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X-9421 INTERPRETATION BANKING ACT OF 1955 (Copies to be sent to all Federal Reserve banks) January 7? 1956. Mr. , Assistant Vice President, ------- Bank & Trust Company of , Dear Sir: This refers to your letter dated December 15, 1935, in which you request a ruling upon the question whether the Christniar Club accounts of your bank constitute savings deposits within the definition contained in section l(e) of the revision of Regulation Q , effective January 1, 1936. Inclosed with your letter was a specimen of the Christmas Club book used by your bank and a specimen of the card on which the bank keeps a record of the deposits made in such accounts. The first paragraph of section l(e) of the recent revision of Regulation Q states thut "the term 'savings deposit' means a deposit, evidenced by a pass book, * ~r 1~ " The last paragraph of sec- tion l(e) of such regulation reads as follows: "Every withdrawal made upon presentation of a pass book shall be entered in the pass book at the time of the withdrawal, and every other withdrawal shall be entered in the pass book as soon as practicable after the withdrawal is made." In view of the above provisions_, it is the opinion of the Board that the term "pass book" as used in such definition means an account book in which depo~its and withdrawals are entered. It appears that the Christmas CJ.ub book inclosed with your 45 X-9421 - 2 ... letter is a book containin6 coupons Whl.ch o.re stamped "Paid 11 at the time tho deposits are made ::,nd art: torn out by the bank and retained for its records as evidenc..:; of each of th•3 50 weekly deposlts or "paymeuts" made by the depositor. The book also contains a stub for each coupon which is stamped to E:ho·w that a deposit has been made, such stub being retained by the depositor. It appears, however, that such ./ book contains no provision for entries of withdrawals and, accordingly, it is the view of the Board that it. is not a "pass book" ·Ni thin the meaning of such term as used in section l.(e) of Regulation Q. Since • the Chrtistmas Club book does not constitute a "pass book" within the meaning of such section, the deposit is not a savings deposit even though i t may have some of the other characteristics of a savings deposit. However, as indicated in footnote 2 of the recent r·evision of Regulation Q, such a Christmas Club account may constitute a time deposit, open account if it meets the other requirements of the definition conudned in section l(d) of such regulation. If you hc;,ve any further question regarding th.Ls matter or any similar matter, it wi1.l be appreciat(:;d if you will communicate with the Federal Reserve B~nk of ------------------' which will be glad to answer your inquiries. Very truly yours, Chester Morrill, Secretary.
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