When most people think of secret bank accounts, they think of Switzerland, Luxembourg, and the Cayman Islands. Not Robert Svoboda. He thinks of Montana.

The retired banker is trying to open a Swiss-style bank smack in the middle of Big Sky Country.

The plan: offer highly confidential bank accounts to foreigners and inspire other banks in the state to follow suit. Ultimately, Mr. Svoboda reckons, this cottage industry could contribute handsome fees to the state's coffers.

Though Mr. Svoboda remains unsure whether the plan will pass political and regulatory muster, state authorities appear to be giving it serious attention.

A Montana legislative interim committee, formed to explore the idea, has met four times and will meet for probably the last time in late January in Billings. Attending the meeting will be representatives from the Internal Revenue Service, the Treasury Department, and the Federal Reserve System, in addition to state government and banking officials.

Swiss banks and their ilk have long been renowned for their confidentiality and anonymity. These banks can set up accounts whose ownership is veiled both to outsiders and to most employees. The accounts are identified only by numbers, not names, and are often further cloaked through offshore transactions.

Numbered accounts, proponents say, offer protection from political instability and frivolous civil litigation.

"This isn't for money-laundering or helping people to keep from paying taxes," Mr. Svoboda said. "It's a safe haven for money and it's private."

The institution would be state chartered, but privately insured. Foreigners seeking to stash cash would be able to deposit it in the Montana bank, which then would put it in trusts that could deposit it in other bank's countries. Mr. Svoboda said that depending on the customer's needs, there would be varying "levels of privacy."

Mr. Svoboda says the proposed Montana bank would be the first institution in the United States to offer secret accounts.

So why has he picked Montana for the project? For one thing, he lives there part time, and owns a small ranch there. He ran California Thrift and Loan, Santa Barbara, before retiring, and he's a citizen of California.

In addition, he maintains that the state's relatively lean bureaucracy would be more conducive to the plan than the larger government of another state.

If all goes well, numbered accounts would be a real boon for Montana, Mr. Svoboda says. For example, business could provide revenue for the state through an annual fee based on the size of the bank's assets.

The state could also benefit from escheatment laws, which involve reversion of property to the state if the owner dies with no heirs or the account remains inactive for many years and no owner can be found.

"There were off-the-cuff projections made that a lot of money - hundreds and hundreds of millions of dollars - would be deposited in such accounts," he said. "That would generate a lot of money, which could be used as revenue and alleviate some of the burden for taxpayers."

But there are still many obstacles. The most critical question is how much anonymity can actually be provided.

Montana's banking commissioner, Don Hutchinson, said he doesn't want so much anonymity as to hinder law enforcement officials or allow criminals to deposit funds.

Mr. Svoboda said he doesn't have a problem with the Bank Secrecy Act, which requires banks to report deposits of $10,000 or more to the Internal Revenue Service. International transactions are reportable to the U.S. Customs Agency.

"This is a confidential matter," he said. "It goes to a government agency and remains confidential, and I don't think that's bad. How that money is used afterward is a different matter. It isn't any of the government's business."

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