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BOARD OF GOVERNORS

0SJHB

FEDERAL RESERVE SYSTEM

April 9, 1938.
COMMENT ON H.R.7230
Introduced by Mr. Patman
The fundamental purpose of H.R. 7230 is to establish a mechanism
that would control the volume of money v/itfa a view to maintaining a
fixed price level.
The mandate
In an amendment the Board of Governors is instructed to raise the
all-commodity index until full employment of all persons able and will­
ing to work shall have been achieved, and until the price level shall
at least reach the all-commodity index of 100, as established by the
Department of Labor, for the year 1926.

The Board is further directed

to maintain this price level with variations not to exceed 2 per cent.
To accomplish this the Board is dircctcd to expand and contract demand
deposits by engaging in opon-market operations.
The position of the Board of Governors on the problem of monetary
objectives was indicated in a statement issued on August 2, 1937, in
response to a Congressional inquiry.

The Board is in full agreement

with the ultimate objective of proposals to promote economic stability,
which means the maintenance of a volume of business activity and of
national income adequate to assure as full employment of labor and of
the productive capacity of the country as cat» fee continuously sustained.
The Board is aware that commodity prices are an important element in
the Nation’s economic life and that violent fluctuations of prices have




disastrous effects.

It believes, however, that price stability does

not necessarily lead to economic stability and, therefore, should not
bo the principal objective of public policy.

In its opinion the ob­

jective of economic stability cannot be achieved by monetary means
alone, but rather should be sought through coordination of monetary
and other major policies of the Government which influence business
activity.
The principal difficulty with a stable price level as the objec­
tive of economic policy is that it is not in itself a satisfactory in­
dicator of a continuously smooth working of the economic machine.
There have been periods in the past when the price level was stable
and nevertheless there were developing numerous maladjustments which
led to an economic collapse.

For example, from the latter part of 1927

to the latter part of 1929 the index of wholesale prices showed little
change, but other developments were threatening oconomic stability.
Prices and activity on the stock market were rising rapidly, and brok­
ers’ loans grew at an unprecedented rate*

Construction of office and

apartment buildings was being promoted with a view to quick profits at
a rate that endangered the longer-time outlook in the building industry*
Loans were being made for enterprises abroad without careful investiga­
tion of credit risks, and business activity in general was increasing,
partly as a result of speculative developments, to a level that could
not be sustained.

The use of the commodity price level as a guide to

credit policy in these circumstances would have been entirely unsatisfactory.




-3There is no assurance that it would be satisfactory in the future.
The proposal is that the Board of Governors bring the commodity
price index up to at least the 1926 level#

Tho average for that year

is about 25 per cent above the present level and an advance of that
magnitude, except over an extended period, would cause speculative
buying and would lead to boom conditions which would culminate in a
break and a depression.

Furthermore, in periods of rapid advance dis­

parities between prices of different groups of commodities generally
become more pronounced and yet, both from the point of view of justice
and of economic stability, tho most important thing in regard to prices
is the maintenance of proper relationships between prices of different
commodities that are exchanged for each other.

Activity of producers

depends on the relationship between their costs, including principally
prices of materials, labor, taxes, and debt service, and the prices
at which they can sell their products.

In the last quarter of 1936

and in the first quarter of 1937, for example, building costs and
prices of new houses rose so rapidly and so far as to discourage buy­
ing, and this resulted in a decline in residential building.

More­

over, the rise in prices of industrial raw materials at that time was
much sharper than the advance in finished goods, and this was a factor
in causing speculative purchases, forward orders, and building up of
inventories, all of which contributed to the subsequent collapse of
business.




-4Present prices of individual commodities in the Bureau of Labor
statistics index, compared with 1926, range from a decline of 75 per
cent to an increase of 100 per cent.

A restoration of the 1926 level

could be achieved through an advance of all commodities, including
those that are too high, as well as those that are too low, or through
a rise in one or the other group of these commodities.

There is

nothing in monetary policy that could determine which of the commodi­
ties would rise, and yet this would be all-important from the point
of view of tiie effects that the rise in prices would have on the
economy.
In the Board’s view the essential objective of monetary policy
is to contribute to the maintenance of a flow of money and incane
through the channels of trade, industry, and agriculture that would
tend to utilize to the full the country's human and material resources.
This is the Board's understanding of tho broad mandate stated in the
Federal Reserve Act as "accommodating commerce and business".

To this

end and to the maintenance of sound banking conditions the Board de­
votes its efforts, and there is nothing in the proposed mandate that
would add to tho Board's desire or ability to achieve those objectives.
In directing the Board to achieve price stability and full em­
ployment through open-market operations, the proposed mandate disre­
gards the limitations on tho effectiveness of this instrument of
credit policy.




It assumes that opon-markot operations can always

-5 -

create or destroy deposits, and that changes in the volume of depos­
its in turn are immediately reflected in the price level.

The fact

is that open-market operations do not always create deposits,.since
purchases of securities from the banks do not increase deposits.
"Whether open-market purchases result directly in an increase in de­
posits or not, they do result in the creation of a corresponding
amount of reserves.

These reserves may or may not result in the

creation of deposits, depending on whether conditions are favorable
for the expansion of loans and investments by banks.

The groat bulk

of deposits in the banks of the United States are created through
such an expansion.

A given volume of reserves created by Board ac­

tion, therefore, might result in no increase in deposits at all, or
on the other hand might result in a growth of deposits several times
as large as the reserves.

lihich of these developments would actually

occur would depend on forces that are largely, if not wholly, outside
the control of the Board of Governors.
It is not true, furthermore, th.-.t the creation of deposits neces­
sarily results in an equivalent rise in prices.

We have had increases

in deposits without corresponding increases in prices.

The volume of

deposits at the present time is greatly in excess of the amount that
existed in 1929 and yet the price level is much lower.

Nor is it

clear that a rise in prices necessarily results in an increase in em­
ployment.

An unbalanced advance in prices may, on the contrary, be an

influence in decreasing employment, as was the case early in 1937.




-6 -

Aside from many factors that are not under the control of the Gov­
ernment, there are numerous phases of Government activity other than
monetary action by the Federal Reserve System that have effects on prices
and on economic activity.

Among such factors are the actions of the

United States Treasury in relation to the inactive gold account and the
stabilization account; policies in regard to taxation, exchange rates,
the volume and character of Government spending; its action in regard to
the capital market, to railroads and utilities; the Government’s housing
program, its agricultural policies, and its policies in regard to labor.
All of these Government activities have a distinct bearing on the volume
of business activity and on the price level.

They are beyond the influ­

ence of the Federal Reserve System, and yet without them and their co­
ordination with monetary policy the System would be powerless to achieve
either an advance in prices or the restoration of full employment, as
would be required under the proposed mandate.
The Board of Governors, therefore, does not favor the adoption of
the proposed mandate.
Federal Reserve System operates in the public interest
In addition to prescribing a mandate for the Federal Reserve policy,
the bill proposes a reorganization of the Federal Reserve System.

The

reasons offered for this reorganization are that the System has not been
operated in the public interest; that it has been dominated by bankers;
that it has been conducted in the selfish interests of a small group, and
that it has Joade large profits at the expense of the community.

The Board

of Governors does not believe that any of these assertions can be sustained
by the record.



-7 -

Ovmership of stock by member banks does not enable the bankers to
control the Federal Reserve System.

It is more nearly in the nature of

a compulsory capital contribution than stock ownership.

Although the

member banks elect two-thirds of the directors of the Reserve banks, the
large banks elect only two out of nine directors.

The small banks elect

two, the medium-sized banks elect two and the Board of Governors in
Washington appoints three.

Only a third of the directors can be bankers

and all directors and officers are subject to removal by the Board of
Governors.

The Board in Washington appoints the chairman and deputy

chairman of each Reserve bank, and the appointment of all presidents
and first vice presidents, as well as the salaries of all officers and
employees, are subject to its approval.
Complete authority over all matters of major national policy, such
as the determination of discount rates, reserve requirements, margin re­
quirements on security loans, and maximum rates of interest to be paid
on time deposits, is vested in the Board of Governors.

Authority over

open market operations is vested in an open market committee consisting
of seven members of the Board of Governors and five members elected by
the Reserve banks.
It is clear, therefore, that in matters with which the bill is pri­
marily concerned the System is dominated not by banks, but by the Board
of Governors, a Governmental body whose members are appointed by the Presi­
dent and confirmed by the Senate.
Federal Reserve banks not operated for profit
During the twenty-three years of its existence the Federal Reserve
System has earned approximately one and a quarter billions of dollars, of



-8which about one-half has been used for operating expenses incurred largely
in performing public services, such as the clearing and collection of
checks, the supplying of currency to the banks and to the public, the per­
formance of many duties for the United States Government, and in furnish­
ing rediscount facilities for the member banks.
Earnings of the Federal Reserve banks above these expenses and re­
serves for contingencies amounted to $600,000,000.

Of this amount approx­

imately $150,000,000 has been paid to the Government as franchise tax,
about $140,000,000 has been appropriated by Congress for the Federal De­
posit Insurance Corporation as capital, $160,000,000 has been paid as the
statutory dividends to member banks, and the remainder is held in a sur­
plus account which in case of liquidation becomes the property of the
Government.
Member banks contribute 3 per cent of their capital and surplus to
the capital of the Reserve banks and receive 6 per cent annually on this
contribution.

In addition, member banks are required to keep balances

with the Reserve banks amounting on the average to 16 per cent of the
member banks* deposits and receive no return on these balances.

For ex­

ample, a member bank having a capital and surplus of $100,000 and de­
posits of $1,000,000 contributes $3,000 to the Reserve bank's capital and,
on the average, would be required to hold $160,000 on deposit with the
Reserve bank as legal reserves, on which it receives no interest.

The

dividends such a bank would receive on its stock in the Reserve bank would
be $180 a year.
The System was established and is operated in the public interest and




-9 -

dominated by public officials; it performs a service that saves the
people of the country far more than the cost of the System; and it makes
no profits for any private interest other than the amount paid annually
to stockholders at a fixed rate, which has been prescribed and can be
changed by Congress.
Proposals would not improve banking system
Proposals in the bill for reorganizing the Reserve System would trans­
fer ownership of the stock in the Federal Reserve banks to the Government
and would have all the directors of the Reserve banks appointed by the
President and approved by the Senate.

It would enlarge the membership of

the Board of Governors to fifteen, including three ex-officio members —
the Secretary of the Treasury, the Comptroller of the Currency, and the
Chairman of the Federal Deposit Insurance Corporation.
A Board of Governors of fifteen members proposed in the bill would be
too unwieldy to function promptly and effectively.

The proposal in the

bill to offer all the privileges of membership to nonmember banks so long
as they choose to keep their reserves in a Federal Reserve bank would re­
move all incentive to become members of the System.

It would enable all

banks to profit by the services of the System so long as it suited them,
without contributing anything to its strength or complying with its regu­
lations, and to withdraw their reserves when to maintain them would seem
to be burdensome.

It would make futile the proposed enlargement of the

power to increase reserve requirements.

It would remove all incentive to

membership and would make it impossible for the System to discharge its
responsibility for maintaining sound credit conditions.



-10-

Distinotion between monetary and fiscal authorities should be maintained
The primary function of the Treasury is to collect taxes, borrow
money, and provide funds for the various agencies of the Government in ac­
cordance with Congressional appropriations.

The primary function of the

Federal Reserve System is to influence the flow of money and to contribute
to tho soundness of the banking situation.

In a broad sense the objec­

tives of both agencies are the same, namely, to serve the public interest,
but their points of view and experience, and their approach to current
problems may at times be different.

The maintenance of an organization

for the regulation of credit separate from the fiscal arm of the Govern­
ment has been found advantageous in most countries of the world, and its
abandonment, which is proposed in the bill, would, in this Board’s opinion,
be a backward step.
Local autonomy in local matters should be preserved
Since its establishment in 1914, the Federal Reserve System has under­
gone many changes in the direction of increased control by the Board of
Governors.

With the passage of the Banking Act of 1935 this control has

been greatly strengthened in ¡30 far as national policies are concerned*
In regard to local matters, the maintenance of local autonomy under general
supervision and close Government regulation is advantageous in a country
like the United States, consisting, of various regions with diverse economic
interests.

The maintenance of locally elected directors on Federal Reserve

bank boards is of great advantage in creating local pride and local in­
terest in the System and in inspiring the business community with confi­
dence in its management.



This advantage would be lost if the appointments

-1 1 -

of all local directors were handled entirely from Washington.

Consequently,

the System’s ability to render a disinterested public service to all class­
es of the community would be greatly diminished.
To sum up, the Board is convinced that improvement in our banking sys­
tem is needed but sees nothing in this bill that would tend in this direc­
tion.

The Board is convinced that the main objective of the bill is not

practicable; that the evils which the reorganization features of the bill
propose to correct do not exist; that the organization which it proposes
to establish would result in less satisfactory service to the country;
and that enactment of the bill would be a backward and not a forward step
in the development of the banking system in the public interest.