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Ill'
V.«rch 4, 1935

Mr* George J. B&rthold, Vice ?res. i Treas.
The Miners and Mechanics Savings 5; Trust Co.
Gteubenville, Ohio
Dear *4r* Eartholdi
I appreciate very much your writing to ae about the
manner in which the real estate provisions of the proposed
Banking Act of 1935 would effect your bank, and I quite agree
with you that the provisions should be altered in order to take
care of just such situations as the one you describe.
The point is one that I intend to develop fully in
ay testimony at the committee hearings on the bill*
The Koune Committee began hearings on Title II of the
bill this uoraing, but at +iiis session I presented only a prepared introductory statement. In the course of this statement,
hammwmtm I suggested that it might be best, in the aatter of real
estate loans, to vest in the Federal Reserve Board the authority
to prescribe roles and re.;relations, r&ther than for Congress to
arite them into the statute*
When I take up the detailed iscussion of the section
of the bill relating to real estate loans, it is ay intention to
show that the provisions as now drawn would work an undue hardship on some of our State zaeaber banks and would also operate in
& similar manner against non-aember banks that might presently
desire to qualiiy for aembership in the Federal Reserve System*
As a matter of fact, it seems to mo that real estate
loan restrictions, when incorporated in a statute, are necessarily
arbitrary and impractical* 5Jcperience shows, furtherraore, that
t^ey are ineffectual in operation, and cannot in any sense be regarded as a substitute for good judgment and o-ood management*
The course that I would personally favor, therefore, is
t at of removing frora the statute the detailed restrictions on




George Barthold

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5/4/55

real estate loans, and leaving to the Federal Reserve Board the
natter of determining such rules and regulations as may be required in the light of the conditions existing at any given time*
In this manner, the Board would be able to take account of the
state of the real estate market, the mortgage market, and the
banking and business coiaaiunity in general*




Yours sincerely,

M. S. Eccles,
Governor