The National Banking Act requires that all national banks “elect and appoint directors, and by its board of directors to appoint a president, vice president, cashier, and other officers.” 12 USC 24(5). (OCC publications use the terms “cashier” and “chief financial officer” interchangeably (for example, in its New Bank Organization Checklist, available here), so this requirement would likely be met even if using the “chief financial officer” title instead of the “cashier” title.)

 In contrast, the Illinois Banking Act requires only that the directors “elect one of their number as president” and “appoint such officers as the by-laws may provide.” 205 ILCS 5/12(a)(2), (4)see also 16(b)(5).