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Form F. H. 131 B O A R D DF GOVERNORS • F THE FEDERAL RESERVE SYSTEM Office Correspondence n To Chairman Eccles From Mr> Smead Date. March„14, 1938 Subject:. In accordance with the request of Governor Ransom, there is attached for your information a copy of comments with respect to Section 2 (c) of the Patman Bill, H.R. 7230, prepared in compliance with his request at the Board meeting on Friday, March Attachment• COMMENTS WITH RESPECT TO SECTION 2(c) OF THE FATM/IN BILL, HR 7^50 Section 2(c) of the Patman Bill provides that "After all necessary expenses have been paid or provided for, the net earnings of the Federal Reserve banks shall be covered into the Treasury as miscellaneous receipts"® Section 7 of tho present Act requires that all net earnings of the Federal Reserve banks after the payment of dividends shall be transferred to surplus* The reasons for the proposed change in tho Law, it is assumed, are based on the assumption that (1) the net earnings of the Federal Reserve banks, after the payment of dividends, are substantial, (2) the United States Government will have no claim on such net earnings if they are not paid to the Government currently each year, and (3) the surplus of the Federal Reserve banks is adequate in relation to their liabilities. rJo one of the above assumptions is valid. During the period of the world war and for a few years thereafter member banks were borrowing very large amounts from the Federal Reserve banks9 and as a consequence the earnings of the Federal Reserve banks were exceptionally large. At that time Federal Reserve banks paid a franchise tax, the franchise tax payments amounting to over §120,000,000 for the calendar years 1920 and 1921, as compared with total franchise taxes of §1^9,138,300, for the period from the organization of the Federal Reserve banks to the end of 1932 after which the requirement for the payment of a franchise tax was repealed. * It was also during this period that tho Federal Reserve banks - 2 - added substantial amounts to their surplus accounts* The Federal Reserve Act, as amended on March 3> 1919* provided that all of the net earnings of a Federal Reserve bank remaining after the payment of dividends* including those for the calendar year 1918* should be paid into a surplus fund until it amounts to 100 percent of subscribed capital and that thereafter 10 percent of such net earnings should be paid into the surplus and the remainder paid to the United States as a franchise tax. This provision of the Law was again modified by the Banking Act of 1933* to provide that all of the net earnings of a Federal Reserve bank* after payment of the 6% dividend provided by law* shall be paid into its surplus fund. At the same time* however* Congress required the Federal Reserve banks to use one-half of their surplus to purchase stock in the Federal Deposit Insurance Corporation* on which they receive no dividends. In other words* one-half of the surplus of the Federal Reserve banks was appropriated by Congress for the purpose of furnishing the Federal Deposit Insurance Corporation with a part of its capital funds. The net earnings of the Federal Reserve banks available for transfer to surplus during recent years have been relatively small* amounting to $2*616*352 in 1937. to $352,5214 in 1936* and to |607,ij22 in 1935* In some years the Federal Reserve banks have had deficits in net earnings after payment of dividends which were charged to surplus. With respect to the second assumption mentioned above* Congress has the right at any time to legislate with respect to the surplus funds of the Federal Reserve banks. If at any time Congress should consider the surplus of the Federal Reserve banks more than adequate* in the light of - 3 - their liabilities and responsibilities, it could appropriate a portion thereof for such purposes as it saw fit* As stated above* Congress did in 1933 appropriate one-half of the surplus of the Federal Reserve banks to be used as a part of the capital funds of the Federal Deposit Insurance Corporation. While the Federal Reserve banks technically own stock in the Federal Deposit Insurance Corporation* they are not permitted under the Lar to receive any dividends on such stock. Under present law member banks are entitled to a 6 percent cumulative dividend on their paid-in subscription to capital stock of the Federal Reserve banks. No further distribution to member banks i of the net earnings of the Federal Reserve banks is possible under existing law. In case of liquidation of a Federal Reserve bank the Law provides that its surplus shall bo paid to and become the property of the United States» The acquisition by the Government of the capital stock of the Federal Reserve banks, as provided in Section 2(a) of the Patman Bill, would necessitate an initial expenditure of Government funds in the amount of approximately $133*000,000 for the cost of such stock, and, in view of the fact that the public indebtedness of the Government presumably would bo increased by a corresponding amount, the not income derived by the Government from the ownership of such stock would bo limited to the difference between the interest cost to the Government of money borrowed by it and the annual divi- - k dends of the Federal Rosorvo banks. - The annual 6 percent dividend payable to member banks in accordance with Section 7 of the Federal Reserve Act amounts to about ^7*800,000, and if the cost to the Government of borrowed money bo considered to bo say 2-l/2 percent per annum on the basis of long torn bonds the not profit which would accrue to the Government from its investment of v133j000,000 in the capital stock of the Federal Reserve banks would bo less than $>5*000,000 per annum With respect to the adequacy of the surplus, the Federal Rosorvo bonks now have deposit and note liabilities of about $11,960,000*000 and surplus accounts aggregating $1148,739*000, the surplus accounts amounting to about 1*2 percent of deposit and note liabilities* If the operations of the Federal Rosorvo banks are to be governed with a view to accommodating corjnerce and business and with regard to their bearing upon the general credit situation of the country as required by statute, the Federal Reserve banks cannot function with a profit motive in view. Moreover, if they are to dis- charge effectively their statutory responsibilities, they must have adoqtiate surplus funds to permit them to operate at a loss, if necessary, over substantial periods. Present surplus funds, amounting to 1#2 percent of liabilities are certainly not excessive - 5 and could easily provo inadequate particularly as there are no present prospects for substantial increases therein. Since the Federal Reserve banks vere organized in I91I4 their total earnings have amounted totfl,2i4l,000,000.Of this amount $610,000,000 has been utilized to cover costs of operation, 133,000,000 has been sot aside as reserves for contingencies and the balance of #598,000,000 has been used as follows: Payment of 6 percent dividend on capital stock, as required by Section 7 of the Act |l62,000,000 Payment of franchise tax to the United States Government 1^9,000,000 Contribution to the capital stock of the Federal Deposit Insurance Corp. 139,000,000 Balance in surplus accounts lij.8,000,000 It will be noted from the above that of the net earnings of $598,000,000 of the Federal Reserve banks since their organization, I48 percent has gene to the Treasury as franchise taxes and to the Federal Deposit Insurance Corporation as a contribution to its capital funds, 27 percent has gone to member banks in payment of the 6 percent dividend required by statute, and 25 perccnt remains as surplus. - 6 - The oxponscs of tho Fodoral Reserve banks wore incurred in rendering the services and performing tho functions required by the Federal Reserve Act. One of the purposes of tho Federal Reserve System, as stated in the preamble of the Act, is to furnish an elastic currency, and in order to do so Section 16 of tho Act authorizes the Federal Reserve banJ.cs to issue Fodoral Reserve notos# In accordance with tho provisions of the Act the Federal Reserve banks furnish member banks and through them the public with tho currency needed for carrying on the country's business; they collect large volumos of checks and other items payable upon presentation for member banks; they provide rediscount facilities for member banks; and perform fiscal agency, depositary and custodianship services for tho Treasury and a large number of Government agencies* In carrying out these and other important functions the Federal Reserve banks have endeavored to be of as much service to their member banks, and through them to commerce, industry, agriculture, and tho public in general, and to the United States Government, as is consistent with the efficient and economical operation of the System. All compensation provided by the boards of directors of the Federal Reserve banks for directors, officers or employees is subject to the approval of the Board of Governors. In discharging this responsibility the Board gives individual consideration to the salary of each officer in every Federal Reserve bank, and has provided a classification plan whereby all of the non-official positions in each Federal Reserve bank are classified and a maximum salary provided for each# The Board of Governors also requires each Federal Reserve bank to submit periodically detailed reports of its expenses and of salaries paid each Officer and employee. The reports of expenses are tabulated by the Board*s staff and summaries thereof are furnished each Federal Reserve bank in order that it may compare its costs with similar costs at other Federal Reserve banks. Shortly after the present Board took office on February 1, 1936, it instituted a survey of the organization at each Federal Reserve bank and as a result thereof many economies were effected, among which were the placing of the chairmanships at the Federal Reserve banks on an honorary basis and the fixing of their compensation on the same basis as that of any other director in lieu of annual salaries of from $20,000 to $50,000, as had been the previous practice. Wherever it is found that certain operations can be handled more economically without sacrificing efficiency prompt steps are taken to effect the economies. There has been a gradual reduction in the unit costs reported for the principal operating units of the Federal Reserve banks. For example, in the Country Checks-Outgoing unit, which is the largest single operating unit in the Federal Reserve banks, the average cost of handling a thousand items was $3.65 ten years ago as compared with $2.59 in 1936 and in 1937. With a few exceptions, the unit cost in the Country ChecksOutgoing unit for each of the past ten years has been lower than that reported in the immediately preceding year as may be noted from the following tabulation: - 8 Cost per thousand items in the Country Chocks-Outgoing unit 1928 1929 1930 1931 1932 $3.65 3*35 3-35 3.23 1933 193k 1935 1936 1937 3.30 3*05 2.88 2,59 2.6k The reductions in operating costs reported for tho Country Checks-Outgoing unit are due to improved methods of procedure. A survey of the Country Checks unit at all Federal Reserve banks has recently been completed by members of the Board's staff. Since the new Board took office members of its staff have also made field surveys of the Bank Examination, Auditing and Legal Departments at tho Federal Reserve banks. On occasions when the unit costs of some particular bank appear to be out of line special field surveys are made. For example, last month a special survey was mo.de of a certain operating unit at two banks where there was a substantial variation in unit costs and suggestions were made to the bank reporting tho higher cost. The costs of performing tho various services rendered by the Federal Reserve banks during 1937 are sot forth below in summary form. EXPENSES OF FEDERAL RESERVE SYSTEM, YEAR 1937 Currency and Coin The cost of receiving and handling 2,257,889,000 pieces of currency and 2,730,387*000 pieces of coin, including shipping charges to and from member banks was 11)9*671 - 9 - Assessment by the Treasury Dept. to cover the cost of printing new Federal Reserve currency, the cost of issuing such currency at the Reserve banks, and the cost of redeeming Federal Reserve currency unfit for circulation, including shipping charges, amounted to Total §1,787,036 05,936,707 Check Clearing and Collection Handling and collecting 926,792,000 checks and 6,705,1+13 maturing notes, drafts, coupons, etc. cost .••..««•••• $3,802,889 Loans, Rediscounts and Investments The cost of making 13,571 discounts and advances to member banks; of handling 388 applications for advances to industry for working capital under Section 13b of the Federal Reserve Act; of maintaining credit information, of holding in safekeeping and servicing about 000,000,000 of securities for member banks and purchasing and selling Government securities for member banks cost «... §1,366,258 - 10 - Fiscal Agency, Custodianship and Depositary Receiving, proving, and paying 127,823,063 Government checks and coupons, including work relief checks; maintaining the general account of the Treasury of the United States, etc. cost $1,125,1*02 Fiscal Agency work for the U. S# Treasury Dept. comprising principally the issue, redemption, and exchange of 3,982,751 pieces of securities cost Total Reimbursed by Treasury Dept §1,380,352 §2, 505,751+ 01,6314,363 Net cost 0871,391 Services performed for various Government agencies such as the Reconstruction Finance Corporation, Federal Farm Mortgage Corporation, Federal Land Banks, Federal Intermediate Credit Banks, Federal Emergency Administration of Public Works, and the Federal Home Loan Banks and Home Owners* Loan Corporation amounted to Reimbursed by Government Agencies Net cost $2,231,1142 2,20l|,l426 026,716 - 11 - Accounting This function, which includes the maintenance of the general books, member and Federal Reserve bank accounts, etc., and the making of transfers of funds for the account of member banks, cost $1*579*520 Banking House and Furniture and Equipment Cost of operation of banking houses, including payment of taxes, the salaries of janitors, elevator operators, etc., less deductions for income received from rented space, etc., was 02,612,685 Reserves set aside for depreciation on banking houses 1*297*859 Furniture and equipment, net cost 233*290 Total Bank examination The cost of examining state member banks and incidental work in connection therewith was 01,101,800 Expenses of the Board of Governors Assessments for expenses of the Board of Governors of the Federal Reserve System •.. 01,7148,379 12 Statistical and Analytical Preparing and publishing monthly reviews of credit, business and agricultural conditions; and obtaining and assembling various statistical data, etc. cost Bank .. $1+80,028 Relations Bank relations work; visiting member and nonmember banks, conferences, etc. cost . $195,001+ Personnel and Service The maintenance of personnel records, the purchasing of supplies and equipment, telephone service, filing, mailing, etc., cost ...... §2,29l+,23U Protection The salaries of special officers and watchmen, and the cost of other protective services amounted to 09614*932 Postage and Insurance The cost of postage on ordinary mail* insurance on equipment and supplies, etc.; the cost of employees' fidelity bonds* bankers blanket bond, etc., amounted to yl,32l{-,298 - 13 - Auditing Maintaining general audits of the Federal Reserve banks and branches cost 0552*623 Legal The employment of counsel and other legal expenses cost 4)190,086 General Overhead General overhead and supervisory expenses, including directors1 fees and expenses amounted to $1,685*101 Total Net Expenses §28,263*800