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HEBER J. GRANT, President JOHN F. BENNETT, vice President w? MS E W A N , ASS'C cashier GEO. s. SPENCER, vice President WILLARD R. SMITH, Cashier J. FORBES DONE, ASS'C casnier WS" T. PATRICK, Ass't Cashier CAPITAL $ I.OOO.OOO. OO - SURPLUS $500,000.00 llarch 30, 1955 Mr. Ivlarriner S. Eccles Governor of Federal Reserve Board Washington, D.C. Dear Mr. Secies: Ever since the Federal Deposit Insurance Corporation went into effect, we have been working on legislation which would be as favorable to strictly stock savings banks as present legislation is to mutual Banks, The "Banking Act of 1933" made no differentiation between strictly stock savings banks, (referred to herein as "nonmutual savings banks1*) and commercial banks; whereas, as you know, non-mutual savings banks more closely resemble mutual banks than commercial institutions. We are the only non-mutual savings bank in the State of Utah, and compared with other banks in this Country, non-mutual banks are rather limited. However, they represent assets of close to one and one-half billions of dollars, distributed in thirteen states throughout the Union. Y/e believe the FD1C looks with favor on the Amendments to the "Banking Act of 1933",. which we have suggested be included in the "Banking Act of 1955". It seems the Amendments which it is suggested be included in the "Banking Act of 1935", must also be included as Amendments to the "Federal Heserve Act". Vfithout doubt, inquiry will be made of you with regard to the propriety of such Amendments being made to the Federal Reserve Act, and naturally we are very desirous of engaging your favorable recommendations. You may be familiar with the suggested Amendments, but if not, for convenience sake, we are enclosing H.IUB111 5357, in which the suggested Amendments are inserted. {S©e pages 3,10,37, affecting the "Banking Act of 1935* aad pages 65 and 67, affecting the "Federal Iteaerr* Act11. ) Bttiefly, m £©#1 justified in asking for such Amendments on the following grounds; HEBER -J. GRANT, President JOHN F. BENNETT, vies presiflent w * M? EWAN, Ass't cashier G E O . S SPENCER, vice president WILLARO a SMITH, CasWer j . FORBES DONE, ASS'I casnier w~ T. PATRICK, Ass't Cashier CAPITAL $ I,OOO.OOO. OO - SURPLUS $500,000.00 M * W k <**%» Utah l.Ir. Larriner °. Secies 3-50-35 First: I] on-mutual savings banks should be placed in the same class as mutual savings banks, inasmuch as neither of these classes of institutions makes any commercial,or loans of a risky nature. You know, of course, State Laws rigorously restrict savings banks in their investments and do not permit them to make unsecured loans, of. any kind. It is therefore unfair to require such banks to join in guaranteeing the deposits in banks making investments and loans of a more risky, unsecure nature. This is not required of mutual banks, and should not be required by non-mutual savings banks. Second; Inasmuch as savings banks pay interest on every dollar of their deposits, they should be granted the right to obtain interest on their deposits in approved commercial banks, of their reserves and surplus funds, similar to the rights granted mutual savings banks under the present Banking Act. Third: Savings banks should not be reoxuired to join the Federal Reserve System to obtain insurance, since they do no commercial business and therefore, are not able to avail themselves of any of its facilities. Fourth; Some of the non-mutual savings banks in the West, as you perhaps know, allow depositors to use checks against short notice savings accounts, in order to protect their term savings accounts against competitors. This practice is more common in California and other western banks and is not employed at all by our institution; and the banks employing such practice are desirous of being continued such right in the "Banking Act of 1035*• I feel certain you will recognize the justice snd equity of tne above briefly stated reasons for the suggested Amendments, and hope we can rely on your co-operation in having them incorporated in the "Federal Heserve Act*. HEBER J. GRANT, Presidant JOHN F. BENNETT, vica president w» Mf EWAN, Ass't cashier OEO.s. SPENCER, vice president j . FORBES DONE, Ass't cashier WILLARD R.SMITH, Cashier W* T PATRICK, Ass't Cashier CAPITAL $ I.OOO.OOO, OO - SURPLUS $ 500,000.00 karriner S. Secies 3-30-35 _ — 3... I am enclosing a little amplification of each of the four above mentioned points with a more detailed explanation, which I will be very kappy "to have you read, as they greatly the arguments. I am doing this so that /th$s letter will not burden you with its length. With personal greetings and wishes, I am 2nc: H.H.Bill