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ESSAYS ON ISSUES

THE FEDERAL RESERVE BANK
OF CHICAGO

MAY 2007
NUMBER 238

Chicago Fed Letter
The branch banking boom in Illinois: A byproduct of restrictive
branching laws
by Tara Rice, financial economist, and Erin Davis, equity analyst, Morningstar Inc.

What’s behind the boom in bank branches across Illinois, particularly in Chicago? The
authors explore the history of branch banking within the state and across the nation to
help explain this recent trend and discuss its future implications.

Bank branches, like coffee shops, have be-

come a ubiquitous part of the American
landscape. In Chicago’s commercial
banking district, twelve banking offices
now dot LaSalle Street between the
Chicago River and the Chicago Fed,
more than double the five coffee shops
along this half-mile stretch.1

As of June 30, 2006, Illinois
boasted 4,349 bank branches,
66% more than in 1994.
This statewide growth is
extraordinary; the number of
branches nationwide grew just
23% between 1994 and 2006.

As of June 30, 2006, Illinois boasted 4,349
banking offices, two-thirds more than
in 1994.2 This aggregate state growth
is unusual, since the number of banking offices nationwide grew only 23%
between 1994 and 2006. Politicians
in Illinois have begun to take notice.
The City of Chicago amended Chapter
17-3-0504-I of its zoning code in 2004
to require banks to apply for special use
permits to build new banking offices
in certain areas, and several Chicago
suburbs have enacted similar restrictions. In this Chicago Fed Letter, we explore the reasons behind the recent
bank branching boom and discuss
its implications.
The history of branch banking in Illinois

In large part, the current trend in banking office growth is a product of Illinois’
banking history. Restrictive bank branching laws in Illinois suppressed expansion
for decades. With the relaxation of these
restrictions, the number of banking offices has increased sharply in the last
dozen years or so.

The state of Illinois was one of the most
restrictive bank branching states in the
country. It was what is known as a “unit
banking” state in which each bank was
allowed to operate only one office.3 The
state constitution of 1870 prohibited
branch banking, and that prohibition
remained in place until the mid-1960s.
The first revision, adopted in 1967, allowed a bank to operate one additional
drive-up facility within 1,500 feet of the
unit bank. By 1985 banks were allowed
to have up to five offices, two of which
could be in other counties if they were located no more than ten miles from the
head office. Finally, in 1993, the limitations on interstate branching were completely removed; for the first time Illinois
banks were allowed to branch freely within
the state. These laws applied both to national banks chartered by the federal government and to state banks chartered by
the individual state regulatory agencies.4
Until 1994, federal law prohibited bank
branching across state lines. The Riegle–
Neal Interstate Banking and Branching
Efficiency Act (IBBEA) removed these
restrictions when enacted in 1994. IBBEA
allowed states to opt in to interstate
branching and, if they chose to do so,
determine how restrictive statewide provisions on interstate branching could
be. Illinois opted in to IBBEA in 1997
and, as of 2004, allows nearly unrestricted interstate branching.

1. Banks and banking offices in Illinois, 1935–2006
4,500
4,000
3,500
3,000
2,500
2,000

banking
offices

1,500

concentration of its
banking markets.
In 2006, Illinois was
less concentrated
than 42 states, while
Chicago was the
sixth least concentrated metropolitan
area out of 369 metropolitan areas in
the U.S.

1,000

Figure 1 shows the
change in the total
0
number of banks ver1935 ’40 ’45 ’50 ’55 ’60 ’65 ’70 ’75 ’80 ’85 ’90 ’95 2000 ’05
sus the total number
NOTES: Vertical lines represent years of branch banking deregulation. Banking
of banking offices
offices include both main offices (banks) plus “other” offices (branches) of state
and national banks.
from 1935 through
S OURCES: Authors’ calculations based on data from the Federal Deposit Insurance
Corporation and Federal Reserve System.
2006; the vertical
lines represent major
regulatory changes
The explosion of bank branches
in Illinois. The total number of banks
was fairly constant until 1967, and nearIn addition to suppressing banking
ly all of these were unit banks. Banks
office growth, Illinois’ once restrictive
were able to expand their branch netbranching environment also protected
works, to a limited extent, by acquiring
small banks, allowing a relatively large
existing banks. As banks merged, the
number of them to operate in the state.
number of banks operating in Illinois
In 1994, Illinois had 994 banks (0.84
grew more slowly and, after 1980, began
banks per 10,000 residents) with an
to fall. In 1988, legal changes steepened
average of $296 million in assets (in
this decline; Illinois began to allow bank
2006 dollars). Nationwide (excluding
Illinois), each state had on average 207 holding companies with more than one
bank to merge their banks without giving
banks (0.60 banks per 10,000 residents)
up any of the branches.
with $671 million in assets (in 2006 dollars). Today, though there are fewer
Figure 1 also highlights the banking
banks nationwide, Illinois is still home office growth. When intrastate branchto more small banks than other states,
ing restrictions were relaxed, branch
on average. As of June 2006, Illinois
expansion boomed. Many institutions
had 650 banks (0.54 banks per 10,000
began to compete for market share, as
residents) with $545 million in assets,
larger out-of-state banks began acquirwhile other states had on average 145
ing and building banking office netbanks (0.43 banks per 10,000 residents)
works in Illinois and existing Illinois
with $1,858 million in assets.
banks opened additional banking ofbanks

500

Because this environment allowed many
small banks to exist, Illinois’ banking
markets were among the least concentrated in the country (measured at both
the city level and state level), and this
trend continues today. Using a common measure of market concentration, Illinois was less concentrated than
47 states in 1994.5 Back then, Chicago
was the third least concentrated metropolitan area out of 369 metropolitan
areas in the U.S. Interestingly, the relaxation of branching restrictions in
Illinois did not significantly change the

fices.6 The combination of large outof-state banks and small Illinois banks
fueled the banking office growth, which
appears more dramatic when compared with national averages. In 1967,
each state in the U.S. had on average
1.86 banking offices per 10,000 residents, while Illinois had only 0.99. Only
one state (Florida) had fewer banking
offices per capita. By 1994, Illinois had
2.20 banking offices per 10,000 residents.
This rose to 3.39 banking offices per
10,000 residents by 2006, surpassing
the national average of 3.21.

These two observations—that Illinois’
banking markets are relatively unconcentrated and that Illinois has experienced
higher branch growth—are related.
Figure 2 shows this pattern: The trend
line illustrates a negative relationship
between branch growth and market
concentration. This figure plots the
percentage growth in banking offices
with our measure of market concentration for the largest 15 cities. Chicago is
located in the top left-hand corner of
the figure, above the line; of these 15
cities, it has experienced the highest
branch growth and remains the most
competitive market. Interestingly, five
of the seven cities plotted above the trend
line are located in states that were once
unit banking states.
The political economy of bank
branching

There are a number of reasons why
Illinois and many other states enacted
restrictive branching regulations. One
objective was to limit the power of banks
by constraining their size. Opponents
of branch banking thought that if banks
became too large they would exert excessive political and economic influence.7
Residents were concerned that if big
banks were allowed to branch into small
towns, they would siphon deposits out
of these towns and use them to make
loans to larger clients in financial centers.8 As a result, small businesses and
local communities would be without the
capital they needed to thrive. Branching
restrictions were also intended to make
banking safer by shielding banks from
excessive competition9 and to protect
and enhance state banking regulation
fees, which made up a large percentage
of many states’ revenues.10
The banks that were the beneficiaries
of these regulations were naturally strong
supporters of branching restrictions.
Bankers in small towns, in particular,
lobbied effectively against branch banking, motivated in part by their desire to
insulate themselves from competition
by larger out-of-state banks.11
Experience has shown that branch banking did not merit many of these early
concerns. When states introduced statewide branching, banks’ loan losses and

2. Market concentration and branch growth in largest 15 cities, 1995–2006
percent of branch growth per 10,000 residents

100
80

• Chicago, IL

60
40
20
0
–20

Dallas, TX
•
• Houston, TX

San Antonio, TX
•

• Detroit, MI
Jacksonville, FL
Philadelphia, PA
•
• • San Jose, CA •
• San Francisco, CA
•
•
•
New York, NY
Los Angeles, CA Indianapolis, IN •
Phoenix, AZ
San Diego, CA

Columbus, OH
•

–40
0
500
more competitive

1,000

1,500

2,000

2,500

3,000

3,500
4,000
less competitive

market concentration (average HHI)
NOTES: Concentrations are measured using the Herfindahl-Hirschman Index (HHI). For further details, see
www.usdoj.gov/atr/public/testimony/hhi.htm. The HHI increases, indicating higher concentration (or less competition),
both as the number of firms in the market decreases and as the disparity in size between those firms increases.
SOURCES: Authors’ calculations based on data from the Federal Deposit Insurance Corporation and Federal Reserve System.

noninterest expenses decreased significantly, and these savings were largely
passed along to consumers in the form
of lower loan rates.12 Branching has
been shown also to increase the stability
of the banking system by reducing bank
failures through diversifying banks’ customer base and increasing competition,
forcing less efficient banks to exit.13
Deregulation: What changed?

The preceding discussion highlights how
regulation of bank branching involved
competition among several parties.
Disparate interests among the various
parties provided an environment that
allowed continuance of branching restrictions as barriers to entry, meant to
protect the competitive position of small
banks. These restrictions did, for a while,
enhance small banks’ profits. However,
a number of events undermined the
value of supporting these restrictions
on branching.14 Lobbies for small banks
in Illinois had the political clout for many
years to defeat attempts to liberalize the
state’s branching laws.15 Significant
changes to the branching laws finally
surfaced in the 1980s when the benefits
of local monopolies were being challenged by technological advances, such
as automatic teller machines (ATMs)
and telephone banking.16 At the same
time, high interest rates and increased

competition from nonbanks made it
more difficult for many banks to maintain profitability. As a result, some faltering banks desired to merge with larger
banks but were unable to do so because
of branching restrictions.17 As technological and economic factors threatened
the status quo, the net burden of maintaining regulatory restrictions increased
until one-time opponents began to support liberalization of branching laws.18
One of the most significant changes
to branching laws, however, sprang
from external forces. In 1987, a court
ruling in Mississippi allowed national
banks to branch in Illinois and 20 other
states.19 The ruling did not apply to
state-chartered banks. Illinois politicians
were thus concerned that the state’s
current branching restrictions would
put state-chartered banks at a disadvantage relative to federally chartered banks.
As a result, in 1993, Illinois changed its
laws to allow all banks to branch within
the state without restriction.
Conclusion

Will this expansive branching trend in
Illinois, particularly in Chicago, continue,
or will it fall in line with national branch
growth rates? This question seems appropriate in light of consumers’ rapid
adoption of online banking and electronic payments. Recent contradictory

announcements by Chicago banks give
no clear indication. Several banks plan
to build additional branches in Chicago
in hopes of generating new accounts;
estimates suggest that more than 90%
of new transaction accounts in the U.S.
are opened at physical branches.20
Conversely, the market may be posed
for a slowdown in branch growth, as
several financial institutions announced
plans to close underperforming branches
in the Chicago area.21 As the Illinois
banking market becomes more saturated, banks may decide they can no
longer maintain the current number
of banking offices.
While the future growth of bank branching in Illinois is unclear, there is one
lesson: Though an overarching objective
of the original branching restrictions
was to prevent large out-of-state banks
from competing with smaller banks,
ironically, these restrictions have contributed to a great deal more local competition in the long run.
1

Branch banking is defined as a single legal bank entity operating more than one
banking office. See C. E. Cagle, 1941,
“Branch, chain, and group banking,” in
Banking Studies, Federal Reserve Board,
Baltimore, MD: Waverly Press, p. 113. In
our article, banking offices include both

Michael H. Moskow, President; Charles L. Evans,
Senior Vice President and Director of Research; Douglas
Evanoff, Vice President, financial studies; Jonas Fisher,
Economic Advisor and Team Leader, macroeconomic
policy research; Richard Porter, Vice President, payment
studies; Daniel Sullivan, Vice President, microeconomic
policy research; William Testa, Vice President, regional
programs and Economics Editor; Helen O’D. Koshy,
Kathryn Moran, and Han Y. Choi, Editors; Rita
Molloy and Julia Baker, Production Editors.
Chicago Fed Letter is published monthly by the
Research Department of the Federal Reserve
Bank of Chicago. The views expressed are the
authors’ and are not necessarily those of the
Federal Reserve Bank of Chicago or the Federal
Reserve System.
© 2007 Federal Reserve Bank of Chicago
Chicago Fed Letter articles may be reproduced in
whole or in part, provided the articles are not
reproduced or distributed for commercial gain
and provided the source is appropriately credited.
Prior written permission must be obtained for
any other reproduction, distribution, republication, or creation of derivative works of Chicago Fed
Letter articles. To request permission, please contact
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Letter and other Bank publications are available
on the Bank’s website at www.chicagofed.org.
ISSN 0895-0164

2

3

4

5

6

main offices (banks) plus “other” offices
(branches) of state and national banks.

7

George Kaufman, 1985, “Banking without
the barriers,” Chicago Tribune, January 15.

Branching statistics in this article are calculated by the authors using Federal Deposit
Insurance Corporation (FDIC) data.

8

Eugene Nelson White, 1983, The Regulation
and Reform of the American Banking System,
1900–1929, Princeton, NJ: Princeton
University Press, pp. 196–197.

Unit banking states were: Colorado,
Arkansas, Florida, Illinois, Iowa, Kansas,
Minnesota, Missouri, Montana, Nebraska,
North Dakota, Oklahoma, Texas, Wisconsin,
and West Virginia; see Kevin J. Stiroh and
Philip E. Strahan, 2003, “Competitive dynamics of deregulation: Evidence from
U.S. banking,” Journal of Money, Credit,
and Banking, Vol. 35, No. 5, October,
pp. 801–828.
Bank branching is governed by both federal
and state level laws; laws at either level may
affect branching across state lines (interstate
branching) and/or branching within a
state (intrastate branching). Federal law
allows national banks to branch wherever
state banks are allowed to branch, but does
not grant national banks any additional
branching powers.
Concentration is measured using the
Herfindahl-Hirschman Index (HHI), calculated from Federal Reserve and FDIC bank
data. For further details, see www.usdoj.gov/
atr/public/testimony/hhi.htm.
Steven Reider, president of Bancography
states: “In any market, the bank with the
largest network gains a disproportionate
share of deposits.” See Rob Garver, 2007,
“Why branch growth will maintain its
momentum,” American Banker, January 16.

9

David A. Alhadeff, 1962, “A reconsideration
of restrictions on bank entry,” Quarterly
Journal of Economics, Vol. 76, No. 2, May,
pp. 246–263.

14

Edward J. Kane, 1996, “De jure interstate
banking: Why only now?,” Journal of Money,
Credit, and Banking, Vol. 28, No. 2, May,
pp. 141–161.

15

Bennett (1981); and William R. Bryan,
1975, “To branch or not to branch, an
issue that finds Illinois bankers divided,”
Illinois Issues, December, Vol. 1, No. 12,
pp. 364–366.

16

Kroszner and Strahan (1999).
Note, however, a provision in the 1982
Garn–St Germain Act authorized federal
banking agencies to arrange interstate acquisitions for failed banks with total assets
of $500 million or more.

10

Randall S. Kroszner and Philip E. Strahan,
1999, “What drives deregulation? Economics
and politics of the relaxation of bank branching restrictions,” Quarterly Journal of Economics,
Vol. 114, No. 4, pp. 1437–1467.

17

11

Robert A. Bennett, 1981, “Turnabout by
Chicago banks,” New York Times, August
31, Section D; and Steven Horwitz and
George A. Selgin, 1987, “Interstate banking: The reform that won’t go away,” Policy
Studies, Policy Analysis, Cato Institute,
No. 97, December 15.

18

Kane (1996).

19

Department of Banking and Consumer
Finance v. Clarke, 809 F.2d 266 (5th Cir.)
cert. denied, 483 U.S. 1010 (1987).

20

Hal Hopson, 2006, “De novo branch performance: Portfolios and places,” presentation at BAI Retail Delivery Conference
and Expo, Las Vegas, NV, November 16.

21

Becky Yerak, 2006, “Washington Mutual steps
back,” Chicago Tribune, September 8, p. 3;
Steve Daniels, 2006, “Banks begin to retrench,” Crain’s Chicago Business, December
18; and Becky Yerak, 2007, “Chase plans
growth while others fight cuts,” Chicago
Tribune, February 14.

12

13

Jith Jayaratne and Philip E. Strahan, 1997,
“The benefits of branching deregulation,”
Economic Policy Review, Federal Reserve
Bank of New York, Vol. 3, No. 4, December,
pp. 13–29.
Mark Carlson and Kris James Mitchener,
2005, “Branch banking, bank competition,
and financial stability,” Finance and
Economics Discussion Series, Board of
Governors of the Federal Reserve Board,
working paper, No. 2005-20, March.