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SPRAGUE, 0. M. W. Foreign exchange* Lecture January 1 2 , 1912 The subject of my lecture today is "Foreign Exchange," 3?oreigli-i^0hari^# deems' couiino-nly to be regarded an u very Biy«t€riouB subject, one beset with innumerable conp3 ications. Th.e general principles of the subject are* however, by no means fib^truee* To conduct a Foreign .Exchange Department does reouire a special training and a certain natural aptitude, but any intelligent person can, 1 think, readily secure a general understanding of the subject taken as a whole, and such a general understanding is of much value, 2 think, to persons engaged in other "branches of banking. First let me define Foreign Kxohange* It is the business which is concerned with the buying and selling in one- country of • righto to .money in other countries, either immediate- or 'in':Vthe • future* Much of our Foreign Exchange business i& cloB^ly parallelled with certain kinds of domestic tueiness carried on in all tanks* I refer to the-business of making payments between different parts of the country. In particular, the domotic exchange ,are eloeely 'Analogous to the Foreign K-xohiuige b-usiness9 Dozoeotic Exchange rates riee and fall within oeytain limits, which are aet by the cost of shipping currency between any two placed* The quotations are usually expressed in a • 2 • premium or discount on one thousand dollars• If it costs, for B%amplm9 fifty cent© to ship ont thousand dollars between two places, the rate of exchange laay be anywhere up to fifty cents above or below par. Now, Foreign Exchange "Irate© fluctuate in exactly the -A way, fhey fluctuate above and below par to the export or import points, and these export and iraport points are determined by the cost of shipping, not currency, but gold, the quotations are, however, expressed in a somewhat different manner, and neoesearily so, "because of differences in currency betv/een different countries. It would be a moist roundabout fashion to express Foreign Exchange rate© in the terms used in Boaestic Exchange, although it would be possible. If it costs, for example, $2*50 to send one thousand dollars in gold to Bngland, then that |2»50 sets the limit to V the possible fluctuation in «cchange# in that way. The rate i® not expressed The par of exchange between the United States and England is f4*86-2/3, because the araount of gold in a sovereign makes, when coined into United States dollars, $4.86-2/3, and exchange rates fluctuate above and below $4.86~2/3 by the cost of shipping gold to England* In the case of France, the quotation is expressed in a slightly different fashion. Instead of being expressed in United State® isoney, it is. expressed in francs * in the number of francs which the gold in a dollar will make* How, the gold in a dollar will mak© 5 francs, 18 and a fraction centimes/^ A " 1 - 3 ~ Ixohang© on Paris, therefore, fluctuates above and below by the cost of shipping gold to Paris* Exchange on Berlin is*like that on London, expressed in United States money, but 3HB-' not erep*MM»g«H>Hh^ of taking the mark, 4 marks are made the basis of the quotation* low, the gold in 4 marks, coined into dollars, makes 95 and a fraction cents* Consequently, exchange on Berlin may rise and fall by the amount that it cost© to send gold to Berlin. When exchange is expressed in your own currency, a rising quotation indicates an approach toward the export point* It indicates that there is a demand for remittance to Burope say, Bngland «* which is in excess of the supply• gold export point to London is about |4.88. Thus, the When, however, quotations are expressed in the currency of a foreign country, just the opposite is the case. A fall in the quotation then indicates an approach toward the export point. That Mwi34H»e"* Suppose you have to make a payment of a thousand pounds in London* If exchange is toward the export point, you will m&te&**4m pay more, a£$$#*$S^, than if it were toward the Import point, because at the ©xport point you have to pay tht gold value of Jft sovereign plus the cost of shipping the sovereigns, andJ&Qj^JL&^^ If the rate were |4*88 you obviously would hav© ~ 4 - to pay more to get your thousand pound© than you would if the rate were |4*86* Suppose, however, you have to pay a thousand francs in Paris, and the quotation is expressed in francs*, Clearly you have to pay more to get your thousand francs in Paris if you can only get 5 francs 16 centimes for a dollar than if you could get 5 francs 18 centimes for a dollar* How a few words B,B to what determines the export and the import poin%&» gold? What are the expenses incurred in shipping fhe very obvious expenses are, freight, insurance, and the cost of packing the gold* These element© of expense, however, are somewhat variable; the freight charges inay not be uniform, and it makes a good deal of difference what sort of gold you are shipping* purpose is gold in bars* The moat inexpensive, form for the -ftifft cnn be packed more handily, end there is less loss froia abrasion than there is if you ship coin* Gold bars are secured from the United States treasury, a nominal charge being exacted. In the past it has not alv/ays been possible to get an adequate supply of gold bars, but in the future that difficulty will probably not present itself, because the Government has recently been empowered to hold gold in the form of bars against gold certificates in circulation* Formerly all the gold against the gold certificates had to be coined* Therefore, the export point will be in the future, cm the average, a little less than in the paett because now it will always be po>lble tn get gold bars* A irery important elegant of expense is time* If one of the faat express eteamern is sailing* the MIiUaitaniaf< for instance, the otqxrot point is lo^er than during a week when no faet sship is sailing. OJQ^M^^^ The interest, however, counts only in one direotion|^rt only in eaee you are importing* ryi|Siaafc«^ If you export a million dollars1 worth of gold,, you can sell sight exchange at once to an equivalent amount. quently, you are not out of your money at all* it is a cace of importing gold# Conse- Suppose, however, Tnmi you are out of the interest while the ^old ia in transit,v.and for ta?t reanon the goldi import point is somewhat further laiiaMi par than the gold export point# If we assume, for exa&ple, that the gold export point is about 1-1/2 ctsnts abf>ve par, then we will probably fin<l that the gold import point ia oomathing like 2 oento<rbelov/. Q^S&®^^ There has been a alow but pretty steady reduction in the possible range of exchange fluctuations iii^jy&s**^ J!ULjtfMM^ 20 or 30 years ago the export point was about $4*90* It is now in the neighborhood of (lAA^Us The import point then in the vicinity of £4.82, i t is now^pt g4,84. So far I have only spoken of sight exchange. A glance in the newspaper will show that there are various other rates regularly quoted, ~ hankers 1 hills a^isUsommwoial -toi"3fire- and various kinds of commercial bills, drawn for varying periods of time. Now t these rates are always below the sight rates. They vary with eight rates in a perfectly definite fashion, but they also vary for certain other reasons. If you should find that the sight rate was $4*86, you might find that the rate on bankers* sixty day bills was 14.83, and you might find that the rate on a certain class of commercial bills was $4.82-1/2, and on anotherkkind, perhaps, $4•82, The quotation on time bills is lea® than that for Bight exchange by the ^ont'of discounting theue lime bills in the foreign country on which they are drawn* * If the rate of discouni on a sixty day bankers 1 bill ie Z% in London, then the quotation for a bill of that sort in Hew York will Tje the sight rate of exchange in Hew York lees the discount on that bill in I^ -f If the discount rate in London advance© on that particular sort of bill, then the quotation oiuthat "frtifrl will move somewhat further away from the Bight quotations mr*t i&he reason that there are these different prices or quotations for various kinds of time bills is that there are a variety of discount rates in the London market, depending upon the character of the bill. The lowemt rate is secured by bills drawn on*and accepted by, a London banker. Then there are various other rates, running all the way up to the M bank rate; 11 that is, the rate of the Bank of England, whatever that may b#. A little description of the more important kinds of time bills will, perhaps, not be unnecessary* Most of the goods exported from this country to Europe give rise to documentary bills of exchange. The seller draws upon the purchaser, or upon the bank of the purchaser, and the various document© are attached to the bill of exchange, the moat important being the bill of lading, without which it will be impossible to secure possession of the goods. 1 Documentary bills are of various kinds, fhey may be documentary for payment, or documentary accept ance bills• If they are documentary payment bills, the purchaser of the good® cannot get possession of them until he has paid the bill of exchange„ Now, theee documentary payment bill© are of two general classes, first, those on perishable goods and othergoods which the purchaser is pretty certain to want iiamediately on arrival, and, second, those in connection with goods which the purchaser is not likely to want until the maturity of the b&ll* If the purchaser wants the goods and makes the payment, he is allowed a rebate, which is \% below the Bank of England rate, whatever that may be* Therefore, the price of such bills in this country is readily figured by taking the eight rate of exchange, determining what the Bank of England rate i@, deducting 1^, computing that rate of discount and deducting it from the sight I - 8 -; /-• / <4* oonfident of the solvtnoy or the credit of the drawer of the bill. If th@ goods are of a kind which are not likely to wanted by the purchaser until maturity, then you »-4k^^ London"/ 4S^#au^%*t2T'ft^'tt^&^f^ymk. or your agent in London may be obliged to hold it until it matures. But perhaps you would like the money, perhaps you do not care to finance this business during the life of the bill. You may in that caee use aucja bills as collateral with your London correspondent^ppjBaiy^'Wtnnet bo t they may be used a^ ^aa-l-larta^arl-'r-^awi you may draw your own #bi11 on ynrr Londnn correBpondent, the London correspondent afoceptl«ffr ti^^t bill, | W N i t can then be discounted* -1 itttxiB your balance will be built up. acceptance bi 11 s .^JSZvm^ are of two kinds^-thoae which are drawn for acceptance "by & merchant and those which are drawn for acceptance by a bank or accepting house. Naturally, the latter get the better rate in the London market, because Jfb»{f will be universally known andjrssU&fc-Hr^ of»«J&ittwr«^^ The documentary acceptance bills on merchants will be discounted at a slightly higher rate in London, and, consequently, the price of BUCII a bill in this country will be slightly lower than documentary acceptance bills on banker©. When goods are sold to other parts of the world than Buropt, the arrangements are somewhat different. We do not draw « 9 ~ bills ©n South Asierioan cities, for instance, to any appreciable extent, There is not a sufficiently broad market in bills of exchange to isa&e that a feasible arrangement* Th^re are a number of possible arrangements, but I shall only mention cm© of them* A commission house exporting goods to South America will, very likely, be paid in 90 day drafts on some London bank* which will be drawn by the Oouth American purchaser of the good® Well* this cleans that the commission house will be a long time out of its money* The time that the floods are going to South America, the time that is taken in sending the bill of exchange to Londonf- and 90 days thereafter..- something 3 ike six months will be absorbed before the maturity of this bill* wants its money. The commission house in Kew York It may itself draw a bill - a 90 day bill «• upon a 'London bank •» coswifff-!^^ .»J*isw^^ w h i c h the C&fflK""™* - an4 by selling its own 90 day bill in the Hew York market the co&aiBsion hou^a will get the ready cash* The 90 day bill will be sent to London and die-- counted on the London market* Thun t you. see that London realy finances, in such an instance* the shipment of goods from Hew York to £outh .America. When the 90 day bill falla due f the Hew York house nust', of course, provide payment^ an4-«iaaftl; js^TtWTffiy the South American bill is not yet due. It may pwr~ chase sight exchange in Hew York.! in order to meet its 90 day draft, and also draw another one to oover another 90 days, • 10 - the time-JtaJ* second draft reaches maturity the proceeds of the South American draft will be at hand. Thus, by drawing two bills, each for 90 days, the Hew YorS: commission house > will throughout the period have secured the funds, 4 ^ ^ ^ f e ^ ^ the London discount market* J^4J**^^ How let us take a case of imports to this country. The most common method of arranging payment is through a commercial letter of credit. Let us suppose that a Boston wool house is going to purchase a quantity of wool in Australia. a&#*2fHt±ti»^ It will %«•* secure, through some foreign exchange banker here, a credit with some London bank. Under the terms of this credit the agent in Australia of the Boston wool house will be empowered to draw documentary bill© of exchange up to a certain amount* The purchase of wool is made, the bill on the London bank ia drawn, the documents attached, and it is disposed of to some Australian bank. Thus the fund si are provided for the wool. The Australian bank sends this bill t0^S*aii^m with documents to its correspondent 3$gmm**> and at the same time, very likely, will ©ell an equivalent amount of eight exchange in Australia against the credits which'will be given it in London throughvthis long bill. _ *\A ^ ' -1 0 one 1 «HBDB# Hi i^ Australia has any further connection with this transaction. The correspondent of the Australian bank in London takes the bill, with its documents, to the London bank on which it is drawn for acceptance, Hpvinff been accepted by the London takes the documents, %M the bill is discounted ~ 11 - in the open market and the funds provided with which to meet the sight exchange which we assume the Australian bank had sold. The London bank which accepted and took the documents then n#€% .f( i< ix *v..*-^Ki^ sends ifamm on to this cmrntry, presumably to a shipping broker, according to instructions, or to the foreign exchange banker here through whoin the arrangements were made, fhe wool house cannot get possession of the wool until it can get these documents, and the foreign exchange banker need not give up these documents until he is provided with funds sufficient to pay the si^ht exchange on London necessary to meet the payment of ttmrt time bill accepted by the London bank* Thus everehody is secured at every point in the transaction, in B O far as the .wo«>l itself may be regarded as security. It is a natural 'query* I suppose, at this point* why we do not finance any of this business. It is largely because the demand for capital In this country is such that rates for loans are higher, ordinarily, here than they are in European cities, and particularly in London. ' rl Of course, commissions have to be paid alonft the line in connection with this transaction that I have outlined in the case of the wool, but even with the commissions added to the London rates of discount the cost is, ordinarily, not what it would be at our prevailing rates for loans. If a lower average rate for loans csmeB in this country, then we may presumably finance not a little of our foreign trade, though it is doubtful whether we shall at any time in the immediate future displace London* It - 12 - in of confix arable advantage to have souse one city in the world which ie a center for payment© for all of the other countries. Juet as in this country Hew York is the center for the payrn.fln.ti. of QJM&sdbs^ between different parts of the eoimtry, London occupies that position for the world at large$ largely for historical reasons, largely because of the extent of the English Empire, and even more because of the extent of English trade and investment©« It seems to me extremely unlikely that the position of London will, in any time that is worth while considering, be seriously threatened by Hew York, or by any other financial center* In the actual practice of exchange, bills are drawn on London; London jteelf draws very few bills indeed, In the case of our exports, for instance, commercial bills are at once drawn, and ordinarily those bills are discounted in the London market, and, as you have seen in the case of imports &&mmt while the goods are in transit the business is financed in London• The commercial bills of exchange drawn largely supply or feed the balances in London against which sight exchange ie sold. Our merchandise export© amount to something like SS,000,000,000.(|§ annually. That provides an enormous amount of bills of exchange, mostly time bills, drawn chiefly on London,and to a lesser extent upon other foreign financial centers. a year Our importa amount to something over 01,000,000,000. toefoggfiiLJt^^ They do not give - 13 ~ to any considerable quantity of time bills. They are paid, very largely, in sight exchange, and the possibility of providing sight exchange comas through the proceeds of the billn drawn againet exports. But merchandise paymenta do not make up, by any means, all of the foreign exchange material. whether they make up even half of it, of invisible exports and imports. It may be doubted There are a great variety Shipping charges, tourists1 expenditures, remittance© of home of foreign residents* are all very large items. Then there Is the interest upon foreign capital, and on the other side of the account there i© n w capital - additional capital - invested in thin country# there a»e^*i4i^ Then due to dealings in securities - resale to this country of securities held abroad* All these operations give rise to foreign exchange *• create foreign exchange * juet ae'zmch as merchandise dealings. of such dealings may be no one can say# What the total amount Bu/ there can be no question that we owe, year after year, prgmahly some thing like 15,QoSu 000.00 or $6,000,000.00, ana for/Vnat reason we must export nN%r.ehan«3ize to a greater value Ahan we import merchaii&iBe# In addition to all of these exchange creating factors, there is the matter of temporary loans made by one foreign market in another foreign market* variety of different ways, They may be made in a A foreign exchange hou^e enjoying good credit abroad may, for example, draw bills upon a London correspondent payable ©ay in three months* Those bills, if accepted by the London correspondent, may t>& readily discounted - 14 * thus giving the American exchange aouee credit to that extent in London, and enabling it to sell here an equivalent quantity of Eight exchange« That is what happens when you read about foreign borrowing. There is no money, ordinarily, sent acrooa. What actually happens is that a time bill is drawn on and accepted by a London bank, discounted in London and. sight exchange to an equivalent amount sold hers, thus giving the exchange house the money here, but no money lias passed between the two countries, this is done, maybe, by an exchange banker for one of his clients who nay deposit collateral securityh ere* Sometimes the initiative may be taken by a foreign bank which desires to loan ir* thi& market,. In that case it may or xs&y not assume the risk of a change in the Bight rate of exchange, for the profit in foreign loans in Tary largely determined by the course of the sight exchange rato. If, for example* trie sight rate of exchange ie #4»85 and a long bill is drawn, ©ay at $4*82, reflecting the discount rate in Loddoru Ko%f if you borrow in that way, when the long bill matures you irsust supply enough sight exchange to meet it. If the si^ht exchange rate remains at $4.8bf then you have only paid tra 3 cents on each pound for tae use of the money during the period, Suppose the Bi;:ht rate %M gone to &4»87 then^MJibMi h4v& to pay a good deal more - yru Uave to pay 5 centb for each pound* Xhio will explain largelyf I think, why Qjui^f^^^y these foreign loais do not involve' any lavement of money. Tney usually sJHKt when trie rate of exchange is high ~ toward the export point, "hen • 15 - we are approaching the export point aQji^j^ ^i^t**, and rates for loans, in Hew York, ^N^^^mm^e^^ are likely to be high, is the time that it may he desirable to borrow in foreign markets. For example, if you would have to pay 5^> on eollater&l loans in New York, and the rate in London is 3£J, than it may be worth your while to borrow in the way 1 have mentioned, and partieularly uo if the eight rate is around $4.87, or a littH higher, because then it can 1 1 get away from you very much. It canft go above £4.88 anyway, and it nay go much lower before you nave \o make the payment, and if it goes down that reduce© >*f®o much what you are actually paying for the money during the three months. If, however, you Bhould enter upon this transaction when the si^ht exchange rate wan |4.85, you would toe, ordinarily, very ill advised indeed, because the possibilities are that the ekchange rate might go up to $4*07 or &4.88f and then the cost of your loan would "be very heavy, what this borrowing does is to provide, "by rricuns of the loans, additional si^ht exchange, and it thu*"*, ]M£fhhff4hLff, prevents gold exports and brings down the sight rate of exchange but it does not involve - ij^4n&-w^r^^ - a positiTe xooyeisent of money. The foreign lender, as I intimated a moment ago, may be willing tn take the risk of a fluctuation in the 8-i^ht exchange rate, or he may not. If he in will in?:; to take the risk, he loans in currency. Suppose, for example, that the quotation on bankers1 time "bills is $4.83, and thai uomeone in !few York winhes to "borrow ?SQO,OQO*OO. A bill in drawn for, say, a hundred thousand pounds, on London, by the a^ent of the London bank, acting on instructions, That bill is eold for |4*83, and the proceeds are turned over to the wouldte borrower in Hew York; that is, he gets $483,000.00. Vhen the bill matures the borrower must return $483,000.00 plus whatever rate of interest han been agreed upon, let us say 5J-># The borrower has not been affected at all by fluctuations in sight exchange. "How, the foreign banker may desire to get back his money in London. He inBtructs his Hew "fork correspondent to buy Bi^ht exchange on London ^ttfp^BT^ If the rate has ^onn down, then the London bank go ins from having ansumed the risk. If the sight exchange rate is down to £4.05, for invfcfince, and it can buy a oi?ht draft on London for & hundred thousand pounds for t485t000.00, it gets, obvious]y>*father return than if the f rate ware #4 # 87 and it had to p&y g407f 000*00 in o n e r to get its money back to London, vr hen, therefore, the foreign banker is inclined to think that the rate for eight exchange i« going down, he will be rather willing to loan in currency in this market, if hi a - 17 - opinion is the other way, then the rink will h%%® to be p.noumed by the borrower here. He will \uz~u£sL£j£LJ&*i>i 11i) ^ but at the maturity of the 'bill he rrap.t provide the means for its liquidation, paying whatever the si^ht rate may be. You will thus see that interest rates have a profound influence upon the current or short time fluotuatione in exchange rates. If we should have an enormously large balance of p<^/fflentet for one reason or another - because of the falling off of merchandise emortn, because of the resale to this country of American securities held abroadf and so on,-no poraible temporary borrowing wouldt for any great length of time, prevent the exchange rate from moving tow^srtF^ the 1ja@fp point* But within very considerable limits it is ponsibie to postpone f?old moveraeiits, if in thie maricet interest rates reach a higher lAvel than those in the foreign countries to which it is to Kake payiaents. Under euoh cirouio^tanGei^^ if tVie credit of the isarivet remain a good in the foreign, country, yft^nfaii?*^^ # then very oonBiderable teaspor-* nry loano may ba !nadet and that provides, for the time being, si^ht exchange, but, of course, if youtfrav/a lot of three month bill£ now and ma-ke loans in that way, tit the end of thQ three months it it? neceseary to make payments, or saeura renewals, and renewals cannot be continued indefinitely* 1 :roay mention one instance: In the active markets • 18 - of 1906, enormous quantities of temporary indebtedness were incurred "by means of MIIB other European markets. of exchange drawn on London and In fact, the amount of such bills in that year wjuaJLJU>---4?ittc^ as to involve gold imports, rather an exceptional result of temporary borrowing. The jfr "C 4* "0' ^'*V a n o u n t o f s u c h b i l l n w a s so l a r g e t h a t lMW¥f*irth*thfi e n d o f t h e •*&i4$e they *;ere discriminated against in the London market, and then it became necessary to remit in payment, and that caused, very serious strain in our financial markets in the early part of 1907. Within moderate limits these bankers1 bills serve a very useful/ purpose, because they tend to greater steaciness of the oi&ht rate of exchange,-prevent its «oinu to m e export point when there is a very slight excess of demand for payment over the amount of London balances. ^vi^<. w AAticipatory Bills11 ^W^W^^^fff^ -c v Bunker a' bills drawn 1 'S in the Bummer becaune it is known that in the I?ajn , on account of cotlon exports, there will be a ^reat quantity of comrieroial paper coming into the market. Anticipatory bill8 are in no senr^e different fron any other bankers1 bills; it ie ©imply that, when used in moderate amounts and with that in view they really are anticipatory* The terra "Finance Bills11 is also used. a technical exureBsion. That is not It r«frt»&p»Tnea&8 that a large number of bankers1 billa are beinp: drawn in order to finance financial 5/28/54 Original memo in posession of Theodore Sprague, 13 Follin St. Cambridge, Mass. This document contains internal or confidential information and has been removed. Author(s): O. M. W. Sprague Title: Memorandum for the Council of National Defense: Gold and Credit Policies and Reconstruction Date: Page Numbers: 5/28/54 Original memo in posession of Theodore Sprague, 13 Follin St. Cambridge, Mass. MEMORANDUM ON THE GLASS-OWEN BANKING BILL 0. M. W. Sprague Converse Professor of Banking in Harvard University. In forming an opinion regarding the merits of the GlassOwen Bill for the reform of our banking system, the measure must be considered from three points of view. In addition to some changes in the powers of the national banks, the bill provides for the establishment of entirely new banking machinery— at least twelve regional reserve banks under the supervision tfed in the exercise of some of their powers under the control of a Federal Reserve Board. Whether these new powers granted the national banks and whether the new banking mechanism, if properly handled, will remove the recognized defects in our banking system, are matters to be judged in the light of sound banking principles and praq* tice. Equally and indeed more important in estimating tjie wis- dom of this legislation are the provisions regarding the choice of the management of the regional banks and the membership of thf Federal Board. They must be such as may give reasonable that a wise and conservative body of men will be secured, the likelihood of securing the general acceptance of the plan the banks must be considered, since they are to provide the necessary capital, and without their very general co-operation the plan could not be carried out. While there are many and often fundamental differences between the Glass-Owen Bill and the measure proposed by the National Monetary Commission, the two plans contain a number of identical provisions and are in general sufficiently Bimilar in purpose and method to make a somewhat detailed comparison advisable* The changes proposed in the powers of the national banks require little comment. To take care of foreign business, the Glass-Owen Bill allows banks with a capital of one million dollars to establish branches in foreign countries; while the Monetary Commission Bill permitted the banks to invest in the stock of a new kind of bank, foreign national banks, to an amount not exceeding ten per cent of their own capital• Both measures authorize country banks to make real estate loans— the Glass Bill to an amount not exceeding fifty per cent of capital or of time deposits; the bill of the Commission only to thirty per cent of time deposits• The possible danger from the higher limit is, however, perhaps offset by a provision that loans secured by real estate must mature within nine months* A more considerable difference is to be noted with reference to acceptances, regarding which a general power was granted by the Monetary Commission Bill; while the Glass Bill, restricts their i use to foreign business. It is here that the acceptance is chief- ly needed, and it may be reasonably argued that its use may well at the outset be restricted in this way* Some changes in methods of bank examination are found in both bills but are of no great importance, though a clause in the - 2 Glass Bill, that no two successive examinations shall be made by the same examiner, should most certainly be eliminated* One of the administrative clauses of the bill designed to prohibit the taking of gratuities from borrowers by officials and directors is so drawn as practically to exclude note brokers and Investment bankers from national bank directorates. This clause should be re-drawn* The two measures contain identical provisions regarding capital and the disposition of profits in the new banking organization. Each national bank is to subscribe an amount equal to twenty per cent of its capital, one-half of which is to be paid int the other half remaining a liability subject to call. After the payment of a five per cent cumulative dividend, half of the profits are to go to the Government, the other half to surplus} bat after the surplus reaches twenty per cent of capital, all profits In excess of the dividend requirement are to go to the Government# If one could be sure that practically all the banks, stats as well as national, would become members of the association, the payment of a smaller part of the subscription to the capital by each bank would probably be entirely adequate* A higher dividend rate, at least six per cent, would be a desirable change,, especially in the case of the Glass Bill which, as we shall see, takes away from the banks some of their sources of income. Both measures confine the deposits of the new institutions to be established to those made by the Government and by member banks. On bank deposits no interest is to be paid, but a provision in the Glass-Owen Bill requires such payment on Govern- - S - ment deposits— a difference from the Commission Bill of no particular significance. The general character of the discounting operations as determined "by the two bills is very similar. Only under unusual circumstances is anything but commercial paper to be accepted for re-discount, except that the Glass Bill does place state and municipal bonds on the same footing* Some objection has been raised against this provision but it would not seem to be well taken. There is no strong banking reason for eliminating any class of securities; it is a matter that might well be left to the management, as is the case with the European central banks. Political consid- erations and the existing preference for collateral loans resulting from our faulty banking system make it, upon the whole, desirable to discriminate against security loans. ceptable paper into two classes: The Glass Bill divides ac- one maturing in forty-five days, the other within one hundred and twenty days; thirty and one hun- dred and twenty days were the corresponding periods in the bill of the Monetary Commission. The amount of re-discounts which might be granted to a bank was subject to some limitations in the Commission bill. Whether the absence of similar restrictions in the Glass Bill is a defect should be given careful consideration. We now come to differences of a fundamental character between the Glass-Owen Bill and that prepared by the Monetary Commission. These fundamental differences are in organization and in matters relating to discount rates, note issue, and reserves. A simpler form of organization and a simpler method for - 4 - selecting the management characterize the new plan. Under provi- sions in the Monetary Commission Bill, the "banks were to be grouped into local associations, for electoral purposes and in order to guarantee the paper of members which was to be re-discounted. associations are eliminated in the new measure. Local Bach bank is to deal directly with its regional association in securing re-discounts and in no case is its paper to be guaranteed by other banks. The Commission measure provided for fifteen branches which were to be directly operated by a national board. This board was to be direct- ly engaged in the banking business, fixing a uniform rate of discount, appointing the managers of the branches, and determining to what extent authority should be delegated to the local directorate of each branch. The feature in the new bill analogous to these branches is the regional associations, of which there are to be at least twelve, but these regional associations are given a far more independent status and more important functions. While subject to control by the Federal Reserve Board in some matterst the directorate of each regional association is in most respects entirely independent. It is, for example, to take the initiative in fixing the rate of discount and is to act altogether independently in determining the amount of paper to be re-discounted for member banks 9 and in passing upon its quality. The only direct power over loans possessed by the central board is that of requiring one regional association to discount for other associations, and even in such cases the Board of the lending association would pass upon the security offered by the borrower. - 5 - The other functions of the Central Board are strictly supervisory, with the exception of its power over note issue and over the rates of discount charged by the various regional associations which, in the phraseology of the bill, are ••subject to the review and determination of the Federal Reserve Board•• In prac- tice it is probable that in this matter and also in that regarding inter-regional association loans, the Federal Reserve Board would exercise its authority but seldom. The purpose of these provisions presumably is, and certainly should be, simply to enable the Board to exercise a restraining influence upon the regional associations and to enable it to prevent any working at cross purposes among them. The circumstances are quite inconceivable under which it would ever be desirable that the Central Eoard should require a regional association to discount at a lower rate than that deemed wise by its own directors. It is, however, not unlikely that, in some periods of active business and especially in those parts of the country where there is a relative scarcity of capital, the management of a regional association might fail to exhibit all the caution that the situation of affairs required. Every purpose to be served by giving the Central Board authority over discount rates would be secured through a provision granting it the power to require a regional association to advance its rates of discount. It is a more difficult matter to include within the provisions of a statute just those situations in which it might become expedient for the Federal Board to require co-operation among the regional associations through inter-regional loans. - 6 - After all, the danger from an unrestricted power of this sort would seem to be slight. The Federal Board, however constituted, is most un- likely to force the management of a regional association to extend loans to other associations except on occasions of most serious emergencies. If it "becomes clearly recognized that the primary function of the Federal Reserve Board is the exercise of a restraining influence over the regional associations, there is little danger to be feared from the wrong exercise of this power* This general understanding of the true function of the Federal Board is certainly quite as important as the method of its selection. It should also be noted that the Federal Board is not to take the initiative in this matter. It can only act upon requests for accommo- dation made by the Board of a regional association. A provision might well be inserted in the bill that no inter-regional loans can be required by the Federal Board at a lower rate than six or even seven per cent. Such a provision would largely remove the danger of frequent recourse to this means of securing funds by any regional association. The very great differences in the powers and functions of the Federal Reserve Board of the Glass Bill and the Board of Directors of the National Reserve Association of the Monetary Commission Bill afford some ground for the distinctly different method of constituting these boards found in the two measures. Under the Monetary Commission Bill, the Board of Directors was to consist of five Government appointees and thirty-nine others chosen in various ways by the banks. According to the Glass Bill, there is to be a - 7 - board of only seven, three of whom are Government officials, the Secretary of the Treasury, the Secretary of Agriculture, and the Comptroller of the Currency, and four others to be appointed by the President with the advice and consent of the Senate. As the term of one of these four members would expire every two years, each President at the very beginning of his term would have occasion to appoint a majority of this board. It is further provided that one of the four members must be a banker. That this board must be appointed by the President, if popular support is to be found for a measure of banking reform similar to either the Glass or the Monetary Commission Bills, seems certain. It does notf however, seem wise or necessary that each President should at the very beginning of his term re-constitute a majority of the board. If all of the three Government officials^ are to remain on the board, it would require a board of eleven, one retiring every two yearsf to provide a body, the majority of which would outlast a single presidential term. The only apparent objection to a modification of the bill of this sort is the long term of sixteen years1 service for each member which this arrangement would involve. Certainly some change should be made In the bill designed to remove the very real fear that the board might be directly subject to political influence. In securing satisfactory results from the working of the new banking machinery to be set up under the provisions of the Glass-Owen Bill, the character of the management of the regional associations is quite, if not more, important than that of the - 8 - central "board. These regional boards will "be in most respects entirely independent of the central board; they alone will deter- mine the amount to "be loaned to member banks and will pass upon the merits of the paper offered for re-discount and upon the purchase of foreign bills. These boards will also have the power to raise or lower their rates of discount, subject only to review by the central board. The disposition to be made of the resources of each of the regional associations is entirely within the control of its own board of directors, except that it may be required to re-discount for other associations, but even here the board of the lending association would pass upon the security offered for such loans. Even if the central board were unwise and incompe- tent, there would seem to be no consequent danger that the funds entrusted to the regional associations by the banks would be endangered. They could only be lost through unsound banking on the part of the local boards. The functions of the management of the regional associations are distinctly and even technically banking functions. It is essential, therefore, that the boards of directors of these associations should be chosen in such a manner as to insure the selection of men of wide banking and business experience. The provisions in the bill regarding this matter are simple and ingenious and if slightly modified seem altogether likely to yield good results. The member banks of each regional association are to be divided into three groups, as nearly as may be equal in number and of the same capitalization. Each group is to select one banker - 9 - and one person not an officer or director of a tank as members of the directorate of the regional association. This second group of three directors is to represent fairly the commercial, agricultural, and industrial interests of the locality. Finally, three additional directors are to be designated by the Federal Reserve Board, one of whom is to be the chairman of the board of the regional association. The selection of two-thirds of these boards by the banks might seem to guard sufficiently the resources invested by them in the regional associations, but, as their functions are strictly banking functions, at least the six directors selected by the banks and of course the Chairman should be persons who possess banking experience. The method of dividing the banks into groups fcr electoral purposes minimizes the influence of the large banks, but they are in a measure protected, since the right of withdrawal from the system is always open. The resources of the regional associations cannot be estimated with any degree of certainty. If all of the national banks should subscribe to the arrangement, the regional associations would have a paid in capital of more than one hundred million dollars. The deposits of the United States Government will also generally amount to rather more than one hundred million dollars. These deposits are to be distributed among the regional associations by the Secretary of the Treasury, though doubtless in this matter the opinion of the Federal Reserve Eoard would have great weight. As in the Bill of the Monetary Commission, deposits of member banks are the sole remaining resource. Provisions regarding this matter - 10 - in the Glass-Owen Bill are, however, in every respect fundamentally different from those found in the Bill of the Commission. According to the latter, that part of the required reserve which may be deposited with reserve agents was left undisturbed. The banks were to be permitted to transfer to the national reserve association such part of their cash holdings as they deemed advisable and were to be allowed to count the deposit thus created as a part of their required cash reserve• It will thus be seen that the deposits secured by the National Reserve Association at the outset would not have involved any reduction in the reserves of the banks and consequently would not have made necessary any contraction of credit on their part. Any loans made by the reserve association would, therefore, have been a net addition to the available supply of credit. This was a serious defect in the bill of the Monetary Commission. If the National Reserve Asso- ciation had been established four years ago, such loans as it might have made would not have strengthened the business situation; they would merely have strengthened the tendency to rely upon short time credit for purposes which properly should be met by means of investment capital. The Glass-Owen Bill provides for a radical change in reserve requirements. Country banks are to hold a reserve of five per cent in cash in vault, instead of six as at present; are to establish a reserve of three per cent with their regional association at once, and at the end of a year increase it to five per cent; and may further keep the remaining one-third of their required - 11 - reserve with reserve agents for a period of two years more; there- after this portion of their reserve may be left with reserve agents or transferred to the regional association, as the Federal Reserve Board may determine. The distinction between reserve cities and central reserve cities is to disappear at the end of three years. These banks are to maintain a reserve of twenty-five per cent for two years, then twenty-two and one-half per cent for a year, and thereafter a reserve of twenty per cent. An amount of cash equal to ten per cent of deposit liabilities must be retained in the vaults of the banks. Three per cent, and after a year five per cent, must be deposited with regional associations. The remaining five per cent may be held either in cash or with the association. A somewhat elaborate calculation is required to form an estimate of the effect of these changes. On the basis of present liabilities and reserves if all the banks enter, the initial changes involving the deposit of three per cent of their deposit liabilities with the regional associations, together with the subscription to the capital of these associations, would make it necessary for the banks to re-discount with the associations to the extent of something like one hundred and fifty million dollars. The further change at the end of the first year, increasing balances with reserve associations to five per cent, would involve additional rediscounts of perhaps one hundred million dollars. And finally, if the Federal Reserve Eoard were to transfer from reserve agents remaining reserve balances, still another one hundred and fifty million of re-discounts would be required. - 12 - The first and perhaps the second step in this complicated rearrangement of reserves would seem to be wise and also entirely feasible. The one hundred and fifty millions of re-discountst and even the two hundred and fifty millions, would give the reserve associations a moderate amount of business at the outset without involving any danger of credit expansion. Some business the re- serve associations must have, if they are to exercise any influence over the banking situation. But the further transfer of all reserve balances from agents not only would seem to be unnecessary but also almost certain to endanger the success of this plan of banking reform. It would give the reserve associations an unnecessarily large amount of business and render the banks unnecessarily dependent upon them for accommodation. Further, there is every reason to believe that a very large number of banks would decline to become members of the associations on these terms. Country bankers would resent the loss of the interest which they receive from reserve agents, and reserve agents would lose virtually the only advantage which they possess over their neighbors operating under state charters. General and hearty co-operation of the banks is essential to any scheme of banking reform; but since the advantages from a better system are far more important to the community generally than they are to bankers or to the investor in bank shares, unnecessarily burdensome requirements should not be imposed upon the banks. Some slight inducement to enter the system is indeed held out to the banks, since those who do not, will cease to be national - 15 - "banks and must at once relinquish their right of note issue and either hold their two per cent bonds to maturity or incur certain loss in marketing them. Banks entering the system continue to issue notes, subject to a provision in the bill for their gradual retirement and the coincident exchange of their bonds for an issue yielding a higher rate of return. This privilege should also be extended to other United States bonds held by the banks, in particular to those which serve to secure United States deposits, inasmuch as these deposits are to be transferred to the regional associations. It is doubtful, however, whether the loss in con- nection with their holdings of Government bonds will be sufficient to induce by any means all of the national banks to accept the new arrangements provided for in the bill. It is even less likely that any considerable number of state banks will be converted into the national system, unless the bill is so modified as to make its provisions distinctly more attractive. Something in this direc- tion would be accomplished if the capital of the reserve associations to be paid in were reduced to five per cent of the capital of the banks if the dividend rate were advanced to six per cent; and if part, at least five per cent, of the required reserve of country banks is left with reserve agent3. None of these changes would in the slightest degree diminish the effectiveness of this plan of banking reform. Another matter regarding which the new bill goes beyond its predecessor is with reference to the handling of checks. Ac- cording to the Bill of the Monetary Commission, the branches of - 14 - the National Reserve Association might undertake clearing-house functions and transfer funds "between branches at rates to be fixed by the managers of the branches. Under the Glass Bill, collection of checks and drafts on member banks is to be made free of cost for members by each regional association, and transfers of funds between associations are to be made at par. Under this provision of the bill, it will be necessary for each regional association to set up machinery for the handling of checks within its own region, machinery analogous to that of the foreign department of the Boston Clearing House. Further, all places in which there is a regional association will become par points for the entire country^ It may be expected that, as a consequence, exchange charges on all checks will disappear. A Boston bank, for example, while unable to collect checks on Illinois points through the Chicago Regional Association, will be able to do so through some Chicago bank; and the Chicago bank, through its reserve association, will be enabled to remit to Eoston at par. Transfers on the books of the reserve associations will vastly lessen the shipments of currency between banks in different parts of the country. Requirements for the use of cash will become more regular than at present and machinery for making settlements between different parts of the country which will not break down in future emergencies will have been provided. On the other hand, it must be admitted that the taking over by regional associations of this function takes away business which has been profitable to many banks, lessening the Inducements for accepting the system. - 15 - Much more attention than the importance of the subject warrants has been given to the provisions in the Glass-Oweil Bill regarding the issue of notes. Assuming that the reserve associa- tions had been established four years ago and that their affairs had been handled conservatively, it is probable that no notes whatever would have been issued up to the present time. Throughout this period there has been in general an entirely adequate supply of banking credit; and even on the few occasions characterized by some strain, the cash and credit of the reserve associations would have been ample for every purpose without resort to the power of note issue. The bill provides for new issue of notes amount- ing to five hundred million dollars, together with such amounts in addition as will take the place of the existing note issues of the banks as they are gradually retired under provisions included in the bill. A limited issue is eminently wise, and the particular limit which has been set will permit quite as much increase in the currency as can possibly be needed for many years to come* These notes are to be a direct obligation of the Government and are to be issued to the reserve associations on the deposit of security and at rates to be determined by the Federal Reserve Board, if that board is convinced that there is a real need for the notes* of notes is not to be subjected to any special tax. This issue Reliance is placed upon the wisdom of the management of the reserve associations in applying for notes and upon the policy of the central board. A valuable safeguard, however, is found in the separate interests of the various reserve associations. Those managed with a high degree - 16 - of conservatism would doubtless oppose any considerable use of the limited right of issue by other associations, unless the need was evident. The criticism which would be directed against liberal issues to a recklessly managed reserve association should prove a far more potent safeguard than legislative taxation devices through taxation. The limited right of issue serves another useful pur- p o s e — it will prevent the substitution of notes for gold certificates now in circulation, a substitution which would have provided the National Reserve Associations proposed by the Monetary Commission with the basis for an enormously and dangerously large lending power* Taken as a whole, the Glass-Owen Bill seems to provide the mean3 for very great improvement in our banking system* It is superior in a number of respects to the bill proposed by the National Monetary Commission, notably so in the provision that reserve requirements may be temporarily suspended by the Federal Board and in the absence of the requirement of a uniform rate of discount throughout the country, a most unsound and dangerous feature of the Commission bill. Unless some of the provisions of the Glass-Owen bill are modified, however, it does not seem probable that it would prove effective, because of the probability that large numbers of banks would not enter the system. Fortunately, the changes which are needed to make the bill more attractive to the banks do not involve concessions on principle. Surely it must be possible to formulate conditions regarding qualifications for membership on the Federal Reserve Board which will cive bankers - 17 - confidence in its competence and freedom from political influence* Surely also sound banking under national charters does not require burdensome restrictions which will enhance the attractiveness of organization under state laws and jeopardize the very existence of the national banking system. - 18 - eJ/' • u/U,c*v>utx- / This document contains internal or confidential information and has been removed. Author(s): O. M. W. Sprague Title: Memorandum for the Council of National Defense: Reconstruction Policies and the Maintenance of Peace Date: Page Numbers: