regulatory equality in the provision of fiduciary services.

One last

note, the provision of trust services requires considerable professional

skill and experience.

The Congress should exercise due caution in opening

up this new area to an entirely new class of financial institutions. In fact in view of the action taken by the Congress last year in authorizing the Comptroller to issue national association charters for trust powers only we urge the Committee to consider striking Section 302 leaving it up to the savings and loan associations to seek trust charters from the Comptroller for trust subsidiaries. The Comptroller already has in place the processes and procedures to consider such applications and the staff to supervise and examine such subsidiaries if trust powers are granted. This approach would provide protection for trust beneficaries of savings and loan associations

and equal regulations between competing financial institutions including capital and surplus requirements.

APPENDIX C

APPENDIX C

ANALYSIS OF STATE

USURY STATUTES

This chart is intended to present an overview of the law in each state and the
District of Columbia placing an interest rate ceiling on mortgage loans. The
format displays the maximum contract rate for individuals, unincorporated
businesses, and corporations, respectively. EXCEPT AS NOTED UNDER THE
FHA/VA OR CONVENTIONAL MORTGAGE COLUMNS, THE INDIVIDUAL
CONTRACT RATE IS APPLICABLE TO HOME MORTGAGE LOANS. In addition
to the rates noted herein, state chartered banks in a number of states are
expressly authorized to charge rates permitted to national banks pursuant to 12
U.S.C. §85. The chart makes no attempt to detail the specific loan rates for the
wide variety of personal loans such as bank installment loans, loans by licensed
lenders, and the like.

The figures given are annual interest rates, with the entry N/L as an abbrevia-
tion for "No Limit." "UCCC" refers to the Uniform Consumer Credit Code.
Individual contract rates in those states which have adopted the UCCC or a
variant are those applicable to consumer loans by non-supervised, non-
regulated lenders. Citations listed under the name of each state are
supplemented by a notation under a particular entry where appropriate.

Office of the State Legislative Counsel
American Bankers Association

THIS CHART IS INTENDED TO PROVIDE AN OVERVIEW AND NOT A DEFINITIVE ANALYSIS OF THE LAW IN EACH STATE.

Copyright May. 1979, American Bankers Association All rights reserved.