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'·
X-5060
January 4, 1928.
Mr. H. F. Strater, Cashier,
Federal Reserve Bank,
Cleveland, Ohio.
Dear Mr. Strater:
Pressure of other work has prevented me from replying
more promptly to your letter of November 23rd with regard to
criticisms of the proposed Regulation K governinG non-cash collections submitted by Messrs. Ira Clerk, Deputy Governor of the
Federal Reserve Bank of San Francisco, and Mr. A. C. A£new, their
Counsel. I hope you will pardon the delay.
As you know, the Board has decided not to adopt a regulation on non-cash collections, but to leave the matter to be
covered by uniform circulars on this subject to be prepared by
your Conmittee, as suggested by the Governors' Conference. This
leaves the matter in your very capable hands and I am perfectly
content to let it rest there. .As you know, the proposal to issue
a regulation on non-cash collections was not initiated by me but
by the Federal Reserve Board itself and I have never felt that
such a regulation was essential. I believe that the subject can be
covered equally as well in a uniform circular. If I can be of any
assistance to your Committee in preparing such a circular, I shall
be very happy to do so, but I hope that you will not feel constrained to consult me on the subject merely out of politeness, unless
you think I can be of some real assistance.
With all best wishes for a very happy and prosperous
New Year, I- a':l,
Cordially yours,
Walter Wyatt
General Counsel.
X-5060-a.
FEDERAL RESERVE :B.AUK
OF CLEVZL.AliD
November 23, 1927.
Mr. Walter Wyatt., General Counsel,
Federal Reserve :Board,
Washington, D. C.
Dear Mr. Wyatt:
I am very sorry that pressure of other work has prevented my
reylyine to your letters of N9,vember 10 and 11, enclosing copies of
comuunication received by you~ from Mr. Ira Clerk, Deputy Governor of the
Federal Reserve :Bank of San Francisco, and Mr. A. C. AGnew, their counsel,
bearing upon the proposed Regulation K governing the handling of non-cash
collections.
I have given careful consideration to both of the letters from
San Francisco, and in view of the action taken at the last Governors1
conference when it was recorJmended that no regulation on non-cash collections be issued and your conversation and 1nine with Governor Young on
the proposed terms of collection incorporated in the tentative draft of
Regulation K, it seems to mo that the terms of collection incorporated in
the pro~osed uniform non-cash collection circulars of the twelve reserve
batiks could very well be modified to fix responsibility for the use of
due diligence only on tho Federal reserve banks. This would dispose of
Mr. Clerk's objection to the use of the phrase "solvent credits" and
Mr. Agnew's objection to the same phrase coupled with "bank drafts", and
would permit the Standing Comoittee on Collections to frame a sectio~
covering the terms of collection to be uniformly used by all of the
Federal reserTe barits which would take care of the necessity of establishing the relationship of IlrincipcJ. and agent in the handling of these i terns.
With respect to Mr. Clerk's reference in his letter to you of
November l, to the contemplated use of a special endorsement by a member
bank 0:1 non-cash collection items, I believe his recommendation that the
form of endorsement to be used by member banks on all non-cash items deposited with any Federal reserve bank or branch for collection, be
definitely prescribed in the check collection circUlar and provisions made
in the circular that any other forr.1 of endors~~ent will be disregarded.
It seems to ne that there should be added to the language
sugGested by Mr. Clerk, a provision warranting the memb0r baru~'s authority
to waive its rights which night accrue through endorsements bearing special
instructions, conditions, or qualifications, and to abTee to indeonify any
Federal reserve baruc for any loss resulting from the failure of the depositin~; bank to have such authority.
This would be in accordance with a similar
provision in Regulation J.
I have not as yet heard what the Federal Reserve Board has
decided to do in connection with the issuance of a new regulation on
non-cash collections, but if it is decided that such a regulation be
issued, I shall be very much in favor of modifyinG the terms of collection
so as to h~onize with Governor Young's views which I believe to be perfectly sound. I shall be very much interested in knowing the Board's
decisio~ on this question inascruch as if the Board approves the recomoendation of the Governors' conference that a uniform no~cash collection circula: 'be prepared by the Standing Comoittee on Collections, it is essential
,that the committee begin to work on the preparation of such a circular at
the earliest possible moment so that it may be presented as a finished
product to the next conference.
I hope that ,my views as expressed to yOU in this letter, do not
reach you too late to be of any value to you.
Very truly
~~ours,
H. F. Strater,
Cashier.
X-5060-b
FEDERAL RESERVE BANK OF S.AJ."i FIWWISCO
November 5, 1927.
Walter Wyatt, Esq.,
General Counsel,
Federal Reserve Board,
WashinGton, D. C.
Dear Mr. Wyatt:
I have read carefully and with a creat deal of interest the two
very illuminatinG articles transmitted "ith your letter of October 26,
being extracts frou the Virginia Law Rec;ister furnished throuc;h the courtesy of Mr. Stearu~an, the editor of that ~ublication.
The articles referred to are the best resumes of the law on that
subject I have seen and will be of great value in the preparation of briefs
involving the subject covered. I ru:., as you ~ay perhaps rcmeober, in
syru--patl1.y with the position taken by Mr. H~la in his article, inasmuch as
I have always felt that the doctrine of the Peters case is contrary to the
reason and yrinciple of our law. I have, ho~ever, been seeking an opportunity to establish the theory of that case in the states of this district.
The perusal of these articles prompts me to recall to your attention a matter mentioned in a letter, dated November 1, 1927, addressed by
Mr. Clerk, one of the Deyuty Governors of this barik, to you. In the letter
referred to Mr. Clerk calls to your attention the pNJvisions of parae;raph
2 of Section V of the revised draft of Regulation K, Series of 1927 (X-4915-a),
wherein the new regulation provides that collection items may be forwarded
for payment in cash, baruc draft, or solvent credits.
It seems to me that it even is more essential to preserve, so far
as :?ossible, the relation of princi1Jal and agent in the handling of collection items thru1. in the handling of ~ash items. The anthorities cited by
both Mr. Bryan and Mr. Harris seem to draw a very clear distinction between
those cases in which the forwarding bank has transmitted the items with the
understanding that the ?roceeds thereof were to be intermil~led ~ith the
general assets of the collecting barik and those cases where the it€ms are
forwarded merely for collection and remittance, and having been collected,
the proceeds thereof are, in violation of contract, intermingled with the
general assets of the baruc and credit given in the form of a draft or otherwise. In the first class of cases the courts quite generally hold that the
action of the bank which fonvards the items in consenting that the proceeds
be intermingled with the assets of the collecting bank constitutes a consent to the establishment of the relation of debtor and creditor and prevents the establishment of a preference, while in those cases wheTe the items
arc forwarded for collection and remittance, the collecting bank is hold to
be a constructive trustee for the proceeds of the collection.
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x-5o6Q-b
r26G
Therefore, it seems to me that if the Federal reserve ba11ks
expressly reserve the right to forward collection iter.1s for payment
in cash, bank draft, or in solvent credits, this constitutes ~n
implied consent to the establishment of the relationship of debtor
and creditor and even in such states as Virginia and Missouri, would
prevent the establishoent of a preferred claim where a settlement
was made under the recirpocal account oethod. Would it not,
therefore, be better to reward paragraph,2 of Section V of the new
regulation to read as follows:
11 Feder~l
reserve banks may present or forward such
items direct to the bank on which they are drawn and at
which they are payable, or throuGh which they are collectible, for collection and remittance; or present them
direct to the person, firm, or corporation on which they
are drawn, for collection and rerJ.ittance; or, if the item
is not payable in a city in Yrhich there is a Federal reserve bank or a branch of a Federal reserve ban~ 1 then
they may, in their discretion, forward them to another
aGent ~ith the same authority that they have to present
or fonvard them for payment. Such fo~s of remittance as
are custo~rily accepted by other banks in settlement for
collection items oay be accepted by Federal reserve banlcs."
I realize that the foregoing leaves indefinite the specific kin4
of remittance which Federal reserve banks are authorized to accept,
but it seems to me that this uncertainty is preferable to the use
of terms which carry with them notice ~~d consent to the establishment of the relation of debtor and creditor.
I submit the foregoing merely for.your consideration.
Yours very truly,
(Signed) Albert C. Agnew
Counsel.
XC 5060-.i:!
FEDERAL RESERVE :sA...W. OF SAN FR.AlWISCO
Uovember 1, 1927.
Walter Wyatt, Esq.,
General Counsel,
Federal Reserve ]oard1
Washincton, D. c.
Dear Mr. Wyatt:
In reviewing rather hastily the revised fu•aft of Regulation K, Series of 1927, (X-4915-a), several ideas have occurred to us
which you may desire to consider before r.1akinc; tho final draft of this
regulation.
SECTION II.
DEFINITIOl~
In paraGra_:.)h 5 we sugcest insertA.nc"or non-me::1ber clearing
Bank", r;1aJ.cinc the paracra:r:>h read as follows:
***provided that any Federal reserve bank may
require any depositing member bank or non~member
cleari1y; ba1ik to Ohow to such Federal reserTe
bank's satisfaction ***etc.
SECTION IV. ITEMS RECEIVED FOE COLL::JCTIOH
Paragraph (c) yrovides that Faderal reserve ba11k may authorize
member and non-member clearing ba1L~s to direct route to other Federal reserve banks in order to eliminate ttnnecessary delay and expenso. It would
see8 that for this a&~e reason Federal reserve ba11ks should have the optinn
to require direct routinG if the volume of transactions warrants it.
Vlherever y;e have had a material volti.me of items we have as:ced our member
ba:::il:;:s to direct route them and in all cases, but one, have received the
fullest cooperation. The one bark declininG has a large volmno of coupons
payable in New York; that barik l1as refused to diroct route in the absence
of a specific rulint; roquirint; it. Its failure to direct route imposes a
double e;s-,ense upon the Federal Reserve Systom and , in addition, gi vos
the dissenting meober ba:::il:( the adva~taGe in the oatter of shippinc costs
over those banks which have a.Greed to coo~erate with us.
SECTION V. TERMS OF COLLECTION
Recently i t came to our attention that a m.er.1ber bank contemplacing a special endorsement on its i ter.:.s forwarded to the Federal
res.erve bank for collection, as follows:
pl~ted
X-5060-c
-2-
"For collection and rer~:ittance rri thout depc.oi t or
in terr:1inG1 inf; with the Eanlc' s funds."
To reeove the additional responsibility which would be :;?laced upon the
Federal reserve bank as a consequence of such endorsement, we contemplated
inserting in our revised Circular 101, covering the collection of non-cash
items, the following provision'
All items received and sent fonvard for collection will be forwarded under indorsement of this bank
substantially as follows:
"Pay to the order of any bank, banker, trust
company, or Federal Reserve Bank for collection only. Prior indorsements guaranteed."
This bank does not undertake to procure for the
owners of items entrusted to it for collection any
greater rights than those accorded by law under the
foregoing indorsement. Items bearing indorsements containing special instructions, qualifications, or conditions,
will be forwarded by this bank as ai'~resaid, and banks sanding them to this bank, and ?rior indorsers, will be dee:oed
to have waived any rights which night accure through indorese:oents bearing such special instructions, conditions
or qualifications.
Inasnmch as the proposed Regulation K. reguires all Federal reserve
banks to promulg!iJ:!;.e rulsc and rC&'Ulations indcntical in terms, you mey de
sire to give consideration as to whether this provision should be incorporated in such regulation. It appears to us as a rratter of particular importance,
Paragraph 2 of Section V, provides that items rJ.aY be forwarded for
in cas~, bank draft, or solvent credits. The thought has occurred to
us that the use of 11 sol vent credi ts 11 would imply that the Federal reserve b~
may forward items to member and non-member clearing barucs for collection and
CREDIT. While it is true that Federal reserve banks accept solvent credits
in settlement of collections, it would seem preferable not to ask for such
forw of payment for fear that the credit given~~ not prove to be solvent
and the Federal reserve bank may find itself in the position of having asked
for credit and therapy having act up the debtor and creditor relationship
which experience has shown it was desirable to avoid. (Colo. & So. Ry.
Co. v. Docking- 124 Kans. 48:257 Pac. 743o)
p~ent
Yours very truly,
(Signed) Ira Clerk
Deputy Governor.
X-5060-d
August 8, 1927
MZli~OR.ANDUM
FOR MR. MARTili:
As requested, I have studied the revised draft
of Regulation K, Series of 1927, X-4910, which you brat oack with
;}'OU from iVashincton.
I have the following comr:J.ents and sugGestions
to ma..l.ce:
Section V. 1, provides that Federal Reserve Ea1iks
***** will be responsiole 01uy for due diliGence and care in forwarding
and presentiD£ such items ********·
Tho effect of paragraph 2 is not entirely clear
to me. For instance: Su~JposinG a d;roft on an individual or firm,
with bill of lading or securities attach0d, is forwarded by a Federal
Ros8rve Ba1ik to a cor~orcial b~~ in another city for collection and
returYJ.s. T:•o collectil1£ banlc presents the draft to the drawee for
payment and delivers the draft and doc1unents upon payment in the form
of a check of the drawee on its account in a local bank. The check
develops to be no good, and there is a loss. The collecting bank
can sho11 tl1at it was justified in accepting the check, in tl1.at it had
no reason to believe that the drawer was not coed, and as a r!la~ter of
fact r:1ight be able to indicate that it had on numerous occasions accepted checks of the same maker, all of which were prouptly paid.
Under the circw~stances, would the collecting bank hD.ve exercised due
diligence and be relieved frOJ:i the uore or less established rule that
results in res?onsibili ty for accepting pa;~rment in a form other than
cash?
Now, let us take the case of an iteu p~able in a
Federal Reserve Eanlc or Branch Bank City, where presentation is rnade
by the Federal Reserve Banl'.: or Branch and not thru another bank. Under
circumstances siciilar to those en~erated in respect to where an item
is handled thru ru1other ba~,would a Federal Reserve BaPlc or Branch
have exercised due diligence?
It occurred to me that these two paragraphs might
pormi t and encourac;e tha acceptance of chec~::B both on the part of the
Federal Reserve :Ban."k::s as well as collectinG agents they may select,
when the acceptance of such checks is unwise from a credit standpoint,
and doubtful from the standpoint of huving exorcised due diligence.
-2Memorandum to Mr. Martin.
8/8/27
Paragraph 4 provides that "Federal Reserve :Banks
shall be held liable only when they have received actual payment in
cash or in the final proceeds of any barik draft or check received in
remittance".
The fact that the terr.1s 11 bank draft or check" arc
used in this paragrayh leaves the impression that it applies both to
reoitt~nces received from collecting agents as well as remittances
received from payers where personal presentation is rJadc by the
Federal Reserve Batik.
I am thoroly in accord with the idea that the
Regulation should provide for the acceptance of remittances in the
form of .baruc draft of collecting agents along tho sane lines as is
follow6.d in the ehock collection system, but I do question the desirability of the Regulation authorizing Federal Reserve Banks to
accept checks in l)aymont of collections where the Federal Reserve
Baruc ~Akes the presentation direct, or tho authorization of a sinilar
practice on the part of collecting agents they may select. I do
not believe that such authorization in the Regulation would have the
effect of relievinc~ Federal Reserve ]ames or the agents they select
from negligence in accepting checks, and I am of the opinion that if
member banks using the collection system understood that the Federal
Reserve Banks were trying to contract or successfully contracting
against such negligence, the System's value to them •ould be considerably reduced.
In paragraph 2, first line, the words 11 or forward"
to me the possibility of Federal Reserve Batiks turning over
local items to member or non-member bariks for collection along the
lines recently tried out in Minneapolis.
sug5~st
Section Vii, paragra~hs 2 and 3 apparently make it
optional with each Federal Reserve Bank whether the actual expense of
registration, insurance or transportation and all telegraph and telephone charges in connection with the collection of maturing notes and
bills are recovered from the bank which deposits such items. Tho
question of uniformity again crops up. As worded, the Federal Reserve
Bam~ of St. Louis would be permitted to waive such items of expense and
at the same time, the Federal Reserve Bank of Chicago or any other Federal
Reserve Batik might adopt the opposite practice, and the question is i~
mediately raised - Why is one Federal Reserve Barik more liberal than the
other? At the present time, the Federal Reserve Bank of St. Louis does
not absorb any teleGraph and telephone charges in co!h~ection with the collection of maturing notes and bills, nor does it assume the actua~ expense
of registration, insurance or transportation of mattrring notes and bills
forwarded to other points for collection w~en the cost exceeds 25¢
Very truly yours,
0. M. Attebery,
Deputy Governor.
X-5060...e
July 25, 1927.
Mr. F. J. Zurlinden, Deputy Governor,
Federal Reserve Bank of Cleveland,
Cleveland, Ohio.
My dear Mr. Zurlinden:
I enclose for your information and for such further
criticism and comment as you~ care to submit a revised draft
of the proposed regulation on the collection of maturing notes
and bills. This draft was prepared after consideration of the
various sucgestions submitted by the other Federal reserve banks
and is based upon the draft prepared by the Federal Reserve Batik
of Cleveland. I shall indicate briefly the reasons for the various
changes which I have made in the Cleveland draft:
. Section II. A slight change is made in the first :paragraph to improve the phraseology. The change in subdivision (a) 3
was suggested by several of the other Federal reserve batiks and is
believed to be desirable. In subdivision 5 the words "evidence
of indebtedness" have been inserted in lieu of the words 11 negotiable instruments", because several Federal reserve banks pointed
out that non-cash items very frequently are non-negotiable and that
it would be burdensome on the Federal reserve banks to undertake
to determine whether or not such items are negotiable. Similar
changes are made in subdivision (c) and (d) for the same purpose.
:sectioniV. I have inserted in subdivision (a) the words
payable in the continental United States" to distinguish this from
the items handled under (b) and (c) which must be payable in the
district of the receiving Federal reserve bank. I have combined
subd.i vision (c) and (d) and believe that I have improved the language
somewhat without changing the meaning.
11
Section v. Owing to suggestions made by several Federal
reserve banks, I have incorporated in the first paragraph of this
section a provision for the·guarantee of all prior indorsements; and,
at the end of subdivision 2, I have added the words "and for its
guarantee of prior indorsements". The change made in subd.i vision 3
was suggested by several differe.et Federal reserve banks to cover
the situation where it is desirable for items payable in other
districts to be forwarded direct to the place of payment instead of
being forwarded to the Federal reserve bank of such other district.
f~6G
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X-5060-e
Section VII. The lanf~e of subdivisions 1 and 2 has been
changed so as to make it possible either to charge the bank from which
such items are received or to deduct the charge from the proceeds and
give credit for the actual net proceeds. In subdivision 2 the words
11 maturing notes and bills" have been substituted for the words "bonds
arid coupons 11 because it was suggested that the words "maturing notes
and bills 11 are broad enough to include 11 bonds and coupons" and also broad
enough to include "notes and bills" to which bonds and coupons are
attached and ~hich should be registered or insured. In subdivision 3
the words 11 from which such items were received" have been inserted in
lieu of the words 11 making tho request involving such expense" because
it was suggested that very often telegraph and telephone Charges must
be incurred without any specific request having been made, and that
such charges should be collected from the sending banks even though
such banks did not r~e any request involvil~ such expense. Subdivisions
2 and 3 have also been made permissive and not rnandatory because it was
suggested that the banks may wish to waive expenses amounting to less
than 25 cents.
I am submitting this to you info~lly because I have not had
an opportunity to su bni t to the :Board and because I desire to obtain
your further cornments and criticisms at the.earliest possible date.
I do not know when the :Board will take up the regulations for final
approval but if it should decide to take them up this week 1 ma,y call
you on the telephone to obtain your further comments and criticisms
regarding this regulation.
T.hal1king you and the other officers of the bank for your kind
assistance in this matter, and with all best wishes, I am,
Cordially yours,
Walter Wyatt,
General Counsel.
Enclosure.
WW lvlD
X-5060-f
FEDERAL RESERVE B.A..U OF ST.LOUIS
June 28, 1927.
Denr Mr. Strater:
Replying to your letter of the 25th, I have carefully gone over Regulation K, as submitted by the Federal Reserve
Board with its letter X-4s78, bearing date of June 21st. I have
the following comments or suggestions to offer:
Section II, (a), 3 and 5, would seem to preclude
our handling as a collection checks or drafts drawn on bariks unless such items have been previously dishonored. I imagine the
practice of all of the Reserve Bariks is to handle checks and drafts
on banks for collection when special advice of payment is desired,
irrespective of previous dishonor. I would, therefore, suggest
that No. 3 be eliminated, and that No. 5 bo made to read: "All
other negotiable instruments payable in the United States".
Section IV, (b). At th0 present time, I believe
all of the Federal Reserve Bariks, with the exception of Minneapolis,
have given other Federal Reserve Banks blar~et authority to handle
non-cash items received from all of their member banks and non-mem
ber clearinG banks. If this authority is continued, the wording of this paragraph will not up-set things, but if it becomes necessary, as a result of the way in nbich this paragraph is now worded,
for each Federal Reserve Barile to furnish each other Federal Reserve
Ba1ik with a list of the member and non-member claaring bariks authorized to route direct, and for the Federal Reserve Banks receiving
collections from ba1ucs in other Districts to check such collections
to sec whother they a~e from ba.nlcs that have authority to route direct, it will result in what I consider unnecessary work, inconvenience and expense. I would suggest that in the third line 11 are
authorized to 11 be omitted.
Section IV, (c). As you are aware, we now handle
for the account of the Treasurer of the United States cheCks drawn
on barucs which we do not know whether can be collected at par.
Possible the fact that such items are handled only for the Treasurer
of the United States makes no difference so far as the Regulation is
concerned. I have, however, thot it well to mention the rJatter,
in order that it oight not be overlooked.
'
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L.
~]6(:;
X-5060-f
Section V, 2. l am not so sure about the possibilities under this paragraph. Would it permit a Federal Reserve
Bank to follow the plan recently inaugurated by Minneapolis?
Section V. 3. The Standing Committee on Collections, in its Report to the Conference of Governors Uovember 12th,
1923, recommended that Federal Reserve Banks be permitted, in their
discretion, to route any documentary draft payable at sight or on
demand, whether such draft be purchased, discounted or received for
collection, direct to the point of payment in another District,
but only when specifically requested to do so by the member ba11k
selling, rediscounting or depositing for collection. This recor!~Dcndation was, in r.;y jud~ent, a proper one, and I thir..k the paragr~~h under review should be altered so as to provide for items payable in another District being forwarded direct to point of payment
either when the depositing bark re~!asts that they be so forwarded or
it is necessary to so forward an i ten in order that it nay reach the
point of payoent by naturity.
Section VI. Tnis is the most important Section in
the Regulation. It is the custom in this District to expect that
credit covering the proceeds of a collection is final; and I think
this is the general custoB thruout the Country. n1iS paragraph,
as drawn, makes credit conditional. The Federal Reserve Bank of
St. Louis never knowingly credits a collection until the proceeds
are in actually collected funds. If we send an item to an out-oftown bank and receive returns in St. Louis excl1ange, credit is given
after the draft on St. Louis is actually collected. If we receive
retLTns in the form of exchange on some other point, credit is only
given after such exchar~e has been converted into actual funds on
which thoro is no possible recourse. n1o same is true of local
collections handled by our four offices - credit is never intentionally passed until we know we have the money. I would strongly
recommend that this paragraph be worded so as to meet the practice
just described.
Sectio~ VII, (a), 2 suggests that expense other
than collection cha~~s be deducted when giving credit for the
proceeds of the cqll~ction. This is rather impractical, and I
believe has been discussed at previous meetings of the Standing
Co~mittee on Collections - particularly in respect to telegraphic
costs. To illustrate:
Suppose the Federal Reserve Bank of St. Louis received a collectior.. from the Federal .Reserve Ba!ik of Cleveland
payable at Evansville, Indiana, which is to be forwarded by registered mail and insured. The expense of registration and in
u
'lfi'~
f~
X-5060-f
-3-
surance would have to be held in suspense, awaiting returns on
the collection, and then deducted from the returns received before
crediting the net proceeds, whereas, followinb the usual procedure,
the &aOent the expense was incurred, that is, the day the item was
forwarded or not later than the following day, a charge would go
thru and the accol4iting procedure would be ended, so far as the
expense was concerned. When an item is returned unpaid, there
is nothing from which to deduct such expense, and the charge must
necessarily be put thru in the m8crh~er I have just described.
Section VII,. {b) would appear to permit the making
of a reasonable charge for the collecting of checks and drafts
drawn on banks which have previously been dishonored, and, if the
suggestions I have made in respect to Section II were adopted, would
permit a collection charge on any checks and drafts drawn on ba11ks,
which, of course, is inconsistent with the Act and other Regulations.
Very truly yours,
0. M. Attebery,
Deputy Governor.
OMA:S
Mr. H. F. Strater, Chairman,
Standing Committee on Collections,
Federal Reserve Bank of Cleveland,
C~eveland, Ohio.
@FedFRASER