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X-7850

INTERPRETATION OF BANKING ACT OP 1933
(Copies to "be sent to all Federal reserve banks)
April 3, 1934.
Mr.

Dear Sir:
Receipt is acknowledged of your letter of March 5,
1934, regarding the question whether a Federal Savings and
Loan Association organized under the provisions of the Home
Owners' Loan Act of 1933, may be considered a "bank" within
the meaning of Section 19 of the Federal Reserve Act.
Section 5 of the Home Owners' Loan Act of 1933 provides
for the organization of Federal Savings and Loan Associations "in
order to provide local mutual thrift institutions in which
people may invest their funds and in order to provide for the
financing of homes."

Such associations are authorized to raise

their capital "only in the form of payments on such shares as
are authorized in their charter, which shares may be retired
as is therein provided" and to lend their funds "only on the
security of their shares or on the security of first liens upon
homes or combination of homes and business property within fifty
miles of their home office."

They are expressly prohibited from

accepting deposits and from issuing certificates of indebtedness




X-7850
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except for such borrowed money as may be authorized by
regulations of the Federal Home Loan Bank Board.
In the circumstances, the Federal Reserve Board is
of the opinion that Federal Savings and Loan Associations
are not to be considered banks within the meaning of those
provisions of Section 19 of the Federal Reserve Act which
relate to the computation of reserves.




Very truly yours,

(Signed) Chester Morrill
Chester Morrill,
Secretary.