Requests for the names of top stockholders and amounts of holdings went from Senator Metcalf to the 50 largest banks in 1970 based on assets. Twenty-four of the 50 declined to provide any of the information requested, mostly due to reasons of confidentiality. Frequently cited as authority for not supplying the information were the National Banking Act (12 U.S.C. 484), and regulations of the Comptroller of the Currency (Ruling 7.6025), which limit the disclosure of bank records by banks to anyone other than the Comptroller of the Currency except as authorized by law.

Nevertheless, nine banks did provide the information requested, including three of the 10 largest banks in the United States which also happen to be three of the six largest banks in New York City. Thus it would appear that there was, to say the least, considerable divergence of interpretation as to what barriers, real or imaginary, exist in providing the information requested. It may also be of interest to note that two of the nine fully reporting banks are in Dallas, Texas, where the county requires banks to file a certified list of shareholders which then becomes a matter of public record.

PARTIAL RESPONSES

Eleven of the banks provided very limited information, information they believed might be helpful without at the same time being specific as to particular holdings. Thus the Bank of America, the largest bank in the United States, indicated that no shareholder held more than 6 percent of the 69,003,590 outstanding shares, with the largest block of shares, 3,855,576, or 5.6 percent of the outstanding shares held by a trustee in trust for the employees of the bank.

Chase Manhattan, the third largest bank, did not name the 30 top holders of its stock, but did indicate the amount held by type of holder, e.g., bank nominees, insurance companies, brokers. From the data it supplied the following information can be gleaned: of the total of 31,881,747 common shares outstanding, 6,508,219, or 20.0 percent were held by the top 30 holders as follows:

J. P. Morgan & Co., reporting somewhat along the lines of Chase Manhattan, but not in as much detail on an individual account basis, disclosed that 4,871,000 or 27 percent of the 18,267,207 shares of the company were held by the top 30 stockholders. These 30 stockholders consisted of 17 nominees of 10 commercial banks, the nominees of three insurance companies, a nominee of the Stock Clearing Corporation (Cede & Company), two insurance companies, a stock exchange member firm, and five nominees of Morgan Guaranty Trust Company of New York, a wholly owned subsidiary of J. P. Morgan & Co., Inc. Charter New York Corporation indicated that the two largest holders of its shares were a nominee for a national securities exchange (almost certainly Cede and Company), with 300,433 or 4.1 percent of the total of 7,210,028 shares outstanding, and a bank nominee with 250,000 shares, about 3.4 percent. No other entity owned as much as 100,000 shares or 1.4 percent of the total.

Wells Fargo of San Francisco reported along the same pattern as Chase Manhattan. It indicated that the top 30 stockholders held 3,049,946 or 32.6 percent of the total of 9,287,040 outstanding shares, with the following breakdown:

Franklin New York Corporation reported two major holders of voting securities, Loews Corporation with 20.2 percent of the outstanding voting securities, and Sol Kittay, a director of the corporation, with 1.7 percent of the outstanding voting securities. In July 1972 Loews sold most of its holdings to Fasco International Holding, S.A., controlled by the Italian financier, Michele Sindora. As of Dec. 31, 1972, Fasco International owned about 18.3 percent of Franklin New York Corporation's voting stock. No other person is believed to control or hold power to vote 5 percent or more of the outstanding voting securities of the corporation.

First Pennsylvania reported the same kind of information as Chase Manhattan and Wells Fargo. The 30 largest stockholders accounted for 3,859,298 or 31.5 percent of the 12,241,922 shares of voting common stock outstanding. This is broken down into the following categories:

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