[Congressional Record Volume 165, Number 156 (Thursday, September 26, 2019)]
[Extensions of Remarks]
[Pages E1215-E1218]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




            SECURE AND FAIR ENFORCEMENT BANKING ACT OF 2019

                                 ______
                                 

                               speech of

                           HON. ED PERLMUTTER

                              of colorado

                    in the house of representatives

                     Wednesday, September 25, 2019

  Mr. PERLMUTTER. Madam Speaker, I include in the Record the following 
letters of endorsement for H.R. 1595, the SAFE Banking Act.

                                              National Association


                                         of Attorneys General,

                                      Washington, DC, May 8, 2019.
     Hon. Nancy Pelosi,
     Speaker of the House,
     Washington, DC.
     Hon. Mitch McConnell,
     Majority Leader,
     Washington, DC.
     Hon. Steny Hoyer,
     Majority Leader,
     Washington, DC.
     Hon. James E. Clyburn,
     Majority Whip,
     Washington, DC.
     Hon. Mike Crapo,
     Chair, Senate Committee on Banking, Housing & Urban Affairs, 
         Washington, DC.
     Hon. Kevin McCarthy,
     Minority Leader,
     Washington, DC.
     Hon. Charles E. Schumer,
     Minority Leader,
     Washington, DC.
     Hon. Steve Scalise,
     Minority Whip,
     Washington, DC.
     Hon. Richard J. Durbin,
     Minority Whip,
     Washington, DC.
     Hon. Sherrod Brown,
     Ranking Member, Senate Committee on Banking, Housing & Urban 
         Affairs, Washington, DC.
       Dear Congressional Leaders: We are a bipartisan group of 
     state and territorial attorneys general who recognize that 
     the states, territories and federal government share a strong 
     interest in protecting public safety and bringing grey market 
     financial activities into the regulated banking sector. To 
     address these goals, we urge Congress to advance legislation 
     that would allow states and territories that have legalized 
     certain use of marijuana to bring that commerce into the 
     banking system.
       This issue is of broad relevance: for example, thirty-three 
     states and several U.S. territories have legalized the 
     medical use of marijuana. However, because the federal 
     government classifies marijuana as an illegal substance, 
     banks providing services to state-licensed cannabis 
     businesses and even to other companies which sell services 
     and products to those businesses could find themselves 
     subject to criminal and civil liability under the federal 
     Controlled Substances Act and certain federal banking 
     statutes. This risk has significantly inhibited the ability 
     of financial institutions to provide services to these 
     businesses and companies.
       Despite the contradictions between federal and state law, 
     the marijuana industry continues to grow rapidly. Industry 
     analysts estimate 2017 sales at $8.3 billion and expect those 
     totals to exceed $25 billion by 2025. Yet those revenues are 
     handled outside of the regulated banking system. Businesses 
     are forced to operate on a cash basis. The resulting grey 
     market makes it more difficult to track revenues for taxation 
     and regulatory compliance purposes, contributes to a public 
     safety threat as cash-intensive businesses are often targets 
     for criminal activity, and prevents proper tracking of 
     billions in finances across the nation. Importantly, this 
     measure in no way constitutes an endorsement of any state or 
     territory's specific approach to the legalization of 
     marijuana-related transactions, and the Act is in no way an 
     endorsement for the legalization of medical or retail 
     marijuana in those jurisdictions that choose not to pursue 
     such an approach. But regardless of how individual 
     policymakers feel about states permitting the use of medical 
     or recreational marijuana, the reality of the situation 
     requires federal rules that permit a sensible banking regime 
     for legal businesses.
       To address these challenges, we request that Congress 
     advance the SAFE Banking Act or similar legislation that 
     would provide a safe harbor for depository institutions that 
     provide a financial product or service to a covered business 
     in a state that has implemented laws and regulations that 
     ensure accountability in the marijuana industry. An effective 
     safe harbor would bring billions of dollars into the banking 
     sector, enabling law enforcement; federal, state and local 
     tax agencies; and cannabis regulators in 33 states and 
     several territories to more effectively monitor cannabis 
     businesses and their transactions. Compliance with tax laws 
     and requirements would be simpler and easier to enforce with 
     the regulated tracking of funds in the banking system, 
     resulting in higher tax revenues.
       Our banking system must be flexible enough to address the 
     needs of businesses in the various states and territories, 
     with state and territorial input, while protecting the 
     interests of the federal government. This includes a banking 
     system for marijuana-related businesses that is both 
     responsive and effective in meeting the demands of our 
     economy. We look forward to working with

[[Page E1216]]

     you as Congress moves forward in this process and to lending 
     our voice and expertise as you develop legislation.
           Respectfully,
       Phil Weiser, Colorado Attorney General; Karl A. Racine, 
     District of Columbia Attorney General; Aaron D. Ford, Nevada 
     Attorney General; Wayne Stenehjem, North Dakota Attorney 
     General.
       Kevin G. Clarkson, Alaska Attorney General; Mark Brnovich, 
     Arizona Attorney General; Leslie Rutledge, Arkansas Attorney 
     General; Xavier Becerra, California Attorney General; William 
     Tong, Connecticut Attorney General; Kathleen Jennings, 
     Delaware Attorney General; Leevin Taitano Camacho, Guam 
     Attorney General; Clare E. Connors, Hawaii Attorney General; 
     Kwame Raoul, Illinois Attorney General; Tom Miller, Iowa 
     Attorney General; Andy Beshear, Kentucky Attorney General; 
     Aaron M. Frey, Maine Attorney General; Brian Frosh, Maryland 
     Attorney General; Maura Healey, Massachusetts Attorney 
     General; Dana Nessel, Michigan Attorney General; Keith 
     Ellison, Minnesota Attorney General; Jim Hood, Mississippi 
     Attorney General; Gurbir S. Grewal, New Jersey Attorney 
     General.
       Hector Balderas, New Mexico Attorney General; Letitia 
     James, New York Attorney General; Edward Manibusan, Northern 
     Mariana Islands Attorney General; Dave Yost, Ohio Attorney 
     General; Mike Hunter, Oklahoma Attorney General; Ellen F. 
     Rosenblum, Oregon Attorney General; Josh Shapiro, 
     Pennsylvania Attorney General; Wanda Vazquez Garced, Puerto 
     Rico Attorney General; Peter Neronha, Rhode Island Attorney 
     General; Sean Reyes, Utah Attorney General; T.J. Donovan, 
     Vermont Attorney General; Denise N. George, U.S. Virgin 
     Islands Attorney General; Mark R. Herring, Virginia Attorney 
     General; Robert W. Ferguson, Washington Attorney General; 
     Patrick Morrisey, West Virginia Attorney General; Joshua L. 
     Kaul, Wisconsin Attorney General.
                                  ____

       On behalf of the 1.3 million members of the United Food and 
     Commercial Workers International Union (UFCW), including 
     thousands of cannabis workers, we urge you to vote ``yes'' on 
     the Secure and Fair Enforcement Banking Act of 2019 when it 
     comes to the House floor.
       UFCW's cannabis members can be found in growing and 
     cultivating facilities; manufacturing and processing 
     facilities; and in laboratories and dispensaries in multiple 
     states.
       The current ban on banking access for cannabis related 
     businesses has led to confusion and uncertainty for cannabis 
     workers who are just trying to do their jobs and support 
     their families. The lack of uniform treatment of cannabis by 
     federal, state and local laws has resulted in workers being 
     denied personal loans for homes and cars, even when they have 
     high credit scores. Hardworking Americans in the cannabis 
     industry should not have to struggle with financial and legal 
     ambiguity while on the job.
       Since cannabis employers must pay their workers in cash, 
     they are also vulnerable to violent crime both inside and 
     outside their place of business. When employers gain access 
     to conventional banking, their workers gain both economic and 
     personal security.
       A majority of states have some form of legal cannabis and 
     it is imperative that the federal government update our 
     nation's banking laws to include this new and growing 
     industry.
       As the nation's largest union of cannabis workers, we urge 
     Congress to pass the SAFE Banking Act and give cannabis 
     workers access to the same financial systems that all other 
     American workers enjoy.
     Ademola Oyefeso,
       International Vice President, Director, UFCW Legislative & 
     Political Action Department.
                                  ____





                                 American Bankers Association,

                                               September 24, 2019.
     Hon. Nancy Pelosi,
     Speaker, House of Representatives,
     Washington, DC.
     Hon. Kevin McCarthy,
     Minority Leader, House of Representatives,
     Washington, DC.
       Dear Speaker Pelosi and Minority Leader McCarthy: The 
     American Bankers Association (ABA) is pleased to express our 
     support for H.R. 1595, the Secure and Fair Enforcement 
     Banking Act (SAFE Banking Act) of 2019, which is scheduled 
     for consideration before the House of Representatives in the 
     coming days.
       Currently, 33 states covering 68 percent of the nation's 
     population have legalized cannabis for medical or adult-use 
     and at least seven additional states are expected to consider 
     ballot initiatives in the next two years. Despite that, 
     current federal law prevents financial institutions from 
     .banking cannabis businesses, as well as the ancillary 
     businesses that provide them with goods and services. As a 
     result, a majority of states are struggling to address the 
     significant challenges to public safety, as well as 
     regulatory compliance and tax compliance that go hand-in-hand 
     with cash-reliant businesses. Although we do not take a 
     position on the legalization of marijuana, our members are 
     committed to serving the financial needs of their 
     communities--including those that have voted to legalize 
     cannabis.
       H.R. 1595, sponsored by Representatives Ed Perlmutter (D-
     CO), Denny Heck (D-WA), Steve Stivers (R-OH) and Warren 
     Davidson (R-OH), along with over 200 members of the House, 
     takes an important step toward enabling financial services 
     for cannabis-related businesses.
       The bill specifies that proceeds from a legitimate cannabis 
     business would not be considered unlawful under federal money 
     laundering statutes or any other federal law, which is 
     necessary to allow financial services to cannabis businesses 
     and any ancillary businesses that derive some portion of 
     their income from cannabis businesses. The bill would also 
     direct the Financial Crimes Enforcement Network (FinCEN) and 
     the federal banking regulators, through the Federal Financial 
     Institutions Examination Council, to issue guidance and exam 
     procedures for banks doing business with cannabis related 
     legitimate businesses. We believe such explicit, consistent 
     direction from federal financial regulators will provide 
     needed clarity for banks and help them to better evaluate the 
     risks and supervisory expectations for cannabis-related 
     customers.
       As the legal state-cannabis industry continues to grow, the 
     indirect connections to cannabis revenues--from real estate 
     owners, security firms, utilities, law firms and employees of 
     cannabis businesses, as well as investors--will also continue 
     to expand. Without greater clarity, that entire portion of 
     economic activity in legal cannabis states--estimated by some 
     to be in the tens of billions of dollars--will continue to be 
     marginalizes from the banking system.
       Providing a mechanism for the cannabis industry to access 
     the banking system would help those communities reduce cash-
     motivated crimes, increase the efficiency of tax collections, 
     and improvethe financial transparency of the cannabis 
     industry. It would also subject cannabis businesses to 
     increased oversight of their financial activities since bank 
     accounts are monitored in accordance with existing anti-money 
     laundering and Bank Secrecy Act requirements which help law 
     enforcement identify suspicious transactions--an opportunity 
     that is not available in an all-cash environment.
       The SAFE Banking Act, as amended, is an important measure 
     that helps clarify many issues for the banking industry, 
     regulators, businesses and consumers. It also provides 
     immediate relief for urgent public safety and cannabis 
     industry oversight challenges, which will help keep our 
     communities safe and should not be delayed while Congress 
     works to build consensus on broader questions of national 
     drug policy. ABA urges members of the House to support H.R. 
     1595.
           Sincerely,
                                                      Rob Nichols,
     President and CEO.
                                  ____

                                               September 19, 2019.
     Hon. Nancy Pelosi,
     Speaker, House of Representatives,
     Washington, DC.
     Hon. Kevin McCarthy,
      Minority Leader, House of Representatives,
     Washington, DC.
       Dear Speaker Pelosi and Minority Leader McCarthy: On behalf 
     of the undersigned state bankers associations, representing 
     banks throughout the country, we write to express our support 
     for H.R. 1595, the Secure and Fair Enforcement (SAFE) Banking 
     Act of 2019, which will soon be considered before the House 
     of Representatives.
       Since 1996, 33 states comprising 68 percent of the nation's 
     population have legalized cannabis for medical or adult use, 
     and that number is only expected to grow. Despite this ever-
     growing voter preference, current Federal law continues to 
     prevent banks from offering products and services to these 
     businesses without fear of federal sanctions. Inevitably, 
     leaving the cannabis industry unbanked presents serious 
     public safety, revenue administration, and legal compliance 
     concerns and must be remedied immediately.
       As a result of the federal prohibition and lack of 
     regulatory clarity, legal cannabis businesses must operate on 
     an all-cash basis, subjecting their employees and the general 
     public to serious risk of criminal activity and harm. These 
     businesses also must remit payments for state taxes and 
     licensing fees in cash, denying the states the efficiencies 
     and safety of more modern payment methods. This in turn 
     significantly increases state compliance auditing costs, 
     since operating on an all-cash basis leaves no paper trails 
     for auditors to follow.
       The impact on local economies is also significant. As the 
     cannabis industry continues to grow in states where it is 
     legal, unrelated businesses that provide products and 
     services to the industry also become ensnared in the problem. 
     Because revenue paid to them by cannabis businesses can be 
     considered monies derived from illegal activities, and 
     financial institutions that bank the unrelated businesses can 
     be accused of violating anti-money laundering laws. If banks 
     are forced to discontinue relationships with these unrelated 
     businesses, a significant portion of the economy in states 
     where cannabis is legal will be cut off from the regulated 
     banking system.
       Although we do not take a position on the legalization of 
     marijuana, our members are committed to serving the financial 
     needs of their communities--including those that have voted 
     to legalize cannabis. That is why we support H.R. 1595. This 
     is fair and balanced legislation that will permit depository 
     institutions to serve the needs of their customers in states 
     where cannabis is legal. The bill provides a mechanism for 
     the cannabis industry and its service providers to deposit 
     their cash in regulated financial institutions, which allows 
     banks to meet the needs

[[Page E1217]]

     of their communities and helps those communities reduce 
     cash--motivated crimes, increase the efficiency of tax 
     collections, and improve the financial transparency of the 
     cannabis industry.
       We urge you to support H.R. 1595 when this legislation 
     comes before the House.
           Sincerely,
       Alabama Bankers Association, Alaska Bankers Association, 
     Arizona Bankers Association, Arkansas Bankers Association, 
     California Bankers Association, Colorado Bankers Association, 
     Connecticut Bankers Association, Delaware Bankers 
     Association, Florida Bankers Association, Georgia Bankers 
     Association.
       Hawaii Bankers Association, Idaho Bankers Association, 
     Illinois Bankers Association, Indiana Bankers Association, 
     Iowa Bankers Association, Kansas Bankers Association, 
     Louisiana Bankers Association, Maine Bankers Association, 
     Maryland Bankers Association, Massachusetts Bankers 
     Association.
       Michigan Bankers Association, Minnesota Bankers 
     Association, Mississippi Bankers Association, Missouri 
     Bankers Association, Montana Bankers Association, Nebraska 
     Bankers Association, Nevada Bankers Association, New 
     Hampshire Bankers Association, New Jersey Bankers 
     Association, New Mexico Bankers Association.
       New York Bankers Association, North Carolina Bankers 
     Association, North Dakota Bankers Association, Ohio Bankers 
     League, Oklahoma Bankers Association, Oregon Bankers 
     Association, Pennsylvania Bankers Association, Puerto Rico 
     Bankers Association, Rhode Island Bankers Association, South 
     Carolina Bankers Association.
       South Dakota Bankers Association, Tennessee Bankers 
     Association, Texas Bankers Association, Utah Bankers 
     Association, Vermont Bankers Association, Virginia Bankers 
     Association, Washington Bankers Association, West Virginia 
     Bankers Association, Wisconsin Bankers Association, Wyoming 
     Bankers Association.
                                  ____

                                               September 19, 2019.
     Hon. Nancy Pelosi,
     Speaker of the House, House of Representatives,
     Washington, DC.
     Hon. Kevin McCarthy,
     Minority Leader, House of Representatives,
     Washington, DC.
       Dear Speaker Pelosi and Minority Leader McCarthy: On behalf 
     of our members, we write to express our support for H.R. 
     1595, the Secure and Fair Enforcement (SAFE) Banking Act of 
     2019 which is scheduled for consideration before the House of 
     Representatives in the near future.
       This important bipartisan legislation, introduced by 
     Representatives Ed Perlmutter (D-CO), Steve Stivers (R-OH), 
     Denny Heck (D-WA) and Warren Davidson (R-OH) and supported by 
     over 200 cosponsors would permit depository institutions to 
     serve the needs of their customers in states where cannabis 
     is legal.
       The House Financial Services Committee has held substantive 
     hearings on H.R. 1595 and worked cooperatively to solve the 
     practical problems caused by the disparate treatment of 
     cannabis under federal and state laws. Although we do not 
     take a position on the legalization of marijuana, our members 
     are committed to serving the financial needs of their 
     communities--including those that have voted to legalize 
     cannabis. The current threat of criminal and civil liability 
     under federal law is suppressing the provision of vital 
     financial services in the thirty-three states that have 
     legalized cannabis in some form.
       The SAFE Banking Act of 2019 provides a mechanism for the 
     cannabis industry and its service providers to deposit their 
     cash in regulated financial institutions, which allows our 
     members to meet the needs of their communities and helps 
     those communities reduce cash-motivated crimes, increase the 
     efficiency of tax collections, and improve the financial 
     transparency of the cannabis industry.
       Without congressional action, a significant portion of 
     economic activity, including those businesses with only 
     indirect connections to the cannabis industry, such as 
     vendors, suppliers, and utility companies, risk being 
     marginalized from the financial system in states with legal 
     cannabis industries. H.R. 1595 provides needed legal 
     protection and clarity for financial institutions to accept 
     deposits, extend credit, and provide other financial services 
     to individuals and businesses that derive some portion of 
     their income from legal state cannabis related activity.
       We urge members of the House to support H.R. 1595.
           Sincerely,
       American Bankers Association (ABA), Credit Union National 
     Association (CUNA), Independent Community Bankers of America 
     (ICBA), National Bankers Association (NBA).
                                  ____

         M B C A, Mid-Size Bank Coalition of America,
                                               September 23, 2019.
     Hon. Nancy Pelosi,
     Speaker of the House,
     Washington, DC.
     Hon. Steny H. Hoyer,
     House Majority Leader,
     Washington, DC.
     Hon. James E. Clyburn,
     House Majority Whip,
     Washington, DC.
     Hon. Kevin McCarthy,
     House Minority Leader,
     Washington, DC.
     Hon. Steve J. Scalise,
     House Minority Leader,
     Washington, DC.
       Speaker Pelosi, Majority Leader Hoyer, Majority Whip 
     Clyburn, Minority Leader McCarthy, and Minority Whip Scalise: 
     The Mid-Size Bank Coalition of America (MBCA) is writing to 
     urge House consideration of Secure and Fair Enforcement 
     (SAFE) Banking Act of 2019, which would allow the provision 
     of banking services to cannabis-related businesses (CRBs) 
     through a federal safe harbor. We deeply appreciate the House 
     Financial Services Committee's bipartisan passage of the bill 
     in March, and look forward to the full House passing it as 
     well.
       The conflict between federal and states laws and the 
     evolving legal and regulatory environment surrounding 
     cannabis has put banks and CRBs in an untenable position. 
     While the public policy question of whether cannabis should 
     be legalized is outside the scope of the MBCA charter, it is 
     greatly concerning that our member banks could find 
     themselves the subject of regulatory enforcement actions as a 
     result of extending services to legally licensed businesses 
     directly involved in cannabis commerce, or even businesses 
     that provide services to those cannabis businesses.
       While a variety of attempts have been made to restrict 
     federal enforcement of cannabis laws, including the Cole 
     Memorandum and the Leahy and Joyce-Blumenauer amendments, the 
     Director of the Financial Crimes Enforcement Network (FinCEN) 
     has stated unequivocally that it is a federal crime to sell, 
     manufacture or purchase marijuana (the terms used in the 
     Controlled Substances Act of 1970). It is therefore 
     prohibited under federal law to provide banking services to 
     CRBs, which includes a wide range of ancillary businesses 
     that have no direct involvement in the sale, manufacture or 
     purchase of marijuana. Even if banks attempt to avoid banking 
     businesses that are involved directly in the cannabis 
     industry, questions arise regarding businesses that may 
     service those cannabis establishments. Is a payroll processor 
     that provides services to a dispensary violating federal law, 
     and therefore ineligible for banking services? Is a real 
     estate developer who might have one property occupied by a 
     dispensary or grower likewise in violation? Unfortunately, 
     our member banks simply do not know what is allowed and what 
     we are not allowed to do. These questions assume enormous 
     importance due to the massive negative impact on banks 
     resulting from potential Bank Secrecy Act (BSA) and anti-
     money laundering (AML) violations. We fear, however, that due 
     to the complicated legal and regulatory environment, 
     violations could occur that result in significant 
     reputational, economic and legal damage despite our bankers' 
     best efforts to avoid violating federal laws and regulations.
       As of today, thirty-three states and the District of 
     Columbia have legalized cannabis for medical and/or adult 
     use, and, as such, this is now a national issue that requires 
     a federal solution. It is clear that only Congress can take 
     effective action to resolve these issues, and while the SAFE 
     Banking Act is not a perfect solution to the problem of a 
     federal-state conflict in this area, the MBCA supports the 
     SAFE Banking Act as an important step forward, and we urge 
     the House to consider it.
       The Mid-Size Bank Coalition of America appreciates your 
     attention to this critical matter. If you have any questions 
     about this letter or any additional information would be 
     helpful, please contact Brent Tjarks, the MBCA's Executive 
     Director.
           Sincerely,

                                           Alessandro DiNello,

                                                         Chairman,
                               Mid-Size Bank Coalition of America.


               MID-SIZE BANK COALITION OF AMERICA MEMBERS

       1. Ameris Bank (Moultrie, GA)
       2. Apple Bank (New York, NY)
       3. Arvest Bank (Fayetteville, AR)
       4. Associated Bank (Green Bay, WI)
       5. BancorpSouth (Tupelo, MS)
       6. BannerBank (Walla Walla, WA)
       7. BankUnited (Miami Lakes, FL)
       8. Banc of California (Santa Ana, CA)
       9. Bank of Hope (Los Angeles, CA)
       10. Bank Leumi USA (New York, NY)
       11. Bank of Hawaii (Honolulu, HI)
       12. Bank of the Ozarks (Little Rock, AR)
       13. Berkshire Bank (Pittsfield, MA)
       14. BOK Financial (Tulsa, OK)
       15. Bremer Bank (Saint Paul, MN)
       16. Busey Bank (Champaign, IL)
       17. Cadence Bank (Houston, TX)
       18. Cathay Bank (Los Angeles, CA)
       19. Cenlar FSB (Ewing, NJ)
       20. Centennial Bank (Conway, AR)
       21. CenterState Bank (Winter Haven, FL)
       22. Central Bancompany (Jefferson City, MO)
       23. Chemical Bank (Midland, MI)
       24. CIT Bank (Pasadena, CA)
       25. CIBC U.S. (Chicago, IL)
       26. City National Bank (Los Angeles, CA)
       27. Columbia Bank (Tacoma, WA)
       28. Commerce Bank (Kansas City, MO)
       29. Community Bank (De Witt, NY)
       30. Cullen/Frost Bankers (San Antonio, TX)
       31. Customers Bank (Phoenixville, PA)
       32. Dollar Bank (Pittsburgh, PA)
       33. EagleBank (Bethesda, MD)
       34. Eastern Bank (Boston, MA)
       35. East West Bank (Pasadena, CA)
       36. F.N.B. Corporation (Pittsburgh, PA)
       37. FirstBank Holding Company (Lakewood, CO)

[[Page E1218]]

  

       38. First Citizens Bank (Raleigh, NC)
       39. First Financial Bank (Cincinnati, OH)
       40. First Financial Bankshares (Abilene, TX)
       41. First Hawaiian Bank (Honolulu, HI)
       42. First Horizon Bank (Memphis, TN)
       43. First Interstate Bank (Billings, MT)
       44. First Merchants Bank (Muncie, IN)
       45. First Midwest Bank (Itasca, IL)
       46. First National Bank of Omaha (Omaha, NE)
       47. Flagstar Bank (Troy, MI)
       48. Fulton Financial (Lancaster, PA)
       49. Glacier Bank (Kalispell, MT)
       50. Great Western Bank (Sioux Falls, SD)
       51. Hancock Whitney (Gulfport, MS)
       52. Heartland Financial (Dubuque, IA)
       53. Hilltop Holdings (Dallas, TX)
       54. Independent Bank (McKinney TX)
       55. International Bancshares (Laredo, TX)
       56. Investors Bank (Short Hills, NJ)
       57. IBERIABANK (Lafayette, LA)
       58. Mechanics Bank (Richmond, CA)
       59. MidFirst Bank (Oklahoma City, OK)
       60. NBT Bank (Norwich, NY)
       61. Northwest Bank (Warren, PA)
       62. Old National Bank (Evansville, IN)
       63. Opus Bank (Irvine, CA)
       64. Pacific Premier Bank (Irvine, CA)
       65. PacWest Bank (Beverly Hills, CA)
       66. People's United Bank (Bridgeport, CT)
       67. Pinnacle Bank (Lincoln, NE)
       68. Pinnacle Financial Partners (Nashville, TN)
       69. Popular Community Bank (New York, NY)
       70. Provident Bank (Iselin, NJ)
       71. Raymond James Bank (Saint Petersburg, FL)
       72. Renasant Bank (Tupelo, MS)
       73. Rockland Trust (Rockland, MA)
       74. Sandy Spring Bank (Olney, MD)
       75. Seacoast Bank (Palm Beach, FL)
       76. ServisFirst Bank (Birmingham, AL)
       77. Signature Bank (New York, NY)
       78. Silicon Valley Bank (Santa Clara, CA)
       79. Simmons Bank (Pine Bluff, AR)
       80. South State Bank (Columbia, SC)
       81. Sterling National Bank (Montebello, NY)
       82. Stifel Bank & Trust (Saint Louis, MO)
       83. Synovus Bank (Columbus, GA)
       84. TCF Bank (Sioux Falls, SD)
       85. Texas Capital Bank (Dallas, TX)
       86. Third Federal Savings (Cleveland, OH)
       87. TIAA Bank (Jacksonville, FL)
       88. TowneBank (Portsmouth, VA)
       89. Trustmark (Jackson, MS)
       90. UMB Financial (Kansas City, MO)
       91. Umpqua Bank (Roseburg, OR)
       92. Union Bankshares (Richmond, VA)
       93. United Community Bank (Blairsville, GA)
       94. United Bankshares (Charleston, WV)
       95. Valley (Wayne, NJ)
       96. Washington Federal Bank, N.A. (Seattle, WA)
       97. Webster Bank (Waterbury, CT)
       98. WesBanco Bank (Wheeling, WV)
       99. Western Alliance Bank (Phoenix, AZ)
       100. Wintrust Financial (Rosemont, IL)