Large Bank Supervision Forum 2023

Project to identify pain points for large state banks attempting to do business in multiple states STRATEGY:

• Understand why banks may pursue a national charter by collecting, analyzing, and addressing their pain points.

MEASURES: • Interview 5 banks with assets over 50B • Interview 10 banks with assets between 10B and 50B • Top three reasons identified for each group • A total of two actions agreed upon and in flight

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Confidential (For State Bank Supervisors Only) / Not For Redistribution / Pre ‐ Decisional

BY THE NUMBERS: NATIONAL BANKING INDUSTRY

1,045 National banks

21% of all are National Banks

792 banks under 1B

63 national banks over $10B

The four National Banks over $1 Trillion represent 60% of total National Bank assets and 40% of all banking assets.

Banks over $10 Billion represent 95% of all National Bank assets

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Confidential (For State Bank Supervisors Only) / Not For Redistribution / Pre ‐ Decisional – Data as of March 31, 2021