The rst national bank charter was issued to the First 

National Bank of Philadelphia on June 20, 1863.
Library of Congress Prints and Photographs Division

The disorderly pre-Civil War money supply, 

based on state bank notes, contributed to 

periodic “panics” and economic hardship.
The story of the Office of the Comptroller of the 

Currency (OCC) and the national banking system 

begins in 1863, when the National Currency Act 

was passed by Congress and signed into law by President 

Abraham Lincoln.

The law was a response to the mishmash of local banks, 

local money, and conflicting regulatory standards that 

prevailed before the Civil War. Banking systems varied 

from state to state. Some states required a special act of 

the legislature before prospective bankers could obtain an 

operating charter. Other states adopted “free banking,” 

under which charters were granted to all applicants that 

met established conditions. In such states as Indiana 

and Tennessee, banks were state-operated and -owned; 

elsewhere, ownership was vested in public-private 

partnerships. And in states like Ohio, several of these 

institutional arrangements were in use at the same time.

The pre-Civil War money supply consisted of various 

types of gold and silver coins along with paper notes issued 

in multiple denominations by each of the thousands of 

individual banks. In theory, holders of notes could return 

them to the issuer and receive their face value in precious 

metal. However, especially where state supervision and 

oversight were weak, banks tended to issue notes beyond 

their redemption capabilities, which led to bank runs and 

failures. 

But the biggest problem with state banking before the 

Civil War was that it discouraged the development of an 

integrated national market and a shared national identity. 

At each destination, long-distance travelers had to convert 

their bank notes into local money, usually sustaining a loss 

with each exchange. The cost and inconvenience were 

significant deterrents to interstate travel and commerce.

Such a fragmented banking and monetary system increased 

the likelihood that people would think of themselves as 

citizens of a state or a region rather than citizens of the 

United States.
2 Office of the Comptroller of the Currency

The National Currency Act of 1863 created the national 

banking system and the Office of the Comptroller of the 

Currency.
A Short History 3

Founding of the National 

Banking System, 1863–1865

Local and sectional loyalties tore the country apart in 

1861. The National Currency Act of 1863 was part 

of Congress’s attempt to stitch it back together.

The immediate challenge was meeting the costs of a civil 

war that vastly exceeded anything the government had 

confronted before. As the war 

ground on, the challenge of keeping 

the troops paid and provisioned 

became a crisis that rivaled the 

military challenges on the battlefield.

Congress acted on several fronts. 

Taxes were raised. Assets, especially 

land, were sold. Fiat currency—

the unsecured paper known as 

greenbacks—was printed and used 

to pay the troops and their suppliers. 

And the government borrowed. But 

in the face of military reverses that raised doubts about 

the government’s prospects and permanence, bond sales 

faltered.

One of the purposes 

of the national 

banking 

legislation 

introduced in 

December 1862 

was to stimulate 

bond sales and 

generate a rush of 

cash for the hard-pressed 

U.S. Treasury. The legislation 

would create the first national bank charter. Applicants 

would have to meet minimum capital standards, pass 

Abraham Lincoln
4 Office of the Comptroller of the Currency

muster with the system’s administrative officer (designated 

the Comptroller of the Currency), and be willing to buy 

U.S. bonds to be deposited with the Comptroller as security 

for the new national currency. Supporters of the legislation 

promised that tens of millions of dollars would be raised 

annually for the war effort through such bond sales; in the 

end, the wartime take amounted to a fraction of that.

Some members of Congress supported 

the national banking legislation as 

a simple act of patriotism. But the 

legislation’s leading proponents—

President Abraham Lincoln, Treasury 

Secretary Salmon P. Chase, and Ohio 

Senator John Sherman—saw the 

legislation not only as a way to tap the 

North’s wealth and 

win the war but also 

as a means to assure 

the future greatness 

and permanence of the United States.

At the heart of their vision was a 

safe, sound, and reliable banking and 

monetary system. The OCC would 

write uniform rules that would apply to 

all national banks and send examiners 

into the banks to make sure those rules 

were being followed. The national 

currency itself would be identical except for the name of 

the issuing bank and the signatures of its officers. The idea 

behind the system was simple, but the system’s impact on 

commerce, public confidence, and national unity would be 

profound.

 Salmon P. Chase

John Sherman
A Short History 5

The bill that Lincoln signed into law on February 25, 1863, 

established the system’s basic framework. Because it was 

passed with relatively little review or debate, the bill was 

imperfect and incomplete, prompting the first Comptroller, 

Hugh McCulloch of Indiana, to change and clarify many 

of its provisions. Congress passed McCulloch’s expanded 

and redrafted version, called the National Banking Act, in 

June 1864.

McCulloch was in fact an unlikely choice for Comptroller. 

He had come to Washington in his capacity as president 

 Hugh McCulloch
6 Office of the Comptroller of the Currency

of the state-owned Bank of Indiana to fight against the 

national banking legislation, which he rightly perceived 

as a threat to state-chartered banking. Although he had 

tried to block the system’s creation, McCulloch was now 

determined to be its champion.

McCulloch was an industrious, able administrator. He 

acquired office space, hired a staff, assisted in the design 

of the new national bank notes, and arranged for their 

engraving, printing, and distribution. He personally 

evaluated applications for bank charters and consoled 

prospective bankers who were late with their paperwork 

and the initial installment of their paid-in capital, thus 

losing out to competitors for the coveted designation of 

“First National Bank” in the same locality.

McCulloch was keenly aware that his decisions would set 

standards for years to come. In a letter of advice to bankers 

in 1863, McCulloch encouraged the pursuit of 

“a straightforward, upright, legitimate banking business.”

“Never be tempted by the prospect of large returns to do 

anything but what may be properly done” under the law, he 

advised.

Although the new law allowed both new charters and the 

conversion of state banks into national ones, McCulloch, 

as a former state banker, gave preference to the latter, 

convinced that experienced bank managers were essential 

to the system’s success.

For various reasons, they were slow to take him up on 

the offer. Some bankers were reluctant to abandon the 

descriptive, sometimes colorful names their institutions 

had borne for years, like the Safety Society Bank and 

the Planters and Drovers Bank, in favor of the dry “First 

National” and “Second National” nomenclature prescribed 

by the new law. Bankers also balked at the law’s capital 

requirements, the prospect of tougher federal oversight, 
A Short History 7

and the restrictions on activities that state laws allowed 

them to conduct, such as real estate lending.

In March 1865, in the face of this reluctance, Congress 

passed a 10 percent tax on the notes of state banks, 

signaling its determination that national banks would 

triumph and the state banks would fade away. And, for a 

time, they did.
8 Office of the Comptroller of the Currency

Within its vaults, the OCC held the U.S. government 

bonds that secured national currency.

OCC officials sorted, bundled, and destroyed national 

bank notes that were turned in for redemption.
A Short History 9

The System in Operation, 

1866–1913

Of the 1,600 state banks that existed in 1860, only 

300 remained by 1866, while the national banking 

system shot ahead in numbers and influence. 

In his 1872 Annual Report to Congress, Comptroller John 

Jay Knox took pride in the nearly decade-old system’s 

contribution to the country’s rising wealth and power.

In 1868, the OCC’s headquarters staff consisted of 72 

clerks, a third of them women. Their work was tedious. 

The office dispatched orders to the examiner force 

across the country, received and processed applications 

for charters and other corporate changes, and filed the 

examination reports. The national currency had to be 

ordered from printers (initially private contractors and later 

the federal Bureau of Engraving and Printing). Under tight 

security, the currency had to be cut, registered, bundled, 

and shipped to the issuing national bank, where each 

note was supposed to be signed by hand. The U.S. bonds 

deposited with the Comptroller’s office required similar 

care. When a bank failed or was voluntarily dissolved, the 

outstanding notes had 

to be withdrawn and 

destroyed and the bond 

security liquidated.

Although the OCC’s 

headquarters 

operations were initially 

funded by Congress, 

national bank 

examiners were more akin to independent contractors, paid 

directly by the banks they examined at a rate of $5.00 a day 

plus $2.00 for every 25 miles traveled. Assessing banks for 

the cost of their supervision was not only a matter of being 

frugal with public funds; the assessment system was also 
10 Office of the Comptroller of the Currency

designed to insulate examiners from the pressures of the 

federal budgeting and appropriations process.

This approach, while well intentioned, did not always result 

in effective supervision. Many examiners were overwhelmed 

by the number of banks in their supervisory portfolios 

and by the challenge of getting from one to the next. One 

OCC examiner in 1887 had responsibility for 90 banks 

scattered throughout seven states. He could have hired an 

assistant to help, but that would have been an out-of-pocket 

expense. Nineteenth-century rail travel was physically 

grueling; schedules 

and connections were 

erratic. Examiners were 

sometimes tempted to 

rush through their work 

to avoid missing the 

train that could leave 

them stranded—and 

unpaid—for days. One 

Comptroller after the 

other pleaded with 

Congress to abolish 

the fee-based system in favor of regular salaries, but that 

change was not adopted until 1913.

Who were the people who examined national banks during 

these early years? Many were attorneys and auditors; others 

had worked in banks as tellers and cashiers. Some of them 

stayed with the OCC for life, while for others, the job of 

national bank examiner became a stepping-stone to other 

ambitions, especially in banking or politics. For the writer 

O. Henry and the naturalist John Burroughs, the OCC was 

a way station to a career in the arts and sciences.

The first generations of national bank examiners were all 

white males. The first female examiner, Adelia M. Stewart, 

was not commissioned until the 1920s. African-Americans 

were hired as messengers and watchmen. Such was the 
A Short History 11

United States in the decades after the 

Civil War.

The Comptrollers of the Currency in 

this period were men of accomplishment 

and distinction befitting the office’s 

broad responsibility for the banking 

and monetary systems. 

McCulloch went on 

to serve two terms as Secretary of the 

Treasury. Knox, who joined the OCC as a 

clerk and rose through the ranks to become 

one of the longest-serving Comptrollers in 

history, wrote several outstanding treatises 

on banking and financial history during 

his tenure. Charles G. Dawes already had 

published a study on banking when he became Comptroller 

in 1898. After leaving the OCC in 1901, Dawes ran 

unsuccessfully for the U.S. Senate, founded a bank, became 

a brigadier general in World War I, developed the Dawes 

Plan for the economic recovery of post-war Europe, served 

as the 30th Vice President of the United States, and was the 

U.S. Ambassador to the United Kingdom. In his idle time, 

he was an accomplished musician and composer of popular 

tunes that enjoyed considerable commercial success.

Congress had established the OCC as a “separate bureau” 

of the Department of the Treasury under the “general 

direction” of the Secretary. Other 

provisions of the National Banking 

Act underscored the Comptroller’s 

independence by giving the Comptroller 

a five-year term, a direct reporting line 

to Congress, and protection against 

arbitrary removal. But ambiguity about 

the Comptroller’s status existed from the 

beginning and has persisted throughout 

the OCC’s history. Democratic presidents invariably 

selected Democrats to serve as Comptroller, Republicans 

Charles G. Dawes

Lawrence O. Murray

John Jay Knox
12 Office of the Comptroller of the Currency

picked Republicans, and, notwithstanding the five-year 

term, incumbent Comptrollers often were pressured to 

leave early when the White House changed hands. A break 

in this tradition came in 1908, when Republican President 

Theodore Roosevelt appointed Lawrence O. Murray, a 

Democrat, as the 12th Comptroller.

The law required that Comptrollers report annually to 

Congress on the condition of the national banking system, 

making recommendations for improvements as they saw fit. 

Some of the issues they identified were addressed legislatively, but larger questions about the system’s adequacy and 

fairness remained.

The unexpected resurgence of state banking was an 

increasing concern for the OCC. State banks had 

circumvented efforts to tax their notes into oblivion by 

encouraging customers to pay bills with checks instead of 

currency. State regulators and legislators eased chartering 

requirements, reduced lending limits, broadened eligible 

collateral, and cut the fees that banks paid for examinations. 

The Comptrollers urged Congress to help national banks 

Eugene T. Wilson, National Bank Examiner

Merchant, journalist, and member of the 

Washington State Senate, Eugene T. 

Wilson was appointed a national bank 

examiner in 1892. During the Panic of 

1893, he was assigned to supervise 

the national banks of Helena, Montana, 

where he uncovered evidence of fraud 

and mismanagement and took steps to 

force the banks to clean up their affairs. 

The bankers tried to bribe and discredit 

him, but Wilson prevailed. According to 

a scholar who studied his OCC career, 

Wilson “brought to his job profound personal integrity, a well 

developed concept of public responsibility, and a firm idea 

of fairness to all classes in connection with the banks.”
A Short History 13

compete by easing restrictions and expanding powers. 

Nonetheless, by 1900, state banks outnumbered national 

ones.

Fifty years after it was created, one thing was clear: The 

national banking and national currency system was a vast 

improvement over the system it had replaced. Yet public 

dissatisfaction with banking was still keen. There was a perception that the national system was national in name only, 

that it favored Eastern, urban interests over Western, rural 

ones. Moreover, the economy was still subject to periodic 

bouts of extreme instability, when liquidity and loans dried 

up and banks failed in alarming numbers.

Changes in the nation’s financial structure were on their 

way.
14 Office of the Comptroller of the Currency

Comptroller Daniel R. Crissinger (center), who served 

between 1921 and 1923, meeting with his senior national bank 

examiners. 

A Great Depression-era bank run. 
A Short History 15

Years of Transition, 1914–1935

The passage of the Federal Reserve Act in 1913 was 

a watershed in U.S. banking history. It created the 

Federal Reserve System, consisting of a network of 

branches in large American cities, tied together by a Board 

of Governors headquartered in Washington, D.C. The 

Fed would serve as the country’s central bank, regulating 

its members (including all national banks) and overseeing a 

new, more flexible currency that could grow with the needs 

of the economy and would gradually take the place of national bank notes in the money supply. The last such notes 

were issued in 1929. Despite its name, the OCC was now 

officially out of the currency business.

No longer burdened with the administration of a complex 

monetary system, the OCC sharpened its focus on bank 

examination and regulation. It became essentially an organization of national bank examiners charged with doing 

one job: maintaining the safety and soundness of the banks 

they supervised.

While the OCC’s work after 1913 was simplified in one 

respect, it was complicated by the surge in new bank formation. By 1921 there were more than 29,000 commercial 

banks in the United States, three-quarters of them statechartered and many so thinly capitalized that the loss of a 

single large deposit or loan could bankrupt them. In addition, there were thousands of savings and loan institutions 

that specialized in making residential mortgages and that, 

consequently, were extremely vulnerable to fluctuations in 

house prices. 

The OCC had long taken a stand against chartering new 

banks in communities that already had more banks than 

they could support. The shift in banking resources away 

from the national charter and federal authority nevertheless 

was a development the OCC could not ignore.
16 Office of the Comptroller of the Currency

With the agency’s support, Congress passed the McFadden 

Act of 1927, which empowered national banks to increase 

their loans to single individuals, to make real estate loans, to 

deal in securities, and to open branches. The Comptrollers 

in office between the two world wars were resolute in maintaining high supervisory standards, upholding the quality 

of OCC supervision, and refusing charters to banks they 

believed had little or no prospect of success. 

All this mattered little when the Great Depression struck 

with devastating force after 1929. First to feel the effects 

were banks involved in stock trading—and those whose customers were. Unfortunately, the 1920s bull market on Wall 

Street had brought millions of Americans into the market 

for the first time, and many of them were wiped out when 

the market turned against them. Loan losses soared, and 

bank deposits dwindled. Whole industries shut down. As 

the crisis worsened, people lost their jobs, their homes, and 

their hopes. 

On March 6, 1933, just two days after taking office, President Franklin D. Roosevelt declared a bank “holiday”—a 

Adelia M. Stewart, National Bank Examiner

Adelia M. Stewart made history when, 

in 1921, she became the OCC’s first 

female national bank examiner. But 

setting precedents was nothing new 

for her. While working as a clerk at 

the OCC, she earned a law degree 

with high honors and was one of two 

women admitted to the Washington, 

D.C., bar in 1914. Her superiors 

recognized her accomplishments 

in 1922 by appointing her chief of the OCC’s Division of 

Examinations. In Stewart’s 44-year career at the OCC, 

she served under 11 Comptrollers, displaying the grit and 

dedication to public service that made her a model for men 

and women alike. 
A Short History 17

respite designed to calm frazzled nerves, conserve assets, 

and begin the process of healing the nation’s shattered 

banking system.

The OCC played a major role in that effort. The 

temporary shutdown of the nation’s banks was no holiday 

for state and national bank examiners, who worked under 

heavy pressure to review the condition of thousands of 

banks and decide whether to issue or deny them the licenses 

they needed to reopen. National banks failing the test were 

placed into OCC-supervised receiverships that liquidated 

the banks’ assets. Banks judged to be salvageable were 

returned to private management, offered government 

capital until money could be raised privately, and placed 

under intensive supervision to nurse them back to health.

For many Americans, the crisis underscored the weaknesses 

of the existing regulatory framework, with its liberal if 

not runaway chartering, inconsistent supervision, and 

regulations that allowed banks to engage in the riskiest 

activities. Major changes came with the passage of the 

Glass–Steagall Act of 1933, which created “firewalls” 

separating investment and commercial banking, regulated 

many deposit products, and raised minimum capital 

requirements for national banks. Glass–Steagall also 

created a system of federal deposit insurance, which 

proved instrumental in restoring public confidence and 

luring funds back into the banks, where the money could 

be used to promote recovery. State banks that opted for 

protection under the federal deposit insurance umbrella 

were subject to co-supervision by the newly created Federal 

Deposit Insurance Corporation (FDIC) and state banking 

authorities—an important step toward more consistent 

supervisory standards.

By now, there were three major federal bodies regulating 

commercial banks—the OCC, the Federal Reserve, and the 

FDIC—as well as authorities in each state. Calls to resolve 

differences in how the agencies’ examiners rated banks and 
18 Office of the Comptroller of the Currency

evaluated their assets led to a 1937 interagency agreement 

that prescribed a more consistent treatment of loans 

and securities and common reporting forms. Differences 

persisted nonetheless, as each agency adopted its own 

policies within the shared framework.

A new era of conservatism and government involvement in 

banking was about to begin.
A Short History 19

The Federal Thrift Charter

The original national banking laws essentially 

forbade national banks from making residential 

mortgage loans. Savings institutions—variously 

known as savings and loans, savings banks, and building 

associations—helped fill the gap.

The U.S. thrift industry’s roots date back to 1831, when 

townspeople in Frankford, Pennsylvania, agreed to pool 

their money to purchase their own homes. The result 

was the Oxford Provident Building Association, which 

lasted until all 40 original members had been given the 

opportunity to become home owners. The Oxford’s 

example of cooperative finance to promote home 

ownership inspired the founding of other associations 

across the country. By 1893, there were nearly 6,000 

such institutions in the United States.

The Great Depression brought a wave of foreclosures and 

thrift institution failures. In response, Congress created a 

federal thrift charter, administered by the Federal Home 

Loan Bank Board and funded by the Federal Home 

Loan Bank System, and the Federal Savings and Loan 

Insurance Corporation to protect thrift depositors. This 

structure remained in place for the next half-century. At 

their height, savings institutions originated two-thirds of 

the nation’s home mortgages.

The deregulation of financial markets in the 1970s and 

1980s threatened the thrift business model, which 

depended on low-cost retail deposits. Congress 

broadened thrift powers, which led many institutions 

to venture into riskier investment and lending activities. 

In the late 1980s and the 1990s, hundreds of savings 

institutions failed. To revive and supervise the struggling 

industry, the Office of Thrift Supervision (OTS) was 

created under the Treasury Department to replace the 

independent Federal Home Loan Bank Board. During its 

more than 20 years, the OTS regulated institutions that 

helped millions of Americans achieve the dream of home 

ownership.
20 Office of the Comptroller of the Currency
A Short History 21

Stabilization and Challenge, 

1936–1966

World War II, with its insatiable demand for manpower 

and matériel, signaled the end of the Great Depression. 

National service pulled many bank examiners off the 

front lines of supervision and moved them to the front 

lines of combat, which meant increased responsibility 

for the remaining staff. Fortunately, with the newly 

restrictive regulatory framework and the emphasis on 

lending to government rather than individuals, bank 

safety and soundness was never 

compromised.

After the war, consumer 

spending and borrowing grew 

briskly. With relatively few new 

banks being chartered, national 

banks could be extremely 

selective about those with whom 

they did business and how much 

they charged customers for their 

services. Loan losses were low, 

bank failures were practically 

nonexistent, and banks were 

profitable.

Stability in the banking system eased the pressure on 

OCC examiners. The interstate highway system and airconditioned cars made travel more comfortable, and the 

team approach to examination bred camaraderie and esprit 

de corps.

These relatively tranquil days for the national banking 

system—and those who were responsible for it—were 

fleeting. Competition arose from financial providers that 

were not commercial banks and were therefore not subject 

to Glass–Steagall restrictions. By the early 1960s, a century 

after the national banking system began, James J. Saxon, 
22 Office of the Comptroller of the Currency

the 21st Comptroller, was issuing warnings about the 

“spectre of over-regulation” that threatened to erode the 

system’s future strength and relevance.

Saxon was among the 

most innovative and 

assertive Comptrollers 

in OCC history, but his 

legacy was mixed. Some 

of his key regulatory 

initiatives, one of which 

permitted national banks to 

underwrite revenue bonds 

for state and municipal 

governments, were later overturned in court. His muscular 

assertion of the Comptroller’s independence produced a 

backlash: By the time he left office, the OCC’s relations 

with the Fed, the FDIC, and the Treasury Department were 

all seriously strained.

P. Brantley “Preacher” Knight, 

National Bank Examiner

“Preacher” Knight—he got the nickname 

as a four-year-old for his impersonation 

of the local minister—joined the OCC 

as an assistant national bank examiner 

in 1947. For most of the next 32 years, 

he tooled the highways and byways of 

Texas and New Mexico, supervising 

mainly rural community banks, some 

of them so small that they didn’t have 

a restroom on the premises. Driving his beloved 1950 

Plymouth, “Old Grey,” through blinding ice and dust storms, 

Knight became a familiar and respected figure among local 

bankers, who quickly learned that it was no use trying to 

hide their problems from him. “Examiners,” as he wrote after 

his retirement, “are just like the Pony Express. Nothing stops 

them.” 

James J. Saxon
A Short History 23

His reforms, however, were significant and their effects 

lasting. He set up an OCC international banking unit; 

created an economics department, which he staffed with 

graduate-level economists; and strengthened the law 

department, which he kept busier than ever. He raised 

hiring standards for new examiners, who for the first time 

were required to hold college degrees. He encouraged 

national bank expansion into new geographic and product 

areas, liberalized chartering policies, and aggressively 

promoted the national charter to state banks. Saxon’s 

policies helped reinvigorate the national banking system 

and improved the OCC. 
24 Office of the Comptroller of the Currency
A Short History 25

Past, Present, and Future

The Vietnam War became a catalyst for discontent with 

many national institutions, including government itself. 

This activism fed the civil-rights movement, with its call for 

greater social and economic justice. The result was a wave 

of legislation, some of it affecting financial institutions. 

Some laws, like the Equal Credit Opportunity Act of 1974, 

responded to evidence that bank policies had discriminated 

against women and certain minority groups. Other laws, 

like the Community Reinvestment Act of 1977, addressed 

the declining fortunes of many American cities, a decline 

that was blamed in part on bank business strategies. For the 

OCC, ensuring compliance with consumer protection and 

community development laws while continuing to safeguard 

national bank safety and soundness became a major 

organizational challenge.

One fundamental change in the banking environment after 

the war was not related to banking or any act of Congress. 

Rather, the change was a function of advances in microchip 

technology and the reduced cost of computing power. 

As primarily an information business, banking was 

profoundly affected by computerization and the subsequent 

development of the Internet. Access to this technology 

not only changed the way basic banking transactions were 

conducted but also tied individual banks into a national and 

global financial nexus that brought new risks and benefits.

Funds could now be deposited and withdrawn with a single 

keystroke, giving banks a new ability to tap distant sources. 

That also meant they instantly could be tapped themselves, 

in response to swift-moving news or even rumors. 

Ultimately, the digitization of money reduced the dominant 

role that banks once played as financial intermediaries.

Banks found that they did not necessarily need a physical 

presence to take advantage of deal-making opportunities in 
26 Office of the Comptroller of the Currency

distant markets (although most large U.S. banks eventually 

established a presence abroad). Foreign-owned institutions 

were free to cast their nets just as widely, creating new 

competition for U.S. banks in their home markets.

Technology would also help the OCC manage these 

changes. After two national banks failed in the mid1970s, evoking anxious memories of the Great 

Depression, Comptroller James E. Smith commissioned 

a comprehensive review of the OCC’s organization and 

supervisory processes. A large number of adaptations 

flowed from that study for several years. Communication 

between banks and examiners became more automated. 

Supervisory activities were increasingly risk-based. 

The OCC, like the industry it supervised, expanded 

internationally: The agency established an office in 

Emory Wayne Rushton, 

National Bank Examiner

Wayne Rushton was one of the 

bright, young college graduates 

whom Comptroller James J. Saxon 

recruited to the OCC in the 1960s. 

A graduate of the University of 

South Carolina, Rushton found 

that the OCC rewarded diligence, 

courage, and technical know-how. 

He quickly developed a sixth sense 

for banks with hidden problems. 

One of those was the National 

Bank of Georgia, owned by T. Bertram Lance, a friend of 

President Jimmy Carter’s and Carter’s director of the Office 

of Management and Budget. Lance left that office after 

Rushton and OCC colleagues uncovered questionable use 

of the bank’s assets. After moving to Washington, Rushton 

helped establish the OCC’s Multinational Banking Program 

and became one of its earliest Deputy Comptrollers. A 

career marked by high-level cases and breakthroughs 

in supervisory policy and execution culminated in his 

appointment as Chief National Bank Examiner. He retired in 

2008, after 43 years of OCC service.
A Short History 27

London and became an active participant in forums like 

the Basel Committee on Banking Supervision that brought 

professionals together from around the world with the goal 

of harmonizing supervisory policies and standards.

The closer integration of America and the world brought 

changes to the OCC as well as to the industry it supervised. 

Communications improvements meant faster and more 

consistent decision making across the OCC’s districts, 

which, accordingly, were reduced from 14 to six, and then 

to four. Women, African-Americans, Hispanic-Americans, 

and members of other previously underrepresented groups 

became indispensable parts of the OCC team—not 

because equal opportunity had become the law of the land 

but because the OCC needed the best people available to 

effectively fulfill its mission.

The information revolution revived the long-standing 

debate over whether banks are regulated too heavily or 

not heavily enough. The relaxation of Glass–Steagall 

restrictions, which Comptroller Saxon advocated in the 

1960s, began in earnest in the 1980s, as interest-rate 

Jerry Martin, Certified Thrift Examiner

Jerry Martin began his supervisory career 

in 1974 as a financial intern at the OCC. 

After examining troubled institutions in 

the Southwest and Northeast during the 

banking crisis of the 1980s, he moved 

to the OTS in 1990. His OCC experience 

supervising real estate loan portfolios 

served him especially well at the OTS, 

whose institutions specialized in just such 

lending. He found high-quality colleagues 

at both agencies and formed relationships that sustained 

him throughout his 37 years of government service, 

culminating in his assignment as resident examiner at ING 

Bank. He retired in 2011 after 37 years of service as a federal 

bank examiner.
28 Office of the Comptroller of the Currency

ceilings on deposit accounts, limitations on interstate 

activity, and other regulations were phased out. The 

Gramm–Leach–Bliley Act of 1999 broke down the wall 

separating commercial and investment banking, giving 

banks greater autonomy than they had had since the 1930s. 

A decade later, in the wake of the worst financial crisis 

since the Great Depression, events came full circle with 

the passage of the Dodd–Frank Wall Street Reform and 

Consumer Protection Act of 2010, which points to a more 

comprehensive, more exacting regulatory regime. 

The OCC faces a number of organizational challenges 

as it looks toward its 150th anniversary and beyond. 

Under Dodd–Frank, most of the agency’s compliance 

responsibilities migrate to the new Consumer Financial 

Protection Bureau. Oversight of the waning thrift industry, 

which over time lost its unique identity as a source of 

mortgage funding, comes to the OCC from the Office of 

Thrift Supervision (the descendant of the Federal Home 

Loan Bank Board), which Dodd–Frank dissolved. The 

OCC also takes its place on a new Financial Stability 

Oversight Council, which aims through interagency 

cooperation to identify and address potential sources of 

systemic risk.

Throughout these changes, the agency continues to fly 

its flag proudly as the oldest regulatory agency of the 

U.S. government. The OCC’s name harks back to the 

time of Abraham Lincoln. But its fundamental mission 

of assuring a safe and sound national banking system is as 

modern as the 21st century.

Revised November 2011
Library of Congress Prints and Photographs Division

The designers of the national currency had several goals: attracting c

and building condence in, the new banking system and money supp

promoting patriotism and civic awareness; preventing counterfeiting; 

stimulating the sale of U.S. government bonds; and striking a balance 

local autonomy and federal authority.

Anatomy of Natio

To make them legally binding instruments, the National 

Bank Act required that each note issued by a national 

bank be signed by its ofcers. 

The disorderly pre-Civil War money supply, 

based on state bank notes, contributed to 

periodic “panics” and economic hardship.

The front of a $10 note issued by the 

National Bank of Commerce in St. Louis, 

1889.

National banks were attracted by the prestige of having their 

name (and charter number) inscribed on the notes they issued.

National banks were required to purchase U.S. bonds or other investment-grade 

in an amount equal to 90 percent of the face value of their notes. These securitie

placed on deposit with the OCC. If a national bank was unable to meet its redem

requirements, the OCC could sell the bonds and distribute the proceeds to note

National banks were required to hold reserves 

of precious metal, to be paid “on demand” 

when notes were presented to them.
2011

The rst national bank charter was issued to the First 

National Bank of Philadelphia on June 20, 1863.

Ofcial seal of the OCC, 1863.