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CABLE

ADDRESS—

BAMERICAL

1 0 4
3 4

SAX FRANCISCO
LEGAL

HEADQUARTERS

DEPARTMENT




SAN FRANCISCO.

CALIFORNIA

August 28, 1941a

Mr. Lawrence Clayton,
Assistant to the Chairman,
Board of Governors,
Federal Reserve System,
Federal Reserve Building,
Washington, D. C#
Res S. E. C# 19(a)(2) Proceeding
vs.Transamerica Corporation.
Dear Larry:
Enclosed i s a copy of Memorandum of
La M Giannini in Reply to Response Memorana
dum of Counsel for the Securities and Exchange
Commission«
In our opinion, this Memorandum constitutes a complete answer to the contentions
of the Commission!s staff regarding the i n t e r pretation of the Agreement of March 10, 1941.
After you have had an opportunity to
go over this Memorandum, we shall appreciate
your l e t t i n g us have your comments.
Kind regards!
Yours ve:

G.I D; j^CHILLING
Assistant Vice President
and Counsel.
GDSsMMcG
Enclosure
Airmail

October 22, 19^+1»
Dear George:
I hope you w i l l not think m too dilatory because of ay
e
failure to actaiowleuge and reply to yours of August 2fc, with which
you enclosed a copy of kariol s memorandum in the SEC proceedings.
I t so happened that .this arrived just after w had finished tne
e
work of preparing regulation ft and tnere w^s a great accumulation
of other matters, including a flocK of meetings of tne Boaro and of
the Ooen market Confcittee, ana i t seems that I have just now caught
my oreatn again. Incidentally, I oas out of town last weeK, which
further* delayed ay patching up on correspondence.
I did appreciate your sending m the copy of Mario's memoe
randum, and I read i t with a grea:, oeal of interest. I thought i t
good and strong and yet thers was throughout an appeal to fairness
which evidently bore some f r u i t , as i have noticed oy press reports
recently that the Commission accepted the amendments to the famous
registration statement. I naturally assume that this just about
settles the long and tedious dispute, but would be glad to have
your views, i f I am wrong i n this assumption.
Please remember m most kindly to A.P., kario, Louie, Porter
e
and the others w o I have met personally.
hm
Althovjgh I presume you have less occasion to come back here
i n the future, I hope for the pleasure of seeing you ere long.
With best wishes, I am
Yours sincerely,

Mr. George Schilling,
Bank of America,
National Trust and Savings Department,
No. 1 Powell Street,
San Francisco, California.
LC c
m