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were all State-chartered mutual savings banks. Fla. Stat. Ann.
secs. 655.012, 655.005, 665.012 (West 1984). Respondent’s
position with respect to section 591(b) is a reiteration of the
position that Southwest and Pinellas, as commercial banks, are
necessarily excluded from the types of institutions eligible for
the special reserve method of accounting under section 593.
As previously discussed, although chapter 655 applies to
financial institutions generally, Florida law distinguishes
between institutions chartered as mutual savings banks under
chapter 665 and those chartered as banks under chapter 658. Fla.
Stat. Ann. secs. 665.012, 655.005 (West 1984). Both Southwest
and Pinellas were chartered as banks under chapter 658 and,
therefore, were not subject to and were not operated under the
same statutory provisions that apply to mutual savings banks and
associations as contemplated by section 591(b).
The nature of the disputes between the parties in these
cases convinces us that the emphasis that respondent places on a
charter is justified. If any financial institution were
permitted to use the reserve method of accounting under section
593 and then, when challenged, to argue that the nature of its
operations was controlling, the administration of section
7701(a)(19), section 593, and related regulatory provisions would
be a practical nightmare. Petitioner’s position would add
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