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X-474.

F E D E R A L

R E S E R V E
WASHINGTON

B O A R D

Memorandum:
In re - Clearing House Examinations.

In nineteen cities members of the Clearing House
Association and nonmembers with clearing privileges are sub­
ject to examination by the Clearing House Examiner, usually
once each year.

The examination is thorough, particular at­

tention being paid to the loans, discounts and credits of the
bank.

After each examination a copy of the examiners report is

delivered to the bank for the information of the directors.

In

case an unsatisfactory condition is disclosed, the report is
called to the attention of the Clearing House Committee.
Clearing House Examinations have proven very effective
in the elimination of unsatisfactory assets and the correction
of unsound tendencies in institutions under criticism.

While

no disciplinary power is vested in the Clearing House Committee,
still it was in a position to recommend the discontinuance of
clearing privileges which in itself would be a public notice of
unsatisfactory condition.




X-474.

- 3In Spokane the Clearing House Examinations are no-'/
being made under the supervision of the Federal Reserve Branch,
the manager being the Clearing House Exaiminar.

In Portland, it

is apparently the intention to have the examinations under the
supervision of the Portland Branch of the Reserve Bank.

The

Clearing House Association at Seattle is desirous of having the
local branch undertake the examination of Clearing House member
banks in that city.
In view of the fact that Reserve Banks or Branches are
located in at least two-thirda of the cities where Clearing House
examinations are now conducted, and further that a majority of the
Clearing House members in those cities are members of or maintain
clearing balances with the Reserve Bank, it is quite likely that
the question of the Reserve Bank undertaking the supervision of
the Clearing House Examinations is likely to be suggested to the
Board in the near future for consideration*
If the Clearing House Examinations are to be undertaken
by the Reserve Banks with the approval of the Federal Reserve >loard,
it should be definitely understood that the responsibility for 3uch
examinations shall be vested solely in the Federal Reserve 3ank and




X-474
—3 t
not in the Clearing House Committee.
will prove very unsatisfactory.

Dual control or supervision

In the appointment of examiners,

while it would he well to consider the suggestions of the Clearing
House Association, still the Reserve Banks, subject to the approval
of the Reserve Board, should appoint the examiners and have the super­
vision of all examinations.
With reference to the expense of maintaining the examining
department, there seem3 to be no reason why the present joint fee
system should not he continued if agreeable to the Clearing House
Banks, otherwise the cost of examination should he assessed upon
the hank examined, as provided for in the Federal Reserve Act.
The Reserve Bank should he free to assign men in the examining
division to other duties or assign them to make examinations of
institutions in other cities.

Reports of examinations should he

filed with the Federal Reserve Bank and if an unsatisfactory
condition is disclosed, the matter should he handled by the Re­
serve Bank officials and not the Clearing House Committee.
Banks are now examined efficiently twice each year.

National

If a further

investigation is to be made, it should be limited to loans, credits,
and investments, unless a complete examination is requested by the




X-474.

- 4

bank under examination.
Unless it is possible to nake an arrangement as out­
lined above, the Clearing House examinations should not be under­
taken by the Reserve Banks.

The Reserve Banks should have in its

files information as to the condition of all state banks and of
banks maintaining clearing accounts with it.

-

For that reason in

the event of the examinations not being undertaken by the Reserve
Bank, it would be well to arrange a system of cooperation with the
Clearing House Associations whereby copies of reports of examinations
should be given to the Reserve Bank for its files.

Under such a

plan it would be possible and desirable to designate a local Clear­
ing House Examiner to act as Special Federal Reserve Examiner in
the

examination of State Member Banks and State Banks maintaining

clearing accounts with the Reserve Banks, so that examinations made
by him might be accepted in lieu of special examinations made by
examiners of the Board or of the Federal Reserve Bank.

This is

desirable particularly in instances where it has not been possible
to make satisfactory arrangements with the State Banking Conmisioners,
or where the report of the Clearing House examination would be prefer­
able to that of the State Banking Commissioner.




X-474

- 5 -

Reserve Banks should have definite data as to condition,
before permitting a nonmember bank to open a clearing account for
the reason that the public is likely to assume that the Reserve
Bank is satisfied with financial condition of such nonmember bank.




Respectfully submitted,
(Signed)

J. A. BRODERICK.

N

W . P . 6 . HARDING. GOVERNOR
P A U L M. WARBURG. VICE GOVERNOR
FREDERIC A. DELANO
ADOLPH C. M ILLER
CHARLES S. HAMLIN

EX-OFFICIO MEMBERS
W ILLIAM 6 . MCADOO
SECRETARY OF THE TREASURY
CHAIRMAN
JOHN SKELTON W ILLIAM S
COMPTROLLER OF THE CURRENCY

FEDERAL RESERVE B O A R D

H. PARI
SHERM)
and fiscal

SECRETARY

. ASST. SECRETARY

Agent

ADDRESS REPLY TO

W A S H IN G T O N

FEDERAL RESERVE BOARD

November 6, 1917

Dear Sir:-r
For some weeks past the Board has been making an analysis
of the items constituting the "float" and has ascertained in
the case of each Federal Reserve bank the percentage that this
flo at bears to total earning assets and to deposits.
Reference
is made to the table attached hereto, from which it w ill be seen
that these percentages are by no means uniform, but that there
are wide variations.
In some instances the amount of the
float is entirely out of proportion to what it should be and it
should be remembered that investments in float weaken the loaning
power of the Federal Reserve bank because it is a nominal or
unavailable asset which cannot be uCed as security for the issue
of Federal Reserve notes.
However, the present figures cannot
fa ir ly be used as a basis for defihite conclusions, because of
the abnoimaliy large transfers which are now being made for
government adCount)
and normal Conditions are naturally ob­
scured or affected by the loan subscriptions now in prbcess of
'
settlement.
But the Board prcpasds to continue its analysis,
which w ill, in the course of time, show more clearly the real
conditions at each tank*
The attached sheet is sent you for
the purpose of directing the attentidn of your officers and ex­
ecutive committee to the problems involved, and with the reunest
that careful consideration be ^iveil to the best methods of re­
ducing the bank's investment in floatt
The Board wishes to be
advised at your early convenience as to the interest rates ad-*
Opted by your bank ih dealing with transfers» purchases Of checks
dr b ills for collection and similar items Which constitute float.
In the opinion of the Board this rate of interest should ap­
proximate the fifteen day interest rate, and in cases where the
bank is inclined to invest too large a proportion of its funds
in float, it might be even higher.
.
Very truly yours

Governor.
Chairman.
Federal Reserve Bank