Nominees

Akres & Co..

within a given bank into a single shareholder entity for purposes of ranking the 30 largest shareholders.

Includes 31 stockholders, the 29th, 30th, and 31st each having 5,000 shares. Omitted is one unnamed individual holding 5,460 shares.

199.24% owned by Shawmut Association.

Four stockholders held 2 or more percent of such stock, led again by the bank itself through three nominees and one trust account, with 5.7 percent; followed by:

Eight New York banks combined held a total of 15.6 percent of the common stock of Bankers Trust. First Bank System (Minneapolis)

The First Bank System (Minneapolis) identified by name the 19 of the largest stockholders that were bank nominees and beyond that designated the kind of holder and amount of shares (e.g., insurance company, mutual fund, charitable foundation, individual, family estate) of the other 11 holders without disclosing the names of such holders.

The 30 largest shareholders accounted for 40.6 percent of First Bank System's capital stock. By far the largest holder was the First Bank System itself, through the various nominees of the member banks of the System. These include: (1) two nominees of the First Trust Company of St. Paul, Brack and Company with 7.1 percent of the stock, and Sod and Company with 1.2 percent of the stock; (2) two nominees of First National Bank of Minneapolis, with 5.1 percent of the stock between them; and (3) one nominee of the Northern City National Bank of Duluth with 1.1 percent of the stock. Thus, the nominees of three member banks of the First Bank System held among them 14.6 percent of the stock of the System.

The only other holders of more than 2 percent of the stock were two New York banks, First National City

1 The largest single account in Brack and Company was the Employee's Deferred Payment Profitsharing Trust Plan, with 2 percent of the total stock of the First Bank System.

at least 54 nominee accounts including 17 in Morgan Guaranty of New York, and 11 of Citizens and Southern, itself. The inclusion of all nominees would tend to increase the concentration of holdings among the top 30 companies, and of those banks with many nominees in particular, as compared with other reporting banks.

With this caveat, it can be seen that Citizens and Southern National Bank reported that 42.5 percent of its stock was held by the 30 largest stockholders. Five firms, all banks through their nominees, held over 2 percent of the total stock of Citizens and Southern National Bank. They were, in order of size of holdings:

Citizens and Southern..

(itself, through 11 nominees, as noted above, and as trustee in one instance)

3. 2

3. 2

First National City..

2.9

(in three nominee accounts)

Mellon National Bank, Pittsburgh.

(in three nominee accounts)

Morgan Guaranty.

(in 17 nominee accounts)

Bankers Trust..

(in four nominee accounts)

Percent 10. 8

6.7

4.5

3. 6

2.3

Six New York banks combined held 14.1 percent of the common stock of Citizens and First National, with the three New York banks just mentioned accounting for 12.6 percent.

Shawmut Association

In reporting its largest stockholders, Shawmut actually listed 31 holders (the 29th, 30th, and 31st all holding equally 5,000 shares). Omitted was the holding of one unnamed individual with 5,460 shares, or 0.2 percent of the total outstanding.

On the basis of this tabulation, Shawmut Association has far less concentration of its common stock holdings than the other reporting banks with the top 31 holders accounting for only 15.0 percent of the stock. No single holder had as much as 2 percent of the shares. Three New York banks combined held 1.6 percent and five Boston banks held 3.4 percent of the shares. Olsen & Company, a nominee of National Shawmut Bank of Boston, Trust Department, subsidiary of Shawmut Association, was the largest holder with 24,206 shares or 1.3 percent of the total; this represents primarily shares held for employees of affiliated banks in the holding company under profit sharing and stock purchase plans.

A few at least tentative conclusions can be reached from the information in this section of the report. Perhaps most striking is the small number of banks supplying the infor

the common stock of First National Bank in Dallas.

Citizens and Southern National Bank

The response from Citizens and Southern National Bank of Atlanta, Georgia, is not strictly comparable to the other eight banks (or any of the other reporting companies) whose tabulations are summarized here. In some ways it is the most informative response received. Instead of treating a single nominee account as one of the largest stockholders, Citizens and Southern chose to consider all of the nominees of a single bank or other financial institution as one account. Thus, information is supplied on the holdings of

fully were spread fairly evenly by size among the 50 banks circulated (i.e. three in the first quintile; one in the second quintile; two in the third quintile; one in the fourth quintile; and two in the fifth quintile). Second is the fact that the principal holder in eight of the nine reporting banks was the bank itself through various nominee accounts. The extent of bank discretion in voting or influencing the voting of such shares would be worthy of further exploration.

A concomitant question also worthy of consideration is why so rarely any holders outside of banks appear in the list of holders of more than 2 percent of bank stock.