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F e d e r a l r e s e r v e B a n k OF DALLAS Dallas, Texas, January 27, 1944 To All Banking Institutions in the Eleventh Federal Reserve District: There is enclosed a copy of a letter, dated January 24, 1944, addressed by the Board of Governors of the Federal Reserve System to the Honorable Robert F. Wagner, Chairman of the Committee on Banking and Currency of the United States Senate. This letter very clearly sets forth the Board’s position with respect to that portion of Section 19 of the Federal Reserve Act which prohibits the payment of interest, directly or indirectly, by any device whatsoever, upon any deposit which is payable on demand. It is felt that the management of your bank would like to have authen tic information with regard to the Board’s position, and it is believed that the enclosed letter will serve to clarify the questions which have arisen since the publication of the Board’s ruling on this subject in the Septem ber, 1943, edition of the Federal Reserve Bulletin. Yours very truly, R. R. GILBERT President This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org) BOARD OF GOVERNORS O F THE FED ER AL R ESER VE S YS TEM WASHINGTON ADDRESS OFFICIAL C O R R E S P O N D E N C E TO THE BOARD January 24, 1944, Honorable Robert F. Wagner, Chairman, Committee on Banking and Currency, United States Senate, Washington, D. C. Dear Senator Wagner: This is in response to the request fo r the opinion o f the Board o f Governors o f the Federal Reserve System as to the merits o f S. 1642, "A B i l l to amend the Federal Reserve Act, as amended, to provide that the absorption o f exchange and c o llectio n charges sh all not be deemed the payment o f interest on d ep osits." The pertinent part o f section 19 o f the Federal Reserve Act, ns amended, which the proposed b i l l would fu rth er amend, now reads as f o llo w s : "No member bank s h a ll, d ire c tly or in d ire c tly , by any device whatsoever, pay any in terest on any de posit which i s payable on demand: * * * " The foregoing prohibition was enacted by the Congress as a Part o f the Banking Act o f 1953. P r io r to 1933 there was no such pro h ib itio n . Widespread abuses had developed in the practice of paying interest on deposits. Many banks, in order to attract accounts from other banks, o ffered and paid excessive rates o f in terest on demand de posits. Accounts o f others, p a rtic u la rly national concerns, w e re .lik e ^ise sought and obtained. The r e s u lt , as concerned correspondent bank Relationships, was, in many cases, an unnatural and unhealthy concen tration in the la rg e r centers o f funds from the sm eller communities ^rithout regard either to geographical or business a f f i li a t i o n between the two points. Moreover, these balances proved to be the most vola t i l e deposits such banks had. When, during the depression, deposits h©elined, the impact o f the demand made by the re a l owners o f the de posits was fe lt by two and sometimes more banks, rather than one. The ^®positor in the sm aller community demanded his balance, and his banker, J-11 order to meet the demand, had to withdraw or to try to withdraw his balance from h is correspondent bank in the la rg e r center. Meanwhile the banks in the la rg e r centers were also receiving lik e demands from th e ir individual customers. National and other accounts, obtained by the BOARD OF GOVERNORS OF THE Honorable Robert F. Wagner, Chairman FEDERAL RESERVE SYSTEM -2 - inducement o f high rates o f in te re st, were being brought closer home and "smart money" was the f i r s t to go. One has only to remember the experiences in D etroit, Cleveland, Baltimore, New Orleans, and many other la rg e centers to re c a ll what happened to many o f the sm aller banks and would have happened to more but fo r the intervention of the Banking Holiday and the measures which follow ed. These are the reasons, as understood by the Board, fo r the enactment of the le g is la t io n and the Board believes any relaxation o f the statute would be a step backward and not in the public in te re st. The proposal in S. 1642 and in the companion b i l l in the House o f Representatives, H.R. 3956, would re la x the existing statutory prohibition to the extent that exchange or co llectio n charges might be absorbed by a member bank as an inducement to a depositor, bank or other wise, to maintain an account with i t . Senator Maybank, in introducing the b i l l in the Senate, stated: "The substance o f the b i l l is to prohibit the Federal Reserve from interpretin g a law to the e ffe c t that small, banks are unable to charge exchange and la rg e r banks are unable to absorb the country*s banking exchange." The Board hastens again to state that i t has not interpreted section 19 o f the Federal Reserve Act (which is the statute in question) to the e ffe c t that small banks are unable to charge exchange. At the request o f the Comptroller o f the Currency i t has in terpreted section 19 in i t s application to the fa c ts o f a s p e c ific case and, under such fa c ts, expressed the view that the bank in question was v io la tin g the statute and the Board* s Regulation Q. This ru lin g was pub lish ed in the September 1943 issue of the Federal Reserve B u lle tin . The Board understands that the bank in question amended i t s practices in respect to the subject matter o f the ru lin g . I t also understands that other banks, reviewing th e ir p ractices in the lig h t of the ru lin g , have likew ise amended th e ir practices, and th is no doubt accounts fo r the pro posal that the statute be amended to le g a liz e the practice. The September 1943 ru lin g has been discussed in informal hear ings before the Committee on Banking and Currency in the House o f Repre sentatives. I t i s appropriate, however, to acquaint a l l o f the members o f the Committee -with the background of the ru lin g and the p rin c ip le s in volved. In 1935, section 19 o f the Federal Reserve Act was fu rth er amended to authorize the Board "to determine what sh a ll be deemed to be a payment o f in t e r e s t ." But the Board in i t s Regulation Q, has not availed i t s e l f of the power to define as thus authorized. On the contrary, the Board has rested the meaning of the term "in te re s t" squarely upon it s meaning as a matter of general law. The Board*s reasons fo r not exercising the authority given it in 1935 are as fo llo w s. The general question whether the absorption o f BOARD OF GOVERNORS OF THE FEDERAL Honorable Robert F. Wegner, Chairman RESERVE SYSTEM -3 - exchange eharges by a bank fo r a depositor maintaining a compensating balance constituted the payment o f interest has been a controversial one from the beginning. In 1935, the Board amended it s Regulation Q, to include a d e fin itio n of in terest under which the absorption o f ex change and collection charges by a member bank as compensation fo r the maintenance o f a deposit would have been expressly defined as a payment o f interest on such deposit; but the e ffe c tiv e date o f th is amendment was deferred from time to time and the amendment never became e ffe c tiv e . This was la rg e ly because the Federal Deposit Insurance Corporation would not take the same position with respect to the banks i t supervised. The Federal Deposit Insurance Corporation contended f i r s t that the absorp tion o f exchange did not constitute the payment o f interest and secondly that it did not have authority, corresponding to that o f the Board, to define the term "in te re s t” and thus, by d e fin itio n , to extend it s o rd i nary meaning. Always, however, the Federal Deposit Insurance Corporation has emphasized, more than the question whether the practice should be construed as constituting the payment of in terest, the question of the e ffe c t such a construction would have on some 2,500 banks which were charging the exchange being absorbed. F in a lly , in 1937, in order par t i a l l y to solve the dilemma, the Board proposed and the Federal Deposit Insurance Corporation agreed to the adoption o f uniform language in th e ir respective regulation s. Thereupon both regulations were amended to pro vide that f o r the purposes o f the regulations the term "in te re s t” should m®an "any payment to or fo r the account of any depositor as compensation Tor the use o f funds constituting a d ep o sit." By joint announcement i t was made clear that the purpose o f the action was merely to restate prin ciples o f law as decided by the Courts and to provide fo r dealing with each case upon the fa c ts o f that sp e c ific case. The action also had the e ffe c t of elim inating the question o f any differen ce in the respective powers o f the Federal Deposit Insurance Corporation and the Board because i t was also made clear that the intention was not to use any rule-making power to extend the d efin itio n of the term "in te re s t” beyond it s meaning as already declared by the Courts. Since then the Board has adhered to ibe position thus agreed upon and made no rulin g upon the question, either general o r sp e c ific , u n til it was requested to do so by the O ffic e o f the Comptroller of the Currency. On December 6, 1943, the Federal Deposit Insurance Corporation adopted a ru lin g o f general application to insured nonmember banks on ■tbe subject of "Absorption of Exchange Charges as Payment o f In t e r e s t " . This general ru lin g expressed the view "that the absorption o f exchange charges by an insured nonmember bank in connection with it s routine collection fo r i t s depositors o f checks drawn on other banks cannot be considered a payment o f in te re st, within the terms o f the interest regu latio n s o f the Federal Deposit Insurance Corporation, in the absence o f Tacts or circumstances establish in g that the practice is resorted to as a device fo r the payment o f in terest^" BOARD OF GOVERNORS OF THE Honorable Robert F. Wagner, Chairman FEDERAL RESERVE SYSTEM -4 - In the s p e c ific case with which th is Board dealt in i t s September 1943 rulin g the fa c ts were that the bank had absorbed ex change charges fo r customers keeping so -called compensating balances; that in 1942 i t had absorbed fo r such customers $18,000 out o f $25,000 exchange charges paid; that in the f i r s t three months o f 1943 i t had absorbed fo r such customers $4,600 out o f $5,600 exchange charges paid; that in some instances the amount absorbed fo r some customers amounted to as much as 2 or 3 per cent o f t h e ir balances; that i t s t o t a l corre spondent bank deposits had increased from le s s than $7,000,000 at the end of 1941 to nearly $18,000,000 in 1943, a ra tio fa r greater than the increase in i t s to ta l demand deposits or o f the corresponding increases o f other banks in the same area; that exchange charges were not absorbed but were charged back when, because o f a lack o f a compensating balance, the bank had "no way o f making it back"; that, on occasion, the bank had written to i t s correspondent banks suggesting that they par items sent to such banks in return fo r the parring by the subject bank o f items re ceived from such banks; and f i n a lly th at, in at le a s t one instance, ac counts had been shifted from a competing bank to the subject bank be cause o f i t s w illin gn ess to absorb such charges. In these circumstances, the Board expressed the view that the bank in question was v io la tin g the prohibition against the payment o f in terest on demand deposits. The Board believes that it would be d i f f i c u l t to conceive o f clearer "fa c ts or circumstances establish in g that the practice is resorted to as a de vice fo r the payment o f in te re s t". The b i l l before the Committee would le g a liz e a practice such as described in the Board* s September 1943 ru lin g and would permit a member bank to reward or compensate i t s customers fo r the use o f th e ir demand funds so long and only so long as the reward or compensation con sisted o f absorbing exchange charges* "Exchange" i s the name applied to charges exacted by some banks fo r paying checks drawn upon them by th e ir customers when presented through the mails fo r payment. There has been so much misunderstanding as to what is meant by "exchange charges", p a rtic u la rly by some Members o f Congress from sections or communities where the practice does not e x ist, that i t may be worth while to describe the practice in some detail* Let us assume that a bank in Forest, M ississip p i, charges exchange on i t s checks presented through the m ails. A customer o f the bank, John Jones, wishes to s e ttle a transaction in L o u is v ille , Kentucky, and to do so he sends his check drawn on the Forest bank fo r $1,000 to Smith M ail Order Corporation in L o u is v ille . Smith M ail Order Corporation deposits the check in i t s bank in L o u is v ille . The L o u is v ille bank sends the check to the Forest bank fo r payment but the Forest bank remits only $999. Th© d o lla r which the Forest bank has retained i s the "exchange charge". The use o f the one d o lla r fig u re is not to be construed as meaning that the BOARD OF GOVERNORS DF THE Honorable Robert F. Wagner, Chairman FEDERAL RESERVE SYSTEM -5< charge made is at the rate of $1,00 per $1,000. Such charges are fixed by exchange-charging banks in d iv id u a lly and vary. The Board’ s Septem ber 1943 ru lin g does not prohibit the Forest bank from making the charge; but it does deal with the question whether a member bank may pay the charge as a means to compensate a depositor fo r the use o f his funds. This la t t e r question can a ris e in a number o f d iffe re n t ways. In the f i r s t place it may be that Smith M ail Order Corporation maintains a b a l ance with the L o u is v ille bank deemed to be s u ffic ie n t ly large to ju s t ify an arrangement whereby the L o u is v ille bank is w illin g to absorb a l l or a part o f the exchange charges. This case probably would a rise only in the event Smith M ail Order Corporation did enough business at points where there are exchange-charging banks to. cause the amount o f exchange charged to be a fa c to r. Secondly, it may be that the L o u is v ille bank bas an account with a New Orleans bank with an arrangement under which the L o u is v ille bank w i l l send the checks it receives on exchange-charging banks in the New Orleans area to the New Orleans bank, maintaining with the New Orleans bank a compensating balance deemed su ffic ie n t by the New Orleans bank to ju s t ify i t in absorbing a l l or a part of the exchange charges exacted by the Forest bank. In this case Smith M ail Order Cor poration would deposit the check with the L o u is v ille bank; the L o u is v ille bank would send it to the New Orleans bank; and the New Orleans bank would send it to the Forest bank fo r payment. The Forest bank would pay only $999 but the New Orleans bank would credit the L o u is v ill e bank with $1,000 and the L o u is v ille hank in turn would credit Smith M ail Order Cor poration with $1,000. T h ird ly , it may be that the New Orleans bank and the Forest bank w ill have an arrangement whereby the Forest bank w i l l Maintain a compensating balance with the New Orleans bank and the New Orleans bank w i l l absorb a l l or a part o f the exchange charges which the Forest bank has exacted on checks sent it by the New Orleans bank. Here again, the Forest bank would remit only $999 on the $1,000 check drawn by John Jones, i t s customer, in favor of Smith M ail Order, Corporation. The New Orleans bank would absorb the $1.00 exchange charge; and the L o u is v ille bank and, in turn, Smith M ail Order Corporation would receive bhe f u l l amount, $1,000. Since the transaction which the $1,000 check was to s e ttle was between John Jones and Smith M ail Order Corporation, one would think that "kbe $1.00 charge should be paid eith er by John Jones fo r services ren dered by the Forest bank or at le a st by Smith M ail Order Corporation as a charge fo r tran sferrin g the funds from Forest to L o u is v ille . By no etretch o f the imagination could the obligation to pay such charges be ^bat o f eith er the New Orleans or L o u is v ille banks, and th is Committee can be sure that they are not so -opid g ra tis . The absorbing bank pays ihe charge only because it is getting the use o f someone’ s funds and it would not pay them otherwise. Considering that there is a statute pro h ib itin g the payment o f interest on demand deposits i t is plain to see BOARD DT GOVERNORS DF THE Honorable Robert F. Wagner, Chairman FEDERAL RESERVE SYSTEM -6 - what could be done competitively by the use of the device which the b i l l before the Committee would sanction. I t is small wonder, therefore, that already one outlying sub urban bank by using th is device to reward correspondent banks spread it s business even into surrounding States and ran i t s deposits from $800,000 to over $8,000,000 in le s s than a year. Of th is over $6,800,000 or 82 per cent was represented by correspondent bank accounts and, mind you, th is i s a small outlying suburban bank. Another bank, bailed as a $150,000,000 country bank, the la rg e st individual or unit bank in any city with a population o f 110,000 or le s s , has $90,000,000 correspondent bank balances as against $38,000,000 in dividual deposits. Obviously, demand bank balances would not be concentrated in such amounts at such points i f there were not some corresponding reward or compensation fo r th e ir use. That th is i s the fa c t i s fu rth er substantiated by the current fe a r that the balances w i l l not be maintained as they now are unless the absorption o f exchange i s continued. I t i s inconceivable to the Board that the Congress would continue the statutory prohibition against the payment o f in terest on demand deposits and at the same time le g a liz e a practice which partakes o f the ch aracteristics o f the old secret rebates by ra ilro a d s and which would accomplish fo r a lim ited few and by indirec tion the same re su lt as though in terest were being openly and d ire c tly paid. I t i s appropriate also to analyze the proposal under consid eration to ascertain to whom i t would apply and the favors i t would grant. There are some 2,500 exchange-charging banks. These are known as non-par banks because they do not remit at par. Other banks which re mit at par are known as par banks and to ta l in number about 11,500, of which about 4,800 are not members of the Federal Reserve System. From the charts attached to th is report the Committee w i l l note that there ar® 20 States and the D is tric t o f Columbia in which no banks charge exchange and in which a l l o f the 4,763 banks remit at par. These States are Arizona, C a lifo rn ia , Colorado, Connecticut, Delaware, Idaho, Iowa-, Main®> Maryland, Massachusetts, Nevada,New Hampshire, New Jersey, New Mexico, New York, Ohio, Pennsylvania, Rhode Islan d , Utah and Vermont. In addi tion , i t i s noteworthy that in I l l i n o i s only 12 out o f 828 banks are nofl" par banks; in Indiana 3 out o f 496; in Kansas 2 out o f 627; in Kentucky 10 out o f 389; in Michigan 1 out of 443; in Oklahoma 12 out of 384; in Oregon 1 out of 69; in West V irg in ia 6 out o f 180; and in Wyoming 1 out o f 56. Iowa has required i t s banks to remit at par. The proposed le g is la t io n would permit a practice tantamount to the payment o f in terest on demand deposits but i t s application would be lim ited to those having checks on exchange-charging banks and to the amount o f the exchange charged on such checks. In practice i t would be lim ited s t i l l fu rth er because banks would not be w illin g to absorb the exchange except fo r depositors maintaining compensating balances, and only depositors having enough checks on non-par banks to ju s t ify the Honorable Robert F. Wagner, Chairman -7- maintenance o f compensating balances would keep such balances. The prac t ic a l re su lt would be that, with few exceptions, the amendment would be aP plicable only to correspondent banks and la rg e national accounts. The Board has a further objection to the proposed le g is la t io n , In the hearings before the Banking and Currency Committee in the House the Board*s September 1943 rulin g has been characterized as an attempt to enforce par clearance. This charge i s not in accordance with the fa c ts . The Board has repeatedly stated that i t favors par clearance and i t i s , ° f course, a fact that the question of absorption o f exchange is inex tric a b ly involved in the question o f par clearance, as i t is also with other questions. On the other hand, to charge that the ru lin g was d i rected at the 2,500 non-par banks disregards the fact that the ru lin g ap plied to a member bank which was absorbing the exchange, not charging i t , 88 w ell as the fa c t that the ru lin g could re su lt in causing member banks desirous o f resorting to the practice to decide to withdraw from the Federal Reserve System. The Board recognizes that the fin a l determina tion of the question o f par clearance i s one f o r appropriate le g is la t iv e bodies. Congress has already enacted le g is la t io n which requires remission at par o f a l l checks collected by Federal Reserve Banks, The le g is lation to which the Board r e fe rs is known as the "Hardwick Amendment" to section 13 o f the Federal Reserve Act. I t was enacted in 1917 and reads as follow s: "Provided, fu rth e r. That nothing in th is or any other sec tion o f th is act s h a ll be construed as prohibiting a member or nonmember bank from making reasonable charges, to be de termined and regulated by the Board o f Governors of the Fed e ra l Reserve System, but in no case to exceed 10 cents per $100 or fra c tio n thereof, based on the to ta l o f checks and d ra fts presented at any one time, fo r collection or payment o f checks and d ra fts and remission therefor by exchange or otherwise; but no such charges sh a ll be made against the Fed e ra l reserve banks. " (Underscoring supplied) lb w i l l be noted that, by virtu e o f this provision o f law, about 6,700 Member banks are prohibited from charging exchange on checks presented Federal Reserve Banks. Checks on some 4,800 nonmember banks are c°lle c te d through the Federal Reserve collection f a c i l i t i e s which, under, "this amendment, involves remission at par. Since a f a i r estimate would that 90 per cent or more o f the amount of a l l out-of-town checks are collected through the Federal Reserve collection system, the practical e^fect of the Hardwick Amendment is to nrohibit a l l member banks from charging exchange and to require a l l nonmember banks wishing to aVail themselves of Federal Reserve collection f a c i l i t i e s to forego making any such charges. BOARD OF GOVERNORS OF THE FEDERAL Honorable Robert F. Wagner, Chairman -8 RESERVE SYSTEM In the current discussion o f the Board’ s September 1943 ru lin g at the hearing i t has been stated that many of the non-par banks w i l l be forced to close i f member banks are not permitted to absorb the exchange charges which they make. This i s on the theory that i f member banks do not absorb the charges but pass them back to th e ir customers, the pres sure from these customers w i l l re su lt f in a lly in the abandonment of ex change charges. The Board makes no such prediction. I t does a v e r , how ever, that there are in the same States, in the same counties, and often in the same towns equally small national or State member banks which, fo r a l l p ra c tic a l purposes, cannot charge exchange and which are liv in g and competing with non-par banks which do. Now i t is proposed that member banks be authorized to absorb the exchange the non-par banks charge. Here again i t i s inconceivable to the Board that the Congress would authorize member banks to absorb exchange charges fo r small non par banks when equally small member banks are prohibited from making such charges. For the reasons stated the Board is opposed to the enactment o f S. 1642 and the companion b i l l , H.R* 3956. Since the Board has also received a request fo r a report on th is le g is la t io n from the Banking and Currency Committee in the House o f Representatives, a sim ilar report is being sent to i t . Very tru ly yours, Chester M o r r ill, Secretary Enclosures NUMBER OF BANKS ON PAR LIST AND NOT ON PAR LIST, BY STATES, ON DECEMBER 31 , 1 9 k 3 ^ ( i n c lu d e s a l l member ba n k s, and a l l nonmember banks on w hich ch e ck s a re drawn, e x c e p t m utual s a v in g s banks on a few o f w hich some ch eck s a re d ra w n .) S t a te Alabama A r iz o n a Arkansas C a lifo r n ia C o lo ra d o C o n n e c t ic u t D elaw are D i s t . o f Colum bia F lo r id a G e o rg ia Member banks 84 7 63 112 92 62 17 18 60 64 Nonmember bank on w hich ch eck s a re drawn On I Not on I par parT o ta l lis t | lis t 1 5 5 31 82 47 12 3 21 364 274 47 823 K entucky L o u is ia n a Maine M aryland M a ssa ch u se tts 112 38 40 79 154 267 M ich iga n M in n esota M is s is s ip p i M is s o u r i Montana 227 209 215 41 2 332 20 N ebraska Nevada New Hampshire New J e r s e y New M exico 145 8 53 Oregon P e n n s y lv a n ia Rhode I s la n d Sou th C a r o lin a S ou th Dakota 352 4 26 96 38 105 2 12 58 14 113 18 3 267 159 765 36 267 13 28 59 32 2 10 I 0I4 496 653 627 12 94 194 139 116 41 22 77 80 47 816 493 653 625 277 108 26 96 38 389 146 66 175 379 42 66 175 216 46l 443 442 420 174 176 670 201 94 426 41 593 110 4o4 10 65 — 259 2 12 58 14 127 113 145 699 — — — 1 21 154 — — — 111 — 12 192 350 4i 192 250 27 499 89 250 10 65 350 4l 199 699 72 114 267 171 .681 384 45 681 372 37 69 1,0 3 2 1,0 3 2 1 156 68 9 3 5 — 114 98 9 22 117 103 145 162 52 166 218 225 88 313 23 32 120 294 846 57 71 313 128 758 57 71 128 180 106 W ashington W est V ir g in ia W is co n s in Wyoming 56 105 149 266 36 19 — 23 32 — 83 37 50 22 69 6 145 1 72 75 4 il 20 560 2 ,5 2 9 7 ,2 9 2 1 4 ,0 3 0 6,501 13,2 39 4 ,7 6 3 -S773B-----~C7^3— “ 27278 — 491 414 89 267 76 533 34 39 193 6 ,7 3 8 — 41 22 T o ta l banks on par l i s t — T en nessee Texas Utah Vermont V ir g in ia T o ta l In su re d N on insu red 54 24 4 — 21 4 12 213 116 I 65 343 213 54 42 4 14 194 139 105 279 271 586 — 88 263 491 New York N orth C a r o lin a N orth D akota O hio Oklahoma 128 216 12 222 17 16 162 292 27 5 159 82 47 — 26 464 222 167 132 — 54 24 4 Idaho Illin o is In d ia n a Iowa Kansas 25 127 T o t a l banks on w hich ch e ck s a re drawn 540 251 791 on w h ich no ch eck s a re draw n; in c lu d e s 104 p r iv a t e banks w hich do n o t r e p o r t t o S t a te bankin g d ep a rtm en ts, and 13 c o o p e r a t iv e banks ( i n A rk a n sa s ). 56 791 22 31 64 276 174 415 55 1 1 ,5 0 1 i o , 96r 54o BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM, DIVISION OF BANK OPERATIONS, JANUARY 2 0 , 191(4. ALL B A N K S-M E M B E R AND NONMEMBER PAR AND NONPAR PAR NONPAR Par 89 12 94 194 139 116 4| 22 77 80 47 816 493 653 625 379 42 66 175 192 442 250 27 499 89 250 10 65 350 4I 699 72 45 681 372 68 032 22 3J 64 128 758 57 7I ^76 106 174 415 55 DECEM BER 31. 1943 NUMBER OF BANKS non par 0 127 128 - ALAB A M A ARIZONA ARKANSAS CALIFORNIA COLORADO 88 263 CONNECTICUT DELAWARE DISTRICT OF COLUMBIA FLORIDA GEORGIA 12 3 2 200 400 600 800 IDAHO ILLINOIS INDIANA IOWA KANSAS 10 104 ~ - KENTUCKY LOUISIANA MAINE MARYLAND MASSACHUSETTS I 420 '7 4 94 21 MICHIGAN MINNESOTA MISSISSIPPI MISSOURI MONTANA '5 4 ~ ~ NEBRASKA NEVADA NEW HAMPSHIRE NEW JE R S E Y NEW MEXICO ] 27 1I I 12 NEW YORK NORTH CAROLINA NORTH DAKOTA OHIO OKLAHOMA I ~ 114 98 OREGON PENNSYLVANIA RHODE ISLAND SOUTH CAROLINA SOUTH DAKOTA '6 6 89 ' ~ 37 TEN NESSEE TEXAS UTAH VERMONT VIRGINIA 22 8 145 1 WASHINGTON WEST VIRGINIA WISCONSIN WYOMING PAR BANKS TOTAL 11,501 ] NONPAR BANKS TOTAL 2,529 1000 NONMEMBER BANKS PAR AND NONPAR DECEMBER 31,1943 M r a par I— i NONPAR NUMBER OF BANKS PAR NONPAR 5 5 31 82 47 127 - 54 24 4 - 17 16 88 263 21 352 271 491 412 128 - 12 3 2 267 4 26 96 38 10 104 - 215 41 2 332 20 1 420 174 94 21 105 2 12 58 14 154 — 1 13 18 3 267 159 36 267 9 3 5 - 0 100 200 300 400 500 ALABAM A ARIZONA ARKANSAS GAUFORNIA COLORADO C0NNE0T10UT DELAWARE DISTRICT OF COLUMBIA FLORIDA GEORGIA ] ZJ IDAHO ILLINOIS INDIANA IOWA KANSAS K EN TUC KY LOUISIANA MAINE MARYLAND MASSACHUSETTS — 127 1I 1 12 1 1 14 98 52 225 23 32 83 166 88 50 69 266 19 22 6 145 1 — — 37 MICHIGAN MINNESOTA MISSISSIPPI MISSOURI MONTANA 3 N EBRASKA NEVADA NEW HAMPSHIRE NEW JE R S E Y NEW MEXICO NEW YORK NORTH CAROLINA NORTH DAKOTA OHIO OKLAHOMA OREGON PENNSYLVANIA RHODE ISLAND SOUTH CAROLINA SOUTH DAKOTA TE N N ESS EE TEXAS UTAH VERMONT VIRGINIA 3 □ ■ » I .... ~ 1 ] WASHINGTON WEST VIRGINIA WISCONSIN WYOMING PAR BANKS INSURED 4,223 NONINSURED 540 TOTAL 4,763 ] NONPAR BANKS INSURED 2,278 NONINSURED 251 TOTAL 2,529
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