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Federal Reserve Bank of Minneapolis




1992 Annual Report

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Banking’s Middle Ground:
Balancing Excessive Regulation
and Taxpayer Risk

Federal Reserve Bank of Minneapolis




1992 Annual Report

Banking’s Middle Ground:
Balancing Excessive Regulation
and Taxpayer Risk

By Gary H. Stern, President
Federal Reserve Bank o f M inneapolis

The views expressed in this annual report are solely those of the
author; they are not intended to represent a formal position of the
Federal Reserve System.




President s Message

Two themes predom inate in this year’s economics essay.
First, we urge an approach to banking policy that balances
the interests of bank custom ers with those of taxpayers.
If achieved, such balance will avoid both an excessively
regulated banking system unable to m eet custom er needs
and an excessively accident-prone system potentially costly
to the taxpayer.
The second them e is a renewed call for enhanced
m arket discipline o f banks. M arket discipline can help to
contain excessive risk-taking by banks and can help Congress
and bank regulators assess the degree and pace with which
deregulation of the industry should proceed. M ajor banking
legislation passed in late 1991 (FDICIA) moves toward
greater market discipline in several respects but also
adds stringent regulations that seem, in some instances,
overly intrusive and costly. Im portantly, because the legisla­
tion contains action on so m any fronts, it will be difficult
to attain an unam biguous reading on the effectiveness of
m arket discipline.
We believe that an emphasis on m arket discipline in
future banking policy and legislation will help restore a bal­
ance to banking that is in the best interests o f the industry,
regulators, bank custom ers and taxpayers.

Gary H. Stern
President

1

Granted that safety and
soundness and limited
taxpayer exposure are both
legitimate objectives, is the
balance between them proper
or have we gone too far in
assuring stability, at the
expense of the taxpayer?







Banking’s Middle Ground:
Balancing Excessive Regulation
and Taxpayer Risk

M ost o f us would agree that a safe and sound banking system is a high priority.
Similarly, m any would favor a system in which the taxpayer is not unduly
exposed to the costs o f resolving mishaps in banking. A nd m ost would prefer
an efficient industry that serves its custom ers well.
Unfortunately, agreem ent on these broad objectives does not provide
m uch assistance in addressing some o f the issues affecting banking. The devil,
or in this case the substance, really is in the detail. Prom otion of a m ore efficient
banking system better able to m eet the needs o f its custom ers suggests further
deregulation and, m any bankers argue, greater flexibility in offering products
and services. But does such a step make sense in view o f concerns about system
stability and taxpayer exposure?
Put another way, w hat other policy changes are required if further deregu­
lation is to occur? G ranted that safety and soundness and lim ited taxpayer expo­
sure are b oth legitimate objectives, is the balance between them proper or have
we gone too far in assuring stability, at the expense o f the taxpayer? If so, how do
we best rem edy the situation?
There are no simple answers to these questions; indeed, there are m eritori­
ous b u t com peting objectives for banking that m ust be carefully balanced in for­
m ulating public policy. Proposals that simply advocate one issue— the advan­
tages o f deregulation or the need for an extensive safety net— implicitly favor
one objective over others and in so doing may result in a financial system that is
n o t only far from optim al bu t less satisfactory than the one we have today.

Deregulate Banking?
O ne m ajor policy objective is to prom ote efficient banking so that bank cus­
tom ers are well-served. If this were the only objective, the appropriate recom ­
m endation would be to remove the bulk o f the regulatory apparatus restraining

3

banks, freeing them to com pete on the basis o f product, service, location, and
price, as do private sector firms generally Freedom o f m anagem ent to decide
which products and services to offer, how to price them , and where to locate
geographically is central to assuring that the custom er is well-served. In general,
bankers will be better at identifying opportunities and taking advantage o f them
than regulators, and the public will benefit to the extent they do so. However,
bank m anagem ent is now precluded to varying degrees from m aking these judg­
m ents, and thus it is virtually certain that custom ers would gain from further
deregulation o f the industry.
However, these benefits may only be m arginal because banks, after all, are
only one o f a plethora o f providers o f financial services, a group that includes,
am ong others, insurance com panies, investm ent banks and brokerage firms,
finance companies, credit unions, pension funds, and a range o f foreign institu­
tions. In general, com petition is fierce, both w ithin banking and from non-bank
financial services firms encroaching on banks’ traditional turf. W hatever this
com petition may m ean for banks, it is clear that custom ers already have a wide
range o f options when seeking financial services.
Heightened com petition is undoubtedly changing the face o f banking and

Even if the banking industry
shrinks considerably at some
point, it is far from clear that
policymakers should be
alarmed by this outcome.
Public policy should focus on,
among other things, the
interests of customers of
financial services firms,
and not on the well-being of a
particular class of institution.

is som etim es cited as an im portant reason to deregulate the industry. There has
been a tendency in recent years to depict banking as an industry in decline,
unable and perhaps unwilling to com pete effectively in lending to m any o f its
traditional business customers. Deregulation is viewed by some as central to the
industry’s survival.
To be sure, there are balance sheet data which suggest that commercial
banks have lost an appreciable am ount o f m arket share. But other evidence leads
to a different conclusion. Banks’ off-balance sheet activities have increased con­
siderably, as the volum e o f asset securitization has expanded and as banks have
stepped up participation in the swap markets, issued standby letters o f credit,
and so on. The growing im portance o f these activities implies that balance
sheets are at best an im perfect and increasingly unreliable indicator o f the role of
banks in financial transactions and in the econom y generally. Sector data from
the gross dom estic product accounts tell a similar story, since they indicate that
banking has grown m ore rapidly than the econom y as a whole over the past 40
years. Finally, bank capital positions and earnings recently have been im proving
markedly, and it is interesting to note that som e o f the m ost successful institu­
tions have concentrated on traditional banking businesses.

4



In general, competition is
fierce, both within banking
and from non-bank financial
services firms encroaching
on banks’ traditional turf.
Whatever this competition
may mean for banks, it is
clear that customers already
have a wide range of options
when seeking financial
services.

CHECKING

S A V I N G S f.CCOUH'!
CMSCKIHG M C d |
H O M E ? M A R K E T l.Ct
loan app_r°v;

CAK LOANS
MORTGAGE LOANS
HOME S iQ ijlT V W X S J f




5

Even if the banking industry shrinks considerably at som e point, it is far
from clear that policymakers should be alarm ed by this outcom e. Public policy
should focus on, am ong other things, the interests o f custom ers o f financial
services firms, and n o t on the well-being o f a particular class o f institution. It
would be foolhardy to argue that banking should be preserved in its current
form if other institutions or m arkets perform banking functions as well or
better. Even if th at were n o t the case, the costs o f any such preservation effort
would have to be evaluated.
Irrespective o f the strength o f the case for deregulation, such action
would conflict w ith other objectives for banking, nam ely concerns for a safe and
sound banking system and limits on taxpayer exposure as a result o f disruptions
in banking. Since it is not clear at this tim e that these two objectives have been
adequately addressed, it would be prem ature, in our opinion, to grant banks
additional powers and perm it them to engage in new activities. Deregulation

Irrespective of the strength
of the case for deregulation,
such action would conflict
with other objectives for
banking, namely concerns
for a safe and sound banking
system and limits on taxpayer
exposure as a result of
disruptions in banking.

should await conclusive evidence that it will not unduly com prom ise these other
goals and, as discussed below, given the proliferation o f new regulations, it may
well be very difficult to develop such evidence.
As an alternative to deregulation, consolidation o f the banking industry
has at times been pushed on the grounds that it leads to gains in efficiency or
m ore-than-proportional cost savings and that these results, in turn, will be
passed to custom ers in the form o f better service. This conclusion is doubtful,
to p u t it mildly, because the evidence o f m any studies simply does not support
the position that there are m eaningful economies o f scale in banking once an
organization attains a fairly m odest size.
From a narrow perspective, it is not o f any great m om ent if there are,
or are not, significant economies o f scale in banking. Larger institutions will
either com pete effectively or they will not, and m anagem ent and shareholders
will benefit accordingly But if mergers are approved by the regulatory agencies
on the presum ption o f appreciable gains in efficiency, which at least in p art will
be passed on to custom ers, and this presum ption is in fact in error, then public
policy has a stake in this issue, a stake that ought to p u t the burden o f p ro o f on
those who assert that considerable operational efficiencies are gained through
com binations o f sizable banking firms.
Indeed, m uch of the com m entary surrounding the topic o f consolidation
in banking is confused, and largely beside the point from a public policy p er­
spective. There, the principal issue remains antitrust, which is intended to get
directly to the heart o f service to customers. Will there be adequate com petition

6



after consolidation so that custom ers are well-served? W hen regulatory approval
is required, the agencies involved have the responsibility to assure that adequate
com petition will be sustained. Given the num b er and diversity o f financial ser­
vices firm s in the country, it is hard to see consolidation proceeding so far and so
fast as to appreciably alter the com petitive landscape at the national level. Local
m arkets m ay be considerably different, though, and there is reason to be con­
cerned th at som e custom ers— small and m id-size businesses and consum ers, for
example— may be disadvantaged from “in-m arket” consolidation in particular.
W here an titrust concerns are n o t an issue, there would seem to be no poli­
cy reason to oppose consolidation. Unfortunately, however, w ith all o f the state
an d federal regulation in place, it is virtually impossible to get a reading on the
scope and pace o f consolidation consistent w ith m arket forces, so policymakers
are w ithout this guidance. Indeed, the situation m ay be worse if consolidation is
propelled by considerations that size confers higher m anagem ent com pensation,
continuing institutional independence, and the advantages o f the “too big to
fail” um brella. To the extent that these or sim ilar considerations go unrecog­

Much of the commentary
surrounding the topic of
consolidation in banking is
confused, and largely beside
the point from a public policy
perspective. There, the
principal issue remains
antitrust, which is intended
to get directly to the heart of
service to customers.

nized, regulators m ay encourage consolidation, thinking it a desirable response
to m arket forces.

Banking Stability and Taxpayer Exposure
A second m ajor policy objective, and one whose im plications at times conflict
w ith those o f the prom otion o f efficient banking, is to assure a safe and sound
banking industry. Com m ercial banks are special institutions in that they offer
dem and deposits— accounts whose balances are payable on dem and at par—
which form the basis o f b oth the electronic and paper-based paym ents system.
Because o f these deposits’ characteristics, banks cannot perfectly and profitably
m aturity m atch such liabilities on the asset side o f their balance sheets, and thus
banks can be subject to severe bouts o f instability, to depositor runs. D eposit
insurance is clearly central to containing such instability, for it assures the p re­
ponderance o f depositors that their funds are secure should the institution fail.
Federal Reserve discount w indow lending, for either short-term liquidity
purposes or to help resolve longer-term problem situations, constitutes the
second critical elem ent o f the safety net in place to prom ote stability.
W hile there is little question that a safety net underpinning banking is
desirable, once one is in place bank activities m ust be regulated and supervised
to at least som e extent in order to offset the “m oral hazard” problem . T hat is,
w ith protection afforded by the safety net o f deposit insurance and the discount




7

As the financial experience
of the 1980s forcefully
demonstrates, a broad
safety net not balanced by
adequate depositor discipline
and effective supervision is
costly to the taxpayer.




window, depositors have little incentive to m onitor the caliber o f the institutions
w ith which they do business. Due to this lack o f depositor discipline, risk taking
is priced too low in banking, and therefore too m uch risk is systematically
assum ed. By taking greater risk, banks potentially earn higher returns and, given
the safety net, if the strategy fails m uch o f the cost m aybe borne by the taxpayer.
As the financial experience o f the 1980s forcefully dem onstrates, a broad
safety net n o t balanced by adequate depositor discipline and effective supervi­
sion is costly to the taxpayer. W itness the cost o f honoring deposit insurance
com m itm ents in the savings and loan industry. W hile problems in banking were
n o t as severe, the industry hardly distinguished itself. W ith hindsight, it is clear
th at a large n um ber o f federally insured institutions took excessive risk in deal­
ings w ith developing countries; in lending to the energy, agricultural, and
com m ercial and residential real estate industries; in support o f highly leveraged
transactions and through inordinate interest rate risk.
In light o f this experience, there is a com pelling case to reexamine the safe­
ty net and the resulting exposure o f the taxpayer. To guarantee a stable banking
system, 100 percent deposit insurance m ight be the answer, but protection o f the
taxpayer w ould require a regulatory apparatus that could be very expensive and
perhaps infeasible. Banks m ight simply be unable to compete if regulations were
too restrictive. Even m ore im portant, it is far from certain that supervision and
regulation, no m atter how intense, can fully replace m arket discipline as a m eans
o f influencing safe and sound banking. We need to find ways to restore balance
between these objectives.
This is hardly an original observation. Congress recognized that taxpayer
exposure had risen to indefensible levels and, late in 1991, passed the Federal
Deposit Insurance Corp. Im provem ent Act (FDICIA). Although flawed, this
legislation, in o u r opinion, is in som e ways a good deal better than is generally
acknowledged. At least implicitly, it recognizes that further deregulation o f
banking is ill-advised until the issues o f risk taking and taxpayer exposure are
addressed. And FDICIA attem pts to control bank risk taking, and thereby to
reduce taxpayer exposure, through b oth extended and more stringent supervi­
sion and regulation and increased reliance on m arket or marketlike discipline,
which narrow s the scope o f the safety net.
FDICIA requires, for example, risk-sensitive deposit insurance prem ium s,
limits on discount w indow lending to troubled institutions, inter-bank credit
limits, and constraints on brokered deposits. M ost significantly, it substantially
reduces deposit insurance coverage relative to recent practice. U nder FDICIA,




9




It is far from certain that
supervision and regulation,
no matter how intense, can
fully replace market discipline
as a means of influencing
safe and sound banking. We
need to find ways to restore
balance between these
objectives.

w ith only very lim ited potential exceptions, deposits over $100,000 are com ­
pletely uninsured, and an individual’s ability to m aintain m ultiple insured
accounts at any one institution is restricted. The FDIC is a good deal m ore
constrained in extending insurance coverage than it recently has been, as is the
Federal Reserve constrained in its provision o f discount window credit.
Im plem ented as intended, this legislation should go some meaningful distance
to achieve the greater degree o f m arket discipline essential to reduce m oral
hazard in banking, which in tu rn should lead to decreased risk taking, healthier
institutions, and less taxpayer exposure.
O ne reservation about this aspect o f FDICIA centers on the issue o f too big
to fail, the practice o f protecting all depositors, including the uninsured, o f large
banks for reasons o f systemic instability. Although FDICIA has provisions to
discourage the FDIC and the Federal Reserve from treating a bank as too big to
fail, there is still the latitude to do so. To the extent that too big to fail persists, or
m arket participants believe that it does, the largest banks will not be subject to
adequate m arket discipline. To the extent this is true, such banks ought to be
subject to m ore stringent supervision and regulation than others, if taxpayer
exposure is to be limited.
The intensified supervision and regulation o f FDICIA takes several forms.
It emphasizes the adequacy o f bank capital, lim iting significantly the activities
and opportunities o f undercapitalized institutions and calling for prom pt super­

One troubling aspect about
this side of FDICIA is the way
in which it changes the role
of the regulator. On the one
hand, it sharply curtails the
discretion available to
regulatory authorities in
addressing supervisory
problems while, on the other,
in some cases it almost
substitutes the regulator for
bank management.

visory intervention in the case o f weak banks. FDICIA also requires regulators to
prescribe operational and m anagerial standards, allows regulators to impose
limits on executive com pensation, requires outside audits, and imposes addi­
tional limits on loans to insiders. In some instances, these provisions appear
intrusive and costly relative to the potential benefits that m ight be achieved in
term s o f safety and soundness.
O ne troubling aspect about this side o f FDICIA is the way in which it
changes the role o f the regulator. O n the one hand, it sharply curtails the discre­
tion available to regulatory authorities in addressing supervisory problem s
while, on the other, in some cases it alm ost substitutes the regulator for bank
m anagem ent. There is not only a broad array o f new regulations under FDICIA,
b u t also considerably less discretion perm itted in the application o f regulations
to particular facts and circumstances. The premise, apparently em bodied in
FDICIA, that “cookbook” supervision and regulation is essential to lim it the
cost o f m oral hazard to the taxpayer is questionable. Indeed, its effect may be
perverse. The “one size fits all” approach that the regulatory agencies have taken




11

12



to im plem ent FDICIA’s capital-based pro m p t corrective action fram ework
seriously reduces its relevance for the vast m ajority o f banks.
Another im portant problem w ith FDICIA is that it gives little if any weight
to the objective o f enhanced efficiency and custom er service. Indeed, FDICIA
threatens to com prom ise this objective by curtailing m anagem ent’s latitude to
make business decisions. To the extent this happens, custom ers will not be as
well-served by banks as they could be. Moreover, while FDICIA’s constraints on
the safety net are a positive step, it will be difficult to judge the effectiveness o f
those constraints because they are coupled w ith tightened regulatory require­
m ents and are im plem ented (approximately) simultaneously. Thus, we will not
know when and if it is safe to deregulate, because we will not have a clear reading
on the consequences o f increased m arket discipline for stability and for taxpayer
exposure.

Conclusion
We have to acknowledge at the outset that w ithin banking policy are a num ber
o f legitimate but com peting objectives. The appropriate course is n o t to declare
one objective preem inent and pursue it single-mindedly. D epending on the
objective selected, we could have a highly regulated banking system unable to
m eet the needs o f its custom ers effectively, or an increasingly risk-prone system
that could prove expensive to the taxpayer. The responsibility o f public policy is
to appropriately order and balance these objectives so that progress can ulti­
mately be m ade on all fronts. This strategy would suggest, in our judgm ent,
dealing first with the scope o f the safety net and the issue o f taxpayer exposure.
After these issues are resolved, policy can move to the question o f banking
deregulation.
We are convinced that it would be ill-advised to grant banks expanded
powers before we are sure the incentives are corrected that encourage excessive
risk taking. FDICIA makes a start in this direction, b u t unfortunately its m ulti­
tude o f provisions will m ake it difficult to determ ine if and when deregulation is
appropriate. In giving short shrift to the objective o f efficiency and custom er ser­
vice, FDICIA does not represent the balanced approach we believe appropriate.
Future policy, and subsequent legislation, should restore balance by m ore specif­
ically emphasizing m arket discipline and by rem oving regulations that unduly
lim it m anagem ent latitude for norm al business decisions and that m ake the job
o f the regulator overly intrusive.




Future policy, and subsequent
legislation, should restore
balance by more specifically
emphasizing market
discipline and by removing
regulations that unduly limit
management latitude for
normal business decisions
and that make the job of the
regulator overly intrusive.

13

Federal Reserve Bank of Minneapolis

14



Statement Of Condition (in thousands)

December 31,
1992

December 31,
1991

$195,000
186,000
15,746
1,400

$171,000
172,000
13,688
0

84,354
4,597,670

78,144
3,445,178

414,847

544,358

42,374
565,807
110,165
2,554,661

44,161
781,816
64,696
2,640,173

$8,768,024

$7,955,214

7,458,324

6,690,635

721,109
3,656
5,374

653,413
4,245
37,620

730,139

695,278

Deferred Credit Items
Other Liabilities

390,367
29,256

398,577
31,072

Total Liabilities

8,608,086

7,815,562

79,969
79,969

69,826
69,826

159,938

139,652

$8,768,024

$7,955,214

Assets

Gold Certificate Account
Special Drawing Rights
Coin
Loans to Depository Institutions
Securities:
Federal Agency Obligations
U.S. Government Securities
Cash Items in Process of Collection
Bank Premises and Equipment
Less Depreciation of $39,475 and $34,525
Foreign Currencies
Other Assets
Interdistrict Settlement Fund
Total Assets
Liabilities

Federal Reserve Notes1
Deposits:
Depository Institutions
Foreign, Official Accounts
Other Deposits
Total Deposits

Capital Accounts

Capital Paid In
Surplus
Total Capital Accounts
Total Liabilities and Capital Accounts

1 Amount is net o f notes held by the Bank o f $733 million in 1992 and $1,427 million in 1991.




Earnings and Expenses (in thousands)

For the Year Ended December 31,

1992

1991

$255,108
56,066
1,301
40,733
449

$266,252
71,102
3,395
39,930
426

353,657

381,105

37,950
8,560
2,266
5,738
458
2,074
2,161

35,230
8,188
2,009
5,880
492
1,787
2,189

923
1,244
939
1,167

1,004
1,298
886
1,396

687
5,108
2,673
4,131
429
1,752

1,113
5,828
2,773
5,165
2,014
1,305

78,260

78,557

(4,899)

(1,798)

73,361

76,759

280,296

304,346

(26,635)

13,769

3,431
6,643
4,682
228,762

2,963
3,836
4,146
305,855

10,143

1,315

69,826
10,143

68,511
1,315

$79,969

$69,826

Current Earnings

Interest on U.S. Government Securities and
Federal Agency Obligations
Interest on Foreign Currency Investments
Interest on Loans to Depository Institutions
Revenue from Priced Services
All Other Earnings
Total Current Earnings
Current Expenses

Salaries and Other Personnel Expenses
Retirement and Other Benefits
Travel
Postage and Shipping
Communications
Software
Materials and Supplies
Building Expenses:
Real Estate Taxes
Depreciation—Bank Premises
Utilities
Rent and Other Building Expenses
Furniture and Operating Equipment:
Rentals
Depreciation and Miscellaneous Purchases
Repairs and Maintenance
Cost of Earnings Credits
Net Costs Distributed/Received from Other FR Banks
Other Operating Expenses
Total Current Expenses
Reimbursed Expenses 1
Net Expenses
Current Net Earnings
Net (Deductions) or Additions2
Less:
Assessment by Board of Governors:
Board Expenditures
Federal Reserve Currency Costs
Dividends Paid
Payments to U.S. Treasury
Transferred to surplus
Surplus Account

Surplus, January 1
Transferred to Surplus— above
as
Surplus, December 31

1 Reimbursements due from the U.S. Treasury and other Federal agencies;
$1,958 was unreimbursed in 1992 and $3,993 in 1991.
2 This item consists mainly of unrealized net gains or (losses) related to revaluation
of assets denominated in foreign currencies to market rates.

Directors

Federal Reserve Bank of Minneapolis

December 31, 1992

Delbert W. Johnson
Chairman and Federal Reserve Agent

Class C Appointed by the Board of Governors

Helena Branch

Gerald A. Rauenhorst
Deputy Chairman

Delbert W. Johnson
President and Chief Executive Officer
Pioneer Metal Finishing
Minneapolis, Minnesota

J. Frank Gardner
Chairman

Class A Elected by Member Banks
Rodney W. Fouberg
Chairman
Farmers & Merchants Bank & Trust Co.
Aberdeen, South Dakota
Charles L. Seaman
President and Chief Executive Officer
First State Bank of Warner
Warner, South Dakota
William W. Strausburg
Chairman and Chief Executive Officer
First Bank Montana, N.A.
Billings, Montana

Class B Elected by Member Banks
Bruce C. Adams
Partner
Triple Adams Farms
Minot, North Dakota
Duane E. Dingmann
President
Trubilt Auto Body, Inc.
Eau Claire, Wisconsin
Earl R. St. John, Jr.
President
St. John Forest Products, Inc.
Spalding, Michigan

16



Jean D. Kinsey
Professor of Consumption and
Consumer Economics
University of Minnesota
St. Paul, Minnesota
Gerald A. Rauenhorst
Chairman and Chief Executive Officer
Opus Corporation
Minneapolis, Minnesota

Federal Advisory Council Member
John F. Grundhofer
Chairman, President and Chief Executive
Officer
First Bank System, Inc.
Minneapolis, Minnesota

James E. Jenks
Vice Chairman

Appointed by the Board of Governors
J. Frank Gardner
President
Montana Resources, Inc.
Butte, Montana
James E. Jenks
President
Jenks Farms
Hogeland, Montana

Appointed by the Board of Directors
Federal Reserve Bank of Minneapolis
Beverly D. Harris
President
Empire Federal Savings and Loan
Association
Livingston, Montana
Donald E. Olsson, Jr.
Executive Vice President
Ronan State Bank
Ronan, Montana
Nancy McLeod Stephenson
Executive Director
Neighborhood Housing Services
Great Falls, Montana

Officers

Federal Reserve Bank of Minneapolis

December 31, 1992

Gary H. Stern
President

John H. Boyd
Senior Research Officer

S. Rao Aiyagari
Research Officer

Kent C. Austinson
Supervision Officer

Thomas E. Gainor
First Vice President

Kathleen J. Erickson
Vice President

Robert C. Brandt
Assistant Vice President

Marvin L. Knoff
Supervision Officer

Phil C. Gerber
Vice President

Marilyn L. Brown
Assistant General Auditor

Robert E. Teetshorn
Supervision Officer

Caryl W. Hayward
Vice President

James T. Deusterhoff
Assistant Vice President

Ronald O. Hostad
Vice President

Richard K. Einan
Assistant Vice President and
Community Affairs Officer

Sheldon L. Azine
Senior Vice President
Melvin L. Burstein
Senior Vice President
and General Counsel
Leonard W. Fernelius
Senior Vice President
Ronald E. Kaatz
Senior Vice President
Arthur J. Rolnick
Senior Vice President and
Director of Research
Colleen K. Strand
Senior Vice President and
Chief Financial Officer




Bruce H. Johnson
Vice President
Thomas E. Kleinschmit
Vice President
Richard L. Kuxhausen
Vice President
David Levy
Vice President and
Director of Public Affairs
and Corporate Secretary
James M. Lyon
Vice President
Susan J. Manchester
Vice President
Preston J. Miller
Vice President and
Monetary Advisor
Susan K. Rossbach
Vice President and
Deputy General Counsel
Charles L. Shromoff
General Auditor
Thomas M. Supel
Vice President
Theodore E. Umhoefer, Jr.
Vice President

Jean C. Garrick
Assistant Vice President
Peter J. Gavin
Assistant Vice President
Karen L. Grandstrand
Assistant Vice President

Helena Branch

John D. Johnson
Vice President and Branch Manager
Samuel H. Gane
Assistant Vice President and
Assistant Branch Manager

James H. Hammill
Assistant Vice President
William B. Holm
Assistant Vice President
H. Fay Peters
Assistant Vice President and
Assistant General Counsel
Richard W. Puttin
Assistant Vice President
Claudia S. Swendseid
Assistant Vice President
Kenneth C. Theisen
Assistant Vice President
Thomas H. Turner
Assistant Vice President
Mildred F. Williams
Assistant Vice President
William G. Wurster
Assistant Vice President

Warren E. Weber
Senior Research Officer

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