Enclosed is a list of names, addresses and shareholdings of the thirty largest shareholders of record as of March 15, 1972, the record date for our most recently declared dividend. On that same date, there were 1,919,569 shares of voting common stock outstanding, which is the only authorized class of capital stock, and which was listed in the names of 11,853 shareholders of record. The largest single record holder, Olsen & Co., is a nominee of our own National Shawmut Bank of Boston, Trust Department, and represents principally shares held for 868 employees of affiliated banks in the holding company under profit sharing and stock purchase plans. In addition, there are several listings of other nominee names used by banks which we have reason to know represent shares beneficially owned by individuals. The list includes the names of 16 savings banks or nominee names used by savings banks. Overall, 156 savings banks own about 15 percent of the Corporation's outstanding shares. We have omitted the name of an individual stockholder owning 5,460 shares, since we have not been able to contact him for permission to disclose his name. Sincerely, H. EDWARD REED, 30 LARGEST STOCKHOLDERS AS OF MARCH 15, 1972 Number of shares 24, 206 19, 812 Holder Olsen & Co., P.O. Box 4044, Boston, Mass- Mass The Commonwealth of Massachusetts, State Employees Gastown, Inc., 622 State St., Springfield, Mass. Merrill Lynch, Pierce, Fenner & Smith, Inc., 70 Pine St., Eliot Savings Bank, 165 Dudley St., Boston, Mass- Mass. 14, 900 14, 455 13, 900 11, 900 11, 200 11, 109 11,000 10, 650 Hare & Co., care of the Bank of New York, Bank Window, Church Street Station, New York, N.Y. Gerlach & Co., care of First National City Bank, 20 Ex change Pl., New York, N. Y. Amoskeag Savings Bank, Manchester, N.H.. Mass Lisco, care of Lynn Institution for Savings, 270 Union St., Lynn, Mass.. Lynn Five Cents Savings Bank, Lynn, Mass. Ince & Co., Church Street Station, P.O. Box 1479, New Calif.. 10,380 10,200 9,320 8,761 8,500 Savings Bank of Danbury, Danbury, Conn- Cambridge, Mass. East Boston Savings Bank, attention: R. E. Turpin, County, 58 Suffolk St., Holyoke, Mass Berkshire County Savings Bank, Pittsfield, Mass.- 7,111 7,030 7,000 7,000 6,850 6,600 6,500 6,440 6,131 6,000 6,000 5,290 5,222 5,000 5,000 5,000 UNIONAMERICA MAY 18, 1972. DEAR SENATOR METCALF: I am responding to your letter of May 9, 1972 addressed to Mr. Robert H. Volk in which you request certain information regarding our Company's shareholders. This information is not available as a matter of public record. I'm sure you will appreciate the need to keep our individual stockholdings confidential and understand that we have a fiduciary responsibility to our shareholders to protect this confidentiality. Our by-laws restrict the availability of this type of information even to our own shareholders. One of the restrictions in our by-laws is that the shareholder must show a purpose reasonably related to his or her interests as a shareholder. As no such purpose is indicated by your letter, we must respectfully decline your request. Sincerely yours, RICHARD D. FARMAN, U.S. BANCORP MAY 22, 1972. DEAR SENATOR METCALF: This is in response to your letter dated May 9, 1972, requesting a list of the 30 major shareholders of U.S. Bancorp and the amount of stock held by each. The information you have requested is confidential and our legal counsel has long advised us that our duty to our shareholders does not permit us to release such data. I can tell you, since it is a matter of public record, that the total issued and outstanding common stock of U.S. Bancorp consists of 4,080,257 shares, of which 30,000 shares are currently held by this corporation as Treasury stock. I regret that we are not able to give you the other information you have requested. Sincerely, LEROY B. STAVER, WACHOVIA CORPORATION Chairman. JUNE 1, 1972. DEAR SENATOR METCALF: Thank you for your letter of May 9, 1972, requesting certain information concerning stockholders of this corporation. Wachovia considers the information requested regarding a list of the top thirty stockholders of our corporation to be confidential, and that we have a fiduciary responsibility to our stockholders to protect this confidentiality. Thus, we regret that we cannot supply such a list. I am, however, enclosing for your information our most recent Proxy Statement and direct your attention to page 4 thereof entitled "Voting Shares of Wachovia" for a publicly available discussion of our stock ownership.' I trust that this information will be of use to you. In answer to your other request, the total number of shares of voting stock of this corporation outstanding as of June 1, 1972 is approximately 10,562,886 shares of $5.00 par value voting Common Stock (taking into consideration the additional shares issued pursuant to our recent 2-for-1 Common Stock split) and approximately 1,926,863 shares of $5.00 par value voting Cumulative Convertible Preferred Stock. Very truly yours, 1 Retained in committee files. MICHAEL J. MULRONEY, WELLS FARGO & COMPANY thirty persons shown by our records to be the largest JUNE 9, 1972. holders of our stock, a request for permission to disclose DEAR SENATOR METCALF: This is in reply to your letter to you their identity and the amount of their holdings. of May 9, 1972 requesting a list of our 30 top stockholders, We will promptly give you the information you ask to the amount of common stock each holds, and the total the extent permission to do so is granted by these stock holders. number of voting shares of common stock. We trust that the information given herein will be of Absent a subpoena, we are reluctant to identify the assistance to you and we regret our inability presently stockholders by name. However, we are pleased to give to furnish the additional data you request. you the list of our 30 top stockholders by substituting for the names a description of the stockholders, such as Sincerely, CLIFFORD TWETER, President. "bank nominee", "insurance company" or "individual”. We believe that supplying you with this information in VI. INSURANCE COMPANIES CNA FINANCIAL CORPORATION May 16, 1972. List of 30 TOP STOCKHOLDERS AS OF MARCH 31, 1972 DEAR SENATOR METCALF: Your letter of May 8 Number of addressed to Mr. Jacque Sammet, President of the Holder shares Continental Assurance Company, has been referred to Bank nominee. 481, 134 Do.. 250, 000 my office. Do... 190, 937 Continental Assurance Company is a wholly-owned Do.. 176, 806 subsidiary of CNA Financial Corporation; therefore, in New York Stock Exchange.. 168, 400 Bank nominee. 162, 043 response to your specific question, there is but one stockDo. 149, 047 holder in Continental Assurance Company and that is Do.. 142, 887 CNA Financial Corporation. CNA Financial Corporation Insurance company 110, 000 has 33.8 million shares of Common stock outstanding. Bank nominee 98, 514 This stock is widely held and a list of the 30 top stockDo.. 88, 063 Insurance company. 86, 625 holders would include substantially all nominee and street Bank nominee 85, 572 names. Do... 84, 561 I trust the foregoing is responsive to your inquiry. Do... 78, 700 Do... Respectfully, 71, 115 Individual.. 70, 951 THOMAS R. IGLESKI, Secretary. Bank nominee. 58, 167 Individual.. 53, 000 Bank nominee. 49, 000 Doc. CONNECTICUT GENERAL INSURANCE CORPORATION 46, 069 Insurance company 44, 400 May 25, 1972. Do... 42, 000 Bank nominee. 40, 000 DEAR SENATOR METCALF: Mr. Roberts has asked me Do. 39, 359 Corporation. to respond to your letter of May 8. We have 17,982,639 39, 200 Bank nominee. 36, 258 shares of capital stock (all common) outstanding, of Do.. 36, 104 which 17,957,160 are entitled to be voted. We have Do.. 35, 525 approximately 20,900 stockholders. Stock broker.. 35, 509 We feel we must decline your request for a list of our Note.-Common stock, $10 par value as of May 31, 1972: top 30 stockholders and the amount of stock held by Authorized, 12,000,000 shares; issued 9,287,040 shares. each. We can tell you that as of a recent date the top 30 included three individuals, all of them long-time residents WESTERN BANCORPORATION of Hartford, two state retirement systems, and an invest ment banking house, some of whose shares are undoubtedly May 23, 1972. held for the benefit of other persons or interests. All the DEAR SENATOR METCALF: This will acknowledge receipt rest were bank nominees. In fact, some 68 percent of our of your recent request for a list of the thirty top stock- voting shares are registered in nominee name, with a preholders of this Corporation, the number of shares held dictable concentration in the nominees of the larger banks. by each, and the total number of voting shares out- There is nothing surprising about this. Our stock has standing long been considered a prime investment for various This Corporation has issued but one class of stock, and types of trust funds, and is also held by several mutual at February 11, 1972, the record date for the 1972 annual funds and certain other types of substantial institutional meeting of stockholders, there were 22,871,074 shares investors. This necessarily means that the trust departoutstanding. A few shares have been issued since that ments of many of the largest banks in this country hold date, and if you wish a more recent figure, we can advise large amounts of our stock, much of it in a fiduciary you of the number of shares outstanding on June 2, capacity, some of it in a custodial capacity, and virtually 1972, the record date for the next dividend, as soon as all of it in nominee name. The same is true, of course, of the information becomes available. the stocks of many other large corporations, and this We consider the identity of our stockholders and the situation was reflected very clearly in the facts you recited amount of their holdings to be confidential information in your April 25 remarks in the Senate, to which you in our hands, and not subject to disclosure in the absence referred in your letter. of legal requirement or permission given by the stock- Sincerely, holders. Accordingly, we are forwarding to each of the W. L. WILKINSON, Secretary. EQUITABLE LIFE INSURANCE COMPANY OF IOWA LIBERTY NATIONAL LIFE INSURANCE COMPANY May 12, 1972. May 12, 1972. DEAR SENATOR METCALF: Your letter of May 8, 1972, DEAR SENATOR METCALF: I have your letter of May 8 to Mr. K. R. Austin has been referred to me. requesting a list of the 30 largest stockholders in our This Company was originally founded in 1867 by Fred- company and the amount of common stock held by each. erick M. Hubbell, a pioneer Des Moines capitalist. During I am sorry to say that it is not our policy to release this his lifetime, Mr. Hubbell created an inter vivos trust and information since we consider it to be the private business assigned to that trust most of his stock holdings in the of the stockholders themselves. Company. The beneficiaries of the Hubbell Trust were You also inquire as to the total number of voting shares Mr. Hubbell, who is long since deceased, and his lineal of common stock. This number is 15,027,644. descendants. The Trust is still in existence, but will ter Very truly yours, minate by its terms in 1983, at which time the corpus of the FRANK P. SAMFORD, Jr., President. Trust will be distributed to Mr. Hubbell's lineal descendants per stirpes and not per capita. There are over seventy such lineal descendants. LIFE AND CASUALTY INSURANCE COMPANY OF At the present time, the Trustees of the F. M. Hubbell TENNESSEE Estate own 68.9 percent of the outstanding common stock of the Company, and individual members of the Hubbell May 11, 1972. family, all descendants of Mr. Hubbell, or trusts created DEAR SENATOR METCALF: In reply to your letter of by them for the benefit of their descendants, own an additional 16.1 percent. The remaining 15 percent of the May 8 I wish to advise as follows: That total number of voting shares of this corporation issued and outstanding stock was recently sold in a secondary offering. If you are 22,680,000 shares of common stock. All of these would like a copy of the prospectus, I would be pleased shares are owned by American General Insurance Comto send it to you on request. pany, 2727 Allen Parkway, Houston, Texas 77019. Sincerely yours, Very truly yours, ALLEN M. STEELE, President. LIFE INSURANCE COMPANY OF VIRGINIA May 15, 1972. DEAR SENATOR METCALF: Franklin Life has 21,007, DEAR Senator METCALF: I acknowledge your letter of 853 shares of capital stock outstanding, of which 14,518 of the Life Insurance Company of Virginia, requesting May 8, 1972, addressed to Mr. Warren M. Pace, President shares are held as treasury stock owned by the company. a list of the 30 top stockholders of this Company and their Our largest stockholder is the Continental Corporation of New York, which owns 5,711,624 shares. This holding holdings along with a total number of voting shares of Common Stock. is a matter of public record through the Annual Report of the Continental Corporation. As of December 31, 1971, Life of Virginia had issued and We have long regarded the holdings of an individual outstanding 3,523,912 shares of voting Common Stock. stockholder as a private matter, to be disclosed only with Of this amount 99.5 percent is owned by a single shareholdthe consent of the stockholder. I can tell you, however, er, Richmond Corporation. Sincerely yours, that the second largest holding of Franklin stock amounts J. MAURICE MILLER, Jr., to 276,669 shares or 1.32 percent of the total and that the Senior Vice President. third largest stockholder owns 263,347 shares or 1.25 percent of the total. The latter account is a major brokerage house, who according to my latest information holds the stock in street name for over 1,200 customers. LINCOLN NATIONAL LIFE INSURANCE COMPANY Cordially yours, MAY 30, 1972. GEORGE E. HATMAKER, President. DEAR SENATOR METCALF: We are pleased to respond to your letter of May 8 addressed to our President, Mr. Thomas A. Watson, and asking us to furnish you with a JEFFERSON STANDARD LIFE INSURANCE COMPANY list of the 30 top stockholders in our Company and the MAY 17, 1972. amount of common stock which each holds. Dear SENATOR METCALF: In your letter of May 8, 1972, Several years ago the stockholders of The Lincoln you asked for a list of the thirty top stockholders of National Life Insurance Company exchanged their stock Jefferson Standard Life Insurance Company and the Corporation which is now the parent company and the on a share for share basis for shares of Lincoln National amount of common stock held by each, and the total sole stockholder of The Lincoln National Life Insurance number of voting shares of common stock. All of the com Company. mon stock of Jefferson Standard Life Insurance Company is owned by Jefferson-Pilot Corporation. During 1971 Lincoln National Corporation had approxFor your information I am enclosing copy of the latest imately 10,002,021 common shares outstanding, including proxy statement of Jefferson-Pilot Corporation.' Sincerely, shares of $3 Cumulative Convertible Preferred stock W. ROGER SOLES, President. which had equal voting rights. For purposes of further information, a copy of the annual report for 1971 of Lin1 Retained in committee files. coln National Corporation is enclosed.' We also enclose a copy of a recent news release which tells of a stock split OCCIDENTAL LIFE OF CALIFORNIA which will be effected during June. Regarding the disclosure of specific information con May 24, 1972. cerning individual holdings, we have always treated this DEAR SENATOR METCALF: This is in response to your information as private and confidential, and we would letter of May 8, 1972 requesting certain information with hope to be allowed to continue in this capacity in accord respect to our common stock and stockholders. Occidental with the fiduciary responsibility which we believe that the Life Insurance Company of California is a wholly-owned Corporation holds. subsidiary of Transamerica Corporation. All shares of our Sincerely yours, ALLEN C. STEERE, voting common stock are held by Transamerica Insurance Senior Vice President. Corporation of California which is wholly owned by Transamerica Corporation. Please let me know if you have further questions. NATIONWIDE CORPORATION Sincerely, MENO T. LAKE, President. May 22, 1972. DEAR SENATOR METCALF: This is with reference to your letter of May 8, 1972, regarding the shareholders of Nation- PROVIDENT LIFE AND ACCIDENT INSURANCE COMPANY wide Corporation. Nationwide Corporation has outstanding two classes of common shares. On March 13, 1972, the May 15, 1972. record date for the most recent annual meeting of share DEAR SENATOR METCALF: Chairman H. C. Unruh has holders, there were outstanding 4,710,397 Class A Com- asked me to reply to your letter of May 8, requesting a mon shares and 5,506,593 Class B Common shares. list of the 30 top stockholders of our Company, and the All of the Class B Common shares are owned by Nation- amount of common stock held by each. wide Mutual Insurance Company (5,025,807 shares) and Our stockholder list and the amounts of stock held by Nationwide Mutual Fire Insurance Company (480,786 each are confidential matters, and we feel that divulging shares). The Class A Common shares are publicly held, this information, other than as provided by law, would and on March 13, 1972, there were 15,678 shareholders of constitute a breach of our fiduciary relationship with our record. Each class of shares has one-half of the voting shareholders. powers and rights of the Corporation as a class, except in The only provision of Tennessee corporate law dealing the election of directors. Presently, each class elects one with this subject, Section 48-717, Tennessee Code Annohalf of the members of the Board of Directors. tated, provides for inspection of our stockholder list only With respect to the Class A shareholders, it is the policy by a stockholder, upon his written request, and we regret of the Corporation to keep the shareholders' names confi- that we are therefore unable to comply with your request. dential. The Ohio General Corporation Law provides that In response to the other inquiry in your letter, we are a shareholder may examine the shareholder list for a pleased to advise that our Company has 3,937,472 outreasonable and proper purpose. It is the opinion of our standing shares of common stock. counsel that this requires the Corporation to not make such Very sincerely yours, information public, except in accordance with the statute. DUDLEY PORTER, Jr., Of the thirty largest shareholders of Class A Common Vice Chairman of the Board and Senior Counsel. shares as of March 13th, twenty-four were nominee accounts and brokerage firms. Very truly yours, SOUTHWESTERN LIFE INSURANCE COMPANY May 17, 1972. requesting a list of the top thirty stockholders of this NORTHWESTERN NATIONAL LIFE INSURANCE COMPANY Company, the amount of common stock each holds and the information as to the total number of voting shares of MAY 25, 1972. common stock. DEAR SENATOR METCALF: I am replying to your letter of One item of this information I can give you without any May 8 in which you asked for a list of the 30 top stock- problem and I gladly do so. The total number of voting holders in our company, the amount of common stock each shares of this Company is 10,330,667. holds, and the total number of voting shares of common With respect to your request for a list of the thirty top stock. stockholders in our Company and the amount of stock As a matter of Company policy, we do not disclose the each holds, I have discussed this matter with our General names of our stockholders without their consent because Counsel. He advises me that in his opinion our list of we consider this information to be confidential. stockholders is confidential and that the stockholders You may not be aware that our company is a stock and have a right of privacy with respect to that information, mutual company with both stockholders and participating subject always to our compliance with the law. He further policyholders having the right to vote. At our last annual advises me that it would not appear that your request is meeting held in April of this year, stockholders were en- predicated upon any existing law that he is aware of, but titled to 220,000 votes while policyholders were that if he has overlooked any item he will be most willing titled to 1,790,000 votes. Actual votes represented at the to check out any legal authority which might indicate that meeting were 164,403 votes for stockholders and 423,327 we are legally required to disclose the information that votes for participating policyholders. you request. I must, therefore, respectfully decline to furnish the information requested because of its confidential nature. 1 Retained in committee files. If there is some provision in law which, in your opinion, en requires this disclosure, please do not hesitate to advise TRAVELERS INSURANCE COMPANIES me and I will take it up with our General Counsel; and you may be assured of our full cooperation consistent with the May 22, 1972. duty that we owe our stockholders. MY DEAR SENATOR METCALF: In reply to your letter Respectfully, of inquiry of May 8th, I am pleased to report that the W. H. SEAY, President. total number of shares outstanding of The Travelers Corporation common stock as of April 28, 1972 is 45,098,926, not including our Treasury Shares. The numTEACHERS INSURANCE AND ANNUITY ASSOCIATION OF ber of Issued Shares as of April 28, 1972 is 45,201,533, AMERICA COLLEGE RETIREMENT EQUITIES FUND including 102,807 held in the treasury or by a subsidiary. I am attaching a list showing the thirty largest stock May 18, 1972. holders and the total number of shares held by each as of DEAR SENATOR METCALF: I have your letter to our April 28, 1972. president requesting information about stockholders of I trust this information is responsive to your request. Teachers Insurance and Annuity Association (TIAA). Sincerely, There is only one stockholder, a Special Act membership ELI SHAPIRO, corporation called "Trustees of T.I.A.A. Stock”. This Chairman, Finance Committee. came into being in 1937 for the purpose of receiving from the Carnegie Corporation all of the nonprofit stock of 30 LARGEST STOCKHOLDERS AS OF APRIL 28, 1972 TIAA, to be held in trust for the college community. Number There are 1,000 shares of capital stock. Holder of shares TIAA is a limited-eligibility, nonprofit service organiza Johnson & Co.-- 1, 576, 430 Kane & Co. tion through which colleges, universities, independent 1, 041, 487 Stuart & Co.. schools and other nonprofit and tax-exempt educational 903, 196 Carson & Co... 839, 620 and scientific institutions provide retirement and insur- Perc & Co. 800,000 ance benefits for their staff members. TIAA was founded Cede & Co. 789, 684 Schmidt & Co.. in 1918 by the Carnegie Corporation and The Carnegie 783, 104 Touchstone & Co. Foundation for the Advancement of Teaching. It devel 740, 000 Carothers & Clark.. 650, 000 oped, through the cooperation of the educational institu- Lerche & Co.- 633, 834 tions, statesmen, life insurance experts, economists and Reing & Co.-- 490, 500 others, a nationwide benefit program limited to the Bark & Co.-- 485, 000 Harwood & Co.. nonprofit educational field. Today, more than 2,400 477, 900 New York State Teachers Retirement System. 457, 700 institutions of learning, and more than 350,000 staff Calpers & Co. 450,000 members participate in the TIAA program. Elm & Co... 376, 171 “Trustees of T.I.A.A. Stock” was incorporated by the Sigler & Co.. 347, 307 Ince & Co. New York Legislature in 1937 (Chapter 880 of the Laws 347, 106 Atwell & Co. 331, 418 of New York). The purpose of the corporation is to for- Merrill Lynch, Pierce, Fenner & Smith, Inc.- 318, 533 ward the cause of education and promote the welfare of Cudd & Co. 295, 028 Parness & Co. the teaching profession (a) by acquiring the stock of 290, 489 Emp & Co. Teachers Insurance and Annuity Association of America, 261, 950 Dike & Co. 254, 904 a corporation organized and existing under article two The State Teachers Retirement Board of Ohio. 247, 500 of the New York state insurance law, whose purpose is Dart & Co 237, 002 to aid and strengthen non-proprietary and non-profit- Lynn & Co. The Standard Investment Co. 230, 000 making colleges, universities, and other institutions 225, 000 Barnett & Co. 224, 500 engaged primarily in education or research work by pro Saul & Co. 221, 614 viding annuities and life insurance suited to the needs of such institutions and of the teachers and other persons employed by, them on terms as advantageous to the UNITED BENEFIT LIFE INSURANCE COMPANY holders and beneficiaries of such contracts and policies as shall be practicable, and by counselling such institutions May 15, 1972. and their employees concerning pension plans or other DEAR SENATOR METCALF: Your letter of May 8, 1972 measures of security, all without profit to the corporation to Mr. Gale E. Davis, President of our Company, has or its stockholders, and (b) by administering the stock of been referred to me for reply as the Corporate Secretary said association in such manner as in the judgment of the trustees of the corporation hereby formed will best ensure in charge of the stock books of the Company. The total number of voting shares of common stock the continued accomplishment of the above-mentioned outstanding at this time is 600,000. There is no treasury purposes of said association. stock. There is no preferred stock. The present Trustees of T.I.A.A. Stock are listed at the It is a well publicized fact and included in the Notice top of the inside cover of the TIAA-CREF annual report and Proxy material of our Annual Meeting of Stockenclosed. This Special Act corporation owns no other holders that Mutual of Omaha Insurance Company, as stock and is, itself, a nonprofit, charitable corporation. of December 31, 1971, owned over two-thirds or 70.18 perRespectfully yours, cent of all the stock of United Benefit Life Insurance CLARENCE E. GALSTON, Company. This one account involved 421,083 of the outExecutive Vice President and General Counsel. standing 600,000 voting shares. We regard the identification of stockholders as privi* Retained in committee Ales. leged and confidential and, therefore, not available without |