The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.
MINUTES OF THE MEETING OF THE FEDERAL ADVISORY COUNCIL
April 3, 1962
A special meeting of the Federal Advisory Council was held in Room 928 of the
Mayflower Hotel, Washington, D.C., on April 3, 1962, at 8:15 P.M.
Present:
Milton H. Glover, Alternate
George A. Murphy
Howard C. Petersen
Reuben B. Hays
Robert B. Hobbs
J. Finley McRae
Kenneth V. Zwiener
Sidney Maestre
John A. Moorhead
Maurice L. Breidenthal
I. F. Betts
Elliott McAllister
Herbert V. Prochnow
William J. Korsvik
District No. 1
District No. 2
District No. 3
District No. 4
District No. 5
District No. 6
District No. 7
District No. 8
District No. 9
District No. 10
District No. 11
District No. 12
Secretary
Assistant Secretary
Absent:
Ostrom Enders
District No. 1
President Murphy stated that Chairman Martin had indicated that the Board would
like to have the views of the members of the Federal Advisory Council on the desirability
of amending Regulation Q. This was outlined in a letter dated March 21, 1962 from Merritt
Sherman, Secretary of the Board of Governors. A copy of the letter, together with
enclosures, is made a part of these minutes.
The ensuing discussion disclosed that the majority of the members of the Council
favored no change in the present Regulation. However, there was a feeling on the part
of some members of the Council that in addition to the present $2 a month absorption
allowance, the absorption of exchange charges on items of $50 or less might be in the
best interests of the banking system as a whole.
The Council felt strongly that the Regulation, as finally determined by the Board
of Governors, should be rigidly enforced by the appropriate agencies.
The meeting adjourned at 10:35 P.M.
HERBERT V. PROCHNOW
Secretary
W IL LIA M J. KORSVIK
Assistant Secretary
14
COPY OF LETTER
BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM
WASHINGTON 25, D. C.
March 21, 1962
Mr. Herbert V. Prochnow, Secretary,
Federal Advisory Council,
c/o First National Bank of Chicago,
38 South Dearborn Street,
Chicago 90, Illinois.
Dear Mr. Prochnow:
In accordance with arrangements made by Chairman Martin with President Murphy,
the Board would like to have the views of the Federal Advisory Council with respect to
a problem of considerable importance and difficulty that arises out of the Board’s efforts
to interpret and enforce provisions of the Federal Reserve Act that prohibit member
banks from paying interest on demand deposits, directly or indirectly, by any device
whatsoever. A special meeting of the Council with the Board has been set tentatively for
10:00 a.m. on Wednesday, April 4, 1962, in the Board’s building, with the thought that
as much of the day as may be necessary will be devoted to discussion of this subject.
For many years the Board has consistently followed the position that the absorption
by member banks of exchange charges deducted by drawee nonpar banks in remitting
for checks collected by the member banks for their depositors involves an indirect pay
ment of interest on demand deposits in violation of the law. However, the practical
difficulties of effective enforcement of this position have become increasingly apparent.
The Board has also been concerned by the inequities of the resulting situation in which
member banks are placed at a disadvantage in competing with nonmember insured banks,
since the Federal Deposit Insurance Corporation has interpreted similar provisions of
law as not precluding the absorption of exchange charges on behalf of demand depositors.
Repeated efforts to find acceptable administrative means of meeting the problem
without imposing undue burdens upon member banks have been unsuccessful. Con
sequently, the Board is now giving consideration to the desirability of amending Regula
tion Q to provide that the absorption of normal and customary exchange charges by
member banks, in connection with the routine collection for their depositors of checks
drawn on other banks, will not be considered a payment of interest on deposits. This
would be consistent with the position taken by the Federal Deposit Insurance Corporation
with respect to nonmenber insured banks.
15
Mr. Herbert V. Prochnow
There is enclosed a memorandum that summarizes the background of this problem
and indicates some of the arguments that might be advanced for and against reversal of
the Board's position that absorption of exchange charges by member banks constitutes
an indirect payment of interest on deposits.
If any member of the Council should be unable to be present at the special meeting
tentatively set by Chairman Martin and President Murphy for April 4, it is hoped that
an alternate might attend in his place, and if neither the member nor an alternate can
attend, the Board would appreciate receiving the member’s views in writing.
Very truly yours,
(Signed) Merritt Sherman,
Secretary.
Enclosure
P.S. A copy of this letter is being sent direct to each member of the Council together
with the enclosure.
cc: Mr. Korsvik
16
EN CLOSURE
ABSORPTION OF EXCHANGE CHARGES AS A
PAYM ENT OF INTEREST ON DEPOSITS
For many years, the Board has been confronted by the problem growing out of its
efforts to interpret and enforce the provisions of section 19 of the Federal Reserve Act
and the Board’s Regulation Q prohibiting the payment of interest on demand deposits
by member banks, particularly as applied to the absorption by member banks of exchange
charges deducted by drawee nonpar banks in remitting for checks collected by the member
banks for their depositors.
The problem has been emphasized by the difficulty of reconciling the Board’s position
that absorption of exchange charges constitutes an indirect payment of interest with its
position that certain free services performed by member banks for their customers do
not constitute an indirect payment of interest. Moreover, the Board’s position with respect
to absorption of exchange charges has had the effect of placing member banks at a dis
advantage in competing with nonmember insured banks, since the Federal Deposit
Insurance Corporation, in applying similar provisions of law, has taken the position that
the absorption of such charges by nonmember insured banks does not involve an indirect
payment of interest.
In connection with further consideration of this problem, there are set forth below
(A) a summary of the background of this matter, and (B) some considerations relating
to the possibility of a reversal of the Board’s position as a means of achieving a solution
of the problem.
(A) Summary of the Background
1.
The Banking Act of 1933 amended section 19 of the Federal Reserve Act to
prohibit member banks from paying interest on demand deposits “directly or
indirectly, by any device whatsoever.” Shortly thereafter, the Board took the
position that the absorption by a member bank of exchange charges on checks
collected for its demand depositors would result in an indirect payment of interest
if the amount of exchange absorbed bore a substantially direct relation to the
amount of the deposit.
2.
The Banking Act of 1935 expressly authorized the Board “to determine what
shall be deemed to be a payment of interest”. The same Act for the first time
made the prohibition against payment of interest on demand deposits applicable
17
also to nonmember insured banks, although the FDIC was not expressly authorized
to determine what constitutes a payment of interest. Pursuant to the new legisla
tio n , both the Board and the FDIC drafted regulations on the subject to become
effective January 1, 1936. The Board’s Regulation would have expressly defined
“interest” as including the absorption of exchange charges. The FDIC, however,
objected to this provision, and the proposed definition was never included in
Regulation Q.
3.
As a compromise, the Board and the FDIC in 1937 agreed to amend their respec
tive regulations to define “interest” in identical language as follows:
“Within this regulation, any payment to or for the account of any
depositor as compensation for the use of funds constituting a deposit
shall be considered interest.”
At the same time, the Board and the FDIC issued a joint press statement to the
effect that these amendments were intended only to declare “existing law” and that the
definition of interest would permit “the general application by each agency of a uniform
law and a determination of specific cases upon the facts involved.” In other words,
“interest” would be defined in accordance with general court decisions and without
resort to the Board’s specific statutory authority to define the term.
4.
In 1943, the Board ruled that absorption of exchange charges by a particular
member bank in the circumstances of the particular case constituted an indirect
payment of interest. (By this time, the Board had concluded that it was not
necessary for the amount absorbed to vary with the amount of the deposit in
order for such absorption to constitute interest.) The 1943 ruling immediately
gave rise to heated controversy. The House of Representatives passed a bill that
would have expressly declared absorption of exchange not to be a payment of
interest, but the bill failed of enactment in the Senate.
5.
The FDIC, in 1944, amended its regulation on this subject to include the follow
ing footnote:
“6 The absorption of normal or customary exchange charges by an in
sured nonmember bank, in connection with the routine collection for
its depositors of checks drawn on other banks, does not constitute
the payment of interest within the provisions of this Part.”
As explained by counsel for the FDIC at that time, this provision meant that virtually
no absorption of exchange by nonmember insured banks would be regarded as a payment
of interest.
6.
In 1945, the Board sought an administrative solution of the problem by adopting
the position that absorption of exchange charges in amounts of not more than
$2 per month for any one depositor would be considered trivial and would not
be regarded as interest, but that if a member bank absorbed exchange in greater
amounts it would be presumed to be in violation of the law.
18
7.
By 1954, there was evidence that the so-called “$2 rule” was not being strictly
adhered to by all member banks. The Federal Reserve Banks were requested to
make a survey; and the FDIC was asked to reconsider its position in this matter.
However, the survey led to no acceptable solution and the FDIC in March 1955
reiterated its position that no absorption of exchange by nonmember insured
banks was considered to be a payment of interest.
8.
In 1956, when the “Financial Institutions Act” was under consideration in
Congress, the Board proposed that Congress settle the issue one way or the other
as to both member and nonmember insured banks. However, no such legislation
was enacted.
9.
In August 1960, the Board took the position (1) that absorption of exchange
constitutes a payment of interest on demand deposits even where the amounts
absorbed by a member bank are less than the cost of collecting them from
depositors, and (2) that a member bank would be considered as paying interest
on demand deposits if it maintained balances with another bank in return for
which such other bank would directly or indirectly absorb for the member bank
(and for the ultimate benefit of the member bank’s depositors) exchange charges
made by the drawee banks. The Board stated that this position should be regarded
as superseding all earlier interpretations on the subject. (1960 BULLETIN 858)
10.
The position just described was modified by a published ruling of the Board in
November 1960 (1960 BULLETIN 1226), which stated that, pending a survey
of the matter and as a tentative authorization, member banks were “authorized
to absorb exchange charges in amounts aggregating not more than $2 for any one
depositor in any calendar month or any regularly established period of 30 days.”
This modification made no change in the second part of the August 1960 ruling
regarding the maintenance of balances with other banks, but it had the effect of
relaxing the first part of that ruling so as in effect to restore the so-called “$2 rule”.
11.
Since 1960, a further survey of the matter has been made through the Federal
Reserve Banks. The possibility of adopting an administrative rule in lieu of, or
in addition to, the “$2 rule” , has been explored; but no such rule appears to
afford a satisfactory solution of the problem. Moreover, the FDIC has again
reiterated its unwillingness to change its own position in this matter.
(B) Considerations Relating to Possible Reversal of the Board's Position
Arguments against reversal of the Board’s position that absorption of exchange con
stitutes a payment of interest may be summarized as follows:
1.
The Board’s past position has been based on the ground that, when a member
bank pays an exchange charge in collecting a check for its depositor and credits
the depositor with the full amount of the check, the member bank makes a
“payment” to its depositor in the amount of the exchange charge and that the
circumstances usually warrant the conclusion that such payment is made as
compensation for the use of the deposit and is therefore a payment of “interest”.
The soundness of this position is supported by the fact that the law broadly
prohibits payment of interest on demand deposits, directly or indirectly, by any
19
device whatsoever, and by the fact that absorption of exchange has clearly beer,
utilized by member banks as an indirect means of attracting and retaining
demand deposits.
2. Reversal of the position followed by the Board for more than 20 years could be
attacked as constituting an arbitrary or capricious action by the Board, partic
ularly if it should appear that the real reason for such reversal was to place
member banks on competitive equality with nonmember insured bank:, rather
than to implement the prohibition of the statute against direct or indirect pay
ment of interest on demand deposits.
It might, of course, also be argued that reversal of the Board’s position would tend
to encourage the making of exchange charges by nonpar banks and that this would be an
undesirable result. However, the Board’s only authority under the law is to determine
what constitutes a payment of interest on demand deposits; and the fact that reversal
of the Board’s interpretation in this respect might tend to encourage exchange charge?
themselves would not be a relevant legal consideration. Even as a practical matter, it
may be arguable whether reversal of the Board’s position in the long run would have
that result.
Arguments for reversal of the Board’s position as to absorption of exchange charges
may be summarized as follows:
1.
It is difficult to reconcile the position of the Board that absorption of exchange
involves a “payment” to a depositor with the position taken by the Board in a
number of cases in recent years that a variety of free services (such as free
armored car and messenger service, free safe deposit boxes, etc.) do not involve
an indirect payment of interest, even though the Board has recognized that such
services are offered in order to obtain deposits. In November 1961, in an unpub
lished opinion, the Board held that the absorption by a member bank of wire
transfer charges, although similar to absorption of exchange charges, represented
only an expense incident to a normal banking service which the bank might
refrain from charging to its customer, and that therefore the absorption of such
transfer charges should not be considered an indirect payment of interest. By
the same reasoning, it may be argued that an exchange charge paid by a member
bank (regardless of the justification for such a charge) is nevertheless an expense
incident to a normal banking service rendered by the member bank for its
customers.
2. In many instances, the clerical expense to a member bank of charging exchange
back to its customers would be greater than the amount of exchange involved;
and on this basis again it may reasonably be argued that, to this extent, absorp
tion of such charges does not involve a payment of interest.
3. The Board’s express statutory authority to determine what constitutes a payment
of interest affords a basis for going beyond what may be regarded as the “general
law” and for defining interest in such manner as the Board may deem best in
order to achieve effective enforcement of the statute.
Practical arguments for reversal of the Board’s position are (a) the inequity of
20
applying different rules, under similar statutory provisions, to member banks and non
member insured banks, and (b) the impracticality of enforcing or policing the Board’s
present position with respect to absorption of exchange by member banks. While these
are not legal grounds for reversal of the Board’s position, they might be regarded as sound
policy reasons for such a reversal if it would otherwise be supportable on legal grounds.
March 21, 1962.
21
MINUTES OF JOINT CONFERENCE OF THE FEDERAL ADVISORY COUNCII
AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
April 4, 1962
At 10:00 A.M., a joint conference of the Federal Advisory Council and the Board of
Governors of the Federal Reserve System was held in the Board Room of the Federal
Reserve Building, Washington, D. C.
Present: Members of the Board of Governors of the Federal Reserve System:
Chairman Wm. McC. Martin, Jr.; Vice Chairman C. Canby Balderston; Governors
A. L. Mills, Jr., J. L. Robertson, Chas. N. Shepardson, G. H. King, Jr., and George W.
Mitchell; Mr. Howard H. Hackley, General Counsel of the Board of Governors; also
Mr. Merritt Sherman, Secretary, and Mr. Kenneth A. Kenyon, Assistant Secretary of
the Board of Governors.
Present: Members of the Federal Advisory Council:
Mr. George A. Murphy, President; Mr. Milton H. Glover, Alternate for Mr. Ostrom
Enders; Messrs. Howard C. Petersen, Reuben B. Hays, Robert B. Hobbs, J. Finley
McRae, Kenneth V. Zwiener, Sidney Maestre, John A. Moorhead, Maurice L. Breidenthal,
I. F. Betts, Elliott McAllister, Herbert V. Prochnow, Secretary, and William J. Korsvik,
Assistant Secretary.
Absent: Mr. Ostrom Enders.
In introductory comments, Chairman Martin indicated that the Board was con
cerned about the difficulty of enforcement of its position in the absence of a uniform
point of view among Federal banking agencies.
Mr. Howard Hackley, General Counsel, Board of Governors of the Federal Reserve
System, then outlined the history of the problem beginning with the Banking Act of 1933
which, among other things, prohibited member banks from paying interest on demand
deposits directly or indirectly by any device whatsoever.
Chairman Martin then asked Governor Robertson to comment, noting that he had
worked on this problem for many years.
Governor Robertson summarized negotiations that had taken place in an effort to
achieve uniformity of approach among Federal banking agencies.
President Murphy then reported that the Council had held a lengthy discussion of
this subject. He stated that the members of the Council felt that the position of the
Board over the years had been a sound one; that the absorption of exchange charges
was in fact the payment of interest on demand deposits.
22
Mr. Moorhead noted that there were more nonpar banks in the ninth district than
in any other district and that they would like to see the Board’s present rule maintained
without change.
In the extended discussion which followed, there seemed to be widespread agreement
in support of the present Regulation as enforced by the Board of Governors.
President Murphy, in a concluding comment, said that whatever the decision of the
Board, the Council would recognize that it represented the Board’s best judgment and
that the banking industry would support it.
The meeting adjourned at 12:10 P.M.
HERBERT V. PROCHNOW
Secretary
WILLIAM J. KORSVIK
Assistant Secretary
23
NOTE:
This t r a n s c r i p t of the S e c r e t a r y 1s notes is not to be
r e g a r d e d as c o m p l e t e or n e c e s s a r i l y e n t i r e l y accurate*
The
t r a n s c r i p t is f o r the sole u s e of the m e m b e r s of the Federal
Advisory Council.
The c o n c i s e o f f i c i a l m i n u t e s for the
enti r e y e a r are p r i n t e d and d i s t r i b u t e d later.
H aV . P .
W.J.K.
The S e c r e t a r y {s n o t e s of a s p ecial m e e t i n g of the F e deral
A d v i s o r y C o u n c i l o n A p r i l 3, 1962, at 8:15 P.M., in R o o m 928
of the M a y f l o w e r H o t e l , Washington,, D. C. All me m b e r s of
the C o u n c i l w e r e p r e s e n t e x c e p t M r u Enders.
Mr. M i l t o n H.
Glover, P r e s i d e n t of the H a r t f o r d N a t i o n a l B a n k and Trust
C o mpany, H a r t f o r d , C o n n e c t i c u t , a t t e n d e d as an A l t e r n a t e for
Mr. O s t r o m E n d e r s .
P r e s i d e n t M u r p h y b r i e f l y r e v i e w e d his c o n v e r s a t i o n w i t h C h a i r m a n
Martini The . C hairman h a d i n d i c a t e d that the B o a r d w o u l d like to have
the views of the m e m b e r s of the F e d e r a l A d v i s o r y C o u n c i l on the
desirability of a m e n d i n g R e g u l a t i o n Q to p r o v i d e tha t the a b s o r p t i o n
of normal a n d c u s t o m a r y e x c h a n g e c h a r g e s b y m e m b e r banks in c o n n e c t i o n
with the r o u t i n e c o l l e c t i o n f o r t h e i r d e p o s i t o r s of checks d r a w n on
other banks, w i l l n o t be c o n s i d e r e d a p a y m e n t of inte r e s t on deposits.
Pre s i d e n t M u r p h y s t a t e d t h a t an estimated. $9 m i l l i o n of exchange
charges w e r e c o l l e c t e d l a s t year.
He t h e n d i s p l a y e d a map sh o w i n g the
distribution of n o n - p a r b a n k s in e a c h state a n d a s u m m a r y of a Fe d e r a l
Reserve s u r v e y (of 1 1 1 b a n k s ) of n o n - p a r items' and e x c h a n g e . c h a r g e s •
Copies of the m a p a n d the s u m m a r y are a t t a c h e d and m a d e ,a part of these
minutes. A n e x t e n d e d d i s c u s s i o n f o l l o w e d in w h i c h e a c h m e m b e r d e s c ribed
the s i t u a t i o n in h i s r e s p e c t i v e d i s t r i c t .
M o o r h e a d , r e p r e s e n t i n g the N i n t h D i s t r i c t , w h i c h i n c l u d e s a large
number of n o n - p a r b a n k s , s t a t e d that he v i g o r o u s l y o p p o s e d a change
in the R e g u l a t i o n w h i c h w o u l d p e r m i t 'banks to a b s o r b e x c h a n g e charges.
He stated that h i s b a n k a l o n e p r o c e s s e d over one m i l l i o n n o n - p a r items
a month and that e x c h a n g e c h a r g e s c o l l e c t e d e x c e e d $ 1 m i l l i o n a year.
He also a r g u e d t h a t the c o s t f i g u r e s i n d i c a t e d b y the F e d e r a l R e s e r v e
survey we r e n o t m e a n i n g f u l as t h o s e b a n k s w h i c h are o b l i g e d to process
a large v o l u m e of n o n - p a r c h e c k s h a v e s t r e a m l i n e d the p r o c e s s so that
costs are r e l a t i v e l y n o m i n a l .
Hobbs of the F i f t h D i s t r i c t , w h i c h also i n c l u d e s a s u b s t a n t i a l
number of n o n - p a r b a n k s , u r g e d t h a t the R e g u l a t i o n n o t be changed.
He estimated t h a t the e x c h a n g e c o l l e c t e d in h i s d i s t r i c t exceeds
$2 million, a n n u a l l y .
The d i s c u s s i o n d i s c l o s e d t h a t the m a j o r i t y of the m e m b e r s of the
Council f a v o r e d no c h a n g e in t h e p r e s e n t Regulation,,
H o w e v e r , there
w&s a f e e l i n g on the p a r t of some m e m b e r s of the C o u n c i l that in a d d i
tion to the p r e s e n t $ 2 a m o n t h a b s o r p t i o n a l l o w a n c e , the a b s o r p t i o n
exchange c h a r g e s o n i t e m s of $ 5 0 or les s m i g h t be in the best
interests of the b a n k i n g s y s t e m as a w h o l e ?
The C o u n c i l f e e l s s t r o n g l y t h a t the R e g u l a t i o n , a s f i n a l l y deter
mined by the B o a r d o f G o v e r n o r s , s h o u l d b e r i g i d l y e n f o r c e d b y the
appropriate a g e n c i e s *
The m e e t i n g a d j o u r n e d at 1 0 : 3 5 P*M*
ON A P R I L l±, 1 9 6 2 A T 1 0 : 0 0 A .M * T H E F E D E R A L A D V I S O R Y COUNCIL
H E L D A J O I N T M E E T I N G W I T H T H E B O A R D OP G O V E R N O R S OP T H E
F E D E R A L R E S E R V E S Y S T E M IN T H E F E D E R A L R E S E R V E BUILDING,
W A S H I N G T O N , D. C*
A L L M E M B E R S OF T H E C O U N C I L W E R E P R E SENT
E X C E P T MR* O S T R O M E N D E R S » MR* M I L T O N H* G L O V E R A T T E N D E D AS
A N A L T E R N A T E F O R MR. E N D E R S *
TH E F O L L O W I N G M E M B E R S OF T H E B O A R D OF G O V E R N O R S W E R E PRESENT:
C H A I R M A N M A R T I N , V I C E C H A I R M A N B A L D E R S T O N ; G O V E R N O R S MILLS,
R O B E R T S O N , S H E P A R D S O N , K I N G A N D M I T C H E L L ; MR* H O W A R D H*
H A C K L E Y , G E N E R A L C O U N S E L OF T H E B O A R D OF G O V E R N O R S ; MR* SHERjMAN, S E C R E T A R Y , A N D M R * K E N Y O N , A S S I S T A N T S E C R E T A R Y , OF THE
B O A R D OF G O V E R N O R S , A L S O W E R E P R E S E N T *
The m i n u t e s of the j o i n t m e e t i n g are b e i n g p r e p a r e d in the office
of the S e c r e t a r y of t h e B o a r d of G o v e r n o r s of the F e d e r a l Reserve System.
Their content 'will be c o m p a r e d w i t h the n o t e s of the S e c r e t a r y of the
Council* A s s u m i n g t h e y a r e in s u b s t a n t i a l a g r e e m e n t , they w i l l be r e
produced and d i s t r i b u t e d to m e m b e r s of the C o u n c i l .
The m e e t i n g a d j o u r n e d at 12 :10 P » M *
The ne x t m e e tin g o f th e C o u n c il w i l l be h e ld A p r i l 30-May 1 , 1962
SURVEY OF NOW-PAR ITEMS AND EXCHANGE CHARGES
EFFECT OF VARIOUS ALTERNATE RULES FOR ABSORPTION OF SMALL CHARGES
( One M o n th P e r io d - 0 0 0
Alternative Proposals
Absorption of;
O m itte d )
Number of Items
Deposited By
Banks Others Total
Banks
Others
Total
Cost of Collecting*
Deposited By
Banks
Others Total
E x ch an ge
Deposited By
Net Cost (- )
Deposited By
Banks
Total
Others
Charges under 34
2,291
l, 08 l
3,372
$ 3 5 .9
$ 20 „7
$ 56,6
$103.5
$ 55.3
$15808
Items $25 or less
3 ,1 6 1
1,588
7^9
104.2
55.^
159.6
142,7
78.7
221. k
- 38,5
- 230
- 61.8
Items $50
3 ,8 5 7
1,961
5,818
1^ 3.8
77-5
221.3
174,2
97’
5
271.7
- 30.4
- 20.0
- 50.k
4 ,3 6 1
2,222
6 ,5 8 3
I851.O
99*7
284.7
197,0
110 08
307,8
- 12.0
- 11.1
- 23.1
657
371
1 ,0 2 8
271,5
168 30
*39-5
31 o0
20,8
51,8
+2^0.5
+147.2
+3 8 7 ,7
less
Items $100 or less
Items over $100
$- 67.6 $- 34,6
A nnual
* A t m e d ia n r e c o r d in g u n i t c o s t o f 4 ^ j f o r a l l banks and
m e d ia n m o n th ly c h a r g e cost, o f 1 7 # f o r m a j o r i t y o f b a n k s .
Based on R e p o rt o f S u rv e y o f 111 b a n k s
by F e d e r a l R eserve System
March 2 7 , 1961
Basis
$-102.2
$4,652.4
STATES CLASSIFIED ACCORDING TO PERCENTAGE
OF NON-PAR BANKS TO TOTAL BANKS
Mississippi............ 71 *0$
Georgia................ 66.0
North Dakota........... 62.8
South Dakota........... 59*2
Minnesota.............. 57*7
Louisiana.............. ^k.2
Arkansas..... ......... kh»3
South Carolina......... *4-3*8
North Carolina......... k l . l
Alabama................ 3^*5
Tennessee.............. 2^-.^
Alaska.................. lU.3
Florida............ . • • • 12.7
Missouri...............
8*5
T e xas................... 2.8
Oklahoma............... 1*3
Virginia................... 3
Illinois..... ............. 1
M e m b e r 31,
1961
N o n -P ar Banks in Each State and Percentage of T o ta l B an k s
Dec. 31,
1961
@FedFRASER