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Mr. SMITH. He was feeling a little sensitive because he was consulting with me about the regulations. I said, "Just tell him you were carried from the room on your shield with blood gushing from your chest." Senator METCALF. That is a so-called Chinese wall.

Mr. SMITH. That is right.

Senator METCALF. We also hear that it has been breached in probably more instances than it is held inviolate.

Mr. SMITH. I would not take the position that the Chinese wall has never been breached. I am certain that is true.

Senator METCALF. I really am not quarreling with you, Mr. Smith. I think you have made a fine statement about the need for disclosure and you are doing something about it.

I am just inquiring as to what is ahead and what we can find out about the banks because it seems to me that there is an area where we have had very little information.

Mr. SMITH. Let me say this, Mr. Chairman: I will be happy to have our staff meet and discuss with the staff of the subcommittee the types of disclosure that you think are appropriate, which might have bank director affiliations.

As I say, the type we are proposing to acquire for our purposes is going to be very extensive. I am certain we can find some middle ground where more disclosure might well be possible.

Senator METCALF. You are going to require rather extensive reports. Maybe we can find some common ground for that sensitive area of privacy that both of us agree should be protected and we will also have disclosure.

Mr. SMITH. We would be happy to explore that.

Senator METCALF. I am sure that with all good will-and we both have good will-we will be able to work something out.

Mr. TURNER. Mr. Chairman, in regard to that, I would like to have incorporated into the record, if we might, this document that we have presented to the Comptroller General which is form Y-6 (exhibit B, item 2, table 1) from the Federal Reserve Board. Form 4-6 sets forth a rather comprehensive list of the affiliations of directors and officers of bank-holding companies, among other items. This exhibit relates to the First City Bancorporation of Texas.

I think that as a beginning thing here the staff might suggest that this would be the kind of information that they would like to see made public by the Comptroller with respect to the banks under its jurisdiction.

Senator METCALF. Is this public information?

Mr. TURNER. This is public information.

Senator METCALF. Without objection, it will be made a part of the record.

Mr. SMITH. Mr. Miller advises me this is with respect to directors of bank-holding companies.

Mr. TURNER. They hold lots of banks.

Mr. SMITH. Yes; they do.

Mr. TURNER. I think about 65 percent of the bank assets in the United States are held by bank-holding companies.

Mr. SMITH. They are situated in banks which in turn are situated. in holding companies. That is right.

[The information referred to follows:]

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(Submitted in accordance with Instructions in Form Y-6)

(Este and Initi=1} FRB-DALLAS

CERTIFICATE

I, P. L. Sampson, Vice President and Secretary of First City Bancorporation of Texas, Inc., hereby certify, on the 29th day of March, 1974, that this

Annual Report has been examined by me and is true and complete to the best of my knowledge and belief.

(Signature)

EXHIBIT B

3

1.

List the name and address of any shareholder that directly or indirectly (a) owns; (b) controls; or (c) holds with power to vote 5 per cent or more of the outstanding shares of the Bank Holding Company. State number and percentage of shares in each category for each shareholder. Give record ownership and, to the extent information is available, list beneficial ownership of shares held by nominees or in street name.

2.

No shareholder of First City Bancorporation of
Texas, Inc. (hereinafter referred to as the
"Company") owns, controls, or holds with power
to vote 5 per cent or more of the outstanding
shares of the Company.

List the directors, trustees, partners, or persons exercising similar functions, and principal officers of the Bank Holding Company showing: (a) name; (b) address (City and State only); (c) number of each class of the Bank Holding Company shares owned, controlled, or held with power to vote (or any other proportional interest in the Bank Holding Company); (d) title of position with the Bank Holding Company; (e) similar connections with each subsidiary of the Bank Holding Company (showing share ownership, or any other proportional interest, greater than 5 per cent in such subsidiaries); (f) similar connections with other business companies (showing share ownership, or any other proportional interest, greater than 5 per cent in such companies); (g) amounts receivable from the Bank Holding Company at year end, or at any time during the year, in excess of $20,000; and (h) principal Occupation. (NOTE: The term "principal officer" includes every individual who participates, or has authority to participate, in major policy making functions of the company regardless of whether he has a title or whether he is serving without salary or other compensation.)

See Table No. 1.

3. List each company (bank and nonbank), other than subsidiaries which the Bank Holding Company directly or indirectly owned, controlled, or held with power to vote, 5 per cent or more of the outstanding voting shares and state the number and percentage of shares held, (a) at the end of the current year and (b) at the end of the prior year. Also provide location of head office and SIC

Code of principal business activity.

See Table No. 2.

4. State the exemptive provision of the Act, Regulation, or Order, relied upon for authority to continue to own each of the companies listed in Item 3. If section 4 (c) (8) of the Act is relied upon, refer to the specific activity authorized in section 225.4 of Regulation Y.

All of the companies listed in Item 3 are banks.
Ownership of banks is permitted by section 4 (a) (1)
of the Bank Holding Company Act of 1956, as amended,
subject to the requirements of section 3 (a) concern-
ing the necessity for prior Board approval of cer-
tain bank acquisitions. If required, First City
Bancorporation will furnish the Board with informa-
tion concerning Board approvals of acquisitions for
each situation wherein such approval was required.

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