Legal Seminar, Chicago, IL

Status of Independent Trust Companies (“ITCs”) • Total number of “pure” non-depository trust companies in U.S. is estimated to be around 400; 55 OCC – as of 4/30/19, with the remainder being state chartered. • Some trust companies are being acquired by other trust companies, banks, brokers, RIAs, etc. As the number declines, interest in acquisitions has increased. • It is not an easy business to enter due to capital requirements and need to quickly gather assets in order to be profitable.

• Increased capital standards and other economic issues stopped growth of new charters in the mid-2000s. • When was last ITC chartered in your state? • Statutory Capital standards vary significantly by state (per CSBS survey). SD, NH, and NV have been on low end <$500,000. $1.5MM to $2MM seems “typical”. • Insurance E&O/D&O-minimums $1MM. • Can this help with capital standards? • Would attitude be different if entities were FDIC insured?