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F E D E R A L D EP O S IT IN S U R A N C E C O R P O R A T IO N
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PR 24-81 (4-28-81)

IMMEDIATE RELEASE

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29 1981

SOME THOUGHTS ON BANKING TODAY

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An address by

William M. Isaac, Director
Federal Deposit Insurance Corporation
Washington, D.C.

presented to the

80th Annual Convention of the
Conference of State Bank Supervisors

Houston, Texas
April 28, 1981
*1

FEDERAL DEPOSIT INSURANCE CORPORATION, 550Seventeenth St. N.W., Washington, D.C. 20429



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202-389-4221

I
am particularly happy to be with you today as I was
unable to attend your last annual convention in Las Vegas as
planned. As you may recall, the remarks I had prepared for
last year's meeting were delivered for me by Bob Shumway;
the topic was the challenge to the dual banking system.
This year I would like to follow up on those remarks by
reviewing briefly how our state banking system is striving
to enhance its performance and strength.
I will then switch
topics and offer some observations of mutual interest on the
condition of our financial system.
It is clear to me that our dual or state/federal banking
system has many positive attributes. First, state super­
vision of banks offers the advantage of local level juris­
diction -- of bringing government closer to the governed.
This proximity to the regulated banks and their communities
provides the opportunity to develop laws and regulations
that are based on a more intimate knowledge and greater
understanding of local problems and needs. Second, our dual
banking system provides an important deterrent to undue
concentration of government power by counterbalancing the
federal presence in bank regulation. Third, our dual system
allows for the development of a healthy variety of approaches
to banking issues, giving us a greater likelihood of arriving
at optimal programs or solutions. This potential for
innovation by banks and bank regulators is, perhaps, the
most significant strength of our dual system.
While the dual banking system has served our country
quite well for over a century, it has come under increasing
pressure for change in recent years. Some critics have even
suggested abolishing the dual banking system and substi­
tuting a centralized structure for the chartering and
regulation of banks.
A more concrete and specific threat to the system is
last year's Depository Institutions Deregulation and Mone­
tary Control Act. The Act's provisions establishing mandatory
universal reserve requirements and uniform access to Federal
Reserve services and the discount window have perhaps the
most significant potential consequences for the dual banking
system. After the new reserve requirements for nonmember
banks are completely phased in, the current advantage that
state nonmember banks have over national banks will have
been eliminated, which may result in a greater incentive for
banks to select a national charter to avoid dual regulation.
If we are to maintain the vitality of our dual banking
system, minimization of the burden of dual regulation is
one of the most important challenges that the states and the
FDIC must meet.
I believe we have made significant progress along these
lines over the past year. Perhaps most noteworthy has been
the increase in participation in the divided examination
program. Under this program, banks that do not require




2

special supervisory overnight are examined by the state
authority and the FDIC in alternate years rather than by
each agency each year. Currently 18 states participate in
the divided exam program, up from only 7 a year ago; over
3,200 state banks now obtain the benefits of a more effi­
cient, less costly system of oversight.
In addition to the divided examination program, the
FDIC and a number of states are cooperating to reduce
duplication and delay in the area of applications proc­
essing. Not only do we encourage simultaneous submission of
applications to the FDIC and the state authority, we process
the applications concurrently with the state whenever
possible. Our goal is to virtually eliminate the time-lag
between action by the state authority and action by the
FDIC. Moreover, the FDIC and 18 states currently share
common application forms, which further reduces the time and
expense of such transactions as opening branches and.con­
summating mergers.
Another area in which the FDIC has expanded its co­
operation with the states is that of data collection and
analysis. The number of states participating in the divided
exam program that are tied into our data base has increased
to a current total of 10. This access to the call reports
and other information allows states to avoid collection and
processing costs that they would otherwise have.
These are but a few examples of the progress that we
have made toward bringing about a more efficient system of
supervising state banks.
I am confident that as the months
and years go by, we will broaden our efforts and will devise
additional means for enhancing the strength of our state/
federal system and eliminating its weaknesses. We at the
FDIC appreciate the close cooperation we have received from
many of you during the past year in connection with these
efforts, and we know we can count on your continued leader­
ship and support.
Let me now turn to the condition of our financial
system. This is a fascinating and challenging time to be in
the field of bank supervision. We are witnessing a virtual
revolution in the financial services sector; there are so
many events, trends, and difficult issues confronting us and
the banks we supervise.
Formerly distinct product lines that separate various
kinds of financial institutions are becoming increasingly
blurred: commercial banks make mortgage and consumer loans,
brokerage houses offer bank-like services, and even re­
tailers engage in activities that once were the exclusive
province of financial institutions. Most dramatic has been
the explosive growth of the money market mutual funds, whose




3
assets are approaching $120 billion. This erosion of pro­
duct distinctions among institutions was accelerated by last
year’s Depository Institutions Deregulation and Monetary
Control Act. The Act called for the abolition of deposit
interest rate ceilings and gave thrifts new powers, in­
cluding the ability to offer checking accounts nationwide
and to diversify their loan portfolios.
In addition to the increased homogeneity among banks
and nonbank financial intermediaries, technological develop­
ments in recent years have allowed the geographic restraints
that have traditionally limited banking markets to be
bypassed.
Improved transportation, computer, and commu­
nications systems have enabled banks and other financial
intermediaries to reach out farther and farther for busi­
ness.
In addition we have seen a tremendous growth in loan
production offices, Edge Act corporations, and various
nonbanking affiliates, all of which have further contributed
to the circumvention of geographic restraints on banks.
These trends are not likely to abate in the years ahead. As
the competition intensifies among financial institutions
formerly isolated from one another by product and geographic
market boundaries, pressures will intensify to fashion
regulatory techniques and a regulatory structure that treat
financial institutions in an equitable and evenhanded manner.
Perhaps the most difficult challenge that depository
institutions are facing is the current harsh economic
climate, with its high and volatile interest rates accom­
panied by substantial unemployment in some sectors and
regions. Volatile rates make it more difficult to manage
portfolios. High rates cause depreciation in financial
assets. Unemployment leads to additional credit losses.
The unsettled economic environment, combined with the
heightened competitive climate, makes banking a more complex
business today than ever before. Because of this, some
people have raised questions about the strength of our
banking system.
I can assure you that our banking system is in good
health, that banks appear to be weathering these harsh and
unpredictable conditions remarkably well, and that, while
some individual institutions are suffering some ill effects,
the banking system as a whole is coping in a way that attests
to its underlying strength.
I will be specific and give you
some figures that reflect what happened in banking over the
last year.
Total assets of ajl insured commercial banks grew
approximately 10 percent in 1980, almost as much as in 1979.
This growth was more expensive to fund, however, as interest
rates soared and funds at commercial banks shifted from




4
relatively low-cost, fixed-rate deposits to more costly
instruments with market-related rates. These more expensive
deposits increased from 55 percent of interest-bearing
liabilities at all commercial banks at year-end 1979 to 68
percent at the end of 1980. The deposit shift was most
pronounced at smaller banks (those with less than $100
million in assets). For these banks the percent of inter­
est-bearing liabilities in deposits without fixed ceilings
increased from 35 percent at year-end 1979 to 58 percent by
year-end 1980.
Banks were able to offset the higher cost of funds and
increased noninterest operating expenses by generating even
higher operating revenues, so that net income after taxes
rose by 14 percent. The median ratio of net income to
average assets was 1.2 percent, up slightly from 1979. As
in the past, earnings were inversely related to asset size,
ranging from a return on assets of 1.28 percent for.banks
under $25 million in size to 0.63 percent for banks over $5
billion. Only banks of over $5 billion experienced a growth
in assets exceeding their growth in net income.
Asset quality deteriorated somewhat, as might be
expected in light of economic conditions, but loan loss
reserves increased correspondingly. We saw an increase in
loan losses during 1980 of 40 percent over 1979; however,
this increase was lower than in the 1974-75 recession when
net losses increased 69 percent in 1974 and 66 percent in
1975.
The liquidity of the commercial banking system improved
in 1980, but with some offsetting developments. One measure
of liquidity is the ratio of temporary investments (mainly
federal funds sold and securities maturing in less than one
year) to rate-sensitive purchased funds (mainly federal
funds purchased and time deposits of more than $100,000).
As of year-end 1980 this ratio was 135 percent as compared
to 107 percent at year-end 1979 -- a significant liquidity
improvement -- although there were substantial differences
in this ratio between large and small banks.
This improvement in the liquidity position of banks was
offset somewhat by shifts in the deposit structure to a
greater proportion of short-term instruments. At the end of
1980, six-month money market certificates, passbook accounts,
and large certificates of deposit, most of which had matu­
rities of six months or shorter, constituted 53 percent of
all domestic deposits in commercial banks. When demand
deposits are included, 90 percent of all bank deposits were
subject to withdrawal in six months or less. This is up two
percentage points from the end of 1979.




5
Capital in the banking system increased last year, with
the ratio of equity capital to total assets for all insured
commercial banks growing from 8.06 percent in 1979 to 8.27
percent in 1980. This overall increase is attributable
primarily to increased equity ratios in banks with under $1
billion in assets; banks with between $1 and $5 billion had
approximately the same equity ratios in 1980 as in 1979,
while ratios in banks over $5 billion declined slightly.
We have handled thus far in 1981 three bank failures
with a total of $75 million in deposits. Projected out over
the entire year, that is about the same failure rate as in
recent years. Failures in recent years have resulted from
internal factors largely unrelated to the economic environ­
ment. There are no detectable trends to relate these
failures to the general condition of the economy.
The number of banks on our problem list continues to
decline despite the economy and interest rates. As of March
31, 1981, 204 banks of all types were on the list, down from
217 banks at the end of 1980 and 287 banks at the end of
1979.
I should note, however, the problem list contains a
built-in lag, since it is usually about 18 months before
poor conditions in the economy magnify the weaknesses that
cause banks to go on the problem list.
The FDIC fund which currently exceeds $11.3 billion in
size, is strong and growing. Our net income in 1980 was
$1.2 billion; that was the first time net income exceeded $1
billion.
For 1981, we project net income in the range of
$1.3 billion.
Where once the bulk of the fund’s income was attribut­
able to bank assessments, today only about one-third comes
from assessments, with about two-thirds coming from invest­
ment income. Moreover, our fund is highly liquid, with
approximately $200 million in overnight obligations and an
overall average maturity of 3.1 years, down from 3.9 a year
ago.
We have never had to use our statutory right to -raw up
to $3 billion from the U.S. Treasury should we need it. Nor
do we anticipate any circumstances that would cause us to
exercise this right, although it does provide essential
backup should we experience unusual circumstances.
From the figures I have given you, you can see that the
banking system emerged from the turbulent months of 1980
relatively unscathed and, in fact, with a modest improvement
in its overall condition.
I think it is particularly
heartening to consider the general condition of small
banks -- those under $100 million in assets -- which often

C




6
have been considered more vulnerable to the volatile inter­
est rate environment than large banks. Despite the fact
that these smaller institutions experienced a dramatic shift
in liabilities from low-cost deposits to more expensive,
market-sensitive instruments, they have been successful in
generating sufficient returns on their portfolios to protect
their net interest margins. The margins of these institu­
tions increased in 1980, while the margins of larger
banks -- over $1 billion in assets -- generally showed
little improvement.
While I think we can take comfort from the strength of
our banking system, it would be foolish to ignore the
possibility that a prolonged continuation of current economic
conditions could eventually undermine the stability of the
system and sap its strength. The present vulnerability of
some of our 341 FDIC-insured mutual savings banks stands as
a reminder of the importance of the safety mechanisms built
into our banking system. The Federal Deposit Insurance
Corporation is cognizant of its responsibilities in this
regard and is prepared to discharge them fully.
It is no secret that inflation and its accompanying
high interest rates have dominated the economy over the past
few years and have created serious problems for many mutual
savings banks. Higher interest rates have significantly
increased the cost of savings bank deposits. Yields on
earning assets have risen, but much more slowly than deposit
costs. Assets are heavily concentrated in long-term, fixedrate mortgages and bonds which turn over slowly. The
problem has been exacerbated by slow deposit growth re­
sulting from a low personal savings rate, the diminished
appeal of taxable, fixed-return investments, and increased
competition from money market funds and market instruments.
These conditions have severely limited the ability of savings
banks to acquire higher-yielding assets.
Last year, FDIC-insured mutual savings banks lost money
in the aggregate. The loss amounted to about 0.17 percent
of average assets compared with net income of about 0.45
percent of assets in 1979 and 0.59 percent in 1978. The
loss was not evenly spread throughout the country. New York
City savings banks, which account for about 40 percent of
the deposits of FDIC-insured thrift institutions, lost about
0.62 percent of average assets last year. The rest of the
industry had net income of about 0.17 percent. The weaker
performance of many of the New York City savings banks
reflects a combination of factors, including past restric­
tions on permissible lending, past restrictive usury ceil­
ings, extremely harsh state and city tax treatment, a




7
relatively static mortgage market, and a high degree of
competition from large money center institutions and money
market funds.
Even if interest rates decline moderately over the next
year or so, deposit costs at savings banks are likely to
increase as deposits continue to shift out of passbook
accounts and as certificates paying 7-1/2 and 7-3/4 percent
mature.
If interest rates decline markedly and remain lower
for a sustained period, most savings banks should be able to
adjust portfolio returns to bring them into line with the
market and attain a profitable position. Savings banks then
would have the opportunity to take advantage of the broadened
lending powers authorized by the Monetary Control Act of
1980 and state laws, thereby reducing their exposure to
future interest swings.
Late last year we established a high-level project team
at the FDIC to monitor conditions in the savings bank
industry and develop strategies for addressing the situation.
We do not have the time today to go into detail regarding
the work of our project team; suffice it to say that we have
put in a great deal of effort, and we are confident that we
know both the nature and extent of the problems and that we
have the capacity to handle them. We have projected what is
likely to transpire under a variety of economic scenarios.
Even assuming very pessimistic interest rate environments,
the FDIC’s resources are more than adequate to ’eal with
every contingency.
We may decide to seek legislation to provide us with
additional flexibility in dealing with troubled institu­
tions. We will not seek it unless we believe it is nec­
essary to enable us to effectively perform our job. In' the
event we do propose legislation, I hope we can count on the
support of CSBS and of all of you in the audie ice to ensure
its swift passage.
I thank you for inviting me to participate in your
annual meeting. Your gathering together at this meeting to
share experiences and opinions about banking and bank
regulation is testimony to the most positive attribute of
our dual banking system -- that is, the strength that comes
from diversity. As I look back over the three years I have
spent at the FDIC, I am gratified by the cooperation and
support we have received from so many of you. As I look ahead
to the many challenges confronting the financial services
industry, I feel certain that we must and will develop an
even better working relationship -- a relationship designed
to help us achieve our mutual objective of maintaining a
strong, innovative financial system.




FEDERAL DEPOSIT INSURANCE CORPORATION
Washington, D.C. 20429
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