| For immediate release |
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The Federal Reserve Board today announced its decision denying the notice filed by BancSecurity Corporation to acquire Marshalltown Financial Corporation and its thrift subsidiary, Marshalltown Savings Bank, FSB, all of Marshalltown, Iowa. Attached is the Board's Order relating to this action. |
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BancSecurity Corporation |
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BancSecurity Corporation, ("BancSecurity"), a bank holding company within the meaning of the Bank Holding Company Act ("BHC Act"), has requested the Board's approval under section 4(c)(8) of the BHC Act (12 U.S.C. § 1843(c)(8)) and section 225.23 of the Board's Regulation Y (12 C.F.R. 225.23) to acquire Marshalltown Financial Corporation ("MFC"), and MFC's wholly owned thrift subsidiary, Marshalltown Savings Bank, FSB ("Savings"), all of Marshalltown, Iowa, and thereby to engage in operating a savings association. Notice of the proposal, affording interested persons an opportunity to submit comments, has been published (61 Federal Register 42,251 (1996)). The time for filing comments has expired, and the Board has considered the notice and all comments received in light of the factors set forth in section 4(c)(8) of the BHC Act. BancSecurity is the 12th largest depository institution in Iowa, controlling deposits of $415 million, representing approximately 1.1 percent of total deposits in depository institutions in the state.1 MFC, with deposits of $103 million, is the 57th largest depository institution in the state, representing less than 1 percent of deposits in depository institutions in the state. On consummation of the proposal, BancSecurity would become the ninth largest depository institution in Iowa, controlling total deposits of $518 million, representing approximately 1.4 percent of total deposits in depository institutions in the state. The Board previously has determined by regulation that the operation of a savings association by a bank holding company is closely related to banking within the meaning of section 4(c)(8) of the BHC Act. 12 C.F.R 225.25(b)(9). Competitive Considerations
The Board and the courts have found that the relevant geographic banking market for analyzing the competitive effects of a proposal must reflect commercial and banking realities and should consist of the local area where the depository institutions involved offer their services and where local consumers can practicably turn for alternatives.3 In making a determination on the geographic market in this case, the Board has considered worker commuting patterns (as indicated by census data), shopping patterns and other indicia of economic integration and the transmission of competitive forces among depository institutions, and relevant banking data. In addition, the Board has reviewed information from on-site investigations of the area conducted by staff of the Board and the Federal Reserve Bank of Chicago in connection with the proposal ("Federal Reserve Survey"), which included interviews with bankers, consumers, and owners of small businesses in Marshall County and adjacent areas.4 |
| The Board has determined that the relevant market for analyzing the
competitive effects of this proposal is a rural area in central Iowa approximated
by Marshall County plus the townships of Spring Creek, Carlton, Indian Village
and Highland in Tama County ("Marshall County banking market"). The Board
also has concluded that the relevant banking market does not include Howard,
Toledo, Tama and Columbia Townships in Tama County and Felix and Clay
Townships in southern Grundy County as proposed by BancSecurity.5
Banking data reveal that a very high proportion of deposits and loans of BancSecurity's subsidiary bank, Security Bank, Marshalltown, Iowa ("Security Bank"), and Savings are received and originate from the Marshall County banking market. Data provided by BancSecurity show that approximately 96 percent of Security Bank's deposit accounts and 94 percent of its loans, and approximately 78 percent of Savings's deposits and 95 percent of the loans made by Savings, originated in the Marshall County banking market.6 In contrast, approximately 2 percent of Security Bank's deposit accounts and approximately 3 percent of its loans are from the portions of Tama County not included in the banking market. In addition, Security Bank received approximately 1 percent of its deposit accounts from and made approximately 2 percent of its loans in Felix and Clay Townships in southern Grundy County. Discussions with senior management of depository institutions in Marshall, Tama and Grundy Counties, moreover, confirmed that competition among banking organizations in different counties is limited. Banks in Marshall County generally reported only a modest amount of business from Tama County, mostly from the western townships that are included in the Marshall County banking market. In addition, Marshall County banks that were located near the border with Tama County reported that only 5 to 8 percent of their business originated in Tama County. On the other hand, banks located in the eastern three quarters of Tama County generally reported few or no accounts with Marshall County residents. Banks in Clay Township indicated that they derived small to modest amounts of business in Marshall and Tama Counties.7 The Federal Reserve Survey also suggests that there is relatively little advertising by area financial institutions outside their local communities.8 The Federal Reserve Survey of households and businesses in Marshall County indicated that Marshall County consumers almost exclusively obtained banking services from Marshall County depository institutions. Almost all the transaction and savings accounts, and all the certificates of deposit reported in a telephone survey of Marshall County residents were in Marshall County depository institutions. In addition, 40 of the 47 consumer loans and 16 of 17 commercial and industrial loans to the Marshall County participants in the telephone survey within the last five years were from Marshall County depository institutions, and none of the eight remaining consumer loans were from depository institutions in either Tama or Grundy Counties. An overwhelming majority of households and business owners interviewed in Marshall County stated that they would seek another Marshall County depository institution if they became dissatisfied with their current institution. Almost none of the respondents stated that they would consider an institution in Tama or Grundy County. Marshalltown, with a population of approximately 25,000 residents, is the largest town in the Marshall County banking market. The communities surrounding Marshalltown, particularly those identified by BancSecurity as included in the relevant banking market, are small, offer few incentives for regular travel to these areas by Marshall County residents, and are not conveniently located to Marshalltown.9 Tama and Toledo, for example, have populations of approximately 2,700 and 2,400 residents, respectively, and are located approximately 20 miles from Marshalltown. Travel time between the communities and Marshalltown is approximately 30 minutes.10 Clay and Felix Townships in southern Grundy County have populations of approximately 1,500 and 300 residents, respectively, and are located approximately 15 miles from Marshalltown. Travel time between the communities and Marshalltown is approximately 20 to 25 minutes. |
| Commuting data indicate that Marshall County residents generally do
not regularly travel outside of their county.11 In addition, except for the Tama
County townships included in the Marshall County banking market, residents of
Tama County generally do not commute in large numbers to Marshall County.12
Approximately 13 percent of the work force residing in Tama County commute
to Marshall County, with more than half of these commuters traveling from the
four Tama County townships that are included in the Marshall County banking
market. Only 4.5 percent of the Tama County work force commuting to
Marshall County resides in Howard, Toledo, Tama, and Columbia Townships,
that BancSecurity argues should be included within the Marshall County banking
market. A significant percentage of the labor force from Felix and Clay
Townships in southern Grundy County commute to Marshall County. Other
data, including interviews with Grundy County banking officials, indicate,
however, that banks in these southern Grundy County townships do not consider
Marshall County banks to be significant competitors. Moreover, even if these
Grundy County townships were included in the market, the competitive effects
of this proposal still would be significantly adverse.13
The Federal Reserve Survey found that Marshalltown's large number of retail shopping options provided a disincentive for Marshalltown residents to shop in neighboring communities. In addition, on-site visits to communities surrounding Marshall County did not lend support to broadening the Marshall County banking market beyond the previously identified westernmost townships in Tama County on the basis of travel patterns for goods and services. Basic services such as restaurants, clothing stores, and medical and financial services were available in most of the communities surrounding Marshall County. Based on all the facts of record, and for the reasons discussed above, the Board concludes that the Marshall County banking market, an area that includes all of Marshall County and Spring Creek, Carlton, Indian Village, and Highland Townships, in Tama County, is the appropriate geographic market for analyzing the competitive effects of the proposal. The Board also concludes that Howard, Toledo, Tama, and Columbia Townships in Tama County, and Felix and Clay Townships in southern Grundy County, should not be included in the relevant banking market.
Competitive Effects in the Marshall County Banking Market
The Board notes that HHI thresholds are used as guidelines to help the Board, the Justice Department, and other banking agencies identify cases in which a more detailed competitive analysis is appropriate to ensure that the proposal would not have a significantly adverse effect on competition in any relevant banking market. A proposal that fails to pass the HHI market screen nevertheless may be approved if other information indicates that the proposal would not have a significantly adverse effect on competition.18 The Board has carefully considered BancSecurity's contentions that consummation of the proposal would not result in significantly adverse competitive effects because BancSecurity and Savings do not provide the same types of banking products and services other than residential mortgage loans and retail deposits19 and that a number of considerations would mitigate any potential adverse competitive effect in any relevant banking market, including the number of depository institution competitors remaining in the banking market, the attractiveness of the banking market to potential entrants and low regulatory barriers for entry, and competition provided by credit unions and other providers of financial services located within and outside the banking market. Security Bank and Savings compete directly in a number of products, including residential mortgage loans, an individual product that is important to Marshall County banking market residents.20 Security Bank is the largest provider of residential mortgage loans in the market, with a market share of approximately 36 percent. Savings is the second largest provider, with approximately 25 percent of the market. After consummation of the proposal, the concentration in the market for residential mortgage loans, as measured by the HHI, would increase 1758 points to 3953 and BancSecurity would have a pro forma share of more than 60 percent of the residential mortgage loan market. This pro forma market share would be approximately five times larger than the market share of the next largest competitor, and 10 of the remaining competitors would each control a market share of less than 5 percent. |
| Security Bank and Savings also compete directly with respect to federally
insured deposit accounts. Security Bank is the largest provider of these
accounts in the Marshall County banking market with a market share of
approximately 34 percent. Savings is the third largest provider of these
accounts with approximately a 14 percent market share. After consummation of
this proposal, concentration in the market for federally insured deposit accounts,
as measured by the HHI, would increase 961 points to 2933, and BancSecurity
would have a pro forma share of greater than 48 percent of the market.21
BancSecurity's market share after consummation of the proposal would be more
than twice as large as the share of the next largest competitor, more than five
times as large as the third largest competitor, and ten competitors would have
market shares of less than 5 percent.
The Board has carefully considered the mitigating effect of the fact that 13 depository institutions would remain in the market after consummation, including several banks controlled by large bank holding companies, in light of BancSecurity's pro forma share of market deposits. BancSecurity would control market deposits at least ten times larger than market deposits controlled by all but two of the remaining competitors. In addition, 10 of the 12 remaining competitors would have less than 5 percent of deposits, and nine of these competitors would have less than 3 percent of deposits.22 BancSecurity's share of market deposits would approximately equal the market shares of all other depository institutions combined, and would be more than twice as large as the market share of its closest competitor. The degree of disparity between the market shares of BancSecurity and its competitors significantly reduces the mitigating effect of the number of remaining competitors and would permit BancSecurity to maintain a dominant market position despite the presence of firms that may have overall greater organizational resources. The Board also notes that, although several large depository institutions have competed in the banking market for a number of years, deposit market shares have been fairly stable in the past five years, without significant encroachment on BancSecurity's market share by competitors. Between 1991 and 1994, for example, Security Bank continued to control more than twice the share of market deposits as its next largest competitor.23 Data also indicate that Security Bank currently has a dominant market share in every lending category examined in the Federal Reserve Survey.24 For certain types of credit, Security Bank's share in the Marshall County banking market is two or three times more than the share of the next largest provider. These conditions have prevailed despite the entry into the market of five banking organizations since 1994.25 Moreover, the Federal Reserve Survey found that residents tended to form long-standing banking relationships with local depository institutions that were not easily displaced by depository institutions that did not have an established record of serving the Marshall County community. Although the Marshall County banking market has characteristics that make it attractive for entry,26 the barriers to entry imposed by Iowa law on new entrants into a banking market substantially offset the mitigating effect of this consideration. Specifically, office protection laws restricting intrastate branching significantly limit the number of potential competitors eligible to enter the Marshall County banking market.27 Entry by acquisition of an existing financial institution is permissible; however, this proposal would effectively eliminate MFC as an entry vehicle, and entry through the acquisition of a competitor to BancSecurity would not increase the number of competitors in this market. Although interstate banking will be permitted in Iowa after June 1, 1997, out-of-state banking organizations will only be permitted to acquire an Iowa bank that has operated for at least five years and will not be able to establish de novo branches.28 BancSecurity contends that credit unions and other financial institutions in and outside the Marshall County banking market exert a mitigating competitive influence. In the aggregate, however, the four credit unions in the Marshall County banking market control less than 7 percent of the market deposits. Three of the four credit unions control small amounts of deposits and have restrictive membership requirements. The largest credit union is open for membership to all residents of Marshall, Tama, Grundy, and Hardin Counties, but offers a narrow product line that excludes residential mortgages and commercial deposit and lending services.29 In addition, as previously discussed, the Justice Department guidelines used to screen the competitive effects of depository institution acquisitions implicitly take into account competition provided by credit unions and non-depository lenders in the banking market. Specifically, the adoption of higher thresholds for screening bank mergers recognizes that competition by nonbank sources not included in the calculation of the HHI may serve to mitigate the adverse competitive impact of a merger. The Board concludes in light of all the facts of record, including the Federal Reserve Survey, which indicates that the overwhelming majority of retail and commercial customers in the Marshall County banking market obtain their banking services from a local depository institution, that out-of-market financial institutions, including institutions providing electronic banking services, do not mitigate the substantially adverse competitive effects of this proposal.30 Public Benefits
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| The requirement under section 4 of the BHC Act that the Board
must determine that public benefits from a proposal can reasonably be expected
to outweigh potential adverse effects necessarily involves a balancing process
that takes into account the extent of the potential for adverse effects. The Board
notes that MFC and Savings are well-managed organizations in satisfactory
financial condition and that Savings received a "satisfactory" rating from its
primary federal supervisor in its most recent evaluation for performance under
the Community Reinvestment Act. For the reasons discussed in this order,
however, the effects on competition in the Marshall County banking market are
substantially adverse. In light of these and all the facts of record, the Board has
concluded that the public benefits resulting from potential costs savings, gains in
efficiency or greater convenience identified in the proposal are not sufficient, on
balance, to outweigh the significantly adverse effects on competition in the
Marshall County banking market.
For reasons noted above, and based on all of the facts of record, the Board concludes that the proposed transaction would have significantly adverse effects on the Marshall County banking market. The Board also concludes that considerations relating to public benefits, including financial and managerial resources of the institutions involved, do not lend sufficient weight to outweigh these adverse competitive effects. Accordingly, the Board hereby denies BancSecurity's notice under section 4(c)(8) of the BHC Act. |
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By order of the Board of Governors,31 effective December 9, 1996.
Deputy Secretary of the Board |
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Footnotes 1 State deposit data are as of June 30, 1995. In this context, depository institutions include commercial banks, savings banks, and savings associations. 2 12 U.S.C. § 1843(c)(8). 3 See St. Joseph Valley Bank, 68 Federal Reserve Bulletin 673 (1982). The key question to be considered in making this selection "is not where the parties to the merger do business or even where they compete, but where, within the area of competitive overlap, the effect of the merger on competition will be direct and immediate." United States v. Philadelphia Nat'l Bank, 374 U.S. at 357 (1963); United States v. Phillipsburg Nat'l Bank, 399 U.S. 350 (1969). 4 BancSecurity objects to consideration by the Board of any information or staff submissions that have not been provided to it under the Freedom of Information Act ("FOIA"). Certain information in the record has been withheld from BancSecurity as privileged from disclosure under the FOIA. The Board notes that the rules regarding access to information under the FOIA provide the appropriate framework for considering a challenge to confidential treatment accorded staff's submissions and other information, and that BancSecurity's challenge was reviewed under the FOIA and denied. The Board's rules do not provide an applicant access to information that is otherwise exempt from disclosure under the FOIA. BancSecurity, moreover, has been provided all nonconfidential information in the record of this notice. 5 During the processing of the notice, BancSecurity proposed additional larger geographic areas as the relevant banking market. For the reasons discussed in detail in this order, the Board concludes that these alternative proposals would not constitute the relevant banking market for considering the competitive effects of the proposed acquisition. 6 The data have been adjusted to exclude banking data from offices of Security Bank in Jasper and Hardin Counties. 7 There are no banks in Felix Township. 8 All Marshall County banks advertise in the Marshalltown daily newspaper that circulates primarily in Marshall County. The newspaper has few subscribers in Tama and Toledo in Tama County or Felix and Clay Townships in southern Grundy County. Security Bank and Savings are two of only three depository institutions with offices in both Marshall and Tama counties. Security Bank's Tama County branch advertises primarily in a local weekly newspaper in the town where the branch is located. The Toledo branch of Savings advertises primarily in a Tama weekly newspaper. Although Security Bank and Savings also advertise on Marshalltown radio stations, these stations broadcast over an area even larger than the extended area identified by BancSecurity as the relevant banking market. For example, one Marshalltown station broadcasts over an area encompassing 25 Iowa counties. Banking data also show little indication that the radio advertising has been effective in generating customers from outside the Marshall County banking market. 9 The Board notes that general survey data suggest that individuals in households and small business owners have a strong preference for purchasing basic banking services very close to where they live or work, and that the data are similar in urban and rural markets. 10 BancSecurity maintains that designation of Tama and Marshall Counties as a Rand-McNally basic trade area and the overlap of school district boundaries between the Counties, among other things, support its contention that the relevant banking market should be larger. The Board notes that these delineations are made for purposes not related to the competitive overlap between depository institutions and that the facts of this case, including those noted above, indicate that these delineations do not adequately reflect the area in which competition for banking services is real and immediate. See Wyoming Bancorporation v. Board of Governors, 729 F.2d 687 (1984). |
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11 Residents of Marshall County have one of the lowest rates of commuting outside their county in Iowa. Only 9.5 percent of the county's workers commute outside Marshall County for employment, and only approximately 1.8 percent commute to Tama or Grundy County. 12 BancSecurity states that 1990 census data understate the number of commuters because the data do not fully reflect the 1,500 new jobs created in the Marshalltown area in the last five years nor the large number of retirement-age residents of Tama County who may travel to the Marshalltown area for reasons other than employment. BancSecurity also argues that data from the Iowa Department of Transportation show a high traffic flow on the main highways between Marshall and Tama Counties and that, in a 1992 labor survey, many Tama County residents reported that they would accept a daily commuting distance of up to 60 miles. The Board has considered these data in light of all the facts of record, including data that suggest that events since 1990 may have decreased the amount of commuting into Marshalltown. For example, the data indicate that firms have exited or downsized in Marshalltown, a number of workers from out of state have transferred to Marshalltown in the case of the relocation of workers after a corporate consolidation, and there have been increases in employment opportunities in Tama County, such as the recent opening of a gambling casino in the Meskwaki Indian Settlement in southwest Tama County and the expansion of several other companies in Tama County. 13 The Herfindahl-Hirschman Index would increase by 733 points to 2623, and BancSecurity would control 45.3 percent of total deposits in the market. 14 Market data are as of June 30, 1995, and are based on calculations that include the deposits of thrift institutions at 50 percent. The Board previously has indicated that thrift institutions have become, or have the potential to become, significant competitors of commercial banks. See WM Bancorp, 76 Federal Reserve Bulletin 743 (1984). Because the deposits of Savings would be controlled by a commercial banking organization after consummation of the proposal, those deposits are included at 100 percent in the calculation of BancSecurity's pro forma market share. See Norwest Corporation, 78 Federal Reserve Bulletin 452 (1992); First Banks, Inc., 76 Federal Reserve Bulletin 669 (1990). 15 BancSecurity contends that the methodology used to assess the competitive effects in the market does not give sufficient weight to the deposits of a thrift competitor in the market and gives too much weight to the deposits acquired from Savings, which will continue to be operated as a traditional thrift after consummation of the proposal. The deposits controlled by the thrift competitor have not been given full weight because it does not provide the full range of products and services offered by commercial banks in the relevant market, particularly residential mortgages or commercial loans. The deposits of Savings, however, have been included pro forma at 100 percent because the deposits would directly enhance the capacity of BancSecurity to offer a full range of commercial banking products. Indeed, in this case, BancSecurity characterizes as a public benefit of the transaction the fact that Savings will be able to attract larger lending transactions as a result of combined lending limits available through loan participations with BancSecurity's banking subsidiaries. BancSecurity also has referred to public benefits from the availability of other new banking services from Savings. In this light, the Board concludes that its traditional methodology appropriately considers thrift deposits in analyzing the competitive effect of the proposal. 16 Under the revised Department of Justice Merger Guidelines, 49 Federal Register 26,823 (1984), a market in which the post-merger HHI is above 1800 is considered highly concentrated. The Justice Department has informed the Board that a bank merger or acquisition generally will not be challenged (in the absence of other factors indicating anticompetitive effects) unless the post-merger HHI is at least 1800 and the merger increases the HHI by more than 200 points. The Justice Department has stated that the higher than normal HHI thresholds for screening bank mergers for anticompetitive effects implicitly recognize the competitive effect of limited-purpose lenders and other non-depository institutions. 17 The proposal also would significantly exceed the Justice Department Merger Guidelines under BancSecurity's delineation of the relevant banking market by causing the HHI to increase 697 points to 2224. In addition, market share calculations based on BancSecurity's contentions regarding the weight accorded deposits held by thrift competitors in the Marshall County banking market also would significantly exceed the screening guidelines. If deposits of the thrift competitor in the market were given full weight, the HHI would increase 823 points to 2933, and BancSecurity would control 48.3 percent of market deposits. If the deposits controlled by Savings were weighted at 50 percent pre- and post-merger, the HHI would increase 578 points to 2761 and BancSecurity would control 45 percent of market deposits. 18 HHI calculations are based on deposit data that were assembled before Tama State Bank moved its main office to Marshalltown in September 1996. The Marshalltown office is a recently established de novo office, and the bank has retained its office in Tama County. The deposits of this institution, therefore, have not been included in the HHI calculations. |
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19 Savings, a thrift institution, engages primarily in accepting federally insured deposits and making residential mortgages. Security Bank engages in a wide variety of banking products and services including mortgage, commercial, agricultural, and consumer lending, and deposit taking. 20 The analysis of the proposal's structural impact on residential mortgage loans is based on call report mortgage data, discussions with area bankers, and a telephone consumer survey of borrowing practices by local residents. 21 This calculation is based on weighting thrift institutions in the market at 100 percent. 22 In addition to the small market shares held by nearly all remaining competitors, the Board notes that more than half of the remaining firms are in small communities throughout Marshall County. 23 BancSecurity indicates that Norwest Bancorp, Minneapolis, Minnesota ("Norwest"), has increased its share of market deposits by 63 percent since entering the market through the acquisition of a branch of a failed thrift institution in June 1994, has established a second location in Marshalltown for the purpose of offering mortgage and other loans as well as securities brokerage services, and has announced plans to build a new bank facility in Marshalltown. The Board notes, however, that Norwest controls less than 3 percent of the deposits in the Marshall County banking market. 24 In addition to Security Bank's share of the market for federally insured deposits, residential mortgage loans, and consumer loans, Security Bank also controls approximately 44 percent of the market for small commercial and industrial loans (loans in amounts of less than $1 million) and approximately 57 percent of the market for all commercial and industrial loans. 25 Recent entry by banking organizations appears to have contributed little to increasing competition in the banking market because four of the five entrants have acquired existing banking offices. The fifth entrant, Tama State Bank, relocated its headquarters from Tama County to Marshalltown in September 1996. 26 Data indicate that population and deposits per banking office, per capita income and growth in market deposits, and profitability of banks in the banking market (as measured by the return on assets (annualized)) are all above the average for Iowa's rural counties. 27 See Iowa Code Ann. §§ 524.1202 & 524.1419. Iowa law would permit a bank headquartered in a contiguous county to establish a new branch in Marshall County only in towns that do not already have a bank office in operation. De novo branching into the relevant banking market would therefore be limited to eight very small towns, none of which has a population in excess of 350. A bank headquartered in a contiguous county could also relocate its home office into the market, or a new bank could be established. (See Iowa Code Ann. §§ 524.312 & 524.301) However, the fixed costs of building a suitable facility, hiring additional staff, advertising costs and other activities associated with establishing a new headquarters make this option unrealistic for many small banking firms. The establishment of a new bank would involve costs similar to those of relocating an existing bank, but also would include costs to meet the initial capital requirements and to gain regulatory approval. Federal savings banks may branch without restriction under Iowa law and may act as an agent for their banking affiliates under federal interstate banking law. However, this affects only a small number of institutions and does not make the office protection barriers any less significant for most potential competitors. 28 Iowa Code Ann. §§ 524.1205 & 524.1805. 29 If deposits controlled by this credit union were given the same weight as thrift institutions in the banking market, the HHI would increase 818 points to 2903 on consummation of the proposal. The HHI for federally insured retail deposits would increase by 880 points to 2705 under the proposal if deposits in this credit union were given full weight. 30 BancSecurity has noted the absence of any comments by the Justice Department, any other federal regulator of financial institutions, or any competitor in the market about possible adverse competitive effects of this proposal. The BHC Act, however, charges the Board with determining independently whether a particular proposal can reasonably be expected to produce benefits to the public that outweigh possible adverse effects, such as undue concentration of resources or decreased or unfair competition. (12 U.S.C. § 1843(c)(8)). In making its determinations, however, the Board carefully considers the views provided to it by other agencies. 31 Voting for this action: Chairman Greenspan and Governors Kelley, Lindsey, Phillips, Yellen, and Meyer. Absent and not voting: Vice Chair Rivlin. |
1996 Orders on banking applications
