So that there may be no misunderstanding whatever as to my attitude in this regard, I want to repeat that politics should play no part whatever in the administration of the office of the Comptroller of the Currency.

Appointment of bank examiners, receivers, and others under that office should be made on merit, in the effort to secure efficient and impartial execution of the law.

Your action in regard to the appointment of a receiver is approved.

Not satisfied with the action of the Secretary of the Treasury in sustaining the Deputy Comptroller in declining to appoint his man as receiver, the senator appealed to President Roosevelt and the President, after informing himself as to the facts in the case, wrote the senator as follows:

I think this is peculiarly a case where the Government should clear up the whole situation in its own way, with its own officers, and without any regard whatever to anything connected with politics.

The failure of the two banks named and the incidents related in the preceding pages following the biography of Mr. Crissinger have no connection with his administration of the Comptroller's office, but they were introduced in the belief that they might be of interest to the reader as showing some of the annoyances and difficulties encountered by an administrative official in an honest endeavor to discharge his duties in the best interests of the public and the service which he represents, and also to enable him to contrast the attitude of President Roosevelt with that of the two representatives in Congress and the United States senator hereinbefore mentioned when he was advised by the same subordinate official that the man he expressed a desire to have appointed receiver was not qualified under departmental regulations for the position and that it was not considered for the best interests of the service that he should be appointed.

President Roosevelt simply suggested the appointment of the man of his choice when he had the power to have directed the appointment to be made, but when he was advised of the reasons

why the appointment was considered inadvisable he readily accepted the views of his subordinate and acquiesced in his decision because he believed the Deputy Comptroller was actuated by what he considered to be for the best good of the service, and President Roosevelt invariably sustained the official whom he believed to be governed by such considerations.

The occurrences related were by no means rare or isolated cases. Many incidents of a similar nature could be recited in the career of President Roosevelt as showing that in all matters of this kind he placed the good of the service above every other consideration.

First Official Act of Comptroller Crissinger

The first official act of importance of Mr. Crissinger after assuming charge of the office was the revision and simplification of the forms on which national banks make and publish the reports of condition required by law in response to the calls of the Comptroller, not less than five times each year.

When Comptroller Williams assumed charge of the office on February 2, 1914, the form of report used on the last call immediately preceding that date contained forty-three items of resources and liabilities on the face of the report and eleven schedules on the reverse side. At that time and for many years previously it had been the practice of the office to make very few changes in the form of the report, as it was held that frequent changes in the form were calculated to destroy its usefulness for comparative purposes, therefore uniformity was considered very desirable and necessary.

The forms used by Mr. Williams for the first and nine succeeding calls after he became Comptroller contained no material changes or increase in the number of items, but the tenth call made by him contained an aggregate of fifty-one items on the face of the report, an increase of eleven, and thirty schedules on the reverse side, an increase of nineteen.

Each succeeding report called for by Mr. Williams was materially changed by the elimination of old items and the substitution of new ones, and the number was increased until the last

call made by him immediately before his retirement from office contained one hundred and five items on the face of the report, including those below the total figures and twenty-nine schedules on the reverse side, each containing from three to thirteen items.

The constant changing of the form of the report and the addition of new items with each change was the cause of a great deal of dissatisfaction and complaint on the part of the banks, as their books did not contain the information called for in a way to enable them to readily make up the report, therefore they claimed that its preparation became more and more difficult with each call, and consequently more burdensome, annoying and expensive, so that when Mr. Crissinger assumed charge of the office he had received so many requests from the banks for a simplification of the form, that the first official act to which he directed his attention was a revision of the form by the elimination of all items which he regarded as non-essential and declaring it to be his purpose to return to the practice of the office before Mr. Williams became Comptroller, of maintaining a uniform report blank for each succeeding call. He thereupon reduced the number of items on the face of the form used in his first call for a report from one hundred and five items on the face of the report, including those below the total figures, and twenty-nine schedules on the reverse side, to fifty-eight items on the face of the report including those below the total figures, and seventeen schedules on the reverse side, and rescinded also the regulation made by Mr. Williams that the copy of the report retained by the bank for its files and the copy furnished the newspaper for publication should be a duplicate original, signed, attested and sworn to the same as that furnished the Comptroller's office, instead of a copy as formerly required.

This action of Mr. Crissinger was received with general satisfaction by the banks, and for which he was warmly commended.

With no intention to detract in the least from the credit and commendation so generally given Mr. Crissinger for his prompt modification of the form for reports of condition, at the same time, inasmuch as the Deputy Comptroller was regarded by many bankers as being largely responsible for these objectionable forms, it is deemed proper to state that when Mr. Williams retired

from office it was assumed from past experiences by the Deputy Comptroller, who became Acting Comptroller immediately when the vacancy occurred, that some weeks would probably elapse before a successor to Mr. Williams would be nominated by the President and confirmed by the Senate, and that the duty of making the next call on the banks would, therefore, devolve upon him as Acting Comptroller. He therefore immediately instructed the Chief of the Statistical Division of the Comptroller's office to carefully revise the report of condition form and to eliminate therefrom all items which were regarded as unnecessary and nonessential, and when Mr. Crissinger assumed charge of the office fifteen days later he approved and accepted this revised form with practically no change and used it in his first call upon the banks for a report.

Suit to Forfeit the Charter of the First National Bank,

Hagerstown, Md.

On September 28, 1921, a suit was entered in the United States District Court for the District of Maryland at Baltimore, by the United States Attorney, in the name of the Comptroller of the Currency, to annul the charter of the First National Bank of Hagerstown, Md., for violations of the national banking laws.

The court being of the opinion that the mere filing of a complaint of such a character would precipitate a run on the bank and cause irreparable injury and damage to the institution and many of its creditors, appointed National Bank Examiner Robert D. Garrett temporary receiver, until a hearing could be had on the bill of complaint and an answer thereto filed by the defendant.

Upon filing a bond with the Clerk of the Court in the penal sum of fifty thousand dollars the receiver was directed to take immediate charge of the bank and all of its assets of every character and description and to hold the same subject to the further orders of the Court, to suspend all payments, and to collect all maturing notes and obligations of every character owned by the bank. The receiver was also authorized by the Court to do and perform any and all things that were necessary or proper for him to do as receiver.

The authority of the court to appoint a receiver to take charge of a national bank pending the hearing of a complaint of the Comptroller of the Currency in a suit to forfeit the charter of the association for violations of law was seriously questioned. There was no precedent for such action. The law specifically stated the conditions under which a receiver might be appointed for a national bank, but was silent as to the method of procedure in the case of forfeiture proceedings.

In discussing with representatives of the Department of Justice, previous to the institution of the suit, the method to be followed in the Hagerstown case, the Deputy Comptroller advised them that he would arrange to have a national bank examiner in readiness to take charge of the bank in the name of the Comptroller of the Currency in the event that a run on the institution should develop when it became known that a suit had been filed to forfeit the charter of the bank. The Comptroller being fully satisfied that the bank was not in a condition to meet all demands that would be made upon it by depositors and other creditors, would have been well within his authority to appoint a receiver under such circumstances and take possession of the institution to prevent preference of creditors.

It always has been contended by the Comptroller's office that when a court of competent jurisdiction declared the charter of a national bank forfeited, the Comptroller of the Currency, under authority of such decree, could appoint a receiver for the bank to liquidate its affairs. On the other hand, it has been contended that the directors of the bank would have authority to liquidate the bank the same as if the association had been voted into voluntary liquidation by its stockholders, but no precedent or authority was known for the Court to appoint a receiver pending a hearing of a suit brought by the Comptroller to forfeit a charter

Between the date of filing of the complaint and the time fixed for a trial of the case, the United States Attorney telephoned the Comptroller's office that the president of the defendant bank was in his office and had indicated a willingness to make such changes in the management of the bank and in its personnel as would satisfy the Comptroller of the Currency, if further proceedings