Legal Seminar, Chicago, IL

• South Dakota is the state where the greatest number (100+) of ITCs have been chartered due to favorable trust laws, “reasonable” capital standards ($500,000) and more welcoming attitude. Some have then qualified as a “foreign fiduciary” in their “home state” or other states, but this has become more challenging. • Tennessee is another state that has attracted new charters. The Ohio DFI chartered an ITC last year. • Many states per CSBS Interstate Compact cooperate regarding trust examination and regulation, but state laws are not always conducive to interstate operation.

• Even where operating in other states is available, it is not easy to accomplish due to the complexity of the laws and regulations, applications, etc. • Is it possible to have standardized forms for qualification across state lines or is this intended to be somewhat challenging so that the various state regulatory agencies have an better opportunity to review? • ATO has been in discussions with Jim Cooper, Marty Beth Quist and others CSBS over the potential standardization of call report formats and other issues and we look forward to continued dialogue.