Private banking is a general description for banking , investment and other financial services provided by banks and financial institutions primarily serving high-net-worth individuals (HNWIs) – those with very high income or substantial assets. Private banking is presented by those who provide such services as an exclusive subset of wealth management services, provided to particularly affluent clients. The term "private" refers to customer service rendered on a more personal basis than in mass-market retail banking , usually provided via dedicated bank advisers. It has typically consisted of banking services (deposit taking and payments), discretionary asset management, brokerage, limited tax advisory services and some basic concierge services, typically offered through a gateway provided by a single designated relationship manager.
67-569: Banking originated in provision of some services of what is now seen as "private" banking. Early Venetian banks provided personal finance for wealthy families. Private banks came to be known as "private" to stand out from the retail banking and savings banks aimed at the new middle class . Traditionally, private banks were linked to families for several generations. They often advised and performed all financial and banking services for these families. Historically, private banking has developed in Europe (see
134-481: A notary before depositing the articles with a banker, and Law 123 stipulated that a banker was discharged of any liability from a contract of bailment if the notary denied the existence of the contract. Law 124 stipulated that a depositor with a notarized contract of bailment was entitled to redeem the entirety of their deposit , and Law 125 stipulated that a banker was liable for replacement of deposits stolen while in their possession . Cuneiform records of
201-494: A firm's position. Wells Fargo was exposed for opening millions of unauthorized bank accounts in 2016. This was done by the firm's retail bankers, who were encouraged or coerced by some supervisors. The CEO ( John Stumpf ) and other executives were dismissed. Regulators subjected the bank to fines and penalties, and customers reduced, suspended, or discontinued activities with the bank. The company suffered from heavy reputational damage and financial losses. Reputational risk
268-499: A foreigner thou mayest lend upon interest; but unto thy brother thou shalt not lend upon interest; that the LORD thy God may bless thee in all that thou puttest thy hand unto, in the land whither thou goest in to possess it. In general, it was seen as advantageous to avoid debt at all, to avoid being bound to someone else. Debt was to be avoided and not used to finance consumption, except when in need. However, laws against usury were among many
335-453: A foul smell caused employees to complain. Toyota recalled 8 million vehicles worldwide and froze the sales of eight models in the U.S. in January 2010 amongst pressure from the public, industry regulators and the media. By company estimates, Toyota lost approximately US$ 2 billion due to the recalls and subsequent lost sales. Additionally, Toyota was fined US$ 16 million for failing to report
402-570: A lower price than traditional private banking. These are called premium banking or priority banking services. They are meant for mass-affluent customers. The accounts do not generate as much revenue as traditional private banking, but given the number of customers, can provide sizeable revenue to the bank. In 2016, Credit Suisse and UBS replaced the phrase "private banking" with "wealth management"; private banking has faced reputational risk as an area for tax avoidance or even tax evasion . Private banking services are only accessible to customers with
469-474: A minimum amount of investible assets. For instance, in 2016, J.P. Morgan began requiring a minimum of $ 10 million in assets to qualify for private banking, with those with less being moved into their Private Client Direct program. Nevertheless, this seems to be an exception as a majority of banks establish the minimum threshold between $ 500,000 and $ 1 million. Indeed, private banking customers are frequently segmented according to their wealth. HNW are customers with
536-424: A niche that only caters to HNWIs—specifically those with liquidity over $ 2 million, though it is now possible to open private banking accounts with as little as $ 250,000 for private investors. An institution's private banking division provides services such as wealth management, savings, inheritance, and tax planning for their clients. For private banking services, clients pay either based on the number of transactions,
603-409: A percentage of AUM (e.g. 0.75% of entire AUM). A few banks offer both a transactional model and an advisory model. The clients choose what suits them. A recent industry trend is towards the advisory fee model, because margins on commissions may go down in the future. History of banking#Italian bankers The history of banking began with the first prototype banks , that is, the merchants of
670-605: A total worth between €500,000 and €5 million; very high net worth individuals (VHNWI), with assets ranging between €5 million and €30 million; and ultra high net worth individuals (UHNWI), with wealth in excess of €30 million. In terms of AUM, the world's 10 largest private banks (or private banking divisions/subsidiaries of large bank holding companies ), as of 2019, are: Results from Euromoney's annual private banking and wealth management ranking in 2019, which consider, amongst other factors, assets under management (AUM), net income and net new assets. UBS Global Wealth Management took
737-623: Is Banca Monte dei Paschi di Siena , headquartered in Siena , Italy, which has been operating continuously since 1472. Until the end of 2002, the oldest bank still in operation was the Banco di Napoli headquartered in Naples , Italy, which had been operating since 1463. Development of banking spread from northern Italy throughout the Holy Roman Empire , and in the 15th and 16th century to northern Europe. This
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#1732863172230804-867: Is a criminal offence in Switzerland, tax evasion is only a civil offence , not requiring banks to notify taxing authorities. In Switzerland, there are many banks providing private banking services. Switzerland has remained neutral since the Congress of Vienna in 1815, including through two World Wars. After World War I, the former nobles of Austro-Hungarian Empire moved their assets to Switzerland for fear of confiscation by new governments. During World War II, many wealthy people, including Jewish families and institutions, moved their assets into Switzerland to protect them from Nazi Germany. However, this transfer of wealth into Switzerland had mixed and controversial results, as beneficiaries had difficulties retrieving their assets after
871-552: Is recorded to have stolen from the deposits on occasion. The temple served as a depository for Aristotle, Caesar, Dio Chrysostomus, Plautus, Plutarch, Strabo and Xenophon. The temple to Apollo in Didyma was constructed sometime in the 6th century. A large sum of gold was deposited within the treasury at the time by king Croesus . In ancient India there are evidences of loans from the Vedic period (beginning 1750 BCE). Later during
938-471: Is that Jews are forbidden to charge interest upon loans made to other Jews, but obliged to charge interest on transactions with non-Jews. However, the Hebrew Bible itself gives numerous examples where this provision was evaded. Deuteronomy 23:19 Thou shalt not lend upon interest to thy brother: interest of money, interest of victuals, interest of any thing that is lent upon interest. Deuteronomy 23:20 Unto
1005-441: Is unbiased. They believe there is no incentive to push proprietary products, and the client gets the best of what they offer. A few banks claim to have a "strong advisory team" that reflects in the products they offer the client. A couple of banks also define their value proposition on their unified platform, their ability to comply with all regulations, yet serve the client without restrictions. Open architecture product platform
1072-445: Is where a private bank distributes all the third party products and is not restricted to selling only its proprietary products. Closed architecture product platform is where the bank sells only its proprietary products and does not entertain any third party product. These days the needs of the clients are so diverse that it is practically impossible for a bank to cater to those needs by its proprietary products alone. Clients today demand
1139-751: The List of private banks ). Some banks in Europe are known for managing the assets of some royal families. The assets of the Princely Family of Liechtenstein are managed by LGT Group (founded in 1920 and originally known as The Liechtenstein Global Trust). The assets of the Dutch royal family are managed by MeesPierson (founded in 1720). The assets of the British Royal Family are managed by Coutts (founded in 1692). Historically, private banking has been viewed as
1206-623: The Maurya dynasty (321–185 BCE), an instrument called adesha was in use, which was an order on a banker desiring him to pay the money of the note to a third person, which corresponds to the definition of a bill of exchange as we understand it today. During the Buddhist period, there was considerable use of these instruments. Merchants in large towns gave letters of credit to one another. Main: History of banking in China In ancient China, starting in
1273-579: The Persian Wars produced a government and culture sufficiently organized for the birth of a private citizenship and therefore an embryonic capitalist society, allowing for the separation of wealth from exclusive state ownership to the possibility of ownership by the individual. According to one source (Dandamaev et al. ), trapezites were the first to trade using money, during the 5th century BCE, as opposed to earlier trade which occurred using forms of pre-money. The earliest forms of storage utilized were
1340-595: The Qin dynasty (221–206 BCE), Chinese currency developed with the introduction of standardized coins that allowed easier trade across China, and led to development of letters of credit. These letters were issued by merchants who acted in ways that today we would understand as banks. Some scholars suggest that the Egyptian grain-banking system became so well-developed that it was comparable to major modern banks, both in terms of its number of branches and employees, and in terms of
1407-402: The counting of agricultural produce. Commencing in the late fourth millennia mnemonic symbols were in use by members of temples and palaces to record stocks of produce. Types of records accounting for trade exchanges of payments were first being made about 3200 BCE. The Code of Hammurabi , written on a clay tablet around 1700 BCE, describes the regulation of banking activity within
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#17328631722301474-595: The house of Egibi of Babylonia describe the family's financial activities as having occurred sometime after 1000 BCE and ending sometime during the reign of Darius I . These records suggest a "lending house" (Silver 2002), a family engaging in "professional banking..." (Dandamaev et al. 2004), and economic activities similar to modern deposit banking. Another interpretation is that the family's activities are better described as entrepreneurship rather than banking (Wunsch 2007). The Murashu family apparently took part in providing credit (Moshenskyi 2008). From
1541-570: The "parent brand" to gain a client’s trust and confidence. These banks have a strong presence across the globe and present private bank offerings as a part of the parent group. "One Bank approach" is where private banks offer an integrated proposition to meet clients personal and business needs. Since private banking concerns understanding a client’s need and risk appetite, and tailoring the solution accordingly, few banks define their value proposition along this dimension. Most modern private banks follow an open product platform, and hence claim their advice
1608-465: The 17th century, in parallel with the development of sophisticated agriculture, managing the assets of the royal family, nobility and the landed gentry. The United States has one of the largest private banking systems in the world, in part due to the 3.1 million HNWIs accounting for 28.6% of the global HNWIs population in 2010, according to the co-research of Capgemini and Merrill Lynch . Some American banks that specialize in private banking date back to
1675-491: The 19th century, such as U.S. Trust (founded in 1853) and Northern Trust (founded in 1889). Internationalisation of the economy, technological developments such as the internet and mobile phones ensure that banks have to innovate and look for new markets . For example, the growth of HNWIs is low in traditional private banking markets such as Europe, compared with Asia where the number of millionaires has grown to 3.6 million. Banks also provide some private banking services at
1742-599: The 6th century. Before the destruction by Persians during the 480 invasion, the Athenian Acropolis temple dedicated to Athena stored money; Pericles rebuilt a depository afterward contained within the Parthenon . During the reign of the Ptolemies, state depositories replaced temples as the location of security-deposits. Records exist to show this having occurred by the end of the reign of Ptolemy I (305–284). As
1809-450: The Empire described " letter from Caesar to Quietus " show rental monies to be collected from persons using land belonging to a temple and given to the temple treasurer, as decreed by Mettius Modestus, governor of Lycia and Pamphylia. A law, receptum argentarii , obliged a bank to pay its clients debts under guarantee. Cassius Dio advocated the establishment of a state bank, funded by
1876-418: The annual portfolio performance or a "flat-fee", usually calculated as a yearly percentage of the total investment amount. "Private" can also allude to bank secrecy and minimizing taxes through careful allocation of assets, or by hiding assets from the taxing authorities. Swiss and certain offshore banks have been criticized for such cooperation with individuals practising tax evasion. Although tax fraud
1943-525: The banking of taxes were known as peptoken-records. Trapezitica is the first source documenting banking ( de Soto – p. 41). The speeches of Demosthenes contain numerous references to the issuing of credit (Millett p. 5). Xenophon is credited to have made the first suggestion of the creation of an organisation known in the modern definition as a joint-stock bank in On Revenues written c. 353 BCE The city-states of Greece after
2010-446: The best of breed products and most banks have to follow an open architecture product platform where they distribute products of other banks to their clients in return for commission. Products offered to private banking clients include equities, fixed-income securities, structured products, foreign exchange, commodities, deposits and real-estate investments. Different banks charge their clients in different ways. There are banks that follow
2077-446: The boundaries of Athens, bankers' loans are recorded as having been issued on eleven occasions altogether (Bogaert 1968). Banks sometimes made loans available confidentially, which is, they provided funds without being publicly and openly known to have done so. In addition, they kept depositors' names confidential as well. This intermediation per se was known as dia tes trapazēs, translated from Latin as "God will trap you". A loan
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2144-593: The city. Thirty-five Hellenistic cities had private banks during the 2nd century (Roberts – p. 130). Of the settlements of the Greco-Roman world of the 1st century CE, three were of pronounced wealth and centres of banking: Athens , Corinth and Patras . Many loans are recorded in writings from the classical age, although a very small proportion were provided by banks. Provision of these were likely an occurrence of Athens, with loans known to have been provided at some time at an annual interest of 12%. Within
2211-563: The civilization (Armstrong); although still rudimentary, banking was well enough developed to justify laws governing banking operations. Later during the Achaemenid Empire (after 646 BCE), further evidence is found of banking practices in the Mesopotamia region. By the 5th millennium BCE, the settlements of Sumer , such as Eridu , were formed around a central temple. In the fifth millennium, people began to build and live in
2278-399: The civilization of cities, providing a structure for the construction of institutions and establishments. Tell Brak and Uruk were two early urban settlements. Banking as an archaic activity (or quasi-banking ) is thought to have begun as early as the latter part of the 4th millennium BCE, to the 3rd millennia BCE. Prior to the reign of Sargon I of Akkad (2335–2280 BCE )
2345-409: The code commissioned by Hammurabi , king of Babylon c. 1792 –1750 BCE. Law 100 stipulated that repayment of a loan by a debtor to a creditor was to be on a schedule with a maturity date specified in written contractual terms . Law 122 stipulated that a depositor of gold , silver , or other property must present all articles and a signed contract of bailment to
2412-527: The company is directly responsible for said event (as was the case of the Chicago Tylenol murders in 1982). Extreme cases may lead to large financial losses or bankruptcy , as per the case of Arthur Andersen . Reputation is recorded as an intangible asset in a company's financial records. Hence, damage to a firm's reputation has financial repercussions. Minor issues can be amplified by external social processes which lead to even more severe impacts on
2479-515: The decrease in economic activity after the fall of Rome and Islamic invasions, banking likely temporarily ended in Europe and was not revived until Mediterranean trade commenced again in the 12th century. Most early religious systems in the ancient Near East, and the secular codes arising from them, did not forbid usury . These societies regarded inanimate matter as alive, like plants, animals and people, and capable of reproducing itself. Hence if you lent 'food money', or monetary tokens of any kind, it
2546-509: The eastern parts of the United States. Ancient types of money known as grain-money and food cattle-money were used from around 9000 BCE as two of the earliest commodities used for purposes of bartering . Anatolian obsidian as a raw material for Stone Age tools was being distributed from as early as about 12,500 BCE, and organized trading of it was occurring during the 9th millennium BCE (Cauvin; Chataigner 1989). Sardinia
2613-402: The fourth millennium previously agricultural settlements began administrative activities. The temple of Artemis at Ephesus was the largest depository of Asia. A pot hoard dated to 600 BCE was found in excavations by The British Museum during 1904. During the time of the cessation of the first Mithridatic war, the entire debt being held at the time was annulled by the council. Mark Antony
2680-477: The historical roots of the modern banking system to medieval and Renaissance Italy , particularly the affluent cities of Florence , Venice and Genoa . The Bardi and Peruzzi families dominated banking in 14th century Florence, establishing branches in many other parts of Europe . The most famous Italian bank was the Medici Bank , established by Giovanni Medici in 1397. The oldest bank still in existence
2747-418: The issues promptly and endangering lives. More tangible financial harm became evident in 2014, when Toyota and the U.S. Justice Department agreed on a settlement of US$ 1.2 billion and a public admission of guilt from Toyota for neglecting the defects. The reputational aftermath of these events was measured by Rasmussen , who found that despite 59% of Americans finding Toyota at least somewhat "favorable", there
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2814-620: The loans. Reputational risk Reputational damage is the loss to financial capital , social capital and/or market share resulting from damage to an organization's reputation. This is often measured in lost revenue , increased operating, capital or regulatory costs, or destruction of shareholder value . Ethics violations , safety issues , security issues , a lack of sustainability , poor quality, and lack of or unethical innovation can all cause reputational damage if they become known. Reputational damage can result from an adverse or potentially criminal event, regardless of whether
2881-606: The mercantile practices from Greece (Parker). During 352 BCE a rudimentary public bank (known as dēmosía trápeza ) was formed, with the passing of a consular directive to form a commission of mensarii to deal with debt in the impoverished lower classes. Another source shows banking practices during 325 BCE when, on account of being in debt, the Plebeians were required to borrow money, so newly appointed quinqueviri mensarii were commissioned to provide services to those who had security to provide, in exchange for money from
2948-589: The middle of enclosed courtyards called macella on a long bench called a bancu , from which the words banco and bank are derived. As a money changer, the merchant at the bancu did not so much invest money as merely convert the foreign currency into the only legal tender in Rome—that of the Imperial Mint. Operations of banking within Roman society were known as officium argentarii . Statutes (125/126 CE) of
3015-597: The most important were the temple to Artemis in Ephesus , and temple of Hera within Samos , and within Delphi , the temple to Apollo . These consisted of deposits, currency exchange, validation of coinage, and loans. The first treasury to the Apollonian temple was built before the end of the 7th century BCE. A treasury of the temple was constructed by the city of Siphnos during
3082-516: The need for new buildings to house operations increased, construction of these places within the cities began around the courtyards of the agora (markets). Athens received the Delian league's treasury during 454. During the late 3rd and 2nd century BCE, the Aegean island of Delos became a prominent banking center. During the 2nd century, there were for certain three banks and one temple depository within
3149-446: The occurrence of trade was limited to the internal boundaries of each city-state of Babylon and the temple located at the centre of economic activity therein; trade at the time for citizens external to the city was forbidden. In Babylonia of 2000 BCE, people depositing gold were required to pay amounts as much as one sixtieth of the total deposited. Both the palaces and temple are known to have provided lending and issuing from
3216-460: The operators or pilots. It was discovered that Boeing had offshored the software development to low pay overseas Indian software programmers with no experience in flight critical code. Boeing, grilled in congress for safety lapses, eventually fired the CEO for putting "profits ahead of safety". The planes were grounded for over a year while defects were corrected and airworthiness could be re-certified. He
3283-458: The prophets condemned the people for breaking. The interpretation that interest could be charged to non-Israelites would be used in the 14th century for Jews living within Christian societies in Europe to justify lending money for profit. This conveniently side stepped the rules against usury in both Judaism and Christianity, as Christians were not involved in the lending but were still free to take
3350-455: The public treasury. Another source (J. Andreau) has the shops of banking of Ancient Rome firstly opening in the public forums during the period 318 to 310 BCE. In early Ancient Rome deposit bankers were known as argentarii and at a later time (from the 2nd century CE onward) as nummularii (Andreau 1999 p. 2) or mensarii . The banking-houses were known as Taberae Argentarioe and Mensoe Numularioe . They would set up their stalls in
3417-484: The rudimentary money-boxes (ΘΗΣΑΥΡΌΣ ) which were made similar in form to the construction of a bee-hive, and were found for example in the Mycenae tombs of 1550–1500 BCE. Private and civic entities within ancient Grecian society, especially Greek temples , performed financial transactions. (Gilbart p. 3) The temples were the places where treasure was deposited for safe-keeping . The three temples thought
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#17328631722303484-565: The sale of all the properties owned at the time by the state. In the 4th century monopolies existed in Byzantium and in the city of Olbia in Sardinia. The Roman empire at some time formalized the administrative aspect of banking and instituted greater regulation of financial institutions and financial practices. Charging interest on loans and paying interest on deposits became more highly developed and competitive. The development of Roman banks
3551-587: The top spot in Euromoney's 2019 survey for "Best private banking services overall 2019". This table displays results of one category of the private banking ranking, "Best global private banking services overall 2019". Most private banks define their value proposition along one or two dimensions, and meet the basic needs across others. Some of the dimensions of value proposition of a private bank are parent brand, one-bank approach, unbiased advice, strong research and advisory team and unified platform. Many banks leverage
3618-665: The total volume of transactions. During the rule of the Greek Ptolemies, the granaries were transformed into a network of banks centered in Alexandria, where the main accounts from all of the Egyptian regional grain-banks were recorded. This became the site of one of the earliest known government central banks, and may have reached its peak with the assistance of Greek bankers. According to Muir (2009) there were two types of banks operating within Egypt: royal and private. Documents made to show
3685-401: The transactional model where the client is not charged any advisory fee at all. The banks thrive totally on the commissions they get by distributing third party products. There are other private banks that follow a hybrid model. In this model, the bank charges a fixed fee for certain products and advisory fee for the rest. Some of the other banks are totally advisory driven and charge the clients
3752-475: The war. After World War II, in eastern Europe, assets were again moved into Switzerland for fear of confiscation by communist governments. Today, Switzerland remains the largest offshore center, with about 27% ($ 2.0 trillion) of global offshore wealth in 2009, according to Boston Consulting Group . Offshore wealth is defined as assets booked in a country where the investor has no legal residence or tax domicile. In Great Britain , private banks were established in
3819-543: The wealth they held—the palaces to a lesser extent. Such loans typically involved issuing seed-grain, with re-payment from the harvest. These basic social agreements were documented in clay tablets, with an agreement on interest accrual . The habit of depositing and storing of wealth in temples continued at least until 209 BCE, as evidenced by Antiochus III having ransacked or pillaged the temple of Aine in Ecbatana ( Media ) of gold and silver. More information comes from
3886-589: The world's largest banks, and provoked much debate about bank regulation . The shift from a reliance on hunting and gathering of foods to agricultural practices , starting sometime after 12,000 BCE, resulted in increased stability of economic relations. Such changes in socio-economic conditions began approximately 10,000 years ago in the Fertile Crescent , about 9,500 years ago in northern China, about 5,500 years ago in Mexico, and approximately 4,500 years ago in
3953-541: The world, who gave grain loans to farmers and traders who carried goods between cities. This was around 2000 BCE in Assyria , India and Sumer . Later, in ancient Greece and during the Roman Empire , lenders based in temples gave loans, while accepting deposits and performing the change of money . Archaeology from this period in ancient China and India also show evidences of money lending . Many scholars trace
4020-459: Was a significant portion (29%) who found Toyota "very unfavorable". A Boeing 737 Max jet crashed in 2018 in Indonesia killing 189 people then in 2019 another jet crashed killing 157 people. Boeing initially blamed lack of training and pilot error. Later it was discovered the aircraft had a secret pitch adjustment system called MCAS that would override pilot input. This was never disclosed to
4087-586: Was followed by a number of important innovations that took place in Amsterdam during the Dutch Republic in the 17th century, and in London since the 18th century. During the 20th century, developments in telecommunications and computing caused major changes to banks' operations and let banks dramatically increase in size and geographic spread. The 2007–2008 financial crisis led to many bank failures , including some of
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#17328631722304154-558: Was further worsened in 2019 when new legislation was introduced by the House of Representatives. The new legislation uncovered Wells Fargo's practice of offshoring thousands of American jobs and forcing soon to be unemployed workers to train their foreign replacements. Wells Fargo reputation was further damaged when an Indian Wells Fargo executive was caught urinating on a fellow passenger on an international flight, and again when an employee died at her desk and no one noticed for over 4 days until
4221-601: Was legitimate to charge interest. Food money in the shape of olives, dates, seeds or animals was lent out as early as c. 5000 BCE, if not earlier. Among the Mesopotamians , Hittites , Phoenicians and Egyptians , interest was legal and often fixed by the state. The Torah and later sections of the Hebrew Bible criticize interest-taking, but interpretations of the Biblical prohibition vary. One common understanding
4288-404: Was limited, however, by the Roman preference for cash transactions. During the reign of the Roman emperor Gallienus (260–268 CE), there was a temporary breakdown of the Roman banking system after the banks rejected the flakes of copper produced by his mints. With the ascent of Christianity, banking became subject to additional restrictions, as the charging of interest was seen as immoral. With
4355-468: Was made by a Temple of Athens to the state during 433–427 BCE. Roman banking activities were a crucial presence within temples. For instance the minting of coins occurred within temples, most importantly the Juno Moneta temple, though during the time of the Empire, public deposits gradually ceased to be held in temples, and instead were held in private depositories. Still, the Roman Empire inherited
4422-507: Was one of the four main sites for sourcing the material deposits of obsidian within the Mediterranean; trade using obsidian was replaced during the 3rd millennium BCE by trade of copper and silver . Objects used for record keeping, " bulla " and tokens , have been recovered from within Near East excavations , dated to a period beginning 8000 BCE and ending 1500 BCE, as records of
4489-647: Was replaced by then Boeing chairman Dave Calhoun. In 2024 a door plug fell off a Max 737 airplane operated by Alaska Airlines. United Airlines - one of the major customers of Boeing stated they no longer have confidence in Boeing to meet its contractual obligations. Southwest Airlines stated they were turning to Airbus - a Boeing competitor - for new airplanes. The persistent and ongoing quality lapses have tarnished Boeing's reputation. "The 737 MAX crisis severely damaged Boeing’s reputation and eroded trust among key stakeholders, including airlines, passengers, regulators, and
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