To put my comments about examination fees into perspective, let me give you some additional statistics. One argument that I always hear from the OCC is that our fees are lower because the FDIC and Fed perform alternating exams with the state banking departments and don't charge the state bank an examination fee. In Texas, we have analyzed our costs and have determined that if the FDIC and Fed got out of the supervision business and we did all of the exams of the state banks in Texas, which we are capable of doing, that we would still be cheaper than the OCC because of lower infrastructure costs. This is not to say that the State Banking Departments don't have any pressures on them. The current merger frenzy, as well as the implementation of the 18-month examination cycle, is having a serious impact on all regulatory agencies in terms of staffing.
Fewer examinations mean fewer examiners.
The bankers are going to expect lower exam fees and assessments, and it will be up to us as regulators to staff down and deliver cost reductions. In Texas alone, we have gone from 120 bank examiners several years ago to 90 examiners today, and we have been able to reduce assessments accordingly. The dual banking system will continue to expose to the light of day any inefficiencies in the state or federal regulatory system to the benefit of the banking industry. Historically, and up to 1991, the states have been the incubator of innovation, with Congress being able to adopt these new ideas if they prove successful. We have just modernized our 1943 Texas Banking Code with the passage of the Texas Banking Act of 1995 .