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Pollaek Foundation,
Newton, Mass,,
February 14, 1935.

Hon. Marriner 0. E c c l e s ,
Federal Reserve Board,
Washington, D. C.
Dear Mr. Eccles:
When I had lunch with you in Washington I
spoke to you about the Bill introduced by Senator
King for the regulation of small loans in the District.
At your suggestion I wrote my objections to
the Bill and sent a copy to Fritz Champ and a copy to
Governor Dern. I asked Fritz to take it up with Senator King.
I enclose a copy of my statement.
With much appreciation of the opportunity
you gave me for the talk in Washington, I am
Faithfully,

WTF:R

I

concerning proposed SmallLonn Law for the District of Columbia!
Small Loan Law for the
rict of Columbia, introduced in
session by Senator
(S.110£ and ! . .3463), would not achieve its!
avowed purpose but on the contrary would deprive the most necessitous
borrowers in the District of full services under protection of the law,
Moreover the passage of this law would tend to discredit throurh^t the
country the achievements of two generations of social 'Yorkers who have
opposed the unlicensed operators and brought abou^
adoption in twentyj
six states of the Uniform Small Loan Lav, as sponsored by the Russell Sag!
Foundation.
very year powerful organizations of unlicensed members work under
cover in every state, either for the repeal of the Small Loan Law or for
changes in the lav which would prevent reputable companies from doing business. The passage, in the nation*s capital, of a bill that seems to discredit the present Small Loan Lav; in twenty-six states would be used by
illegal lenders in every state as an argument for undoing the notable
achievements of the past twenty years.
The sponsors of this bill ignore the previous studies and recommendations of the District Conrnissioners and the 3ub-Go:i:aittee. The bill
introduced by Senator Capper (S.5629), in the Third Session of the 71st.
Congress, was favored by the Committee, although no vote was taken by th<
Senate. The bill introduced by Congressman Bowman, (H.R.9592), in the
First Session of the 72nd. Congress, was recomended by the District
Commissioners and by the Committee, but did not come to a final vote.
These two bills ?:ere introduced again in 1934 and referred to tve Committee on District Affairs, but the Committee took no action. These two
bills, unlike the one now before Congress (3,1162), are based on the
principles which have been thoroughly tested during twenty-three years
of experience with small loan legislation now covering twenty-six states.
These principles have not yet cone to a vote in either branch of Congress
though the;
e been endorsed repeatedly by the District G
Lssioners
and by the Committee on District Affairs.
Experience under the small loan laws proves that, even in f
nost favorable localities, a maximum rate lower
3r Lonth on I
first $100.00 and 2f9 on the next §200.00 (or a rate of 2f& on all loans
up to JoOG.OO) does not achieve the purpose of providing necessitous
borrowers with loans by licensed lenders. Indeed, even these rates do
not guarantee full service to borrowers, because these rates do not
cover the costs of making very small loans. In ever
he
maximum rate
fixed by law as low as the rates in the proposed
law, (S.1162), the law has driven licensed lenders out of business, and
.: prevented necessitous borrowers from obtainin
regulated
services which the law was designed to provide. The rates specified in
e proposed law are lower than the rate
i
ie a Is
in
~rork State, while President Roosevelt was Governor of that state.




-

I
The proposed lav, Moreover, legalizes special fees and discounting in advance. 'Experience in many states proves that provisions for
special fees and for discounting
idvance because of special expenses
of operation In connection
certain loans, to a large extent prevent
the lav; from accomplishing its purpose. In the files of the Russell Sare
Foundation is a long list of evasions of the lav in cases where, in the
past, the lav has allowed special fees; and no v/ay has yet been found of
preventing these evasion .
ore is 1
. objection to the provisions
in the proposed lav for higher rates for loans vhich are regarded as unusu
"lazardous. In actual practice all
se provisions open the way
evasions and injure many more borrowers
elp.
Moreover, the proposed la^
mj
•
or rates than
the Uniform Snail Loan Law. fciaxiraum rate per month, vhich is permitted in any of the v
-six states v
he Uniform Snail Loan
Lav/, is •.. *,
ereas the proposed bill permits a rate per month on,certain
.11 loans, where fees are collected in advance, of over 40^. The !Triform Small Loan Lav;, under fire for many years in many states, has been
tested in various courts. It provides no loop-holes. Lenders who wish
evade that 1
been unable to find a
to do it, in any state
has made a reasonable attempt to enforce the lav. The proposed bill
. . ,
>h var"
ly in its phrasing fr
the Uniform
Small Loan Lav, is hi 1 T experimental. It has many features which probably are dangerous. It is impossible to tell in advance, hovever, what
difficulties of administration would arise.
• nee the original draft of the Uniform Small Loan La:
de
in 1916, the ]
is been modified repeatedly b.
issell Sage Founda>n in order to prevent evasions and abu.
to make its language
clear. The loner; experience
11
I Law and
Lumerous interpretations
e courts rive it a guarantee of fitness for its purpose which no
ily experimental law can possibly have.




proposed law should not be passed.

7i].: '

-'. Foster

POLLA^ FOUNDATION FOR
ECONOMIC RESEARCH
NEWTON, MASSACHUSETTS

was started in
1920 by Waddill Catchings. The purpose, as
stated in the deed of trust, is to study "the
means whereby industry may be so organized, and the products of industry so distributed, as to yield the people generally the
largest possible satisfactions." The work of
the Foundation still has to do solely with the
original central purpose. The publications
are concerned largely with various aspects of
the problem of sustaining the purchasing
power of consumers.
The Foundation has made appropriations
tofinancespecific researches at Harvard University, Yale University, and the University
of Chicago. Since the beginning of the National Recovery Administration, the Foundation has endeavored to further the objectives of the Consumers Advisory Board, of
which Board the Director is a member.

THE POLLAK FOUNDATION




The scope of the work of the Foundation is
indicated bv the Pollak Books: i
J
"Business without a Buyer," by William Trufant Foster
and Waddill Catchings
"Real Wages," by Paul H. Douglas
"The Road to Plenty," by William Trufant Foster and
Waddill Catchings
"Cycles of Unemployment," by William A. Berridge
"Costs and Profits," by Hudson Bridge Hastings
"Money," by William Trufant Foster and Waddill
Catchings
"Profits," by William Trufant Foster and Waddill
Catchings
"The Making of Index Numbers," by Irving Fisher
"Is it Safe to WTork?" by Edison L. Bowers
"The Problem of Business Forecasting," by Warren
M. Persons, William T. Foster, and Albert J.
Hettinger, Jr.
"Population Problems," by Louis I. Dublin and others
"Progress and Plenty," by William Trufant Foster and
Waddill Catchings
"Social Consequences of Business Cycles," by Maurice
B. Hexter, with introduction by Allyn A. Young
" Pollak Prize Essays," by R. W. Souter, Frederick Law
Olmsted, C. F. Bickerdike, and Victor Valentinovitch Xovogilov



The Pollak Books as well as the Pollak
Pamphlets, may be purchased from the
Foundation.
For the first ten years, the funds were contributed solely by Waddill Catchings. Other
donors have been Robert J. Caldwell, Edward A. Filene, Henry L. Shattuck, Committee on the Costs of Medical Care, Household Finance Corporation, Julius Rosenwald
Fund, Twentieth Century Fund, Milbank
Memorial Fund, and the Beneficial Management Corporation.
The Foundation is a non-profit, educational institution. As such, it is exempt from
Federal Government taxation; and gifts to
the Foundation, under the law, may be deducted by the donors in computing taxable
income. Contributions and bequests will be
gladly received, to be used in carrying out
the purposes of the Foundation as stated in
the deed of trust.




ADVISORY COUNCIL I
WADDILL CATCHINGS, Lawyer, New York City
GEORGE H. DERX, Secretary of War

CARL F. DANNER, President of the American Hide and
Leather Company
PAUL H. DOUGLAS, Professor of Industrial Relations,
University of Chicago
HENRY I. HARRIMAN, President of the Chamber,of

Commerce of the United States
VIRGIL JORDAX, President of the National Industrial
Conference Board
ERNEST H. LINDLEY, Chancellor of the University of

Kansas
WABBKN M. PERSONS, Consulting Economist, New

York City
ROBERT F. WAGNER, Member of the United States
Senate
RICHARD H. WALDO, President of the McClure Newspaper Syndicate
HENRY A. WALLACE, Secretary of Agriculture

DIRECTOR
WILLIAM TRUFANT FOSTER

ASSOCIATE DIRECTOR
LE BAROX RUSSELL FOSTER