Bank was largely driven by the money collected from Black soldiers. In the bank's first year, in 1865, two of the branches established were created through the transfer of existing local military savings institutions. Many other branch locations were chosen specifically based on the local Black soldier population. Bank officials made efforts to build the bank legitimacy and deposits raising part of the Black soldiers’ wages. For example, many cashiers at branches also worked as military disbursing officers. Fraud and other financial misconduct From the Freedman's Savings Bank's creation, there were several deficiencies in its governance and management that contributed to its ultimate collapse. The bank trustees had little incentive to govern effectively. All fifty original trustees were White and were not required to give "any security for the faithful discharge of their trust." Many trustees had little to no involvement with the bank, some even denying they had agreed to join the board. The bank's founding charter lacked any penal clauses to hold trustees personally liable for the bank's solvency. It prohibited lending until the amendment of 1870. While two-thirds of the bank's deposits were required to be invested in U.S. government securities, the use of the remaining funds was unrestricted; Osthaus wrote that this provision was "somewhat disquieting to those familiar with the history of savings banks, for they knew that available funds frequently became unavailable". There is also evidence that the bank's management misled depositors about a supposed government guarantee, interest payments, and the use of the deposit funds. During its initial years, the bank marketed itself widely to attract deposits, distributing bank pamphlets at churches and Freedmen's Bureau schools, advertising in local newspapers, and holding public meetings at churches, beneficial societies, and the bank's branches. Its advertisements often depicted the bank as having the backing and guarantee of the federal government, but as a private corporation it had no guarantee. For example, an article in the Semi-Weekly Louisianan stated: "there is no possibility of loss, for the reason that the government of the United States is responsible for every dollar deposited." The bank promised its depositors 6% interest, but often paid a lower rate. The bank's management closely linked its affairs to the investment bank Jay Cooke and Company, which invested heavily in railroads. As head of the finance committee of the bank, Henry D. Cooke, Jay Cooke’s brother, deposited a significant share of the cash