Untitled Texas Attorney General Opinion

THE ATTORNEY GENERAL OFTEXAS AUSTIN. TEXAN e This Opinion f Modifier OpMon Honorable J. T. ?6oMillln Deput9 Comuini~loner Department of Bankinp, Auatln, Texas Dear Sir!. Opinion Ho.. O-1938 Rer State ,bankr - Iuaorporation k Fesr tar amendment of ahar- ter - Delinquent teen - Collection by fhe preeent Commlrrioner We aaknouledge receipt of the following re- quest far ar~oplnion, to-wit; -_._ "This io to aaknorlsdge the mat&p% of'your opinion In *hl-da you oonatrue the provielons’of Artlole 3521~0f the Revised Statutei, relative to Seer charged in oon- neotlon with the character8 bf benka and benke and truet ~oompanies. "Under that opinion a ice of $50.00 is aolleotlble,with any amendment. In addition .to thla See, if;the Pmendment in- cludes an lnareaee'of capital etoak in ex- aem of $10;000.00 then a fee of $10.00 ..~ per $lO,OOO.CO for aoh $lOIOOO.OO In ex- oem of the Sirat i 8 aolleotible. *Thh Department has been, ,ior a num- ber of' years, operating.under an erroneous oonetruation of AxMale 3921. It haa In the past aolleated only $50.00 in conueatlon with an9 emendmeixt lrrespeative of whether the amendment inareaeed the capital stock or not.~ Obviously It la the duty of the Honorable J. T. McYIllIn, page 2 present CommIasIoner to colleat this de- ficiency of ices in 80 far aa It was incurred during hle admlniatratlon. “It haa occurred to me, however, that It might poasiblg be my duty to’hatre the booka of thIa Department audited and to aol- lect the deficiency In fee&wbIoh arose during past admInIstratIona. Thin obvlous- ly would entail considerable expenre, and before undertaking such an operation I would like to reapecttilly submit the fol- lowing questiona: “1. Being aware that, during past ad- ministrationa, the several banking commla- sloners operating under an erroneous con- struotlon of Article 3921 have failed to collect the.full fees due the State In con- nection with the amendment of bank charters and the amendment of charters to bank and tN8t companies. Ia It my duty, aa the present Incumbent, to have the books of thIe Department audited for the purpose of determining the deficiency and the corgora- tions from whom fees are due., and to proceed to collect those fees? @2. In a number of lnetancea the bank%‘- in question, sate+ increasing their capital, have nat$onallced. Would thin fact in any-' wire affect by duty or the liability of the _ reapeative corporations to pay the feea In queationt “i. Subsequent to the Increase In oapltal rome of these corporationa have become lmolvent and/or either, are now In the process of liquidation, or have been &mpletelp liquidated. Ie it my duty to ,attempt to collect the fees In question from the Insolvent banks, if the rame la in the court of liquidation, or from the stock: holders If the bank Ie completely liquidated? Falling to collect, Is It my duty to pursue . the bond of the Commlaeioner under whose ad- ministration the shortage aro8aT” Honorable J. T. YcMIllln, Page 3 We have careft+ky oonsldered your questions and beg to answer them as follows: 1, By the terms Of Article 3921 of the Rep vised Civil Statutes, it is made the duty of the BankIng Comnissloner to charge a& receive for.the use of the State aertain aharter and charter amendments fee, as therein set out, It Is the duty of the Bw Com- missioner to oolleat all fees properly chargeable under this article of the statutes, whether such fees aa- aNi#ed under his admlnlstratlon or that of a predecessor.- It oan make no difference whether the delinquency was due to oversight, mIaconstructlon of the law, or other cause whatsoever. The law fixes the amount of such fees and it is not within the scope of the CommIssIoner~s power to remit the ssme, or any part thereof. What he cannot do directly he aannot do Indirectly, as by more failure for any retison to collect the proper fees. It will be seen that these fees are collectible by the Bankl~ Cotissloner, but:: they are for the we of the State. So that, no period of limitation will bar the State*8 rl&t to aolleot delinquent fees, or fees not paid through oversight or mistake. Of course, the Banking CommlsslonerIs clothed wLth the power to make such collea~lons. Your first wetion, therefore, is answered to the effect that 10 la the duty of the pzepent? Bsnk- lng CosWssloner to ascerta.ln.froti the books of your department the respective defiolenales, and the amounts thereof, dub by State banks, whose aharters have bien amended In accordance with the statutes, whether such . fees aoormed under 9vur om adminIstration or snother. 2. Where a State bsnk shown bg your boo&s to be Indebted to the State for charter of charter-smendment fees has natlonallsed, the dissolving corporation would, of course, be liable for such unpaid fees, and the National bank taking over its affairs ml&t or might not itself be liable; according to the terms of the aontract of take-over. In other words, a National Bank tskIng over the affairs of a State bank would become lndlvIdually liable only for such debts of the r(rtlx%g Stat6 bank as It assumed to pay but none other, Honorible J, T, YcXillin~ page 4 3. Whsre a bank shown by your books to be delinquent wltla respeot to oharter .or amendment of ahsr- ter $sdi'lrin pPooes8 of llquldatlon,you, as'llqul- dator of ::sudh bank, should list and ,approvq as .a claim on behal(lof the.atats of Texas the amount .of such de- lIn~ent*$ees, mase.,to ba pald.out 6f the assets ‘of the bank.a.8 a general unppdferred cU4.m~ If the llquida- tlon’ hasp bski ilnall olosed withoat the fiowanae of such a olalm~ it woJ d appear to be lost to the State. .Artl+le ‘465. of the .Bevised Olvil Statutes of Texas, authoriilng .&d risquIrIng the.deposltin trust by the B~~ng.;Cqnmifssl&er.of .a .~sumruffioIent to pay.the un+al@ed: dlvldends ang ~deposltors of. i f&tiled bank $8 ‘not .broad enough to corer, au& au item. Such un- gald ‘fess’ be to the ,State. do not constitute a’dlv%dend or deposit, wlthln the meaning .of *hat statute. Further- mare; :lf the liquidation has been blosed, aad the B-0 ing Com&ssloner has -been dlsahsrged, then he no longer has any offlalal dut oi. authotilty rith respeat4o .@ach llquldated bsnk ,or i t ‘a affairs. .As Banking Contmlssloner, he is; a:,+tmnger to the whole +atteri .. It ,$a no; the duty 'of' yourself~ as Banking Cgsm.%ssloner, in. any”eveat $0 undertake. the aolleatlon of ‘iuohmdeUnquent fees .upoa tie .:bond of: a redeaessor. of 9ows~'~der~~whoseadml.plrt~atloa thi deP lnqwen6y aa9 h+ve rClasti Tbo .Bank2~ Cosns%rsloner~s orfiaial- bond runs; to thi Stat? ,to ,be approved. by the Governor, (Rev.‘:. dir; Stat l Art l 3&j ,., ,and suaoes’sor CommIssloners. end therefor?&, are not .authorined to lnstltute suit upon suah ,a bond, for an$ breaap of.duty lfutsorver of a for&r .OaamUrlonerc llp&another, reading of our opinionNo. o-1841, we deslre.t6 dlsauss further the questlan there under aons$deratio& From ths opinion of Chlef’Justlae ealnes in St,Louis ~8.W.R9. 00. YE* Tad, 64 8.W. 778, we quote oxcerptaas foll6ws’ tat page 776779 1 s. , 6 . The determlnatlon of the aase depends upon the aonstructloa of so Honorable J, T. YcMIllIn, pagi 5 much of article 24.39 of the Revised Statutes as presarlbes the fees to be charged by the secretary of state for fllIng oharters or railroad corporations and smendments thereto. That~ part of the article reads as follows: *Art. ,2439. The secretary of state, besides athsr fees that may be pre- sarlbed by law, ti authorlsed and regired to charge for.the use of the state the fol- lowing fees8 For’ each and every charter’ amendment or supplement thereto of a prl- vate aorporatlan created for the punpose of operating or construoting a railroadi magnetla telegr- line, or street railway, or express company, authorized or required by law to be recorded in said department, a fee of one hundred dollars, to be paid when ssId.charter is filed; provided, that if the authorlsed capital stock of said cor- poration shall exceed one hundred thousand dollars, it shall be required to pay an ad- ditional fee of twenty-five dollars for each one hundred thousand dollars authar- lsed capital stock or fraatlonal part there- of, after the first.@. ‘. . .s “. . ~. On tie other hand, It is but _ just and equitable, whenever a corporation organized for profit tenders an amendment which increases .its aapltsl stock, that It should pay the additional tax for such in- arease, just as if it had filed an original charter with the same smount of oapltsl stock as the increase. . ‘.* a:. ‘. The reasoziab%e and equitable Nle upon the filing of an amendment is to charge for the amendment .the fixed fee as for an original. charteri snd, in case the amendment adds to the aapltal stock Honorable J, T, Mck!lllln, page 6 of the oorporatlon, to charge the same ad- ditional fee for such Increment as would be aharged for an original aharper with a aapltal stock of that smount, TMs is our oonstruatloa of what the legislature In- tended by the statute In questloa;and it is lnaonslstent with its terms, , ,* (atwee,7~9~7@) s, , . , We oonalude that the only reasonable construction of the statute in question 18 that when an~amendment to a ahsrter is filed, if there be sn increase of the capital stock by au amount ‘over $100,000, t&en the additional fee Is charge- able upon the excess of such increase over the amount named, but that, if the amendment does not authorize au Increase of stock, then the fixed fee 6f $100 only should be charged far its filing." A# the time the above oase was.declded, the statute therein Involved applied also to state banks and the filing fees for such bdnk&@ corporations were paid to the Secretary of State.' However, In 1917the Legislature provided that amendments to bank aharters should be filed with the BankIng Commlss~loner snd that he should charge the same fees as were then charged by the Secretary of State. Ch. 205, p, 469, _ General Laws, 35thLeg. Thereupon, in'~the 1925 codi- fication, Article 3921 appeared, reading In part as _iplbBBr "The BankIng Commlssloner shall charge; and receive for the use of the State the following Sees: 'I. . . . "For each charter, amendment or supple- ment thereto, of a bank or bank and trust company, a fee of fifty dollars'shall be paid when ka3.d charter is filed, and If the Honorable J. T. YcMlllln, page 7 authoriced aaplt'al stock of such aorpora- tlon exoeeds ten thousand dollars, it shall be required to pay an additional fee of ten dollars for iaoh additional ten thoussnd dollars of its authorlsed acpltsl stook or fraatlohaLai part thereof after the fir&, provide4 suah fee shall not exceed twenty-five hundred dollsrs.' It 1s readily seen that the present Article 3921 is praatlaally ldentloal dth the statute under oonslderatlon in the Tod aase, suptia. We advert to' a dlsausslon of Judge Gaines' language lnthat case. Be says that "it is but just.ard equitable, whenever a aomoratlon. . . tenders an am&sent which in - crea& its &pita stock, that it should pay @ ad- dltlonal tax for such increase. just as if it had filed an-orlnlnal charter rith the same smount of capital as the increase." Camp re an orl@ml charter Soti a corporation having a aapltal stoak of $~O,OOO.OO dth an amendment increasingthe capltai st&k'of another oorporatlon by ttie sum of $~O,OOOcOO.~ Judge Gaines plainly says that the fee for filing the amendment of the one corpora- tion should be the same asth6 fee for flllng the original charter of the other. For SIlIng the original chsrter the fee would be $90.00. The fee for filing' the amendment would'be the iame amount if we ape to regard~his language. Further on he says that #The reabonable and equitable mile upon the SllIng of an amendment is $0 charge for the amendment.the fired fee as for an.orlnlnal chartert end, In case the smendment adds to the oapital stock of the aorpora- tlon, to charge the ssme~addltlonalfee far au-& increment as would be aharged for an orlRIna1 charter tth a aavltal stock of that amount.". The,words "that axnotit" have referenoe to the amount of the. lmiwment. For~the~flllng~ of a charter the fee if 10.00 ~er~,#10,000.00 is not laid uppn ths first 10*000;00. ffths fee for sin smendment Inoludes t 10.00 for the first $lO,OOO.OO of the increase, then the aam& fee is not'belng charged for the fib lngof the smeadmeat as muld be aharged fati,the fll- lng of an orlgInal.chart&r with a capital Honorable J, T, ~abtillin,page 8 the 811018smount as the increment, A lsrger fee is being charged, The statute says that "For each darter, amendment or supplement thereto, of a bank or bsnk and trust oompany, a fee of fifty dollars shall be pal& when said Charter 1s filed, 'etc. Quite evl- dently, for the-to be entitled to the flfty- dollar fee for the SllIng of the smendwnt, the word "aharter" as underlined lnthe.quotatlan must be given the meaning "charter, smendment or supplement." We think this neaessarlly calls for the term "authorlxed capital stock" as theregfter used in the statute to mean nauthorlxed lnorease of a&tal stock" In oase of smendments. And such we.thlnk was the holding of Judge Galnes. Practically an identical statute govermthe fees collected by the Secretsry.of State from private corporations created for profit. Art. 394, Civil Statutes. Our construction of Art. 3921 is in aaaord 'with the opinion of Assltant Attorney General E.F. Smith to 9. L. Staples, Searetsry 6f State, dated August 23, 1921, pertaining to Art. 39l& From tha+ oplnlbn we quote: "Youi are therefore advised that the ____ flll,ng fee paid by a foreign corporation' does not entitle the corporation to file an amended charterincreasing its capital stock without payihg fifty dollsrs for the first ten thousand dollars of suoh Increase and tba dollars for each addl- tlonal tba thousand dollars of suoh in- crease *provided that in no event shall such fee exaeed the sum of twenty-five hundred dollars.~a Attorney General Pollard took the ssme posl- tlon in his brief filed In the ease of General Notors ;;ietance Corporation vs. YcCallum, in the Suprems However,'that aase w&s dealded without reachin& this ;oInt. 10 8.W. (2d) 687. It is our understandIng 656 Honorable J. T. McdcA[lllIn, page 9 that the construction placed on Art. 3821 has varlad from tlms to time in ths Ranklng~Dapsrtmant:-- Ffa also understand, however, thst the dspartmsntal praatlcs in the Ssarstary of Stats*s offios, with refarenas to Art1 3914, has bean uniform In fmmrdmas with this and %r. Smith*8 opinion an6 Sor an artandsd period of years. Es shoal6 not 1Iks to attsmpt to ravarss that oonstruotlon and praotiae, psctIcularly when rour&wl apon an opinion from the Attorney Genaral's Dapartasnt, without being at least fairly well oonvincad that it Is wrong. Our opinion No. C-184l is modlfled acoordlng- 19, and you sra sdvlsad that ths fee for tlllq, sn amsna- nent Inarsaslilg the oapltal stock ehoala bs $50.00, plan $lO.OO for eaoh $lO,OOO.OO (or fraotloael part thereof) of tha imrasss after the first ~lO,COO.OO. Yours very truly ATTCRNEYCENEFAL OF TXAf3 Assistant GRL:IK