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incorrect practices, which occur through ignorance or inexperience, are developed by these reports, and timely warning and suggestion from the Comptroller's office are all that is necessary to prevent recurrence.

The items which are most frequently omitted from the schedules are the following:

Bad debts, as defined by section 5204, Revised Statutes. Other suspended and overdue paper.

Liabilities of directors (individual and firm) as payers.

Under the first of these three the bank is required to state, not debts that are actually worthless, but all such as are technically "bad debts" as clearly defined by section 5204. The amount of "bad debts" on the books of a bank has a very important bearing on its condition, for if this exceeds the sum of its surplus fund and net undivided profits, it is an indication that its capital may be impaired.

The schedule of "stocks, securities, judgments, claims, etc.," should clearly show the different items composing the total of these, and is intended to embrace only such items as are owned by the bank. Any such items held as collateral for loans should not be entered here, but in the

appropriate place in schedule of "loans and discounts." No real estate items should be entered here, but in the schedule for "loans and discounts," if held as collaterals, and in schedule for "other real estate and mortgages owned," if owned by the bank. In this latter schedule, as also in the schedules provided for listing "loans and discounts, secured by mortgages or other real estate security," it is important to state how and when such investments or collaterals were acquired, in order to show whether they were acquired in conformity to provisions of section 5137, and whether they have been held longer than five years.

In a great many cases replies from the banks show that no entries are to be made in the schedules left blank, but as it is impossible to infer this from the face of the report in the case of bad debts, overdue paper, liabilities of directors, and excessive loans, it is necessary to address a letter of inquiry to the bank in each case. For this reason a note in red ink is printed conspicuously on the back of the report, requesting the bank to "fill all schedules, writing in the word 'none' wherever no amount is to be entered."

Verification and Attestation.

After seeing that a report of condition has been properly filled out, both with regard to the items of "resources" and "liabilities" on its face and the schedules on the back, it is necessary to see that it is signed, sworn to, and attested as required by law. It must be signed either by the president or cashier, as no other officer is empowered by section 5211 to do this, and attested by three directors, as required by the same action. The officer signing the report, if a director, should not sign in attestation of his own signature, as it is hardly to be supposed that this was contemplated by the law; and finally the officer signing should swear to it before a notary public, or other officer having an official seal, and authorized to administer oaths, as required by the act approved February 26, 1881. As this act provides that the officer administering the oath should not be "an officer of the bank," the oath should not be administered by a director acting in that capacity, for the reason that in section 5497, enacted prior to the act of February 26, 1881, a director is evidently regarded as an officer, inasmuch as the following language is used: "Every presi

dent, cashier, teller, director, or other officer of any bank or banking association."

How to Proceed in Absence of Three Directors, or of both President and Cashier.

Should it ever happen that the signatures of three attesting directors required by law can not be procured within five days after receipt of report blanks, or should it be impossible to obtain the signature of either the president or the cashier in time, through the absence or disability of both these officers, all that can be done is to make up a temporary report signed by some other officer, attested by the signatures of as many directors (not over three), as it is possible to obtain, and promptly forward this to the Comptroller within the five days allowed. In such cases, a letter explaining the circumstances should always accompany the report, and a complete report, made up in all respects as required by law, should be forwarded to him at the earliest possible day thereafter

Penalty for Delay in Forwarding Reports.

It will be observed that section 5213 prescribes a penalty of $100 a day for each day's delay beyond the period named for forwarding reports of condition,

and for this reason particular care should be taken to forward these reports to the Comptroller's office "within five days after the receipt of a request or requisition therefor from him;" that is, within five days after the date upon which the "call" and report blanks are received by the bank.

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