Untitled Texas Attorney General Opinion

Honorable J. M. Falkper No. c- ‘.4aa Banking CommlsEiionerof Texas Austin, Texas ., Re: Under the given factual situation and the provisions of the Texas Trust Act, la the bank ~ln quektlon, as trustee, prohibited from depositing the '. !%Zc~e%~oslts lq its.de inatl- .iiatution for a period .of more~than.one y.earand 'related Deay Mr. Balkner:. ~questions. i 'You hav&~reQueated.our opinlon:on certain,Quesflons undetithe following relevant . facts: ‘!A6 &at& chartered.bank and trust.company has b.&nrx=&d:truatee tinderVarlou~;tri~stinden; 'tureswhich auttibx$zethe .bw-In its-.flduciary capacity,'irrespectlve~of any proviklon..or pakt bf'thk.%.xasTrust Act,..to'lnveat $r’shares of a savings- and loan tisociatlon located in ,the .s&nti zl$y and deposit money‘fn the trustee bank. The trustee Is &so given the right and ~1s requested to depdslt the income ftim the trust estates in the savlngs~and.loah asso&atlons'to earn the .curxent rate of Interest, "The tkstee~bank 'has deposllzedkth it&f on time c.ertiflcatea.ofdeposit.$37.500 which has been so deposited'for bn6 year. Trus'tee bank has alko deposited with a sayings and loan 'aasoc+atlonvarious savings accounts which form part of the trust'--eetates,under sbeclflc author- ization in the various trust -dentures ltitie,spect$ve PC any provlafon of the Texas Trust-Act. . . . : -2302- Honorable J.'M. Falkner, Page 2 ,(C-488) "The bank's directors own 85.4$ of the outstand- ing stock in the bank. The savings and loqn dlrec- tors own 97% of the outstanding stock In the savings and loan association. Mrectors of both the bank and the savings and loan association own 82.3% of the bank stock.and 77.6% of~the savings and loan stock." Under the foregoing facts you have.reqtieatedour opinion to the following questions: Is the trustee bank prohibited f’rom depositing the $& 500 In time certificate deposits In Its own ln- stltutl& for a.perlod of more than'one year? .2,. Is the.trus$ke bank prohibited from.maklng deposits In savings accounts ln.$he savings and loan of trust f'inxia assbclat$@ 3. If queatloti'number2 ls.anawered,ln,$he affirma-. tlve, then Uthe savings and loan asaociat~o~l~c~eaa~s its permanent reserve stock by selling shares-of additional stock, would.the trustee bank be prohibited from +ve%tlng tiuat funds In such'atock of the savings and loan asaocla- lqion? .Ir-some legal relatlonahlps, the.fiduclaryelement Is ‘inore Intense than In others. It la pecullar.ly,lntense in the caae'of a trust. While this fiduclary~relatlonahlp creates zinumber of duties, none Is more fundamental than the duty owed by the trustee .to the beneficiaries In the nature of the dtityof loyalty. This duty Is.sometimes characterized as.not permlttlng a trustee'to place hlm- self fi'a position where,lt would be Sor-his own benefit to violate his duties to the beneficiaries. This duty 6f 'lojralty Is based on‘a .generalprincipal ~of'pollby and morality which forblds~a fi'duclaryfrom placing himself' In a sltuatiotiwhere there is or could be 'confll.ct'b+ween his self-interest and his duty to others. See Scott on Trust, 8 170, Duty of $,yalty, et seq.. A number of .states.haveexpr&asly enacted statutes that set out the duty of loyalty.ln-clear and unambiguous terms. In Tegas; any dev$atlon.from this hi loyalty Is exprkssly prohibited by Article 7 which provides: -2303- . Honorable J. Mi Falkner, Page-3 (C- 488) II . but no act of the trustor shall relieve . . a corporate trustee from the duties, restrlctions,- .and llabllltles Imposed upon It by Sectldns 10, 11, and 12 of the Texas Trust Act." (Qnphasls added) Neither can the beneficiary relieve the trustee of the prohlbltlons contained in Sections 10, ll.and 12 of the Texag.Trust Act. See Article 7ti25b-23. However, pursuant'to Article 7425b-24 (E),V&nonls Civil Statutes, a court of competent jur$suict.ionmay modify or entirely relieve any trustee from any or all of ~he'duties,~llmltatlons and restrictions Imposed upon him by the Texas Trust Act,:to-wlt: "E. A court of competent lurlsdlction may, for cause.shown and upon notice to the beneficlarlc s:eve.a' trustee from any or all of the'dutlea, 'limitations,and restrdotlona~whlch .would.otherwlse be placed upon .hlm'bythis Act, or.whol.ly'oroartly release.and excu8e.a trustee..who .has acted'honestls and reationably,'f*m llablil~y.for~~olatloris of thk provisions of this Act." @nphasls .added).. ~_ Obviously.,the .princlpleswhich are applicable,to a corporate .truqtee are equally'applicable~to 'ocirooratiolis affiliated with.it. Bystatutory deflnltion, an affilllate IS .deflnedltiArtlc,ie'7.425b-J+(E) to mean: .. 11 any peraon.dlrectly or Indirectly con- trolil&'or controlled by.the person, or zany oer- son .under d1tiec.t or Indirect common'control wlth another'person . ;. V (Eknphaalsadded) The:aforementlbned Sections XI, .ll and ‘12 of the Texas Trust Act; that are equally appllcable.to both the corporate trustee and~any affiliate, are as follows: "Art. 74~5~io. Loan of.trust~funtis ~"Exkeptaa.&ovlded 'ln~Sectl& 11 oi:,+&ls.A&, a corporate trustee.shall not lend trust funds to Itself or an affiliate (as defined herein); or to at~,director,~offlcer, or employee of Itself 'or of an affiliate; nor.shall any noncorporate trustee lend trust funds to hImseLf, or to his relative, emplbyer,.employee, parttier,or.other business zy3oclate. -2304- . Honorable J. M. Falkner, Page 4 ,(~-488) '"Art.7$25b-11. Corporate trustee depositing trust funds with self "A corporate trustee may deposit with Itself trust funds which are being held Cendlng lnvest- ment, distribution, or to pay debts, provldedt maintains under control of Its trust department (If It .h+s a trust department separate from its banking department) as securlty'for such deposit a separate.fund consisting of securities legal for trust Investments which have at all times dur- lng the deposit a total market .value equal to the' .amountof the deposit. No such security shall be requlred to the extend said deposit Is Insured or otherwlse.secured by or under state or federal law. The separate fund of securltles.shall be marked as.such. Withdrawals from or additions to It may be made from time to time, as long as the required value.ls malntalned. The~lqcome of such securities shall belong to thencorporate trustee. "A& 7&2$b-12. ,mstee buying from orselld~ng to sel'f "A:trustee shaxl~not buy nor sell. either dl- rectly or indlrectly,~any property owned by or .-belongingto the.trust ,estate;: from or .to'ltaelf or an affiliate; or from orto ,a director, officer, or.emolcvee of such trustee..~drof an affiliate: or from &to himself, a relative, employer, ..part- ner or caner business associate; provlded,.a:natlon- al banking assdclation, or a state chartered bank andltrust company, or a statechartered trust company, or a state:.charteredbank having ~trust n~owetis, or any other.state chartered corporation having the Fight to exercise trust powers. when acting or~servlng as ~executor,administrator, .guarolan, trustee, or receiver, may sell-shares of the xapltal stock o.fltself'so owned .or held by Itself, -for any estate, to one.~o.rmore of Its officers, stockholders or directors, upon a court of comnetent jurisdiction .findlng that any such sale will be to the best interest ofthe estate owning such shares; flxlng or approving the price to be paid .therefor,and tlieterms of sale, upon entering an order,'.decpeeo,rjudgment, authorizing, approving and'dlrectlng such sale to'be made; and provided furtherthat a corporate trustee, executor, -230% :Honorable J..,M.Falkner,.Page 5 (C-488 ) In the absence of a court of competent jurisdiction relieving the trustee bank of the proi%slons of Sections 10, 11 and 12. '~upra,‘lt~ 1s the oplnlon'of this office