb.

323,256

Sept. 28

938,000

INDIANA

MARYLAND

Maryland National Bank, Baltimore (13745), purchased Eutaw Savings Bank of Baltimore, Baltimore

Apr.

MICHIGAN

Michigan National Bank of Macomb, Warren (16387), purchased The Tri-City Bank, Warren
OHIO

The People's National Bank of Georgetown, Georgetown (5996), purchased Citizens Bank Co., Hamersville Feb.

203,671

Nov.

1,209,372

Apr.
The Baraboo National Bank, Baraboo (14397), purchased Farmers State Bank, Rock Springs
The First National Bank of the City of Superior, Superior (3926), purchased Wisconsin State Bank, Superior July

12
15

162,603
304,000

PENNSYLVANIA

National Bank of the Commonwealth, Indiana (14098), purchased The Houtzdale Bank, Houtzdale
WISCONSIN

197

TABLE

B-16

Consolidations* of National banks, or National and State banks, by States, calendar 1974
Consolidating banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

Total: 8 consolidations
ALABAMA

The First National Bank of Jasper, Jasper (7746)
Dora Banking and Trust Company, Dora
Apr. 30 The First National Bank of Jasper, Jasper (7746)

$1,000,000
200,000
2,280,000

$2,000,000
200,000
2,280,000

$2,426,004
331,060
1,604,610

$52,221,754
7,334,748
59,584,573

2,266,640
500,000
3,356,640

4,223,360
2,100,000
6,343,360

1,640,223
526,120
1,556,342

111,756,697
45,408,250
157,164,947

263,900
508,980
659,750

950,000
2,600,000
3,663,130

659,750

3,663,130

162,620
105,721
278,375
328,664

21,453,037
37,504,693
58,957,729
57,810,852

797,500

1,650,000

402,383

38,611,251

1,082,425

5,687,955

731,047

96,422,102

869,028
1,104,900
1,179,900

250,000
5,800,000
6,275,000

19,028
1,282,705
1,301,733

11,817,634
105,753,788
117,571,421

250,000
240,000
490,000

300,000
260,000
560,000

243,200
138,606
381,806

9,719,392
7,274,631
16,994,023

165,000
250,000
415,000

220,000
415,000
635,000

506,402
518,215
1,024,617

15,188,669
22,416,787
37,605,457

4,760,000
1,250,000
8,000,000

6,240,000
2,500,000
8,000,000

5,660,730
964,857
5,375,586

302,480,978
108,584,051
411,065,029

MASSACHUSETTS

Aug. 16

The County Bank, N.A., Cambridge (4771)
Lexington Trust Company, Lexington
The County Bank, National Association (4771)
MISSISSIPPI

Mar.

Oct.

First National Bank of Monroe County, Aberdeen (3656) .
Peoples Bank Starkville
1 First United National Bank, Starkville (3656)
National Bank of Mississippi, Starkville (3656)
The National Bank of Commerce of Columbus, Columbus
(10361)
1 National Bank of Commerce of Mississippi, Starkville
(3656)
NEW HAMPSHIRE

Indian Head National Bank of Manchester, Manchester
(15563)
Indian Head National Bank of Nashua, Nashua (1310) . . .
Nov. 29 Indian Head National Bank of Nashua, Nashua (15563) ..
OHIO

Apr.

The First National Bank of Versailles, Versailles (9336) ..
The Peoples Bank Company, Versailles
1 Peoples National Bank, Versailles (9336)

July

The First National Bank of Confluence, Confluence (5307)
First National Bank of Somerset County, Berlin (5823) . . .
29 National Bank of Western Pennsylvania, Berlin (5307) . . .

Jan.

United Virginia Bank/First & Citizens National, Alexandria (651)
United Virginia Bank of Fairfax, Vienna
2 United Virginia Bank/National, Alexandria (651)

PENNSYLVANIA

VIRGINIA

Excludes consolidations involving only one operating bank, effected pursuant to corporate reorganization.

198

TABLE B-17

Mergers* of National banks, or National and State banks, by States, calendar 1974
Effective
date

Merging banks
Resulting bank

Outstanding
capital
stock

Surplus

Undivided
profits and Total assets
reserves

Total: 43 merger actions
CALIFORNIA

Palm Springs National Bank, Palm Springs (15276)
First National Bank and Trust Company, Ontario (6268)
Jan. 1
First National Bank and Trust Company, Ontario (6268)
Hayward National Bank, Hayward (15343)
The First National Bank of San Jose, San Jose (2158)
July 31 The First National Bank of San Jose, San Jose (2158)
Commercial National Bank, Buena Park (15434)
Wells Fargo Bank, National Association, San Francisco (15660) .. .
Aug. 23 Wells Fargo Bank, National Association, San Francisco (15660) . . .

$181,113
$859,365
2,349,950
1,840,080
2,985,308
2,245,200
425,900
705,020
7,600,000
5,603,690
6,308,710
8,025,900
483,724
1,355,865
93,010,320 260,664,910
94,461,100 261,053,719

$195,366 $24,710,462
2,155,404 128,773,855
1,960,038 153,484,317
608,877
16,876,039
4,444,381 283,984,707
5,053,258 300,860,747
512,854
33,069,076
78,416,062 9,819,837,927
78,928,916 9,852,907,003

INDIANA

Farmers State Bank, Plainville
The Peoples National Bank and Trust Company of Washington,
Washington (3842)
Apr. 30 The Peoples National Bank and Trust Company of Washington,
Washington (3842)

25,000

50,000

137,576

1,876,645

300,000

400,000

562,737

24,867,345

346,250

450,000

679,063

26,682,905

100,000
1,500,000
1,589,000

100,000
2,000,000
2,111,000

96,000
1,502,605
1,596,437

375,066
95,337,656
93,805,519

271,000
5,500,000
5,771,000

229,000
6,000,000
6,229,000

769,000
9,134,904
9,903,905

9,128,913
169,462,647
178,591,559

300,000
17,000,000
17,000,000

600,000
38,000,000
38,000,000

97,500
3,159,160
3,256,660
125,000
246,905
303,155

52,500
7,899,880
7,952,380
105,000
263,000
436,750

361,006
3,999,780
4,360,786
200,817
1,362,606
1,563,423

7,553,765
172,221,639
179,775,404
5,474,903
33,622,896
39,097,799

300,000
10,481,625
10,808,625

1,200,000
37,018,375
39,191,375

130,787
2,527,709
1,661,844

17,544,879
775,645,596
789,457,648

400,000
400,000
800,000
250,000
16,725,870
16,975,570

400,000
265,000
665,000
250,000
33,467,013
33,717,013

630,000

590,305

900,000

1,762,000

906,027

72,047,509

1,125,000
1,000,000
1,000,000
2,000,000
899,890
7,836,000
7,836,000

4,417,000
1,500,000
1,000,000
2,500,000
1,000,000
14,501,375
14,501,375

906,027
428,639
712,705
1,279,292
2,096,470
7,608,908
7,423,768

83,449,286
44,837,737
37,317,025
82,605,008
56,959,716
486,446,643
543,281,539

IOWA

Farmers Loan and Trust Company, Sioux City
The Toy National Bank of Sioux City, Sioux City (10139).
Sept. 16 The Toy National Bank, Sioux City (10139)
KANSAS

The Victory State Bank, Kansas City
Security National Bank of Kansas City, Kansas City (13801)
Nov. 29 Security National Bank of Kansas City, Kansas City (13801)
MARYLAND

Jan.

Sykesville State Bank, Sykesville
Maryland National Bank, Baltimore (13745).
4 Maryland National Bank, Baltimore (13745).

455,185
14,481,227
61,523,378 1,732,138,222
62,878,563 1,745,392,289

MICHIGAN

The Farmers State Bank of Concord, Concord
The National Bank of Jackson, Jackson (13741)
May 31 The National Bank of Jackson, Jackson (13741)
New Haven Savings Bank, New Haven
The National Bank of Richmond, Richmond (13793)
Dec. 31 The National Bank of Richmond, Richmond (13793)
MISSISSIPPI

Leflore Bank and Trust Company, Greenwood
Deposit Guaranty National Bank, Jackson (15548)
June 28 Deposit Guaranty National Bank, Jackson (15548)
NEW JERSEY

Mar. 31
Mar. 31

May

June

Aug.

Midlantic National Bank/Parsippany, Parsippany-Troy Hills (15975)
Midlantic National Bank/Morris, Morristown (15360)
Midlantic National Bank/Morris, Morristown (15360)
Millburn-Short Hills Bank, Millburn
Midlantic National Bank, Newark (1316)
Midlantic National Bank, Newark (1316)
Madison State Bank, Madison Township
Peoples National Bank of Monmouth County, Hazlet Township
(4147)
United Jersey Bank/Mid State, National Association, Hazlet Township (4147)
First National State Bank of Ocean County, Lakewood (16035)
First National State Bank of the Jersey Coast, Spring Lake (13898)
First National State Bank of the Jersey Coast, Spring Lake (13898)
Belmar-Wall National Bank, Wall Township (13848)
The First Jersey National Bank, Jersey City (374)
The First Jersey National Bank, Jersey City (374)

93,129
8,997,817
107,135
12,315,879
200,265
21,313,697
903,425
49,402,960
25,648,937 1,004,152,034
26,552,362 1,053,554,995
9,895,881
0

See footnote at end of table.

199

TABLE

B-17—Continued

Mergers* of National banks, or National and State banks, by States, calendar 1974
Effective
date

Oct.

Nov.

Dec.

Merging banks
Resulting bank

NEW JERSEY—Continued
Citizens State Bank, Vineland
Citizens Bank of Maple Shade, Maple Shade
Citizens National Bank of South Jersey, Bridgeton (2999)
Citizens Bank of Marlton, National Association, Marlton (13125) . . .
Citizens United Bank, National Association, Vineland (13125)
Oakland State Bank, Oakland
Citizens First National Bank of New Jersey, Ridgewood (11759)
Citizens First National Bank of New Jersey, Ridgewood (11759)
Fairneld National Bank, Fairfield (15857)
New Jersey Bank (National Association), Clifton (15709)
New Jersey Bank (National Association), Clifton (15709)
Egg Harbor Bank and Trust Company, Egg Harbor City
Mechanics National Bank of Delaware Valley, Burlington Township
(1222)
First National State Bank/Mechanics, Burlington (1222)
United Jersey National Bank of Cherry Hill, Cherry Hill (15971)
Third National Bank of New Jersey, Camden (13203)
United Jersey Bank/Third National, Camden (13203)
The First National Bank of Westwood, Westwood (8777)
New Jersey Bank (National Association), Clifton (15709)
New Jersey Bank (National Association), Clifton (15709)

Outstanding
capital
stock

Surplus

$1,250,000
500,000
460,005
675,568
2,885,573
500,000
5,239,760
5,614,760
500,000
9,693,096
9,693,096
900,000

$750,000
473,013
670,001
1,036,562
2,929,576
387,538
5,388,230
5,913,230
500,000
24,921,108
23,639,069
900,000

2,750,000
3,650,000
500,000
1,062,500
1,562,500
425,250
9,693,096
9,693,096

2,750,000
3,650,000
250,000
724,706
1,098,869
1,074,750
23,639,069
19,856,010

350,000
789,669
1,090,450
100,000
3,876,720
4,156,720

1,000,000
2,470,324
3,519,543

Undivided
profits and
reserves

$543,711
291,295
389,833
212,575
1,437,414
70,000
10,136,247
10,113,449
167,731
9,563,098
9,563,098
673,003
929,771
1,602,774
124,163
0
0
1,147,693
9,105,272
9,105,272

Total assets

$50,685,279
20,129,415
26,441,564
33,498,441
130,754,699
8,566,397
241,475,526
249,151,711
8,095,383
758,661,811
764,858,801
24,280,566
109,646,386
133,926,951
10,836,278
64,102,809
74,939,087
37,882,853
752,139,150
783,462,337

NEW YORK

May

June

July

Nov.

Lewis County Trust Company, Lowville
The St. Lawrence National Bank, Canton (8531)
The St. Lawrence National Bank, Canton (8531)
The National Bank of Hobart, Hobart (4497)
The National Bank and Trust Company of Norwich, Norwich (1354)
The National Bank and Trust Company of Norwich, Norwich (1354)
Republic Bank, National Association, New York
Kings Lafayette Bank, New York
Republic National Bank of New York, New York (15569)
Republic National Bank of New York, New York (15569)
The First National Bank of Cooperstown, Cooperstown (280)
Bankers Trust Company of Albany, National Association, Albany
(15758)
Bankers Trust Company of Albany, National Association, Albany
(15758)

26,017,160
79,901,518
107,033,826
6,251,306
143,864,859
150,157,667

200,000
10,000,000
11,282,080
21,482,080

150,000
3,876,720
4,156,720
40,000
6,500,000
14,841,090
22,466,261

783,069
2,242,466
3,027,974
351,968
3,815,580
3,864,191
0
6,315,363
29,484,282
29,484,282

965,000
224,190,575
565,630,656
782,781,076

250,000

400,000

992,860

17,791,081

4,400,000

8,000,000

11,662,879

266,520,970

4,400,000

8,650,000

12,655,739

284,312,051

300,000
46,171,968
46,471,968

700,000
52,180,946
52,880,945

100,000

1,100,000

19,174,569
716,020
31,633,945 3,109,145,446
32,374,378 3,128,334,357
334,578
16,584,986

51,360,070

70,800,000

57,842,297 2,975,719,479

51,360,070

72,000,000

58,176,876 2,992,304,465

150,000
2,200,000
2,560,000
40,000
150,000
190,000

500,000
2,560,000
3,060,000
100,000
210,000
310,000

369,106
3,060,953
3,290,098
66,599
405,906
462,548

10,286,299
100,413,248
109,383,244

250,000

246,148

7,473,617

1,000,000

500,000

461,093

8,631,213

1,250,000

746,148

461,093

16,104,831

NORTH CAROLINA

May

Dec.

The First National Bank of Mount Airy, Mount Airy (4896)
North Carolina National Bank, Charlotte (13761)
17 North Carolina National Bank, Charlotte (13761)
Citizens Bank, Marshall
Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)
30 Wachovia Bank and Trust Company, National Association, Winston-Salem (15673)
OHIO

Jan.

Dec.

Beach City Banking Company, Beach City
The United National Bank and Trust Company, Canton (14501)
1 The United National Bank and Trust Company, Canton (14501)
The Freeport State Bank, Freeport
Harrison County National Bank, Hopedale (6938)
21 Harrison County National Bank, Hopedale (6938)
The Farmers and Merchants Bank of Englewood, Englewood
The Central Trust Company of Montgomery County, National Association, Dayton (16330)
31 The Central Trust Company of Montgomery County, National Association, Dayton (16330)

See footnote at end of table.

200

2,866,775
9,505,483
12,372,258

TABLE

B-17—Continued

Mergers* of National banks, or National and State banks, by States, calendar 1974
Merging banks
Resulting bank

Effective
date

Outstanding
capital
stock

Surplus

Undivided
profits and
reserves

Total assets

PENNSYLVANIA

May

June 10

Sept. .30

Nov. 15

The Hummelstown National Bank, Hummelstown (2822)
The Fulton National Bank of Lancaster, Lancaster (2634)
The Fulton National Bank of Lancaster, Lancaster (2634)
The Dime Bank of Lansford, Lansford
Pennsylvania National Bank and Trust Company, Pottsville (1663)
Pennsylvania National Bank and Trust Company, Pottsville (1663)
The First National Bank of Factoryville, Factoryville (9130)
The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre (732) .
The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre (732) .
The Duncannon National Bank, Duncannon (4142)
Cumberland County National Bank and Trust Company, New
Cumberland (14542)
Cumberland County National Bank and Trust Company, New
Cumberland (14542)
The Berwick National Bank, Berwick (6162)
The First National Bank of Eastern Pennsylvania, Wilkes-Barre (30)
First Eastern Bank, National Association, Wilkes-Barre (30)

$250,000
2,485,875
2,767,125
50,000
1,737,500
1,837,500
75,000
1,300,600
1,431,850

$1,250,000
5,652,350
6,902,350
350,000
8,150,000
8,500,000
250,000
3,381,560
3,722,810

278,435
3,127,937
3,241,091
254,555
3,302,133
3,409,188

$19,652,739
255,255,958
274,908,698
10,719,813
206,100,697
216,877,111
5,750,662
134,984,599
140,735,261

130,000

235,000

490,713

10,887,945

1,845,620

5,129,380

3,969,460

225,799,364

1,845,620
174,000
4,926,800
5,579,300

5,494,380
976,000
8,286,400
9,262,400

4,460,173
412,392
7,678,690
7,960,810

236,687,309
22,048,850
381,565,461
403,091,570

800,000

1,048,306

815,681

33,698,335

16,329,490

5,686,005

7,389,821

519,892,860

18,196,160
300,000
2,000,000
2,430,000

5,667,641
500,000
3,000,000
3,320,000
1,000,000
15,000,000
17,000,000

8,205,502
334,635
2,753,489
3,088,124
697,749
17,025,395
16,930,530

475,000
15,000,000
17,000,000

240,371
17,025,395
16,930,530

553,591,195
16,784,082
97,918,723
114,702,805
14,351,449
511,034,589
532,638,256
12,621,018
511,034,589
532,638,256

25,000
3,000,000
3,025,000

350,000
3,000,000
3,350,000

298,025
2,945,444
3,243,469

6,430,772
180,284,114
186,714,886

499,600
1,802,875
3,051,875
50,000
125,000
800,000
800,000

787,320
2,556,545
3,343,865
100,000
160,000
800,000
800,000

1,180,986
2,938,677
3,370,263
335,481
14,900
1,015,377
1,015,377

34,785,131
121,496,942
154,110,108
4,560,089
5,726,429
30,688,474
39,836,587

709,030
1,875,970
2,506,350

523,562
2,924,481
3,305,742

243,687
1,200,183
1,664,821

19,496,742
94,885,747
112,274,685

$434,496
8,049,268
8,452,514

SOUTH CAROLINA

The Peoples Bank, Beaufort
Bankers Trust of South Carolina, National Association, Columbia
(10635)
Apr. 22 Bankers Trust of South Carolina, National Association, Columbia
(10635)
The Farmers Bank, Loris
The National Bank of South Carolina of Sumter, Sumter (10660)
June 10 The National Bank of South Carolina, Sumter (10660)
Palmetto Bank and Trust Company, Lake City
First National Bank of South Carolina, Columbia (13720)
Dec. 31 First National Bank of South Carolina, Columbia (13720)
The Bank of Walterboro, Walterboro
First National Bank of South Carolina, Columbia (13720)
Dec. 31 First National Bank of South Carolina, Columbia (13720)

220,000
5,000,000
6,000,000
275,000
5,000,000
6,000,000

SOUTH DAKOTA

Oct.

The First National Bank in Bristol, Bristol (10868)
First National Bank of Aberdeen, Aberdeen (2980)
1 First National Bank of Aberdeen, Aberdeen (2980)
VERMONT

Montpelier National Bank, Montpelier (13915)
Vermont National Bank, Brattleboro (1430)
Nov. 29 Vermont National Bank, Brattleboro (1430)
The Northfield National Bank, Northfield (1638)
The First National Bank of Fair Haven, Fair Haven (344).
First National Bank of Springfield, Springfield (122)
Dec. 30 First National Bank of Springfield, Springfield (122)
VIRGINIA

Apr.

Peoples Bank and Trust Company of Fairfax, Fairfax County,
Alexandria
Dominion National Bank, Baileys Cross Roads (14904)
1 Dominion National Bank, Baileys Cross Roads (14904)

* Excludes mergers involving only one operating bank, effected pursuant to corporate reorganization.

201

TABLE

B-18

Mergers resulting inNational banks, by assets of acquiring and acquired banks, 1960—74*
Assets of acquired bank—
Assets of acquiring bankst

Under $10 million
$10 million to $24 9 million
$25 million to $49.9 million
$50 million to $99.9 million
$100 million and over
Total

Acquired
banks
1960-74

Under $10
million

$10 million to $25 million to $50 million to $100 million
and over
$99.9
$49.9
$24.9
million
million
million

92
144
164
181
564

92
126
109
110
231

0
18
43
44
200

0
0
12
24
73

0
0
0
3
26

0
0
0
0
34

1,145*

668

305

109

* Includes all forms of acquisitions involving two or more banks from May 13, 1960 through December 31, 1974.
t In each transaction, the bank with larger total assets was considered to be the acquiring bank.
t Comprises 1,101 transactions, 25 involving three banks, eight involving four banks, and one involving five banks.

TABLE

B-19

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Branches opened for business

Title and location of bank

Local
392

Total

11820
15339
15473
3185
15342
14638
14414
6380
14664
5249
14614
8765
15267
7746
1595
9550
3452
15604
7558
1853

ALABAMA
T h e Albertville National Bank, Albertville
Auburn National Bank of Auburn, Auburn
,
City National Bank of Birmingham, Birmingham
The First National Bank of Birmingham, Birmingham . . .
First National Bank of Butler, Butler
First National Bank of Childersburg, Childersburg
Central Bank of Alabama, National Association, Decatur
First National Bank of Decatur, Decatur
City National Bank of Dothan, Dothan
The First National Bank of Dothan, Dothan
,
First National Bank of Eufaula, Eufaula
The Henderson National Bank of Huntsville, Huntsville ,
Peoples National Bank of Huntsville, Huntsville
The First National Bank of Jasper, Jasper
,
The First National Bank of Mobile, Mobile
The Farmers National Bank of Opelika, Opelika
,
The First National Bank of Opelika, Opelika
Central Bank of Mobile National Association, Prichard .,
The Talladega National Bank, Talladega
The First National Bank of Tuscaloosa, Tuscaloosa

12072
14651
14747
12578

The First National Bank of Anchorage, Anchorage
National Bank of Alaska, Anchorage
Alaska National Bank, Fairbanks
The First National Bank of Ketchikan, Ketchikan

ALASKA

ARIZONA

3728 First National Bank of Arizona, Phoenix
14324 The Valley National Bank of Arizona, Phoenix
* Includes 6 automated teller machines beginning operations in 1974.

202

Outside
branches
794

Total
1,186*

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Branches opened for business

Title and location of bank

Total

Outside
branches

Local

ARKANSAS

10087
16173
14493
13719
15504
7046
12424
9501
1950
15039
2832
14000
13949
13958
13693
16272
15665
12156
15257
12914
14631
11312
15608

Citizens First National Bank of Arkadelphia, Arkadelphia
First National Bank of Sharp County, Ashflat
First National Bank, Batesville
The First National Bank of Conway, Conway
First National Bank of Crossett, Crossett
The First National Bank of El Dorado, El Dorado
National Bank of Commerce of El Dorado El Dorado
The First National Bank of Fordyce Fordyce
The First National Bank of Fort Smith Fort Smith
...
...
.
The First National Bank in Harrison, Harrison
First National Bank of Hot Springs, Hot Springs
The Commercial National Bank of Little Rock, Little Rock
The First National Bank in Little Rock, Little Rock
Union National Bank of Little Rock Little Rock
First National Bank in Mena, Mena
First National Bank of Russellville, Russellville
First National Bank, Siloam Springs
First National Bank in Stuttgart, Stuttgart
Commercial National Bank of Texarkana, Texarkana
Jackson County National Bank in Tuckerman, Tuckerman
Citizens National Bank of Walnut Ridge, Walnut Ridge
The First National Bank of Lawrence County at Walnut Ridge, Walnut Ridge
Fidelity National Bank of West Memphis West Memphis

14695
15434
11282
15453
14823
16139
15305
2491
6919
6268
15532
16154
15349
3050
13044
9655
1741
15660
2158
15217
15180

City National Bank, Beverly Hills
Commercial National Bank, Buena Park
The First National Bank of Cloverdale, Cloverdale . .
Escondido National Bank, Escondido
...
Valley National Bank, Glendale, Glendale
Foothill National Bank, Glendora
Valley Bank, National Association, Livermore
Security Pacific National Bank, Los Angeles
Central Bank, National Association, Oakland
First National Bank and Trust Company, Ontario
Commercial and Farmers National Bank, Oxnard
Delta National Bank, Riverbank
Valley National Bank, Salinas
Southern California First 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
Tahoe National Bank, South Lake Tahoe
Security National Bank, Walnut Creek

7904
2355
3879
15332
14384
13624

The First National Bank in Alamosa, Alamosa
The National State Bank of Boulder, Boulder
The First National Bank, Canon City Colorado, Canon City
The First National Bank of Bear Valley, Denver
The First National Bank in Golden, Golden ..
First National Bank in Loveland, Loveland

780
335
14750
1338
16125
2
15549
16006
497

The City National Bank of Connecticut, Bridgeport
The Connecticut National Bank, Bridgeport
First National Bank of Enfield, Enfield
Hartford National Bank and Trust Company, Hartford
National Industrial Bank of Connecticut, Meriden
The First New Haven National Bank, New Haven
Citizens National Bank of Southington, Southington
Liberty National Bank, Stamford
The First National Bank of Suffield, Suffield

1
0
1
0
0
1
1
1
1
1
0
3
1
3
1
1
1
1
0
0
0
1
1

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

1
1
1
1
1
1
1
1
1
1
1
3
1
3
1
1
1
2
1
1
1
1
1

0
0
0
0
0
0
0
1

1
1
1
1
1
1
1
14
1
2
1
1
1
1
27
1
9
8
3
1
1

1
15
1
2
2
1
1
1
27
1
10
9
4
1
2

0
0
0
0
0
0

1
1
1
1
1
1

2
2
0
1
1
2
0
0
1

2
2
1
1
1
2
1
1
1

CALIFORNIA

....

0
1
...

o
o
o
0

...

o1
1
1
0
1

COLORADO

CONNECTICUT

0
0
1
0
0

1
1
0

203

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Local

DISTRICT OF COLUMBIAt

15656
15208
3425
15605
5046
3275

McLachlen National Bank, District of Columbia
Madison National Bank, District of Columbia
The National Bank of Washington, District of Columbia
National Savings and Trust Company, District of Columbia
The Riggs National Bank of Washington, D.C., District of Columbia . . .
Union Trust Company of the District of Columbia, District of Columbia

15425
14556
15050
16008
15878
6888
14923
11038
14845
15103
14639
15043
15062
9007
14902
15107
14«44
13352
14714
14897
14827
15071
15270
13437
14767

Second National Bank of Clearwater, Clearwater
Sun First National Bank of Delray Beach, Delray Beach
Barnett Bank of Fort Myers, National Association, Fort Myers
Hollywood National Bank, Hollywood
Citizens First National Bank of Citrus County, Inverness
The Atlantic National Bank of Jacksonville, Jacksonville
Sun First National Bank of Lake Wales, Lake Wales
Sun First National Bank of Leesburg, Leesburg
Sun First National Bank of Melbourne, Melbourne
First National Bank of Merritt Island, Merritt Island
Peoples First National Bank of Miami Shores, Miami Shores
First National Bank of New Port Richey, New Port Richey
Sun Bank of East Orlando, National Association, Orlando
The Citizens and Peoples National Bank of Pensacola, Pensacola
Florida First National Bank at Port St. Joe, Port St. Joe
National Bank Gulf Gate, Sarasota
National Bank of Sarasota, Sarasota
Palmer First National Bank and Trust Company of Sarasota, Sarasota .
Barnett Bank of St. Petersburg, National Association, St. Petersburg ..
The National Bank of St. Petersburg, St. Petersburg
Pan American Bank of Tampa, National Association, Tampa
First National Bank of Venice, Venice
Barnett Bank of Cypress Gardens National Association, Winter Haven .
The Exchange National Bank of Winter Haven, Winter Haven
Barnett Bank of Winter Park, National Association, Winter Park

1559
9617
15789
15541
14499
4691
15148
14817
7616
11936
15373
10302
13068
15616
9302

The First National Bank of Atlanta, Atlanta
The Fulton National Bank of Atlanta, Atlanta
Mercantile National Bank, Atlanta
The National Bank of Georgia, Atlanta
The Commercial National Bank, Cedartown
The National Bank and Trust Company of Columbus, Ga., Columbus ..
First National Bank of Newton County, Covington
National Bank of Fort Benning, Fort Benning
The Gainesville National Bank, Gainesville
First National Bank of Gwinnett County, Lawrenceville
First National Bank of Houston County, Perry
The National City Bank of Rome, Rome
The Citizens and Southern National Bank, Savannah
The Security National Bank, Smyrna
The First National Bank of Thomson, Thomson

FLORIDA

GEORGIA

IDAHO

16237 Bank of Idaho, N.A., Boise
14444 First Security Bank of Idaho, National Association, Boise .
1668 The Idaho First National Bank, Boise
ILLINOIS

12779
15459
4735
14752
14463
14416
15458
14346

First National Bank of Blue Island, Blue Island
Seaway National Bank of Chicago, Chicago
The Elgin National Bank, Elgin
The First National Bank of Lincolnwood, Lincoln wood
First National Bank, Marshall
Central National Bank of Mattoon, Mattoon
Midwest National Bank of Moline, Moline
The Ogle County National Bank of Oregon, Oregon . . .

t Includes 1 non-National bank in Washington, D.C.

204

Branches opened for business

Outside
branches

Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business

Local

Outside
branches

Total

INDIANA

4675
14515
206
12132
12444
14468
13759
984
869
16018
2612
15784
13717
14921
9756
4678
4800
7946
13987
12028
47
13888
3842

First National Bank of Madison County, Anderson
First National Bank of Angola, Angola
First National Bank, Elkhart
The National City Bank of Evansville, Evansville
Old National Bank in Evansville, Evansville
Gary National Bank, Gary
American Fletcher National Bank and Trust Company, Indianapolis
The Indiana National Bank, Indianapolis
Merchants National Bank & Trust Company of Indianapolis, Indianapolis
Midwest National Bank, Indianapolis
The Peoples National Bank of Lawrenceburg, Lawrenceburg
Citizens National Bank of Grant County, Marion
First National Bank in Marion, Marion
American National Bank and Trust Company of Muncie, Muncie
The American National Bank of Noblesville, Noblesville
The First National Bank of North Vernon, North Vernon
The Farmers National Bank of Shelby ville, Shelby ville
The Shelby National Bank, Shelbyville
The National Bank and Trust Company of South Bend, South Bend
The First National Bank of Spurgeon, Spurgeon
Terre Haute First National Bank, Terre Haute
The First National Bank in Wabash, Wabash
The Peoples National Bank and Trust Company, Washington

8603
8725
13321
14746
16324
16197
3420

The Peoples National Bank of Albia, Albia
Okey-Vernon First National Bank, Corning
Central National Bank & Trust Company of Des Moines, Des Moines
National Bank of Des Moines, Des Moines
Valley National Bank, Des Moines
Second National Bank, Eldora
The Farmers National Bank of Webster City, Webster City

2758
11056
7285
6494
3885
13801
3849
15503
3475
4742
12490

The Exchange National Bank and Trust Company of Atchison, Atchison
The American National Bank of Baxter Springs, Baxter Springs
First National Bank in Dodge City, Dodge City
First National Bank & Trust Company, El Dorado
The First National Bank of Hays City, Hays
Security National Bank of Kansas City, Kansas City
The Lawrence National Bank and Trust Company, Lawrence
City National Bank of Pittsburg, Pittsburg
The National Bank of Pittsburg, Pittsburg
The First National Bank and Trust Company of Salina, Salina
The Fourth National Bank and Trust Company, Wichita, Wichita

9365
4260
6028
14894
2927
4271
2901
10254
109
14320
1831
14138
12961

The American National Bank and Trust Company of Bowling Green, Bowling Green
The Citizens National Bank of Covington, Covington
The First-Hardin National Bank of Elizabethtown, Elizabethtown
Fort Knox National Bank, Fort Knox
First National Bank and Trust Company, Georgetown
The Farmers National Bank of Lebanon, Lebanon
The Second National Bank and Trust Company of Lexington, Lexington
Cumberland Valley National Bank & Trust Company, London
First National Bank of Louisville, Louisville
,
Liberty National Bank and Trust Company of Louisville, Louisville
The First National Bank and Trust Company, Nicholasville
The Owensboro National Bank, Owensboro
The Peoples First National Bank & Trust Company of Paducah, Paducah

5807
15338
14989
13732
14503

The First National Bank of Abbeville, Abbeville
First National Bank of St. Bernard Parish, Arabi
First National Bank, Covington
First National Bank of Jefferson Parish, Gretna
First National Bank of Houma, Houma

IOWA

KANSAS

KENTUCKY

LOUISIANA

205

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Branches opened for business

Title and location of bank

Outside
branches
LOUISIANA—Continued

13851
13689
14477
14977
14685

First National Bank in St. Mary Parish, Morgan
First National Bank of Commerce, New Orleans
National American Bank of New Orleans, New Orleans
Whitney National Bank of New Orleans, New Orleans
First National Bank of West Monroe, West Monroe

498
1254
2260
941
4128
13768

Bank of Maine, N. A., Augusta
The Ocean National Bank of Kennebunk, Kennebunk
Northeast Bank N.A. of Lewiston and Auburn, Lewiston
Canal National Bank, Portland
Maine National Bank, Portland
Northern National Bank, Presque Isle

15314
1244
1413
13745
381
15051
8606
13840
14564
15365
14937
15154

Aberdeen National Bank, Aberdeen
The Farmers National Bank of Annapolis, Annapolis
,
The First National Bank of Maryland, Baltimore
Maryland National Bank, Baltimore
The First National Bank and Trust Company of Western Maryland, Cumberland
The Central National Bank of Maryland, Hillandale
The First National Bank of St. Mary's at Leonardtown, Leonardtown
The Cecil National Bank at Port Deposit, Port Deposit
State National Bank of Maryland, Rockville
University National Bank, Rockville
,
American National Bank of Maryland, Silver Spring
Peoples National Bank of Maryland, Suitland

1049
200
15509
4771
590
1320
2153
474
10059
7452
13241
383
1194
726
308
15005
79

Northeast National Bank, Amesbury
The First National Bank of Boston, Boston
The National Shawmut Bank of Boston, Boston
The County Bank, N.A., Cambridge
The Fall River National Bank, Fall River
The Falmouth National Bank, Falmouth
First Safety Fund National Bank, Fitchburg
First National Bank of Franklin County, Greenfield
Merchants National Bank of Leominster, Leominster
Security National Bank, Lynn
Needham National Bank, Needham
Pioneer National Bank-Hampshire, Northampton
Rockport National Bank, Rockport
Merchants-Warren National Bank of Salem, Salem
Third National Bank of Hampden County, Springfield
Hampshire National Bank of South Hadley, South Hadley
Worcester County National Bank, Worcester

15164
16185
14185
14641
16371
1924
16157
15801
14948
13671
15446
15575
15392
14062
14560
7676
14187
13741

Huron Valley National Bank, Ann Arbor
The American National Bank in Battle Creek, Battle Creek
Security National Bank of Battle Creek, Battle Creek
Peoples National Bank & Trust Company of Bay City, Bay City
Commercial National Bank, Cassopolis
The Southern Michigan National Bank of Coldwater, Coldwater
Michigan National Bank-Dearborn, Dearborn
First Independence National Bank of Detroit, Detroit
Michigan National Bank of Detroit, Detroit
National Bank of Detroit, Detroit
First National Bank of Fenton, Fenton
Union Bank and Trust Company, National Association, Grand Rapids
Grand Valley National Bank, Grandville
Hillsdale County National Bank, Hillsdale
First National Bank and Trust Company of Holland, Holland
Houghton National Bank, Houghton
The Ionia County National Bank of Ionia, Ionia
The National Bank of Jackson, Jackson

MAINE

MARYLAND

MASSACHUSETTS

MICHIGAN

206

,
,

Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business

Local

Outside
branches

Total

MICHIGAN—Continued

13820
15444
14280
390
12697
3256
15899
13739
15274
3886
3378
15527
15167
15611
13807

The American National Bank and Trust Company of Michigan, Kalamazoo
Michigan National Bank-West Metro, Livonia
The First National Bank at Manistique, Manistique
First National Bank & Trust Company of Marquette, Marquette
The Dart National Bank of Mason, Mason
The First National Bank of Menominee, Menominee
West Oakland Bank, National Association, Novi
Community National Bank of Pontiac, Pontiac
National Bank of Rochester, Rochester
The First National Bank of St. Ignace, St. Ignace
Clinton National Bank and Trust Company, St. Johns, St. Johns
Michigan National Bank-Oakland, Southfield
National Bank of Southfield, Southfield
First National Bank of Warren, Warren
The National Bank of Ypsilanti, Ypsilanti

14949
11861
14805
16128
203
15659

Franklin National Bank of Minneapolis, Minneapolis
The Marquette National Bank of Minneapolis, Minneapolis
Zapp National Bank of St. Cloud, St. Cloud
Shelard National Bank, St. Louis Park
The First National Bank of Saint Paul, Saint Paul
First National Bank of Wayzata, Wayzata

14487
5176
15539
15661
15516
15548
10523
11898
13551
13722
15672
9865
3656
16194
3430
12587

MISSISSIPPI
Gulf National Bank, Gulfport
First Mississippi National Bank, Hattiesburg
Southern National Bank of Hattiesburg, Hattiesburg
First National Bank, Hernando, Mississippi, Hernando
Citizens National Bank, Jackson
Deposit Guaranty National Bank, Jackson
First National Bank of Jackson, Jackson
The Commercial National Bank and Trust Company of Laurel, Laurel
First National Bank in Meridian, Meridian
Britton & Koontz First National Bank, Natchez
First National Bank of Jackson County, Ocean Springs
The First National Bank of Oxford, Oxford
National Bank of Commerce of Mississippi, Starkville
Peoples Bank of Mississippi, National Association, Union
Merchants National Bank, Vicksburg, Mississippi, Vicksburg
The Delta National Bank of Yazoo City, Yazoo City

4611
13162
11472
5973
6272
15176
4933

The First National Bank of Cape Girardeau, Cape Girardeau
First National Bank and Trust Company of Joplin, Joplin
Columbia Union National Bank and Trust Company, Kansas City.
The First National Bank of Monett, Monett
The American National Bank of St. Joseph, St. Joseph
Belt National Bank of St. Joseph, St. Joseph
The Trenton National Bank, Trenton

2357
8328
13408
2848
14340

The First National Bank & Trust Company of Beatrice, Beatrice
First National Bank and Trust Company of Columbus, Columbus
First National Bank & Trust Company of Fremont, Fremont
The Fremont National Bank, Fremont
The Commercial National Bank & Trust Company, Grand Island, Nebraska, Grand
Island
The First National Bank of Grand Island, Grand Island
The Overland National Bank of Grand Island, Grand Island .
First National Bank, Hastings, Hastings
First National Bank & Trust Company of Lincoln, Lincoln ..
The Delay First National Bank & Trust Company, Norfolk..
Northwestern National Bank of Norfolk, Norfolk
The First National Bank of Omaha, Omaha
The United States National Bank of Omaha, Omaha

MINNESOTA

MISSOURI

NEBRASKA

2779
14018
13515
1798
13582
14339
209
2978

207

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business
Local

NEVADA

7038 First National Bank of Nevada, Reno, Nevada, Reno
15645 Nevada National Bank, Reno
14406 Security National Bank of Nevada, Reno
NEW HAMPSHIRE

2443
4037
1070
15563
1179

The Franklin National Bank, Franklin
Laconia Peoples National Bank and Trust Company, Laconia
The Souhegan National Bank of Milford, Milford
Indian Head National Bank of Nashua, Nashua
First National Bank of Peterborough, Peterborough

12617
15913
9498
1222
13203
1209
12984
15709
15430
1326
1436
15570
399
16169
4147
374
16035
13127
1191
1113
15360
1452
1316
587
14240
12732
15835
11759
5005
12917
16129
13898
4365
329
1327
13125
14673
10440
12606

The Atco National Bank, Atco
Shore National Bank, Brick Township
The Farmers and Merchants National Bank of Bridgeton, Bridgeton
First National State Bank/Mechanics, Burlington Township
Third National Bank of New Jersey, Camden
Heritage Bank National Association, Cherry Hill
Friendly National Bank of New Jersey, Cinnaminson
New Jersey Bank (National Association), Clifton
Midlantic National Bank/Raritan Valley, Edison
First National Bank of South Jersey, Egg Harbor Township
The National State Bank, Elizabeth, N.J., Elizabeth
Garden State National Bank, Hackensack
First Peoples National Bank of New Jersey, Haddon Township
The Hamilton Bank, National Association, Hamilton Township
United Jersey Bank/Mid State, National Association, Hazlet
The First Jersey National Bank, Jersey City
First National State Bank of Ocean County, Lakewood Township
Citizens Bank of Marlton, National Association, Marlton
The Burlington County National Bank, Medford
Heritage Bank National Association-Iron, Morristown
Midlantic National Bank/Morris, Morristown
First National State Bank of New Jersey, Newark
Midlantic National Bank, Newark
The National Bank of New Jersey, New Brunswick
First National Bank in Newfield, Newfield
Meadowlands National Bank, North Bergen
Jefferson National Bank, Passaic
Citizens First National Bank of New Jersey, Ridgewood
National Community Bank of Rutherford, Rutherford
The National Bank of Mantua, Sewell
Suburban National/A United Jersey Bank, South Plainfield
First National State Bank of the Jersey Coast, Spring Lake
Midlantic National Bank/Citizens, Tenafly
First National Bank of New Jersey, Totowa
New Jersey National Bank, Trenton
Citizens United Bank, N.A., Vineland
City National Bank, Vineland
Minotola National Bank, Vineland
The Yardville National Bank, Yardville

12485
12924
8132
13438

Albuquerque National Bank, Albuquerque
First National Bank in Raton, Raton
The American National Bank of Silver City, Silver City
Hot Springs National Bank, Truth or Consequences

5178
15758
16203
1301
963
1253

Community National Bank, Addison
Bankers Trust Company of Albany, National Association, Albany
Chase Manhattan Bank of Eastern New York (National Association), Albany
National Commercial Bank and Trust Company, Albany
Union National Bank, Albany
Ballston Spa National Bank, Ballston Spa

NEW JERSEY

NEW MEXICO

NEW YORK

208

Outside
branches

Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business
Outside
branches

15917
10029
9669
13952
10258
15080
1122
8531
5816
11511
8847
13825
13126
2517
8613
6587
11087
15976
15626
13121
11897
598
15922
13956
13314
1106
2370
15558
1461
7703
15569
1354
14734
1887
1090
2151
16089
15641
10781
4230
16050
1040
1226
10258
14763
16047
721
8158
10525
9990
15968

NEW YORK—Continued
Citibank (Suffolk), National Association, Bay Shore
Manufacturers Hanover Trust Company/Suffolk, National Association, Bay Shore . . .
The Bridgehampton National Bank, Bridgehampton
Chase Manhattan Bank of Western New York (National Association), Buffalo
Citibank (Western), National Association, Buffalo
Liberty National Bank and Trust Company, Buffalo
Central National Bank, Canajoharie, Canajoharie
The St. Lawrence National Bank, Canton
Citibank (Eastern), National Association, Castleton-on-Hudson
Marine Midland Tinker National Bank, East Setauket
Deak National Bank, Fleischmanns
The National Bank of Florida, Florida
The First National Bank of Glen Head, Glen Head
Chemical Bank-Eastern, National Association, Greenwich
The First National Bank of Hancock, Hancock
Security National Bank, Hempstead
Long Island National Bank, Hicksville
Citibank (Mid-Western), National Association, Honeoye Falls
The First National Bank of Jamestown, Jamestown
The Mahopac National Bank, Mahopac
The Citizens National Bank of Malone, Malone
The Farmers National Bank of Malone, Malone
Chase Manhattan Bank of Long Island (National Association), Melville
Empire National Bank, Middletown
Nanute National Bank, Nanute
Highland National Bank of Newburgh, Newburgh
The Chase Manhattan Bank (National Association), New York
Community National Bank and Trust Company of New York, New York (Staten Island)
First National City Bank, New York
National Bank of North America, New York
Republic National Bank of New York, New York
The National Bank and Trust Company of Norwich, Norwich
Chemical Bank Hudson Valley, N.A., Nyack
The First National Bank of Olean, Olean
The Oneida Valley National Bank of Oneida, Oneida
Wilber National Bank, Oneonta
Citibank (Central), National Association, Oriskany Falls
Bankers Trust Hudson Valley, National Association, Poughkeepsie
The Red Creek National Bank, Red Creek
The Suffolk County National Bank of Riverhead, Riverhead
Chase Manhattan Bank of Greater Rochester, National Association, Rochester
Chase Manhattan Bank of Mid-Hudson (National Association), Saugerties
The Mohawk National Bank of Schenectady, Schenectady
Citibank (Western), National Association, Silver Creek
Chemical Bank of Suffolk, National Association, Smithtown
Chase Manhattan Bank of Central New York, National Association, Syracuse
Marine Midland Bank-Eastern National Association, Troy
Seaway National Bank, Watertown
National Bank of Westchester, White Plains
Citibank (Mid-Hudson), National Association, Woodbury
Hudson Valley National Bank, Yonkers

11091
15650
13761
14481
13779
4597
14676
6744
10610
13859
10608
16114
15673

The First National Bank of Albermarle, Albemarle
First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
Citizens National Bank of Concord, Concord
The Citizens National Bank in Gastonia, Gastonia
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, Lumberton
The Union National Bank of Oxford, Oxford
The Planters National Bank and Trust Company, Rocky Mount
Columbus National Bank, Whiteville
Wachovia Bank and Trust Company, N.A., Winston-Salem

0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
0
1
0
0
0
0
1
5
0
11
2
14
0
0
1
0
1
0
1
0
1
0
0
0
0
0
1
1
0
0
0
1

2
5
0
3
3
4
1
3
3
2
1
1
1
1
1
4
1
4
0
1
0
2
2
1
1
0
4
1
3
10
4
1
1
0
1
0
3
2
1
0
2
4
1
1
2
1
1
1
2
6
0

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

0
5
8
1
1
0
1
1
2
0
3
0
14

Total

NORTH CAROLINA

209

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Branches opened for business

Title and location of bank

Total

Outside
branches
NORTH DAKOTA

2434
5087
2377
13790
13357
6429

The First National Bank and Trust Company of Bismarck, Bismarck
The Fargo National Bank & Trust Company, Fargo
The First National Bank and Trust Company of Fargo, Fargo
First National Bank in Grand Forks, Grand Forks
Red River National Bank and Trust Company of Grand Forks, Grand Forks
First National Bank in Minot, Minot

15609
14579
5075
3274
6249
14501
15423
4318
786
7621
7745
5065
13923
10
2604
14968
15591
5996
56
829
6938
2360
1064
15456
2036
2577
4^42
3234
9179
15416
14686
13832
1989
14105
5828
3157
2479

Akron National Bank and Trust Company, Akron
First National Bank of Akron, Akron
The Northeastern Ohio National Bank, Ashtabula
The Second National Bank of Bucyrus, Bucyrus
The First National Bank of Burton, Burton
The United National Bank & Trust Company, Canton
The Capital National Bank, Cleveland
Central National Bank of Cleveland, Cleveland
National City Bank, Cleveland
The City National Bank & Trust Company of Columbus, Columbus
The Huntington National Bank of Columbus, Columbus
The Ohio National Bank of Columbus, Columbus
Coshocton National Bank, Coshocton
Third National Bank and Trust Company of Dayton, Ohio, Dayton
Winters National Bank and Trust Co., Dayton
First National Bank of Elyria, Elyria
Tri-County National Bank, Fostoria
People's National Bank, Georgetown
The First National Bank and Trust Company of Hamilton, Hamilton
The Second National Bank of Hamilton, Hamilton
Harrison County National Bank, Hopedale
The Lebanon-Citizens National Bank, Lebanon
The First National Bank of London, London
The Central Security National Bank of Lorain County, Lorain
The Vinton County National Bank of McArthur, McArthur
First National Bank of Mansfield, Mansfield
The Old Phoenix National Bank of Medina, Medina
Clermont National Bank, Milford
The Park National Bank, Newark
Mid-American National Bank and Trust Company, North Wood
The Lake County National Bank of Painesville, Painesville
The National Bank of Portsmouth, Portsmouth
The Quaker City National Bank, Quaker City
Lagonda National Bank of Springfield, Springfield
The First National Bank of Wadsworth, Wadsworth
The First National Bank of Wapakoneta, Wapakoneta
The Second National Bank of Warren, Warren

1
0
1
1
1
1

0
1
0
0
0
0

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

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

1
1
1

0
0
0

0
0

2
6

1
2
0
0
0
0
0
0
0

2
0
4
2
84
1
1
1
1

OHIO

,
,

OKLAHOMA

6258 First National Bank in Bartlesville, Bartlesville
13751 The Citizens National Bank & Trust Company, Okmulgee, Oklahoma, Okmulgee
15750 National Bank of Sallisaw, Sallisaw
OREGON

1553 First National Bank of Oregon, Portland
4514 United States National Bank of Oregon, Portland
PENNSYLVANIA

373
6645
539
723
1
10128
5307
8421
2137

210

The First National Bank of Allentown, Allentown
The Merchants National Bank of Allentown, Allentown
The Philadelphia National Bank, Ardmore
Central Penn National Bank, Bala-Cynwyd
First Pennsylvania Bank N.A., Bala-Cynwyd
The Kishacquillas Valley National Bank of Belleville, Belleville
First National Bank of Western Pennsylvania, Berlin
The Blue Ball National Bank, Blue Ball
The National Bank of Boyertown, Boyertown

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business
Local

Outside
branches

Total

PENNSYLVANIA—Continued

15422
355
661
5019
9868
1233
5118
2515
8854
7702
580
644
31
4965
14098
252
6158
13781
2634
694
680
3147
912
11244
5599
12
870
9511
562
14542
2222
6301
252
649
1663
2366
13947
6483
2333
12261
1237
4984
4355
5034
30
14344
732
175
14082
5184

Provident National Bank, Bryn Mawr
Southeast National Bank of Pennsylvania, Chester
The Downingtown National Bank, Downingtown
Deposit National Bank, DuBois
The First National Bank of Dunmore, Dunmore
Easton National Bank and Trust Company, Easton
The Northampton National Bank of Easton, Easton
The Ephrata National Bank, Ephrata
The Citizens National Bank of Evans City, Evans City
Peoples National Bank of Susquehanna County, Hallstead
The Commonwealth National Bank, Harrisburg
The Honesdale National Bank, Honesdale
Penn Central National Bank, Huntingdon
Union National Bank & Trust Company of Huntingdon, Huntingdon
National Bank of the Commonwealth, Indiana
Pittsburgh National Bank, Jeannette
The First National Bank of Jermyn, Jermyn
United States National Bank in Johnstown, Johnstown
The Fulton National Bank of Lancaster, Lancaster
National Central Bank, Lancaster
Lebanon Valley National Bank, Lebanon
The National Bank of Malvern, Malvern
The Manheim National Bank, Manheim
The First National Bank of Mapleton, Mapleton
The Mars National Bank, Mars
The First National Bank of Pennsylvania, Meadville
Marine National Bank, Meadville
The Farmers National Bank and Trust Company of Millheim, Millheim . . . .
First National Bank of Lawrence County at New Castle, New Castle
Cumberland County National Bank and Trust Company, New Cumberland
Equibank N.A., Pittsburgh
Mellon Bank, N.A., Pittsburgh
Pittsburgh National Bank, Pittsburgh
The Miners National Bank of Pottsville, Pottsville
Pennsylvania National Bank and Trust Company, Pottsville
The Quakertown National Bank, Quakertown
Scranton National Bank, Scranton
The First National Bank of Slippery Rock, Slippery Rock
Union National Bank and Trust Company of Souderton, Souderton
The Peoples National Bank of Central Pennsylvania, State College
First National Trust Bank, Sunbury
The First National Bank of Troy, Troy
First Blair County National Bank of Tyrone, Tyrone
Gallatin National Bank, Uniontown
First Eastern Bank, National Association, Wilkes-Barre
The Hanover National Bank of Wilkes-Barre, Wilkes-Barre
The Wyoming National Bank of Wilkes-Barre, Wilkes-Barre
Fidelity National Bank of Pa., Williamsport
Citizens National Bank in Windber, Windber
Southern Pennsylvania National Bank, York

14425
2044
10635
13720
15134
10085
13918
10660

The Citizens and Southern National Bank of South Carolina, Charleston
The South Carolina National Bank, Charleston
Bankers Trust of South Carolina, N.A., Columbia
First National Bank of South Carolina, Columbia
Horry County National Bank, Loris
Marion National Bank, Marion
First National Bank in Orangeburg, Orangeburg
The National Bank of South Carolina, Sumter

3326
2980
15639
10592

Aberdeen National Bank, Aberdeen
First National Bank of Aberdeen, Aberdeen
United National Bank, Rapid City
Northwestern National Bank of Sioux Falls, Sioux Falls

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

3
1
1
1
0
1
1
1
1
1
6
0
1
1
2
5
1
1
1
2
1
1
1
1
1
2
1
1
1
3
1
2
2
0
3
0
0
1
1
0
2
1
1
0
1
1
1
3
0
1

0
1
0
0
0
1
0
0

7
3
8
7
1
0
1
4

1
0
0
1

0
1
1
0

SOUTH CAROLINA

SOUTH DAKOTA

211

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

TENNESSEE

14611
9027
6930
13948
8443
14657
2049
12080
336
13681
14736
3032
13103
14828
16076
3530
16410

American National Bank and Trust Company of Chattanooga, Chattanooga .
Hamilton National Bank of Polk County, Copperhill
The First National Bank of Dickson, Dickson
Union National Bank of Fayetteville, Fayetteville
The Harpeth National Bank of Franklin, Franklin
First Tennessee National Bank, Kingsport
Park National Bank of Knoxville, Knoxville
Hamilton National Bank of Loudon, Loudon
The First National Bank of Memphis, Memphis
National Bank of Commerce, Memphis
The National Bank of Murfreesboro, Murfreesboro
First American National Bank of Nashville, Nashville
Third National Bank in Nashville, Nashville
National Bank of Newport, Newport
Citizens National Bank, Sevierville
The Peoples National Bank of Shelbyville, Shelbyville
First Tennessee National Bank, White's Creek
UTAH

2597 First Security Bank of Utah, National Association, Ogden
4341 Zions First National Bank, Salt Lake City
VERMONT

7267
1430
1197
3080
1195
194
2274
122
3484
1133

The Bradford National Bank, Bradford
Vermont National Bank, Brattleboro
The Merchants National Bank of Burlington, Burlington
The Factory Point National Bank of Manchester Center, Manchester Center
The National Bank of Middlebury, Middlebury
Catamount National Bank, North Bennington
The Randolph National Bank, Randolph
First National Bank of Springfield, Springfield
The First National Bank of White River Junction, White River Junction
The Woodstock National Bank, Woodstock
VIRGINIA

14904
11976
16246
12229
16184
6389
1582
16313
12267
11694
15315
6206

1558
15819
14904
5032
7026
15139
10524
10194
9885
11381
6782
1111
15530
15027
11817
2737
11569
1824
14824
10973

212

Branches opened for business
Local

Dominion National Bank, Baileys Cross Roads
The First National Bank of Bassett, Bassett
The First National Exchange Bank of Montgomery County, Blacksburg
The National Bank of Blacksburg, Blacksburg
First & Merchants National Bank of Tidewater, Chesapeake
The National Bank of Fairfax, Fairfax County
The National Bank of Fredericksburg, Fredericksburg
Fidelity National Bank, Halifax County
The Old Point National Bank of Phoebus, Hampton
Valley National Bank, Harrisonburg
Fairfield National Bank, Highland Springs
The Page Valley National Bank of Luray, Luray
United Virginia Bank/First National, Lynchburg
Virginia National Bank/Lynchburg, Lynchburg
Dominion National Bank, P.O. McLean
First Virginia Bank-Manassas National, Manassas
The First National Bank of Martinsville and Henry County, Martinsville
The First National Bank, Narrows
Citizens National Bank, New Market
United Virginia Bank/Seaboard National, Norfolk
Virginia National Bank, Norfolk
American National Bank, Portsmouth
The First and Merchants National Bank of Radford, Radford
First & Merchants National Bank, Richmond
Metropolitan National Bank, Richmond
Richmond National Bank, Richmond
Colonial-American National Bank, Roanoke
The First National Exchange Bank of Virginia, Roanoke
The Round Hill National Bank, Round Hill
The Farmers National Bank of Salem, Salem
Fairfax County National Bank, Seven Corners
The Farmers & Merchants National Bank of Stanley, Stanley

Outside
branches

Total

TABLE

B-19—Continued

Domestic branches entering the National Banking System, by de novo opening, merger, or conversion, by
States, calendar 1974
Charter
No.

Title and location of bank

Branches opened for business
Outside
Total
Local
branches

VIRGINIA—Continued

1620 United Virginia Bank/National Valley, Staunton
651 United Virginia Bank/National, Vienna
6084 Farmers and Merchants National Bank, Winchester
15984 First & Merchants National Bank of the Peninsula, York County

0
10
1
1

1
10
1
1

WASHINGTON

13351
3417
11280
4668

The First American National Bank of Port Townsend, Port Townsend
Pacific National Bank of Washington, Seattle
Seattle-First National Bank, Seattle
Old National Bank of Washington, Spokane

16002
4643
7681
13811
16097
7998
10480
15406
8983

Raleigh County National Bank, Beckley
The First National Bank of Bluefield, Bluefield
The Union National Bank of Clarksburg, Clarksburg
First National Bank in Fairmont, Fairmont
Citizens National Bank of Follansbee, Follansbee
The National Bank of Summers of Hinton, Hinton
Albright National Bank of Kingwood, Kingwood
First National Bank of West Hamlin, West Hamlin
The First National Bank and Trust Company of Wheeling, Wheeling .

14397
2125
12124
1602
13086
3936

The
The
The
The
The
The

WEST VIRGINIA

WISCONSIN

Baraboo National Bank, Baraboo
First National Bank of Chippewa Falls, Chippewa Falls
First National Bank of Eagle River, Eagle River
First National Bank of Neenah, Neenah
Oshkosh National Bank, Oshkosh
First National Bank of the City of Superior, Superior

213

TABLE

B-20

Domestic branches of National banks closed, by States, calendar 1974
Charter
No.

Branches closed

Title and location of bank

Outside
branches

Local
Total

Total

317

377

0
1

1
1

1
0
0
0
0
1
0
0

1
2
3
2
1
0
4
9
1

2
2
3
2
1
1
4
9
1

1
1

0
0

1
1

0
0

1
1

0
1

1
1

1
0
0
0
1

0
1
2
1
0

1
1
2
1
1

2
0
1

1
1
0

3
1
1

0
6

1
6

ALABAMA

3041 The First National Bank of Anniston Anniston
11846 The First National Bank of Russellville Russellville

ARIZONA

3728 First National Bank of Arizona, Phoenix
CALIFORNIA

13348
15557
2491
15174
15349
3050
13044
1741
15660

Beverly Hills National Bank, Beverly Hills
Imperial Valley National Bank, El Centro
Security Pacific National Bank, Los Angeles
Sierra National Bank, Petaluma
Valley National Bank, Salinas
First National Bank, San Diego
Bank of America National Trust and Savings Association, San Francisco
Crocker National Bank, San Francisco
Wells Fargo Bank, National Association, San Francisco

CONNECTICUT

1314 The Clinton National Bank, Clinton
GEORGIA

9617 The Fulton National Bank of Atlanta, Atlanta
15148 First National Bank of Newton County, Covington

.
.

.
..

ILLINOIS

5638 The First National Bank of Dundee Dundee
14372 First National Bank in Harvey Harvey
.

INDIANA

206 The First National Bank, Elkhart
869 Merchants National Bank and Trust Company of Indianapolis, Indianapolis
IOWA

15524 First National Bank of Eldora Eldora
KENTUCKY

718 The First National Bank and Trust Company of Covington, Covington
14320 Liberty National Bank and Trust Company of Louisville Louisville
MASSACHUSETTS

15509
2504
13222
5944
2108

The National Shawmut Bank of Boston, Boston
First County National Bank, Brockton . . . .
The Buzzards Bay National Bank, Buzzards Bay
United National Bank, North Attleboro
The Union Market National Bank of Watertown, Watertown

MICHIGAN

13671 National Bank of Detroit, Detroit
13820 The American National Bank and Trust Company of Michigan, Kalamazoo
15167 National Bank of Southfield, Southfield
MISSISSIPPI

15559 First National Bank of Greenwood Greenwood
5176 First Mississippi National Bank Hattiesburg
MISSOURI

6272 The American National Bank of St. Joseph, St. Joseph
NEW JERSEY

4365 Midlantic National Bank/Citizens, Tenafly
NEW MEXICO

14081 The First National Bank in Tucumcari, Tucumcari

214

TABLE

B-20—Continued

Domestic branches of National banks closed, by States, calendar 1974
Charter
No.

Branches closed

Title and location of bank
Local

Outside
branches

Total

NEW YORK

12997
13956
13955
2370
1461
7703
465

Franklin National Bank, Brooklyn
Empire National Bank, Middletown
First Westchester National Bank, New Rochelle
The Chase Manhattan Bank (National Association), New York
First National City Bank, New York
National Bank of North America, New York
Marine Midland Bank of Southeastern New York, N.A., Poughkeepsie ..

15650
13761
14676
10610
10608
15673

First Union National Bank of North Carolina, Charlotte
North Carolina National Bank, Charlotte
Bank of North Carolina, National Association, Jacksonville
Southern National Bank of North Carolina, Lumberton
The Planters National Bank and Trust Company, Rocky Mount
Wachovia Bank and Trust Company, N.A., Winston-Salem

100
1
11
0
0
2
1

NORTH CAROLINA

NORTH DAKOTA

2377 The First National Bank and Trust Company, Fargo
13790 First National Bank in Grand Forks, Grand Forks
OKLAHOMA

15350

Republic National Bank of Tulsa, Tulsa

247
1
13868
15422
4923
2634
5773
2222
6301
705
478
77
5184

The First National Bank of Altoona, Altoona
First Pennsylvania Bank N.A., Bala-Cynwyd
Blairsville National Bank, Blairsville
Provident National Bank, Bryn Mawr
The Farmers National Bank of Ephrata, Ephrata
The Fulton National Bank of Lancaster, Lancaster
Farmers First National Bank, Lititz
Equibank N.A., Pittsburgh
Mellon Bank, N.A., Pittsburgh
The Union National Bank of Pittsburgh, Pittsburgh
The First National Bank of Pittston, Pittston
Northeastern Pennsylvania National Bank and Trust Company, Scranton
Southern Pennsylvania National Bank, York

PENNSYLVANIA

5
1
0
1
0
15
9
2
0
1
1
10
6

SOUTH CAROLINA

10635 Bankers Trust of South Carolina, N.A., Columbia
13720 First National Bank of South Carolina, Columbia

80
0

VERMONT

13755 National White River Bank in Bethel, Bethel
1197
The Merchants National Bank of Burlington, Burlington
VIRGINIA

14904
1522 Dominion National Bank, Baileys Cross Roads
15315 The Fidelity National Bank, Lynchburg
11817 Fairfield National Bank of Highland Springs, Richmond
2737 Colonial-American National Bank, Roanoke
The First National Exchange Bank of Virginia, Roanoke
VIRGIN ISLANDS

14335 Virgin Islands National Bank, St. Thomas
WASHINGTON

15223 Valley National Bank of Auburn, Auburn
14502 Guaranty National Bank of White Center, White Center
WISCONSIN

2125 The First National Bank of Chippewa Falls, Chippewa Falls
6604 First Wisconsin National Bank of Oshkosh, Oshkosh

215

TABLE B-21

Principal assets, liabilities, and capital accounts of National banks, by deposit size, year-end 1973 and 1974
[Dollar amounts in millions]
Deposits

Securities*
Number
of banks

Total
assets

Cash and
cash
items

Loans *
Total

U.S.
Treasury
securities

Fixed
assets
Total

Demand

Time
and
savings

Capital
stock

Capital
notes and
debentures

Surplus,
undivided
profits,
and

1974
Deposit size
Less than $1.0..
$1.0 to $1.9 . . . .
$2.0 to $4.9 . . . .
$5.0 to $9.9 . . . .
$10.0 to $24.9 ..
$25.0 to $49.9 ..
$50.0 to $99.9 ..
$100.0 to $499.9
$500.0 and over.
Total

20
54
360
743
1,666
888
490
369
118

35
120
1,575
6,387
30,980
35,590
38,858
91,221
329,656

5
18
212
776
3,563
4,158
4,981
13,758
49,086

6
42
693
3,052
15,626
18,584
20,619
48,426
190,803

8
27
448
1,922
9,248
10,022
10,383
21,045
53,898

7
16
201
689
2,784
2,622
2,550
5,164
13,408

3
6
39
115
550
678
785
1,827
5,048

13
84
1,344
5,640
27,466
31,177
33,767
76,712
255,022

8
49
625
2,403
10,793
12,066
13,162
33,171
108,114

5
35
719
3,238
16,673
19,111
20,605
43,541
146,907

11
15
61
138
525
641
669
1,584
4,706

0
0
1
7
53
85
126
369
1,618

10
19
133
426
1,829
1,944
1,996
4,449
14,419

4,708

534,422

76,557

297,851

107,001

27,441

9,051

431,225

180,391

250,834

8,350

2,259

25,225

15
51
371
799
1,659
847
457
348
114

20
104
1,572
6,743
30,249
33,865
36,140
87,337
293,570

4
17
201
826
3,571
4,054
4,648
12,977
44,426

3
34
686
3,192
15,060
17,750
19,041
46,568
169,238

5
26
468
2,090
9,359
9,792
9,874
20,454
52,616

4
17
242
864
3,243
2,948
2,801
5,659
13,119

1
4
31
106
503
598
699
1,580
4,621

9
81
1,360
5,997
26,985
29,830
31,637
73,692
226,289

6
50
645
2,726
11,168
12,133
13,111
33,476
105,731

3
32
715
3,271
15,817
17,697
18,526
40,216
120,558

5
8
52
131
506
590
627
1,502
4,519

0
0
1
6
45
86
111
420
1,531

5
13
124
427
1,713
1,770
1,805
4,087
13,051

4,661

489,600

70,724

271,572

104,684

28,897

8,143

395,880

179,046

216,835

7,940

2,200

22,995

1973
Deposit size
Less than $1.0..
$1.0 to $1.9 . . . .
$2.0 to $4.9 . . . .
$5.0 to $9.9 . . . .
$10.0 to $24.9 ..
$25.0 to $49.9 ..
$50.0 to $99.9 ..
$100.0 to $499.9
$500.0 and over.
Total

* Loans and securities figures are shown gross, that is, reserves are not deducted from the respective assets.
NOTE: Data may not add to totals because of rounding.

TABLE B-22

Dates of reports of condition of National banks, 1914—1974
[For dates of previous calls see Annual Report for 1920, vol. 2, Table no. 42, p. 150]
Year

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
I960
1961
1962
1963
1964 ....
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

Feb.

Mar.

Apr.

4
4
7
5
4
4

28
21

June

1
1
1
10
12
4
28

May

31
6
12
23
28
27
27
25
5
4
4
31
7
29
26
4
4
13
20
12
11
24
9
31
20
15
11
10
14
4
12
15
12
26
18
15
26
5
25
18
30
30
20
18
28
24

30
23
30
20
29
30
30
30
30
30
30
30
30
30
30
29
30
30
30
30
30
29
30
30
30
30
29
30
30
30
30
30
29
30
30
30
30
30
30
30
30
30
30
6
23
10
15
30
30
29
30
30
30
30
29
30
30
30
30
30
30

July

Aug.

Sept.
12
2
12
11

Oct.

Nov.

Dec.

31
10
17
20
1
17
15

31
12
8
6
15
14
10
28
10
3
4
24
29
30
25
17

1
28
2
24
18
30
6
1
5
30
26

4
10
7
5
11

24
6
3
27
28
30

1
13

20
4
30
21
28
30
10
17
15

31
31
27
31
31
31
29
31
29
31
31
31
31
31
31
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
30
31
31
31
31
31
30
31
31
31
31
31
31
31
31
31
31
30
28
20
31
31
31
30
31
31
31
31
31
31
31

See notes on next page.

217

NOTES

Act of Feb. 25, 1863, provided for reports of condition on the
1st of each quarter before commencement of business.
Act of June 3, 1864—1st Monday of January, April, July, and
October, before commencement of business, on form prescribed
by Comptroller (in addition to reports on 1st Tuesday of each
month showing condition at commencement of business in respect
to certain items; i.e., loans, specie, deposits, and circulation).
Act of Mar. 3, 1869, not less than 5 reports per year, on form
prescribed by Comptroller, at close of business on any past date
by him specified.
Act of Dec. 28, 1922, minimum number of calls reduced from
5 to 3 per year.
Act of Feb. 25, 1927, authorized a vice president or an assistant
cashier designated by the board of directors to verify reports of
condition in absence of president and cashier.
Act of June 16, 1933, requires each National bank to furnish
and publish not less than 3 reports each year of affiliates other
than member banks, as of dates identical with those for which the
Comptroller shall during such year require reports of condition of
the bank. The report of each affiliate shall contain such information as in the judgment of the Comptroller shall be necessary to
disclose fully the relations between the affiliate and the bank and
to enable the Comptroller to inform himself as to the effect of
such relations upon the affairs of the bank.
Sec. 21 (a) of the Banking Act of 1933 provided, in part, that
after June 16, 1934, it would he unlawful for any private bank not

218

under State supervision to continue the transaction of business
unless it submitted to periodic examination by the Comptroller of
the Currency or the Federal Reserve bank of the district, and
made and published periodic reports of condition the same as
required of National banks under sec. 5211, ILS.R.S. Sec. 21(a)
of the Banking Act of 1933, however, was amended by sec. 303
of the Banking Act of 1935, approved Aug. 23, 1935, under the
provisions of which private banks are no longer required to submit to examination by the Comptroller or Federal Reserve bank,
nor are they required to make to the Comptroller and to publish
periodic reports of condition. (Five calls for reports of condition
of private banks were made by the Comptroller, the first one for
June 30, 1934, and the last one for June 29, 1935.)
Sec. 7(a)(3) of the Federal Deposit Insurance Act (Title 12,
U.S.C., sec. 1817(a)) of July 14, 1960, provides, in part that,
effective Jan. 1, 1961, each insured National bank shall make to
the Comptroller of the Currency 4 reports of condition annually
upon dates to be selected by the Comptroller, the Chairman of
the Board of Governors of the Federal Reserve System, and the
Chairman of the Board of Directors of the Federal Deposit Insurance Corporation, or a majority thereof. Two dates shall be selected within the semiannual period of January to June, inclusive,
and 2 within the semiannual period of July to December, inclusive. Sec. 161 of Title 12 also provides that the Comptroller of the
Currency may call for additional reports of condition, in such
form and containing such information as he may prescribe, on
dates to be fixed by him, and may call for special reports from any
particular association whenever in his judgment the same are
necessary for use in the performance of his supervisory duties.

TABLE

B-23

Total and principal assets of National banks, by States, June 30, 1974
[Dollar amounts in millions]
Number
of banks

Total
assets

Cash
assets*

Securities, gross"t
U.S. Government
obligations^

State
and
local

Other

Loans,
gross

Federal
funds
sold§

United States

4,695

$516,770

$73,719

$43,843

$57,396

$3,437

$293,362

$20,408

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

93
5
3
74
57
126
24
5
13
274

5,855
800
4,822
3,300
71,654

748
110
555
457
10,037
875

603
75
383
353

908
146
444
413
5,432

21
3
13
13

163
24
114
250
2,771
202
68
3
170
823

64
2
6

7,766

3,215
405
3,042
1,702
42,854
3,213
2,178
31
1,535
8,248
4,712
77
1,270
28,129
5,953
1,901
1,973
2,091
3,221

District of Columbia - allf . . .

5,632
3,723
54
2,765

16,470
139

726
4

409
2,250
1,232
21

2,066

263

46,069
11,349

5,177
1,649
537

419
121
99
171
80
52
19
40
78
113
202
42
106
54
122
4
48
126
34
154
24
43
217
193
8
259
5
19
32
74
560
11
21
106
24
98
127
42
1
1
16

4,123

3,633

4,166
3,968

567

6,645

867

1,031
4,342
12,269
18,795
10,612
2,853
8,809
1,490
3,937
1,270
1,002
15,671
1,864
73,917
9,380
1,244
19,457
7,111
5,186
35,947
2,632
3,008
1,606
8,574
32,910
1,566
455
8,710

114
494

8,644

3,138
7,282
1,046
113
25

514

2,056

3,069
1,267
414
1,413
142
513
141
113
1,725
228
14,657
1,371
127
2,154
1,022
761
4,192
258
477
159
1,182
5,010
257
38
970
1,073
317
878
110
10

5,958
398
199
11
253
1,641
268
25

154
4,621
1,238
450
578
462
863
55

320
732
1,549
1,169
279
690
165
380
128
105
1,580
195
4,433
591
186
2,101
739
377
2,928
176
218
170
831

678
374
2
282

2,810
690
6
239
4,676

1,335
427
547
455
847
159
493
1,149
2,167
1,193
362

126
1
2

1,219
224
477
156
106
2,495
242
5,557
1,235
183
2,927
1,199
660
4,246
227
322
237
936
4,997
135
59
1,075
855
489
745
155
1
1

614

432

447

2,653

111
30
651
536

469
636

267

19
22
19
130
92
5
463

135
12
15
9
22
4
24
66

156
91
12
21
4
13
6
2
262
4
580
34
2
220
37

12
252
8
6
5
66

149
4
3
27
24
18
56
5

638
2,687

7,098
10,742
6,117
1,596
4,437
890
2,216
769
619
8,571
1,022
42,676

5,516
704
10,536
3,380
2,889
20,525
1,846
1,700

971
4,959
16,406
956
302
5,438
4,992
1,459
4,258
587
93
15
2,254

Direct
lease
financing

280
5
68

1,237
608
195
351
271
572
25
180
411
512
402
92
734
21
225
14
27
413
112
828
217
8
731
497
144
2,212
1
180
16
195
2,436
44

12
201
653
287
375
26
3

1
216

* Cash, balances with other banks, and cash items in process of collection.
t Includes investment securities and securities held in trading accounts.
$ Includes U.S. Treasury securities and obligations of other U.S. Government agencies.
§ Also includes securities purchased under agreements to resell.
\\ Includes national and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts of less than $500,000.

219

TABLE

B-24

Total and principal liabilities of National banks, by States, June 30, 1974
[Dollar amounts in millions ]
Deposits
Total
liabilities

Total
deposits

Demand
deposits,
total

Time and Demand
deposits
savings
IPC*
deposits,
total

Time
deposits
IPC*

Reserves
Federal
on loans
funds
and
purchased^
securities

United States

$476,967

$408,035

$171,102

$236,933

$128,221

$199,005

$41,808

5,353
741
4,499
3,026
67,215
5,198
3,441
49
2,518
15,130
7,115
130
1,920
42,746
10,543
3,353
3,781
3,662
6,106
947
3,993
11,255
17,341
9,799
2,628
8,087
1,381
3,616
1,168
899
14,396
1,718
67,786
8,638
1,147
17,806
6,504
4,755
33,029
2,431
2,765
1,481
7,926
30,297
1,442
417
8,008
8,084
2,874
6,737
959
104
23

4,932
695
3,859
2,732
57,246
4,580
3,120
47
2,319
13,661
5,628
128
1,767
34,924
8,849
3,014
3,418
3,369
5,253
872
3,526
9,778
15,612
7,898
2,463
6,487
1,274
3,245
1,114
832
13,492
1,610
55,263
7,170
1,051
15,700
5,887
4,169
27,156
2,152
2,433
1,411
6,744
26,218
1,275
405
7,269
6,588
2,528
5,845
905
98
22

2,149
350
1,406
1,284
19,943
2,144
1,655
18
1,327
6,076
2,913
54
674
12,186
3,670
1,311
1,589
1,596
2,358
359
1,610
5,012
5,780
3,030
1,118
3,259
433
1,442
463
424
5,189
678
28,011
3,076
386
6,095
2,668
1,769
9,979
685
1,479
470
2,817
12,797
505
122
2,688
2,692
981
2,021
339
20
4

2,783
344
2,452
1,44S
37,302
2,436
1,465
30
992
7,585
2,715
74
1,093
22,738
5,179
1,703
1,829
1,773
2,894
513
1,916
4,767
9,833
4,869
1,345
3,229
841
1,803
651
407
8,303
932
27,252
4,094
666
9,605
3,219
2,400
17,177
1,467
954
941
3,927
13,422
771
283
4,581
3,896
1,548
3,825
566
78
18

1,647
295
1,209
993
16,303
1,660
1,235
16
1,121
4,833
2,214
45
560
9,634
2,650
919
1,131
1,261
1,829
306
1,325
3,548
4,059
2,216
803
2,387
361
1,064
379
340
4,168
531
16,322
2,450
329
4,893
2,030
1,506
8,024
531
1,231
392
2,087
9,758
410
105
2,233
2,269
731
1,593
268
12
3

2,428
183
2,214
1,255
30,500
2,026
1,284
29
976
6,010
2,256
50
962
19,077
4,595
1,577
1,495
1,572
2,202
457
1,788
4,006
8,317
4,418
1,072
2,761
747
1,631
519
376
7,576
704
21,443
3,526
631
8,559
2,531
2,135
15,011
1,359
884
835
3,162
10,138
654
270
4,049
3,573
1,459
3,213
460
34
14

210
26
426
195
6,585
416
185
0
94
1,015
630
0
78
5,110
1,173
24£
274
183
622
41
315
919
1,223
1,377
83
1,384
50
246
0
27
418
51
5,735
874
47
1,133
466
363
2,958
196
216
8
704
3,000
111
2
335
1,174
243
625
14
0
0

3,750

3,417

1,957

1,460

1,650

1,439

197

District of Columbia - allt

* IPC deposits are those of individuals, partnerships, and corporations.
t Also includes securities sold under agreements to repurchase.
$ Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

220

TABLE B-25

Capital accounts of National banks, by States, June 30, 1974
[Dollar amounts in millions ]

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

....

Debentures

Preferred
stock

Common
stock

$34,966

$2,301

$31

$8,295

$13,678

$10,186

$476

454
53
283
247
3,751
386
247

24
1
74
23
435
30
12
0
1
40
64
2
8
67
4
12
19
5
18
1

104
18
37
60
785
88
62
1
44
322
131
3
35
714
161
57
85
65
95
22

177
21
91
77
1,562
141
124
2
100
503
163
2
59
1,401
287
76
126
107
210
24

4
1
0
6
105
1

60
170
268
173
45
146
35
65
27
16
285
38

144
12
82
82
863
127
50
2
76
340
179
2
27
601
255
99
124
87
152
26
123
266
336
247
12
243
15
108
35
31
322
34
1,788
144
25
416
229
90
699
58
75
28
194
755
22
13
184
139
81
113
35
3

223
1,225
587
8
128
2,822
715
248
356
268
482
73
...

Capital
reserves

Total
capital
accounts

4
49
94
98
9
29
9
22
0
1

306
891
1,280
721
201
646
96
284
90
93
1,137
133
5,323
654
85
1,483
557
384
2,611
177
214
109
577
2,323
111
33
614
473
242
476
79
8
2

65
12
242
134
5
36
45
101
238
5
12
11
27
105
15
1
28
5
7
43
7
0
0

336

0o
0
0

o
0
1
0
0

0
0
0
2
0

Surplus

0
0
0

148
25
336
121
94
502
30
52
32
135
627
30
7
153
134
46
118
7

117
404
569
195
134
222
35
85
28
45
449
46
1,794
223
28
693
159
100
1,117
84
74
36
211
766
43
10
247
184
102
197
29
4
1

134

o0
o
0
5

o
0

18
0
0
0

0
2
0
0

o
0
0

Undivided
profits

1
19
50
0
0
37
8
5
2
4
4
1
3
2
13
8
1
1
1
4
1
15
3
2
4
2
2
3
0
53
0
1
10
70
0
1
2
12
5
5
1
0

129

* Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

221

TABLE

B-26

Total and principal assets of National banks, by States, Dec. 31, 1974
[Dollar amounts in millions]
Securities, gross'
Number
of banks
4,708

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

....
....
..

...

..
...

..
..

District of Columbia - all II

Total
assets
$534,422

Cash
assets*
$76,557

U.S.
Government
obligations^
$45,870

93
5
3
74
55
127
24
5
13
282
64
2
6
420
121
99
171
80
52
20
40
78
117
202
39
110
55
121
4
47
122
34
154
26
43
217
193
8
250
5
18
31
75
569
11
17
109
23
100
128
44
1
1

6,295
901
4,875
3,509
75 414
5 908
3,889
56
2,958^
17,138
7,995
141
2 166
47,526
11,841
3 940
4,527
4,436
7,325
1,018
4,559
12,516
18,776
11,285
2,899
9,896
1,750
4 266
1,283
1,030
16,148
1 924
72,336
9,326
1,293
20,418
7,684
5,563
36,474
2,641
2,517
1,691
8,784
35,079
1,634
390
8,987
9,436
3,359
7,318
1,150
124
31

855
162
591
596
9,933
1,071
755
5
451
2,798
1,106
20
270
5,736
1,669
694
724
566
1,088
131
553
1,666
2,931
1,643
445
1,840
214
679
177
152
1,868
273
11,835
1,429
152
2,455
1,316
881
3,999
257
392
199
1,400
6,365
284
44
1,065
1,336
362
955
150
14
8

568
81
393
340
7,310
402
206
10
245
1,617
267
24
175
4,998
1,286
446
569
473
854
56
302
917
1,559
1,153
268
796
164
388
137
99
1,579
188
4,180
636
161
2,200
738
334
3,157
174
216
148
795
2,727
106
27
640
547
480
589
143
1
2

4,304

664

414

State
and
local
$57,296

Loans,
gross

Other
$3,835

918
142
462
439
5,114
672
423
3
265
2,630
659
6
272
4,454
1,293
434
573
516
920
138
536
1,505
2,164
1,230
377
1,248
241
494
143
95
2,542
251
5,104
1,229
184
2,899
1,247
747
4,266
219
271
244
894
5,209
147
46
1,147
841
522
753
166
1
3

32
4
15
13
319
32
37

418

$297,852

17
146
85
11
479
123
17
14
9
23
3
15
72
141
94
12
24
5
16
6
3
303
5
464
35
2
243
43
18
568
9
5
6
62
163
4
3
31
35
15
40
12

Federal
funds
sold§
$23,751

Direct
lease
financing
$2,414

3,341
441
3,005
1,751
44,116
3,233
2,138
33
1,562
8,186
4,637
87
1,293
28,865
6,146
1,936
2,032
2,214
3,408
634
2,727
7,123
10,934
6,186
1,601
4,577
1,012
2,171
755
615
8,632
1,039
43,386
5,352
738
10,642
3,490
3,006
20,795
1,797
1,304
1,004
4,758
16,826
970
251
5,386
5,280
1,519
4,222
592
91
16

338
33
173
251
2,910
243
141
4
329
1,161
708
0
74
1,011
744
296
468
457
790
19
225
447
277
562
90
1,103
63
388
11
36
521
99
662
149
22
1,200
603
190
1,793
42
238
42
433
2,424
62
9
330
800
347
371
50
10
2

20
2
4
5
922
19
15
0
2
16
31
0
7
78
113
1
3
39
26
0
28
74
32
39

2,273

375

39
1
23
10
74
177
31
0
82
31
19
201
8
1
39
72
9
11
80
2
25
2
0
0

* Cash, balances with other banks, and cash items in process of collection.
t 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.
II Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

222

TABLE

B-27

Total and principal liabilities of National banks, by States, Dec. 31, 1974
[Dollar amounts in millions]
Deposits

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

Federal
funds
purchased^

Demand
deposits,
total

Time and
savings
deposits,
total

Demand
deposits,
IPC*

Time
deposits,
1PC*

$493,400 $431,225

$180,391

$250,834

$137,829

$207,794

$36,323

5,772
837
4,548
3,224
70,778
5,447
3,598
51
2,700
15,735
7,341
131
2,014
44,065
10,967
3,650
4,130
4,107
6,766
930
4,205
11,469
17,271
10,439
2,668
9,151
1,620
3,934
1,178
925
14,843
1,773
66,257
8,545
1,192
18,699
7,053
5,111
33,505
2,435
2,306
1,561
8,125
32,343
1,506
357
8,254
8,847
3,080
6,759
1,057
114
29

5,286
763
3,862
2,956
62,004
4,900
3,339
49
2,464
14,421
6,072
125
1,913
38,170
9,372
3,322
3,765
3,708
5,873
877
3,684
9,792
15,660
8,779
2,502
7,255
1,513
3,512
1,141
869

2,923
364
2,428
1,529
41,288
2,486
1,503
31
1,048
7,808
2,908
74
1,136
24,005
5,548
1,823
1,892
1,947
3,123
502
2,062
4,882
9,860
5,167
1,356
3,336
960
1,858
665
431
8,445
969
30,328
4,073
663
9,905
3,478
2,554
17,594
1,505
779
990
4,071
14,412
820
242
4,681
4,330
1.681
3,668
595
84
22

1,807
34«
1,273
1,080
17,626
1,826
1,379
16
1,141
5,032
2,387
44
647
10,330
2,760
1,072
1,325
1,420
2,075
317

2,565
216
2,195
1,317
33,190
2,087
1,289
30
1,000
6,165
2,360
50
996
20,086
4,781
1,645
1,570
1,728
2,377
457

13,997
1,650
55,503
7,544
1,112
16,473
6,457
4,367
28,018
2,192
2,063
1,502
7,153
28,772
1,408
347
7,545
7,329
2,743
5,971
994
109
28

2,363
400
1,433
1,427
20,716
2,415
1,835
18
1,416
6,613
3,164
50
111
14,165
3,824
1,499
1,873
1,761
2,750
375
1,622
4,910
5,799
3,612
1,146
3,919
553
1,654
476
439
5,552
680
25,175
3,471
449
6,569
2,978
1,813
10,424
687
1,284
512
3,082
14,360
588
105
2,864
2,998
1,062
2,303
399
26
7

1,410
3,674
4,116
2,586
855
2,649
452
1,189
392
347
4,471
557
16,877
2,724
390
5,362
2,225
1,566
8,513
571
1,086
437
2,291
10,720
466
90
2,409
2,540
823
1,812
311
12
4

1,866
4,011
8,363
4,536
1,109
2,911
850
1,660
520
392
7,630
736
23,055
3,442
632
8,823
2,746
2,126
15,178
1,386
681
885
3,376
10,819
667
230
4,145
3,641
1,565
3,176
481
38
15

257
52
455
184
4,551
313
117
0
175
900
720
0
25
3,885
1,062
247
277
282
622
27
346
984
1,044
1,109
89
1,558
44
332
0
25
348
66
4,435
508
42
1,426
449
481
3,024
160
165
13
622
2,587
51
1
359
1,117
238
528
24
0
0

3,916

3,586

2,069

1,517

1,674

1,460

234

Total
liabilities

Total
deposits

Reserves
on loans
and
securities

223

TABLE B-28

Capital accounts of National banks, by States, Dec. 31, 1974
[Dollar amounts in millions]
Undivided
profits

Capital
reserves

Total
capital
accounts

Debentures

Preferred
stock

Common
stock

United States

$35,830

$2,258

$13

$8,336

$14,067

$10,652

$503

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

469
57
288
259
3,821
409
255
5
231
1,282

24
1
74
23
432
30
12
0
1
40

0
0
0
0
0
0
0
0
1
1

104
18
37
60
787
91
62
1
45
336

180
26
91
80
1,567
148
127
2
100
521

157
12
86
89
924
139
54
2
84
365

4
1
0
7
111
1

586
10
134
2,894
781
256
367
287
496
77
310
914
1,318
749
205
667
114
294
94
95
1,162
137
5,257
690
89
1,542
578
403
2,641
181
189
113
585
2,421
115
29
645
493
254
487
84
8
2

64
2
8
72
4
13
18
6
18
1

0
0

133
1
31
646
272
104
130
100
164
28

....

...

0
0
0

203
3
61
1,418
332
77
129
111
212
25
117
412
573
202
148
225
40
86
27
47
448
49
1,909
231
29
706
162
99
1,133
83
71
37
214
778
43
9
254
185
106
199
30
4
1

134

6
44
93
99
9
29
10
22
0
1

0
0

o
0
0
0
OCMC

65
13
189
141
6
36
46
101
238
5
7
11
29
106
15

0
0
0

349

32
5
7
44
7
0
0

131
4
35
719
163
57
86
65
96
23
61
171
278
175
44
150
40
66
27
15
290
39
1,453
149
26
338
123
94
496
30
35
33
136
643
30
7
156
134
48
120
8

0
0
0
0
0

122
285
363
263
3
256
24
117
39
32
344
34
1,705
165
26
459
245
109
717
63
74
31
197
813
26
12
202
157
88
118
38
4

1
19
55
0
0
37
8
6
2

5
5
1
3
2
12
9
1
1
1
3
1
15
3
1
4
bototo

otoo

....

o 1 oenoo o

..
..

CM O

District of Columbia — all*

Surplus

0
56
0
2
1
10
81
0
1
12
5
5
2
0

141

* Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500,000.

224

TABLE B-29

Loans of National banks, by States, Dec, 31, 1974
[Dollar amounts in millions]
Loans

Loans
secured
by real
estate

Loans to
financial
institutions

Loans to
purchase
or carry
securities

Loans to
farmers

Commercial
and industrial loans

Personal
loans to
individuals

United States.

$297,852

$73,739

$27,505

$4,475

$9,120

$114,825

$59,451

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

3,341
441
3,005
1,751
44,116
3,233
2,138
33
1,562
8,186
4,637
87
1,293
28,865
6,146
1,936
2,032
2,214
3,408
635

650
174
981
467
12,788
747
742
17
487
2,473
1,018
46
368
3,871
2,230
509
286
677
850
247
1,081
1,046
4,252
1,575
401
845
283
257
340
192

128

157
30
4,507
181
49
0
267
314
258

13
57
350
37
3
0
8
66
44
0
4
754
50
44
60
11
65

255
98
1,424
316
2
1
0
68
37

23
36
128
179
24
115
1
99
3
1
22
8
1,004
39
1
82
103
18
141
2
7
1
45
660
4

25
5
80
312
50
201
187
657
13
3
9
105
192
44
144
130
433
130
175
1
16
301
77
912
39
6
97
229
11
104
122
0
0

1,112
148
813
502
16,718
955
723
3
319
2,605
1,646
32
326
13,705
1,636
524
612
610
1,301
185
669
3,917
2,868
2,292
458
1,911
245
548
169
203
2,309
366
22,890
2,274
212
3,193
1,194
1,230
7,613
589
435
236
1,701
7,101
278
47
1,577
1,968
313
1,348
169
12
12

1,200
112
738
572
7,102
930
547
11
349
2,521
1,480
9
380
3,401
1,755
442
539
648
850
180
715
1,146
2,196
1,176
527
995
285
507
211
209
2,007
314
4,428
1,787
160
3,303
766
520
4,060
263
500
211
1,424
3,474
232
60
1,661
1,042
601
748
144
13
2

448

486

District of Columbia - all*

2,727
7,123
10,934
6,186
1,601
4,577
1,012
2,171
755
615
8,632
1,039
43,386
5,352
738
10,642
3,490
3,006
20,795
1,797
1,304
1,004
4,758
16,826
970
251
5,386
5,280
1,519
4,222
592
91
16
2,273

3,730
198
7,036
875
213
3,202
709
853
5,833
759
297
243
1,203
2,709
359
134
1,636
1,457
544
1,636
147
64
1
760

16
5,245
224
27
35
93
210
5
154
833
888
573
71
378
6
61
14
2
374
22
6,624
235
1
518
188
232
2,268
116
9
5
231
1,032
36
185
471
25
201
2
0

16
36
5
67
4

386

182
711
140
364
479
113
44
7

225

TABLE B-30

Outstanding balances, credit cards and related plans of National banks, Dec. 31, 1974
Credit cards
Number of
banks

Outstanding
volume
(dollars in
thousands)

Other related credit plans
Number of
banks

Outstanding
volume
(dollars in
thousands)

United States*

861

$6,052,634

1,040

$1,397,922

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

18
2
6
25
48
5
0
1
64

75 647
91,245
23,050
1,281,463
139 282
84,225
0
68,863
179,207
218,017
25,622
339,283
102,647
34 297
45,157
49,571
57,236
13,298
90,821
110,378
268,915
12,383
26,686
184,362
2 966
99,458
19,494
14,166
78,396
20,663
482,187
124,657
713
323,707
83,079
90,001
224,674
33,945
41,233
0
119,671
283,525
31,780
2,436
160,399
154,839
15,775
105 309
1,543
16,363
0
0
0

7
2
6
30
51
10
0
8
50
8
2
103
17
17
16
5
9
11
12
43
38
102
1
25
15
18
1
13
51
4
49
16
13
52
20
0
38
2
4
5
11
44
I
1
21
6
8
57
16
0
1
0
0

2,660
20,628
560
207,286
18,847
24,018
0
30,343
63,970
24,054
9,389
51,036
13,730
1,988
1,787
3,754
8,368
4,684
21,648
108,233
48,615
50,866
811
13,781
1,344
3,106
4,955
2,804
70,657
2,060
222,599
51,776
1,736
35,077
3,272
0
186,487
16,418
1,775
332
7,077
13,933
359
15
10,868
13,171
933
13,471
2,109
0
532
0
0

....
....
...

....

....
...
...

..
... .

.
..

...
....

26
3
33
58
8
5
33
6
15
2
40
30
3
2
9
6
5
3
21
20
5
31
9
5
105
7
3
17
4
4
0
13
57
3
4
22
5
10
47
10
3
0
0
0

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

226

TABLE B-31

National banks engaged in direct lease financing, Dec. 31, 1974
Total number
of banks

Number of banks
engaged in direct
lease financing

Amount of direct
lease financing
(dollars in thousands)

United States.

4,708

679

$2,414,038

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

93
5
3
74
55
127
24
5
13
282

12
2
2
7
19
30
3
0
3
43
13
0
2
54
21
13
21
9
8
0
4
8
23
18
7
25
12
12
3
2
9
2
15
6
0
39
73
3
16
2
3
2
15
48
3
2
9
6
10
23
17
0
0

20,150
1,908
4,118
4,862
921,740
19,470
15,471
0
2,462
15,996
30,569
0
7,398
77,897
113,494
1,455
2,934
38,812
26,237
0
27,669
74,022
32,006
39,360
297
39,364
1,047
22,839
9,632
5
74,288
58
176,647
30,701
0
81,726
30,610
19,279

District of Columbia - all*

64
2
6
420

121
99
171
80
52
20
40
78
117
202
39
110
55
121
4
47
122
34
154
26
43
217
193
8
250
5
18
31
75
569
11
17
109
23
100
128
44
1
1
16

200,966

8,431
849
4fi
38,541
71,550
9,081
219
10,750
79,706
2,138
25,042
2,194
0
0
14,290

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

227

TABLE

B-32

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
United
States
Number of banks

4708

Operating income:
Interest and fees on loans
$28,418,563
Income on Federal funds sold and securities purchased under
2,173,089
agreements to resell
Interest and dividends on investments:
1,752,716
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
1,018,360
Obligations of States and political subdivisions
2,531,299
Other securities
258,901
Trust department income
853,728
Service charges on deposit accounts
827,191
Other service charges, collection and exchange charges, commissions,
938,515
and fees
1,675,980
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

127

$306,203

$41,582

$299,601

$150,886

$4,346,195

$330,525

$214,588

28,270

3,909

7,835

27,347

223,834

21,838

7,589

24,989

1,614

14,226

13,061

209,416

19,425

6,730

14,041
42,064
1,864
8,577
14,914

3,834
7,169
763
662
3,466

10,922
21,580
305
7,406
11,648

10,403
18,970
775
2,567
7,511

141,658
219,849
41,638
99,097
144,599

8,282
31,690
1,299
15,739
16,668

6,762
18,208
2,736
15,861
6,310

10,612
9,242

3,329
945

5,610
7,036

6,017
4,067

180,179
383,363

14,701
8,810

8,690
8,633

40,448,342

460,776

67,273

386,169

241,604

5,989,828

468,977

296,107

5,593,025
1,033,991
16,584,980

71,897
14,102
177,668

15,434
2,162
23,395

70,615
12,033
160,606

38,341
6,027
87,472

864,968
149,630
2,802,292

79,966
12,887
162,729

61,687
10,387
95,801

4,277,220
519,256
147,782
1,146,564

23,536
5,032
2,025
11,767

2,352
46
50
2,544

44,433
1,068
4,463
15,633

21,713
745
1,585
8,095

518,992
68,516
26,588
192,390

38,141
2,665
2,319
12,949

24,513
4,021
589
14,270

811,897
1,391,805
3,734,922

11,991
12,787
52,123

2,315
1,102
6,774

11,350
9,843
33,303

7,704
4,389
27,142

94,492
215,218
448,893

12,645
15,478
69,139

9,581
9,154
32,594

35,241,442

382,928

56,174

363,347

203,213

5,381,979

408,918

262,597

5,206,900
1,122,623
4,084,277
- 42,420
4,041,857
+ 2,758
- 141

77,848
16,832
61,016
- 43
60,983
+ 87
0

11,099
1,929
9,170
- 181
8,989
0
0

22,822
- 493
23,315
- 305
23,010
0
0

38,391
8,553
29,838
- 129
29,709
-82
0

607,849
192,356
415,493
- 3,376
412,117
+ 621
0

60,059
12,173
47,886
- 71
47,815
+ 3,451
0

33,510
8,667
24,843
- 100
24,743
- 264
0

4,044,474

61,060

8,989

23,010

29,627

412,738

51,266

24,479

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
Capital stock, notes and debentures sold or issued including
premium received
Addition to surplus, undivided profits and reserves incident to
mergers and consolidations
Transfers from reserves on loans and securities
All other increases
Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases
Net change in capital accounts
Capital accounts!
Ratios:
Net income before dividends to capital accounts (percent) ..
Total operating expense to total operating revenue (percent)
See footnotes at end of table.

to
to FRASER
Digitized for

4,044,474

61,060

8,989

23,010

29,627

412,738

51,266

24,479

570,368

5,600

227

2,600

66,462

10,734

1,533

117,912
65,420
229,833
983,533

1,214
320
14,884
22,018

0
161
51

0
0
0

76
1,288
2,945

237

227

6,909

3,516
1,843
10,224
82,045

1,165
524
2,373
14,796

0
61
1,278
2,872

1,670,232
977

22,148
0

1,089
0

11,016
0

6,717
0

202,841
0

17,928
0

13,260
0

87,768

146

129

4,404

683

32,298
216,362
212,413

1,902
2,688
13,081

0
474
217

0
77
501

7
1,270
1,515

9,117
51,814
22,549

0
1,016
1,156

0
- 269
179

2,220,050

39,819

1,800

11,740

9,638

290,725

20,783

13,177

2,807,957

43,259

7,426

11,497

26,898

204,058

45,279

14,174

34,646,893

450,027

53,260

282,710

245,322

3,735,620

386,518

248,465

11.67

13.57

16.88

8.14

12.08

11.05

13.26

9.85

87.13

83.11

83.50

94.09

84.11

89.85

87.19

88.68

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Delaware

Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income

Florida

Georgia

Hawaii

282

$2,674

$144,877

$800,811

$517,572

$8,900

424

17,361

102,933

47,585

483

13,175

62,084

174
94
4
0
106

2,866
11,538
1,035
6,727
6,144

60
46

Idaho

Illinois

Indiana

420

121

$115,827

$2,810,847

$550,228

302

8,512

150,384

69,407

12,448

926

8,014

169,299

53,127

46,078
129,275
8,597
28,658
32,195

5,385
33,346
3,522
17,118
23,568

826
261
10
0
66

2,948
11,507
479
998
5,898

140,755
210,293
34,920
87,965
43,523

28,137
61,731
23,659
17,524
18,202

2,527
4,061

30,932
25,793

18,177
32,272

391
128

3,673
848

60,304
113,784

23,308
16,972

4,065

210,311

1,267,356

710,993

11,810

158,704

3,822,074

862,295

749
140
1,470

40,433
7,067
66,540

186,468
30,483
512,969

121,467
22,144
191,771

2,661
352
5,171

27,569
4,807
68,701

371,473
68,364
1,722,441

118,098
19,961
338,327

1
0
0
134

11,049
1,905
85
7,506

99,760
5,634
2,675
30,444

100,381
48,089
3,988
21,927

36
4
75
741

3,274
1,171
500
3,733

620,166
23,405
5,217
73,274

114,068
6,504
308
24,562

157
21
539

4,925
4,475
21,758

28,044
50,685
174,947

19,193
51,661
83,316

328
302
1,830

4,000
3,065
15,354

55,135
93,713
278,316

20,560
22,844
85,075

3,211

165,743

1,122,109

663,937

11,500

132,174

3,311,504

750,307

854
318
536
- 7
529
0
0

44,568
15,965
28,603
+ 70
28,673
+ 325
0

145,247
9,406
135,841
- 1,191
134,650
+ 69
0

47,056
1,450
45,606
- 546
45,060
+ 39
0

310
37
273
+ 22
295
- 4
0

26,530
7,354
19,176
- 79
19,097
+ 43
0

510,570
131,343
379,227
- 783
378,444
+ 923
- 2

111,988
23,092
88,896
- 803
88,093
+ 135
0

529

28,998

134,719

45,099

291

19,140

379,365

88,228

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

District of
Columbia

Changes in capital accounts:
Increases:
Net income transferred to undivided profits
..
Capital stock, notes and debentures sold or issued including

529

28,998

134,719

45,099

291

19,140

379,365

88,228

2,252

65,435

10,031

1,572

3,812

23,094

1,780

0
0
82

900
202
52

8,194
4,562
7,563

561
922
8,880

0
0
54

0
0
248

1,395
12,071
11,865

344
2,375
37,743

3,406

85,754

20,394

1,626

4,060

48,425

42,242

123
0

10,602
356

62,144
0

23,967
0

175
0

6,976
0

169,395
88

29,237
0

953

2,785

7,968

6,847

0
18
97

0
1,808
356

200
4,416
3,978

325
2,035
3,881

0
235
0

0
1,445
110

112
39,970
7,415

234
3,354
1,944

238

14,075

73,523

38,176

410

8,531

223,827

34,792

373

18,329

146,950

27,317

1,507

14,669

203,963

95,678

4,600

222,595

1,211,903

575,319

8,588

127,042

2,802,509

727,598

Ratios:
Net income before dividends to capital accounts (percent) . . .

11.50

13.03

11.12

7.84

3.39

15.07

13.54

12.13

Total operating expense to total operating revenue (percent) .

78.99

83.28

86.64

87.01

Addition to surplus, undivided profits and reserves incident to
mercers and consolidations
...
Transfers from reserves on loans and securities
Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including preReduction in surplus, undivided profits and reserves incident
Transfers to reserves on loans and securities
All other decreases
Total decreases
Net change in capital accounts

See footnotes at end of table.

78.81

88.54

93.38

97.38

to
to

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Iowa
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions,
and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries

Net income

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

171

117

$164,343

$179,377

$191,235

$316,773

$60,931

$252,104

$743,200

$1,001,290

28,698

34,545

27,211

55,962

2,718

19,993

43,763

65,114

17,802

25,847

22,908

40,469

2,611

15,569

37,830

74,016

10,862
18,516
1,013
5,465
5,340

12,804
23,998
914
4,378
7,343

7,953
22,416
647
3,441
5,679

14,640
39,495
2,742
4,617
12,360

1,181
6,830
211
2,314
1,966

6,060
22,454
1,518
4,537
10,381

14,948
54,835
3,715
45,509
17,221

27,270
98,002
10,407
29,255
28,081

7,818
2,618

10,032
3,645

5,993
8,754

13,307
11,009

2,121
903

6,604
5,335

33,299
59,732

22,255
23,257

262,475

302,883

296,237

511,374

81,786

344,555

1,054,052

1,378,947

37,252
5,904
101,888

45,230
7,537
113,849

44,657
7,313
104,822

63,417
10,754
202,786

15,534
3,155
29,391

59,976
9,94fi
108,452

166,097
33,591
367,093

198,146
35,853
635,863

27,067
907
900
7,240

23,511
2,761
1,288
7,652

20,652
3,488
417
9,577

57,088
11,556
1,582
14,080

3,408
175
96
3,650

38,118
1,913
289
12,846

124,952
9,429
3,226
35,250

124,043
4,066
6,121
40,167

9,185
2,683
25,453

8,310
6,757
29,845

8,198
5,602
33,162

14,080
11,482
51,339

2,534
1,940
10,898

8,502
11,487
46,802

20,957
58,869
115,230

28,759
22,317
113,605

218,479

246,740

237,888

438,164

70,781

298,333

934,694

1,208,940

43,996
12,297
31,699
- 284
31,415
- 20
- 11

56,143
15,660
40,483
- 506
39,977
- 92
0

58,349
15,885
42,464
- 886
41,578
- 5
0

73,210
16,850
56,360
- 1,513
54,847
- 126
0

11,005
1,835
9,170
+ 108
9,278
+ 99
0

46,222
11,751
34,471
- 492
33,979
+ 35
0

119,358
31,539
87,819
- 3,038
84,781
+ 102
0

170,007
34,378
135,629
- 2,201
133,428
+ 1,629
-6

31,384

39,885

41,573

54,721

9,377

34,014

84,883

135,051

31,384

39,885

41,573

54,721

9,377

34,014

84,883

135,051

1,470

2,532

1,849

7,384

500

5,745

16,830

13,273

207
155
1,504
3,336

1,041
470
1,888
5,931

102
1,980
1,992

135
1,756
1,648

700
228
228

2,850
1,021
6,127

5,923

10,923

1,656

2,666
674
1,190
10,275

26,828

3,830
399
4,911
22,413

11,032
0

11,583
0

8,929
0

15,925
0

4,537
0

14,466
0

42,476
0

55,719
0

371

308

233

10,044

2,624

2
1,106
2,327

50
1,425
2,735

0
4,088
1,166

0
5,270
4,435

8
337
133

0
2,557
6,875

1,385
2,481
933

279
6,259
1,365

14,473

16,164

14,236

26,048

5,015

24,131

57,319

66,246

20,247

29,652

33,260

39,596

6,018

20,158

54,392

91,218

245,136

353,129

269,830

478,410

73,909

301,842

887,775

1,274,116

12.80

11.29

15.41

11.44

12.69

11.27

9.56

10.60

83.24

81.46

80.30

85.68

86.54

86.59

88.68

87.67

Ratios:
Net income before dividends to capital accounts (percent) . .
Total operating expense to total operating revenue (percent)
See footnotes at end of table.

to
00

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Minnesota
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions,
and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income

Mississippi

Missouri

Montana

Nebraska

202

110

121

$567,688

$141,835

$440,955

$86,614

$202,897

43,575

12,578

80,335

4,750

36,043

10,710

25,363

26,887
48,973
2,558
19,865
14,189

6,241
16,501
1,031
2,155
7,835

25,409
42,219

Nevada

New
Hampshire

New Jersey

122

$68,841

$58,322

$748,406

26,993

2,751

4,495

51,296

8,036

15,025

6,664

5,681

64,943

16,876
49,477
1,254
20,504
7,978

3,096
11,005
339
804
3,574

9,695
21,916
867
6,871
5,588

2,179
6,836
380
1,963
4,824

997
4,912
152
1,655
3,147

38,569
115,136
19,158
22,383
27,662

7,455
3,677

17,378
41,338

3,54£
1,798

10,360
6,114

2,493
1,171

972
1,675

17,788
22,180

827,406

210,018

701,458

123,564

306,326

98,102

82,008

1,127,521

95,297
17,252
335,318

31,874
5,328
85,164

84,753
15,365
236,693

16,686
2,919
57,701

43,448
7,440
114,052

18,806
3,220
39,497

15,648
3,043
25,241

196,989
36,923
476,090

122,509
22,768
6,668
15,543

11,503
392
485
5,768

145,345
3,394
1,414
14,129

4,151
475
677
2,950

26,582
4,054
1,493
8,766

29
113
0
4,074

2,795
366
65
3,882

41,750
7,465
4,490
45,742

14,638
15,076
69,868

6,453
7,909
24,685

14,819
21,954
70,666

2,977
2,637
14,102

7,795
7,804
31,318

2,443
2,070
9,971

2,391
1,833
13,314

33,268
24,481
118,915

714,937

179,561

608,532

105,275

252,752

80,223

68,578

986,113

112,469
32,286
80,183
- 806
79,377
+ 261
0

30,457
6,285
24,172
+ 213
24,385
+ 13
0

92,926
18,701
74,225
- 527
73,698
+ 90
0

18,289
3,543
14,746
- 127
14,619
+ 417
0

53,574
12,575
40,999
- 59
40,940
- 104
0

17,879
5,258
12,621
+ 50
12,671
0
0

13,430
3,967
9,463
- 346
9,117
+ 212
0

141,408
10,535
130,873
- 206
130,667
- 84
0

79,638

24,398

73,788

15,036

40,836

12,671

9,329

130,583

79,638

24,398

73,788

15,036

40,836

12,671

9,329

130,583

8,280

3,120

7,446

1,215

993

14,896

180
871
4,103
13,434

9,247
229
632

0
510
2,495

589
90
941
2,613

9,838
3,535
3,405

4,220

100
481
1,943
2,622

0
0
0

13,228

1,021
620
4,651
13,738

31,674

29,177
0

9,643
0

42,847
289

4,439
0

15,166
6

4,845
0

4,370
0

65,750
3

185

120

200

4,431

364
5,531
1,807

27
114
338

0
2,366
1,610

0
1,061
328

0
641
1,531

0
540
811

11,732
4,600
2,204

37,064

10,242

47,127

5,828

17,354

4,853

5,921

88,720

56,008

27,384

40,399

13,428

26,104

7,818

6,021

73,537

720,889

196,554

646,350

100,895

282,486

89,830

93,245

1,129,992

11.05

12.41

11.42

14.90

14.46

14.11

10.00

11.56

86.41

85.50

86.75

85.20

82.51

81.78

83.62

87.46

Ratios:
Net income before dividends to capital accounts (percent) . .
Total operating expense to total operating revenue (percent)
See footnotes at end of table.

to
as
TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec, 31, 1974
[Dollar amounts in thousands]
New York

New
Mexico
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions,
and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries
Net income

North
Carolina

North
Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

154

217

193

250

$97,747

$4,125,144

$549,658

$58,129

$975,896

$335,845

$278,568

$1,906,075

9,918

67,171

27,031

2,837

96,693

52,934

21,208

173,640

7,581

175,489

14,164

7,473

99,122

39,102

12,783

111,043

4,730
11,922
260
1,525
4,836

69,867
222,010
32,132
111,289
69,117

27,613
57,101
1,970
18,420
19,401

4,692
8,151
206
1,347
2,183

35,761
134,456
11,642
31,472
35,720

6,786
50,900
2,184
8,089
12,856

12,714
32,681
464
8,053
16,876

67,624
177,299
16,210
69,979
25,471

4,704
1,691

109,156
475,051

20,686
19,604

2,576
740

36,133
31,931

11,211
14,071

37,817
132,427

144,914

5,456,426

755,643

88,334

1,488,826

533,978

9,910
7,274
400,531

2,717,585

23,540
3,558
63,082

658,530
163,839
2,242,121

124,102
18,499
287,179

11,907
2,311
37,247

213,013
33,787
597,372

69,455
11,000
225,002

79,392
12,588
142,887

344,303
70,770
1,098,368

6,128
367
1,042
3,645

564,831
86,447
10,346
171,032

84,162
8,461
9,715
24,564

3,362
919
450
2,055

132,332
7,192
2,257
40,413

50,374
3,554
2,821
10,753

29,178
2,494
6,377
14,739

307,598
100,773
16,705
75,863

3,814
4,950
15,250

75,426
323,535
419,421

16,153
19,964
75,432

2,062
921
8,609

34,337
40,137
160,004

10,219
16,747
52,873

9,491
7,421
32,158

50,011
75,349
214,712

125,376

4,715,528

668,231

69,843

1,260,844

452,798

336,725

2,354,452

19,538
3,571
15,967
- 57
15,910
- 10
0

740,898
137,711
603,187
- 1,901
601,286
- 51
- 4

87,417
15,559
71,858
- 3,462
68,396
+ 63
0

18,491
5,086
13,405
- 123
13,282
+ 3
0

227,982
42,309
185,673
- 3,706
181,967
+ 357
- 14

81,180
12,014
69,166
- 1,211
67,955
+ 2,407
-1

63,806
17,060
46,746
- 604
46,142
- 16
0

363,133
58,040
305,093
- 5,262
299,831
+ 612
- 107

15,900

601,231

68,459

13,285

182,310

70,361

46,126

300,336

15,900

601,231

68,459

13,285

182,310

70,361

46,126

300,336

300

24,101

43,093

1,775

6,073

14,169

557

61,022

0
0
1,700
2,000

13,398
8,356
23,102
68,957

7,978
190
1,042
52,303

400
81
478
2,734

2,214
2,198
10,858
21,343

42
276
4,136
18,623

0
0
147
704

3,54fi
3,371
8,030

75,971

5,460
0

243,578
5

26,176
0

3,718
0

74,421
0

20,535
0

10,056
0

147,260
98

33,010

2,862

433

131

1,836

0
946
1,561

718
5,759
55,530

0
4,109
1,012

850
744
565

920
5,298
2,821

109
2,219
4,029

0
1,100
14,007

652
11,490
8,845

8,056

338,600

34,159

5,877

83,893

27,023

25,163

170,181

9,844

331,588

86,603

10,142

119,760

61,961

21,667

206,126

132,564

5,254,131

650,218

84,453

1,432,327

551,562

389,457

2,492,900

11.99

11.44

10.53

15.73

12.30

12.76

11.84

12.05

86.52

86.42

88.43

79.07

84.69

84.80

84.07

86.64

Ratios:
Net income before dividends to capital accounts (percent) ..
Total operating expense to total operating revenue (percent)
See footnotes at end of table.

Digitized for
Co FRASER

8
00

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Rhode
Island
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions,
and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds purchased and securities sold under
agreements to repurchase
Interest on borrowed money
Interest on capital notes and debentures
Occupancy expense of bank premises, net
Furniture and equipment, depreciation, rental costs, servicing,
etc
Provision for loan losses (or actual net loan losses)
Other operating expenses
Total operating expense
Income before income taxes and securities gains or losses
Applicable income taxes
Income before securities gains or losses
Net securities gains or losses (after tax effect)
Net income before extraordinary items
Extraordinary charges or credits
Minority interest in consolidated subsidiaries

Net income

South
Carolina

South
Dakota

Tennessee

Texas

Utah

Vermont

Virginia

569

109

$175,762

$133,092

$82,833

$476,607

$1,647,180

$93,941

$20,483

$531,908

4,555

16,152

3,035

33,720

254,258

7,368

1,688

26,402

4,908

7,660

6,849

30,652

110,962

5,576

1,228

27,041

6,037
9,344
494
8,922
3,158

4,754
12,009
287
4,112
9,078

4,502
10,924
680
1,304
3,804

21,115
44,048
4,528
11,603
15,849

64,664
220,313
10,915
50,220
52,812

1,526
6,854
332
1,799
4,645

432
2,273
196
226
874

18,100
50,698
1,622
13,471
11,465

4,358
8,526

3,601
5,037

3,527
860

17,745
21,964

53,198
54,081

5,436
706

298
326

15,948
10,800

226,064

195,782

118,318

677,831

2,518,603

128,183

28,024

707,455

27,904
6,752
102,764

44,853
7,876
47,116

15,251
3,090
57,515

99,111
15,976
273,870

305,243
51,804
968,176

20,150
3,061
52,641

5,140
920
12,764

103,656
18,598
291,980

21,798
3,391
313
6,236

13,478
285
774
5,782

1,193
448
834
2,620

83,331
11,076
1,420
19,037

327,614
33,464
6,851
45,823

7,982
2,366
1,285
2,611

58
27
34
993

42,017
5,134
2,240
19,041

2,988
6,864
24,033

7,098
5,534
24,998

2,950
3,136
10,207

21,891
52,076
68,436

49,328
67,589
254,875

3,335
2,151
13,025

827
394
3,141

15,616
24,006
95,780

203,043

157,794

97,244

646,224

2,110,767

108,607

24,298

618,068

23,021
6,177
16,844
- 304
16,540
0
0

37,988
12,314
25,674
- 40
25,634
+ 38
0

21,074
5,172
15,902
-259
15,643
+ 1
0

31,607
2,384
29,223
- 1,227
27,996
+ 285
+ 11

407,836
87,028
320,808
- 2,158
318,650
+ 971
- 7

19,576
5,890
13,686
- 27
13,659
0
0

3,726
647
3,079
+ 13
3,092
+ 26
0

89,387
17,748
71,639
- 2,697
68,942
- 21
0

16,540

25,672

15,644

28,292

319,614

13,659

3,118

68,921

16,540

25,672

15,644

28,292

319,614

13,659

3,118

68,921

1,867

858

17,599

51,479

1,935

36,933

0
820
429

3,284
527
77

594
0
579

1,322
2,666
5,679

14,415
4,146
22,369

5
0
44

1,824
2
353

6,840
4,058
10,491

1,249

5,755

2,031

27,266

92,409

4,114

58,322

7,984
0

8,309
0

5,175
0

21,332
0

87,232
0

6,370
0

1,211
21

33,212
0

6,239

105

0
1,064
948

1,000
292
314

0
613
645

125
1,617
3,585

1,217
19,580
25,334

0
796
168

749
236
329

155
1,841
2,515

9,996

9,915

6,473

26,724

139,602

7,334

2,591

37,828

7,793

21,512

11,202

28,834

272,421

6,374

4,641

89,415

76,825

201,123

108,448

572,768

2,301,373

111,223

31,515

604,406

Ratios:
Net income before dividends to capital accounts (percent) . . .

9.35

12.76

14.43

4.94

13.89

12.28

9.89

11.40

Total operating expense to total operating revenue (percent) .

89.82

80.60

82.19

95.34

83.81

84.73

86.70

87.36

Total increases
Decreases:
Cash dividends declared:
On common stock
On preferred stock
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases
Net change in capital accounts
Capital accountst

See footnotes at end of table.

Digitized 00
for FRASER

TABLE

B-32—Continued

Income and expenses of National banks,* by States, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Washington
Number of banks
Operating income:
Interest and fees on loans
Income on Federal funds sold and securities purchased under
agreements to resell
Interest and dividends on investments:
U.S. Treasury securities
Obligations of other U.S. Government agencies and corporations
Obligations of States and political subdivisions
Other securities
Trust department income
Service charges on deposit accounts
Other service charges, collection and exchange charges, commissions,
and fees
Other operating income
Total operating income
Operating expense:
Salaries and wages of officers and employees
Pensions and other employee benefits
Interest on deposits
Expense of Federal funds 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

West
Virginia

Wisconsin

Wyoming

Virgin
Islands

Puerto
Rico

District of
Columbia —

allt

100

128

$484,652

$120,542

$392,651

$55,055

$1,807

$8,861

$208,807

75,774

31,380

40,775

3,507

198

538

19,397

23,446

18,665

24,231

5,942

174

23,611

10,675
38,335
1,523
13,973
28,238

12,570
21,994
912
2,881
2,345

17,470
33,818
2,976
9,792
7,982

3,399
7,223
352
636
2,319

0
20
493
0
91

0
49
11
0
85

4,049
18,092
1,482
11,712
8,754

24,214
23,901

2,698
3,442

17,941
10,654

1,740
1,058

6
37

270
374

5,298
6,074

724,731

217,429

558,290

81,231

2,826

10,279

307,276

128,383
22,727
249,718

27,269
4,011
88,727

72,479
14,617
251,196

11,540
1,798
36,772

305
40
1,571

1,863
278
5,659

55,386
9,952
96,102

111,810
5,717
413
25,056

24,494
305
442
4,627

67,383
3,787
3,249
17,999

2,047
919
536
1,826

0
3
0
102

132
0
0
462

17,833
3,142
658
11,714

17,566
15,286
73,548

5,001
4,777
22,679

14,243
19,086
45,888

1,516
1,738
8,509

23
124
454

273
382
614

6,754
5,865
30,553

650,224

182,332

509,927

67,201

2,622

9,663

237,959

74,507
13,170
61,337
- 126
61,211
11,659
0

35,097
5,555
29,542
+ 66
29,608
- 103
0

48,363
9,471
38,892
- 1,042
37,850
+ 2,008
0

14,030
3,033
10,997
- 176
10,821
+ 38
0

204
98
106
0
106
+ 39
0

616
259
357
+ 25
382
0
0

69,317
25,451
43,866
+ 89
43,955
+ 325
0

49,552

29,505

39,858

10,859

145

382

44,280

49,552

29,505

39,858

10,859

145

382

44,280

598

10,047

16,189

985

2,252

1,104
516
51

14
622
1,486

11,059
70
1,410

0
154
1,373

0
0
0

0
19
99

202
56

2,269

12,169

28,728

2,512

118

3,410

17,729
1

7,606
0

20,858
0

3,488
0

0
0

17,242
356

202

116

1,473

0
5,593
896

0
1,419
1,615

59
2,201
1,008

0
710
1,075

0
0
29

0
0
5

0
1,972
356

24,219

10,670

24,328

5,389

21,399

27,602

31,004

44,258

7,982

116

495

26,291

477,485

238,402

469,554

79,642

2,007

8,045

336,034

Ratios:
Net income before dividends to capital accounts (percent) . ..

10.38

12.38

8.49

13.63

7.22

4.75

13.18

Total operating expense to total operating revenue (percent). .

89.72

83.86

91.34

82.73

92.78

94.01

77.44

Decreases:
Cash dividends declared:
On common stock
On preferred stock
..
....
....
Capital stock, notes and debentures, retired including premium paid
Reduction in surplus, undivided profits and reserves incident
to mergers and consolidations
Transfers to reserves on loans and securities
All other decreases
Total decreases
Net change in capital accounts
Capital accounts!

900

* 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.
t Includes aggregate book value of debentures, preferred stock, common stock, surplus, undivided profits, and reserves. Excepting Puerto Rico, these are averages
from the June and December call dates in the year indicated and the previous December call date.
X Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the Currency.
NOTE: Data may not add to totals because of rounding.

TABLE B-33

Income and expenses of National banks,* by deposit size, year ended Dec. 31, 1974
[Dollar amounts in thousands]
Total
Number of banks

4708

Operating income:
$28,418,563
Interest and fees on loans
Income on Federal funds sold and securities purchased
2,173,089
under agreements to resell
Interest and dividends on investments:
1,752,716
U.S. Treasury securities
Obligations of other U.S. Government agencies
1,018,360
and corporations
Obligations of States and political subdivisions . .
2,531,299
Other securities
258,901
Trust department income
853,728
Service charges on deposit accounts
827,191
Other service charges, collection and exchange charges,
938,515
commissions, and fees
1,675,980
Other operating income
Total operating income

40,448,342

Banks operating full year with deposits in December 1974, of —
Over
$2,000.0
$5,000.1
$10,000.1 $25,000.1 $50,000.1 $100,000.1
$2,000.1
and under to $5,000.0 to $10,000.0 to $25,000.0 to $50,000.0 to $100,000.0 o $500,000.0 $500,000.0
74

360

743

1,666

888

490

369

118

$2,538

$54,816

$251,007

$1,296,464

$1,596,627

$1,795,940

$4,484,143

$18,937,028

2,111

18,425

55,003

185,185

166,104

163,730

442,797

1,139,734

1,307

14,756

49,202

197,123

181,618

173,953

344,415

790,342

384
78
137
182

7,443
4,170
1,102
907
3,927

30,292
30,455
2,828
1,746
15,411

122,731
192,529
15,527
4,828
75,424

117,897
241,996
19,469
17,621
79,567

121,344
258,937
23,412
42,442
79,687

202,127
542,039
53,553
165,059
161,529

416,142
1,261,095
142,873
621,125
411,464

89
204

2,303
1,359

7,402
4,828

36,137
24,954

43,110
30,284

49,731
34,871

180,052
126,533

619,691
1,452,947

7,030

109,208

448,174

2,150,902

2,494,293

2,744,047

6,702,247

25,792,441

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

2,294
238
1,270

24,949
2,949
35,179

83,595
11,373
171,385

352,844
55,604
909,736

392,382
65,658
1,094,369

432,658
74,398
1,222,181

1,053,775
186,908
2,737,496

10,413,364

4,277,220
519,256
147,782
1,146,564

244
188
56
4,145

1,563
717
387
13,527

11,896
4,459
3,719
62,690

36,699
6,416
6,045
76,538

71,704
11,531
9,331
90,337

513,842
42,074
27,058
224,799

3,641,272
453,811
101,186
674,061

467

636,863

300
139
2,047
6,815

3,421
3,335
17,945

11,106
12,850
58,239

51,896
58,591
255,623

61,306
68,654
290,568

68,807
65,298
309,987

186,667
187,467
726,842

428,394
995,471
2,073,671

92,411

364,742

1,767,058

2,098,635

2,356,232

5,886,928

22,668,621

5,206,900
1,122,623
4,084,277
- 42,420
4,041,857
+ 2,758
- 141

215
222
-7
- 25
- 32
+ 26

16,797
5,161
11,636
-3
11,633
+ 29

83,432
22,326
61,106
- 546
60,560
+ 199

383,844
88,550
295,294
- 2,651
292,643
4- 1,745
- 11

395,658
77,945
317,713
- 2,060
315,653
+ 710
-1

387,815
66,108
321,707
- 2,658
319,049
+ 1,567
- 16

815,319
134,937
680,382
- 5,020
675,362
+ 3,226
- 13

3,123,820
727,374
2,396,446
- 29,457
2,366,989
- 4,744
- 100

Net income

4,044,474

-6

11,662

60,759

294,377

316,362

320,600

678,575

2,362,145

Cash dividends declared:
On common stock
On preferred stock

1,670,232
977

166

3,260

15,067

75,982
11

101,268
103

115,072
25

295,582
481

1,063,835
357

1,671,209

166

3,260

15,067

75,993

101,371

115,097

296,063

1,064,192

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
.

Total cash dividends declared

811,897
1,391,805
3,734,922
35,241,442

* Includes all banks operating as National banks at year-end, and full-year data for those State banks converting to National banks during the year.
NOTE: Data may not add to totals because of rounding. Dashes indicate amounts less than $500.

ISO

3,250,528

5,593,025
1,033,991
16,584,980

TABLE

B-34

Capital accounts, net income, and dividends of National banks, 1944-1974
[Dollar amounts in thousands]

Year (last call)

1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
I960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

5,031
5,023
4,013
5,011
4,997
4,981
4,965
4,946
4,916
4,864
4,796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,503
4,615
4,773
4,815
4,799
4,758
4,716
4,669
4,621
4,600
4,614
4,661
4,708

Preferred

$110,597
80,672
53,202
32,529
25,128
20,979
16,079
12,032
6,862
5,512
4,797
4,167
3,944
3,786
3,332
3,225
2,050
2,040
9,852
24,304
27,281
28,697
29,120
38,081
57,704
62,453
62,572
56,761
42,627
38,660
26,705

Common

$1,440,519
1,536,212
1,646,631
1,736,676
1,779,362
1,863,373
1,949,898
2,046,018
2,171,026
2,258,234
2,381,429
2,456,454
2,558,111
2,713,145
2,871,785
3,063,407
3,257,208
3,464,126
3,662,603
3,861,738
4,135,789
4,600,390
5,035,685
5,224,214
5,503,820
6,165,757
6,326,508
6,640,849
7,132,092
7,676,452
8,178,696

Total

$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
7,174,719
7,715,112
8,205,401

Ratios (percent)

Cash dividends

Capital stock (par value)*
Number of
banks

Total
capital
accounts*

$4,114,972
4,467,618
4,893,038
5,293,267
5,545,993
5,811,044
6,152,799
6,506,378
6,875,134
7,235,820
7,739,553
7,924,719
8,220,620
8,769,839
9,412,557
10,003,852
10,695,539
11,470,899
12,289,305
13,102,085
14,297,834
16,111,704
17,971,372
19,095,324
20,585,402
22,158,066
24,080,719
25,986,802
28,714,775
31,787,879
34,646,893

Net income
before
dividends

$411,844
490,133
494,898
452,983
423,757
474,881
537,610
506,695
561,481
573,287
741,065
643,149
647,141
729,857
889,120
800,311
1,046,419
1,042,201
1,068,843
1,205,917
1,213,284
1,387,228
1,582,535
1,757,491
1,931,556
2,534,029
2,829,334
3,041,122
3,307,906
3,767,667
4,044,474

On
preferred
stock

$5,926
4,131
2,427
1,372
1,304
1,100
712
615
400
332
264
203
177
171
169
165
99
119
202
1,126
1,319
1,453
l,34fl
2,124
4,344
4,428
4,677
4,011
2,703
2,398
977

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
1,307,628
1,446,994
1,670,232

Net income
before
dividends
to total
capital
accounts

Cash dividends to
net income
before
dividends

Cash dividends on
preferred
stock to
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
11.52
11.85
11.67

35.04
31.76
34.38
40.51
45.76
43.11
42.69
49.04
46.14
48.01
40.50
48.16
50.99
49.85
44.20
52.84
43.09
46.64
48.44
45.46
48.86
49.25
46.63
45.30
46.45
42.15
45.16
45.71
39.61
38.47
41.32

4.79
5.12
4.56
4.22
5.19
5.24
4.43
5.11
5.83
6.02
5.50
4.87
4.49
4.52
5.07
5.12
4.83
5.83
2.05
4.63
4.83
5.06
4.63
5.58
7.53
7.09
7.46
7.07
6.34
6.20
3.66

* These are averages of data from the reports of condition of the previous December, and June and December of the respective years.
t Ratios for years 1963 through 1973 inclusive have been restated to reflect removal of capital notes and debentures.
NOTE: For earlier data, see Annual Reports of the Comptroller of the Currency, 1938, p. 115, and 1963, p. 306.

Cash
dividends
to total
equity
capital^
3.53
3.48
3.4£
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
4.19
4.22
4.46
4.38
4.45
4.65
5.09
5.57
5.63
4.87
4.89
5.16

TABLE

B-35

Loan losses and recoveries of National banks, 1945-1974
[Dollar amounts in thousands]
Year

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
I960

Total loans, end
of year, net

$13,94«,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
48,24#,332
50,502,277
52,796,224
59,961,989
63,693,668

Ratio of net
Net losses or losses or net
recoveries (+) recoveries (+)
to loans
+$7,740
3,207
29,913
19,349
33,199
14,445
22,108
19,326
32,201
25,674
29,478
41,006
35,428
38,173
25,767
130,177

Percent
+0.06
.02
.14
.08
.14
.05
.07
.05
.08
.06
.07
.08
.07
.07
.04
.20

Year

Total loans, end
of year, net

Ratio of net
Net losses or losses or net
recoveries (+) recoveries (+)
to loans
Percent

1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
Average for
1945-74

$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
226,354,896
266,937,532
292,732,965

$112,412
97,617
121,724
125,684
189,826
240,880
279,257
257,280
303,357
601,734
666,190
545,473
731,633
1,193,730

0.17
.13
.15
.13
.16
.19
.20
.17
.18
.35
.35
.24
.27
.41

92,326,239

198,617

.22

NOTE: For earlier data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Reports of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 233.

TABLE

B-36

Securities losses and recoveries of National banks, 1945-1974
[Dollar amounts in thousands]

Year

1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960

Total securities,
end of year,
net
$55,611,609
46,642,816
44,009,966
40,228,353
44,207,750
43,022,623
43,043,617
44,292,285
44,210,233
48,932,258
42,857,330
40,503,392
40,981,709
46,788,224
42,652,855
43,852,194

Losses and
chargeoffs*

$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
4^3,526
154,372

Ratio of net
losses to
securities
Percent
0.04
.09
.10
.07
.04
.04
.12
.15
.25
.08
.32
.56
.35
.12
1.09
.30

Year

Total securities,
end of year,
net

Losses and
chargeoffs*

Ratio of net
losses to
securities
Percent

1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
Average for
1945-74

$49,093,539
51,705,503
52,601,949
54,366,781
57,309,892
57,667,429
69,656,371
76,871,528
70,216,983
84,157,505
95,948,647
103,658,543
104,606,665
106,930,804

$51,236
47,949
45,923
86,500
67,898
302,656
149,545
344,068
286,215
137,704
+ 189,347
+94,506
36,738
43,469

0.08
.08
.07
.15
.11
.52
.21
.44
.41
.16
+ .20
+ .09
.04
.04

58,220,978

106,396

.18

* Excludes transfers to and from valuation reserves beginning in 1948.
NOTE: For earner data, including figures on gross losses and chargeoffs and gross recoveries, see Annual Reports of the Comptroller
of the Currency, 1947, p. 100 and 1968, p. 234.

245

TABLE

B-37

Ratios of classified assets to total loans for National banks, deposit size category under $100 million
Latest examination in —
Classified
assets as a
percent of
total loans

1968
Number of
banks

Percent

Number of
banks

Percent

Number of
banks

Percent

Number of
banks

Percent

Number of
banks

1974

1973

1972

1971

1970

1969

Percent

Number of
banks

Percent

Number of
banks

Percent

2,124
0-.9
899
1-1.9
518
2-2.9
303
3-3.9
186
4-4.9
126
5-5.9
75
6-6.9
50
7-7.9
151
8.0 and over ..

47.9
20.3
11.7
6.8
4.2
2.8
1.7
1.1
3.4

2,099
953
488
321
180
108
65
48
118

47.9
21.8
11.1
7.3
4.1
2.5
1.5
1.1
2.7

1,779
971
560
354
219
135
89
62
143

41.3
22.5
13.0
8.2
5.1
3.1
2.1
1.4
3.3

1,716
945
599
364
235
118
77
50
138

40.5
22.3
14.1
8.6
5.5
2.8
1.8
1.2
3.3

1,839
1,006
608
314
182
97
59
45
80

43.5
23.8
14.4
7.4
4.3
2.3
1.4
1.1
1.9

2,005
958
578
287
161
79
47
28
73

47.5
22.7
13.7
6.8
3.8
1.9
1.1
0.7
1.7

1,741
961
603
363
183
128
66
45
118

41.4
22.8
14.3
8.6
4.3
3.0
1.6
1.1
2.8

Total . . . . 4,432

100.0

4,380

100.0

4,312

100.0

4,242

100.0

4,230

100.0

4,217

100.0

4,208

100.0

TABLE

R-38

Ratios of classified assets to total loans for National banks, deposit size category $100 million and over
Latest examination in —
Classified
assets as a
percent of
total loans

1968
Number of
banks

1969

Percent

Number of
banks

1970

Percent

Number of
banks

Percent

Number of
banks

Percent

Number of
banks

1974

1973

1972

1971

Percent

Number of
banks

Percent

Number of
banks

Percent

0-.9
1-1.9
2-2.9
3-3.9
4-4.9
5-5.9
6-6.9
7-7.9
8.0 and over ..

146
74
44
12
9
6
3
2
4

48.7
24.7
14.7
4.0
3.0
2.0
1.0
0.7
1.3

159
76
49
9
7
5
2
1
3

51.1
24.4
15.8
2.9
2.3
1.6
0.6
0.3
1.0

98
84
65
26
16
14
8
1
8

30.6
26.3
20.3
8.1
5.0
4.4
2.5
0.3
2.5

119
90
67
37
21
10
6
4
10

32.7
24.7
18.4
10.2
5.8
2.7
1.6
1.1
2.7

151
88
81
29
12
13
5
3
6

38.9
22.7
20.9
7.5
3.1
3.4
1.3
0.8
1.5

161
130
77
30
16
8
4
2
6

37.1
30.0
17.7
6.9
3.7
1.8
0.9
0.5
1.4

118
103
88
57
27
18
6
4
18

26.9
23.5
20.0
13.0
6.2
4.1
1.4
0.9
4.1

Total . . . .

300

100.0

311

100.0

320

100.0

364

100.0

388

100.0

434

100.0

439

100.0

246

TABLE B-39

Assets and liabilities of National banks, date of last report of condition, 1950-1974
[Dollar amounts in thousands]
Year

Number

banks
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

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

4,965
4,946
4,916
4,864
4,796
4,700
4,659
4,627
4,585
4,542
4,530
4,513
4,505
4,615
4,773
4,815
4,799
4,758
4,716
4,669
4,621
4,600
4,614
4,661
4,708

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
430,768,064
484,887,096
529,232,286

Cash
and due
from banks

Total
securities,

Loans,

net

$23,813,435
26,012,158
26,399,403
26,545,518
25,721,897
25,763,440
27,082,497
26,865,134
26,864,820
27,464,245
28,674,506
31,078,445
29,683,580
28,634,500
34,065,854
36,880,248
41,689,580
46,633,658
50,952,691
54,727,953
56,040,460
59,200,995
67,401,118
70,723,613
76,556,699

$43,022,623
43,043,617
44,292,285
44,210,233
48,932,258
42,857,330
40,503,392
40,981,709
46,788,224
42,652,855
43,852,194
49,093,539
51,705,503
52,601,949
54,366,781
57,309,892
57,667,429
69,656,371
76,871,528
70,030,342
84,157,465
95,948,647
103,658,543
104,606,665
106,930,804

net

Other
assets

Total
deposits

$29,277,480
32,423,777
36,119,673
37,944,146
39,827,678
43,559,726
48,248,332
50,502,277
52,796,224
59,961,989
63,693,668
67,308,734
75,548,316
83,388,446
95,577,392
116,833,479
127,453,846
136,752,887
154,862,018
168,004,686
173,455,791
190,308,412
226,354,896
266,937,532
292,732,965

$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
33,353,507
42,619,286
53,011,818

$89,529,632
94,431,561
99,257,776
100,947,233
106,145,813
104,217,989
107,494,823
109,436,311
117,086,128
119,637,677
124,910,851
135,510,617
142,824,891
150,823,412
169,616,780
193,859,973
206,456,287
231,374,420
257,883,926
256,426,791
283,784,496
314,211,616
359,427,154
395,880,964
431,225,358

Liabilities
for

borrowed
money
$76,644
15,484
75,921
14,851
11,098
107,796
18,654
38,324
43,035
340,362
110,590
224,615
1,635,593
395,201
299,308
172,087
1,015,147
296,821
689,087
2,283,717
1,280,365
866,103
2,370,204
3,721,870
3,285,509

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
38,616,017
52,149,689
58,891,284

$2,001,650
2,105,345
2,224,852
2,301,757
2,485,844
2,472,624
2,638,108
2,806,213
2,951,279
3,169,742
3,342,850
3,577,244
3,757,646
4,029,243
4,789,943
6,089,792
6,299,133
6,602,519
7,008,482
7,347,948
7,680,597
8,277,752
9,629,168
10,140,173
10,607,205

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
20,722,810
22,994,400
25,222,930

* After deduction of securities and loan reserves.
t Beginning in 1973, includes minority interest in consolidated subsidiaries.
NOTE: For earlier data, revised for certain years and made comparable to those in this table, references should be made as follows: years 1863 to 1913, inclusive Annual Report
of the Comptroller of the Currency, 1913; figures 1914 to 1919, inclusive, report for 1936; figures 1920 to 1939, inclusive, report for 1939; and figures 1936 to 1949, inclusive, report
for 1966.

TABLE

B-40

Foreign branches of National banks, by region and country, Dec. 31, 1974
Region and country

Number

Central America

El Salvador
Guatemala
Honduras
Mexico
Nicaragua
Panama

1
3
3
5
4
32

South America

131

Argentina
Bolivia
Brazil
Colombia
Ecuador
Guyana
Paraguay
Peru
Uruguay
Venezuela

37
3
19
36
15
1
5
6
5
4

West Indies (Caribbean)
Antigua
Bahamas
Barbados
British Virgin Islands
Cayman Islands
Dominican Republic
French West Indies
Grenada
Haiti
Jamaica
Montserrat
Netherlands Antilles
St. Lucia
Trinidad and Tobago
West Indies Federation of States
Europe
Austria
Belgium
England
France
Germany
Greece
Ireland
Italy
Luxembourg

Region and country
Europe - Continued
Monaco
Netherlands
Northern Ireland
Scotland
Switzerland
Africa
Kenya
Liberia
Mauritius
Middle East

248

Bahrain
Israel
Jordan
Lebanon
Qatar
Saudi Arabia
Trucial States

156
1
64
6
3
33
18
3
1
4
8
1
4
1
6
3
129
1
6
33
13
24
18
4
8
6

Asia and Pacific
Brunei
Fiji Islands
Hong Kong
India
Indonesia
Japan
Korea
Malaysia
Pakistan
Philippines
Republic of China
Singapore
Thailand
Vietnam
U.S. overseas areas and trust territories
American Samoa
Canal Zone (Panama)
Caroline Islands
Guam
Marianas Islands
Marshall Islands
Puerto Rico
Virgin Islands
Total

Number

110
3
5
24
11
6
23
3
5
4
4
4
13
2
3
53
1
2
1
7
1
1
22
18
649

TABLE

B-41

Total assets of foreign branches* of National banks, year-end 1953-1974
[Dollar amounts in thousands]
1953
1954.
1955.
1956.
1957.
1958.
1959.
1960.
1961.
1962.
1963.

$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

1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974

$3,319,879
7,241,068
9,364,278
11,856,316
16,021,617
28,217,139
38,877,627
50,550,727
54,720,405
83,304,441
99,810,999

Includes military facilities operated abroad by National banks from 1966 through 1971.

TABLE

B-42

Foreign branches of National banks, 1960-1974
End of year

National bank
Number of branches
branches as a
operated by
percentage of total
National banks
foreign branches
of U.S. banks

1960
1961
1962
1963
1964
1965
1966
1967

93
102
111
124
138
196
230
278

75.0
75.6
76.6
77.5
76.7
93.5
94.3
95.5

TABLE

End of year

National bank
branches as a
Number of branches
percentage of total
operated by
foreign branches
National banks
of U.S. banks

1968
1969
1970
1971
1972
1973
1974

355
428
497
528
566
621
649

95.0
93.0
92.7
91.5
90 2
89.5
89.4

B-43

Assets and liabilities of foreign branches of National banks, Dec. 31, 1974: consolidated

statement

[Dollar amounts in thousands]
Assets
Cash and cash items in process of collection
Demand balances with other banks
Time balances with other banks
Securities
Loans, discounts and overdrafts, etc
Customers' liability on acceptances outstanding . .
Customers' liability on deferred payment letters of
credit
Premises, furniture and fixtures
Accruals—interest earned, foreign exchange profits, etc
Due from other foreign branches of this bank . . . .
Due from head office and its domestic branches . .
Other assets
Total assets

Liabilities
$453,251
2,335,036
32,778,114
1,106,170
42,383,397
3,735,743
70,607
241,447
2,098,678
10,514,795
3,378,116
715,645
$99,810,999

Demand deposits
Time deposits
Liabilities for borrowed money
Acceptances executed
Deferred payment letters of credit outstanding . . .
Reserve for interest, taxes and other accrued
expenses
Other liabilities
Due to other foreign branches of this bank
Due to head office and its domestic branches . . . .
Total liabilities

$7,479,349
71,319,752
2,019,570
3,773,765
56,917
2,130,848
488,743
9,922,867
2,619,188
$99,810,999

Memoranda
Letters of credit outstanding
$4,086,326
Future contracts to buy foreign exchange and
bullion
$41,564,993
Future contracts to sell foreign exchange and
bullion
$50,601,286

249

TABLE B-44

Trust assets* and income of National banks, by States, calendar 1974
[Dollar amounts in millions]

Number
of banks

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

Other
Employee
benefit
trust
account st accounts^

Total
trust
accounts

Total
Agency
trust and
accounts^ agency
accounts

Trust department
income
(Dollar
amounts in
thousands)

1,795

$57,253

$84,653

$141,906

$40,919

$182,824

$858,713

31
4
2
37
13
32
9
0
6
98
31
0
3
177
98
53
55
53
23
16
11
56
42
23
23
42
15
22
3
22
66
19
76
15
12
67
46
2
113
4
7
11
30
157
2
7
51
10
37
46
17
0
0

364
40
245
75
7,139
711
4SS
0
443
358
756
0
63
6,215
593
156
131
76
278
42
148
3,303
4,773
1,253
70
961
15
237
24
12
373
34
14,203
1,172
42
2,121
629
296
4,830
352
145
33
334
2,434
107
2
313
477
42
341
7
0
0

1,062
46
718
300
8,522
1,322
1,572
0
1,209
3,845
1,147
0
128
6,403
2,425
628
597
421
341
226
638
3,383
2,631
1,702
245
2,544
87
653
325
223
1,736
229
8,705
1,732
145
4,934
1,003
662
8,139
1,032
408
127
1,432
5,399
200
22
1,272
1,598
450
1,993
89
0
0

1,426
86
963
375
15,661
2,033
2,055
0
1,652
4,203
1,903
0
192
12,617
3,017
783
728
497
619
268
786
6,686
7,404
2,955
315
3,505
103
890
348
235
2,110
264
22,908
2,905
187
7,055
1,632
958
12,970
1,384
553
160
1,766
7,833
307
24
1,586
2,076
492
2,334
97
0
0

221
47
79
53
1,971
376
795
0
1,296
727
1,387
0
16
4,126
1,097
378
322
110
119
118
176
1,066
1,977
658
14
1,428
19
321
25
90
862
36
6,950
665
73
1,713
573
319
6,176
270
133
50
545
2,000
20
4
744
296
65
394
19
0
0

1,647
133
1,042
429
17,632
2,409
2,850
0
2,948
4,929
3,290
0
208
16,743
4,114
1,162
1,050
606
738
386
962
7,752
9,381
3,614
330
4,933
122
1,211
374
326
2,972
300
29,858
3,569
260
8,768
2,205
1,277
19,145
1,654
686
210
2,311
9,833
327
27
2,330
2,372
556
2,727
115
0
0

8,577
662
7,406
2,567
99,097
15,739
15,861
0
11,712
28,658
17,118
0
998
87,965
17,524
5,465
4,378
3,441
4,617
2,314
4,537
45,509
29,255
19,865
2,155
20,504
804
6,871
1,963
1,655
22,383
1,525
111,289
18,420
1,347
31,472
8,089
8,053
69,979
8,922
4,112
1,304
11,603
50,220
1,799
226
13,471
13,973
2,881
9,792
636
0
0

* As of December 31, 1974.
t Employee benefit accounts include all accounts for which the bank acts as trustee, regardless of whether investments are partially, or wholly, directed by others. Insured plans or portions of plans funded by insurance are omitted, as are employee benefit accounts
held as agent.
$ Includes all accounts, except employee benefit accounts and corporate accounts, for which the bank acts in the following, or
similar capacities: trustee (regardless of whether investments are directed by others), executor, administrator, guardian; omits all agency
accounts and accounts for which the bank acts as registrar of stock and bonds, assignee, receiver, safekeeping agent, custodian,
escrow agent, or similar capacities.
§ Includes both managing agency and advisory agency accounts.
II Includes National and non-National banks in the District of Columbia, all of which are supervised by the Comptroller of the
Currency.
NOTE: Data may not add to totals because of rounding.
Digitized250
for FRASER

APPENDIX C

Addresses and Selected
Congressional Testimony

Addresses and Selected Congressional Testimony
Date and Topic
Feb. 5, 1974, Remarks of James E. Smith, Comptroller of the Currency, before the American Bankers Association National Trust
Conference, San Francisco, Calif
May 8, 1974, Testimony by James E. Smith, Comptroller of the Currency, before the Subcommittee on Securities of the Senate
Committee on Banking, Housing, and Urban Affairs, Washington, D.C
May 8, 1974, Testimony by James E. Smith, Comptroller of the Currency, before the Subcommittee on Securities of the Senate
Committee on Banking, Housing, and Urban Affairs, Washington, D.C
June 27, 1974, Statement of James E. Smith, Comptroller of the Currency, before the Subcommittee on Budgeting, Management,
and Expenditures and the Subcommittee on Inter-Governmental Relations of the Senate Committee on Government Operations, Washington, D.C
July 31, 1974, Testimony by James E. Smith, Comptroller of the Currency, before the Subcommittee on Financial Institutions of
the Senate Committee on Banking, Housing, and Urban Affairs, Washington, D.C
Aug. 13, 1974, Testimony of James E. Smith, Comptroller of the Currency, before the Subcommittee on Securities of the Senate
Committee on Banking, Housing, and Urban Affairs, Washington, D.C
Nov. 11, 1974, Remarks of James E. Smith, Comptroller of the Currency, before the Robert Morris Associates Fall Business
Conference Session, Atlanta, Ga
Dec. 11, 1974, Testimony by James E. Smith, Comptroller of the Currency, before the Subcommittee on Bank Supervision and
Insurance of the House Banking and Currency Committee, Washington, D.C
Apr. 9, 1974, Remarks of Robert A. Mullin, Deputy Comptroller of the Currency, before the Bankers Association for Foreign
Trade, San Diego, Calif
May 13, 1974, and May 23, 1974, Remarks of David C. Motter, Deputy Comptroller of the Currency (Economics), before the Dun
& Bradstreet Seminar for Bank Executives, Chicago, 111., and New York, N.Y
Aug. 16, 1974, Remarks of Justin T. Watson, First Deputy Comptroller of the Currency, at the Graduation Ceremonies of the
School of Banking of the University of Florida, Gainesville, Fla
Sept. 12, 1974, Remarks of Justin T. Watson, First Deputy Comptroller of the Currency, before the Alabama Bankers Association,
Gulf Shores, Ala
Oct. 24, 1974, Remarks of Justin T. Watson, First Deputy Comptroller of the Currency, before a Symposium of the World Trade
Institute, New York, N.Y
Nov. 8, 1974, Remarks of Justin T. Watson, First Deputy Comptroller of the Currency, before the First Gold, Silver, and Foreign
Exchange Seminar, Amsterdam, Netherlands
Nov. 9, 1974, Remarks of David H. Jones, Special Assistant to the Comptroller (Strategic Policy Planning), before the Annual
Homecoming Luncheon of the University of Texas at El Paso College of Business Administration, El Paso, Tex

252

Page
253
256
258
260
262
263
264
268
274
275
279
283
287
289
296

REMARKS OF JAMES E. SMITH, COMPTROLLER OF THE CURRENCY, BEFORE THE AMERICAN BANKERS
ASSOCIATION NATIONAL TRUST CONFERENCE, SAN FRANCISCO, CALIF., FEB. 5, 1974

The leading public policy issue relating to the
operation of trust departments by commercial banks
concerns that conjunction itself. Vocal critics of
bank trust operations have generated a rising chorus
of demands that trust activity be divested completely
from the commercial banking industry. That is not
a new challenge, certainly, but it must be viewed by
us from the new perspectives that have been created
by a public that has become much more analytical in
its approach to our institutions. It is no longer an
academic exercise; it is a serious threat. Therefore,
we must face this issue squarely.
We begin with the observation that the relationship between banks and their trust departments is
one which has endured for many generations. It
should be severed only if there develop demonstrated abuses which can't be dealt with otherwise.
The disadvantages to the public resulting from separation are many. Let me touch upon some of these.
The first relates to the number of sources of trust
services available to the public. At this time, commercial banks represent the most important corporate fiduciary. There are some 3,800 banks with
trust powers. Were public policy to require commercial banks to leave the trust field, the number of
corporate fiduciaries would decline drastically as
that policy was effected. The trust business would
then be handled entirely by individuals and by nonbank corporate fiduciaries.
The inherent problems associated with individuals
acting in a fiduciary capacity are well known. No
individual enjoys the perpetual life of a corporation.
No individual can possibly possess the comprehensive investing and management skills available in a
large trust department. Individuals are not subject
to any counterpart of bank trust department regulation. As to non-bank corporate fiduciaries, it appears
not unlikely that, over time, with the disappearance
of banks from the fiduciary area, the total number of
corporate fiduciaries offering trust services would
decline substantially. It is unrealistic to assume that
one independent trust company would replace each
bank department which is divested. An aggregation
or conglomeration of several such units is much

more apt to result because of capital requirements
and the economies of scale that are inherent in the
investment function of trust departments. Thus we
see that the public would suffer a decline in the
number of alternative sources of trust services, a
probable decline in the average quality of services
available, and a probable decline in competition in
the offering of trust services.
The second major disadvantage for the public in
the separation of trust operations from commercial
banks relates to capitalization. Currently, total bank
capital of about $50 billion is available as a protection or cushion for trust beneficiaries. Non-bank
corporate fiduciaries have a much smaller ratio of
capital to the total trust assets managed. However
a spinoff of trust operations from commercial banks
were to be handled, there does not appear to be a
conceivable way, let alone a practical way, of maintaining a capital cushion of the same magnitude now
enjoyed by trust accounts.
The third disadvantage to the public is a nonquantifiable one. It relates to the utility, that is, the
degree of satisfaction, enjoyed by an individual
establishing a trust when he is able, if he wishes, to
utilize the services of one of many of well established
commercial banks that enjoy a reputation for stability, continuity, and financial expertise. To remove
the option of establishing a trust under the aegis of
one of those institutions would appear to create a
disutility that many critics of bank trust operations
fail completely to take into consideration.
On the other side of the coin, I think a bank
benefits from having a trust department in a nonmaterial but very real manner. The trust department, with its strict adherence to sound fiduciary
principles constitutes the pulse beat of conscience
for a bank. By its very existence within the corporate
structure of a bank, it radiates responsibility—a
standard of duty for the entire operation to follow.
That pulse beat hopefully resonates even through
the "Chinese Wall" which now must exist between
commercial and trust departments.
I must point out here that I also do not find any
compelling merit in the suggestions that trust depart253

ments should be spun off as affiliates in a bank
holding company. The change effected by a spinoff
to an affiliate would be slight indeed—only cosmetic
at best. That is not to say that I object to spinoff of a
trust department if a bank finds valid business
reasons for such corporate restructuring; that is a
matter of the bank's management judgment. But do
not expect that such a separation will answer the
call for divestiture.
Let me emphasize that our Office is aware of the
necessity of vigilant regulation of trust departments
of National banks, so that we are able to give appropriate and soundly based rebuttals to the arguments
of bank trust critics. It is also incumbent upon all of
you, as trust officers, and upon us, as regulatory
officials, to provide greater publicity concerning
the comprehensiveness of bank regulatory procedures in the trust area. Too often we hear statements
—and occasionally they even emanate from Congress—that would lead the listener to believe that
trust departments are totally unregulated. You obviously know better, but we must strive to make the
public aware of the situation. We need to point out,
over and over again if necessary, the advantages
that we see for the public in the continued operation
of trust departments by commercial banks. At the
same time we must recognize that if banks are to
continue to have trust departments, several principles must be observed, some old, some new. Let
me first deal with the old.
It is no surprise to us that there are conflicts of
interest between a bank's commercial operations
and its trust department. It is a fact of life with
which you have lived for years. In the process, banks
have acquired a very real awareness of the precautions which must be taken so as to prevent the conflict from prejudicing the interests of the trust
department customers, the commercial customers,
the public, or the bank. Thus, it is not news to a
banker that the business of the bank cannot be
mixed with that of the trust department—that one
cannot be used to serve the other to the disadvantage
of the first.
In addition, the monitoring of those conflicts of
interest has been the primary target of trust department supervision by the banking agencies. It has
been what the trust department examiner looks for.
That is the primary concern of the regulations concerning trust departments. While those things are
old hat to you and me, they are not always appreciated by the outsider.
Yet, we cannot remain static in our mutual awareness of the problems which the conflicts of interest
between a bank and its trust department pose. That
254

is because we do not live in a static society or economy. As various types of trust activity expand, as
new adaptations of traditional trust services are
adopted, as banks themselves similarly adapt to the
emerging developments and financial needs of our
nation, it is inevitable that there will result the need
to apply established fiduciary and regulatory principles in new contexts. You, as bankers, have been
doing that, as have we regulators. One example is
our increased awareness of the problems inherent in
the selection of brokers; another is the need to insulate trust investment decisions from non-public
information possessed by the commercial side.
Banks have established policies and procedures to
deal with those matters, and we have made them a
subject of scrutiny in examinations. We are now
considering the adoption of amendments to Regulation 9 and to our instructions to examiners which will
further strengthen our inquiry here, and perhaps add
some clarity to the legal framework in the process.
Those amendments would deny trust department
investment decision-makers access to commercial
credit files. Also, the changes would articulate the
necessity that trust department investment decisions cannot be based upon non-public information
obtained, even by accident, from any source. Examiners would make specific checks to verify that those
limitations are observed.
However, it is now apparent that we are in an era
when the adaptation of preexisting regulatory principles and procedures is not sufficient. New principles and procedures are required in some areas.
That, I think, results primarily from the fact that
there have occurred some striking changes in the
character of the American public. They no longer
accept things on faith, but demand to be informed—
to make their own judgments. And, as much as possible, it is necessary, therefore, that they be informed as to the operation of bank trust departments, and the extent of the relationships with the
bank's commercial customers. Disclosure of the
stock holdings—indeed, of all the assets held—in
trust departments is essential to enable banks to
continue to hold the confidence of the public. Knowing what assets an institution possesses and what it
has done with those assets by way of purchases and
sales may well counter much of the criticism that has
been made of bank trust departments. Few actual
abuses of the bank-trust department relationship
have occurred; most of the criticism is based upon
supposition, upon conjecture—in a word, upon
ignorance. Dispelling that ignorance, even if it
doesn't end the criticism, may make it more constructive and lessen the opportunities for other

interests to play upon it for their own selfish objectives. I note that Jay Hambleton and I are in agreement here.
With those ends in mind, this Office is considering the issuance of regulations requiring National
banks to disclose their asset holdings, and their
transactions in securities to this Office and to the
public. I hope that we may be able to publish those
proposals for comment in the near future. We would
hope to be able to develop regulations which would
apply to all National banks of a significant size—say
with trust assets of over $100 million; and all transactions over a certain aggregate amount—possibly
$500,000 which have occurred in a quarter would be
disclosed. We shall also seek a uniformity of regulation among the three banking agencies. They now
have a uniform annual report. The proposed reports
could be adopted in lieu of the present reports for
banks above the requisite size, for example. According to our figures, if the $100 million cutoff is used, it
would affect some 200 National banks and 100 State
banks. I am satisfied that we have the statutory
authority to require reports of that nature. I would
hope that any legislation which might be considered
in that area would be drafted so as not to restrict the
flexibility of present authority; it is very important
that we be in a position to respond to changing
circumstances. It may be that there is no need for a
statutory requirement. Possibly the appropriate
regulatory agencies, including the SEC, might
cause the institutions under their jurisdiction in this
matter to report the information necessary for each
agency to carry out its functions, and make that
information available to each other, and to the
public. Thus, I hope the SEC, and all other affected regulatory bodies, will view the proposal with
favor. We will work with them to meet any problems
they might have with our proposals. Knowing the
character and ability of the Commissioners and the
staff of the SEC as I do, I am optimistic that we
can achieve a mutually satisfactory result to the
benefit of all concerned, including the public.
There are other areas of reform which we must
recognize. It comes as no surprise to trustmen that
the bottom line of most trust operations appears in
red. Fee schedules often appear designed only to
cover expenses, and even then liberal exceptions are
made when a community need or a commercial
customer is to be served—particularly the latter.
Neither is it surprising, as has been recently reported, that some bank critics have concluded that,
because bank fiduciary operations are not profitable,
corners have been cut in the services provided in
order to effect economies. I feel that banks have left

themselves open to that criticism. That, I understand, is one basis of the reported conclusion of
Ralph Nader's Center for Corporate Responsibility
in its study of the trust operation of First National
City Bank, that banks, in general, do not provide
individual service, as they claim, but use the assembly line approach. No sophisticated trustman would
deny that uniform agreements are promoted and
collective investment funds are utilized in our banks.
However, the use of those tools is easily defended,
and cannot fairly be characterized as "assembly
line." Economies of scale may be a more descriptive and more realistic definition.
Not only have most trust departments been unprofitable in the past, but management in a number
of banks seems to be content to let them remain so
in the future. The sinister conclusion might be
drawn that banks are willing to operate an apparently unprofitable trust department because their
greatest rewards exist in undisclosed form. What
were acceptable practices in the past may be viewed
with the suspicion that they are lurking evils. Indeed,
the very fact that banks hold a vast amount of stocks
of certain corporations is being questioned this very
day before a subcommittee of the United States
Senate. In previous hearings before this same subcommittee, it was suggested that banks were wrecking the stock market and might even be guilty of
manipulation of the market—the reward there being
the concentration of economic power that banks
control through their trust departments. Others have
pointed an accusing finger at banks for abuses in the
authorized practice of maintaining uninvested trust
cash balances in the bank's commercial department.
The claim is made that these balances are excessive,
resulting in unjustified profits for the bank. That
claim is given more creditability, in the eyes of the
public, by statements of trust officers that their
department would only be profitable if credit is given
for trust balances. Checking for excessive trust
cash balances has been given high priority by our
trust examiners for many years. It has been our
experience that there are very few abuses in that
area in National banks. In recent years, trust balances have been significantly reduced through the
use of short-term collective investment funds and
variable amount notes which provide for investment
of cash for periods as short as one day. But the questions will continue to arise as long as trust departments are not profitable on the basis of fee income.
The continuation of an unprofitable trust department is subject to even more legitimate criticism, I
believe. Probably most damning is the attitude
toward the department that this naturally tends to
255

create on the part of a bank's management. New
resources, both human and material, may appear
better allocated to the profit centers. The result will
be a decline in the efficiency of the department and
of the quality of its product, which only tends to
heighten its unprofitability. The personnel of the
trust department may be less apt to be promoted
within the bank—their motivation suffers, and once
again the quality of their product.
If necessary to provide a reasonable margin of
profit, banks should give serious consideration to
revising their fee schedules to reflect the true value
of the services which they are providing. Furthermore, the established fee schedule should be followed even if the prospective customer has a substantial commercial relationship with the bank. I
suggest that if the separate identities of commercial
and trust departments are not observed by bank
managements in the pricing of their products, they
are permitting a group of potentially damaging conflicts of interest to continue—conflicts which we
may no longer be able to tolerate. This may be
viewed as an extension of the Chinese Wall; I feel it
is necessary if banks' managements are to make a
serious commitment to their continuation of the trust
business.
Just as we tend to blunt the instrument with which
we write, so also can we dull and blur the true meanings of our most familiar words with constant repetition. Reflect, if you will, on what the words "fiduciary" and "trust" really mean.
If "duty" is the most sublime word in the English
language—and many have lived and died in that
belief—then the assumption of a fiduciary duty must
be the highest calling to which a conscientious
banker can respond.
If "trust" is that degree of earned respect and
confidence without which no bank can adequately
serve its customers, then no effort should be spared
to keep it inviolate.
If periodic disclosure of aggregate holdings and
transactions made in bank trust departments can
strengthen public confidence in the soundness of a
system working for the general good, we should
welcome it.
I have full confidence in the high ethical standards
that characterize bank trust activities. Given a fuller
understanding, I am sure that the public will share
that confidence. I count on the banking industry for
full cooperation to that end.
TESTIMONY BY JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE SUBCOMMITTEE ON
SECURITIES OF THE SENATE COMMITTEE ON

256

BANKING, HOUSING, AND URBAN
WASHINGTON, D.C., MAY 8, 1974

AFFAIRS,

Mr. Chairman and members of the Subcommittee,
I appreciate the opportunity to appear before you
today to support S. 1933, which would permit National banks to underwrite and deal in revenue
bonds.
I am the latest in a line of Comptrollers of the
Currency who have come to the Congress to urge
that National banks be at last permitted to serve the
public interest by underwriting and dealing in nongeneral obligation securities issued by State and
local governments. My distinguished predecessors,
in testimony before committees of previous Congresses, have perceived and articulated the tremendous public needs of State and local governments,
and the unutilized resources of National banks
which could be employed in meeting these needs. In
1965, then Comptroller Saxon told the House Banking Committee: "We must help our cities develop
the transportation, housing and other facilities which
they need." Now, 9 years later, the urban and State
problems are even greater, and National banks are
still hobbled by archaic underwriting and dealing
restrictions. Now is the time for Congress to show
the American public that those problems are being
addressed in Washington.
S. 1933 is an excellent vehicle for action in this
area. It would amend the National Banking Act to
permit National banks to underwrite and deal in all
types of revenue bonds, except special assessment
obligations and industrial revenue bonds, while
imposing certain conditions to assure prudence.
Briefly, those limitations would require that:
1. Banks underwrite and deal only in those revenue bonds which are eligible for purchase by National banks;
2. Bank investment in revenue bonds of any one
obligor in all of its accounts be limited to 10 percent
of the bank's capital and surplus;
3. A bank acting as an underwriter or dealer not
sell revenue bonds to any of its trust accounts unless
lawfully directed by court order;
4. No member of an underwriting syndicate sell
bonds to the trust department of any other bank
which is a member of the syndicate until the syndicate has closed;
5. Sales of revenue bonds by a bank to its depositors, borrowers or correspondent banks be accompanied by a statement disclosing the fact that the
bank is acting as an underwriter or dealer; and
6. Banks not transfer revenue bonds which they
purchased as an underwriter to their investment

account during the underwriting period, with certain
exceptions.
In addition, the bill would require the Secretary of
the Treasury to submit an annual report to the Congress showing the extent to which the business of
underwriting and dealing in State and local obligations is being carried on by commercial banks as
compared with other institutions in order to determine the effect of the enabling amendment on the
institutional distribution of this business.
Revenue bonds have for many years been important in financing vital public projects. They gain
public support by making those who benefit from a
specific project pay for it. Also, communities faced
with a statutory debt limit may find revenue bonds
the only means of raising the money to provide
needed facilities and services. It is highly significant
that from a negligible amount of revenue bonds
issued during the 1930's, the amount of revenue
bonds issued in 1973 was $10,632,000,000, 44.5 percent of all municipal bond sales for that year.
While popular, revenue bonds have suffered the
disadvantage of not being eligible for underwriting
by commercial banks. Studies have shown that the
average number of bids for revenue bonds has been
below those for general obligation bonds. Consequently, net interest costs on revenue issues has
been greater than that on general obligations. The
end result has been that the taxpayer paid more than
he should have. Our studies show that significant
interest savings would accrue to the public if, in accordance with our free enterprise philosophy and
practical business experience, commercial banks
were allowed to compete in the revenue bond underwriting field.
In brief, I believe that National banks should
serve the public interest and, whenever possible,
use their resources to respond to public needs. If
S. 1933 is enacted, commercial bank entry will
increase competition in the bidding for, and distribution of, revenue bonds. That will broaden and
strengthen the market for revenue bonds by improving their marketability and character as liquid investments suitable for bank portfolios and fiduciaries
generally. State and local governments should be
able to make needed public improvements more
readily, and at a smaller cost to the taxpayer.
Despite those obvious advantages, those who have
a privileged competitive position under the status
quo oppose S. 1933. Let me examine briefly their
arguments.
The first argument relates to the Congressional
policy of separating commercial banking from investment banking. While Congress did act in the

extraordinary circumstances of the early 1930's to
make such a separation in the Glass-Steagall Act, it
reaffirmed the earlier authority in the McFadden Act
of 1927 to permit National banks to underwrite
general obligations of States and their subdivisions.
Throughout the Depression and until the present
time, that authority has remained as a recognition
that debt obligations of State and local governments
have a special status. In 1968, Congress even broadened the authority to include revenue bonds issued
by State and local governments for housing, university, or dormitory purposes. The extension of underwriting and dealing authority to all revenue bonds
would simply be a logical and belated acknowledgement that modern financing techniques of State and
local governments fall into the same category of
special and privileged securities as more traditional
methods.
In this connection, Congress has frequently recognized the desirability of permitting commercial
banks to underwrite and deal in securities which it
authorizes and considers socially worthy. Examples
are obligations of the Federal National Mortgage
Association, the Government National Mortgage
Association, and even the Inter-American Development Bank and the Asian Development Bank. The
public needs of our own citizens should certainly be
accorded at least as favorable a Congressional preference.
Another argument against S. 1933 is that the
underwriting of revenue bonds entails too much risk
for commercial banks. The conditions in the bill
which I have previously discussed make clear to me
that the financial condition of National banks will not
be adversely affected by the granting of this authority. Specifically, a bank would be limited to holding
at one time in all its accounts the securities of any
one issuer only in an amount up to 10 percent of the
bank's capital and surplus. In addition, the bank
could only underwrite and deal in securities of at
least as high quality as those which it is now permitted to hold in its investment portfolio.
It is interesting to note that the default record for
revenue bonds and the ratings they receive from
bond rating services compare very favorably with
general obligation bonds. In fact, some general obligation bonds are definitely riskier than many revenue bonds. I think it is time to change the situation
in which National banks may underwrite the less
desirable general obligation bonds while being prohibited from underwriting the better revenue bonds.
Another argument against the authority concerns
possible conflicts of interest. There are those who
raise the sinister specter of bankers selling undesir257

able revenue bonds they have underwritten to unsuspecting depositors and correspondents or putting
them in trust accounts.
S. 1933 provides, by its conditions, safeguards
against such abuses. Under the bill, a bank acting as
an underwriter or dealer may not sell revenue bonds
to any of its trust accounts unless lawfully directed
by court order. No member of an underwriting syndicate may sell bonds to the trust department of
another bank which is a member of the syndicate
until the syndicate has closed. Furthermore, sales of
revenue bonds by a bank to its depositors, borrowers
or correspondent banks must be accompanied by a
statement disclosing the fact that the bank is acting
as an underwriter or dealer. Thus, the customers are
on notice and can take appropriate action to protect
their interests.
It is unrealistic to say that a bank would jeopardize
its customer relations in order to sell bonds. After
all, this is but a small portion of a bank's business.
A more likely result is that increased knowledge
concerning the revenue bond issue would permit
banks to give more accurate and useful investment
advice. At any rate, a bank would not keep a correspondent very long by palming off inferior securities on it.
Finally, the experience of my Office in regard to
National banks that underwrite other government
obligations is that conflict of interest does not seem
to be a problem. I do not think the underwriting of
revenue bonds will create a sudden dilemma in this
respect.
The Senate has previously recognized the wisdom
of permitting commercial banks to underwrite and
deal in revenue bonds. In 1967, a bill similar to
S. 1933 was passed by the Senate. At that time, the
Senate Banking Committee considered in detail the
benefits to local governments which would result
from bank competition in revenue bond underwriting. I think it would be appropriate to quote the wellconsidered conclusions of the Committee:
In addition to a higher incidence of negotiated
sales, revenue bonds also enjoy fewer bids, even
when they are issued through competitive bidding. . . .
The number of bidders is extremely important
to a hard-pressed municipality since the figures
show the interest paid is inversely related to the
number of bidders. In other words, the greater
the number of bidders the lower the rate of
interest which the city will have to pay on its
bonds. (S. Rept. No. 713, 90th Cong.)
S. 1933 is good for the American people, good for
258

the local governments and good for the National
banks. I hope that I will be the last Comptroller of
the Currency to come to the Congress to urge passage of a revenue bond underwriting bill.
TESTIMONY BY JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE SUBCOMMITTEE ON
SECURITIES OF THE SENATE COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS, WASHINGTON, D.C., MAY 8, 1974

S. 2474 is designed to establish a system of Federal supervision of parties trading in the municipal
securities market. That market has, in the main,
performed its debt financing function for State and
local governments and other public agencies over
the years with commendable efficiency and integrity. That has occurred in a setting largely free
from Federal supervision, although the anti-fraud
provisions of the securities laws have been applicable. However, there have been a number of isolated
cases of abuses in recent years which we believe
may justify consideration of adoption of some degree
of Federal regulation and enforcement supervision of
certain aspects of the municipal securities business.
This Office has been working with the Securities
and Exchange Commission in an attempt to arrive
at a legislative approach which both our agencies
would be able to support. Although we have not at
this point reached such an agreement, I am optimistic that it is still within the bounds of possibility
that we do so. For that reason, I shall confine my
testimony to a few general observations covering the
subject of S. 2474.
We do not believe that the evidence at hand respecting abusive practices supports such a sweeping
and undefined regulatory power as S. 2474 would
establish. It should be noted that nearly all of the
abuses of which we are aware have been subject to
the SEC anti-fraud powers. We believe that the historic concept of this nation, of a government of
limited powers, imposes a heavy obligation on those
of us in the regulatory agencies to spell out with
reasonable clarity the business practices or activities
which justifiably should be regulated to protect
legitimate public interests. The carte blanche delegation of regulatory powers which S. 2474 would
entail seems to us contrary to the fundamental
philosophies of our government and in excess of
what the situation requires.
S. 2474 contemplates the creation of another selfregulatory agency with rule-making and enforcement
powers, similar to the National Association of
Securities Dealers. For the reasons I have just
stated, we do not believe that the establishment

of another such self-regulatory body is warranted.
While the establishment of a rule-making board
composed of segments of the municipal securities
industry plus representatives of the public interest
may be of benefit, existing enforcement mechanisms
contain the potential to carry out the rules and
policies which legislation in this area would provide for. The NASD and/or the SEC could perform
that enforcement function for non-bank dealers. The
banking agencies are ready, willing, and able to perform a similar function for bank municipal bond
dealers. Such a solution was wisely adopted by the
Committee on the regulation of stock transfer agencies and depositories in S. 2058, which passed the
Senate. That is a more desirable solution on enforcement, we believe, because it makes allowance for
the preservation of bank soundness while still accomplishing the purposes of the bill. In addition,
utilization of those existing enforcement mechanisms will avoid the increased expense and bureaucracy which the creation of a full-blown self-regulatory body would entail.
After all, it is the result which is important. Rather
than a simplistic identicalness of enforcement
mechanisms which makes no allowance for bank
solvency, we believe that investor protection can
best be achieved through a coordinated enforcement
endeavor, with the banking agencies expressly
having the first opportunity to correct an abuse, and
the SEC having a residual authority which it should
exercise only after consultation with the appropriate
banking agency. In addition, it would appear that
the banking agencies should have the right to request that the Commission take action against a nonbank municipal securities dealer.
The enforcement provisions of legislation in this
field should make those principles explicit. At the
same time, they should make clear that the banking
agencies can use their present powers, including
Section 8 of the Federal Deposit Insurance Act, to
enforce the requirements of the legislation, and any
rules promulgated thereunder.
Similar comments might be made with respect to
inspections of bank municipal securities dealers.
Inspections for information purposes, such as
S. 2058 contemplates, should be differentiated from
those for enforcement. As to the former, we recommend that authority be made subject to similar constraints as S. 2058 contains, basically that the Commission coordinate its inspections with the examinations of the appropriate banking agency. As to the
latter, the same safeguards as we have recommended for enforcement actions should apply.
We also believe that the principles of limited gov

ernmental interference with legitimate business
practices which we mentioned a moment ago dictate
that the powers of any agency which is given the
authority to issue rules and regulations governing
municipal securities dealers should be carefully circumscribed and defined. It would appear desirable
that it be required that all government agencies involved in the regulatory process be consulted at
some stage in the establishment of such rules. We
have included in an appendix to this statement a list
of the powers which we believe should be the limit
of authority given the rule-makers under this legislation. Those subjects are reasonably related, we believe, to the undesirable practices which have been
observed in the industry. We believe it far better for
the agencies involved to return to Congress for additional powers if experience develops that those given
are insufficient. We have no doubt that this body
would respond promptly and responsibly to such a
request.
We also have a number of suggestions on technical points. Those points are also contained in the
appendix to this statement.

APPENDIX

List of Subjects of Authority for Rulemakers
1.
2.
3.
4.
5.
6.
7.
8.
9.

Fraudulent, manipulative or deceptive practices
Suitability
Markups
Excessive transactions
Trading by members of syndicates
Authorization and acceptance of accounts
Approval and review of transactions
Voluntary arbitration procedures
Accounts, correspondence, memoranda, papers, books, records and other data which must
be maintained.
10. Procedures for periodic inspections
Section 2(23).
Section 2(25). Add "subsidiary" before "department" wherever it appears. This is consistent with
the treatment accorded bank operating subsidiaries
in S. 2058 and recognizes that such entities are subject to many of the same considerations as apply to
parent banks.
Section 2(24). Preserve "actively." Delete "including any employee of such dealer. The Commission
may by rules and regulations classify, for the purposes of any portion of this title, persons, including
employees, controlled by a municipal securities
dealer."
259

The requirement that a person within this definition must be "actively engaged" in dealer activities
is desirable—any broadening of this group to persons
"directly or indirectly" engaged in these activities is
too broad, especially when viewed in the context of a
large bank affiliated with a bank holding company.
It would impose unnecessary burdens upon persons
and entities whose functions are largely unrelated to
a bank's conduct of municipal bond dealer operations.
Section 7. Revise to read: "The Commission and the
bank regulatory agencies shall include in their
annual reports to Congress a summary of their regulatory activities with respect to municipal securities
dealers." We see no reason for singling out banks
for special treatment, and believe that such reports
regarding banks could best be made by the appropriate banking agency. It is possible that such reports could be potentially damaging to existing
banks; the banking agency could best apprise Congress of the sensitivity of such information and in
appropriate cases make recommendations for its
safeguarding.
STATEMENT OF JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE SUBCOMMITTEE
ON BUDGETING, MANAGEMENT, AND EXPENDITURES AND THE SUBCOMMITTEE ON INTERGOVERNMENTAL RELATIONS OF THE SENATE
COMMITTEE ON GOVERNMENT OPERATIONS,
WASHINGTON, D.C., JUNE 27, 1974

"Disclosure of Corporate Ownership"
We appreciate having the opportunity to testify
here today. The area of your inquiry is a very vital
one; one in which our Office has for years been concerned. It has been a matter of some surprise to us
in the past few years to observe that much of the
public discussion of bank trust departments and
their supervision has not taken cognizance of the
role of the bank regulators in this area, both present
and potential. So it is that we welcome this invitation
here this morning, hopefully, to add some perspective to this subject.
Some background of the activities of the Office of
the Comptroller of the Currency might be useful.
This Office has the primary regulatory authority
over the National banks of this country. However,
until 1962, that authority was shared with the Federal Reserve Board with respect to the trust departments of National banks. National banks had to
obtain the approval of the Federal Reserve before
they could establish such a department, and to con260

form to the Federal Reserve's rules, then Regulation F, in the operation of that department. At the
same time, they were examined and otherwise
supervised by this Office.
In 1962, Congress corrected that anomaly and
transferred the licensing and regulation-making
authority over National bank trust departments to
this Office. In the same act, the regulation-making
authority over common trust funds of all banks and
pooled pension and profit sharing trusts of National
banks was also placed in the Comptroller.
The trust departments of all National banks have
been regularly examined by this Office since the
mid-1930's. In addition to the examinations which
we conduct at least three times each 2 years of the
National banks' commercial operations, a specialized examination is conducted annually of their
trust departments. Those examinations are performed by trust specialists. Neither the examinations of the banks nor of the trust departments are
rigidly compartmentalized, so that examiners of
either function may and do obtain the necessary
information through reference to the records found
in either section of the bank.
In the course of their examination of a bank's trust
department, our representatives scrutinize very
carefully the investments of the trust portfolios.
They look for conflicts of interest, self dealing, or
other violations of the law of trusts, as well as applicable State and Federal laws. In the performance
of that examination they, as a matter of course,
ascertain which securities are owned by each account and who the beneficial owners of those securities are. The fact that the trustee bank holds
entrusted securities in the name of a nominee does
not conceal the beneficial ownership of each trust
asset. Violations of law, regulation or sound fiduciary
principles discovered by the examiner are criticized
in the report of examination. Such criticisms are followed up by this Office until satisfactory correction
is made. In addition, all trust holdings of stock of the
trustee bank and affiliated companies are reported
to this Office in the report of examination. Thus,
over the years there has been no lack of knowledge
on the part of this Office as to what was held by
National bank trust departments, or identity of the
beneficiaries of each account being administered.
What I have discussed thus far indicates that the
report of examination deals with specific criticisms
and with trust holdings of securities of the bank and
its affiliates. Where additional information has been
needed, it has been obtained by requiring the filing
of other reports. Thus, National banks have, since
the 1930's, been required to file annual reports with

this Office, setting forth the amounts of trust department assets held by category—stocks, bonds, real
estate, etc. In 1963, this Office amended that system
of reports to require market value figures, rather
than the often inaccurate book values which had
prevailed theretofore. The other banking agencies
followed our lead in this revision a couple of years
later, and it was this method of reporting which was
adopted by Chairman Patman's Subcommittee in its
report on commercial banks and their trust activities, published in 1968.
Since 1963, this Office has also required all banks
operating common trust funds and National banks
operating pooled trusts for the collective investment
of pension and profit sharing funds to file their
annual reports for such funds with us, and to make
them available upon request to anyone. Previously,
under the regulations of the Federal Reserve Board,
banks were prohibited from disseminating information regarding common trust funds. The 1963
amendments of this Office required the disclosure
by National banks of the assets held in all collective funds. As you know, those funds are used by
banks collectively to invest the assets of separate
trusts. As such, the funds represent the largest
asset pools within banks and, thus, are the most
relevant sources of information for one who is interested in ascertaining what the investment policies
and holdings of given banks may be. At the same
time the reports do not reflect the individual accounts which are invested in the collective funds or
their beneficiaries, thus their disclosure does not
interfere with the confidentiality of individual holdings.
In an effort to provide further information on bank
fund holdings, this Office, in 1965, initiated an
annual questionnaire to all banks operating common
trust funds. That questionnaire elicits information as
to common fund holdings as of a given date, thus
furnishing a basis of comparison for such holdings.
Those data have been assembled annually in tabular
form and made available to the public by this Office,
occasionally accompanied by analyses of their
investment composition and performance as against
other types of funds, prepared by members of our
Department of Economics.
In April of this year, this Office published for
comment proposed regulations requiring National
banks to make disclosures of trust department
holdings of individual securities. Under those proposals, National banks having trust assets of $100
million or more would be required to file this additional report with this Office. Holdings in excess of
10,000 shares of any one company will be reported.

This report would require disclosure of the degree of
investment responsibility and voting power over the
shares held. In addition, the proposed rules would
require National banks tofilereports quarterly on all
transactions which have occurred during that period
which are in excess of 10,000 shares of $500,000 in
value.
That additional reporting system, we believe, is
desirable in view of the increased awareness and
interest of the public in this subject. As I stated in
announcing those proposals in February of this year:
They no longer accept things on faith, but
demand to be informed—to make their own
judgments. And, as much as possible, it is
necessary, therefore, that they be informed as
to the operation of bank trust departments, and
the extent of the relationships with the bank's
commercial customers. Disclosure of the stock
holdings—indeed, of all the assets held—in
trust departments is essential to enable banks to
continue to hold the confidence of the public.
Knowing what assets an institution possesses
and what it has done with those assets by way of
purchases and sales may well counter much of
the criticism that has been made of bank trust
departments. Few actual abuses of the banktrust department relationship have occurred;
most of the criticism is based upon supposition,
upon conjecture—in a word, upon ignorance.
Dispelling that ignorance, even if it doesn't end
the criticism, may make it more constructive
and lessen the opportunities for other interests
to play upon it for their own selfish objectives.
It is our understanding that the other banking
agencies are preparing similar reporting requirements. At present, 224 National banks would be
covered by the proposal. If the Federal Reserve were
to adopt a similar requirement, 80 State member
banks would be affected. If the FDIC were to do
likewise, another 39 State banks would be subject
to the rules. Our Office plans to make the information contained in the reports available to other
government agencies, and the public. The period for
comment on the proposed rules has just expired,
and we are in the process of analyzing the comments
we have received. We hope to be able to make the
regulations final in the near future and to receive the
first annual report of holdings as of December 31,
1974, along with the initial quarterly report of transactions, covering the last quarter of this year.
We believe that between the requirements of
disclosure which we are going to impose, and the
supervision of trust departments which we are per261

forming through the examination function, the necessary protection to the public can be achieved with
the minimum interference with business, while
similarly keeping the expansion of the federal
bureaucracy under restraint.
Our philosophy throughout the period which I
have just reviewed, has been one of requiring increased disclosure by bank trust departments. We
have endeavored to provide the maximum of meaningful disclosure while imposing a minimum of burdensome reporting requirements, and also avoiding
any unwarranted governmental intrusion into the
privacy of individual estates. We have not, and we
do not intend, to require public disclosure of the
holdings of individual accounts, or of the persons
holding beneficial interests in them. Frankly, we can
see no justification for proceeding so far into the private financial affairs of individuals. Adequate authority exists for the respective agencies of government to obtain such information where it is relevant
for legitimate government purposes.
TESTIMONY BY JAMES E. SMITH, COMPTROLLER
OF THE CURRENCY, BEFORE THE SUBCOMMITTEE
ON FINANCIAL INSTITUTIONS OF THE SENATE
COMMITTEE ON BANKING, HOUSING, AND URBAN
AFFAIRS, WASHINGTON, D.C., JULY 31,
1974

It is a pleasure to appear today in support of S.
3817, a bill to amend the National Bank Act and
certain other acts to permit federally insured financial institutions to charge 5 percent above the Federal Reserve discount rate on loans to corporate
borrowers.
As the regulator of National banks, our Office is
well aware of the reasons for this bill. In a number
of states, usury laws limiting the amount of interest
that National banks may charge on loans apply to
corporate loans as well as to personal, consumer
loans. In Tennessee, Arkansas, and Montana, for
example, the maximum loan contract rate for corporations is 10 percent, a figure below the prime rate
and the Federal funds rate. The inevitable result of
that condition is the lack of funds available for the
normal and productive conduct of the banking business as it relates to the corporate sector. Let me give
you some examples.
A National bank in Tennessee has had a restrictive policy on loans for the past 4 months. Its senior
loan officer has told us that $22 million of creditworthy loans had to be refused. Although the stringent money market conditions have been partially
responsible, the rate limit factor has been present in
every case. The bank estimates that around 50 percent of those loan applications would have been
262

approved if the bank had the ability to price the loan
terms competitively.
Examining the situation on a case-by-case basis,
another National bank in Tennessee had to turn
down an otherwise creditworthy loan of about $1
million to a new company in the furniture manufacturing field. That new operation would have added
new jobs to the Tennessee economy but has not been
able to commence operations because of the lending
restrictions in Tennessee.
The same bank had another application for a
$400,000 loan from a coal company for the purchase
of coal mining equipment. Despite the offer of personal endorsements on the loan and good equipment
collateral, the loan was turned down because of the
credit restrictions in Tennessee. Certainly that loss
to the energy resources of the country is a very
undesirable consequence of the special problems
National banks face in states which extend usury
laws to corporate borrowers.
In addition to those instances I have seen copies
of letters from businessmen in the affected states
that reflect their deep concern about the restriction
of available funds. A food company executive says:
"Our business is hurt by this restriction." A small
businessman cites the possibility that his company
might "run short in relation to current payables,
payroll, capital expenditures and expansion." Yet
another letter, this one from a shopping center
development company executive, states:
Because of the 10 percent usury law, we are
being slowed up and find it very difficult to continue to develop in our State. Most of the other
areas we are operating in are not handicapped
by this law.
In the vital area of health products, officials of a
company supplying drug prescription products
states: "Our ability to meet these needs is being
seriously impaired due to the critical shortage of
corporate money in Tennessee."
Of course, those examples illustrate the more
fundamental question of usury laws and their social
utility. Usury laws have always been presented by
their proponents as offering protection against unreasonably high or unfair rates of interest. As long as
the legal rate ceiling is above the going market rates,
it is obvious that the law has no effect. During those
periods the existence of usury statutes is widely
ignored.
When the level of interest rates moves upward,
and the going market rates for particular types of
loans would, in the absence of restrictions, exceed
the legal maximum, the funds funnelled by lending

institutions to those types of loans dwindles over
time and eventually disappears. While banks certainly attempt to meet the needs of their long-time
customers, they are not charitable institutions.
Therefore, they cannot indefinitely channel funds to
uses yielding rates of return well below rates available on alternative uses or at rates below the bank's
marginal cost for funds. It is cold comfort to a prospective borrower to be aware that he is "protected"
from "usurious" rates of interest when no funds
are available to him at the legal rates.
While the most desirable solution to this problem
would be remedial action at the State level, we must
confront the reality that in some affected states there
is scant chance of such action, at least in the near
term. In a State such as Tennessee, where the rate
limit is a constitutional provision, the elaborate
machinery simply cannot be cranked up in time to
solve the very immediate dilemma. That, of course,
mandates Federal attention to an economic problem
which is regional in scope and National in effect.
There is adequate precedent for Federal action in
this area. In 1933, the National Bank Act (12 U.S.C.
85) was amended to permit National banks to charge
1 percent above the discount rate on 90-day commercial paper in effect at the local Federal Reserve
Bank. Senator Glass, who introduced the amendment, perceived that when such a rate exceeded the
State interest rate ceilings, National banks had to
be the instrumentalities to permit businesses to borrow money, or face possible collapse.
Although the Federal Reserve discount rate no
longer reflects market rates and the 5 percent above
discount rate provision is a necessary amendment,
I think that precedent has some value in itself. It has
been suggested that the Congress select an index,
such as the 90-day Treasury bill rate, that would be
more responsive to market conditions. As the need
is for immediate remedial action, the most effective
procedure would be a modification of the existing
law, referring to the discount rate, in the manner of
the bill introduced by Senator Brock. In this connection, the 5 percent leeway will give a sufficient
margin of return to reopen the channels of credit to
many deserving corporate borrowers in states such
as Arkansas, Montana, and Tennessee.
I am pleased to note that S. 3817 extends the
coverage of the proposed amendment to all federally insured banks and savings and loan associations. This is in line with a recommendation transmitted to Senator Brock by our Office.
National banks in those states need the additional
authority granted in S. 3817 in order to serve adequately the financial needs of businesses, on which

payrolls and economic development depend. Swift
passage of the bill would be a service to the public
in those states.
TESTIMONY BY JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE SUBCOMMITTEE ON
SECURITIES OF THE SENATE COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS,
WASHINGTON, D.C., AUG. 13, 1974

We are pleased to testify here this morning on
S. 2234 and S. 2683. While they have individual
variations, they also have in common certain features upon which my comments today will primarily
focus.
These bills would establish a comprehensive
system of disclosure of securities held by institutional investors. Also required would be the reporting of securities transactions by those investors.
These reports would be filed with the Securities and
Exchange Commission.
We believe that the objectives sought to be accomplished by the bills have desirable aspects. The
need for public disclosure of what is held by institutions, and what they are doing with those holdings,
has been shown. The Comptroller's Office has
recognized this by imposing additional disclosure
requirements upon National bank trust departments
which by the end of the year will be providing much
of the information called for by these bills.
Both bills, however, would impose disclosure
requirements which go beyond what appears to be
justifiable for regulatory objectives. In the process
they would impose unjustified cost and administrative burdens upon banks.
We do not believe reports of bank holdings of
securities need be made more frequently than once a
year. Neither do we believe that reports of debt
securities are necessary. There would also be added
cost to banks in providing such reports on a more
frequent and comprehensive basis.
If the purpose of the legislation is only to enable
all agencies of government and the public to be informed of the power wielded by institutions, and the
effect their securities transactions have on the
market, that can be accomplished by requiring
annual reports of equity holdings, and quarterly
reports of transactions in those securities. The information which an annual report reveals, supplemented by information revealed in quarterly reports
of transactions, will provide a reasonably accurate
source of information on the potential influence
which a single or any several institutions might have
over particular companies or industries. Reports of
263

trading in debt securities are not very necessary or
helpful to these purposes.
On the other hand, if increased disclosure is also
desired to enable persons to measure the performance of institutions, it is not accomplished by
requiring banks to give quarterly reports of securities held in all types of accounts. The total securities
holdings in a bank trust department will be a reflection of the varying restrictions which a myriad of
governing instruments impose both on retention of
assets received with various estates, and on the
permissible range of investments to be made by the
bank. That can be no basis for any intelligent or
accurate measurement of performance. The best,
perhaps the only, reliable basis for measuring bank
performance is the thorough analysis of asset composition of bank collective investment fund portfolios. Current regulations already require the
annual disclosure of the holdings of those funds, plus
all transactions which have occurred in that period.
Another possible index of performance would be the
holdings of individual pension funds. That information would not be brought forth by the reports required by these bills. It is, of course, already available in the reports required under the Welfare and
Pension Plans Disclosure Act, as amended. In any
event, we believe that the foregoing shows that quarterly reporting of holdings of all securities held by
banks cannot be justified by the performance data
which those reports would yield.
As indicated previously, the Office of the Comptroller has imposed on National banks a system of
disclosure which is consistent with the foregoing
principles. It requires what is needed for all legitimate needs, and no more. It can be effectuated
within a reasonable period. Best of all, it is flexible.
It can be readily amended to provide any additional
disclosure which the Congress believes appropriate.
It coincides with the existing bank supervisory
framework, and will cover the bulk of the bank institutional investors. The information will be available
to the SEC and all other agencies, as well as Congress and the public.
Given this set of circumstances, we respectfully
ask this Subcommittee to consider carefully whether
legislation placing an across-the-board reporting
requirement with the SEC is warranted. We suggest
that consideration be given instead to the enactment
of authority in the SEC to compel the production of
reports from any institution which is not already
providing reports which conform to certain set
standards—which standards we hope would be along
the lines of our present reporting system. We submit
that that would satisfy the essential public concerns,

264

while at the same time avoiding an unnecessary
expansion of the Federal bureaucracy through a
duplication of regulatory efforts.
REMARKS OF JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE ROBERT MORRIS
ASSOCIATES

FALL

BUSINESS

SESSION, ATLANTA, GA., NOV. 11,

CONFERENCE
1974

Although the title of my address appears in your
program as "Famous Banking Wrecks", it should be
more discreetly and appropriately described as
"The Advancing Art of Bank Regulation" or "Some
Lessons from Recent Bank Failures". As a compromise I am entitling this speech "Address by James
E. Smith".
Actually, I am not here today simply to rehash
some old war stories for the sake of their entertainment and dramatic value, to which it would take a
Shakespeare to do full justice, but rather to extract
the lessons from recent bank problems for instruction in desirable directions for regulation in the
future. Some of those lessons have already found
form in new regulations, and others are now being
evaluated with better informational and analytical
tools. These matters are of substantial import to our
industry, and it is appropriate that I bring them to
the attention of those bank officials most directly
affecting the safety and soundness of our banking
system in their daily decisions—the men who determine the nature of the loan portfolios of our banks.
Let me start out with a couple of lessons that we
learned in the failure of United States National
Bank of San Diego. This was a case, as you know, of
a total corruption of sound and honest credit administration principles that ultimately brought about the
bankruptcy of a major institution and economic
injury to many innocent people, though thankfully to
no depositors.
Upon being sworn in as the 23rd Comptroller of
the Currency in the summer of 1973, I immediately
joined my new colleagues in the salvage effort being
directed toward USNB, an effort which culminated
in the failure and sale of that bank to Crocker National in October of the same year. Our post-mortem
analysis certified that which we already knew; that
USNB was the victim of what I have characterized
on more than one occasion as "self-dealing lending
run riot."
The interrelationship between C. Arnholt Smith,
USNB, Westgate California Corporation, British
Columbia Investment Company, and other affiliated
interests has been detailed previously in major news
publications. Moreover, I believe that between
Frank Wille and me, the USNB story has been

recounted at least once during the past year to every
individual even remotely connected with the banking
industry.
I will try to hold repetition to a minimum but, in
order to give you some perspective on the scope of
the self-dealing involved, let me throw out a few
numbers. Our examination of USNB, completed in
March 1973, showed credit extensions of about $340
million to affiliated interests of Arnholt Smith,
roughly 38 percent of the loans of the bank. An
additional $42 million had been indirectly channeled
to associated companies through standby letters of
credit. We were clearly not dealing with a small time
operation.
Within the realm of failed banks, self-dealing is
not an uncommon causal factor. In fact, 11 of the 31
bank failures since 1968 may be primarily attributed
to insider transactions and that same factor was
significantly present in 16 others. The FDIC reports
that 75 percent of the banks appearing on the
"Serious-Problem-Potential Pay-out" list and 54
percent of those listed as "Serious Problems"
involve excessive insider dealing.
Almost a year ago I testified on the USNB receivership before the House Subcommittee on Bank
Supervision and Insurance. At the conclusion of that
testimony, I indicated that we had tentatively identified some potential problem areas which would be
reviewed with the goal in mind of developing regulations to curtail future USNB-type abuses.
The first regulatory response directly associated
with USNB's impact came last August when the
three Federal regulatory agencies adopted rules
making the single borrower lending limit and the
restrictions on lending to affiliates applicable to
standby letters of credit. There is a statutory limit of
10 percent of capital funds allowed for the extensions
of credit to any one borrower. The effect of the new
regulation will be to require the aggregation of direct
loans and standby letters of credit when extended
for the benefit of the same borrower.
The rationale of that rule is that under a standby
letter of credit the bank is undertaking a legally
enforceable commitment that resources will be
available to support a particular borrower if funds
are subsequently needed and the concept of concentration of risk is every bit as present in this device as
it is in a straight loan. From the standpoint of administering the law aimed at preventing undue concentration of risk by a bank as to any one borrower, the
greatly increased use of standby letters of credit in
recent years has made it imperative that the loan
limit be applied to those instruments. We will also
now be in a better position under that regulation to

prevent imprudent use of the standby facility, such
as occurred in the United States National Bank case,
for the benefit of the controlling interests.
The other major regulatory development thus far
to have been spun-out of the USNB case is the regulation we have proposed to require the identification
of officer and director business interests so that
bank examiners can properly review the appropriateness of extensions of credit to affiliated interests of
those individuals. That was a major element in the
USNB problem. Arnholt Smith was able through
numerous business entities in which he had undisclosed interests to subvert bank loans to his own
use, greatly in excess of the legal maximum to one
party. The core of that problem was that the examiners had no records within the bank to turn to that
would identify all of the various business interests of
Smith so that they could properly police the loan
limit. The new regulation, which I am publishing in
final form this week with an effective date of January 31, 1975, will substantially reduce the likelihood
of massive self-dealing occurring again in a National
bank.
The new regulation will provide that directors and
principal officers of National banks will be required
to keep on file at the bank, for review by our examiners, by the bank's board of directors, management,
and appropriate lending officers, auditors, and attorneys, a statement identifying any business enterprise in which the reporting officer or director, his
spouse, or his minor children have an interest, and
any relationship such an enterprise might have with
the bank. In order to assure completeness and truthfulness in answers, the statements filed are made
subject to the penalty provisions of the Federal
criminal statutes. With that comprehensive treatment of the business interests of bank officers and
directors in hand, bank examiners will be able to
identify all credit relationships of the bank to
affiliated interests of those officials, and determine
whether such relationships are within the statutory
limits in amount and whether they are fair from the
standpoint of the bank.
One of the primary benefits of that regulation will
be that, from the standpoint of a responsible bank
president or credit officer, there will be a strong
regulatory policy behind that regulation for him to
rely upon in requiring that any extensions of credit
to officers and directors and their affiliated interests
must meet the toughest standards applicable to any
non-affiliated customer. The bank's best interests,
not those of the officer or director seeking the loan,
will be the criterion in such loans.
The types of business interests to be covered by
265

that regulation include the ownership of stock, or
other legal or beneficial interest in a business enterprise, which amounts to 10 percent or more of the
outstanding equity interests in the enterprise or any
class of stock therein. Included also will be any indebtedness owed to another enterprise in the amount
of $100,000 or more, and certain holdings of indebtedness of other enterprises. Additionally, all
instances of an authority in a director or officer to
direct the management or the policies of another
enterprise, whether through the ownership of securities, by contract, by intercompany relationships, or
otherwise, will be reported. Any positions in an
enterprise, including those of employment, trusteeship, beneficiary, or partnership, will be reported.
For the purposes of determining the "interests and
positions" in an enterprise, a director or officer's
immediate family's interests or positions will be included, the family being defined as his spouse and
minor children.
Our expectation is that the new regulation should
prevent much of the abusive self-dealing practices in
the relatively small portion of the National Banking
System where they exist. The banking industry will
do credit to itself in the eyes of the regulators, the
Congress, and the banking public by affirmatively
implementing both the letter and the spirit of the
regulation.
Out of our general experiences with troubled
banks in recent years we are also moving in several
other areas where problems for banks can appear.
One of our recent efforts to strengthen regulatory
oversight capabilities in the bank lending area includes a past-due loan report series. Soon all National banks will be submitting to us, on a regular
basis, a summary of their past-due loans as a porportion of their total loans. We plan to require submission of those reports every 2 months, with the report
date falling on the last business day of the cycle's
second month. The first such date is the last business day of November, with submission due on
December 10. Data on four loan categories, including real estate, commercial and industrial, personal,
and "all other'^_are__rejjuired.
We believe that the report will furnish our Office
with a useful regulatory tool. Our Regional Administrators will receive a copy of those reports and thus
will be able to follow loan delinquencies for each
individual bank on a more frequent basis than our
present examination cycle allows. We will subject
the data to intensive computer analysis. The results
will allow us to distinguish regional differences, sizeof-bank differences, and differences by type of loan.
Over time we will be able to make valuable year-to266

year comparisons. We plan to return to every
National bank a summary of the results so that the
individual bank can comparatively place itself within
the spectrum of banks of its own size and region, and
generally structure its loan and past-due policies
from a more informed position. I think that the ultimate result of this better information will be a lower
proportion of past-due to total loans, which naturally
improves the safety of the system, and will probably
improve bank profitability as well.
From the 200 largest National banks, we have also
requested a new report, entitled the "Maturity
Schedule of Assets and Liabilities", to be completed
as of the last business day of October 1974 and
due by November 15, and thereafter every three
months.
We have felt for some time that the "Bank Liquidity Analysis" (BLA) form, which every National bank
has been submitting with the Report of Condition
since December 1966, has imperfectly measured the
liquidity of the larger National banks. Perhaps the
principal weakness of the BLA form is that it does
not measure access to market funds possessed by
those banks. We give less credence to another criticism of it from bankers, that it does not take into
account the liquidity entailed in a loan runoff.
It is our observation that an ongoing bank that plans
to be a continuing institution can not rely upon its
ability to cut back the extension of loans, and that
such new extensions typically match or more than
match funds received in the runoff.
Ideally, in any attempt to analyze the matching of
maturities of assets and liabilities, one would want
access to a maturity breakdown for all those assets
and liabilities for which the maturity concept has
meaning. In our discussions with the banking industry during the spring and summer, however, it became apparent that at this time we could not secure
comprehensive maturity data on loan portfolios from
even the larger National banks. Consequently, our
initial Maturity Schedule does not require loan maturity data. I have urged the larger National banks,
however, to pursue the task of computerizing loan
records as rapidly as possible. We believe that for
both our purposes and the purposes of bank management, such information is invaluable.
We are aware of the argument that loan maturity
data would tend to overstate liquidity, because there
are often unwritten commitments to rollover C&I
loans. We recognize the existence of such commitments. However, we also tend toward the view that
the contractual terms of a loan agreement provide
the best base from which to begin the process of
estimating the effective maturities of loan portfolios,

an element which will be important to a fully satisfactory data base.
With the data we develop from the Maturity
Schedule, we will be able to run analytical programs on individual banks and on the aggregate. We
believe that can provide us with a comprehensive
picture of the true liquidity situation of each bank
and of the industry as a whole. Projections might be
able to be made of what the impact on each bank
might be of changes in certain major variable factors
such as interest rates, aggregate deposits in the
system, increases in loan demand, and so forth.
Significant findings will be made available to the
individual bank and/or to the industry as a whole, as
may be appropriate.
The end result of the Maturity Schedule project
should be a much better informed banking system
where banks can properly plan future actions with
an understanding of what changes in their true
liquidity situation may develop as a result. At some
point it may be possible to carry this system on an
individual bank basis to the smaller banks as well,
although they will also benefit with the initial program in knowing more about the general liquidity
situation in their industry.
Another current endeavor of our Office relates to
our examination treatment of loans to large national
corporations in which two or more banks provide the
loan proceeds. Our Office has arrived at the fairly
logical conclusion that we cannot justify divergent
treatment of the same loan among participating
banks. To achieve uniform treatment calls for new
procedures.
We have taken steps to set up a procedure under
which a team of senior examiners from various
regions will go to the "lead" banks for all loans totaling $20 million or more in which two or more banks
are participating. The examiner team will decide
upon the appropriate classification of the national
credit during the visit to the lead bank. That will
continue to be the sole classification in all participating banks until the next examination of the credit in
the lead banks. Additional reviews of such credits
may be made on an unscheduled basis when there
are significant developments that have affected, or
would be likely to affect, the quality of the credit.
Each of our Regional Administrators will receive a
copy of the classifications of national credits and we
also plan to furnish a copy to the Conference of State
Bank Supervisors (CSBS). We have worked closely
with the Conference and with the American Bankers
Association in developing the nuts and bolts of this
program.
According to our latest information, it appears

likely that CSBS will begin a similar program. If that
is the case, CSBS will furnish us those classifications
made for national credits in which State banks take
the lead position. Not only will this program eliminate the obvious inequities of divergent classifications, but will also improve the efficiency of our
examination procedure. We are instituting a similar
program to secure uniform classification of foreign
credits in our examination of the international operations of National banks.
Despite our regulatory activities in the lending
area, we all know that the real responsibility for
maintaining high loan policy standards and, among
other things, thwarting self-dealing, rests with individual banks. The fundamental element of a bank's
efforts to assure quality in its loans is a written loan
policy. Unfortunately not every bank has a good
policy or, for that matter, any formal policy at all and
even some who have good written loan policies do
not observe them. From time to time, our Office gets
inquiries on how to formulate or strengthen a loan
policy and we generally recommend a nine point
program which is not far different from that proposed in a number of banking publications.
One point which we emphasize in our recommendations and one which becomes increasingly important in today's economy concerns loan review. The
importance of periodic loan review and of increasing the frequency of that review when economic
conditions dictate cannot be stressed too much.
Our examination records show that many of today's
criticized loans result from failure to establish a firm
loan review procedure.
We are seeing a good example of the importance
of loan policy and loan review in the construction
and the housing industries. The energy crisis, rising
building material costs, high interest rates, and general inflationary pressures have caused some
builders to default on their loans. While banks
should continue to support the mortgage market to
the maximum extent feasible, they also need to be
wary of acting too casually in this area, particularly
in the construction field.
I am speaking specifically of so-called "front-end
loans" or "front money loans". As you know, that
type of loan is short-term, unsecured, and typically
used to cover such preliminary building costs as
architect fees, feasibility studies, or picking up land
options. It is also the mechanism that provides the
builder with the front money equity which is required by the financial institution providing the construction loan. Thus, the promoter of a construction
project may reach the construction loan stage without involving any of his own funds. When the project
267

shows signs of weakness and either construction
loan funds or sales funds do not show up, the frontend lender may be left with little or no prospect of
repayment.
The bank with a solid written loan policy that is
enforced would probably be insistent on obtaining a
better secured position with respect to such loans to
begin with, and probably in a systematic loan review procedure would have identified the developing
problem in that area in time to retrench such lending
activities. But, as I said earlier, some banks do not
apply a rigorous written loan policy or review procedure and are learning the costs of that lack of
proper internal control the hard way. The lesson for
all of us in the front-end loan experience is that the
developing and maintaining of a firm written loan
policy and loan review procedure is an essential factor in the maintenance of high quality assets in our
system.
This has been a brief review of some of the new
regulations, new information systems, and improved
concepts that we will be using in the future to help
assure that banks maintain asset quality in the National Banking System. The primary motivation for
high quality in our system, however, must come
from bankers themselves. Regulators can only facilitate and encourage careful and reasoned credit
extension, they cannot make the actual credit judgments for a bank. Our regulations can help focus
proper attention on systems and procedures, but
they cannot substitute for good judgment and good
faith on the part of the Nation's bankers. My experience with bankers has shown me that these virtues
are vastly predominant, and that this Nation can
continue to rely upon the banking system to perform
its essential economic functions in a sound, efficient,
and fair manner.
TESTIMONY BY JAMES E. SMITH, COMPTROLLER OF
THE CURRENCY, BEFORE THE SUBCOMMITTEE ON
BANK SUPERVISION AND INSURANCE OF THE
HOUSE BANKING AND CURRENCY COMMITTEE,
WASHINGTON, D.C., DEC. 11, 1974

"United States National Bank Insolvency"
On October 18, 1973, I declared United States
National Bank of San Diego, Calif., to be insolvent
and appointed the Federal Deposit Insurance Corporation as receiver. In testimony before this Subcommittee on November 27, 1973, FDIC Chairman
Wille and I recounted the events leading up to this
action, and described the overnight transaction by
which Crocker National Bank took over certain of
268

the assets and most of the liabilities of USNB, thus
preventing any loss to depositors.
I stated then that the Comptroller's Office still was
studying the causes of the failure and the means of
diminishing the chances of a recurrence of similar
problems at another bank. In the course of that
evaluation, my staff" and I reviewed the examination
reports of USNB for the last 15 years. Additionally,
two seasoned National bank examiners reviewed the
loan slips relating to credits of C. Arnholt Smith,
Westgate California Corporation, British Columbia
Investment Company, Hollis Roberts, and any related companies or individuals which were prepared
during the examinations of USNB commenced on
August 11, 1969, April 15, 1970, December 11, 1970,
and September 10, 1971. We investigated any suggested possibilities of malfeasance on the part of
employees of the Comptroller's Office. On the basis
of that review I offer to the Subcommittee the following comments and recommendations.
First, there is no basis to conclude that there was
malfeasance on the part of any person in the Comptroller's Office. There is no basis for newspaper
speculation that examiners were bought off or that
various reports prepared by examiners at USNB
were stopped at the regional level.
We reviewed the records of the bank looking for
evidence of gifts or loans to our examiners. We made
inquiries of each senior officer of USNB and interviewed at length the bank's vice president for public
relations, Mr. Lipton. All information we developed
was made available to the Department of Justice,
which is conducting its own investigation. As a result
of the investigations, we discovered that some
Comptroller of the Currency employees received
from the bank a baseball ticket to the San Diego
Padres, a half-dozen cans of tuna fish at Christmas,
a lunch or dinner, or a Magic Kingdom discount card
to Disneyland. Mr. Lipton apparently was an insistent gift giver, and some of our employees may not
have reacted to his insistence as well as they should
have. I find no evidence, however, that any gift other
than of nominal value was ever given, and no evidence that the judgment of any examiner ever was
influenced. In short, there is no evidence that any
employee of the Comptroller's Office was bought off.
If anyone has such evidence, I wish he would make
it available to me so that I may evaluate it and take
remedial action and, if warranted, refer the facts to
the Justice Department.
Similarly, there is no evidence that reports were
stopped at the regional office. Various newspaper
stories have suggested that, somehow, our then
Regional Administrator, Mr. A. E. Larsen, failed to

call to the attention of the Washington Office serious
problems reported to him about USNB. I know of no
foundation for that charge. All important information
concerning USNB promptly was sent to the Comptroller's Washington Office, particularly during the
critical years of 1962, 1972, and 1973. Indeed, I
should point out that the June 1973 complaint filed
against Westgate California Corporation and Mr.
C. Arnholt Smith by the Securities and Exchange
Commission and the July 1974 indictment against
Mr. Smith both are largely based on information
originally supplied by the Comptroller's Office.
Second, the self-dealing loans which led to the
downfall of USNB were not unusual for that bank.
It should be remembered in this connection that
C. Arnholt Smith acquired control of this bank in the
early 1930's, when its deposits were approximately
$1.8 million. During his 40 years of leadership, the
bank grew to the 86th largest bank in the United
States with over $1 billion in deposits. The Comptroller's Office thus was dealing with a banker with
a proven track record.
Part of that track record included a continuing
substantial volume of loans from the bank to Westgate California Corporation and other entities associated with Mr. Smith. Mr. Smith and his related
companies also had substantial borrowing relationships with other banks. Our examination reports for
195&-1963 and 1968-1973 show a pattern of heavy
loans to Westgate which frequently were criticized
by the examiner as being in excess of the bank's legal lending limit under 12 U.S.C. 84. Whenever such
a violation was found, USNB immediately cured it
by selling some of the loans to other banks. A recurring problem also existed concerning inadequate
credit files on some of these loans. The following
chart, compiled from the Comptroller's examination
reports, shows for each of the dates on which the
bank was examined during the years 1958-1973, the
deposits on those dates, the total loans, and the total
loans involving Smith-related companies.
Overline loans and incomplete credit files are frequently encountered by National bank examiners.
Those problems usually are written up by the examiner, corrected by the bank, and not repeated.
The unusual part of the picture at USNB was the
recurring nature of the violations. In general, those
recurring violations did not cause too much alarm
because the Smith-related loans, both at USNB and
at other banks, had not resulted in losses, and the
companies which were using the funds seemed
prosperous.
Third, the Office did become alarmed about some
of the problems discovered during an examination of

TABLE A
Date of Exam
Jan. 1958
Dec. 1958
Apr. 1959
Dec. 1959
Sept. 1960
May 1961
Dec. 1961
Sept. 1962
Feb. 1963
Sept. 1963
Apr. 1964
Nov. 1964
June 1965
Feb. 1966
July 1967
Feb. 1968
Oct. 1968
Sept. 1969
Apr. 1970
Dec. 1970
Sept. 1971
June 1972
Jan. 1973

Deposits

Total Loans

97.0
103.3
122.7
130.7
137.0
131.4
153.6
179.9
192.9
212.3
224.4
223.9
238.2
267.3
354.2
366.2
406.4
409.1
437.0
4S0.9
600.0
779.9
896.7

41.3
42.1
56.0
66.7
71.8
73.9
80.3
98.1
113.0
114.8
122.0
141.8
150.4
187.0
225.0
223.7
265.9
288.7
299.4
332.8
363.2
431.1
539.2

Total SmithRelated Loans
8.9
3.7
8.0
a
b

13.0
13.5
20.0
17.0
c
d
d
d
d
d
d

60.0
55.5
57.1
74. lf
69.0f
254.0gg
340.0

a
Not reported. $12 million in Smith-related loans participated
bybUSNB to other banks.
No numbers given. Examiner described USNB as having
"usual
quantity" of Smith-related loans.
c
Not reported. $11.1 million in loans to Westgate California
Corporation and Southern Mortgage Company has been sold to
other banks. Mr. Smith listed borrowings from other banks of
$2dmillion.
No mention of loans to Mr. Smith or any of his interests.
e
Not reported. Loans by USNB to Westgate California Corporation and related interests were $10.2 million. Mr. Smith listed
borrowings
of $7 million from other banks.
f
Excludes letters of credit.
g
Includes extension of credit to British Columbia Investment
Company. Includes letters of credit.

the bank begun on September 11, 1962. Loans whose
creditworthiness was criticized by the examiner rose
to $9.6 million, or 72 percent of the bank's capital.
Of that $9.6 million, $3.2 million were in loans to
Westgate California Corporation. Loans to Smithrelated interests totalled $20 million, or 152 percent
of the bank's capital, and $13.6 million of those loans
were found to be in violation of the statutory limits
on loans by a National bank to its affiliates. The
affiliate relationship existed because of Westgate's
ownership of 50.53 percent of the bank's outstanding
shares. Section 23A of the Federal Reserve Act
limits aggregate affiliate loans to 20 percent of a
bank's capital stock and surplus, and requires all
such loans to be secured fully. The loans to Mr.
Smith's enterprises exceeded that 20 percent figure
and were not secured in the manner required by the
statute. In addition, a number of irregularities were
discovered in the treatment on the books of the bank
and of borrowers concerning loans from the bank to
Smith-related companies. Those irregularities were
the subject of a draft report of possible criminal
269

violations written by the examiner and forwarded by
Regional Administrator Larsen to the Washington
Office for disposition. Apparently because of substantial doubts among Washington staff members as
to whether the facts amounted to criminal conduct,
the report was not forwarded to the Criminal Division of Justice.
Deputy Comptroller Justin Watson met with Mr.
Smith in San Diego in December of 1962 to discuss
the bank's condition. Mr. Smith reported that 42,696
of the USNB shares held by Westgate had been
transferred to Mr. Smith, thus apparently ending the
affiliate relationship between the bank and Westgate.
A $10 million reduction had been achieved in the
Smith-related loans since the starting date of the
September examination. The Deputy Comptroller
and Mr. Smith agreed, inter alia, that Mr. Smith
would supply the Comptroller's Office with a list of
all companies in which he and his family were interested; that all loans to Smith-related companies
would have the prior approval of the bank's board,
either on an individual or a line of credit basis; that
the books of the bank and of the borrowing corporation should at all times show the true use of proceeds
for any loan involving a Smith-related company; and
that any unsecured loan to a Smith-related company
would be supported by an audited financial statement. Those agreements were confirmed by a letter
to Mr. Smith from Comptroller Saxon dated December 11, 1962, and that letter was read to and
discussed by the bank's board of directors on December 20, 1962.
In the next few years, the loans to Smith-related
companies diminished to the point that they were
not even mentioned in the bank examination reports.
Additionally, Mr. Smith began to relax his domination of the bank, and turn the management of its
affairs over to younger officers, including his son.
Mr. Smith's son died in 1965 and Mr. Smith again
took over full time active control of the bank. No
significant amount of loans to Smith-related companies appeared, however, until 1968.
Fourth, in 1967 construction was begun by Westgate California Corporation on two hotels adjoining
the bank in downtown San Diego. Additionally,
Smith-related companies began to make heavy investments in real estate. Those projects created a
need for cash. It has been learned since the bank
was closed, for example, that Westgate California
Corporation's borrowings from its subsidiaries and
its investment in the two hotel properties both
totalled about $50 million. In other words, Westgate
drained about $50 million from its operating companies to finance its real estate investments. The
270

ultimate supplier of those funds was USNB, although
the USNB records did not always accurately reflect
that ultimate use of the proceeds of the loans. Those
big investments in non-income producing real estate
may have been a large contributing factor to the
inability of the Smith-related companies to meet
their maturing debts, and that inability in turn resulted in the rollover of loans; that is, repaying a
loan to one of the Smith-related companies when it
became due at the bank with funds borrowed by
another company in an amount sufficient to cover
the original principal plus interest. Such transactions always were disguised so that the true purpose
of the loan and the use of its proceeds were not
reflected on the bank's books.
Fifth, the previously mentioned review of the
examination reports and underlying work papers for
that period, 1969, 1970, and 1971, shows that our
examination team was not as thorough as it should
have been in evaluating the loans to Smith-related
companies. Information from Westgate's public
financial statements does not seem to have been
used to any great extent in judging loans at USNB.
Records of loan performance, i.e., current payments
of interest and principal, were relied upon to evaluate a loan as sound, in spite of the absence of complete financial data.
Without going into detail of individual credits, the
credits found by the review examiners to have insufficient supporting credit information on the
August 11, 1969 examination totalled about $56 million, or 22 percent of total loans. The review examiners classified an additional $17 million of loans
as substandard.
In the April 15, 1970 examination, the two review
examiners listed an additional $70 million of credits
which lacked supporting credit information, or 28
percent of total loans. That examination was the
first instance in which the review examiners noted
letters of credit to Smith. Also, the review examiners
classified as substandard an additional $16 million
of loans. Classified loans on that examination, as
listed by the review examiners, were 75 percent of
gross capital funds, as compared to a 37 percent
ratio in the original report.
As regards the December 11, 1970 examination,
the review examiners again noted that the examiners
failed to list many loans which lacked supporting
credit information. Additionally, the review examiners increased the substandard classification by $73
million. Consequently, classified loans to gross capital funds were estimated at 190 percent, rather
than the report figure of 20 percent.
In the last report reviewed, September 10, 1971,

the review examiners listed an additional $133 million which lacked supporting credit information.
They classified an additional $214 million in loans as
substandard. Classified loans to gross capital funds
were estimated to be 486 percent, instead of the
original report figure of 25 percent.
I would like to say in defense of those who performed earlier examinations that the classification of
credits is not an exact science, and each examiner's
judgment of a particular credit might be different.
In addition, the two examiners who performed this
task of reclassifying USNB's credits had the hindsight benefit of knowing the fate of the bank.
A major factor in the substantial increase in classified loans for the review examiners was their
classification of loans which lacked adequate credit
information. In fairness to the examiners who conducted the original examinations of USNB, it should
be noted that Office policy concerning classification of loans solely because of a lack of credit information has been somewhat equivocal. Some discretion must be left to the examiner not to classify
loans which are obviously good because of supporting collateral or otherwise, even though the loans
may lack complete credit information. During the
past 7 months I have participated in staff conferences in most of the 14 regions of the Comptroller's
Office and at each such conference I have emphasized the importance of a National bank maintaining adequate credit files on its loans.
Sixth, the report of September 1971 contained
some items which, with 20/20 hindsight, should have
been a red flag to the Comptroller's Office. Direct
loans to interests of the Smith family totalled $62
million. Loans secured by stock or debentures of
Westgate California Corporation totalled $7 million.
Ninety-five million dollars in letters of credit had
been issued by USNB to support Smith-related
enterprises. Loans requiring unusual attention,
although not classified substandard from a credit
standpoint, increased from $9 million to $19 million,
with approximately $8 million of that total in loans
to Smith-related enterprises. Eighty-nine million
dollars in Smith-related loans were found to be supported by inadequate credit data. Mr. Smith had
promised correction of many of the problems, and
there seemed no reason to disagree with the examiner's statement that the Smith family for many
years had used the bank as a vehicle to expand the
family's financial empire, but that no loss had been
incurred by the bank because of those activities.
Similarly, the Comptroller's Office may not have
acted as vigorously as it should in following up on the
June 1972 report of Examiner Martin. The steps

taken are outlined at pp. 41-42 of the printed record
of this Subcommittee's November 27, 1973, hearings. Here again, the Comptroller's Office can be
criticized in relying too heavily on the past record of
performance by Mr. Smith at USNB and for not
digging hard enough to get the facts and making an
independent judgment based on those facts.
Seventh, to some extent our examiners and the
entire Office seemed to have been deceived by outright fraud. Examiner Martin traced, often through a
half-dozen or more accounts, the ultimate use of the
proceeds of many loans. Such tracing is not a routine
part of the examination procedure. The tracing of
those funds showed that they frequently were used
for purposes other than those stated on the bank's
records. Whether or not any violations of the Federal
criminal laws were committed has yet to be determined, but it seems clear that the bank records were
kept in a way deliberately designed to mislead our
examiners, and the examiners in fact were mislead.
Eighth, as the Subcommittee knows, C. Arnholt
Smith was indicted in June 1974 for alleged actions
involving USNB. That indictment resulted from
criminal referrals made by our Office in the fall of
1972 and spring of 1973. The indictment is 44 pages
long and contains 25 counts. I would like to submit
a copy for the record. We have cooperated fully with
the Department of Justice in its investigation and
preparation of this matter and several examiners,
including Mr. Martin, have been made available to
the U.S. Attorney's Office. We also have made
available to the U.S. Attorney's staff all records of
our Office relating to USNB.
Ninth, I understand from Chairman St. Germain's
letter that the Subcommittee is interested in my view
of the similarities or differences between the record
failure of Franklin National Bank and the 1973
failure of USNB. There are two superficial similarities. First, each bank was much larger than the previous experience of any Federal banking agency with
a bank which became insolvent. Second, cooperation among the banking agencies enabled a takeover procedure in each case which completely protected all depositors, and held to a minimum disruption of the financial markets. Otherwise, the two
situations are dissimilar. The failure of USNB
resulted from massive fraud. At Franklin, while
there were some fraudulent transactions in the
bank's foreign currency operations, fraud was not
the principal cause of the bank's downfall. Franklin
National Bank was caught in a liquidity bind resulting from a downturn in the economy coupled with
incredibly poor management. Franklin was a peculiar situation in that it is only the second National

271

bank within the memory of the present staff of the
Comptroller's Office to fail as a result of something
other than fraud.
Finally, the Comptroller's Office is taking several
steps which should diminish the possibility of a
recurrence of the events leading to the downfall of
USNB.
1. On November 21, 1974, I issued regulations
requiring that each director and principal officer of
a National bank keep on file at the bank, for review
by bank lending officers and our examiners, a current statement of the business ventures with which
he is associated either as an officer or director or in
significant ownership capacity, and of the relationships between those enterprises and the bank.
Those regulations had been published in proposed
form on June 20, 1974. The Comptroller's legal staff
believes that the filing of false information or deliberate omissions on that statement would violate
existing felony statutes. Thus, National bank examiners should be provided with a reliable source of
information as to loans and other financial transactions between the National bank and its directors
and principal officers. That information was not
readily available at USNB and was ascertained in
some instances only by the tedious tracing of loan
proceeds through many checking accounts. I would
like now to submit for the record a copy of those
regulations together with the accompanying statement as sent to the Federal Register for publication.
2. Our examiners have been instructed to prepare
at each examination a schedule of violations of law,
such as the statutory lending limitation (12 U.S.C.
84) or the limitation on loans to affiliates (12 U.S.C.
371c), for comparison to previous examinations
whether or not these violations are cured during the
examination. Recurrent violations will become the
subject of cease and desist proceedings by the
Comptroller's Office.
3. A regulation including letters of credit within
obligations subject to the lending limits of 12 U.S.C.
84 was published in the Federal Register on August
9, 1974. That regulation had been in the drafting
stage prior to the closing of USNB, but had been
delayed due to the problems of achieving uniform
treatment of State and National banks. The final
regulation was published in similar form by the Federal Reserve and the FDIC this past summer. The
misuse of letters of credit at USNB was thoroughly
explored at this Subcommittee's hearing of November 27, 1973. That regulation, if in effect during the
last 4 years, might have eliminated one way in which
the Smith-related companies obtained funds from

272

USNB. I would like to submit for the record a copy
of this regulation as published in the Federal Register.
4. Our examiners have been reminded of the
importance of satisfactory credit information about
borrowers being retained in the bank files. The lack
of such information was chronic at USNB. I personally have mentioned this subject at many staff conferences throughout the country. Large commercial
loans of the sort involved at USNB should be supported by audited financial statements for the last 3
years, including profit and loss figures, and by information about the officers and owners of the company. When a borrower is a public company, its
public filings with the SEC for the last 3 years should
be retained in the bank's loan files and reviewed by
our examiners. Those procedures are not new, but
they are being reemphasized.
5. The Comptroller's Office has taken a number
of steps to improve coordination within the Office
when a situation appears to call for special oversight of a particular bank. Systems have been devised to speed up communication and to assure that
the Comptroller and his top staff work with the
examiners and the regional staff to develop and
present to each bank an appropriate program to deal
with that bank's problems.
6. In response to requests from members of the
House Banking and Currency Committee my immediate predecessor as Comptroller, Mr. Camp, twice
recommended amendments to the Financial Institutions Supervisory Act of 1966. Mr. Camp's proposals
included:
(a) Under the present statute an officer or director
may not be removed from a National bank for repeated violations of law unless personal dishonesty
and damage to the bank or another institution are
provable. Under that statute, the repeated violations
of the statutes regarding lending limits and loans to
affiliates by Mr. C. Arnholt Smith would not of
themselves have been grounds for removal. Not until
fraud was discovered in the June 1972 examination
could any action appropriately have been commenced against Mr. Smith. Even then, there is some
doubt as to whether such a removal action would
have been successful. Mr. Camp thus recommended, and I support the recommendation, that
the Financial Institutions Supervisory Act, 12
U.S.C. 1818, be amended to eliminate the need
for showing personal dishonesty and loss or damage
as predicates for removal from a National bank of an
officer or director who has violated a statute.
(b) Under the present Act, unless a person has

been convicted or indicted for a felony involving
breach of trust, we may prevent his participation in
the affairs of a National bank only after a cumbersome certification procedure involving the Federal
Reserve Board. The Board of Governors, on receiving such a certification, must meet with the Comptroller and determine whether it wishes to serve a
notice of charges and conduct a hearing. Mr. Camp
suggested eliminating that cumbersome procedure
by giving to the Comptroller's Office the same
removal powers vested in the Federal Reserve, as to
officers of State member banks, and in the FDIC, as
to officers of State nonmember banks.
However, I do not believe that the solution is to
vest full removal power in the Comptroller as suggested by Mr. Camp. I believe that may be too much
authority to be placed in any one individual. I do
think, however, that the statute should be amended
to give the Comptroller authority to issue a formal
notice starting the removal proceedings, which will
then be adjudicated before the Board. I recommend
that the prosecutorial function now vested in the
Board be given to the Comptroller, and that the
Federal Reserve Board be left solely with the adjudicatory function. The Comptroller, since he will in
effect be a prosecutor, should not sit as a member of
the Board to judge the case. The power to initiate
such a proceeding, without waiting for action by the
Board, will in itself be a useful regulatory tool. Consideration is also warranted as to whether the Comptroller should be given the power to suspend someone in an appropriate situation pending adjudication
by the Board.
7. The definition of affiliate contained in Section
2a of the Banking Act of 1933, 12 U.S.C. 221a should
be broadened so that an affiliate relationship could
be established by showing actual control of the bank,
without the need to find 50 percent control of the
bank's shares. That amendment would prevent evasion of the intention of the affiliate statute by juggling the number of shares around while retaining
effective control in some other manner. Once an
entity is determined to be an affiliate, its loans must
be fully collateralled by marketable securities, and
the total loans to all affiliates of any one bank cannot exceed 20 percent of that bank's capital and surplus. Had this proposed amendment to Section 2a
been in effect, the situation at USNB could not have
developed in the way that it did.
8. I understand from staff discussions that the
Subcommittee is particularly interested in the
number of times the Comptroller has exercised his
power under the cease and desist procedures of the

Financial Institutions Supervisory Act of 1966. That
Act, of course, was not available when the Comptroller's Office encountered difficulties with USNB
in 1962. It was available and was used in 1973.
My predecessor Mr. Camp started an Enforcement and Compliance Division in the Law Department of the Comptroller's Office. In one form or
another that Division has used the enforcement
powers of the 1966 Act in each of the past 3 years as
indicated below:
1971—3
1972—5
1973—9
1974—15 to date
9. Some courts have held that an officer making a
loan for his own benefit and concealing that fact
from the board of directors does not constitute a
false statement on the books and records of the bank
even though the loan is really only a sham transaction. Likewise some courts have held that where the
debtors turned over the proceeds of loans to a bank
official for his own personal use, that would not
constitute a misapplication of funds of the bank
unless the debtor was fictitious, financially irresponsible, or assured by the bank official that he would
not be looked to for repayment. Title 18, sections 656
and 1005 should be amended to make clear that
those interpretations are erroneous.
10. The Comptroller's Office is undertaking a
complete review of the manner in which it exercises
its statutory functions. Fifteen different formal bids
were submitted to the Office by management consulting firms and others for conducting that review.
We selected the firm of Haskins and Sells to undertake the study. They are being assisted by the firm
of Carter H. Golembe Associates, Inc., and by Dr.
Jack Guttentag and Dr. Samuel Sapienza who are
associated with the Wharton Graduate School, University of Pennsylvania.
The Haskins and Sells study has been divided into
several phases and will be completed by June of next
year. The study has been in progress for approximately 5V2 months. The Washington Office has been
canvassed, approximately half of the regional offices
have been studied in depth, a survey questionnaire
has been mailed to the chief executive officers of all
4,600 National banks, and a survey questionnaire is
prepared for mailing to all 2,000 National bank
examiners. In addition, interviews with other regulators, members of Congress, and representatives of
industry are in progress.
This will be a sweeping review of all aspects of the
agency. Special emphasis will be placed upon the
273

examination process, examination techniques, and
the organizational structure of the Office. In addition, the study will deal with the evaluation of the
banking industry in the years ahead, all support
functions in the Office, recruiting and training operations, and automation improvements. The Haskins
and Sells recommendations are expected to include
goals for improved performance and guidelines for
achieving them.
There is no procedure, or group of procedures,
which could completely eliminate the chances of a
bank becoming insolvent because of self-dealing by
the bank's management. Banks are run by human
beings who may be clever and deceitful enough to
defeat the restraints built into any system. The
Comptroller's Office is run by human beings who
may be deceived and who occasionally may make
mistakes in judgment. Nevertheless, it is hoped that
the new procedures and actions outlined here will do
much to eliminate the possible recurrence of a situation such as that that caused the downfall of USNB.
REMARKS OF ROBERT A. MULLIN, DEPUTY COMPTROLLER OF THE CURRENCY, BEFORE THE
BANKERS ASSOCIATION FOR FOREIGN TRADE,
SAN DIEGO, CALIF., APR. 9, 1974

"Country Credit Exposure"
You may be assured that I do not disagree with
the remarks of the other members of this panel. The
fact that they have independent methods of evaluating the degree of country risks deemed appropriate
for their banks confirms my faith in an independent
banking system, with a minimum of governmental
controls.
Bank supervision, international in scope, is the
business of the Comptroller of the Currency, and as
required by the laws of this country, bank supervision includes regular examinations of our privately
owned, National banks.
Our examinations do include an evaluation of the
country risks taken by each National bank, and we
also consider a number of other related factors. The
foremost of those factors is the overall soundness
and solvency of the bank and the bank's ability to
serve its community.
Liquidity is a major factor we consider in determining the solvency of a bank. Country credits are
a major factor in determining a bank's liquidity. The
liquidity of country credits or in any bank asset
depends largely on two basic factors: When will the
asset be paid and/or when can the asset be sold.
A country credit with a 4-year grace period followed by semiannual payments for 6 years and end274

ing, hopefully, with a balloon payment, has no liquidity in its first 4 years and, indeed, can be considered
as a fixed asset except for its marketability.
When I first commenced examining banks, more
than 26 years ago, our three adverse classifications
of bank assets bore the Roman numerals of II, III,
and IV and represented the captions Slow, Doubtful,
and Loss. The caption of "Substandard" has replaced number II, but the element of slow, that is,
lack of liquidity, is still included in an examiner's
decision to classify a country credit as "Substandard."
You may have noted that we have been tolerant of
country credits lacking liquidity only by their terms.
If you have no concentration of such credits in your
portfolio or by obligors they are usually free of criticism. However, such credits are highly vulnerable
to adverse criticism, either as Other Loans Especially Mentioned or as Substandard, in periods of
tight money when their marketability declines or
when current information indicates the borrower
may be unable to service the debt as agreed. I find
current estimates of an obligor's inability to service
his future debts as previously agreed, to be the
principal cause of examiners' criticism of country
credits. The examiner is, in effect, saying this asset
appears to lack liquidity and the bank's solvency is
jeopardized to that extent.
I seldom, if ever, except in the case of Cuba, see
country credits classified as "Doubtful" or "Loss"
assets. Except for those, the examiner is not contending that the bank will experience a loss, he is
contending the asset lacks liquidity.
In today's banking, when we see your substantial
liability totals in accounts captioned "Fed Funds
Purchased," "Eurodollar Placements," "Security
Repos," "Finance Acceptances," and "Stand-by
Letters of Credit," you may be assured that we will
take a serious look at the liquidity factors involved
in country credits. Unlike countries, banks can disappear when they become insolvent.
We often include, as country credits, those loans
to separate entities which are in reality a part of a
government's operations or are dependent upon the
resources of that government for the servicing of
their debts. Under those circumstances, the examiner may list all of those credits of one country, not
as assets subject to criticism, but as a concentration
of credit. To qualify for such a listing, the total of
such credits must be 20 percent or more of the
bank's gross capital funds.
The examiner may also combine such credits and
consider them to be in violation of the law, 12 U.S.C.
84, if they are dependent upon the government for

their payment, or if they are for the general use of
the government, or if the government is also borrowing. The examiners will use discretion in making
such listings and they will be guided by factors
which could affect the soundness and solvency of
the bank.
We will expect your lending officers to know their
borrowers, their country credits, and, I do not mean
that we will simply expect to find some financial
data on file. I will expect your lending officers to
have been in the country and to intimately know its
characteristics.
I also expect my examiners to be knowledgeable
in that field. This month, I have some 40 examiners
in Europe, Latin America, and the Far East. That is
part of a crew of some 150 men and women examiners who have their official passports and are subject to foreign examination assignments. I am also,
since the first of this year, making the direct assignments for the examinations of the international
departments of our 100 largest banks. The examiners on those examinations may come from your
head office city or they may come from New York,
San Francisco, Chicago, or elsewhere, but they will
be capable and they will render a separate report on
your bank's international activities.
We are also conducting quarterly seminars for our
international examiners and some of you have
assisted on this project by providing speakers on the
subject of country credits.
Our examiners must render a service to National
banks. We have no funds allocated by Congress; we
cannot ask you for sterile reserves to invest and we
have not included your foreign office assets in your
examination fee. Our progress in attempting to keep
pace with your rapidly expanding activities is due
largely to your assistance and cooperation and I am
most appreciative.
REMARKS OF DAVID C. MOTTER, DEPUTY COMPTROLLER OF THE CURRENCY (ECONOMICS),
BEFORE THE DUN & BRADSTREET SEMINAR FOR
BANK EXECUTIVES, CHICAGO, I I I . , MAY 13,1974,
AND NEW YORK, N.Y., MAY 23, 1974

"Bank Capital Adequacy"
The rather nebulous nature of the topic before us
today offers a mixed blessing to both panelists and
members of the audience. Presumably, no one here
seriously expects this discussion to lay the capital
adequacy issue to rest. Therefore, no one has great
hopes and expectations for the results. On the negative side, it is somewhat frustrating for all concerned
to have to wrestle with a problem, which, although

perhaps soluble, promises to remain with us for the
indefinite future.
As an economist, there is a special frustration in
this topic, we like to think that economic analysis
can usually provide solutions to problems in the economic sphere. But the notion of "adequacy" itself is
not an economic or market concept per se; it is,
rather, a loose regulatory construction that sometimes appears to mean all things to all people.
There are several reasons why bank capital questions are receiving so much attention today. First, a
number of far-reaching changes have been and are
occurring in the banking industry. A sharp expansion in the product and service mix of banking
organizations has taken place. That expansion has
been facilitated by the rapid growth of bank holding
companies. The bulk of bank assets have moved
under holding company umbrellas thus creating a
new picture which still holds many uncertainties for
both the industry and its regulators. The expansion
of foreign banking activity by U.S. banks has proceeded rapidly, again generating new relationships
whose full ramifications will not soon be known. The
liability structure of the larger U.S. banks has been
altered dramatically. Non-deposit short-term liabilities have grown in importance, while money market
CD's have become a key element in liability management. Those changes have led to expressions of
concern about the adequacy of banking's capital
cushion. Whatever else may be said, it seems clear
that each of the indicated changes—international
expansion, broadening of product-service mix, creation of the holding company overlay, and increasing
reliance on short-term money market sources of
funds—has reinforced the importance of the capital
structure of banks.
Another reason for the increased attention being
given to bank capital is the recognition that the
expected continued growth of commercial banking
will generate a need for a substantial inflow of new
capital over the next few years. One authority estimates that the industry will need to double its existing capital of over $60 billion during the next 6 years.
Only about half of that increase, it is estimated, will
be available from retained earnings. If that prediction is borne out, the industry would have to tap the
capital market for over $5 billion per year for each of
the next 6 years, about twice the amount raised in
1972, the record calendar year to date. Doubt that
the banking industry can successfully raise amounts
of that magnitude has heightened the interest in the
concept of capital adequacy.
A third factor, and the proximate one, that has
focussed attention on capital adequacy is the over275

lapping jurisdiction among the banking agencies.
Many National banks, and most of the larger ones,
are now subsidiaries of bank holding companies.
Bank holding companies, of course, are under the
direct jurisdiction of the Federal Reserve. Instances
have occurred in which approval by the Fed of holding company acquisitions has been made contingent
upon the raising of more equity capital by one or
more subsidiary banks. Quite understandably, in its
role as the regulator of bank holding companies, the
Federal Reserve has taken a strong interest in the
capital structure of both holding companies and
subsidiary banks. In our Office, we look with favor
upon the affiliation of a National bank with a parent
holding company only when the net effect is to
strengthen the position of the bank. We would not
favor, and indeed would attempt to disallow, any
affiliation in which it appears that the relationship
with the parent holding company would weaken the
position of the bank. We also believe that in all those
instances in which the holding company is fully
identified in the public mind with the bank, and that
same identification exists for other subsidiaries of
the holding company, that there is no realistic way
to avoid bank association with any difficulties
experienced by the affiliates. In other words, since
banking is built upon public confidence, it is unrealistic to assume that a bank could stand idly by and
allow the insolvency of a related affiliate. In consequence, we are aware that a realistic assessment of
bank capital needs within a holding company structure must take account of that entire structure.
In his November address, the Comptroller took
note of the difficulties experienced by National
banks when they wind up in the middle in an argument between regulatory authorities. The Comptroller offered a proposal that the Federal Reserve
accept our position on the capital adequacy of National banks as a "rebuttable presumption." In other
words, the Federal Reserve would accept our assessment except in those cases where it had what it
considered to be good reason to differ. In the latter
cases, interagency discussion would ensue with the
purpose of attaining a regulatory agreement.
In response to that initiative by the Comptroller,
discussions at the staff level have been initiated
between the Federal Reserve Board and our Office.
Interchanges of relevant documents have occurred,
and it is expected that the discussions will continue
for some time. It is too early to indicate any resolution.
With that introduction, let us look briefly at what
the functions of bank capital are. In line with the
traditional stance of bank regulators, it seems appro-

276

priate to call for capital as depositor protection.
Such protection serves best when it allows a bank to
absorb unexpected losses, and thus continue as a
strong viable institution. A solid capital cushion
allows bank regulators to sleep better at night.
Coming close to the heart of any controversy concerning capital adequacy is another function of
capital that has been advanced; that of a brake on
undue or unwise bank growth stretching beyond the
capabilities of management. That role may occur as
a result of a conscious decision by bank officials, or
it may stem from a regulatory directive. The former
has been termed "conscious moderation of growth,"
the latter has been referred to many ways, often
unprintable.
One way to get a handle on the slippery concept of
"adequacy" may be to look at certain historical relationships between losses and capital. Brent Leavitt,
whose name is not unknown to many bankers who
have recently given more than passing attention to
bank capital, has noted that in 1934, the worst year
for loan losses in the Great Depression, losses were
equal to about 8 percent of total capital. In 1971, the
aftermath of Penn Central led to loan losses equalling 2 percent of total equity capital. The 1971 losses
exceeded those of any other year since 1939.
At first glance, that relationship appears to demonstrate the "adequacy" of bank capital in some
sense. However, we have already noted several
banking developments of recent years that have
added new and uncertain dimensions to the "adequacy" concept. Those developments have occurred
while the capital ratios of the banking industry have
fallen sharply.
The decline of those ratios is not new. Comptroller of the Currency John Skelton Williams in
1914 suggested a statutory limit for deposits of eight
times capital. At that time, the average for the
National Banking System was 4.2 times capital. At
a recent date, the aggregate figure for the system
was 11.3 times capital.
After some recovery during World War II and the
next 15 years, a sharp decline in capital ratios has
taken place since 1960. Assets have tripled while the
growth of capital has been only half as great. Total
capital as a percent of total assets has fallen from
about 9 percent to about 7 percent, and the decline
for the largest banks has been even larger. It is
probable that the juxtaposition of falling capital
ratios and developments generating new demands of
unknown dimensions on capital structure would
have focussed a good deal of attention on bank capital even in the absence of overlapping regulatory
jurisdictions.

In effect, the question for the banking industry
and for bank regulators is this: Is there some minimum capital ratio below which the banking system is
endangered? I do not pretend to have the answer to
that question. Those who claim to have the answer
usually maintain that the existing capital ratios represent rock bottom from the standpoint of banking
solvency, and that from here on out, banks should
be forced to add to capital in the same proportion
that they add to total footings. That approach would
necessitate spelling out minimum capital ratios. By
the nature of things, those minima would have to be
set at some sort of average level for the banking
system today. One can easily see that if a minimum
were announced at the average level of capital ratios
for the industry, there would be a tendency for the
management of all banks with ratios above the
average to gravitate toward the minimum. That is
the strongest single argument, I believe, for avoiding
a hard and fast regulatory position tied to a particular ratio.
Studies that have attempted to isolate the relationship between capital ratios and bank failure have not
found a significant correlation. The difficulty in making such studies is that a given capital structure, as
stated on the balance sheet, assumes that assets are
worth their book value. An apparently strong capital
structure can be wiped out by loan chargeoffs. The
tautology that all insolvent banks have negative
capital doesn't shed much light on the basic issue.
The question of the status of capital notes and
debentures arises in most discussions of capital adequacy. You are aware that there are some differences among the agencies as to the proper role of
capital notes and debentures. Our Office encouraged the issuance of notes by a ruling in the early
60's that removed the stigma from them. We applied
a rule-of-thumb that total capital notes and debentures could not exceed 50 percent of total equity
capital. In point of fact, few banks have come close
to that rule-of-thumb limit. For the National Banking
System as a whole, capital notes and debentures
make up about 7 percent of total capital. Our Office
carefully reviews every application to issue notes,
requiring evidence that the fixed charges can be
met without weakening the bank.
It is our view that the availability of note issuance
provides a needed flexibility to bank management.
In some market situations, it would be highly disadvantageous for banks to endeavor to sell equity
capital. The basic premise behind our ruling on
capital notes was that they provide depositor protection. We do not claim that they can fully serve the
function of equity capital; it is obvious that notes

cannot provide a cushion to cover losses as long as
the issuing bank is a going institution.
A subsidiary issue in connection with capital notes
relates to interbank transactions, i.e., the sale of the
notes of one bank to a second bank. Our Office
prefers to hold such transactions to a minimum. Our
basic reason for that position is that such transactions do not result in any net inflow of capital funds
into the banking industry. In consequence, to the
extent that such transactions become widespread,
there is, in effect, a watering-down of capital requirements. We do not favor totally disallowing the
use of interbank transactions, however, as, on occasion, that avenue can provide room to maneuver for
the bank and for the bank regulator.
Mr. George Vojta of Citibank has articulated in its
most complete form a view of bank capital adequacy
that I will call the market test approach. It rests on
the basic premise, as I see it, that banks and bank
holding companies must continuously subject themselves to a capital market test. Banking organizations must at all times compete for scarce capital
with firms from every other industry in the economy.
It is held that, if "unrealistic" and "artificial" requirements for additional capital are imposed by
bank regulators, above and beyond those the market
would require, banking organizations will be unable
to compete effectively for capital funds. The rate of
return on capital is the key factor in determining
whether or not a firm can continue to "go to the
well." Unrealistically large capital bases will lead to
lower net yields on capital for a given level of net
income.
I must say, in all candor, that we have a considerable empathy for that "market view" of capital
adequacy. We are aware that it would be unwise,
from the standpoint of bank soundness and solvency,
to force unrealistically high levels of capital upon
banks, even were the market willing to make available such funds. It would lead to mounting pressures
for ever higher rates of return on earning assets.
Further, our Office has been in the forefront in the
movement, during the past 12 years, to increase the
responsiveness of bank organizations to the emerging financial needs of businesses and individuals. As
banking organizations have expanded their product
and service mix, they have improved their performance from the standpoint of the public, i.e., users
of financial services and products. That expansion
has cut two ways in terms of the impact on capital
requirements. To the extent that bank managers
foresaw correctly an emerging need for certain
financial services, such foresight was likely to be
rewarded with a good rate of return. Since even the
277

best managers are not omnisicient, however, on
occasion there was a negative impact on earnings
from new operations with an accompanying capital
drain. Even those operations that prove to be quite
successful over the years, e.g., credit cards, often
generate substantial losses during the early operations.
A forward looking regulator tries to encourage the
institutions under his jurisdiction to be responsive
and innovative. He recognizes the need for an adequate capital cushion to provide the necessary
depositor protection as entry into new areas occurs.
Yet there must also be recognition that imposition of
unrealistically high capital requirements may, over
time, be counter-productive.
The "market test" approach to capital adequacy
assumes a considerable degree of knowledge on the
part of the investors in our capital markets. How
good is the information held by, or available to,
investors concerning banks?
We believe that during the past 10 years, there
have been significant improvements in the quality
of information available to the public, both for
depositors and investors. The annual reports to
shareholders are more comprehensive and more
meaningful than before. For banks with a relatively
large number of shareholders, and for registered
bank holding companies, additional reports are
made available during the year. Beginning in 1972,
the three Federal banking agencies began to make
available upon request the statistical reports of
income of commercial banks. In addition, for the
first time the supporting schedules on the back side
of the Report of Condition were made available. One
may now request, and receive, from our Office, the
statistical reports of income for 1971, 1972, and 1973
for any National bank. The supporting schedules for
the Report of Condition for National banks are being
made available upon request from 1960 forward.
In general, then, despite some admitted gaps and
imperfections, prospective investors can secure
reasonably good income and expense and balance
sheet data for commercial banks. From those figures, rates of return on capital and rates of growth
may be computed and compared.
It is clear that the regulatory agencies have an
additional type of information concerning individual
commercial banks that is not available at this time
to the general public. I refer to the quality of assets,
as determined in the bank examination process. In
that connection, I would like simply to advance two
points today, neither of which has moved very far as
yet, as grist for the mill.
278

First, as most of you have noted from the Comptroller's speech on capital adequacy given in San
Francisco in November, one of the exercises we
have been carrying forward in the Office concerns
the possibility of requiring higher capital ratios for
banks with relatively poorer asset quality and allowing somewhat lower ratios for banks with higher
quality assets. ("Higher/lower" adjectives would
apply to the basic ratios between total capital and
total assets. The adjectives are, of course, just
reversed where the reference is to "asset to capital"
ratios.)
We have computed, for example, frequency distributions that show how many National banks would
be required to add to their capital structure if banks
with the highest quality of assets were allowed to
reach, say, a ratio of total loans to total capital of
8.5, while those banks with the poorest quality of
assets would be allowed to reach, say, a ratio of
only 6.5. We find, of course, that some banks, were
these standards to be applied, would need to add to
their total capital, while many banks would not.
Second, a valid question may be asked concerning
whether the market should have additional information concerning the asset quality of banks. A large
proportion of bank assets are in loans of various
types, and loan quality varies substantially. Aside
from chargeoff records after the fact, investors do
not have a basis for comparing asset quality among
banks. No one is seriously considering taking the
step of nailing examination reports to the front door
of banks, as has been facetiously suggested. However, it is conceivable that some additional information on asset quality could be made available. The
purpose, of course, would be to bring some market
pressure to bear upon banking institutions to maintain high quality loan portfolios.
It is likely that our Office will carry out further
computations relating to capital of National banks.
We like to think that the more information we have,
the more informed our judgment can be. However,
such computations do not signal a departure from
our basic Office position that in the final analysis, a
reasoned and informed regulatory judgment must be
made. We do not think that a purely mechanistic
formula can ever be developed that will remove the
necessity of such informed judgments. You are
aware of the eight factors relating to capital adequacy which were inserted in the Comptroller s
Manual in the early 1960's. Though these were
deleted from a later edition, the current Comptroller
emphasized in his San Francisco remarks that the
factors still remained paramount in our Office con-

sideration of capital adequacy. The eight factors are
as follows:
1. The quality of management;
2. The liquidity of assets;
3. The history of earnings and of the retention
thereof;
4. The quality and character of ownership;
5. The burden of meeting occupancy expenses;
6. The potential volatility of deposit structure;
7. The quality of operating procedures; and
8. The bank's capacity to meet present and future
financial needs of its trade area, considering the
competition it faces.
You will note that the "quality of management" is
listed as the first and foremost factor. In a very real
sense, we believe our concern needs to be even more
with "managerial adequacy" than with capital adequacy. We would like better touchstones against
which to measure the quality of management. We
are directing serious efforts toward this end within
our Office. It is also certain that the contractor
engaged to carry out a complete evaluation of our
Office will devote a good deal of eflFort to the goal of
securing better measures of managerial adequacy.
There are some obvious criteria. In large part,
these duplicate the market tests that are applied as
banks seek additional capital funds. Certainly, the
historical record of earnings, the rates of return on
capital, the rates of overall growth, and the record of
expansion into new and promising areas of financial
service are all relevant. Again, the factor of asset
quality is crucially important, and we are able to
make some continuing judgment on that score. However, I think it is fair to state that, just as is the case
with capital adequacy, we shall never be willing to
live with a completely mechanistic formula in
measuring managerial adequacy. At the margin, the
element of reasoned judgment must take over.
REMARKS OF JUSTIN T. WATSON, FIRST DEPUTY
COMPTROLLER OF THE CURRENCY, AT THE
GRADUATION CEREMONIES OF THE SCHOOL OF
BANKING OF THE UNIVERSITY OF FLORIDA,
GAINESVILLE, FLA., AUG. 16, 1974

"Bank Capital and Liquidity"
Today perhaps the two most discussed topics
relating to banking are bank capital and liquidity.
Those topics come to the forefront when there is an
erosion of public confidence. Bank stocks have
fallen off sharply. The stability of our Nation's financial system, even the international financial system,
has suffered severe shocks in the past few years. It

started about 4 years ago with the Penn Central
bankruptcy. That was followed by Equity Funding,
the failure of the United States National Bank of San
Diego, the Beverly Hills Bancorporation and the
problem with its commercial paper, and now "serious trouble" in the Franklin National Bank of New
York. In the international area, a prominent German
bank recently failed. Other West European banks
have suffered sizable losses in foreign exchange, and
it is common knowledge that many of the so-called
fringe banks in London are in trouble and, at the
urging of the Bank of England, are being supported
by the London clearing banks.
I suppose the prime function of bank capital is to
radiate confidence in the banking system. One
banker said, "Capital begets courage, courage
begets credit, and credit overcomes depression."
Another banker said, "To move against the ebbtide
of depression takes courage; it also takes capital."
The commercial banking system relies on confidence for its continued successful operation to a
greater extent than any other business. Adequate
bank capital contributes to that confidence by placing a bank in position to absorb normal, and even
unusual, losses as they occur. Adequate capital
also gives confidence to the regulatory authorities as
they have a comfortable feeling that the banking
system will be able to absorb losses without impairing its capability to serve the credit needs of the
economy.
The problem is determining what is adequate
capital. There can be no precise answer since we do
not know what losses a bank will encounter in the
future. A mathematical formula can be devised to
obtain an answer but it has to be based on a set of
hypothetical assumptions and can only be as valid as
the assumptions.
In much of the study devoted to capital adequacy,
great emphasis has been placed upon various capital
ratios. If those ratios show declining trends, it is
often hurriedly concluded that bank capital is less
than adequate and the strength of the commercial
banking system is deteriorating. That is faulty reasoning. Perhaps an example can best illustrate. In
1893, the ratio of capital to assets was 30 percent. In
1945, the ratio was only 6 percent. Based on those
ratios, the commercial banking system would seem
to have been much stronger in 1893 than in 1945.
Yet, there were 491 bank failures in 1893 and only
one in 1945.
Nevertheless, one should recognize there has
been a historical decline in capital ratios. In 1875,
the ratio of capital to total assets was 36 percent. In
279

1973, it fell to less than 7 percent. Today, the capital
to assets ratio of the 10 largest banks in the Nation is
5 percent. That means capital is leveraged 20 to 1.
Among the 30 largest banks in the Nation, the best
capitalized bank has double the capital per asset
dollar of the thinnest capitalized institution. While
one should not make a fetish out of ratios, nevertheless, there appears to be a need for some guidelines
so that everybody is playing in the same ballpark.
Prior to World War II, the measurement of capital
adequacy was the capital to deposit ratio. If deposits
did not exceed 10 times capital funds, the regulatory
authorities felt the bank was adequately capitalized.
One regulator stated it was immoral for a bank to go
over the one-to-10 ratio. In fact, former Comptroller
John Skelton Williams considered issuing a regulation which would prohibit a National bank from
accepting deposits if its ratio was over one-to-8.
While the capital to deposit ratio had some validity,
it gave no weight to the quality of assets or the capability of bank management.
During and after World War II, the capital to
deposit ratio got considerably out of line, principally
due to large deposit increases which were invested
primarily in government bonds as loan demands at
that time were not particularly heavy. A new, arbitrary formula known as the risk assets ratio was
devised by the agencies. Cash and Governments,
which were considered riskless assets, were deducted from total assets, and capital was related to
the remainder, all of which were considered risk
assets. If a bank had more than $6 in risk assets for
every dollar of capital, management could expect to
be hearing from the regulatory agencies. Later, the
formula was refined and the same standards maintained.
Other formulas were also devised. One of the
more prominent ones was the so-called A B C formula. That was an allocation of capital against
assets. It was arbitrarily concluded that bank assets
have varying degrees of risk. Those assets were lined
up and a certain percentage of capital was allocated
against them. The allocated capital was then totaled,
and if the bank's existing capital structure was less
than the total of the allocated capital, the difference
was the amount that the bank was considered undercapitalized.
In 1962, the Comptroller's Office abandoned the
risk asset ratio and determined capital adequacy on
such factors as asset quality, liquidity, management,
etc. We are currently using that subjective test.
There are other theories on capital adequacy. Perhaps the most prominent one now being discussed is
the study made by George Vojta of the Citibank on
280

capital adequacy. Basically, Vojta's theory is that
current earnings should be two times the average
annual loss over the past 5-year period, and, that
capital funds should be at least 20 times the average
annual loss over the past 5 years.
That formula does not provide for catastrophic
losses. As Vojta emphasizes, if such losses occur, it
is the responsibility of the Federal Reserve to support the banking system.
Another theory is that capital should be sufficient
to cover the three following conditions:
• Absorb losses on the sale of unpledged liquid
assets to meet approximately 20 percent of the
unsecured deposits and short-term liabilities;
• To cover substandard and doubtful assets by 20
and 50 percent, respectively;
• To cover all fixed assets on the books.
The problem of capital adequacy became more
pronounced with the amendments to the Bank Holding Company Act several years ago. In many cases,
the Comptroller felt a National bank which was a
subsidiary of a bank holding company was adequately capitalized. However, when the holding
company made application to the Federal Reserve
for permission to make a non-bank acquisition, in
many cases the Federal Reserve felt the bank was
undercapitalized and required an injection of additional capital funds as a condition for approval of the
acquisition. That left the bank squarely in the middle
as here was one regulatory agency advising the bank
it was adequately capitalized and another regulatory
agency saying it was undercapitalized.
At the suggestion of the Comptroller, discussions
have been held between the Comptroller's Office
and the Federal Reserve regarding capital guidelines. The fundamental disagreement between the
two offices is the matter of subordinated capital
debentures. The Board in Washington is presently
using a ratio of equity capital to total liabilities.
Subordinated capital debentures are included in
liabilities and, therefore, a bank that has issued such
obligations is penalized. The Comptroller's Office
maintains that subordinated capital debentures are a
part of capital as they afford depositor protection.
For example, in the United States National Bank of
San Diego failure, the subordinated debentures remained in the receivership while all the deposit
liabilities were assumed by the Crocker National
Bank.
I believe the Federal Reserve had been under the
impression that the Comptroller's Office was approving subordinated capital debentures without
much of an investigation. However, the Comp-

troller's Office has been quite meticulous in reviewing capital note agreements to make certain that
such things as acceleration do not come into play at
the drop of a hat. I hope we have reassured the Fed.
Also, the Federal Reserve dislikes short maturities apparently feeling that a 7- to 10-year obligation is nothing more than a time certificate of
deposit. In order to reach an agreement, the Comptroller's Office has proposed more stringent standards. For example, we indicated a willingness to
lengthen maturities out to a minimum of 20 to 25
years with a sinking fund coming into play during the
latter life of the obligations. Also, we would probably be receptive to requiring that subordinated
debentures be convertible. In retrospect, I believe it
would have been wise had we made the convertibility feature mandatory 10 years ago on the theory that
we would only approve subordinated capital debentures for an institution we felt was viable. If the
institution continued to operate successfully, the
attractiveness of the convertibility feature would
have come into play and those subordinated debentures would then move down into the equity capital
base.
The Comptroller's Office does not want to be
wedded to any inflexible mathematical computations. We believe management is the key to a well
run institution. Therefore, we believe a well-managed bank, free of asset problems, is entitled to
operate on a higher leveraged capital base than one
which has asset problems. Some of you may be
aware of the rating system which is used by the
Federal Reserve and this Office. Generally speaking, banks rated "A" have classified assets not exceeding 20 percent of capital funds, "B" 20 to 40 percent, "C" 40 to 80 percent, and "D" over 80 percent.
We proposed to the Federal Reserve that "A" banks'
loan portfolios not exceed 8V2 to 9 times capital
funds; "B" banks, 7Vfc to SV2; "C" banks, 6V2 to 71/2;
and "D" banks, no higher than 6V2 times. The Federal Reserve thought that proposition had merit but
preferred a ratio of capital to total assets with allowances being given for highly liquid unpledged assets.
We cannot disagree with that suggestion and we are
hopeful that some guidelines can be worked out
which will be beneficial for the industry. We would
hope those guidelines are not rigid but flexible.
Even if suitable guidelines can be developed, the
present climate for raising capital is bleak. It is
virtually impossible to sell common stock today because of investor disenchantment with the market
generally. Most banks' price-earnings ratios have
fallen considerably in the past year. Capital debentures are not attractive because of high interest

rates. However, an interesting source of capital has
recently come to light, and its immediate acceptance
by the investment community seems to assure it a
prominent place in the market of finance. It is the
floating or variable interest rate note.
Citicorporation was the first to enter those uncharted waters. It announced a $250 million dollar
issue but, when prospects for success were so overwhelming, the offer was increased to $850 million.
Several other bank holding companies have followed
suit, and Standard Oil of Indiana has recently announced plans to market a similar issue.
Floating or variable interest rate notes are not
attractive to banks because present regulations require a minimum maturity or redemption period of
at least 7 years. However, it seems feasible to explore the suitability of that instrument's use by
banks on a subordinated basis. It seems to me that
it would be quite attractive to certain investors who
are interested in safety and are satisfied with a rate
slightly higher than the market rate for a prime
security such as Treasury bills. If the average investor is willing to forego the protection offered by
Federal Deposit Insurance, and it seems many of
them at the present time are, perhaps that could be
a new source of capital for banks.
If that type of instrument catches on, and it seems
that it will, serious imbalances in the banking system
could occur. Funds could flow from the smaller
banks to the large holding companies if the saver
believed it was imprudent to keep his funds in time
or savings accounts. Floating notes appear to appeal
to savers with balances in the $5 to 25 thousand
range, probably the most desirable and profitable of
all retail time accounts. Non-holding company banks
could very well be left with an ever-increasing volume of small, low profit savings accounts. Bank
liquidity already stretched could come under further
strain as the competitive advantages passed to the
holding companies. One shudders to think what
could happen if large corporations make a massive
move into the market with floating rate notes. So,
therefore, I believe serious exploration should be
given to the matter, in order that banks, particularly the small and medium-sized ones can remain
competitive. Some people may claim that those instruments could be a step towards indexing the
economy and bowing to inflation. However, that is
already happening now that many labor contracts
have cost of living escalation clauses.
Regulation Q is the culprit causing disintermediation by the small saver. The overwhelming success
of the recent offering of the "Nifty Nines" by the
U.S. Treasury indicates that the small saver is no
281

longer satisfied with the artificial ceilings imposed
by that regulation. The artificial ceilings on interest
that banks could pay on time deposits was one of the
more important causes of the credit crunches of
1966 and 1969. The shift of funds from financial
institutions into direct investments in both those
years strained the liquidity of the banking system.
We are witnessing that again today. It seems
patently unfair that ceilings be imposed on the small
saver while rates on prime loans, Federal funds, and
CD's over $100,000 can go through the roof. Even
though those loan rates today are hitting their historical highs, they would be even higher were it not
for the fact that the small saver has been subsidizing
them by foregoing a fair return on his funds. Some
people can justify low rates as a way to preserve an
adequate supply of mortgage money. Interest ceilings are not attracting funds for the mortgage
market. Those ceilings that were designed to provide
mortgage money are the very instruments that are
drying up the pool. Clearly, the ceilings are not
accomplishing the only purpose that can justify
them.
Consumer activists are running around the country literally trying to tear down banks and business.
Those activists have, for the most part, maintained
complete silence on the loss of purchasing power
experienced by the small saver who, by the way, also
is a consumer. It seems to me that those activists
define a consumer as a borrower and a saver as a
capitalist.
Now I'll get back to the second part of my topic,
bank liquidity. In many respects, bank liquidity is
more important than capital adequacy. Bank regulatory agencies cannot pay cash letters. Furthermore,
there is some flexibility in asset evaluation and the
regulatory agencies can stretch a little in a touch and
go situation.
The Comptroller's Office has been carefully following the liquidity positions of National banks for
over 10 years. We have devised a liquidity formula
which, although not perfect, had worked reasonably
well until the Nation's larger banks began extensive
money market operations. The present liquidity
formula appears adequate for non-money market
banks. Its reliability diminishes when used for
money market banks. A bank can acquire shortterm liabilities and place $1 in liquid assets for every
$5 or $6 it places in long-term assets and retain what
appears to be on the surface a reasonable liquidity
ratio. In fact, there was an article recently published entitled, "Let the Comptroller's formula work
for you," and the article advocated precisely that.
282

Perhaps there has been some abuse, but that is a
rather futile way to windowdress liquidity.
Bank liquidity has been significantly reduced over
the past several years. For example, we have seen
situations where the net borrowed Federal funds
position, securities sold under agreements to repurchase, and due to banks—time, primarily foreign,
represent as much as 40 percent of total balance
sheet footings. If negotiable CD's and CD's over
$100,000 are added to the above figures, the percentage shoots up to 50 and 60 percent.
Another disturbing observation is the habitual
heavy use of Federal funds by certain banks. We
recently reviewed a selected group of 30 banks
which have been heavy in a net borrowed Federal
funds position. Their Federal funds borrowed positions as of March 31, 1974 ranged from a low of 63
percent to a high of 482 percent of capital funds,
including loan loss reserve. It also ranged from 3 to
22.8 percent of total balance sheet footings. For the
period ending March 31, 1974, the 331 large Federal
Reserve reporting banks had 106 percent of their
capital funds and loan loss reserves in a net borrowed Federal funds position.
We also analyzed the 30 largest National banks on
a little diflFerent basis to determine what percent of
short-term liabilities were being used to support a
loan portfolio. We took total deposits and deducted
secured deposit liabilities, due to banks—time, and
CD's over $100,000 to arrive at an adjusted deposit
figure. In some cases, loans to adjusted deposits ran
as high as 150 percent.
From that analysis, it appears quite obvious that
many banks are borrowing short and lending long.
Their ability to maintain liquidity depends upon the
buying of funds and that depends upon market confidence. If confidence is lost, a bank has a liquidity
problem of almost unmanageable proportions.
Therefore, I cannot overemphasize the need to
match asset maturities and liability maturities in
such a manner that assets can be liquidated, if
necessary, at a minimum loss.
At the present time, this Office is devising a more
sophisticated liquidity analysis for money market
banks. Basically, it will match asset and liability
maturities. Of significance, it will not consider the
general loan portfolio as a source of liquidity. Our
experience has taught us that over-reliance on the
loan portfolio for liquidity is a fatal mistake. In a
critical situation, loan liquidation never comes up to
expectations. That is even more so today, when
many banks have strayed from sound credit standards and many industries which, a few years ago,

appeared to be acceptable credit risks are now experiencing financial difficulties. Those credit problems are also compounded in some cases by sizable
market depreciation in the investment portfolio.
When interest rates ease, banks seem to stretch
their investment maturity positions. They then
become locked in when the credit crunch comes and
liquidity in the portfolio evaporates.
I think the time is ripe for bank management to
review capital and liquidity positions. Efforts should
be made to upgrade loan portfolios. Speculative
loans should be shut off and those on the books
should be weeded out. A heavy loan portfolio should
be offset by unpledged high-grade short-term securities. I think we are in an era where the banking
business will face its severest test since the 30's. It
behooves us to reassess our operations and then ask
ourselves, "Do we feel comfortable?"
REMARKS OF JUSTIN T. WATSON, FIRST DEPUTY
COMPTROLLER OF THE CURRENCY, BEFORE THE
ALABAMA BANKERS ASSOCIATION, GULF SHORES,
ALA., SEPT. 12, 1974

"Changes in National Bank Examinations"
Our country, its society, and the economy are
always on the move. The business of banking has
not taken a back seat and, in fact, it has been at the
forefront and provided leadership in our changing
times. New banking services, new ideas, and new
methods are constantly being offered to the public.
Competition triggers such action. The Office of the
Comptroller of the Currency is giving a great deal of
attention to the environment in which National
banks operate so that we will be abreast, if not
ahead, of changes in order for us to function in a
constructive manner.
By way of background, let me say that when the
government feels it necessary to have administrative
regulation for an industry, as it has for banking for
more than a century, it almost always does so by
assigning such responsibility to a particular agency
or group of agencies. The purpose of regulation by
independent agencies such as we have in banking is
to insure that the performance of that industry is
consistent with the National interest and the individual needs of the public. Surveillance may be
directed mainly toward the prevention of abuses
which, in banking, will injure the public through
bank failures. Regulation, however, may go beyond
monitoring and may establish minimum standards
for performance.
The reason for the use of independent regulatory

agencies is that the necessary degree of regulation
involves close supervision of the management of the
industry. Standards of performance are too complex
and too changeable to be prescribed by statute.
Considerable judgment is required in the assessment
of performance. The strength of the independent
regulatory agency is the combination of the executive, legislative, and judicial powers it holds. Its
actions and decisions are usually not subject to review by another office or agency in the executive
branch of government.
The Comptroller's Office was the first independent regulatory agency established by the Congress;
the first Federal agency to which the Congress made
a broad delegation of executive, legislative and
judicial powers; and the first on which it conferred
an independent status within the executive branch.
Examinations and special reports are used as a
regulatory tool by the Comptroller's Office and, I am
sure, by all bank regulators. The severity and scope
of an examination may vary depending upon the
condition of the bank in relation to the economy.
However, there is usually no disagreement between
bankers and the regulatory authority about its ultimate objective, sound and safe banks.
Managing liabilities is a highly important banking
function. It relates to the source of funds for meeting
loan requests and commitments, and depositor demands. Often today, liability management means to
locate, accept, and purchase additional liabilities to
meet those requests and demands. The manner in
which that is accomplished ties to the liquidity, and
perhaps the solvency, of the individual bank, if not
the banking system.
Successful liability management in the sense that
it is generally referred to in banking today, demands
full recognition that certain basic rules must not be
violated. That is, we should recognize the difference
between daily excess cash on deposit and hot money
in search of a home at the highest price. Second,
restrictions are necessary on the maturities of assets
which are to offset hot money purchased. That, I
feel, is a pressing issue in view of the proportions of
large CD's, Federal funds, securities sold subject to
repurchase, and other forms of day-to-day and shortterm borrowing, including foreign transactions. The
latter have been used freely in some liability management concepts and in the quest for a better
bottom line. Further, in that regard, we cannot overlook loan commitments, letters of credit, and ineligible acceptances. With respect to the nature of
commitments to lend, you may recall that the
Federal Reserve Board, the Federal Deposit Insur283

ance Corporation, and the Comptroller of the Currency, on April 6, 1973, addressed letters to the
chief executive officer of any bank with deposits
exceeding $100 million, asking for careful judgment
on the appropriateness of the bank's credit risks and
the source of funds for the take-down, based on a
consideration of economic conditions.
In summary, dangers associated with the practice
of liability management are borrowing short to lend
long, excessive interest rate competition, and reverse fund flows resulting from confidence crises or
for other reasons. I hasten to add that the risk of
borrowing short to lend long is not uncommon to
banking, in a sense it is what banking is all about.
But the assumption of such risks, while necessary in
banking, must be kept within reasonable limits. The
practice of liability management, as it has evolved,
has permitted the creation of a large volume of interest sensitive and potentially confidence sensitive
short-term liabilities. In addition, a fundamental
theory of traditional banking states that risk assumption in assets will vary in proportion to cost of liabilities to carry those assets. The fundamentals should
not be forgotten.
Our new "Maturity Schedule of Assets and
Liabilities", which at outset will be requested from
only the 200 largest National banks, is the outgrowth of the considerable attention in our Office
recently to our need for more comprehensive liquidity data. That schedule has been discussed with
officers from a number of banks, and the BAI has
also been most helpful and constructive to us in our
deliberations.
Another area that we are looking into is the matter
of the loan evaluation on large national credits which
are held by two or more banks under a master loan
agreement. We are of the strong opinion that identical loans to national concerns by banks in various
parts of the country should be treated uniformly by
our examiners. That has not always been the case,
and it has created problems for bank management
where a line is classified at their bank, but has been
passed elsewhere. We know bankers exchange such
information. Also, lack of uniformity has created
some problems with the Internal Revenue Service in
their acceptance of loss classifications in National
banks. Accordingly, the Comptroller's Office is
taking steps to initiate a program whereby a team,
probably three, of select examiners from various
regions will visit lead banks for the purpose of
classifying or passing lines of credit totaling $20
million or more, in which participations have been
sold to various banks throughout the country.
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That classification would then apply to all National
banks sharing in the credit until the next review at
the lead bank. Interim reviews would not occur unless there were significant changes in the credit.
Each participating bank, Regional Administrator of
National Banks, and the Conference of State Bank
Supervisors would receive a copy of the classification. Incidentally, the American Bankers Association and the Conference of State Bank Supervisors
have worked closely with us in formulating this program and it appears likely that the Conference of
State Bank Supervisors will initiate a similar
arrangement. When that happens, classifications
arrived at in State banks that are lead banks will be
made available to us. We believe this program will
eliminate the existing inconsistencies and, more
important, will lead to a more thorough and more
constructive evaluation of the particular credits
under consideration. In the long run there should be
a time savings because it will not be necessary to
repeat a thorough evaluation of each and every one
of the participating banks. In our examination of
foreign departments, we have already initiated a
similar program concerning the treatment of country
credits.
Our Office is establishing a Consumer Affairs
Division to work in a broad area affecting consumerism as it relates to banking. Those areas of
concern include the refusal to grant credit on the
basis of sex or race, violations by banks of various
statutes designed to protect consumers' interests,
improvement of banking public relations in helping
individual borrowers understand extensions of credit
and encouragment to banks to establish systems to
answer customers' questions about credit. We also
want banks to educate their officers and employees
about consumer laws and regulations so that they do
not give the public erroneous, or unlawful, information. It is probably relatively rare that a bank deliberately attempts to take advantage of a customer,
but it is not rare for a bank or loan officer to act in
ignorance of pertinent laws. The examining function
of the Comptroller's Office must be prepared to
anticipate such problems. The Division will be prepared to advise the Comptroller on policy matters,
for example, the repossession procedures of banks.
The Division's director, who has experience in
bank examination, will be responsible for implementing the program and will be assisted by a staff
consisting of consumer affairs specialists and National bank examiners who are knowledgeable about
consumer banking. Because of their familiarity with
the examination process, those examiners should be

able to develop examination procedures dealing with
consumer affairs and statutes and to coordinate the
necessary training of regional staff and field examiners. Legal counsel will also be available to the
staff in order to keep abreast of various Federal and
State consumer protection laws and to give advice
on the Division's response to specific complaints.
The purpose of establishing a consumer affairs
division stems from the commitment by the Comptroller's Office to uniformly enforce both Federal
and State consumer protection laws as they relate to
National banks. That commitment extends beyond
answering Congressional criticism of our past endeavors and should also consist of more than courteous cooperation with various State enforcement
agencies. National banks must understand that it is
our policy to enforce those laws and to encourage
their cooperation in executing the spirit of the law.
A worthwhile result will be increased confidence in
the banking system and the Office of the Comptroller.
Earlier I mentioned that the banking industry is
experiencing rapid and profound changes. The
barriers to statewide and even nationwide banking
are falling. Commercial banks are becoming financial conglomerates, and are spreading out both
geographically and in terms of services provided to
their customers. Tremendous asset growth, centralization or decentralization of various banking functions, greater sophistication in asset and liability
management and the development of new and specialized services are part of the challenge before the
Office of the Comptroller of the Currency and the
individual National bank examiner. Accordingly, a
thorough and all-encompassing review of the Office
and bank examination practices and procedures is
underway by Haskins and Sells. That project is our
effort to ensure that the services provided by our
Office are relevant to today's needs. The Office must
be capable of not only participating in, but leading
the rapid evolution of dramatic change which the
banking industry is currently undergoing. The
project will help to determine and improve the quantity and the quality of services provided to the public
and to the National banks. The major objective is to
attain the highest possible level of professionalism
and expertise in the Office of the Comptroller of the
Currency.
The evaluation will be a review of the objectives,
scope, and resulting examination report of the work
done by the examiners, with the idea of determining
whether the objectives of the Office are properly
stated in view of the Comptroller's responsibilities

as established by law. The study will review the
impact of expanded computer capabilities on the
total operation of the Office. We will try to determine
what National bankers would like from the Comptroller's Office that they do not get at present. We
want to establish a comprehensive early warning
system so that we will be able to act instead of reacting. The study is scheduled to be completed during the summer of 1975.
Perhaps some of the more significant changes to
take place in banking over the past 10 to 15 years
have been in the area of automation. As a result, we
have had to change some of our examination procedures and that has affected banks, their operating
policies and procedures, their internal audit programs, and their reporting.
The most obvious change in examination was the
initiation of the EDP examination back in 1967-68.
We now have select examiners, trained in data processing, located in all regions. Their responsibility
is the annual examination of data processing operations in banks, bank service corporations, and private companies performing automated services for
banks. As a result, banks have had new standards
and procedures for EDP operation, auditing and
output.
Before the days of automation, when our field
representatives went into a bank to conduct an
examination they were instructed to take control of
various ledgers (demand, savings, installment, etc.)
and run up the individual ledger sheets on an adding
machine to prove totals to the bank's general ledger
controls. Then came automation. Suddenly, we
found ourselves unable to make an independent
proof of automated applications. Instead, we accepted printed trial balance reports generated by a
computer. In our original procedure that would be
analogous to asking the bank's various posting clerks
to run up individual ledger sheets on an adding
machine after posting and then to present the tape to
us as a trial balance. In other words, as we accept
computer output not produced under our control,
the integrity of the information declines. Often the
format of data contained on computer output is not
easy to follow and transcribing to work papers is
difficult and time consuming.
With that in mind, our Office is currently testing
an automated retrieval system to be used in conjunction with commercial and trust examinations. Basically, the system will give us the capability to extract
selected data from individual bank magnetic files
and print reports designed to our specifications. Not
only will that restore data integrity to former levels
285

but it should also improve examiner efficiency and
effectiveness by:
• Standardizing the output an examiner must use;
• Eliminating much of the laborious and time consuming task of transcribing data from the bank's
output media to work papers;
• Performing some analysis on the data which
would aid the examiner in his evaluation of the
condition of the bank;
• Assisting the training of new examiners by making output reports consistent and identical no
matter what bank is being examined.
Let me hasten to add that such a retrieval system is
by no means a reality. We are only in the testing
stages of a pilot program. If the results of our tests
indicate that the automated retrieval examination
system is unworkable, we will have to explore alternative methods. The biggest problem we foresee is
operational. It is very difficult to develop a retrieval
system with enoughflexibilityto be used in the wide
variety of computer system environments existing in
the country's 4,700 National banks.
Another area relating to data processing is our
minimum standards of output. Those standards
simply outline the information our Office deems
necessary to effectively examine and regulate the
bank. In most instances the bank should already
have all of that data and more, so there should be
little effect on banks. The minimum standards of
output are being revised and will soon be reissued.
Any new requirements we come up with would certainly directly affect only new systems under development.
During the examination a great deal of time is
spent on the loan portfolio. Many banks have, or are
in the process of, automating commercial loans. The
computer output that replaces the manually posted
liability ledger has not always proven adequate for
our needs, or even for the bank's needs. The history
of the loan and any indirect liability are often missing
or are very difficult to get. Therefore, in many parts
of the country, our examiners have taken the initiative and have discussed our data requirements with
the systems design people to make sure those requirements are incorporated into systems before
they become fixed. In the past those efforts have not
always proven successful, but our Office's emphasis
on cooperation and involvement will continue.
In many instances the banks have actually developed specialized reports for examiners, including
automated line sheets. Some of the very large banks
have what is referred to as the "examiner's package"
which kicks out pre-defined reports specifically for
286

use by the examiner. A request to have the package
run may be made directly or through the audit department. We recognize that increased complexity
of bank operations, tightly scheduled computer
usage, and delayed posting, make it imperative that
our Office request only reports that are needed.
Another significant change in recent years has
been the closer look at bank audit departments,
their levels of competence, and the completeness of
the internal audit program. To a large extent, that is
a result of the EDP examination. Initial reviews
found audit department quality poor and audit coverage inadequate. Traditional audit techniques were
found to be ineffective in an automated environment. We feel our EDP examination has highlighted
the audit weakness, not only to the Comptroller, but
also to the bank and particularly to the bank auditor.
The tremendous increase in volume and the advent of computerized bookkeeping has made the
proof and balancing of trial balance totals to the
bank's general ledger increasingly complex and difficult to accomplish. That is particularly true for such
applications as demand deposits and credit card
operations. Perhaps our examiners have not kept
pace with developments and, therefore, find it increasingly difficult to understand the entire operation, the handling of unposted and rejected items,
and the final settlement to preestablished totals.
We hope to improve that phase of the examination
through better training of new examining personnel
and closer supervision by the examiner-in-charge.
The curriculum of our new assistant examiner's
school will have a large section on the settlement of
automated applications.
With the widespread use of computer output
microfilm, our Office for the first time is confronted
with the problems of examining an application without the benefit of printed hard copy output. Up to
this point we have always insisted on hard copy output. How much longer can we insist on printed hard
copy? The rising cost of printing and other complications may force us to reconsider and accept other
forms of output. That may require new methods of
examination.
The last matter I would like to comment upon is
our concern over self-dealing. The experience of the
Comptroller's Office indicates that unsafe and unsound banking practices are frequently associated
with self-dealing by the bank's managing officials.
Thus, the identification and scrutiny of self-dealing
transactions is important both to the bank and to the
Comptroller's Office. One of the most common
manifestations of self-dealing is the extension of
credit on an unsound basis. Other examples include

various types of contracts negotiated between the
bank and a business enterprise of a bank official on
other than an "at arms length" basis which sometimes benefit those individuals improperly on their
interests, to the detriment of the bank.
This past summer we solicited in the Federal
Register, comments concerning a proposed regulation to deal with that problem. Many constructive
suggestions were received and the regulation in its
final form will be published before year-end. The
purpose of the regulation, which will require principal officers and directors of National banks to keep
on file with the bank a report relating to their business interests, is to establish an informational base
upon which bank management and the Comptroller's
Office may more accurately assess the extent to
which and manner that a National bank may be engaging in transactions with its own directors and
senior officers.
I believe that sums up the major changes in the
Comptroller's Office recently. We hope these
changes will be constructive, not only for ourselves,
but the National Banking System as well.
REMARKS OF JUSTIN T. WATSON, FIRST DEPUTY
COMPTROLLER OF THE CURRENCY, BEFORE A
SYMPOSIUM OF THE WORLD TRADE INSTITUTE,
NEW YORK, N.Y., OCT. 24, 1974

"Identifying Legitimate Off-Shore Investors"
I am honored to participate in this symposium and
to be among such distinguished guests. The topic
suggested to me is, "Identifying Legitimate OffShore Investors." In view of the rather narrow range
of that topic, I thought perhaps that I would first
endeavor to introduce you to the Office of the Comptroller of the Currency and comment briefly on the
bank regulatory setup in the United States.
The Office of the Comptroller of the Currency is
the oldest regulatory agency in the United States
Government. It was organized in 1863. The Comptroller of the Currency is a one-man bank regulator
who is appointed by the President and confirmed by
the Senate for a 5-year term. All other regulatory
agencies are boards or commissions of from 3 to 7
members. The Comptroller is also a director of the
Federal Deposit Insurance Corporation.
The primary responsibility of the Comptroller's
Office is the supervision of the National Banking
System. That is done through the examination
process. The purposes of bank examinations are to
determine solvency of the particular institution
under examination and to ascertain whether it is
operating within the framework of applicable bank

ing laws. The existing law requires that the Comptroller examine each National bank four times every
2 years, however, he may waive one examination
during this period. The Comptroller also has the
authority to examine any National bank as frequently
as he deems advisable. A report of examination is
prepared by the field examiner in charge and a copy
is submitted to the Comptroller and one to the bank.
The Office of the Comptroller of the Currency has
several divisions. They are examining, legal, economic, organization, and administrative. We have
are approximately 2,550 employees. The examining
division is by far the largest, with over 2,000 people
in the field in addition to Washington personnel. The
examining division is in a constant state of travel,
moving from one National bank to another conducting field examinations. The principal function of the
examining process is the evaluation of bank assets
for collectibility. The examiner has the authority to
chargeoff assets which he believes are uncollectable. Those chargeoffs diminish capital funds and if
they exceed a bank's capital structure the Comptroller has no choice but to put the bank into receivership or attempt to merge it with a stronger institution.
Other functions of the Comptroller's Office are
the chartering of new National banks, granting permission to existing National banks to branch within
the geographic limitations imposed by State law, and
permitting mergers to take place where the resulting
bank will be a National bank.
There are approximately 4,650 National banks.
Those banks have approximately 15,000 domestic
branches and 600 foreign branches. Total resources
in the National Banking System are $490 billion, outstanding loans $272 billion, deposits $395 billion,
and capital funds $38 billion. Last year National
banks had net income of $3.8 billion. Although
National banks represent approximately one-third of
banking institutions in the United States, they hold
approximately 60 percent of the Nation's banking
resources.
There are approximately 13,500 commercial banks
operating in the United States; 9,000 are Statechartered banks which are under the supervision of
the 50 State banking authorities. Those that are
members of the Federal Reserve System are also
supervised by the Federal Reserve. State-chartered,
federally insured banks that are not members of the
Federal Reserve System are also supervised by the
Federal Deposit Insurance Corporation. All National
banks are required by law to be members of the
Federal Reserve System. That membership is optional for State banks, and only approximately 1,000
287

are members. Those members are, however, generally the larger State-chartered institutions.
The banking industry has expanded rapidly in the
past 15 years. New banking services have been
initiated and competition has become much more
fierce. The scramble for deposits and non-deposit
funds has continued at an accelerated pace. Funds
to meet loan demands have out-stripped the normal
deposit growth and that has created an active and
aggressive money market and the development of
new money market instruments.
Along with that development came the money
brokerage business. That business not only deals
with the brokerage of negotiable certificates of
deposit, security repurchase transactions, and Federal funds, but also with deposit placements. Most
such operations are conducted on a highly ethical
basis, however, as in any field of endeavor, unethical
operators creep into the picture. With most banks
aggressively seeking additional loanable and investable funds, they can become victims of unethical
operators, commonly known as confidence men.
Banks have always been plagued with external and
internal crimes. In the days gone by, it seemed the
classic crimes were bank robberies and embezzlements. However, in the 60's, confidence men were
able to get into the banks through fraudulent loan
schemes. That continues; however banks are much
more vigilant. In the late 60's, groups of banks
sprang up in the Channel and Guernsey Islands and
in some of the Carribbean Islands. Those banks
were nominally capitalized and solicited funds in the
United States offering high interest rates. Most of
the depositors' funds were placed in insider loans
and the banks subsequently failed with the American investors losing sizable amounts of money.
Several banks in the United States were also victims
of those institutions. In some cases banks made
loans against their worthless certificates of deposit,
granted immediate credit on drafts drawn upon
those institutions, and, in some cases, even made
direct deposit placements. The Comptroller's Office
endeavored to warn National banks when that situation came to our attention. The classic case of fraud
was perhaps the Bank of Sark, which operated on
the Isle of Guernsey in a rented, one-room, third
floor office staffed by an ex-barmaid. In another
case, a bank was operated out of a gasoline station
in Nassau, Bahamas.
In April 1972, a new scheme came to the attention
of the Comptroller's Office through inquiries by a
number of financial institutions in Florida and Ohio.
We learned that individuals were approaching banks
and indicating to them that they represented for288

eign interests, primarily from the Middle East,
who desired to place millions of dollars with them for
a long period of time at rates very favorable to the
banks. The typical offer was that many millions of
dollars would be delivered to a bank in exchange for
a 20-year maturity certificate of deposit at a rate
approximately 4 percent below the market. The
interest would be compounded over a 20-year period.
None of the depositors' names were revealed to the
banks. When interest rates fell in the United States
those propositions slowed down; however, they
picked up again at the beginning of 1974. Mysterious
money brokers began making the rounds of U.S.
banks offering to deposit millions of dollars of
Middle East wealth at terms that seemed too good to
be true.
Although most banks were wary, some were
sufficiently enticed that they began negotiating with
those brokers. Thus far, we know of no banks receiving deposits under that scheme. We did closely
follow one transaction in which a bank agreed to
accept such deposits, but to date, the funds have not
arrived. We fear the letter could be used to swindle
another financial institution. We believe the real aim
of the suspected confidence men is to get a bank
letter signed by the chief executive officer agreeing
to accept a huge deposit. That letter, perhaps
altered, could then be used as a reference to get a
loan somewhere else or as an inducement to get
another bank to pay a finder's fee in advance for
promised big deposits that would never materialize.
One banker reported he was approached by a man
offering $20 million to be deposited in the form of a
certificate of deposit with a 20-year maturity at a rate
approximately 4 points below the current market
rate. He practically lived at the bank for 3 months.
Details of the proposed transaction kept changing,
telexes flew back and forth between Switzerland and
the United States. Finally, everything was agreed
upon; however, the funds failed to show up. The man
the bank had been dealing with went to Switzerland
and only postcards have been arriving since.
Another banker informed this Office that his bank
was offered a multi-million dollar deposit in exchange for certificates of deposit by a money broker.
The banker indicated interest. The money broker
said he knew of $300 million in foreign funds which
certain unnamed depositors wanted to place in
American banks for a long period of time. Names of
the prospective certificate holders were indefinite;
however, two organizations were mentioned which
have international business interests. The banker
subsequently informed the broker he was not interested in the proposition due to lack of information as

to the source of funds and the principals involved.
He also questioned why the large money center
banks were not approached and why an investor
would want to freeze funds for 15 years or more at
fixed low interest rates. He also was unable to obtain any information on the financial responsibility of
the broker.
Overall, approximately 100 National banks reported to us that they had been approached with
virtually identical propositions. To the best of our
knowledge no bank has received funds through
such an arrangement, and none have lost funds
through the payment of advanced brokerage fees.
Thus, we have no basis on which to report those
transactions to the Department of Justice.
In addition to approaches to commercial banks,
solicitations have also been made to corporations
operating in this country. Basically, a money broker
offers to lend a company several millions of dollars
again at a rate approximately 4 percent below the
current prime. A fiduciary bank will supposedly
handle the loan for the unnamed lender and confirmation will come within 15 days. All the corporation has to do is produce a letterhead application
agreeing to the loan and a separate letterhead agreeing to the payment of 4 to 5 points to the money
broker. Here again we have no knowledge of funds
actually being delivered to make the loan and,
we believe in some cases the corporation
paid the points and thus was bilked.
We have endeavored to obtain information on
several of the firms and individuals to determine
their types of business, methods of operation, and
business connections. One firm operating in Georgia
was not listed as a Georgia corporation or as a foreign
corporation authorized to do business in Georgia.
The Securities Division of the Secretary of State of
the State of Georgia did not list the firm as a broker
in securities. Local banks had no credit information
on the firm and the firm did not have a listed telephone number in the Atlanta, Ga. telephone directory. Although the firm's letterhead contained an
address, the management of the building where the
firm was supposedly located stated that no such
tenant existed. They also reported they had received
numerous inquiries about the firm.
Another broker whom we checked had a very
checkered career. He was promoting stock of the
company and managed to unload that stock on various insurance companies over which he and some
other disreputable associates had working control.
He was also involved with an infamous land swindler
who was under indictment.
There is an old principle in banking which states,

"know your customer." That is applicable not only
to borrowing customers but depositing customers as
well. Dealing with strangers can be hazardous and
identifying legitimate domestic and off-shore investors is of the utmost importance. Fortunately, the
American banking system has a very good record in
that respect.
REMARKS OF JUSTIN T. WATSON, FIRST DEPUTY
COMPTROLLER OF THE CURRENCY, BEFORE THE
FIRST GOLD, SILVER, AND FOREIGN EXCHANGE
SEMINAR, AMSTERDAM, NETHERLANDS, NOV. 8,

1974
"How Inflation is Affecting and
Will Affect American Banking"
I am honored to participate in this Seminar and to
be among such distinguished guests. My subject is
"How Inflation is Affecting and Will Affect American Banking." Inflation is the most important thing
on the minds of the American public today. Although
the inflation rate is higher in many other countries,
the American economic and financial community
agree that the continuation of the present high rate
of inflation in the United States will wreak havoc on
the country.
The U.S. economy has been in an inflationary
spiral for the past 40 years. At times the rate has
been negligible, but during the past few years it has
been accelerating to reach the present level of about
12 percent.
During the Great Depression of the 30's, which
was accompanied by 8,800 bank failures, the price
level in the United States dropped dramatically. The
Roosevelt Administration undertook a set of economic policies designed to maintain and even to
increase existing price levels. Certain legislation
such as the National Recovery Act and the Fair
Trade Act was passed. That was nothing more than
legalized pricefixingin an attempt to eliminate price
competition and was ultimately ruled unconstitutional.
After the Depression and through the early 60's
the American banking system operated in an ultraconservative manner. President Kennedy came into
office in early 1961 at a time the economy of the
Nation was almost at a standstill. He was persuaded
that a slowing rate of economic growth was in the
large part a consequence of unduly restrictive
monetary policy. For the previous 10 years, the
money supply had been increasing at an annual rate
of 2.1 percent, which was less than many economists
and bankers thought necessary to support a real
growth of the economy on the order of 4 percent a
289

year. President Kennedy expressed the view that a
tight monetary policy could not be allowed to induce a
recession and a marked change in monetary policy
ensued. From 1961 to 1967, a period of sustained
high performance by the economy, the money supply
increased at a rate of 3.3 percent per annum, well
above the average rate of increase in the 50's.
President Kennedy appointed James J. Saxon as
Comptroller of the Currency. A cordial, vigorous
extrovert, Saxon brought many changes in bank
regulation to the Office of the Comptroller of the
Currency. Those changes were followed by many of
the State banking authorities. Mr. Saxon encouraged
vigorous bank expansion, more liberal powers, and
innovative ideas to make the banking industry not
only more competitive but to serve the public interest as well. With dramatic changes in mind, Saxon
requested each National bank to give its judgment
concerning needed changes in the laws, policies,
and regulations affecting operations. At the same
time, he appointed a committee of 24 bankers and
lawyers to review the National bank responses and
to report their conclusions and recommendations.
The committee published a document entitled,
"National Banks and the Future." In general, the
committee recommended many changes that would
broaden the lending and investing powers of National banks and that would enable many of them to
expand the scope of their activities.
From 1962 to date, the banking system of the
United States has experienced unprecedented expansion. Annual Federal expenditures during that
period have increased from $100 billion to $300 billion. Government deficits and rapid credit expansion
are the two principal causes for inflation in the
United States.
The Federal Reserve System has been applying
monetary brakes on the economy. That has resulted
in high interest rates but has had little effect on
dampening the ardor of bank borrowers. In fact,
soaring interest rates have placed an additional
burden upon the United States banking system. For
all practical purposes the equity market in the U.S.
is closed. The long-term bond markets are very thin.
The commercial paper market has become very
restrictive with only the largest high-grade corporations able to use that avenue of finance. The banking
system has been accommodating those borrowers
who, under ordinary conditions, would be going to
the marketplace.
The economic psychology of the average American individual and the business community seems
to be, "it is cheaper to buy today than to buy tomorrow, and what is borrowed today can be paid
290

back tomorrow in depreciated currency." That attitude has placed increasingly heavy demands upon
the credit facilities of U.S. banks.
The rate of savings in the United States has slowed
down. Many depositors are drawing down deposit
funds to place them in U.S. Government bonds or
money market instruments where the rates are substantially more attractive.
Loan demand has far outstripped deposit growth
in the past decade. That has resulted in a new technique called "Liability Management." That is simply
buying money on a short-term basis by selling large
certificates of deposit, obtaining time deposits from
other banks, buying Federal funds, and selling securities under agreements to repurchase. Those transactions are engaged in to support and expand loan
portfolios. We have seen cases where such items
make up as much as 50 to 60 percent of a bank's
balance sheet footings. It is, in essence, borrowing
short and lending long. The ability to continue that
practice depends on market confidence. If confidence is lost, a bank has a liquidity problem of
unmanageable proportions.
Inflation and high interest rates have resulted in
distortions in credit markets. Housing is a classic
example. Banks have diverted funds from the housing market because more attractive rates could be
found elsewhere. Thrift institutions which are
limited in interest payment to depositors have also
experienced deposit run-offs. That has resulted in a
substantial decrease in home building. Home building is highly sensitive to money market developments. Soaring interest rates and reduced availability of mortgage credit have greatly aggravated
the poor condition of that industry which is already
suffering from sharply higher land and construction
costs and from the erosion of the consumer's purchasing power.
A few benchmark indicators of the level of inflation in the United States may be useful. Between
1971 and 1972, consumer prices in the United States
rose 3.3 percent, a level which we regarded as uncomfortable at the time because consumer prices
had risen about 1.6 percent a year from 1960 to 1965.
Now, an annual rate of growth for prices of 3.3 percent would be considered a desirable and difficult
goal to achieve.
Between 1972 and 1973, price increases accelerated to a rate of 6.2 percent. In 1973, from January
to December, prices rose about 8.5 percent. That
price acceleration has continued, with the consumer
price index up 8 percent between January and
August of 1974.
If the rate of inflation continues at the pace of

TABLE 1

Rate of Change of Prices and Money Supply as Compared to Federal Budget Surplus or
Deficit, Selected Postwar Years

Year

Percent change, year to
year in consumer prices

Percent change in
the money supply1

1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973

1.7
2.3
8.5
14.4
7.8
-1.0
1.0
7.9
2.2
0.8
0.5
-0.4
1.5
3.6
2.7
0.8
1.6
1.0
1.1
1.2
1.3
1.7
2.9
2.9
4.2
5.4
5.9
4.3
3.3
6.2

-1.0
-0.3
4.5
5.6
3.8
1.1
2.7
2.2
1.3
-0.7
3.8
1.6
0.6
3.1
1.5
3.7
4.6
4.6
2.4
6.6
7.8
3.5
6.0
6.3
8.7
5.7

Surplus or deficit in
Federal Gov't budget
(National Income Accounts)
as a percent ofG.N.P.

3.3
-0.9
3.2
1.9
-1.1
-1.9
-1.6
1.0
1.4
0.5
-2.3
-0.2
0.7
-0.7
-0.7
0.1
-0.5
0.2
0.0
-1.6
-0.8
0.9
-1.2
-2.1
-1.4
0.0

Dashes indicate information not available.
1
Money supply is defined here as private demand deposits plus all currency outside the Treasury, the Federal Reserve Banks, and the
vaults of all commercial banks.
SOURCE: Economic Report of the President, Feb. 1974, pages 249, 300, 310, and 328.

TABLE 2

Percent Change in Consumer Price Index for Selected Countries, 1963-1974
Year
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
19741

United States

United Kingdom

1.2
1.3
1.7
2.9
2.9
4.2
5.4
5.9
4.3
3.3
6.2
12.4

1.9
3.2
4.8
3.9
2.5
4.7
5.4
6.4
9.4
7.1
9.2
21.6

France
4.8
3.4
2.5

2.7
2.6
4.6
6.4
5.3
5.5
5.9
7.3
16.8

Germany
3.0
2.3
3.4
3.5
1.4
1.5
2.7
3.7
5.2
5.7
6.9
7.0

Italy
7.4
6.0
4.5
2.4
3.2
1.3
2.6
5.0
4.8
5.7
10.8
21.4

Netherlands
3.8
5.5
5.2
5.8
3.2
3.6
7.5
4.4
7.6
7.8
8.0
10.8

1974 figures are based on trends in price index from December 1973 to June 1974.
SOURCE: Economic Report of the President, Feb. 1974, page 359. International Financial Statistics,
146-147, 202-203, 264-265, 368-369, and 374^375.

Oct. 1974, pages 140-141,

291

recent months, the United States will experience a
gain of better than 12 percent for the year, the first
time the United States will have experienced such a
rate of price increases since 1947. The shock and
dismay we in the United States presently feel concerning rapid price increases arises from our history
of rather modest inflation, even during the turbulent
times of World War II.
By way of comparison with the experience of other
countries, United States prices rose approximately
6 percent between January and July of 1974. During
the same period, Canada experienced a gain of 7 percent, the United Kingdom an increase of 9 percent,
West Germany 3 percent, France 7 percent, Japan
10 percent, and Italy 12 percent. As you can immediately see, the German experience is considerably better than that of the United States, but, some
other European countries are experiencing rates of
inflation even more troublesome than that felt in the
United States. Expressed as an annual rate, some
European countries will see price increases near
20 percent this year, and others will have figures
closer to 6 percent.
Naturally, we know not all countries