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;£r. Eccles COPY BANK OF AMERICA National Trust and Savings Association San F r a n c i s c o , California, November 25, 1936. Honorable John K. McKee, Board of Governors, Federal Reserve System, Washington, D. C. Dear Mr. McKee: Attached i s a copy of a l e t t e r which I j u s t forwarded to the Board of Governors through the l o c a l Federal Reserve Bank. I am informed t h a t i t w i l l be considered at t h e i r Executive Committee meeting tomorrow and t r a n s m i t t e d by a i r m a i l . I though t h a t you might be i n t e r e s t e d i n having a copy so t h a t you can be informed. Kind regards. Very t r u l y yours, (Signed) Hugh L . Clary Vice P r e s i d e n t . COPY BANK OF AMERICA San F r a n c i s c o , C a l i f o r n i a . November 25, 1936. Board of Governors of the Federal Reserve System, c/o Federal Reserve Bank, San Francisco, C a l i f o r n i a . Gentlemen: On behalf of Transamerica Corporation and Inter-America Corporation who have heretofore f i l e d an a p p l i c a t i o n f o r a general v o t i n g permit as provided i n Section 5144 of the Revised Statutes of the United States, I would l i k e to apply f o r a temporary v o t i n g permit f o r the sole purpose of v o t i n g the stock which these corpora t i o n s own or c o n t r o l , d i r e c t l y or i n d i r e c t l y , i n the F i r s t National Bank of Portland a t a meeting t o be held as soon as p r a c t i c a l , and f o r the sole purpose of increasing "the c a p i t a l stock of said bank by a t r a n s f e r of $500,000 from the surplus, undivided p r o f i t s and reserves. For your i n f o r m a t i o n , the F i r s t National Bank of Portland has acquired otmership or c o n t r o l of banks i n Grants Pass, Ashland, Coquille and Oregon C i t y and may s h o r t l y acgyflj? qthft-r Jagflfca* App l i c a t i o n s f o r permission to operate these banks as branches are now on f i l e w i t h the Comptroller of the Currency. As you know, Section 5155 of the Revised Statutes of the United States provides t h a t the c a p i t a l of a branch bank s h a l l be a t no time less than the aggregate minimum c a p i t a l required by law f o r the establishment of an equal number of n a t i o n a l banking associations s i t u a t e d i n the various places where such association and i t s branches are s i t u a t e d . I t i s t h e r e f o r e necessary t h a t the c a p i t a l of the F i r s t National Bank of Portland be increased i n t h i s manner i n order to q u a l i f y these a p p l i c a t i o n s f o r permission to operate branches f o r f u r t h e r consideration by the Comptroller. At the same time we would l i k e to c a l l your a t t e n t i o n to the f a c t t h a t our a p p l i c a t i o n f o r a general v o t i n g permit i s s t i l l pending before you and has not been acted upon. Some time i n December 1935 a general agreement was proposed as a condition precedent to the g r a n t i n g of a general v o t i n g p e r m i t . I t was our opinion a t t h a t time t h a t t h i s agreement established i n many respects Board o f Governors Federal Reserve System 11-23-56 (2) a measure o f c o n t r o l and domination o f the a f f a i r s o f holding company a f f i l i a t e s which was not contemplated by Section 5144 of the Revised Statutes* We presented arguments i n support of our p o i n t o f view. No f i n a l conclusion, however, was reached before the date o f our annual meetings and as a r e s u l t the stock of Transamerica Corporation and Inter-America Corporation was not voted a t these meetings* We would now l i k e t o request t h a t cons i d e r a t i o n of our a p p l i c a t i o n be renewed and t h a t the Board also give consideration t o a r e v i s i o n o f the general agreement h e r e t o f o r e proposed. We are informed t h a t many holding company a f f i l i a t e s were u n w i l l i n g t o s i g n t h i s proposed agreement and no doubt also presented arguments i n opposition t h e r e t o . T h i s , coupled w i t h the f a c t t h a t the economic and f i n a n c i a l s i t u a t i o n i s e n t i r e l y d i f f e r e n t than i t was then, would suggest t h a t an e n t i r e l y new approach be made t o the whole problem. This l a t t e r we r e s p e c t f u l l y request. Very t r u l y yours, Hugh L . C i a r y , Vice President.
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