NationsBank, BankAmerica, and other institutions creating the tidal wave of mergers could end up paying much lower assessments to the Office of the Comptroller of the Currency.
Why? As banks get bigger, OCC fees as a percentage of assets drop dramatically. So two banks with $200 billion and $240 billion of assets last year would have paid a total of $32.5 million in assessments. If the banks had combined and rolled all their operations into one charter, their assessment would have been reduced nearly $2 million, to $30.8 million.
But OCC officials say they have no reason to panic and predict it's unlikely that fees will have to be raised to make up for revenue lost in the merger craze.
"Other things are going on that have an impact on overall assessments, such as growth in total industry assets or whether there is a movement from state-chartered to national banks," said Roy C. Madsen, the agency's deputy chief financial officer.
Mr. Madsen also denied that a big drop in assessment revenue is a given for the merged companies. "Exactly what happens with these mergers depends on the corporate structure these companies choose," he said.
For instance, companies such as Banc One Corp. and First Chicago NBD Corp. will enjoy only a modest reduction in fees from the $20 million the two companies paid in 1997, unless they combine the 18 national bank charters they own between them.
If all those banks were merged into one charter, Banc One could cut its assessment by almost $5 million, according to calculations based on the OCC assessment schedule.
The OCC could offset almost $1 million of that lost revenue, however, if Banc One converted state-chartered assets held in Michigan to a national charter.
A spokeswoman for Banc One said the company has not decided how many of the post-merger corporation's charters will be merged or whether any state banks will be converted to national charters.
Mr. Madsen conceded that the merger wave has made predicting assessments difficult.
"Twenty years ago the banking industry was a stable entity, and we could do easy revenue projections," he said. "But with so much going on right now, it's very difficult to speculate."
He also insisted that the OCC would have sufficient revenue because total assets in the national banking system continue to rise. Besides, it will cost less to supervise institutions that combine charters.
Currently, national banks control 57.7% of total banking assets. From 1993 to 1997, national bank assets increased from $2.01 trillion to $2.69 trillion. During that time, assessment revenue remained stable at roughly $350 million a year because the OCC cut its fees.
Despite the recent growth in national bank assets, the OCC will be under continuing pressure to keep its assessment rates low, said James H. Chessen, chief economist for the American Bankers Association.
"The OCC has to be very sensitive to their pricing," he said. "Even though they've adjusted rates very fairly over the last few years, they still face competition from state regulators."
State regulators insist that the merger wave will not result in an exodus from state charters. In recent testimony before the House Banking Committee, Texas Banking Commissioner Catherine A. Ghiglieri pointed out that state banks often enjoy powers not permitted to national banks. For instance, 21 states let their banks underwrite municipal revenue bonds, and 32 have authorized broader insurance sales powers than those permitted to national banks.
