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GUIDE TO ORGANIZING A NEW STATE BANK IN
FLORIDA
Office of Financial Regulation
Licensing and Chartering
200 East Gaines Street
Tallahassee, Florida 32399-0371
(850) 410-9528
TABLE OF CONTENTS
I. About This Guide
II. Preliminary Considerations
a. Executive Officers and Directors b. Organization
Compensation and Expenses c. Market Area d. Bank Location and Premises
e. Capital f. Choice of Charter g. Formation of Bank Holding Company
h. Name of Proposed State Bank i. S Corporation Tax Election j. Restriction
on Interstate Merger k. Timing of Process
III. Organizing a State Bank
a. State Application b. Federal Application c.
Post Application Organization and Charter
IV. Raising Capital
V. Securities Law Issues - Banks
VI. Securities Law Issues - Bank
Holding Companies
VII. List of Actions to Perform
VIII. Financial Institutions
This guide is provided by the Office of Financial
Regulation as a tool to assist individuals who are interested in chartering
new state banks. It is intended to provide the reader with general information
and issues for consideration only, and is not legal advice nor a substitute
for legal or other professional advice. For ease of reference in this
guide, the Office of Financial Regulation is referred to as "OFR", the
Office of the Comptroller of the Currency is referred to as the "OCC",
the Federal Deposit Insurance Corporation is referred to as the "FDIC",
the Federal Reserve Bank of Atlanta is referred to as the "Federal Reserve",
and the Secretary of State's Division of Corporations is referred to
as "Corporations".
Before getting to the charter application and process,
the organizing group must make several strategic decisions:
Executive Officers and Directors
One of the organizing group's most important decisions
is the selection of a chief executive officer. The organizers must thoroughly
investigate the background and qualifications of their proposed chief
executive officer prior to submitting their application. A qualified
chief executive officer is viewed as essential in the overall assessment
of the likelihood of a new bank's success. The proposed chief executive
officer's prior banking experience is especially relevant. The organizing
group's failure to propose a suitable chief executive officer reflects
poorly on the group's judgment and raises doubts about the future success
of the proposed bank.
Rule 69U-105.206(2)(c), Florida Administrative Code
provides that executive officers shall have demonstrated abilities and
experience commensurate with the position for which they are proposed.
Executive officers must have reputations evidencing honesty and integrity
and an employment history demonstrating competent past financial institution
experience. The rule does not require that the names of the president,
chief executive officer, and/or senior trust officer be submitted with
the application. However, these individuals must be named and have submitted
executed Interagency Biographical and Financial Reports (Form OFR-U-10)
in substantially complete form not later than ninety (90) days prior
to an applicant's intended opening date. The proposed state bank may
not open for business without prior approval of these executive officers,
as applicable, by OFR.
These guidelines are consistent with the organizers'
objective of choosing a well-rounded person for the leadership of a
new state bank. If the proposed bank's plan is to offer specialized
types of services, its executive officers should have experience relevant
to the development and administration of those services.
Extensive background investigations will be undertaken
not only on the proposed chief executive officer, but also on other
executive officers, all organizers, principal stockholders and directors.
Principal stockholders are those proposed stockholders expected to own
ten percent (10%) or more of the new bank's outstanding shares. Background
checks are intended to provide information on the competence, experience,
integrity and financial ability of each person named in the proposed
bank's application. Anyone whose previous banking experience is tied
to failed or problem financial institutions will be closely scrutinized
to determine his/her ability to carry out applicable duties.
Rule 69U-105.206(2)(c), Florida Administrative Code
also provides that the proposed directors shall generally have reputations
evidencing honesty and integrity and similar reputations within the
local community where the proposed state financial institution is to
be located. Directors shall have employment and business histories demonstrating
their responsibility in financial affairs. The fact that a proposed
director has been adjudicated bankrupt or has filed for relief under
the Federal Bankruptcy Act shall be considered a material factor in
the evaluation of his/her responsibility in financial affairs. At least
two (2) of the proposed directors, who are not also proposed officers,
shall have had direct experience as an executive officer, regulator,
or director of a financial institution within 3 years of the date of
the application. If in the opinion of OFR the aggregate level of financial
institution experience represented by the proposed board of directors
is not substantial, OFR shall require the addition of other outside
directors to the board who have had previous financial institution experience.
At least five (5) directors of a proposed independent bank or association
shall demonstrate strong and well-established residency and/or business
ties to the local community for at least the last five years prior to
the date of the application, and shall represent diverse occupation
and business interests.
Generally, the organizing group should seek directors
who are knowledgeable about the market and the services to be provided,
and who have ties in the community. The proposed directors should have
diverse experience and backgrounds, and at least a majority of the proposed
directors should have banking or business experience. For a period of
two years after commencement of business, any new executive officers
or new directors of a new state bank must obtain prior OFR approval
before assuming office.
To successfully establish a new bank, the organizers
must make a substantial personal and financial commitment.
Organizer Compensation and Expenses
The general character of management and the adequacy
of capital structure are important in the charter application process.
Organizer compensation methods should not reflect negatively on those
aspects of an application, and should not hinder the bank's future ability
to raise required capital. Instead, organizer compensation should be
structured so that any gains are proportionate to each organizer's financial
risk and the success of the bank. Organizers cannot be allowed to purchase
or acquire a separate class of holding company stock with greater voting
rights, or at an original issue price lower than that paid by other
investors.
Section 658.24, Florida Statutes, states that, after
the corporate existence of a bank has commenced and stock has been issued,
but no less than 30 days prior to the intended opening date, a shareholders'
meeting shall be held with approval of organization expenses as one
of the agenda items. Within ten days after this meeting, a detailed
accounting of the organization expenses approved by the shareholders
shall be provided to OFR.
Rule 69U-105.205, Florida Administrative Code states
that organization expenses shall be borne by the applicant. After approval
of the shareholders, those expenses may be reimbursed as provided in
Section 658.24, Florida Statutes. The rule further states that an accounting
of the organization expenses must be provided to each subscriber as
well as OFR no later than the date upon which the call for payment of
stock subscriptions is made.
The expenses incurred by the organizing group in making
an application and organizing the bank usually may be charged to the
bank's capital or may be capitalized, provided they are documented and
approved by the board of directors. Expenses typically include filing
and organizational fees, cost of professional and consulting services,
travel expenses, printing, postage, telephone, supplies, salaries and
rent, and the lease or purchase of fixed assets. Organizers are expected
to contribute time and expertise to the bank's organization and should
neither rely unduly on professional and consulting assistance nor make
excessive charges to its accounts for those services.
Payment of organizational expenses for disapproved
applications are the responsibility of the organizing group. Those expenses
for banks that do not open must be paid by the directors and organizers.
Market Area
Extensive analysis of the proposed bank's market area
is a necessary part of the application process. Rule 69U-105.206(2)(a)
states that local conditions [should] indicate a reasonable promise
of a successful operation. Applicants should determine if there does
and will exist a significant volume of business for which the proposed
state bank can realistically compete. Competition is encouraged and
does benefit consumers but must be intertwined with the objective of
maintaining a stable and safe financial institution environment for
the potential customers.
In a given market area, there may be competing applications
for a new bank charter. There may also be strenuous objections to the
issuance of a new charter in a given market. Requests for administrative
hearings on a denovo bank application may be filed in accordance with
Rule 69U-105.104, Florida Administrative Code.
Organizers should consider other entities offering
financial services in the market area, including factors such as the
distance from the proposed bank location and the types of services offered.
This information will be useful in developing a pro forma balance sheet
and income statement for the date of opening through the end of the
first three years of operation. A proposed bank in a market with a strong
local economy and weak competition has a much greater prospect of success
than where the economy is weak or the competition is strong.
Bank Location and Premises
The location of the proposed bank's main banking premises
is another important consideration. Although a market area may be identified,
the charter application cannot be filed until the proposed location
is established. Demographic information obtained by the organizers should
be helpful in identifying and prioritizing desirable locations.
The organizing group must decide whether to lease
or purchase the main banking premises. Organizers must be mindful of
the statutory limitation on their investment in fixed assets [See Section
658.67(7), Florida Statutes], and the effect that an excessive investment
in fixed assets would have on the bank's profitability. Also, organizers
must bear in mind that proceeds from the sale of stock must be held
in escrow and cannot be used before the bank opens to pay acquisition
or construction expenses of the main banking premises. Details of the
planned main banking premises, including copies of blueprints, floor
plans and leases, as well as any plans for temporary premises, must
be provided to the regulators. Construction of the banking premises
should comply with security standards set forth by federal regulation.
If the main banking premises is being built, purchased
or leased from an organizer, a proposed director, officer or principal
stockholder, then the agreements or contracts for the transaction must
be submitted for regulatory approval. Generally, at least one independent
appraisal of the property and terms of the transaction, plus any other
evidence necessary to show that the proposed transaction is fair, reasonable,
and comparable to similar arrangements that could have been made with
unrelated parties, must also be submitted [See Rule 69U-105.206(4),
Florida Administrative Code]. The agreement should also be disclosed
to stockholders.
Finally, any agreements or contracts for the purchase
or lease of the main banking premises should provide a contingency for
application approval and delays in the application and organization
process.
Capital
How much capital is enough for a new bank? Although
there are statutory minimums for state banks [$4 million in non-metropolitan
areas and $6 million in metropolitan areas], OFR will generally require
capital in excess of those minimums. Capital shall be allocated among
capital stock and paid-in surplus in the ratios set forth in Subsection
658.21(3), Florida Statutes.
Factors that are considered in determining the adequacy
of capital include: organizing expenses; earning prospects; economic
and competitive conditions in the community to be served; the experience
and competence of management; the risks inherent in the expected asset
and liability mix; the amount of fixed asset investment; and the ability
to raise additional capital when needed. The size of the community where
the bank will be located also is a significant factor in capital adequacy.
A location in a larger community generally will require greater capital.
No later than six months after commencement of corporate
existence, and at least thirty days prior to the issuance of stock,
the directors shall file with OFR a final list of subscribers to all
the capital stock as required in Rule 69U-105.206(3)(c)1, Florida Administrative
Code.
Section 658.21(2), Florida Statutes states that, in
the aggregate, the proposed board of directors must subscribe to at
least twenty-five percent (25%) of the initial shares of stock for OFR
to determine that the proposed state bank will have a reasonable promise
of successful operation.
Choice of Charter
Organizers must choose one of two commercial bank
charters -- either a Florida state-chartered bank, or a national bank
chartered under federal law. Each charter allows for performing the
general business of banking in Florida. However, because of different
enabling statutes and regulations, state banks and national banks have
some substantive differences. For example, an Florida state bank may
be, but is not required to be, a member of the Federal Reserve System.
National banks are required to be members of the Federal Reserve System
and must meet the then current legal reserve requirements in Regulation
D for member banks, and must subscribe for and purchase shares of the
Federal Reserve Bank of its district. The choice of charter may also
depend on previous experience and familiarity with the regulator. Members
of the organizing group may have previously been regulated by, and established
a relationship with, OFR or the OCC.
Formation of a Bank Holding Company
A bank holding company is any company which has control
over a bank. Generally, a company controls a bank if: it directly or
indirectly, or acting through one or more other persons, owns, controls,
or has power to vote twenty-five percent (25%) or more of any class
of voting securities of the bank; it controls in any manner the election
of a majority of the directors of the bank; or the Federal Reserve determines
that the company directly or indirectly exercises a controlling influence
over the management or policies of the bank.
The organizing group should determine whether it wishes
to establish a one bank holding company while applying for a new bank
charter. It will be necessary for the organizers to file an application
on Form Y-3 with the Federal Reserve to establish a one bank holding
company.
Name of Proposed State Bank
To avoid confusion by the public, the proposed bank's
name should not be the same as or deceptively similar to any other bank
in the state. Many bank names include a geographic reference and the
word "Bank", resulting in some similarity among bank names in any given
community. While a geographic reference may not be beneficial if a new
bank later establishes additional locations outside the referenced geographic
area, some names using a geographic reference seem to suggest a bank
is older or established.
Organizers should check with Corporations [call (850)
245-6900] to determine the availability of the proposed name. It should
be noted that Corporations no longer reserves proposed names.
S Corporation Tax Election
The Small Business Job Protection Act of 1996 removed the long-standing
prohibition against financial institutions being taxed as S corporations.
Financial institutions can now elect S corporation status effective
for tax years beginning after December 31, 1996. For tax purposes, an
S corporation passes through the stockholder's pro-rata share of taxable
income or loss to the stockholder's personal tax return. Each organizing
group should determine the bank's eligibility for an S corporation election
and the effect of the election on the bank and its stockholders.
Restriction on Interstate Mergers
Florida law prohibits a denovo bank from being acquired
by an out of state bank, until the denovo bank has existed and continuously
operated for at least three years. Because Florida has not opted into
interstate denovo branching, out of state financial institutions cannot
establish denovo branches in Florida. This law does not effect the ability
of a denovo bank to merge with or into another Florida bank.
Timing of Process
Generally, the process of organizing a new bank consists
of seven phases: 1) pre-application filing discussions; 2) application
filing; 3) application processing; 4) issuance of a final order approving
organization of the proposed state bank; 5) completion of the organization
of the bank and stock subscriptions; 6) pre-charter examination and
pre-opening procedures; and 7) issuance of charter.
Under Administrative Procedures Act time frames, OFR
must render a decision on a denovo bank application by no later than
180 days after an application has been deemed to be substantially complete.
Therefore, if an application is complete as received, the countdown
begins on the date of receipt.
It is OFR 's experience that the greatest delays in
rendering a decision on an application are generally due to incomplete
background and financial information filed by the organizers on behalf
of the proposed officers and directors. It is therefore strongly recommended
that all biographical and financial information filed with OFR be complete
when the application is originally filed, in order to ensure a timely
review of the application.
After an application to organize a state bank is approved,
the time frame for opening the bank rests with the organizing group
and their ability to satisfy any conditions of an approval order. Final
Orders typically allow one year for a proposed bank to open. Upon the
request of an organizing group, and at the discretion of OFR, an extension
of this deadline may be approved for good cause shown.
To charter a denovo state bank, Form OFR-U-1 (the
"Application") must be submitted to OFR along with the applicable filing
fee. Before an Application is filed, it is recommended that the organizers
request a pre-filing meeting with OFR. At least five individuals are
required to act as directors. Each proposed officer, director, and principal
stockholder of a denovo state bank must complete and submit Form OFR-U-10
for a background check.
The Florida Financial Institutions Code does permit
a bank holding company to be the sole shareholder of a state bank.
State Application
After the pre-filing meeting, the completed Application
must be filed with OFR. The filing fee currently is $15,000. To complete
the Application, the following information and documents must be compiled:
Name and address of the proposed bank holding company,
if applicable, or the names and addresses of the organizers.
Names of the proposed directors, chief executive
officer, senior loan officer, and cashier.
Name and address of the proposed bank.
Number of shares, par value, and the price for which
each share of stock is to be sold.
Determine aggregate amounts of common stock and surplus
and reserves for operating expenses.
Number of shares of bank stock that each organizer
intends to purchase.
Identify the amount and provide verification of the
source of funds to be used by each organizer to purchase the stock.
If assets are to be liquidated to finance the acquisition, provide a
detailed explanation. If necessary, separate schedules should be provided.
If any funds will be borrowed by the organizers or otherwise obtained
for the purpose of acquiring stock of the proposed bank, attach a detailed
description of the collateral to be pledged and the terms of the transaction,
including interest rates, amortization requirements, co-maker, guarantors,
endorsers and any other arrangements, agreements and understandings
between and among the parties. Copies of any loan commitments should
also be provided. If borrowed funds are to be obtained, indicate the
sources of funds for debt service. Additionally, explain the extent
to which salaries, dividends, fees, etc., from the bank will be needed
for debt servicing requirements.
Names and addresses of every proposed investor or
trustee of a voting trust, other than the organizers, who are expected
to own ten percent (10%) or more of the proposed bank's stock.
Form OFR-U-10, and supplements, for each organizer,
proposed director and principal stockholder, the proposed chief executive
officer, senior loan officer, cashier and all other executive officers.
Pro forma financial statements of the proposed bank.
The balance sheet should include specific categories identifying all
assets, liabilities and capital for the date of opening and the end
of each of the first three years of operation. The capital presentation
must be prepared in a risk-based format, with Tier 1 and Tier 2 capital
identified. A risk-based capital ratio and leverage ratio must be calculated
at the end of each projected year. The income statement should also
include specific categories of income and expenses for the end of each
of the first three years of operation.
Addendum to the pro forma financial statements explaining
the assumptions and strategies that will be used to achieve the projected
market share for each type of product and service.
Provide the assumptions that are used to calculate
the earnings projections. Provide a description of the proposed main
banking premises, including a summary of the cost. Describe any plans
for temporary quarters. Provide copies of blueprints and leases, if
available or applicable.
Identify all parties involved in the acquisition
or lease of the proposed site of the banking premises.
Identify any business or personal affiliations between
the seller or lessor of the property and any of the organizers, proposed
directors, officers or anticipated stockholders who will own 10% or
more of the proposed bank stock. Include copies of any sales agreements,
lease agreements and appraisals.
Provide copies of any feasibility studies conducted
for the location of the banking premises. Provide evidence that the
proposed banking premises will be in compliance with the local zoning
laws.
Provide the results of any environmental tests conducted
on the site of the proposed banking premises.
Provide a list of projected organization costs and
explain each category of expense. The list of organizational costs will
generally include filing and regulatory fees, professional and consulting
services, payroll and payroll taxes, rent, capital raising costs, printing,
postage, telephone, and office supplies.
Provide a list of the proposed salaries and benefits
for all bank officers.
Indicate whether any officers will be given employment
contracts. If so, provide copies or drafts of the proposed contracts.
Provide copies of all proposed bank policies, including
asset/liability management, bank secrecy, business plan, budget, investment
and loan.
Provide a business plan detailing the purpose, objectives,
and business philosophy of the proposed state bank.
After the application is filed, OFR begins independent
investigations of the proposed bank, assessing its capital adequacy,
its future earnings prospects, and the general character and experience
of its management.
Should all statutory requirements to establish a state
bank be met or can be met through compliance with certain conditions,
OFR will issue a Final Order approving the state bank application. The
Final Order will be issued within 180 days from the date of acceptance
of a substantially complete application. The Final Order does not enable
the proposed state bank to commence business.
Federal Application
For state chartered banks, the Florida Financial Institutions
Code requires that deposit insurance be maintained with the FDIC. Proposed
state banks must file an application for deposit insurance with the
FDIC.
Post-Application Organization and Charter
After this organizational process, OFR will conduct
an examination to confirm that no intervening circumstance has occurred
to change OFR 's findings made in Final Order and that all conditions
of such Order have been satisfied. Assuming no adverse changes, the
FDIC will be notified that a charter will be issued. The FDIC will have
independently notified the proposed state bank and OFR whether deposit
insurance will be provided. The FDIC will issue its certificate of deposit
insurance immediately prior to the scheduled opening date for the bank.
Raising Capital
The concern of bank regulators for the soundness of
the banking industry is evident in the requirements imposed on raising
capital. The organizing group must plan to raise capital sufficient
to support the projected growth of the proposed bank.
Securities Law Issues – Banks
The initial offering of subscriptions for the shares
of a new state bank is exempt from the registration requirements of
the Florida Securities and Investor Protection Act when an application
for a state bank has been deemed complete by OFR, and OFR has reviewed
the offering circular. Bank securities are also exempt from the federal
Securities Act of 1933 and the Securities Exchange Act of 1934, unless
the 1934 Act applies because the proposed bank will have five hundred
or more stockholders. Generally, an offering circular should identify
permissible investors and tell them how to subscribe; identify risk
factors involved in a denovo bank; provide certain projected financial
information; describe the offering and how proceeds of the offering
will be used; describe the business of the bank and state the material
effects that compliance with state and federal banking laws will have
on the bank's operations; identify the organizers, directors and executive
officers; and disclose any transactions with insiders.
Securities Laws Issues - Bank
Holding Companies
Bank holding companies are corporations organized
under state law, and the issuance of bank holding company stock is not
covered by the exemption under state and federal securities laws for
banks.
List of Actions to Perform
The following is a list of actions that should be
performed by an organizing group as part of the start-up process. It
is not in "chronological" order, nor should it be considered all-inclusive.
Obtain final approval from State/FDIC/Federal Reserve.
Send notice of proposed opening date to State/FDIC/Federal
Reserve.
Establish service charges, fees, and rates.
Review products and services.
Establish: corporate policy, personnel policy, general
accounting (charts of accounts, expense, control, signing authorities,
etc.), credit/commercial/ consumer loan policies, investment policy,
trust policy/procedures, corporate compliance.
Identify and obtain staff members.
Train staff on polices and procedures.
Obtain directories: internal telephone directory,
internal corporate telephone directory, bank directory, city directory,
bank operations contact list, zip code directory.
Provide bank operations overview.
Insure that head teller: records bait money numbers,
orders adequate opening cash/currency.
Establish cash/currency limits for: banking office,
each teller.
Arrange for signing and operating authorities.
List distribution of all keys and establish key control
records.
Order business cards for personnel as appropriate.
Order/install equipment: PCs/printer, teller terminals,
microfiche viewer, copy machine, adding machine, shredder, currency
counter, cash drawer trays, safe deposit vault clock, micro-film machine,
encoder, typewriters.
Order letterhead stationery and envelopes with bank
logo.
Establish control records for negotiable instruments:
travelers checks, cashiers checks, counter checks.
Prepare marketing program: marketing strategies,
necessary publicity, advertisements.
Opening ceremonies.
Advertising and services stand (lobby display rack
with initial supply of brochures).
Develop budgetary projections.
Prepare and implement business development plan and
public notification.
Obtain appropriate permits, licenses and posters:
U.S. Department of Labor, OSHA, Federal Wage and Hour Law, Equal Employment
Opportunity, Age Discrimination Law, Workers Compensation Law, Occupational
License.
Order safe deposit supplies: forms, safe deposit
key, set-up in system.
Meet vendors to make arrangements as necessary.
Select and order supplies.
Order starter kit supplies, forms, etc.
Secure paying and issuing agent number for Series
EE Bonds.
Secure designation as depository for TTL and order
necessary supplies.
Order bags and agreements if office will have courier
and/or night depository service.
Procure sample checkbooks, order/reorder stamps and
supplies and other vendor materials.
Establish appropriate system security levels for
personnel.
Assign teller numbers and order stamps.
Train tellers, platform personnel, etc. on: products
and services, teller procedures, operations procedures/instructions,
price schedules, equipment usage, systems capabilities.
Arrange report distribution.
Coordinate insurance requirements: blanket bond coverage,
liability coverage, building and contents coverage, plate glass, if
necessary.
Display state charter in conspicuous location.
Coordinate internal signage: obtain FDIC door and
teller window signs, FDIC plaques and certificate in place.
Arrange for mail service and postage matters.
Mail supplies, forms and equipment.
Obtain certified number(s) from post office.
Courier service.
U.S. Mail pick-up and delivery.
Registered, certified mail processing.
Internal mail processing.
Arrange for armored car service and establish cash
ordering/shipping procedures.
Order all requisite security equipment: obtain security
system, alarm and burglary protection, perimeter alarm, hold-up alarm,
cameras, security guard, after-hours security.
Notify police of proposed opening date.
Implement and train staff on security program and
specific procedures such as hold-up, robbery, office opening/closing,
fraud, etc.
Supervise and complete construction.
Equip bank with the following: carpet, chairs, clocks
(wall), desks, desk supplies, calendars, pencil cups, waste baskets,
drapery/venetian blinds, planters and vases, safe/vault and related
equipment, telephones, kitchen supplies, kitchen furniture, china, silverware,
appliances, tables.
Arrange for telephones and service.
Arrange for electricity and water service.
Develop and supervise signage installation: outdoor
site and/or building signs, lobby signs, banking hour signs.
Arrange for building and landscape maintenance services.
Financial Institution Regulation
Through OFR, state-chartered financial institutions
are licensed, examined and regulated to ensure that private funds invested
in Florida's state-chartered financial institutions are protected from
potential loss due to failure or insolvency. OFR has regulatory authority
over state-chartered commercial banks, credit unions, savings associations,
non-deposit trust companies, international banking agencies, representative
and administrative offices. Nationally or federally chartered financial
institutions are chartered and regulated by various agencies of the
federal government and the OFR does not have regulatory authority over
those entities. OFR processes all applications for new banks, savings
associations, foreign banks, trust companies, and credit unions. Applications
for acquisitions, mergers, cross-industry conversions, changes of control,
requests for trust powers, purchase and assumptions, branches, and office
relocations are also processed through OFR.
OFR is also responsible for non-regulatory activities,
including technical staff training, all budgetary, purchasing and revenue
issues, drafting legislation and rules, monitoring federal legislative
initiatives, maintaining analytical and statistical information, preparing
special research projects, and office automation.
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