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F o r m F. R. 131

BOARD DF GOVERN•RS
DF THE

FEDERAL RESERVE

Office
To

SYSTEM

C o r r e s p o n d e n c e

Chairman Eccles

Date

April 6 . 1938

Subject:

!M

From

Mr. Smead

Referring to our "Comments with respect to section 2(c) of the
Patman Bill, HR 7230" dated March 29, 1933, attached to my memorandum
of March 30, after further consideration and discussion with Governor
Ransom it has been decided to eliminate from the memorandum any reference
to the relationship between the present surplus of the Federal Reserve
banks and their deposit and note liabilities.

A copy of the memorandum

as rewritten is attached.
It is suggested that the memorandum dated March 29 be destroyed.

Attachment•




April 6, 1938

COMMENTS WITH RESPECT TO SECTION 2(c) OF THE PATMAN BILL, HR ?230

Section 2(c) of the Patmnn Bill provides that "After all necessaryexpenses have "been paid or provided for, the net earnings of the Federal
Reserve banks shall be covered into the Treasury as miscellaneous receipt st!.
Section 7 of the Federal Reserve Act as amended requires that all net earnings of the Federal Reserve banks after the payment of dividends shall be
paid into the surplus funds of the banks.
The reasons for the proposed change in the Law, it is assumed, are
based on the assumption that
(1) the not earnings of the Federal Reserve banks, after the
payment of dividends, are substantial, and
(2) the United States Government will have no claim on such
not earnings if thoy are not paid to the Govornmont
currently each year*

Net earnings of Federal Reserve banks #

During the period of the

world war and for a few years thereafter member banks were borrowing very
large amounts from the Federal Reserve banks* and as a consequence the earnings of the Federal Reserve banks were exceptionally large.
Federal Reserve banks paid a franchise tax.

At that time

The franchise tax payments for

the calendar years 1920 and 1921 amounted to over $120*000,000.

For the

eighteen year period from the organization of the Federal Reserve banks in
1911* to the end of 1932 total franchise tax payments amounted to $ll|9* 138*300,
or only §30,000*000 more than the amounts paid for the two years 1920 and 1921.




The requirement for the payment of a franchise tax was repealed by the Banking Act of 1953*

The surplus accounts of the Federal Reserve banks were

built up in large part during the World War and early post World War periods
when the earnings of the Reserve banks were relatively large.
The Federal Reserve Act, as amended on March 3* 1919* provided that
all of the net earnings of a Federal Reserve bank remaining after the payment of dividends* including those for the calendar year 1918* should be
paid into a surplus fund until it amounted to 100 percent of subscribed
capital and that thereafter 10 percent of such net earnings should be paid
into the surplus and the remainder paid to the United States as a franchise
tax.

This provision of the Law was again modified by the Banking Act of

1933* to provide that all of the net earnings of a Federal Reserve bank,
after payment of the 6 percent dividend provided by law, should be paid into
its surplus fund®

At the some tim3, however, Congress required the Federal

Reserve banks to use one-half of their surplus to purchase stock in the
Federal Deposit Insurance Corporation, on which they receive no dividends.
In other words, one-half of the surplus of the Federal Reserve banks was
appropriated by Congress for the purpose of furnishing the Federal Deposit
Insurance Corporation with a part of its capital funds.
The net earnings of the Federal Reserve banks available for transfer to surplus during recent years have been relatively small, amounting
to $2,616,352 in 1937# to $352,5214 in 1936, and to |607,1|22 in 1935.

In

some years the Federal Reserve banks, after payment of dividends, have had
deficits in not earnings which were charged to surplus.
Since the Federal Reserve banks were organized in 191I4 their total
earnings have amounted to $l,2ljl,000,000. Of this amount |6l0,000,000 has




boon utilized to cover costs of operation, '133,000,000 has been set aside
as reserves for contingencies and the balance of $598*000,000 has been used
as follows:
Payment of 6 porcont dividend on
capital stock, as required bySection 7 of the Act

1162,000,000

Payment of franchise tax to the
United States Government

114-9*000,000

Contribution to the capital stock of
the Federal Deposit Insurance Corp.

139*000,000

Balance in surplus accounts

1148,000,000

Of the net earnings of the Federal Reserve banks since their organization, I48 porcent has gone to the Treasury as franchise taxes and to the
Federal Deposit Insurance Corporation as a contribution to its capital
funds, 27 percent has gone to member banks in payment of the 6 percent dividend required by statute, and 25 percent remains as siarplus.
Since the operations of the Federal Reserve banks must under the law
be governed with a view to accommodating commerce and business and with regard
to their bearing upon the general credit situation of the country such banks
should be in a position, if necessary in the public interest, to operate over
substantial periods with income insufficient to cover expenses.

Furthermore,

if the Federal Reserve bonks are to serve the productive enterprises of the
country adequately they must at times take unusual risks«

In the circum-

stances, it is importownt that the surplus of the Federal Reserve banks bo increased from time to time as earnings permit.




-

k

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Government's right to surplus. With rospoct to the sccond assumption
mentioned above, Congress has the right at any time to legislate with rospoct to the surplus funds of the Federal Reserve banks.

If at any time

Congress should consider the surplus of the Federal Reserve banks more than
adequate, in the light of their liabilities and responsibilities, it could
appropriate a portion thereof for such purposes as it saw fit. As stated above,
Congress did in 1933 appropriate one-half of the surplus of tho Federal Reserve
banks to be used as a part of the capital funds of the Federal Deposit
Insurance Corporation. While the Federal Reserve banks technically ovm stock
in the Federal Deposit Insurance Corporation, they are not permitted under the
law to receive any dividends on such stock.
Under present law member banks are entitled to a 6 percent cumulative
dividend on their paid-in subscription to the capital stock of tho Federal
Reserve banks.

Ho further distribution to member banks of tho net earnings

of the Federal Reserve banks is possible under existing law.

In case of

liquidation of a Federal Reserve bank tho Law provides that its surplus shall
be paid to and become tho property of the United States.
Tho acquisition by tho Government of tho capital stock of the Federal
Reserve banks* as provided in Section 2(a) of tho Patman Bill, would necessitate an initial expenditure of Government funds in the amount of approximately
1133*000,000 for tho cost of such stock, and in view of the fact that tho
public indebtedness of the Government presumably would be increased by a
corresponding amount, tho net income derived by tho Government from tho owner-




ship of such stock would be limited to tho difference between the interest
cost to the Government of money borrowed by it and the annual dividends received from the Federal Reserve banks.

The annual 6 percent dividend payable

to member banks in accordance with Section 7 of the Federal Reserve Act
amounts to about $8,000,000, and if the cost to the Government of borrowed money
bo considered to bo say 2~l/2 percent per annum on the basis of long term bonds
the net profit which would accrue to the Government from its investment of
$133*000,000 in the capital stock of the Federal Reserve banks would bo loss
than ¥5,000,000 per annum*

Should Congress decide to reduce the dividend on

Federal Reserve bank stock this profit would bo largely eliminated.
Federal Reserve notes*

It is frequently stated that the Federal Re-

serve banks obtain Federal Reserve notes from the United States Treasury for
the cost of printing, and that they place large volumes of such notes in
circulation and thus obtain substantial profits which should belong to the
Government*

It is important, therefore, to review the factors that determine

the volume of Federal Reserve notes in circulation, what the Federal Reserve
banks have to do to get them and the costs connected with the supplying of
currency to the public•
The amount of money in circulation at a given time represents what
the public collectively wants, since currency always mrves out of the Federal
Reserve banks when the demand for it increases and returns to them when the
demand subsides.

This is what is meant by an elastic currency. When cur-

rency is needed, the public obtains it from the local banks, and the latter




-

6

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obtain it from the Federal Reserve banks. Whon it is not needed, the public
deposits it in the local banks, and the local banks in turn redeposit it in
the Fedoral Reserve banks.

The Federal Reserve banks may be regarded as

reservoirs from which additional currency is drawn when the public requires it
and to which currency not required by the public is returned.

The Federal

Reserve banks have no way of keeping in circulation a larger amount of currency than the public requires, or reducing the amount of currency that the
public needs to finance its current operations.
The demand for currency is determined by various conditions.

A certain

minimum is required for day-to-day cash expenditures of individuals; a certain
minimum is required for payrolls.

There are times when personal expenditures

rise, as during holidays, and there are times when payrolls rise, as during
harvest.

Certain individuals, businesses, and communities have their own

periods when they need more or need less cash than ordinarily.

The net effect

of all of these factors is a normal and regularly repeated cycle of demand
for currency year after year —

slack after the first of January, when retail

trade falls off following tho holidays, larger during the succeeding spring
months, when payrolls increase and outdoor industries become active, slack
again in mid-summer,and steadily increasing during autumn and early winter to
the regular peak in December.
In addition to this regular annual cycle, the amount of currency also
responds to increases and decreases in the volume of retail trade and of payrolls as the amount of business done by the country increases or decreases.
There have been times also vrhen the demand for currency was greatly increased
as in the period preceding the banking holiday in 1933*




In the course of a

-

7

-

few weeks at that critical time the Federal Reserve banks furnished the
public with as much as $2,000,000,000 of additional currency.
For more than twenty years the Federal Reserve banks have fully met
the normal demands of the country for currency* they have also fully met
peak demands both in times of prosperity and in times of depression, and they
have made it possible for the volume of currency to decline automatically
when the public demand for it declined.
Machinery of note issue*

Before a Federal Reserve bank can obtain

Federal Reserve notes it must deposit as security with the local representative of the Government, known as the Federal Reserve agent, collateral at
least equal in amount to the notes to be issued*
by law, may consist of the following assets only:

This collateral, as provided
(l) promissory notes,

drafts, bills of exchange, or acceptances, usually referred to as "eligible
paper"; (2) gold certificates on hand or due from the United States Treasury;
and (3) until June 30, 1939* United States Government securities bought in the
open market.

In addition to being secured by the pledge of specific col-

lateral, Federal Reserve notes are a first lien on all the assets of the
issuing Federal Reserve bank, and a J^O percent reserve in gold certificates
must be maintained against them.
As of March 16, 1938, the Federal Reserve banks had obtained
$lj.,]L|i|0,000,000 of Federal Reserve notes from the Federal Reserve agents, of
which

125,000,000 were in circulation, constituting about two-thirds of the

total of 16,330,000,000 of money in circulation, and $315*000,000 were held in
the vaults of the Federal Reserve banks•
notes was as follows:




The collateral held against those

Gold certificates on hand and due from U.S. Treasury

$>14*533*000,000
10,000,000
7*000*000
$14,550, 000,000

Gold certificates are receipts which are isstied to the Federal Reserve banks
by the United States Treasury for gold deposited with it by the Federal Reserve banks in compliance with the Gold Reserve Act of 193^4* which required all
monetary gold in tho United States to be delivered to the Treasury.

The Fed-

oral Reserve banks do not have tho right to pay out these gold certificates.
As indicated, tho Federal Reserve bonks havo pledged $14*533*000,000 of these
certificates against fJ^l^O, 000,000 of their own notes in circulation.

Federal

Reserve notes, therefore, at present are virtually substitutes for gold held
by the United States Treasury.

So long as the Federal Reserve banks pledge

one dollar in gold certificates against each dollar of Federal Reserve notes
in circulation they cannot obtain a profit by issuing Federal Reserve notes.
Moreover, all costs connected with the printing, shipping and redemption of
Federal Reserve notes are borne by the Federal Reserve banks.

As will be noted

from page 10 of this memorandum, it cost the Federal Reserve banks nearly
£'6,000,000 during 1937 to obtain currency from the Treasury and supply it to
member banks and through them to tho general public•
Expenses of Federal Reserve banks.

The expenses of the Federal Re-

serve banks were incurred in rendering the services and performing the functions
required by the Federal Reserve Act. As stated above, they furnish the public
with an adequate, safe and elastic currency; they collect largo volumes of
chocks and other items payable upon presentation for member banks; they provide
rediscount facilities for member banks; and perform fiscal agency, custodianship, and depositary services for the Treasury and other Government agencies.




-

9

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In carrying out those and other important functions the Federal Reserve banks
have endeavored to be of as much service to their member banks, and through
them to coinmerce, industry, agriculture, and the public in general, and to the
United States Government, as is consistent with the efficient and economical
operation of the System.
All compensation provided by the boards of directors of the Federal
Reserve banks for directors, officers or employees is subject to the approval
of the Board of Governors.

The Board of Governors requires each Federal Re-

serve bank to submit periodically detailed reports of its expenses and of
salaries paid each officer and employee.

The reports of expenses are re-

viewed and summaries thereof are furnished the Federal Reserve banks in order
that their costs may be compared.
Shortly after the present Board took office on February 1, 1936, it
instituted a survey of the organization at each Federal Reserve bank and as
a result thereof many economies wore effected, among which were the placing
of the chairmanships at the Federal Reserve banks on an honorary basis and
the fixing of the compensation of the Chairmen on the same basis as that of
any other director in lieu of annual salaries of from §20,000 to $50,000, as
had been the previous practice. Wherever it is found that certain operations
can be handled more economically without sacrificing efficiency prompt steps
are taken to effect the economies.
There has been a gradual reduction in the unit costs reported for
the principal operating units of the Federal Reserve banks.

For example, in

the Country Checks-Outgoing unit, which is the largest single operating unit
in the Federal Reserve banks, the average cost of handling a thousand items




10

-

was $3*65 ton years ago as compared with $2.59 i n 1936 and

•61+ in 1937*

'With a few exceptions, the unit cost in the Country Checks-Outgoing unit
for each of the past ten years has been lower than that reported in the
immediately preceding year as may be noted from the following tabulation:
Cost per thousand items in the Country Checks-Outgoing unit
1928
1929
1930
1931
1932

65
3*35
3*35
3*23
3-30

1933
1931+
1935
1936
1937

$3*1*7
3.05
2,88
2*59
2.61+

The reductions in operating costs reported for the Country Checks-Outgoing
unit are due principally to improved methods of procedure.
The costs of performing the various services rendered by the Federal
Reserve banks during 1937 a**e set forth below in summary form.
EXPENSES OF FEDERAL RESERVE SYSTEM, YEAJR 1937
Currency and Coin
The cost of receiving and handling
2,257*889,000 pieces of currency and
2j730,387*000 pieces of coin, including
shipping charges to and from member
banks was

$1+, 12*9,671

Assessments by the Treasury Dept. to cover
the cost of printing new Federal Reserve
currency, the cost of issuing such currency
at the Reserve banks, and the cost of redeeming Federal Reserve currency unfit for
circulation, including shipping charges,
amounted to




$1*787,036
Total

936,7 07

11
Cheek Clearing and Collection
Handling and collecting 926,792,000 checks
and 6,705*^13 maturing notes, drafts,
coupons, etc. cost .•••••««••

.......

$3*802,889

Loans, Rediscounts and Investments and Safekeeping
Making discounts and advances to member
banks; handling applications for advances
to industry for working capital under
Section 13b of the Federal Reserve Act;
maintaining credit information, holding
in safekeeping and servicing about
§1^000,000,000 of securities for member
banks and purchasing and selling Government securities for member banks cost • •••

£>1*366,258

Fiscal Agency, Custodianship, and Depositary
Receiving, proving, and paying 127,823,053
Government checks and coupons, including
work relief checks, and maintaining the
general account of the Treasury of the
United States, etc. cost ........
Fiscal Agency work for the U* S. Treasury
Dept. comprising principally the issue,




§1,125,L02

12 redemption* and exchange of 3*892,0Olj.
pieces of securities cost

44

Total
Reimbursed by Treasury Dept

$1,380,352
02,505,751*
0l,63i4,363

Net cost

0871,391

Services performed for various Government
agencies such as the Reconstruction Finance
Corporation, Federal Farm Mortgage Corporation, Federal Land Banks, Federal Intermediate Credit Banks, Federal Emergency
Administration of Public Works, and the
Federal Home Loan Banks and Home Owners1
Loan Corporation cost

§2,231,lii2

Reimbursed by Government Agencies •••
Net cost

2,20ii,I|26
§26*716

Accounting
This function, which includes the maintenance of the general books, member and
Federal Reserve bank accounts, etc#, and
the making of transfers of funds for the
account of member banks, cost
Banking House and Furniture and Equipment
Cost of operation of banking houses,
including payment of taxes, the salaries




$1*579*520

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13

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of janitors, elevator operators, etc.,
less deductions for income received from
rented space, etc.

$2,612,685

Reserves set aside for depreciation
on banking houses

1,297,859

Furniture and equipment, net cost ••••••
Total

233,290

..

Bank examination
Cost of examining state member banks
and of analyzing condition and examination reports of National and State member
banks, etc.. amounted to

$1,101,800

Expenses of the Board of Governors
Assessments for expenses of the Board of
Governors of the Federal Reserve System. •

$1,7^8,379

Statistical and Analytical
Preparing and publishing monthly reviews
of credit, business and agricultural conditions; and obtaining and assembling
various statistical data, etc. cost •••««.

Bank

$J480, 028

Relations

Bank relations work; visiting member and
nonmember banks, conferences, etc. cost •••




$195*0014

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Ih

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Personnel and Service
Maintenance of filing, mailing and personnel
departments; vaults and telephone service;
purchasing supplies and equipment; equipment
repairs; page service, etc., cost ..«•«..•...

v2, 29l4,23l4

Protection
Salaries of special officers and watchmen,
and the cost of other protective services
amounted to

$961j.,932

Postage and Insurance
Postage on ordinary mail; insurance on
equipment and supplies; premiums on
employees* fidelity bonds, bankers blanket
bonds, etc., cost

$l#32i*,298

Auditing
Maintaining general audits of the Federal
Reserve banks and branches cost ....••••••

0552,623

Legal
The employment of counsel and other legal
expenses cost

§190,086

General Overhead
General overhead and supervisory expenses,
including directors' fees and other miscellaneous expenses, amounted to •...••••••••••




Total Net Expenses ....

$1,685*101
$28,263,800

BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM
April 9, 1938.
COMMENT ON B.R.7230
Introduced by xMr. Patman

The fundamental purpose of H.R. 7230 is to establish a mechanism
that would control the volume of money with a view to maintaining a
fixed price level.
The mandate
In an amendment the Board of Governors is instructed to raise the
all-commodity index until full employment of all persons able and willing to work shall have been achieved, and until the price level shall
at least reach the all-commodity index of 100, as established by the
Department of Labor, for the year 1926.

The Board is further directed

co maintain this price level with variations not to exceed 2 per cent.
To accomplish this the Board is directed to expand and contract demand
deposits by engaging in opon-markot operations.
The position of the Board of Governors on the problem of monetaiy
objectives was indicated in a statement issued on August 2, 1937, in
response to a Congressional inquiry.

The Board is in full agreement

with tha ultimate objective of proposals to promote economic stability,
which moans the maintenance of a volume of business activity and of
national income adequate to assure as full employment of labor and of
the productive capacity of the_ countiy as c m be continuously sustained*
The Board is aware that commodity prices are an important element in
the Nation's economic life and that violent fluctuations of prices have




—f
f)
w—

disastrous effects.

It believes, hoy/ever, that price stability does

not necessarily lead to economic stability and, therefore% should not
be the principal objective of public policy.

In its opinion the ob-

jective of economic stability cannot be achieved by monetary means
alone, but rather should be sought through coordination of monetary
and other major policies of the Government which influence business
activity.
The principal difficulty with a stable price level as the objective of economic policy is that it is not in itself a satisfactory indicator of a continuously smooth working of the economic machine.
There have been periods in the past when the price level was stable
and nevertheless there were developing numerous maladjustments which
led to an economic collapse.

For example, from the latter part of 1927

to the latter part of 1929 the index of wholesale prices showed little
change, but other developments wore threatening economic stability.
Prices and activity on the stock market were rising rapidly, and brokers1 loans grew at an unprecedented rate.

Construction of office and

apartment buildings was being promoted with a view to quick profits at
a rate that endangered the longer-time outlook in the building industry*
Loans were being made for enterprises abroad without careful investigation of credit risks, and business activity in general was increasing,
partly as a result of speculative developments, to a level that could
not be sustained.

The use of the commodity price level as a guide to

credit policy in these circumstances would have been entirely unsatisfactory.




There is no assurance that it would be satisfactory in the future.
The proposal is that the Board of Governors bring the commodity
price index, up to at least the 1926 level.

The average for that year

is about 25 per cent above the present level and an advance of that
magnitude, except over an extended period, would cause speculative
buying and vyould lead to boom conditions which would culminate in a
break and a depression.

Furthermore, in periods of rapid advance dis-

parities between prices of different groups of commodities generally
become more pronounced and yet, both from the point of view of justice
and of economic stability, the most important thing in regard to prices
is the maintenance of proper relationships between prices of different
commodities that are exchanged for each other.

Activity of producers

depends on the relationship between their costs, including principally
prices of materials, labor, taxes, and debt service, and the prices
at which they can sell their products.

In the last quarter of 1936

and in the first quarter of 1957, for example, building costs and
prices of new houses rose so rapidly and so far as to discourage buying, and this resulted in a decline in residential building.

More-

over, the rise in prices of industrial raw materials at that time was
much sharper than the advance in finished goods, and this was a factor
in causing speculative purchases, forward orders, and building up of
inventories, all of which contributed to the subsequent collapse of
business.




Present prices of individual commodities in the Bureau of Labor
statistics index, compared with 1926, range from a decline of 75 per
cent to an increase of 100 per cent.

A restoration of the 1926 level

could be achieved through an advance of all commodities, including
those that are too high, as well as those that are too low, or through
a rise in one or the other group of these commodities.

There is

nothing in monetary policy that could determine which of the commodities would rise, and yet this would be all-important from the point
of view of the effects that the rise in prices would have on the
economy.
In the Board1s view the essential objective of monetary policy
is to contribute to the maintenance of a flow of money and income
tiirough the channels of trade, industry, and agriculture that would
tend to utilize to the full the country's human and material resources.
This is the Board's understanding of the broad mandate stated in the
Federal Reserve Act as "accommodating commerce and business".

To this

end and to the maintenance of sound banking conditions the Board devotes its efforts, and there is nothing in the proposed mandate that
would add to the Board's desire or ability to achieve these objectives.
In directing the Board to achieve price stability and full employment through open-market operations, the proposed mandate disregards the limitations on tho effectiveness of this instrument of
credit policy.




It assumes that open-market operations can always

-5-

create or destroy deposits, and that changes in the volume of deposits in turn are immediately reflected in the price level.

The fact

is that open-market operations do not always create deposits, since
purchases of securities from the banks do not increase deposits.
Whether open-market purchases result directly in an increase in deposits or not, they do result in the creation of a corresponding
amount of reserves.

These reserves may or may not result in the

creation of deposits, depending on whether conditions are favorable
for the expansion of loans and investments by banks.

The great bulk

of deposits in the banks of the United States are created through
such an expansion.

A given volume of reserves created by Board ac-

tion, therefore, might result in no increase in deposits at all, or
on the other hand might result in a growth of deposits several times
as large as the reserves.

Which of these developments would actually

occur would depend on forces that are largely, if not wholly, outside
the control of the Board of Governors.
It is not true, furthermore, tfant the creation of deposits necessarily results in an equivalent rise in prices.

We have had increases

in deposits without corresponding increases in prices.

The volume of

deposits at the present time is greatly in excess of the amount that
existed in 1929 and yet the price level is much lower.

Nor is it

clear th-it a rise in prices necessarily results in an increase in employment.

An unbalanced advance in prices may, on the contrary, be an

influence in decreasing employment, as was the case early in 1937.




-6Aside from many f&bibrs that are not under the control of the Government, there are numerous phases of Government activity other than
monetary action by the Federal Reserve System that have effects on nrices
and. on economic activity.

Among such factors are the actions of the

United States Treasury in relation to the inactive gold account and the
stabilization account; policies in regard to taxation, exchange rates,
the volume and character of Government spending; its action in regard to
the capital market, to railroads and utilities; the Government's housing
program, its agricultural policies, and its policies in regard to labor.
All of these Government activities have a distinct bearing on the volume
of business activity and on the price level. They are beyond the influence of the Federal Reserve System, and yet without them and their coordination with monetary policy the System would be powerless to achieve
either an advance in prices or the restoration of full employment, as
would be required under the proposed mandate•
The Board of Governors, therefore, does not favor the adoption of
the proposed mandate»
Federal Reserve System operates in the public interest
In addition to prescribing a mandate for the Federal Reserve policy,
the bill proposes a reorganization of the Federal Reserve System.

The

reasons offered for this reorganisation are that the System has not been
operated in the public interest; that it has been dominated by bankers;
that it has been conducted in the selfish interests of $ amall group, and

that it has made large profits at the expense of the community.

The Board

of Governors does not believe that any of these assertions can be sustained
by the record.




-7Ownership of stock by member banks does not enable the bankers to
control the Federal Reserve System.

It is more nearly in the nature of

a compulsory capital contribution than stock ownership. Although the
member banks elect two-thirds of the directors of the Reserve banks, the
large banks elect only two out of nine directors.

The small banks elect

two, the medium-sized banks elect two and the Board of Governors in
Washington appoints three.

Only a third of the directors can be bankers

and ail directors and officers are subject to removal by the Board of
Governors.

The Board in Washington appoints the chairman and deputy

chairman of each Reserve bank, and the appointment of all presidents
and first vice presidents, as well as the salaries of all officers and
employees, are subject to its approval.
Complete authority over all matters of major national policy, such
as the determination of discount rates, reserve requirements, margin requirements on security loans, and maximum rates of interest to be paid
on time deposits, is vested in the Board of Governors. Authority over
open market operations is vested in an open market committee consisting
of seven members of the Board of Governors and five members elected by
the Reserve banks•
It is clear, therefore, that in matters with which the bill is primarily concerned the System is dominated not by banks, but by the Board
of Governors, a Governmental body whose members are appointed by the President and confirmed by the Senate.
Federal Reserve banks not operated for profit
During the twenty-three years of its existence the Federal Reserve
System has earned approximately one and a quarter billions of dollars, of




-8which about one-half has been used for operating expenses incurred largely
in performing public services, such as the clearing and collection of
checks, the supplying of currency to the banks and to the public, the performance of marry duties for the United States Government, and in furnishing rediscount facilities for the member banks*
Earnings of the Federal Reserve banks above these expenses nnd reserves for contingencies amounted to $600,000,000.

Of this amount approx-

imately $150,000,000 has been paid to the Government as franchise tax,
about $140,000,000 has been appropriated by Congress for the Federal Deposit Insurance Corporation as capital, $160,000,000 has been paid as the
statutory dividends to member banks, and the remainder is held in a surplus account which in cose of liquidation becomes the property of the
Government.
Member banks contribute 3 per cent of their capital and surplus to
the capital of the Reserve banks and receive 6 per cent annually on this
contribution.

In addition, member banks are required to keep balances

with the Reserve banks amounting on the average to 16 per cent of the
member banks* deposits and receive no return on these balances.

For ex-

ample, a member bank having a capital and surplus of $100,000 and deposits of Si,000,000 contributes $3,000 to the Reserve bank's capital and,
on the average, would be required to hold $160,000 on deposit with the
Reserve bank as legal reserves, on which it receives no interest. The
dividends such a bank would receive on its stock in the Reserve bank would
be $180 a year.
The System was established and is operated in the public interest and




-9dominated by public officials; it performs a service that saves the
people of the country far more than the cost of the System; and it makes
no profits for any private interest other than the amount paid annually
to stockholders at a fixed rate, which has been prescribed and can be
changed by Congress,
Proposals would not improve banking system
Proposals in the bill for reorganizing the Reserve System would transfer ownership of the stock in the Federal Reserve banks to the Government
and would have all the directors of the Reserve banks appointed by the
President and approved by the Senate.

It would enlarge the membership of

the Board of Governors to fifteen, including three ex-officio members —
the Secretary of the Treasury, the Comptroller of the Currency, and the
Chairman of the Federal Deposit Insurance Corporation.
A Board of Governors of fifteen members proposed in the bill would be
too unwieldy to function promptly and effectively.

The proposal in the

bill to offer all the privileges of membership to nonmember banks so long
as they choose to keep their reserves in a Federal Reserve bank would remove all incentive to become members of the System.

It would enable all

banks to profit by the services of the System so long as it suited them,
without contributing anything to its strength or complying with its regulations, and to withdraw their reserves when to maintain them would seem
to be burdensome.

It would make futile the proposed enlargement of the

power to increase reserve requirements.

It would remove all incentive to

membership and would make it impossible for the System to discharge its
responsibility for maintaining sound credit conditions.




-10Distinction between monetary and fiscal authorities should be maintained
The primary function of the Treasury is to collect taxes, borrow
money, and provide funds for the various agencies of the Government in accordance with Congressional appropriations.

The primary function of the

Federal Reserve System is to influence the flow of money and to contribute
to tho soundness of the banking situation.

In a broad sense the objec-

tives of both agencies are the same, namely, to serve the public interest,
but their points of view and experience, and their approach to current
problems may at times be different.

The maintenance of an organization

for the regulation of credit separate from the fiscal arm of the Government has been found advantageous in most countries of the world, and its
abandonment, which is proposed in the bill, would, in this Board's opinion,
be a backward step*
Local.autonomy in local matters should.be preserved
Since its establishment in 1914, the Federal Reserve System has undergone many changes in the direction of increased control by the 3oard of
Governors.

With the passage of the Banking Act of 1935 this control has

been greatly strengthened in so far as national policies are concerned.
In regard to local matters, the maintenance of local autonomy under general
supervision and close Government regulation is advantageous in a country
like the United States, consisting of various regions with diverse economic
interests.

The maintenance of locally elected directors on Federal Reserve

bank boards is of great advantage in creating local pride and local interest in the System and in inspiring the business community with confidence in its management.




This advantage would be lost if the appointments

-11of all local directors were handled entirely from Washington.

Consequently,

the System's ability to render a disinterested public service to all classes of the community would be greatly diminished.
To sum up, the Board is convinced that improvement in our banking system is needed but sees nothing in this bill that would tend in this direction. The Board is convinced that the main objective of the bill is not
practicable; that the evils which the reorganization features of the bill
propose to correct do not exist; that the organization which it proposes
to establish would result in less satisfactory service to the country;
and that enactment of the bill would be a backward and not a forward step
in the development of the banking system in the public interest.