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F e d e r a l R e se rv e

December 14,1973

In a world of multinational corpo­
rations, multinational banks have a
growing role to play, as is seen from
the expanded scope of foreign-bank
operations inside this country in
recent years. Between 1965 and
1972, assets of foreign-bank agen­
cies and branches in the U.S.
increased three-fold to about $13
billion. This growth does not com­
pare with the eight-fold expansion
of American banks' branches over­
seas (to $75 billion), but it has
created an important new force in
the leading American financial
centers.
About 150 foreign banks now oper­
ate in the U.S., with their activities
ranging in size from one-man
representative offices, through
agencies and subsidiaries with reg­
ular banking charters. (In fact, some
subsidiaries now rank among the
100 or 200 largest American banks.)
These institutions have come to the
United States because they realize
that they must operate inside the
world's largest market if they are to
offer a competitive range of inter­
national-banking services to their
customers.
The U.S. is a major trading nation
and, despite the turmoil of the past
several years, the dollar is still the
principal currency used in inter­
national finance. A New York, San
Francisco, or Los Angeles office, for
example, permits direct participa­
tion in U.S. financial markets with
resulting benefits in lower costs and
saving of time. In dealing with their
corporate customers, moreover,

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foreign banks are at a competitive
disadvantage if they cannot offer
those firms banking services in
overseas as well as home markets.
This consideration becomes in­
creasingly important as foreign
manufacturing and trading firms
expand their beachhead in the
continent-sized American market.
New York is the most important
center of foreign banking, because
it is the leading financial center for
both domestic and international
trade, and because it has obvious
locational advantages for financing
trade with Europe. California is next
in importance, because of its ad­
vantages for financing Pacific trade
as well as the large size of the state's
economy. (Foreign-bank affiliates in
California accounted for almost 6
percent of the state's $43 billion
total business loans at mid-year.)
With the easing of banking laws
in other states, centers such as
Chicago, Boston and Seattle can be
expected to attract more foreign
banks in the future.
Types of activities
The most common type of oper­
ation for a foreign bank is the
representative office, but it also has
the most limited functions. It cannot
make loans or accept deposits.
Basically, the representative office
attempts to develop business which
will be handled by the parent bank
abroad. About 80 foreign banks
have representatives in New York
City, and another 20 have repre­
sentatives in either San Francisco or
Los Angeles. A few offices also are
(continued on page 2)

F e d e r a l R e se rv e
B arak ®ff
Sam Fram cke®
Opinions expressed in this newsletter do not
necessarily reflect the views of the management of the
Federal Reserve Bank of San Francisco, nor of the Board
of Governors of the Federal Reserve System.

located in Chicago, Dallas and
Houston.
To make loans in the U.S., a foreign
bank must establish an agency or a
branch— or a domestically-char­
tered commercial-bank subsidiary.
The actual powers of an agency or
branch vary from state to state, but
the principal difference is that a
branch can accept— and an agency
cannot accept— domesticallyowned deposits.
Under New York banking law, a
branch of a foreign bank not only
can accept deposits, both domestic
and foreign-owned, but it also can
make the same types of loans per­
mitted to domestic banks. Loan
limits are determined by the size of
the foreign head office, rather than
by the size of the domestic branch
or agency. Most loans are asso­
ciated with the financing of foreigntrade, but many agencies and
branches also seek domestic busi­
ness in making loans and accepting
deposits. Some New York City
branches of foreign banks actively
solicit consumer-type deposits and
make instalment loans, while under
California banking law, foreignbank offices are permitted only to
accept foreign-owned deposits.
Thus California offices operate like
agencies in New York, and work
primarily in foreign-trade financing.
Subsidiaries of foreign banks are
able to conduct a full domestic­
banking business in the states
where they are chartered. (All

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foreign-controlled banks presently
have state charters, because Federal
law requires that ail directors of
Federally chartered banks be U.S.
citizens.) At present, subsidiaries
are chartered in New York, Cal­
ifornia and Illinois. In California,
where state-wide branch banking
is permitted, five of the eleven
foreign-controlled subsidiaries have
developed branch networks and
compete actively for consumer
business, whereas the other six
conduct a wholesale banking busi­
ness with a strong international
emphasis. In Illinois, where branch­
ing is forbidden to all banks, each
subsidiary is permitted only a single
office which these institutions gen­
erally choose to locate in the
financial district of Chicago.
Regulatory differences

Where foreign banks maintain only
branches or agencies, they are sub­
ject only to state law. Foreign banks
thus can operate branches or agen­
cies in more than one state, which
means that they have a form of
interstate banking open to them
which is unavailable to domestic
banks. (States can stop entry, of
course, and at the moment, nine
states forbid all foreign-bank
offices.) In addition, they are not
covered by the Glass-Steagall Act,
which prevents domestic banks
from engaging in investment bank­
ing. Thus, foreign banks can par­
ticipate in both commercial- and
investment-banking functions.
When foreign banks maintain sub­
sidiaries, they are subject to reg-

ulation by the Federal Reserve
System under the Bank Holding
Company Act. This act prohibits the
acquisition or formation of subsid­
iaries in more than one state. Sub­
sidiaries consequently do not have
the interstate branching powers
available to foreign branches and
agencies, and because of this lim­
itation, they tend to concentrate in
the largest financial centers. The
Bank Holding Company Act brings
both the banking and nonbanking
subsidiaries of foreign banks under
regulation. For example, the Federal
Reserve Board, applying the prin­
ciples of the Glass-Steagall Act,
recently required an Italian bank
to divest itself of a one-third
interest in a U.S. investment­
banking operation before being
permitted to buy into a Chicago
commercial bank.
The Federal government does not
possess statutory authority to gov­
ern all aspects of foreign-bank
activities in this country. As a result,
Federal efforts to negotiate with
foreign governments to reduce bar­
riers against U.S. banks sometimes
are impeded because the Federal
government can not guarantee
uniform regulations in all states.
Many state banking superintendents
are aware of this problem, and
therefore attempt to keep national
objectives in view when processing
applications from foreign banking
institutions.
Last month, Congressman Patman
introduced legislation to authorize
Federal regulation in this area,



which would require foreign banks
to apply to the Treasury Depart­
ment for permission to establish
new offices or continue present
operations. Under the provisions of
the Patman bill all foreign banking
operations in the U.S. would be
conducted through subsidiaries,
rather than through a combination
of branches, agencies and subsid­
iaries— in a sense, paralleling the
type of system under which U.S.
banks operate in most foreign
countries. Only two types of sub­
sidiaries would be permitted any
foreign bank under the Patman
proposal: up to five federallychartered international-banking
subsidiaries, and one state-char­
tered domestic bank. Bank holding
companies could also be formed.
The Federal Reserve System has
been conducting its own study of
the foreign-banking situation, in an
attempt to develop a coordinated
policy which would reconcile
national and international needs
with the interests of the individual
states. The System became involved
in this study partly because of its
responsibilities under the Bank
Holding Company Act, but also
because of the growing importance
of foreign banking for domestic
financial activity and monetary pol­
icy. While further efforts are made
to develop a national policy in this
very complex field, multinational
banking will continue to exert a
growing influence on the
domestic economy.
Robert Johnston

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BANKING DATA—TWELFTH FEDERAL RESERVE DISTRICT
(Dollar amounts in m illions)
Selected Assets and Liabilities
Large Com m ercial Banks
Loans adjusted and investments*
Loans adjusted— total*
Securities loans
Com m ercial and industrial
Real estate
Consum er instalment
U.S. Treasury securities
Other securities
Deposits (less cash items)— total*
Dem and deposits adjusted
U.S. Governm ent deposits
Tim e deposits— total*
Savings
O ther time I.P.C.
State and political subdivisions
(Large negotiable CD 's)
W eekly Averages
of Daily Figures
Member Bank Reserve Position
Excess reserves
Borrowings
Net free ( f ) / Net borrowed (— )
Federal Funds— Seven Large Banks
Interbank Federal funds transactions
Net purchases ( f ) / Net sales (— )
Transactions: U.S. securities dealers
Net loans ( -) / Net borrow ings (— )

Am ount
O utstanding
11/28/73
76,117
57,977
1,337
20,001
18,004
8,878
5,934
12,206
71,684
21,805
474
48,224
17,479
22,053
5,579
10,461

Change
from
11/21/73
+
+
+
+
+
+
+
+
+
-

223
236
66
24
32
5
157
154
151
35
51
100
42
114
47
197

W eek ended
11/28/73

Change from
year ago
D o llar
Percent
+
+
+
+
+
+
+
+
+
+
+
+

9,156
9,164
14
2,698
3,195
1,299
965
957
6,015
934
856
5,813
760
5,115
570
3,812

W eek ended
11/21/73

+
+
+
+
+
+
+
+
+
+
+
+

13.67
18.77
1.04
15.59
21.52
17.14
13.99
8.51
9.16
4.48
64.36
13.71
4.17
30.20
11.38
57.33

Com parable
year-ago period

12
19
7

89
88
+ 1

-

+ 933

+ 686

-2 1 8

-

-2 1 9

+ 172

-

21

-

10
64
74

*Includes items not shown separately.

Information on this and other publications can be obtained by calling or writing the
Digitized for f R A S E R istrative Services Department. Federal Reserve Bank of San Francisco, P.O. Box 7702,
http://fraser.stloUiSflfiaOVg^ co ’ California 94120. Phone (415) 397-1137.
Federal Reserve Bank of St. Louis

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