The more things change, the more they stay the same. The guidance banks received in the 1863 from the first Comptroller of the Currency could easily be cut-and-pasted into an alert from the modern-day regulator.

The Office of the Comptroller of the Currency celebrated its 150th anniversary this week with a day-long conference in Boston. A hand-out to attendees included a letter to national banks drafted by Hugh McColloch, the first comptroller, in an effort to advise bank executives of their responsibilities and his expectations. Much of the letter wouldn't have been out-of-place in a Dodd-Frank Act stump speech or Volcker rule pitch.

We've selected a few paragraphs to illustrate how little regulatory concerns have changed from the Reconstruction Era to the aftermath of the Financial Crisis. McColloch's letter even foreshadows the modern developments of excessive bonuses, proprietary trading, collateralized debt obligations, know-your customer controls, and the “splendid financiering” behind market and exchange rate manipulations.

“Let no loans be made that are not secured beyond a reasonable contingency. Do nothing to foster and encourage speculation. Give facilities only to legitimate and prudent transactions.”

“Distribute your loans rather than concentrate them in a few hands. Large loans to a single individual or firm, although sometimes proper and necessary, are generally injudicious and frequently unsafe. Large borrowers are apt to control the bank.”

“If you have reason to distrust the integrity of a customer, close his account. Never deal with a rascal under the impression that you can prevent him from cheating you. The risk in such cases is greater than the profits.”

"Pay your officers such salaries as will enable them to live comfortably and respectably without stealing; and require of them their entire services. If an officer lives beyond his income, dismiss him, even if his excess of expenditures can be explained consistently with his integrity. Still dismiss him. Extravagance, if not a crime, very naturally leads to crime.”

“The capital of a bank should be a reality, not a fiction; and it should be owned by those with money to lend, and not by borrowers.”

“Pursue a straightforward, upright, legitimate banking business. Never be tempted by the prospect of large returns to do anything but what may be properly done under the National Currency Act. ‘Splendid financiering' is not legitimate banking, and ‘splendid financiers' in banking are generally either humbugs or rascals.”

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