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X-7720 IETERPHETATIOH OF BANKBTG- ACT OF 1933 4> (Copies t o "be sent to a l l Federal Reserve Banks) Dec erab er 7 , 1933. Mr. , President, Corporation, v * Dear S i r : Receipt i s acknowledged of your l e t t e r of November 29, 1933, i n which you ask whether Section 32 of the Banking Act of 1933 i s a p p l i c a b l e to a director of a member bank of the Federal Reserve System who i s a l s o serving as a director of your corporation. You s t a t e that the s o l e business of your corporation i s the holding f o r investment of the majority of the c a p i t a l stock of a trust company i n County, the majority of the cap- i t a l stock of a t i t l e and mortgage company, and the majority of the c a p i t a l stock of an investment company, and that your corporat i o n i s , t h e r e f o r e , only a holding company which holds the control of three operating companies. I t does not appear that t h e phrase "engaged primarily i n the business of purchasing, s e l l i n g , or n e g o t i a t i n g s e c u r i t i e s " i n ยป Section 32 i s a p p l i c a b l e to a corporation whose s o l e b u s i n e s s i s that of a holding company. Accordingly, Section 32 would not be a p p l i c a b l e to the s e r v i c e of a d i r e c t o r of a member bank under the circumstances described above. Very t r u l y yours, (Signed) Chester Morrill Chester M o r r i l l , Secretary.
@FedFRASER