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X-7713

INTERPRETATION 0? BAHKIUG- ACT OF 1933.

476

(Copies to "be sent to a l l Federal Reserve Banks)

December 11, 1933.
Mr. George W. Morris, Governor,
Federal Reserve Bank of Philadelphia,
Philadelphia, Pennsylvania.
Dear Governor Norris;
Receipt i s acknowledged of your l e t t e r s of November 8
and November 21, 1933, regarding the withdrawal of savings d e p o s i t s .
You s t a t e that i t i s the practice of some hanks i n

to

permit withdrawals from savings deposits without n o t i c e , i n cases of
emergency, of an amount s u f f i c i e n t to meet the emergency, and inquire
i f , a f t e r a statement of the emergency and approval "by an o f f i c e r of
the hank, the depositor i s allowed to withdraw a s p e c i f i e d sum of h i s
savings deposit without n o t i c e , the bank must permit the withdrawal
of the same s p e c i f i e d sum by a l l depositors without n o t i c e .
Under the provisions of subsection (a) of Section VI,
Regulation Q,, the payment by a member bank of any portion or percentage
of the savings deposits of any depositor without requiring notice of
intended withdrawal can only be made on condition t h a t , upon request
and without requiring such n o t i c e , i t s h a l l pay the same portion or
percentage of the savings deposits of every other depositor which are
subject to the same requirement,

As indicated i n the Board's l e t t e r of

November 6, 1933, (X-7671), the word "portion", as here used, i s to be
interpreted as including a s p e c i f i e d amount.

The Board i s of the opin-

i o n , therefore, that i f a member bank pay any s p e c i f i e d sum of a savings



X-7713

Mr. George W. Horris - 2

deposit of a depositor "because of an emergency or for any other reason
without requiring n o t i c e of intended "dthdravral, such "bank would "be
required to pay the same s p e c i f i e d amount of the savings d e p o s i t s of
every other depositor which are subject to the same requirement regardl e s s of the purpose for ~rhich the withdrawals are made.

The f a c t that

an emergency e x i s t s which j u s t i f i e s the withdrawal of the deposit cannot
"be regarded as a "requirement" to which such deposit i s subject within
the meaning of the r e g u l a t i o n .




Very truly yours,

(Signed) Chester Morrill
Chester M o r r i l l ,
Secretary.