Bank Charters - Variety is Spice of Life

on 11:07 AM

Credit unions may be state or federally chartered, but chartering a bank has a lot more options.

A blog post by Robert Klingler of Bryan, Cave, Leighton and Paisner Law Firm addresses 5 primary options for chartering a bank.  The author says there are strong, die-hard advocates for the superiority of one over the other, but all are functionally similar.

Looking at the breakdown of charters as of the beginning of 2019, while the majority of all U.S. banks are state, non-member banks (i.e. with primary federal supervision by the FDIC), each charter choice appears to continue to have its advocates.

The Office of the Comptroller of the Currency, the primary federal prudential regulator for national banks, has earned a reputation as the regulator of the largest banks, but the underlying data doesn’t necessarily support that viewpoint. While all of the four largest U.S. banks are national banks, in all asset classifications, there remains a variety of bank charter, showing that no one charter type is necessarily better based purely on asset size.

While national banks represent a plurality of the largest depository institutions (and thus the OCC is the most likely regulator of the largest banks), given the overall landscape of the U.S. banking industry in which smaller institutions absolutely dominate the number of institutions, each of the federal regulators predominantly regulates smaller institutions.

Thus while the OCC may be the most likely to have dealt with an issue for one of the largest banks in the United States, the majority of banks supervised by the OCC are less than $500 million in assets (with over 80% having less than $1 billion in assets).

What About Vermont?

There are only 6 banks chartered in Vermont:

  • Brattleboro Savings & Loan
  • Northfield Savings Bank
  • Passumpsic Savings Bank
  • Peoples Trust Company of St. Albans
  • Union Bank
  • Wells River Savings 
Another 6 are domiciled in Vermont bu have national charters:
  • Bank of Bennington
  • Community National
  • Mascoma
  • First National Bank of Orwell
  • Ledyard National
  • National Bank of Middlebury
And, another 9 out-of-state banks have one or more branches in Vermont:
  • Bar Harbor
  • Berkshire
  • Community
  • KeyBank
  • NBT
  • People's United
  • RBS Citizens
  • TD
  • Trustco
Finally, Vermont has 13 state-chartered and 6 federally-chartered credit unions domiciled in the state with one or more locations each. 

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