With so many banks in the U.S. by the late 19th century, surely there were some law departments?

A fascinating chapter in a recent book on natural experiments in history explains our country’s history of so-called free banking (anyone could set up a bank, rather than have to get government approval). According to Jared Diamond and James A. Robinson, Eds., Natural Experiments in History (Harvard Univ. 2010) at 98, in 1914 there were 27,349 banks in the United States, which sounds like fertile fishing for law departments. One-third of them were federal-chartered, and they controlled $11.5 billion in assets.

It’s unlikely, however, that in-house bank lawyers abounded, since almost none of the banks had branches. Stunted this way, most of them probably had no in-house lawyer. Still, even if only one out of a hundred was big enough to support an in-house lawyer, that leaves hundreds of possible departments. Was the first sizable U.S. law department (five or more lawyers) in a bank, a railroad, an insurance company?